Statement of evidence of Mark Gauntlett...

Statement of evidence of Mark Gauntlett Tansley

Dated: 30 July 2014

REFERENCE: JM Appleyard ([email protected])

TA Paddock ([email protected])

in the matter of: the Resource Management Act 1991

and

in the matter of: submissions and further submissions by Christchurch

International Airport Limited on proposed plan change

84: Special Purpose (Airport) Zone to the Christchurch

City Plan

2

STATEMENT OF EVIDENCE OF MARK GAUNTLETT TANSLEY

1.0 INTRODUCTION, EXPERIENCE & SUMMARY

1 My name is Mark Gauntlett Tansley and I am a Statistical and

Retailing Consultant, based in Auckland.

2 I am a Registered Property Consultant under the auspices of the NZ

Property Institute and the sole proprietor and director of

Marketplace New Zealand Limited, which is a consultancy providing

advice, information and evidence on growth and demographics,

retail planning and related resource management matters. I have

forty-seven years of professional experience, throughout New

Zealand, and have been called as an expert witness for forty-two of

those.

3 While this is a Council hearing, I acknowledge I have read and I

comply with the Environment Court’s Code of Conduct for Expert

Witnesses contained in the Environment Court Practice Note 2011 in

presenting this statement. Other than where I state that I am

relying upon the evidence of another person, the evidence in this

statement is within my area of expertise. I have not omitted to

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

the opinions which I express below.

1.1 Airport-related Experience

4 I have undertaken strategic work on retail and commercial activities

for Palmerston North City Council since 2002. In 2012/13, I

participated in the development of proposed Plan Change Nº 12,

concerning Objective, Policy and Rule amendments for Palmerston

North Airport's "Airport Zone". The draft Plan Change has gone

through a public submission process and formal notification is

expected in two months' time.

1.2 Canterbury Experience

5 I have undertaken work in Christchurch and Canterbury for most of

my professional career. In 1997, I was engaged to advise the

owner of the Northwood / Belfast Supa Centa, in their objective of

bringing it up to capacity. In 2001, I was approached by CCC

personnel to advise Council in relation to commercial provisions in

its earlier notified review of the City Plan. I was subsequently

released by my then employer to undertake that work, which, in due

course, gave rise to the preparation of Variation 86.

6 In 2005, I was asked to assist CIAL in an endeavour to obtain

consent for a retail / commercial development on the site

immediately east of the now consented Spitfire Square

development. I presented evidence on behalf of CIAL to the

Environment Court in July 2005. In 2006, my primary work for

CCC had culminated in the notification of Variation 86. I was then

released by CCC to work on an extended Belfast project, provided I

3

supported the Variation in subsequent proceedings, which I did. I

was also actively involved as a peer reviewer of other proposals, for

CCC, during this period.

7 In mid-2008, I was reapproached by CIAL to assist concerning a

resource consent application for a revised commercial development.

(This may well have related to what is now described as Spitfire

Square.) However, I declined due to a prospective conflict of

interest. My work on Belfast ultimately contributed to what became

proposed Plan Change 22, culminating in appeals heard in the

Environment Court from October 2010 to November 2011, due to

the implications of and after the 22 February 2011 earthquake.

8 I was first approached to ascertain whether I could provide evidence

in support of CIAL's position on proposed Change 84 ("PC84") in

June 2014. I do support it, in relation to Airport retailing and the

related planning context, on which my evidence focuses.

1.3 Scope of My Statement

9 Proposed PC84 has been developed and notified in order to provide

a clear policy framework for the SPAZ (in the absence of such in the

operative Plan) and consequent clarification concerning the intended

scope of, and procedures in relation to activities outside those

provided for by the designation. However, as noted in its

Explanation, the Change is not isolated from ongoing issues facing

activities in the City, with particular emphasis on recovery from the

2010/2011 earthquake events and on potential adverse

distributional effects on centres and communities. My statement

addresses those matters.

9.1 In topic 2.0, I have provided an overview concerning changes

in the City's population, dwelling / household and

employment counts to March 2013 and on the changes in the

level of retail trade, with a particular emphasis on outlets

selling hardware, building and garden supplies, to March

2014.

9.2 Topic 3.0 is directed to a brief overview of relevant aspects of

the broad planning context within which PC84 has been

prepared. The Airport's Master Plan is also discussed, given

the extent to which it falls within both the Airport designation

and the SPAZ.

9.3 In Topic 4.0, I discuss PC84 as notified, aspects of the s32

report which supports its provisions and exclusions and the

submissions of CIAL and others on commercial matters

arising from the Change.

9.4 In Topic 5.0 I set out the opinions that I have reached

concerning the submissions, with reasons.

9.5 In Topic 6.0, I comment on the section 42A report and

evidence of Mr Tim Health.

4

10 Acronyms or abbreviations previously used in this statement and/or

subsequently introduced are listed below, in alphabetical order.

au(s) area unit(s)

CBD Christchurch Central Business

District

CCC Christchurch City Council

CIAL Christchurch International Airport

Ltd

City Christchurch City (geographic)

City Plan The Plan

comparison

shopping

Shopping for specialised and

durable goods such as appliances,

furnishings, clothing and jewellery

as distinct from food, groceries

and toiletries

CRTI Christchurch Retail Trade

Indicator (Statistics NZ)

gfa gross floor area

gla gross leasable area – that part of

a building's gfa that is solely

occupied by lessee activities

Greater

Christchurch

Christchurch City and adjacent

areas within the Christchurch

Urban Development Strategy

KAC Key Activity Centre

lfr Large format retailing

LURP The Land Use Recovery Plan

MP Airport Master Plan

PC84 Proposed Plan Change 84

PER 2013 The Property Economics Report

for Council dated August 2013

Qtr One quarter of a calendar year

5

RMA Resource Management Act 1991

RPS Regional Policy Statement

RTS NZ Retail Trade Survey (Statistics

NZ)

SPAZ Special Purpose (Airport) Zone

1.4 Summary of my Conclusions

11 In this evidence, I provide information in sections 2.0, 3.0 and 4.0

concerning real-world changes in Christchurch since the March 2011

year (which encompassed the main earthquake events); a

contextual breakdown of the RMA background as it provides a

baseline for the Objectives and Policies of PC84; then a summary of

the PC84 provisions and submissions thereon. I provide my

opinions concerning the submissions in topic 5.0; then my views on

the s42A Report and related evidence in topic 6.0.

12 Insofar as topic 6.0 is concerned, I have reached strong views,

supporting and reinforcing my earlier decision that CIAL's

submissions were soundly based. My evidence on these matters is

therefore robust. In summary, it conveys the following opinions:

12.1 There is reliable evidence in the public domain to support the

view that retail activity in post-earthquake Christchurch is,

for the most part, very buoyant. In the absence of

recognition of such buoyancy by Council witnesses, CCC has

developed PC84 in the immediate post-earthquake mode of

conservatism, rather than the evolving recognition of retail

and commercial realities.

12.2 The main issue in dispute in this case revolves around

whether, or the extent to which, PC84 should enable the

development of trade supplier activities within the SPAZ, as a

permitted activity. From CIAL's viewpoint, trade supply

outlets are those defined in the City Plan.

12.3 The totality of the information relied upon by the s42A

reporting planner does not justify either the exclusion of

trade supplier activities from the notified permitted provisions

of PC84, or the proposed but entirely different s42A Report's

recommendations, masquerading as a trade supply response,

for which no justification or provenance exists.

12.4 In essence, my opinion in sub-paragraph 12.3 reflects the

fact that the PER 2013 attributable to Mr Heath supported a

provision to enable trade suppliers to establish in the SPAZ,

whereas that opinion was obfuscated and effectively ignored

in Mr Heath's evidence in support of PC84. It was not

6

explicitly countermanded, nor was the change of opinion

explained in Mr Heath's evidence.

12.5 The outcome of the s42A Report is that some notional

activities described as "wholesale trade suppliers" are

proposed (subject to a small aggregate threshold) to be

added to the list of permitted SPAZ activities in Rule 3.4.2(b)

18. This is a "Clayton's" provision, because the activities

purported to be enabled do not exist, the response to the

submissions is arguably "ultra-vires" and certainly irrelevant,

in my view.

12.6 On the basis that the foregoing is perceived to be the most

appropriate rule outcome for trade supply activities in the

SPAZ, alterations to both notified Objective 12.12 and Policy

12.12.1 are recommended in the Report. In my opinion,

these represent an inappropriate "bottom-up" or "bottom-

driven" approach to policy formulation, completely opposed

to the "top-down" requirements of s32 of the RMA, in relation

to the formulation of plan reviews and changes.

13 For the above reasons, as expanded in my ensuing evaluation, I fully

support the CIAL submissions on PC84.

2.0 CITY OVERVIEW

14 Christchurch urban area differs from New Zealand's other two main

urban areas in that for the most part, it is compact and continuous,

rather than a series of connected, but relatively distinct sub-areas,

as is the case for Auckland and Wellington. Both for those living

within Christchurch City (other than south of Lyttelton) or entering it

at one of the gateways, a choice of commercial centres, including the

CBD, is readily available. The disruption of shopping opportunities

in and after the 2010/11 year was less than could otherwise have

been the case, because of the City's compactness. Patronage was

in the main simply diverted to alternative centres, or to locations in

which retailers and other commercial operators were able to relocate

and remain accessible.

15 From my experience outlined in sub-topic 1.2, I consider that the

distribution and hierarchy of centres was effective prior to the

earthquakes. In principle, the centre devastation wrought by the

earthquakes has not altered the appropriateness of the City Plan's

operative retail / commercial strategy, though it has redistributed

both demand for and the supply of retail and commercial activities.

I have summarised some of the implications and outcomes below.

In so doing, I have grouped together the census aus containing or

east of the Airport, which I refer to as the North-Western Area. This

is not intended to be regarded as a trade catchment, simply a

proximate swathe of the City. This area is shaded blue on a copy of

the CCC Area Unit Map, in Appendix One.

7

2.1 2013 Census

16 The five-yearly Census of Population and Dwellings scheduled for

March 2011 was abandoned for NZ as a whole as a consequence of

the main February 2011 earthquake. The census was undertaken in

March 2013, to better capture outcomes in and around the City and

at the regional level. In Appendix One, I have summarised salient

2013 results (with 2006 and 2001 equivalents) for population,

dwellings and employment. Parts of the first two tables are

reproduced as Tables 1 and 2, which follow.

2.2 Population

17 Table 1 summarises 2001-2013 population data, as published in the

2013 Census, for areas as then defined1. This shows that after solid

growth from 2001 to 2006, there was, in the seven years to March

2013, a 2.0% decline in the City's usually resident population, and a

3.1% drop in the census-night counts. In the North-Western Area,

both 2013 counts increased (more rapidly than from 2001 to 2006)

and its share of the City's population increased. Looking at changes

from 2001 to 2006, the City's usually resident and census-night

counts were very close to the NZ trend.

TABLE 1 : POPULATION CHANGES 2001-2013 (2013 Census - Statistics NZ)

2001 Population 2006 Population 2013 Population

Usually Census Difference Usually Census Difference Usually Census Difference

Resident Night - Resident Night - Resident Night -

North-Western Area 33,315 33,420 +105 34,878 35,442 +564 35,919 36,798 +879

Percentage of City 10.3% 10.0% 1.2% 10.0% 9.8% 4.2% 10.5% 10.5% 9.3%

CHRISTCHURCH CITY 324,078 333,195 +9,117 348,456 361,965 +13,509 341,469 350,889 +9,420

Change from prev census N/A N/A - 24,378 28,770 - -6,987 -11,076 -

Changed Percentage N/A N/A - 7.5% 8.6% - -2.0% -3.1% -

NEW ZEALAND 3,737,280 3,820,749 +83,469 4,027,947 4,143,282 +115,335 4,242,048 4,353,198 +111,150

Change from prev census N/A N/A - 290,667 322,533 - 214,101 209,916 -

Changed Percentage N/A N/A - 7.8% 8.4% - 5.3% 5.1% -

Geographic Area

2.3 Dwelling Units

18 Table 2 summarises dwelling unit changes over the same time-span,

backed up by Table 2A in Appendix One. This shows that while

the City's 2013 dwelling count was some 4,000 higher than in 2006,

the proportion vacant had almost doubled, with occupied dwellings

down by 3.1% on 2006. In the North-Western Area, despite an

increased proportion of vacant dwelling units, the occupied count

was consistent with the 2006-13 population trends. In the rest of

NZ, the occupied dwelling increase was 7.2%, but for the Country as

a whole, Christchurch's loss reduced the gain to 6.2%. Reverting to

2001-06 occupied dwelling changes, the City's growth of 6.8% was a

little below the NZ-wide gain of 8.1%.

