is a A - Auckland Council · Auckland Council Level 24, 135 Albert Street Private Bag 92300...

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submission on Private Plan Ghange 6 (Auranga Bl) to the Auckland unitary Plan To: The Chief Executive Attn: Planning Technician Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 u n itarvpla [email protected]. nz Name of submitter: submitter") 1. This is a submission on Private Plan Change 6 Auranga Bl - Drury West (PPC 6) to the partly operative Auckland Unitary Plan ("AUP"). 2. The submitter could not gain an advantage in trade competition through this submission. 3. The submitter has an interest in the PPC 6 as a whole, and as such this submission relates to the PPC 6 in its entirety. 4. The submitter is a landowner within Auranga A - the operative Drury 1 Precinct. 5. The submitter supports PPC6 in its entirety and seeks that it be approved as proposed. Reasons for submission : 6. ln summary, the submitter supports PPC 6 being approved in its current form on the basis that the PPC: (a) Will promote sustainable management of resources, achieve the purpose of the RMA and is not contrary to Part 2 and other provisions of the Resource Management Act 1991 ("RMA"). (b) Will enable the social, economic and cultural well-being of the community in the Auckland region. (c) Will meet the reasonably foreseeable needs of future generations. (d) Appropriately gives effect or has regard to all applicable higher order planning instruments, including the New Zealand Coastal Policy Statement and the Regional Policy Statement provisions of the AUP. lntroduction: #44 Page 1 of 4

Transcript of is a A - Auckland Council · Auckland Council Level 24, 135 Albert Street Private Bag 92300...

Page 1: is a A - Auckland Council · Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 u n itarvpla n@aucklandcouncil.oovt. nz Name of submitter: submitter") 1.

submission on Private Plan Ghange 6 (Auranga Bl) to the Auckland unitaryPlan

To: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel 24, 135 Albert StreetPrivate Bag 92300Auckland 1142u n itarvpla [email protected]. nz

Name of submitter: submitter")

1. This is a submission on Private Plan Change 6 Auranga Bl - Drury West (PPC6) to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

3. The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

4. The submitter is a landowner within Auranga A - the operative Drury 1

Precinct.

5. The submitter supports PPC6 in its entirety and seeks that it be approved asproposed.

Reasons for submission :

6. ln summary, the submitter supports PPC 6 being approved in its current formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purposeof the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ("RMA").

(b) Will enable the social, economic and cultural well-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations.

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

lntroduction:

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7.

8.

(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Council to in carrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPC6 provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enable the most integrated and efficient possible urban form betweenAuranga A and Auranga 81.

Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

A/eed for a consistent planning framework across Auranga A and 81

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and 81, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efficiencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and 81. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPCO area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupport.

(d) The economics of developing Drury West rely on the coordinatedplanning, funding and provision of new public trunk infrastructure. Toensure an equitable solution is achieved across all landowners, it isimperative that we each have equal opportunity to benefit from thatsubstantial expenditure. Planning outcomes that create a disincentive forPPC6 landowners to contribute, such as through different rules for PPC6that enable less efficient use of land, could result in unjustified down-stream development problems.

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Drury 1 Precinct provisions are superior to the default AUP provisions

9. ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPC6 land, ratherthan the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

(a) The Drury I Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly interms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) Together with other landowners in the Drury 1 Precinct, the submitterexpended considerable time and resources developing the Drury 1

Precinct provisions in consultation with neighbours, iwi, our Local Board,government agencies and the Council's staff. The result is an integratedpackage of provisions that specifically responds to the conditions in DruryWest and achieves an appropriate balance between design, amenity,development, Council and cultural priorities. lt is demonstrably moreappropriate to apply this planning framework to the PPC6 land ratherthan use the AUP's default (and generic) zone provisions.

(c) Using the Drury 1 precinct provisions will enable deliverable affordabilityto be built-in to the development within the PPCG area. For example, thesubdivisions and development within Auranga A have to date achievedover 15o/o affordable housing, considerably exceeding the 10% minimumthat other developments are unable to meet or the default position underthe AUP, which no longer requires the provision of affordable housing.

Additional provisions required regarding infrastructure funding

10. To support the development of Drury West, transformative infrastructure isbeing installed on a "best for Auckland" basis. To date, this has largely beenfunded by the Drury 1 Precinct landowners. The submitter therefore considersit is appropriate and necessary to include additional objectives, policies andother methods that apply to the PPC6 land and require infrastructure to befunded and implemented in an integrated, equitable and co-ordinated manner,as proposed by PPC6.

Summary

11. For the above reasons, overall the submitter supports PPCO being approved inits current form.

Relief sought:

12. The submitter seeks that PPC 6 be approved as proposed.

13. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

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(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, including its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPC6 as notified, in order toimplement the above.

14. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and suppo(ed by thePPC6 applicant, Karaka and Drury Limited.

Hearing:

15. The submitter wishes to be heard in support of its submission.

16. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

Signature

Date i|-.!t tT

Address of Auranga A land 1,*q

Title

PostalAddress

Phonenumber rl.rll<-97l( f -

c\p , tlr+iJLr.,ol l<-, <( .s)t;,i kJ 5F

e-mail ch'.rl.e ' 0 ,*^rrunIct -:,;s, '17'J-

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Submission on Private Plan Change 6 (Auranga Bl) to the Auckland UnitaryPlan

To: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel 24, 135 Albert StreetPrivate Bag 92300Auckland 1142u n itarvplan@aucklandcou ncil.qovt. nz

Name of submitt.r, l1;,,A,n t-hL.^ ("the submitter")

lntroduction:

1. This is a submission on Private Plan Change 6 Auranga Bl - Drury West (PPC6)to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

3. The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

4. The submitter is a landowner within Auranga A - the operative Drury 1

Precinct.

5, The submitter supports PPC6 in its entirety and seeks that it be approved asproposed.

Reasons for submission :

6. ln summary, the submitter supports PPC 6 being approved in its current formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purposeof the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ("RMA').

(b) Will enable the social, economic and cultural well-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations,

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

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7.

8.

(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Council to in carrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPC6 provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enable the most integrated and efficient possible urban form betweenAuranga A and Auranga B1.

Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

IVeed for a consistent planning framework across Auranga A and 81

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and Bl, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efficiencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and B1. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPCO area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupport.

