AUCKLAND UNITARY PLAN OPERATIVE IN PART

PROPOSED PLAN CHANGE 30

Pukekohe Park Raceway (Private)

SUMMARY OF DECISIONS REQUESTED

Enclosed

bull Explanation

bull Summary of Decisions Requested

bull Submissions

Explanation

bull You may make a ldquofurther submissionrdquo to support oroppose any submission already received (seesummaries that follow)

bull You should use Form 6bull Your further submission must be received by 08

November 2019bull Send a copy of your further submission to the original

submitter as soon as possible after submitting it to theCouncil

Summary of Decisions Requested

Sub Sub Point Submitter Name Address for Service Theme Summary Reasons

1 11 Keith Houston keithcarevetsconz Flooding stormwater Decline the plan modification unless it is amended to address and resolve concerns raised

The plan change area is subject to flooding There should be a provision in the plan change which requires a minimum

freeboard level of 500mm above the 100 year flood level

2 21 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The ITA should be amended to ensure a full and appropriate assessment of the adverse effects of the plan

change on the local and wider transport network

2 22 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

Clarification is required for the traffic modelling as there is still uncertainty in the actual and potential effects of the

proposed rezoning

2 23 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is a lack of specific assessment of the potential effects of removing parkng during large events

2 24 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is uncertainty around the provision of upgrades to transport infrastructure to support public and active

transport modes

2 25 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The development constraints caused by natural hazards and the potential for adverse effects on transport

infrastructure has not been adequately considered

2 26 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is the potential for multiple conflict points between the main road and the driveways which may be formed

2 27 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The assessment of potential cumulative effects of increased traffic generation has been inadequate

2 28 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There are no appropriate mechanisms identified to ensure that the matters raised in the ITA and the matters identified

in this submission can be appropriately addressed

3 31 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe is currently facing a notable shortfall of land for businessindustry use Pukekohe is losing business

opportunities as a result

3 32 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe Park is an asset to Pukekohe and the wider Auckland region through its ability to host a range of events

The plan change will help the club to continue their operations

3 33 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

The Plan Change will see an extension of business uses which is contiguous with the existing business activites along Manukau Road There are benefits such as co-

location and access to existing transport infrastructure

Plan Change 30 - Pukekohe Park Raceway Summary of Decisions Requested

1 of 1

Submissions

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

Explanation

bull You may make a ldquofurther submissionrdquo to support oroppose any submission already received (seesummaries that follow)

bull You should use Form 6bull Your further submission must be received by 08

November 2019bull Send a copy of your further submission to the original

submitter as soon as possible after submitting it to theCouncil

Summary of Decisions Requested

Sub Sub Point Submitter Name Address for Service Theme Summary Reasons

1 11 Keith Houston keithcarevetsconz Flooding stormwater Decline the plan modification unless it is amended to address and resolve concerns raised

The plan change area is subject to flooding There should be a provision in the plan change which requires a minimum

freeboard level of 500mm above the 100 year flood level

2 21 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The ITA should be amended to ensure a full and appropriate assessment of the adverse effects of the plan

change on the local and wider transport network

2 22 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

Clarification is required for the traffic modelling as there is still uncertainty in the actual and potential effects of the

proposed rezoning

2 23 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is a lack of specific assessment of the potential effects of removing parkng during large events

2 24 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is uncertainty around the provision of upgrades to transport infrastructure to support public and active

transport modes

2 25 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The development constraints caused by natural hazards and the potential for adverse effects on transport

infrastructure has not been adequately considered

2 26 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is the potential for multiple conflict points between the main road and the driveways which may be formed

2 27 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The assessment of potential cumulative effects of increased traffic generation has been inadequate

2 28 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There are no appropriate mechanisms identified to ensure that the matters raised in the ITA and the matters identified

in this submission can be appropriately addressed

3 31 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe is currently facing a notable shortfall of land for businessindustry use Pukekohe is losing business

opportunities as a result

3 32 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe Park is an asset to Pukekohe and the wider Auckland region through its ability to host a range of events

The plan change will help the club to continue their operations

3 33 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

The Plan Change will see an extension of business uses which is contiguous with the existing business activites along Manukau Road There are benefits such as co-

location and access to existing transport infrastructure

Plan Change 30 - Pukekohe Park Raceway Summary of Decisions Requested

1 of 1

Submissions

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

Summary of Decisions Requested

Sub Sub Point Submitter Name Address for Service Theme Summary Reasons

1 11 Keith Houston keithcarevetsconz Flooding stormwater Decline the plan modification unless it is amended to address and resolve concerns raised

The plan change area is subject to flooding There should be a provision in the plan change which requires a minimum

freeboard level of 500mm above the 100 year flood level

2 21 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The ITA should be amended to ensure a full and appropriate assessment of the adverse effects of the plan

change on the local and wider transport network

2 22 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

Clarification is required for the traffic modelling as there is still uncertainty in the actual and potential effects of the

proposed rezoning

2 23 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is a lack of specific assessment of the potential effects of removing parkng during large events

2 24 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is uncertainty around the provision of upgrades to transport infrastructure to support public and active

transport modes

2 25 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The development constraints caused by natural hazards and the potential for adverse effects on transport

infrastructure has not been adequately considered

2 26 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is the potential for multiple conflict points between the main road and the driveways which may be formed

2 27 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The assessment of potential cumulative effects of increased traffic generation has been inadequate

2 28 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There are no appropriate mechanisms identified to ensure that the matters raised in the ITA and the matters identified

in this submission can be appropriately addressed

3 31 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe is currently facing a notable shortfall of land for businessindustry use Pukekohe is losing business

opportunities as a result

3 32 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe Park is an asset to Pukekohe and the wider Auckland region through its ability to host a range of events

The plan change will help the club to continue their operations

3 33 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

The Plan Change will see an extension of business uses which is contiguous with the existing business activites along Manukau Road There are benefits such as co-

location and access to existing transport infrastructure

Plan Change 30 - Pukekohe Park Raceway Summary of Decisions Requested

1 of 1

Submissions

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

Sub Sub Point Submitter Name Address for Service Theme Summary Reasons

1 11 Keith Houston keithcarevetsconz Flooding stormwater Decline the plan modification unless it is amended to address and resolve concerns raised

The plan change area is subject to flooding There should be a provision in the plan change which requires a minimum

freeboard level of 500mm above the 100 year flood level

2 21 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The ITA should be amended to ensure a full and appropriate assessment of the adverse effects of the plan

change on the local and wider transport network

2 22 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

Clarification is required for the traffic modelling as there is still uncertainty in the actual and potential effects of the

proposed rezoning

2 23 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is a lack of specific assessment of the potential effects of removing parkng during large events

2 24 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is uncertainty around the provision of upgrades to transport infrastructure to support public and active

transport modes

2 25 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The development constraints caused by natural hazards and the potential for adverse effects on transport

infrastructure has not been adequately considered

2 26 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There is the potential for multiple conflict points between the main road and the driveways which may be formed

2 27 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

The assessment of potential cumulative effects of increased traffic generation has been inadequate

2 28 Auckland Transport RebeccaPhillipsatgovt nz Traffic Decline the plan modification unless it is amended to address and resolve concerns raised

There are no appropriate mechanisms identified to ensure that the matters raised in the ITA and the matters identified

in this submission can be appropriately addressed

3 31 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe is currently facing a notable shortfall of land for businessindustry use Pukekohe is losing business

opportunities as a result

3 32 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

Pukekohe Park is an asset to Pukekohe and the wider Auckland region through its ability to host a range of events