1 Census area units in some parts of the City had been reconfigured since 2006.

8

TABLE 2 : DWELLING CHANGES 2001-2013 (2013 Census - Statistics NZ)

2001 Dwellings 2006 Dwellings 2013 Dwellings

Occupied Vacant Total Occupied Vacant Total Occupied Vacant Total

North-Western Area 12,288 534 12,822 12,726 552 13,278 13,269 636 13,905

Change from prev census - - - 438 18 456 543 84 627

Changed Percentage - - - 3.6% 3.4% 3.6% 4.3% 15.2% 4.7%

CHRISTCHURCH CITY 126,654 9,336 135,990 135,270 9,478 144,748 131,010 17,784 148,794

Change from prev census - - - 8,616 142 8,758 -4,260 8,306 4,046

Changed Percentage - - - 6.8% 1.5% 6.4% -3.1% 87.6% 2.8%

NEW ZEALAND 1,368,207 147,435 1,515,642 1,478,709 159,273 1,637,982 1,570,695 185,445 1,756,140

Change from prev census - - - 110,502 11,838 122,340 91,986 26,172 118,158


Geographic Area

2.4 Job Distribution

19 Table 3 summarises the assessed employment level attributable to

the Yaldhurst au in 2006 and 2013, compared with that of the rest of

the City and the City as a whole. Tables 3A and 3B in Appendix

One, together with their explanation, provide the assessed Table 3

counts. However, these are subject to the caveat that the Yaldhurst

data, incorporating all Airport activity but no other Business-styled

Zones, will be understated by comparison with City or Regional

totals. This is explained in sub-paragraph 4(5) of the Appendix.

20 The Yaldhurst au results essentially reflect new dwelling activity

south of the Airport and job growth within or related to the Airport

and its SPAZ. The increased workplace counts represent an average

annual increase of 7% pa and were not influenced by major

construction work at Census 2013 time. In other words, the growth

trend was based mainly on increased long term job demand, albeit

recognising that some displaced CBD workers could return to their

former job location.

9

TABLE 3 : EMPLOYMENT CHANGES 2006-2013 (2013 Census - Statistics NZ)

Workers by Residential Location Workers by Job Location*

2006 2013 Change 2006 2013 Change

Yaldhurst au 378 798 +420 3,434 5,479 +2,045

Rest of City 177,729 172,812 -4,917 188,395 187,810 -585

Christchurch 178,107 173,610 -4,497 191,829 193,290 +1,461

Rest of Region 91,587 104,049 +12,462 79,134 88,420 +9,286

Canterbury 269,694 277,659 +7,965 270,963 281,710 +10,747

*Job Location values adjusted by Marketplace to account for under-reporting and

non-fixed location workplaces.

Note: All census data of this kind is randomly rounded so values do not necessarily sum

exactly.

Geographic Area

2.5 Evaluation

21 In the 2001-06 inter-censal period, the City's resident population

and occupied dwelling growth was close to but below the national

trend, while the census-night counts suggest that its non-resident

(visitor) counts had grown slightly more strongly than the rest of the

Country, over that period.

22 The foregoing results unequivocally indicate that within the City

boundaries, consequences of the 2010 and 2011 earthquakes were

that there remained a material displacement of resident population

and of occupied dwellings as at March 2013, two years after the

most devastating earthquake. The effect was greater in the census-

night population results, probably reflecting a greater post-

earthquakes decline in visitors to the City than of usual residents.

23 In terms of usually resident population, the City's 2013 count was

roughly equivalent to the count it had passed in about September

2004. In terms of occupied dwellings, the 2013 census revealed

that the count had returned to a level earlier reached about June

2003. (The comparison indicates an increase in average dwelling

occupancy in 2013, relative to 2006.) Numerically, the City lost

about 9 years of growth in those terms.

24 It is, of course, a fact that nearly all of the "losses" referred to above

were displacements, very marked by increases in Selwyn and

Waimakariri Districts, a lesser stimulus in other parts of Canterbury,

and to some extent, the rest of the Country. A modest proportion

appear to have left New Zealand on a long-term basis.

25 Table 3 shows salient 2006-2013 employment changes, in the wider

context:

10

25.1 Some 4,500 fewer workers were housed in the City in 2013,

consistent with the declines in both usually resident

population and dwelling counts, as shown in Tables 1 and 2.

25.2 However, this loss was more than offset by gains in resident

workers outside Christchurch, lifting the employed resident

labour force count by about 8,000, within the Region. These

gains mainly occurred in Selwyn and Waimakariri Districts.

25.3 Some of the increase in workers by residence referred to in

sub-paragraph 0 above were employed in Christchurch, lifting

its 2013 workplace (job) count to record a small increase

(some 1,500 more than the 2006 tally).

25.4 However, most of the net increases in regional workplaces

occurred outside the City.

25.5 Given the City's occupied dwelling decline of some 3%

between 2006 and 2013, the increase in employment in and

near the City has contributed to a more buoyant retail scene

than might otherwise have been expected. This will be

discussed in sub-topic 2.6.

26 My comment that the assessed Yaldhurst employment count is

conservative is confirmed (or at the very least, not contradicted) by

a study undertaken in 2012 for CIAL, found in the 2013 Airbiz

report2, at the top of p35. This exercise disclosed that nearly 6,000

full- and part-time Airport jobs existed, prior to the 2013 census. If

employment growth in Yaldhurst continues at an average of about

300 jobs annually to March 2018, there will be some 7,000 or more

jobs within the Airport campus by March 2018. That would be

equivalent of the entire labour force of well over 5,000 households,

which would be equivalent to a township and associated rural

catchment the size of Kaiapoi and environs in 2013. This alone

would generate spending power to support a much wider range of

retailing and associated commercial activities within the SPAZ than

now exists, albeit that most of such expenditure would be home-

based (i.e. on a trip emanating directly or indirectly from home),

rather than work-based.

27 Finally, I would note that PC84's identification of 5.5 million

travellers in 2011 is likely now greater, with the acceleration of the

City's recovery and also of tourism generally. These people, along

with greeters, farewellers, delivery drivers and other non-travelling

visitors, such as company reps and consultants, will make different

and better use of the Airport if its commercial offer is expanded.

2.6 Retail Sales Trends

28 In the foregoing analysis, I have focused on the City and provided

comparisons with New Zealand data. This is because as a

2 Christchurch Airport Land Use Zoning, Airbiz, 1 August 2013 (Appendix 5 to the Section 32 Report for PC84)

11

consequence of the earthquakes' physical damage, to the CBD in

particular, Statistics NZ quickly introduced a quarterly Christchurch

Retail Trade Indicator ("CRTI") as a subset of its quarterly Retail

Trade Survey ("RTS") for NZ as a whole. The March 2014 Qtr

version is attached to my statement, as Appendix Two. It relates

to Christchurch City only and to seasonally-adjusted sales, not actual

sales.

29 A graph on the front page of the March 2014 CRTI commences at the

March 2006 Qtr and reflects retail and hospitality trends to the March

2014 Qtr. "Retail" includes automotive and fuel sales, while

"hospitality" includes commercial accommodation and food and

beverage services (bars, restaurants, cafés, takeaway/fast food etc)

so the lines on the graph are not representative of only bricks and

mortar shops. However, their import as a reflection of wider

commercial trends is clear:

29.1 From the March 2006 Qtr to June 2010, the two lines follow

very similar paths, indicating that the City's trade was a close

mirror of the Country's.

29.2 However, the City line fell below the NZ trend for the last

three Quarters of the 2010/11 year, before recovering much

of that lost ground in the June 2011 Qtr.

29.3 After more or less holding ground to the end of the 2011

calendar year, the City has trended up faster, crossing the NZ

trend-line around September 2012 and continuing to lift

above it in and from the March 2013 Qtr. This is no doubt

largely driven by insurance-funded replacement of both

homes and possessions.

30 The trends discussed above provide an interesting comparison with

the population and dwelling trends in Tables 1 and 2. Whereas the

City's 2013 counts effectively returned the City to its 2004

components, its retail / hospitality trade was up about 25% from

2006-2013. Some of this is inflation, but the full general

merchandise basket price index has actually fallen (since both 2004

and 2006) so that will have curbed the inflation component.

Besides, any inflation component is, for practical purposes, common

to both lines on the graph.

31 Both the RTS and CRTI include tabular data, including actual – as

distinct from seasonally adjusted – sales. In Table 4, I have

provided comparable actual sales data for the 2009/10 year, out to

the 2013/14 year, with comparisons based on the former. For this

Table, it is possible to exclude the hospitality categories included in

the CRTI graph, but automotive trade is still included. The shaded

central columns reflect national totals from the RTS, for each Qtr

shown. As to the rest of Table 4:

12

31.1 To the left, NZ is split into Christchurch City (data drawn from

the CRTI) and Rest of NZ, the difference between the first

and third columns.

31.2 To the right of Table 4, the NZ sales attributed to Hardware,

Building and Garden Supply stores are distinguished from the

other retail categories which make up the total. There is no

equivalent breakdown in the CRTI.

32 Looking first at the City, the early point of significance is that retail

trade did not decline on a year-by-year basis as a consequence of

the earthquakes. In fact, the only Qtr in which Christchurch sales

fell was that of March 2011. Even in the following Qtr (June 2011)

the City's retail sales were ahead of June 2010. For the 2010/11

year as a whole, the City's sales were up by 2.9%, not far short of

3.4% for the rest of NZ, or 3.3% for the Country. In subsequent

years:

32.1 In 2011/12, City retail trade was up by 8.5% on 2009/10,

even closer to the national trend than in 2010/11. In and

from part-way through 2011/12, the City's retail growth was

outpacing the Country's.

32.2 In 2012/13, the second year after the main earthquakes, the

City's retail sales increases from 2009/10 grew at more than

double the national rate, to be more than 16% ahead of the

2009/10 level. On a year-by-year basis (2012/13 v

2011/12) Christchurch's sales were up by 7.1%, whilst in the

rest of NZ, sales were up by 2.8%, giving a NZ average gain

of 3.2%.

32.3 In 2013/14, City retail sales grew at more than three times

the rate of the rest of the Country, relative to the 2009/10

base year. Compared with the previous year, Christchurch

sales were up 8.9%, whereas in the rest of the Country, the

increase was 2.9%.

33 The righthand columns of Table 4 provide a particular comparison

which, to a material extent, explains the City's recently accelerating

retail trend. From the 2009/10 base year, the hardware, building

and garden outlet group maintained pace with other shop-types to

2012/13 (albeit with poor results in 2011/12) but in the year to

March 2014, the year-on-year sales growth was 11.8% for the

hardware etc category, but only 2.7% for other store categories.

This divergence is discussed in sub-topic 2.7 below.

