In 2010, Fonterra received consents allowing it to develop a new milk powder plant at Darfield. Construction of the proposed plant has commenced and is expected to be completed and the plant operational by August 2012. Fonterra considered the plant necessary to allow for the current and future expansion of milk processing in the Canterbury Region.
In 2010, Fonterra received consents allowing it to develop a new milk powder plant at Darfield. Construction of the proposed plant has commenced and is expected to be completed and the plant operational by August 2012. Fonterra considered the plant necessary to allow for the current and future expansion of milk processing in the Canterbury Region.
In 2010, Fonterra received consents allowing it to develop a new milk powder plant at Darfield. Construction of the proposed plant has commenced and is expected to be completed and the plant operational by August 2012. Fonterra considered the plant necessary to allow for the current and future expansion of milk processing in the Canterbury Region.
Mike Copeland Brown, Copeland & Co Ltd 13 July 2011
1. INTRODUCTION
Report Objective and Format
1.1 In 2010, Fonterra received consents allowing it to develop a new milk powder plant at Darfield. Construction of the proposed plant has commenced and is expected to be completed and the plant operational by August 2012. This (Stage 1) development will have the capacity to process up to 2.2 million litres of milk per day but there is capacity to accommodate future plant expansions on the 680 hectare site. Fonterra considered the plant necessary to allow for the current and future expansion of milk processing in the Canterbury Region.
1.2 Fonterra now wishes to proceed with obtaining consents to enable the construction of a second plant on the site with an additional capacity of 5 million litres of milk per day (the Stage 2 Project), giving a total processing capacity on the site of 7.2 million litres of milk per day. To expand the processing capacity as proposed, Fonterra requires land use consent for construction and resource consents for land use, stormwater, discharge to air and land and disposal of wastewater. This report accordingly undertakes an assessment of the economic impacts of the Stage 2 Project and forms part of Fonterras assessment of environmental effects (AEE) of the Stage 2 Project.
1.3 This report is divided into 6 parts (in addition to this introductory section). These are: (a) the background to Fonterras development at Darfield; (b) a consideration of the relevance of economic effects under the Resource Management Act (RMA); (c) a description of the key economic drivers of the Selwyn District economy; (d) the local district economic impacts during the Stage 2 Projects construction and operational phases; (e) a discussion of the potential economic costs; and (f) some overall conclusions.
2. BACKGROUND TO PROPOSED DEVELOPMENT 1
2.1 New Zealand is the worlds largest exporter of milk products and Fonterra, which processes 92% of New Zealands total milk production, is the largest dairy exporter to the global open market. Fonterra is New Zealands biggest company and is responsible for 25% of New Zealands total exports by value. Each year Fonterra processes around 14 billion litres of milk at 24 processing sites in New Zealand, employing 9,500 people and earning $16 billion in annual revenues. The company is co-operatively owned by 10,500 shareholders, who are a mix of family owned farms and corporate entities.
2.2 Whereas milk production in the North Island has ceased growing, milk production in the South Island continues to grow, especially in the Canterbury region, which now produces 10% of New Zealands milk. Canterbury is the fastest growing dairying region in New Zealand with milk production in Canterbury growing at 5% per annum.
2.3 To cope with the growth in milk production in Canterbury (and the South Island), Fonterra over the last 10 years has expanded its plant(s) at Clandeboye 2 near Timaru (and Edendale 3 near Invercargill). However, to meet anticipated future
1 Material in this section provided by Fonterra. 2 Clandeboye is now Fonterras third largest milk processing site. 3 Edendale is now the worlds largest milk processing site by milk volume. growth in Canterburys milk supply, Fonterra proposed the new plant situated near Darfield in the Selwyn District.
2.4 Fonterra has analysed the location of existing and projected future milk production from farms in the Canterbury region and has assessed the advantages of the proposed site near Darfield relative to other potential new sites and the expansion of the existing plant at Clandeboye. Fonterra has concluded that the key advantages of the proposed Darfield site are: The surrounding area has dairy growth potential; The site is large enough to allow for future expansions such as the proposed Stage 2 Project to cope with predicted future increases in North and Mid Canterbury milk supply; The site is on a main road with good road network links; The site is adjacent to the rail network for delivery of inputs and export of milk products; The site is close to Lyttelton Port; The site is close to Darfield and Christchurch City for skilled staff and support industries; The site has a sufficient supply of good quality water, a reliable electricity supply and is of sufficient size to enable on-site wastewater disposal; and The site is some distance from neighbours and effects on them can be mitigated.
3. ECONOMICS AND THE RMA
Community Economic Wellbeing
3.1 Economic considerations are intertwined with the concept of the sustainable management of natural and physical resources, which is embodied in the RMA. In particular, Part II section 5(2) refers to enabling people and communities to provide for their economic ... well being as a part of the meaning of sustainable management, the promotion of which is the purpose of the RMA.
3.2 As well as indicating the relevance of economic effects in considerations under the RMA, this section also refers to people and communities (emphasis added), which highlights that in assessing the impacts of a proposal it is the impacts on the community and not just the applicant or particular individuals or organisations, that must be taken into account. This is underpinned by the definition of environment which also extends to include people and communities.
Economic Efficiency
3.3 Part II section 7(b) of the RMA notes that in achieving the purpose of the Act, all persons shall have particular regard to ... the efficient use and development of natural and physical resources which include the economic concept of efficiency 4 . Economic efficiency can be defined as:
the effectiveness of resource allocation in the economy as a whole such that outputs of goods and services fully reflect consumer preferences for these goods and services as well as individual goods and services being produced at minimum cost through appropriate mixes of factor inputs 5 .
3.4 More generally economic efficiency can be considered in terms of: Maximising the value of outputs divided by the cost of inputs; Maximising the value of outputs for a given cost of inputs; Minimising the cost of inputs for a given value of outputs; Improving the utilisation of existing assets; and Minimising waste.
Viewpoint
3.5 An essential first step in carrying out an evaluation of the positive and negative economic effects of a development project is to define the appropriate viewpoint that is to be adopted. This helps to define which economic effects are relevant to
4 See, for example, in Marlborough Ridge Ltd v Marlborough District Council [1998] NZRMA 73, the Court noted that all aspects of efficiency are economic by definition because economics is about the use of resources generally. 5 Pass, Christopher and Lowes, Bryan, 1993, Collins Dictionary of Economics (2 nd edition), Harper Collins, page 148. the analysis. Typically a district or wider regional viewpoint is adopted and sometimes even a nationwide viewpoint might be considered appropriate 6 .
