Before a joint hearing of the Christchurch City Council and the Canterbury Regional Council

Transcription

1 Before a joint hearing of the Christchurch City Council and the Canterbury Regional Council In the matter of the Resource Management Act 1991 And In the matter of an application by Canterbury Aggregates Producers Group BRIEF OF EVIDENCE OF PETER JAMES SAVAGE ON BEHALF OF FULTON HOGAN LIMITED 26 May 2016 Duncan Cotterill Solicitor acting: Ewan Chapman PO Box 5, Christchurch Phone Fax ewan.chapman@duncancotterill.com _1

2 INTRODUCTION Qualifications and Experience 1 My full name is Peter James Savage. 2 I am the Environment and Resource Development Manager for Fulton Hogan Limited ( Fulton Hogan ). In that role I am responsible for: Providing strategic oversight over key projects and, as the escalation point for all South Island environmental issues, delivering practical solutions for environmental issues ranging from large scale quarry consenting through to onsite erosion and sediment control plans; The development and implementation of ISO Environmental Management Systems and leading the development of environmental training for Fulton Hogan staff. This includes erosion and sediment control implementation and maintenance, spills training and environmental considerations for works in landfills and the like; Ensuring compliance within the business with district and regional council resource consents, designations, outline plans and Heritage New Zealand Act authorisations,. I prepare regional and district council resource consent applications for construction phase and constructed discharges, air discharges, passive discharges, gravel extraction and works in waterways; Crown Minerals permit strategy, applications and management for Fulton Hogan nationally; Leading environmental management of large infrastructure projects such as the Genesis Energy Tekapo Canal Lining and Christchurch Southern Motorway which was awarded NZ Civil Project of the Year 2013; Key account management and responsible for the development of a Memorandum of Understanding and significant national sponsorship package with the Department of Conservation; Project managing the due diligence, purchase and subsequent consent of more than 200 hectares of quarry land in four separate acquisitions _1 2

3 3 I hold a Bachelor of Science in Natural Resource Science and Economics. 4 I previously worked for Canterbury Regional Council for five years in both the Compliance Management and Consenting Sections specifically in: The processing and monitoring of consents for stormwater and air discharges hazardous substance storage, 1080 and herbicide application, municipal wastewater discharges and passive discharges for closed landfills; Acting as Resource Management Act decision maker for non-notified resource consent applications and responsible for the recommendation of notification/non-notification for all the above activities; I brokered a protocol between the Canterbury Regional and District Councils around stormwater consents and any compliance issues where such consents were transferred at the time of s224 grant; I am an Associate Member of the New Zealand Planning Institute and a Full Member of the Environment Institute of Australia and New Zealand. 5 I am familiar with the application lodged by Canterbury Aggregate Producers Group ( CAPG ) to win further aggregates at a number of existing quarry sites to the north and west of Christchurch by the deepening of aggregate extraction under certain conditions. 6 I record that Fulton Hogan has two sites within the application area: The first is to the northwest of Christchurch at Miners Road with the entrance to this quarry directly off Miners Road adjacent to State Highway 73; and Fulton Hogan s McLeans Island quarry with access from McLeans Island Road. SCOPE OF EVIDENCE 7 In my evidence I provide an overview of Fulton Hogan s activities at both the Miners Road and McLeans Island quarry. 8 Describe Fulton Hogan s view on the need for a further aggregate extraction to provide for long term supply to the greater Christchurch market _1 3

4 9 Explain why Fulton Hogan has joined the CAPG and the benefits of an approach of working under common conditions. 10 Provide a description of the cleanfill market at both sites. 11 Describe the methods under which cleanfill is currently received by the quarries and the changed methodologies that will arise from protocols agreed for this hearing. 12 Describe the mode of extraction of deep fill at both sites and the mode and availability of backfilling on completion of extraction and subsequent works as the quarry works to its rehabilitation plan. FULTON HOGAN OVERVIEW 13 Fulton Hogan is one of New Zealand s largest roading and infrastructure construction companies and operates throughout New Zealand, as well as in Australia and the South Pacific. Within New Zealand, Fulton Hogan employs close to 4000 staff and has an annual turnover of around NZ$1.5 billion. 14 Fulton Hogan employs approximately 760 staff within Canterbury. In addition, other sub-contractors contribute in excess of 120 further jobs across the region. The company has operated within this area since 1979, and has a proud history of road and infrastructure construction, within a diverse operational portfolio. Core operations include Major Projects, Asset Management, Manufacturing, Contracting, Industries and Land Development. 15 The company extracts and processes aggregates from several land-based quarries across the Greater Christchurch metropolitan area. Fulton Hogan also relies on riverbased (fluvial) aggregate resources to supplement these quarries, although this resource is in decline 1. Cleanfilling and remediation of land-based quarry sites occurs behind, and generally in tandem with, extraction. This element of Fulton Hogan s operations provides a valuable, if largely invisible, service by allowing surplus topsoil and excavated material from rebuild activities to be disposed of in a managed way. 16 Major Project s contracts presently in operation within Canterbury include the Christchurch Western Belfast Bypass and the Lyttelton Port Company Inland Port in Rolleston. Fulton Hogan is also a partner in the Christchurch Rebuild Alliance (SCIRT). 1 Regional Gravel Management Report, ECan Report R06/1, December 2005 (Executive Summary) _1 4