13

TABLE 4 : COMPARISON OF CHRISTCHURCH CITY AND NEW ZEALAND RETAIL

SALES AS PUBLISHED BY STATISTICS NZ

Unadjusted Sales Unadjusted Sales Unadjusted Sales Unadjusted Sales Unadjusted Sales

Jun 1,145 11,687 12,832 1,001 11,831

Sep 1,181 11,931 13,112 1,067 12,045

Dec 1,340 13,489 14,829 1,231 13,598

2010 Mar 1,205 12,207 13,412 1,113 12,299

2009/10 Year 4,871 N/A 49,314 N/A 54,185 N/A 4,412 N/A 49,773 N/A

Jun 1,241 12,260 13,501 1,126 12,375

Sep*¹ 1,226 12,322 13,548 1,159 12,389

Dec 1,367 13,669 15,036 1,243 13,793

2011 Mar*² 1,177 12,723 13,900 1,089 12,811

2010/11 Year 5,011 2.9% 50,974 3.4% 55,985 3.3% 4,617 4.6% 51,368 3.2%

Jun 1,284 12,790 14,074 1,085 12,989

Sep 1,267 12,899 14,166 1,124 13,042

Dec 1,439 14,597 16,036 1,255 14,781

2012 Mar 1,293 13,297 14,590 1,130 13,460

2011/12 Year 5,283 8.5% 53,583 8.7% 58,866 8.6% 4,594 4.1% 54,272 9.0%

Jun 1,328 13,332 14,660 1,133 13,527

Sep 1,371 13,128 14,499 1,196 13,303

Dec 1,568 14,968 16,536 1,400 15,136

2013 Mar 1,391 13,656 15,047 1,247 13,800

2012/13 Year 5,658 16.2% 55,084 11.7% 60,742 12.1% 4,976 12.8% 55,766 12.0%

Jun 1,464 13,591 15,055 1,292 13,763

Sep 1,468 13,646 15,114 1,373 13,741

Dec 1,705 15,470 17,175 1,529 15,646

2014 Mar 1,526 13,986 15,512 1,367 14,145

2013/14 Year 6,163 26.5% 56,693 15.0% 62,856 16.0% 5,561 26.0% 57,295 15.1%

Note: All Christchurch Sales Values are provisional.

All New Zealand Sales Values are as updated retrospectively.

NZ excluding Christchurch and All Other NZ Sales Values are derived from NZ and NZ Hardware etc data.

Percentages calculated by Marketplace NZ.

All Values exclude gst and also exclude accommodation and food and beverage services.

*¹ Quarter of September 2010 earthquake.

*³ Quarter of February 2011 earthquake.

Inc on

09/10$m

Inc on

09/10$m

Inc on

09/10$m

Inc on

09/10$m

Inc on

09/10

CHRISTCHURCH

CITY

NZ EXCLUDING

CHRISTCHURCH

CITY

NEW ZEALAND

NZ HARDWARE,

BLDRS & GARDEN

SUPPLIERS

ALL OTHER NZ

RETAIL

CATEGORIES

$m

34 As noted in sub-paragraph 31.2, the CTRI does not publish a

breakdown by retail category of its sales data. However, in my

opinion, the City's unusually accelerating retail sales will have been

significantly attributable to the hardware etc group. Much of the

national sales disparity in the righthand columns of Table 4 can be

attributed to a more significant increase in demand in Christchurch

and to a lesser extent (but on a larger scale) enhanced demand in

14

Auckland. The former attribution is confirmed in general terms at

the top of p3 of the attached March Qtr RTS.

2.7 Implications of the Sales Trends

35 Salient aspects of the sales trends in the City column of Table 4

(even allowing for the special impetus provided by hardware,

building and garden supply outlets) include these, in my opinion:

35.1 Despite the substantial demolition of the CBD and damage of

varying extents to fringe CBD and non-CBD City retail areas

in 2010/11, turnover inside the City boundary was ahead of

the preceding years and grew in each ensuing year. This

means, incontrovertibly, that substantial and ongoing windfall

trade has been and is being enjoyed by most of the City's

retail centres (other than where adverse local effects have

outweighed the broader-based benefits).

35.2 The CBD's outreach beyond the City boundaries originally

disappeared and remains limited. It is increasingly apparent

that the CBD's foreseeable recovery – especially in retail

terms – will be slow and of relatively limited extent,

compared with its role prior to 2010/11.

35.3 In considering the extent to which retail development on the

Airport could adversely impact, either on the CBD retail

recovery, or on centres that continue to benefit from

earthquake damage elsewhere, regard should be had to the

Table 3 trends and the actual and potential diversion of

housing growth to the City's north and south-west and to

other parts of Greater Christchurch, including the City's

north-western suburbs.

35.4 The accelerated demand for hardware, building and garden

supplies in Christchurch has clearly ramped up substantially

over a short period, during which appropriate supply

responses have not been possible. There is a rapidly

growing gap between demand and supply, in this category.

36 The above implications are in my view, relevant to Plan Change 84

and submissions upon it. I shall be referring to them subsequently.

3.0 PLANNING CONTEXT

3.1 Statutory Plans

37 As I understand matters, the LURP has added a new Chapter 6 to the

Canterbury RPS, to provide provenance for necessary amendments

to the three affected District Plans. In the City Plan's case,

significant amended or new provisions have been adopted, whilst the

LURP directs ongoing actions to be implemented in the City Plan, by

the City and within specified time frames, to give effect to the RPS.

15

38 The position I have taken is that while there are specific statutory

requirements in terms of s75(3) of the RMA for City Plan provisions

to give effect to the RPS, where these regional provisions are

intended to be changed as a result of LURP directives, there is a

statutory requirement to not be ‘inconsistent’ with the LURP. To the

extent that this statement refers to such matters, my comments are

set out in Topic 5.0 sub-topic 5.1.

3.2 City Plan Issues

39 The City Plan was prepared in a format which elevated the Issues for

Christchurch to Volume 1 of the Plan. Whilst such an approach

(enunciating issues) is no longer mandatory, an advantage of so

doing is to provide a real world context for the Objectives. Issues

are problems justifying intervention, to which Objectives are the

response. PC84 reinforces that connection by introducing

amendments to Volume 1, Chapter 3, at 3.15.9 and 3.18.3.

40 Given that the context for all Objectives, including proposed new

Objective 12.12 is that spelt out in the Plan's Issues, I have scanned

the summaries of issues for sub-Chapters 3.11, 3.13, 3.15, 3.17 and

3.18, which appeared to me to be the most likely to provide

provenance for Objective 12.12 as notified, were it adopted.

"3.11.7 Summary of business issues a. existing commercial centres, in particular the central city and

district centres, represent an agglomeration of significant resources,

play important roles in providing for the economic and social well-

being of the city and have an associated value and range of benefits to

the community; this presents challenges for the identification of

appropriate mechanisms to ensure that such resources are sustainably

managed for existing and future communities.

(emphasis in text added)

b. retailing in new localities, or the expansion of existing centres,

may improve access to goods and services and better enable people

and communities to meet their social and economic needs. However,

any change in the pattern of distribution of commercial centres can

result in particular adverse effects or require consideration of linkages

with other aspects of urban form, including the following:

….

- impact upon existing centres, the significance of the impact,

and whether there is a likely reduction in social and

economic function and amenity of those centres;

- consequential impacts upon the ability of existing centres to

function as focal points contributing to the wellbeing of

people and communities; and

- whether affected centres have outlived their original

historical function and whether the rate of transition is such

as to maintain an appropriate level of function and amenity.

….

16

d. the central city, as a diverse urban environment providing the

greatest scale and intensity of business activities, may struggle to

maintain its role if there is significant dispersal of retail/commercial

activity even with alternative methods of support. ….

3.13.10 Summary of community issues

….

i. the role of suburban centres in providing a focus for local

community activities and buildings accessible to the community. ….

3.15.10 Summary of transport issues

….

k. the provisions that need to be made for the future operations of

Christchurch International Airport, including intensification within, and

outward growth of, the airport, and the impacts of traffic and noise on

the roading network and residential areas. ….

o. potential effects upon the transport network of new commercial

activities, centres and (out of zone) expansion of existing centres.

p. the costs of upgrading the road network to safely and efficiently

accommodate activities generating high levels of vehicle trips, where

necessary and where it is appropriate. ….

3.17.7 Summary of city form and design issues

….

3.18.5 Summary of growth issues

….

j. the effects on future growth directions of a number of important

existing activities, such as the airport, sewage treatment works and

major recreation facilities and some agricultural activity.

….

l. the potential effects of any dispersal of retailing and related

activities on any local or wider community, in terms of reduced access

to consolidated shopping and communal facilities."

41 Other Issues, which follow "d" under the 3.11.7 Summary, have not

been quoted above, given the earthquake events that succeeded

their adoption. LURP-related provisions appear to over-ride them.

The City Form and Urban Design sub-Chapter does not, in my

opinion, identify any matters that are particularly relevant to PC84's

distributional content.

42 My opinions in Topic 5.0 have regard to the above City Plan issues.

17

3.3 Airport Master Plan ("MP")

43 The MP, dated July 2006, devotes its Section 4 to "Land Use

Planning". From its Tables 4-1 and 4-2, the following information is

available:

43.1 CIAL's interest in the Airport and environs (plus non-CIAL

interests within the Airport designation) may be tabulated as

follows (with approximate areas in rounded hectares):

Designation SPAZ Outside Total

CIAL Freehold in Designation & SPAZ

668 668 0 668

CIAL Freehold in SPAZ/not Designation

0 15 0 15

CIAL Freehold in Designation/not SPAZ

53 0 0 53

CIAL Freehold Outside Designation/SPAZ

0 0 45 45

CIAL Freehold Sub-Total

721 683 45 781

CIAL Leasehold in Designation

163 0 0 163

Total CIAL Interest 884 683 45 944

Non-CIAL Interests 28 28 0 28

Area Totals (excl roads)

912 711 45 972

43.2 Table 4-2 allocates 756ha in its righthand column, to the land

use analysis of land (excluding roads) within the SPAZ, plus

CIAL holdings outside the SPAZ (711ha plus 45ha). This

includes 15ha which lies outside the Airport designation, as

shown in the second line of the detailed floorspace schedule

in paragraph 43.1 above. It is understood that CIAL has

formally sought to have this area included in the designation,

during the imminent Plan review.

43.3 The MP’s Table Table 4-2's righthand column shows that of

CIAL's (plus non-CIAL's) interests of 711ha of SPAZ / 58ha

falls within the Commercial Support Precinct (called a Sub-

Zone in the MP). This CSP represents 8.2% of the SPAZ, but

deducting 15ha of the CIAL holding on Russley Road land that

is outside the designation, the balance of 43ha represents

only 4.7% of the latter. Apart from 45ha of the SPAZ

allocated for future development (the western quarter of

which is in a completely non-commercial area) the balance of

18

the SPAZ and Airport designations are specifically allocated to

actual or potential dedicated airside activities.

43.4 Mr Rhys Boswell of CIAL provides an update on CIAL land

ownership, occupation and use as it has changed since the

2006 Master Plan.

4.0 PROPOSED PC84

44 Proposed PC84 is not attributable to any directive of the LURP. I

accept the context provided for it from paragraphs 3.2-3.11 of the

Section 42A Report. At p11, the s32 Report states (in relation to

the "Recall" decision):

”The Decision highlighted this policy gap and suggested that the

Council should seek to amend the City Plan as such to provide

greater guidance on the purpose and outcomes sought through

the Special Purpose (Airport) Zone provisions."

4.1 The Section 32 Report

45 The fourth paragraph of the s32 Report's Introduction contains the

following sentence:

"In essence, the Plan Change seeks to provide relatively limited

constraints on development of Airport zoned land, to support

the airport as a resource, where such development will not

cause adverse effects on the environment."

(emphasis added)

The context of this approach was the selection of the "Plan Change

C" option among those discussed at section 5.1 of the Report.

46 At section 5.2 of the Report, there is no reference to consideration of

possible alternative wording of Objective 12.12, or its Explanation

and Reasons. Recognition of the implicit "issue" of adverse

distributional effects forms aspect (d) of the Objective, whilst (b) and

(c) also touch upon other distributional considerations.

47 Section 5.3 addresses proposed Policy 12.12.1. There is a brief and

discounted discussion about alternative approaches, culminating in

the assertion that the proposed Policy is both efficient and effective.

There is no explicit consideration of alternative policy scope and no

assertion that the notified version is the most appropriate. Aspects

(b)(ii), (c) and (e) of the Policy are directly concerned with

distributional matters.

48 Section 5.3 also addresses Rules and Methods. In consideration of

Specific Rules / Provisions, the Report opens with the following

comment, which reflects the high order approach quoted in

paragraph 45 above:

19

"The overall premise behind the development of the new and

amended rule package, is that it is only necessary to control/limit

activities that would result in some kind of adverse effect on the

environment. As part of enabling the appropriate development

at the airport resource, it is considered appropriate to permit

any activity where there is no resource management

reason for restraint…."

(emphasis added)

49 The "rule package" referred to includes the following Permitted

provisions:

….

