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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 the Proposed Auckland Unitary Plan, Topic 081
Rezoning and Precincts
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CONTENTS
SUMMARY STATEMENT 3
1
INTRODUCTION 5
2
CODE OF CONDUCT 5
3 SCOPE OF EVIDENCE 5
4
SUMMARY OF COUNCIL POSITION 6
5 BENEFITS AND STRATEGIC ALIGNMENT 7
6
METROPOLITAN CENTRE COMPARISONS 9
7 RESPONSE TO COUNCIL OFFICERS 10
8 BUNNINGS SITE, LAMBIE DRIVE, MANUKAU 11
9 GOODMAN PROPERTY TRUST SITE, PLUNKET AVENUE, MANUKAU 13
10
CONCLUSION 15
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SUMMARY STATEMENT
A. We support the rezoning of the land bound by Cavendish Drive, Lambie Drive, State Highway
20 and Puhinui Stream (‘the Site’) from General Business zone to Metropolitan Centre zone.
B. We do not agree with the Auckland Council Officers that the site is not suitable for rezoning due
to the presence of the High Aircraft Air Noise (HANA) overlay or the adjoining Heavy Industry
zone. The HANA results in only a small reduction in the development potential of the site, but,
in our view, does not mean that rezoning the Site to Metropolitan Centre is inappropriate. The
Sensitive Activity Restriction overlay is considered redundant, as the site on the opposite side of
Puhinui Stream owned by Goodman Property Trust (Goodman) at 70-100 Plunket Avenue is
developed with light industrial activities and we support the rezoning of the Goodman site to
Light Industry zone.
C. We consider that the rezoning of Goodman’s land to Light Industry zone reflects the existing
and planned activities on the site and the loss of Heavy Industry zoned land will be ‘offset’ by
the rezoning of Winstone Aggregates’ Wiri land. In accordance with Chapter C, Section 7.12,
Policy 4 the benefits of rezoning the Goodman land will outweigh the reverse sensitivity effects
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network, which includes motorway connections, public transport and walking and cycling
opportunities and will contribute to centre vitality, social cohesion, connectedness and
integration and reduce the cost of infrastructure. Importantly, well located intensification will
ease the pressure for new infrastructure investment and outward expansion of the City.
F. In our opinion, the rezoning of the Site to Metropolitan Centre represents an appropriate
planning response to the policy framework set out in the Regional Policy Statement, the
Metropolitan Centre zone provisions of the PAUP, and the higher order strategic documents.
Importantly, it will provide for more intensive development in a location and manner that will, in
our opinion, enhance and support the role and function of the Manukau Metropolitan Centre.
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1 INTRODUCTION
1.1 This is a joint supplementary planning statement of Jennifer Marie Carvill and Susannah
Vrena Tait.
1.2 Our qualifications, expertise and experience were attached to our statement of evidence
dated 10 February 2016.
1.3 We have been retained by a group of submitters with collective interests in the land bound by
Cavendish Drive, Lambie Drive, State Highway 20 and Puhinui Stream (‘the Site’) comprising
PSPIB Waiheke Incorporated, Harvey Norman, John Woolley and John Murdoch, Mitre10
and Lambie Drive Nominees (the Submitters).
2 CODE OF CONDUCT
2.1 We confirm that we have read the Code of Conduct for Expert Witnesses set out in the
Environment Court of New Zealand Practice Note 2014. We have complied with the Code of
Conduct in preparing this evidence and agree to comply with it while giving oral evidence
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c. A response to those matters raised by Auckland Council (Council) in opposition to the
rezoning of the Site to Metropolitan Centre zone;
d. The rezoning of 55 Lambie Drive, being land occupied by Bunnings Limited
(Bunnings), to Metropolitan Centre zone; and
e. The rezoning of 70-100 Plunket Avenue, being land owned by Goodman Property
Trust (Goodman), from Heavy Industry zone to Light Industry zone.