The plan change will help the club to continue their operations

3 33 Jason Woodyard jasonwoodyardhotmailcom Planning economic effects Accept the plan change

The Plan Change will see an extension of business uses which is contiguous with the existing business activites along Manukau Road There are benefits such as co-

location and access to existing transport infrastructure

Plan Change 30 - Pukekohe Park Raceway Summary of Decisions Requested

1 of 1

Submissions

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

Submissions

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

From UnitaryPlanSubmissionFormdonotreplyaucklandcouncilgovtnzTo Unitary PlanSubject Unitary Plan Publicly Notified Submission - PC 30 - keith robert houstonDate Tuesday 3 September 2019 113012 AM

The following customer has submitted a Unitary Plan online submission

Contact details

Full name of submitter keith robert houston

Organisation name the vet centre pukekohe

Agents full name

Email address keithcarevetsconz

Contact phone number

Postal address1043 river roadqueenwoodhamilton 3210

Submission details

This is a submission to

Plan modification number PC 30

Plan modification name PC 30 (Private) Pukekohe Park

My submission relates to

Rule or rulesrelating to the flood levels wrt a 100 year flood

Property address pukekohe raceway

Map or maps

Other provisionsthis relates to the drainage maps and the contour maps of the suggested areas where one sees thatthe flow of water is across the proposed land either massive water collection and diversionmeasures must be added to the plan or insist on buildings being 500 above the 100 year flood level

Do you support or oppose the provisions you have specified I or we oppose the specific provisionsidentified

Do you wish to have the provisions you have identified above amended Yes

The reason for my or our views arethe flood plain information from the Auckland council horological engineer states that any buildingshould bee 500mm above the 100 year flood level i think an amendment to the PC 30 shouldinclude this provision as this area has always been subject to flooding and the works undertakenon the motor race track have still not addressed the excess of water flooding the track thus i seefuture flooding issues that may fall onto councils to fix should flooding occur

I or we seek the following decision by council Amend the plan modification if it is not declined

Details of amendments accept plan with amendments for improved and correct flood and watercontrol

01

Page 1 of 2

Submission date 3 September 2019

Attend a hearing

Do you wish to be heard in support of your submission No

Declaration

Could you gain an advantage in trade competition through this submission No

Are you directly affected by an effect of the subject matter of this submission that

Adversely affects the environment andDoes not relate to trade competition or the effects of trade competition

No

I accept by taking part in this public submission process that my submission (including personaldetails names and addresses) will be made public

01

Page 2 of 2

From Erin Whooley (AT)To Unitary PlanCc Rebecca Phillips (AT) Christina Robertson (AT)Subject PC 30 (Private) Pukekohe Park RacewayDate Thursday 26 September 2019 35113 PMAttachments Pukekohe Park PPC30 AT submissionpdf

Good afternoon

Attached is a submission from Auckland Transport relating to Proposed Private Plan Change 30 -Pukekohe Park Raceway

If you have any queries in relation to this submission please contact Rebecca Phillips ManagerLand Use Policy and Planning Central South on +64 9 448 7346

Kind regards

Erin Whooley | Senior Planner (Beca consultant)Strategic Land Use and Spatial Management | Planning amp Investment

Important notice The contents of this email and any attachments may be confidential and subject to legal privilege Ifyou have received this email message in error please notify us immediately and erase all copies of the message andattachments any use disclosure or copying of this message or attachments is prohibited Any views expressed in thisemail may be those of the individual sender and may not necessarily reflect the views of Auckland Transport

02

Page 1 of 17

From Erin Whooley (AT)To Unitary PlanCc Rebecca Phillips (AT) Christina Robertson (AT)Subject PC 30 (Private) Pukekohe Park RacewayDate Thursday 26 September 2019 35113 PMAttachments Pukekohe Park PPC30 AT submissionpdf

Good afternoon

Attached is a submission from Auckland Transport relating to Proposed Private Plan Change 30 -Pukekohe Park Raceway

If you have any queries in relation to this submission please contact Rebecca Phillips ManagerLand Use Policy and Planning Central South on +64 9 448 7346

Kind regards

Erin Whooley | Senior Planner (Beca consultant)Strategic Land Use and Spatial Management | Planning amp Investment

Important notice The contents of this email and any attachments may be confidential and subject to legal privilege Ifyou have received this email message in error please notify us immediately and erase all copies of the message andattachments any use disclosure or copying of this message or attachments is prohibited Any views expressed in thisemail may be those of the individual sender and may not necessarily reflect the views of Auckland Transport

02

Page 1 of 17

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and Places

Private Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

f) Safe operation of the transport network and

g) Walking and cycling for access connectivity and safety

Auckland Transports opposition to the proposed rezoning is set out in Attachment 1 to thissubmission relating to the matters identified above The position reasons and relief soughtreflect Auckland Transports overall objective of ensuring that PPC30 has appropriatelyidentified the extent scale and intensity of potential effects and the methods for mitigatingthese effects where this is required including provisions that are appropriately representativeof the transport context

Auckland Transport seeks resolution of the various matters raised in this submission throughthe provision of additional information andor amendments to the information provided insupport of the PPC andor other methods to ensure any transport effects are managed to thesatisfaction of Auckland Transport

Auckland Transport seeks the following decision from Auckland Council

1 1 That the Council declines PPC30 unless Auckland Transports concerns areappropriately addressed and resolved

If the proposed plan change is not declined then the following amendments should be madeas outlined below and included in this submission

1 1 1 The retention of the boundary for the Pukekohe Park sub-precinct to enableappropriate provisions to be set to address the matters raised in this submission

1 1 2 The Integrated Transport Assessment should be updated to include

o Modelling results for the existing situation and calibration of the existingbase model

o Consideration of more realistic trip distribution (ie 90) tofrom the northto reflect expected growth patterns

o Adjustment of inboundoutbound splits for both commercialoffice andwarehouse activities

o Consideration of additional peak periods given the potential variability inactivities that may occupy the General Business Zone

o Assessment of a more conservative trip generation scenario andorsensitivity analysis using maximum development potentiala higherproportion of retail or higher trip generating activities

o Assessment of actual and potential effects on pedestrian and publictransport accessibility particularly during large events

o Details of proposed access points for General Business Zone sites andassessment of potential safety risks and

o Assessment of current and future residential catchments with respect towalking and cycling and mitigation to enable safe walking and cyclingaccess to the proposed General Business Zone

1 13 Methods to ensure that the required transport network upgrades are implementedprior to development occurring or at the initial stage of development to avoid

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^r

Signed for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

f) Safe operation of the transport network and

g) Walking and cycling for access connectivity and safety

Auckland Transports opposition to the proposed rezoning is set out in Attachment 1 to thissubmission relating to the matters identified above The position reasons and relief soughtreflect Auckland Transports overall objective of ensuring that PPC30 has appropriatelyidentified the extent scale and intensity of potential effects and the methods for mitigatingthese effects where this is required including provisions that are appropriately representativeof the transport context

Auckland Transport seeks resolution of the various matters raised in this submission throughthe provision of additional information andor amendments to the information provided insupport of the PPC andor other methods to ensure any transport effects are managed to thesatisfaction of Auckland Transport

Auckland Transport seeks the following decision from Auckland Council

1 1 That the Council declines PPC30 unless Auckland Transports concerns areappropriately addressed and resolved

If the proposed plan change is not declined then the following amendments should be madeas outlined below and included in this submission

1 1 1 The retention of the boundary for the Pukekohe Park sub-precinct to enableappropriate provisions to be set to address the matters raised in this submission

