UNDER the Resource Mangement Act 1991 PANUKU DEVELOPMENT AUCKLAND. Applicant AUCKLAND COUNCIL. Regulatory Authority

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1 2002 BEFORE THE ENVIRONMENT COURT AT AUCKLAND ENV-2018-AKL UNDER the Resource Mangement Act 1991 IN THE MATTER BETWEEN of the direct referral of applications for resource consent for the necessary infrastructure and related activities associated with holding the America's Cup in Auckland PANUKU DEVELOPMENT AUCKLAND Applicant A N D AUCKLAND COUNCIL Regulatory Authority STATEMENT OF EVIDENCE OF ANGELA BULL ON BEHALF OF VIADUCT HARBOUR HOLDINGS LIMITED CORPORATE 21 AUGUST 2018 ELLIS GOULD LAWYERS AUCKLAND REF: Douglas Allan Level 17 Vero Centre 48 Shortland Street, Auckland Tel: / Fax: PO Box 1509 DX CP22003 AUCKLAND

2 INTRODUCTION 1.1 My name is Angela Jennifer Bull. 1.2 I am the Chief Executive Officer of Tramco Group, which is responsible for three significant property portfolios, including Viaduct Harbour Holdings Limited (VHHL). I was appointed to my current role in February I graduated from the University of Auckland in 1998 with Bachelor of Laws and Bachelor of Arts degrees. I have extensive experience in the property investment, development and infrastructure fields. Between 2008 and 2015 I was the General Manager Property Development at Foodstuffs North Island Limited. I am also a qualified lawyer with expertise in resource management and property law. I practised between 1998 and 2006 at leading national law firms and at the Crown Law Office and hold a current practising certificate. 1.4 My role at VHHL includes being responsible for all aspects of the management of the VHHL land holdings in the Viaduct Harbour and Wynyard Quarter precinct, including any planning, consenting and land development matters. 1.5 As a substantial land owner in the Viaduct and Wynyard precincts, VHHL has been involved in the master planning of both precincts to create a high amenity mix of commercial office, residential and hospitality uses with high quality public spaces and a focus on the unique connection to the Auckland waterfront. VHHL has actively participated in plan change processes, and more recently the Auckland Unitary Plan, over the last 20 years to ensure a co-ordinated approach to the development of this part of the City s waterfront. 1.6 This evidence addresses matters raised in VHHL s submission dated 28 May 2018 and section 274 notice dated 3 July 2018 on Panuku Development Auckland s ( Panuku ) application for consents for infrastructure and related activities associated with hosting the 36 th America's Cup ( AC36 ) and any subsequent America's Cup event during a 10 year perioid. 1.7 I confirm I have the appropriate authority to give evidence at this hearing on behalf of VHHL.

3 This statement will address the following matters: (a) (b) (c) (d) (e) (f) VHHL s interests in the Viaduct Harbour and Wynyard Precincts. The long term or permanent infrastructure works proposed to accommodate the AC36 events (with a particular focus on the Hobson Wharf Extension). The shorter term infrastructure works proposed to accommodate the AC36 events (including most notably the syndicate bases). Eastern Viaduct. Construction effects. The effects of the America s Cup events. 2. EXECUTIVE SUMMARY 2.1 VHHL supports hosting the AC36 Event at the proposed locations. 2.2 The Viaduct Harbour precinct is unique for its accessibility and connectivity to the water. The proposed Hobson Wharf Extension in particular is in a sensitive location and VHHL is keen to ensure that appropriate regard is had to the design of Base B and the future legacy outcomes of the extension wharf, so as to preserve the unique qualities of this waterfront location. 2.3 The Viaduct Harbour and Wynyard precincts have a mix of commercial, residential, industrial (in the case of Wynyard Wharf) and public spaces, coupled with complex construction activities occurring on several sites. These activities occur in a relatively confined space with limited points of access, so careful consideration needs to be given to the construction, operation and event periods. 2.4 VHHL has been actively involved in the mediation process and supports the application on the basis of the proposed conditions of consent attached to Vaughan Smith s evidence, and the Design Requirements attached to the Landscape and Visual Effects Joint Witness Statement dated 7 August Those conditions have been the subject of extensive discussions with Panuku and have largely been agreed between the parties. In addition, VHHL and Panuku have entered into a