Community Standard [3.3.1]

"One Supermarket, not exceeding 2,700m² gross leasable floor

area."

….

Activities within the SPAZ Development Precinct [3.4.2 b)9]

"Retail activities limited to:

a) a total gross leasable floor area within the zone of

1,400m² (excluding any supermarket), provided that

no single tenancy shall exceed 450m² of gross

leasable floor area, except that this limit does not

include:

i. Any retail activity inside the terminal buildings;

ii. Food and beverage outlets.

(Note: one supermarket is provided for under community

standard 3.3.1.)"

50 I further understand that:

50.1 Insofar as a supermarket is concerned, any proposal for a

supermarket of more than 2,700m² gla, or for a second

supermarket lifting the aggregate gla of both to more than

2,700m² gla would be a discretionary activity.

50.2 Insofar as Rule 3.4.2 b)9 is concerned, commercial service

activities (eg banks, travel or booking services, hairdressers,

drycleaners) fall within the category of "retail" activities,

under provisions of the Plan.

50.3 The proposed 1,400m² gla upper threshold therefore applies

to the aggregate of permitted retail and commercial service

activities outside the terminal complex. Any proposal to

establish more than 1,400m² gla of those activities outside

the terminal would be non-complying.

50.4 The foregoing limits would not include food and beverage

outlets (eg restaurants, lunch bars, fast food and takeaway

food services) so that in conjunction with retail stores and

commercial services, more than 1,400m² gla would be

permitted.

20

51 In the summary of conclusions concerning Rules, a significant section

is devoted to retail activities. This includes the following passages:

"Retail activities are generally intended to be limited to ensure

that there are not adverse effects on the central city, key activity

centres, or suburban centres. To achieve this outcome, and

based on economic advice, it is proposed that retail activities

generally are limited in extent to reflect the resource consent

granted for the "Spitfire Square" development. …. In addition a

limit on individual tenancy size is included to avoid an imbalance

in activity scale. …"

Beyond this, it is not considered appropriate or necessary to limit

retail activity inside the terminal buildings as this provides a

specific function for travellers/visitors. …

Similarly the economic advice is that food and beverage

outlets, and trade suppliers do not need to be limited in

the zone as establishment of such activities would not result in

business distribution impacts.

"Large format retail is not anticipated within the zone as the

advice received is that it could have distributional effects.

Likewise advice received is that specialty or department style

(sic?) retail activity could cause adverse impacts on the central

city recovery or suburban centres.

Alternative approaches to managing retail activity were

considered. It would be inappropriate to enable all retail activity

in an unlimited manner where there is clear advice that this could

lead to adverse effects on the environment. Likewise,

restricting all retail activity (such that consent is necessary)

would be inappropriate where some such activity would

not lead to adverse effects and is necessary to the

functioning of the zone. It is therefore considered efficient

and effective to provide for some reasonable activity as is

proposed."

(emphasis added)

52 I will also refer to the above-quoted passages when offering my

opinions on the submissions to the proposed Change.

4.2 CIAL Submissions

53 At paragraph 4 of its Notice of Submission, CIAL indicates that

(among others) it is particularly interested in the following aspects of

PC84:

"4.1 Inclusion of a specific Objective (12.12) and Policy

(12.12.1) recognising the role and function of the

Special Purpose (Airport) Zone;

21

4.2 Recognition of specific 'Precincts' within the Special

Purpose (Airport) zone and the range of activities

enabled within the precincts; and

4.3 The range of business activities provided for within the

'Development Precinct'. …"

Elements 4.1-4.3 of the sought relief fundamentally cover the

matters of Airport retailing and the related planning context to

which this statement is addressed (cf paragraph 8 above).

54 CIAL seeks modification of proposed new Objective 12.12 by

amending its clause (d) to replace the terms "key activity centres"

and "suburban centres" with "district centres" and by adding the

qualification "significant" to the words "adverse distributional

effects". CIAL seeks equivalent modifications to Policy 12.12.1

clauses (b)(ii) and amendments to clauses (c) and (e):

54.1 In relation to clause (c) the submission seeks only to

rephrase the thrust (from limiting to enabling) whilst not

altering the substance of the policy.

54.2 In relation to clause (e) the submission seeks to delete the

reference to lfr activities as being inappropriate.

55 Insofar as proposed Rule 3.4.2 is concerned, CIAL seeks that trade

suppliers be added as "iii" to the exemptions listed in item 9a) which

relates to retail activities. The reasons for the amendment sought

by CIAL are indicated by proposed wording changes to the

Explanation and Reasons for both the Objective and Policy.

4.3 Other Submissions and Further Submissions

56 Submissions and further submissions which have a direct interest in

or bearing on the above CIAL submissions are briefly summarised

below:

NZ Transport Agency (NZTA) Submissions

56.1 NZTA seeks to extend the constraints concerning retail

activities in Policy 12.12.1 and supports the notified

provisions of its clause (e).

56.2 NZTA also opposes CIAL submissions concerning Objective

12.12, Policy 12.12.1 and its Explanation, the inclusion of

Trade Suppliers in Rule 3.4.2(b)9 and related wording

changes.

National Investment Trust (NIT) Submissions

56.3 NIT is opposed to additional retail activity within the SPAZ,

and considers that retail activity within the terminals should

be restricted. NIT is also opposed to entrenchment of the

current but unimplemented consent for the Spitfire Square

development within the zone rules.

22

56.4 NIT also opposes the CIAL submissions, more or less in

parallel with the NZTA further submission.

Joie de Vivre (JDV) Submission

56.5 JDV opposes provision for a supermarket and opposes any

expansion of retail and office activities within the terminal.

They oppose the Calder Stewart submission supporting non-

precinctual / stand-alone trade suppliers on the Development

Precinct.

56.6 JDV also opposes the CIAL submission concerning the

wording of Volume 2, Objective 12.12 and Policy 12.12.1 and

its Explanation, a definition in Volume 3, and elsewhere in

relation to Volume 3, the wording under Clause 1.3 and

aspects of the ensuing Rules.

Calder Stewart Submission

56.7 Calder Stewart seeks to add stand-alone trade supply outlets

to Rule 3.4.2. Calder Stewart also opposes numerous CIAL

submissions concerning Objective 12.12, Policy 12.12.1 and

Explanations, Clause 1.3, Rules 3.4.2 and Reasons underlying

Rules 13.2.6 and 13.2.9.

Bunnings Limited (Bunnings)

56.8 Bunnings conditionally supports the Calder Stewart

submission and aspects of the CIAL submission, whilst

opposing aspects of the JDV, NZTA and other submissions.

Progressive Enterprises Limited (Progs)

56.9 Progs opposes the above JDV and NIT submissions.

5.0 OPINION CONCERNING THE SUBMISSIONS

57 In considering the various submissions, I have had regard to the

material in Sections 2.0-4.0 above. I have not up to this point

presented any opinions concerning those topics.

5.1 Objective 12.12

58 The objective as notified is not inconsistent in its thrust with

providing responses to those City Plan issues that identify adverse

distributional effects. However, at a more specific level, clause

12.12(d) is inconsistent with Business Issue "a" in sub-Chapter

3.11.7 (cf paragraph 40 above). This particular Issue emphasises

(appropriately, in my opinion) that among the City's commercial

centres, threats to the "central city and district centres" are of

greatest significance.

59 I support that provision because the CBD and district centres have

(or are intended to have) higher-order commercial functions than

suburban centres, including comparison shopping (cf paragraph 10)

plus a wide range of commercial services, offices and community

services. They have more of a far-reaching importance. I

23

therefore consider it appropriate to reflect the Issue's terminology in

Objective 12.12.

60 The term "key activity centre" ("KAC") is not yet defined in the City

Plan. I accept that it will need to be, to give effect to regional

policy, but its use in that context is not hierarchical in the same

sense as is the Plan's term "district centres". The KAC

nomenclature is flavoured or influenced by the RPS' recovery-related

considerations and in that context, spans both district and suburban

centres. I think it very unwise to introduce the term to the Plan via

PC84 before commensurate consideration has been given to

hierarchical considerations, including the identification of KACs that

may not be intended to undertake a district centre function.

61 As to the term “suburban centres" it is relegated, by its distinction

from district centres, to lower-order (regular but more limited)

functions. This status is reinforced by Issue "i" at sub-Chapter

3.13.10 of the Plan (cf paragraph 40 above). It is also reinforced by

the unavoidable fact that in distributional terms, smaller

convenience-orientated centres are necessarily much more

numerous than more specialised district centres. That is the

distributional system that has evolved to best meet the wellbeing of

communities.

62 In light of the foregoing, the s32 Report's silence on the pros and

cons of Objective 12's wording (cf paragraph 46 above) and my

comments in paragraph 39, I fully support CIAL's submission on the

terminologies used in item (d) of Objective 12.12. I consider that

submissions in favour of the notified status quo lack equivalent

merit.

63 Insofar as the absence of the term "significant" is concerned, I

consider this an important omission. While there has continually

been uncertainty about a precise interpretation, this flexibility is

necessary. The alternative would be to adopt some resource

management version of the Duckworth-Lewis formula (for resolving

inequal cricket match opportunities, in shortened forms of the

game).

5.2 Policy 12.12.1

64 Clause (b)(ii) of the new Policy mirrors the wording of Objective

12.12. For the reasons given under topic 5.1 above, I consider the

CIAL amendments more appropriate than the notified version. It is

a natural extension of that opinion to align sub-policy (b)(ii) with the

Objective. I therefore support CIAL's submission on this part of the

Policy.

65 Jumping to clause (e) as notified, I consider that its inclusion of

"large format retail activities" as inappropriate in the Zone alongside

noxious industry, but with no other inappropriate activities

exemplified (ie, nothing to link or contextualise these two extremes)

is inherently pejorative. Before considering the justification or

otherwise for that inclusion in the Policy, I would simply note that it

24

would have been more logical to identify perceived inappropriate

retail examples in an amended version of clause (c). For that

reason, I include this aspect of Policy 12.12.1 within my discussion

of clause (c).

66 Clause (c) as notified seeks to create a nexus as between the retail

and office activities deemed acceptable on the one hand and the

needs of travellers, other Airport visitors and workers in the SPAZ on

the other. It is a very restrictive approach, which I am unable to

attribute to Objective 12.12 (as notified or, preferably, amended as

sought by CIAL). As discussed below, I am also unable to identify

any "real-world" circumstances, Plan provisions or s32 justification

for clause (c) as notified.

67 Turning first to my Section 2.0, the "real-world" evidence is:

67.1 There has been a modest acceleration of population and

occupied dwelling counts in the suburban areas close to the

Airport since 2006, against the City's wider experience;

67.2 There was, between 2006 and 2013, a very substantial

increase in employment in and close to the Airport,

representing more jobs than were gained by the City as a

whole;

67.3 In the last two years, Christchurch's retail turnover increases

have far outstripped those of the Country as a whole, largely

driven by demand for hardware, building and garden

supplies, and at a rate significantly exceeding that of

population and dwelling growth;

67.4 These sales results have outstripped, by an even wider

margin, the level of City retail supply, meaning that sales

productivity in retail centres – particularly district centres –

and even more so in building supply outlets, is uniquely

buoyant.

This is not a market which justifies significant constraints on Airport

retailing unless such were driven by non-distributional

considerations.

68 The City Plan's Issues in relation to retailing and other commercial

activity – in my opinion – fall within what I would term the

mainstream approach, whereby related Policies include provision for

the assessment of significant un-zoned developments to determine

whether or not (or the extent to which) they can proceed, whilst

avoiding significant adverse effects on other centres and their

communities. Turning to Airport Issues, Transport Issue 3.15.10(k)

identifies the need to provide for the future operations of the Airport

and related traffic impacts. As the Airport designation and land

holdings significantly exceed the extent of the SPAZ, I infer that

there is no particular Issue (ie concern) that there is inadequate land

in reserve for future core activity expansion.

25

69 The Section 32 Report's Introduction describes proposed constraints

as "relatively limited" and related to development that could cause

adverse effects on the environment (paragraphs 45 and 48 above).

The Report quotes economic advice that food and beverage outlets

(cafés, restaurants, takeaways etc) and trade suppliers (of which

builders supply outlets are the largest and most commonly

recognised) need not be limited in the SPAZ.