(d) The economics of developing Drury west rely on the coordinatedplanning, funding and provision of new public trunk infrastructure. Toensure an equitable solution is achieved across all landowners, it isimperative that we each have equal opportunity to benefit from thatsubstantial expenditure. Planning outcomes that create a disincentive forPPC6 landowners to contribute, such as through different rules for PPC6that enable less efficient use of land, could result in unjustified down-stream development problems.

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Drury i Precinct provisions are superior to the default AUP provisions

9. ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPC6 land, rather

than the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

(a) The Drury 1 Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly in

terms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) Together with other landowners in the Drury 1 Precinct, the submitterexpended considerable time and resources developing the Drury 1

Precinct provisions in consultation with neighbours, iwi, our Local Board,government agencies and the Council's staff. The result is an integratedpackage of provisions that specifically responds to the conditions in DruryWest and achieves an appropriate balance between design, amenity,development, Council and cultural priorities. lt is demonstrably moreappropriate to apply this planning framework to the PPCO land ratherthan use the AUP's default (and generic) zone provisions.

(c) Using the Drury 1 precinct provisions will enable deliverable affordabilityto be built-in to the development within the PPC6 area. For example, thesubdivisions and development within Auranga A have to date achievedover 15o/o aflordable housing, considerably exceeding the 10% minimumthat other developments are unable to meet or the default position underthe AUP, which no longer requires the provision of affordable housing.

Additional provisions required regarding infrastructure funding

10. To support the development of Drury West, transformative infrastructure isbeing installed on a "best for Auckland" basis. To date, this has largely beenfunded by the Drury 1 Precinct landowners. The submitter therefore considersit is appropriate and necessary to include additional objectives, policies andother methods that apply to the PPC6 land and require infrastructure to befunded and implemented in an integrated, equitable and co-ordinated manner,as proposed by PPC6.

Summary

11. For the above reasons, overall the submitter supports PPC6 being approved inits current form.

Relief sought:

12. The submitter seeks that PPC 6 be approved as proposed.

13. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

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(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, including its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPC6 as notified, in order toimplement the above,

14. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and supported by thePPCO applicant, Karaka and Drury Limited.

Hearing:

15. The submitter wishes to be heard in support of its submission.

16. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

titte rL,*/h; . ,srel * l).u <'<-,+t**,v*)

Date l7-. ,t,,1

Address of Auranga A land ,horuol y'-r /.\

PostalAddress )?4? ,\,u -,-. i ','-..1 | 1a,.1. <I

phonenumber oz itfl A 6(-e-mail

.a

/,'

4

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Submission on Private Plan Change 6 (Auranga 81) to the Auckland UnitaryPlan

To: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel 24, 135 Albert StreetPrivate Bag 92300Auckland [email protected]

Name of submitt"r, l"'rl,,rrrl.i t sl",k (,,the subrnitter,,)

1. This is a submission on Private Plan Change 6 Auranga B1 - Drury West (PPC6) to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

3. The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

4. The submitter is a landowner within Auranga A - the operative Drury 1

Precinct.

5. The submitter supports PPC6 in its entirety and seeks that it be approved asproposed.

Reasons for submission:

6. ln summary, the submitter supports PPC 6 being approved in its current formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purposeof the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ("RMA").

(b) Will enable the social, economic and cultural well-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations.

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

lntroduction:

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7.

8.

(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Gouncil to in carrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPCO provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enable the most integrated and efficient possible urban form betweenAuranga A and Auranga 81.

Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

Need for a consistent planning framework across Auranga A and 81

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and 81, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efficiencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and 81. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPCO area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupporl.

(d) The economics of developing Drury West rely on the coordinatedplanning, funding and provision of new public trunk infrastructure. Toensure an equitable solution is achieved across all landowners, it isimperative that we each have equal opportunity to benefit from thatsubstantial expenditure. Planning outcomes that create a disincentive forPPC6 landowners to contribute, such as through different rules for PPC6that enable less efficient use of land, could result in unjustified down-stream development problems.

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Drury 1 Precinct provisions are superior to the default AUP provisions

9. ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPCO land, ratherthan the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

(a) The Drury 1 Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly interms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) Together with other landowners in the Drury 1 Precinct, the submitterexpended considerable time and resources developing the Drury 1

Precinct provisions in consultation with neighbours, iwi, our Local Board,government agencies and the Council's staff. The result is an integratedpackage of provisions that specifically responds to the conditions in DruryWest and achieves an appropriate balance between design, amenity,development, Council and cultural priorities. lt is demonstrably moreappropriate to apply this planning framework to the PPCG land ratherthan use the AUP's default (and generic) zone provisions.

(c) Using the Drury 1 precinct provisions will enable deliverable affordabilityto be builtin to the development within the PPC6 area. For example, thesubdivisions and development within Auranga A have to date achievedover 15% affordable housing, considerably exceeding the 10% minimumthat other developments are unable to meet or the default position underthe AUP, which no longer requires the provision of affordable housing.

Ad d itio n a I p rov i s io n s req u i red reg a rd i n g i nfra stru ctu re f u n d i n g

10. To support the development of Drury West, transformative infrastructure isbeing installed on a "best for Auckland" basis. To date, this has largely beenfunded by the Drury 1 Precinct landowners. The submitter therefore considersit is appropriate and necessary to include additional objectives, policies andother methods that apply to the PPC6 land and require infrastructure to befunded and implemented in an integrated, equitable and co-ordinated manner,as proposed by PPC6.

Summary

11. For the above reasons, overall the submitter supports PPC6 being approved inits current form.

Relief sought:

12. The submitter seeks that PPC 6 be approved as proposed.

13. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

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(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, including its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPC6 as notified, in order toimplement the above.

14. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and supported by thePPCO applicant, Karaka and Drury Limited.

Hearing:

15. The submitter wishes to be heard in support of its submission.

16. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

Name

Title

C 2 rt ti4i (.7,na

Date ,1 tl ,:l!,

Address of Auranga A land 5S-O . Wrv,r*r-,. F-l , lln*.k"

PostalAddress b*l tt , S | ',f-, u+lr*l t-r* . ,1+di,r/

Phone number

e-mail

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Submission on Private Plan Change 6 (Auranga Bl) to the Auckland UnitaryPlan

To: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel24, 135 Albert StreetPrivate Bag 92300Auckland [email protected]

Name of submift "r, & cH n a JE f4.q t Z / ,fros r("the submitted')

Introduction:

1. This is a submission on Private Plan Change 6 Auranga B1 - Drury West (PPC6) to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

3. The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

4. The submitter is a landownerwithin Auranga 81.

5. The submitter supports PPCO in its entirety and seeks that it be approved asproposed.

Reasons for eubmission:

6. ln summary, the submitter supports PPC 6 being approved in its cunent formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purpose

of the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ('RMA").

