in the matter of: the Resource Management Act 1991
in the matter of: an application by the Central Plains Water Trust to take
water from the Waimakariri River
and applications by the Central Plains Water Trust to use
water from the Waimakariri and Rakaia Rivers and for
all associated consents required for the construction
and operation of the Central Plains Water Enhancement
in the matter of: a Notice of Requirement by Central Plains Water Limited
to the Selwyn District Council for the designation of
land for works associated with the construction and
operation of the Central Plains Water Enhancement
Brief of evidence of Robert Kenneth McAnergney
Dated: August 2008
Chapman Tripp Barristers & Solicitors
119 Armagh St Tel +64 3 353 4130
PO Box 2510 Fax +64 3 365 4587
Christchurch NZ DX WP21035
Reference: JM Appleyard (firstname.lastname@example.org)
BG Williams (email@example.com)
BRIEF OF EVIDENCE OF ROBERT KENNETH MCANERGNEY
1 My name is Robert Kenneth McAnergney. I am employed by
Christchurch International Airport Limited (CIAL) as Manager,
Airport Planning. My role is to oversee the orderly expansion of the
Airport facilities in terms of its Master Plan. I am also charged with
maintaining a watching brief over all matters which fall within the
ambit of the Resource Management Act 1991. I have been
employed in this role since August 1986.
2 This brief of evidence is provided in support of the submissions by
CIAL on the applications by Central Plains Water Trust and Central
Plains Water Limited.
3 My evidence will cover the scale of the present operation of CIAL
and its importance to the local, regional and national economy. This
3.1 Details of the operation of CIAL with respect to the landing
and take off operations of aircraft with special reference to
such operations during limited visibility conditions and
implications of a change in the climate dynamic on the safe
and efficient operation of CIAL.
3.2 Details of the land owned by CIAL and the presence on that
land of closed and abandoned landfills with particular
reference to predicted changes in groundwater levels and the
possible effect on those landfills.
3.3 Details of bird strike hazard at CIAL and the impact of land
use and changes in bird habitat in the general vicinity of CIAL
on the safe and efficient operation of CIAL.
SCALE AND SCOPE OF PRESENT OPERATION
4 CIAL is the largest airport in the South Island and it has grown
steadily over the years, with increasing numbers of domestic and
international scheduled movements by aircraft of all types. The
airport is capable of handling the largest international aircraft which
arrive on long haul routes from Europe, Asia and the Pacific, plus
daily services to and from Australia.
5 The domestic main trunk routes within New Zealand are served by
three airlines and there are other tourist and commuter airlines
operating every day. In addition, the airport is an operating base
for several overnight freight and mail aircraft operations, and is the
operating base supporting the United States, New Zealand, and
Italian Antarctic Research Programmes.
6 CIAL is an uncurfewed airport. Over recent years, scheduled
movements, both by passenger and freight aircraft, have increased
to such an extent that the airport operates 24 hours a day, 7 days a
week on a regular basis. Scheduled aircraft movements for the year
ending 2007 total approximately 89,000 per annum and general
aviation movements total approximately 67,000 per annum (this
includes passenger flights, cargo/courier flights, aircraft
repositioning flights, airline training flights and 1000 military
movements including Antarctic operations).
7 For the year ending 31 March 2008, 1,633,165 international and
4,167,666 domestic passengers passed through CIAL. During 2007
airfreight carried by scheduled domestic and other freight operators
exceeded 53,000 tonnes. International airfreight during the same
period exceeded 26,000 tonnes.
8 The total indicative value of the assets of CIAL in June 2007 was in
the order of $715,000,000. This does not include assets owned by
others such as Air NZ, Pratt & Whitney, NZ Post, the Sudima Hotel,
which could well exceed a further $125,000,000.
9 Based on work done by McDermott Fairgray in July 1997, and
updated by Copeland Brown in 2003 for the Christchurch City Plan
hearing before the Environment Court, CIAL is a significant physical
and economic resource in national, regional and local terms, and is
associated with economic activity equivalent to 34% of Canterbury’s
economic output and 49% of regional employment.