70 By any objective reckoning, I consider that some non-terminal

retailing activities can clearly be permitted in the SPAZ, in reliance

on the matters identified in paragraphs 67 - 69 and on the wording

of Objective 12.12. I do not consider that sub-Policy 12.12.1(c) and

the 12.12.1(e) inclusion of trade suppliers (as large format retail

activities) as notified, are justifiable provisions in PC84, on the

evidence of those paragraphs.

71 However, there are two apparent dichotomies which I must address:

71.1 In the second-last quoted passage of paragraph 51, the s32

Report identifies that the economic advice received

discourages provision for lfr and specialty or department style

(a presumed typo intended to say "department store")

retailing, as such could give rise to adverse distributional

effects. At face value, the blanket term "large format

retailing" includes trade suppliers, which are distinguished in

the previous quotation (and the Plan) as not able to cause

adverse distributional effects.

71.2 In the final quoted paragraph of paragraph 51, the

introduction of the implicit criterion:

"… and is necessary to the functioning of the zone."

is completely unrelated to the distributional effect

considerations that are common ground in the Plan and the

rest of the s32 Report.

72 In relation to sub-paragraph 71.1, lfr is represented in nearly all

retail categories. In the City Plan context, the term refers to retail

outlets with gfa of 450m² or more. These encompass

supermarkets, large grocery, food or liquor stores, department

stores, large apparel and accessory stores, furnishing and larger

appliance stores, some sporting goods, book, stationery and duty

free outlets and a smattering of others. The consistently largest

however, is the category of building supply outlets, which are

classified as trade suppliers in the City Plan, a category which also

includes other suppliers like automotive accessory stores and

plumbers supply outlets. Unless evidence from Council indicates

otherwise, I am confident that lfr observations were not intended to

contradict the lack of concern about trade suppliers, from the

viewpoint of adverse distributional effects. As to other forms of lfr,

whether or not they may raise concern, they, with the exception of

one supermarket, are not intended to be accommodated in the

26

SPAZ. The CIAL submission does not seek to enable the

establishment of such activities. I do not therefore consider that

the apparent dichotomy is any more than that.

73 In relation to sub-paragraph 71.2, I have reviewed the August 2013

Property Economics Report ("PER 2013") commissioned by CCC3.

The topic of non-terminal retailing in the SPAZ appears in its Chapter

8, from part-way down p44. However, immediately above the

section concerned, under the sub-heading "Industrial" the subject of

trade-based activity is raised. The explanation for that

categorisation is found in the second of the two paragraphs,

especially the first and last sentences:

"For clarification trade based activity is included in this category…. These store types do not typically locate in centres for land economic and site requirement reasons, with light industrial zones being the typical zone / location of choice. These activities trade like, look like, perform like, are categorised like and function like light industrial activities, and as such are not considered retail stores, making the light industrial zone an appropriate 'fit' for such activity types."

(emphasis added)

74 I am unclear as to the nature of the "clarification", especially given

the final sentence of the paragraph at the top of page 45 of the

Report and bearing in mind that hardware and building supply

outlets are trade suppliers under the Plan's definitions and therefore

"retail activities". I refer further to this in paragraph 95.

"Trade supplier

Updated 16 November 2009 means a business engaged in sales to businesses and institutional

customers and may also include sales to the general public, and wholly consists of suppliers of goods in one or more of the following categories:

…. • building suppliers." "Retail activity Updated 16 November 2009 means the use of land or buildings for displaying or offering goods

for sale or hire to the public and includes, but is not limited to, food and beverage outlets, trade suppliers, yard based suppliers, service stations, second hand goods outlets and foodcourts."

(emphasis in text added)

I would add that building suppliers are the most visited type of trade

supplier in the marketplace, with leading brands that exhibit and

promote heavily to the general public, as well as to commercial

customers.

75 Notwithstanding their classification however, the PER 2013 is

unequivocal in stipulating (on page 44) that:

3 Found at Appendix 12 to the section 32 Report for PC84.

27

"The level of 'threat' trade supply stores will have on the KACs and Central City recovery is negligible in Property Economics view as they are not prevalent store types in these centres, and nor does their role, function, amenity, vitality, performance and viability of the centres rely of (sic) store types."

(emphasis added)

At page 46, it notes that non-convenience lfr in the general realms of

furnishings, appliances and notably, hardware, building and

garden supplies retailing are not integral, fundamental or critical

to the role and function that KACs play in the market. I agree

totally with this assertion, albeit substituting the term "district and

suburban centres" for KACs, in the City Plan context.

76 Furthermore, the economic assessment supports the immediate

provision of one-only supermarket and the inclusion of the SPAZ as

an option (among others) to meet future non-convenience (ie

comparison and specialty) shopping demands in the north-west of

the City. There is no nexus whatever, between this Report's views

and the fraught PC84 Policy thrust, of limiting retailing to that which

is necessary to the functioning of the SPAZ.

77 I therefore consider that the foregoing matters confirm that the s32

Report gives insufficient weight to the Report's thrust, in that:

77.1 building supply outlets should not be considered as generic

KAC lfr anchor outlets in the PER 2013 context, and that

therefore,

77.2 Policy 12.12.1(c)'s wording is not able to rely on that same

Report for its justification.

78 In my opinion therefore, the CIAL submission concerning the

wording of sub-Policies 12.12.1(c) and (e) is preferable to the

notified version. I support the CIAL's proposed amendments as

both appropriate and necessary.

5.3 The Rules in Relation to Retailing

79 Looking up the cascade from the bottom, the proposed Rules

represent the main method [given that PC84 otherwise adopts

operative methods used in the Plan] of giving effect to Policy

12.12.1, which implements proposed Objective 12.12. At the end

of the day, the Rules are paramount, as to what may or may not

occur, as of right and/or by way of application and consent. Given

my opinions in paragraphs 64, 67.4, 69, 70, 71.1, 72 and 73-77, I

support CIAL's submission on Rule 3.4.2 (cf paragraph 52 above).

With the addition of trade suppliers at Rule 3.4.2 9a) iii (as sought

by CIAL) the Rule package for retail and related commercial

activities in PC84 is very conservative, in my view. It enables the

following permitted development, outside the terminal:

A supermarket no larger than 2,700m² gla;

Retail and commercial services, individually <451m² and

no greater in aggregate extent than 1,400m² gla;

28

Food and beverage service outlets; and

Trade suppliers.

80 Turning first to the supermarket, it is in the medium size range of

full-service supermarkets in large urban areas, but the low range of

modern supermarkets in such situations, if walk-up CBD "Metro"

type stores are excluded. Those parts of the proposed Airport

Development Precinct that are likely to accommodate a super-

market are roughly equidistant from the two strong commercial

corridors to the north and west of the CBD, featuring both large

district centres and dedicated lfr centres, with additional out-of-

centre retailing prominent in the western corridor.

81 Within those two corridors, a residential wedge of suburbs (the

North Western Suburbs) more or less bisected by Memorial Ave,

has numerous roading connections to the corridor centres.

Historically, the commercial centre network that developed within

these suburbs has been convenience-orientated, with comparison

shopping and large-ticket purchasing increasingly directed to the

corridor centres (or to the CBD, to the extent that it has been

available since 2010/11). Within the blue-shaded area on the

Appendix One Map, there are two centres zoned B2 (Bishopdale

and Avonhead/Merrin Mall) whilst on the eastern literal edge of that

North-Western area, there are two more; mixed B1/B2 Zoned

Wairakei Rd / Bryndwr and Ilam North / Clyde Road centres. Both

contain very small supermarkets (around 1,000-1,2000m² gla).

With the limited exception of Bishopdale (which until quite recently

contained two supermarkets) these centres are contained by zoning

boundaries and by the development and zoning on the other side of

that interface.

82 The distributional effect evaluation which supported the Spitfire

Square application found that the development of the supermarket

would not have significant adverse distributional effects. From my

appreciation of the circumstances, I have no reason to doubt such

an assessment. In advancing that view, I am taking into account:

82.1 The extent to which an Airport-based supermarket would

cater for the opportunity to supply inbound travellers and

provide an anchor outlet around which other inbound-tourist

services can establish and better serve the visitor cohort of

the region's non-resident population.

82.2 The extent to which an Airport-based supermarket would

provide a convenient point-of-sale opportunity for those who

work within the Airport campus, or visit it (especially regulars

like taxi drivers, couriers and other transportation workers

who visit it for non-travel reasons).

82.3 The extent to which it is likely to meet the growing demand

for supermarket services among those resident (or shortly to

be resident) in the City's growing North-Western areas,

29

including the extent to which that is likely to divert custom

from existing centre-based supermarkets.

83 A 1,400m² threshold on retail and commercial service development

means that competition for space will ensure that its retail element

will be limited to less than 1,400m². The 450m² individual retail

limitation (which can not sensibly be applied to any foreseeable

commercial service activity) in conjunction with the former retail

constraint, ensures that only a small number of retail stores, none

of them destinational in character, can be established. Such a

limit absolutely precludes the establishment of any kind of

comparison or specialty shopping area, which could compete

directly with established district centres.

84 The absence of constraints on prepared food and beverage services

reflects the fact that such activities have no fundamental under-

pinning role for district or suburban centres, above the smallest of

the latter hierarchical examples. Apart from the potential enabling

of high profile fast food outlets (such as McDonalds) which basically

redistribute trade as between their own and other fast food outlets,

most cafés and restaurants and lower profile prepared food outlets

only "feed" on the level of trade generated by retailing or

employment in their environs. In the case of restaurants,

relatively stand-alone traders can survive or prosper in non-

commercial locations, but normally in circumstances that are more

"amenable" than an Airport precinct. To the extent that such

activities may be able to function successfully outside the terminal

pursuant to Rule 3.4.2 9a) ii, they deserve to be enabled. They

will not adversely affect other centres or communities, whilst

benefiting Airport users.

85 Turning to trade suppliers, the case for enabling such within the

SPAZ is based on their differentiation from other retail activities in

the City Plan and the expert retail / economic evidence (including

the PER 2013) that such outlets do not compete materially with

district or suburban centres. Additionally, there is a current and

foreseeable enhanced demand for such outlets, in the CCC

circumstances. Whilst such activities may have little potential

trading support from Airport personnel and visitors, there is no

distributional basis for excluding them, either in real-world terms,

or as a consequence of the Plan's Issues and Objectives, including

PC84's proposed Objective 12.12. The only appropriate basis for

their exclusion as permitted activities would be concern about their

potential to inhibit future core Airport activities.

5.4 Conclusions regarding Submissions

86 I would observe that outside the provision for a 2,700m²

supermarket, pursuant to Rule 3.3.1, the default situation for other

retail activities, as discussed in above paragraph 50, is

discretionary or non-complying. In my professional opinion, a

permitted gfa or gla threshold beyond which any breach is non-

complying is inherently inequitable. If a 1,400m² threshold is

"safe", the classification of a 1,401m² proposal as non-complying is

30

unrealistic, in my opinion. I would expect to see provision for an

intermediate expansion of such a "safe" threshold as discretionary,

before an absolute non-complying status is applied. The fact that

such a PC84 provision has not been included (or sought) reinforces

my opinion that the 1,400m² retail threshold in proposed Rule 3.4.2

9a) should be regarded as a minimum, when consideration is given

to submissions seeking its cancellation.

87 In my opinion, provision for significantly more such activity, as

discretionary or restricted discretionary activities, would have been

appropriate, together with criteria that ensured assessment of the

wider distributional effects of such expansion. No such provision

has been made in PC84, nor has it been sought, but I consider that

at the very least, the net approach supported by CIAL is

conservative and appropriate.

88 Some other Submitters explicitly or implicitly oppose the provision

for a supermarket and associated retail activity. My position, based

on my experience, is that it would have been remiss of the drafters

of PC84 to not recognise the Spitfire Square resource consent, when

updating the SPAZ provisions. It should be clear from my evidence

that in terms of demographics and trade, circumstances since the

grant of that consent reflect increasing buoyancy in demand. This,

at the very least, supports whatever basis underlay the proposal,

possibly enhances that basis and provides no grounds to consider

deliberately ignoring the consent, in my opinion.

