BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL

IN THE MATTER of the Resource Management

Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010

AND IN THE MATTER of 051 - 054 Centre Zones,

Business Park and Industrial Zones, Business Activities and Business Controls, Section D3, D3.1 – D3.9, I3.1 – I3.6

STATEMENT OF REBUTTAL EVIDENCE OF MATTHEW WILLIAM BONIS

ON BEHALF OF AUCKLAND COUNCIL 28 August 2015

1. INTRODUCTION

1.1 My name is Matthew Bonis. I am a Consultant planner engaged by the Council to

respond to submissions received on the notified PAUP and to provide planning

evidence in relation to the Regional Policy Statement (RPS) Issue 051 - 054. I have

the qualifications and experience set out in my evidence in chief dated 27 July

2015.

1.2 I confirm that this rebuttal statement of evidence has been prepared in accordance

with the Code of Conduct for expert witnesses contained in the Environment Court

Practice Note.

1.3 In preparing this rebuttal statement I have read the evidence prepared on behalf of

submitters on Issue 051 – 054. In particular, I have reviewed the evidence of those

parties set out in Attachment ‘A’.

1.4 This rebuttal statement addresses various issues in that evidence.

2. SCOPE

2.1 My rebuttal evidence refers to the ‘consolidated provisions’. These are the

provisions contained as Attachment C to Mr Jeremy Wyatt’s EiC, as amended by

the rebuttal evidence of Council witnesses and attached to Mr Wyatt’s rebuttal

evidence.

2.2 The sub-groups or "themes" that will be addressed in this evidence include the

following:

(a) Overall approach – Economic approaches and the need for flexibility

(Philpott – DNZ, 2863; Heath – NTC, 2632; and Tansley – The Warehouse

2478,)

(b) The Mixed Use Zone – supermarkets (Foster et al (KRG); the

agglomeration rule (Smith, Tansley – the Warehouse 2478); motor vehicle

sales (Panther Knight – Gilltrap, 6269) Trade Suppliers (Norwell, Boerson

– Bunnings, 6096) ;

(c) The General Business Zone – the DNZ / AMP 400m radius to

Metropolitan centres relief (Carvill / Tait – DNZ / AMP, 3863, 4376);

(d) Local Centres – Department stores (Foster et al (KRG), implications from

agglomeration activities (Carvill / Tait – DNZ / AMP, 3863, 4376; Foster et

al (KRG), Smith, Tansley – the Warehouse 2478), offices and

supermarkets (Sousa – Hogan, 5205).

(e) Neighbourhood centres – the place for supermarkets (Foster et al (KRG),

Bull and Heath – NTC 2632)

(f) Identified Growth Corridors – Provision (Carvill / Tait, McKenzie and

Philpott – DNZ / AMP, 3863, 4376; Foster et al (KRG);

(g) Miscellaneous – Manukau Super-Metro zone (Ben Ross, 1606),

Entertainment facilities and Bars and Taverns (Sousa – Hogan, 5205).

3. SUMMARY

3.1 It is my opinion that the nature of the dispute is relatively narrow. The evidence from

the witnesses generally subscribes to support for the strategic approach. There are

specific and focused reservations as to aspects of the implementation of that approach.

3.2 The primary issue is one of the flexibility inherent in the provisions. The witnesses

seek greater or lesser flexibility to accommodate commercial growth necessary to

support rapid increases in retail spending, whilst achieving a compact urban form

and transport integration.

3.3 My review of witness evidence, maintains my view that the consolidated provisions

are the more appropriate. I have concluded that if the Panel reaches a different

view, the addition of further IGCs is preferred to greater accommodation of

commercial activity in non-centre zones.

4. GENERAL APPROACH

4.1 My EiC identified that the majority of parties supported the overall strategic direction

of the PAUP provisions1. Submissions sought either greater relaxation or

compression of commercial opportunities in Auckland’s centre network and

industrial zonings. 1 Bonis EiC 3.3,

4.2 I consider that the experts representing the parties maintain broad, but qualified

support for the provisions.

Mr McKenzie, (DNZ / AMP, 3863, 4376) - supports the centres based approach for

transport outcomes, particularly overall reduction in adverse effects from ad hoc

business development2.

Mr Philpott, (DNZ / AMP, 3863, 4376) - Support for centres based approach,

especially the role of local centres3.

Ms Carvill / Ms Tait, (DNZ / AMP, 3863, 4376) – Largely support for ‘Consolidated

mark-up’ contained in Attachment C of Mr Wyatt’s EiC4.

Foster et al [Key Retailers Group5] provide general support for the approach taken

in the objectives and policies in the business zones6.

Mr Heath, (NTC 2632). Agrees in principle with the Council approach7.

Mr Walker, (Progressives, 5723). General support for the centres based approach

pursued by the Council8.

Dr Fairgray. (Kiwi and Sscentre, 2968, 5253). Support for centres based

approach9.

4.3 A number of matters raised in the respective paragraphs reference, reiterate or

expand on those matters discussed in the Council’s evidence10. There appears to

be no fundamental dispute as to the strategic approach established in the

‘consolidated provisions’ contained in Mr Wyatt’s EiC.

4.4 The strategic approach seeks to: rationalise the extent of zones under the previous

(legacy) zoning regime11

; create certainty in terms of channelling activities into zones

based upon their character, scale and attributes; promote co-ordination of land-use and

infrastructure; recognise industrial land scarcity and manage reverse sensitivity effects;

and create economies of scale. For commercial activities growth is directed by a

coherent framework. Commercial growth is to be accommodated by primarily

intensifying and encouraging activity into the centres hierarchy; enabling commercial

activity in limited number of Identified Growth Corridors, and then other business zones

as appropriate.

2 McKenzie EiC, (DNZ / AMP, 3863, 4376) Executive Summary

3 Philpott EiC, (DNZ / AMP, 3863, 4376) Paragraph 5.2

4 Ms Carvill / Ms Tait. EiC. (DNZ / AMP, 3863, 4376) Paragraph A Summary.

5 5723 (Progs), 2968 (Scentre), 6096 (Bunnings), 2632 (NTC),

6 Foster . Smith, Thompson, Norwell, McGarr.. Paragraph 2.2

7 Mr Heath. (NTC 2632). Paragraph 3.2

8 Mr Walker. (Progressives, 5723). Paragraphs 3.1 and 3.2

9 Dr Fairgray. (Kiwi and Sscentre, 2968, 5253) Paragraph 3.3

10 Wong-Toi EiC, paragraph 5.1.1, Akehurst EiC, Section 5. Bonis, EIC Section 8.

11 Bonis EiC Paragraph 3.3

4.5 In my view the Council’s strategic approach gives effect to the provisions of the RPS12

,

and has appropriate regard to the Auckland Plan13

and other relevant planning

documents.

4.6 To appropriate manage business distribution in this context, in my view, is to:

incentivise commercial activity into centres and a limited number of Identified

Growth Corridors, (through enabling provisions such as permitted activity rules,

non-notification clauses, and provisions that recognise the functional requirements

of important in-centre activities despite urban design conflicts); and discourage out-

of-centre activities through appropriate drafted objectives and policies and the use

of discretionary / non-complying activity status.

4.7 In my view these matters require a consideration based not solely on effects, but

also the management of land use to achieve an appropriate urban form to help

secure desired outcomes14.

4.8 In terms of retail spending growth there appears to be no dispute as to the rapid

rate of retail sales anticipated as a consequence of growth. Unhelpfully, there

appears to be no common metric between the economic witnesses as to what this

represents, or the forecast years. In summary:

S Fairgray. Retail sales projected to increase by $7.1billion to 2031. Retail

floorspace is projected to increase by 1.1million m2. Approximately 50% of this

growth in floorspace is in large format retail15

.

T Heath. Retail sales projected to increase by $14billion to 2041. This could

support16

retail floorspace of an additional 2.8million m2. For supermarkets alone,

an additional $4billion in retail spend is projected to 204117

.

J Fairgray18

, R Philpott19

and M Tansley20

do not identify specific growth figures but

concur with, or have reservations with the Council’s modelling respectively.

Mr Thompson projects a demand in retail floorspace of 1.125million m2 (inclusive of

5 year rolling buffer) ‘over the life of the PAUP’21

.

12

Bonis EiC. Para 7.2, Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 4.1.16. 13

Bonis EiC Para 7.5 -7.16, Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 4.1.8 – 4.1.9. 14

Bonis EiC 8.71. 15

S Fairgray EiC paragraph 6.1. 16

Heath. Paragraph 6.17. 17

Heath Paragraph 4.13. 18

D Fairgray. Paragraph 4.2 19

Philpott. Paragraph 1.3, 1.8 20

Tansley Paragraph 1.1, 8, 9. 21

Thompson (SFH Consultants). Figure 6

4.9 I have outlined at paragraph 8.17 of my EiC the costs associated with an absence

of flexibility or capacity to accommodate a growth in commercial demand. These

include potential capacity issues, crowding out, and increased rents and reduced

customer choice. Ms Bull22 (NTC 2632) has also correctly, in my view outlined plan

integrity and uncertainty issues that may be associated with a planning framework

that unsuitably constrains capacity and flexibility to accommodate likely increases in

retail growth.

4.10 However, the evidence of Mr Akehurst23 and Ms Fairgray24 points to capacity

surplus, with the exception of the middle or the North Shore and mid-western side

of the isthmus. These deficits are intended to be resolved, in part, by provision of

proximate IGC’s at Wairau Road and New North Road – Kingsland. I also take

some comfort from Mr Akehurst’s identification that the demand modelling does not

take account of the provision for an additional volume of commercial and retail

space25 provided by the Future Urban Zone (‘FUZ’).

4.11 Were the Panel to consider greater flexibility was warranted, in my view this would

bring into focus the number of and extent of IGCs26, as well as the regulatory

response in relation to the status of agglomerated retail activities within the MUZ27

and supermarkets in the LIZ28.

5. THE MIXED USE ZONE – SUPERMARKETS, THE AGGLOMERATION RULE,

MOTOR VEHICLE SALES, TRADE SUPPLIERS

5.1 My EiC provides: a description of the mixed use zone in terms of the legacy

provisions29; Section C:2 sets out the analysis with regard to relevant submissions.

Supermarkets

5.2 Foster et al (KRG) seek the insertion of a new policy to the mixed use zone

provisions30. The recommended policy seeks to recognise: the positive contribution

of supermarkets; and explicitly enable supermarkets within the mixed use zone.