10 There are approximately 5,000 people employed at CIAL.
11 During the years 1992 to 2003, CIAL experienced a remarkable
international passenger growth of 5.2% per annum. Since 2002,
CIAL has had:
11.1 An increase in international seats (35%) and movements
(25%) due to the introduction of Pacific Blue and Emirates
and an increase in services by Singapore Airlines, Air
New Zealand and Qantas; and
11.2 Domestic increases in seats (10%) and movements (9%) due
to the introduction of express class by Air New Zealand and
as a consequence of international increases.
12 Naturally, this has placed considerable pressure on all existing
facilities, and as a result CIAL extended the international terminal to
provide four additional aircraft docking positions.
13 CIAL continues to experience unprecedented passenger growth.
Currently over 5.8 million passengers per year and their associated
meeters and greeters are passing through CIAL. The existing
facility no longer meets the needs of stakeholders and the travelling
14 A new Integrated Terminal will provide a new and improved
domestic facility whilst integrating some of the existing international
functions, i.e. a combined international and domestic check in hall.
It is currently estimated to cost $195 million.
15 The first stage of the project, the multi-level car park building, is
already complete. Construction continues now in the at grade car
parking areas to prepare the site for construction of the new
terminal. We are currently completing a detailed terminal design
and are in consultation with our major airline partners. It is
anticipated that the project will be complete in 2011.
THE NEED FOR LAND USE PLANNING CONTROLS AROUND
16 From the information noted above, it is apparent to CIAL that there
will continue to be growth in passenger numbers, aircraft movement
numbers, air cargo, demand for tarmac space for aircraft and
buildings of all types to accommodate and service this growth. If
this growth is to continue and provide further economic
opportunities both in the urban and rural sectors of the Province of
Canterbury, the airport must have room to grow within its zone and
sit comfortably with both its urban and rural environs.
17 CIAL believes the compatibility of any airport with its environs is an
ideal which can be achieved by proper planning of the continued
development of the airport and its flight paths and land use planning
of the area surrounding the airport and those areas affected by
aircraft operations. The aim should be to provide the best possible
conditions for the needs of the airport and the surrounding
18 The need for management of land and land use in the vicinity of
airports has been recognised for many years. Historically, the
controls related to height control of possible hazards or obstacles to
flight into or out of airports and the need for a certain type of
control for uses such as those which might cause electrical
interference with radio communications or navigation aids, lights
which might confuse pilots, smoke which might reduce visibility, and
uses which might attract birds. However in recent years Airport
Operators and Planning Authorities world-wide have recognised that
in addition to those above mentioned matters there is a requirement
for compatible land use planning in the vicinity of the airport and its
flight paths to ensure minimal interference to the environment and
the public, e.g. by locating dense residential areas and noise
sensitive uses away from areas subjected to increasingly frequent
noise events and now a need to recognise the necessity to assess
land uses which might contribute to any elevation of the risk of bird
Runway operation and fog
19 At Christchurch International Airport there are two principle runways
the 02/20 runway generally referred to as the main runway. It is
orientated roughly in line with the north east and south west winds
which blow approximately 60% and 30% of the time respectively.
The runway description is an abbreviation of 020 degrees magnetic,
i.e. north east and its reciprocal 200 degrees magnetic, i.e. south
west. The other runway is the 11/29 runway commonly referred to
as the nor west runway. It is orientated at 110 degrees and its
reciprocal 290 degrees. The runway dimensions are as follows: the
02/20 runway is 3288m long, and the 11/29 runway is 1741m long.
20 Aircraft have to takeoff and land into wind. So when the north east
wind the predominant wind at Christchurch International Airport is
blowing aircraft approach Christchurch from the south over
Rolleston and fly down the extended centre line and land into the
north east wind in a north easterly direction. When taking off
aircraft takeoff to the north east and fly out in the direction of
Kaiapoi and once sufficient height is reached will join the vector to
proceed to their next destination.
21 When the south west wind is blowing the other dominant wind at
Christchurch International Airport aircraft approach over Kaiapoi and
land in a south westerly direction and takeoff in the same direction
and fly out towards Rolleston before taking up their vector to their
22 From time to time during both north easterly and south westerly
wind conditions low cloud can occur over CIAL and aircraft land
using what is loosely referred to as their instrument landing system.
I will refer to this in detail further on in my evidence.
