In the Matter of:

The Proposed Auckland Unitary Plan

Submitter:

Benjamin Ross

Submission Number:

1606-1, 1602-3 and 1602-5

Topics:

059 Residential Objectives and

Policies, 062 Residential
Development Controls

Evidence:

Primary

Statement of Evidence by Benjamin Ross,

September, 2015

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

Page 1

Contents
Summary ............................................................................................................................................... 3
Introduction............................................................................................................................................ 4
Scope of Evidence ............................................................................................................................... 5
Amendments to Original Submission on Residential Zones and Development Controls ......... 6
Cost Impact on Height Rules applying to (residential) developments ....................................... 10
Final Remarks ..................................................................................................................................... 12

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

Page 2

Summary
1. I (Benjamin Ross) (the Submitter) am submitting to the Proposed Auckland Unitary
Plan as a private citizen.
2. I am seeking the replacement of the current four Residential Zones in the Proposed
Auckland Unitary Plan with seven new Residential Zones.
3. The four Residential Zones to be replaced:
a. D1.4: Single House Zone
b. D 1.5: Mixed Housing Suburban Zone
c. D1.6: Mixed Housing Urban Zone
d. D1.7: Terraced Housing and Apartments Zone
4. Proposed new Residential Zones for the Proposed Auckland Unitary Plan:
a. Residential Standard Low Density Zone
b. Residential Intensive Low Density Zone
c. Residential Classic Medium Density Zone
d. Residential Standard Medium Density Zone
e. Residential Intensive Medium Density Zone
f.

Residential Standard High Density Zone

g. Residential Intensive High Density Zone

5. I am not seeking to change the Residential Zones Objectives and Policies as
proposed in Auckland Councils Primary Evidence apart from what I have proposed
for my proposed Residential Zones. The unchanged Residential Zones Objectives
and Policies would be subsequently retrofitted into these proposed Residential Zones
6. As a result of significant changes to the proposed Residential Zones Objectives and
Policies, and Development Controls through Auckland Councils Primary Evidence, I
will through my Primary Evidence make amendments to my proposals being sought
in the Proposed Unitary Plan
7. The main purpose for the proposed new Residential Zones to replace the current
versions in the Proposed Auckland Unitary Plan is to:
a. Add new residential zones to provide for more variation and higher density
zones1

Evidence Roberts, Planning - ATTACHMENT 4 - SUMMARY OF KEY ISSUES RAISED. Page 2

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

Page 3

Introduction
8. My name is Benjamin Ross and I am a resident residing in the Papakura Local Board
area, Southern Auckland.
9. My formal qualifications are a Bachelor of Arts in Geography and Political Studies
gained from the University of Auckland in 2010.
10. I have been a regular submitter and social commentator to various Auckland Council
and Auckland Transport documents including:
a. The Auckland Plan,
b. The Long Term Plan 2012-2022 and 2015-2025,
c. Regional Land Transport Plan,
d. Regional Public Transport Program,
e. Various Area Plans.
11. I have also previously submitted and/or presented to the Unitary Plan Hearings Panel
on:
a. Topic 044 Transport, Rules and Others
b. Topic 051 Centres Zone
c. Topic 081 Rezoning and Precincts (Geographical Areas) (Upcoming)
12. I have read the Primary Evidence from Auckland Council or consultants hired by
Auckland Council on Topic 059 Residential Objective and Policies, and Topic 062 Residential Development Controls from:
a. Nick Roberts
b. Don Munro
c. Peter Nunns
d. Kyle Balderstone
e. Dr Doug Fairgray
13. I have read the Interim Guidance pieces issued by the Independent Hearings Panel
released so far (as of September, 2015).

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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Scope of Evidence
14. While the reason for the submission and evidence was provided in that submission to
support changes asked for, further evidence is given here to:
a. Further build on the evidence given in my submission written in February
2014.
b. Provide new evidence that has come out since the submission was written in
February, 2014.
c. Provide any clarifications needed from any confusion that may have arisen
since the submission was written.
d. Acknowledge or build on from any Interim Guidance given by the Independent
Hearings Panel (September 21, 2015).
e. Acknowledge, support, and/or rebut Council given evidence on and/or against
my submission, or amendments I sought to the Proposed Auckland Plan via
Mediation in which I attended.

15. Submissions from other submitters will be referenced as required in this document
where they support evidence provided here, evidence in my submission, or rebut
Council evidence.

