IN THE MATTER
Document Sample


IN THE MATTER of the Resource Management Act 1991
AND
IN THE MATTER of a Board of Inquiry appointed under
Section 149J of the Resource
Management Act 1991 to consider a
Notice of Requirement by the
Minister of Corrections for an
alteration to a designation to provide
for the construction, operation,
maintenance and upgrading of a
Men’s Prison at 20 Hautu Drive, Wiri,
Manukau City
BRIEF OF EVIDENCE OF DAVID BEARD
1. QUALIFICATIONS AND EXPERTISE
1.1 I am David Sydney Beard.
1.2 I reside at 70 Memorial Drive, Hamilton East Hamilton.
1.3 I am director of Investment Property Asset Management Ltd.
1.4 Investment Property Asset Management Ltd is the General Partner of
Investment Property Holdings Limited Partnership and I am authorised to speak
on their behalf.
1.5 Investment Property Holdings Limited Partnership owns an industrial property at
12 Hautu Drive, Wiri, Manakau City.
1.6 I have approximately 25 years experience in the construction and management
of industrial buildings.
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2. 12 HAUTU DRIVE
2.1 The property comprises a heavy engineering workshop of 4488m2 with attached
offices and amenities of 514m2 and canopies of 239.6m2, a total floor area of
5002m2. The land area is 1.0760 hectares (10,760m2). The building height is 9
metres and it is constructed with a heavy duty concrete floor, structural steel
frames and steel clad walls and roof. The building contains a gantry crane
suitable for lifting heavyweight steel sections and steel coil. The building is set
back from the front boundary by 18m and from the rear boundary by 6 m. It is
set back 23.5m and 18 m from the side boundaries. The comparatively large
setbacks are to accommodate vehicle manoeuvring, particularly in view of the
large truck requirements of a building designed as a heavy engineering
workshop. The building was constructed in 2002.
2.2 Hautu Drive is particularly suited to buildings that accommodate large and slow
moving trucks because the low traffic volumes and wide carriageway means
that traffic congestion and conflicts are minimised especially when trucks are
coming in or out of the site. This combined with good access and egress to
Roscommon Road make Hautu Drive particularly attractive to heavy industrial
users.
2.3 The current occupant is Kiwi Steel Ltd who manufactures structural steel
elements and steel cladding for buildings. This involves importing heavy steel
plate which is then cut up and fabricated into steel beams and columns. Kiwi
also import rolled steel coil that is roll formed, using presses, to provide profiled
long-run roofing typical on large industrial premises. Transportation is via B train
units and truck and trailer.
2.4 Kiwi Steel’s lease on the premises expires on 31 July 2011and we have
negotiated with them to extend the lease to now expire 30 July 2012. We would
intend to re-lease the premises to a new tenant on expiry of the Kiwi lease or to
renegotiate a further extension with the present tenant. During our discussions
with Kiwi Steel regarding the renewal of the Lease, Kiwi Steel has expressed
concerns as the effect of the proposed men’s prison on their access, in terms of
safety and ease of access, and general security. We would reasonably expect
similar issues to arise with any incoming tenant. Quality, safety and ease of
access are of paramount importance to users.
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3. The reason that we believe access via Kiwi Tamaki Drive is preferable is that it
will minimize disruption, congestion, and access and safety issues that will
occur if the main entry to the Men’s Prison is placed on Hautu Drive. All of these
factors will detract from the amenity of Hautu Drive and reduce its
attractiveness to tenants. There are eight substantial properties fronting directly
to Hautu Drive and a further eleven on Ha Crescent. There are only three users
on Kiwi Tamaki Drive. I further note there is there is only one occupant along
the entire northern side of Kiwi Tamaki Drive, Visy, and as the site is more or
less fully developed there is little likelihood of further demand for street
crossings. It makes little sense, to me, to adversely affect the amenity of a lot of
substantial occupants when there is another viable option that will minimize the
adverse effects.
4. AGREEMENT WITH DEPARTMENT OF CORRECTIONS
4.1 Our original submission was lodged on our behalf by Cowper Campbell on 14
December 2010.
4.2 On 15 December I was contacted by Craig Erskine of Department of
Corrections advising:
(a) Department of Corrections had had a positive response from CYFS
regarding the land that was required for Corrections to obtain access
from Kiwi Tamaki Drive.
(b) He would like to see our submission turned round to support the
proposal if primary access was to be from Kiwi Tamaki Drive. He still
required secondary access from Hautu Drive.
(c) He advised Auckland Transport had no issue with the intersection of
Kiwi Tamaki Drive/ Bolderwood Drive and Roscommon Road, providing
Corrections paid the cost.
4.3 On 16 December our solicitor, Janette Campbell received an email from Peter
Hall of Boska Miskell, consultants to Department of Corrections as follows:
“Craig has asked me to advise you the following in respect of the Kiwi
Tamaki Road access to the proposed men’s prison:
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1. Negotiations between Corrections and CYFS to secure access to Kiwi
Tamaki Road over the CYFS land are now well advanced.
2. Corrections can now confirm that the principal operational and
construction access to the proposed men’s prison will be from Kiwi
Tamaki Road rather than Hautu Drive. Kiwi Tamaki Road, as the
principal operational access, will provide for staff, visitor, and delivery
vehicles to the men’s prison. Hautu Drive may be used as secondary
delivery access (not staff, visitors or primary delivery) however that
would be expected to be limited to the occasional goods delivery or
service vehicle. Both would remain as access options for emergency
purposes.
3. These changes will be confirmed to the Board of Enquiry hearing by
Corrections.
Please call if you require any clarification.”
4.4 On the basis of the above undertaking we agreed to withdraw our submission of
14 December and lodged a new submission in support of the proposal on 17
December 2010.
4.5 However, when we received Corrections’ evidence on 27 January 2011, we
were concerned to see that no mention is made of primary access being
provided via Kiwi Tamaki Road and only secondary and emergency access
being provided via Hautu Drive.
5. CONCLUSION
5.1 I request that if the amendment to the designation is to be confirmed, that
conditions of the designation should require that Kiwi Tāmaki Drive is used as
the primary access to the proposed prison facility and that Hautu Drive is only
used as a secondary and emergency access as described in Mr Hall’s email.
David Beard
Dated: 11 March 2011
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