3.2 In preparing our evidence we have reviewed:
a. The joint statement of evidence of Council witnesses (specifically Anna Jennings,
Roger Eccles And David Wong);
b. Mr Matthew Norwell’s statement of evidence and rebuttal evidence (on behalf of
Bunnings) dated 10 February 2016 and 24 February 2016;
c. Mr Gerard Thompson’s statement of evidence (on behalf of Goodman Property) dated
10 February 2016; and
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5 BENEFITS AND STRATEGIC ALIGNMENT
5.1 As noted in our primary statement2, we consider that there are numerous benefits resulting
from the rezoning of the Site, including:
a. The Metropolitan Centre zone better reflects the existing land use patterns and
development potential for the Site. It builds on the existing Metropolitan Centre zone to
provide for commercial and residential intensification in a location that is well served by
public transport, community facilities and open space. This supports the centres based
approach to planning for commercial growth and is anticipated to support and
strengthen Manukau’s role in the centres hierarchy.
b. The proposed rezoning will increase the realisable retail supply in Manukau3
, which willsignificantly contribute to economic well-being in the area, particularly in the short to
mid-term. The inclusion of the Site in the Manukau Metropolitan Centre will assist with
meeting demand associated with rapid population rise, reduce retail dispersal and retail
leakage, improve amenity and increase product offering. This improved economic
performance will strengthen the Manukau Metropolitan Centre in the hierarchy of
centres and contribute to its function, role and vitality.
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interaction, liveability and visitor experience. Providing for development that is more
intensive and a wider variety of activities on the Site will also ensure more efficient and
effective use of existing infrastructure, and critically will ease the pressure for new
infrastructure investment and outward expansion of the City.
5.2 We consider that rezoning the Site to Metropolitan Centre zone will realise the benefits
outlined above. Conversely, the General Business zone will not realise the potential benefitsand will result in the under-utilisation of the Site.
5.3 Council Officers5 and Mr Norwell have questioned whether the proposed rezoning is well
aligned with the intent of the Regional Policy Statement (RPS). The Council Officers
consider that a General Business zone is the most appropriate way to give effect to the RPS,
but did not provide a detailed analysis. We consider that the rezoning of the Site to
Metropolitan Centre zone is the highest and best use of the Site and is consistent with the
RPS. A detailed analysis of the relevant provisions of the RPS was included in our primary
statement of evidence6. However, we draw attention to the following policies again as we
consider them to be particularly relevant to the proposed rezoning:
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d. Policy B3.1 Commercial and Industrial Growth. Based on the evidence of Mr Philpott,
there are sound economic reasons to include additional land in the Manukau
Metropolitan Centre zone, including a greater ability to meet short term demand
associated with rapid population rise, reduce retail dispersal, potential to reduce
leakage, improve amenity and increase product offering. We also consider that the
inclusion of this Site is an appropriate response to Policy B3.1.5 as it will enable higher
numbers of residents, workers and visitors to establish in close proximity to the
transport network and large urban facilities, while also strengthening the Manukau
Metropolitan Centre in the hierarchy of centres.
e. Policy B3.3 Transport10. Based on the evidence of Mr McKenzie and Mr Hughes, the
rezoning of the Site will create further efficiencies between the transport network and
adjoining land use and therefore has the potential to reduce reliance on privatevehicles.
5.4 Our primary statement also included a section 32 and section 32AA analysis11. We
concluded that the Metropolitan Centre zone is the most efficient and effective means of
achieving the objectives and policies of the PAUP and therefore the most appropriate way to
achieve the purpose of Resource Management Act 1991.
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6.4 As noted in our primary evidence12, Manukau is the second largest centre in terms of
employment and in “nearest catchment” terms, is the closest Metropolitan Centre for
approximately 186,000 people13 (or 13 % of Auckland’s population). As such, Manukau has
the greatest potential demand for retail floorspace (out to 2031) out of any of the City’s sub-
regional areas14. However, Manukau has only the third largest Metropolitan Centre (by land
area) after Henderson and Albany15. Given the scale of employment and the size of the
catchment (including both Manukau and Papakura16), it is reasonable that the Metropolitan
Centre at Manukau should be larger, possibly the largest of the Metropolitan Centres in
Auckland. If the Site is rezoned as proposed, this would increase the Metropolitan Centre by
16.8 ha to approximately 62.5 ha, meaning it would be the second largest of the Metropolitan
Centres after Albany (which is approximately 69 ha – and includes both the Westfield Mall
and the Albany Mega Centre).
