REBUTTAL: 051-054 Hrg - Auckland Council (Matthew Bonis) - Planning
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Transcript of REBUTTAL: 051-054 Hrg - Auckland Council (Matthew Bonis) - Planning
BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL
IN THE MATTER of the Resource Management
Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010
AND IN THE MATTER of 051 - 054 Centre Zones,
Business Park and Industrial Zones, Business Activities and Business Controls, Section D3, D3.1 – D3.9, I3.1 – I3.6
STATEMENT OF REBUTTAL EVIDENCE OF MATTHEW WILLIAM BONIS
ON BEHALF OF AUCKLAND COUNCIL 28 August 2015
1. INTRODUCTION
1.1 My name is Matthew Bonis. I am a Consultant planner engaged by the Council to
respond to submissions received on the notified PAUP and to provide planning
evidence in relation to the Regional Policy Statement (RPS) Issue 051 - 054. I have
the qualifications and experience set out in my evidence in chief dated 27 July
2015.
1.2 I confirm that this rebuttal statement of evidence has been prepared in accordance
with the Code of Conduct for expert witnesses contained in the Environment Court
Practice Note.
1.3 In preparing this rebuttal statement I have read the evidence prepared on behalf of
submitters on Issue 051 – 054. In particular, I have reviewed the evidence of those
parties set out in Attachment ‘A’.
1.4 This rebuttal statement addresses various issues in that evidence.
2. SCOPE
2.1 My rebuttal evidence refers to the ‘consolidated provisions’. These are the
provisions contained as Attachment C to Mr Jeremy Wyatt’s EiC, as amended by
the rebuttal evidence of Council witnesses and attached to Mr Wyatt’s rebuttal
evidence.
2.2 The sub-groups or "themes" that will be addressed in this evidence include the
following:
(a) Overall approach – Economic approaches and the need for flexibility
(Philpott – DNZ, 2863; Heath – NTC, 2632; and Tansley – The Warehouse
2478,)
(b) The Mixed Use Zone – supermarkets (Foster et al (KRG); the
agglomeration rule (Smith, Tansley – the Warehouse 2478); motor vehicle
sales (Panther Knight – Gilltrap, 6269) Trade Suppliers (Norwell, Boerson
– Bunnings, 6096) ;
(c) The General Business Zone – the DNZ / AMP 400m radius to
Metropolitan centres relief (Carvill / Tait – DNZ / AMP, 3863, 4376);
(d) Local Centres – Department stores (Foster et al (KRG), implications from
agglomeration activities (Carvill / Tait – DNZ / AMP, 3863, 4376; Foster et
al (KRG), Smith, Tansley – the Warehouse 2478), offices and
supermarkets (Sousa – Hogan, 5205).
(e) Neighbourhood centres – the place for supermarkets (Foster et al (KRG),
Bull and Heath – NTC 2632)
(f) Identified Growth Corridors – Provision (Carvill / Tait, McKenzie and
Philpott – DNZ / AMP, 3863, 4376; Foster et al (KRG);
(g) Miscellaneous – Manukau Super-Metro zone (Ben Ross, 1606),
Entertainment facilities and Bars and Taverns (Sousa – Hogan, 5205).
3. SUMMARY
3.1 It is my opinion that the nature of the dispute is relatively narrow. The evidence from
the witnesses generally subscribes to support for the strategic approach. There are
specific and focused reservations as to aspects of the implementation of that approach.
3.2 The primary issue is one of the flexibility inherent in the provisions. The witnesses
seek greater or lesser flexibility to accommodate commercial growth necessary to
support rapid increases in retail spending, whilst achieving a compact urban form
and transport integration.
3.3 My review of witness evidence, maintains my view that the consolidated provisions
are the more appropriate. I have concluded that if the Panel reaches a different
view, the addition of further IGCs is preferred to greater accommodation of
commercial activity in non-centre zones.
4. GENERAL APPROACH
4.1 My EiC identified that the majority of parties supported the overall strategic direction
of the PAUP provisions1. Submissions sought either greater relaxation or
compression of commercial opportunities in Auckland’s centre network and
industrial zonings. 1 Bonis EiC 3.3,
4.2 I consider that the experts representing the parties maintain broad, but qualified
support for the provisions.
Mr McKenzie, (DNZ / AMP, 3863, 4376) - supports the centres based approach for
transport outcomes, particularly overall reduction in adverse effects from ad hoc
business development2.
Mr Philpott, (DNZ / AMP, 3863, 4376) - Support for centres based approach,
especially the role of local centres3.
Ms Carvill / Ms Tait, (DNZ / AMP, 3863, 4376) – Largely support for ‘Consolidated
mark-up’ contained in Attachment C of Mr Wyatt’s EiC4.
Foster et al [Key Retailers Group5] provide general support for the approach taken
in the objectives and policies in the business zones6.
Mr Heath, (NTC 2632). Agrees in principle with the Council approach7.
Mr Walker, (Progressives, 5723). General support for the centres based approach
pursued by the Council8.
Dr Fairgray. (Kiwi and Sscentre, 2968, 5253). Support for centres based
approach9.
4.3 A number of matters raised in the respective paragraphs reference, reiterate or
expand on those matters discussed in the Council’s evidence10. There appears to
be no fundamental dispute as to the strategic approach established in the
‘consolidated provisions’ contained in Mr Wyatt’s EiC.
4.4 The strategic approach seeks to: rationalise the extent of zones under the previous
(legacy) zoning regime11
; create certainty in terms of channelling activities into zones
based upon their character, scale and attributes; promote co-ordination of land-use and
infrastructure; recognise industrial land scarcity and manage reverse sensitivity effects;
and create economies of scale. For commercial activities growth is directed by a
coherent framework. Commercial growth is to be accommodated by primarily
intensifying and encouraging activity into the centres hierarchy; enabling commercial
activity in limited number of Identified Growth Corridors, and then other business zones
as appropriate.
2 McKenzie EiC, (DNZ / AMP, 3863, 4376) Executive Summary
3 Philpott EiC, (DNZ / AMP, 3863, 4376) Paragraph 5.2
4 Ms Carvill / Ms Tait. EiC. (DNZ / AMP, 3863, 4376) Paragraph A Summary.
5 5723 (Progs), 2968 (Scentre), 6096 (Bunnings), 2632 (NTC),
6 Foster . Smith, Thompson, Norwell, McGarr.. Paragraph 2.2
7 Mr Heath. (NTC 2632). Paragraph 3.2
8 Mr Walker. (Progressives, 5723). Paragraphs 3.1 and 3.2
9 Dr Fairgray. (Kiwi and Sscentre, 2968, 5253) Paragraph 3.3
10 Wong-Toi EiC, paragraph 5.1.1, Akehurst EiC, Section 5. Bonis, EIC Section 8.
11 Bonis EiC Paragraph 3.3
4.5 In my view the Council’s strategic approach gives effect to the provisions of the RPS12
,
and has appropriate regard to the Auckland Plan13
and other relevant planning
documents.
4.6 To appropriate manage business distribution in this context, in my view, is to:
incentivise commercial activity into centres and a limited number of Identified
Growth Corridors, (through enabling provisions such as permitted activity rules,
non-notification clauses, and provisions that recognise the functional requirements
of important in-centre activities despite urban design conflicts); and discourage out-
of-centre activities through appropriate drafted objectives and policies and the use
of discretionary / non-complying activity status.
4.7 In my view these matters require a consideration based not solely on effects, but
also the management of land use to achieve an appropriate urban form to help
secure desired outcomes14.
4.8 In terms of retail spending growth there appears to be no dispute as to the rapid
rate of retail sales anticipated as a consequence of growth. Unhelpfully, there
appears to be no common metric between the economic witnesses as to what this
represents, or the forecast years. In summary:
S Fairgray. Retail sales projected to increase by $7.1billion to 2031. Retail
floorspace is projected to increase by 1.1million m2. Approximately 50% of this
growth in floorspace is in large format retail15
.
T Heath. Retail sales projected to increase by $14billion to 2041. This could
support16
retail floorspace of an additional 2.8million m2. For supermarkets alone,
an additional $4billion in retail spend is projected to 204117
.
J Fairgray18
, R Philpott19
and M Tansley20
do not identify specific growth figures but
concur with, or have reservations with the Council’s modelling respectively.
Mr Thompson projects a demand in retail floorspace of 1.125million m2 (inclusive of
5 year rolling buffer) ‘over the life of the PAUP’21
.
12
Bonis EiC. Para 7.2, Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 4.1.16. 13
Bonis EiC Para 7.5 -7.16, Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 4.1.8 – 4.1.9. 14
Bonis EiC 8.71. 15
S Fairgray EiC paragraph 6.1. 16
Heath. Paragraph 6.17. 17
Heath Paragraph 4.13. 18
D Fairgray. Paragraph 4.2 19
Philpott. Paragraph 1.3, 1.8 20
Tansley Paragraph 1.1, 8, 9. 21
Thompson (SFH Consultants). Figure 6
4.9 I have outlined at paragraph 8.17 of my EiC the costs associated with an absence
of flexibility or capacity to accommodate a growth in commercial demand. These
include potential capacity issues, crowding out, and increased rents and reduced
customer choice. Ms Bull22 (NTC 2632) has also correctly, in my view outlined plan
integrity and uncertainty issues that may be associated with a planning framework
that unsuitably constrains capacity and flexibility to accommodate likely increases in
retail growth.
4.10 However, the evidence of Mr Akehurst23 and Ms Fairgray24 points to capacity
surplus, with the exception of the middle or the North Shore and mid-western side
of the isthmus. These deficits are intended to be resolved, in part, by provision of
proximate IGC’s at Wairau Road and New North Road – Kingsland. I also take
some comfort from Mr Akehurst’s identification that the demand modelling does not
take account of the provision for an additional volume of commercial and retail
space25 provided by the Future Urban Zone (‘FUZ’).
4.11 Were the Panel to consider greater flexibility was warranted, in my view this would
bring into focus the number of and extent of IGCs26, as well as the regulatory
response in relation to the status of agglomerated retail activities within the MUZ27
and supermarkets in the LIZ28.
5. THE MIXED USE ZONE – SUPERMARKETS, THE AGGLOMERATION RULE,
MOTOR VEHICLE SALES, TRADE SUPPLIERS
5.1 My EiC provides: a description of the mixed use zone in terms of the legacy
provisions29; Section C:2 sets out the analysis with regard to relevant submissions.
Supermarkets
5.2 Foster et al (KRG) seek the insertion of a new policy to the mixed use zone
provisions30. The recommended policy seeks to recognise: the positive contribution
of supermarkets; and explicitly enable supermarkets within the mixed use zone.