22

Bull EiC. Paragraph 30 23

Akehurst. EiC. Paragraph 7.39. 24

S Fairgray. EiC Paragraph 6.15. 25

Akehurst EiC. Paragraph 7.43. Acknowledging Mr Tansley’s concerns with that approach (EiC paragraph 29). 26

Foster et al [KRG]. Paragraph 11.8. Carvill / Tait. Paragraph 9.32. 27

Smith (the Warehouse, 2478) EiC. Paragraph 21. McGarr / Thompson (Kiwi, Sscentre 5253, 2968) Section 3. 28

Heath (NTC, 2632). 29

Bonis EiC (Paragraph 5.6) 30

Foster et al (KRG). Paragraph 7.6, 7.22(b).

5.3 No changes are sought in terms of the activity status which permits supermarkets

up to 450m2, applies a restricted discretionary status where between 450m2 and

2,000m2, and renders supermarkets above 2,000m2 as discretionary activities.

5.4 Paragraph 7.13 of the KRG Planning evidence identifies 10 supermarkets in the

PAUP mixed use zone. Five of these are smaller brands such as Four Square,

Fresh Choice, SuperValue, Nosh and others. There is no identification of scale,

although I reasonably assume that the Pak n Save (1), New World (1) and

Countdown (3) offers will be well in excess of the 450m2 permitted in the zone31.

5.5 The suggested policy is bluntly worded. It seeks to encourage supermarkets

regardless of scale. Neither does it provide criteria as to the management of likely

resultant effects.

5.6 I consider that the requested policy is unnecessary and inappropriate. The

consolidated objectives and policies for the Mixed Use Zone are more nuanced as

to the commercial outcomes anticipated in the mixed use zone. In particular, Policy

2 (relating to distributional effects) and Policy 7 (promoting and management

development to a standard of amenity recognising moderate scale and intensity).

The consolidated provisions do not preclude supermarkets, but equally do not

explicitly seek to enable them regardless of scale and effects. In my view, that

remains the appropriate policy response.

5.7 As discussed in my EiC32 supermarkets vary in scale, catchment and offer. For

larger scale supermarkets, there can be opportunity costs in terms of reducing the

range of anticipated activities in the mixed use zone, decreased opportunities for

intensification, and the generation of adverse transport effects on the roading

network.

5.8 Accordingly the requested policy would be less appropriate in achieving Objectives

1 to 3 which respectively seek: moderate to high intensity residential and

employment; activities that do not diminish the function and role of adjoining

centres; and encouraging a mix of activities.

31

Bonis EiC Paragraph 14.7 identifies six of the 11 supermarkets identified by Council in the zone are less than 2,000m2.

32 Bonis EiC Paragraphs 29.7 – 29.14

The agglomeration rule I:3.3.2, I:3.3.2a and I3.3.2b

5.9 The analysis for introducing Policy 2A and associated provisions I:3.3.2, I:3.3.2a

and I:3.3.2b is identified in my EiC33. The purpose of the provisions is to preclude

agglomeration of retail, and food and beverage outlets in the mixed use zone /

general business zones. The effects that are sought to be managed by the

restricted discretionary activity provision relate to distributional effects, and a shift in

zone integrity through accommodating a wider range of commercial activities than

envisaged in the zone purpose and objectives. The provisions stem from RPS B3.1

which seeks to focus and encourage commercial growth in centres34 yet provide for

commercial growth in business zones where appropriate as subject to criteria35.

5.10 The consolidated provisions are supported by McGarr and Thompson (Kiwi and

Sscentre)36, and Carvill / Tait (DNZ / AMP)37. There is tacit support from Smith (the

Warehouse) with regard to Rule I:3.3.238, but opposition to proposed Rules I:3.3.2a

and I:3.3.2b39. Mr Tansley also opposes Rules I:3.3.2a and I:3.3.2b40.

5.11 Mr Smith identifies that the rule is unnecessary and inappropriate, and that ‘Mr

Bonis’ apocalyptic vision is unsupported by evidence’41. He has identified that food

and beverage outlets have been generally unrestrained by planning provisions in

the past, and that there is a substantial growth projected for cafes and restaurants

where intensification is occurring. Mr Tansley identifies that food and beverage

outlets for on-premises consumption largely follow markets created by communities,

and with off-premises consumption largely replacing retailing in smaller centres. Mr

Tansley is of the view that the markets needs are being met, without collateral

damage42.

5.12 My EiC identifies that there are individual regulatory costs43. In my view these costs

remain offset by the likely extent of community benefits. The provisions remains

appropriate in:

(a) achieving Objectives and Policies in B3.1 which seek to focus commercial

activities in centre;

33

Bonis EiC. Paragraph 14.4, Paragraphs 28.8, Paragraphs 31 and 32 34

B3.1 Objective 2, Policy 2 (Mediated Version) 35

B3.1 Policy 8. 36

McGarr and Thompson EiC. (Scentre and Kiwi, 5253, 2968) Paragraph 1.4, 3.1 – 3.7, 13 37

Carvill / Tait (DNZ / AMP, 3863, 4376) Paragraph 3.3, 4.7.1 – 4.7.3, 6.2.1 – 6.22. 38

Smith (the Warehouse, 2478) 39

Smith (the Warehouse) paragraphs 1, 2 and 9 40

Tansley (the Warehouse) paragraphs 19 - 25 41

Smith (the Warehouse) Paragraph 21. 42

Tansley (the Warehouse) Paragraph 22, 23. 43

Bonis EiC. Paragraph 31.6

(b) provision for some commercial development fringing centres, noting that

this reinforces the centre network, rather than diluting or dispersing

commercial activity44; and

(c) being both effective and efficient in terms of achieving Policy 2A (for the

Mixed Use Zone); and Policies D.3.8.4 and D.3.8.4 of the General

Business Zone in terms of managing the extent of commercial activity in

these zones.

5.13 Lastly, I note my recommendation for the provision is not predicated on an ‘end of

days’ scenario as outlined by Mr Smith. My support for the regulation is based on

the following:

The regulatory status is restricted discretionary with a narrow range of matters

to be considered;

The control does not apply to those parts of the mixed use zone located within

200m of the city centre, metropolitan, town or local centres. I understand that

the majority of the mixed use zone is unaffected by the rule. I have provided

examples of Dominion Road, Newmarket and Otuhuhu at Attachment B to

identify the spatial extent of where the rule would and would not apply for those

examples.

Within the mixed use zone, the control does not apply to retail that is not part of

an integrated development with more than 5 retail activities or a maximum

‘retail’45 total GFA exceeding 1,000m2. This level of permitted development

enables food and beverage demand generated by intensifying communities in

the area to be met46.

Within the general business zone, my observations are that the threshold of five

food and beverage outlets would provide for the existing situation, and in many

instances provide flexibility for provisional increases in such outlets, without

changing the focus of the zone.

Trade Suppliers and Motor Vehicle Sales

5.14 Mr Norwell47 and Mr Boerson48 generally agree with the approach for Trade

Suppliers in the consolidated provisions. They do seek a restricted discretionary

activity status for trade suppliers in the mixed use zone.

44

Akehurst. Rebuttal Paragraph 4.14. 45

Smith (the Warehouse, 2478). Paragraph 46

Tansley. (the Warehouse). Paragraph 22. 47

Norwell EiC (Bunnings, 6096) paragraphs 3.1, 3.2

5.15 Ms Panther Knight49 agrees with the approach for motor vehicle sales, but seeks a

restricted discretionary activity status within the mixed use zone.

5.16 I have set out in my EiC my response to the respective submissions at paragraphs

26.5 to 26.13; I maintain those views.

5.17 I note activities contained within the broad definition of Trade Suppliers range in

scale, form and extent of servicing the needs for the general public. Bunnings,

Placemakers and Mitre10 Mega represent the larger scale offerings within that

spectrum, but exhibit significant differences as to the proportion of sales to the

public.

5.18 There are other Trade Supply formats, such as architectural hardware50 that due to

scale, design and intensity may be more easily accommodated in the Mixed Use

Zone. By comparison to larger space extensive and lower employment density

outlets such as Bunnings / Mitre 10 Mega, smaller grain trade supply outlets would

better achieve the respective objectives and policies. Objective 1 seeks to provide

moderate to high intensity (residential and) employment opportunities; and Policy 7

seeks to promote and manage a reciprocal level of amenity.

5.19 Mr Boerson cogently sets out at his paragraph 7.11 particular functional issues

inherent with establishing a Bunnings warehouse. I understand and agree with his

evidence. He has outlined, that with contextual design and transport management51

that a non-typical format could appropriately be established in more sensitive

environments, such as the mixed use zone. In particular, Mr Boerson outlines that

some 2-3ha is typically required52 to accommodate such an activity.

5.20 A DA status of Trade Suppliers is, in my view, more appropriate in achieving

objective 1 and policy 7 in particular. A DA status allows for:

(a) the broad consideration of the merits of the proposal and the environmental

context for the application;

(b) does not preclude outcomes such as that identified by Mr Boerson for the Grey

Lynn Bunnings outlet; but

48

Boerson EiC (Bunnings, 6096), paragraph 7.6, 7.7. 49

Panther-Kniight EiC (Gilltrap Holdings 6269) paragraph 2.1(a), Section 4. 50

Examples include Knobs and Knockers, Burton Street – Grafton, and 293 Ti Rakau Drive. 51

Boerson. EiC (Bunnings 6096). Paragraph 6.2(b) 52

Boerson. EiC (Bunnings 6096). Paragraph 6.1(a).

(c) neither narrows the consideration of effects and the ability to mitigate such,

which based on the spectrum of activities within the umbrella definition of

Trade Suppliers can vary widely.

Importantly, a DA status still provides for notification as appropriate53

.

5.21 In terms of motor vehicle sales, I acknowledge that the mixed use zone

‘environment’ for the purpose of s76(3) contains the presence of such traders54 Ms

Panther Knight also correctly points to existing clusters of motor vehicle sales

operators in the zone55.

5.22 The Auckland Unitary Plan review and rationalisation of the legacy plans provide for

a revised approach to land use management. RPS B2.156 and B3.157 recognise the

importance of centre fringe areas in terms of both consolidating and intensifying

residential and commercial provision to accommodate Auckland’s rapid growth. The

fundamental consequences, in terms of the application of the mixed use zone to

these areas is an unequivocal signal to the market to intensify such areas.

Promoting either Trade Suppliers or Motor Vehicle Sales as appropriate uses,

regardless of scale or density, in my view does not reflect, or give effect to that

wider regional approach.

5.23 Motor vehicle sales activities are typically space extensive, provide for lower

densities of employment, and have an operational amenity reflecting that context.