1 1 2 The Integrated Transport Assessment should be updated to include

o Modelling results for the existing situation and calibration of the existingbase model

o Consideration of more realistic trip distribution (ie 90) tofrom the northto reflect expected growth patterns

o Adjustment of inboundoutbound splits for both commercialoffice andwarehouse activities

o Consideration of additional peak periods given the potential variability inactivities that may occupy the General Business Zone

o Assessment of a more conservative trip generation scenario andorsensitivity analysis using maximum development potentiala higherproportion of retail or higher trip generating activities

o Assessment of actual and potential effects on pedestrian and publictransport accessibility particularly during large events

o Details of proposed access points for General Business Zone sites andassessment of potential safety risks and

o Assessment of current and future residential catchments with respect towalking and cycling and mitigation to enable safe walking and cyclingaccess to the proposed General Business Zone

1 13 Methods to ensure that the required transport network upgrades are implementedprior to development occurring or at the initial stage of development to avoid

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^r

Signed for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

f) Safe operation of the transport network and

g) Walking and cycling for access connectivity and safety

Auckland Transports opposition to the proposed rezoning is set out in Attachment 1 to thissubmission relating to the matters identified above The position reasons and relief soughtreflect Auckland Transports overall objective of ensuring that PPC30 has appropriatelyidentified the extent scale and intensity of potential effects and the methods for mitigatingthese effects where this is required including provisions that are appropriately representativeof the transport context

Auckland Transport seeks resolution of the various matters raised in this submission throughthe provision of additional information andor amendments to the information provided insupport of the PPC andor other methods to ensure any transport effects are managed to thesatisfaction of Auckland Transport

Auckland Transport seeks the following decision from Auckland Council

1 1 That the Council declines PPC30 unless Auckland Transports concerns areappropriately addressed and resolved

If the proposed plan change is not declined then the following amendments should be madeas outlined below and included in this submission

1 1 1 The retention of the boundary for the Pukekohe Park sub-precinct to enableappropriate provisions to be set to address the matters raised in this submission

1 1 2 The Integrated Transport Assessment should be updated to include

o Modelling results for the existing situation and calibration of the existingbase model

o Consideration of more realistic trip distribution (ie 90) tofrom the northto reflect expected growth patterns

o Adjustment of inboundoutbound splits for both commercialoffice andwarehouse activities

o Consideration of additional peak periods given the potential variability inactivities that may occupy the General Business Zone

o Assessment of a more conservative trip generation scenario andorsensitivity analysis using maximum development potentiala higherproportion of retail or higher trip generating activities

o Assessment of actual and potential effects on pedestrian and publictransport accessibility particularly during large events

o Details of proposed access points for General Business Zone sites andassessment of potential safety risks and

o Assessment of current and future residential catchments with respect towalking and cycling and mitigation to enable safe walking and cyclingaccess to the proposed General Business Zone

1 13 Methods to ensure that the required transport network upgrades are implementedprior to development occurring or at the initial stage of development to avoid

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^r

Signed for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

f) Safe operation of the transport network and

g) Walking and cycling for access connectivity and safety

Auckland Transports opposition to the proposed rezoning is set out in Attachment 1 to thissubmission relating to the matters identified above The position reasons and relief soughtreflect Auckland Transports overall objective of ensuring that PPC30 has appropriatelyidentified the extent scale and intensity of potential effects and the methods for mitigatingthese effects where this is required including provisions that are appropriately representativeof the transport context

Auckland Transport seeks resolution of the various matters raised in this submission throughthe provision of additional information andor amendments to the information provided insupport of the PPC andor other methods to ensure any transport effects are managed to thesatisfaction of Auckland Transport

Auckland Transport seeks the following decision from Auckland Council

1 1 That the Council declines PPC30 unless Auckland Transports concerns areappropriately addressed and resolved

If the proposed plan change is not declined then the following amendments should be madeas outlined below and included in this submission

1 1 1 The retention of the boundary for the Pukekohe Park sub-precinct to enableappropriate provisions to be set to address the matters raised in this submission

1 1 2 The Integrated Transport Assessment should be updated to include

o Modelling results for the existing situation and calibration of the existingbase model

o Consideration of more realistic trip distribution (ie 90) tofrom the northto reflect expected growth patterns

o Adjustment of inboundoutbound splits for both commercialoffice andwarehouse activities

o Consideration of additional peak periods given the potential variability inactivities that may occupy the General Business Zone

o Assessment of a more conservative trip generation scenario andorsensitivity analysis using maximum development potentiala higherproportion of retail or higher trip generating activities

o Assessment of actual and potential effects on pedestrian and publictransport accessibility particularly during large events

o Details of proposed access points for General Business Zone sites andassessment of potential safety risks and

o Assessment of current and future residential catchments with respect towalking and cycling and mitigation to enable safe walking and cyclingaccess to the proposed General Business Zone

1 13 Methods to ensure that the required transport network upgrades are implementedprior to development occurring or at the initial stage of development to avoid

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^r

Signed for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^r

Signed for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief sought

amendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effects

Given that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief sought

current situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief sought

that they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include

methods to ensure theurbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief sought

Road frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to

adequately address theactual and potential effectsassociated with the loss of

parking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sites

and address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

1^Transport ^

An Auckland Council Organisation

20 Viaduct Harbour Avenue Auckland 1010Private Bag 92250 Auckland 1 142 New Zealand

Phone 09 355 3553 Website wwwATgovt nz

26 September 2019

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Attention Planning Technician

Dear Sir Madam

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

Please find attached Auckland Transports submission on Proposed Private Plan Change 30to the Auckland Unitary Plan (Operative in Part)

Should you have any queries in relation to this submission please contact Rebecca PhillipsManager Land Use Policy and Planning Central South on 021 190 5751

Yours Sincerely

^^gtcChristina RobertsonGroup Manger Strategic Land Use and Spatial Management

Enc Auckland Transports submission on Proposed Private Plan Change 30- Pukekohe Park Raceway

ec SFH Consultants Limited

^

02

Page 2 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

SUBMISSION ON PROPOSED PRIVATE PLAN CHANGE 30 - PUKEKOHE PARKRACEWAY

To

From

Auckland CouncilPlans and PlacesPrivate Bag 92300Auckland 1142

Auckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Submission on Proposed Private Plan Change 30 - Pukekohe Park Raceway at 222-250 Manukau Road Pukekohe Auckland

Introduction

Auckland Transport (AT) is a Council Controlled Organisation of Auckland Council with thelegislated purpose to contribute to an effective efficient and safe Auckland land transportsystem in the public interest Auckland Transport is responsible for managing and controllingthe Auckland transport system and is a Road Controlling Authority

In fulfilling this role Auckland Transport is responsible for

a The planning and funding of public transport

b Promoting alternative modes of transport (i e alternatives to the private motor vehicle)

Operating the local reading network andc

d Developing and enhancing the local road public transport walking and cyclingnetworks

This is Auckland Transports submission on Proposed Private Plan Change 30 (PPC30) to theAuckland Unitary Plan (Operative in Part) (AUPOIP)

The submission relates to the proposed change in zoning of a 58393 hectares portion of landwithin the Special Purpose - Major Recreational Facility Zone to Business - General BusinessZone and an amendment to the boundaries of the Pukekohe Park Sub-precinct at PukekohePark 222-250 Manukau Road Pukekohe Auckland The amendments seek to enable futuredevelopment of business premises in the north-western part of the Pukekohe Park site

Auckland Transport could not gain an advantage in trade competition through this submission

Auckland Transports submission is

Auckland Transport opposes PPC30 in its entirety for the reasons set out below unlessAuckland Transports concerns are appropriately addressed

