Kirkdale Investments Limited Kimbrae Farms Limited · specialising in urban design and urban planning. 2. I have experience in preparing urban design assessments for development proposals,

Rototuna Structure Plan, Plan Change 12 – 4/11/2011 1 Urban Design Evidence of Nicholas James Rae

In the matter of the Resource Management Act

And in the matter of submissions and further submissions pursuant to clauses 6 and 8,

Schedule 1 of the Act

Between

Kirkdale Investments Limited

And

Kimbrae Farms Limited

Submitters

And

Hamilton City Council Respondent

STATEMENT OF URBAN DESIGN EVIDENCE OF NICHOLAS JAMES RAE

__________________________________________________________________

4th November 2011


INTRODUCTION

1. My name is Nicholas Rae. I am a qualified urban designer and landscape

architect. I hold a Master of Urban Design from the University of Sydney and

a Bachelor of Landscape Architecture (Honours) degree from Lincoln

University. I have approximately 14 years experience in this field in New

Zealand, the United Kingdom, France, Portugal, Saudi Arabia, and Australia. I

am the Director of Transurban Limited, a consultancy based in Auckland

specialising in urban design and urban planning.

2. I have experience in preparing urban design assessments for development

proposals, particularly of a commercial / mixed-use nature and in assisting plan

change processes. I am familiar with the area that is the subject of this Plan

Change and I am familiar with the relevant planning controls that are proposed.

3. My experience includes providing urban design advice with regard to a number

of plan changes including:

• Kumeu Town Centre (PC162)

• Newmarket Mixed Use Zone (PC196);

• Orewa High Intensity Residential Zone – multi-level development

(Variation 101);

• Takanini Area 1A confirmed as a mixed use zone (PC12);

• Waitakere City Council - city wide urban design provisions (PC18);

• Massey North Town Centre (PC15);

• Takanini Area 6a and 6b (PC15);

• Hingaia Area 1b (yet to be notified);

• Karaka North - Growth Node Village (PC14);

• Pokeno Village

• Mangere Gateway - North Airport (PC14);

• Southern Gateway – East of Airport (yet to be notified);


• Frankton Flats – Queenstown (PC19);

• Omaha Park Village, Omaha.

4. In addition, I have prepared urban design assessments for the following

resource consent applications:

• A mixed use commercial building development on the corner of Halsey

Street and Victoria Street West, Auckland;

• A mixed use commercial building development on the corner of Beach

Road and Mahuhu Crescent, Auckland;

• A mixed use residential, medical and retail building for the City Mission

between Hobson Street and Federal Street, Auckland;

• An upgrade to the existing historic Lopdell House plus a modern

extension, Titirangi;

• A large scale mixed use development proposed for the new town centre

at Massey North, West Auckland;

• Retail development adjacent to Clevedon Road, Papakura.

• A two level retail development in Wynen Street, Blenheim;

• Development options for Rotorua Central, Rotorua;

• Mixed use commercial / community / and residential development in

Takanini Area 1A;

• A number of new and renovation projects for supermarkets.

5. I have been engaged by Kirkdale Investments Limited to provide urban design

advice and evidence with regard to specific submissions made by Kirkdale

Investment Limited (“Kirkdale”) and Kimbrae Farms Limited, (together I refer

to them as the “submitter”) to Plan Change 12 – Rototuna Structure Plan.

6. While I appreciate that this is not an Environment Court hearing, I confirm that I

have read the Code of Conduct for expert witnesses contained in the

Environment Court Practice Note (2011) and that I agree to comply with it. I


confirm that I have considered all the material facts that I am aware of that

might alter or detract from the opinions I express. In particular, unless I state

otherwise, this evidence is within my expertise and I have not omitted to

consider material facts known to me that might alter or detract from the

opinions I express.

7. When I talk about urban design I refer to the arrangement, appearance and

functionality of buildings, and the shaping and uses of urban public space and

the activities and elements that contribute to public space.

8. Throughout my evidence I refer to CDP Areas. These can be found in

“Appendix 1C-2 CDP Areas Maps, Suburban Centre” at the end of the

Rototuna Urban Design Guide contained within the provisions for Plan Change

12.