3.6 For Fonterras proposed expansion of the its new milk powder plant at Darfield it is appropriate to consider Selwyn District economic impacts given the Stage 2 Projects likely impacts on local residents and businesses. At the Canterbury regional level many of the projects economic impacts net out in that without the new plant expansion, Canterburys expanding milk production will need to be processed somewhere in the region either at an expanded Clandeboye or at an alternative site for a new plant. However in terms of economic efficiency effects the project generates district, regional and national level economic benefits.
3.7 There are also private or financial costs and benefits associated with this proposal. If consents are granted for the Stage 2 Project, and Fonterra gives effect to those consents then it can be assumed that these private or financial costs and benefits have been responsibly and properly analysed and that from the viewpoint of those with money at risk, the expected financial benefits exceed the expected costs. Accountability for accuracy of the financial analysis clearly rests with Fonterra and ultimately the net financial benefits Fonterra might receive from the proposal are not directly relevant to the assessment of effects under the RMA. The focus of this report is therefore on the wider economic effects on parties other than Fonterra and its customers. Economists refer to such effects as externalities 7 .
Economic Rationale for Land Use Controls
3.8 Over the past thirty years or so there has been a growing acceptance in New Zealand and other countries that economic efficiency is maximised when investment decisions are left to individual entrepreneurs or firms, without intervention from Government. The reason for this is that a perfectly competitive market achieves an efficient allocation of resources. Accordingly, the efficient use of resources (and therefore sustainable management) occurs through the
6 For example, there was an inference that the consideration of Project Aqua and other Waitaki River water allocation cases by a central government appointed body was to broaden the viewpoint from a local district or regional level to a wider national level. 7 Defined as the side effects of the production or use of a good or service, which affects third parties, other than just the buyer and seller. creation of a climate where the market enables people to make investment decisions to provide for their economic well-being.
3.9 Despite this, markets are not perfect, and the presence of externalities affects the working of the market and the results that could be expected from a totally unregulated system of resource allocation. Externalities arise because the actions of individuals or firms sometimes create positive or negative impacts on others.
3.10 It is also unrealistic to assume that development of particular forms of economic activity and/or the location of that economic activity will avoid the imposition of costs on the community in general. Where the developer, and/or those engaged in the various forms of economic activity at the site do not face the incidence of these costs, externalities arise and intervention of some form may be justified. In other words the development may create costs or benefits for parties other than those commercially involved in the development.
3.11 Externalities may be in the form of environmental effects such as visual, noise, water or air pollution effects. Externalities in an economic context may relate to the provision of infrastructure where a strict user pays system is not in place; to traffic congestion and road accident effects; and to the so called agglomeration economies and public amenity benefits, which relate to the beneficial effects for businesses, customers and residents in concentrating particular forms of economic activity within confined areas.
3.12 It is the presence of externalities (economic and non economic), which justify land use constraints since if externalities are not present the market can be left to itself to optimise resource use efficiency. However the existence of externality costs per se does not justify intervention for example by not granting resource consent for the expansion of Fonterras new milk powder plant at Darfield and preventing a more 8 market determined outcome with respect to the use of the land.
8 Granting resource consent for the proposed expansion of the milk powder plant at darfield would not constitute a completely free market outcome. Expansion of the plant will still be subject to the constraints which already exist in the District Plan and any additional constraints imposed when consents are granted. These consenting constraints may have the effect of addressing externalities which would otherwise arise. Also Fonterra in developing and operating its expanded plant will be subject to various regulatory constraints other than those imposed under the RMA for example, occupational safety and health regulations. 3.13 Firstly intervention is not costless in that it prevents a market determined outcome, maximising producer and consumer choice. Preventing Fonterra from best meeting the needs of its customers and suppliers will have economic efficiency costs for Fonterra, its customers, farmer suppliers and shareholders. Incurring these costs is only justified if significant economic (or non-economic) externality costs are associated with the proposed development.
3.14 Secondly there may be externality benefits from the proposed Fonterra plant expansion that outweigh any externality costs which may result from it. Therefore a range of economic externalities (both positive and negative) arising from the proposed Stage 2 Project expanding the new milk powder plant are discussed later in this report.
4. THE SELWYN DISTRICT ECONOMY
Population 9
4.1 The 2006 census recorded a population in the Selwyn District of 33,669 persons, which represented 6.5% of Canterburys population. In 2001, Selwyn Districts population was 27,312 and the growth of 18.8% over the period 2001 to 2006 was considerably higher than that for Canterbury (8.0%) and New Zealand (7.8%) over the same period. Between 2006 and 2010, Selwyns population is estimated by Statistics New Zealand to have grown by a further 11.3%, as compared to growth of 4.8% for the Canterbury region and 4.4% for New Zealand as whole.
4.2 Statistics New Zealands medium population projections 10 have Selwyns population growing at an average rate of 2% per annum over the period 2006-31, compared to an average rate of growth for the Canterbury region and New Zealand of only 0.8% per annum.
Gross Domestic Product 11
9 Data in this section from Statistics New Zealand. 10 Statistics New Zealand prepare three sets of projections high, medium and low according to natural population change (i.e. the net effect of birth and death rate assumptions) and net migration assumptions. These projections do not explicitly incorporate assumptions about different rates of economic development. 11 Data in this section taken from work undertaken for the Selwyn District Council see Selwyn Economic Base for the District; Caroline Saunders, Meike Guenther and Paul Dalziel, AERU,
4.3 An analysis of contributions to Gross Domestic Product (GDP) for the Selwyn District highlights its reliance on the agricultural sector insofar as economic activity within the District is concerned. 12 For 2007, the agriculture, forestry and fishing industry group 13 accounted for 29.0% of GDP for the Selwyn District, as compared to only 6.1% for the whole of New Zealand. 14 The second most important industry group is the government administration and defence group which accounted for 18.4% of Selwyns GDP, as compared to only 4.4% for all of New Zealand. 15 This reflects the presence of the Burnham military camp within the Selwyn District. Manufacturing accounted for 8.5% of Selwyns GDP but this is much lower than the 14.0% for all of New Zealand.
4.4 The Selwyn District, given that it is not a metropolitan centre, is also underrepresented in electricity, gas and water supply, wholesale trade, retail trade, communication services, finance and insurance, property and business services, health and community services and cultural and recreational services. It is overrepresented in education reflecting the presence of Lincoln University within the District. In other industry groups including accommodation, cafes and restaurants, the GDP contribution percentages are similar to those for the national economy.