Accordingly, the efficient and effective achievement of Objective 1 and Policy 7 in

particular, in my view is more appropriately met through retaining a DA status.

6. THE GENERAL BUSINESS ZONE – DNZ / AMP (3863 / 4367) 400M RADIUS TO

METROPOLITAN CENTRES RULE

6.1 Ms Carvill and Ms Tait seek addition of a new rule58 to the general business zone.

The proposed rule would provide for retail up to 450m2 GFA per tenancy in the

general business zone as an RDA activity, where the general business zone is

53

Auckland Unitary Plan. Part 3:G.2.4 Clause 1 “Restricted discretionary activities will be considered without public or limited notification, or the need to obtain written approval from affected parties, unless otherwise specified in the Unitary Plan…”

54 Bonis EiC. Paragraph 26.12.

55 Panther Knight EiC (Gilltrap 6269) paragraph 4.3.

56 RPS B2.2 Objective 3.

57 RPS B3.1 Policy 7

58 Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 6.4.1 to 6.4.13.

located within a 400m walk from a metropolitan centre zone. There is no supporting

economic evidence provided on this relief from Mr Philpott (DNZ 3863). Respective

assessment matters suggested are intensity and scale, centre vitality and parking

design59. No additional policy is recommended to provide a nexus to the rule60.

6.2 The relief favours a limited number of Metropolitan Centres, being: Sylvia Park;

Westgate / Massey North; New Lynn; and in particular Manukau61 (Attachment C)

given the proximate extent of general business zone around this centre.

6.3 Ms Carvill and Ms Tait support the provision based upon, on their interpretation of:

Policy B3.1 Policy 562; and the Economic Expert Joint Statement63. That statement

reflects the understood principle that expanding centres provides a preferable

approach to increasing retail capacity, compared to non-centre locations. I have

provided evidence to the Panel on this matter in the RPS considerations of B3.164.

6.4 I consider that Ms Carvill and Ms Tait have conflated the principle stated in the

Economic Joint Statement with that of the purpose and application of B3.1 Policy 5.

That policy is not unconstrained; it provides for the managed expansion of the

centre (zoning) upon having regard to a number of factors65. I do not find support for

the DNZ / AMP proposition within B3.1 Policy 5, and there is no evidence provided

by DNZ / AMP that would suggest that matters (a) to (h) have been considered.

59

Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 6.4.10 60

Carvill / Tait (DNZ / AMP 3863, 4376). Paragraphs 4.8.1 -4.8.3 61

Carvill / Tait (DNZ / AMP 3863, 4376). Attachment E. 62

Carvill / Tait (DNZ / AMP 3863, 4376). Paragraph 6.4.5 63

Carvill / Tait (DNZ / AMP 3863, 4376). Paragraph 6.4.5 64

Bonis EiC B3.1 Paragraph 5.28 and 6.47 to 6.55 65

5. Provide for the outward expansion of metropolitan and town centres having regard to whether it:

a. will provide for compact mixed-use environments on the periphery of the centre; b. will provide for a greater level of access by a community to a wide range of facilities, goods and

services in a convenient and efficient manner; c. facilitates the efficient and sustainable distribution of centres, in relation to the existing

distribution of commercial activity and population growth d. retains or enhances the existing centre’s role and function; e. adversely impacts the role, function, role and amenity of other the city centre, and other

metropolitan and town centres in the hierarchy, to a significant extent beyond those effects ordinarily associated with trade effects or trade competition.

f. manages the effects of commercial activity at the interface with adjoining land uses; g. substantially reduces the opportunity for medium to high density residential development; h. maintains the safety and efficiency of the road network in a way that promotes integrated

transport, by providing strong connections to a range of transport modes including walking and cycling, and enabling efficient connections to the existing public transport network to link with adjoining centres and identified growth corridors. Supports a safe and efficient transport system which is integrated with the centre.

6.5 I also draw to the Panel’s attention to Ms Fairgray’s capacity surplus figures66,

which show an existing surplus of capacity at the four areas where the proposed

rule would provide additional capacity: Sylvia Park; Westgate / Massey North; New

Lynn; and Manukau.

6.6 I agree with the comments of Ms Fairgray67. The additional flexibility is

unnecessary, and would only assist in duplicating or dispersing economic activity

away from the adjoining centre. I do not consider the relief to be appropriate in

implementing the policy, in particular policy 4, nor the objectives for the general

business zone, in particular objective 1.

7. LOCAL CENTRES – AMENDMENTS TO POLICY 6 TO ENCOURAGE

DEPARTMENT STORES; IMPLICATIONS FROM AGGLOMERATION

ACTIVITIES ON LOCAL CENTRES; OFFICES AND SUPERMARKETS

Department Stores

7.1 Foster et al (KRG) seek to amend Policy 6 to provide explicit recognition of

Department Stores in local centres, and provide for their functional requirements68. I

have commented on this matter at paragraphs 12.26 to 12.30 of my EiC, and I

maintain that view. I do not consider that department stores represent a necessary

and present component of the local centre network, such that their recognition and

provision of functional requirements necessitates policy support.

7.2 I have identified that department stores are not precluded by the local centre

provisions, and I note Ms Shilton (the Warehouse 2748) has identified that two

Warehouse offers are located in local centres (Clendon and Snells Beach)69. I

consider that a policy encouraging department stores in local centres, regardless of

scale or composition, would be incongruent with: the zone description; and

objective 1 which seeks to enable commercial activity that primarily serves local

convenience needs.

Offices and Supermarkets

66

S Fairgray. EiC. Figures 1 and 2. 67

S Fairgray. Rebuttal Paragraph 8.1, 8.2. 68

Foster et al (KRG). Paragraph 8.5 69

Shilton EiC (the Warehouse 2478). Paragraph 18.4

7.3 Mr Sousa (Hogan, 5205) seeks to provide greater provision for offices70 and

supermarkets71 as permitted activities in the local zones. A synopsis of Mr Sousa’s

analysis, (and I acknowledge that this summary may be criticized as an

oversimplification) is that:

The actual ‘threat’ of large scale commercial activity in the local centre, is not a

real risk, given the small land holdings and ownership patterns in the local

centre zones;

Mr Hogan has a unique site, capable of supporting larger commercial premises

and managing interface effects, accordingly a permitted status for supermarkets

on sites larger than 1ha is appropriate;

Providing for permitted retail and office uses would preserve Mr Hogan’s

development rights that existed under the Papakura Legacy Plan.

7.4 My EiC responds to Mr Sousa’s office considerations at paragraphs 27.2 – 27.9,

27.16. I also draw to the Panel’s attention the useful summary from Foster et al

(KRG)72. In terms of supermarkets, my EiC outlines my views at paragraphs 29.4 –

29.15.

7.5 The provisions seeking to manage the scale and range of commercial activities

stem from RPS B3.1 which seeks to concentrate such activities in the City Centre,

Metropolitan and Town Centres, given the role of those centres in terms of a

compact urban form and integration with transport. Reciprocal provisions in the

Local Centre seek to limit the scale and intensity of development73.

7.6 The limitations on the scale of offices and supermarkets as expressed in the

consolidated table in my view are more efficient and effective in giving effect to the

RPS, and achieving the respective zone objectives and policies than the approach

recommended by Mr Sousa. As noted in my EiC74 Local Centre policy 4 does not

preclude larger scale commercial activity, but seeks to manage the merits of

specific proposals within the broader framework established by the wider plan.

7.7 Mr Sousa has identified in evidence what he considers to be specific merits

associated with Mr Hogan’s development potential. However in my view, to amend

70

Sousa (Hogan, 5205), paragraphs 9.1 – 9.5. 71

Sousa (Hogan, 5205), paragraphs 10.1 – 10.4. 72

Foster et al (KRG). Paragraph 10.2 – 10.6. 73

Objective 1, 2 and Policies 1 and 4. 74

Bonis EiC. Paragraph 12.23

the Plan framework to accommodate the specific merits of an individual project on a

specific site amounts to the ‘tail wagging the dog’.

7.8 Foster et al (KRG)75 seeks to remove from the Local Centre zone description:

“The zone discourages single, larger scale commercial activity that would

prevent a mix of activities within the local centre”.

The zone description does not have any regulatory effect, but provides a useful

contextual description of the environmental outcomes anticipated in the zone. For

the local centre zone, the zone description reflects both the respective objectives

and policies which seeks a scale and intensity of development reflective of the

surrounding environment76; and the context and description provided in the

Auckland Plan77. In my view, this text has currency and provides context for policy

4 in terms of conveying these attributes, although I note I am not wedded to its

retention.

Impacts on Local Centres

7.9 Rules 3.2(a) and 3.2(b) are discussed above; they seek to manage the

agglomeration of food and beverage outlets in the mixed use and general business

zone respectively. Assessment criteria I:3.6.2.2a seeks to consider the effects of a

breach of these rules on local centres (b ‘centre vitality’, matter (i)).

7.10 This approach is supported by Carvill / Tait (DNZ / AMP 4376, 3863) 78 on the basis

of the importance of local centres within the centre hierarchy, and McGarr /

Thompson (Scentre / Kiwi 2968, 5253)79 that “we consider that local centres are

particularly vulnerable to adverse effects arising from the agglomeration of food and

beverage and small-scale retail in the Mixed Use zone as these are the same sort

of activities that are the most prevalent in the local centres”.

7.11 The approach is opposed by Mr Smith (the Warehouse, 2478)80 as his view is that

it is inevitable that local centres will evolve over time; and Mr Tansley (the

Warehouse, 2478)81 on the basis that there is little or no prospect of a mixed use

zone development having an adverse effect on a local centre, primarily because of

75

Foster et al (KRG). Paragraph 7.3 - 7.5. 76

Objective 1,2 and Policies 1 and 4. 77

Bonis EiC. Paragraph 7.13 78

Carvill / Tait. EiC (DNZ / AMP 4376 / 3863). Paragraph 8.2.1 79

McGarr / Thompson EiC (Scentre / Kiwi 2968, 5253). Paragraphs 4.3, and 4.4. 80

Smith (the Warehouse 2478). Paragraph 35 – 38. 81

Tansley (the Warehouse 2478). Paragraphs 26 – 27

the regulatory constraints on individual larger retailers locating in the mixed use

zone.

7.12 Mr Akehurst has set out in his rebuttal evidence the predominance of food and

beverage outlets within the Local Centre network, and his support for retention of

the scope of the current assessment matters to include local centres.