89 Turning directly to those other submissions, my opinions are as

follows:

89.1 NZTA's further submission opposes all aspects of the CIAL

primary submission. I have no professional view about the

merits of both NZTA submissions, from the viewpoint of

transportation concerns. However, for reasons I have

detailed above, I consider that the NZTA's position

concerning proposed Policy 12.12.1 is neither supported by

Objective 12.12, nor by the City Plan, the s32 Report or the

factual commercial circumstances of the City.

89.2 NIT's submissions on the provisions for retailing go beyond

those of NZTA, by seeking to cap terminal-based retailing at

October 2013 levels. I consider that to disenable CIAL's

need to cater within the terminal for growing passenger and

associated personnel counts, in the absence of any City Plan

or real-world provenance for such a Policy, is unreasonable.

89.3 The JDV / Canterbury Trustees (2012) submissions raise no

matters concerning distributional aspects of PC84 that I have

not already referred to above, and/or expressly or implicitly

in the earlier paragraphs of part 5.0. I do not consider, from

the viewpoint of my expertise, that the JDV position is

appropriate.

31

89.4 Calder Stewart adopts a similar approach to the above

submissions, but with one exception. It supports the

provision of trade supply outlets in the SPAZ, provided they

are stand-alone outlets. From this I take it that the

Submitter is opposed to a planned trade supply precinct. I

infer that the Submitter's support for such a constraint is

rather less driven by urban design considerations than by

concerns about scale and impact. In the latter regard

however, so long as participants were to qualify as trade

suppliers, there would be no material impacts on centres.

Insofar as scale and integration are concerned, the precinct

approach would represent a significantly more efficient use of

land and greater efficiency and convenience for potential

customers. I do not consider that there is any justification

for the stand-alone requirement, so apart from supporting

the inclusion of trade suppliers as permitted activities in the

SPAZ, I oppose the rest of this submission.

89.5 Bunnings' further submission is supportive of the CIAL

submissions, which I support.

89.6 Progs' further submission is covered either by my generic

comments in paragraph 70 above, or those given re sub-

paragraphs 82.1-82.3 above. I support this submission.

6.0 S42A REPORT & EVIDENCE OF MR HEATH

90 The s42A Report is accompanied by appendices, some containing

statements of evidence from experts. Appendix 9 contains the

evidence of Mr Tim Heath, dated nearly a year from completion of

his 2013 Report (which forms Appendix 12 to the section 32

assessment for PC84). I have reviewed Mr Heath’s s42A statement

in light of the PER 2013 and comment on it below.

6.1 2014 Evidence of Mr Heath

91 After introductory comments, Mr Heath retrospectively outlines the

"Key Baseline Findings" of the PER 2013. This summary does not

identify that the PER 2013 recommended adoption of a scenario (one

of four) in which trade supply activity would be provided for (PER

2013, page 9, second bullet) albeit in the context of light industry,

as I commented on in paragraphs 70-74 above. The statement

goes on in paragraphs 19-25 to discuss the notified provisions. As

these do not provide for trade suppliers, they are not mentioned.

Nor is the dichotomy raised in the "SPAZ Retail Overview", which

takes the evidence through to paragraph 33.

92 In my opinion, this is an example of "the elephant in the room",

which in this case, relegates a change of position to side-stage,

insofar as the "higher level" discussion in Mr Heath's statement is

concerned. In fact, and significantly in my opinion, there is no

32

passage within Mr Heath's evidence, which clarifies and explains why

the latter is inconsistent with the PER 2013. In the absence of such,

and in support of the CIAL position, I am therefore obliged to

illustrate and exemplify my concerns.

93 Before doing so however, I wish to refer to what Mr Heath terms the

"CIA Core Retail Catchment" in paragraphs 28-30 and Figure 1 of his

statement4. The latter can not represent a retail catchment,

because there was no retail activity outside the terminal in

December 2008 to which retail shoppers could have been attracted.

It is a surrogate Airport-influence marker, having no regard to the

significant retail and associated functions of large centres at or near

its periphery. My concern is that if the geographic area depicted on

Figure 1 is accepted at face value, as a potential catchment for any

Airport Centre, the latter may implicitly (and quite wrongly) be seen

as having widespread adverse distributional connotations –

especially as the evidence is more or less silent on the absence of

such, were trade suppliers permitted.

94 To some extent, such a perception is or should be diluted by

comments in paragraphs 31-33 of Mr Heath's statement. These

implicitly recognise that the catchment influences of any centre are

primarily determined by the nature and extent of its retail and

related activities, having regard to the nature, location and extent of

the influences of competing centres. However, I am aware that "a

picture is worth a thousand words" and it is the picture, captioned as

a catchment, to which my last comments are addressed.

95 Picking up the thread from paragraph 92 above, I turn to paragraph

77 of Mr Heath's evidence, with its list of activities classified as

wholesale, for statistical purposes. In Appendix Three, I have

provided excerpts from the ANZSIC 2006, including the differences

between activities with similar product ranges, by which they are

categorised as "wholesale" or "retail". I have added some

explanatory notes and emphasis to otherwise original ANZSIC 2006

pages. This material reinforces that trade suppliers are a subset of

retail and that the concept of a wholesale trade supplier has no

distributional context. The material reinforces and explains my

earlier comments at paragraphs 73-75, concerning the context given

building suppliers and wider trade supply activities in the PER 2013,

relative to Statistics NZ categories and the operative Plan's

provisions.

96 Notwithstanding what I perceive to be material inconsistencies in

that approach, Mr Heath's evidence from paragraphs 78-82 makes

no attempt to rationalise the approach discussed in paragraph 92

above. In fact, I consider these paragraphs to reinforce the change

of direction to which I referred in paragraph 92.

97 It is stated in paragraph 64 of Mr Heath's evidence (in a broader lfr

context) that:

4 The same data was included in the PER 2013

33

"The balance of other non-convenience LFR activity is generally in the retail sectors of:

• Furniture, Floor Covering, Houseware and Textile Goods Retailing • Electrical and Electronic Goods Retailing."

This passage omits the third bullet of the PER 2013, which, in the

same context and otherwise identical paragraph, added a third bullet

to the above two:

"• Hardware, Building and Garden Supplies Retailing, albeit this

activity type is considered a trade based activity and should be treated as such for strategic planning purposes."

(emphasis added)

98 In the distributional context of the PER 2013, provision for such an

activity within the SPAZ was explicitly supported. In his s42A

statement, when discussing distributional effects, it rates no

mention, that I can find, prior to paragraph 92 of his statement,

under the topic "Comparative Industrial Area Analysis". However,

that mention is specifically focused on what is termed "the Wholesale

Trade sector", which I discussed in above paragraphs 92 and 93 and

in respect of which I introduced Appendix Three. Thus, it does not

refer to the unqualified trade suppliers which are defined in the Plan.

The approach is inconsistent with the PER 2013, as is the description

"a non-retail RMA issue"

at paragraph 95 of Mr Heath's statement.

99 The above approach leads to a suggested

"Wholesale Trade GFA trigger of 2,500 sqm"

in paragraph 98 of the evidence, qualified as invoking discretionary

consent status. I am at a loss in trying to rationalise this end point

of the foregoing devolution from the clear PEL 2013 findings to a

recommended rule purporting to apply to wholesalers, who have no

propensity whatever to adversely impact on centres and their

communities, under the guise of "a non-retail RMA issue". This

dichotomy is hinted at in Mr Heath's paragraph 113. None-the-less,

the "trigger" proposal is reiterated in his "Conclusion", ending at

paragraph 119 with what I find to be a completely confounding

definition of it as:

"… a simple and pragmatic retail mechanism…."

(emphasis added)

6.2 The Section 42A Report

100 Following on directly from the previous paragraph, I note that Rule

3.4.2 b) is subject to changes recommended in the s42A Report

concerning notified clause 9 and the introduction of a new clause 18.

100.1 At clause 9, trade suppliers are specifically detached from the

provisions covering retail activities.

34

100.2 New clause 18 is worded as follows, to provide for

"Trade suppliers not otherwise provided for as a permitted activity,

limited to a total gross leasable floor area within the zone, of 2,500m²."

101 These amendments have no provenance arising from Mr Heath's

evidence, in my opinion:

101.1 The added words at clause 9 do not, for practical purposes

alter the notified provision, beyond requiring that the

1,400m² retail activity threshold can not include any trade

suppliers. However, the wording of proposed clause 18 can

not be interpreted as applying to trade suppliers as defined in

the Plan, if this provision is adopted.

101.2 Clause 18 otherwise introduces a cumulative zone threshold,

above which "wholesale trade suppliers" would be non-

complying.

101.3 Mr Heath, in his statement of evidence, provides no

unambiguous discussion, opinion or explanation concerning

the distributional effects of what I might describe as "normal"

trade suppliers, having regard to the PER 2013's findings on

the matter. However, subject to the ambiguity inherent in

its last two sentences, paragraph 37 opens on a note at least

consistent with the PER 2013 thrust. At face value, the

words concerned imply continuing support for Mr Heath's

2013 opinions. At the end of the day however, there is no

updated guidance in the evidence concerning defined trade

suppliers. I do not believe that the Rule changes can be

attributed to Mr Heath's advice.

102 The rationale presented in relation to the amended trade supplier

proposals is set out on page 24 of the s42A Report. However,

paragraphs 5.32 and the top of paragraph 5.33 reveal an absence of

rational (step-by-step) justification.

102.1 Paragraph 5.32 discusses submitter positions about trade

supply activities but does not recognise that in the context of

their submissions, especially those having regard to the PER

2013, trade suppliers means what the Plan says it means.

That is the only conceivable basis on which the submissions

could have been made. However, the first sentence of

paragraph 5.33 posits the response as one responding to the

submissions. In fact, it has no relationship to the

submissions, because the response contains no outcome in

relation to the submissions. The provision that has been

made is for activities that qualify as wholesalers, not trade

suppliers.

102.2 As the originator of the definition of and provision for "trade

suppliers" in the City Plan (in the context of Variation 86) I

can state with certainty that the definition "trade suppliers"

35

does not extend to legitimate wholesalers. The terminology

of "wholesale trade suppliers" is a contradiction in terms and

in my view, is an oxymoron. Wholesalers are wholesalers.

102.3 There is no distributional evidence to support the discussion

on page 24 of the Report. Most of paragraph 5.33 ignores

the above dichotomy. Reference to "larger building

suppliers" in the final sentence is gratuitous, in that there is

no evidence in Mr Heath's statement (or in the PER 2013) to

support the contention.

102.4 The reliance on the retail evidence of Mr Heath part-way

through paragraph 5.34 is misleading and equally off-point

for the reasons outlined above. Any "retail" trade supply

issues were sidelined and bypassed in the latest evidence of

Mr Heath. What is more, Mr Heath did not propose a zone-

wide threshold. He proposed an individual store threshold,

above which applications for a discretionary consent would

have to be made. Use of the word "accordingly" in the final

sentence of the paragraph is therefore not appropriate. The

provisions do not accord with Mr Heath's evidence and are

completely opposite to the more transparent views expressed

in the PER 2013.

103 Paragraph 5.35 reads as follows:

"I have also recommended some consequential amendments to the objectives, policies and explanatory text to reflect the changes above. These are detailed in Appendix 4."

I refer to these "details" below, but in the context that my

appreciation of the RMA is that methods and rules are supposed to

implement policies and give effect to objectives, not to formulate

them.

104 Turning first to the proposed changes to Objective 12.12, I refer only

to sub-Objective (d). For reasons that I have already outlined in

paragraphs 55-58, I agree with all but the final provision. However,

insofar as retail parks are concerned, having regard to their health

is, by their nature and definition, inconsistent with the Plan's

emphasis on the City's centres. These lfr centres are commercially

driven and are not justifiable where they would significantly

adversely affect the wider role and community function of district

centres. I therefore consider that aspect of the proposed

amendment to be inappropriate.

105 Turning to proposed changes to Policy 12.12.1, I focus on the s42A

Report's suggested amendments at clauses (b) and (c) of that

provision:

105.1 Proposed amendments at clause (b)(ii) include repetition of

the provision to protect the function of retail parks. For the

reasons set out in paragraph 104, I consider that aspect of

the s42A recommendation to be inappropriate.