The reasons for Auckland Transports submission

The reasons for Auckland Transports views on the provisions are outlined in Attachment 1and can be summarised as follows

02

Page 3 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

a) Uncertainty in the transport modelling used to determine the actual and potentialeffects of the proposed rezoning Specifically the rationale for trip distributioninboundoutbound splits lack of SIDRA modelling results for the current situationinsufficient consideration of peak periods and lack of sensitivity testing underconservative development scenarios

b) Lack of specific assessment of the potential effects of removing parking and useof the area proposed for rezoning during events such as the VS Supercars andlarge race meetings

c) Lack of specific assessment of the potential effects of removing the access tofromthe raceway particularly during events

d) Uncertainty surrounding methods to ensure the provision of changesupgrades toinfrastructure to support public and active transport modes including (but notlimited to) footpaths along road frontages road crossing facilities speedtransitions and cycle connections with the wider network

e) Lack of consideration of ootential development constraints caused by naturalhazards (flood prone land and overland flow paths) and the potential for adverseeffects on transport infrastructure as a result of any increases in impervious areas

f) Potential for multiple driveways onto the main road to create multiple conflict pointswith vulnerable road users and turning vehicles

g) Inadequate assessment of potential cumulative effects of increased trafficgeneration on existing road network congestion

h) With the removal of this area of land from the existing precinct there is noappropriate mechanism identified to ensure that the matters raised in theIntegrated Transport Assessment and the resolution of the matters identified in thissubmission can be appropriately addressed

Plan change proposals such as PPC30 must ensure that a full and appropriate assessmentis undertaken Such assessments must clearly identify how the proposal will appropriatelymanage any adverse effects on the local and wider transport network including identifyingwhat infrastructure is necessary to service the implementation of the zone development ofthe site and how this will be provided for by the applicant (or future developers) If suchinfrastructure cannot feasibly be provided or enabled then alternative less intensive activitiesshould be considered where appropriate or the plan change proposal declined

Auckland Transport makes this submission to ensure that PPC30 appropriately manages theeffects of the proposal (amended provisions and the resulting anticipated developmentenabled by these amendments) on the local and wider transport network

Specific aspects of the Plan Change this submission relates to includes

a) Integrated Transport Assessment of the proposed rezoning

b) Traffic modelling

c) Intersection upgradesimprovements required to support the proposed rezoning

d) Pedestrian and public transport improvements

e) Implications of parking and access changes

02

Page 4 of 17

f) Safe operation of the transport network and

g) Walking and cycling for access connectivity and safety

Auckland Transports opposition to the proposed rezoning is set out in Attachment 1 to thissubmission relating to the matters identified above The position reasons and relief soughtreflect Auckland Transports overall objective of ensuring that PPC30 has appropriatelyidentified the extent scale and intensity of potential effects and the methods for mitigatingthese effects where this is required including provisions that are appropriately representativeof the transport context

Auckland Transport seeks resolution of the various matters raised in this submission throughthe provision of additional information andor amendments to the information provided insupport of the PPC andor other methods to ensure any transport effects are managed to thesatisfaction of Auckland Transport

Auckland Transport seeks the following decision from Auckland Council

1 1 That the Council declines PPC30 unless Auckland Transports concerns areappropriately addressed and resolved

If the proposed plan change is not declined then the following amendments should be madeas outlined below and included in this submission

1 1 1 The retention of the boundary for the Pukekohe Park sub-precinct to enableappropriate provisions to be set to address the matters raised in this submission

1 1 2 The Integrated Transport Assessment should be updated to include

o Modelling results for the existing situation and calibration of the existingbase model

o Consideration of more realistic trip distribution (ie 90) tofrom the northto reflect expected growth patterns

o Adjustment of inboundoutbound splits for both commercialoffice andwarehouse activities

o Consideration of additional peak periods given the potential variability inactivities that may occupy the General Business Zone

o Assessment of a more conservative trip generation scenario andorsensitivity analysis using maximum development potentiala higherproportion of retail or higher trip generating activities

o Assessment of actual and potential effects on pedestrian and publictransport accessibility particularly during large events

o Details of proposed access points for General Business Zone sites andassessment of potential safety risks and

o Assessment of current and future residential catchments with respect towalking and cycling and mitigation to enable safe walking and cyclingaccess to the proposed General Business Zone

1 13 Methods to ensure that the required transport network upgrades are implementedprior to development occurring or at the initial stage of development to avoid

02

Page 5 of 17

adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^rSigned for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

02

Page 6 of 17

Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

02

Page 7 of 17

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

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adverse effects of increased vehicle movements on the wider transport networkincluding

o A roundabout at the intersection of Manukau Buckland and KitchenerRoads

o Urbanisationconstruction of a 18 metre wide footpath along the ManukauRoad and Buckland Road frontages

o Pedestrian crossing facilities to provide safe passage across ManukauRoadand

o Provision for a bus stop on the Manukau Road frontage

1 14 Clarification of how development of the proposed General Business Zone land willbe undertaken what the full development potential of the site is and how this willbe assessed to ensure adverse effects are avoided remedied or mitigated

1 15 A comprehensive assessment of actual and potential effects caused by accesschanges and the loss of parking and use of the land proposed to be rezonedincluding cumulative effects and implications for the management of events atPukekohe Park

1 16 Consideration of whether any conditions of consent under which the racewayoperates andor the Pukekohe Park Precinct provisions require revision as a resultof the proposed rezoning or whether the development of the proposed GeneralBusiness Zone land may give rise to actual or potential adverse effects on theraceway andor Pukekohe Park Precinct

In all cases where amendments to the plan change are proposed Auckland Transport wouldconsider alternative wording or amendments which address the reason for AucklandTransports submission Auckland Transport also seeks any consequential amendmentsrequired to give effect to the decisions requested

Auckland Transport is available and willing to work through the matters raised in thissubmission with the applicant

Auckland Transport wishes to be heard in support of this submission If others make a similarsubmission we will consider presenting a joint case with them at a hearing

^^rSigned for and on behalf of Auckland Transport

Christina RobertsonGroup Manger Strategic Land Use and Spatial Management

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Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

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From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

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Date 26 September 2019Address for service of submitterRebecca Phillips Manager Land Use Policy and Planning CentralSouthAuckland TransportPlanning and InvestmentPrivate Bag 92250Auckland 1142

Telephone 021 1905751Email RebeccaPhillipsatgovt nz

02

Page 7 of 17

From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

02

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From Auckland TransportAttachment 1 - Comments and Points Requiring Addressing Further Clarification

_AucklandTransport

w Auckland Counds OfganisQtion

Issue Position

Integrated Transport OpposeAssessment of theproposed rezoning

Reasons

The Integrated Transport Assessment (ITA) supporting theproposed rezoning is not sufficient to determine the actual andpotential transport effects resulting from PPC30 There is insufficientconsideration of the potential development and activities that couldoccur within the proposed Business - General Business Zone areaand the consequent transport effects that would be generated bypotential development Until the ITA is amended to demonstratethat the proposed plan change provisions are appropriate to addresstraffic effects arising from the proposed rezoning AucklandTransport considers that there is insufficient evidence to support theproposal

The General Business Zone provides for a wide range of businessactivities from light industrial to limited office large format retail andtrade suppliers The description of the General Business Zone inthe AUPOIP suggests that the zone is designed primarily toaccommodate large format retail and commercial activity and limitthe establishment of small retail activities The range of activitiesprovided for in the General Business Zone are acknowledged inPPC30 and the accompanying ITA through the variation in theresults of the traffic modelling which reflect low and highscenarios for traffic generation Policy H 14 3(21) requiresdevelopment within the zone to manage adverse effects on the safeand efficient operation of the transport network

