043 & 044 - Hrg - Key Retailers Group - Joint Transport Statement

8/21/2019 043 & 044 - Hrg - Key Retailers Group - Joint Transport Statement

1/48

Topics 043/044 - TransportJoint Transport Statement

JOINT TRANSPORT STATEMENT OF EVIDENCE FORMULTIPLE PARTIES

TOPICS 043/044 - TRANSPORT

16 JUNE 2015

IN THE MATTER of the Resource Management Act 1991 and the

Local Government (Auckland Transitional

Provisions) Act 2010

AND

IN THE MATTER of the Proposed Auckland Unitary Plan


2/48

2Topics 043/044 - TransportJoint Transport Statement

2898637

1. INTRODUCTION, QUALIFICATIONS AND EXPERIENCE

1.1 This is a joint statement prepared by the following qualified traffic

experts (in alphabetical order) on behalf of the listed submitters

(together the Key Retailers Group or "KRG"):

(a) John Burgess - The National Trading Company of New

Zealand Limited ("NTC") and The Warehouse Limited ("The

Warehouse").

(b) Brett Harries - Scentre (New Zealand) Limited ("Scentre"),

Harvey Norman Properties (NZ) Ltd and Harvey Norman

Stores (NZ) Pty Ltd ("Harvey Norman").

(c) Don McKenzie - Progressive Enterprises Limited

("Progressive").

(d) John Parlane - Kiwi Income Property Trust ("Kiwi").

1.2 A complete list of our relevant qualifications and experience is

attached as Appendix 1 to this statement.

1.3 Retail transport planning is an area in which we all have vast

knowledge and understanding. Our combined experience and

familiarity with planning for retail (in particular, supermarkets, large

format retail and shopping centres) has enabled us to help craft a

workable set of transport provisions for the Proposed Auckland

Unitary Plan ("Unitary Plan").

1.4 We consider the provisions proposed by the KRG will enable the

functional and operational viability of retail in Auckland.

Code of conduct

1.5 We confirm that we have read the Expert Witness Code of Conduct

set out in the Environment Court's Practice Note 2014. We have

complied with the Code of Conduct in preparing this evidence and

agree to comply with it while giving oral evidence before the Hearings

Panel. Except where we have stated that we are relying on the


3/48


2898637

evidence of another person, this written evidence is within our area of

expertise. We have not omitted to consider material facts known to us

that might alter or detract from the opinions expressed in this

evidence.

Scope of Evidence

1.6 This statement addresses Chapters C1.2 and H1.2 of the Unitary

Plan.

Joint approach

1.7 Prior to the mediation sessions on C1.2 and H1.2, the KRG met

several times to agree a consolidated version of their proposed

changes to the transport provisions. Additional meetings were held

with Auckland Council ("Council") to endeavor to further narrow the

differences between the two groups. This included both formal and

informal expert conferencing between the traffic experts.

1.8 The KRG's consolidated relief was provided without prejudice to the

Council on 23 February 2015. Council provided its proposed trackchanges to C1.2 and H1.2 on 15 April 2015. Some areas of

disagreement were resolved through this process.

1.9 At the mediation sessions held on 23 - 24 April and 6, 14 - 15, 20 - 22

May 2015, the parties resolved further issues. However, throughout

the informal and formal mediation sessions, there remained a

fundamental disagreement between the KRG and the Council as to

the approach that should be taken to parking in the Unitary Plan;

specifically, whether the Unitary Plan should only specify maximum

parking rates, or whether it should also include minimum rates for

certain activities.

1.10 The Council's track changes, attached to the evidence of Mr Kevin

Wong-Toi are an improvement on the notified version, however, the

KRG still has a number of serious concerns, which are addressed in

this Joint Traffic Statement and in other evidence to be lodged on

behalf of the KRG. Consolidated relief sought by the KRG is set out in


4/48


2898637

Appendix 2 to the Joint Planning Statement, which has been

prepared by the planners acting for various members of the KRG.

Additionally, the KRG members have provided individual corporate

evidence briefs. These statements should be read and considered

collectively.

2. EXECUTIVE SUMMARY

2.1 In our opinion, and for the reasons set out in this statement, the

Hearings Panel should accept the relief sought by the KRG, as set out

at Appendix 2 to the Joint Planning Statement.

2.2 The KRG's relief can be summarised as follows:

(a) We consider that 60 trips per hour is too low a trip generation

threshold for activities to become restricted discretionary and

this would lead to too many developments requiring

assessment reports from traffic engineers. We consider the

trip generation thresholds should be increased from 60 trips

per hour to 100 trips per hour.

(b) We oppose the Council's approach to imposing no car

parking minima in centres. This will lead to businesses being

developed with insufficient parking to cater for their own

needs, leading to excess demand on adjacent sites because

customers will simply choose to park at the closest available

carpark.

(c) The KRG is proposing a more balanced approach of keeping

minimum parking rates in centres while providing maximum

rates for some activities.

(d) In our opinion, the KRG relief should be accepted because it

reflects the reality of parking generated by retail activities in

centres. The use of minimum rates in centres would ensure

that the effects of each development are mitigated and avoid

the potential for cars generated by development to spill-over

into neighbouring properties and streets.


5/48


2898637

(e) The KRG proposed amendments will allow for maximum

parking rates to be used where they could be effective in

reducing peak hour traffic flows.

(f) If a maximum rate is to be imposed, we suggest that this

should be at a maximum rate of 1/17m2 for supermarkets,

given the requirements of supermarkets for car parking.

(g) We consider that the proposed cycle parking rules should

reflect commercial realities and set realistically attainable

targets in order to ensure that achievement of the desired

goals is positively supported and affordable. The KRG isproposing somewhat reduced requirements for cycle parking

and end-of-trip facilities that still go well beyond what is

currently experienced, but remain realistic and affordable to

developers.

(h) We support the addition of flexibility to the Vehicle Access

restriction requirements to properly recognise existing access to

existing developments, and to enable future developability of the

sites served by those accesses. We therefore endorse the

Council track-change version of the proposed amendments and

additions to Rule 3.4.1 regarding vehicle access.

(i) We generally support the proposed rules regarding the number

of vehicle crossings, subject to a minor modification to the

wording of the provision for crossings to ‘all other sites’, and we

support the proposed deletion of Rule 3.4.2.3 which would

remove the requirement for access to be taken off local roads in

favour of arterial roads. However, we consider that greater

flexibility needs to be applied to the permitted maximum width of

vehicle crossings to better recognise the crossing capacity

demands of high traffic generators, and the swept path

requirements of various truck sizes.


6/48


2898637

3. TRIP GENERATION / INTEGRATED TRANSPORT ASSESSMENTS

Trip Generation Table

3.1 The Unitary Plan has two separate but related rules requiring traffic

assessments and Integrated Transportation Assessments. In H1.2

Transport section 3.1 Table 1 sets out thresholds above which

activities located outside of centres would become restricted

discretionary and require a transport assessment. By contrast any of

these activities located within centres would not specifically require an

assessment in terms of traffic.

3.2 The Council's position is that these thresholds are based on the scale

of land use that would generate more than around 60 trips per hour.

There are some exceptions to this noted below.

3.3 We support the intention of the rule, ie setting a scale of development

below which no traffic assessment is specifically required by a rule in

the Unitary Plan. Small scale developments generate few trips and

there is often little scope to do anything meaningful other than

estimate traffic flows and recommend consent.