4 side agreement which primarily addresses legacy issues (ie: use of the facilities after the expiry of the 10 year consents for the America s Cup activities). As a consequence, VHHL no longer seeks additional conditions governing those legacy matters. 3. VHHL S INTERESTS IN THE VIADUCT HARBOUR AND WYNYARD PRECINCTS 3.1 VHHL is the owner of the fee simple interest in approximately 14 hectares of land located in the southern parts of the Viaduct Harbour and Wynyard Precincts, immediately to the north of Fanshawe Street and occupied by extensive commercial office, food and beverage and residential activities ( the VHHL Land ). The VHHL Land is identified by blue shading on the plan attached as Annexure 1. VHHL does not own any land that is subject to the Panuku AC36 Application. 3.2 The VHHL Land forms the southern edge of the Viaduct Harbour between Quay Street and Halsey Street. In addition, VHHL through its Viaduct Harbour Marina manager is responsible for managing the waterspace and 69 marina berths adjacent to the VHHL Land and the berth edge on the southern side of the Eastern Viaduct as shown in red on the attached plan in Annexure VHHL has facilitated and enabled the development of the VHHL Land over the past 20 years in a manner that has ensured high quality residential, commercial and entertainment amenity. Development around the Viaduct Harbour has involved the provision of public access along the waterfront in conjunction with a conservation covenant. As a consequence, members of the public have access to the waterfront along the entire length of the water s edge within the VHHL Land. 3.4 Viaduct Harbour has been the New Zealand home of the America s Cup since first hosting the Cup in 2000, which was the catalyst for development and the transformation of this previously industrialised part of the city. 3.5 This has resulted in the integrated master planned precincts at Viaduct Harbour and more recently Wynyard Quarter. The Viaduct Harbour Waterspace and surrounding land now provides a regionally important level of amenity and a unique degree of accessibility to the waterfront:

5 (a) (b) The Viaduct Harbour is located immediately adjacent to the Auckland Central Business District and provides a convenient and accessible opportunity for members of the public to interact with the waterfront. Much of the harbour edge to the east of Queen Street is occupied by port activities, as is the harbour edge north and west of the Sanford fish market on Jellicoe Street. As a consequence, the extent and quality of public access to the waterfront between Queen Street and Brigham Street, including the Viaduct Harbour, represents a regionally important and scarce resource that VHHL considers should be respected and retained. 3.6 There is an extensive outlook from public and private spaces within and adjacent to the VHHL Land to the north towards the Waitemata Harbour, across the Viaduct Harbour Waterspace, Te Wero, Hobson Wharf and the Western Viaduct Replacement Wharf. While those wharves and viaducts are located between the VHHL Land and the wider harbour, they are relatively narrow structures that are usually free from buildings, enabling unobstructed views of the harbour across and beyond those wharves. Currently, there are views across the Western Viaduct Replacement Wharf and Hobson Wharf from Te Wero and the Eastern Viaduct. In addition, the proximity of the open harbour is also apparent from the promenade areas to the south including Waitemata Plaza. 3.7 VHHL considers that the sense of proximity and connectivity to the Viaduct Harbour and the Waitemata Harbour beyond is a critical aspect of the area s attractiveness. The wharves and viaducts to the north add to its character and attractiveness but they do not form a strong visual or functional barrier between the Viaduct Harbour and the Harbour beyond. 3.8 For that reason, VHHL has been particularly concerned to ensure that works undertaken as part of the AC36 proposal do not, in the long-term, compromise the relationship between the Viaduct Harbour and the wider Waitemata Harbour and in particular do not lead to the Viaduct Harbour losing the sense of openness to the north so that it becomes an enclosed pocket, separated from the Waitemata Harbour by walls and structures. This concern gives rise to VHHL s support for conditions 6, 198A and 198B-D of the proposed conditions of consent and the JWS Design Requirements for the syndicate base buildings and open space.

