Dear Wellington City Council,

The primary criteria of the Change 33 Ridgelines and Hilltops Overlay was Visibility.
However, undisclosed in any publicly available online document is the methodology and actual metrics used to develop the overlay.

Please provide the full list of locations (addresses or identifiable google map name) - and the viewshed radius used from each point - from which the Overlay was assessed, along with any other *measured metric* used and source thereof.

Yours faithfully,

Wellington City (Brooklyn) Rate Payer

Dear Chelsea,
Thank you for your response and those links.

We had and have again reviewed the following sources relating to the Ridgelines & Hilltops overlay:

Change 33 Section 32 Report
https://wellington.govt.nz/-/media/your-...

Ithmus Phase 2 Report (2020)
https://wellington.govt.nz/-/media/your-...

Change 33 Overview Page
https://wellington.govt.nz/your-council/...

The original early deliberations considered a broad set of criteria, including natural character, heritage, and recreational values. However, the independent review panel and decision-makers specifically narrowed the purpose to managing visual impacts, explicitly distinguishing this from other amenity values that were to be addressed through different instruments. That directive was clear: visibility was to be the primary determinant.

Despite this, the operative Section 32 report developed afterwards describes the method as based on “district wide and local scale visibility, slope and landform continuum.” This reintroduces morphology and slope as co-determinants, which appears inconsistent with the earlier instruction to focus on visibility. Morphology may assist visibility mapping for coherence, but not replace visibility as the anchor criterion.

This creates a critical gap. If visibility was the primary determinant, the overlay should have been grounded in documented viewpoints and viewshed analysis. Without a list of viewpoints, it is impossible to verify whether visibility genuinely drove the mapping or whether morphology dominated in practice.

The current overlay shapes—symmetrical bands descending from ridge crests—suggest a morphology-led approach rather than one derived from actual views. If visibility were primary, the overlay would vary significantly depending on viewing direction and context.

The same issue applies to later reviews. To confirm that the overlay still achieves its visual amenity purpose, a list of viewpoints would have been essential to the task. Without it, there is no way to validate that the mapped areas remain visible from the intended vantage points, or to assess changes in vegetation, built form, or urban growth. Furthermore, when Ithmus undertook its review, it would also have needed to qualify the views to ensure that morphology was assisting visibility, not replacing it. Without the initial documented viewpoint set, that validation could not have been robustly performed.

Our request is therefore for:

A copy of the original viewpoint list used when the Ridgelines & Hilltops overlay was first determined, and any associated viewshed analyses or mapping notes in addition (please not in lieu of).

If no such list exists, confirmation of the methodology applied—specifically whether morphology and slope were used in lieu of viewpoint modelling—and evidence that this approach was tested as the most appropriate under section 32 of the Resource Management Act.

Such testing would have required comparison against a viewpoint-based method, which presupposes a documented set of viewpoints and viewshafts. Without that, it is unclear how the chosen approach could have been robustly evaluated as being the most appropriate.

Any supporting technical papers or appendices referenced in the Section 32 report (e.g., Boffa Miskell working papers) that may clarify the intended method.

This information is essential to assess the accuracy and defensibility of the overlay, given its ongoing role in managing visual amenity.

If the original viewpoint list and supporting analyses cannot be provided, we ask for confirmation of whether any formal dispensation or policy determination was made—either by the independent review panel or Council—stating that the overlay shape was not required to be strictly view-based, and that a morphology-led approach was considered acceptable. This clarification is essential to understand whether the current overlay aligns with its intended purpose and statutory requirements under the Resource Management Act.

Yours sincerely,

Wellington City (Brooklyn) Rate Payer