3.4 Where we differ from the Council is in how the thresholds have been

set. Specifically we consider that 60 trips per hour is too low a

threshold for activities to become restricted discretionary and in our

opinion this will lead to too many developments requiring assessment

reports from traffic engineers. We also do not support the thresholds

proposed by the Council that deviate from a direct calculation of trip

generation. We understand that the Council's position is that some of

the assessment criteria relate to other issues such as connectivity for

pedestrians and are not strictly related to trip rates. Our opinion is that

urban design issues such as connectivity should be addressed in the

appropriate section of the Unitary Plan and that this table should focus

specifically on the scale and intensity of development as it relates to

trip generation.

3.5 The KRG proposed approach is to increase the thresholds in each ofthe categories to reflect a development of 100 vehicles per hour. In


7/48


2898637

our opinion that is a more appropriate intensity of traffic effects to

require a specific assessment of traffic capacity and safety.

Development below that scale could be expected to create less than

minor effects.

3.6 We have reached that view because these assessments would all be

carried out for development located outside of centres where usually

there is reasonable traffic capacity. In our opinion setting these

thresholds too low would lead to the situation where we are preparing

traffic assessments for very small developments outside of centres

where there is little congestion and not being required to assess large

developments within centres in the same manner, despite the

likelihood of significant congestion.

3.7 For that reason the KRG approach, as set out below in strikethrough

and underline, is preferred:

3.1 Trip Generation

1. In all zones, other than those listed in clause (iii) below,resource consent as a restricted discretionary activity is

required where:

...

(iA)

activities not identified in Table 1 requiring a controlled orrestricted discretionary land use activity consent in theapplicable zone and generating more than 60v/hr 100v/hr (anyhour) where there are no requirements for an assessment oftransport or trip generation effects in the applicable zone.

Table 1

Activity Council

Positon

KRG

Position

Reason

Residential Dwellings 60 100 units 1 veh/unit

Retirement 100 500 units 0.2 veh/unit

Visitor

Accommodation

60 100 units 1 veh/unit

Education Primary 100 167 students 0.6 veh/pupil

Secondary 200 333 students 0.3 veh/pupil

Tertiary 300 500 students 0.2 veh/pupil

Office Office 3000 5000 sqm 2 veh/100sqm

Retail Retail 1000 1667 sqm 6 veh/100sqm


8/48


2898637

Drive through 200 333 sqm 30 veh/100sqm

Industrial Warehouse &

Storage

12000 20000 sqm 0.5 veh/100sqm

Other Industrial 6000 10000 sqm 1 veh/100sqm

3.8 The KRG position would in our opinion reflect the scale of out of zone

development that should be assessed and focus the rule on expected

traffic generation rather than the arbitrary limits contained in the

Council's current version.

Integrated Transport Assessments

3.9 Integrated Transport Assessments are required by Rule G1.4B of the

Unitary Plan. These assessments require a considerable amount of

additional material than the regular traffic assessments typically

carried out for developments. We agree with the position now

proposed by Council where these ITAs would only be required once

for a development, usually at a plan change stage.

4. CAR PARKING MAXIMUMS AND MINIMUMS

4.1 The Council's approach to carparking as set out in its evidence is to

limit carparking within the CBD, the CBD fringe and in Metropolitan

areas and Town Centres. This is a significant departure from the

previous District Plans in Auckland where parking was limited only

within the CBD but required within all other areas.

4.2 The Council seeks to limit parking through a series of maximum

parking rates set out in Tables 1, 2 and 3 of the Unitary Plan that

provide maxima based on activity types. A key point of the Council's

approach is the removal of minimum parking rates in these areas.

4.3 Outside of the CBD, the CBD Fringe, Metropolitan Centres and Town

Centres parking would still be required with minimum rates set out in

Table 4.

4.4 Within the Council's approach there are two distinct elements: firstly

the removal of minimum parking rates or the removal of therequirement to provide any parking at all; secondly the introduction of


9/48


2898637

maximum parking rates in areas where maximum rates have never

been imposed in the past. We address these in turn below.

Removal of Minimum Rates in Centres

4.5 The removal of minimum rates means there would be no requirement

to provide parking on each site to cater for its expected parking

demand. In fact there would be no requirement for parking

whatsoever and so a development could be built without any parking

even if that development resulted in a significant or even severe

impact on parking on neighbouring sites or on adjacent streets. We

do not support this approach as in our opinion it is likely to result inadverse effects of development that will not be mitigated.

4.6 The most likely outcome of not requiring parking at all is that some

sites will be developed with insufficient parking to cater for their own

needs leading to excess demand on adjacent sites as users will

simply choose to park in the closest available carpark, often on a

neighbouring site. In effect the owners of the site with insufficient

parking will be able to "free ride" by externalising their effects at the

cost of their neighbours who have already paid for a parking area in

order to mitigate their own effects and support their own businesses in

accordance with the previous planning regimes. A similar parallel

situation is likely to occur where neighbouring streets will be used as

free parking for adjoining commercial activities. That in itself might not

be a problem but if the parking on that street is already used to

support existing activities then significant adverse effects could occur.

4.7 The Council appears to be taking a view that any adverse effects can

be managed through people installing barriers to their own carparks

and through Auckland Transport managing parking in neighbouring

streets through restrictions such as time limits, residents' schemes or

pricing. Our view is that this approach is naïve as it does not account

for the significant externalities, both positive and negative, that parking

can create.


10/48


2898637

4.8 Parking represents a significant cost to a developer, both in terms of

the use of land and the cost of building the parking space. We know

that parking in town centres has a significant flow-on impact on

business, because good parking areas that provide adequate spaces

and are easy to use function as an anchor drawing people into a

centre. Parking enables high value activities such as specialty retail

and supermarkets to establish and remain viable. These activities in

turn allow for centres to develop and cater for multiple purposes.

Ironically it is the presence of parking that allows people to get out of

their car and walk around and remain in a centre for longer.

4.9 This anchoring effect is well understood by major retailers and our

involvement with these retailers has always focussed on providing the

correct number of parking spaces to serve a development as well as

designing a high quality layout that links easily to their shops. Over-

provision of parking has seldom been a problem as Auckland District

Plans have all included dispensation mechanisms to allow a

development to reduce the parking rate below the default rules where

the higher level of parking is not required. Our opinion is that these

dispensation assessment criteria in principle have allowed most

development to occur with the correct number of parking spaces

(although various refinements to the criteria themselves could usefully

be made).

4.10 We can quantify the benefits of parking by considering the simple fact

that most customers travelling to retail activities in centres use private

cars to access the site. Work carried out for Scentre at St Lukes

shows the following breakdown of transport mode share1:

1 Reported by Booz and Company, Public Transport: Westfield St Lukes Plan Change,

November 2008


11/48


2898637

4.11 The important point to note here is that 82% of week day customers

arrived at St Lukes in private cars and 86% of weekend customers

arrived in private cars. In this example, even if bus usage doubled,

then 77% of people on weekdays, and 82% of people at weekends,

would still be reliant on cars to visit the shopping centre.

4.12 In contrast to the positive externalities of providing parking to support

activities and mitigate effects, inadequate parking can result in

significant negative externalities. For example an owner may have

invested a significant sum to build a carpark to accommodate their

own parking needs, and then be faced with neighbouring development

that occurs without adequate parking. In that situation, shoppers will

simply choose to park next door. When one development's parking

shortage results in parking problems for neighbouring sites that is anadverse effect. In effect the shortage of parking is transferred to


12/48


2898637

others. If the Council's position is accepted then these parking

problems in centres are a potential effect of high probability.

4.13 One of the reasons advanced by the Council for removing parking

minima is that the land could better be used for other activities. Rules

requiring parking mean that the land owner is not able to maximise the

use of their land. We disagree with that position as, in our experience,

developers have few problems obtaining a dispensation for parking

when parking is not required or where fewer spaces are needed. In

the past we have all encountered Council officers who have insisted

on high parking rates where that level of provision is not warranted.