22
Bull EiC. Paragraph 30 23
Akehurst. EiC. Paragraph 7.39. 24
S Fairgray. EiC Paragraph 6.15. 25
Akehurst EiC. Paragraph 7.43. Acknowledging Mr Tansley’s concerns with that approach (EiC paragraph 29). 26
Foster et al [KRG]. Paragraph 11.8. Carvill / Tait. Paragraph 9.32. 27
Smith (the Warehouse, 2478) EiC. Paragraph 21. McGarr / Thompson (Kiwi, Sscentre 5253, 2968) Section 3. 28
Heath (NTC, 2632). 29
Bonis EiC (Paragraph 5.6) 30
Foster et al (KRG). Paragraph 7.6, 7.22(b).
5.3 No changes are sought in terms of the activity status which permits supermarkets
up to 450m2, applies a restricted discretionary status where between 450m2 and
2,000m2, and renders supermarkets above 2,000m2 as discretionary activities.
5.4 Paragraph 7.13 of the KRG Planning evidence identifies 10 supermarkets in the
PAUP mixed use zone. Five of these are smaller brands such as Four Square,
Fresh Choice, SuperValue, Nosh and others. There is no identification of scale,
although I reasonably assume that the Pak n Save (1), New World (1) and
Countdown (3) offers will be well in excess of the 450m2 permitted in the zone31.
5.5 The suggested policy is bluntly worded. It seeks to encourage supermarkets
regardless of scale. Neither does it provide criteria as to the management of likely
resultant effects.
5.6 I consider that the requested policy is unnecessary and inappropriate. The
consolidated objectives and policies for the Mixed Use Zone are more nuanced as
to the commercial outcomes anticipated in the mixed use zone. In particular, Policy
2 (relating to distributional effects) and Policy 7 (promoting and management
development to a standard of amenity recognising moderate scale and intensity).
The consolidated provisions do not preclude supermarkets, but equally do not
explicitly seek to enable them regardless of scale and effects. In my view, that
remains the appropriate policy response.
5.7 As discussed in my EiC32 supermarkets vary in scale, catchment and offer. For
larger scale supermarkets, there can be opportunity costs in terms of reducing the
range of anticipated activities in the mixed use zone, decreased opportunities for
intensification, and the generation of adverse transport effects on the roading
network.
5.8 Accordingly the requested policy would be less appropriate in achieving Objectives
1 to 3 which respectively seek: moderate to high intensity residential and
employment; activities that do not diminish the function and role of adjoining
centres; and encouraging a mix of activities.
31
Bonis EiC Paragraph 14.7 identifies six of the 11 supermarkets identified by Council in the zone are less than 2,000m2.
32 Bonis EiC Paragraphs 29.7 – 29.14
The agglomeration rule I:3.3.2, I:3.3.2a and I3.3.2b
5.9 The analysis for introducing Policy 2A and associated provisions I:3.3.2, I:3.3.2a
and I:3.3.2b is identified in my EiC33. The purpose of the provisions is to preclude
agglomeration of retail, and food and beverage outlets in the mixed use zone /
general business zones. The effects that are sought to be managed by the
restricted discretionary activity provision relate to distributional effects, and a shift in
zone integrity through accommodating a wider range of commercial activities than
envisaged in the zone purpose and objectives. The provisions stem from RPS B3.1
which seeks to focus and encourage commercial growth in centres34 yet provide for
commercial growth in business zones where appropriate as subject to criteria35.
5.10 The consolidated provisions are supported by McGarr and Thompson (Kiwi and
Sscentre)36, and Carvill / Tait (DNZ / AMP)37. There is tacit support from Smith (the
Warehouse) with regard to Rule I:3.3.238, but opposition to proposed Rules I:3.3.2a
and I:3.3.2b39. Mr Tansley also opposes Rules I:3.3.2a and I:3.3.2b40.
5.11 Mr Smith identifies that the rule is unnecessary and inappropriate, and that ‘Mr
Bonis’ apocalyptic vision is unsupported by evidence’41. He has identified that food
and beverage outlets have been generally unrestrained by planning provisions in
the past, and that there is a substantial growth projected for cafes and restaurants
where intensification is occurring. Mr Tansley identifies that food and beverage
outlets for on-premises consumption largely follow markets created by communities,
and with off-premises consumption largely replacing retailing in smaller centres. Mr
Tansley is of the view that the markets needs are being met, without collateral
damage42.
5.12 My EiC identifies that there are individual regulatory costs43. In my view these costs
remain offset by the likely extent of community benefits. The provisions remains
appropriate in:
(a) achieving Objectives and Policies in B3.1 which seek to focus commercial
activities in centre;
33
Bonis EiC. Paragraph 14.4, Paragraphs 28.8, Paragraphs 31 and 32 34
B3.1 Objective 2, Policy 2 (Mediated Version) 35
B3.1 Policy 8. 36
McGarr and Thompson EiC. (Scentre and Kiwi, 5253, 2968) Paragraph 1.4, 3.1 – 3.7, 13 37
Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 3.3, 4.7.1 – 4.7.3, 6.2.1 – 6.22. 38
Smith (the Warehouse, 2478) 39
Smith (the Warehouse) paragraphs 1, 2 and 9 40
Tansley (the Warehouse) paragraphs 19 - 25 41
Smith (the Warehouse) Paragraph 21. 42
Tansley (the Warehouse) Paragraph 22, 23. 43
Bonis EiC. Paragraph 31.6
(b) provision for some commercial development fringing centres, noting that
this reinforces the centre network, rather than diluting or dispersing
commercial activity44; and
(c) being both effective and efficient in terms of achieving Policy 2A (for the
Mixed Use Zone); and Policies D.3.8.4 and D.3.8.4 of the General
Business Zone in terms of managing the extent of commercial activity in
these zones.
5.13 Lastly, I note my recommendation for the provision is not predicated on an ‘end of
days’ scenario as outlined by Mr Smith. My support for the regulation is based on
the following:
The regulatory status is restricted discretionary with a narrow range of matters
to be considered;
The control does not apply to those parts of the mixed use zone located within
200m of the city centre, metropolitan, town or local centres. I understand that
the majority of the mixed use zone is unaffected by the rule. I have provided
examples of Dominion Road, Newmarket and Otuhuhu at Attachment B to
identify the spatial extent of where the rule would and would not apply for those
examples.
Within the mixed use zone, the control does not apply to retail that is not part of
an integrated development with more than 5 retail activities or a maximum
‘retail’45 total GFA exceeding 1,000m2. This level of permitted development
enables food and beverage demand generated by intensifying communities in
the area to be met46.
Within the general business zone, my observations are that the threshold of five
food and beverage outlets would provide for the existing situation, and in many
instances provide flexibility for provisional increases in such outlets, without
changing the focus of the zone.
Trade Suppliers and Motor Vehicle Sales
5.14 Mr Norwell47 and Mr Boerson48 generally agree with the approach for Trade
Suppliers in the consolidated provisions. They do seek a restricted discretionary
activity status for trade suppliers in the mixed use zone.
44
Akehurst. Rebuttal Paragraph 4.14. 45
Smith (the Warehouse, 2478). Paragraph 46
Tansley. (the Warehouse). Paragraph 22. 47
Norwell EiC (Bunnings, 6096) paragraphs 3.1, 3.2
5.15 Ms Panther Knight49 agrees with the approach for motor vehicle sales, but seeks a
restricted discretionary activity status within the mixed use zone.
5.16 I have set out in my EiC my response to the respective submissions at paragraphs
26.5 to 26.13; I maintain those views.
5.17 I note activities contained within the broad definition of Trade Suppliers range in
scale, form and extent of servicing the needs for the general public. Bunnings,
Placemakers and Mitre10 Mega represent the larger scale offerings within that
spectrum, but exhibit significant differences as to the proportion of sales to the
public.
5.18 There are other Trade Supply formats, such as architectural hardware50 that due to
scale, design and intensity may be more easily accommodated in the Mixed Use
Zone. By comparison to larger space extensive and lower employment density
outlets such as Bunnings / Mitre 10 Mega, smaller grain trade supply outlets would
better achieve the respective objectives and policies. Objective 1 seeks to provide
moderate to high intensity (residential and) employment opportunities; and Policy 7
seeks to promote and manage a reciprocal level of amenity.
5.19 Mr Boerson cogently sets out at his paragraph 7.11 particular functional issues
inherent with establishing a Bunnings warehouse. I understand and agree with his
evidence. He has outlined, that with contextual design and transport management51
that a non-typical format could appropriately be established in more sensitive
environments, such as the mixed use zone. In particular, Mr Boerson outlines that
some 2-3ha is typically required52 to accommodate such an activity.
5.20 A DA status of Trade Suppliers is, in my view, more appropriate in achieving
objective 1 and policy 7 in particular. A DA status allows for:
(a) the broad consideration of the merits of the proposal and the environmental
context for the application;
(b) does not preclude outcomes such as that identified by Mr Boerson for the Grey
Lynn Bunnings outlet; but
48
Boerson EiC (Bunnings, 6096), paragraph 7.6, 7.7. 49
Panther-Kniight EiC (Gilltrap Holdings 6269) paragraph 2.1(a), Section 4. 50
Examples include Knobs and Knockers, Burton Street – Grafton, and 293 Ti Rakau Drive. 51
Boerson. EiC (Bunnings 6096). Paragraph 6.2(b) 52
Boerson. EiC (Bunnings 6096). Paragraph 6.1(a).
(c) neither narrows the consideration of effects and the ability to mitigate such,
which based on the spectrum of activities within the umbrella definition of
Trade Suppliers can vary widely.
Importantly, a DA status still provides for notification as appropriate53
.
5.21 In terms of motor vehicle sales, I acknowledge that the mixed use zone
‘environment’ for the purpose of s76(3) contains the presence of such traders54 Ms
Panther Knight also correctly points to existing clusters of motor vehicle sales
operators in the zone55.
5.22 The Auckland Unitary Plan review and rationalisation of the legacy plans provide for
a revised approach to land use management. RPS B2.156 and B3.157 recognise the
importance of centre fringe areas in terms of both consolidating and intensifying
residential and commercial provision to accommodate Auckland’s rapid growth. The
fundamental consequences, in terms of the application of the mixed use zone to
these areas is an unequivocal signal to the market to intensify such areas.
Promoting either Trade Suppliers or Motor Vehicle Sales as appropriate uses,
regardless of scale or density, in my view does not reflect, or give effect to that
wider regional approach.
5.23 Motor vehicle sales activities are typically space extensive, provide for lower
densities of employment, and have an operational amenity reflecting that context.
Accordingly, the efficient and effective achievement of Objective 1 and Policy 7 in
particular, in my view is more appropriately met through retaining a DA status.