7.13 I consider that the agglomeration of food and beverage outlets (and retail) within the

mixed use zone is most likely to provide a prospective threat to the local centre tier

of the centres network. This is due to the likely overlap with the function and role

performed by the local centre network.

7.14 I agree with Mr Smith’s view that the local centre tier of the centres hierarchy does

not have the regional importance established in B3.1, nor composition or sufficient

scale to justify a focus for the growth of commercial activities. In my view however,

local centres are important local physical resources and the effects on individual

centres should be assessed. In my view, there is still a need to consider impacts on

this tier of the centres network. The assessment does not preclude effects, but

requires these to extend beyond “those effects ordinarily associated with trade

effects on trade competitors”.

8. NEIGHBOURHOOD CENTRES – SUPERMARKETS

8.1 Ms Bull (NTC 2632)82 and Foster et al (KRG)83 generally support the approach, but

seek amendment of activity status from the consolidated provisions as follows:

Activity NC LIZ

Supermarkets up to 450m² GFA per tenancy

P NC DA

Supermarkets exceeding 450m2 and up to 2000m² GFA per tenancy

NC RDA NC DA

Supermarkets exceeding 2000m2 per tenancy NC DA NC DA

8.2 Ms Wickham and Mr Akehurst for Auckland have responded with regard to the LIZ.

82

Bull EiC (NTC 2632) paragraphs 6, 38 – 44. 83

Foster et al EiC. Paragraph 7.16

8.3 I retain my consideration of the activity status for supermarkets within the

neighbourhood centre zones84. This is due to:

(a) the status being seen as being both effective and efficient in achieving the

respective policies and objectives, particularly objectives 1 and 2 which

seek to limit the scale and intensity of commercial activities.

(b) the built form and transport intensity of larger scale supermarkets is

typically incongruent with the amenity expectations of both neighbourhood

centres, and the adjoining residential interface.

(c) the displacement of smaller more convenience based activities narrowing

the ability of the local community to access frequent needs. However, it is

acknowledged that in-centre supermarket developments can in some

instances foster reinvestment and improved accessibility to convenience

retail.

(d) the absence of developable sites able to absorb a larger scale

supermarket offer, with the most likely resultant scenario being extension

onto an adjoining zone.

8.4 In terms of matter (d) above, assuming a 40% built form : car parking, loading /

landscaping ratio, supermarkets of up to 2,000m2 GFA require a developable area

of 0.5ha, and supermarkets up to 4,000m2 GFA require some 1.2ha. In my view

these are not realistically obtainable within the scale, current built form, and

fragmented sites represented in neighbourhood zones. The largest 5% of

neighbourhood centres being some 0.6ha to 3.9ha in size85. Figure 1 below

identifies the range and scale of neighbourhood centres. Figure 2 identifies the

cadastral fragmentation.

8.5 There are 539 zoned areas of Neighbourhood Centre Zone, consisting of 1533 land

parcels. The neighbourhood centres typically include clusters of zoned areas that

are separated by road or laneway. A 100m buffer has been utilised to define ‘the

centre’ (refer examples Attachment D)

Figure 1: Neighbourhood Centres Scale

Metric Scale (m2)

Smallest area of zone 142

84

Bonis EiC. Paragraph 29.7 to 29.13. 85

Noting these do not necessary represent contiguous zoned allotments, nor large titles. Refer Attachment B.

Largest 39,761

Mean 2110

Lowest 5% 142m – 417

Lowest 25% 142m – 800

Highest 5% 6198m – 39,761

Highest 25% 2065m – 39,761

Figure 2: Neighbourhood Centres land parcel size

Metric Scale (m2)

Smallest parcel 102

Largest parcel 15,237

Mean 780

8.6 This analysis is not to provide hurdles to the valid considerations raised by both Ms

Bull86 and Mr Heath. I agree that there is a demonstrable need to ensure the

provision of supermarkets across the city to meet growth expectations87.

8.7 The issue comes down to integrity of the zone provisions, scale, and the more

appropriate mechanism to provide additional capacity. Simply put, a larger scale

supermarket extends beyond serving immediate needs, and would likely need to

either traverse into the residential zone, or replace the existing commercial activities

in the centre. The practical effect of the establishment of a larger scale supermarket

is that the role and function of the centre becomes akin to that of a local centre, or

provides a stand-alone supermarket.

8.8 The more appropriate approach in my view is to retain the current rule status within

the framework, and for substantial supermarkets applications to be undertaken by

way of plan change; including zoning the necessary area, and most likely elevating

the status of the centre. A case in point in my view is the difference between Torbay

and Half Moon Bay in terms of their supermarket offer. The latter is served by a

larger scale supermarket (Freshchoice) in the order of 800m2 GFA and is

associated with a range of adjoining convenience and community facilities and

86

MS Bull (NTC 26352). Particularly paragraphs 38 – 44. 87

Mr Heath (NTC 2632) identifies a land area requirement for 90ha to 105ha (to 2041). EiC Paragraph 5.6. Ms Fairgray identifies a requirement for 24 – 29ha (2031) Rebuttal Paragraph 3.15.

should more rightly be deemed a local centre given it serves a reasonably wide

catchment. Torbay contains a smaller supermarket (Four square) and a limited

range of convenience food and beverage outlets.

9. IDENTIFIED GROWTH CORRIDORS – PROVISION

Ms Carvill and Ms Tait (DNZ / AMP 4376 / 3863)

9.1 Ms Carvill and Ms Tait at Section 9 of their evidence, provide a critique of the

consolidation version of the provisions as these relate to Identified Growth

Corridors. In summary:

(a) The consolidated provisions are largely supported, including the objectives and

policies88;

(b) An amendment is sought to the zone description seeking to explicitly state that

IGCs are to provide overflow capacity for large format retail activities unable to

locate in centres, and without adversely impacting transport function or centre

vitality89.

(c) Support for the activity table, development controls and assessment matters90,

except: for retail activities between 200m2 - 450m2 in area which should remain

DA as included in the consolidated provisions, but below this default to the

activity status of the underlying zone91; and trade suppliers which should default

to the underlying zone92.

(d) Support for IGCs at Kingsland, Wairau Road93 and Stoddard Road94.

(e) Opposition to IGCs at Lincoln Road95 and Ti Rakau Drive96.

9.2 In terms of matter (b) above, Ms Carvill and Ms Tait seeks the insertion of the

following into the zone description:

The primary function of the Integrated (sic) Growth Corridors is to provide overflow capacity for

large format retail activities that are unable to establish in centres. It is not anticipated that the

overlay areas will become retail corridors that would adversely impact on the transport function of

the corridor, or the function and vitality of centres.”

88

Ms Carvill and Ms Tait (DNZ / AMP 4376 / 3863). Paragraph 9.1.1 89

Ms Carvill and Ms Tait. Paragraph 9.1.9 90

Ms Carvill and Ms Tait. Paragraph 9.2.1 91

Ms Carvill and Ms Tait. Paragraph 9.2.8 92

Ms Carvill and Ms Tait. Paragraph 9.2.11 93

Ms Carvill and Ms Tait. Paragraph 9.3.3 94

Ms Carvill and Ms Tait. Paragraph 9.3.10 – 9.3.16, acknowledging concerns raised by Messrs Philpott and McKenzie. 95

Ms Carvill and Ms Tait. Paragraph 9.3.17 – 9.3.21 96

Ms Carvill and Ms Tait. Paragraph 9.3.22 – 9.3..27

9.3 The rationale for their recommendation is: the evidence from Mr Philpott97 that the

IGC overlay is primarily a release valve for large format retail, and that if

unmanaged may compromise the viability of centres; and Mr McKenzie’s

commentary on the implications for transport efficiency98.

9.4 I consider that the proposed amendments unnecessary and inappropriate. In

particular, I oppose the blunt assertion that there be no adverse impacts on the

transport function of the corridor, or the function and vitality of centres from the

establishment of IGC’s. In my view, this overlooks the activity table and associated

assessment matters that require consideration of such matters, and an absence of

some qualification as to magnitude of acceptability of such effects in

accommodating growth. In my view these matters, as raised by Ms Carvill and Ms

Tait are more appropriately stated in the existing consolidated provisions as below:

Where commercial activities are enabled by an identified growth corridor, these should:

respect the current land uses and the outcomes anticipated by the underlying zone

support a compact urban form

maintain the safety and efficiency of the road network and promote integrated transport

not diminish the function, role and amenity of the city centre, metropolitan, town and local

centres.

9.5 Both Mr Akehurst99 and Ms Fairgray100 have commented on the issue, and agree

that the formation of de facto centres should be avoided on IGCs. They agree that

the provisions are appropriately set to achieve that outcome. Ms Fairgray has also

identified that retail floorspace is projected to increase by 1.1million m2 by 2031,

with approximately 50% as large format retail101, and thereby there is also a need to

accommodate some 50% that must by association be non-LFR within the

respective business zones of the City. My reading of their evidence does not

extend to explicitly amending the zone description in the manner sought, as the

zone description already cogently expresses this as:

These provisions are applied to a limited number of significant road corridors or significant segments of these corridors. The purpose is to provide additional opportunity to those commercial activities (predominantly retail activities) that:

may not be appropriate for, or are not able to locate in centres due to the size, scale or

nature of the activity, and

are not typically provided for in the underlying zone.

97

Mr Philpott (DNZ / AMP 4376 / 3863) Paragraph 7.6 98

Mr McKenzie (DNZ / AMP 4376 / 3863) Paragraphs 4.1-4.9 99

Akehurst. Rebuttal. Paragraphs 7.2, and 7.4 100

S Fairgray. Rebuttal. Paragraph 6.2 101

S Fairgray. EiC. Paragraph 6.1.

9.6 I terms of matter (c), Ms Carvill and Ms Tait seek to amend the provisions such that

retail activities below 200m2 GFA default to the underlying zone, as would trade

suppliers.

9.7 Economic support from Mr Philpott is predicated on the capacity for trade suppliers

to be accommodated in other business zones of the City, and therefore there is no

‘need’ to accommodate these in the IGC locations102. He also identifies that small

scale retail and service activities in combination with LFR ‘would’ create a de facto

unplanned centre103. I am not aware of any analysis in his evidence as to what the

resource management consequences (in terms of either effects, or consideration of

the policy framework) would be, or whether these matters are appropriately (or

otherwise) considered in the respective activity table, and associated assessment

matters.

9.8 The evidence of Ms Fairgray is that the provisions are appropriately set to consider

the implications of retail below 200m2 as a DA104. Accordingly, I do not agree with

Ms Tait, Ms Carvill and Mr Philpott as to amending the activity status for retail below

200m2 GFA as applied to the IGC overlay.

