14 May 2026

RG26/0293 – Avalon Station Shooting Range, QLDC not doing its job

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Sam,

Thank you for your email.

I acknowledge Council’s position that the LGOIMA request is being processed separately, and that Monitoring and Enforcement is continuing its investigation.

However, your response does not address the key issue I raised: whether Council has satisfied itself that the shooting range activity is presently lawful and whether ongoing shooting should be permitted to continue while that question remains unresolved..

This is not a request for planning advice. I am not asking Council officers to advise me on how to interpret the District Plan. I am asking Council, as the regulatory authority, to identify its own present compliance position in relation to an activity it is investigating.

That is materially different.

Council has already confirmed that:

1. the operator has engaged a planner to review compliance with the District Plan;

2. an acoustic assessment has been undertaken but not yet processed;

3. the review is expected to take another couple of weeks; and

4. if non-compliance is identified, consent applications may follow.

Those facts raise an obvious regulatory concern. If the operator is still reviewing whether the activity complies, and if consent applications may be required, then Council cannot simply leave affected persons in the position of enduring ongoing shooting, impulse noise, vibration, animal disturbance, and possible public safety effects without stating whether interim compliance action has been considered.

For clarity, I do not seek daily updates. I seek confirmation of the following threshold matters:

1. Has Council considered whether the activity should cease or be suspended pending completion of its investigation?

2. If yes, who considered that question, when, and what was the outcome?

3. If Council decided not to require cessation or suspension, what statutory basis and reasons were relied upon?

4. Does Council currently consider the activity to be authorised, unauthorised, or not yet determined?

5. Has Council considered issuing an abatement notice, excessive noise direction, enforcement notice, or any other interim compliance step?

6. Has Council placed a preservation hold on all records relating to the complaint, site visits, communications with the operator or gun club, acoustic material, planning assessments, internal discussions, conflict checks, and enforcement decisions?

7. Has Council checked whether any officer, contractor, consultant, or elected member involved in this matter has any actual, potential, or perceived association with the shooting range, operator, landowner, gun club, planner, or acoustic consultant?

8. Was any site attendance, inspection, or observation notified in advance to the operator, landowner, gun club, or associated person?

9. Has Council received or sought the raw acoustic data, methodology, instructions, scope, and independence details for the acoustic assessment?

10. Has Council recorded any complaints or information concerning animal disturbance, livestock effects, animals being moved, injured, or put down, or Police involvement?

Your comment that safety concerns should be referred to Police is noted. However, that does not displace Council’s separate statutory responsibilities in relation to noise, land-use compliance, adverse effects, enforcement discretion, record preservation, and fair investigation.

Likewise, the need for natural justice does not mean Council must take no protective action while an investigation is ongoing. Natural justice applies to all affected parties, including complainants and those suffering alleged adverse effects. It requires a fair process, proper evidence, independence, and documented reasons. It does not permit an activity to continue indefinitely without Council addressing present lawfulness.

Please also ensure the LGOIMA team treats this correspondence as part of the request. In particular, I continue to request all records relating to:

– communications with the operator, landowner, gun club, planner, acoustic consultant, or associated persons;

– site visits, inspections, attendance records, photographs, videos, notes, and acoustic readings;

– whether any inspection or site attendance was notified in advance;

– complaints, noise records, animal disturbance records, and Police-related records;

– conflict-of-interest checks or declarations;

– enforcement decisions, including decisions not to take interim action;

– internal Council communications and file notes concerning the activity;

– District Plan assessments, existing-use-rights assessments, consent discussions, and legal advice relied upon for any operative decision.

If Council withholds any information, please identify the specific LGOIMA withholding ground relied upon and provide reasons.

I also repeat the request that Council preserve all relevant records, including emails, text messages, Teams messages, handwritten notes, call notes, meeting notes, calendar entries, metadata, drafts, acoustic data, photographs, videos, inspection records, and internal file notes.

Please provide a written response to the threshold regulatory questions above.

This is not a request for daily updates. It is a request for Council to confirm whether it has considered immediate protective steps, whether it presently regards the activity as lawful, and whether the investigation file has been preserved and conflict-checked.

Kind regards,

Tracy Lynch

On May 14, 2026 at 10:01 AM, <Sam de Reeper> wrote:

Dear Tracy,

Your LGOIMA request is being processed by the appropriate Council department. That department will be in touch with you regarding your request.

As I have set out in my previous email, you have raised a complaint which Monitoring and Enforcement have received and are investigating. I have provided you with the actions to date.

Until we receive the information we need to fully appreciate the situation, I have nothing further to add.