6 Public access to and through the VHHL Land and the areas subject to the Wynyard Hobson Proposal is highly integrated and the scale of the activities within a relatively constrained area means that it is desirable that the AC36 event occurs in a way that manages construction and the event to take account of activities in and access through and to the VHHL Land. 4. PROPOSED LONG TERM WORKS INFRASTRUCTURE 4.1 The long term or permanent infrastructure works proposed to accommodate the AC36 events include the works east of Brigham Street on Wynyard Precinct and the extension to Hobson Wharf. 4.2 VHHL supports the proposal to hold the AC36 event in Auckland and in particular to accommodate it within and around the Viaduct Harbour and Wynyard Precincts. The Court will be aware that the proposal before it is the second proposal in relation to the AC 36 event for which Panuku sought resource consent. 4.3 The most significant advantage of the current proposal in comparison with the previous proposal is the removal of the extensions to the Halsey Street Extension Wharf and Western Viaduct Replacement Wharf. The current proposal retains, however, the proposal to extend Hobson Wharf to the north by 72m. 4.4 VHHL considers it desirable to avoid or minimise the extent of long-term or permanent wharf structure in this vicinity, to the extent that is practicable. Doing so will minimise the adverse visual and urban design effects that the structure will have when viewed from the Viaduct Harbour Precinct, Te Wero, Princes Wharf, the Harbour and the commercial, residential, public and other buildings in those areas. 4.5 In its submission, VHHL suggested that the northernmost 10m of the proposed 72m extension (which is identified as public open space, for the purposes of pedestrian access) should be deleted from the proposal or provided for by way of temporary structure so that it could be removed following completion of the AC 36 event. Panuku opposes that relief, however and in light of the agreement reached between the parties, VHHL is no longer seeking that outcome. 4.6 While the consents sought in relation to AC 36 and subsequent America s Cup events are for a 10 year duration, the consent in respect of

7 occupational waterspace for the purposes of the Hobson Wharf Extension is for a 35 year duration. Accordingly, the Hobson Wharf Extension would be in place for a further 25 years after the expiry of the consents in relation to the event that justifies its creation. VHHL therefore supports the proposed Legacy Use Options condition 198B-198D so that regard is had to future uses and the hosting of similar events. The side agreement between the parties addresses the timely initiation of a notified change to the Unitary Plan to introduce controls regarding the long term use of the Hobson Wharf Extension (ie: once the 10 year America s Cup consent has expired). 5. PROPOSED 10 YEAR CONSENT PERIOD SYNDICATE BASES Base Design and Design Requirements (conditions 23-25B) 5.1 The Panuku application was accompanied by a series of plans, prepared by Moller Architects, in respect of the seven proposed syndicate bases. VHHL s understanding of the application was that Panuku expected the syndicates to adopt the Moller plans or make relatively minor amendments to them. It appears, however, that the expectation is now that syndicates will: (a) (b) In some cases, and most notably in respect of Base B, design a bespoke facility that may well depart significantly from the Moller design; and In other cases, and particularly with respect to late comers who are having to erect syndicate buildings under time pressure, design a very basic facility (which may even include containers rather than purpose-built structures). 5.2 VHHL accepts that the syndicate bases can be divided into three categories: (a) Base A involves the use of the existing Viaduct Events Centre for the Team New Zealand base. Given that most of the works in relation to construction of this base will be internal to an existing building, VHHL accepts that relatively little control is required with respect to the external appearance of this building.

8 (b) (c) Proposed Bases C G are to be located on Wynyard Point. That is currently an industrial area that has historically been used by bulk storage activities. In that context, this is not a particularly sensitive environment visually and VHHL accepts that there can be a degree of flexibility regarding the construction appearance of these bases. Proposed Base B is located on the Hobson Wharf Extension which, for the reasons set out above, is a particularly prominent and sensitive location. Accordingly, VHHL considers that particular care should be taken with respect to the conditions governing the design, scale and appearance of the Base B building. 5.3 The issue of base design has been discussed at length through mediation and caucusing. VHHL s urban designer, Ian Munro, was party to the urban design caucusing, which produced significantly revised Design Requirements for the base buildings. VHHL accepts the recommendation of its consultant and agrees with the Design Requirements, which provide a significant degree of flexibility for syndicates. Importantly, the Design Requirements impose different expectations with respect to Base A, Bases C G, and Base B respectively. VHHL also agrees with the text of proposed conditions 23 25B relating to the process through which plans for Base buildings will be submitted and certified as complying with the Design Requirements. 5.4 In his evidence, Panuku s urban designer, Graham McIndoe has departed from the Design Requirements agreed in caucusing. He seeks the addition of some narrative passages, changes to certain parameters and flexibility to exceed some of those parameters. In addition, evidence exchanged on behalf of Panuku from Team New Zealand expresses concern regarding the level of flexibility in the Design Requirements. 5.5 Ian Munro will address those matters in his evidence. From VHHL s perspective, I make the following observations: (a) VHHL considers, as noted above, that the Design Requirements already contain significant flexibility for syndicates. There are some specific bulk and location requirements to be met (consistent with the Moller plans referred to in the application as