SCOPE OF EVIDENCE

9. The scope of my evidence is limited to urban design issues relating to the

following submissions:

• 21.12

• 21.35

• 21.36

• 21.38

• 21.39

• 21.40

• 21.42

10. My evidence is arranged under the following section headings;

1.0 Road access and services to Secondary School, and sports field configuration

2.0 Retail and Staging of Retail

3.0 Activity status, bulk and location, controls and performance standards

4.0 Conclusion


1.0 ROAD ACCESS AND SERVICES TO SECONDARY SCHOOL, AND SPORTS FIELD CONFIGURATION

1.1 I refer to paragraphs 2.1 to 2.8 of Mr Bhana’s evidence which sets out and

explains the submissions and further submissions, to avoid repeating this in my

evidence.

1.2 Briefly, this issue is about how to achieve the design and installation of an

access road and services to the proposed secondary school designation site,

where there is a contractual arrangement between the Ministry of Education

(“MoE”) and Kirkdale which requires Kirkdale to implement this road within 18

months of the issue of a notice from MoE.

1.3 The question from my perspective is whether it is appropriate to design and

install this road before a CDP has been granted resource consent which

includes this road.

1.4 Mr Borsboom discusses in his evidence the options for road connections to

meet this contractual obligation, and why the preference is for that road to be

between the CDP areas ‘O’ and ‘P’ connecting the school to North City Road.

1.5 The location of this road is illustrated in figure 1 and I refer to this as the

“subject road”. Note the MoE school site is labelled ‘Future School Site’.

Figure 1 – Location of preferred road connection to MoE school site


1.6 In this case, I consider where possible, the best outcome will be achieved if

roads are a requirement of the CDP process as their location and design is yet

to be confirmed. I include a passage from the hearing report which supports

my understanding as follows:

3.15.66 Submission (21.29) relates to Rule 4.12.1.2 (CDP process). Kirkdale are proposing the inclusion of a new rule requiring the CDP to incorporate final locations and form of roads, other infrastructure, precinct and CDP boundaries which are presently shown in a diagrammatic form on MS.MAP-35A.

3.15.67 The Concept Plan is indicative only and is not a Masterplan, which implies that the detail design work has yet to be undertaken. The variation is premised on the final locations of roads, other infrastructure, precinct and CDP boundaries being determined through the CDP process via resource consent. Accordingly, it will be via the resource consent assessments and consenting of proposals that the ultimate layout is determined (albeit, guided by the Concept Plan MS.MAP-35A). The tracking of the final form will be via resource consent assessments.1

1.7 Roads are important elements of an urban environment because the location

and design of roads play an important part of the urban structure, and roads

can influence the outcome on adjacent land - just as the desired outcome for

adjacent land should influence how the road is developed.

1.8 I have been involved with design options with Mr Borsboom and Brigit Diprose

of Chow Hill to establish a direction for the design of the water course that is

proposed alongside the subject road. This design consideration included

options for the sports fields and CDP Area Q as an integrated solution.

1.9 This process was similar to the initial phases of the preparation of a CDP for

Area P. The design principles were based on the concept of providing a high

amenity outcome as a main landscape structuring element with a range of

experiences for people as they move along the water course; including a

wetland water treatment area, a lake, weirs which control flood events and

enable people to interpret those events, a stream with various treatments

relating to where in the area the stream exists (such as a more natural

configuration to the north and more urban to the south through the town

centre). The concept is illustrated in Appendix A.

1.10 Figure 2 illustrates land owned by Hamilton City Council in relation to the

subject road in the structure plan. This illustrates that land exists for the

1 Hearing report page 173


concept for the water course in Appendix A to be designed and achieved given

those constraints. This land is owned by the submitter.

Figure 2 – Hamilton City Council land ownership illustrated in Blue hatch.

1.11 If the road between CDP Areas ‘O’ and ‘P’ is constructed on the alignment

illustrated in the Concept Plan 1B (and in Figure 1 and 2 above) without being

part of a CDP, development either side of the road could still result in a positive

urban outcome when the design of each side of the road is undertaken and

implemented.

1.12 This would result in development either side being bound by the road location.

I do not consider this would have a significant adverse effect on the ability to

achieve the desired outcomes for the CDP areas. The sports fields and water

course would need to be designed with the road as a fixed boundary, likewise

this would apply to CDP Area ‘O’ and the residential intended there.