5 17 To complement the company s business needs, Fulton Hogan manufactures products which are used in day-to-day business, major projects, and by clients. These include quarry products (aggregates both raw and processed), and downstream commodities such as asphalt, precast concrete and concrete aggregates, emulsions, bitumen, road signage and associated products. 18 Fulton Hogan s diverse portfolio is heavily reliant on the availability of a suitable aggregates supply. 19 Infrastructure and asset management services are also provided by Fulton Hogan. Examples of this work stream include road maintenance (for both local authorities and New Zealand Transport Agency), facilities maintenance (for example, for the New Zealand Defence Force), airport and port maintenance. The company is also moving into areas such as rail, water, energy and communications, whilst maintaining its core capabilities. 20 Core contracting activities include the more traditional operations, such as road construction, civil construction, drainage works, paving, water cutting and grooving, and suchlike. Land development is another element of the diverse portfolio. In Canterbury, Fulton Hogan is involved in land development joint ventures at Lincoln (91.6 ha of residential land) and Halswell (117 ha of residential land), amongst others. This aspect encapsulates many of those contracting activities I have already described. 21 Fulton Hogan operates within, and all operations are guided by, a strong environmental and social philosophy. The company is committed to minimising the environmental impact of its activities and to promoting sustainable development. 22 Compliance with resource consents and other regulatory standards forms a key plank of environmental policy for the company, as is achieving excellence in environmental management. These priorities underpin all aspects of operations, including activities that may affect immediate neighbours and the wider community. A Miners Road 23 Fulton Hogan acquired the 80 hectare site in two stages between 1979 and Miners Road is the hub for the Canterbury suite of quarries owned and operated by Fulton Hogan. In addition to aggregate extraction and processing operations Fulton Hogan also operates the following activities from the site: _1 5

6 A construction related laboratory approved to ISO standard; An asphalt plant; A staff training facility. 24 At Miners Road Fulton Hogan conducts gravel extraction within the terms of the Christchurch City Council Plan and holds various consents from the Canterbury Regional Council which I append to my evidence. 25 Given the requirement to operate to 1 metre above the highest recorded groundwater level the RL level to which Fulton Hogan operates at Miners Road is in the range of RL 54 RL 47 as the contours change across the site. B - McLeans Island. 26 The McLeans Island quarry was acquired in 2012 and fully developed firstly through a joint resource consent process with KB Quarries Limited who own and operate the adjoining land to the East. I attach the McLeans Island resource consent held by Fulton Hogan and KB Quarries for this site. 27 Neither Fulton Hogan s Miners Road nor McLeans Island operations are open to the public. Contractors must have a pre-approved account to purchase aggregates or deposit materials on these sites. Fulton Hogan also serves its own projects for roading and infrastructure directly from this site. CLEANFILL OPERATIONS GENERALLY 28 As relatively new quarries the McLeans Island and Miners Roads sites have worked under the protocols for cleanfill management developed by the Ministry for the Environment and adopted by two Christchurch City Council bylaws. 29 Fulton Hogan s primary cleanfill operation for the Christchurch market is at Pound Road Quarry which is not subject to this application. The products of demolition, site preparation, works and old roading material have been received at the site from a very early stage. Whilst precise volumes and description of these materials is not generally known, they were generally placed as fill following quarry extraction and have remained in situ without being disturbed in any way. 30 Given the long life of Pound Road Quarry, established in 1953, and the very extensive monitoring data there appears to be no effects detected directly from this material downstream from the quarry zone _1 6

