Professional Documents
Culture Documents
Submitter:
Benjamin Ross
Submission Number:
1606-2
Topic:
Evidence:
Primary
Page 1
Contents
Summary ............................................................................................................................................... 3
Introduction............................................................................................................................................ 5
Scope of Evidence ............................................................................................................................... 6
Clarification sought by Auckland Council on their evidence given to Topic 051 Centres
Zones ..................................................................................................................................................... 7
Points of Council Evidence being rebutted to Topic 051 Centres Zones ............................... 10
Recap of the Super Metropolitan Centre Zone Concept for the Proposed Auckland Unitary
Plan ...................................................................................................................................................... 14
Clarification against evidence provided by Matthew Bonis (Topic 051) (on behalf of Auckland
Council) in regards to Miscellaneous Requests for the Metropolitan Centres .......................... 20
New evidence in support of my submission in seeking to insert the Super Metropolitan
Centre Zone into the Proposed Auckland Unitary Plan ................................................................ 22
Final Remarks ..................................................................................................................................... 47
Attachment A....................................................................................................................................... 48
Attachment B....................................................................................................................................... 51
Attachment C ........................................................................................................................................ 52
Attachment D ...................................................................................................................................... 53
Altered Definition for REGIONAL AND DISTRICT OBJECTIVES AND POLICIES
Chapter D: Zone objectives and policies3 Business zones Metropolitan Centre zone
(after inclusion of Super Metropolitan Centre) ....................................................................... 59
Page 2
Summary
1. I (Benjamin Ross)(the Submitter) am submitting to the Proposed Auckland Unitary
Plan as a private citizen.
2. I am seeking for the addition for a new zone to be inserted into the Proposed
Auckland Unitary Plan under the Business Zones (PART TWO, Chapter D.3). This
new zone would be called the Super Metropolitan Centre Zone.
3. The Super Metropolitan Centre Zone inserted would sit as PART TWO, Chapter
D.3.3 (between the City Centre Zone, and the existing Metropolitan Centre Zone)
causing the rest of the successive Business Zones to be moved down one place.
4. New objectives, policies, height controls and activity tables would accompany the
insertion of the Super Metropolitan Centre Zone into the Proposed Unitary Plan.
5. Manukau City Centre would be upgraded from a Metropolitan Centre as in the
Proposed Auckland Unitary Plan to this new Super Metropolitan Centre Zone.
6. Residential Developable Capacity for Auckland. A Report on the 013 Topic Urban
Growth for the AUP Independent Hearing Panel by the 013 Expert Group is
referenced in supporting case for the Super Metropolitan Centre Zone.
7. Purpose of the insertion of the Super Metropolitan Centre Zone was:
a. Acknowledging Manukau and Albanys regional importance to Auckland and
inter-regional importance to the immediate surrounding regions (Waikato and
Northland).1
b. Facilitate Auckland Councils desire in Shaping a Business-Friendly City
(see Councils document on this at
http://www.scribd.com/doc/190821467/Shaping-a-Business-Friendly-City ).2
c. For the Manukau Super Metropolitan Centre; the new Objectives and Policies
acknowledging the social provisions (The Southern Initiative) in the Auckland
Plan.
8. Super Metropolitan Centre concept was worked from Auckland Council Property
Limited submission to the Auckland Plan.
9. Per the Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11
(except D3.2)3:
a. 6.2.1 Introduction, General Objectives and Policies, Centre, Mixed Use,
General Business and Business Park Zones. Benjamin Ross proposed a
higher order status for the regional centres at Manukau and Albany and
1
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advised he had a detailed change prepared including all of the provisions that
would be applicable to these two centres. There was no support from any of
the parties.4
b. Comment [Med_Day1-37]: 1606 Benjamin Ross sought a new Super
Metropolitan zone be applied to Albany and Manukau. Auckland Council does
not agree Notified provisions do not elevate individual metropolitan centres
over others. Current framework enables enough potential/capacity.5
4
5
Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11 (except D3.2) Page 4
Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11 (except D3.2 Page 34
Page 4
Introduction
10. My name is Benjamin Ross and I am a resident residing in the Papakura Local Board
area, Southern Auckland.
11. My formal qualifications are a Bachelor of Arts in Geography and Political Studies
gained from the University of Auckland in 2010.
12. I have been a regular submitter and social commentator to various Auckland Council
and Auckland Transport documents including:
a. The Auckland Plan,
b. The Long Term Plan 2012-2022 and 2015-2025,
c. Regional Land Transport Plan,
d. Regional Public Transport Program,
e. Various Area Plans.
13. I have read evidence from Auckland Council or consultants hired by Auckland
Council on Topics 051(Centre Zones) of:
a. Jeremy Wyatt,
b. Matthew Bonis,
c. Trevor Mackie,
d. Susan Fairgray,
e. Michael Akehurst .
14. I have read the Interim Guidance pieces issued by the Independent Hearings Panel
released so far (as of August 1, 2015).
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Scope of Evidence
16. While the reason for the submission and evidence was provided in that submission to
support changes asked for, further evidence is given here to:
a. Further build on the evidence given in my submission written in February
2014.
b. Provide new evidence that has come out since the submission was written in
February, 2014.
c. Provide any clarifications needed from any confusion that may have arisen
since the submission was written.
d. Acknowledge or build on from any Interim Guidance given by the Independent
Hearings Panel (as of August 10, 2015).
e. Acknowledge, support, and/or rebut Council given evidence on and/or against
my submission, or amendments I sought to the Proposed Auckland Plan via
Mediation in which I attended.
17. Submissions from other submitters will be referenced as required in this document
where they support evidence provided here, evidence in my submission, or rebut
Council evidence.