6. THE GENERAL BUSINESS ZONE – DNZ / AMP (3863 / 4367) 400M RADIUS TO
METROPOLITAN CENTRES RULE
6.1 Ms Carvill and Ms Tait seek addition of a new rule58 to the general business zone.
The proposed rule would provide for retail up to 450m2 GFA per tenancy in the
general business zone as an RDA activity, where the general business zone is
53
Auckland Unitary Plan. Part 3:G.2.4 Clause 1 “Restricted discretionary activities will be considered without public or limited notification, or the need to obtain written approval from affected parties, unless otherwise specified in the Unitary Plan…”
54 Bonis EiC. Paragraph 26.12.
55 Panther Knight EiC (Gilltrap 6269) paragraph 4.3.
56 RPS B2.2 Objective 3.
57 RPS B3.1 Policy 7
58 Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 6.4.1 to 6.4.13.
located within a 400m walk from a metropolitan centre zone. There is no supporting
economic evidence provided on this relief from Mr Philpott (DNZ 3863). Respective
assessment matters suggested are intensity and scale, centre vitality and parking
design59. No additional policy is recommended to provide a nexus to the rule60.
6.2 The relief favours a limited number of Metropolitan Centres, being: Sylvia Park;
Westgate / Massey North; New Lynn; and in particular Manukau61 (Attachment C)
given the proximate extent of general business zone around this centre.
6.3 Ms Carvill and Ms Tait support the provision based upon, on their interpretation of:
Policy B3.1 Policy 562; and the Economic Expert Joint Statement63. That statement
reflects the understood principle that expanding centres provides a preferable
approach to increasing retail capacity, compared to non-centre locations. I have
provided evidence to the Panel on this matter in the RPS considerations of B3.164.
6.4 I consider that Ms Carvill and Ms Tait have conflated the principle stated in the
Economic Joint Statement with that of the purpose and application of B3.1 Policy 5.
That policy is not unconstrained; it provides for the managed expansion of the
centre (zoning) upon having regard to a number of factors65. I do not find support for
the DNZ / AMP proposition within B3.1 Policy 5, and there is no evidence provided
by DNZ / AMP that would suggest that matters (a) to (h) have been considered.
59
Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 6.4.10 60
Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 4.8.1 -4.8.3 61
Carvill / Tait (DNZ / AMP 3863, 4376). Attachment E. 62
Carvill / Tait (DNZ / AMP 3863, 4376). Paragraph 6.4.5 63
Carvill / Tait (DNZ / AMP 3863, 4376). Paragraph 6.4.5 64
Bonis EiC B3.1 Paragraph 5.28 and 6.47 to 6.55 65
5. Provide for the outward expansion of metropolitan and town centres having regard to whether it:
a. will provide for compact mixed-use environments on the periphery of the centre; b. will provide for a greater level of access by a community to a wide range of facilities, goods and
services in a convenient and efficient manner; c. facilitates the efficient and sustainable distribution of centres, in relation to the existing
distribution of commercial activity and population growth d. retains or enhances the existing centre’s role and function; e. adversely impacts the role, function, role and amenity of other the city centre, and other
metropolitan and town centres in the hierarchy, to a significant extent beyond those effects ordinarily associated with trade effects or trade competition.
f. manages the effects of commercial activity at the interface with adjoining land uses; g. substantially reduces the opportunity for medium to high density residential development; h. maintains the safety and efficiency of the road network in a way that promotes integrated
transport, by providing strong connections to a range of transport modes including walking and cycling, and enabling efficient connections to the existing public transport network to link with adjoining centres and identified growth corridors. Supports a safe and efficient transport system which is integrated with the centre.
6.5 I also draw to the Panel’s attention to Ms Fairgray’s capacity surplus figures66,
which show an existing surplus of capacity at the four areas where the proposed
rule would provide additional capacity: Sylvia Park; Westgate / Massey North; New
Lynn; and Manukau.
6.6 I agree with the comments of Ms Fairgray67. The additional flexibility is
unnecessary, and would only assist in duplicating or dispersing economic activity
away from the adjoining centre. I do not consider the relief to be appropriate in
implementing the policy, in particular policy 4, nor the objectives for the general
business zone, in particular objective 1.
7. LOCAL CENTRES – AMENDMENTS TO POLICY 6 TO ENCOURAGE
DEPARTMENT STORES; IMPLICATIONS FROM AGGLOMERATION
ACTIVITIES ON LOCAL CENTRES; OFFICES AND SUPERMARKETS
Department Stores
7.1 Foster et al (KRG) seek to amend Policy 6 to provide explicit recognition of
Department Stores in local centres, and provide for their functional requirements68. I
have commented on this matter at paragraphs 12.26 to 12.30 of my EiC, and I
maintain that view. I do not consider that department stores represent a necessary
and present component of the local centre network, such that their recognition and
provision of functional requirements necessitates policy support.
7.2 I have identified that department stores are not precluded by the local centre
provisions, and I note Ms Shilton (the Warehouse 2748) has identified that two
Warehouse offers are located in local centres (Clendon and Snells Beach)69. I
consider that a policy encouraging department stores in local centres, regardless of
scale or composition, would be incongruent with: the zone description; and
objective 1 which seeks to enable commercial activity that primarily serves local
convenience needs.
Offices and Supermarkets
66
S Fairgray. EiC. Figures 1 and 2. 67
S Fairgray. Rebuttal Paragraph 8.1, 8.2. 68
Foster et al (KRG). Paragraph 8.5 69
Shilton EiC (the Warehouse 2478). Paragraph 18.4
7.3 Mr Sousa (Hogan, 5205) seeks to provide greater provision for offices70 and
supermarkets71 as permitted activities in the local zones. A synopsis of Mr Sousa’s
analysis, (and I acknowledge that this summary may be criticized as an
oversimplification) is that:
The actual ‘threat’ of large scale commercial activity in the local centre, is not a
real risk, given the small land holdings and ownership patterns in the local
centre zones;
Mr Hogan has a unique site, capable of supporting larger commercial premises
and managing interface effects, accordingly a permitted status for supermarkets
on sites larger than 1ha is appropriate;
Providing for permitted retail and office uses would preserve Mr Hogan’s
development rights that existed under the Papakura Legacy Plan.
7.4 My EiC responds to Mr Sousa’s office considerations at paragraphs 27.2 – 27.9,
27.16. I also draw to the Panel’s attention the useful summary from Foster et al
(KRG)72. In terms of supermarkets, my EiC outlines my views at paragraphs 29.4 –
29.15.
7.5 The provisions seeking to manage the scale and range of commercial activities
stem from RPS B3.1 which seeks to concentrate such activities in the City Centre,
Metropolitan and Town Centres, given the role of those centres in terms of a
compact urban form and integration with transport. Reciprocal provisions in the
Local Centre seek to limit the scale and intensity of development73.
7.6 The limitations on the scale of offices and supermarkets as expressed in the
consolidated table in my view are more efficient and effective in giving effect to the
RPS, and achieving the respective zone objectives and policies than the approach
recommended by Mr Sousa. As noted in my EiC74 Local Centre policy 4 does not
preclude larger scale commercial activity, but seeks to manage the merits of
specific proposals within the broader framework established by the wider plan.
7.7 Mr Sousa has identified in evidence what he considers to be specific merits
associated with Mr Hogan’s development potential. However in my view, to amend
70
Sousa (Hogan, 5205), paragraphs 9.1 – 9.5. 71
Sousa (Hogan, 5205), paragraphs 10.1 – 10.4. 72
Foster et al (KRG). Paragraph 10.2 – 10.6. 73
Objective 1, 2 and Policies 1 and 4. 74
Bonis EiC. Paragraph 12.23
the Plan framework to accommodate the specific merits of an individual project on a
specific site amounts to the ‘tail wagging the dog’.
7.8 Foster et al (KRG)75 seeks to remove from the Local Centre zone description:
“The zone discourages single, larger scale commercial activity that would
prevent a mix of activities within the local centre”.
The zone description does not have any regulatory effect, but provides a useful
contextual description of the environmental outcomes anticipated in the zone. For
the local centre zone, the zone description reflects both the respective objectives
and policies which seeks a scale and intensity of development reflective of the
surrounding environment76; and the context and description provided in the
Auckland Plan77. In my view, this text has currency and provides context for policy
4 in terms of conveying these attributes, although I note I am not wedded to its
retention.
Impacts on Local Centres
7.9 Rules 3.2(a) and 3.2(b) are discussed above; they seek to manage the
agglomeration of food and beverage outlets in the mixed use and general business
zone respectively. Assessment criteria I:3.6.2.2a seeks to consider the effects of a
breach of these rules on local centres (b ‘centre vitality’, matter (i)).
7.10 This approach is supported by Carvill / Tait (DNZ / AMP 4376, 3863) 78 on the basis
of the importance of local centres within the centre hierarchy, and McGarr /
Thompson (Scentre / Kiwi 2968, 5253)79 that “we consider that local centres are
particularly vulnerable to adverse effects arising from the agglomeration of food and
beverage and small-scale retail in the Mixed Use zone as these are the same sort
of activities that are the most prevalent in the local centres”.
7.11 The approach is opposed by Mr Smith (the Warehouse, 2478)80 as his view is that
it is inevitable that local centres will evolve over time; and Mr Tansley (the
Warehouse, 2478)81 on the basis that there is little or no prospect of a mixed use
zone development having an adverse effect on a local centre, primarily because of
75
Foster et al (KRG). Paragraph 7.3 - 7.5. 76
Objective 1,2 and Policies 1 and 4. 77
Bonis EiC. Paragraph 7.13 78
Carvill / Tait. EiC (DNZ / AMP 4376 / 3863). Paragraph 8.2.1 79
McGarr / Thompson EiC (Scentre / Kiwi 2968, 5253). Paragraphs 4.3, and 4.4. 80
Smith (the Warehouse 2478). Paragraph 35 – 38. 81
Tansley (the Warehouse 2478). Paragraphs 26 – 27
the regulatory constraints on individual larger retailers locating in the mixed use
zone.
7.12 Mr Akehurst has set out in his rebuttal evidence the predominance of food and
beverage outlets within the Local Centre network, and his support for retention of
the scope of the current assessment matters to include local centres.
7.13 I consider that the agglomeration of food and beverage outlets (and retail) within the
mixed use zone is most likely to provide a prospective threat to the local centre tier
of the centres network. This is due to the likely overlap with the function and role
performed by the local centre network.
7.14 I agree with Mr Smith’s view that the local centre tier of the centres hierarchy does
not have the regional importance established in B3.1, nor composition or sufficient
scale to justify a focus for the growth of commercial activities. In my view however,
local centres are important local physical resources and the effects on individual
centres should be assessed. In my view, there is still a need to consider impacts on
this tier of the centres network. The assessment does not preclude effects, but
requires these to extend beyond “those effects ordinarily associated with trade
effects on trade competitors”.