(b) Will enable the social, economic and cultural well-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations.

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

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(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Council to in earrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPC6 provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enab,le the most integrated and efficient possible urban form betweenAuranga A and Auranga 81.

7. Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

Aleed for a consistent planning framework across Auranga A and Bi

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and B1, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efiiciencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and 81. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPC6 area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupport.

(d) The economics of developing Drury West rely on the coordinatedplanning, funding and provision of new public trunk infrastructure" Toensure an equitable solution is achieved across all landowners.

Drury 7 Precinct provislons are superior to the default AUP provisions

ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPC6 land, ratherthan the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

9.

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(a) The Drury 1 Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly interms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) The developers have expended considerable time and resourcesdeveloping the Drury 1 Precinct provisions in consultation withneighbours, iwi, our Local Board, govemment agencies and the Council'sstaff. The result is an integrated package of provisions that specificallyresponds to the conditions in Drury West and achieves an appropriatebalance between design, amenity, development, Council and cutturalpriorities. lt is demonstrably more appropriate to apply this planningframework to the PPCG land rather than use the AUP's default (andgeneric)-zone provisions.

$ummary

10. For the above reasons, overall the submitter supports PPCG being approved inits current form.

Relief sought:

11. The submitter seeks that PPC 6 be approved as proposed.

12. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, ihcluding its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPCG as notified, in order toimplement the above.

13. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and supported by thePPCG applicant, Karaka and Drury Limited.

Hearing:

14. The submitter wishes to be heard in support of its submission.

15. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

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Signature

4g**A

Name Co c n,Qrt^,,f fArmtz ? ,TrzvS frr,,

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o,r" rzf,r/..,,7--/0O/ /2ot /40r t6o {rstvtor\''b RoaP

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PostalAddress 74 0raa Ro*>, ,lZ.D-2.bauo7 2Szt

Phonenumber 07 27Lz2Loe-mail qao/tZ 0 acfrtt- co, ntz

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Page 17: is a A - Auckland Council · Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 u n itarvpla n@aucklandcouncil.oovt. nz Name of submitter: submitter") 1.

Submission on Private Plan Ghange 6 (Auranga B1) to the Auckland UnitaryPlan

lo: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel 24, 1 35 Albert StreetPrivate Bag 92300Auckland [email protected]

Name of submitte,,: 4 , /{ ,, Gcttr*nnte {Sr*rF ('the submiftef)

lntroduction:

1. This is a submission on Private Plan Change 6 Auranga 81 - Drury West (PPC6) to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

3. The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

4. The submitter is a landowner within Auranga 81.

5. The submitter supports PPCO in its entirety and seeks that it be approved asproposed,

Reasons for submission:

6. ln summary, the submitter supports PPC 6 being approved in its current formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purposeof the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ("RMA').

(b) Will enable the social, economic and culturalwell-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations.

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

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(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Council to in earrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPC6 provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enab,le the most integrated and efficient possible urban form betweenAuranga A and Auranga 81.

7. Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

Aleed for a consistent planning framework across Auranga A and Bi

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and B1, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efiiciencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and 81. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPC6 area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupport.

(d) The economics of developing Drury West rely on the coordinatedplanning, funding and provision of new public trunk infrastructure" Toensure an equitable solution is achieved across all landowners.

Drury 7 Precinct provislons are superior to the default AUP provisions

ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPC6 land, ratherthan the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

9.

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(a) The Drury 1 Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly interms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) The developers have expended considerable time and resourcesdeveloping the Drury 1 Precinct provisions in consultation withneighbours, iwi, our Local Board, govemment agencies and the Council'sstaff. The result is an integrated package of provisions that specificallyresponds to the conditions in Drury West and achieves an appropriatebalance between design, amenity, development, Council and cutturalpriorities. lt is demonstrably more appropriate to apply this planningframework to the PPCG land rather than use the AUP's default (andgeneric)-zone provisions.

$ummary

10. For the above reasons, overall the submitter supports PPCG being approved inits current form.

Relief sought:

11. The submitter seeks that PPC 6 be approved as proposed.

12. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, ihcluding its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPCG as notified, in order toimplement the above.

13. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and supported by thePPCG applicant, Karaka and Drury Limited.

Hearing:

14. The submitter wishes to be heard in support of its submission.

15. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

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Signature

1-r./-/-'Name 4, k _ C"c //Ra,rE fszrerr

,u,rn ru,t 4: s,/9 zy t i,l +z K/.{g? t/n *ss/r33 , ,n< +ss/s<+

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n , *Z Orrzn KoiD.Address of Auranga B land 323, 322 /{orzaza EoA >

7q /trz,q (oep ,?.O,2. DarnT 2{7trPostalAddress

phonenumber 07 2q*2Zdoe-mail q a o/r e" d "

c/t 4'r_ , ea .-r,/ z

#48

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Page 21: is a A - Auckland Council · Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 u n itarvpla n@aucklandcouncil.oovt. nz Name of submitter: submitter") 1.

Submission on Private Plan Ghange 6 (Auranga Bl) to the Auckland UnitaryPIan

3.

lo: The Chief Executive

Attn: Planning TechnicianAuckland CouncilLevel 24, 1 35 Albert StreetPrivate Bag 92300Auckland 1142unitarvplan@aucklandcouncil. govt.nz

Name of submitter: submittef')

lntroduction:

1. This is a submission on Private Plan Change 6 Auranga 81 - Drury West (PPC6) to the partly operative Auckland Unitary Plan ("AUP").

2. The submitter could not gain an advantage in trade competition through thissubmission.

The submitter has an interest in the PPC 6 as a whole, and as such thissubmission relates to the PPC 6 in its entirety.

The submitter is a landowner within Auranga 81.

The submitter supports PPC6 in its entirety and seeks that it be approved asproposed.

Reasons for submission:

6. ln summary, the submitter supports PPC 6 being approved in its cunent formon the basis that the PPC:

(a) Will promote sustainable management of resources, achieve the purposeof the RMA and is not contrary to Part 2 and other provisions of theResource Management Act 1991 ('RMA").

(b) Will enable the social, economic and culturalwell-being of the communityin the Auckland region.

(c) Will meet the reasonably foreseeable needs of future generations.