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b. Exhibit B7
Metropolitan Centre zone
11.10 There are 10 metropolitan centres, as contained in Attachment D. These
centres are based in different sub-regional catchments. They are identified as
6
7
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significant areas for growth and intensification and are second only to the city centre
in terms of scale and intensity. They are important public transport hubs for the
region and serve a wide range of activities including commercial, civic, community
and above-ground floor residential activities. Unlike other zones there are no GFA
restrictions on commercial activities as these zones are considered a primary
location for the commercial.
c. Exhibit C (as a note of comparison from the Regional Policy Statement):8
The RPS B3.1 Policy 1 seeks that metropolitan centres function as commercial,
cultural and social focal points for the region, sub-regions and districts local
areas. RPS B3.1 Policy 2, seeks that these centres provide for commercial
intensification, with RPS B3.1 Policy 4 establishing the range of activities
anticipated. The Auckland Plan identifies such centres as having strategic roles
within the region, a diverse range of activities including residential activities, and
good transport access as served by high frequency public transport.
d. Exhibit D (from my amendment sought at Mediation for Topic 051 Centres
Zones):9
19. The clarification point(s) that I wish to be cleared by Auckland Council are the following:
Page 8
a. Clearly define in plain English for Lay Submitters 10: There are 10 metropolitan
centres, as contained in Attachment D. These centres are based in different
sub-regional catchments.
b. How 21.a then conforms to RPS B3.1 Policy 1 that seeks that metropolitan
centres function as commercial, cultural and social focal points for the region,
sub-regions and districts local areas. Basically do the Metropolitan Centres in
functioning as focal points (or rather hubs) for the region et al. mean Metropolitan
Centres have regional catchments?
c. Is Policy 3 for the Metropolitan Centres (as mentioned above) contravening the
relevant Regional Policy Statement, and the role and function per The Auckland
Plan?
d. This then leads to a question that needs to be answered for clarification from the
Auckland Council to submitters on Topic 051 Centres Zones in whether Auckland
Council treats all ten Metropolitan Centres the same through their interpretation
on what a Metropolitan Centre is in the Proposed Auckland Unitary Plan and/or
the operative Auckland Plan? If so then one must question the reasoning behind
treating the Metropolitan Centres all the same. If not then this leads into my main
argument of separating the Metropolitan Centres out through the creation of the
Super Metropolitan Centre zone.
20. It should be noted that the answers from Auckland Council to the clarification points
above do have a consequence to evidence provided in this document.
Page 9
22. Further noted from the evidence of Matthew Bonis (still on Topic 051)12:
a. 10.32 Both Ben Ross 1606-2 and T Greening 3371-22 seek the provision of
recognition of a new tier of centre which is the equivalent of the City Centre zone
(Primary Centres) to be applied to a number of larger Metropolitan Centres
including Manukau Centre.
11
12
Page 10
b. 10.33 The relief is opposed; the notified hierarchy follows the approach
established in the Auckland Plan. The notified hierarchy seeks to create a
classification approach to centre management, where centres of equal form and
function can be grouped together in terms of both land use expectations and
associated public funding and transport initiatives. Such an approach is
consistent with the Councils duty in terms of the integrated management of
physical resources.
c. 10.34 The addition of a further tier of centres that are equivalent to that of the city
centre is unjustified given the primacy of the Auckland CBD as the dominant
location for commercial employment, diversity of activities and economic activity.
Inserting a new classification between the city centre and metropolitan centres
would not aid in the clarity of land use provisions and likely blur the distinctions
between the centres hierarchy for no appreciable benefit.
d. 10.35 Lastly, it is not solely the size of the centre that dictates its placement in the
retail hierarchy, rather the role it plays in the community and the extent of the
catchment from which it attracts shoppers. In general terms bigger centres tend
to hold a higher position in the retail hierarchy compared with smaller centres,
however this is not always the case. In this instance the placement of Manukau
Centre (Greening / Ross) and Albany (Ross) as being metropolitan centres is
supported given their role and function.
23. I have also noted from the evidence of Trevor Mackie on behalf of Auckland Council in
regards to Urban Design Planning Height Limits (still on Topic 051)13:
a. Metropolitan Centre unlimited height, increase height limit, reduce height
limit, retain
b. Submitter requests
i. 10.34. Submissions sought deletion of the height control or unlimited
height in the Metropolitan Centres. Reasons given are that: the taller
the better, by increasing the number of residences and reducing the
need for transport options with people living on or at their workplace;
the PAUP has effectively down-zoned from existing Business 3 zone
(inferred Takapuna), which will stifle development; we currently have
one of the least densely populated cities, to grow we need to focus on
building up, not out; we will not get the desired outcome for our city if
13
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c. Discussion
i. 10.36. In introducing the 72.5m height limit there is a reduction for part
of Takapuna, and for parts or all of other areas that had unlimited
height in the legacy plans. Takapuna Area C (or Sub-precinct C) had
theoretically unlimited height but was constrained by a floor area ratio
(gross floor area limited to 3.5 times the area of the site), HRB
controls applying from the nearest residential zone boundary, and
could have a tower footprint of only 40% of its site area. The proposed
Takapuna precinct controls theoretically allow unlimited height but
have a 6:1 FAR control. There are also constraints on height and
resource consents for tall structures in other centres. There has been
little uptake in the unlimited height provisions for Takapuna, Mangere,
Manurewa, Otara, Pakuranga, Papatoetoe, Te Atatu North, Albany,
Botany, Henderson, Manukau, Glen Eden and Highland Park. That is
not a reason on its own to introduce a height limit, as there have been
resource consent applications and a few taller buildings constructed.
The PAUP does not have a floor area ratio control limiting
development, and the height-in-relation-to-boundary control now only
Benjamin Ross. Primary Evidence
Page 12
Page 13
Super Metropolitan Centres compliment the main City Centre rather than
compete. Also a sustainable argument owing to potential of remote offices being
establish thus leading to less demand on cross city transportation systems.
g. The lack of demand argument that has been touted is one I find underwhelming.
It is not the place of Council to determine demand but to facilitate any future
investment into a Centre within Auckland. E.g. if someone in 2020 wants to build
a 26 storey mixed use complex owing to demand in the Manukau Super
Metropolitan Centre then Council should enable it rather than disable it via the
Benjamin Ross. Primary Evidence
Page 14
25. Extract from Auckland Council Property Limited and their submission to The Auckland
Plan14
a.
14
http://www.aucklandcouncil.govt.nz/SiteCollectionDocuments/aboutcouncil/cco/aucklandcouncilproperty/tca
ndtpreporttoacpl.pdf
Page 15
15
vi. It is important to note that the hierarchy for Town Centres is expressed
in terms of function only (i.e., the difference between Metropolitan
Centres and Town Centres), and should not be confused with the
investment priority for the Council. There are different drivers as to
whether the Council could and should invest its resources in various
Town Centres.
b.