8. NEIGHBOURHOOD CENTRES – SUPERMARKETS
8.1 Ms Bull (NTC 2632)82 and Foster et al (KRG)83 generally support the approach, but
seek amendment of activity status from the consolidated provisions as follows:
Activity NC LIZ
Supermarkets up to 450m² GFA per tenancy
P NC DA
Supermarkets exceeding 450m2 and up to 2000m² GFA per tenancy
NC RDA NC DA
Supermarkets exceeding 2000m2 per tenancy NC DA NC DA
8.2 Ms Wickham and Mr Akehurst for Auckland have responded with regard to the LIZ.
82
Bull EiC (NTC 2632) paragraphs 6, 38 – 44. 83
Foster et al EiC. Paragraph 7.16
8.3 I retain my consideration of the activity status for supermarkets within the
neighbourhood centre zones84. This is due to:
(a) the status being seen as being both effective and efficient in achieving the
respective policies and objectives, particularly objectives 1 and 2 which
seek to limit the scale and intensity of commercial activities.
(b) the built form and transport intensity of larger scale supermarkets is
typically incongruent with the amenity expectations of both neighbourhood
centres, and the adjoining residential interface.
(c) the displacement of smaller more convenience based activities narrowing
the ability of the local community to access frequent needs. However, it is
acknowledged that in-centre supermarket developments can in some
instances foster reinvestment and improved accessibility to convenience
retail.
(d) the absence of developable sites able to absorb a larger scale
supermarket offer, with the most likely resultant scenario being extension
onto an adjoining zone.
8.4 In terms of matter (d) above, assuming a 40% built form : car parking, loading /
landscaping ratio, supermarkets of up to 2,000m2 GFA require a developable area
of 0.5ha, and supermarkets up to 4,000m2 GFA require some 1.2ha. In my view
these are not realistically obtainable within the scale, current built form, and
fragmented sites represented in neighbourhood zones. The largest 5% of
neighbourhood centres being some 0.6ha to 3.9ha in size85. Figure 1 below
identifies the range and scale of neighbourhood centres. Figure 2 identifies the
cadastral fragmentation.
8.5 There are 539 zoned areas of Neighbourhood Centre Zone, consisting of 1533 land
parcels. The neighbourhood centres typically include clusters of zoned areas that
are separated by road or laneway. A 100m buffer has been utilised to define ‘the
centre’ (refer examples Attachment D)
Figure 1: Neighbourhood Centres Scale
Metric Scale (m2)
Smallest area of zone 142
84
Bonis EiC. Paragraph 29.7 to 29.13. 85
Noting these do not necessary represent contiguous zoned allotments, nor large titles. Refer Attachment B.
Largest 39,761
Mean 2110
Lowest 5% 142m – 417
Lowest 25% 142m – 800
Highest 5% 6198m – 39,761
Highest 25% 2065m – 39,761
Figure 2: Neighbourhood Centres land parcel size
Metric Scale (m2)
Smallest parcel 102
Largest parcel 15,237
Mean 780
8.6 This analysis is not to provide hurdles to the valid considerations raised by both Ms
Bull86 and Mr Heath. I agree that there is a demonstrable need to ensure the
provision of supermarkets across the city to meet growth expectations87.
8.7 The issue comes down to integrity of the zone provisions, scale, and the more
appropriate mechanism to provide additional capacity. Simply put, a larger scale
supermarket extends beyond serving immediate needs, and would likely need to
either traverse into the residential zone, or replace the existing commercial activities
in the centre. The practical effect of the establishment of a larger scale supermarket
is that the role and function of the centre becomes akin to that of a local centre, or
provides a stand-alone supermarket.
8.8 The more appropriate approach in my view is to retain the current rule status within
the framework, and for substantial supermarkets applications to be undertaken by
way of plan change; including zoning the necessary area, and most likely elevating
the status of the centre. A case in point in my view is the difference between Torbay
and Half Moon Bay in terms of their supermarket offer. The latter is served by a
larger scale supermarket (Freshchoice) in the order of 800m2 GFA and is
associated with a range of adjoining convenience and community facilities and
86
MS Bull (NTC 26352). Particularly paragraphs 38 – 44. 87
Mr Heath (NTC 2632) identifies a land area requirement for 90ha to 105ha (to 2041). EiC Paragraph 5.6. Ms Fairgray identifies a requirement for 24 – 29ha (2031) Rebuttal Paragraph 3.15.
should more rightly be deemed a local centre given it serves a reasonably wide
catchment. Torbay contains a smaller supermarket (Four square) and a limited
range of convenience food and beverage outlets.
9. IDENTIFIED GROWTH CORRIDORS – PROVISION
Ms Carvill and Ms Tait (DNZ / AMP 4376 / 3863)
9.1 Ms Carvill and Ms Tait at Section 9 of their evidence, provide a critique of the
consolidation version of the provisions as these relate to Identified Growth
Corridors. In summary:
(a) The consolidated provisions are largely supported, including the objectives and
policies88;
(b) An amendment is sought to the zone description seeking to explicitly state that
IGCs are to provide overflow capacity for large format retail activities unable to
locate in centres, and without adversely impacting transport function or centre
vitality89.
(c) Support for the activity table, development controls and assessment matters90,
except: for retail activities between 200m2 - 450m2 in area which should remain
DA as included in the consolidated provisions, but below this default to the
activity status of the underlying zone91; and trade suppliers which should default
to the underlying zone92.
(d) Support for IGCs at Kingsland, Wairau Road93 and Stoddard Road94.
(e) Opposition to IGCs at Lincoln Road95 and Ti Rakau Drive96.
9.2 In terms of matter (b) above, Ms Carvill and Ms Tait seeks the insertion of the
following into the zone description:
The primary function of the Integrated (sic) Growth Corridors is to provide overflow capacity for
large format retail activities that are unable to establish in centres. It is not anticipated that the
overlay areas will become retail corridors that would adversely impact on the transport function of
the corridor, or the function and vitality of centres.”
88
Ms Carvill and Ms Tait (DNZ / AMP 4376 / 3863). Paragraph 9.1.1 89
Ms Carvill and Ms Tait. Paragraph 9.1.9 90
Ms Carvill and Ms Tait. Paragraph 9.2.1 91
Ms Carvill and Ms Tait. Paragraph 9.2.8 92
Ms Carvill and Ms Tait. Paragraph 9.2.11 93
Ms Carvill and Ms Tait. Paragraph 9.3.3 94
Ms Carvill and Ms Tait. Paragraph 9.3.10 – 9.3.16, acknowledging concerns raised by Messrs Philpott and McKenzie. 95
Ms Carvill and Ms Tait. Paragraph 9.3.17 – 9.3.21 96
Ms Carvill and Ms Tait. Paragraph 9.3.22 – 9.3..27
9.3 The rationale for their recommendation is: the evidence from Mr Philpott97 that the
IGC overlay is primarily a release valve for large format retail, and that if
unmanaged may compromise the viability of centres; and Mr McKenzie’s
commentary on the implications for transport efficiency98.
9.4 I consider that the proposed amendments unnecessary and inappropriate. In
particular, I oppose the blunt assertion that there be no adverse impacts on the
transport function of the corridor, or the function and vitality of centres from the
establishment of IGC’s. In my view, this overlooks the activity table and associated
assessment matters that require consideration of such matters, and an absence of
some qualification as to magnitude of acceptability of such effects in
accommodating growth. In my view these matters, as raised by Ms Carvill and Ms
Tait are more appropriately stated in the existing consolidated provisions as below:
Where commercial activities are enabled by an identified growth corridor, these should:
respect the current land uses and the outcomes anticipated by the underlying zone
support a compact urban form
maintain the safety and efficiency of the road network and promote integrated transport
not diminish the function, role and amenity of the city centre, metropolitan, town and local
centres.
9.5 Both Mr Akehurst99 and Ms Fairgray100 have commented on the issue, and agree
that the formation of de facto centres should be avoided on IGCs. They agree that
the provisions are appropriately set to achieve that outcome. Ms Fairgray has also
identified that retail floorspace is projected to increase by 1.1million m2 by 2031,
with approximately 50% as large format retail101, and thereby there is also a need to
accommodate some 50% that must by association be non-LFR within the
respective business zones of the City. My reading of their evidence does not
extend to explicitly amending the zone description in the manner sought, as the
zone description already cogently expresses this as:
These provisions are applied to a limited number of significant road corridors or significant segments of these corridors. The purpose is to provide additional opportunity to those commercial activities (predominantly retail activities) that:
may not be appropriate for, or are not able to locate in centres due to the size, scale or
nature of the activity, and
are not typically provided for in the underlying zone.
97
Mr Philpott (DNZ / AMP 4376 / 3863) Paragraph 7.6 98
Mr McKenzie (DNZ / AMP 4376 / 3863) Paragraphs 4.1-4.9 99
Akehurst. Rebuttal. Paragraphs 7.2, and 7.4 100
S Fairgray. Rebuttal. Paragraph 6.2 101
S Fairgray. EiC. Paragraph 6.1.
9.6 I terms of matter (c), Ms Carvill and Ms Tait seek to amend the provisions such that
retail activities below 200m2 GFA default to the underlying zone, as would trade
suppliers.
9.7 Economic support from Mr Philpott is predicated on the capacity for trade suppliers
to be accommodated in other business zones of the City, and therefore there is no
‘need’ to accommodate these in the IGC locations102. He also identifies that small
scale retail and service activities in combination with LFR ‘would’ create a de facto
unplanned centre103. I am not aware of any analysis in his evidence as to what the
resource management consequences (in terms of either effects, or consideration of
the policy framework) would be, or whether these matters are appropriately (or
otherwise) considered in the respective activity table, and associated assessment
matters.
9.8 The evidence of Ms Fairgray is that the provisions are appropriately set to consider
the implications of retail below 200m2 as a DA104. Accordingly, I do not agree with
Ms Tait, Ms Carvill and Mr Philpott as to amending the activity status for retail below
200m2 GFA as applied to the IGC overlay.
9.9 With trade suppliers, Ms Fairgray does not support the approach of Ms Carvill and
Ms Tait. Ms Fairgray considers that it would be appropriate for trade suppliers to
locate within all areas of IGCs and potentially agglomerate with other retail105. Mr
Philpott does not state the basis of his opposition is to trade suppliers within IGCs,
beyond that of there being no ‘need’106. The only resource management effect that I
consider that could stem from such an approach is one of opportunity costs as to
the efficient utilisation of IGCs; although this is not stated in the evidence of Mr
Philpott.
9.10 Whilst there may be opportunity costs for the efficient utilisation of IGCs, I consider
this risk to be minimised based on:
The current application of IGCs within the consolidated provisions. Lincoln
Road, Wairau, Ti Rakau Road, and parts of Stoddard Road have an underlying
light industry zoning which permits trade suppliers;
102
Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.12, 7.13 103
Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.9 and 7.10 104
S Fairgray. Rebuttal. Paragraph 6.2. 105
S Fairgray. Rebuttal. Paragraph 6.4. 106
Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.13
Those parts of Stoddard Road, Kingsland and Lincoln Road zoned mixed use
zone already contain a substantial proportion of trade supply activity107, and the
IGC provisions would assist in recognising and providing for existing activities;
and
I am unsure as to how ‘need’ as framed by Mr Philpott with regard to the
provision of trade suppliers in IGCs can be substantiated as necessary to
manage a specific resource management effect.