(d) Appropriately gives effect or has regard to all applicable higher orderplanning instruments, including the New Zealand Coastal PolicyStatement and the Regional Policy Statement provisions of the AUP.

4.

5.

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(e) ls not inconsistent with any directive policies or constraints from suchhigher order planning instruments.

(f) Accords with and will assist the Council to in earrying out its functionsunder the RMA, having regard to the efficiency and effectiveness of thePPC6 provisions relative to other means.

(g) ls necessary to achieve the relevant objectives and implement thepolicies of the AUP district and regional plans.

(h) ls based on a suite of planning provisions that have been developed androbustly tested through a public process and which are superior and moreappropriate than the more generic city-wide alternatives within the AUP.

(i) Will enab,le the most integrated and efficient possible urban form betweenAuranga A and Auranga 81.

7. Without limiting the generality of the foregoing, the submitter's grounds forsupporting PPC 6 are as follows.

Aleed for a consistent planning framework across Auranga A and Bi

The submitter considers that there should be a consistent planning frameworkacross both Auranga A and B1, as proposed by PPC6. This will result in anumber of benefits (or avoid creating a range of issues), as follows:

(a) lt would create significant procedural and administrative efiiciencies tohave the same planning provisions applying to the Auranga A and 81areas.

(b) lt is imperative that an integrated, continuous, and coherent developmentoutcome is achieved across Auranga A and 81. This requires that bothareas be subject to the same planning provisions.

(c) The master plan work undertaken by the developer to date has identifiednumerous opportunities to integrate development across the boundariesof the Drury 1 Precinct and the PPC6 area. Having a single planningframework for both areas will allow these opportunities to be realised anda coherent and seamless urban form to eventuate. By contrast, havingdifferent planning provisions applying to each area will result in bothprecinct edges becoming "hard boundaries", which the submitter does notsupport.

(d) The economics of developing Drury West rely on the coordinatedplanning, funding and provision of new public trunk infrastructure" Toensure an equitable solution is achieved across all landowners.

Drury 7 Precinct provislons are superior to the default AUP provisions

ln addition to achieving a consistent planning framework, the submitterconsiders that applying the Drury 1 Precinct provisions to the PPC6 land, ratherthan the AUP's default zone provisions, as proposed by the PPC is appropriatefor the following reasons:

9.

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(a) The Drury 1 Precinct provisions have been specifically developed toensure they result in an exceptional community outcome, particularly interms of urban design, which is far superior to what could be achievedusing the AUP's default zone provisions and is more consistent with thedeveloper's vision and objectives for Drury West.

(b) The developers have expended considerable time and resourcesdeveloping the Drury 1 Precinct provisions in consultation withneighbours, iwi, our Local Board, govemment agencies and the Council'sstaff. The result is an integrated package of provisions that specificallyresponds to the conditions in Drury West and achieves an appropriatebalance between design, amenity, development, Council and cutturalpriorities. lt is demonstrably more appropriate to apply this planningframework to the PPCG land rather than use the AUP's default (andgeneric)-zone provisions.

$ummary

10. For the above reasons, overall the submitter supports PPCG being approved inits current form.

Relief sought:

11. The submitter seeks that PPC 6 be approved as proposed.

12. For the avoidance of doubt, the submitter supports and seeks the retention of:

(a) The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

(b) The notified Precinct Plan 2.

(c) The use of the Drury 1 Precinct and the application of those Precinctprovisions to the area of PPC 6, ihcluding its integrated subdivision,urban design, bulk and location rules package, and includingrequirements for affordable housing.

(d) The changes to the Drury 1 Precinct provisions (explanation, objectives,policies, rules and criteria) as included in PPCG as notified, in order toimplement the above.

13. The submitter does not support any changes being made to the PPC 6 asproposed, except where those changes are agreed to and supported by thePPCG applicant, Karaka and Drury Limited.

Hearing:

14. The submitter wishes to be heard in support of its submission.

15. lf others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

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Signature

4,/,/d^^Name 4 ,r"t , AC//RA*/E GuS,

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1

Submission on Private Plan Change 6 (Auranga

B1) to the Auckland Unitary Plan

To: The Chief Executive

Attn: Planning Technician Auckland Council Level 24, 135 Albert Street Private Bag 92300 Auckland 1142 [email protected]

Name of submitter: Ngati Te Ata (Te Ara Rangatu) Po Box 437 Pukekohe 2340 Attn: Karl Flavell

Introduction: 1. This is a submission on Private Plan Change 6 Auranga B1 – Drury West

(PPC 6) to the Auckland Unitary Plan (AUP). 2. The submitter could not gain an advantage in trade competition through this

submission. 3. The submitter has an interest in the PPC 6 as a whole, and as such this

submission relates to the PPC 6 in its entirety. 4. The interest and values of Ngati Te Ata are identified in the Cultural Impact

Assessment (CIA) included in the PPC 6 application as Attachment 18. These should be read in conjunction with this submission.

5. The pre-notification assessment and review (Addendum CIA) by Ngati Te

Ata Waiohua, Te Akitai Waiohua and Ngati Tamaoho is included in the section “Post lodgement iwi consultation” of the PPC 6 documents. This was provided to Council prior to the notification of the PPC 6 application, and consequently forms the basis of this submission on PPC 6. It relies upon the CIA in respect to the values of the area, the subject land and the Drury 1 Precinct.

Submission:

6. Ngati Te Ata submits in support of PPC 6. The submitter seeks that PPC 6

be approved as proposed. The submitter does not support any changes to the PPC 6 policy and rules framework that is, in the submitters’ view, superior to the default zones of the AUP.

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7. Our support is on the condition that our expectations are provided for regarding;

i. Section 6[e] of the Resource Management Act requires that consent authorities shall recognise and provide for “the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, Waahi tapu, and other Taonga as a matter of national importance.”

ii. Section 6[f] of the Resource Management Act requires that consent authorities shall recognise and provide for “the protection of historic heritage from inappropriate subdivision, use, and development.”

iii. Section 7[a] of the Resource Management Act requires that consent authorities shall have regard to kaitiakitanga, Kaitiakitanga means the exercise of guardianship and in relation to a resource includes the ethic of stewardship based on the nature of the resource itself.

iv. Section 8 of the Resource Management Act states that theprinciples of the Treaty of Waitangi shall be taken into account. Aset of principles have emerged over the years and emphasisedtribal rangatiratanga, the active protection of Maori people in theuse of their lands, waters and other taonga, and the duty to consultwith Maori.