15
This is a new Town Centre Hierarchy category introduced by the Project Team and not recognised in the
Draft Auckland Plan
Figure 1 Proposed Hierarchy of Town Centres
NB: Mega Centres have not been included in this hierarchy
Page 16
c.
8.3.1 Manukau
i. Manukau has traditionally been a strong area and has developed into
a major Primary Centre extensively servicing South Auckland.
ii. It would benefit from the overview of the City Transformation
Unit. The commitment and focus this brings is beneficial. It
sends a signal to the market that Council is committed to
continuing investment in order to strengthen Manukau.
iii. The key issues Council should focus on are:
I.
II.
III.
IV.
V.
VI.
d.
8.3.2 Albany
i. Albany is a centre with good bones but with little soul.
ii. It needs a more sophisticated approach to create a heart for the
Centre.
iii. Albany needs a robust, strategic rethink. It is in danger of becoming a
large dispersed centre. If the heart and soul of Albany is to be
created, then this requires careful thinking and probably a small range
of works and actions which will build a sense of place and community
at Albany.
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e.
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iv. Auckland will benefit from this (as will the Waikato) in economic
returns as much as in the opportunity that such a corridor presents to
accommodate future growth in the South Auckland/Northern Waikato
super region.
v. The significant existing investment in rail, road and broadband
infrastructure between Auckland and Hamilton also offers significant
opportunity for Provincial Centre development along this major
transport corridor. Further investment in this corridor may yield large
gains for Auckland and relieve pressures elsewhere within the system.
The relative merits of leveraging this infrastructure against alternate
transport and economic investment is at least worthy of consideration
in the next 2-5 years.
vi.
With the main New Zealand market and economy located in Auckland
and to the south, vacant land supply south and the connections to
primary transport make the Auckland-Hamilton corridor a critical factor
that warrants recognition and close consideration in the future.
Page 19
27. In clarifying the what Mr Bonis has said in his Point 10.32 ((26a) of this document) in
regards to my original submission to the Proposed Auckland Unitary Plan
a. My submission (1606-2) called for a new hierarchy to be placed into the
Proposed Auckland Unitary Plan. This new hierarchy is named the Super
Metropolitan Centre
b. Prior to the PAUP submission I had written pieces and presented numerous
times to Auckland Council on elevated Manukau City Centre to the same
hierarchy as the main City Centre as listed in the Auckland Plan
c. However, the then proposed elevation of Manukau to the same as the main
City Centre was received coolly
d. Subsequently the Super Metropolitan Centre concept was created and to be
proposed as a new hierarchical spot in the Business Zones of the Proposed
Auckland Unitary Plan. The Super Metropolitan Centre Zone would be
inserted in between the City Centre Zone and the Metropolitan Centre Zone.
The Super Metropolitan Centre would have its own unique Objectives and
Polices inside the Proposed Auckland Unitary Plan
e. In refuting Mr Boniss 10.32 specifically I have not sought the provision of
recognition of a new tier of centre that is equivalent to the main City Centre
Zone. What I have sought is a creation and recognition of a new tier of centre
that while is in between the City Centre and the Metropolitan Centre, the
Super Metropolitan Centre. As stated above in (27d.) the Super Metropolitan
Centre contains its own Objectives and Policies albeit blended from both the
original City Centre and Metropolitan Centre zones.
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i. Where Mr Bonis might have thought Primary Centres has come from
in creating the new tier of centre could have been from Auckland
Council Property Limited submission to the Auckland Plan in 201117.
ii. Again in ACPLs submission a Primary Centre was (and would be
inserted between the Metropolitan Centre and City Centre): While
there is some debate about whether Auckland legitimately has two or
three Primary Centres, the conclusion of this report is that there are
two centres one to the South (Manukau) and one to the North
(Albany). These Primary Centres fundamentally complement the City
Centre in servicing core parts of the region, and reflect the linear
geography of Auckland.18
iii. Continuing with ACPLs Auckland Plan submission a Primary
Centre19 is a Primary Commercial, employment and cultural hub at a
regional scale. While Metropolitan Centres contains important retail,
employment and residential function at a sub-regional scale
iv. Thus it would be ACPLs Auckland Plan submission providing the
foundation to the Super Metropolitan Centre concept in my submission
to the PAUP. It would also provide the basis of refuting Council
evidence through this document.
f.
17
http://www.aucklandcouncil.govt.nz/SiteCollectionDocuments/aboutcouncil/cco/aucklandcouncilproperty/tca
ndtpreporttoacpl.pdf
18
Per footnote 15
19
Primary Centre would foundation to the creation of the Super Metropolitan Centre concept in my
submission
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29. To start this off I am going to provide this following article from the Sydney Morning
Herald written in May this year. The reason being as it illustrates what our closes
competitor Sydney is up to given they have got their Sydney Plan20 under way. The
article will also lay down the foundation of why I believe Auckland Council is actually
being timid especially towards the Metropolitan Centres given what our Australian
cousins are doing and also that we are meant to be a Business Friendly City21
30. The
May 23, 2015. Melanie Kembrey and Matt Wade Sydney Morning Herald
As its colonial heritage testifies, Parramatta has been a big part of Sydneys past.
Now theres growing recognition of how vital Parramatta will be to the citys future.
A marker of Parramattas emerging economic clout came this week when a $2
billion proposal to rejuvenate its commercial hub took a major step forward. Plans for
Parramatta Square were first mooted more than two decades ago but demolition
work is now approved and there are hopes the project will be completed by 2019.
The redevelopment has been billed as western Sydneys Martin Place and will be
one of Australias biggest urban renewal projects. At least five civic, residential and
20
http://www.strategy.planning.nsw.gov.au/sydney/
https://www.scribd.com/doc/190821467/Shaping-a-Business-Friendly-City
22
http://www.smh.com.au/nsw/the-rise-of-parramatta-once-in-a-lifetime-opportunity-20150522-gh7eg3.html
21
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commercial towers will rise around a large public domain adding 150,000 square
metres of high-end commercial office space that will accommodate more than
18,000 workers, students and residents on any given day.