Employment 16
4.5 Like the GDP data, employment data also highlight the dependence of the Selwyn District economy on the agriculture, forestry and fishing industry group. In the November 2010, 2,269 jobs (21.3%) of Selwyn Districts 12,540 jobs were in this
Lincoln University, 20 September, 2009 and Quarterly Economic Monitor Selwyn District; Infometrics; December 2009. 12 Some persons residing in the Selwyn District commute into Christchurch City for employment. To this extent the reliance of the District on the agricultural sector, measured only in terms of economic activity generated within the District, is overstated. 13 Statistics New Zealand data on the number of firms shows that agriculture predominates over the other industries within this group. Agriculture accounts for 89.2% of all firms in this industry group. Of the remaining 10.8% of firms in this industry group 6.4% are agriculture, forestry and fishing support services firms and many of these will also be orientated towards the agriculture sector. 14 For 2009, Infometrics estimate this industry groups contribution to Selwyn Districts GDP was 27.8%. No 2009 comparative estimate is available for New Zealand. 15 For 2009, Infometrics estimate this industry groups contribution to Selwyn Districts GDP was 19.1%. 16 Data in this section from Statistics New Zealand. industry group. The next most important sectors by employment were public administration and safety (19.1%), education (13.5%), and manufacturing (10.1%).
5. ECONOMIC BENEFITS OF THE PROPOSED DARFIELD MILK POWDER PLANT
Increased Economic Activity during Plant Construction 17
5.1 The Stage 2 Projects construction is likely to commence sometime in the five years after the Stage 1 plant is constructed and operational (i.e. sometime in the five years after August 2012) and last for eighteen months. The project has an estimated construction cost of $240 million (excluding land costs). The majority of the equipment, materials and services required for the plants expansion will be sourced from within New Zealand, with the remainder imported from overseas. Local Selwyn District suppliers will be used wherever possible, but realistically most suppliers from the Canterbury region will be predominantly located in Christchurch City rather than the Selwyn District. Goods and services, which may be supplied from the Selwyn District during the Stage 2 Project, include excavation services, concrete, road construction materials, fencing, shelter belt planting, re-grassing, catering services, construction labour, laundry services, accommodation and security services.
5.2 During the Stage 2 Project construction an on-site workforce starting at 50 employees and peaking at 700 employees will be required with an estimated monthly average of around 300 employees. Wage and salary payments for these employees are estimated to average $17 million per annum. 18 How much of these wage and salary payments will be injected into the Selwyn District economy is difficult to estimate. This depends on how many construction workers will reside permanently in the District over the construction period, how many construction workers will reside temporarily in the District over the construction period and how much of non-resident construction workers incomes will be spent in the District.
17 Unless stated otherwise data in this section provided by Fonterra. 18 Based on an average salary per employee of $55,000 per annum. This is the same as the average salary assumed in 2010 for the Stage 1 development assessment of economic effects report. Wage and salary inflation is likely to have lifted this figure slightly but within the margins of error of estimates in this report, which expresses all costs in 2011 price terms. 5.3 Statistics New Zealand forecasts indicate that in 2011, Selwyns population will be 8.7% of the combined populations of Christchurch City (378,900), Waimakariri District (49,100) and Selwyn District (40,900). On the basis of this a very conservative estimate is that something in the vicinity of 10% of the workforces income will find its way into the Selwyn District economy i.e. there will be an equivalent of 30 extra fulltime on-site construction jobs created for Selwyn District residents and an additional $1.7 million per annum in additional income for Selwyn resident households. These are the direct economic impacts for the Selwyn District economy during the Stage 2 Projects construction.
5.4 However in addition to these direct economic impacts there are indirect impacts arising from: The effects on suppliers of goods and services provided to the site from within the District (i.e. the forward and backward linkage effects). As noted above these will be limited by the equipment, materials and services required for Stage 2 of the milk powder plants construction being sourced mostly from outside the Selwyn District; and The supply of goods and services to employees at the site and to those engaged in supplying goods and services to the site (i.e. the induced effects). For example, there will be additional jobs and incomes for employees of supermarkets, restaurants and bars as a consequence of the additional expenditure by employees directly involved in the plants construction at the site and living within the Selwyn District.
5.5 District multipliers can be estimated to gauge the size of these indirect effects. The size of the multipliers is a function of the extent to which a district economy is self-sufficient in the provision of a full range of goods and services and the districts proximity to alternative sources of supply. District multipliers typically fall in the range of 1.5 to 2.0 and taking the low point of 1.5, given the Selwyn Districts close proximity to Christchurch, implies total impacts (i.e. direct plus indirect impacts) during the Stage 2 construction period of: 45 additional jobs for local Selwyn District residents; and $2.6 million per annum in additional wages and salaries for local Selwyn District residents.
Increased Economic Activity during Expanded Plants Operation 19
5.6 After the Stage 2 Project expansion is completed, the plant will require additional inputs of materials and services other than milk and employee labour. Again these are likely to be largely drawn from Christchurch City. Fonterra estimates about 80% of operational input supplies other than milk and employee labour will come from Christchurch City. However some local Selwyn District firms may provide goods and services to the plant including, for example security services, laundry services, gardening services, canteen outsourcing, electrical maintenance services and mechanical maintenance services. Fonterra estimate a maximum of 10% of the value of operational input supplies (other than milk and employee labour) might be supplied from within the Selwyn District.
5.7 Of the expected additional Stage 2 operational on-site workforce of 23 fulltime equivalent (FTE) employees and up to an additional 39 milk tanker drivers, it is estimated that at least 50% or 31 additional FTEs are likely to reside permanently within the Selwyn District. 20 This estimate is based on travel times from Darfield of around 5 minutes, from Sheffield of around 10 minutes, from Springfield of around 15 minutes, from Rolleston and West Melton of 20 to 25 minutes and from Christchurch of up to 1 hour depending where in the City an employee resides and peak versus off-peak travel times. This implies an ongoing increase in direct employment within Selwyn District of 31 jobs and an increase in direct household income of $2.3 million per annum (on the basis of an average salary for plant employees and drivers of $75,000 per annum).
5.8 Again using a district multiplier of 1.5 implies an increase in direct plus indirect employment of 46.5 FTE jobs for local Selwyn District residents and an increase in direct plus indirect household income of $3.5 million per annum within the Selwyn District economy.