If you have safety concerns, you should call the Police.

Some of the information you are seeking is advice. Council officers do not provide advice and if you need assistance with interpretation of the District Plan, or on other legal matters, then you should seek independent professional planning or legal advice.

In the meantime, Council will continue with its investigation. It is not obliged to provide you with a daily update as this is an investigation, and Council officers need to be independent in their roles and must undertake their duties accordingly, and with care, fairness, and in accordance with the principles of natural justice.

I have no further information for you in any case. I will contact you once it has completed the assessment of the activity.

Regards

Sam

Sam de Reeper

Senior Monitoring, Enforcement & Environmental

Officer | Assurance, Finance and Risk

Queenstown Lakes District Council

DD: +64 3 441 1805 | P: +64 3 441 0499

Email: sam.dereeper@qldc.govt.nz

P Please consider the environment before printing this e-mail

From: F Q <[email protected]>
Sent: Thursday, 14 May 2026 7:20 AM
To: Sam de Reeper <[email protected]>
Cc: QT105 <[email protected]>; Records <[email protected]>
Subject: Re: RG26/0293 – Avalon Station Shooting Range

Dear Sam,

Thank you for your email.

I respond formally, as this matter now appears to raise serious questions of present lawfulness, regulatory oversight, evidential preservation, public nuisance, animal welfare impacts, and potential future proceedings.

For the avoidance of doubt, this correspondence should be treated as both:

a request for urgent compliance action; and

a request that Council preserve and disclose relevant records capable of bearing on any future Court, Tribunal, Ombudsman, or other oversight process.

You have advised that:

the business has engaged a planner to review compliance with the District Plan;

an acoustic assessment has been undertaken, but the report has not yet been processed; and

the review is expected to be completed within the next couple of weeks, with consent applications to follow if non-compliance is identified.

That response is not sufficient to address the immediate issue.

The primary question is not whether the operator may later apply for consent. The primary question is whether the activity is presently authorised, whether it has been operating lawfully to date, and whether Council is permitting ongoing adverse effects while the operator undertakes a retrospective compliance exercise.

1. Seriousness of reported effects

The reported effects are substantial and ongoing.

They include repeated shooting at short intervals, including activity described as cannon-type firing. The effect on nearby people is reported as severe, with persons being repeatedly startled and effectively “shell-shocked” by the noise and vibration.

There are also serious concerns regarding disturbance to animals, including reports that animals have been distressed, adversely affected, and in some cases put down as a consequence of disturbance.

If Council presently holds no record of those effects, that absence is itself relevant. It may indicate that Council’s complaint-handling, monitoring, and compliance systems have not adequately captured the true scale of the effects.

I also understand there has been a report to Police concerning related issues. Council should therefore treat this as a serious compliance, public-safety, and evidential matter, not merely as a planning paperwork issue.

2. Request for immediate suspension / cease-shooting position

My position is that shooting should cease or be suspended unless and until Council is satisfied, on proper evidence, that:

the activity is authorised;

all necessary consents or existing-use rights are established;

noise and acoustic effects are lawfully managed;

public safety and animal welfare impacts have been properly assessed; and

the activity is not causing ongoing unlawful adverse effects.

It is not acceptable for the activity to continue simply because the operator is arranging its own planner review or acoustic material.

Please confirm whether Council has considered requiring the operator to cease or suspend shooting pending completion of Council’s investigation.

If Council declines to take that step, please provide the reasons, the decision-maker, the date of the decision, and the statutory basis relied upon.

3. Independent report required

Given the seriousness of the matter, any assessment must be genuinely independent.

An assessment commissioned, scoped, controlled, or filtered by the operator is not sufficient by itself. Council must not simply accept operator-produced material without independent testing.

Please confirm whether Council will require, commission, or obtain an independent acoustic and planning assessment.

That assessment should address, at minimum:

the actual frequency of firing;

the duration of firing events;

the intensity and impulse characteristics of the sound;

the calibre and type of firearms used;

any cannon-type firing or explosive discharge activity;

cumulative effects over a day, week, and operating period;

vibration and startle effects;

effects on nearby occupiers, land users, and residents;

effects on livestock and other animals;

whether animal disturbance has occurred;

whether animal injury, forced relocation, or euthanasia has occurred;

whether the activity complies with the District Plan;

whether resource consent is required;

whether existing-use rights are claimed; and

whether any such claimed rights are properly evidenced.

Please also confirm who prepared the existing acoustic assessment, who instructed them, who paid for it, when it was undertaken, what data was collected, and whether Council will require the raw data and methodology to be provided.