36

105.2 For reasons already outlined at length, there is no

justification attributable to Mr Heath's work on distributional

effects, for the recommended introduction of this Policy

element, as sub-Policy (b)(iii).

105.3 Insofar as the new introduction to sub-Policy 12.12.1 is

concerned, there is no distributional justification whatever for

its incorporation in the City Plan. I need not re-iterate the

many reasons why.

106 For the reasons summarised above, but elaborated upon in more

detail throughout this statement, I consider the proposed s42A

Report's above Policy recommendations to lack justification and to be

contrary to s5 of the RMA. They are not consistent with any real-

world Objective and rely upon Policy enunciations that are

unsupported by expert evidence. They represent the Report's Rule-

focused tail wagging the Objective and Policy dog.

107 From the viewpoint of a distributional effect analysis, I consider that

the s42A Report's evaluation is flawed and unsupportable in a s32

context. I consider that its rejection of CIAL's submission lacks

distributional integrity.

Dated: 30 July 2014

Mark Gauntlett Tansley

APPENDIX ONE : DEMOGRAPHIC DATA

A1

1. All tabular information in this Appendix has been sourced from Statistics NZ, with added

calculations by Marketplace NZ Ltd.

2. Area units (aus) contributing to the North-Western Area, including Yaldhurst, are illustrated

on the City's Area Unit Map overleaf and detailed in Tables herein. The Yaldhurst au

contains all of the SPAZ, and, mainly to the Airport's south-west, it includes Rural zoned

land, with minor other Zone contributions, none of them of a Business nature. Apart from

some Primary Industry employment and a small number of persons who work from home,

the SPAZ would, for practical purposes, be the venue of almost all of the au's job/workplace

counts.

3. Tables 1A and 2A are considered self-explanatory, assisted by the brief comments at

paragraphs 2.2.1 and 2.3.1 of the statement to which this Appendix is attached.

4. Tables 3A and 3B however, require additional explanation. They adopt a consistent format,

drawing upon data from the 2013 census, which also incorporated comparable 2006 data

aligned to the revised area unit boundaries. Lines a and c for each geographic area

represent census counts; "a" being job location and "c" the residential location of persons

actively working full or part-time. The lines do not necessarily cross-add exactly, as all

census data of this kind is randomly rounded. The adjustments on lines b of the tables are

explained as follows:

(1) As can be seen from the NZ data, the general trend is for line c values to exceed the

values of line a. This is due to a combination of factors, including that:

(i) Some jobs (especially in the construction and transport industries) are not

associated with a fixed workplace; whilst

(ii) Unlike the home addresses from which census returns are collected, places of

employment can be inadequately or not identified.

(2) Notwithstanding the discrepancy, the actual value of line a, at the national level, must

be the same as that of line c. Residents not enumerated in the census do not appear in

either line.

(3) Different groups of industries have different propensities to identify a primary

workplace. At the NZ level, the line b adjustment factors identify the shortfall in line a

and therefore, the average propensity to under-account for job locations, in that group.

For the purpose of Tables 3A and 3B, that NZ-wide propensity is adopted as the

adjustment factor for each column. This results in the workplace shortfall being

adjusted pro-rata, using the adjustment factor. In the Yaldhurst au, for example, 96 x

1.1625 Primary Industry jobs converts to an effective 111 workplaces, including workers

"at large".

(4) It is pointless to adopt declared workplaces from census to census as a guide to change.

In the Table 3A total column, 85% of the employed labour force in 2006 identified a

workplace at District or City level. That 15% shortfall shrank to 9% in the 2013

census, presumably as a result of a greater level of rigour being applied by

enumerators, before accepting the response to the workplace question. Only the

adjusted data, at local authority level, provides helpful comparisons.

(5) Data by au is collectively less helpful, as some responses identifying a local authority

area; eg Christchurch, will be included in the City total but will not appear in a specific

area unit. For that reason, the Yaldhurst workplace values will be understated, in both

lines a and b. This results in line b of the Yaldhurst results being a conservative tally of

its effective employment contribution.

5. The data in Tables 3A and 3B shows a NZ-wide increase of less than 1% in the numbers

engaged in 2013, relative to 2006. In Christchurch City, notwithstanding the earthquake

effects, the increase essentially paralleled that trend. In the Yaldhurst au however, effective

workplaces increased by around 60% or 7% pa compounded. For the reasons explained in

sub-paragraph (5) above, data in both 2006 and 2013 is likely to be understated, relative to

the City equivalent, if such comparisons are made.

A3

TABLE 1A : POPULATION CHANGES 2001-2013 (2013 Census - Statistics NZ)

2001 Population 2006 Population 2013 Population

Usually Census Difference Usually Census Difference Usually Census Difference

Resident Night - Resident Night - Resident Night -

Yaldhurst 585 708 +123 642 819 +177 1,389 1,776 +387

Bishopdale North 4,515 4,443 -72 4,575 4,530 -45 4,686 4,671 -15

Harewood 2,760 2,712 -48 3,231 3,195 -36 3,219 3,240 +21

Bishopdale 2,406 2,358 -48 2,454 2,451 -3 2,421 2,451 +30

Russley 2,757 2,949 +192 2,994 3,369 +375 3,174 3,504 +330

Burnside 2,313 2,289 -24 2,367 2,349 -18 2,325 2,334 +9

Wairarapa 1,758 1,761 +3 1,830 1,824 -6 1,836 1,857 +21

Jellie Park 2,322 2,313 -9 2,535 2,553 +18 2,658 2,640 -18

Hawthorndon 3,180 3,180 0 3,306 3,324 +18 3,174 3,162 -12

Merrin 1,512 1,494 -18 1,578 1,575 -3 1,479 1,485 +6

Westburn 2,730 2,691 -39 2,868 2,901 +33 2,940 2,958 +18

Avonhead West 2,943 2,988 +45 2,967 3,015 +48 3,060 3,105 +45

Avonhead West 3,534 3,534 0 3,531 3,537 +6 3,558 3,615 +57

North-Western Area 33,315 33,420 +105 34,878 35,442 +564 35,919 36,798 +879


Rest of City 290,763 299,775 +9,012 313,578 326,523 +12,945 305,550 314,091 +8,541


CHRISTCHURCH CITY 324,078 333,195 +9,117 348,456 361,965 +13,509 341,469 350,889 +9,420

Change from prev census N/A N/A - 24,378 28,770 - -6,987 -11,076 -

Changed Percentage N/A N/A - 7.5% 8.6% - -2.0% -3.1% -

REST OF NZ 3,413,202 3,487,554 +74,352 3,679,491 3,781,317 +101,826 3,900,579 4,002,309 +101,730



NEW ZEALAND 3,737,280 3,820,749 +83,469 4,027,947 4,143,282 +115,335 4,242,048 4,353,198 +111,150



Area Unit or Wider

Geographic Area

6. For the Canterbury Region however, the assessed job count was up by 4% in 2013 over 2006,

while in the rest of NZ, the increase barely registered. The regional gain was the aggregate of

the City's modest increase (<1%) plus Selwyn's 34% and Waimakariri's 21%, in the main.

Christchurch City's assessed share of Regional jobs fell from about 71% in 2006 to around 69%

in 2013.

A4

TABLE 2A : DWELLING CHANGES 2001-2013 (2013 Census - Statistics NZ)

2001 Dwellings 2006 Dwellings 2013 Dwellings

Occupied Vacant Total Occupied Vacant Total Occupied Vacant Total

Yaldhurst 201 12 213 225 15 240 507 24 531

Bishopdale North 1,719 60 1,779 1,743 78 1,821 1,803 72 1,875

Harewood 1,008 51 1,059 1,194 51 1,245 1,212 48 1,260

Bishopdale 939 39 978 936 39 975 945 42 987

Russley 999 39 1,038 1,062 21 1,083 1,158 51 1,209

Burnside 855 36 891 867 30 897 855 39 894

Wairarapa 642 24 666 657 21 678 654 30 684

Jellie Park 816 30 846 846 48 894 870 48 918

Hawthorndon 1,152 57 1,209 1,200 45 1,245 1,203 57 1,260

Merrin 552 24 576 552 30 582 552 30 582

Westburn 1,029 33 1,062 1,023 54 1,077 1,026 60 1,086

Avonhead West 1,089 60 1,149 1,101 57 1,158 1,164 57 1,221

Avonhead West 1,287 69 1,356 1,320 63 1,383 1,320 78 1,398

North-Western Area 12,288 534 12,822 12,726 552 13,278 13,269 636 13,905

Change from prev census - - - 438 18 456 543 84 627


Rest of City 114,366 8,802 123,168 122,544 8,926 131,470 117,741 17,148 134,889



CHRISTCHURCH CITY 126,654 9,336 135,990 135,270 9,478 144,748 131,010 17,784 148,794



REST OF NZ 1,241,553 138,099 1,379,652 1,343,439 149,795 1,493,234 1,439,685 167,661 1,607,346



NEW ZEALAND 1,368,207 147,435 1,515,642 1,478,709 159,273 1,637,982 1,570,695 185,445 1,756,140



Area Unit or Wider

Geographic Area

A5

TABLE 3A : RATIONALISATION OF WORKPLACE DATA (2006 ex 2013 Census)

Ref

TLA or Sector

Pri

mary I

ndu

str

y

Manu

factu

rin

g &

In

fra-s

tructu

ral

Svces

Constr

ucti

on

Wh

ole

saling, W

are

hou

sin

g,

Tra

nsport

, P

osta

l &

Com

mu

nic

ati

on S

vces

Reta

il T

rade

Personal, B

usin

ess, H

ospit

ality

,

Techno/P

rofe

ssio

nal,

Fin

an

ce,

In

sura

nce a

nd R

ealt

y S

vces

Govern

men

t, E

ducati

onal, H

ealt

h,

Socia

l, A

rts a

nd R

ecre

ati

on

Svces

Oth

er

TO

TA

L

Job S

elf

-suff

icie

ncy %

a Yaldhurst au Workplaces 96 324 45 1,317 129 528 534 18 2,997

b Adjusted 111 357 66 1,538 140 580 580 62 3,434 908.5%

c Yaldhurst au Labour Force 45 33 33 54 39 84 72 21 378

a Rest of City Workplaces 1,917 24,393 8,967 19,875 23,628 44,691 37,398 2,202 163,065

b Adjusted 2,229 26,893 13,139 23,216 25,660 49,066 40,625 7,567 188,395 106.0%

c Rest of City Labour Force 2,772 23,598 12,570 21,840 23,787 46,545 38,711 7,905 177,729

a Christchurch City Workplaces 2,013 24,717 9,012 21,192 23,757 45,219 37,932 2,220 166,062

b Adjusted 2,340 27,250 13,205 24,754 25,800 49,646 41,205 7,629 191,829 107.7%

c Chch City Labour Force 2,817 23,631 12,603 21,894 23,826 46,629 38,781 7,926 178,107

a Hurunui Dist Workplaces 1,980 219 180 249 291 771 597 135 4,422

b Adjusted 2,302 241 264 291 316 846 649 464 5,373 94.3%

c Hurunui Dist Labour Force 2,118 375 291 378 408 945 813 375 5,700

a Waimakariri Dist Workplaces 1,791 1,410 891 798 1,704 2,034 2,067 285 10,977

b Adjusted 2,082 1,555 1,306 932 1,851 2,233 2,245 979 13,183 59.8%

c Waimak Dist Labour Force 2,052 3,330 2,112 2,577 2,775 4,338 3,855 996 22,032

a Selwyn District Workplaces 3,117 879 495 549 894 2,202 2,538 267 10,938

b Adjusted 3,624 969 725 641 971 2,418 2,757 917 13,022 68.5%

c Selwyn Dist Labour Force 3,255 2,190 1,260 1,968 1,869 3,708 4,020 750 19,017

a Rest of Cant'y Region W'kplaces 7,959 6,336 2,556 3,264 5,085 7,206 6,867 834 40,116

b Adjusted 9,252 6,986 3,745 3,813 5,522 7,912 7,460 2,866 47,556 106.1%

c Rest of Cant'y Region Lab F'ce 8,829 7,200 3,090 3,600 5,283 7,452 7,200 2,178 44,838

a Canterbury Region Workplaces 16,860 33,561 13,134 26,052 31,731 57,432 50,001 3,741 232,515

b Adjusted 19,600 37,001 19,245 30,431 34,460 63,055 54,316 12,855 270,963 100.5%

c Cant'y Region Labour Force 19,071 36,726 19,356 30,417 34,161 63,072 54,669 12,225 269,694

a Rest of NZ Workplaces 105,261 177,087 87,561 151,374 187,518 387,531 335,748 28,593 1,460,667

b Adjusted 122,366 195,238 128,303 176,820 203,645 425,470 364,723 98,257 1,714,822 99.9%

c Rest of NZ Labour Force 122,892 195,522 128,190 176,829 203,946 425,460 364,359 98,886 1,716,084

a New Zealand Workplaces 122,121 210,648 100,695 177,426 219,249 444,963 385,749 32,334 1,693,182

b Adjustment factor 1.1625 1.1025 1.4653 1.1681 1.0860 1.0979 1.0863 3.4364 1.1728 100.0%

c New Zealand Labour Force 141,963 232,248 147,546 207,246 238,107 488,532 419,028 111,111 1,985,778

Source : lines a and c : Statistics NZ

lines b : Calculated by Marketplace

Note:

Above industry groupings, other than where separately reported by Statistics NZ, comprise as follows:

Primary Industry : Agriculture, Forestry, Fishing and Mining / Quarrying.