8. With regard to PPC 6 and its potential impact on taonga, three key factors need to be assured:

i. that the mana of iwi is upheld, acknowledged and respected.

ii. that iwi assert and exercise (their) rangatiratanga over ancestral taonga.

iii. that as kaitiaki iwi fulfil (their) obligations and responsibilities to our people (and future generations) as custodians, protectors and guardians of the tribes interests, its taonga and the various resources it inherently owns.

9. The key matters identified in the CIA and addendum CIA relevant to PPC 6 are:

i. PPC 6 requires park edge roads to the esplanade and neighbourhood reserves.

ii. PPC 6 requires the planting of the riparian margins of the streams.

iii. PPC 6 require stormwater retention, detention and quality measures in accordance with the low impact design approach and the Stormwater Management Plan (SMP).

iv. The SMP for PPC 6 be based on the same agreed outcomes fromthe Bremner Road Special Housing Area (SHA) SMP and utilisesthe same agreed best practice approaches.

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v. Precinct Plan 2 should establish a perimeter of Mixed Housing Suburban Zone and a park edge road around the coast.

vi. The Drury 1 Precinct provisions should apply to the PPC 6 area.

vii. The agreed approaches contained in the Drury 1 Precinct shouldnot be altered.

viii. The concept of directing offsets, where required, to the Drury CreekIslands Recreation Reserve should be encouraged.

10. The extensive consultation between the submitter and the applicant isoutlined in the Addendum CIA. This consultation has ensured that the manaof iwi is upheld, acknowledged and respected. Through this consultation theapplicant has provided assurances to iwi as follows:

i. The extension identified by PPC 6 would utilise the existing Drury 1 Precinct policies and rules, which include matters important to iwi and the CIA recommendations on the Bremner Road SHA.

ii. The matters identified above are addressed in PPC 6 through Precinct Plan 2 and the utilisation of the Drury 1 Precinct provisions.

11. The submitter met with Council officers on 19 July 2017. It is understoodthat Council officers may not be supportive of the continued use of the Drury1 Precinct provisions, with matters defaulting in the Auranga B1 area to theAuckland-wide provisions of the AUP. Having considered the relevantmatters, and the important (and superior) rules reflected in the Drury 1Precinct compared to the default AUP provisions, the submitter opposeswhat it understands may be the Council officers’ approach and supports theuse of the Drury 1 Precinct provisions by PPC 6. The submitter contendsthat there is no basis within the AUP or RMA that could justify Councilofficers seeking to re-work the PPC6 Precinct provisions based on their ownpreferences given that the Drury 1 Precinct is of itself a fully operative part ofthe AUP and has been found to be appropriate in resource managementterms.

12. The Drury 1 Precinct and its provisions reflect extensive consultationbetween the applicant and iwi. The Drury 1 Precinct is a significant stepforward in resource management compared with the default AUP zones andzone rules. Losing key provisions by not adopting the Drury 1 Precinct as anintegrated whole would significantly impact on matters of interest to iwi.Examples of these, to illustrate the matters raised in the submission, areoutlined below.

i. Rule 6.2 – the submitter supports the use of the Precinct rules that result in rear lots being non-complying activities. The approach of ensuring that buildings front public spaces and roads, rather than turning their backs on them, is important to developing a high quality community. The submitter understands that no equivalent rule exists in the AUP, and that far from discouraging rear lots, the default AUP would allow rear lots. That would be an inferior outcome.

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ii. Rule 6.3 – The submitter supports the Precinct’s movement

network rule which requires the establishment of pedestrian and cyclist oriented road and block networks that are well connected. The submitter considers urban design to be important to the development of this community, and the Precinct rules create a grid style urban block network. The submitter supports the non-complying activity status for cul-de-sacs, and the Precinct road cross sections that include dedicated cycle lanes and wide pedestrian footpaths. The submitter understands that no equivalent rule exists in the AUP, and that far from discouraging cul-de-sacs, the default AUP would allow these. That would be an inferior outcome.

iii. Rule 6.4 – a fundamental issue to iwi is the establishment of park

edge roads to reserves, and in particular the esplanade reserve along the coast, which is a requirement of this existing Precinct rule. Iwi maintain concerns that the default AUP allows the privatisation of reserves because houses and lots are allowed to back onto these. The Precinct’s park edge road rule ensures that public access to the coast and reserves is maintained, that buildings are separated from the coast by the park edge road and that reserves are not spaces left over behind housing, but rather key features and amenity for the community. The Drury 1 Precinct rule is in the submitters’ view superior to the AUP’s approach.

iv. Rule 6.5 (and rules 4.12 and 5.12) – The submitter supports the

existing Precinct rule which prevents vehicle access over the dedicated cycle lanes and 3m shared paths. Designing for safety is an important consideration to the submitter. The current AUP does not address this issue and again the Drury 1 Precinct provisions are superior.

v. Rule 6.6 – the restoration of riparian margins of streams is a key

recommendation of the CIAs. The area’s streams have been degraded by farming activities, and their replanting with subdivision is important. Again, this existing Precinct rule has no equivalent rule in the default AUP and therefore represents a superior approach to implement the issues raised in the submitters’ CIAs.

vi. Rules 3 and 6.7 – The submitter strongly supports the Precinct’s

rule for stormwater management. As background, Iwi invested considerable effort in the review of the Stormwater Management Plan (including its recommendations on the best options to address a treatment train, onsite stormwater detention, raingardens and green outfalls). The rule and the submitter’s input to the SMP is important as it is specifically tailored to this catchment and the values of the stream networks and the Drury Creek. Iwi would oppose Council discontinuing the agreed approach in the PPC 6 area and consider that the existing Drury 1 Precinct reflects a superior approach to these matters than defaulting to the AUP’s generic “one size fits all” approach.

vii. Rules 2.2 and 6.8 – the submitter supports the applicant’s proposal

to continue to require affordable housing in the Auranga B1 area

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through the extension of the Drury 1 Precinct to the additional area. Affordable housing is an important issue for the community, and the contribution that this rule can provide (at least 130 affordable houses) is considerably superior than the default position of the AUP which does not require any affordable housing.

viii. Urban design rules – the submitter supports the applicant’sproposal to utilise the Drury 1 Precinct rules because these containmany urban design based rules which Council, mistakenly in thesubmitters’ view, deleted from the decisions version of the AUP.The rules assist in ensuring that houses do not turn their backs onthe street. These include: requiring 50% of the front yard to belandscaped; requiring dwelling to have their front doors andminimum glazing standards facing the street; dwellings having low1.2m front fences; garages having maximum sizes and be setbackfrom the street so they do not dominant the street. The submitterrecognises that these are part of the overall Precinct’s integratedpackage of rules, and consequently would oppose any changes tothe approach proposed by PPC 6. The submitter is comfortable andsupportive of the applicant seeking to have superior urban designstandards applying to the Precinct than are contained in the defaultAUP.