23 During north westerly wind conditions which occur much less
frequently aircraft approaching Christchurch International Airport to
land fly over the city and land on runway 29 moving in a north
westerly direction. To take off during north westerly wind conditions
aircraft move along the north west runway and take off over
McLeans Island and away to the west and turn onto their new vector
once sufficient altitude has been achieved. During such wind
conditions (north wester) low cloud and low visibility never occurs
and as a consequence the nor-west runway is not equipped with an
instrument landing system.
24 It should be added that on a regular basis during north easterly
wind conditions when there is sufficient head wind component some
aircraft land on runway 11 in other words they approach the airport
over McLeans Island and land towards the city. CIAL does not
permit aircraft under normal circumstances to takeoff on this
runway because there would be an environmental impact on the
25 CIAL proposes to upgrade the status of the 11/29 runway so that
the size of aircraft using the runway can be increased to
accommodate B777 and the future B787 in north west wind
conditions. CIAL also intends to increase the use the reciprocal
11 runway by landing aircraft in a south easterly direction in north
east and nil wind conditions.
26 I have attached to my evidence copies of pages out of the CAA
document used by pilots which gives the dimensions of the two
runways at Christchurch International Airport (see Appendix 1).
27 As noted, CIAL experiences low cloud and fog events from time to
time which affect its safe and efficient operation. In low cloud
conditions aircraft coming in to land at CIAL use an instrument
landing system (ILS) which operates on the main runway only. This
allows aircraft to approach the runway using instruments to fly down
a radio beam which aligns the aircraft with the runway and the glide
slope which decreases at 300ft per nautical mile to a point where
the pilot at a minimum height of 200ft above ground level must be
able to see the ground beneath him and have visibility ahead to
enable him to see sufficient runway lights and markings before
proceeding to land.
28 The landing operation just described can and does occur during low
cloud limited visibility events. The aircraft may be flying above a
cloud layer and then uses the ILS equipment to descend safely
through the cloud into clear visibility conditions to land on the
appropriate runway for the wind conditions.
29 In fog events aircraft have to be flown from clear visibility conditions
into fog to allow the pilot to be able to see the ground at 200ft
altitude and with sufficient forward visibility to be able to land
30 Dr James Renwick will be giving evidence on the occurrence of
ground fog at CIA.
31 If such events were to become more frequent as a result of changes
in the climate dynamic then CIAL may have to, or be required to (by
pressure from the airlines) install category III ILS capability. CIAL
currently has category I. The installation of such new equipment
would involve upgrades to the ILS, runway centre line and edge
lighting, taxiway centre line and edge lighting, and stop bar lights
(compulsory stop) control installations at taxiway and runway
intersections and entry and exit points). There would also be a
necessity to install ground movement surveillance equipment to
allow pilots and air traffic controllers to know with certainty the
location of aircraft while taxiing etc on the ground.
32 Preliminary estimates indicate that the cost of such an upgrade
would be of the order of $12m (2007). It is not considered to be
required at this time but if the number of limited visibility events
caused by a decrease in the operational efficiency of CIAL then it
may have to be installed to meet airline efficiency expectations and
airspace management requirements.
33 Such a project would take up to 3 years to install with major
disruption to aircraft operations. The effects of such disruptions
have not been factored into the cost estimate.
34 CIAL has a concern having read the assessment of environmental
effects that the number of ground fog events may increase as a
result as a result of a change in a climate dynamic brought about by
the Central Plains Water Enhancement Scheme.
35 CIAL has had advice from Dr Jim Renwick of NIWA on climatic
matters over the years and as stated previously he will present
evidence on this matter.
Groundwater levels at Christchurch International Airport
36 CIAL is located over the unconfined aquifer and draws drinking
water from wells within its property. It has a high quality
environmental compliance monitoring programme and extensive,
expensive monitored storm water installations to protect the purity
of the ground water flowing beneath the airport and on and under
Christchurch City to the east. The airport has inherited over the
years several old landfill sites which at the moment are inert. CIAL
has a concern that one of the effects of the Central Plains Water
Enhancement Scheme will be an increase in ground water level
which could reactivate these abandoned landfills/rubbish tips to the
detriment of our own water supply and that of Christchurch City.