Parramatta Lord Mayor, Scott Lloyd, said the renewal project was a once in a
lifetime opportunity and the Premier, Mike Baird, praised the council for taking plans
for Parramatta Square forward.
The NSW Government has identified Parramatta as our second CBD it will play a very
significant role in providing employment and housing opportunities that are essential for
Sydneys global competitiveness, he said.
This is a great state, Parramatta is a great city, and the future of both is heavily
connected, he said on one of his many stops in western Sydney during this years
state election campaign.
Tim Williams, chief executive of lobby group the Committee for Sydney predicts the
citys future will be determined in its west.
Sydneys structure is challenging. Weve got this rather constrained CBD on the far
east of our city but about two million people live west of Parramatta, he says. The
next big step in Sydneys transformation is to do Parramatta comprehensively and
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To the north west of Liverpool, Penrith also has a grand plan. It has embraced the
slogan "Penrith is Here" and is pushing itself as the "capital of the New West" on the
premise that Sydney's eastern CBD is a global hub and Parramatta its "central city."
Like Liverpool, Penrith plans to revamp its city centre and in the process bring an
extra 10,000 jobs and 5,000 dwellings to the area. Penrith Council has shifted
its policy position on Badgerys Creek airport and now supports the project in the
belief that it is better to be "inside the tent" to gain access to resources.
Mayor Ross Fowler said Penrith residents want a city that is bold.
"Penrith has always had its own separate identity to the rest of western Sydney.
We've probably evolved over the last 30 years from a proud country town to now a
very proud city," he said.
Western Sydney Leadership Dialogue chairperson Chris Brown said Parramatta was
the "older brother" influencing and inspiring the rest of western Sydney,
"Parramatta is the beach head which has given the decision makers in the city a
confidence about moving jobs, money and office space to western Sydney and now
there is an opportunity for the others, like Liverpool, to come through and say they
want a slice of that action as well," Mr Brown said.
"With Parramatta dominating central Sydney, Liverpool dominating the south west
and Penrith dominating the outer west, there are nodes around which the
government can build."
The transport challenge
A Committee for Sydney report released last month said much more attention should
be given to the "east-west spine" of Sydney between the CBD and Parramatta. It
called for a much faster and more frequent heavy rail connection on the existing line
that connects the CBD and Parramatta so the two economic hubs can be more
closely linked.
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"The analogy is with the old financial centre of London and the new one created in
Docklands at Canary Wharf, which did not succeed until a public transport link was
created," the report said.
"This enabled a business person to get from one to the other in less than 15 minutes
with services so speedy and frequent that they didn't have to know the timetable."
As well as a high speed rail to link Sydney's dual CBDs, there is a need for improved
public transport connections between the various commercial centres in western
Sydney.
The government is currently considering which of four light rail routes will be built
around Parramatta, with the hope of eventually delivering a light rail network around
western Sydney. The four routes are Parramatta to Macquarie Park via
Carlingford, Parramatta to Castle Hill via Old Northern Road, Parramatta to
Bankstown, and Parramatta to Sydney Olympic Park and Strathfield/Burwood.
While there is no hint of when a decision will be revealed, construction on a route
was due to start in this term of government and the different commercial centres are
lobbying hard for their causes.
Parramatta Council has proposed a route from Westmead to Epping, which would
link centres to the north, east and west of Parramatta CBD, such as the Westmead
health precinct, Parramatta Stadium and UWS's Rydalmere and proposed
Parramatta Square campuses.
Parramatta Mayor, Cr Scott Lloyd, says it will make Parramatta the new Central
station and provide a spine that would allow for future light rail expansions
to Macquarie Park, Castle Hill and Olympic Park.
The jobs challenge
Greater Western Sydney is one of Australia's biggest regional economies, with
annual output of nearly $100 billion, but job creation in the region has been dwarfed
by population. About 200,000 people leave western Sydney each day for work and
Benjamin Ross. Primary Evidence
Page 27
that daily migration could swell to 400,000 by mid-century unless jobs growth in the
region improves. The movement of so many workers to and from western Sydney
puts huge pressure on the city's transport networks and is a major drag on the
economy.
31. Parramatta as the second Central Business District (or City Centre) is a major
initiative being undertaken by the local authorities in Greater Sydney and the New
South Wales State Government. The initiative is set out in the Sydney Plan which is
the equivalent of our Auckland Plan (notwithstanding Sydney being more ambitious
arguably).
The Sydney Plan vs The Auckland Plan and Proposed Auckland Unitary Plan
32. I am going to copy over extracts of The Sydney Plan23 relevant to the debate and
seeking of the relief of the insertion of the Super Metropolitan Plan into the Proposed
Unitary Plan
33. It is to acknowledge first that while The Auckland Plan is the overarching master
document (framework) that inevitability guides the Proposed Auckland Unitary Plan
the Auckland Plan is a non-statutory document. Given that, and the fact city evolution
is fluid it can be argued that the Auckland Plan is already obsolete to both the City
(Aucklands) needs and current development trends. Thus Council should not be
opposing any alterations to the Auckland Plan if hierarchical changes come through
from the Proposed Auckland Unitary Plan as a result if the changes are backed by
solid evidence.
34. Thus in setting the Proposed Auckland Unitary Plan (which will last 30-years) we as a
City need to make sure per the Resource Management Act 1991 the Plan is as
enabling as possible while still meeting its obligations under the Act. Thus I argue
without the Super Metropolitan Centre concept the Proposed Auckland Unitary Plan
23
http://www.strategy.planning.nsw.gov.au/sydney/
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Business Zones is a disabling document as the PAUP does not actually recognise
adequately the different geographies of our Metropolitan Centres. Consequently
(again) I rebut 10.33 and 10.34 of Matthew Boniss evidence24 against the seeking of
the insertion of the Super Metropolitan Centre into the Proposed Auckland Plan.
35. Below is the introduction to the Sydney Plan. Given that the Auckland Plan is meant
to frame the Unitary Plan comparing both to the Sydney Plan and how it will frame
Sydneys development would be helpful:
a. INTRODUCTION
b. Sydney is an iconic global city and it is growing.
c. Sydney is currently home to over four million people living in communities as
different as Cabramatta, Manly and the Blue Mountains. Each has its own
identity but collectively they enrich the life and character of Sydney.
d. Sydney is a global city, the premier city in Australia and the economic capital
of the country. What happens in Sydney is important to the rest of the nation
because of its impact on jobs, the economy and our capacity to produce
goods and services that are in demand around the world.
e. Sydneys strong economy, skilled labour force, spectacular natural
environment and relaxed lifestyle have made our city the envy of other cities
around the world.
f.
