23 December 2025
File Ref: IRC-9471
Wellington City (Brooklyn) Rate Payer
[FYI request #33010 email]
Tēnā koe Wel ington City (Brooklyn) Rate Payer
Thank you for your letter email of 26 November 2025 to Te Kaunihera o Pōneke | Wellington City
Council (the Council) requesting the following information:
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.
On 4 December 2025 we provided you with the following publicly available information:
2000 District Plan:
•
Plan Change 33: Ridgelines & Hil tops (Visual Amenity) & Rural Area - Plans, policies and
bylaws - Wellington City Council
•
District Plan Change 33 - Ridgelines & Hil tops (Visual Amenity) & Rural Area : Table 1:
Options for the Alignment of the Hazard (Fault Line) Area on Planning Maps
2024 District Plan:
•
Section 32 - Part 2 - Natural Features and Landscapes
•
Ridgelines and Hil tops - Initial review Report April-2020.pdf
•
Ridgelines and Hil tops Review Phase 2
On 12 December 2025 you subsequently asked for the following information:
A copy of the original viewpoint list used when the Ridgelines & Hil tops 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—specifical y whether
morphology and slope were used in lieu of viewpoint model ing—and evidence that this
approach was tested as the most appropriate under section 32 of the Resource Management
Act.
Your request has been considered under the Local Government Of icial Information and Meetings Act
1987 (LGOIMA). Please find my response below.
In the Report and Recommendations to the Wellington City Council by hearing commissioners
appointed pursuant to section 34 of the act, the ful assessment from the panel making the decision
was as fol ows:
“In 2004, the Council decided to adopt only visibility, one of the visual values, as a basis for identifying
significant hil tops and ridgelines. In principle the Panel has no difficulties with this approach. In
particular it accepts as appropriate the visibility values as providing the primary threshold for
identifying the most important ridgelines and hil tops in the city. However, the Panel came to believe
that other values associated with these areas should also be recognised.
Submitters presented cogent evidence that landscape values include much more than just visibility.
The Panel believes that the 2001 study that identified the intrinsic natural values and the amenity
values of Wel ington’s ridgelines and hil tops should be fully implemented in order to enable landscape
features to be appropriately protected, maintained and enhanced. Submitters noted that omitting to
identify and address those landscape issues restricts the Council in fulfil ing its obligations under the
RMA. The Panel recognises that Wel ington wil continue to grow, and the currently undeveloped
ridgelines and hil tops wil come under increasing pressure. We are of the view that the overlay
provisions wil provide an effective framework for controlling development in those areas.”
This clarifies that while visibility was a primary determinant, it was not intended to be the only
determinant applicable to the identification of ridgelines and hil tops. This report is linked here -
Final
Composite Decision Report.
We have identified one memo which provides additional information and methodology for identifying
ridgelines and hil tops under plan change 33, this has been included as an appendix.
The links previously provided outline the 2024 methodology and section 32 analysis. These are here:
• Methodology:
Ridgelines and Hil tops Review Phase 2
• Section 32 evaluation:
Section 32 - Part 2 - Natural Features and Landscapes
I trust this information is helpful. If you have any concerns about this response please contact
of [email address]. Alternatively, you are advised of your right to raise any concerns
with the Of ice of the Ombudsman at
www.ombudsman.parliament.nz or freephone 0800 802 602.
Nāku noa, nā
Chelsea McHugh
Senior Advisor Of icial Information
Of icial Information & Privacy
Wellington City Council
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