9.11 Lastly in terms of matter (e), Ms Carvill and Ms Tait identify their opposition of IGCs
at Lincoln Road108 and Ti Rakau Drive109.
9.12 The basis of the opposition is:
(a) transport effects as outlined by Mr McKenzie, in particular that corridors should
be a secondary or subsidiary approach centres to achieve the objective for a
compact urban form, and a preferable approach to managing transport
efficiency and safety110
- that approach is endorsed by Mr Wong-Toi111
; and
(b) an absence of a retail supply deficit in Council’s economic model (which has
then been extrapolated to a likely impact on centre vitality)112
– which Mr
Akehurst suggests does not represent a nuanced consideration of the model
outputs, and would result in removing managed flexibility for additional retail
provision in the City113
.
9.13 Lincoln Road and Ti Rakau Road are discussed at paragraphs 20.18 to 20.28 of my
EiC. There is little further that is raised by parties witnesses that is not already
expressed in that evidence. I do wish to however respond to the following matters:
(a) In terms of Lincoln Road, I do not agree with the assertion by Ms Carvill, Ms
Tait or Mr Philpott that an IGC on this corridor is inappropriate as it may
compromise the amenity and vitality of the Henderson Metropolitan Centre114
.
The DNZ / AMP witnesses appear to base their assertion that if the Council’s
model does not identify a retail deficit in supply (which in this instance it does,
albeit a modest deficit), then additional provision must result in a significant
adverse effect on proximate centre vitality and amenity.
107
Refer S Fairgray. Table 2. 108
Ms Carvill and Ms Tait. Paragraph 9.3.17 – 9.3.21 109
Ms Carvill and Ms Tait. Paragraph 9.3.22 – 9.3..27 110
McKenzie. (DNZ / AMP 4376 / 3863) Section 2. 111
Wong-Toi. Rebuttal. Paragraph 4.11 112
Philpott (DNZ / AMP 4376 / 3863) Paragraphs 8.5, 8.6 and 8.14. 113
Akehurst. Rebuttal. Paragraph 7.4 – 7.6 114
Philpott (DNZ / AMP 4376 / 3863) Paragraph 8.14 is more assured in stating there would be an impact.
(b) This represents an overstatement of the purpose of the model, as well as the
ability of the IGC provisions to temper such effects. The model identifies the
appropriateness of further retail by location, and the ability of existing zoned
business zones to provide for growth in retail demand to 2031. To extrapolate
the conclusions of the model to be determinative of a significant adverse effect
on a specific centre is incorrect. The usefulness of the model is fundamentally
based upon around aspects of “urban form – whether spatial structural
changes are required to the centre network and what form the emergence of
new centres [and IGCs] may take”115
in order to provide for retail spending
growth and provide for community wellbeing.
(c) I also note Mr Akehurst’s response (to Mr Philpott) that a limited number of
IGCs are appropriate, regardless of capacity surplus, in order to provide
appropriate flexibility to accommodate larger footprint retailers that may not be
easily located within centres116
. That approach is preferable to the dispersed
spread of LFR into a large number of light industrial zones117
.
(d) Ms Carvill and Ms Tait object to my consideration of the prevailing commercial
character of Lincoln Road in recommending an IGC overlay118
. However, I
consider such an approach to be entirely appropriate in terms of both s5 and
s76(3), which require a consideration of the environment in establishing rules
under s32(1) and (2).
(e) Lastly, in terms of transport, I reiterate the concerns of Mr Wong-Toi’s as to the
traffic considerations associated with an IGC on Lincoln Road119
, and his
agreement with Mr McKenzie120
. It would also be remiss of me as a Planning
witness to not draw the Panel’s attention to Mr Wong-Toi’s concerns as to the
absence of detailed transport assessments associated with the IGC
overlays121
.
(f) In terms of Ti Rakau Drive, opposition stems from the likely dispersal of retail,
and associated transport effects122
. For the reasons set out by Mr Akehurst123
115
S Fairgray. Rebuttal. Paragraph 8.8 116
Akehurst. Rebuttal. Paragraph 7.4. 117
Akehurst. Rebuttal. Paragraph 7.6. 118
Carvill / Tait (DNZ / AMP 4376 / 3863) Paragraphs 9.20 119
Wong-Toi EiC. Paragraph 5.4.22. 120
Wong-Toi Rebuttal. Paragraphs 4.16. 121
Wong-Toi. Rebuttal. Paragraph 4.1 122
Carvill / Tait (DNZ / AMP 4376 / 3863) Paragraphs 9.3.27 to 9.3.28
and Mr Wong-Toi including the need to consider proposed infrastructural
upgrades as recommended in the assessment matters (J:4.4.3), I consider
that the effects of development as an IGC overlay along this corridor can be
appropriately managed.
Foster et al (KRG)
9.14 Foster et al, at Section 11 of their evidence supports the IGC provisions124, the
IGCs in the consolidated provisions125, but seeks additional IGCs126 at:
(a) Constellation Drive, Albany
(b) Great North Road, Arch Hill
(c) Lunn Avenue, Mt Wellington
(d) Ellerslie-Panmure Highway
(e) Great South Road, Takanini (west)
(f) Great South Road, Takanini (east)
9.15 I have considered these matters at paragraphs 20.31 to 20.44 of my EiC. I also
reiterate my statement at paragraph 16.10 of my EiC:
“An inadequate number of IGCs, coupled with a restrictive approach to commercial provision,
renders the mechanism redundant. Too many IGCs will promote a diffuse patter of commercial
activity to the detriment of the centres network”.
9.16 Ms Fairgray has stated this far more eloquently at paragraph 8.8 of her Rebuttal
evidence:
“Therefore, in my view, the issue becomes more focused around aspects of urban form –
whether spatial structural changes are required to the centre network and what form the
emergence of new centres may take. In this respect, I consider the KRG recommendations to
allow retail to locate on an incremental and ad-hoc basis across a range of IGCs a departure
from a centres-based urban form as this type of development may not occur in the form of new
centres. It has the potential to result in lineal tracts of dispersed retail development without the
critical mass or cohesiveness to function as a centre. As such, in my view, I do not consider
that the KRG have adequately taken into account the possible effects on existing centres if new
configurations of retail were to emerge; or the benefits of a centre configuration of retail”.
9.17 I am unassisted by the analysis contained in the KRG evidence.
123
Akehurst. Rebuttal. Paragraph 7.4. 124
Foster et al (KRG). Paragraph 11.1, 11.4 125
Foster et al (KRG). Paragraph 11.5 126
Foster et al (KRG). Paragraph 11.8
9.18 I maintain my view that then KRG Planner’s recommended corridors not be notated
as IGCs. However, and as outlined in paragraph 4.11, if the Panel after considering
all the evidence were of a mind that sufficient commercial flexibility was not present
in the Council’s framework, I recommend additional IGCs as a mechanism for
appropriately managing commercial enablement in comparison to greater dispersal.
Accordingly, I note that Ellerslie – Panmure Highway corridor127, has some tacit
economic128 and transport support129; Lunn Avenue130 does not; and the remaining
recommendations from the KRG Planners lie in a spectrum between the two.
10. MISCELLANOUS – ENTERTAINMENT FACILITIES, MANUKAU SUPER METRO
ZONE
Manukau – Super Metro
10.1 Mr Ben Ross (Ben Ross, 1606) has pursued his submission that the Manukau
Commercial centre be rezoned as a ‘Super Metropolitan Centre Zone’ and a suite of
objectives, policies and rules be inserted into the Unitary Plan to manage growth in
the centre. The central premise is that Manukau (and Albany131) should be afforded
greater regional and inter-regional prominence, than the current position as
contained in the Metropolitan Centre tier of the commercial hierarchy.
10.2 I have read Mr Ross’s evidence in its entirety. I do not agree with his proposition. I
retain my views as expressed at paragraphs 10.8, 10.9, 10.32 to 10.34 of my EiC.
10.3 Principally, I reiterate my EiC paragraph 10.34, that there is no appreciable benefit
in the proposition. The Ross approach would not in my view: better give effect to the
provisions of B3.1; would increase the extent of complexity in the plan provisions;
inappropriately be predicated on servicing markets outside the region132 with
resultant transport and retail distribution inefficiencies; and is unnecessary in terms
of providing for additional commercial growth133.
127
Bonis EiC. Attachment B. 128
S Fairgray. EiC. Paragraph 8.32(vii) 129
Wong-Toi. Rebuttal. Paragraph 4.25. 130
S Fairgray Paragraph 8.32 (vii) and Wong-Toi Rebuttal 4.22 Table1. 131
B Ross. 1606. Paragraph 7(a). 132
Bonis EiC 10.18. Refer Ross EiC. Attachment D, Super Metro Centre Objective 1 “To serve as complementary to the main City Centre Zone in servicing core parts of the region (Manukau serving Southern Auckland and arguably the northern Waikato, and Albany in time serving the North Shore, Rodney and Northland)…” 133
S Fairgray. EiC. Figure 1 and 2 Capacity surpluses at Manukau. Refer also Ross EiC paragraph 40 “I agree with Mr Bonis on his point that the Metropolitan Centres do enable significant growth and (in theory) unlimited scope for commercial activities”.
Entertainment Facilities
10.4 Mr Sousa (Hogan, 5205) has raised two concerns with the treatment of
‘Entertainment Facilities’ and ‘Taverns’134 in the consolidated version of the plan.
Two concerns are raised:
Entertainment facilities (‘EFs’) are permitted in the Metropolitan and Town
Centres and the Mixed Use zone. EFs are discretionary in local and
neighbourhood centres. Given the environmental context of local centres, Mr
Sousa considers that EFs should also be permitted in the local centre
zones135; that the 30m buffer rule136 will manage related amenity effects on
sensitive proximate residential activities; and there should be no distinction to
the approach in the mixed use zone.
Taverns nest under the definition of ‘Food and beverage’, which are permitted
within the Local Centre zone. ‘Bars and nightclubs’ are a subset of
‘Entertainment facilities’ which are discretionary in Local Centres137.
Therefore any additions to a tavern could be considered an extension of a
‘bar’ activity and therefore subject to a discretionary resource consent. Mr
Sousa seeks a dedicated definition for ‘bars and nightclubs’ in the plan, such
that the distinction with ‘Taverns’ is apparent.
10.5 My EiC identifies issues associated with accommodating ‘Entertainment Facilities’
in local centres. These relate to both the scale and catchment of such facilities, and
the generation of a higher level of night time activity that can be incompatible with
the anticipated residential amenity surrounding local centres.
10.6 I am not of the view that activities such as ‘theatres’, ‘concert venues’, ‘cinemas’,
and ‘nightclubs138’; would primarily service local convenience needs (objective 1),
nor be of a scale or intensity that respects the surrounding environment (policy 4).