1.13 To confirm whether Area ‘O’ can achieve the required 223 residential units2

with the road in the proposed location, I have undertaken a basic preliminary

2 Plan Change 12 - Appendix 4.12-IV Yield Table


assessment. I have used the area from Appendix 4.12-ll – Comprehensive

Development Plan Areas of 5.2709ha. after being advised by Mr Borsboom

that the figures in Areas ‘O’ and ‘P’ should be swapped.

1.14 223 units on 5.2709ha of land would result in 42.3 dwellings per hectare gross.

The most likely form of development to achieve this is an apartment typology,

or a mix of apartments and terrace housing given the current maximum site

coverage of 50%3 and the maximum building height of 12.5m for Area ‘O’4.

This confirms to me that this residential outcome is possible with the subject

road in the location between Areas ‘O’ and ‘P’. If Area ‘O’ needs to be

adjusted, the CDP boundaries to the north and west could accommodate any

change.

1.15 If it is considered that the subject road could precede a CDP, the actual design

and implementation of that road needs to be considered to ensure resources

are utilised wisely. By this I mean it might be suitable to install the carriage

way and a basic footpath to achieve the connection, however each side of the

road could be designed through the CDP process to enable the design of

intersections with side roads, locations of footpaths, street trees and other

elements. This would avoid the installation of parts of the road that interface

with the CDP areas avoiding unnecessary cost and use of resources and

achieve an integrated outcome.

1.16 I understand that upon receipt of the notice from the MoE, Kirkdale have 18

months to provide the road and services.

1.17 Significant design work is required to develop a CDP for the adjacent high

density residential area, the sports fields and water course in order to deliver

the road through the CDP process. I assume the boundary of the CDP areas

could be adjusted so that the subject road is in one or other of the CDP Areas

allowing it to be designed within Area ‘O’ or ‘P’. The boundary is currently

centre to the subject road. If the CDP process is forced to obtain consent for

the road, then I have a concern that the outcome might not be as good as it

could be.

1.18 The design of the subject road could be undertaken through either a CDP

process, or prior to a CDP process depending on when the MoE require the

3 Design Guide 3.2.4 – Development Intensity - Residential High Density


road, and when CDP’s are granted consent. I understand that it is likely that

the road will need to precede the CDP process and I consider an application

for the road and services could be made without an approved CDP in this case

where specific provisions and criteria apply.

1.19 I have provided the specific assessment criteria which have been included in

Mr Bhana’s evidence on this matter5.

1.20 Other roads especially in the commercial centre should have flexibility in their

location allowing the design response in a CDP process to consider the

development holistically. I note that the Concept Plan clearly indicates that the

format proposed is diagrammatic only and I anticipate that there will be

significant changes as CDP’s are developed.

1.21 This is recognised in the s42A report quoted above. I do not consider that any

other road is subject to implementation requirements that would require

specific provisions.

2.0 RETAIL AND STAGING OF RETAIL

2.1 This section addresses three submissions made by the submitter, namely:

a) The deletion of the requirement to stage retail development in CDP

areas A, B, C, D and E under the provision of Appendix 4.12-III Staging

Table (submission number 21.38).

b) The restriction on maximum GFA per tenancy in Retail 2 Precinct to be

increased from 3,500m2 to 4,000m2 (submission number 21.35); and

c) The zoning of land at the corner of North City Road and Borman Road

as Retail 2 Precinct (submission number 21.40)

4 Design Guide 3.2.1 – Building Height - Residential High Density 5 Mr Bhana Evidence in Chief paragraph 2.15


The deletion of the requirement to stage retail development in CDP areas A, B, C, D and E

2.2 Mr Bhana has provided detailed evidence on the inconsistencies in the

proposed provisions with regard to the staging provisions. I rely on this

evidence and do not consider it beneficial to repeat it.

2.3 Whilst there are inconsistencies, I consider that the staging provisions as

recommended in the hearing report6 would restrict development in CDP areas

B,C,D and E until 80% of all development proposed in CDP Area A (not just

Retail 1) is built and occupied.

2.4 This strategy is flawed because Area A will need to rely on surrounding

activities including other businesses, services and residential. Delaying the

development of these areas will not benefit the establishment of the vibrant

mixed use centre intended.

