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EVIDENCE LIBRARY

The Evidence

Every claim broken into the same five parts, so a reader can see exactly where the applicant’s evidence ends and where the open questions begin.

By Ridgeburn Press · Evidence Desk16 September 202615 min read
The He Tohu document room at the National Library of New Zealand, Wellington, which holds He Whakaputanga, Te Tiriti o Waitangi and the Women's Suffrage Petition

This is the working record. Each proposition below is a claim that matters to the decision, set out under the same five headings so that it can be checked rather than believed. Where the evidence is the applicant’s, we say so. Where our own analysis goes beyond the evidence, we say that too. Where there is nothing, there is a gap label, and the gap label is the honest content.

A note on the word Ridgeburn. Under the heading “What Ridgeburn Says”, “Ridgeburn” means Ridgeburn Limited, the applicant. It does not mean Ridgeburn Press. Where this page states a view of our own it is under “Independent Analysis” and is labelled as analysis.

Only propositions with a figure in the record appear here. We have not seeded this library with claims we cannot source. The classification scheme is published at How We Classify Evidence.

1 · The proposal is for 1,200 dwellings at Arrow Junction

What Ridgeburn Says

The application is for a development of 1,200 dwellings at Arrow Junction, Queenstown Lakes District, advanced through the fast-track pathway.

Evidence

  • Application material — dwelling yield of 1,200, applicant — [Source to be added]
  • Deposited Plan 601937, and Records of Title 1174253 and 1174254, which establish the land to which the application relates. See Property & Development Timeline. — [Source to be added]

Independent Analysis

Nothing turns on whether 1,200 is exactly right; it is the order of magnitude that drives every other figure on this site. The dwelling count is the input from which the traffic, wastewater and nitrogen figures are derived, which means any error in it propagates into all of them. It is also the figure most likely to change between application, decision and construction — through staging, variation or subsequent consents — and a figure that can grow after consent should be assessed at the size it could reach, not only the size applied for.

Questions Remaining

  • Is 1,200 the maximum yield, or an indicative figure capable of increase?
  • Is the development staged, and if so what is the yield of each stage?
  • What is the dwelling mix, and what occupancy does the application assume for it? — [Awaiting client evidence]

Public Comment

Comment is not open on this page. Where to comment is set out at the end of this library.

Evidence note: Applicant Evidence. The dwelling count is the applicant’s own and is reproduced as stated; the source document reference has not yet been attached. — [Source to be added]

2 · The development would generate approximately 3,000 vehicle movements a day

What Ridgeburn Says

The application material puts traffic generation at approximately 3,000 vehicle movements per day.

Evidence

  • Application material — traffic generation estimate, applicant — [Source to be added]
  • Integrated transport assessment and intersection modelling, applicant’s traffic engineer — [Source to be added]
  • Road controlling authority and state highway manager responses — [Source to be added]

Independent Analysis

A daily total is the wrong unit for an effect that is produced in the peak hour at a single intersection. Every one of those movements passes through the development’s access and its junction with the wider network, and intersection delay does not rise in proportion to demand — it rises sharply as capacity is approached. The three receiving corridors are also not interchangeable: SH6 is a strategic route already carrying freight and visitor traffic, Gibbston Valley Road is rural in function and geometry, and the Crown Range Road approach is alpine. Set out in full at Traffic & Transport.

Questions Remaining

  • What is peak-hour generation, and how does the access intersection perform at peak?
  • What directional split across SH6, Gibbston Valley Road and the Crown Range Road approach is assumed, and on what basis?
  • What household trip rate was used, in a district with high car dependence?
  • Is the assessment cumulative with other consented and proposed growth in the corridor?
  • What roading and intersection works are required, when, and at whose cost?

Public Comment

Comment is not open on this page.

Evidence note: Applicant Evidence as to the figure; Analysis as to what it implies. The underlying transport assessment is not held, so the figure has not been independently verified. — [Source to be added]

3 · The development would produce approximately one million litres of wastewater a day

What Ridgeburn Says

The application material puts wastewater volume at approximately 1,000,000 litres per day, to be collected, treated, and disposed of to land, with disposal at Morven Hill.