13. In respect to the proposed Precinct Plan 2 (dated 6 July 2017 and includedin the applicant’s clause 23 responses), the submitter’s comments are asfollows:

i. The Precinct Plan illustrates the location of the streams identified in the RMA Ecology Report. The identification of streams on the maps is important and supported.

ii. The Precinct Plan illustrates a continuous park edge road to the Esplanade Reserve and coast. This is critical and the link to rule 6.4 of the Drury 1 Precinct is important.

iii. The provisions of a suburban and neighbourhood park in the Precinct is important, and again the link to rule 6.4 of the Drury 1 Precinct is important.

iv. The Precinct Plan illustrates an ecological corridor and park edgeroads up the main stream (stream A) and this is important.

v. The Precinct Plan identifies the requirement to vest the missing 20m of esplanade reserve along the coast (321 Bremner Road). This is the only part of the esplanade reserve network that is missing and this is important.

vi. In the Drury 1 Precinct the submitter sought that the area adjoiningthe esplanade reserve along the coast was zoned Mixed HousingSuburban to have a graduation of density in proximity to the coast.The submitter acknowledges that this is reflected in PPC 6 and thisis supported. However, this support is qualified on the basis that thepark edge road must be delivered along the edge of the esplanadereserve to separate housing from the coast and ensure public

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access. It is noted that only the Drury 1 Precinct rules would provide this certainty to the submitter.

14. The submitter supports notified Precinct Plan 2. The submitter opposes anychange to the Precinct Plan.

15. The submitter supports the use of the Drury 1 Precinct provisions in the PPC6 area. The submitter does not want matters agreed in the Bremner RoadSHA (existing Drury 1 Precinct) to be relitigated by the Council’s officers inPPC 6. The submitters expended considerable time and resources inconsultation on this project, and consider that its CIA recommendations arebetter served by the applicant’s Precinct provisions as proposed whencompared with the default AUP. Related to this, the submitters consider thatit would create significant inefficiencies and other administrativedisconnections to create a new Precinct distinct from the Drury 1 Precinctthat was worded and constructed differently to the Drury 1 Precinct. Thesubmitters consider that it is imperative that the most integrated, continuous,and coherent development outcome across the existing and proposedPrecinct areas be achieved and that to do this a single set of Precinctprovisions should be relied on.

16. In terms of the proposed offset policy (14) supporting the Drury CreekIslands Recreation Reserve, while effects should be avoided in the firstinstance, where offsets are required for unavoidable adverse effects thenthe submitter does prefer that these are directed to the Drury Creek IslandsRecreation Reserve to restore its conservation and intrinsic values. TheIslands are currently grazed and this is contributing to their degradation. Thesubmitter has reviewed Dr Ussher’s rationale for restoring the islands andconsiders it to be appropriate. The submitter always seeks that developersdo more than the minimum, and in this case the islands potentially representa transformative and exemplar opportunity to achieve this.

17. The submitter looks forward to working with Auranga and the Department ofConservation on the restoration plan for the islands. In saying this thesubmitter reaffirms its position that the Drury Creek Islands RecreationReserve should be reclassified by the Department of Conservation in amanner which prohibits commercial activity.

18. Overall the submitter is supportive of the private plan change provided that itis approved as notified.

Relief:

19. The submitter seeks that PPC 6 be approved as proposed.

20. For the avoidance of doubt, the submitter supports and seeks the retentionof:

i. The extent of the notified Mixed Housing Urban and Mixed Housing Suburban Zones.

ii. The notified Precinct Plan 2.

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iii. The use of the Drury 1 Precinct and its application to the area of PPC 6 including its integrated subdivision, urban design, bulk and location rules package.

iv. The notified amendments to the Drury 1 Precinct provisions(explanation, objectives, policies, rules and criteria) to implementthe above.

21. The submitter does not support changes to the notified PPC 6.

General reasons for relief:

22. The submitter considers that PPC 6:

a. will promote sustainable management of resources, achieve the purpose of the RMA and is not contrary to Part 2 and other provisions of the RMA.

b. will enable the social, economic and cultural well-being of the community in the Auckland region.

c. will meet the reasonably foreseeable needs of future generations.

d. represents the most appropriate means of exercising the Council's functions, having regard to the efficiency and effectiveness of the provisions relative to other means.

23. In the submitter’s opinion PPC 6 has more cultural and environmentalbenefits to iwi than can be currently gained under the default AUP.

24. The submitter and PPC 6 requester have spent considerable effort in findingmiddle ground in respect to Auranga A and B. The negotiations that led tothese cultural and environmental outcomes have been extensive, and on thebasis of a progressive and collaborative approach.

Hearing:

25. The submitter wishes to be heard in support of its submission.

26. If others make a similar submission, the submitter will consider presenting ajoint case with them at any hearing.

Dated: 23rd November 2017 Signature:

Karl Flavell Manager Environment/Heritage Ngati Te Ata

Po Box 437 Pukekohe 2340 Email: [email protected]

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Submission on Private Plan Change 6 (Auranga B1) to the Auckland Unitary Plan

Name of submitter:Te Akitai Waiohua Waka Taua Incorporated Introduction: 1. This is a submission on Private Plan Change 6 Auranga B1 – Drury West

(PPC 6) to the Auckland Unitary Plan (AUP). 2. The submitter could not gain an advantage in trade competition through this

submission. 3. The submitter has an interest in the PPC 6 as a whole, and as such this

submission relates to the PPC 6 in its entirety. 4. The interest and values of Te Akitai Waiohua are identified in the Cultural

Impact Assessment (CIA) included in the PPC 6 application as Attachment 18. These should be read in conjunction with this submission.

5. The pre-notification assessment and review (Addendum CIA) by Te Akitai

Waiohua is included in the section “Post lodgement iwi consultation” of the PPC 6 documents. This was provided to Council prior to the notification of the PPC 6 application, and consequently forms the basis of this submission on PPC 6. It relies upon the CIA in respect to the values of the area, the subject land and the Drury 1 Precinct.