19 Unless stated otherwise data in this section provided by Fonterra. 20 This may be conservative in that the additional drivers required as a result of the Stage 2 Project are more likely to be within a 30 minute drive time to the plant where the tankers will be based, given the shift work involved. In the case of Stage 1, no new tanker driver positions were assumed.
Economic Benefits from Increased Economic Activity
5.9 As indicators of levels of economic activity, economic impacts in terms of increased expenditure, incomes and employment within the Selwyn District economy are not in themselves measures of improvements in economic welfare or economic wellbeing. However, there are economic welfare enhancing benefits associated with increased levels of economic activity. These relate to one or more of: Increased economies of scale: Businesses and public sector agencies are able to provide increased amounts of outputs with lower unit costs, hence increasing profitability or lowering prices; Increased competition: Increases in the demand for goods and services allow a greater number of providers of goods and services to enter markets and there are efficiency benefits from increased levels of competition; Reduced unemployment and underemployment 21 of resources: To the extent resources (including labour) would be otherwise unemployed or underemployed, increases in economic activity can bring efficiency benefits when there is a reduction in unemployment and underemployment. The extent of such gains is of course a function of the extent of underutilized resources within the local economy at the time and the match of resource requirements of a project and those resources unemployed or underemployed within the local economy; and Increased quality of central government provided services: Sometimes the quality of services provided by central government such as education and health care are a function of population levels and the quality of such services in a community can be increased if increased economic activity maintains or enhances population levels.
21 Underemployment differs from unemployment in that resources are employed but not at their maximum worth; e.g. in the case of labour, it can be employed at a higher skill and/or productivity level, reflected in higher wage rates. 5.10 It is reasonable to presume that increases in economic activity (i.e. expenditures, incomes and employment) within the Selwyn District economy as a consequence of the Stage 2 expansion of Fonterras new milk powder plant will give rise to one or more of these four welfare enhancing economic benefits for the local community. For example, increases in population in the District will help underpin existing school rolls.
Economic Efficiency Benefits from Optimising Plant Location
5.11 Fonterra, in choosing the proposed site for its new milk powder plant has sought to minimise milk collection costs having regard to the existing and likely future pattern of milk production throughout the Canterbury region. A reduction of some 20,000 vehicle kilometres per day travelled by milk tankers has been estimated for the Stage 1 development. 22 Other factors influencing the choice of the Darfield site are its proximity to Port Lyttelton and its access to the rail network for receiving inputs into the site and the export of finished products.
5.12 Fonterra has estimated that, from a milk collection point of view, there is an additional saving of 10,000 vehicle kilometres per day travelled by milk tankers if the plant at Darfield is expanded compared to a similar expansion of its Clandeboye plant. In addition because the finished product will travel by rail from Darfield to Port Lyttleton instead of by road from Clandeboye to Port Lyttelton there will be a reduction of 52 truck movements per day between Clandeboye and Lyttelton or 8,100 vehicle-kilometres per day.
5.13 Reducing road transport kilometres associated with the collection of milk and the export of products from the site will reduce the externality costs associated with road transport. It is therefore appropriate to expect a reduction in road accident costs, road transport pollution costs and travel time costs for other road users. For example Fonterras initial estimates show that the Stage 2 Project expansion at Darfield will result in a reduction in the carbon footprint of 23 tonnes per day in CO 2 emissions as a consequence of reduced milk collection distances and rail transport replacing road transport for the export of products from the site.
22 Assuming the alternative to the new plant is the expansion of the existing Clandeboye plant. See Section 9.1, Appendix J: Transportation Assessment Report (for the Stage 1 Development); Traffic Design Group; June 2010.
Increased Diversity for the Selwyn District Economy
5.14 As noted in Section 3 of this report, the Selwyn District economy is primarily driven by the agricultural, forestry and fishing industry group 23 , which accounted for 29.0% of the Districts GDP in 2007. The comparative New Zealand-wide percentage is only 6.1%. The next most significant industry group is government administration and defence, which accounted for 18.4% against a national figure of 4.4%, reflecting the presence of the Burnham military camp within the Selwyn District. Manufacturing at 8.5% is the next most significant industry group in the District but this is much less than the national figure of 14.0%.
5.15 Therefore Fonterras Stage 2 expansion of its proposed new milk powder plant at Darfield will help provide greater diversity and balance to the Selwyn District economy. Although it will involve the processing of milk, additional manufacturing activity in the District will provide employment opportunities and incomes less dependent upon returns to the agricultural sector. This will make the Selwyn District economy more resilient to agricultural commodity price cycles.
5.16 Also the proposed expansion of Fonterras milk powder plant at Darfield (and the ongoing construction of the Stage 1 plant) will provide much needed confidence to the manufacturing sector of greater Christchurch following the major earthquakes of September 2010, February 2011 and June 2011 and ongoing aftershocks.
Increased Rates Revenue for Selwyn District Council
5.17 Fonterra will pay increased rates as a consequence of the Stage 2 Project as the general rate is applied to the capital value of properties. Because of economies of scale it is likely that the increase in rates paid by Fonterra will be greater than the increase in Councils costs. From the perspective of the Selwyn District Council and other ratepayers in the District, this broadening of the rating base provides the opportunity for a greater range of Council provided services or a reduction in the rates burden for other ratepayers.
23 Predominantly agriculture. Community Sponsorship Programme
5.18 In recognition of the important role the community plays in helping Fonterra realise its potential, the company provides financial support to a number of initiatives at the community and national level. At the community level 6 regions have been identified for local community support in the areas of environment, education, emergency response and nutrition and well being. These regions are at the various locations where Fonterra has significant milk processing plants. A new region has been established at the plant at Darfield and a community site relations champion appointed as a point of contact for the Selwyn District community. Expanding the plant at Darfield as compared to expansion of one of Fonterras alternative plants or establishment of a plant at a new site will lead to a greater contribution by Fonterra to the local Selwyn District community.
6. POTENTIAL ECONOMIC COSTS OF THE PROPOSED DARFIELD MILK POWDER PLANT
Lost Agricultural Production
6.1 Lost agricultural production is not an external cost of Fonterras proposed new milk powder plant at Darfield. The productive value of the land in alternative uses will be internalised into the cost structure of the development in other words Fonterra in purchasing the land will pay a price reflective of future net returns from alternative uses for the land. Such costs are not costs to be borne by the wider community.
