Table 1: Requests for amendments
Point #
Topic
Reason for comment
Change Sought
1
Approach to zoning
The zoning approach applied in the draft maps appears to Zone land in accordance with the direction in the
boundaries and qualifying
have the zone boundaries follow site boundaries. This amendment act and NPS-UD in the first instance. If there
matters
includes locations where qualifying matters have resulted in are qualifying matters, use other methods such as overlays
a “lower” zone, for example to protect nationally significant to manage development in the affected area. If there is a
infrastructure such as Transpower’s network and to manage technical reason why this cannot be achieved then the low
coastal erosion. While these matters need to be addressed, density zoning should only be mapped to the qualifying
this approach includes land within larger sites which appear matter, not whole sites.
to be able to be developed without impacting on the
qualifying matter. This has the result of limiting
development on developable portions of land below that
required by the NPS-UD and the amendment Act.
2
Qualifying matters
Related to point 1 above, the proposed zoning includes Zone properties in accordance with the NPS-UD and the
‘two-storey single dwelling residential area’ and ‘two storey amendment act and adjust the development controls on
medium density residential area’ due to the presence of land affected by the qualifying matters (not the site), if
qualifying matters. However, it appears irrelevant to the required to take account of qualifying matters.
qualifying matters such as SEAs and aircraft noise what
height structures are in these locations and this form of Remove all zones such as these and the ‘single house zone’
control is inappropriate as it unnecessarily restricts from the urban area.
development capacity.
3
Special character
The draft maps released by the council retain the majority Reduce the overall scale of special character areas and
of Special Character areas. In the most highly accessible substantially remove them where they are located within
locations and areas closest to the city centre, the proportion highly accessible areas and/or walkable catchments of
of special character areas retained appears even higher. centres and stations.
These highly accessible areas are not just those which are
within walking distance of stations and centres and include
areas such as Ponsonby and Grey Lynn.
1 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
Waka Kotahi is concerned that the correct balance has not
yet have been struck between meeting the desires of the
council to retain some areas of Special Character and to
enable growth in those areas of Auckland most accessible
by active and public transport and which best support a
healthy and sustainable future for Auckland.
As set out in Te Tāruke-ā-Tāwhiri (Auckland’s Climate Plan)
“
Integrating land-use and transport planning is vital to
reduce the need for private vehicle travel and to ensure
housing and employment growth areas are connected to
efficient, low carbon transport systems”. Enabling
development in the city centre fringe and other highly
accessible areas in the inner isthmus is Auckland’s best
opportunity to implement this integration.
We note the two-tier system used to determine whether an
area contains enough ‘special character’, differentiating
between walkable catchments and other areas. While we
appreciate that walkable catchments have been taken into
account through this approach, we consider that a higher
level of priority should be applied to areas of high
accessibility and/or walkability. As the council is well aware,
areas outside of walkable catchments can offer greater
levels of accessibility to jobs and other opportunities than
locations within a walkable catchment. Waka Kotahi has
mapped the region in terms of accessibility and can provide
these maps to enable Council to identify the area with the
highest levels of accessibility.
Similarly improved levels of nuance and enabling of
intensification should also be applied between walkable
catchments. Areas such as Grafton, within the walkable
catchment of the City Centre, a Metro Centre and a rail
station should have to reach an even higher threshold than
that applied to a standard walkable catchment. As a general
point, Waka Kotahi is disappointed by the council’s decision
to use the 66% level of ‘special character’ that reflects
2 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
merely the “general presence of special character” rather
than the “high quality” reflected by the 75% threshold.
Waka Kotahi would encourage the council to significantly
revise these thresholds to better balance the retention of
areas they consider worthy of special character with the
need to reduce emissions and enable development in
accessible areas.
4
Walkable catchments
In general, at this time, Waka Kotahi support the walking In conjunction with the centres review requested below,
distances adopted by Council but will review other feedback review each walkable catchment and expand to a logical
when it is submitted on the draft proposal. We do suggest area.
that the walkable catchment of the city centre could extend
further and encourage the council to consider distances of
1500-1800m.