However in recent years we have noted that it is much easier to obtain

realistic dispensations. This process could be improved through

clearer assessment criteria and better training of Council staff to

ensure they understand that the parking minima are only a starting

point for an assessment. We do not support the removal of parking

rules to address what we consider to be a non-existent concern

regarding over-supply of parking.

4.14 Part of the argument advanced by the Council appears to be that even

if a significant demand for parking is likely to be created by a

development then it should be the developers' choice whether they

mitigate their effects by providing for that demand, or choose not to

provide parking. We strongly disagree with that position. We

acknowledge that providing parking comes at a cost to developers.

So does every other mitigation measure required under the RMA and

the Unitary Plan. Our advice is that the efficiency arguments

advanced against parking minima are no different to what could be

mounted against rules requiring storm water mitigation, daylight rules

or protection of view shafts. The important point is that parking, in

areas where car access is paramount, is a resource that needs to be

sustainably managed. Requiring parking to be provided is the best

way to ensure a major parking shortage does not occur, a shortage

that would have serious adverse effects on a wide area.

4.15 The Council has promoted the removal of minima and the use ofmaxima in centres in part to try and reduce car use. We support that


13/48


2898637

general approach in the CBD where public transport use is high and

where significant future investment in public transport is already

scheduled. We do not consider that approach is appropriate in

metropolitan centres and town centres as these areas are highly

reliant on private cars. Indeed one of the well documented effects of a

parking shortage is that it can lead to much longer trips and an

increase in traffic congestion.

4.16 If shoppers find they can no longer drive to their most convenient town

centre as there is no longer parking provided then a few might choose

to change mode but many more will simply drive to a more distant,

less convenient centre to do their shopping (as long as it provides

parking). That situation in Auckland would not only result in longer

trips but because of our congested network those drivers are likely to

pass through more congested intersections resulting in higher delays

to other drivers than would be necessary had they been able to find a

convenient carpark at their preferred location.

4.17 Similarly if drivers choose to try and park in local streets where

parking is in short supply or on neighbouring sites where the parking is

now overloaded, then the result will be an increase in local traffic

congestion. Evidence of this effect has been widely documented in

the USA where it has been estimated from sixteen studies that as

many as 30% of all congested downtown trips are due to people

looking for parking.2 Surveys establishing this include one in

Manhattan3 where 28% of drivers were cruising for parking and

another survey in Brooklyn4 showing 45% of traffic on one street was

there specifically looking for a parking space to become free.

4.18 In our view removing minimum parking rates in centres, particularly for

retail activities, is unlikely to result in a reduction in traffic. On the

contrary it is more likely to result in local traffic congestion,

2 D Shoup, Free parking or free markets, Retrieved from

http://www.accessmagazine.org/articles/spring-2011/free-parking-free-markets/3 Schaller Consulting, Curbing Cars: Shopping, Parking and Pedestrian Space in SoHo,

December 2016 retrieved fromhttp://www.transalt.org/sites/default/files/news/reports/soho_curbing_cars.pdf

4 Transport Alternatives, No Vacancy- Park Slope's Parking Problem And How to Fix It,February 2007, retrieved fromhttp://www.transalt.org/sites/default/files/news/reports/novacancy.pdf


14/48


2898637

overloading of adjacent streets and parking areas, and longer

distance trips. All of these impacts are adverse transportation effects

that are likely to be significant.

Impact on intensification

4.19 If parking is no longer easily available at some metropolitan and town

centres, despite the fact that the vast majority of Aucklanders use

private cars when they go shopping, then those centres that have

parking will become increasingly more successful than those centres

that do not. That has implications for the intensification goal of the

Unitary Plan. As transport professionals we are unanimous in oursupport for public transport and for cycling and walking, but we know

from our experience that these are all minor modes when it comes to

shopping trips. Our advice is that the very goal of intensification of

centres could be at risk if adequate provision is not made for what is

currently and likely to remain the major transport mode.

4.20 If parking is fully catered for outside of centres, but problematic within

centres, then we consider that developers will choose to make a non-

complying application to locate outside of centres.

Management of Parking

4.21 Throughout our discussion with Council experts they have put forward

the claim that any potential adverse effect on neighbouring sites can

be mitigated by the neighbours themselves controlling access to their

own parking area. The Council position appears to be that if retailers

with parking do not want cars associated with adjacent activities

coming into their site then it is simply a matter of installing barrier arms

or warning signs to keep them out.

4.22 That approach can work for offices and premises that do not have a

significant level of public activity. But at retail centres and large format

stores with carparks it is impossible to tell when a car enters whether

the driver and passengers are customers at your shops or your

neighbours' development. For example we know that WestfieldHenderson already has people using their carpark who are visiting the


15/48


2898637

nearby offices of Auckland Transport (premises that were built

specifically by Waitakere City Council with a limited number of parking

spaces).

4.23 Warning signs only work if they are enforced and if the parking owner

is actually prepared to have cars towed away. The Countdown

Supermarket on the corner of Quay Street and Tangihua Street near

Britomart is a good example of a carpark that is commonly used by

visitors to other activities. But because it is so difficult to identify

errant parkers and because towing away one of your own customers

is a potential public relations disaster, it is seldom that the operator

can actually effectively keep non-customers out.

4.24 Barrier arms and ticket systems can be installed and this is done

where parking costs are higher such as at Two Double Seven in

Newmarket. However this means you then have to charge your own

customers for parking which is a disincentive for them to visit your

shops. Discounts for people who hold receipts from your shops are

also problematic as many shoppers do not know in advance if they will

actually find something to buy. But they do know in advance that you

will charge them for parking. The other problem we have encountered

with this type of customer discount is that people might use your

parking to visit neighbouring activities, then simply buy a low cost item

such as a sandwich on their way out. Kiwi have encountered this very

issue at the Hamilton City carparking building adjacent to Centre

Place.

4.25 In some cases it will not only be the owners of neighbouringcommercial development that will be adversely affected by the

removal of parking minimums. Many residential streets located near

to centres already experience heavy on-street parking on business

days. That might not be a problem where houses have been built with

adequate off street parking for residents and visitors. However in

many older areas and areas where more recently town houses have

been built, on-street parking is used to meet some of the existing

residential parking needs. Even in newer areas, where houses havebeen built, with two parking spaces each, subdivision rules have


16/48


2898637

required on-street parking specifically to cater for visitors. If these

spaces then get filled due to neighbouring commercial development

that has been allowed to occur without mitigating its effects then there

will be an effect on residential amenity.

4.26 In some older areas houses were built prior to the widespread use of

cars and there is no chance of providing off-street parking. Similarly,

as residential intensification occurs under the Unitary Plan, new

residential developments are resulting in fewer carparks. Losing on-

street parking will have a severe adverse impact on these residents.

Pricing of Parking

4.27 An implicit assumption of the Council's position appears to be that

parking in and around centres should all be priced. Certainly they

must be expecting the removal of parking minima to result in greater

pressure on on-street parking. The Auckland Transport Parking

Strategy released in April 2015 suggested that when parking in streets

regularly exceeds 85% occupancy at peak times, time limits will be

introduced and, when these fail to work, pricing will occur. We

consider that will be inevitable in many places if significant

development occurs without parking.

4.28 Pricing of parking in existing shopper centre carparks is a different

matter. Charging for parking is likely to have the same impact on

customers as charging for access to the front door would. Retail

shops work by attracting people in to look at the goods that are for

sale. We have all had extensive experience working for both major

retailers and on Main Street projects for local shopping centres. The

key issue we are often faced with is making it as easy as possible for

as many people as wish to come to the centre and browse. The

models we use in transport planning predict people's preferred

destination based on the total cost of travel. If parking is charged at

one centre and free at another that is likely to have an impact on both

traffic distribution and on the success of the centre. We know that

customers are sensitive to parking charges.