6.2 In any case the increase in the lands rateable value if land use consent is granted will be indicative of the land being used more efficiently than if it continued only in its current use.
6.3 In terms of reduced economic activity within the District from a reduction in agricultural use, current employment on the site is estimated at 5 FTEs and therefore even with District multiplier impacts taken into account the additional economic activity generated within the Selwyn District by the new milk powder plant and the subsequent Stage 2 Project expansion of the plant will significantly outweigh any reductions in economic activity from any displaced farming. Furthermore the plant and roads on the site after Stage 2 is completed are estimated to require less than 2% of the site (12.5 hectares 24 out of 680 hectares), and the remainder of the site will continue to be used for agricultural purposes with an improved supply of irrigation water from the plants treated wastewater system. Therefore any reduction in agricultural activity on the site as a consequence of the Stage 2 Project will be insignificant. Also Fonterra are in the processing of seeking consent for a further 212 hectares of third party irrigation, increasing production from these properties which are not currently irrigated.
Reductions in Tourism
6.4 The accommodation, cafes and restaurants industry group accounts for 1.5% of the Selwyn Districts GDP. This is same percentage as for New Zealand as a whole. Whilst tourism is not as significant a driver of the District economy as other industries (e.g. agriculture), the District is the home to several ski-fields (Broken River, Craigieburn, Mt Olympus, Porter Heights, Mt Cheeseman and Temple Basin) and the Arthurs Pass National Park and offers a wide range of outdoor activities for visitors to the District to enjoy.
6.5 The new milk powder plant will be situated outside of any main centre in the District, will not be adjacent or near to tourist attractions and will be almost invisible from State Highway 73. The new milk powder plant and its proposed Stage 2 expansion will not impact on outdoor pursuits in the District such as skiing, tramping, mountain climbing or fishing. The evidence of Mr Greenaway concluded in relation to the Stage 1 plant proposal concluded that it would not cause adverse impacts on regional tourism activity. Therefore I believe that it is unlikely that the plant or its proposed expansion would have any discernable negative impact on tourist visitor numbers, their length of stay in the District and tourist expenditure in the District.
6.6 In fact the expansion of a major manufacturing plant within the District is likely to lead to some increase in visitor numbers to the District and benefits in terms of additional visitor spending on locally provided accommodation and hospitality. During the construction phase of the Stage 2 Project, there will be significant
24 The Stage 2 expansion only involves and additional 0.5 hectares of site coverage. increases in demand for short-term and long-term accommodation within the District, especially in and around Darfield. Once the expanded plant is operational there will be an increased number of visitors to the project site who will require overnight accommodation within the general vicinity of the plant.
Utilities
6.7 Externality costs can arise when utilities provided by central or local government (e.g. roads, water supply, storm water and flood control systems and wastewater disposal) are not appropriately priced. In the case of Fonterras proposed expansion of its milk powder plant at Darfield no such externality costs will arise.
6.8 Stage 2 will not require any further improvements to the intersection onto State Highway 73 and the level crossing providing access to the site from the existing road network. The assessment of traffic effects concludes that the access arrangements consented for Stage 1 will readily accommodate the volume of vehicles envisaged during the construction and operation of Stage 2, although it will be necessary to adopt working practices to ensure that traffic volumes are spread over a 30 minute period rather than 15 minutes, in order to reduce queue lengths at the access. However, with this arrangement in place it is considered that the traffic generated will be safely and efficiently accommodated within the adjacent road network. 25
6.9 Fonterra and its farmer suppliers will make payments via road user charges and rates for any additional ongoing maintenance and necessary upgrades to the state highway and local district council road networks as a consequence of increased milk tanker movements within the Selwyn District resulting from the Stage 2 expansion.
6.10 With respect to water supply on-site bores will be used for the new plant and its expansion. For storm water and wastewater disposal the new expanded Fonterra milk powder plant will be totally self-sufficient. The plant will not use the Selwyn District Council provided services and there can be no concerns that other
25 See Fonterra Co-operative Group Ltd, Darfield Milk Powder Plant Stage 2 Transportation Assessment Report; Traffic Design Group, 2011. ratepayers of the District will be providing subsidised services to the expanded plant.
Local Road Congestion Costs
6.11 An analysis of the traffic effects of the Stage 2 Project has concluded that the access arrangements agreed in relation to the Stage 1 development are sufficient to accommodate the additional volumes of vehicles envisaged and that the traffic generated during both the construction and operation of the expanded plant will be safely and efficiently accommodated within the adjacent road network. 26
7. CONCLUSIONS
7.1 The proposed expansion of Fonterras Darfield Milk Powder Plant will enhance the economic well being of the Selwyn community by:
(i) Creating an additional 45 jobs for Selwyn District residents during the Stage 2 Projects eighteen month construction period;
(ii) Creating an additional 46.5 jobs for Selwyn District residents once the plant is operational;
(iii) Increasing total household income in the District by $2.6 million per annum during the plants eighteen month construction period;
(iv) Increasing total household income in the District by $3.5 million per annum once the plant is operational;
(v) Increasing population in the District, thereby increasing or maintaining the quality of some central government provided services;
(vi) Providing the local economy with greater diversity and resilience;
26 See See Fonterra Co-operative Group Ltd, Darfield Milk Powder Plant Stage 2 Transportation Assessment Report; Traffic Design Group, 2011. (vii) Increasing confidence in the Greater Christchurch manufacturing sector following the major earthquakes of September 2010, February 2011 and June 2011 and ongoing aftershocks;
(viii) Providing greater employment choice for local residents;
(ix) Broadening the rating base of the Selwyn District Council; and
(x) Fonterra making additional contributions to local community activities, in its role as a responsible employer and good corporate citizen.
7.2 The new plant will improve resource use efficiency by:
(i) Increasing economic activity and population in the Selwyn District, enabling increased economies of scale in the local provision of goods and services;
(ii) Reducing transport costs for the collection of milk and the export of finished products; and
(iii) Reducing externality costs associated with road transport including road accident costs, road transport pollution costs and travel time costs for other road users.