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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Amendments to Original Submission on Residential Zones and

Development Controls
16. Below are amendments to respective sections of my original submission (1606) on
the Residential Zones and Development Controls. These amendments come about
from changes to the development controls as presented in Auckland Councils
Primary Evidence by Nick Roberts in comparison to the notified version of the
Proposed Auckland Unitary Plan to which the submission was written to.
17. New Zone Residential Classes to replace the D.1.4 Single House Zone to D.1.7
Terrace Housing and Apartment Zone of the Unitary Plan:
Relief Sort

Existing Unitary Plan Objectives and

Policy to be used for the new zones

D.1.4 Single House Zone

D.1.4 Single House Zone Objective

Residential Standard Low

and Policies

Density Zone

D.1.5 Mixed Housing Suburban

D1.5 Mixed Housing Suburban Zone

Zone and D.1.6 Mixed Housing

Objective and Policies, AND D.1.6

Urban Zone

Mixed Housing Urban Zone Objective

Residential Intensive Low

and Polices

Density Zone

D.1.5 Mixed Housing Suburban

D1.5 Mixed Housing Suburban Zone

Zone, D.1.6 Mixed Housing

Objective and Policies, D.1.6 Mixed

Urban Zone and D1.9 Terrace

Housing Urban Zone Objective and

Housing and Apartment Zone

Polices, and D.1.7 Terrace Housing

Residential Classic Medium

and Apartment Objective Policies

Density Zone

D1.7 Terrace Housing and

D.1.7 Terrace Housing and Apartment

Apartment Zone

Objective Policies

Residential Standard Medium

Density Zone

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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Relief Sort

Existing Unitary Plan Objectives and

Policy to be used for the new zones

D1.7 Terrace Housing and

D.1.7 Terrace Housing and Apartment

Apartment Zone

Objective Policies

Residential Intensive Medium

Density Zone

Residential Standard High

D.3.2 City Centre Zone Objective and

Density Zone

Polices, D3.3 Super Metropolitan

(Would be found in Metropolitan,

Centre and D3.4 Metropolitan Centre

Super Metropolitan, and City

Objectives and Policies

Centre Zones as an overlay)

Residential Intensive High

D.3.2 City Centre Zone Objective and

Density Zone

Polices, D3.3 Super Metropolitan

(Would be found in Metropolitan

Centre and D3.4 Metropolitan Centre

Centre, Super Metropolitan

Objectives and Policies

Centre, and City Centre Zones as

an overlay)

18. D3.3 Super Metropolitan Centre has been included in Point 17 as a consequence of
my submission 1606-2.
19. Italics strikeout means original proposed amendment withdrawn through this Primary
Evidence document.

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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20. New Residential Zone Basic Development Controls (minimum lot size) for
Unitary Plan
Relief Sort

Consequential Change

Residential Standard Low

Mostly single family homes to be built. Some

Density Zone

infill allowed
Minimum Lot Size 400m2 (if it applies)

Residential Intensive Low

Mostly detached homes to be built. More

Density Zone

intensive infill allowed. Some Terraced Housing

possible
Minimum Lot Size 300m2 250m2 although
rest of the original Mixed Housing Suburban
Density rules apply.

Residential Classic

Ranging from detached homes through to Walk-

Medium Density Zone

Up Apartments and Terrace Housing

No Minimum Lot Size, No Density Limits
apply.

Residential Standard

Ranging from Walk-Up Apartments and Terrace

Medium Density Zone

Housing to 6 storey 24 metre high apartments

No Minimum Lot Size

Residential Intensive

Ranging from Walk-Up Apartments and Terrace

Medium Density Zone

Housing to 8 storey 32 metre high apartments

No Minimum Lot Size

Residential Standard High

Allows up to 12-15 storey 48 metre 60 metre

Density Zone

high Apartment Towers

No Minimum lot Size

Residential Intensive High

15 storeys 60 metres or higher (but subject to

Density Zone

any height rules set by the Metropolitan Centres)

No Minimum Lot Size

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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21. New Residential Zone Basic Development Controls (maximum height

development controls) for Unitary Plan
Relief Sort

Consequential Changes

Residential Standard Low

Two Storeys Eight Metres in height Maximum

Density Zone

permitted, Three Storeys 10 metres in height is a

Restricted Discretionary Activity. Above 10 metres in
height is non-complying

Residential Intensive Low

Two Storeys 8 metres in height is permitted, Three

Density Zone

Storeys 10 metres in height is a Restricted

Discretionary Activity, 12 metres in height in height is
a Discretionary Activity.
Above 12 metres in height and/or apartments and
Terraced Housing are non-complying

Residential Classic

Up to three storeys 12 metres in height as permitted

Medium Density Zone

activity. Four Storeys 15 metres in height is a

Restricted Discretionary Activity. Above four storeys
15 metres in height is non-complying

Residential Standard

3-6 storeys Up to 24 metres in height permitted.