17/48


2898637

4.29 This impact of parking costs has been demonstrated by surveys in

Sydney of transport elasticities5 and cross-elasticities as shown in the

table below. While these relate to CBD parking buildings we would

expect similar results in Metropolitan Town Centres.

4.30 The elasticities show the effect of a 1% cost in parking. In all cases

an increase in parking cost results in less people travelling to that

area. In fact more people choose not to go there than actually choose

to change to public transport, as shown in the bottom two rows of the

table.

4.31 Care needs to be exercised using cross-elasticities like these as they

relate to very specific surveys carried out in different conditions to

ours. However the general pattern that more people would avoid a

trip to that centre than would choose to use public transport is likely to

hold true. In fact given the lower level of public transport at most of

our centres outside the CBD and the fact that shoppers have a higher

choice in destination, we would expect the trend to be even more

pronounced. Based on our analyses we do not consider pricing

parking at a centre to be a realistic way of improving transport

outcomes.

4.32 Not only will pricing a shopping centre carpark result in less people

visiting that centre, the more important issue for the major retailers is

that they have no way of keeping out non-customers ie those visiting

the development that has been built next door without parking. We

believe that it is this simple fact that has been missed by the Council's

5 Demand elasticity is a measure of how much the quantity demanded will change if

another factor changes.


18/48


2898637

advisor Mr Donovan. He has made the assumption that parking is

excludable and rivalrous and therefore a private good not subject to

the so called 'free rider' problem.6 Parking is excludable only in a very

narrow economic definition that you can exclude people who do not

pay to be there (see the table below). But our clients are not carpark

operators seeking to maximise the revenue of their parking. They are

shopping centre owners and retailers who use the parking only as a

means of attracting customers to their stores. Assuming that the

parking in these shopping areas is an excludable good treats these

parking spaces as if they are owned by a parking business whom is

indifferent to who actually uses the spaces.

4.33 A barrier arm can exclude people who have not paid but there is no

practical way to exclude only those people who are not going to visit

the shops that the carpark was built to serve. In that sense the

commercial parking may be a private good but shopping centre

parking operates more like a common good. The important point

here is that the parking exists to serve a specific store or integrated

shopping centre, it is neither private parking nor is it public parking

available for anyone to use.

4.34 The Council's position has assumed that large format retailers and

shopping centre owners are operators of commercial parking buildings

rather than integrated businesses who focus on attracting customers

for their own retailers.

6 Evidence of Stuart Donovan, on behalf of Auckland Council, at paragraph 7.4.


19/48


2898637

Public demand to build parking

4.35 Finally we would like to comment on where we believe this policy will

take us if it is approved. In our experience, people do not like parking

shortages. They do not like paying for something that was free in the

past and they particularly do not like finding that the shopping centre

or shop they are familiar with and where they fulfil their needs is no

longer accessible or convenient. In our experience both as engineers

and as advisors to local government, such an outcome would lead to

complaints. It seems to us that if these rule changes result in parking

shortages in many town centres as we expect will occur, then it is

inevitable that the Auckland Council will come under intense pressure

to start building public parking areas to alleviate the problem. That

would mean the parking demand created by private business will have

been externalised and made into a cost to the community.

4.36 We have all been involved in parking studies for local authorities and

we all consider that it will be inevitable that removing minimum parking

rates in centres outside the CBD will result in pressure to build new

parking facilities. We note that the Auckland City Council was still

building carparking structures7 in the CBD to respond to demand in

2002 some 15 years after parking limits were brought in.

Minimum rates relief

4.37 In relation to minimum parking rates in centres, the KRG seeks the

following:

For all retail, including supermarkets and food and beverage,

a minimum rate of 1/30m2.

For a new category "commercial services", a minimum rate of

1/30m2 and a maximum rate of 1/20m2.

4.38 The suggested minimum rate of 1/30m2 is considered by the KRG to

be a reasonable but fairly lenient rate when compared with the typical

minimum rates of 1/17m2 and 1/20m2 contained in the Operative

7 Notices of Requirement to add floors to both the Victoria St and Downtown carpark

were confirmed in 2002 and constructed shortly after.


20/48


2898637

District Plans in Auckland and the minimum 1/25m2 rate now

proposed in the Unitary Plan for areas outside Centres. This rate of

1/30m2 will ensure that all retail and commercial service activities at

least go some way to providing a level of car parking to meet their

needs, and so minimise the detrimental effects on those activities

(such as supermarkets and department stores) that do provide a

reasonable level of parking even under the maximum parking rate

controls. In all other areas (Development Control 3.2, Table 4), a

minimum parking rate of 1/25m2 is applied to all general retail

activities (including food and beverage), and the KRG supports this.

The Council is now proposing that Large Format Retail (excluding

supermarkets and department stores) should be separately identified

in the Neighbourhood Centre and other zones with a minimum parking

rate of 1/45m2, and we consider this to be a more reasonable rate for

LFR. We also note that "commercial services" are identified as a

separate group with a minimum parking rate of 1/25m2, consistent with

the above proposal for Centre zones.

Maximum rates

4.39 The Council's position is that maximum rates for parking (permitted

parking) should apply to activities located in the CBD, CBD fringe,

Metropolitan Centres, Town Centres and Local Centres. Activities

other than offices would be subject to minimum parking rates (required

parking) outside of the centres. Offices would be subject to maximum

parking regardless of where they are located.

4.40 We support the concept of maximum rates for the CBD, although wedo not consider a blanket rate of 1 space per 200 m2 for all of the

CBD to be the best way of achieving that. (John Parlane will address

this matter in a separate statement.)

4.41 We also support the application of maximum parking rates for offices

regardless of where they are located, as in our opinion it is regular

commuter trips that are best able to be catered for by public transport,

and removing as many of these trips as possible from general traffic in

the peak periods is supported.


21/48


2898637

4.42 We believe the Council is wrong in only applying maximum rates to

retail in the centres outside the CBD as private cars are currently and

likely to remain the predominant form of transport to shops in these

centres. Ms Joyce has expressed the opinion that "the proposed

rates are generous and will not significantly restrict parking supply for

land use activities."8 We disagree that the rates are generous.

4.43 Parking for retail activities cannot be set at an overall average

because shopping centres and large format retail typically generate

different levels of parking demand at different times. Even if people

wanted to use public transport to go to the shops, peak times for

shopping centres and large format retail occur at weekends and on

public holidays when public transport services are often at reduced

levels. Most shops experience their regular peak customer demand in

the early afternoon on Saturdays and Sundays with extreme peaks

occurring at times such as Boxing Day.

4.44 There is also the problem of transporting purchases home.

Supermarkets in particular tend to be located in shopping centres or

on arterial roads at sites with a generous parking area. The

overwhelming majority of customers drive to the supermarket in order

to load their car with groceries regardless of how good public transport

services in the area are.

4.45 There is little direct link between public transport services and the

success of shopping areas and for that reason we do not support the

imposition of maximum rates on retail activities outside the CBD.

4.46 One of the justifications for maximum rates advanced by the Council

advisors in our discussions is that maximum rates prevent too much

parking being provided. In our experience developers have every

reason to get the level of parking right as each additional parking

space has a significant cost. There are also times when a developer

provides sufficient parking to cater for the development and their

expected future extension as it is often cheaper to build a full structure

8 Mairi Joyce statement of evidence paragraph 36.


22/48


2898637

at the outset rather than extend later. Maximum parking rates would

prevent that type of future proofing.

4.47 Another potential problem with maximum parking rates for retail is that

shopping centre owners and other retailers will experience higher

parking demand if their neighbours do not build sufficient spaces.