The ITA should be amended to ensure the full potential developmentenabled b the ro osed rezonin is considered and that otential

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to ensure the fullpotential development enabledby the proposed rezoning isconsidered that potentialeffects are assessed on thebasis of maximum potentialdevelopment and such effectsare mitigated appropriatelyaddressing the matters raisedin this submission

The amendment to theboundaries of the PukekohePark Precinct to remove thisland area is opposed if this isthe only mechanism availableto ensure appropriately setprovisions for the developmentof this land to address thematters raised in thissubmission including the

02

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AucklandTransport

An Aucktend Ctwncil Organisation

Issue Position

Traffic modelling Oppose

Reasons

effects are assessed on the basis of maximum probabledevelopment Alternatives to this may include the ITA identifyingdevelopment and activity intensity thresholds including the nominalproposed mixed commercial development which could not beexceeded without assessment and addressing of transport andtransport network effects

In addressing the matters raised in this submission through anamended ITA there needs to be an appropriate mechanism in placeto ensure they are implemented

Rather than pulling back the boundaries of the Pukekohe ParkPrecinct from this land area as proposed by this plan changeadditional or amended objectives policies rules and standardsrelating to activities within the portion of the Precinct rezoned toGeneral Business Zone could be applied through the retention of theexisting precinct boundaries or the creation of a sub-precinct whichcould provide a greater level of control over potential development

Auckland Transport opposes the Plan Change as the trafficmodelling provided as part of the ITA is not considered sufficientlyrobust to support the proposed plan change The modelling resultsfor the current situation are not shown and thus the impacts of theproposed development cannot be correctly assessed The basemodel should be calibrated to observed queues and other conditionsthat are applicable to the current performance of the network Thetraffic modelling provided is considered insufficient to identify andassess the actual and potential effects of the proposed plan changeas the traffic that will be generated for reasons including

PC - Decision relief soughtamendments required to theITA

The Plan Change should bedeclined

If the Plan Change isprogressed the followingmatters should be addressed

The base traffic modellingshould be calibrated toobserved queues and otherconditions applicable to thecurrent situation andmodellin results for the

8

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AucklandTransport

An AucUsnii Council 0 Isatlon

Issue Position Reasons

The rationale for trip distribution is unclear Using the distributionof existing trips as provided in Figure 4-1 of the ITA -76 of thetrips were tofrom the north in the AM peak and -80 of the tripswere tofrom the north in the PM peak respectively A higherproportion (90) should be used for trips tofrom the north asmore growth is expected to occur to the northThe basis for the inboundoutbound splits used in the ITA isunclear For commercialoffice activities the split should be atleast 80 inbound and 20 outbound For warehouse activitiesthe split should be closer to 5050 as staff would arrive beforedeliveries It is assumed that the splits are for the AM peak andswitch around for the PM peakThe ITA only assesses the weekday AM and PM peak periodsFor retail activities Saturday lunchtime is also a predominantpeak and must also be considered and assessedAs noted above the General Business Zone provides for arange of different commercial activities The assessmentprovided is based on the development of six separate lots undertwo scenarios A high level scenario which assumes a 4800m2gross floor area (GFA) of light industrialvehicle sales activity3 600m2 GFA of retail activity and 740m2 GFA of commercialactivity The low level scenario assumes 7 200m2 GFA of lightindustrialvehicle sales activity The trip generation results aresignificantly different for the two scenarios and the high levelscenario has been used as a worst case for effectsGiven that the subdivision and development of the areaproposed for rezoning has not yet been finalised the modellingand ITA should consider the maximum probable developmentpotential for the land under the General Business ZoneConsideration of a higher proportion of retail activity andsensitivit anal sis of alternative combinations of activities within

PC - Decision relief soughtcurrent situation areincluded

Trip distribution should beamended to reflect a higherproportion of trips tofrom thenorth in line with futuregrowth expectations

Inboundoutbound splitsshould be amended toreflect activities accurately

Additional peak periodsshould be considered forretail and other activities thatcould establish within theGeneral Business Zone

Effects should be assessedbased on maximumdevelopment potential (e ga higher proportion of retailactivity etc) so that a trueworst case scenario can beunderstood and mitigationconsidered accordingly

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_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

02

Page 11 of 17

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief soughtthat they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include methods to ensure the

urbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

02

Page 12 of 17

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief soughtRoad frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

02

Page 13 of 17

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to adequately address the

actual and potential effectsassociated with the loss ofparking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

02

Page 14 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

_AucklandTransport

if AurM^nd Council 0 wisaton

Issue Position Reasons PC - Decision relief sought

Intersectionupgradesimprovementsrequired to support therezontng

Oppose

the proposed lots is required to understand the true scale andnature of the potential effects of additional traffic on the transportnetwork

Until the ITA is amended to address these matters AucklandTransport considers that there is insufficient information for theCouncil to determine that the proposed plan change is appropriate

The PPC30 Implementation Plan indicates that the initialdevelopment will necessitate the upgrade of the ManukauRoadBuckland Road intersection to accommodate a painted flushmedian and right turn bay The assessment recognises a triggerlevel of gt150 vehicles per hour for an upgrade of the ManukauRoadKitchener Road intersection to a single lane roundabout

Given the uncertainty surrounding the scale and nature of theactivities that may establish within the proposed General BusinessZone Auckland Transport supports the upgrade of the intersectionto a roundabout at the initial stage of the development

Upgrading the intersection to a roundabout at the initial stage ofdevelopment would avoid the need for two separate upgrades withina live traffic environment and could remove potential limitations onthe scale and nature of business activities that may establish withinthe proposed General Business Zone in relation to trip generationand consequent effects on the transport network

The roundabout would not only facilitate safe turning manoeuvresbut could also provide an effective threshold treatment for calmingtraffic from the higher speed rural southern approach transitioninginto the lower s eed commercialindustrial urban environment

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended to reflect the need forthe intersection to be upgradedto a roundabout at the initialstage of the development and amechanism be put in place toensure that this upgrade isprovided by the developer toservice the developmentproposal and mitigate adverseeffects

The Plan Change should beamended to retain the precinctmechanism with appropriateprovisions provided to enablecertainty that activities withinthe proposed General BusinessZone will be controlled such

10

02

Page 11 of 17

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief soughtthat they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include methods to ensure the

urbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

02

Page 12 of 17

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief soughtRoad frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

02

Page 13 of 17

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to adequately address the

actual and potential effectsassociated with the loss ofparking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

02

Page 14 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

_AucklandTransport

An AucMsnd Council arosafto-i

Issue Position Reasons

Pedestrian and public Opposetransport improvements

Auckland Transport considers that urbanisation of the ManukauRoad frontage should occur as part of the initial development Safecrossing facilities should be provided to enable pedestrianmovement across Manukau Road tofrom the proposed GeneralBusiness Zone Pukekohe Park bus stops and neighbouring areas

The ITA should consider the functionality of the area for pedestriansand public transport particularly during large events Connectivityto existing bus stops and provision for an additional bus stop on theManukau Road frontage alongside the intersection upgrade andorurbanisation is required as part of the initial development

The Plan Change should consider how it would be possible tominimise vehicle crossings over the frontage of Manukau Road andto ensure these are sufficiently spaced apart

PC - Decision relief soughtthat they do not result in thegeneration of traffic thatexceeds the trigger level atwhich a roundabout is required