7.3 The new plant will not give rise to economic externality costs.
INITIAL DATE DESIGNED AC 150711 DRAWN EG 150711 APPROVED AC 150711 CLIENT FONTERRA DARFIELD DRAWING NUMBER: FILENAME: SCALE 1:7500 @ A4 FD2#-A4-P1-XR FD2.indd ATTACHMENT 1 - FONTERRA DARFIELD STAGE 2 LANDSCAPE PLAN setback 50m from rail Oak trees (Quercus robur) to be 4.0m high at time of planting with maximum 6.0mspacing between trees in each group INITIAL DATE DESIGNED AC 150711 DRAWN EG 150711 APPROVED AC 150711 CLIENT FONTERRA DARFIELD DRAWING NUMBER: FILENAME: SCALE 1:2000 @ A4 FD2#-A4-P2-XR FD2.indd ATTACHMENT 1 - FONTERRA DARFIELD STAGE 2 LANDSCAPE PLAN OAKS setback 50m from rail Oak trees (Quercus robur) to be 4.0m high at time of planting with maximum 6.0m spacing between trees in each group 0 50 100 m INITIAL DATE DESIGNED AC 150711 DRAWN EG 150711 APPROVED AC 150711 CLIENT FONTERRA DARFIELD DRAWING NUMBER: FILENAME: NOT TO SCALE FD2#-A4-P3-XR FD2.indd FONTERRA DARFIELD STAGE 2 COMPARATIVE ELEVATIONS - EAST AND NORTH East Elevation North Elevation NOTE: Elements shaded blue are identifed as part of stage 2 application. Unshaded areas represent stage 1. INITIAL DATE DESIGNED AC 150711 DRAWN EG 150711 APPROVED AC 150711 CLIENT FONTERRA DARFIELD DRAWING NUMBER: FILENAME: NOT TO SCALE FD2#-A4-P4-XR FD2.indd FONTERRA DARFIELD STAGE 2 COMPARATIVE ELEVATIONS - WEST & SOUTH West Elevation South Elevation NOTE: Elements shaded blue are identifed as part of stage 2 application. Unshaded areas represent stage 1.
NOTE: This photograph shows the location of dwellings and degree of visual effects. The Stage 1 plant is shown only, not the stage 2 extension, which has no effect on the location of vantage points. The degree of effects relative to Stage 1 and 2 remains the same.
DARFIELD MILK POWDER PLANT Stage 1 VIEW EFFECTS ON DWELLINGS ATTACHMENT 2 July 2011
Proposed Darfield Milk Powder Plant Stage 2
Assessment of Environmental Effects - Landscape
Prepared by Andrew Craig for Fonterra Co-operative Group Limited (the Applicant)
Andrew Craig Landscape Architect Ltd Poynton House 68 Oxford Terrace Christchurch
In this report the effects on the landscape of a proposal to develop Stage 2 of the milk powder processing plant north of Darfield is assessed. A full description of the proposal, including architectural drawings, accompanies the application. The extent and location of the proposal is also shown within that documentation.
Much of the landscape assessment prepared for Stage 1 remains relevant for the Stage 2 proposal. This will principally concern the description of the application site and receiving environment and statutory landscape matters arising from the Selwyn District Plan. Fundamentally the conditions for these remain the same as for Stage 1. The same applies to the recommended landscape conditions, as it is concluded that Stage 2 will not necessitate that these need to be altered or expanded. Consequently the following matters are addressed.
A description of the Stage 2 proposal and its potential effects within its landscape setting.
Measures taken to avoid and / or mitigate any adverse effects arising.
Conclusions
In preparing this assessment it is understood that the overall activity status for the proposal is fully discretionary.
This assessment is based on plans prepared by Babbage Consultants Limited and elevations prepared by DLA Architects Limited attached to the application. From these photo-simulations have been prepared 1 which give an accurate indication of what the visual effects are going to be as viewed from key vantage points.
2.0 THE LANDSCAPE EFFECTS OF THE STAGE 2 PROPOSAL
The Stage 2 proposal will fundamentally involve expansion of the Stage 1 plant, and this will include the following;
An additional 56.2m high drier, plus rooftop discharge stacks An extended 30,000m 2 drystore and loadout area A second boiler which does not include a second chimney Various minor accessory structures
Of these the dryer, drystore and boiler will potentially create the greatest visual effects. The taller structures, namely the dryer and to a lesser extent the boiler, are the ones most likely to be visible due to their height. This is because visibility increases with height, unless there are site specific circumstances that counteract this effect. The Stage 2 drier will be 4m higher than the consented Stage 1 drier, thereby informing the visual effects baseline.
Even though the drystore is by far the largest structure in terms of site coverage, its relatively low 13m height means that it will be substantially less visible than the taller structures. Further its full site coverage extent cannot be readily appreciated because all that can be potentially seen are no more than two of its four facades.
1 By Virtual View Ltd 3 Consequently its visual effects are confined to the length and height of the facades including the visible roof, which in principal also applies to the other structures such as the drier.
Proportion is also another consideration regarding the drystore. Because the building is to be considerably lengthened its height to length ratio is changed substantially in favour of the latter. Or to put it another way, the extended drystore will display a strongly horizontal character rather than vertical. This will have the effect of visually flattening the building or making it seem lower than it really is.
The taller driers will further cement the impression that the drystore appears as a low slung structure. This is because the vertically proportioned driers will contrast with the horizontally proportioned drystore. That is, each defines the proportions of other by way of the contrast between them. This will be especially apparent in this case because the two buildings sit side by side.
As intimated, because the drier is the taller building, it will be potentially the more visible. At 56.2m high the Stage 2 drier will be 4m taller than the consented Stage 1 drier, although this is now to be 41.25m high. The same principals of proportion apply to it as they do for the dry store. Because the two driers will be side by side, the overall proportion is changed in favour of the horizontal. Consequently the two driers in combination will appear squatter or less vertical than the single consented drier. It will however, present greater visual bulk. Resulting from this will be a corresponding increase in reflectivity and therefore visibility. There are however factors present that will help overcome the increased visibility effects arising from both the dry store, drier and boiler, which will be discussed later regarding avoidance and mitigation.
Visual effects will also depend on vantage point location in relation to the orientation of the proposed structures and their relationship to those consented. As noted for the Stage 1 application, the key vantage point in terms of numbers potentially affected is State Highway 73 and the Midland Railway. It is acknowledged however that the same dwellings identified in the Stage 1 application also stand to be potentially affected. These are identified on the Attachment 2 Aerial Photograph. Accompanying the application are Photo-simulations which have been prepared showing the effects of the Stage 2 expansion. The photo-points for these are the same as for Stage 1. The comparable differences are listed by photo-point reference as follows.
Photo- point
01 No discernable difference
The visual effects are therefore non-existent.