They could then be prevented from increasing the size of their own

carpark to meet overall demand as the maximum rates are based on a

calculation of their own floor area and do not take into account the

neighbouring land use activities creating the demand.

Proposed approach by KRG

4.48 Notwithstanding those concerns, the KRG is proposing a more

balanced approach of retaining minimum parking rates in centres

while providing maximum rates for some activities.

4.49 In our opinion, the KRG relief should be accepted because it reflects

the reality of parking generated by retail activities in centres. The use

of minimum rates in centres would ensure that the effects of each

development are mitigated and avoid the potential for cars generated

by development to spill over into neighbouring properties. The

Council has assumed that this can be avoided with barriers and signs.

In our view that is simply naïve.

4.50 The KRG's proposal will allow for maximum parking rates to be used

where they could actually be effective in reducing peak hour traffic

flows. Sites located in the CBD and office activities across the city

generate trips that can, and in our view should, be catered for in the

first instance by public transport. In contrast public transport is not the

predominant means of accessing retail activities outside the CBD. In

our opinion maximum rates are the wrong method of addressing the

impacts of these retail activities. Minimum rates would ensure that

adverse effects are appropriately avoided, remedied and mitigated.


23/48


2898637

5. PARKING RATES FOR SUPERMARKETS

5.1 Within the general group of "retail" activities, supermarkets have their

own specific characteristics in terms of particularly high levels of traffic

generation and parking demand, and therefore should be specifically

acknowledged as a particular type of retail in terms of appropriate

parking rates. The KRG seeks the addition of a new separate car

parking category for "supermarkets" within the retail group of activities.

5.2 The main characteristics of a modern supermarket from a

transportation perspective are that supermarkets attract large volumes

of customers, who make regular visits to purchase significantquantities of groceries and other household items. Whilst cross-

shopping (and therefore shared trips) can and should be encouraged

wherever possible, the fact remains that a large proportion of

supermarket shopping trips are and will continue to be sole-purpose

trips.

5.3 The need to transport large quantities of goods between the

supermarket and (generally) home means that the private vehicle is

realistically the only practical alternative for many grocery shopping

trips, and the use of public transport or walking and cycling is typically

not a feasible option. Depending on the particular type and location of

the supermarket, varying proportions of customers can and will make

smaller purchases and travel by other modes (public transport,

walking, cycling), but the underlying characteristics of most

supermarkets do involve the private vehicle. Realistically, this is

unlikely to change in the foreseeable future.

5.4 As a result, supermarkets generate high levels of parking demand,

and the provision of customer car parking that is readily available at all

times is fundamental to supermarket operation. Whereas customers

of many retail activities may be able to use "shared" parking

opportunities (and indeed in many situations should be encouraged to

do so), the simple need to utilise shopping trundlers for large

quantities of groceries means that car parking must be provided as

close as possible to the supermarket. Imposing maximum parking


24/48


2898637

rates without recognising the particular characteristics and needs of a

supermarket can have a serious impact on the convenience, operation

and viability of that supermarket and, whilst avoiding the over-

provision of parking will be appropriate in many circumstances, under-

providing short term customer parking for supermarkets can seriously

affect the operation and viability of the supermarket.

5.5 The Council currently proposes (Development Control 3.2, Table 3) a

maximum parking rate of 1 space/20m2 GFA for all retail other than

food and beverage, on sites within the City Centre Fringe overlay and

Metropolitan Centre, Town Centre Local Centre, Mixed –Use and

Terrace Housing and Apartment Buildings ("THAB") zones. This is a

generic approach to all retail in general, and makes no recognition of

any specific characteristics of supermarkets.

5.6 Within the "retail" group of activities, the parking rates sought by the

KRG are as follows:

For general retail, excluding supermarkets, retain a maximum

rate of 1/20m2 as currently proposed by the Council.

For supermarkets, introduce a maximum rate of 1/17m2.

5.7 The intention of seeking the slightly higher maximum rate for

supermarkets of 1/17m2 is to provide a small degree of flexibility for

applicants to ensure that the full car parking provision can be made to

ensure that supermarket customer demand is met under differing

circumstances.

5.8 In the statement of evidence of Ms Mairi Joyce on behalf of the

Council, some data on parking rates at existing supermarkets is

provided9 from which Ms Joyce concludes that "based on the

evidence available I am comfortable that the proposed rates for

general retail (being a maximum of 1 per 20m2 in the Centre, Mixed

Use and THAB zones) provides a range in which the current parking

demands for supermarkets and discount department stores can be

accommodated."

9 Paragraph 132, Table 1.


25/48


2898637

5.9 We too have put together some data on a sample of existing NTC

supermarkets, as set out in the table below.

Recently Developed and Propo sed New World Superm arkets

New World GFA SPACES RATE

Papakura 3081 156 1/19.8

Howick 3093 163 1/19.0

Orewa 2967 143 * 1/20.8

Kumeu 2852 173 1/16.5

Te Puke 2678 138 1/19.5

* 40 of 183 spaces legally assigned to Council public parking

5.10 The supermarkets included in the above table have been chosen as

being recently approved or developed New World stores in the

Auckland area, therefore illustrating the current general trend in

supermarket parking provision. Whilst it is acknowledged that there

are numerous supermarkets in Auckland that do provide lower parking

rates (for whatever reason), the table demonstrates that a parking rate

of at least 1/20m2 is the level of parking currently being provided at

new, modern supermarkets, in which case a 1/20m2 maximum rate

would be too low for these supermarkets. All but one of the stores

would comply with the 1/17m2 maximum rate sought by KRG, which

illustrates that this would be a realistic but not excessive maximum

rate for providing supermarket car parking.

5.11 It is noted that for a supermarket of 3,000m2

(a fairly typical size formodern New World supermarkets), the worst-case scenario of

allowing a maximum rate of 1/17m2 rather than the generic 1/20m2

could potentially result in an additional 26 parking spaces (moving

from 150 spaces to 176 spaces). In the context of a wider transport

environment this is unlikely to have a significant detrimental effect, but

it could have a very noticeable beneficial effect on the operation and

viability of the supermarket.


26/48


2898637

5.12 In discussing the rationale for maximum parking rates, Ms Joyce

states:10

…I consider the rates to provide a generous "upper limit" forland use activities located within or close to centres. Thisallows for developers to determine the most appropriate levelof parking for their land use activity, whilst also providingprotection from significant parking over supply.

5.13 Then when discussing the rationale for minimum parking rates, Ms Joyce

states that:

the reduction in the minimum rates is intended to provideincreased flexibility to allow developers to select the mostappropriate parking provision for their site whilst providingprotection from a significant undersupply of parking…

5.14 Clearly Ms Joyce appreciates the importance of allowing developers

some flexibility to select the most appropriate parking provision for

their particular site and activity, but the reluctance of the Council to

acknowledge any different type of retail such as a supermarket

appears to revolve around the desire to reduce the number of land

uses for which parking rates have been included in the Unitary Plan to

simplify the rules.11

5.15 In terms of oversupplying or undersupplying car parking for their

customers, our experience is that supermarket operators are very

conscious of avoiding the unnecessary costs associated with

providing large areas of car parking that might not be needed, but are

equally conscious of ensuring that sufficient car parking is provided to

meet all demand. Both of these scenarios have a significant effect on

the viability of the supermarket, as discussed in the evidence of

Angela Bull on behalf of NTC.12

We consider that the provision of aspecific parking rate for supermarkets (maximum rate of 1/17m2) will

provide the necessary flexibility to achieve viable and efficient

supermarkets, with minimal overall additional impact on surrounding

areas or activities.

5.16 The desire to retain some degree of flexibility (specifically the 1/17m2

maximum rate for supermarkets) will become increasingly important

10 At paragraph 33.11

At paragraphs 35 and 45.12

At paragraph 21.