2.5 There is a risk that a scatter gun approach to development could occur if the

staging rule were to be removed, whereby buildings are developed sporadically

through the area potentially without a focus on development in Area A in order

to establish the main street and town centre. This could be dealt with through

the CDP process which could consider whether any proposal would have a

detrimental effect on creating the development either side of the main street as

a priority.

2.6 The retail centre is proposed to provide for the local population, plus a

population that will travel from further afield to utilise the aquatic centre, library

and sports fields, and supporting retail.

2.7 The staging provisions restricts the ability for residential and business to

develop in close proximity to Area A in Area B, or in the employment precincts

of Areas C, D and E until the trigger is met. This does not provide for a range

of activities in the initial stages of development and is unnecessarily

constrained in my opinion. I note that retail activities (either as part of a CDP

or following a CDP) have a non complying status for Precincts C, D and E, and

any ancillary retail is Discretionary in a CDP and permitted following.

6 Proposed Variation 12 tracked changed 14 October 2011 – Appendix 4.12-III Staging Table


2.8 The Speer and Speer report dated 10 August 2011 refers in a number of

locations to the staging of retail, not to the entire development of Area A.

2.9 I agree that retail developing in CDP areas other than Area A could be

detrimental to achieving the built form outcome of the main street especially as

the demand for retail might be low initially. I consider the issue relates to the

primacy of developing the main street in Area A with sufficient retail, cafes

restaurants and other services to support the community facilities and create a

centre with high amenity and identifiable as the focal point of the community.

2.10 Retail anchors such as a supermarket could establish in the initial phase to

attract more people to the area in a way that supports the main street and town

square outcome, which might be necessary depending on when the Library

and Aquatic Centre is developed. I consider that development adjacent to the

main street should progress either side of the town square along North City

Road as a priority to achieve the amenity and vibrancy anticipated. This can

be added to as demand allows.

2.11 The recommended provisions7 would prevent a larger format anchor type

tenancy from establishing in the initial stage as this is provided for in Retail 2

Precinct which exists in CDP Area B, constrained by the staging rule.

2.12 I consider a larger tenancy that could assist with the viability of the smaller

retail could exist in either Retail 1 or Retail 2, with the appropriate design

response to achieve the anticipated outcome for each area. This is based on

my recent experience with developing a retail component to the mixed use

zone in Takanini (south Auckland) where advice provided to me from Match

Reality is such that a larger anchor is highly beneficial to the viability of smaller

retail.

2.13 A larger format anchor could be a supermarket or department type store. Mr

Bhana has included an example of Albany Town Centre including a

supermarket. A recent plan change for Beachlands (east Auckland) includes a

concept whereby a supermarket is sleeved by other retail that front on to the

streets. This is illustrated in Figure 3.

7 Proposed Variation 12 tracked changed 14 October 2011


Figure 3 – Proposed concept plan included in Plan Change 30A to the Manukau City

District Plan for Beachlands Village Business Centre

An older built example is within the Valley Road shops on Dominion Road in Auckland

Central. I am not saying this example is the best outcome, rather provide to illustrate the

potential relationships and how this is situated behind a main street. This is illustrated in

Figure 4.


Figure 4 – Dominion Road / Valley Road Shops illustrating supermarket behind main street

retail. Source: Auckland Council GIS web portal.

To understand the size of the centre in Figure 4 in relation to Rototuna, I have scaled the

image in Figure 4 to be approximately the scale as the MS.Map-41 version1 which has a

scale bar on it. The length of components in the image were measured in Google Earth to

determine the scale. This is illustrated in Figure 5. Figure 6 is another example using Grey

Street Hamilton East, which I note does not include a supermarket in this image.


Figure 5 – Dominion Road / Valley Road Auckland shops scaled to approximately fit Rototuna CDP areas map.

Figure 6 – Grey Street Hamilton main street scaled to approximately fit Rototuna CDP areas map


2.14 The CDP process should determine the best location for a supermarket or

other larger format retail, rather than restricting this to Retail 2.

2.15 The proposed Plan Change for the Kumeu Town centre (west Auckland) has a

recommendation from the reporting planner that a staged approach should also

be applied, however in this case the concern was not whether the main street

would develop, rather related to traffic generation and effects on the road

network. In this case it is likely that a supermarket will develop first as access

to the area is required to be created on a state highway which can be achieved

through a new supermarket. This would most likely stimulate other

development to occur.