02 Apparent increase in building bulk visible until year 5 which will be fully screened by vegetation by year 10. Note that due to distance and the effects of perspective that the Stage 2 drier does not exceed the 4m height of the pivot irrigator shown in the foreground of the photo-simulation. The visually affected field of view is therefore not particularly significant.
The visual effects are therefore insignificant becoming increasingly so as the trees mature.
03 No photo-simulation is provided from this vantage point as it was The Oaks which has since been acquired by the Applicant. 4
The visual effects are therefore not relevant.
04 From this point at the vehicle entryway the dairy plant is substantially exposed to view. This is because some middle distance pines had to be removed as they were recently assessed by an arborist as being unsafe to retain. To compensate a substantial group of broadleaf exotics (oaks) will be planted as shown in the photo-simulation. These will be 4m high at time of planting which will immediately screen the visually complex lower half of the dairy plant. By year 10 it will more or less be fully screened as is shown in the photo-simulation, although there may be a fleeting glimpse of it down the access way when travellers on SH73 pass by. The location and extent of the oak planting is shown on the Attachment 1 planting plan.
The visual effects are therefore insignificant becoming increasingly so as the trees mature.
05 No discernable difference
The visual effects are therefore non-existent
06 From this vantage point the change in view is the most substantial of all points. The bulk of the Stage 2 drier is a dominant middle ground feature which also intrudes the distant mountain skyline. The dairy plant cannot be screened from this point as the foreground land does not belong to the applicant. However, there are some factors that contribute to the lessening of visual effects. One is the considerable distance from the vantage point to the dairy plant which means that the visual bulk of the building is not overly dominating. Or to put it another way, the surrounding rural land maintains its prevalence. Further the key views of the background mountain peaks of the Torlesse range remain un-obscured. Finally, the vantage point is on a road that is little used other than by local landholders and their visitors. So the road is not a significant vantage point when compared to SH73 and the Midland Railway.
The visual effects are therefore significant, but at the lower end rather than higher.
07 Although the visible bulk of the dairy plant is apparent from this view point on Kimberley Road the structure is at such a distance that its bulk is not domineering. Nor does the building intrude the mountain skyline in the background.
The visual effects are therefore negligible.
08 From Landsborough Drive near Darfield the dairy plant is partially visible in the distance. Because it is a considerable distance from this view point the structure is not at all dominant. Further it does not intrude the mountain backdrop skyline.
The visual effects are therefore negligible.
In relation to these vantage points the greatest extent of visual effects will occur in respect of the east and west elevations see these in the Attachment 3 Elevations. 5 The latter shows the most affected view shafts will, as stated, project to the east and west. The north and south axis are least affected as essentially only the top of the proposed drier will introduce a discernably visible difference in terms of increased building bulk. This is evident in the Attachment 1 Elevations also.
Looking east the view shaft extends from a point more or less just west of The Oaks (now owned by the Applicant) to a corresponding point on Auchenflower Road. The view shaft boundaries are perpendicular to these roads where a line extending from them meets the westernmost corners of the consented and proposed structures. Beyond that foreshortening takes effect thereby significantly reducing potential visibility of the west facade. The same principal applies to the east faade. Here the view shaft meets at the corner of Auchenflower and Loes Road and in the opposite direction at the point where the vehicle entry to the plant meets SH73.
These view shafts take in all of the dwellings considered to be potentially affected by the Stage 1 proposal, with the exception of The Oaks (which is now owned by the applicant). And as stated, the least affected areas are going to be those views from the north and south, the extent of which is also shown on the Attachment 2 Aerial Photograph.
As for Stage 1, avoidance and mitigation measures are advanced with a view to overcoming any adverse visual effects. These are discussed next.
3.0 AVOIDANCE AND MITIGATION OF ADVERSE EFFECTS
A number of measures have been taken to minimise adverse visual effects. These mainly arise from the location of the proposed extensions in combination with the landscape mitigation measures applying to the Stage 1 consent.
Concerning location, all of the major structures the drier and dry store, except for the boiler are positioned further from the highway than those in Stage 1. That is, they are extended northward 2 toward Auchenflower Road in a direction in which there are no potentially affected dwellings. Additionally, the Stage 2 structures effectively move away from neighbouring dwellings, and in this regard are optimally sited so as to lessen effects as much as possible. It is acknowledged however that location largely reflects operational requirements as was the intention regarding Stage 1, but is nonetheless favourable to the reduction of adverse visual effects.
Clustering of the Stage 2 structures also occurs as a product of their location and function in relation to the Stage 1 complex. This means that visual effects are concentrated toward the core of the plant rather than dispersed. This is particularly important with regard to the taller structures namely the driers and boiler. The reason is that, as mentioned, they are potentially the most visible due to their height and because of this convey the impression that the plant is compact in its overall extent. Further, the clustering promotes visual coherence of the plant where like structures are associated with like. It also denotes a visual hierarchy that culminates in the driers, and so aesthetically is more visually coherent than dispersed and apparently less well organised features.
The operational dictates of the consented and proposed Stage 2 plant will, (as noted in the Stage 1 landscape assessment), lead to a series of buildings and accessory structures resulting in a complex that is more or less broken down into its constituent
2 As referred to in the elevations and on site plan as Project North 6 parts. The visual effect is that the complex as whole is modulated, which substantially reduces potential building domination. The different shapes, heights and proportions of the various buildings and allied structures will assist in this regard. These are apparent in the architectural drawings that accompany the application. This effect will still apply to the Stage 2 proposal.
In order to mitigate visual effects most reliance will be placed on the provision of landscaping, and in particular that provided for in Stage 1. Essentially this comprises two shelterbelt plantings to be established immediately surrounding the plant and on the outer application site perimeter. The location and extent of this planting is shown on the consented Stage 1 landscape plan. Because the anticipated visual effects arising from Stage 2 are concentrated around the Stage 1 structures, their mitigation remains the same. Consequently there is no need to provide landscaping additional to that proposed for Stage 1 as it will adequately screen the Stage 2 extensions.
To illustrate visual effects arising from the Stage 2 proposal and their mitigation a series of photo-simulations have been prepared. 3 The simulations are taken from the same vantage points as that for Stage 1, and show the differences between it and the Stage 2 proposal. Also shown are the effects of mitigation. It is evident from the photo-simulations that over time the entire plant will be screened from the key vantage points as indicated for Stage 1. The only views that cannot be readily or fully screened are those from the dwellings on Loes Road. There will also be some additional interruption of the backdrop mountain skyline for these residents that will be beyond mitigation or avoidance.