Submission: 6. Te Akitai Waiohua submits “Not Opposed” to PPC 6. The submitter seeks

that PPC 6 be approved as proposed. The submitter does not support any changes to the PPC 6 policy and rules framework that is, in the submitters’ view, superior to the default zones of the AUP.

7. Our “Not Opposed” is on the condition that our expectations are provided for

regarding;

i. Section 6[e] of the Resource Management Act requires that consent authorities shall recognise and provide for “the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, Waahi tapu, and other Taonga as a matter of national importance.”

ii. Section 6[f] of the Resource Management Act requires that consent

authorities shall recognise and provide for “the protection of historic heritage from inappropriate subdivision, use, and development.”

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iii. Section 7[a] of the Resource Management Act requires that consent authorities shall have regard to kaitiakitanga, Kaitiakitanga means the exercise of guardianship and in relation to a resource includes the ethic of stewardship based on the nature of the resource itself.

iv. Section 8 of the Resource Management Act states that the

principles of the Treaty of Waitangi shall be taken into account. A set of principles have emerged over the years and emphasised tribal rangatiratanga, the active protection of Maori people in the use of their lands, waters and other taonga, and the duty to consult with Maori.

8. With regard to PPC 6 and its potential impact on taonga, three key factors

need to be assured:

i. that the mana of iwi is upheld, acknowledged and respected. ii. that iwi assert and exercise (their) rangatiratanga over ancestral

taonga. iii. that as kaitiaki iwi fulfil (their) obligations and responsibilities to our

people (and future generations) as custodians, protectors and guardians of the tribes interests, its taonga and the various resources it inherently owns.

9. The key matters identified in the CIA and addendum CIA relevant to PPC 6

are:

i. PPC 6 requires park edge roads to the esplanade and neighbourhood reserves.

ii. PPC 6 requires the planting of the riparian margins of the streams. iii. PPC 6 require stormwater retention, detention and quality

measures in accordance with the low impact design approach and the Stormwater Management Plan (SMP).

iv. The SMP for PPC 6 be based on the same agreed outcomes from

the Bremner Road Special Housing Area (SHA) SMP and utilises the same agreed best practice approaches.

v. Precinct Plan 2 should establish a perimeter of Mixed Housing

Suburban Zone and a park edge road around the coast. vi. The Drury 1 Precinct provisions should apply to the PPC 6 area.

vii. The agreed approaches contained in the Drury 1 Precinct should

not be altered. viii. The concept of directing offsets, where required, to the Drury Creek

Islands Recreation Reserve should be encouraged. 10. The extensive consultation between the submitter and the applicant is

outlined in the Addendum CIA. This consultation has ensured that the mana

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of iwi is upheld, acknowledged and respected. Through this consultation the applicant has provided assurances to iwi as follows:

i. The extension identified by PPC 6 would utilise the existing Drury 1

Precinct policies and rules, which include matters important to iwi and the CIA recommendations on the Bremner Road SHA.

ii. The matters identified above are addressed in PPC 6 through

Precinct Plan 2 and the utilisation of the Drury 1 Precinct provisions.

11. The submitter met with Council officers on 19 July 2017. It is understood

that Council officers may not be supportive of the continued use of the Drury 1 Precinct provisions, with matters defaulting in the Auranga B1 area to the Auckland-wide provisions of the AUP. Having considered the relevant matters, and the important (and superior) rules reflected in the Drury 1 Precinct compared to the default AUP provisions, the submitter opposes what it understands may be the Council officers’ approach and supports the use of the Drury 1 Precinct provisions by PPC 6. The submitter contends that there is no basis within the AUP or RMA that could justify Council officers seeking to re-work the PPC6 Precinct provisions based on their own preferences given that the Drury 1 Precinct is of itself a fully operative part of the AUP and has been found to be appropriate in resource management terms.

12. The Drury 1 Precinct and its provisions reflect extensive consultation between the applicant and iwi. The Drury 1 Precinct is a significant step forward in resource management compared with the default AUP zones and zone rules. Losing key provisions by not adopting the Drury 1 Precinct as an integrated whole would significantly impact on matters of interest to iwi. Examples of these, to illustrate the matters raised in the submission, are outlined below.

i. Rule 6.2 – the submitter supports the use of the Precinct rules that

result in rear lots being non-complying activities. The approach of ensuring that buildings front public spaces and roads, rather than turning their backs on them, is important to developing a high quality community. The submitter understands that no equivalent rule exists in the AUP, and that far from discouraging rear lots, the default AUP would allow rear lots. That would be an inferior outcome.

ii. Rule 6.3 – The submitter supports the Precinct’s movement

network rule which requires the establishment of pedestrian and cyclist oriented road and block networks that are well connected. The submitter considers urban design to be important to the development of this community, and the Precinct rules create a grid style urban block network. The submitter supports the non-complying activity status for cul-de-sacs, and the Precinct road cross sections that include dedicated cycle lanes and wide pedestrian footpaths. The submitter understands that no equivalent rule exists in the AUP, and that far from discouraging cul-de-sacs, the default AUP would allow these. That would be an inferior outcome.

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iii. Rule 6.4 – a fundamental issue to iwi is the establishment of park edge roads to reserves, and in particular the esplanade reserve along the coast, which is a requirement of this existing Precinct rule. Iwi maintain concerns that the default AUP allows the privatisation of reserves because houses and lots are allowed to back onto these. The Precinct’s park edge road rule ensures that public access to the coast and reserves is maintained, that buildings are separated from the coast by the park edge road and that reserves are not spaces left over behind housing, but rather key features and amenity for the community. The Drury 1 Precinct rule is in the submitters’ view superior to the AUP’s approach.

iv. Rule 6.5 (and rules 4.12 and 5.12) – The submitter supports the

existing Precinct rule which prevents vehicle access over the dedicated cycle lanes and 3m shared paths. Designing for safety is an important consideration to the submitter. The current AUP does not address this issue and again the Drury 1 Precinct provisions are superior.

v. Rule 6.6 – the restoration of riparian margins of streams is a key

recommendation of the CIAs. The area’s streams have been degraded by farming activities, and their replanting with subdivision is important. Again, this existing Precinct rule has no equivalent rule in the default AUP and therefore represents a superior approach to implement the issues raised in the submitters’ CIAs.