9 notified) and a number of standards in terms of aspects of design. Beyond that, however, the Design Requirements appear to comprise a series of criteria against which proposals will be assessed. (b) (c) The consequence of a building going outside the terms of the Design Requirements is that a restricted discretionary activity resource consent is required, in accordance with the existing Unitary Plan provisions. My expectation is that, given the existence of the Moller plans and the Design Requirements, a proposal that is generally consistent with those already anticipated by the consent in terms of adverse effects on the environment would not prove difficult to consent. Neither would I expect it to take a long time for such an application to be assessed and granted. It is important, however, that the Council assess the application on its merits and subject to the Resource Management Act, any proposal for a structure in this sensitive environment which by definition differs from those subject to this application. VHHL s concerns are focused on the Base B buildings. On the basis that the Base B facilities will be temporary (albeit potentially in existence for up to 10 years) and that there will be an opportunity through a plan change to put in place appropriate and focused Unitary Plan provisions for the Hobson Wharf Extension, VHHL is prepared to accept the revised Design Requirements attached to Mr McIndoe s evidence subject to one alteration discussed below. VHHL does, however, reserve the right to oppose any further alterations sought by submitters which would further weaken the regulatory framework governing the base buildings. 5.6 VHHL s remaining concern with the revised Design Requirements is as follows: (a) VHHL understands that the proposal is being promoted on the basis that the public will have views into syndicate bases. It supports that approach as it will create visual interest for the public which will help offset any adverse effects generated by the industrial character of the buildings.

10 (b) (c) VHHL is concerned to ensure that the Base B building and yard are as visible as possible from the Viaduct Harbour Precinct to the south. That includes views from the Eastern Viaduct and Te Wero, along with the promenade and buildings further to the south Mr McIndoe has proposed a change to clause 2.4(e) of the Design Requirements whereby signage on yard enclosure fences shall now be limited to 30% maximum solid area of any fence in place of the 10% maximum agreed in caucusing. Changes of a complementary nature have also been made to clause 4.3 regarding public interface yard enclosures. (d) Mr McIndoe has also proposed a new Interpretation clause 3, which provides that variations to the areas and dimensions underlined and in bold font (which includes the 30% requirement in clause 2.4(e)) may be considered, contingent on the effects of these variations not being materially different from the defined requirement. (e) (f) VHHL is concerned by the cumulative effect of the changes to clause 2.4(e) (i.e.: the 30% requirement) and Interpretation clause 3. VHHL is concerned that those changes will collectively enable far more signage on the fence along the southern face of the Hobson Wharf Extension than was initially (or is currently) anticipated, with the consequence that the visual connectivity between the base and the Viaduct Harbour Precinct to the south will be compromised or lost. In the circumstances, VHHL proposes that the Design Requirements as proposed by Mr McIndoe be amended by ensuring that the 30% maximum solid area requirement in clause 2.4(e) not be subject to the flexibility in Interpretation clause 3, at least in so far as it applies to the southern face of the Hobson Wharf Extension. That will provide certainty as to the extent of signage on any fence along the southern face of the Hobson Wharf Extension and should ensure visual connectivity between this particularly prominent base and the viewing audience to the south.