The restriction on maximum GFA per tenancy in Retail 2 Precinct to be increased from 3,500m2 to 4,000m2

2.16 The submitter (21.35) requests that the maximum GFA of any individual retail

tenancy in Retail 2 Precinct is increased to 4,000m2.

2.17 I have experience with the development of supermarkets in New Zealand

through work I have undertaken on behalf of Foodstuffs (Auckland) Limited and

their property company The National Trading Company of New Zealand. This

experience includes urban design advice for specific supermarket proposals

and with regard to various plan changes both initiated by Foodstuffs or by

others.

2.18 There is no fixed size for a supermarket. The catchment and site constraints

play a role in determining the size. However, as a general rule of thumb a

smaller supermarket such as those developed by Foodstuffs (New World) are

in the order of 3,500m2.

2.19 To illustrate this point the following is a list of supermarkets that either exist or

have consent as per Transurban project files unless stated:

• Thomas Road – 3,600m2 (Figure provided by Mr Bhana)

• Te Rapa – 4,400m2 (Figure provided by Mr Bhana)

• Birkenhead – 3,414m2 (proposed to be increased from 2,413m2)


• Lunn Avenue – 3,565m2

• New Lynn – 3,570m2

• Warkworth – 3,837m2 (proposed to be increased from 3,535m2)

2.20 Currently the rule limiting GFA to 3,500m2 is such that a non-complying consent

would be required for all except one of these examples.

2.21 I consider the issue on size of a tenancy is how any proposal for a larger

building such as a supermarket is designed such that it integrates and

contributes positively to the urban fabric and amenity of the town centre.

2.22 Other recent plan changes have also included GFA limitations for

Supermarkets specifically (rather than any store as proposed in PC12) such

as:

a) Kumeu Town Centre (west Auckland) where a 4,000m2 GFA cap for a

supermarket is proposed8 (This is awaiting a decision from a Council

Hearing), and;

b) Beachlands Village Business Centre Zone (East Auckland) which also

provides for one supermarket of up to 4,000m2 GFA (excluding loading

areas)9. There are appeals outstanding on the decision for this plan

change. I am not aware of what matters these relate.

2.23 There is no urban design reason for limiting a single tenancy to 3,500m2 given

this is aimed at providing for a supermarket. The CDP process should

determine whether it is in the appropriate location and is designed

appropriately to achieve the outcomes intended in the various areas.

2.24 A limit on GFA is useful in such that it provides guidance as to what size of

tenancy is considered appropriate in an area, and I agree with the reporting

planner that large format retail (“LFR”) should be avoided from this centre10.

This is due to the size of land typically required to accommodate these, and the

much larger building grain typically associated with LFR typology which is

contrary to the fine grain pedestrian oriented local centre anticipated.

8 Rule 12.8.34.4.1 in Proposed Plan Change 162 to the Auckland Council District Plan (Rodney Section) 2011 (refer Appendix B) 9 Policy 17.17.4.2 in Proposed Plan Change 30A to the Manukau Operative District Plan 2002 (Refer Appendix C) 10 Hearing Report paragraph 3.15.82 page 177


2.25 If the commissioners do not accept the submission to increase the GFA cap to

4,000m2, an alternative solution would be enabled if submission 21.30 was

accepted to retain the status of any application as Discretionary if it includes a

non-compliance with a performance standard. Mr Bhana has recommended in

his evidence11 that any non-compliance with a performance standard (4.12.1.5)

should not result in the status of an application being Non-complying and

supports a Discretionary status. Under this scenario, any proposal for a

tenancy over the 3,500m2 GFA cap (which is a standard - 4.12.1.5.10 and

4.12.2.2.7) would be able to be assessed against the objectives and policies,

assessment criteria and the guidelines.

The zoning of land at the corner of North City Road and Borman Road as Retail 2 Precinct

2.26 The Submission 21.40 requests to change the proposed precinct for the corner

of North City Road and Borman Road from Community facilities and

Residential Mixed Use to Retail 2. In essence, I understand the submission to

provide more opportunities for activities on that corner site by the range of

activities promoted in the Retail 2 Precinct.