vi. Rules 3 and 6.7 – The submitter strongly supports the Precinct’s

rule for stormwater management. As background, Iwi invested considerable effort in the review of the Stormwater Management Plan (including its recommendations on the best options to address a treatment train, onsite stormwater detention, raingardens and green outfalls). The rule and the submitter’s input to the SMP is important as it is specifically tailored to this catchment and the values of the stream networks and the Drury Creek. Iwi would oppose Council discontinuing the agreed approach in the PPC 6 area and consider that the existing Drury 1 Precinct reflects a superior approach to these matters than defaulting to the AUP’s generic “one size fits all” approach.

vii. Rules 2.2 and 6.8 – the submitter supports the applicant’s proposal

to continue to require affordable housing in the Auranga B1 area through the extension of the Drury 1 Precinct to the additional area. Affordable housing is an important issue for the community, and the contribution that this rule can provide (at least 130 affordable houses) is considerably superior than the default position of the AUP which does not require any affordable housing.

viii. Urban design rules – the submitter supports the applicant’s

proposal to utilise the Drury 1 Precinct rules because these contain many urban design based rules which Council, mistakenly in the submitters’ view, deleted from the decisions version of the AUP. The rules assist in ensuring that houses do not turn their backs on the street. These include: requiring 50% of the front yard to be landscaped; requiring dwelling to have their front doors and minimum glazing standards facing the street; dwellings having low

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1.2m front fences; garages having maximum sizes and be setback from the street so they do not dominant the street. The submitter recognises that these are part of the overall Precinct’s integrated package of rules, and consequently would oppose any changes to the approach proposed by PPC 6. The submitter is comfortable and supportive of the applicant seeking to have superior urban design standards applying to the Precinct than are contained in the default AUP.

13. In respect to the proposed Precinct Plan 2 (dated 6 July 2017 and included

in the applicant’s clause 23 responses), the submitter’s comments are as follows:

i. The Precinct Plan illustrates the location of the streams identified in

the RMA Ecology Report. The identification of streams on the maps is important and supported.

ii. The Precinct Plan illustrates a continuous park edge road to the

Esplanade Reserve and coast. This is critical and the link to rule 6.4 of the Drury 1 Precinct is important.

iii. The provisions of a suburban and neighbourhood park in the

Precinct is important, and again the link to rule 6.4 of the Drury 1 Precinct is important.

iv. The Precinct Plan illustrates an ecological corridor and park edge

roads up the main stream (stream A) and this is important. v. The Precinct Plan identifies the requirement to vest the missing

20m of esplanade reserve along the coast (321 Bremner Road). This is the only part of the esplanade reserve network that is missing and this is important.

vi. In the Drury 1 Precinct the submitter sought that the area adjoining

the esplanade reserve along the coast was zoned Mixed Housing Suburban to have a graduation of density in proximity to the coast. The submitter acknowledges that this is reflected in PPC 6 and this is supported. However, this support is qualified on the basis that the park edge road must be delivered along the edge of the esplanade reserve to separate housing from the coast and ensure public access. It is noted that only the Drury 1 Precinct rules would provide this certainty to the submitter.

14. The submitter is not opposed to the notified Precinct Plan 2. The submitter

opposes any change to the Precinct Plan.

15. The submitter is not opposed to the use of the Drury 1 Precinct provisions in the PPC 6 area. The submitter does not want matters agreed in the Bremner Road SHA (existing Drury 1 Precinct) to be relitigated by the Council’s officers in PPC 6. The submitters expended considerable time and resources in consultation on this project, and consider that its CIA recommendations are better served by the applicant’s Precinct provisions as proposed when compared with the default AUP. Related to this, the submitters consider that it would create significant inefficiencies and other administrative disconnections to create a new Precinct distinct from the

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Drury 1 Precinct that was worded and constructed differently to the Drury 1 Precinct. The submitters consider that it is imperative that the most integrated, continuous, and coherent development outcome across the existing and proposed Precinct areas be achieved and that to do this a single set of Precinct provisions should be relied on.

16. In terms of the proposed offset policy (14) not opposing the Drury CreekIslands Recreation Reserve, while effects should be avoided in the firstinstance, where offsets are required for unavoidable adverse effects thenthe submitter does prefer that these are directed to the Drury Creek IslandsRecreation Reserve to restore its conservation and intrinsic values. TheIslands are currently grazed and this is contributing to their degradation. Thesubmitter has reviewed Dr Ussher’s rationale for restoring the islands andconsiders it to be appropriate. The submitter always seeks that developersdo more than the minimum, and in this case the islands potentially representa transformative and exemplar opportunity to achieve this.

17. The submitter looks forward to working with Auranga and the Department ofConservation on the restoration plan for the islands. In saying this thesubmitter reaffirms its position that the Drury Creek Islands RecreationReserve should be reclassified by the Department of Conservation in amanner which prohibits commercial activity.

18. Overall the submitter is “Not Opposed” to the private plan change providedthat it is approved as notified.

Relief:

19. The submitter seeks that PPC 6 be approved as proposed.

20. For the avoidance of doubt, the submitter is “Not Opposed” and seeks theretention of:

i. The extent of the notified Mixed Housing Urban and Mixed HousingSuburban Zones.

ii. The notified Precinct Plan 2.

iii. The use of the Drury 1 Precinct and its application to the area ofPPC 6 including its integrated subdivision, urban design, bulk andlocation rules package.

iv. The notified amendments to the Drury 1 Precinct provisions(explanation, objectives, policies, rules and criteria) to implementthe above.

21. The submitter does not support changes to the notified PPC 6.

General reasons for relief:

22. The submitter considers that PPC 6:

a. will promote sustainable management of resources, achieve thepurpose of the RMA and is not contrary to Part 2 and otherprovisions of the RMA.

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b. will enable the social, economic and cultural well-being of the

community in the Auckland region. c. will meet the reasonably foreseeable needs of future generations. d. represents the most appropriate means of exercising the Council's

functions, having regard to the efficiency and effectiveness of the provisions relative to other means.

23. In the submitter’s opinion PPC 6 has more cultural and environmental

benefits to iwi than can be currently gained under the default AUP.

24. The submitter and PPC 6 requester have spent considerable effort in finding middle ground in respect to Auranga A and B. The negotiations that led to these cultural and environmental outcomes have been extensive, and on the basis of a progressive and collaborative approach.

Hearing:

25. The submitter wishes to be heard in support of its submission.

26. If others make a similar submission, the submitter will consider presenting a

joint case with them at any hearing.

Date: 23/011/2017 Nigel Denny Kaitiaki Manager Te Akitai Waiohua PO Box 59 185 Mangere Bridge Auckland 2151

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