Evidence

  • Application material — wastewater volume (approximately 1,000,000 litres per day), applicant — [Source to be added]
  • Wastewater treatment and land-application design, applicant’s engineer — [Source to be added]
  • Regional discharge consent conditions, regional council — [Source to be added]

Independent Analysis

A daily volume is a commitment, not a description: it has to be collected, treated and disposed of on the worst day as well as the average one. The pathway from household to receiving environment has seven stages and only two of them — treatment and plant uptake — actually remove anything. Every other stage transfers the problem onward. The volume also implies a matching water supply of similar size drawn from the same catchment, which the material we hold does not address. Set out in full at Water, Wastewater & Nitrogen.

Questions Remaining

  • What occupancy and per-person water use produce the one million litre figure? — [Awaiting client evidence]
  • What is wet-weather flow, and what is the infiltration allowance?
  • What happens to overflow when the network or the plant is at capacity?
  • Where does the potable water for 1,200 dwellings come from?

Public Comment

Comment is not open on this page.

Evidence note: Applicant Evidence. Reproduced as stated; not independently verified. The occupancy assumption behind it has been requested. — [Awaiting client evidence]

4 · The nitrogen load is 2.8 tonnes a year

What Ridgeburn Says

The application material records a nitrogen load of 2.8 tonnes per year associated with the development’s wastewater.

Evidence

  • Application material — nitrogen load (2.8 tonnes per year), applicant — [Source to be added]
  • Nutrient and groundwater assessment for the land-application area — [Source to be added]
  • Catchment nutrient limits for the receiving environment, regional council — [Source to be added]

Independent Analysis

This is the most important entry in the library, because the figure is not yet usable. There are four distinct nitrogen quantities in a system like this — the load entering the plant, the load remaining in treated effluent, the load applied to land, and the load predicted to reach groundwater or surface water — and they are of very different sizes. The record as we hold it does not state which of the four the 2.8 tonne figure measures. The same three digits therefore describe either a modest discharge or a serious one. Separately, the quantity that actually governs whether land disposal works is not an annual total at all but a loading rate per hectare, and that cannot be calculated without the disposal area, which is not published. We have not estimated it.

Questions Remaining

  • Which of the four nitrogen quantities does 2.8 tonnes a year describe?
  • What is the nitrogen loading rate per hectare per year at the disposal area? — [Source to be added]
  • What treatment process is proposed, and what nutrient-removal performance is designed and consented?
  • What is the phosphorus load — it is unquantified in the material we hold. — [Awaiting client evidence]
  • Is the receiving catchment already at or over its nutrient limits?

Public Comment

Comment is not open on this page.

Evidence note: Applicant Evidence as to the figure. Its meaning is undetermined until the applicant states which quantity it measures. — Unverified — under investigation

5 · Treated effluent can be disposed of to land at Morven Hill

What Ridgeburn Says

Treated effluent from the development would be applied to land, with disposal at Morven Hill.

Evidence

  • Application material — land-application and Morven Hill disposal proposal, applicant — [Source to be added]
  • Soil, slope, depth-to-groundwater and groundwater-flow assessment for the disposal area — [Source to be added]
  • Instrument securing tenure of the disposal area for the life of the development — [Source to be added]

Independent Analysis

Land disposal is a transfer, not a disappearance. Whether it works is decided by a short list of physical facts about that specific ground: the area actually available, soil type and drainage, depth to groundwater and its seasonal variation, slope and runoff risk, the storage available for days when ground is saturated or frozen, what vegetation takes the nutrient up and whether it is harvested, and what legal instrument secures the land permanently. Plant uptake is also seasonal, and is lowest in winter when soils are wettest. None of those facts is in front of us, so the capacity of Morven Hill to accept this discharge is, on the public record, unestablished.

Questions Remaining

  • How many hectares are actually available for application?
  • What is the depth to groundwater, and where does that groundwater go?
  • What bores, springs or drinking-water sources lie downgradient?
  • How many days of storage exist, and what happens when storage is full?
  • What secures the disposal land for the life of the development?

Public Comment

Comment is not open on this page.