4. Present lawfulness of the activity

Please confirm Council’s current position on whether the Avalon Station Shooting Range activity is authorised.

In particular, please identify:

the relevant District Plan provisions Council is considering;

any resource consent Council says applies;

any existing-use right Council says may apply;

whether the activity is permitted, controlled, restricted discretionary, discretionary, non-complying, or prohibited;

whether Council has identified any breach;

whether Council has issued, considered, or declined to issue any abatement notice or enforcement step; and

whether Council considers the current activity may lawfully continue while the investigation remains incomplete.

If Council has not yet reached a position on lawfulness, please explain why the activity is being allowed to continue meanwhile.

5. Preservation of evidence

Council is now on notice that records relating to this matter may be relevant to future proceedings or complaints.

Please preserve all records relating to:

the shooting range;

complaints received;

noise concerns;

animal disturbance;

Police involvement;

inspections or site visits;

communications with the operator, landowner, gun club, planner, acoustic consultant, or any associated person;

internal Council discussions;

elected member involvement;

conflict-of-interest checks;

enforcement decisions;

legal advice;

District Plan assessments;

consent discussions;

existing-use-rights discussions; and

any decision not to take enforcement action.

This preservation request includes emails, text messages, handwritten notes, call notes, meeting notes, calendar entries, photographs, videos, acoustic data, file notes, internal messages, Teams messages, draft documents, final documents, and metadata.

Please confirm that a preservation hold has been placed on the relevant Council file.

6. Communications with operator, gun club, and associated persons

I request disclosure under LGOIMA of all communications, contact notes, meeting notes, emails, text messages, phone records, file notes, site-visit notes, or other records held by Council concerning communications between any Council officer, elected member, contractor, consultant, or representative and:

the operator;

the gun club;

the landowner;

any planner;

any acoustic consultant;

any person acting for the operator;

any person acting for the gun club;

any person acting for the landowner; or

any associated business or entity.

This request includes, but is not limited to:

communications about the shooting range activity;

communications about complaints;

communications about noise;

communications about compliance;

communications about consents;

communications about enforcement;

communications about possible enforcement;

prior warnings;

informal advice;

understandings or arrangements given to the operator;

records of site visits or inspections;

any notice given before site attendance;

records explaining whether the operator or club was notified in advance of any Council visit; and

records of conversations or meetings not captured in formal correspondence.

7. Concern regarding site attendance

There is concern that a person attended the site for approximately 30 minutes during which no firearms were discharged, despite the reported pattern of frequent shooting.

Please confirm:

whether that attendance was by a Council officer, contractor, consultant, or person acting for Council;

the date and time of that attendance;

the purpose of that attendance;

whether the operator, gun club, landowner, or any associated person was notified in advance;

who gave any such notice;

when notice was given;

how notice was given;

to whom notice was given;

why notice was given; and

whether any written note, photograph, video, acoustic reading, or inspection record was created.

If no notice was given, please confirm that in writing.

If notice was given, that fact is plainly relevant to the reliability of any observation that no shooting occurred during the attendance period.

8. Conflicts of interest and associations

Please confirm whether any Council officer, elected member, contractor, consultant, or person involved in this matter has any past or present association with:

the gun club;

the shooting range;

the operator;

the landowner;

any associated business;

any planner engaged by the operator;

any acoustic consultant engaged by the operator; or

any person connected with the activity.

This includes:

membership;

personal association;

family association;

business association;

prior involvement with the site;

prior participation in shooting activities at the site;

prior advice given to the operator;

prior consent or compliance involvement; or

any other actual, potential, or perceived conflict of interest.

Please also disclose any conflict checks undertaken and any conflict declarations recorded.

Given the seriousness of the alleged effects, Council must be able to show that the investigation is independent, properly documented, and free from actual or perceived conflict.

9. Records of complaints, Police involvement, and animal disturbance

Please confirm whether Council holds any records concerning:

complaints about the activity;

noise concerns;

animal disturbance;

animals being injured, distressed, moved, or put down;

Police reports or Police involvement;

prior compliance concerns;

previous inspections;

previous enforcement consideration;

communications with the landowner, operator, or gun club; and

previous Council consideration of whether the activity is lawful.

If Council says it holds no such records, please identify what searches were undertaken, by whom, across which systems, and on what date..

10. LGOIMA status

Please confirm the status of the associated LGOIMA request and the expected date for response.

For clarity, this request includes the communications, conflict-of-interest, inspection, acoustic, planning, enforcement, and internal decision-making material referred to above.

If Council intends to withhold any information, please identify the statutory withholding ground relied upon and explain the basis for its application.