37 The attached plan Christchurch International Airport Limited Rubbish
Tips shows highlighted in brown the abandoned rubbish tips
(landfills dumps) that are located within the Special Purpose Airport
zone and with the exception of the one on the corner of Avonhead
and Grays Road marked “Existing Rubbish Tip (Fulton Hogan)” are
all on land owned by CIAL (see Appendix 2).
38 Also attached are plans Christchurch International Airport Limited
Domestic & Public Supply Wells shows wells on CIAL and
surrounding land, and Christchurch International Airport Limited
Landside Reticulation shows the CIAL wells connected to the on
airport drinking water supply (see Appendices 3 and 4).
39 Mr Peter Callander of Pattle Delamore Partners Limited will give
detailed evidence on this issue from an environmental effects
40 CIAL is very concerned about the potential for it to be held
responsible for any remedial works. The extent of CIAL’s liability for
contaminated sites and any required works is at best unclear.
However, as has been set out by CIAL’s legal counsel, there are
BIRD STRIKE - GENERAL
41 CIAL is located in the Rural 5 (airport influences) zone, surrounded
by rural land uses ranging from Horticultural to Agricultural farming
uses, some intensive produce production, some dry stock low
intensity uses, lifestyle blocks, quarrying operations and recreational
42 CIAL owns 593.2 ha of land on which the airport infrastructure is
located. It has a lease in perpetuity from Environment Canterbury
over an additional 166.5 ha of land to the west of the airport. It
owns various other parcels of land purchased for future use, or for
noise protection purposes which are used for farming purposes,
totalling 126 ha. All this land is actively managed by CIAL staff.
CIAL also owns 51.4 ha of land leased to the Harewood Golf Club.
43 Within this land holding lies the aircraft operational area which
comprises the paved Runways, parallel Taxiways, stub Taxiways and
aircraft parking aprons. These paved surfaces are surrounded by
44 As a general rule aircraft take-off and land into the wind if the wind
is blowing. For the purposes of this hearing it may be said that the
flight paths flown by aircraft are located along the extended centre
lines of the four runways at CIAL.
45 Aircraft during take-off operations fly along the extended centre line
until given clearance by Air Traffic Control to head towards the
predetermined vector for their next destination. The heights of
aircraft at particular locations are difficult to stipulate. This is
because different aircraft have different rates of climb which are
45.1 aircraft engines (jet or turbo prop);
45.2 take off weight (distance to destination);
45.3 weather conditions (wind speed, temperature, etc); and
45.4 company operational policy.
46 As another general rule aircraft on take off will achieve heights
above ground level ranging between a low of 875 ft, 1630 ft and
2400 ft at 1, 2 and 3 nautical miles from threshold respectively to
median of 2000 ft, 3000 ft and 4000 ft at 1, 2 and 3 nautical miles.
47 Aircraft on approach for landing operations follow the reverse
procedure except that they follow a procedure of a controlled rate of
descent at 300 ft per nautical mile.
48 So under normal circumstances aircraft will be at 900 ft, 600 ft and
300 ft above ground level at 3, 2 and 1 nautical miles from the
runway threshold as they come in to land.
49 Under Civil Aviation Authority (CAA) rules, CIAL must hold a current
aerodrome operating certificate to operate as an airport (CAR Part
139 Aerodromes – Certification, Operations and Use).
50 Our certificate was first issued on 7 April 1993 and has been
renewed as of 20 October 2003. An important part of this process
was the preparation of operating manuals required to implement
quality assurance principles for airport operations.
51 The CAA, to ensure our continued compliance with CAR Part 139,
carries out regular audits of the airport and its management
processes including bird hazard.
52 Under Civil Aviation Authority rules, CIAL must actively work to
minimise the threat and incidence of bird strike.
Bird strike History
53 Birds have been a potential hazard to aircraft since the beginning of
travel. Bird strikes were a minor risk in the early days as there
were few aircraft in the sky and they travelled at relatively low
speeds. Damage to aircraft was, therefore, limited to shattered
windshields, dented leading edges, and some damage to the
fuselage. The cost of repairs was small and aircraft operators and
airport authorities accepted bird strikes as a normal hazard of flying.
54 In time, with the development of newer generation turbine engines,
the speed of aircraft increased and engine noise levels dropped.
Aircraft simply became too quick and too quiet for birds to sense
and avoid. Birds inadvertently became a serious threat to aircraft
safety as strikes became more frequent and more serious.