A sign of Sydneys prosperity is that its growing its economic output and its
population. By 2031, Sydneys economic output will almost double to $565
billion1 a year and there will be 689,000 new jobs.2 In the next 20 years,
Sydneys population will grow by 1.6 million people, with 900,000 of this
population growth occurring in Western Sydney(3).
g. Its clear that Sydneys population is growing much faster than it did over the
last 20 years (see Figure 1). To meet the needs of a bigger population, we
need a plan to manage growth how to accommodate the 664,0004 new
homes that we will need, how to provide the conditions for growth in jobs, how
to create places that people will enjoy living in and to protect our unique
natural environment.
h. Sydney needs a plan that outlines how to:
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A Plan for Growing Sydney is the Governments plan to achieve these things.
Its an action plan focused on bringing all stakeholders together with a
common purpose to develop a competitive economy with world-class
services and transport; to deliver greater housing choice to meet our
changing needs and lifestyles; to create communities that have a strong
sense of wellbeing; and to safeguard our natural environment.
j.
Planning where people will live and work across Sydney, and how these
places are connected to each other, will influence Sydneys long-term
success and the standard of living our communities will enjoy. It is critical not
to repeat the mistakes of the past dispersed housing growth that resulted in
a sprawling and poorly connected city, complicated by unique geographic
constraints. Planning for Sydneys inevitable population growth has never
been more important.
k. THE PLAN
l.
The Governments vision for Sydney is: a strong global city, a great place to
live.
m. To achieve this vision, the Government has set down goals that Sydney will
be:
i. a competitive economy with world-class services and transport;
ii. a city of housing choice with homes that meet our needs and
lifestyles;
iii. a great place to live with communities that are strong, healthy and well
connected; and
Benjamin Ross. Primary Evidence
Page 30
iv. a sustainable and resilient city that protects the natural environment
and has a balanced approach to the use of land and resources.
n.
o. This Plan sets out actions that will deliver these goals for Sydney. Each goal
has a number of priority areas (directions which provide a focus for the
actions). The actions include:
i. accelerating urban renewal across Sydney at train stations, providing
homes closer to jobs;
ii. growing a more internationally competitive Sydney CBD;
iii. growing Greater Parramatta as Sydneys second CBD;
iv. transforming the productivity of Western Sydney through growth and
investment;
v. enhancing capacity at Sydneys Gateways Port Botany, Sydney
Airport and Badgerys Creek Airport;
vi. delivering the infrastructure that is needed;
vii. promoting Sydneys arts and culture, tourism and entertainment
industries;
viii. protecting our natural environment; and
ix. managing long-term growth.
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p. The Plan includes a new approach to delivery with the establishment of the
Greater Sydney Commission a dedicated new body with responsibility to
drive delivery of the Plan.
q. A Plan for Growing Sydney applies to the Sydney Metropolitan Area 41
Local Government Areas from Pittwater in the north to Wollondilly in the south
and Blue Mountains in the west
36. As one can gather from the Sydney Plan Introduction above, Sydney is facing the
same pressures as Auckland as well as the same opportunities into 204125.
However, the key difference between Auckland and Sydney (who will undertake their
own spatial planning (laying down the zones)) is Sydney recognises its different
geographies with its Centres (like Parramatta) where Auckland treats its ten
Metropolitan Centres (in which also have different geographies) the same according
to 10.33 of Mr Boniss evidence on behalf of Auckland:
a. 10.33 The relief is opposed; the notified hierarchy follows the approach
established in the Auckland Plan. The notified hierarchy seeks to create a
classification approach to centre management, where centres of equal form
and function can be grouped together in terms of both land use
expectations and associated public funding and transport initiatives. Such an
approach is consistent with the Councils duty in terms of the integrated
management of physical resources.
37. The ultimate point being in this evidence document to the Independent Unitary Plan
Hearings Panel that eight26 of our Metropolitan Centres have similar (not equal) form
and function while two do not thus require separate hierarchal. Those two being
Albany and Manukau City Centre and them both being elevated into the new Super
Metropolitan Centre tier as proposed in my submission.
25
26
Auckland Plan
Westgate, Henderson, New Lynn, Newmarket, Takapuna, Botany, Sylvia Park and Papakura
Page 32
39. However, what is being attempted with Parramatta through the Sydney Plan can be
translated into Manukau City Centre (at the minimum with Albany also being elevated
preferable) being pushed into a higher hierarchy (the Super Metropolitan Centre)
given that the geographies of Sydney and Auckland, Parramatta and Manukau are
similar.
40. Below is what the Sydney Plan has outlined for Parramatta in becoming the second
Central Business District of Sydney complementing the main Central Business
District:
41. SYDNEYS COMPETITIVE ECONOMY
a. Our plan for a competitive economy with world-class services and transport
b. Sydney is Australias financial and economic capital.
c. Forty-five per cent of the top 500 Australian companies are based in NSW (1),
and a major proportion of these are based in Sydney. This puts Sydney in the
same league as other international cities including cities in Asia that
compete as a destination for global capital.
d. Sydney drives around 70 per cent of New South Wales total economic
output2 and over one-fifth of the nations Gross Domestic Product (GDP)(3). It
ranks above Singapore and Hong Kong in terms of economic output (4).
e. Within a decade, our neighbours in Asia will account for around half of our
global economic output, opening up opportunities for our industries and
business. Efficient infrastructure, strong centres that attract investment,
competitive international gateways, access to a deep pool of skilled labour,
and a liveable city with high standards of living will allow Sydney to take
advantage of this growth in Asia. These are the preconditions for innovation
and increased productivity.
f.
g. A Plan for Growing Sydney is a plan to sustain strong growth for Sydney,
improve its productivity and competitiveness, and foster higher living
standards.
Page 33
To fulfil its role, Parramatta also needs expanded arts, culture and
entertainment activities to increase its appeal as a dynamic and diverse place
to work, live and play. Development of a Parramatta arts and cultural precinct
is addressed in Action 3.4.2 in Goal 3.