27/48


2898637

into the future. As development within or close to centres continues to

intensify, in line with the overarching objectives of the Unitary Plan,

land will become increasingly scarce and costly, and this is likely to

encourage supermarket operators to design smaller stores that will

have to serve increasing customer numbers within any given

catchment. Even acknowledging the general desire and opportunities

within centres for encouraging the use of public transport, walking and

cycling, the result is likely to be higher customer numbers and higher

parking demand, resulting in higher parking rates to meet that

demand. Building the additional flexibility that is sought by the KRG

into the Unitary Plan Development Controls will take account of these

future trends. The Council's aim of generally reducing the amount of

parking that can be provided by other developments and activities

(see below) can only exacerbate these increasing pressures on

supermarket parking.

6. CYCLE PARKING

Background

6.1 The Unitary Plan introduces for the first time in Auckland,

requirements for cycle parking, and end-of trip facilities such as

showers and changing areas, ("cycle facilities"). Cycle facilities did

not feature in any of the legacy district plans. In this regard then, the

Unitary Plan is essentially starting from a zero base.

6.2 The inclusion of requirements for cycle facilities follows from the

strategic directions set in the Auckland Plan, wherein one of the goals

is to deliver by 2040 a transport system capable of doubling the

proportion of non-car trips made in the morning peak. This means

that cycling, as a non-car mode, will have to play its part in achieving

this target. Cycling currently accounts for 1.5% mode share in

Auckland during the morning peak, and about 1% mode share for all

travel to work.13 This means that the provision of cycle networks and

13 Statistics NZ – New Zealand Household Travel Survey: Travel to work for the

Auckland Metropolitan Urban Area – 3 year moving average.


28/48


2898637

cycle facilities will be necessary to achieve this doubling of cycle use

over the next 25 years.

6.3 However, while there is KRG support for the goal of increased cycle

use, the means of achieving that goal has to be appropriate. Without

derogating from the enthusiasm and passion of Auckland Transport's

and Auckland Council's cycling advocates, their enthusiasm must be

tempered by commercial realities and realistically attainable targets in

order to ensure that achievement of the desired goals is positively

supported and affordable.

6.4 In this regard, we note from the evidence of Ms King

14

that cycleinfrastructure in Auckland is a work in progress. Development of

Auckland's cycle network is still in its early stages, and the Auckland

Plan has a set target to have the Auckland Cycle Network completed

by 2030.

6.5 We also note from her evidence that by far the greatest impediment to

cycling in Auckland is currently the safety implications of using the

existing road network.15 This means that in order to get meaningful

traction in terms of encouraging greater cycle use, ongoing upgrading

of the cycle network must take priority.

6.6 In the evidence of Mr McLean16, he notes that there is currently little

quantitative research either in New Zealand or overseas, which looks

at the demands for cycle parking. Mr McLean therefore looks to what

Christchurch and Hamilton have adopted for their district plans as his

yardstick for Auckland, despite the significant spatial, geographic and

climatic differences between those two cities and Auckland (as has

been discussed in more detail in the KRG Joint Planning evidence).

6.7 The key points to be made with respect to the above comments are

that:

(a) The Unitary Plan is starting from a zero base with regards

requirements for cycle facilities.

14 Evidence of Kathryn King, Page 4.15

Evidence of Kathryn King, Pages 9 and 10.16

Evidence of Christopher McLean, Page 27.


29/48


2898637

(b) The current major impediment to cycle use is not a lack of

provision for workplace cycle facilities but rather the safety (or

lack of) for cyclists using the current road network and the

difficulties associated with cycling given Auckland's

topography.

(c) It is going to take Auckland Transport some significant time to

complete its ongoing development of a safe cycling network

as planned.

(d) There is virtually no empirical basis for adoption of the cycle

parking rates that are proposed in the Unitary Plan.

6.8 Yet despite these constraints, the Unitary Plan seeks to impose at the

outset what the KRG considers to be almost utopian requirements for

cycle facilities, which will come at a significant cost to developers.

6.9 At the other end of the scale, it could be reasonably argued that there

is in fact no need for the mandatory provision of cycle facilities, since

the market will dictate demand for these facilities. As cycling as a

travel mode becomes more popular and ingrained, pressures will

come on employers, building owners and developers to provide the

facilities that the occupants seek. Developers would be incentivised

by the reduced costs associated with cycle parking versus car parking,

and by value premiums associated with being able to provide what the

market seeks.

6.10 A good example of how this has worked in practice is in the

development of green-star rated buildings. It is not mandatory for a

developer to build green buildings, but they are doing so because they

can achieve a value premium by providing what owners and tenants

increasingly want to have.

6.11 Realistically, the answer to the provision of cycle facilities probably sits

somewhere between mandatory provision right now of what we would

eventually all like to see one day in the world's most liveable city,

versus free market drivers.


30/48


2898637

6.12 Accordingly, the KRG is proposing somewhat reduced requirements

for cycle parking and end-of-trip facilities that still go well beyond what

is currently experienced, but still remain realistic and affordable to

developers.

Office Cycle Parking

6.13 The Unitary Plan as notified seeks office cycle parking on the basis of:

(a) 1/100 m2 GFA for visitors (short-stay).

(b) 1/300 m2 GFA as secure (long-stay).

6.14 Subsequent to notification, the visitor (short-stay) cycle parking

requirement was increased by Council to be:

(a) 1 space + 1/1,000 m2 GFA.

6.15 The long-stay cycle parking remained at:

(a) 1 space/300 m2 GFA.

6.16 With regards the visitor (short-stay) cycle parking, Mr McLean17

justifies the parking rates on the basis that it:

… is considered fair and takes into account the significantscale of some office buildings in Auckland, particularly in theCBD.

6.17 As a basis of determining visitor cycle parking in Auckland, this seems

particularly thin. It would seem that this rate has been proposed on

the basis of what seems "about right".

6.18 In order to gauge just what this rate means in reality, and building

upon Mr McLean's reference to CBD offices, we have examined as a

test example, the Vero Centre on Shortland Street in Auckland City.

The Vero Centre has been chosen because it already provides a

significant area for cycle parking within the building (this cycle parking

area being reasonably secure within the parking structure and

immediately adjacent to lifts). The Vero Centre has a gross floor area

17 Evidence of Christopher McLean, Page 6.


31/48


2898637

of 68,900 m² GFA. It is understood that existing visitor cycle use

amounts to the occasional cycle courier. Yet if the Unitary Plan visitor

cycle parking requirement is applied, it would have to provide 70 cycle

spaces for visitors. While this is just one example, it does clearly

serve to demonstrate that there is a gaping disconnect between

aspiration and likely reality.

6.19 Accordingly, the KRG proposes a less onerous, but nevertheless still

aspirational visitor cycle parking rate as follows:

1,000m² GFA

1 plus 1 per 3,000 m² GFA

6.20 The recommendation of nil parking for small offices recognises that

most such offices will have little or no ability to physically provide on-

site visitor cycle parking.

6.21 Tying the above rates back to the Vero Centre example would still

require 24 visitor cycle parking spaces to be provided. In the context

of the occasional cycle courier that presently visits the building, this is

still clearly aspirational.

6.22 The Unitary Plan requirement for long-stay cycle parking at one space

per 300m² has been determined on the assumption that one

employee in 20 will ride a cycle to work, (each employee typically

occupies 15 m²).

6.23 Again, reverting to the Vero Centre example, where ample cycle

parking is available, and showers etc. are provided within a

gymnasium within the building (and on some of the tenanted office

floors of the building), one space for 300 m² for staff would produce a

staff cycle parking requirement of 230 spaces. This total compares to

several recent observations of actual cycle parking demand which

reveals existing demands that have varied between 18 and 23 spaces

(as shown in the photograph below).