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include methods to ensure the

urbanisation of the ManukauRoad frontage as requiredby the developmentproposal is provided at theinitial stage of development

conditions to require safecrossing facilities at theinitial stage of developmentbe provided by thedeveloper to facilitate safepedestrian access tofromthe Park and the proposedGeneral Business Zone

Provision for an additionalbus sto on the Manukau

11

02

Page 12 of 17

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief soughtRoad frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

02

Page 13 of 17

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to adequately address the

actual and potential effectsassociated with the loss ofparking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

02

Page 14 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

Issue Position Reasons

Auckland ^Transporit ^

An Aucidsnd Council Oiganisation

PC - Decision relief soughtRoad frontage at the initialstage of development and a18 metre wide footpath

Consideration of the actualand potential effects onpedestrian and publictransport accessibility andsafety and potentialmitigation measuresparticularly during largeevents

12

02

Page 13 of 17

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to adequately address the

actual and potential effectsassociated with the loss ofparking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

02

Page 14 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

_AucklandTransport

An AucMaml Coundi OrganisBtfon

Issue

Implications of parkingand access changesand compliance with theAuckland Unitary PlanPukekohe Park Precinct

Position

Oppose

Reasons

Auckland Transport opposes the Plan Change in its entirety as itconsiders that the implications of parking and access changes havebeen insufficiently addressed

The ITA acknowledges that the proposed plan change area issometimes used for parking particularly for V8 Supercars eventsWhilst the ITA provides alternative parking areas for overspillparking during events if necessary it does not consider the potentialfor increased use of on street parking in surrounding streets duringevents and consequent effects of congestion within the localnetwork Auckland Transport considers this should be addressedbefore the Plan Change can be accepted It is noted that Standard1434 6 6 of the AUPOIP for the Pukekohe Park Precinct requires anyloss of existing formed and marked parking spaces from 30September 2013 must be accommodated elsewhere within theprecinct unless the number of parking spaces exceeds therequirements set out in Rule E27 6 2

Pukekohe Park currently has four main accesses The ITA statesthat Gate 1 would continue to be used as an access for horse racingactivities but may also provide rear access for industrial orcommercial premises within the proposed General Business ZoneGate 2 is recommended as the primary access point for futurebusiness activities

There is insufficient information regarding what will happen to theremaining accesses (Gates 3 and 4) how access to the Park will bemaintained during events and how any restrictions or changes inaccess to the Park may affect the wider transport networkparticularly during large events Auckland Transport considers thatthese matters need to be considered and addressed before the

PC - Decision relief sought

The Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to adequately address the

actual and potential effectsassociated with the loss ofparking areas and changesin access at Pukekohe Parkparticularly during largeevents

address how relevantconsent andor precinctconditions relating totransport and trafficmanagement for activities atPukekohe Park will be met

13

02

Page 14 of 17

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

^AucklandTransport

An Awi^and Council wfsation

Issue Position Reasons

Council can form a view on whether the provisions of the proposedplan change are the most efficient and effective to give effect to thepurpose of the Act

It is also unclear whether the raceway operates under existingconsent conditions that specify access and parking arrangementsparticularly for large events and whether changing this will berequired as a result of the proposed Plan Change Standard1434 6 5 of the AUPOIP for the Pukekohe Park Precinct specifiestraffic management procedures for activities within the precinctInformation regarding how relevant conditions and standards will bemet for events in light of the proposed access and parking changesbrought about by the PPC should be included in the ITA and theAuckland Unitary Plan

PC - Decision relief sought

14

02

Page 15 of 17

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

AucklandTransport A

An Auctdand Cotnct 0 nisation

Issue Position Reasons

Safe operation of the Opposetransport network

The uncertainty regarding the nature and scale of activities that mayestablish within the proposed General Business Zone means thatpotential access and circulation requirements cannot be determinedThe ITA does not provide sufficient certainty that the number andlocation of access points onto Manukau Road (an arterial road) willnot give rise to unacceptable safety risks Auckland Transporttherefore considers that there is insufficient information on theactual and potential effects of the plan change on the safe andefficient operation of the reading network

PC - Decision relief soughtThe Plan Change should bedeclined

If the Plan Change isprogressed the ITA should beamended the precinctboundary retained andappropriate precinct provisionsprovided to include details ofproposed access points forGeneral Business Zone sitesand address potential safetyrisks

Walking and cycling for Opposeaccess connectivity andsafety

The ITA does not provide sufficient information about walking andcycling access connectivity and safety A more detailedunderstanding of the wider cycle network and connections to keylocations such as the train station town centre and residential areasis needed to determine effects and mitigation The assessment ofpedestrian access safety and connectivity should consider currentand future residential catchments beyond the immediatesurroundings of the PPC area The uncertainty regarding the natureand scale of businesses that may establish within the proposedGeneral Business Zone should be factored into the assessment ofconnectivity via active transport modes

The Plan Change should bedeclined

If the Plan Change isprogressed a more robustassessment of accessconnectivity and safety foractive transport modes isrequired The assessmentshould include reference toexisting and future residentialcatchments in the wider areaand take into account theunceriainty surrounding thescale and nature ofdevelopment that may occurwithin the proposed GeneralBusiness Zone

15

02

Page 16 of 17

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

Auckland ^Transport ^

An Aucldand Coundf Oiganisalion

16

02

Page 17 of 17

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

From jason WoodyardTo Unitary PlanCc jason WoodyardSubject PUKEKOHE PARK- PC 30 SUBMISSIONDate Thursday 26 September 2019 115915 PMAttachments pc-30-form-5pdf

Submission- Jason Woodyardpdf

Hi

Please accept this email and attachments as my formal submission

Attached is

PC 30 form 5My official written submission in the same layout as form 5

Kind Regards

Jason Woodyardm 027 567 8000jasonwoodyardhotmailcom

03

Page 1 of 4

Before you fill out the attached submission form you should know

You need to include your full name an email address or an alternative postal address for your submission to be valid Also provide a contact phone number so we can contact you for hearing schedules (where requested)

Please note that your submission (or part of your submission) may be struck out if the authority is satisfied that at

least one of the following applies to the submission (or part of the submission)

bull It is frivolous or vexatious

bull It discloses no reasonable or relevant case

bull It would be an abuse of the hearing process to allow the submission (or the part) to be taken further

bull It contains offensive language

bull It is supported only by material that purports to be independent expert evidence but has been prepared by

a person who is not independent or who does not have sufficient specialised knowledge or skill to give

expert advice on the matter

Submission on a notified proposal for policy statement or plan change or variation Clause 6 of Schedule 1 Resource Management Act 1991 FORM 5

Send your submission to unitaryplanaucklandcouncilgovtnz or post to

Attn Planning Technician Auckland Council Level 24 135 Albert Street Private Bag 92300 Auckland 1142

For office use only

Submission No

Receipt Date

Submitter details

Full Name or Name of Agent (if applicable)

MrMrsMissMs(Full Name)

Organisation Name (if submission is made on behalf of Organisation)

Address for service of Submitter

Telephone FaxEmail

Contact Person (Name and designation if applicable)

Scope of submission

This is a submission on the following proposed plan change variation to an existing plan

Plan ChangeVariation Number PC 30

Plan ChangeVariation Name Pukekohe Park

The specific provisions that my submission relates to are (Please identify the specific parts of the proposed plan change variation)

Plan provision(s)

Or

Property Address

Or

Map

Or Other (specify)

Submission

My submission is (Please indicate whether you support or oppose the specific provisions or wish to have them

amended and the reasons for your views)

I support the specific provisions identified above I oppose the specific provisions identified above I wish to have the provisions identified above amended Yes No