2.27 This change would enable facilities such as a supermarket or other tenancies

that requires a higher floor area than provided for in the community or

Residential Mixed Use Precinct, and would benefit from the location and

benefit the main street.

2.28 As I have stated previously, I consider a larger format retail tenancy could

locate in CDP Area A which includes the area the subject of this submission.

The Retail 2 Precinct provides for all of the activities in the Community

Facilities Precinct with the same activity status plus: Retail Activities;

Apartments; Service Industry and Yard Based Retailing12 when they are

subject to a CDP. There are some other differences once a CDP is “fully

implemented”.

11 Mr Bhana Evidence in Chief – Paragraph 8.8 12 Plan Change 12 proposed provisions – Table 4.12.1


2.29 I consider the Service Industry to be appropriate in the subject area as it is to

the periphery of the main street and provides for activities that support (and

can be associated with) retail. The definition of “service industry” in the Plan is:

“Service Industry – Means premises occupied by activities involving light manufacturing or the repair or servicing of goods of a light nature and includes repair of household appliances, electronic equipment assembly and servicing, craft manufacture and clothes manufacture but does not include car repairs, furniture and the like”13.

2.30 There is no definition for “Yard Based Retail” however rule 4.12.1.5.10 e)

provides a maximum site area of 150m2. This is a small site area and activities

such as a small garden centre could utilise these provisions adding to the

vibrancy, diversity and choice of retail offerings in the centre. These outcomes

support good urban design in a town centre.

2.31 An example of this is a small garden centre on the corner of Ponsonby Road

and O’Neil Street in Auckland. It is on a site of approximately 420m2 however

part of the site is used for access and for part of a neighbouring retail. An aerial

illustrating this is included at Figure 7, and a photograph at Figure 8.

Figure 7 – Plan of site illustrating garden centre on Ponsonby Road and O’Neil Street in Auckland. Source: Auckland Council GIS web portal

13 Hamilton City Council Proposed District Plan 2001 Operative in Part 8 August 2011 – Definitions section


Figure 8 – photograph of the site from Ponsonby Road

2.32 Whilst this is an old example and the design of this facility is not of a high

standard, it illustrates that even on Ponsonby Road, facilities requiring yards

adds to the mix and are appropriate to the periphery of the main retail area.

2.33 This outcome on the land subject to this submission would be appropriate

given it is well designed. This can be managed through a CDP process.

2.34 The requested change to Retail 2 Precinct does not change the requirements

of secondary street frontages from applying to North City Road and Borman

Road and part of a new local road as illustrated on Appendix 1C-3 in the rear of

the design guidelines. This maintains a requirement that no parking or

servicing areas are within the secondary frontages, tenancies shall have the

main customer entry facing the street and a minimum of 50% of the ground

floor wall facing the street or public space to be clear glass and be capable of

being used for the display of goods and services to passing pedestrians14.

2.35 Other assessment criteria such as at 3.5 relating to Retail 215, seeks to avoid

adverse effects of large scale buildings on the street environment. I consider

that an appropriate outcome could be achieved with the additional activities

provided for by the Retail 2 Precinct for this subject land.

14 Proposed Variation 12 tracked changed 14 October 2011 – 3.2.6 Secondary frontages 15 Proposed Variation 12 tracked changed 14 October 2011 – 3.5


2.36 I do not consider that a supermarket or similar larger retail tenancy will develop

in the southern part of Retail 2 Precinct as promoted by the Concept Plan

especially if the visibility to it was limited from Borman Road and located away

from the passing traffic that will utilise North City Road.

2.37 The reporting planner has concerns that zoning the subject land to Retail 2

Precinct would result in too much land zoned as Retail 2 Precinct. Whilst I am

not an expert on the quantum of land required, if it is found that this concern is

valid, a reduction of the Retail 2 Precinct in the south of CDP Area B could

provide this balance.

3.0 Activity status, bulk and location, controls and performance standards

3.1 This section refers to submissions regarding the following:

a) CDP process

b) Yields

c) Section 3.2 of the design guide

CDP process

3.2 The submitter (21.36) sought modification of Appendix 4.12-l and 4.1 C-l which

set out the information requirements the Comprehensive Development Plan

applications. In particular the submission requested that the information should

reflect the possibility that CDP application could be developed in stages as

provided by Rule 4.12.1.2 (b).