32/48


2898637

6.24 There is, then, a substantial disconnect between what happens now,

and what the Council track-change version proposes. This ten-fold

disconnect is substantially greater than the target doubling of cycle

use as proposed by the Auckland Plan.

6.25 The KRG considers that a more appropriate rate to apply to office

long-stay cycle parking is one space per 600 m2. Tying this back to

the Vero Centre example still results in a requirement for 115 spaces,

which is clearly still hugely aspirational (representing a growth

significantly greater than the goal of doubling cycle use as set by the

Auckland Plan), but at least it is slightly more realistic and affordable.

6.26 With regards the issue of cost, one of the arguments forwarded in

support of the notified version cycle parking rates is that cycle facilities

are cheap to provide18. However, in this Vero Centre example, the

space and infrastructure costs of accommodating 70 visitor cycle

spaces plus 230 staff cycle spaces, totalling 300 cycle spaces, would

be substantial, especially if only ever partially utilised.

Retail Cycle Parking

6.27 The Unitary Plan as notified seeks retail cycle parking on the basis of:



33/48


2898637

(a) Food and beverage:

(i) Visitors: 350m2 – 1 per 350m2

(ii) Long Stay: 1 per 200m2 GFA

(b) All other retail:



6.28 Following mediation, the rates for retail cycle parking were modified to

those now proposed in the evidence on behalf of council. They are as

follows:

(a) Food and beverage:



(b) All other retail:

(i) Visitors: 5,000m2 – 1 per 750m2

(ii) Long Stay: 1 per 300m2 GFA of office

6.29 The modified cycle parking rates for food and beverage in the Council

track-change version are acceptable to the KRG.

6.30 The modified cycle parking rates for all other retail in the Council

track-change version are also acceptable to the KRG. Just by way of

a litmus test, a 6,000 m2 large format retail store would be required to


34/48


2898637

provide 8 visitor cycle spaces; and the 42,500 m2 St Lukes shopping

centre would be required to provide 57 visitor cycle spaces (where

they currently provide 13). These visitor cycle parking totals for all

other retail are therefore considered to be aspirational but realistic.

End-of-Trip Facilities

6.31 The notified version of the Unitary Plan contained very detailed and

prescriptive requirements for cycle end-of-trip facilities (i.e. in terms of

where cycle parking is to be located, how cycles are to be made

secure, etc.) which applied to offices, education facilities and

hospitals.

6.32 Following mediation, many of those prescriptive elements of end-of-

trip requirements have been deleted, which the KRG considers

appropriate.

6.33 However, the Council is still proposing in evidence prescriptive

requirements relating to showers, changing rooms and clothing

storage areas. While the rates proposed are not unacceptable, the

KRG is of the view that is it unnecessary for the Unitary Plan to be

prescriptive about showers and changing rooms in new buildings, and

that this is better left to building developers, owners and tenants to

determine. The KRG therefore considers that these requirements

should be deleted.

6.34 The end-of-trip facilities have now been clarified as applying only for

staff use, and to new buildings. With regard the latter, the intention is

that they would not apply retrospectively to existing buildings.19

This

is fully supported by the KRG.

7. LOADING

7.1 The loading requirements are set out in Development Control 3.2,

Table 7.As an outcome of mediation, the Council proposes to increase

the threshold above which a loading space is required for retail and



35/48


2898637

industrial activities from 100m2 to 300m.220 () We agree that this now

represents a more realistic level below which an activity should still be

able to operate with on-street loading without affecting the transport

environment.

7.2 The KRG supports the remainder of the loading requirements.

8. DESIGN OF PARKING AND LOADING AREAS

8.1 As an outcome of mediation, the Council proposes some minor

changes to the car parking design standards (Table 8), as outlined in

the evidence of Karl Hancock (paragraphs 57-62).

8.2 Particular changes include clarification that these are minimum

standards; provision of a separate set of parking dimensions for

parking areas that are intended for use only by regular users (eg staff,

residents); and inclusion of "retail" within "all other activities" to better

reflect the loading requirements for those retail activities (rather than

applying the "industrial" standard).

8.3 The KRG supports the amended parking design standards.

9. ACCESS

9.1 In the notified Unitary Plan, the access rules are provided to:

(a) enable a safe and efficient interface between a development

site and the frontage roadway;

(b) to protect the operations of adjacent intersections and

motorway interchanges, and arterial roads; and

(c) to limit, discourage or control vehicle crossings within certain

high pedestrian area, and / or to provide for continuity of

building frontages.

20 Evidence of Mairi Joyce, paragraph 57.


36/48


2898637

9.2 With regard the latter point, the access objectives and policies as

notified, used prescriptive language that required the ‘avoidance’ of

vehicle access to and from sites subject to either a:

(a) Vehicle Access Restriction – general within the City Centre

zone; or

(b) Key Retail Frontage (Zone controls, Building frontage maps)

overlay in the Metropolitan Centre, Town Centre and Mixed

Use zones,

and restriction on vehicle access to and from sites subject to a:

(c) General Commercial Frontage (zone controls, Building

Frontage maps in Metropolitan Centre).

Town Centre and Mixed Use Zones

9.3 Following mediation there was agreement on replacement of the word

‘avoid ’ as being overly prescriptive in the context of the activity status

that applies. The language agreed at mediation which we consider to

be more appropriate is now:

(a) ‘Restrict or manage’ site access adjacent to intersections or

motorway interchanges, or onto arterial roads.

(b) ‘Discourage’ access across the Vehicle Access Restriction-

General in the City Centre Zone.

(c) ‘Limit ’ access across the General Commercial Frontage in

Metropolitan Centre, Town Centre and Mixed Use zones.

9.4 It is noted with regard the latter that in the objectives and policies,

Policy 23 retains the words “to and from sites subject to the…”,

whereas in previous clauses these words have in Council's evidence

been replaced with the words “across the…”. This appears to be an

oversight in Policy 23, and it is recommended that Policy 23 be

amended accordingly. This would recognise that there are

circumstances where not all frontages to a site are subject to vehicle

access restrictions, in which case access could be taken from the


37/48


2898637

unrestricted frontage(s) without conflicting with the reason(s) that the

restriction has been placed on the other frontage(s).

9.5 The Council now proposes additions to the activity table to recognise:

(a) Permitted activity status for existing crossings servicing

activities where a Vehicle Access Restriction applies.

(b) Restricted Discretionary status for use of an existing crossing

where a Vehicle Access Restriction (General in the City

Centre Zone or Key Retail Frontage) applies in relation to

new development or redevelopment.

(c) Restricted Discretionary status for the situation where a new

crossing is established where a Vehicle Access Restriction

(General in the City Centre Zone or Key Retail Frontage)

applies, and the new crossing is to enable the relocation or

amalgamation of an existing crossing(s).

9.6 These proposed additions are appropriate from a traffic engineering

perspective, as the impacts on pedestrians along the frontage, and /or the impact upon the continuity of buildings along the frontage, are

both addressed.

9.7 In relation to Vehicle Access Restrictions on Key Retail Frontages

which was subject to a blanket non-complying activity status without

exceptions in the notified Unitary Plan, the Council has neglected to

consider the fact that there are numerous existing developments that

have their only vehicle access across the Vehicle Access Restriction,

and have no other access options available. This clearly means there

would be no opportunity to either change the nature of the activity that

the access serves, or to modify access even if the modification meant

a net improvement to access conditions (for example, by way of

amalgamation of two existing crossings into one new crossing).