6.5 Furthermore, the figures in Attachment A show a notable lack of residential zoned land
adjacent to the Manukau Metropolitan Centre compared to other Metropolitan Centres. We
consider that this further supports the rezoning of the Site to Metropolitan Centre to increase
the opportunity for residential activities to establish in close proximity to retail, commercial,
i i d l t t iti
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7.2 In our primary evidence, we confirmed that the HANA overlay affects only a small portion of
the site (approximately 3.5 ha out of 16.8 ha) (we have attached the overlay map showing
the Air Noise contours at Attachment B). Therefore, the HANA overlay does not significantly
restrict the potential development of sensitive activities within the Site if rezoned to
Metropolitan Centre zone17.
7.3 Furthermore, the Sensitive Activity Restriction overlay is considered redundant, as the site on
the opposite side of Puhinui Stream, which is owned by Goodman Property (70-100 Plunket
Avenue), is characterised by Light Industrial activities. As discussed in Section 6 above, we
support the rezoning of the Goodman site to Light Industry zone.
8 BUNNINGS SITE, LAMBIE DRIVE, MANUKAU
Introduction
8.1 Bunnings has sought to retain the General Business zone for the site that they lease at
55 L bi D i Th it i d b L bi D i N i Li it d h t th
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8.4 Trade Suppliers are permitted activities in the Metropolitan Centre zone19. Furthermore,
additions up to 25 % of the existing GFA or 250 m² (whichever is lesser) are also permitted
activities. Accordingly, minor alterations or additions to Bunnings Manukau would not require
a resource consent that would necessitate an assessment of the amenity of the building or
site.
8.5 However, a larger scale addition to Bunnings would require resource consent. Such an
application would be assessed in accordance with the objectives and policies of the
Metropolitan Centre zone and Assessment Criteria D3.6.2.5 (new buildings and alterations
and additions to buildings not otherwise provided for).
8.6 Notwithstanding this, we consider that a certain level of reasonableness is to be expected of
Council staff when assessing larger format activities in a Metropolitan Centre zone, including
Trade Suppliers, Garden Centres, Supermarkets, Light Industry and Servicing activities and
Warehousing and Storage, all of which are permitted activities in the Metropolitan Centre
zone.
8 7 W id it ld th f b i i t d i l di t id f th ti iti
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Reverse sensitivity
8.9 Trade Suppliers are permitted activities in the Metropolitan Centre zone and the General
Business zone. Dwellings and Visitor Accommodation are also permitted activities in the
Metropolitan Centre zone, although they are not permitted in the General Business zone.
Mr Norwell has cited reverse sensitivity as a concern for Bunnings22. In considering
Mr Norwell’s opinion, we have considered the implications of the mediated noise provisions
(Topic 040)23 as outlined below.
8.10 We agree with Mr Norwell that the night-time noise limit (11pm-7am) will reduce by 5 dBL Aeq
(from 65 dBL Aeq to 60 dBL Aeq) if the Site is rezoned from General Business zone to
Metropolitan Centre zone. However, Mr Norwell does not take into account that Noise
Sensitive Spaces must be designed and insulated so that internal noise levels are managed.
Specifically, Bedrooms and Sleeping Areas are required to achieve 35 dBL Aeq between 11pm
and 7am and other Noise Sensitive Spaces are required to achieve 40 dBL Aeq at all other
times.
8.11 The requirement for Noise Sensitive Spaces to be responsible (at least partly) for managing
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Manukau area. Importantly, retaining Plunket Avenue HI zoning provides for larger HI zoned
block and a better protection against possible reverse sensitivity effects that could arise.
Retention of the HI zoning is the most appropriate way to achieve the objectives of the zone
gives effect to the RPS. (This position is consistent with the 051-054 evidence.)
9.2 As noted in our primary statement25, the nature of the activities on the Goodman site better
align with the Light Industry zone than with the (currently proposed) Heavy Industry zone. In
his evidence26, Mr Gerard Thompson states that the existing activities are a better fit with
those anticipated and provided for in the Light Industry zone. He further notes that there are
no manufacturing activities occurring on the land and that there is little prospect that the land
will ever transition to heavy industrial activities.