Page 34
Page 35
j.
Page 36
Page 37
n.
Page 38
43. Although Sydney is four times bigger in terms of population than Auckland, the
geographies of Sydney and Parramatta are similar to that of Auckland and Manukau.
Page 39
44. The accompanying table illustrates the similarities of the geographies of Manukau
and Parramatta:
Parramatta
Education
University of Western
Sydney: 10,000
students by 2017
Nearby Industrial
Complexes/Areas
Immediate
population
catchment
Knowledge
Industries:
Western Sydney
including Greater
Parramatta
Current Transport
Infrastructure
Heavy Rail,
Motorways, Ferry, Bus
Transit Ways, Arterial
Roads
Light Rail, improved
cycling and walking
connections
Education, Health
Future Transport
Infrastructure
Opportunities
Place in relative City
Manukau
MIT and AUT South
campuses: 1800
27
FTE as of 2015. 5,000
28
FTE by 2020
A more sophisticated
entertainment and retail
30
offer . Te Papa North
campus proposed
Wiri, Airport, East
Tamaki, Highbrook,
Takanini, Drury South
31
Southern Auckland
27
Page 40
45. Thus 10.34 of Mr Boniss evidence against a further tier of Centres in the proposed
Unitary Plan32 in my opinion is redundant for two reasons:
a. Again the Super Metropolitan Centre was not designed to lift a Metropolitan
Centre to the level equivalent of the main City Centre Zone. The Super
Metropolitan Centre sits as an independent hierarchy although its objectives
and policies are blended from both the City Centre Zone and the Metropolitan
Centre Zone. However, that said given the unique geography, form and
function (including social function such as Manukau being part of the
Auckland Plan Southern Initiative33) of the Super Metropolitan Centre(s) the
Objectives and Policies do incorporate specifics such as:
i. For Manukau Super Metropolitan Centre: Support for the social policy
initiatives and approach reflected in the broader Manukau Community
and the opportunities the Manukau City Centre derives to support
these policies34
b.
Page 41
unlimited scope for commercial activities. If the Panel considers the height
limits in the Metropolitan Centre zone too restrictive then this can be
amended, without the need for a new zone. I do not consider that a new
zone of the type described is necessary at this stage of Aucklands
development.
47. Trevor Stewart Mackie on behalf of Auckland Council stated:
a. Metropolitan Centre unlimited height, increase height limit, reduce height limit,
retain
b. Submitter requests
i. 10.34. Submissions sought deletion of the height control or unlimited
height in the Metropolitan Centres. Reasons given are that: the taller
the better, by increasing the number of residences and reducing the
need for transport options with people living on or at their workplace;
the PAUP has effectively down-zoned from existing Business 3 zone
(inferred Takapuna), which will stifle development; we currently have
one of the least densely populated cities, to grow we need to focus on
building up, not out; we will not get the desired outcome for our city if
we bow down to the anti-development and anti-progress lobby groups;
and unlimited height is necessary for major satellite cities outside the
CBD. Patrick Fontein (6282-7) seeks acknowledgement that the
Metropolitan Centres have had their building height and development
potential reduced, and considers that the PAUP falls short of the
intensification targets.
ii. 10.35. Louis Mayo (4797-99) is seeking a 96m (24 storey) height limit
in the Metropolitan Centres. Cooper and Associates (6042-35) seek a
30 storey limit. Nationwide Properties Limited and Estate David
Berryman (1125-1) seek a reduction in the height limit to 50m. Other
submissions 27 seek retention of the notified provision for height, as
the zone reflects the operative plan provisions which enable a variety
of activity supporting the transport network. Hartwig Clasen (5219- 46)
sought a reduction in height limits in the Metropolitan Centres except
for Newmarket, to avoid high rise buildings affecting the character and
living quality of Auckland.
c. Discussion
Benjamin Ross. Primary Evidence
Page 42
i. 10.36. In introducing the 72.5m height limit there is a reduction for part
of Takapuna, and for parts or all of other areas that had unlimited
height in the legacy plans. Takapuna Area C (or Sub-precinct C) had
theoretically unlimited height but was constrained by a floor area ratio
(gross floor area limited to 3.5 times the area of the site), HRB
controls applying from the nearest residential zone boundary, and
could have a tower footprint of only 40% of its site area. The proposed
Takapuna 1 precinct controls theoretically allow unlimited height but
have a 6:1 FAR control. There are also constraints on height and
resource consents for tall structures in other centres. There has been
little uptake in the unlimited height provisions for Takapuna, Mangere,
Manurewa, Otara, Pakuranga, Papatoetoe, Te Atatu North, Albany,
Botany, Henderson, Manukau, Glen Eden and Highland Park. That is
not a reason on its own to introduce a height limit, as there have been
resource consent applications and a few taller buildings constructed.
The PAUP does not have a floor area ratio control limiting
development, and the height-in-relation-to-boundary control now only
applies up to 30m from a residential or public open space zone
boundary.
ii. 10.37. 72.5m as a zone-wide control is not particularly limiting in my
opinion, considering greater height is a restricted discretionary activity.
I consider it reasonable to assess potential effects of visual amenity,
bulk dominance and shading from the upper parts of such taller
buildings, individually as well as cumulatively as the centres grow, as
well as landscape and landmark effects.
d. Conclusion
i. 10.38. In my opinion the 72.5m height development control should be
retained in Metropolitan Centres. In some cases it will be overridden
by overlay or precinct height provisions, or by restricted activity
resource consent for taller buildings.
48. In regard to Mr Boniss evidence above in point 48.a I will address it in two parts. The
part in bold I will address at the end as I conclude this evidence document up. The
Page 43
part in non-bold I will address here alongside Mr Mackies evidence (point 48).
49. Yes I agree with Mr Bonis on his point35that the Metropolitan Centres do enable
significant growth and (in theory) unlimited scope for commercial activities. The two
key differences between the Super Metropolitan Centres and the Metropolitan
Centres are geography and the Objectives and Policies which reflect the
characteristics of the Super Metropolitan and Metropolitan Centres.