55 Between 1912 and 2004 bird strikes caused the loss of at least
88 aircraft and 243 lives in civil aviation. The cost of damage to
aircraft, delays and cancellations to flights have been estimated to
be between US$1.2 and US$1.5billion per year. More than 80% of
bird strikes to civil aircraft occur on or close to airports, where
aircraft are operating at low altitude (International Bird Strike
56 The most serious bird strike event at CIAL occurred on 29 July
1985. An Air New Zealand Boeing-747 bound for Melbourne with
373 passengers on board struck several birds three seconds after it
had achieved V.1 (141 knots) i.e. take off speed. Committed to
take off and climb out the pilot shut down one engine and had
another on idle. The aircraft, although badly crippled, climbed to
6,000 feet and dumped 3.5 tonnes of fuel at sea before returning to
undertake an emergency landing without brakes or ground steering
ability. Subsequently it was found that the third engine had
ingested a bird but was not so badly damaged as to inhibit its
57 By sheer good luck and brilliant flying skill a major accident was
avoided. It was subsequently stated by the Chairman of the City
Council Committee responsible for management of CIAL that
“immediately after the incident - that same evening, in fact – we set
up an investigating group and from that a special committee was
formed involving the Airport Authority, Civil Aviation, airlines and
ornithologists to find the best immediate solution and a long-term
answer”. That committee continues today.
58 The cost of bird damage, or suspected bird damage, can be
59 down-time for the inspection and repair of aircraft;
59.1 aborted flights;
59.2 rescheduling of aircraft passengers and air cargo;
59.3 transfer of passengers to alternative means of transport;
59.4 overnight accommodation at the expense of the aircraft
59.5 the deleterious effects on schedules of connecting flights.
These can often be very significant and damaging to airline
operating budgets and public goodwill.
Christchurch Airport Bird strike Management
60 Because of the importance of bird control, CIAL has implemented a
policy to minimize the bird strike hazard, and implemented an
airport wildlife control programme.
61 The programme is tailored to conditions on the site, and is managed
by an airport Wildlife Control Officer who reports to the Manager,
Quality, who chairs the Bird Strike Control Committee.
62 This Committee includes employees of CIAL involved in bird control,
airport planning, ornithological experts, vegetation management
experts, airport maintenance staff, air traffic services, flight
services, rescue and fire fighting services. The committee reviews
the strike reports and daily activity records to determine effective
control measures and activities.
63 While it is difficult to drive all birds from an airport at all times,
every reasonable effort to do so is made by our staff and the use of
the lethal methods is a last resort. Any bird is a potential hazard to
aircraft. This is especially true as bird numbers and bird size
increase and the faster and quieter new generation high by pass jet
turbine-engine aircraft become more numerous.
64 Any bird, even a small one, has the potential to cause major
damage to an aircraft. The larger the bird, the greater the damage
is expected to be from a single strike. There is also a greater
likelihood of a strike if there are a great number of birds of the same
species flying in flocks.
Environment Management and Site Modification
65 Birds occur on land around the airport for a variety of reasons.
However, they are usually attracted by such essentials as food,
water and shelter, all of which are often to be found on or in the
vicinity of an airport.
66 Modifications to the airport environment can remove or limit the
attractiveness of an airport to birds, thus eliminating a large part of
the hazard. Environment management is integral to bird control as
it offers effective, long-term measures for reducing the numbers of
birds that will come to an airport. Direct action against birds is an
ongoing necessity because environment management has not yet
been fully implemented and further measures are still to be
implemented. Here I am referring to a research project partly
funded by CIAL to produce selected entophyte inoculated grass
species which will be unattractive to birds (as forage) and insects
and their pupae both above and below the ground. At completion of
this project (if it is successful) CIAL’s grassed areas will be
progressively re-sown with a specially selected and bred grass
species to further reduce on-airport bird populations.
67 It is difficult to remove all food sources for birds on airports;
grassland management has an important influence on food available
to birds. All agricultural measures like mowing or hay making,
ploughing and disking attract birds because of the disturbance of
soil animals and insects.