Manufacturing & Infrastructural Services : Manufacturing, Electricity, Gas, Water and Waste Services.

Wholesaling, Warehousing, Transport, Postal and Communication Services : Wholesale Trade; Transport, Postal, Warehousing; Information Media and

Telecommunication Services.

Personal, Business, Hospitality, Techno/Professional, Finance, Insurance & Realty Services : Accommodation and Food; Financial, Insurance;

Rental, Hiring, Real Estate;Professional, Scientific, Technical; and Other Services.

Government, Education, Health, Social, Arts and Recreation Services : Administrative and Support; Public Administration and Safety;

Education and Training; Healthcare and Social Assistance; Arts and Recreation Services.

Other : Not Elsewhere Included.

A6

TABLE 3B : RATIONALISATION OF WORKPLACE DATA (2013 Census)

Ref

TLA or Sector

Pri

mary I

ndu

str

y

Manu

factu

rin

g &

In

fra-s

tructu

ral

Svces

Constr

ucti

on

Wh

ole

saling, W

are

hou

sin

g,

Tra

nsport

, P

osta

l &

Com

mu

nic

ati

on S

vces

Reta

il T

rade

Personal, B

usin

ess, H

ospit

ality

,

Techno/P

rofe

ssio

nal,

Fin

an

ce,

In

sura

nce a

nd R

ealt

y S

vces

Govern

men

t, E

ducati

onal, H

ealt

h,

Socia

l, A

rts a

nd R

ecre

ati

on

Svces

Oth

er

TO

TA

L

Job S

elf

-suff

icie

ncy %

a Yaldhurst au Workplaces 39 564 114 2,415 192 909 801 18 5,049

b Adjusted 43 595 142 2,644 200 958 836 61 5,479 686.6%

c Yaldhurst au Labour Force 39 105 108 90 63 192 177 24 798

a Rest of City Workplaces 2,148 20,181 17,496 19,026 22,155 45,618 42,693 1,689 171,009

b Adjusted 2,348 21,291 21,832 20,830 23,132 48,077 44,550 5,750 187,810 108.7%

c Rest of City Labour Force 2,646 18,795 19,386 19,593 21,150 43,935 41,415 5,895 172,812

a Christchurch City Workplaces 2,187 20,745 17,610 21,441 22,347 46,527 43,494 1,707 176,058

b Adjusted 2,391 21,886 21,974 23,474 23,333 49,035 45,386 5,811 193,290 111.3%

c Chch City Labour Force 2,685 18,900 19,494 19,683 21,213 44,127 41,592 5,919 173,610

a Hurunui Dist Workplaces 2,049 264 291 249 360 918 768 87 4,983

b Adjusted 2,240 279 363 273 376 967 801 296 5,595 89.7%

c Hurunui Dist Labour Force 2,130 423 450 450 453 1,092 993 252 6,240

a Waimakariri Dist Workplaces 1,875 1,731 1,716 951 2,115 2,718 2,967 231 14,307

b Adjusted 2,050 1,826 2,141 1,041 2,208 2,865 3,096 786 16,013 61.9%

c Waimak Dist Labour Force 2,124 3,204 3,516 2,727 3,150 5,202 5,112 840 25,878

a Selwyn District Workplaces 3,501 1,467 1,440 960 1,260 2,841 3,924 243 15,639

b Adjusted 3,827 1,548 1,797 1,051 1,316 2,994 4,095 827 17,455 70.4%

c Selwyn Dist Labour Force 3,501 2,712 2,469 2,739 2,250 4,929 5,523 678 24,804

a Rest of Cant'y Region W'kplaces 8,784 6,552 3,627 3,981 5,355 7,524 8,067 594 44,481

b Adjusted 9,602 6,912 4,528 4,358 5,591 7,930 8,418 2,022 49,361 104.7%

c Rest of Cant'y Region Lab F'ce 9,114 6,963 3,789 4,299 5,403 7,611 8,178 1,770 47,127

a Canterbury Region Workplaces 18,396 30,759 24,684 27,582 31,437 60,528 59,220 2,862 255,480

b Adjusted 20,109 32,451 30,801 30,197 32,823 63,790 61,796 9,743 281,710 101.5%

c Cant'y Region Labour Force 19,554 32,202 29,718 29,898 32,469 62,961 61,398 9,459 277,659

a Rest of NZ Workplaces 108,486 163,743 95,538 160,797 188,808 422,073 403,299 20,526 1,563,255

b Adjusted 118,586 172,749 119,212 176,041 197,134 444,823 420,843 69,873 1,719,261 99.8%

c Rest of NZ Labour Force 119,142 172,989 120,300 176,340 197,499 445,662 421,260 70,155 1,723,347

a New Zealand Workplaces 126,882 194,502 120,222 188,379 220,245 482,601 462,519 23,388 1,818,735

b Adjustment factor 1.0931 1.0550 1.2478 1.0948 1.0441 1.0539 1.0435 3.4041 1.1002 100.0%

c New Zealand Labour Force 138,696 205,191 150,018 206,238 229,968 508,623 482,658 79,614 2,001,006

Source : lines a and c : Statistics NZ

lines b : Calculated by Marketplace

Note:

Above industry groupings, other than where separately reported by Statistics NZ, comprise as follows:

Primary Industry : Agriculture, Forestry, Fishing and Mining / Quarrying.

Manufacturing & Infrastructural Services : Manufacturing, Electricity, Gas, Water and Waste Services.

Wholesaling, Warehousing, Transport, Postal and Communication Services : Wholesale Trade; Transport, Postal, Warehousing; Information Media and

Telecommunication Services.

Personal, Business, Hospitality, Techno/Professional, Finance, Insurance & Realty Services : Accommodation and Food; Financial, Insurance;

Rental, Hiring, Real Estate;Professional, Scientific, Technical; and Other Services.

Government, Education, Health, Social, Arts and Recreation Services : Administrative and Support; Public Administration and Safety;

Education and Training; Healthcare and Social Assistance; Arts and Recreation Services.

Other : Not Elsewhere Included.

APPENDIX TWO : Excerpts from the CHRISTCHURCH RETAIL TRADE

INDICATOR – March 2014 Report Qtr

Christchurch Retail Trade Indicator: March 2014 quarter Embargoed until 10:45am – 24 June 2014

Key facts For the March 2014 quarter, compared with the December 2013 quarter, seasonally adjusted figures show that in Christchurch city:

� Total retail and hospitality sales rose 1.5 percent (nationally, sales rose 0.7 percent). � Retail sales rose 1.8 percent. � Hospitality sales fell 0.1 percent.

Total retail and hospitality growth was similar for Christchurch and New Zealand before the earthquakes, but diverged markedly between the June 2010 and September 2012 quarters. Increases in the Christchurch series over the past year have moved it further ahead of the

national growth level.

Liz MacPherson, Government Statistician ISSN 2253-2803 24 June 2014 � Christchurch retail and hospitality sales move further ahead

� Retail trade sales continue to rise � Hospitality sales fall � Caution about using data

All values are seasonally adjusted, unless otherwise stated, and are not adjusted for price change.

Christchurch retail and hospitality sales move further ahead

Total retail and hospitality sales rose 1.5 percent for Christchurch city in the March 2014 quarter. This follows a 3.4 percent increase in the December 2013 quarter.

Nationally, total sales rose 0.7 percent in the March 2014 quarter, as reported in Retail Trade Survey: March 2014 quarter.

The Christchurch sales trend, as shown in the graph below, fell behind the rest of the country after the quakes began in September 2010. Continued increases over the past year have seen Christchurch city move further ahead of the national trend.

The trend for Christchurch retail and hospitality sales has risen 22 percent since the June 2010 quarter (before the quakes began), compared with a rise of 15 percent at the national level.

This industry grouping combines sales for retail trade and hospitality services (ANZSIC divisions G and H combined).

Christchurch retail sales rose 1.8 percent in the March 2014 quarter. This follows a large increase of 4.2 percent in the December 2013 quarter.

The trend for Christchurch retail sales has risen strongly (up 26 percent) since the slight fall in the December 2010 quarter. This growth continues to be driven by hardware, building, and garden supplies.

The retail industry grouping (ANZSIC division G) includes businesses that mainly sell goods to the public, including motor vehicle and parts retailing, fuel retailing, food retailing, and other store-based and non-store retailing. This grouping currently accounts for 87 percent of the total

retail and hospitality sales in Christchurch.

Hospitality sales fall

Hospitality sales in Christchurch have fallen 0.1 percent in the March 2014 quarter, following decreases of 1.2 percent and 1.0 percent in the December 2013 and September 2013 quarters, respectively.

The trend for hospitality sales has eased slightly in recent quarters, following five quarters of growth, and is 16 percent higher than the most-recent low point in the March 2012 quarter.

The hospitality industry grouping (ANZSIC division H – Accommodation and food services) includes businesses that mainly provide short-term accommodation for visitors, and food and

beverage services. The hospitality group currently accounts for 13 percent of total retail and hospitality sales in Christchurch. About three-quarters of these sales are for food and beverage services, and the rest for accommodation.

Caution about using data

The Christchurch retail trade indicator is an experimental series. We release it to provide information on the state of the Christchurch retail trade industry after the Canterbury earthquakes began in September 2010. The statistics are provisional, because they reflect new methods that we may modify.

When interpreting the data, we recommend focusing on movements in the series rather than the level of sales, because:

� there is a known undercoverage of businesses with no suitable GST or RTS data � sales of capital items may be included in the data � income from insurance payments may be included in the data.

For more information about the design and limitations of the Christchurch retail trade indicator series, see the data quality section.

For more detailed data see the Excel tables in the ‘Downloads’ box.

APPENDIX THREE : Excerpts from the AUSTRALIAN AND NEW ZEALAND

STANDARD INDUSTRIAL CLASSIFICATION (ANZSIC) - 2006

[the version in current usage in 2014]

COMMENTS ON THE ANZSIC 2006 DATA 1. Page 220 is the introductory page to the Wholesale Trade Division of the ANZSIC. It is

all relevant, but the boxed central paragraph is a useful summary of the definition.

2. A list of primary activities which qualify for this definition is available but it is not

included in the Appendix. It spans from page 224 to 226, under Wholesale Group

category 333.

3. Page 244 is the Retail Trade Division introduction, which may be compared with page

220. Again, the boxed paragraph provides a useful summary and contrast.

4. The primary activities within Group 423 are found on pages 253 and 254 of ANZSIC

2006, which are displayed in the Appendix. This list also identifies exclusions, which

default to Wholesale Categories.

5. The examples relate only to activities within Retail Group 423.

6. The Trade Supplier definition in the District Plan covers categories other than "building

suppliers" and "garden and patio suppliers". ANZSIC 2006 categorises such activities

by reference to the definitions at its pages 220 and 244. The full complement can be

accessed on the ANZSIC 2006 web-site.

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