In noting that walking distance is preferable to straight line
measures, it is apparent that temporary restrictions on
walkability are unnecessarily reducing development
capacity in accessible locations. As it is a costly and
complicated process to implement future plan changes to
re-zone land following changes on the ground to pedestrian
connections, it is preferable to implement longer term
zoning decisions now. Examples of areas where the zoning
should be adjusted include the east side of Sylvia Park and
south of New Lynn.
There are also small gaps between walkable catchments
which should be up-zoned such as between Mt Albert and
Avondale and Constellation and Sunnynook.
5
Centres
It appears that no assessment has been carried out as to the Carry out a review of the scale and distribution of centres
extent and future nature of centres. With the re-
across the urban area and the development controls which
development of land for intensive uses around centres, it is apply to them in conjunction with accessibility mapping.
likely that the role and scale of centres will evolve, and
Council should proactively plan for this.
Increase development capacity within centres based on
this review where relevant and measure walking distance
It also appears that the walkable catchment of some smaller from the edge of the practical future centre, not the
centres has been measured too narrowly as they have been current centre zone.
measured from the edge of the centre zone rather than the
3 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
practical current and future extent of centre. Examples of
this include Mission Bay, Takapuna and Browns Bay. A
review of the above issues combined with the accessibility
mapping referred to above would address this issue and
identify where zoning within and around centres should be
expanded.
6
Light rail
Waka Kotahi note that Auckland Light Rail and Council are Continue discussions with Auckland Light Rail and
in discussions around the project and its interaction with ultimately up-zone land within the walkable catchment of
land use with the project inevitably leading to further up-
Mt Eden Road, Dominion Road and Sandringham Road to
zoning under the NPS-UD once its station locations are appropriate high-density zones which provide for a mix of
identified. These discussions are evolving and will continue uses.
separate to these comments.
Review and substantially reduce the extent of special
Regardless of these discussions and timing for when there character controls in this area.
is more certainty around station locations, the land within
the Auckland Light Rail Corridor is highly accessible and
ultimately it should be largely up-zoned around the
Sandringham Road, Dominion Road and Mt Eden Road
corridors. This will require a consequent review and
significant reduction of the extent of qualifying matters such
as the Special Character area in these areas.
7
Other rapid transit corridors Waka Kotahi note that as the Airport to Botany and Eastern Publish a timeline and process for carrying out up-zoning
Busway do not have confirmed station locations, their post station location confirmation.
walking catchments cannot be mapped.
It is however unclear at what point in the planning process
the council intends to map, and up-zone, their walkable
catchments. For the sake of public transparency and
confidence, the council should clarify how and when land
will be up-zoned in these locations.
8
Noise
As Waka Kotahi has previously identified with Council, noise Include an overlay which requires sensitive activities within
from transport corridors, including state highways, can have 100m of a state highway to provide mitigation for noise
an adverse effect on the health and amenity of surrounding effects in accordance with Waka Kotahi standards.
sensitive activities. The management of such effects is a
joint task for the infrastructure authority and the developer
4 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
of the land use. Such effects can also give rise to reverse Do not use the presence of state highway noise to prevent
sensitivity issues for infrastructure providers.
up-zoning of land that would otherwise be re-zoned under
The amendment act provides for ‘related provisions’ such the amendment act or NPS-UD.
as an overlay or similar provisions to require protection of
future receivers where land is to be up-zoned. These
provisions can be based upon the model provisions
contained in the Waka Kotahi guidelines which are available
online. This would have no effect on density enabled by the
future plan change.
9
Enabling a mix of uses as well To achieve sustainable growth and successful Transit Apply a wider suite of zones, including mixed use zone, an
as intensification
Orientated Development (TOD), the council should ensure amended THAB zone or a new Transit Orientated
that new areas of residential intensification also enable the Development zone in walking catchments around stations.
establishment of new supporting non-residential uses such
as cafes, doctors and dairies. These uses are fundamental in
these areas to achieving a well-function urban environment.
THAB is the only zone used within walkable catchments, but
mixed use zone would give similar level of development
while allowing for a mix of uses including additional
business uses. The combination of increased height limits
and a mix of uses may broaden market viability of
development and give effect to NPS-UD intentions. This is
consistent with the Auckland Plan which seeks to repurpose
and intensify centres and business areas, especially those in
accessible locations.