9.9 With trade suppliers, Ms Fairgray does not support the approach of Ms Carvill and

Ms Tait. Ms Fairgray considers that it would be appropriate for trade suppliers to

locate within all areas of IGCs and potentially agglomerate with other retail105. Mr

Philpott does not state the basis of his opposition is to trade suppliers within IGCs,

beyond that of there being no ‘need’106. The only resource management effect that I

consider that could stem from such an approach is one of opportunity costs as to

the efficient utilisation of IGCs; although this is not stated in the evidence of Mr

Philpott.

9.10 Whilst there may be opportunity costs for the efficient utilisation of IGCs, I consider

this risk to be minimised based on:

The current application of IGCs within the consolidated provisions. Lincoln

Road, Wairau, Ti Rakau Road, and parts of Stoddard Road have an underlying

light industry zoning which permits trade suppliers;

102

Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.12, 7.13 103

Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.9 and 7.10 104

S Fairgray. Rebuttal. Paragraph 6.2. 105

S Fairgray. Rebuttal. Paragraph 6.4. 106

Philpott. (DNZ / AMP 4376 / 3863) Paragraph 7.13

Those parts of Stoddard Road, Kingsland and Lincoln Road zoned mixed use

zone already contain a substantial proportion of trade supply activity107, and the

IGC provisions would assist in recognising and providing for existing activities;

and

I am unsure as to how ‘need’ as framed by Mr Philpott with regard to the

provision of trade suppliers in IGCs can be substantiated as necessary to

manage a specific resource management effect.

9.11 Lastly in terms of matter (e), Ms Carvill and Ms Tait identify their opposition of IGCs

at Lincoln Road108 and Ti Rakau Drive109.

9.12 The basis of the opposition is:

(a) transport effects as outlined by Mr McKenzie, in particular that corridors should

be a secondary or subsidiary approach centres to achieve the objective for a

compact urban form, and a preferable approach to managing transport

efficiency and safety110

- that approach is endorsed by Mr Wong-Toi111

; and

(b) an absence of a retail supply deficit in Council’s economic model (which has

then been extrapolated to a likely impact on centre vitality)112

– which Mr

Akehurst suggests does not represent a nuanced consideration of the model

outputs, and would result in removing managed flexibility for additional retail

provision in the City113

.

9.13 Lincoln Road and Ti Rakau Road are discussed at paragraphs 20.18 to 20.28 of my

EiC. There is little further that is raised by parties witnesses that is not already

expressed in that evidence. I do wish to however respond to the following matters:

(a) In terms of Lincoln Road, I do not agree with the assertion by Ms Carvill, Ms

Tait or Mr Philpott that an IGC on this corridor is inappropriate as it may

compromise the amenity and vitality of the Henderson Metropolitan Centre114

.

The DNZ / AMP witnesses appear to base their assertion that if the Council’s

model does not identify a retail deficit in supply (which in this instance it does,

albeit a modest deficit), then additional provision must result in a significant

adverse effect on proximate centre vitality and amenity.

107

Refer S Fairgray. Table 2. 108

Ms Carvill and Ms Tait. Paragraph 9.3.17 – 9.3.21 109

Ms Carvill and Ms Tait. Paragraph 9.3.22 – 9.3..27 110

McKenzie. (DNZ / AMP 4376 / 3863) Section 2. 111

Wong-Toi. Rebuttal. Paragraph 4.11 112

Philpott (DNZ / AMP 4376 / 3863) Paragraphs 8.5, 8.6 and 8.14. 113

Akehurst. Rebuttal. Paragraph 7.4 – 7.6 114

Philpott (DNZ / AMP 4376 / 3863) Paragraph 8.14 is more assured in stating there would be an impact.

(b) This represents an overstatement of the purpose of the model, as well as the

ability of the IGC provisions to temper such effects. The model identifies the

appropriateness of further retail by location, and the ability of existing zoned

business zones to provide for growth in retail demand to 2031. To extrapolate

the conclusions of the model to be determinative of a significant adverse effect

on a specific centre is incorrect. The usefulness of the model is fundamentally

based upon around aspects of “urban form – whether spatial structural

changes are required to the centre network and what form the emergence of

new centres [and IGCs] may take”115

in order to provide for retail spending

growth and provide for community wellbeing.

(c) I also note Mr Akehurst’s response (to Mr Philpott) that a limited number of

IGCs are appropriate, regardless of capacity surplus, in order to provide

appropriate flexibility to accommodate larger footprint retailers that may not be

easily located within centres116

. That approach is preferable to the dispersed

spread of LFR into a large number of light industrial zones117

.

(d) Ms Carvill and Ms Tait object to my consideration of the prevailing commercial

character of Lincoln Road in recommending an IGC overlay118

. However, I

consider such an approach to be entirely appropriate in terms of both s5 and

s76(3), which require a consideration of the environment in establishing rules

under s32(1) and (2).

(e) Lastly, in terms of transport, I reiterate the concerns of Mr Wong-Toi’s as to the

traffic considerations associated with an IGC on Lincoln Road119

, and his

agreement with Mr McKenzie120

. It would also be remiss of me as a Planning

witness to not draw the Panel’s attention to Mr Wong-Toi’s concerns as to the

absence of detailed transport assessments associated with the IGC

overlays121

.

(f) In terms of Ti Rakau Drive, opposition stems from the likely dispersal of retail,

and associated transport effects122

. For the reasons set out by Mr Akehurst123

115

S Fairgray. Rebuttal. Paragraph 8.8 116

Akehurst. Rebuttal. Paragraph 7.4. 117

Akehurst. Rebuttal. Paragraph 7.6. 118

Carvill / Tait (DNZ / AMP 4376 / 3863) Paragraphs 9.20 119

Wong-Toi EiC. Paragraph 5.4.22. 120

Wong-Toi Rebuttal. Paragraphs 4.16. 121

Wong-Toi. Rebuttal. Paragraph 4.1 122

Carvill / Tait (DNZ / AMP 4376 / 3863) Paragraphs 9.3.27 to 9.3.28

and Mr Wong-Toi including the need to consider proposed infrastructural

upgrades as recommended in the assessment matters (J:4.4.3), I consider

that the effects of development as an IGC overlay along this corridor can be

appropriately managed.

Foster et al (KRG)

9.14 Foster et al, at Section 11 of their evidence supports the IGC provisions124, the

IGCs in the consolidated provisions125, but seeks additional IGCs126 at:

(a) Constellation Drive, Albany

(b) Great North Road, Arch Hill

(c) Lunn Avenue, Mt Wellington

(d) Ellerslie-Panmure Highway

(e) Great South Road, Takanini (west)

(f) Great South Road, Takanini (east)

9.15 I have considered these matters at paragraphs 20.31 to 20.44 of my EiC. I also

reiterate my statement at paragraph 16.10 of my EiC:

“An inadequate number of IGCs, coupled with a restrictive approach to commercial provision,

renders the mechanism redundant. Too many IGCs will promote a diffuse patter of commercial

activity to the detriment of the centres network”.

9.16 Ms Fairgray has stated this far more eloquently at paragraph 8.8 of her Rebuttal

evidence:

“Therefore, in my view, the issue becomes more focused around aspects of urban form –

whether spatial structural changes are required to the centre network and what form the

emergence of new centres may take. In this respect, I consider the KRG recommendations to

allow retail to locate on an incremental and ad-hoc basis across a range of IGCs a departure

from a centres-based urban form as this type of development may not occur in the form of new

centres. It has the potential to result in lineal tracts of dispersed retail development without the

critical mass or cohesiveness to function as a centre. As such, in my view, I do not consider

that the KRG have adequately taken into account the possible effects on existing centres if new

configurations of retail were to emerge; or the benefits of a centre configuration of retail”.

9.17 I am unassisted by the analysis contained in the KRG evidence.

123

Akehurst. Rebuttal. Paragraph 7.4. 124

Foster et al (KRG). Paragraph 11.1, 11.4 125

Foster et al (KRG). Paragraph 11.5 126

Foster et al (KRG). Paragraph 11.8

9.18 I maintain my view that then KRG Planner’s recommended corridors not be notated

as IGCs. However, and as outlined in paragraph 4.11, if the Panel after considering

all the evidence were of a mind that sufficient commercial flexibility was not present

in the Council’s framework, I recommend additional IGCs as a mechanism for

appropriately managing commercial enablement in comparison to greater dispersal.

Accordingly, I note that Ellerslie – Panmure Highway corridor127, has some tacit

economic128 and transport support129; Lunn Avenue130 does not; and the remaining

recommendations from the KRG Planners lie in a spectrum between the two.

10. MISCELLANOUS – ENTERTAINMENT FACILITIES, MANUKAU SUPER METRO

ZONE

Manukau – Super Metro

10.1 Mr Ben Ross (Ben Ross, 1606) has pursued his submission that the Manukau

Commercial centre be rezoned as a ‘Super Metropolitan Centre Zone’ and a suite of

objectives, policies and rules be inserted into the Unitary Plan to manage growth in

the centre. The central premise is that Manukau (and Albany131) should be afforded

greater regional and inter-regional prominence, than the current position as

contained in the Metropolitan Centre tier of the commercial hierarchy.

10.2 I have read Mr Ross’s evidence in its entirety. I do not agree with his proposition. I

retain my views as expressed at paragraphs 10.8, 10.9, 10.32 to 10.34 of my EiC.

10.3 Principally, I reiterate my EiC paragraph 10.34, that there is no appreciable benefit

in the proposition. The Ross approach would not in my view: better give effect to the

provisions of B3.1; would increase the extent of complexity in the plan provisions;

inappropriately be predicated on servicing markets outside the region132 with

resultant transport and retail distribution inefficiencies; and is unnecessary in terms

of providing for additional commercial growth133.

127

Bonis EiC. Attachment B. 128

S Fairgray. EiC. Paragraph 8.32(vii) 129

Wong-Toi. Rebuttal. Paragraph 4.25. 130

S Fairgray Paragraph 8.32 (vii) and Wong-Toi Rebuttal 4.22 Table1. 131

B Ross. 1606. Paragraph 7(a). 132

Bonis EiC 10.18. Refer Ross EiC. Attachment D, Super Metro Centre Objective 1 “To serve as complementary to the main City Centre Zone in servicing core parts of the region (Manukau serving Southern Auckland and arguably the northern Waikato, and Albany in time serving the North Shore, Rodney and Northland)…” 133

S Fairgray. EiC. Figure 1 and 2 Capacity surpluses at Manukau. Refer also Ross EiC paragraph 40 “I agree with Mr Bonis on his point that the Metropolitan Centres do enable significant growth and (in theory) unlimited scope for commercial activities”.