3.3 It is highly likely that the actual construction of the CDP areas will be staged

and this is reflected in the provisions at Rule 4.12.1.2b).

3.4 The submitter seeks to be able to provide a CDP with full detail for stage 1 and

less detail for other stages. This is on the basis that the exact design might

change over time and between stages. There is potentially significant cost and

time involved in detailing the full CDP area. For example Area ‘O’ is required


to achieve 223 residential dwellings16 which can be a significant amount of

detail design.

3.5 The main reasons for undertaking a CDP process are to ensure that the area is

considered and designed holistically. The key to this from an urban design

perspective is circulation network, services, reserves and open space, block

structure and a framework for buildings, such as a building envelope. It is also

important in this case that the CDP can demonstrate how the yield can be

achieved.

3.6 This approach would require subsequent stages to obtain consent and comply

or otherwise change the framework that is granted consent in stage 1. I

consider this approach will achieve the same outcome anticipated by the

provisions as currently drafted but staged over time. I note that a CDP can be

adjusted by a further application resulting in potentially the same outcome.

3.7 It might be that some precincts will require more detail than others depending

on the complexity for each.

Yields

3.8 The submitter (21.39) requests that the yield table in Appendix 4.12-IV is

amended to provide greater flexibility for distributing residential yield in the

zone.

3.9 The provision stated above allows for a variance of plus or minus 10% to the

required yield in each CDP area.

3.10 I have estimated that the Residential High Density Precinct is required to

deliver around 40 dwellings per hectare gross, and I refer to my paragraph 1.13

above where I provide that assessment. This precinct is located adjacent to

the open space reserve where higher densities are appropriate and a well

known urban design principle.

3.11 Using the figure of 48,073m2 for CDP Area B17, and the requirement of up to

27.5 residential units in the yield table18, this would result in a maximum density

of 5.72 dwellings per hectare gross.

16 Appendix 4.12-IV yield Table 17 Proposed Variation 12 (notified version) Appendix 4.12-II Comprehensive Development Plan Areas


3.12 Area G has an area of 51,438m2 and a requirement of up to 125.4 residential

units, resulting in a maximum of 24.3 dwellings per hectare gross.

3.13 Area A has no requirement, so I assume that any number of residential units

could be developed or none.

3.14 The Medium Density Residential Precincts work out at approximately 25

dwellings per hectare gross.

3.15 I am surprised to find that the residential density provided for in areas close to

the centre (which I consider is located in Area A as opposed to the location of

the orange dot on the structure plan Appendix 1A to the provisions) are lower

than the Residential High Density areas, some of which are at a much greater

distance from the centre. The principle for Residential High Density at 3.9.2

states:

“Locating higher density housing within a 5 minute walk of the Rototuna Suburban Centre helps to increase the probability of people using public transport. It also increases the likelihood of people walking to the main street as opposed to taking the car”

3.16 If this is taken as a principle for residential in Rototuna supported by good

practice urban design, Areas B and G should have the ability to deliver similar

densities as the Residential High Density Precinct. This is also supported by

the proposed maximum heights for these two areas being equal to, or higher

than the Residential High Density precinct.

3.17 The policies 17.10.4.2 and 17.10.4.3 of the Flat Bush zone in Manukau City,

Auckland19, seek to establish targets for overall densities with greater densities

closer to the town centre, neighbourhood centres, around the edge of Barry

Curtis Park and major transport routes.

3.18 In a mixed use zone or commercial area such as the main street in this case,

residential density targets may not be as high as zones promoting residential

high density due to the need for flexibility to provide for other activities. This is

supported by the proposed density target for local centres in Flat Bush where a

target is lower than for other higher density residential areas. The issue I have

with the proposed provisions is that there is no flexibility if a higher density is

18 Proposed Variation 12 tracked changed 14 October 2011 – Appendix 4.12-IV Yield Table 19 Plan Change 20 to Manukau District Plan 2002,


desired, or indeed in the mixed use areas, lower densities are desired due to

the requirement to provide for other activities.

3.19 The 40 dwellings per hectare proposed for the Residential High Density areas

alongside the proposed reserve is consistent with the strategy for Flat Bush

where development adjacent to a large open space reserve (Barry Curtis Park)

and in close proximity to the proposed town centre is required to achieve a

target of 40 dwellings per hectare on sites larger than 1,000m2. This has

recently been proposed as a higher density through Plan Change 2020 to the 25

dwellings per hectare that previously existed.