7 THE IMPORTANCE OF AGGREGATES 31 At the time of writing the outcome of the Independent Hearings Panel for the Christchurch City Plan hearings process is unknown. Under the umbrella of CAPG and from individual operators submissions were made to the IHP regarding the importance of the aggregate industry to Christchurch, and in relation to the need to provide certainty to the industry regarding permitted extraction. I understand Mr Copeland and Mr Warren for CAPG will be dealing with the economic and industry reasons for making this application in more detail. However, the size and breadth of Fulton Hogan s operations and its reliance on the availability of suitable aggregates lead me to provide the following comments in relation to the importance of aggregates. 32 Aggregates are fundamental to the sustainable management of communities. This has been brought into stark relief in Canterbury, as a result of the Canterbury Earthquake Sequence, where the short term demand for aggregates for recovery activities has accelerated in tandem with the rate of rebuilding. 33 Fulton Hogan submitted on the series of Rural Zone hearings particularly on the fundamental need to retain the quarry zone and permitted extraction. It also submitted on the objectives and policies applicable to the quarry industry and the applicable performance standards in order to ensure that the importance of extraction was recognised as well as recognising the environmental issues that the plan needs to address. 34 The reason for seeking greater clarity of plan provisions this is probably selfexplanatory but the consenting processes associated with gravel extraction are time consuming and require very long term planning to establish a greenfields quarry operation and also expensive and added to the overall price of available aggregate in a city where demand is high. 35 Having certainty in the Proposed Plan s Objectives and Policies and performance standards will assist all operators with the issues around cost, certainty and reliability of supply to the local domestic market. As a result of declining fluvial volumes and reliability of supply, the industry is increasingly focussed on land-based quarries and the efficient use of those land-based supplies. 36 Alongside the availability of aggregates, proximity to demand is a further key aspect. Transportation costs are often the biggest determinant of the end-price of aggregates _1 7

8 As a rule of thumb, it is generally accepted that the cost of aggregates doubles for every 30 kilometres of cartage required. As new quarries are forced to establish further from the source of demand, the cost of both raw and processed aggregates (in all its forms) will increase. 37 Transportation costs are, consequently, a fundamental determinant of the economic costs and benefits that accrue to the wider economy 2. Proximity to market is a critical factor for the establishment of aggregate quarries, as is evident from the existing pattern of quarry development on the northern and western fringes of the Greater Christchurch metropolitan area. 38 Locally, costs for aggregates (and related products) are therefore lower than other centres. This provides a substantial economic advantage over areas where aggregates supply and quality is constrained (for example, the Auckland and Wellington areas). Despite this, the crucial importance of aggregates to society is almost invariably under-recognised. 39 The existence of high quality land-based aggregates is almost ubiquitous across the western Christchurch area. I understand that the Council s recently notified Stage 2 proposals include Appendix High Quality Gravel Resource Overlay, which identifies the geographical extent of this aggregate resource. While this overlay outlines the geographic extent of the resource, in practice, the consenting of new quarries will remain problematic; due to the close proximity of neighbours are road transportation issues from a new site. 40 Excavation of aggregates is a long-term, but transient use of sites. Remediated quarry sites are returned to the land bank for use in a variety of forms. The Fulton Hogan Christchurch Regional Office at Hornby is an example of a worked-out quarry that has been engulfed by urban development as the city of Christchurch has expanded to the west. Put simply, quarrying can be a viable precursor to subsequent built development but, once built development exists, this option is eliminated. 41 A further distinction I would make is that extraction (though not necessarily the processing) undertaken in land-based quarries is, by its very nature a transient land use. Once available aggregate resources are worked out, a new site is sought for raw material to supply the processing plant. 2 Note, also, that other less-tangible environmental costs associated with greater haul distances include increased emissions, traffic congestion and roading safety impacts _1 8

9 42 I would hasten to add that this does not inevitably result in large areas of abandoned voids across the landscape. Fulton Hogan and other operations accept that there are legacy issues arising from past quarry operations. However, today we accept that cleanfilling and site remediation, in accordance with strict protocols form a standard part of quarrying operations to return the land to productive use there are many successful examples of this occurring including Fulton Hogan s own Pound Road operations. 43 Given the high current and forecast demand for aggregates (and associated cleanfilling) to support the rebuild, there is a strong case to be made to provide for or at least not foreclose opportunities to obtain maximum available quantities aggregates from existing sites. Not only does this ensure that there is efficiency of use it also delays the necessity for horizontal expansion of quarries adjacent to the urban boundary. I make this point as a rather academic one because part of the reasoning behind this application is that although there is, in theory, a huge volume of aggregates under the Canterbury Plains, they are seldom available due to the presence of housing and the need to avoid, where possible, new effects to neighbours and resident s where quarries are not currently active. It is for this reason that Fulton Hogan has joined this proposal to win aggregates at greater depths from existing sites. OUTLINE OF OPERATIONS IN ACCORDANCE WITH PROPOSED CONSENT Methods of Extraction 44 The methods of extraction under a proposed deepening operation will be using current methods at the Miners Road site. Essentially a 30 tonne loader will extract aggregates from a face, reverse and load the extracted material into a hopper connected to a field conveyor which transports material on mechanical belts and if necessary through another hopper to the processing plant where the raw material is processed through the process of screening, crushing and washing to produce up to 40 aggregate products. 45 The field conveyor avoids the other option of loading trucks and carting material to the plant then tipping off. The conveyor currently being extended at to go under Miners Road to convey material from the western block of land to the processing plant will be in excess of 1km long and will avoid at least 30,000 truck movements per annum within the quarry and across Miners Road _1 9