Entertainment Facilities

10.4 Mr Sousa (Hogan, 5205) has raised two concerns with the treatment of

‘Entertainment Facilities’ and ‘Taverns’134 in the consolidated version of the plan.

Two concerns are raised:

Entertainment facilities (‘EFs’) are permitted in the Metropolitan and Town

Centres and the Mixed Use zone. EFs are discretionary in local and

neighbourhood centres. Given the environmental context of local centres, Mr

Sousa considers that EFs should also be permitted in the local centre

zones135; that the 30m buffer rule136 will manage related amenity effects on

sensitive proximate residential activities; and there should be no distinction to

the approach in the mixed use zone.

Taverns nest under the definition of ‘Food and beverage’, which are permitted

within the Local Centre zone. ‘Bars and nightclubs’ are a subset of

‘Entertainment facilities’ which are discretionary in Local Centres137.

Therefore any additions to a tavern could be considered an extension of a

‘bar’ activity and therefore subject to a discretionary resource consent. Mr

Sousa seeks a dedicated definition for ‘bars and nightclubs’ in the plan, such

that the distinction with ‘Taverns’ is apparent.

10.5 My EiC identifies issues associated with accommodating ‘Entertainment Facilities’

in local centres. These relate to both the scale and catchment of such facilities, and

the generation of a higher level of night time activity that can be incompatible with

the anticipated residential amenity surrounding local centres.

10.6 I am not of the view that activities such as ‘theatres’, ‘concert venues’, ‘cinemas’,

and ‘nightclubs138’; would primarily service local convenience needs (objective 1),

nor be of a scale or intensity that respects the surrounding environment (policy 4).

Accordingly, I retain my view that a DA status remains the most effective and

efficient status for such activities in the local centre zones. I question the relevance

of Mr Sousa’s comparison to the mixed use zone which has quite different policy

provisions, and is typically located proximate to the city centre, metropolitan and

134

Sousa (Hogan, 5205). Paragraphs 7.1 – 8.3 135

Sousa (Hogan, 5205). Paragraphs 7.2 136

Land use Rule I:3.3.1 ‘Activities within 30m of a residential zone’. 137

Sousa (Hogan, 5205). Paragraphs 8.1 138

Refer recommendation removing ‘bars’ at paragraph 10.7 and 10.8

town centre zones where such facilities are promoted and a higher level of night

time activity is anticipated.

10.7 I agree with Mr Sousa’s concern as to the differentiation of ‘bars’ within the

spectrum of ‘taverns’ and ‘night-clubs’ and the resultant effect in activity status in

the local centre zone. In my view there is little light between a bar and a tavern. A

‘tavern’ is defined in the PAUP as “Facilities used for the sale and consumption of

liquor on the premises”, which is consistent with the Oxford University Dictionary

(Third Edition) definition. ‘Bar’ is undefined in the PAUP, but defined in the Oxford

University Dictionary (Third Edition) as a ‘room or building for serving alcohol;

tavern’. In my view a ‘Nightclub’ is quite a different proposition in terms of operating

hours, likely catchment and scale, and where whilst alcohol is consumed on the

site, the primary purpose is entertainment by way of amplified music.

10.8 Accordingly, I consider that the intent of Mr Sousa’s concerns can be met, albeit by

different means. The term ‘bars’ should be removed from the definition of

Entertainment Facilities as follows:

Entertainment facilities

Facilities used for paid recreation, leisure or entertainment.

Includes:

cinemas

bars and nightclubs

theatres

concert venues.

This definition is nested within the Commerce nesting table.

In addition to the above change, add ‘Bars and’ to ‘taverns’ in the commercial

nesting table, so it is clear that bars and taverns are nested under food and

beverage:

Retail Food and beverage Bars and Taverns

Restaurants

Finally, add ‘bars and’ to I:3.1.1a Activities within 30m of a residential zone (as

associated with taverns) as follows:

3.1 Activities within 30m of a residential zone

1. The following activities are restricted discretionary activities where

they are located within 30m of a residential zone and are listed as

a permitted activity in the zone activity table:

a. Bars and taverns

b. drive­through restaurant facilities

c. outdoor eating areas accessory to restaurants

d. entertainment facilities

e. child care centres

f. animal breeding and boarding.

This control only applies to those parts of the activities subject to the application that are within 30m of the residential zone.

I do not consider a specific definition of ‘nightclub’ is necessary; the term is well

understood and would now be clearly distinguishable from a ‘bar and tavern’.

11. CONCLUSION

11.1 Except as identified above, I maintain the opinions expressed in my EiC.

Matt Bonis

28 August, 2015

ATTACHMENT ‘A’ – SPECIFIC EVIDENCE REVIEWED

DNZ / AMP (Now trading as PSPIB Waheke Incorporated). Sub. 3863, 4376

D McKenzie – Transport

R Philpott – Economics

J Carvell / Tait – Planning

Bunnings, Sub. 6096

D Boerson – Corporate

M Norwell – Planning Key Retail Group Sub. 5723 (Progs), 2968 (Scentre), 6096 (Bunnings), 2632 (NTC),

Foster et al - Joint Planning Statement

The National Trading Company (‘NTC’), Sub. 2632

V Smith – Planning

A Bull – Corporate

T Heath – Economics The Warehouse, Sub. 2478

V Smith – Planning

F Shilton – Corporate

M Tansley – Economics Progressive Enterprises, Sub 5723

A Walker – Corporate Kiwi / Scentre Sub 5253, 2968

D Drew – Corporate

D Fairgray – Economics

McGarr / Thompson – Planning [only just spotted doing this now]. New Zealand Institute of Architects (Auckland). Sub 5280.

Mr J McKay- Design Gilltrap Group Holdings. Sub 6269.

K Panther Knight- Planning Ben Ross, Sub 1606 Phillip Hagan, Sub 5205

P Sousa – Planner

ATTACHMENT ‘B’ – EXAMPLES OF MIXED USE ZONE AGGLOMERATION RULE 200M SPATIAL IMPLICATIONS

KEYSTONE AVENUE

DOMI

NION

ROA

D

MOUNT ROSK

ILL ROAD

MAY ROAD

MEMORIAL AVENUE

LOUVAIN AVENUE

WINS

TONE

ROA

D

MOUNT ALBERT ROAD

FEARON AVENUE

HARD

LEY A

VENU

E

CAMBRAI AVENUE

DONALD CRESCENT

GIFFORD AVENUE

QUEST TERRACE

JASPER AVENUE

MONS

AVEN

UE CLEGHORN AVENUE

MONS

AVEN

UE

DOMI

NION

ROA

D

LOUVAIN AVENUE

MEMORIAL AVENUE

DOMI

NION

ROA

D

LOUVAIN AVENUE

JASPER AVENUE

MONS

AVEN

UE

DOMI

NION

ROA

D

MOUNT ALBERT ROAD

DOMI

NION

ROA

D

CAMBRAI AVENUE

MAY ROAD

DOMI

NION

ROA

D

MOUNT ALBERT ROAD

MOUNT ALBERT ROAD

MOUNT ALBERT ROAD

DOMI

NION

ROA

D

COPYRIGHT© Auckland Council

0 30 60 M

200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use

Dominion Road (via Mount Albert Road)

PINE S

TREE

T

DUNBAR ROAD

PEARY ROAD

BRIXTON ROAD

QUEENS AVENUE

HALSTON ROAD

DEXTER AVENUE

HALESOWEN AVENUE

TENNYSON STREET

MOUNT PLEASANT ROAD

BIRDSONG LANE

CARMEN AVENUE

TELFORD AVENUE

MONT LE GRAND ROADAR

ABI S

TREE

T

VOLC

ANIC

STRE

ET

LANCING ROAD

TENT

ERDE

N AVE

NUE

KENSINGTON AVENUE

WIREMU STREET

CALGARY STREET

THAMES STREET

HIGHC

LIFFE

ROA

D

ELDO

N RO

AD

MATIP

O ST

REET

DOMI

NION

ROA

D

BALMORAL ROAD

ROCKLANDS AVENUE

OXTON ROAD

MARSDEN AVENUE

GORI

NG R

OAD

VOLC

ANIC

STRE

ET

ARAB

I STR

EET

VOLC

ANIC

STRE

ETEL

DON

ROAD

DOMI

NION

ROA

D

DOMI

NION

ROA

D

DOMI

NION

ROA

D

PINE S

TREE

T

BALMORAL ROAD

ROCKLANDS AVENUE

BALMORAL ROAD

DOMI

NION

ROA

D

DOMI

NION

ROA

D

MARSDEN AVENUE

MATIP

O STR

EET

GORI

NG R

OAD

WIREMU STREET

PINE S

TREE

T

BALMORAL ROAD

CALGARY STREET

DOMI

NION

ROA

D

BALMORAL ROAD

DOMI

NION

ROA

D

BALMORAL ROAD

ELDO

N RO

AD

MATIP

O ST

REET

MATIP

O ST

REET

BALMORAL ROAD

KENSINGTON AVENUE

BALMORAL ROAD

BALMORAL ROAD

COPYRIGHT© Auckland Council

0 50 100 M

200m pedshed200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use

Dominion Road (via Rocklands Avenue)