11 EASTERN VIADUCT 6.1 VHHL manages the waterspace and marina berths as previously referred to and shown on annexure 2. This includes 22 berths and the marina infrastructure on the Eastern Viaduct. 6.2 VHHL has the benefit of certain access rights granted under an Access Agreement with Ports of Auckland (now Panuku), dated 16 July 1996 and a deed of variation to that Access Agreement dated 6 May This Access Agreement reflects the need for access and servicing that is required for VHHL s management of the marina and waterspace. The Agreement includes some contractual matters which are to be addressed by the parties separately to this consent process but, as the access and loading zone arrangements are likely affected by the AC36 proposal during construction of the infrastructure and the event, VHHL has sought specific conditions to address this. 6.3 Panuku has accepted that provision of vehicle access and a loading zone to serve the marina and berths on the Eastern Viaduct should be included in conditions 105(f), 183A(ka) and 183G(l) of the proposed conditions of consent. Those changes are included in the annotated schedule of conditions attached to Vaughan Smith s evidence. VHHL considers these conditions are essential because there is no practical alternative to use of the Eastern Viaduct for the servicing of vessels in the marina or the maintenance of the marina structures themselves. These are activities that are necessarily located in the coastal marine area and require access across land and wharf that Panuku proposes to use in conjunction with the event. In my view it is important to ensure ongoing access if the efficient and safe use of the berthage and marina are not to be compromised. 7. CONSTRUCTION EFFECTS 7.1 Panuku is proposing an extensive series of conditions relating to construction management plans. The construction management plans relate to the construction of the key infrastructure (e.g.: the Hobson Wharf Extension) but not to the construction of the syndicate bases themselves. 7.2 These conditions have been the subject of extensive discussion during the mediation process to define the objectives of each management plan

12 and key matters for inclusion. VHHL s consultant planner, Vaughan Smith, will discuss the appropriateness of the construction management plan conditions but in general terms VHHL supports the proposed form of conditions as they relate to the management plans. 7.3 VHHL s traffic engineer, John Parlane, will address the content of the Construction Traffic Management Plan in particular. 7.4 VHHL is pleased with the progress that has been made with respect to both the text of the conditions and the content of the management plans through the mediation and caucusing. I make the following brief comments with respect to those documents: (a) (b) (c) It is essential for VHHL and its tenants that vehicular access be maintained at all times to all properties and to all loading zones. While the AC36 event is important and desirable to hold in Auckland, the Viaduct Harbour and Wynyard Precincts are thriving commercial and residential areas with permanent residents and occupants, many of which have made extensive investments on their properties. Construction activities for temporary events should not compromise those permanent occupiers. As noted above, it is essential, in order to ensure the continued operation of VHHL s marina facilities on the southern side of the Eastern Viaduct, that vehicular access to that area and space for continued servicing of the waterspace and vessels be maintained through the construction process. A matter of particular concern to VHHL with respect to both the construction and event phases is the need for account to be taken by Auckland Council and infrastructure providers (most notably Watercare Services Limited and Auckland Transport) of the AC36 works and activities. From VHHL s perspective the scale and complexity of these works could exacerbate significantly any adverse effects generated by the AC36 proposal if they are not coordinated and sequenced appropriately. By way of example, Mr Parlane s evidence addresses a proposal by Auckland Transport to construct a cycleway through the area in a location that would effectively remove (and not replace) the existing loading bay on the western side of Lower Hobson Street. That would cause

13 significant difficulties not only for VHHL s tenants but also the AC36 event. We appreciate that the Court cannot solve these conflicts but consider that they are relevant to the successful implementation and operation of Panuku s application. This is a process through which Council, Panuku, Auckland Transport and any other Council entities should identify potential conflicts between proposed works and promote their integrated and coordinated management with affected stakeholders such as VHHL. VHHL therefore supports proposed condition 104(f) requiring one of the objectives of the CTMP to be managing the integration of the AC36 project with other construction projects. A similar condition applies during the event phase (condition 181(m)). 7.5 VHHL considers it essential that the conditions be amended to include a requirement for a construction management plan in relation to the Base B facility on the Hobson Wharf Extension. In that regard: (a) (b) The fitting out of Base A in the Viaduct Events Centre building will be a relatively straightforward exercise. In addition, vehicle access to and from Bases C G should be relatively straightforward and those sites are isolated from most sensitive receivers. Accordingly, it may not prove necessary to develop construction management plans for the development of those bases, although VHHL would have no objection to such construction management plans if they were considered appropriate. Base B on the Hobson Wharf Extension is different, however: (i) (ii) Vehicle access to Hobson Wharf Extension is very constrained, both in terms of the narrow driveway onto the wharf and the need for vehicles to traverse the Eastern Viaduct and the very busy Hobson Street /Quay Street intersection, which is an important pedestrian connection as well as significant vehicle intersection. The Hobson Wharf Extension will be in close proximity to a significant number of sensitive receivers (residents and commercial activity), both to the east (Princes Wharf) and to the south (in Viaduct Harbour).