10 46 These processed products are stockpiled by a radial stacker attached to the processing plant itself and then loaded into truck and trailers as necessary. Doubling handling of material is avoided, as far as possible. 47 At McLeans Island, extraction to depth will occur by an excavator which will at all times remain 1 metre above the groundwater surface. 48 Existing extractions commence with the removal and stockpiling of top soil and then gradual extraction down to our authorised level 1m above the highest recorded ground water level. However, where existing extraction operations appear on site as a wall or quarry face which moves gradually from one side of the extraction area to a perimeter fence, the parameters for deeper extraction are more directly controlled. 49 As a first step current methodologies will remain unchanged for extraction down to existing levels. 50 There are then three pre-conditions to deeper extraction. Firstly, we need to ascertain current groundwater levels. We determine groundwater levels through a matrix of three pieces of information. Firstly, we consult the ECan monitoring bore M35/1080, we consult Fulton Hogan s own onsite bore to ensure there is correlation between the ECan monitoring bore and our own onsite bore and thirdly, we are required as part of the consent to dig a groundwater monitoring pit directly adjacent to the area destined for extraction. This will be an approximately a 2m diameter hole with the depth of which needs to be no greater than to the point where groundwater is encountered. 51 The correlation between all of these bore measurements will ensure that at all times our operations maintain a 1m/ 300mm buffer between actual groundwater level and the deepest point of extraction (depending on the site). 52 These onsite groundwater monitoring pits are likely to be dug at the start of each working day so that the reference point directly adjacent to the area of extraction is known to the loader operator. They will be backfilled at the completion of works for that day. 53 The experience of our loader drivers is a key element in maintaining groundwater separation. The fact that the loader driver has a source for visual inspection of groundwater depths provides both a practical and more precise level to work to rather than reliance being placed only on our onsite bore and the ECan monitoring bore _1 10

11 Our loader drivers are very accustomed to working to prescribed depths. Our quarries are surveyed regularly physically and by LIDAR and the quarry has the ability to use physical measuring markers marked with lasered survey levels to indicate the working depth at any particular time. 54 It is also possible to use GPS data (commonly known as machine control ) on site both for the quarry manager and the loader driver directly working with GPS to establish depths whilst not as precise as the bi-annual survey provides a robust indicator of the working depth to keep 1m above current groundwater. 55 The loader driver will need to work in tandem with the overall quarry manager for each site. As excavation proceeds in accordance with this consent the quarry managers will be responsible for establishing any trends in terms of groundwater movement. While they will rely directly on both the onsite bores and ECan s offsite monitoring bores, we expect they will also turn to current climatic conditions and long term forecasting for predictions of likely rises in groundwater. Quarries work on a six day working week and I anticipate at the end of that week the weather trends for the immediate weekend would be a factor in terms of backfilling any area to QFMS levels prior to weekends or public holidays. 56 The second measure of protection that I have alerted to is the fact that deep backfill material will need to be stored in available quantities to completely backfill to QFMS levels immediately. 57 Thirdly, the area of deepening will be confined. Whereas the current operations present as a quarry face with hundreds of metres in length at any one site, the deepening application will be conducted more in the nature of a seam on the quarry floor as the visual imagery as demonstrated. Cleanfill 58 I have read the reports and evidence prepared by Peter Callander and the proposed conditions which the applicants have circulated in relation to cleanfill management at quarry sites. 59 I accept that this will result in a change in the operating procedure for receipt and management of cleanfill for all quarries wishing to exercise this consent. 60 I wish to outline the current procedures for cleanfill management and then to overlay the new procedures for receipt of material suitable for deep fill placement _1 11