11. Written decision required

Please provide a substantive written response confirming:

Council’s present position on the lawfulness of the activity;

whether shooting will be required to cease or be suspended pending investigation;

whether Council will obtain an independent assessment;

whether Council will preserve all relevant evidence;

whether Council has identified any conflict or association issue;

whether any site visit was notified in advance; and

what enforcement or interim protective steps are under consideration.

This is an urgent matter. It concerns ongoing effects, present lawfulness, possible non-compliance, public safety, animal welfare, and the integrity of Council’s investigation.

Please provide a substantive response within 5 working days.

Kind regards,

Tracy Lynch

On May 13, 2026 at 11:31 AM, <Sam de Reeper> wrote:

Good morning Tracy,

Petra has taken some leave, and I have resumed this investigation in her absence.

The business has engaged with a planner to review the activities compliance with the district plan.

An acoustic assessment has been undertaken but the report has not yet been processed.

It is expected that the review will be completed within the next couple of weeks and if non-compliance is identified the applicable consents will be applied for.

Kind regards,

Sam

Sam de Reeper

Senior Monitoring, Enforcement & Environmental

Officer | Assurance, Finance and Risk

Queenstown Lakes District Council

DD: +64 3 441 1805 | P: +64 3 441 0499

Email: sam.dereeper@qldc.govt.nz

P Please consider the environment before printing this e-mail

From: F Q <[email protected]>
Sent: Wednesday, 15 April 2026 12:27 PM
To: Petra Larsen <[email protected]>
Cc: QT105 <[email protected]>
Subject: Re: RG26/0293 – Avalon Station Shooting Range

Subject: RE: RG26/0293 – Avalon Station Shooting Range

Dear Petra,

Thank you for your email.

In response to your queries:

I am the point of contact in relation to the concerns raised and the associated information requests; and

I act under instruction in relation to the subject matter of those concerns.

For clarity, the matters raised relate to observed activity, noise, and potential compliance issues at the Avalon Station Shooting Range. These are objective matters capable of investigation independently of the identity of any individual.

Accordingly, the focus remains on:

The nature and extent of the activity occurring; and

Whether that activity is operating within the relevant regulatory and consent framework.

The identity of any underlying party is not relevant to Council’s ability to investigate or determine compliance.

Please proceed with the investigation on that basis.

I look forward to your update.

Kind regards,

Tracy Lynch

On Apr 15, 2026 at 11:59 AM, <Petra Larsen> wrote:

Hi Tracy,

Following up regarding your concerns raised on the Avalon Station Gun Range.

Recent discussions have been had with the property owners of 1142 Cardrona Valley Road. In light of this, I would appreciate your clarification on the following matters.

Whether you are acting on behalf of the property owners, Mark and Caroline Mackay; and

If so, the capacity in which you represent them.

If you are acting in a legal representative capacity, please can you confirm the legal firm that you work under?

If you can please provide feedback on the above, this would be much appreciated.

Kind regards,

Petra

Petra Larsen BSc

Monitoring, Enforcement and Environmental Officer | Assurance, Finance and Risk

Queenstown Lakes District Council

DD: +64 3 450 9112 | P: +64 3 441 0499

Email: petra.larsen@qldc.govt.nz

P Please consider the environment before printing this e-mail

From: Petra Larsen
Sent: Tuesday, 7 April 2026 11:27 AM
To: [email protected]
Subject: RE: RG26/0293 – Avalon Station Shooting Range

Hi Tracy,

Just following up regarding your concerns raised at 1081 Cardrona Valley Road.

The LGOIMA request is currently being worked through at this time and a further investigation into your concerns is being undertaken.

I wanted to advise you that your concerns are being investigated and we will be in touch with further information in due course.

Cheers,

Petra

Petra Larsen BSc

Monitoring, Enforcement and Environmental Officer | Assurance, Finance and Risk

Queenstown Lakes District Council

DD: +64 3 450 9112 | P: +64 3 441 0499

Email: petra.larsen@qldc.govt.nz

P Please consider the environment before printing this e-mail

From: Petra Larsen
Sent: Tuesday, 10 March 2026 8:15 AM
To: [email protected]
Subject: RG26/0293 – Avalon Station Shooting Range

Hi Tracy,

QLDC’s Monitoring, Enforcement & Environmental Team have received your request (RG26/0293) relating to noise concerns at the Avalon Station Shooting Range.

The matter raised will be investigated and you will be updated with more information in due course. If you are contacting the Council again in relation to this matter, please quote the reference number mentioned above.

Kind regards,

Petra Larsen