Medium Density Zone

Above 6 storeys 24 metres and below 3 storeys on

any new development is noncomplying

Residential Intensive

3-8 storeys Up to 32 metres in height permitted.

Medium Density Zone

Above 8 storeys 32 metres in height and below 3

storeys on any new development is noncomplying

Residential Standard High

Up to 48 60 metres in height but also

Density Zone

Subject to rules such as those prescribed in the

Business Zone definitions

Residential Intensive High

Usually beyond 60 metres in height but also

Density Zone

Subject to rules such as those prescribed in the

Business Zone definitions

22. Italics strikeout means original proposed amendment withdrawn through this Primary
Evidence document.

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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Cost Impact on Height Rules applying to (residential) developments

23. While I used the following excerpt in my 1606-2 (Topic 051 Centres Zones) Primary
Evidence to help build the case for the Super Metropolitan Centre Zone, I am going
to place the Impacts of Planning Rules, Regulations, Uncertainty and Delay on
Residential Property Development report for the Treasury and MBIE written in
December, 2014 by the Motu Economic and Public Policy Research unit2 in this
document as it applies to the Unitary Plan Residential Zones as well.
24.
Table 2: Cost Impacts of Planning Rules and Regulations* Rule and
Regulations
Increase in Cost per Dwelling1
Apartments
Building height limits

$18,000 to $32,000

Subdivisions
See note 2

a. *All costs include opportunity costs in addition to direct construction costs.

b. 1) In cases where this factor is the limiting constraint.
c. 2) There was no definitive information available from the developers surveyed
on the impact of building height restrictions within the selection of
subdivisions included.

25. Intensification - height limits

a. Rules and regulations restricting the height of developments impact on the
development capacity of sites and hence on per unit costs. The proposed
unitary plan has introduced a range of height limits across the urban area,
some of which reduce the development capacity of suburban and central city
sites (as a result of new view shaft requirements).3 The impact of height limits
varies significantly across different sites. On the sample of developments
included in our analysis the impact under the existing planning rules and
regulations ranged from an increased cost per unit of $18,000 to $32,000.
i. The impact of the height limits on the development capacity of a site
resulted in:
ii. A reduction in the number of units in a development of between 0%
and 29% in suburban locations. Note, that in the example of the
development in which the capacity was reduced by 0%, it required the

https://www.scribd.com/doc/253323001/The-Impacts-of-Planning-Rules-Regulations-Uncertainty-and-Delayon-Residential-Property-Development
3
I have read the Interim guidance text for Topic 020 Viewshafts - released 17 July 2015

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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developer to significantly change the design. Achieving the same floor

area required a much larger building footprint, so reducing profitability;
iii. A reduction in the desired capacity by 34% to 49% over the
economically optimal height in the CBD; and
iv. A restriction in the potential number of apartments that can be
developed on a site, particularly when height limits are combined with
view shafts. This results in a large number of potential developments
being abandoned at a very early stage of the feasibility assessment,
particularly within the central city area.

26. Given that per the 013 RPS Urban Growth - Expert Conference Outcome Report Residential Developable Capacity for Auckland report4 said that the Proposed
Auckland Unitary Plan as it stands would only allow 11%5 of the 400,000 proposed
dwellings needed in the operative Auckland Plan. Thus it has to be asked is the
Proposed Auckland Unitary Plan causing that situation?

https://www.scribd.com/doc/272429202/013-RPS-Urban-Growth-Expert-Conference-Outcome-ReportResidential-Developable-Capacity-for-Auckland
5
Page 5 of the report as linked on footnote 4

Benjamin Ross. Primary Evidence.

Topics 059-063 Residential Zones.

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Final Remarks
27. In general I support the Councils proposed changes via its Primary Evidence to the
Proposed Auckland Unitary Plans Residential objectives and policies, activities,
development controls and controls and assessments.
28. However, I have sought amendments to the Residential Zones themselves through
effectively splitting out the existing proposed zones (Single Housing, Mixed Urban
and Suburban, and Terraced Housing and Apartment zones) into new zones to allow
better catering of the specific micro-environments of urban Auckland6.
29. The new proposed Residential Zones focus more on height and lot size while the
overall Residential objectives and policies stay the same from the existing Proposed
Auckland Unitary Plan. That is the new zones incorporate the respective existing
proposed Residential objectives and policies as mentioned in this document.

Benjamin Ross
September 21, 2015

Unitary Plan Submission (1606-Benjamin Ross) page 9

Benjamin Ross. Primary Evidence.

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