68 Birds also enter airport lands in order to feed on mice, earthworms,
insects and spiders as well as seeds and agricultural crops. These
sources of food are very attractive to a variety of birds. Chemicals
are used sparingly on airport land to reduce the foods available to
birds but hopefully the new grass species will remove or at least
reduce the need for this process.
69 Surface water is attractive to birds and on the airport property
surface depressions (old watercourses) which sometimes fill with
water have been or are in the process of being removed by
relevelling the ground thus some rural water races have been piped
altogether. CIAL has avoided creating drainage ditches and instead
has opted for ground soakage by way of piping stormwater from
collection sumps to in-ground boulder pits. Recently the one
remaining redundant borrow (gravel) pit which had exposed water
surface has now been filled. The process took countless hours to
obtain a resource consent and cost approximately $332,000 in
construction costs and that was just to fill the pit to just above
70 In areas adjacent to surface water or where depressions in ground
level have resulted in damp, moist soil conditions, vegetation,
insects and invertebrate life tends to flourish and provide food
sources for many bird species. CIAL, having been made aware of
this, has taken steps to reduce this type of occurrence on its own
land to try to reduce the attractiveness of the airport land to
71 In order to reduce the number of birds, food sources and roosting,
loafing and nesting opportunities on the airport, and the use of the
airport as a flyway to some bird species, CIAL has carried out
environmental and site management measures including:
71.1 active shooting programmes from the ground and from
71.2 all manner of bird scaring devices;
71.3 active pasture management to maintain optimum sward
length, to avoid seed head development, and to discourage
insect and invertebrate infestation;
71.4 removal of perching, nesting, and food source trees;
71.5 active eradication of certain pest bird species at pig farms in
the vicinity of the airport (with full co-operation of owners);
71.6 active management of livestock practices.
Incidence of bird strike at Christchurch International Airport
72 Under Rule Part 12 of Civil Aviation Rules each pilot-in-command of
an aircraft that is involved in a bird incident shall notify the
Authority of the incident as soon as practicable. This information is
collated and analysed to prepare a Summary 12 Month Moving
Average Strike Rate per 10,000 Aircraft Movements Report.
73 The 12 Month Moving Average Strike Rate is currently trending
down from a high of 4.5 strikes per 10,000 Aircraft Movements, and
is currently 2.9 strikes per 10,000 Movements. Statistical analysis
indicates that this decrease in bird strike rate is due to an increase
in both an airport active bird management and a range of active off
airport culling programmes with co-operative landowners. CIAL
believes it is taking all practical steps to manage bird strike hazard
on its own land or the land it manages.
74 However land use activities and proposed developments on land
surrounding the airport which has a possibility of cumulatively
increasing bird numbers is of major concern especially if such
developments result in birds flying across the airport or the flight
paths of aircraft on approach or taking-off from Christchurch
Monitoring of Bird Activity
75 CIAL employ’s a consultant ornithologist to advise the Wildlife
Control Committee and to monitor and report on bird population
trends both on the airport and in the general vicinity.
76 Bird number monitoring in the Northwest sector at Christchurch
indicates a steady increase in what is referred to as pest bird
species, that is those species which pose a danger to aircraft such
as Gulls of various species, Canada Geese, introduced and
indigenous Water Fowl, Spurwinged Plover, and Magpies over the
period 1985 to 2008.
Land use around airports
77 The CIAL Wildlife Hazard Management Programme requires the
Airport Planning Manager to maintain a watching brief on
developments in the region that could have an adverse affect on the
CIAL Bird Control Programme, or increase the number of birds in
critical areas in the vicinity of approach and departure flight paths.
78 This requirement stems from information continued in an
International Civil Aviation Organisation Manual (ICAO Annex 14
Bird Hazard Reduction) paragraph 9.4.4. The appropriate page of
that document is attached as Appendix 5.
79 The above requirement came into effect in November 2004 and
CIAL became aware of it in early 2005. Since that time CIAL have
been taking an even greater interest in the establishment of any
source attracting bird activity in the vicinity of the airport.
80 The particular section from ICAO Standards and Recommended
Practices (SARPS) applicable to this matter states:
“The appropriate authority shall take action to eliminate or to
prevent the establishment of garbage dumps or any such
other source attracting bird activity on, or in the vicinity
of, an aerodrome unless an appropriate aeronautical study
indicates that they are unlikely to create conditions conducive
to a bird hazard problem.”