9.3 Our primary evidence considered that the rezoning of the Goodman land to Light Industry
was appropriate, largely because of the nature of the existing activities, but also because the
proposed rezoning of Winstone Aggregates’ Wiri land to Heavy Industry zone would offset
any potential loss of Heavy Industry zoned land. Importantly, we noted that the rezoning is
consistent with proposed Section 7.12, Policy 427 of the Air Management provisions which
id f th i f l d h th b fit f th i ill t i h th
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existing Metropolitan centre zone boundary), which in turn would reduce to approximately
500 m if the Site is rezoned to Metropolitan Centre (which is comparable to the Sylvia Park
separation distance).
9.6 We consider that rezoning both the Goodman land and the Site (to Light Industry zone and
Metropolitan Centre zone respectively) and consequently increasing the separation distance
between the Manukau Metropolitan Centre and the nearby Heavy Industry zone is more
consistent with other Metropolitan Centres and provides better air quality management and
therefore amenity values for the Manukau Metropolitan Centre.
10 CONCLUSION
10.1 We support the rezoning of the Site to Metropolitan Centre zone. We consider that the
rezoning of the Site will support a quality compact city, by intensifying development in the
‘right’ location where retail demand has been demonstrated and where office and civic
activities are appropriate, and residential and visitor accommodation can be supported. The
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10.3 We consider that rezoning Goodman’s land to Light Industry better reflects the existing and
planned activities on the site and will be ‘offset’ by the rezoning of Winstone Aggregates’ Wiri
land. The rezoning of the Goodman land will outweigh the reverse sensitivity effects on other
Heavy Industry zoned land (as required by Chapter C, Rule 7.12, Policy 4). Lastly, the
rezoning of both the Goodman land and the Site will result in separation distances (from
Heavy Industry zoned land) that are more comparable to other Metropolitan Centres.
10.4 We note that Lambie Drive Nominees Limited, as owners of 55 Lambie Drive, support the
rezoning of this site to Metropolitan Centre zone. We consider that the Metropolitan Centre
zoning will enable the ongoing operation, expansion or redevelopment of the site for Trade
Supplier activities. The PAUP includes suitable development controls in Metropolitan Centre
zones aimed at avoiding reverse sensitivity effects and limiting noise generating businesses.
10.5 Overall, we consider the proposed rezoning of the Site to Metropolitan Centre zone will better
achieve the strategic outcomes sought in the relevant higher order planning documents, the
zoning principles established by the Panel, and better achieves sustainable management
under Part 2 of the Resource Management Act 1991.
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Attachment A
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©
G o l d e r A s s o c i a t e s ( N Z ) L t d .
Manukau
Henderson Newmarket
Albany
¯
Area: 45.83 ha --> 62.68 ha | Distance: 0.85 km --> 1.16 kmExisting Retail GFA: 88,500 m
2(SFR share 56%) --> 152,100 m
2
(SFR share 33%) Area: 69.02 ha | Distance: 1.49 kmExisting Retail GFA: 148,100 m
2(SFR share 33%)
0 200 400
Metres 0 200 400
Metres
Proposed MetropolitanCentre Zone Extension
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©
G o l d e r A s s o c i a t e s ( N Z ) L t d .
Sylvia Park
Westgate / Massey North Takapuna
Botany
¯
Area: 21.50 ha | Distance: 0.80 kmExisting Retail GFA: 84,900 m
2(SFR share 45%)
Area: 23.46 ha | Distance: 0.67 kmExisting Retail GFA: 70,400 m
2(SFR share 39%)
0 100 200
Metres
0 100 200
Metres
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©
G o l d e r A s s o c i a t e s ( N Z ) L t d .
New Lynn Papakura
¯
Area: 44.55 ha | Distance: 1.10 kmExisting Retail GFA: 78,700 m
2(SFR share 58%)
Area: 23.79 ha | Distance: 0.98 kmExisting Retail GFA: 69,000 m
2(SFR share 76%)
0 200 400
Metres
0 200 400
Metres
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Attachment B
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Attachment B – Noise contours
Legend
The site HANA
MANA ANAA