Evidence note: Applicant Evidence as to the proposal; the capacity of the site to accept it is not established on the record we hold. — Unverified — under investigation

6 · Lighting effects on the night sky can be managed

What Ridgeburn Says

We hold no statement from the applicant on lighting or night-sky effects. Any lighting assessment or proposed lighting design forming part of the application — [Source to be added]

Evidence

  • Proposed lighting design and any lighting assessment, applicant — [Source to be added]
  • District plan lighting provisions applying to this site, Queenstown Lakes District Council — [Source to be added]
  • Measured night-sky brightness baseline for the site and its surrounds — [Source to be added]
  • Independent dark-sky assessment — not commissioned; no expert instructed.

Independent Analysis

Fitting-level compliance and sky glow are different quantities. A lighting rule tests one fitting; sky glow is produced by all of them at once, together with light reflected off lit surfaces, interior light through glazing, resident-installed security lighting and vehicle headlights — several of which cannot be conditioned at all. In a dark rural setting the relative change from a new light source is large, because the baseline is low. Set out in full at Dark Skies.

Questions Remaining

  • What is the measured night-sky baseline, and what is the predicted change?
  • Does the assessment include reflected light, interior light and headlights?
  • Is the assessment cumulative with other development in the same basin?
  • Does the site carry or adjoin any formal dark-sky protection? — [Source to be added]
  • Who would monitor lighting conditions after consent, and with what consequence?

Public Comment

Comment is not open on this page.

Evidence note: Under Investigation. No lighting assessment and no measured baseline is held; this proposition is open in both directions. — Unverified — under investigation

Where public comment is open, and where it is not

We would rather tell you exactly where your comment does and does not go than imply a conversation that is not happening.

  • Not open on this page. This library is a record, and it carries no comment thread.
  • Open on published articles and press releases. Every item on News & Media and Press Releases carries the seven-point sentiment scale. It records reaction. It is never evidence, and it is never counted as a vote.
  • Threaded debate opens with the 10 Questions. Public debate threads belong to 10 Questions Ridgeburn Must Answer, which is in preparation and awaiting evidence. When those publish, comment opens with them.
  • Always open: correction and right of reply. If a proposition here is wrong, tell us. That route applies to anyone, including the applicant and the Council, and it is the only route on this site that guarantees publication of your response.
  • Always open: send us material. Documents, corrections and local knowledge reach us through Have Your Say.

How this library will change

Every gap label above is a task, not a decoration. As source documents are attached, the labels come off and the Evidence sections fill. As expert reports are commissioned — none has been, and none is named; see Expert Evidence Centre — the Independent Analysis sections will cite them rather than reason from first principles. Propositions will be added as figures enter the record, and any proposition that the evidence defeats will be marked as defeated rather than removed.

Evidence statement

Classification: Evidence Library (mixed — each proposition above carries its own classification)

Status: A structured record. Each proposition carries its own evidence note. Figures reproduced here are the applicant’s unless stated; the Independent Analysis sections are our analysis and are not expert evidence.

Author: Ridgeburn Press · Evidence Desk

Last reviewed: 16 September 2026

Sources

  1. Application material — dwelling yield, traffic generation, wastewater volume, nitrogen load and land-application proposal, applicant — [Source to be added]
  2. Deposited Plan 601937; Records of Title 1174253 and 1174254; Covenant Instrument 13089567.5 — [Source to be added]
  3. Regional discharge consent conditions and catchment nutrient limits, regional council — [Source to be added]
  4. District plan provisions applying to the site, Queenstown Lakes District Council — [Source to be added]

Assumptions

  • That the applicant’s figures describe the completed development at full occupancy; the occupancy assumption is not published — [Awaiting client evidence]
  • That no proposition here rests on a figure absent from the record. Nothing has been estimated, interpolated or scaled to fill a gap.

What is not established

  • Which of the four nitrogen quantities the 2.8 tonnes a year figure measures.
  • The nitrogen loading rate per hectare at the Morven Hill disposal area.
  • Peak-hour traffic generation and intersection performance.
  • Any measured or modelled change to night-sky brightness.
  • The phosphorus load at any stage.
  • That any proposition here has been tested by an independently instructed expert — none has been instructed.

Right of response

Ridgeburn Limited, Queenstown Lakes District Council and any person named here may respond in full. How to respond.

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