MILTON ROAD

PROSPECT TERRACE

CROYDON ROAD

ST ALBANS AVENUE

FIRST AVENUE

HERBERT ROAD

KENY

ON AV

ENUE

BURNLEY TERRACE

SECOND AVENUE

TAUPATA STREET

HORO

EKA A

VENU

E

PAICE AVENUE

TONGARIRO STREET

KOWH

AI ST

REET

CROM

WELL

STRE

ET

WOOD

FORD

ROA

D

DOMI

NION

ROA

D

LISNOE AVENUE

PARRISH ROAD

ELDO

N RO

AD

ELIZABETH STREET

BOND STREET

ROYAL TERRACE

GORI

NG R

OAD

KINGSLAND TERRACE

NEW NORTH ROAD

VIEW ROAD

LEAM

INGT

ON R

OAD

PENT

LAND

AVEN

UEEWINGTON AVENUE

ONSLOW ROAD

KING EDWARD STREET

MANA

TU ST

REET

AVEN

HAM

WALK

CHARLES STREET

CARR

ICK P

LACE

CONWAY ROAD

VALLEY ROAD

RALEIGH STREET

HENL

EY R

OAD

TANE

KAHA

STRE

ET

ALDE

RLEY

ROA

D

GEORGE STREET

WAIR

EPO

SWAM

P WAL

K

WALTERS ROAD

HOROPITO STREET

MARL

BORO

UGH

STRE

ET

WYNYA

RD RO

AD

BELLEVUE ROAD

RARA

WA ST

REET

TAWARI STREET

BELLWOOD AVENUE

REIMERS AVENUE

STORMONT PLACE

SANDRINGHAM ROAD

CRIC

KET A

VENU

E

GRIBBLEHIRST ROADGRANGE ROAD

MONT LE GRAND ROAD

DOMI

NION

ROA

D

BURNLEY TERRACE

SANDRINGHAM ROAD

VIEW ROAD

MARL

BORO

UGH

STRE

ET

HORO

EKA A

VENU

E

DOMI

NION

ROA

D

ROYAL TERRACE

PAICE AVENUE

CROM

WELL

STRE

ET

CROMWELL STREETWALTERS ROAD

ONSLOW ROADONSLOW ROAD

KING EDWARD STREET

VALLEY ROAD

BURNLEY TERRACE

DOMI

NION

ROA

D

DOMI

NION

ROA

D

PAICE AVENUE

REIMERS AVENUE

ELIZABETH STREET

VIEW ROAD

CARRICK PLACE

DOMI

NION

ROA

D

KOWHAI STREET

TAWARI STREET

BELLWOOD AVENUE

ELDO

N RO

AD

DOMI

NION

ROA

D

WALTERS ROAD

VIEW ROADNEW NORTH ROAD

WALTERS ROAD

DOMI

NION

ROA

D

WALTERS ROAD

COPYRIGHT© Auckland Council

0 75 150 M

200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use

Eden Valley Local Centre

SEAV

IEW RO

AD

MAURANUI AVENUE

THE G

LEN

ALPERS AVENUE

MACMURRAY ROAD

LAURIE AVENUEFOOT

BALL

ROAD

ADA STREET

PARK ROAD

ST MARKS ROAD ON RAMP

ALMO

RAH

ROAD

MORG

AN ST

REET

EDEN STREET

MORTIMER PASS

MAMIE STREET

BELMONT TERRACE

ALMO

RAH

PLAC

E

SOUTHERN MOTORWAY

ELY AV

ENUE

MARG

OT ST

REET

MAUNSELL ROAD

SARAWIA STREET

NUFFIELD STREET

KHYBER PASS ROAD

KIOSK ROAD DOMAIN DRIVEMA

UNGA

WHAU

ROA

D

BEATR

ICE ROADEDGERLEY AVENUE

PERE STREET

ALMA STREET

GILL

IES AV

ENUE

BASSETT ROAD

DILWORT

H AVEN

UE

MCCO

LL ST

REET

SHORT STREET

TITOKI STR

EET

MELR

OSE S

TREE

T

ALBURY AVENUE

COWIE STREET

YORK

STRE

ET

WITHIEL DRIVE

LAURISTON AVENUE

TEED STREET

RAILWAY STREET

MAHU

RU ST

REET

COVE

NTRY

LANE

OSBO

RNE S

TREE

T

PRIMES LANE

ARNEY ROAD

SUITE

R ST

REET

REMUERA ROAD

GEORGE STREET

BOUR

KE ST

REET

KINGD

ON ST

REET

SILVER ROAD

MIDDLETON ROAD

MAUI

GRO

VE

MORROW STREET

BALM STREET

WOOTTON ROAD

PARN

ELL R

OAD

SWINTON CLOSE

MANU

KAU

ROAD

ST MARKS ROAD

GREAT SOUTH ROAD

GILLIES AVENUE OFF RAMP

AYR STREET

CARLTON GORE ROAD

SECCOMBES ROAD

BROA

DWAY

CARLTON GORE ROAD

SOUTHERN MOTORWAY

SOUTHERN MOTORWAY

GILL

IES AV

ENUE

MIDDLETON ROAD

DILWORT

H AVEN

UE

PARK

ROA

D

GILL

IES AV

ENUE

REMUERA ROAD

FOOTBALL

ROAD

PARNELL ROAD

BASSETT ROAD

BROA

DWAY

BROA

DWAY

ALMO

RAH

ROAD

GEORGE STREET

TEED STREET

GEORGE STREET

BROA

DWAY

BROA

DWAY

BROA

DWAY

MAUN

GAWH

AU R

OAD

BASSETT ROAD

BASS

ETT R

OAD

AYR STREET

BASS

ETT R

OAD

REMUERA ROAD

BASSETT ROADBR

OADW

AY

COPYRIGHT© Auckland Council

0 90 180 M

200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use

Newmarket Metro Centre

LIPPIAT

T ROAD

HUIA ROAD

NIKAU ROAD

ALBION ROAD

SALE

YARD

S ROA

D HAUITI ROAD

MOA STREET

TAMAKI AVENUE

HUTTON STREET

CHURCH STREET

STURGES AVENUE

PUKEITI ROAD

LUKE STREET

WALTERS ROAD

RONAKI ROAD

MARJORIE JAYNE CRESCENT

MANGERE ROAD

PUKEORA ROAD

GOLF AVENUE

WEKA STREET

STATION ROAD

QUEEN STREET

WALMSLEY ROAD

KURANUI PLACE

MCGEE STREET

PAPAKU ROAD

MASON AVENUE

GREAT SOUTH ROAD

MEADOW STREET

ALEXANDER STREET

NGAIO STREET

TAHATAI STREET

PARK AVENUE

AWA STREET

ATKINSON AVENUE

FAIRBURN ROAD

VICTORIA STREET

KING STREET

KAKA STREET

HOKONUI ROAD

AVENUE ROAD

GORDON ROAD

PORTAGE ROAD

FORT RICHARD ROAD

HIGH STREET

PRINCES STREET

OAK GROVE

HALL AVENUE

NIXON AVENUE

PRINCES STREET

CHURCH STREET

GREAT SOUTH ROAD

AVENUE ROAD

NIKAU ROAD

GREAT SOUTH ROAD

PORTAGE ROAD

SALEYARDS ROAD

ATKINSON AVENUE

TAMAKI AVENUE

NGAIO STREET

STATION ROAD

ATKINSON AVENUE

MASON AVENUE

ATKINSON AVENUE

PRINCES STREET

PRINCES STREET

MANGERE ROAD

AVENUE ROAD

NIKAU ROAD

CHURCH STREET

WALMSLEY ROAD

HUTTON STREET

LUKE STREET

HIGH STREET

CHURCH STREET

HUIA ROAD

SALEYARDS ROAD

GREAT SOUTH ROADGREAT SOUTH ROAD

AVENUE ROAD

AWA STREET

HUTTON STREET

NIKAU

ROAD

PORTAGE ROAD

HUTTON STREET

HIGH STREET

CHURCH STREET

PORTAGE ROAD

LUKE STREET

NIKAU ROAD

HOKONUI ROAD

MANGERE ROAD

FAIRBURN ROAD

CHURCH STREET

COPYRIGHT© Auckland Council

0 100 200 M

200m pedshed 200m pedshedMixed Use Zone within 200m bufferLocal CentreTown CentreMetropolitan CentreMixed Use