3.20 The general Residential 1 and 3 zones in Flat Bush which are located in similar

relationships to the Residential Medium Density precinct have a required

minimum density of 16.5 dwellings per hectare as stated in the description for

Flat Bush21, however there appears to be inconsistencies with the standards as

the average lot size for the Residential 1 and 3 zones results in approximately

23 dwellings per hectare22.

3.21 There appears to be flexibility in where and how the density for the area is

achieved in Flat Bush, and I consider that flexibility for Rototuna is also

provided, even if just to cater for adjustments to Precinct boundaries, and allow

the potential for higher densities around the town centre.

3.22 This might be achieved by changing the yield table from a specific requirement

to a target, or perhaps providing an overall density target for Rototuna to

enable more flexibility where the density is to be located when undertaking the

CDP process. The provisions should not be such that the last development

needs to provide any remaining density not provided for in previous

developments, rather it needs to be monitored as the area progresses. I have

reviewed the recommendation provided by Mr Bhana and I support this as it

one way of detailing my first option in paragraph 3.22.

Section 3.2 of the design guide

3.23 The submitter (21.42) sought deletion of the specific requirements under "3.1

Specific Requirements for Rototuna Medium Density Area (Western node)" and

20 To the Manukau District Plan 2002 21 Plan Change 20 to Manukau District Plan 2002, 16.15.9.3 22 Plan Change 20 to Manukau District Plan 2002, 17.10.11.4 and 17.10.11.4.2


to "3.2 Specific Requirements for Rototuna Suburban Centre" which are

contained in Appendix 1C Rototuna Urban Design Guide.

3.24 I have been asked to consider only “3.2”.

3.25 The design guide includes three parts and 3.2 contains what are essentially

development controls. The introduction at 3.0 does state that there is a

“degree of flexibility, and that the standards may not be appropriate in every

instance.” The flexibility needs to be assessed as to whether a proposal

creates an equivalent or better outcome.

3.26 The standards are very prescriptive and not ideal in the guide. There are a

number of design guides for other areas which do include specific standards

such as the Design Code (note not design guide specifically) for intensive

housing in the Manukau District Plan. More recently the Residential

Apartment Design Guide (Draft September 09) has been drafted and referred

to in PC20 for Flatbush. This provides guidance, not standards. Other design

guides such as Jack’s point in Queenstown are a result of a design process

and resource consent which any subsequent development needs to comply

with. This includes specific standards as it has gone through a design process

to determine these.

3.27 Given there are standards under Rule 4.12 of the plan change, I consider all

standards should be in that location. The only standard in 3.2 which I consider

should be included in 4.12.1.5 is the maximum height table (3.2.1) and an

explanation should be included outlining the rationale. All the other standards

3.2.2 to 3.2.10 should be deleted to enable the CDP process to achieve a

design that is appropriate for the situation rather than the potential for these

standards to be taken too literally and for the outcome to be designed by these

numbers. Maximum height is a standard used in most district plans and

assists with the anticipated bulk and level of activity on a site, especially if the

development intensity standard (3.2.4) is to be deleted.

3.28 Most of the standards have guidance in Part 3, which discuss what should be

achieved. I consider these to be acceptable but they could be enhanced to

deal with assessment of non-compliance with standards in 4.12.1.5 if the

submission regarding status of a non-compliance is accepted.


3.29 It is not clear what the rationale is for the development intensity table at 3.2.4.

If there is a stormwater or permeability issue that this standard is proposed to

address, then there is some validity to including this table as a standard but

with an explanation as to why. If it relates to building bulk and amenity such as

provision for landscaping, I consider this too restrictive and unnecessary given

a CDP process is required to provide a design solution. This is a good

example where it would be rather difficult to demonstrate an equivalent or

better solution as suggested in 3.0 as discussed earlier.

4.0 Conclusion

In conclusion, I consider the intent of the plan change to be very positive from

an urban design perspective. I have made a number of recommendations in

this evidence which specifically relate to particular submissions made by the

submitter. I have not provided evidence on the totality of the plan change.


Appendix A


Appendix B


Appendix C

Documents

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