50. Where Mr Bonis states If the Panel considers the height limits in the Metropolitan
Centre zone too restrictive then this can be amended, without the need for a new
zone36, looking at the evidence Mr Mackie provided on behalf of Council in regards
to height for the Metropolitan Centres37, I take a neutral position on whether the
Independent Unitary Plan Hearings Panel decides to lift any height restrictions on the
eight Metropolitan Centres not proposed to become Super Metropolitan Centres38.
Again for absolute certainty my neutrality is framed around those two key differences
between the Super Metropolitan Centre and the Metropolitan Centre.
51. However, I do urge caution where Mr Bonis in Point 52. (in italics) did state without
need for a new zone as while the Super Metropolitan Centres do call for unlimited
height the entire concept around the Super Metropolitan Centre is just not around
height. Again the Super Metropolitan Centres have different geographies thus
different Objectives and Policies better suited to them. Two examples of those
(different) Objectives/Policies only found with the Super Metropolitan Centres39:
a. To serve as complementary to the main City Centre Zone in servicing core
parts of the region (Manukau serving Southern Auckland and arguably the
northern Waikato, and Albany in time serving the North Shore, Rodney and
Northland), as well as reflecting the linear Geography from Auckland.
b. For Manukau Super Metropolitan Centre: Support for the social policy
initiatives and approach reflected in the broader Manukau Community and the
opportunities the Manukau City Centre derives to support these policies
35
Page 44
52. Those social policy initiatives would be (as of current) the Auckland Plans second
transformational directive: The Southern Initiative.
53. I will as a reference paste in below an excerpt from the Impacts of Planning Rules,
Regulations, Uncertainty and Delay on Residential Property Development report for
the Treasury and MBIE written in December, 2014 by the Motu Economic and Public
Policy Research unit40. The excerpt is on height rules having possible impacts on the
cost of development.
Table 2: Cost Impacts of Planning Rules and Regulations* Rule and
Regulations
Increase in Cost per Dwelling1
Apartments
Building height limits
$18,000 to $32,000
Subdivisions
See note 2
https://www.scribd.com/doc/253323001/The-Impacts-of-Planning-Rules-Regulations-Uncertainty-andDelay-on-Residential-Property-Development
41
I have read the Interim guidance text for Topic 020 Viewshafts - released 17 July 2015
Page 45
55. Given that per the 013 RPS Urban Growth - Expert Conference Outcome Report Residential Developable Capacity for Auckland report42 said that the Proposed
Auckland Unitary Plan as it stands would only allow 11%43 of the 400,000 proposed
dwellings needed in the operative Auckland Plan, and that if you look on the maps of
that report (page 66 (of 69) onwards) only Takapuna Metropolitan Centre was
deemed viable or rather ready for residential development. The other nine
Metropolitan Centres were deemed not viable to undertake residential construction
and it has to be asked is the Proposed Auckland Unitary Plan causing that situation?
42
https://www.scribd.com/doc/272429202/013-RPS-Urban-Growth-Expert-Conference-Outcome-ReportResidential-Developable-Capacity-for-Auckland
43
Page 5 of the report as linked on footnote 42
Page 46
Final Remarks
56. Finally I go back to the comment from Mr Bonis (point 48.a) that I had placed in bold:
I do not consider that a new zone of the type described is necessary at this
stage of Aucklands development.
57. As I see it Auckland Council needs to be very specific on two aspects of that quote
for sake of clarity now and for the future of Auckland.
a. Does the Council support the Super Metropolitan Centre Zone concept
(regardless of timing)?
b. As for timing when would Council consider the Super Metropolitan Centre
necessary as part of Aucklands development?
59. If the Panel does believe a Super Metropolitan Centre zone should be inserted into
the Proposed Auckland Unitary Plan, may it please the Panel in lieu of Points 58 and
59 above and the evidence provided in this document that an Expert Conference
should be facilitated. The expert conference would between mutual parties work
through the details including development and notification controls for the Super
Metropolitan Centre ready for Council consideration.
Benjamin Ross
August 11, 2015
Page 47
Attachment A
Updated Activity Table (I.3.1.1) as a result of mediation on Topic 051 Centres Zones
Activity
Super
Metro
Centre
Zone
Metro
Centre
zone
Town
Centre
zone
Local
Centre
zone
Neighbourhood
Centre zone
Mixed
Use zone
General
Business
zone
Business
Park zone
NC
NC
NC
NC
NC
NC
NC
NC
Dwellings
NC
NC
Conversion of a building
or part of a building to
dwellings, visitor
accommodation
or boarding houses
RD
RD
RD
RD
RD
RD
NC
NC
Retirement villages
D RD
DP
DP
DP
NC
NC
Supported residential
NC
NC
NC
RD
Commercial services
Commercial sexual
NC
services
Conference facilities
Department stores
RD
NC
RD
NC
Drive-through
restaurant facilities
RD P
RD
RD
RD
NC
Entertainment
NC
facilities
Food and beverage
Funeral directors
NC
premises
Garden centres
NC
RD P
Marine retail
NC
RD P
RD
NC
RD P
Offices up to 500m
Accommodation
care
Visitor accommodation
and
boarding houses
Commerce
Page 48
Activity
Super
Metro
Centre
Zone
Metro
Centre
zone
Town
Centre
zone
Local
Centre
zone
Neighbourhood
Centre zone
Mixed
Use zone
General
Business
zone
Business
Park zone
NC D
NC
RD
NC
RD P
NC
NC
NC
facilities
Supermarkets up to
P
2000m GFA per tenancy
NC
NC
Supermarkets
P
exceeding 2000m2
per tenancy and up to
4000m GFA per site
tenancy
Supermarkets greater
P
than 4000m GFA per
site tenancy
RD
NC
NC
RD
NC
NC
NC
Trade suppliers
RD
NC
RD P
Artworks
Care centres
Community facilities
Education facilities
PD
Emergency services
NC
Healthcare facilities
Hospitals
NC
NC
NC
Justice facilities
NC
Recreation facility
Tertiary education
facilities
Industry
RD
Community
Page 49
Activity
Super
Metro
Centre
Zone
Metro
Centre
zone
Town
Centre
zone
Local
Centre
zone
Neighbourhood
Centre zone
Mixed
Use zone
General
Business
zone
Business
Park zone
Artisan industries
Industrial activities
NC
NC
NC
NC
NC
NC
NC
Industrial laboratories
P RD
NC
Light manufacturing
RD
NC
and servicing
Repair and
RD
maintenance services
Waste management
NC
NC
NC
NC
NC
NC
NC
NC
facilities
Warehousing and
RD
NC
New buildings
RD
RD
RD
RD
RD
RD
RD
RD
Demolition of buildings
RD C
RD C
Alterations to building
facades that are less
than:
- 10 25 per cent of its
total surface area, or