Submission on a notified proposal for policy statement or plan change or variation Clause 6 of Schedule 1 Resource Management Act 1991 FORM 5

Send your submission to unitaryplanaucklandcouncilgovtnz or post to

Attn Planning Technician Auckland Council Level 24 135 Albert Street Private Bag 92300 Auckland 1142

For office use only

Submission No

Receipt Date

Submitter details

Full Name or Name of Agent (if applicable)

MrMrsMissMs(Full Name)

Organisation Name (if submission is made on behalf of Organisation)

Address for service of Submitter

Telephone FaxEmail

Contact Person (Name and designation if applicable)

Scope of submission

This is a submission on the following proposed plan change variation to an existing plan

Plan ChangeVariation Number PC 30

Plan ChangeVariation Name Pukekohe Park

The specific provisions that my submission relates to are (Please identify the specific parts of the proposed plan change variation)

Plan provision(s)

Or

Property Address

Or

Map

Or Other (specify)

Submission

My submission is (Please indicate whether you support or oppose the specific provisions or wish to have them

amended and the reasons for your views)

I support the specific provisions identified above I oppose the specific provisions identified above I wish to have the provisions identified above amended Yes No

The reasons for my views are

(continue on a separate sheet if necessary)

I seek the following decision by Council

Accept the proposed plan change variation

Accept the proposed plan change variation with amendments as outlined below

Decline the proposed plan change variation

If the proposed plan change variation is not declined then amend it as outlined below

I wish to be heard in support of my submission

I do not wish to be heard in support of my submission

If others make a similar submission I will consider presenting a joint case with them at a hearing

__________________________________________ _________________________________________ Signature of Submitter Date (or person authorised to sign on behalf of submitter)

Notes to person making submission

If you are making a submission to the Environmental Protection Authority you should use Form 16B

Please note that your address is required to be made publicly available under the Resource Management Act 1991 as any further submission supporting or opposing this submission is required to be forwarded to you as well as the Council

If you are a person who could gain an advantage in trade competition through the submission your right to make a submission may be limited by clause 6(4) of Part 1 of Schedule 1 of the Resource Management Act 1991

I could could not gain an advantage in trade competition through this submission

If you could gain an advantage in trade competition through this submission please complete the following

I am am not directly affected by an effect of the subject matter of the submission that

(a) adversely affects the environment and

(b) does not relate to trade competition or the effects of trade competition

SUBMISSION FOR PUKEKOHE PARK (PC 30) 26 September 2019

Attn Planning Technician

Submission being sent by email to unitaryplanaucklandcouncilgovtnz

SUBMITTER DETAILS

JASON WOODYARD

jasonwoodyardhotmailcom

027 567 8000

Postal Address

303 Buckland Road

RD2

Pukekohe 2677

PLAN CHANGE NUMBER PC 30

PLAN CHANGE NAME PUKEKOHE PARK

MY SUBMISSION IS I SUPPORT the plan change

The reasons for my views to support the plan change are

bull Pukekohe is currently facing a notable shortfall of land available for business

industry use It is a well known reality that many businesses are struggling to

find land that can accommodate business activities Given the unique location

and characteristics of the subject property I consider it would be well positioned

to be rezoned for the intended use and assist in the future growth of Pukekohe

bull Pukekohe Park is an asset to Pukekohe and wider Auckland It is an

established and popular place for locals and visitors to enjoy It is well

supported over a range of events from horse racing to international supercar

events The event center is hired and frequented by local businesses and a

venue for special events I support that by changing the zoning of their

surrounding land could be revenue gathering and help the club to continue to

operate into the future

SUBMISSION FOR PUKEKOHE PARK (PC 30) 26 September 2019

Attn Planning Technician

Submission being sent by email to unitaryplanaucklandcouncilgovtnz

SUBMITTER DETAILS

JASON WOODYARD

jasonwoodyardhotmailcom

027 567 8000

Postal Address

303 Buckland Road

RD2

Pukekohe 2677

PLAN CHANGE NUMBER PC 30

PLAN CHANGE NAME PUKEKOHE PARK

MY SUBMISSION IS I SUPPORT the plan change

The reasons for my views to support the plan change are

bull Pukekohe is currently facing a notable shortfall of land available for business

industry use It is a well known reality that many businesses are struggling to

find land that can accommodate business activities Given the unique location

and characteristics of the subject property I consider it would be well positioned

to be rezoned for the intended use and assist in the future growth of Pukekohe

bull Pukekohe Park is an asset to Pukekohe and wider Auckland It is an

established and popular place for locals and visitors to enjoy It is well

supported over a range of events from horse racing to international supercar

events The event center is hired and frequented by local businesses and a

venue for special events I support that by changing the zoning of their

surrounding land could be revenue gathering and help the club to continue to

operate into the future

bull Manukau Road is used as a main business corridor linking the centre of

Pukekohe with the southern business hub Recent development has mostly

concentrated on Manukau Road with emphasis on Light Industrial and large

format retail Manukau Road area has historically and continues to be the main

business area of Pukekohe The subject land being an extension of Manukau

Road is ideal for colocation andor clustering with associated business activities

in the immediate area

CURRENT SHORTAGE OF BUSINESS LAND IN PUKEKOHE

bull Pukekohe receives the vast majority of business land inquiry in West Franklin

bull Pukekohe requires more immediate business land on main arterial routes

bull There are currently over 50 businesses looking for options to move expand or

open up new premises in Pukekohe These are a combination of existing

Pukekohe businesses and new businesses wanting to locate to Pukekohe

bull There is virtually no available business land for existing and new business to

expand into As a result Pukekohe is losing business opportunities as existing

businesses are moving out of Pukekohe and new businesses wanting to be in

Pukekohe are not able to come Ability for businesses to expand and contract

is important for growth More business land immediately will encourage local

business and job development that stimulates economic prosperity The wider

economic benefits for Pukekohe are large

bull As a result of lack of land supply both new and existing businesses are needing

to revert to Brownfields development if they are wanting to come to Pukekohe

or wanting to expand This can displace existing businesses and becomes

expensive and often not economically viable

PROXIMITY TO LABOUR

bull Pukekohe offers an abundance of labour evidenced by the large volumes of

labour leaving Pukekohe each day to work across Auckland

bull Pukekohe offers affordable housing options being an attraction for businesses

looking to relocate out of Auckland so their staff can get on the property ladder

and have more quality time with family by not having to sit on congested roads

TRANSPORT

bull Close proximity to the Pukekohe train station (15km)

bull Public bus network drives past property

bull Providing land for employment opportunities on the subject property can reduce

congestion on the roads as there will be less freight and employee peak vehicle

movements out of Pukekohe With the vision for Pukekohe to develop into a

self- sustaining satellite city it will be important to provide access to services

and employment opportunities in Pukekohe to allow for people to both live and

work here

ECONOMIC BENEFITS

bull The land is contiguous with Manukau Road which is the main arterial of

business in Pukekohe Over 70 of the business land (excluding town centre

zone) extends south from the town centre ring road of which Manukau Road

forms the main arterial of the natural ribbon development This provides easy

access to complimentary supporting business services

I SEEK THE FOLLOWING DECISION BY COUNCIL ACCEPT THE PROPOSED

PLAN CHANGE

IF OTHERS MAKE A SIMILAR SUBMISSION I WILL CONSIDER PRESENTING A

JOINT CASE WITH THEM AT A HEARING

I could not gain an advantage in trade competition through this submission

I am a neighbour but do not feel I am directly effected

Signed by Jason Woodyard

26092019

SUBMISSION FOR PUKEKOHE PARK (PC 30) 26 September 2019

Attn Planning Technician

Submission being sent by email to unitaryplanaucklandcouncilgovtnz

SUBMITTER DETAILS

JASON WOODYARD

jasonwoodyardhotmailcom

027 567 8000

Postal Address

303 Buckland Road

RD2

Pukekohe 2677

PLAN CHANGE NUMBER PC 30

PLAN CHANGE NAME PUKEKOHE PARK

MY SUBMISSION IS I SUPPORT the plan change

The reasons for my views to support the plan change are

bull Pukekohe is currently facing a notable shortfall of land available for business