Alternatively, the council should urgently consider revising
the activity rules and tables in the THAB and mixed use
zones to enable these activities with minimal to no
consenting barriers.
This relates to the centres point above and there may be a
requirement for more commercially zoned land due to
population increases, particularly in convenient areas like
around Fruitvale, Sturges Road and Sunnyvale stations.
10
Height around stations and The current proposal is for a uniform maximum height limit Increase development capacity, including height limits, in
centres
of six stories in these locations but the NPS-UD requirement the most accessible locations and avoid a blanket six-story
is to enable ‘at least’ six stories. There is an opportunity for control.
greater height and development potential in some areas,
5 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
particularly in the most accessible locations and the most
accessible parts of walkable catchments. The application of
this approach could include a greater height limit in:
• The most accessible walkable catchments, for
instance those catchments within the 15 or 25 percent
most accessible parts of Auckland e.g. Parnell
• Areas which fall within more than one walkable
catchment e.g. Grafton, Newton and Eden Terrace
• The first 200-400m from a station or centre, reducing
down to six stories in the outer portion of the
catchment.
11
THAB height
It is unclear from the engagement material released Amend the general height limit of the THAB zone to 6
whether THAB within the walkable catchments (minimum 6 storeys.
storeys) will have a different height than THAB elsewhere
(generally 5 storeys). Waka Kotahi would support a general
height limit of 6 storeys for all THAB whether inside or
outside walkable catchments.
12
Industrial zones
Noting that ‘Business land suitable for low density uses’ is a Review existing industrial zoning in walkable catchments of
qualifying matter, there are a limited number of locations stations and replace with mixed use zone where
where retaining such a zoning may not be appropriate due appropriate.
to the presence of centres and stations. It appears that
council’s proposal is to raise the height limit to six stories
but not enable a greater mix of centre focused activities
within these zones that would better support the rapid
transit system and the up-zoned housing areas within the
walkable catchment.
Further, the change of use of such land is unlikely to make a
material difference to the total amount of industrial land
zoned and it would allow most existing commercial
activities to continue while allowing for more intensive uses.
Examples of these locations include Otahuhu and Sylvia
Park.
13
Significant
infrastructure This qualifying matter is mentioned in the communications Provide further information on the proposed approach to
constraints
around the proposed changes, but no detail or extent has this qualifying matter and restrict use of zoning as a tool to
been provided.
implement it, particularly when in walkable catchments
and highly accessible areas.
6 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
Infrastructure provision is a factor to consider in integrated
planning but should only be used to the extent necessary
and generally not through the use of low-density zoning. As
per point 1 above, as a first principle, land should be zoned
for its desired form of development with qualifying matters
addressed by other means such as overlays. If this qualifying
matter relates to three waters, then it is likely that such
constraints are temporary in nature and other methods are
available to control the rate of development (e.g. control of
connections to Watercare’s network).
14
Precincts
It is noted that the existing precincts are subject to further Involve Waka Kotahi in consideration of the approach to
consideration.
precincts
Many of these precincts contain triggers and assessments Retain existing transport provisions in precincts.
regarding transport upgrades and these should remain in
place.
15
Town centre heights
Some town centres indicate the removal of the special Include new height variation controls for town centres,
height overlay but the town centre zone doesn’t have a such as Ellerslie, where special character and associated
height limit.
height controls are being removed.
16
Detailed points
There are a number of site-specific issues which have been
• Mangere East appears to have a high scoring for
identified on the planning maps and these should be
accessibility when it is located some distance
assessed.
from Middlemore Station
• 51 sycamore Drive – spot zoning
• Heights in and around Newmarket should be
increased to the maximum possible under
viewshafts. In particular the portion of the centre
without view shafts should have its height
variation control removed, as required by the
NPS-UD. The council should also take the
opportunity to increase the height variation
control for the mixed use area between George
Street and the Metro Centre to the maximum
possible under the viewshafts, or to rezone it to
Metropolitan
Centre,
to
enable
greater
development and reflect its function as part of the
Metro Centre.
7 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
8 Waka Kotahi – New Zealand Transport Agency Comments on NPS-UD and MDRS