12 61 Firstly, however, I wish to emphasise the benefits to the wider community of the quarries allowing the deposition of this material at the various sites. It is part of the overall economic activities of quarry land management. Cleanfill received on a site assists us in overall rehabilitation of the site by providing inert filled material to elevate and contour sites prior to final rehabilitation irrespective of whether the final use of a quarry area is back into pasture or to recreational opportunities such as wetlands, golf courses or other uses. 62 Quarries need imported material prior to compaction and the laying of top soil. There are many sites within the Fulton Hogan suite of quarries where active redevelopment is reliant on receipt and management of cleanfill. In the last financial year over 10 hectares of land at Pound Road has been returned to existing ground level and return to pasture. 63 Fulton Hogan was involved in the development of the 2015 guidelines in relation to cleanfill management and irrespective of whether they are formally adopted into the Christchurch City Plan Fulton Hogan fully meets the guidelines for receipt and management of cleanfill. 64 This is not a new activity. It has obviously been accelerated as a result of the Canterbury earthquakes and it is an integral part of the regional management of demolition material to ensure that regional landfills such as that at Kate Valley not used for the deposition of material which is otherwise suitable for fill at quarry sites. 65 Even now, however, the process of acceptance of cleanfill at the quarry entrance and the process of inspections is rigorous. 66 We know of no instances where deposition material received at any of the Fulton Hogan sites has led to any issue undermining the drinking water standards beyond the zone or beyond our site. 67 As a general rule over 80% of all cleanfill received at the site comes either from our own operations or with contractors with whom we have a long standing commercial arrangement. Irrespective of whether you are a quarry operator or a contractor delivering material to a quarry, I consider that everyone is aware of the cleanfill bylaw adopted by the Christchurch City Council and the recently made changes to the cleanfill management guidelines _1 12

13 Receipt of Cleanfill 68 Cleanfill is received over our weighbridge and undergoes its first visual inspection on the weighbridge. The documentation completed at the weighbridge records: The company delivering cleanfill; An order and job number; A volume expressed in cubic metres; Registration number of the truck; The activity from where the cleanfill has been derived e.g. roading, trenching, demolition material; and The address. 69 Following receipt over the weighbridge the cleanfill is delivered to the current cleanfill management site where it is deposited on the ground (above the extracted area) prior to stockpiling and prior to any tipping over the working face. 70 At that point, further investigation is conducted by the loader driver to check for vegetative matter, putrescent material and if material is detected which does not meet the cleanfill guidelines the contractor is required to uplift the load and deliver it to Kate Valley and, at the least, remove it from the Fulton Hogan site. 71 The working face of the cleanfill site is approximately 10 metres high down to the quarry floor and when the material is tipped over the working face, the material cascades down as successive loads are delivered to the face. 72 The re-established ground level following cleanfill management is then compacted and ready for final rehabilitation. New Operating Procedures 73 As a result of this consent, we accept that new operating procedures will need to be adopted. A draft management plan has been prepared on a generic basis for all sites in relation to these new procedures. I summarise these new procedures as follows: 73.1 At the point of entry the weighbridge operator will need to verify that the contractor supplying the material has read and understood the new operating procedures for deep cleanfill management; _1 13

14 73.2 The cleanfill needs to be assigned into three categories, which are as follows: Cleanfill which meets all of the requirement for deep fill; Cleanfill which does not meet the deep fill requirement but is suitable for shallow cleanfill placement in accordance with our current practice; and Cleanfill where the detail on delivery is uncertain From that point on the delivery of the deep fill cleanfill will be separated from other cleanfill and deep fill placement material will be transported to the area where deepened gravel extraction is occurring. The same inspection protocols will apply at all stages. The other two categories will effectively be placed under shallow fill management even where material received on site maybe suitable for deep fill placement but the information is either uncertain or there are concerns at either inspection or on the first visual inspection of the cleanfill following deposition at ground level. 74 We accept that separation of the two lines of cleanfill is critical but this is no different to any other quarry function whereby graded materials are held in separate stockpiles and under different management regimes. 75 In addition to deep cleanfill material received through the inspection process, all quarries have large stockpiles of material meeting the criteria for deep fill already on site. These are derived principally from the by-products of aggregate processing which have no or little economic value such as pea gravels and natural material which is stored when the site is prepared for initial extraction. 76 It is intended that these materials will be used in conjunction with the received deep fill material and as they are already in situ, they are likely to be used first. 77 As a company Fulton Hogan accepts compliance and monitoring on these management practices. Monitoring and Surveys 78 Like all quarries Fulton Hogan is subject to annual and random inspection in relation to compliance with cleanfill bylaws and in relation to overall quarry management. I _1 14

15 can provide records to this hearing of audits relating to our cleanfill management at any of our sites. 79 We hold ISO14001 Certification endorsing the robust environmental management systems on site this includes comprehensive annual audits ensuring the systems are being implemented on site. Date: 26 May _1 15