Otahuhu Town Centre

ATTACHMENT ‘C’ – GENERAL BUSINESS ZONE: 400M BUFFERS TO METRO ZONES

Isola PlaceUlay

Plac

ePettitPlace

AriaPlace

Rimini Place

Ryan Place

Ultim a Place

Kerrs

Road

IhakaPlace

Reagan Road

Israel A

venue

Zircon Place

Lambie Drive

Karoro Court

Thorn Place

Putney Way

Invere ll Court

Caspar R

oad

Lamb

ieDr

ive

Oster

leyWa

y

Davies Avenue

Brooks Way

Ixia Place

Sharkey Street

Pesaro Place

Rata Vine Drive

Jontue Place

CeladonPlac e

Granite Place

Lambie Drive

Lambie Drive

Te Irirangi Drive

Druces Road

Lambie Drive

Townle

y Plac

e

Winspear Place

Ronwood Avenue

Redoubt Road

Inverell Avenue

Sikkim Crescent

Druces Road

Marble Place

Ronwood Avenue

Israel Avenue

Carolyn Street

Lakewood Court

Airport Off Ramp

Barrowcliffe Place

Charntay Avenue

Edorvale Avenue

Leyton Way

Ronwood Avenue

Lamb

ieD r

i ve

Great South Road

Putney Way

Sandrine Avenue

Iliad P lace

Almay

PlaceLeyton Way

Lambie Drive

Liggitt Drive

Druces Road

Amersham Way

Sikkim Crescent

Great Sout hRoad

Courant Place

Plunket Avenue

TrevorHosken Drive

Great South Road

Wilisa Rise

Islay Place

Vetor

i Plac

e

Tourmalin Place

Allenby

Road

Great South Road

Allenby

Road

Cavendish Drive

Allenby Road

Jack Conway A venue

Cavendish Drive

Lambie Drive

Redoubt Road

GreatSout hRo ad

Ronwood Avenue

Joval Place

Great South RoadDiorella Drive

Great South Road

Manukau Station Road

Fairchil d Avenue

Great South Road

Reagan Road

Wiri Stati

onRo

ad

Druces Road

Allenby

Road

PutneyWay

Shalimar Place

Puhinui Road

Sikkim CrescentCavendish Drive

Kerrs Road

Mepal Place

Inverel l Avenue

GranthamRoad

Carruth Road

Boundary Road

Pulm

anPlace

Oak Road

Cavendish Drive

Great South Road

Kerrs Road

Reagan Road

Wind

omaCircle

Win d o ma Circ le

Great South Road

Leith Court

Boundary Road

Mana Place

Ihaka Place

Southern Motorway

Lambie Drive

Puhinui Road

Airport Off Ramp

Edsel Way

Avis Avenue

Carruth Road

Cl i st Crescent

Druces Road

Grea

t Sou

th Ro

ad

Wiri Station Road

Bakerfield Place

Lambie Drive Off Ramp

Awatere St ree t

Plunket Avenue

Earl Richardson Avenue

KellowPl

ace

Eleanor Way

Manukau Station Road

Great South Road Off Ramp

Regent S

treet

NormanSpencerDrive

Te Irirangi Drive

Gladding Plac e

South-Western Motorway

Falcon Road

Buckingham

Cresc

ent

Boundary Road

Wiri Station Road

Freeman Way

Airport Off Ramp

Te Irirangi Drive

Puhinui Road Te Irirangi Drive On Ramp

Hobill Avenue

Lambie Drive Off Ramp

Kerrs Road

Lambie Drive On Ramp

Southern Motorway

Cavendish Drive

Ryan Place

Wiri Station Road

Redoubt Road Off Ramp

Airport Off Ramp

Sikkim CrescentSouthern Motorway

Te Irirangi Drive Off Ramp

Southern Motorway

South-Western Motorway

Redoubt Road On Ramp

South-Western Motorway

Southern Motorway

Southern Motorway

Southern Motorway

South-Western Motorway

South-Western Motorway

COPYRIGHT© Auckland Council

0 140 280 M

Metropolitan Centre that has a General Business zone within 400m

Legend400m buffer from Metropolitan Centre

Unitary Plan Base ZoneMetropolitan CentreGeneral Business

Manukau

Pine Street

Ash S

treet

Clark Street

AshS

treet

Sandy Lane

Totara Avenue

Astle

y Ave

nue

Porta

ge Ro

ad

Bolton Street

Bellamy Place

Arawa Street

Elm Street

Nikau Street

Chaucer Place

StedmanPlace

Pecan Place

Davern Lane

Arran

Stree

t

Hinau Street

Westall

Road

Taylor Street

Titirangi

Road

Mccrae Way

Corr e

gidor

Place

Karaka Street

Chettl e Court

Kohekoh

e Stree

t

Dolan Place

Totara Avenue

Pamela Place Lucknow Plac e

Great North Road

Water

sPlac

e

Mcwhirter Place

Margan Avenue

Bolton Street

Kaweka Street

Lynwo

od Ro

ad

Piment

o Plac

e

Astley

Aven

ue

Ambrico Place

RataStree

t

Bleas

eStre

et

Margan Avenue

Skilgate Avenue

Neville Street

Delta

Aven

ue

Hineko

hu St

reet

Marlo

we R

oad

Hill Crescent

Hetan

a Stre

et

Clark Street

Boler Place

Clark Street

Rata

Stree

tLinksRoad

Clark Street

Puriri Street

DrurySt

reet

Rimu Street

Maui Street

Nikau Street

Miro Street

Rank

in Aven

ue

Margan Avenue

Denyer Place

Ash Street

RataStr

eet

The C

los e

Nikau

Stree

t

Great North

Road

Rata

Street

Hugh Brown Drive

Rimu Street

Sheridan Drive

Amsterdam Place

Crown LynnPlace

Arran

Stree

t

Northall Road

Ash Street

Cutler Street

Great North Road

Riverbank Road

Tiki S

treet

Kay D

rive

Taylor Street

Ash Street

Rata

Stree

t

Reiman Street

Busby Street

Quee

n Mary

Aven

ueRa

taStr

eet

Puriri Street

Islington Avenue

Cutler Street

Miro Street

Crow

n Lyn

n Plac

e

Wairau AvenueKels ton

Street

Hutchinson Avenue

Rickards Place

Clark Street

BeverlyPlace

Porta ge Ro ad

Bin s ted Road

Seabrook Avenue

Titiran

gi Roa

d

Titirangi Road

Mayville Avenue

Stock StreetBentinck StreetCrum Avenue

Great North

Road

Trojan Cre scen

t

Veronica Street

Tane Street

M iro Street

Seabrook Avenue

Hutchinso

n Avenue

Kuaka Place

Astle

y Ave

nue

Swinburne StreetAstley Avenue

Rimu Street

Cople

y Stre

et

Arahoe Road

Rewa Street

TaneStreet

Islington Avenue

Lynwo

odRo

ad

Porta

ge R

oad

Hutchinson Avenue

Portage Road

Wingate Street

Melvie

wPlace

Gardner Avenue

Pine S

treet

Miro StreetRa

nkin A

venue

Portage Road

Arawa Street

Stolford Crescent

Veronica Street

Astley

Aven

ue

Gardner Avenue

Wingate Street

RataStree

t

Hutchinson Avenue

Portage Road

Sheridan Drive

Gardner Avenue

Karak

a Stre

et

Delta

Aven

ue

WingateStreet

Margan Avenue

Portage Road

Queen M

aryAv

enue

Falk ir k Street

Kay Drive

Korom

iko St

reet

Parker Avenue

Lynwo

od Ro

ad

Rimu Street

Arawa Street

Akehurst Avenue

Willerton Avenue

Gardner Avenue

Margan Avenue

Wingate Street

Seabrook Avenue

Crowther StreetAlanbro oke Crescent

Tony Segedin Drive

Seabrook Avenue

Canal Road

Ash Street

Ulster Road

Nacton Lane

Nikau

Stree

t

Links Road

Reid Road

Willerton Avenue

Wattle

Stree

t

Portage Road

Golf Road

Beaubank Road

COPYRIGHT© Auckland Council

0 160 320 M

Metropolitan Centre that has a General Business zone within 400m

Legend400m buffer from Metropolitan Centre

Unitary Plan Base ZoneMetropolitan CentreGeneral Business

New Lynn

Vestey Drive

Pacific Rise

Stu d Way

Carbine Road

Penrose RoadWaipuna Road

StudWay

Aranui Road

Wilson W

ay

CarbineRoad

Ruaw

aiRoa

d Waipuna Road

The Oasis

Allright Place

Waipuna Road

Waipuna Road

Carbine Road

Paci fi c Rise

Allright Place

Carbine Road

Roslyn Road

Pacific Rise

Rowlands Avenue

Jarma

n Roa

d

Waipuna RoadWaipuna Road

Sylvia Park Road

Carbine Road

K eateP lace

Ruawai Road

Rayma Place

Ruawai Road

Mus ke

t Plac

e

Mount Wellington Highway

Tide Close

Irelan

d Roa

d

Ruawai Road

Lynton RoadAllright Place

Roslyn Road

Mount Wellington Highway

Irelan

d Roa

d

Bean Place

Carbine Road

Sylvia Park Road

South-Eastern Hwy Off RampCarm

ont Place

Southern Motorway

Lynton Road

Carbine Road

MountWellington Highway

Timaru P lace

Mount Wellington Highway

Carbine Road

Mount Wellington Highway

South-Eastern Highway

Southern Motorway

Penrose Road

Pacifi

c Rise

LyntonRoad

South-Eastern Highway

Bowden Road

Jame

sWalter Place

Clemow Drive

South-Eastern Highway

Waipuna Road

Matangi Road

Carbine Road

South-Eastern Highway

Ruawai Road

Mount Wellington Hwy On Ramp

Southern Motorway

Ruaw

ai Ro

ad

Arthur Brown Place

South-Eastern Highway

Monahan Road

Southern Motorway

Longford Street

Hamlin Road

Mcrae Road

Hamlin Road

Mount Wellington Hwy Off Ramp

Southern Motorway

Vestey Drive

Southern Motorway

Mount Wellington Hwy Off Ramp

South-Eastern Highway

South-Eastern Hwy Off Ramp

Sylvia Park Road

Aranui Road

South-Eastern Highway

Mount Wellington Hwy On RampSouthern Motorway

Southern Motorway

Southern Motorway

South-Eastern Hwy Of fRam

p

Mount Wellington Hwy On Ramp

Clemow Drive

COPYRIGHT© Auckland Council

0 100 200 M

Metropolitan Centre that has a General Business zone within 400m

Legend400m buffer from Metropolitan Centre

Unitary Plan Base ZoneMetropolitan CentreGeneral Business

Sylvia Park

Main

Stree

t

Ballia l Place

Fernhill Drive

Trig Road

Main Street

Rua Road

Westgate Drive

Don B

uck R

oad

Asti Lane

Lazuri

te Drive

Cinnabar Pla ce

Westgate Drive

Pinot Lane

Stonegate Close

Rush Creek Drive

StMa

rgaret

Place

Trusco

tt Place

Fitzh

erbert

Aven

u e

Whit shire Mews

Tahi Road

Alloway Street

Westgate Drive

Fernhill Drive

Hueglow Rise

Trig Road

Alloway Street

Woodh

ousePlace

Westgate Drive

Rima Road

Holmes Drive

Rua Road

Oreil Avenue

Waru Road

Fred Taylor Drive

Lazurite Drive

Hobsonville Road

Don B

uck R

oad

Carne

lianCo

urt

Fred Taylor Drive

Beauchamp Drive

St Catherine Crescent

Richfi

eld Cr

esce

nt

Westgate Drive

Jade

wynn

Drive

Waru Road

Holme

sDrive

St Cath

erine

Cres

cent

Regen ts Park

Place

Main Street

Rua Road

Cabernet C rescent

Richf i

eldCre

s cen

t

Hobsonville Road

Tahi Road

Toru Road

Arlose Place

Rush Creek Drive

Uppe

r Harb

our M

otorwa

y

Reybert Place

RuaRoad

D onB

uckR

oad

Fred Taylor Drive

Rima Road

Rua RoadUpper Harbour Motorway

Oreil

Aven

ue

FresilLane

Trig Road

Hobsonville Road

Don B

uck R

oad

North-Western Motorway

Westga te Drive

Fred Taylor Drive

TrigRoad

Off Ramp

Oreil Avenue

Oreil Avenue

Hobsonvil leRoad Off Ramp

Jadewynn Drive

Upper Harbour Motorway

Tahi Road

Westgate Drive

North-Western Motorway

Fred Taylor Drive

R uz e Vida Drive

Tahi Road

Uppe

r Har b

our M

otorwa

y

Baker La

ne

North-Western MotorwayNorth-Western Motorway

North-Western Motorway

North-Western Motorway

Hobsonville Road Off Ramp

North-Western Motorway

Hobsonville Road On Ramp

North-Western Motorway

Upper Harbour Motorway

Upper Harbour Motorway

North-Western Motorway

COPYRIGHT© Auckland Council

0 110 220 M

Metropolitan Centre that has a General Business zone within 400m

Legend400m buffer from Metropolitan Centre

Unitary Plan Base ZoneMetropolitan CentreGeneral Business

Westgate / Massey North

ATTACHMENT ‘D’ – NEIGHBOURHOOD CENTRE EXAMPLES (SCALE AND CONFIGURATION)

Hi llsboroughEA

TON

ROAD

CLIFTO

N ROAD

HILLS

BOROUGH ROAD

ALEXBOYD

LINK

PREN

TICE P

LACE

WHITMO

RE RO

ADNOTON ROAD

KATHRYN AVENUE

RICHARDSON ROAD

FLORENCE DALY PLACE

ALDERSGATEROAD

ROGAN STREET

STAVELEY AVENUE

OAKDALE ROAD143

397

833

1920

CINDY PLACE

EDGEWATER DRIVE

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