2
- 15m 25m
RD
RD
RD
RD
RD
RD
RD
RD
storage
Mana Whenua
Marae complex
Development
Additions to buildings
that are less than:
- 10 25 per cent of the
existing GFA of the
building, or
- 250m
whichever is the lesser
Internal alterations to
buildings
Additions and
alterations to buildings
not otherwise provided
for
Page 50
Attachment B
Updated Building Height Table (I.3.4.2 Table 1) as a result of mediation on Topic 051 (Centres
Zone)
Table 1
Zone
height
roof form
Unlimited
Unlimited
Metropolitan centre
72.5m
72.5m
Town Centre
Local centre
maps
18m
16m
2m
Neighbourhood centre
13m
11m
2m
Mixed use
18m
16m
2m
General Business
16.5m
16.5m
Business Park
20.5m
20.5m
Page 51
Attachment C
Unitary Plan Map Changes Manukau and Manukau City Centre Area
Reference Map
Renaming the Residential and Business Zones in Manukau and Manukau City Centre
Relief Sort
Map
Reference
Plan Zone
Metropolitan Centre
Note:
Other changes sought in above map will be covered in Topics 080 and 081
Page 52
Attachment D
Relief sought to be inserted into the Proposed Unitary Plan (as part of my original
submission 1606-2)
Page 53
Objectives
1. To serve as complementary to the main City Centre Zone in servicing core parts of
the region (Manukau serving Southern Auckland and arguably the northern Waikato,
and Albany in time serving the North Shore, Rodney and Northland), as well as
reflecting the linear Geography from Auckland.44*
44
Page 54
2. The Super Metropolitan Centre is an attractive place to live, work and visit with a 24hour vibrant and vital business, entertainment and retail areas.
3. Development in the Super Metropolitan Centres is managed to accommodate growth
and the second greatest level intensity of development in Auckland (the City Centre
Zone being the first) and New Zealand while respecting its surrounding physical
geography features such as hills, volcanoes, streams, lakes and harbours
4. A hub of an integrated regional (and inter-regional)*45 transport system is located
within the Super Metropolitan Centre and the Super Metropolitan Centre is
accessible by a range of transport modes.
5. Key retail streets are the focal point of pedestrian activity, with identified general
commercial streets supporting this role. Malls continue to act as centre anchor points
but are retrofitted to incorporate functionality with the surrounding Super Metropolitan
Centre rather than operating in their isolation away from the wider surroundings of
the Super Metropolitan Centre as they are now
6. For Manukau Super Metropolitan Centre: Support for the social policy initiatives and
approach reflected in the broader Manukau Community and the opportunities the
Manukau City Centre derives to support these policies
Policies
Land use and development activities
1. Provide for a wide range and diverse mix of activities that enhance the vitality,
vibrancy and amenity of the city centre including:
a. commercial and residential activities
b. arts, entertainment, events, civic and community functions
c. high-quality visitor experiences, visitor accommodation and associated
services
d. learning, teaching and research activities, with a particular concentration in
the learning precinct.
2. Enable a significant and diverse residential population to establish within a range
of living environments and housing sizes.
45
Page 55
3. Enable the significant concentration of office activity in Auckland (behind the City
Centre Zone) to locate in the Super Metropolitan Centre by providing an environment
attractive to office workers.
4. Provide for a wide range of retail activities throughout the Super Metropolitan
Centre while maintaining and enhancing the vitality, vibrancy and amenity of core retail
areas within the Super Metropolitan Centre and centres outside of the Super Metropolitan
Centre. In particular:
a. enable small-scale, niche retail to occur throughout the Super Metropolitan
Centre
b. Encourage supermarkets and department stores within metropolitan
centres by recognising:
i. the positive contribution these activities make to centre viability and
function, and
ii. Designs that positively contribute to the streetscape and character
of their surroundings, having regard to the functional requirements of these
activities.
c. avoid large department stores and integrated retail developments locating
outside the core retail area where they would adversely affect the amenity, vitality
and viability of core retail areas within the Super Metropolitan City Centre and/or
centres outside of the Super Metropolitan Centre.
5. Support the development of public transport, pedestrian and cycle networks and
the ability to change transport modes.
6. Identify and encourage specific outcomes in areas of the Super Metropolitan
Centre that relate to:
a. distinctive built character; and/or
b. concentration of particular activities; and/or
c. activities that have specific functional requirements; and/or
d. significant transformational development opportunities.
Page 56
Public realm
13. Require building and development of the highest quality that contributes to the
city centres role as an international centre for business, learning, innovation, entertainment,
culture and urban living.
14. Require building frontages along identified public open spaces and streets to be
designed in a way that provides a sense of intimacy, character and enclosure at street level.
Benjamin Ross. Primary Evidence
Page 57
16. Enable high quality and interconnected public open spaces that are accessible
and provide spaces for recreational opportunities, facilities and events.
Other
17. Recognise the importance of particular streets identified on the Key Retail and
General Commercial Frontage overlay as primary places for public interaction:
a. by requiring buildings with frontages to these streets to:
i. provide greater ground floor heights to maximise building
adaptability to a range of uses
ii. avoid blank walls
iii. provide easily accessible pedestrian entrances.
b. and in addition, require building frontages subject to the Key Retail
Frontage overlay to:
i. maximise glazing
ii. erect frontages of sufficient height to frame the street
iii. provide weather protection to pedestrians
iv. avoid new vehicle crossings.
18. In the terms of the Manukau Super Metropolitan Centre: Recognise and facilitate
the fact that the Manukau Super Metropolitan Centre is the commercial hub supporting the
southern Auckland industrial complex in: Wiri, Takanini, Drury South, Glenbrook, East
Tamaki, as well as the rural sector of Southern Auckland and northern Waikato
Page 58
Page 59
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