Accordingly, I retain my view that a DA status remains the most effective and
efficient status for such activities in the local centre zones. I question the relevance
of Mr Sousa’s comparison to the mixed use zone which has quite different policy
provisions, and is typically located proximate to the city centre, metropolitan and
134
Sousa (Hogan, 5205). Paragraphs 7.1 – 8.3 135
Sousa (Hogan, 5205). Paragraphs 7.2 136
Land use Rule I:3.3.1 ‘Activities within 30m of a residential zone’. 137
Sousa (Hogan, 5205). Paragraphs 8.1 138
Refer recommendation removing ‘bars’ at paragraph 10.7 and 10.8
town centre zones where such facilities are promoted and a higher level of night
time activity is anticipated.
10.7 I agree with Mr Sousa’s concern as to the differentiation of ‘bars’ within the
spectrum of ‘taverns’ and ‘night-clubs’ and the resultant effect in activity status in
the local centre zone. In my view there is little light between a bar and a tavern. A
‘tavern’ is defined in the PAUP as “Facilities used for the sale and consumption of
liquor on the premises”, which is consistent with the Oxford University Dictionary
(Third Edition) definition. ‘Bar’ is undefined in the PAUP, but defined in the Oxford
University Dictionary (Third Edition) as a ‘room or building for serving alcohol;
tavern’. In my view a ‘Nightclub’ is quite a different proposition in terms of operating
hours, likely catchment and scale, and where whilst alcohol is consumed on the
site, the primary purpose is entertainment by way of amplified music.
10.8 Accordingly, I consider that the intent of Mr Sousa’s concerns can be met, albeit by
different means. The term ‘bars’ should be removed from the definition of
Entertainment Facilities as follows:
Entertainment facilities
Facilities used for paid recreation, leisure or entertainment.
Includes:
cinemas
bars and nightclubs
theatres
concert venues.
This definition is nested within the Commerce nesting table.
In addition to the above change, add ‘Bars and’ to ‘taverns’ in the commercial
nesting table, so it is clear that bars and taverns are nested under food and
beverage:
Retail Food and beverage Bars and Taverns
Restaurants
Finally, add ‘bars and’ to I:3.1.1a Activities within 30m of a residential zone (as
associated with taverns) as follows:
3.1 Activities within 30m of a residential zone
1. The following activities are restricted discretionary activities where
they are located within 30m of a residential zone and are listed as
a permitted activity in the zone activity table:
a. Bars and taverns
b. drivethrough restaurant facilities
c. outdoor eating areas accessory to restaurants
d. entertainment facilities
e. child care centres
f. animal breeding and boarding.
This control only applies to those parts of the activities subject to the application that are within 30m of the residential zone.
I do not consider a specific definition of ‘nightclub’ is necessary; the term is well
understood and would now be clearly distinguishable from a ‘bar and tavern’.
11. CONCLUSION
11.1 Except as identified above, I maintain the opinions expressed in my EiC.
Matt Bonis
28 August, 2015
ATTACHMENT ‘A’ – SPECIFIC EVIDENCE REVIEWED
DNZ / AMP (Now trading as PSPIB Waheke Incorporated). Sub. 3863, 4376
D McKenzie – Transport
R Philpott – Economics
J Carvell / Tait – Planning
Bunnings, Sub. 6096
D Boerson – Corporate
M Norwell – Planning Key Retail Group Sub. 5723 (Progs), 2968 (Scentre), 6096 (Bunnings), 2632 (NTC),
Foster et al - Joint Planning Statement
The National Trading Company (‘NTC’), Sub. 2632
V Smith – Planning
A Bull – Corporate
T Heath – Economics The Warehouse, Sub. 2478
V Smith – Planning
F Shilton – Corporate
M Tansley – Economics Progressive Enterprises, Sub 5723
A Walker – Corporate Kiwi / Scentre Sub 5253, 2968
D Drew – Corporate
D Fairgray – Economics
McGarr / Thompson – Planning [only just spotted doing this now]. New Zealand Institute of Architects (Auckland). Sub 5280.
Mr J McKay- Design Gilltrap Group Holdings. Sub 6269.
K Panther Knight- Planning Ben Ross, Sub 1606 Phillip Hagan, Sub 5205
P Sousa – Planner
KEYSTONE AVENUE
DOMI
NION
ROA
D
MOUNT ROSK
ILL ROAD
MAY ROAD
MEMORIAL AVENUE
LOUVAIN AVENUE
WINS
TONE
ROA
D
MOUNT ALBERT ROAD
FEARON AVENUE
HARD
LEY A
VENU
E
CAMBRAI AVENUE
DONALD CRESCENT
GIFFORD AVENUE
QUEST TERRACE
JASPER AVENUE
MONS
AVEN
UE CLEGHORN AVENUE
MONS
AVEN
UE
DOMI
NION
ROA
D
LOUVAIN AVENUE
MEMORIAL AVENUE
DOMI
NION
ROA
D
LOUVAIN AVENUE
JASPER AVENUE
MONS
AVEN
UE
DOMI
NION
ROA
D
MOUNT ALBERT ROAD
DOMI
NION
ROA
D
CAMBRAI AVENUE
MAY ROAD
DOMI
NION
ROA
D
MOUNT ALBERT ROAD
MOUNT ALBERT ROAD
MOUNT ALBERT ROAD
DOMI
NION
ROA
D
COPYRIGHT© Auckland Council
0 30 60 M
200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use
Dominion Road (via Mount Albert Road)
PINE S
TREE
T
DUNBAR ROAD
PEARY ROAD
BRIXTON ROAD
QUEENS AVENUE
HALSTON ROAD
DEXTER AVENUE
HALESOWEN AVENUE
TENNYSON STREET
MOUNT PLEASANT ROAD
BIRDSONG LANE
CARMEN AVENUE
TELFORD AVENUE
MONT LE GRAND ROADAR
ABI S
TREE
T
VOLC
ANIC
STRE
ET
LANCING ROAD
TENT
ERDE
N AVE
NUE
KENSINGTON AVENUE
WIREMU STREET
CALGARY STREET
THAMES STREET
HIGHC
LIFFE
ROA
D
ELDO
N RO
AD
MATIP
O ST
REET
DOMI
NION
ROA
D
BALMORAL ROAD
ROCKLANDS AVENUE
OXTON ROAD
MARSDEN AVENUE
GORI
NG R
OAD
VOLC
ANIC
STRE
ET
ARAB
I STR
EET
VOLC
ANIC
STRE
ETEL
DON
ROAD
DOMI
NION
ROA
D
DOMI
NION
ROA
D
DOMI
NION
ROA
D
PINE S
TREE
T
BALMORAL ROAD
ROCKLANDS AVENUE
BALMORAL ROAD
DOMI
NION
ROA
D
DOMI
NION
ROA
D
MARSDEN AVENUE
MATIP
O STR
EET
GORI
NG R
OAD
WIREMU STREET
PINE S
TREE
T
BALMORAL ROAD
CALGARY STREET
DOMI
NION
ROA
D
BALMORAL ROAD
DOMI
NION
ROA
D
BALMORAL ROAD
ELDO
N RO
AD
MATIP
O ST
REET
MATIP
O ST
REET
BALMORAL ROAD
KENSINGTON AVENUE
BALMORAL ROAD
BALMORAL ROAD
COPYRIGHT© Auckland Council
0 50 100 M
200m pedshed200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use
Dominion Road (via Rocklands Avenue)
MILTON ROAD
PROSPECT TERRACE
CROYDON ROAD
ST ALBANS AVENUE
FIRST AVENUE
HERBERT ROAD
KENY
ON AV
ENUE
BURNLEY TERRACE
SECOND AVENUE
TAUPATA STREET
HORO
EKA A
VENU
E
PAICE AVENUE
TONGARIRO STREET
KOWH
AI ST
REET
CROM
WELL
STRE
ET
WOOD
FORD
ROA
D
DOMI
NION
ROA
D
LISNOE AVENUE
PARRISH ROAD
ELDO
N RO
AD
ELIZABETH STREET
BOND STREET
ROYAL TERRACE
GORI
NG R
OAD
KINGSLAND TERRACE
NEW NORTH ROAD
VIEW ROAD
LEAM
INGT
ON R
OAD
PENT
LAND
AVEN
UEEWINGTON AVENUE
ONSLOW ROAD
KING EDWARD STREET
MANA
TU ST
REET
AVEN
HAM
WALK
CHARLES STREET
CARR
ICK P
LACE
CONWAY ROAD
VALLEY ROAD
RALEIGH STREET
HENL
EY R
OAD
TANE
KAHA
STRE
ET
ALDE
RLEY
ROA
D
GEORGE STREET
WAIR
EPO
SWAM
P WAL
K
WALTERS ROAD
HOROPITO STREET
MARL
BORO
UGH
STRE
ET
WYNYA
RD RO
AD
BELLEVUE ROAD
RARA
WA ST
REET
TAWARI STREET
BELLWOOD AVENUE
REIMERS AVENUE
STORMONT PLACE
SANDRINGHAM ROAD
CRIC
KET A
VENU
E
GRIBBLEHIRST ROADGRANGE ROAD
MONT LE GRAND ROAD
DOMI
NION
ROA
D
BURNLEY TERRACE
SANDRINGHAM ROAD
VIEW ROAD
MARL
BORO
UGH
STRE
ET
HORO
EKA A
VENU
E
DOMI
NION
ROA
D
ROYAL TERRACE
PAICE AVENUE
CROM
WELL
STRE
ET
CROMWELL STREETWALTERS ROAD
ONSLOW ROADONSLOW ROAD
KING EDWARD STREET
VALLEY ROAD
BURNLEY TERRACE
DOMI
NION
ROA
D
DOMI
NION
ROA
D
PAICE AVENUE
REIMERS AVENUE
ELIZABETH STREET
VIEW ROAD
CARRICK PLACE
DOMI
NION
ROA
D
KOWHAI STREET
TAWARI STREET
BELLWOOD AVENUE
ELDO
N RO
AD
DOMI
NION
ROA
D
WALTERS ROAD