industry use It is a well known reality that many businesses are struggling to

find land that can accommodate business activities Given the unique location

and characteristics of the subject property I consider it would be well positioned

to be rezoned for the intended use and assist in the future growth of Pukekohe

bull Pukekohe Park is an asset to Pukekohe and wider Auckland It is an

established and popular place for locals and visitors to enjoy It is well

supported over a range of events from horse racing to international supercar

events The event center is hired and frequented by local businesses and a

venue for special events I support that by changing the zoning of their

surrounding land could be revenue gathering and help the club to continue to

operate into the future

03

Page 2 of 4

bull Providing land for employment opportunities on the subject property can reduce

congestion on the roads as there will be less freight and employee peak vehicle

movements out of Pukekohe With the vision for Pukekohe to develop into a

self- sustaining satellite city it will be important to provide access to services

and employment opportunities in Pukekohe to allow for people to both live and

work here

ECONOMIC BENEFITS

bull The land is contiguous with Manukau Road which is the main arterial of

business in Pukekohe Over 70 of the business land (excluding town centre

zone) extends south from the town centre ring road of which Manukau Road

forms the main arterial of the natural ribbon development This provides easy

access to complimentary supporting business services

I SEEK THE FOLLOWING DECISION BY COUNCIL ACCEPT THE PROPOSED

PLAN CHANGE

IF OTHERS MAKE A SIMILAR SUBMISSION I WILL CONSIDER PRESENTING A

JOINT CASE WITH THEM AT A HEARING

I could not gain an advantage in trade competition through this submission

I am a neighbour but do not feel I am directly effected

Signed by Jason Woodyard

26092019

SUBMISSION FOR PUKEKOHE PARK (PC 30) 26 September 2019

Attn Planning Technician

Submission being sent by email to unitaryplanaucklandcouncilgovtnz

SUBMITTER DETAILS

JASON WOODYARD

jasonwoodyardhotmailcom

027 567 8000

Postal Address

303 Buckland Road

RD2

Pukekohe 2677

PLAN CHANGE NUMBER PC 30

PLAN CHANGE NAME PUKEKOHE PARK

MY SUBMISSION IS I SUPPORT the plan change

The reasons for my views to support the plan change are

bull Pukekohe is currently facing a notable shortfall of land available for business

industry use It is a well known reality that many businesses are struggling to

find land that can accommodate business activities Given the unique location

and characteristics of the subject property I consider it would be well positioned

to be rezoned for the intended use and assist in the future growth of Pukekohe

bull Pukekohe Park is an asset to Pukekohe and wider Auckland It is an

established and popular place for locals and visitors to enjoy It is well

supported over a range of events from horse racing to international supercar

events The event center is hired and frequented by local businesses and a

venue for special events I support that by changing the zoning of their

surrounding land could be revenue gathering and help the club to continue to

operate into the future

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Page 2 of 4

SUBMISSION FOR PUKEKOHE PARK (PC 30) 26 September 2019

Attn Planning Technician

Submission being sent by email to unitaryplanaucklandcouncilgovtnz

SUBMITTER DETAILS

JASON WOODYARD

jasonwoodyardhotmailcom

027 567 8000

Postal Address

303 Buckland Road

RD2

Pukekohe 2677

PLAN CHANGE NUMBER PC 30

PLAN CHANGE NAME PUKEKOHE PARK

MY SUBMISSION IS I SUPPORT the plan change

The reasons for my views to support the plan change are

bull Pukekohe is currently facing a notable shortfall of land available for business

industry use It is a well known reality that many businesses are struggling to

find land that can accommodate business activities Given the unique location

and characteristics of the subject property I consider it would be well positioned

to be rezoned for the intended use and assist in the future growth of Pukekohe

bull Pukekohe Park is an asset to Pukekohe and wider Auckland It is an

established and popular place for locals and visitors to enjoy It is well

supported over a range of events from horse racing to international supercar

events The event center is hired and frequented by local businesses and a

venue for special events I support that by changing the zoning of their

surrounding land could be revenue gathering and help the club to continue to

operate into the future

03

Page 2 of 4

bull Manukau Road is used as a main business corridor linking the centre of

Pukekohe with the southern business hub Recent development has mostly

concentrated on Manukau Road with emphasis on Light Industrial and large

format retail Manukau Road area has historically and continues to be the main

business area of Pukekohe The subject land being an extension of Manukau

Road is ideal for colocation andor clustering with associated business activities

in the immediate area

CURRENT SHORTAGE OF BUSINESS LAND IN PUKEKOHE

bull Pukekohe receives the vast majority of business land inquiry in West Franklin

bull Pukekohe requires more immediate business land on main arterial routes

bull There are currently over 50 businesses looking for options to move expand or

open up new premises in Pukekohe These are a combination of existing

Pukekohe businesses and new businesses wanting to locate to Pukekohe

bull There is virtually no available business land for existing and new business to

expand into As a result Pukekohe is losing business opportunities as existing

businesses are moving out of Pukekohe and new businesses wanting to be in

Pukekohe are not able to come Ability for businesses to expand and contract

is important for growth More business land immediately will encourage local

business and job development that stimulates economic prosperity The wider

economic benefits for Pukekohe are large

bull As a result of lack of land supply both new and existing businesses are needing

to revert to Brownfields development if they are wanting to come to Pukekohe

or wanting to expand This can displace existing businesses and becomes

expensive and often not economically viable

PROXIMITY TO LABOUR

bull Pukekohe offers an abundance of labour evidenced by the large volumes of

labour leaving Pukekohe each day to work across Auckland

bull Pukekohe offers affordable housing options being an attraction for businesses

looking to relocate out of Auckland so their staff can get on the property ladder

and have more quality time with family by not having to sit on congested roads

TRANSPORT

bull Close proximity to the Pukekohe train station (15km)

bull Public bus network drives past property

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Page 3 of 4

bull Providing land for employment opportunities on the subject property can reduce

congestion on the roads as there will be less freight and employee peak vehicle

movements out of Pukekohe With the vision for Pukekohe to develop into a

self- sustaining satellite city it will be important to provide access to services

and employment opportunities in Pukekohe to allow for people to both live and

work here

ECONOMIC BENEFITS

bull The land is contiguous with Manukau Road which is the main arterial of

business in Pukekohe Over 70 of the business land (excluding town centre

zone) extends south from the town centre ring road of which Manukau Road

forms the main arterial of the natural ribbon development This provides easy

access to complimentary supporting business services

I SEEK THE FOLLOWING DECISION BY COUNCIL ACCEPT THE PROPOSED

PLAN CHANGE

IF OTHERS MAKE A SIMILAR SUBMISSION I WILL CONSIDER PRESENTING A

JOINT CASE WITH THEM AT A HEARING

I could not gain an advantage in trade competition through this submission

I am a neighbour but do not feel I am directly effected

Signed by Jason Woodyard

26092019

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Page 4 of 4

• Explanation
• Summary of Decisions Requested
• Submissions