81 The ICAO SARPS carry no legal weight in individual countries. Each
country that is a signatory to the Chicago Protocol, and has not filed
a “difference” with ICAO indicating that it is unwilling or unable to
comply with the standard concerned, is expected to implement
appropriate legislation or other regulations to make the standards
effective in their country.
82 The New Zealand Civil Aviation Authority (NZCAA) has not as yet
put any regulation in place to implement this standard, and are
unlikely to do so. NZCAA take the view that it is up to individual
airports to use the Resource Management Act 1991 to take action
via Plan Changes to have policies and rules incorporated into District
Plans to achieve the requirement 9.4.4 as quoted in paragraph 80
above. CIAL has instigated discussions with NZCAA and other
stakeholders and as a result of those discussions is considering
implementing a suitable method of bird hazard control through the
83 In June 2008 NZCAA published a document entitled Guidance
material for land use at or near aerodromes. A copy is attached as
Appendix 6. I wish to draw attention to the overview on page 1.
The section entitled Wildlife Hazard Management on pages 2, 3 and
4 and especially the subsection entitled Water on page 3.
84 In spite of the difficulties of implementing the ICAO SARPS for off air
field bird management CIAL has attempted to comply with its
requirements and has for example presented evidence raising its
concerns at several recent City Council hearings (e.g. Variation 93
to Christchurch City Plan).
85 CIAL has taken this stance so that if despite its best efforts there is
a major bird strike event which involves loss of life an accident
investigation is inevitable and litigation likely. CIAL is determined to
protect itself from liability and will it believes be able to demonstrate
that it has taken all possible steps to provide the safest operating
environment it can in line with international regulations.
86 It is not enough to put in place management systems to “control
birds”, it is more desirable to restrict the establishment of new
habitat or any such other source attracting bird activity in the
vicinity of CIAL unless an appropriate aeronautical study indicates
that they are unlikely to create conditions conducive to a bird
87 Bird management plans require ongoing sometimes expensive
commitment and the success of such management plans is not
88 In the vicinity of CIAL there are several major bird habitat areas,
which generate bird activity such as to be a concern with respect to
possible bird strike. At some of these from time to time it is
necessary to reduce the numbers of birds which are a danger to
aircraft. As an example, CIAL has arranged to have black back gulls
culled at the Paparua Prison pig farm. Such processes can only be
carried out on large blocks of rural land well away from residential
areas and where land owners are prepared to co-operate.
89 CIAL has also worked with Fish & Game New Zealand (North
Canterbury) to cull Canada Goose numbers but it appears to be a
losing battle with respect to these birds.
90 CIAL is engaged in an ongoing struggle to reduce its bird strike rate
and is advised that this is going to become increasingly difficult as
birds from the Rural Band Northwest sector of the City track across
the airport and its flight paths seeking new habitat, food sources,
water bodies or other land uses attractive to them.
91 I have attached for the Commissioners’ information a copy of an
article entitled Christchurch Airport – a bird’s eye view from Air New
Zealand’s Koru Safe magazine published June 2008 (see
92 If as predicted one of the outcomes of the Central Plains Water
Enhancement Scheme is an increase in groundwater levels then
CIAL predicts that a large number of abandoned and active gravel
pits will become new water bodies and hence attract even more
birds into the vicinity of CIA.
93 Should such an effect occur CIAL will be left with no alternative
other than to formally request ECan to take whatever action is
available to reduce this hazard by requiring landowners to remove
the hazard by filling to a point above the increased groundwater
94 CIAL is hopeful that the issues raised can either be addressed
through conditions or that they can be worked through with the
applicant. At this point in time significant concerns exist around:
94.1 groundwater levels and the impact this might have on down-
aquifer water quality;
94.2 the effect the scheme might have on increasing surface water
around CIAL which could lead to bird-strike; and
94.3 fog effects, which may have significant effects on the
operation of CIAL or require the installation of advanced
navigation equipment (or the cessation of irrigation under
95 CIAL is fundamental to the Canterbury Region. Although CIAL is
generally supportive of development in Canterbury, it is also very
eager to ensure it is only done in a manner that does not affect its
current and future operations.
Dated: August 2008
Robert Kenneth McAnergney