VIEW ROADNEW NORTH ROAD
WALTERS ROAD
DOMI
NION
ROA
D
WALTERS ROAD
COPYRIGHT© Auckland Council
0 75 150 M
200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use
Eden Valley Local Centre
SEAV
IEW RO
AD
MAURANUI AVENUE
THE G
LEN
ALPERS AVENUE
MACMURRAY ROAD
LAURIE AVENUEFOOT
BALL
ROAD
ADA STREET
PARK ROAD
ST MARKS ROAD ON RAMP
ALMO
RAH
ROAD
MORG
AN ST
REET
EDEN STREET
MORTIMER PASS
MAMIE STREET
BELMONT TERRACE
ALMO
RAH
PLAC
E
SOUTHERN MOTORWAY
ELY AV
ENUE
MARG
OT ST
REET
MAUNSELL ROAD
SARAWIA STREET
NUFFIELD STREET
KHYBER PASS ROAD
KIOSK ROAD DOMAIN DRIVEMA
UNGA
WHAU
ROA
D
BEATR
ICE ROADEDGERLEY AVENUE
PERE STREET
ALMA STREET
GILL
IES AV
ENUE
BASSETT ROAD
DILWORT
H AVEN
UE
MCCO
LL ST
REET
SHORT STREET
TITOKI STR
EET
MELR
OSE S
TREE
T
ALBURY AVENUE
COWIE STREET
YORK
STRE
ET
WITHIEL DRIVE
LAURISTON AVENUE
TEED STREET
RAILWAY STREET
MAHU
RU ST
REET
COVE
NTRY
LANE
OSBO
RNE S
TREE
T
PRIMES LANE
ARNEY ROAD
SUITE
R ST
REET
REMUERA ROAD
GEORGE STREET
BOUR
KE ST
REET
KINGD
ON ST
REET
SILVER ROAD
MIDDLETON ROAD
MAUI
GRO
VE
MORROW STREET
BALM STREET
WOOTTON ROAD
PARN
ELL R
OAD
SWINTON CLOSE
MANU
KAU
ROAD
ST MARKS ROAD
GREAT SOUTH ROAD
GILLIES AVENUE OFF RAMP
AYR STREET
CARLTON GORE ROAD
SECCOMBES ROAD
BROA
DWAY
CARLTON GORE ROAD
SOUTHERN MOTORWAY
SOUTHERN MOTORWAY
GILL
IES AV
ENUE
MIDDLETON ROAD
DILWORT
H AVEN
UE
PARK
ROA
D
GILL
IES AV
ENUE
REMUERA ROAD
FOOTBALL
ROAD
PARNELL ROAD
BASSETT ROAD
BROA
DWAY
BROA
DWAY
ALMO
RAH
ROAD
GEORGE STREET
TEED STREET
GEORGE STREET
BROA
DWAY
BROA
DWAY
BROA
DWAY
MAUN
GAWH
AU R
OAD
BASSETT ROAD
BASS
ETT R
OAD
AYR STREET
BASS
ETT R
OAD
REMUERA ROAD
BASSETT ROADBR
OADW
AY
COPYRIGHT© Auckland Council
0 90 180 M
200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use
Newmarket Metro Centre
LIPPIAT
T ROAD
HUIA ROAD
NIKAU ROAD
ALBION ROAD
SALE
YARD
S ROA
D HAUITI ROAD
MOA STREET
TAMAKI AVENUE
HUTTON STREET
CHURCH STREET
STURGES AVENUE
PUKEITI ROAD
LUKE STREET
WALTERS ROAD
RONAKI ROAD
MARJORIE JAYNE CRESCENT
MANGERE ROAD
PUKEORA ROAD
GOLF AVENUE
WEKA STREET
STATION ROAD
QUEEN STREET
WALMSLEY ROAD
KURANUI PLACE
MCGEE STREET
PAPAKU ROAD
MASON AVENUE
GREAT SOUTH ROAD
MEADOW STREET
ALEXANDER STREET
NGAIO STREET
TAHATAI STREET
PARK AVENUE
AWA STREET
ATKINSON AVENUE
FAIRBURN ROAD
VICTORIA STREET
KING STREET
KAKA STREET
HOKONUI ROAD
AVENUE ROAD
GORDON ROAD
PORTAGE ROAD
FORT RICHARD ROAD
HIGH STREET
PRINCES STREET
OAK GROVE
HALL AVENUE
NIXON AVENUE
PRINCES STREET
CHURCH STREET
GREAT SOUTH ROAD
AVENUE ROAD
NIKAU ROAD
GREAT SOUTH ROAD
PORTAGE ROAD
SALEYARDS ROAD
ATKINSON AVENUE
TAMAKI AVENUE
NGAIO STREET
STATION ROAD
ATKINSON AVENUE
MASON AVENUE
ATKINSON AVENUE
PRINCES STREET
PRINCES STREET
MANGERE ROAD
AVENUE ROAD
NIKAU ROAD
CHURCH STREET
WALMSLEY ROAD
HUTTON STREET
LUKE STREET
HIGH STREET
CHURCH STREET
HUIA ROAD
SALEYARDS ROAD
GREAT SOUTH ROADGREAT SOUTH ROAD
AVENUE ROAD
AWA STREET
HUTTON STREET
NIKAU
ROAD
PORTAGE ROAD
HUTTON STREET
HIGH STREET
CHURCH STREET
PORTAGE ROAD
LUKE STREET
NIKAU ROAD
HOKONUI ROAD
MANGERE ROAD
FAIRBURN ROAD
CHURCH STREET
COPYRIGHT© Auckland Council
0 100 200 M
200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use
Otahuhu Town Centre
Isola PlaceUlay
Plac
ePettitPlace
AriaPlace
Rimini Place
Ryan Place
Ultim a Place
Kerrs
Road
IhakaPlace
Reagan Road
Israel A
venue
Zircon Place
Lambie Drive
Karoro Court
Thorn Place
Putney Way
Invere ll Court
Caspar R
oad
Lamb
ieDr
ive
Oster
leyWa
y
Davies Avenue
Brooks Way
Ixia Place
Sharkey Street
Pesaro Place
Rata Vine Drive
Jontue Place
CeladonPlac e
Granite Place
Lambie Drive
Lambie Drive
Te Irirangi Drive
Druces Road
Lambie Drive
Townle
y Plac
e
Winspear Place
Ronwood Avenue
Redoubt Road
Inverell Avenue
Sikkim Crescent
Druces Road
Marble Place
Ronwood Avenue
Israel Avenue
Carolyn Street
Lakewood Court
Airport Off Ramp
Barrowcliffe Place
Charntay Avenue
Edorvale Avenue
Leyton Way
Ronwood Avenue
Lamb
ieD r
i ve
Great South Road
Putney Way
Sandrine Avenue
Iliad P lace
Almay
PlaceLeyton Way
Lambie Drive
Liggitt Drive
Druces Road
Amersham Way
Sikkim Crescent
Great Sout hRoad
Courant Place
Plunket Avenue
TrevorHosken Drive
Great South Road
Wilisa Rise
Islay Place
Vetor
i Plac
e
Tourmalin Place
Allenby
Road
Great South Road
Allenby
Road
Cavendish Drive
Allenby Road
Jack Conway A venue
Cavendish Drive
Lambie Drive
Redoubt Road
GreatSout hRo ad
Ronwood Avenue
Joval Place
Great South RoadDiorella Drive
Great South Road
Manukau Station Road
Fairchil d Avenue
Great South Road
Reagan Road
Wiri Stati
onRo
ad
Druces Road
Allenby
Road
PutneyWay
Shalimar Place
Puhinui Road
Sikkim CrescentCavendish Drive
Kerrs Road
Mepal Place
Inverel l Avenue
GranthamRoad
Carruth Road
Boundary Road
Pulm
anPlace
Oak Road
Cavendish Drive
Great South Road
Kerrs Road
Reagan Road
Wind
omaCircle
Win d o ma Circ le
Great South Road
Leith Court
Boundary Road
Mana Place
Ihaka Place
Southern Motorway
Lambie Drive
Puhinui Road
Airport Off Ramp
Edsel Way
Avis Avenue
Carruth Road
Cl i st Crescent
Druces Road
Grea
t Sou
th Ro
ad
Wiri Station Road
Bakerfield Place
Lambie Drive Off Ramp
Awatere St ree t
Plunket Avenue
Earl Richardson Avenue
KellowPl
ace
Eleanor Way
Manukau Station Road
Great South Road Off Ramp
Regent S
treet
NormanSpencerDrive
Te Irirangi Drive
Gladding Plac e
South-Western Motorway
Falcon Road
Buckingham
Cresc
ent
Boundary Road
Wiri Station Road
Freeman Way
Airport Off Ramp
Te Irirangi Drive
Puhinui Road Te Irirangi Drive On Ramp
Hobill Avenue
Lambie Drive Off Ramp
Kerrs Road
Lambie Drive On Ramp
Southern Motorway
Cavendish Drive
Ryan Place
Wiri Station Road
Redoubt Road Off Ramp
Airport Off Ramp
Sikkim CrescentSouthern Motorway
Te Irirangi Drive Off Ramp
Southern Motorway
South-Western Motorway
Redoubt Road On Ramp
South-Western Motorway
Southern Motorway
Southern Motorway
Southern Motorway
South-Western Motorway
South-Western Motorway
COPYRIGHT© Auckland Council
0 140 280 M
Metropolitan Centre that has a General Business zone within 400m
Legend400m buffer from Metropolitan Centre
Unitary Plan Base ZoneMetropolitan CentreGeneral Business
Manukau
Pine Street
Ash S
treet
Clark Street
AshS
treet
Sandy Lane
Totara Avenue
Astle
y Ave
nue
Porta
ge Ro
ad
Bolton Street
Bellamy Place
Arawa Street
Elm Street
Nikau Street
Chaucer Place
StedmanPlace
Pecan Place
Davern Lane
Arran
Stree
t
Hinau Street
Westall
Road
Taylor Street
Titirangi
Road
Mccrae Way
Corr e
gidor
Place
Karaka Street
Chettl e Court
Kohekoh
e Stree
t
Dolan Place
Totara Avenue
Pamela Place Lucknow Plac e
Great North Road
Water
sPlac
e
Mcwhirter Place
Margan Avenue
Bolton Street
Kaweka Street
Lynwo
od Ro
ad
Piment
o Plac
e
Astley
Aven
ue
Ambrico Place
RataStree
t
Bleas
eStre
et
Margan Avenue
Skilgate Avenue
Neville Street
Delta
Aven
ue
Hineko
hu St
reet
Marlo
we R
oad
Hill Crescent
Hetan
a Stre
et
Clark Street
Boler Place
Clark Street
Rata
Stree
tLinksRoad
Clark Street
Puriri Street
DrurySt
reet
Rimu Street
Maui Street
Nikau Street
Miro Street
Rank
in Aven
ue
Margan Avenue
Denyer Place
Ash Street
RataStr
eet
The C
los e
Nikau
Stree
t
Great North
Road
Rata
Street
Hugh Brown Drive
Rimu Street
Sheridan Drive
Amsterdam Place
Crown LynnPlace
Arran
Stree
t
Northall Road
Ash Street
Cutler Street
Great North Road
Riverbank Road
Tiki S
treet
Kay D
rive
Taylor Street
Ash Street
Rata