14 (iii) As noted above, it will be important to maintain access to, and servicing of, the waterspace and vessels that berth on the southern side of the Eastern Viaduct. Any construction activities located on the Eastern Viaduct could compromise those activities. (c) VHHL considers that those matters should be addressed in a specific construction management plan relating to the Base B syndicate facilities and proposes a new condition to that effect, which will be detailed by Mr Smith. 8. EVENT EFFECTS 8.1 As adjacent landowners, VHHL and Panuku have a common interest in wanting to ensure the AC36 event is a success for the public, the hospitality tenants and the occupants and visitors to the Viaduct and Wynyard precincts. 8.2 Through the mediation process, an important issue for VHHL has been ensuring continued access and servicing to businesses and residents within the precincts, to minimise disruption. VHHL also considers that a communication strategy should be developed to ensure visitors to the precincts during the event are aware of public transport options, and the access arrangements in place. VHHL sees the inclusion of new condition 183A (kb) (communication strategy) and the requirement to review the arrangements after the AC36 event (condition 12(d)) as important to assist with the smooth-running and future improvement of the event. 8.3 These issues are also reflected in the objectives of a number of event management plans. VHHL considers that those objectives are essential to minimising the inevitable adverse effects of the AC36 event on existing permanent businesses and residents in the area. It strongly supports those aspects of the conditions. 8.4 The one condition relating to the AC36 event that has not been agreed between VHHL and Panuku concerns the imposition of appropriate low frequency controls on High Noise Events pursuant to condition 183Q. This is a concern shared by VHHL and its residential tenants in The Point Apartment Building. VHHL will rely upon the evidence presented on behalf of The Point in this regard. I make the following brief additional comments:

15 (a) (b) (c) (d) (e) The VHHL Land includes a mix of primarily commercial and residential activities. VHHL and its tenants are aware that the level of acoustic amenity in such a mixed use environment will differ from that in quieter, solely residential areas. Clearly, residents who move into this area will need to accept a degree of noise generated by the commercial activities, and in particular bars and restaurants that operate into the evening. VHHL also accepts that the qualities that make the Viaduct Harbour an attractive residential area also contribute to its attractiveness as a venue for events. VHHL has welcomed the many events that have occurred in the Viaduct Harbour over the past 20 years, including the recent Volvo Ocean Race. That includes accepting an appropriate level of supporting commercial and entertainment activities. Entertainment activities mounted in conjunction with events often include some degree of amplified or live music. In many cases that will be amplified background music but on other occasions it will be in the form of live concerts. Concerts have been held both on Te Wero and at Silo Park (on Wynyard Precinct). My observation is that Silo Park is a better venue for larger concerts, not only because it has more space for an audience but also because it currently has less sensitive activities in its immediate vicinity. In addition to ground floor commercial activities, the eastern, southern and south-western side of the Viaduct Harbour currently accommodate multi-storey residential development. In addition, there is residential development on Princes Wharf and a hotel is under construction immediately south of Karanga Plaza. If a High Noise Event occurs on Te Wero Island it will be experienced (loudly) at each of those residential and tourist accommodation venues. Those residents and visitors will not have a choice as to whether they enjoy or endure the music. Far from being background noise or a small-scale concert that people can choose to attend, such an event will dominate the Viaduct Basin for its duration. The conditions are drafted on the basis that there may be three High Noise Events per year in each Precinct. In practice, that

16 would enable six High Noise Events to occur on Te Wero during the six-month AC 36 Event (and another six such events at Silo Park). (f) VHHL is concerned, on behalf of its tenants, that the conditions enabling High Noise Events on Te Wero will produce disproportionate adverse effects on their amenity. VHHL therefore supports the relief sought by The Point with respect to condition 183Q (the wording of which is reflected in the schedule of conditions attached to Vaughan Smith s evidence). 9. CONCLUSION 9.1 VHHL has appreciated the constructive process adopted by Panuku and Council in advance of the Environment Court hearing, which has seen almost all issues of concern to it resolved by way of proposed conditions of consent and through the side agreement. 9.2 VHHL supports the proposed conditions of consent as attached in Mr Smith s evidence. Angela Bull 21 August 2018

17 ANNEXURE 1 VHHL Land Holdings Shown in Blue

18 ANNEXURE 2 VHHL Managed Waterspace and Marina Berths (shown in red)

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