9.8 By way of example of the frequency with which existing crossings

would become non-complying under the notified rules, an examination

has been made of the Newmarket 1 Precinct which is in the area


38/48


2898637

outlined below. Within this area there is approximately 1510 m of

General Commercial Frontage within which there are 22 crossings,

and 2975 m of Key Retail Frontage within which there are 29 existing

crossings that would immediately become non-complying, and for

which no alternative access exists.

9.9 Flexibility on how the crossings for these sites are managed over time,

and flexibility with regards the ability to undertake redevelopments on


39/48


2898637

those sites, is important and sensible in order to maintain the ongoing

viability and vitality of those sites.

9.10 Accordingly, we strongly support the addition of flexibility to the

Vehicle Access Restriction requirements to properly recognise existing

accesses to existing developments, and to enable future

developability of the sites served by those accesses.

Proposed Rules

9.11 Based on the discussions above, we therefore endorse the track-

change version proposed amendments and additions to Rule 3.4.1

regarding vehicle access.

Width and Number of Vehicle Crossings

9.12 The Council track-change version contains some amendments to

Table 13 which specifies the number of permitted vehicle crossings.

9.13 When considering the maximum number of vehicle crossings, an

amendment has been made to apply the rates to site frontages, rather

than to the site as a whole. This reflects the fact that some sites havemultiple frontages with potentially quite independent access

implications.

9.14 Table 13 also implicitly acknowledges that larger sites can also

accommodate multiple vehicle crossings on the same frontage,

provided that they are adequately separated to ensure no interactive

effects between the crossings.

9.15 Accordingly, those parts of a site subject to a Vehicle Access

Restriction under clauses 3.4.1.2 and 3.4.13, and a General

Commercial Frontage (zone controls, Building Frontage Maps), will

now be permitted up to one vehicle crossing per 50 m of frontage or

part thereof (compared to one overall as required by the notified

provisions); and all other sites will be permitted up to one crossing per

25 m of frontage or part thereof, (compared to two overall as notified).

9.16 With regard to the latter however, while for ‘all other sites’ , the change

from a maximum of two crossings to one per 25 m of frontage was


40/48


2898637

agreed by the traffic experts during mediation, upon further reflection it

is apparent that this will materially disadvantage smaller sites

(residential in particular), where two crossings are either desirable or

necessary – for examples to achieve a pair of one-way entry and exit

crossings, or to achieve crossings to separately accessed parking

areas.

9.17 Accordingly, we recommend a small alteration to the provision for the

maximum number of vehicle crossings per road frontage of the site for

‘All other sites’, to be:

Either two crossings per frontage; or one per 25 m of frontageor part thereof.

Access for Non-Arterial Roads

9.18 The Council track-change version proposes the deletion of Rule

3.4.2.3 which (as notified) required that where a site has frontage to

both an arterial road and a non-arterial road, the vehicle crossing must

be on the non-arterial road.

9.19 We fully support deletion of this rule. Mandating the use of a non-

arterial frontage for access in favour of an arterial frontage has the

potential to introduce unintended consequences, most particularly the

drawing of large volumes of development-related traffic into local

areas. This problem would become greatest in residential areas.

9.20 Further, in a broader transportation sense, it can often be a much

more efficient solution to manage large traffic volumes directly to and

from an arterial road. A Town Centre shopping centre or a large

school are good examples of activities where access is usually best

managed from an arterial frontage, rather than drawing large traffic

flows into non-arterial (potentially residential) roads that are probably

less able to accommodate the generated traffic demands.

9.21 Rule 3.4.1.3d requires a Restricted Discretionary assessment of any

access proposed across an arterial road frontage. This incentivises

the easier route of providing access via the non-arterial road frontage

(if the choice is available). However, for developments that may be


41/48


2898637

better suited to arterial road access, that option will remain available,

albeit by way of a restricted discretionary assessment.

Vehicle Crossing and Vehicle Access Widths

9.22 Table 15 in 3.4.3.2. of the Council track-change version provides

some small adjustments to some vehicle crossings and vehicle access

widths for some zones. These proposed modifications to the table go

at least some way to achieving a better balance between the vehicle

manoeuvring requirements of users, versus the amenity requirements

of passing pedestrians.

9.23 This is further assisted by the proposed note to Table 15, which

applies to the maximum two-way width of crossings in General

Business, Business Park or Industrial zones, and which states that a

maximum width of 9 m is permitted where the crossing needs to

accommodate the tracking path of large heavy vehicles.

9.24 However, there are still some deficiencies in the table that in our

opinion do not adequately address the actual and practical needs of

users of the vehicle crossings. In this regard, we consider that theUnitary Plan still retains an unnecessary emphasis on pedestrian

amenity when considering the design of vehicle crossings, whereas

the primary design consideration should be to achieve the purpose of

the crossing, which is to move vehicles to and from the roadway. It is

fully accepted that the amenity of any pedestrians on the frontage

footpath must be properly considered, but not at the expense of an

ineffectual and inefficient means of accommodating manoeuvring

vehicles.

9.25 For examples, the crossing widths as currently proposed do not take

account of high traffic generators such as schools and retail

developments; nor do they fully take into account the manoeuvring

requirements of large trucks (even notwithstanding the note to the

table).

9.26 With regard the former, a two-way access to a high traffic generator

almost inevitably needs sufficient width to accommodate an entry


42/48


2898637

lane, and separate right and left turning exit lanes. These lanes

cannot be accommodated within either a 6m or 7m crossing width.

Indeed a 6m crossing width is only just able to comfortably

accommodate both an entering and exiting vehicle, as illustrated

below.

9.27 While the two passing cars can be accommodated, it is tight. What

this means is that a crossing of this width will have only a limited

capacity to meet the demands of a high traffic generator.

9.28 If a crossing has inadequate capacity due to insufficient width, then it

substantially increases the potential for on-site and off-site congestion

and queuing, which in turn markedly decreases pedestrian safety and

amenity.

9.29 Rather, and as noted, a high traffic generator requires an crossing of

sufficient width to simultaneously accommodate an entering vehicle,

and separate left and right turning exiting vehicles. In order to

accommodate these turns, separate left turn and right turn exit lanes

are required, and hence a crossing width of around 9m is necessary to

accommodate all these manoeuvres.


43/48


2898637

9.30 This is illustrated in the diagram below. If a high traffic generator is

unable to separately provide for left and right turning exit manoeuvres,

severe on-site congestion is likely. This becomes even more relevant

if some form of access control becomes necessary to manage parking

within the site.

9.31 Further, the note to Table 15 which is intended to enable 9 m

crossings if large trucks are to be accommodated, is fine for small

trucks and / or one-way crossings. Larger vehicles, and/or crossings

intended to accommodate the two-way flow of trucks, will require

more. The diagram below shows the swept path requirements for an

11m single unit truck (larger delivery truck).


44/48


2898637

9.32 As can be seen, with this generic layout, at least a 10m width is

necessary to enable trucks to turn in and out. Wider crossings again

are necessary to accommodate articulated trucks. The point to be

made is that when designing for high traffic volumes or larger vehicles,

minimum standard dimensions are rarely going to produce the

optimum access solution.

9.33 Accordingly, we recommend some modifications to the table, firstly to

recognise the crossing capacity demands of high traffic generators

such as supermarkets, retail complexes, schools, etc ( where in

considering high traffic generators, we recommend reference to those

activities that trigger the trip generation thresholds in Table 1); and

secondly to recognise the swept path requirements of various truck

sizes.

9.34 For the former, we recommend that a third row be added within the

access width requirements for each of “Centres, Mixed Use and all

other zones not listed below”, and “General Busine

043 & 044 - Hrg - Key Retailers Group - Joint Transport Statement

Documents

Transcript of 043 & 044 - Hrg - Key Retailers Group - Joint Transport Statement