Stree
t
Reiman Street
Busby Street
Quee
n Mary
Aven
ueRa
taStr
eet
Puriri Street
Islington Avenue
Cutler Street
Miro Street
Crow
n Lyn
n Plac
e
Wairau AvenueKels ton
Street
Hutchinson Avenue
Rickards Place
Clark Street
BeverlyPlace
Porta ge Ro ad
Bin s ted Road
Seabrook Avenue
Titiran
gi Roa
d
Titirangi Road
Mayville Avenue
Stock StreetBentinck StreetCrum Avenue
Great North
Road
Trojan Cre scen
t
Veronica Street
Tane Street
M iro Street
Seabrook Avenue
Hutchinso
n Avenue
Kuaka Place
Astle
y Ave
nue
Swinburne StreetAstley Avenue
Rimu Street
Cople
y Stre
et
Arahoe Road
Rewa Street
TaneStreet
Islington Avenue
Lynwo
odRo
ad
Porta
ge R
oad
Hutchinson Avenue
Portage Road
Wingate Street
Melvie
wPlace
Gardner Avenue
Pine S
treet
Miro StreetRa
nkin A
venue
Portage Road
Arawa Street
Stolford Crescent
Veronica Street
Astley
Aven
ue
Gardner Avenue
Wingate Street
RataStree
t
Hutchinson Avenue
Portage Road
Sheridan Drive
Gardner Avenue
Karak
a Stre
et
Delta
Aven
ue
WingateStreet
Margan Avenue
Portage Road
Queen M
aryAv
enue
Falk ir k Street
Kay Drive
Korom
iko St
reet
Parker Avenue
Lynwo
od Ro
ad
Rimu Street
Arawa Street
Akehurst Avenue
Willerton Avenue
Gardner Avenue
Margan Avenue
Wingate Street
Seabrook Avenue
Crowther StreetAlanbro oke Crescent
Tony Segedin Drive
Seabrook Avenue
Canal Road
Ash Street
Ulster Road
Nacton Lane
Nikau
Stree
t
Links Road
Reid Road
Willerton Avenue
Wattle
Stree
t
Portage Road
Golf Road
Beaubank Road
COPYRIGHT© Auckland Council
0 160 320 M
Metropolitan Centre that has a General Business zone within 400m
Legend400m buffer from Metropolitan Centre
Unitary Plan Base ZoneMetropolitan CentreGeneral Business
New Lynn
Vestey Drive
Pacific Rise
Stu d Way
Carbine Road
Penrose RoadWaipuna Road
StudWay
Aranui Road
Wilson W
ay
CarbineRoad
Ruaw
aiRoa
d Waipuna Road
The Oasis
Allright Place
Waipuna Road
Waipuna Road
Carbine Road
Paci fi c Rise
Allright Place
Carbine Road
Roslyn Road
Pacific Rise
Rowlands Avenue
Jarma
n Roa
d
Waipuna RoadWaipuna Road
Sylvia Park Road
Carbine Road
K eateP lace
Ruawai Road
Rayma Place
Ruawai Road
Mus ke
t Plac
e
Mount Wellington Highway
Tide Close
Irelan
d Roa
d
Ruawai Road
Lynton RoadAllright Place
Roslyn Road
Mount Wellington Highway
Irelan
d Roa
d
Bean Place
Carbine Road
Sylvia Park Road
South-Eastern Hwy Off RampCarm
ont Place
Southern Motorway
Lynton Road
Carbine Road
MountWellington Highway
Timaru P lace
Mount Wellington Highway
Carbine Road
Mount Wellington Highway
South-Eastern Highway
Southern Motorway
Penrose Road
Pacifi
c Rise
LyntonRoad
South-Eastern Highway
Bowden Road
Jame
sWalter Place
Clemow Drive
South-Eastern Highway
Waipuna Road
Matangi Road
Carbine Road
South-Eastern Highway
Ruawai Road
Mount Wellington Hwy On Ramp
Southern Motorway
Ruaw
ai Ro
ad
Arthur Brown Place
South-Eastern Highway
Monahan Road
Southern Motorway
Longford Street
Hamlin Road
Mcrae Road
Hamlin Road
Mount Wellington Hwy Off Ramp
Southern Motorway
Vestey Drive
Southern Motorway
Mount Wellington Hwy Off Ramp
South-Eastern Highway
South-Eastern Hwy Off Ramp
Sylvia Park Road
Aranui Road
South-Eastern Highway
Mount Wellington Hwy On RampSouthern Motorway
Southern Motorway
Southern Motorway
South-Eastern Hwy Of fRam
p
Mount Wellington Hwy On Ramp
Clemow Drive
COPYRIGHT© Auckland Council
0 100 200 M
Metropolitan Centre that has a General Business zone within 400m
Legend400m buffer from Metropolitan Centre
Unitary Plan Base ZoneMetropolitan CentreGeneral Business
Sylvia Park
Main
Stree
t
Ballia l Place
Fernhill Drive
Trig Road
Main Street
Rua Road
Westgate Drive
Don B
uck R
oad
Asti Lane
Lazuri
te Drive
Cinnabar Pla ce
Westgate Drive
Pinot Lane
Stonegate Close
Rush Creek Drive
StMa
rgaret
Place
Trusco
tt Place
Fitzh
erbert
Aven
u e
Whit shire Mews
Tahi Road
Alloway Street
Westgate Drive
Fernhill Drive
Hueglow Rise
Trig Road
Alloway Street
Woodh
ousePlace
Westgate Drive
Rima Road
Holmes Drive
Rua Road
Oreil Avenue
Waru Road
Fred Taylor Drive
Lazurite Drive
Hobsonville Road
Don B
uck R
oad
Carne
lianCo
urt
Fred Taylor Drive
Beauchamp Drive
St Catherine Crescent
Richfi
eld Cr
esce
nt
Westgate Drive
Jade
wynn
Drive
Waru Road
Holme
sDrive
St Cath
erine
Cres
cent
Regen ts Park
Place
Main Street
Rua Road
Cabernet C rescent
Richf i
eldCre
s cen
t
Hobsonville Road
Tahi Road
Toru Road
Arlose Place
Rush Creek Drive
Uppe
r Harb
our M
otorwa
y
Reybert Place
RuaRoad
D onB
uckR
oad
Fred Taylor Drive
Rima Road
Rua RoadUpper Harbour Motorway
Oreil
Aven
ue
FresilLane
Trig Road
Hobsonville Road
Don B
uck R
oad
North-Western Motorway
Westga te Drive
Fred Taylor Drive
TrigRoad
Off Ramp
Oreil Avenue
Oreil Avenue
Hobsonvil leRoad Off Ramp
Jadewynn Drive
Upper Harbour Motorway
Tahi Road
Westgate Drive
North-Western Motorway
Fred Taylor Drive
R uz e Vida Drive
Tahi Road
Uppe
r Har b
our M
otorwa
y
Baker La
ne
North-Western MotorwayNorth-Western Motorway
North-Western Motorway
North-Western Motorway
Hobsonville Road Off Ramp
North-Western Motorway
Hobsonville Road On Ramp
North-Western Motorway
Upper Harbour Motorway
Upper Harbour Motorway
North-Western Motorway
COPYRIGHT© Auckland Council
0 110 220 M
Metropolitan Centre that has a General Business zone within 400m
Legend400m buffer from Metropolitan Centre
Unitary Plan Base ZoneMetropolitan CentreGeneral Business
Westgate / Massey North
Hi llsboroughEA
TON
ROAD
CLIFTO
N ROAD
HILLS
BOROUGH ROAD
ALEXBOYD
LINK
PREN
TICE P
LACE
WHITMO
RE RO
ADNOTON ROAD
KATHRYN AVENUE
RICHARDSON ROAD
FLORENCE DALY PLACE
ALDERSGATEROAD
ROGAN STREET
STAVELEY AVENUE
OAKDALE ROAD143
397
833
1920
CINDY PLACE
EDGEWATER DRIVE
SNELL PLACE
CHEVIS PLACE
MIRAMAR PLACE
WHEATLEY AVENUE
MARRIOTT ROAD
MANGOSPLACE
ROSE
BURN
PLAC
EOPAL AVENUE
TI RAKAU DRIVE
CARDIFF ROAD
887
3263
WHITE SWAN ROAD
LYNBROOKE AVEN
UE
DONOVAN STREET
SHIPT
ON PL
ACE
BOUN
DARY
ROAD
LYNFIELD PLACEMC
FADZ
EAN
DRIVE
GILL
ETTA
ROA
D1008
3013
COEY PLACE
JOHN WEBSTER PLACE
NANDANA DRIVE
GLENGARRY ROADSH
AHPLACE
MATAMA ROAD
PUKETITIRO STREET
PHILLIP AVENUE
LEO
STRE
ET
KOTIN
GAAV
EN
UE
ROSIE
RRO
AD
SHETLAND STREE
T
262
1028
MCGREGOR STREET
DOMI
NION
ROAD
ANITA AVEN
UE
KATAV I C H PLAC
E
DOMINION ROAD
EXTE
NSION
GLAS
S ROA
D
REVE
L AVE
NUE
FREER STREET
SANFT AVE N UE
PLAYFAIR
ROAD
MORRIE LAING AVENUE
CORMACK STREET
NASH
ROAD
BUDGEN STREET
HOWELL CRESCENT
BURN
ETTA
VENU
E
RICHARDSON ROAD
1293
1631
1672
1738
2179
KELSEY CRESCENT
HILLSBOROUGH ROADCARLTON STREET
LITTLEJOHN STREET
HENDRY AVENUE
MELROSE ROAD EAST
ROGERS WAY
HILLSBOROUGH ROAD OFF RAMP
SOUTH-WESTERN MOTORWAY
CURRIE AVENUE
BELFAST STREET
HILLSBOROUGH ROAD ON RAMP
597
709
739
MOUNT SMART ROAD
MANUKAU ROAD
GREY STREET
ERSON AVENUE
PARK GARDENS
MATIER
E ROA
D HILL STREET
QUADRANT ROAD
SYMO
NDS S
TREE
T
TRAFALGAR STREET
NORMANSHIL
L ROA
D
INKERMAN STREET
FORB
ES ST
REET
1157
1543
GALWAY STREET
WAIAPU LANE
JORDAN AVENUE
YATES STREET
BRAYS RISE
HARDINGTON STREET
BROOKFIELD AVENUEMARIRI ROAD
JUBILEE AVENUE
CAME
RON
STRE
ET
WADE
AVEN
UE
HILL STREET
ARTHUR STREET
TRAFALGAR STREET
GREY STREET
HARBOUR VIEW TERRACE
MOUNT SMART ROAD
ONEHUNGA MALL
CARDWELL STREET
SELWYN STREET
1121
2019
7406
MAYS ROAD
TREASURY PLACERO
OSEV
ELTAVENUE EDMONTON AVENUE
WAITANGI ROAD
GAMBIA PLACESTATE AVENUE
BOW PLACE
HULL PLACE
MOUNT SMART ROAD
CAPTAIN SPRINGS ROAD
FELIX
STRE
ET
1379
1410
1582