Finally regarding vegetative screening, the location of the entire plant, including the Stage 2 proposal, also enables utilisation of existing mature pine shelter belts, whose presence will facilitate immediate visual screening. Additionally these trees, being quite large will help reduce potential building domination. The effect of these is also shown in the photo-simulations. Importantly, and as for Stage 1, the existing mature trees will provide immediate screening for those dwellings located at the junction of SH73, Auchenflower and Bleak House Roads. And as for Stage 1, the efficacy of vegetative screening will increase over time as trees mature. Implementation is being carried out at the present moment, and so will be established, although immature, once Stage 2 gets under way.
Turning to colour, it was noted by the Councils landscape architect 4 regarding the Stage 1 proposal that lighter tones will better prevent the effects of silhouetting against a sky backdrop. As a result it was recommended by the Council to remove the proposed dark colour logo field at the top of the building. The Stage 2 extension will adopt the same colours as that for Stage 1, also minus the logo field. Consequently the taller building while increasing reflectivity will better align with the lighter colour and tones of its sky backdrop when viewed from the various vantage points.
Overall, the avoidance and mitigation measures that apply to Stage 1 are equally effective for Stage 2. There is no need therefore to implement additional measures, and so no further conditions of consent are offered. So while the Stage 2 extensions will substantially add to the collective bulk of the dairy plant, the visual effects will nonetheless be ultimately negligible in the presence of the Stage 1 avoidance and mitigation measures. Resulting from these, all of the lower portions of both the Stage 1 and 2 dairy plant will be fully screened from all potentially affected parties. The
3 Prepared by Virtual View Limited 4 Mr Tony Milne 7 taller components, namely the drying tower and boiler stacks, will remain visible to some parties, and invisible to others. However, the other avoidance measures such as generous setbacks, clustering, appropriate colour scheme and modulation will help to reduce effects considerably.
4.0 DISTRICT PLAN LANDSCAPE MATTERS
The District Plan matters concerning landscape outcomes discussed in respect of Stage 1 are equally applicable to Stage 2. It is the intention therefore not to enter into a detailed level of discussion regarding these except as a reminder of what their general direction is. This is summarised as follows:
That the rural area accommodates a variety of activities allowing for primary production and other business activities, including those which are derived from rural production such as dairying. [SDP Policy B.3.4.1]
That significant adverse amenity effects arising from activity is to be avoided, remedied or mitigated. [Policies B3.4.3 and B3.4.4]. The explanation and reasons recognise that large sites are often needed for certain activities such as dairy plants, and that generous separation from neighbours is an effective avoidance method that large sites enable. The Stage 2 extensions will achieve this.
That building density will be maintained at a low level in the Rural Zones along with a predominance of vegetation cover [B3.4.5]. This policy outcome is delivered by the site coverage rule which is is 5%. 5 The combined Stage 1 and 2 activities will be less than 1% where the remaining land area will be devoted to vegetative cover in the form or pasture and shelterbelt plantings.
That high rise buildings are to be avoided. Of all the objectives and policies this is the most difficult to achieve due to the height of the all driers exceeding the permitted maximum 12m height limit. The Stage 2 drier will compound the effects arising from height. As discussed though, the avoidance and mitigation measures, including generous setbacks, will overcome the adverse effects arising from this. This is evident in the photo-simulations that accompany the application.
That adverse effects from night lighting be avoided [Policy B3.4.9]. As for Stage 1, this will be screened by shelterbelt planting around the dairy plant perimeter.
That buildings are sufficiently setback from property boundaries so as to maintain privacy and outlook for neighbours in addition to a sense of open space [Policy B3.4.16]. As for Stage 1 the Stage 2 extension will be generously setback from neighbouring properties at the very least 650 metres.
As for Stage 1 the objectives and policies clearly contemplate the kind of activity proposed, and therefore the effects this will have on the landscape. They are however, mindful that such activity has the potential to generate adverse effects, and
5 SDP Rural Rule 3.11.1.1(b) 8 where this occurs it is a requirement that they are either avoided or mitigated. The principle landscape effect will arise from tall buildings namely the Stage 1 and 2 driers; the height effects of which Policy B3.4.6 seeks to avoid. For the most part these are addressed through avoidance measures namely via the generous setbacks from road frontages and adjoining properties. Very low site coverage also counters any adverse effects arising from building height, as does the proposed colour scheme. The existing and proposed shelter belt planting, which is being planted at present, is located as close as possible to affected vantage points. With the exception of Loes Road residents, this will fully screen the taller structures from these vantage points as is evident in the photo-simulations. As a consequence of these proposed avoidance and mitigation measures, it is concluded that any adverse effects arising from building height will be successfully avoided and mitigated with respect to most potentially affected parties when considered within the context of the District Plan objectives and policies.
5.0 CONCLUSION
In summary the greatest cumulative visual effect is going to arise from the presence of the combined Stage 1 and 2 driers. In combination they have the potential to dominate the landscape and potentially interrupt views. While the dry store in site coverage terms is by far the larger building, because of its relatively low height it will be easily screened within a very short time frame. Although taller than the drystore, the Stage 2 boiler will also be effectively screened reasonably quickly. This is only from the points where existing mature shelterbelts are not able to provide immediate screening as is shown on the accompanying photo-simulations. In time all planting will mean that from most vantage points the dairy plant in its entirety will be screened from key vantage points. This will be especially so from where planting is proximate to the vantage point which means that screening is effective within a very short time frame.
The visual effects are otherwise avoided through the substantial setbacks and clustering of structures. The plant including the Stage 2 extensions will still appear as a coherent co-location of structures that are visually related to each other. Further, and most importantly they will not appear sporadic or erratic, leading to the dispersal of visual effects.
Finally, as for Stage 1 the Stage 2 proposal is favoured by the District Plan provisions concerning visual amenity and landscape change with the exception of building height effects. Nonetheless the Plan contemplates such activity in the Outer Plains Rural Zone including specific identification of dairy plants, providing any adverse effects are avoided, remedied or mitigated. In this regard the proposed plant has been optimally located, with a view to minimising adverse visual and landscape effects. The mitigation currently being implemented in respect of Stage 1 will further and equally counter any visual effects arising from the Stage 2 proposal. Short of this there is nothing more that could possibly be offered without compromising or precluding the proposal.