Before the Independent Hearings Panel

In the Matter of:

The Proposed Auckland Unitary Plan

Submitter:

Benjamin Ross

Submission Number:

1606-2

Topic:

051 – Centres Zones

Evidence:

Primary

Statement of Evidence by Benjamin Ross,
11 August. 2015

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 1

Contents
Summary ............................................................................................................................................... 3
Introduction............................................................................................................................................ 5
Scope of Evidence ............................................................................................................................... 6
Clarification sought by Auckland Council on their evidence given to Topic 051 – Centres
Zones ..................................................................................................................................................... 7
Points of Council Evidence being rebutted to Topic 051 – Centres Zones ............................... 10
Recap of the Super Metropolitan Centre Zone Concept for the Proposed Auckland Unitary
Plan ...................................................................................................................................................... 14
Clarification against evidence provided by Matthew Bonis (Topic 051) (on behalf of Auckland
Council) in regards to Miscellaneous Requests for the Metropolitan Centres .......................... 20
New evidence in support of my submission in seeking to insert the Super Metropolitan
Centre Zone into the Proposed Auckland Unitary Plan ................................................................ 22
Final Remarks ..................................................................................................................................... 47
Attachment A....................................................................................................................................... 48
Attachment B....................................................................................................................................... 51
Attachment C ........................................................................................................................................ 52
Attachment D ...................................................................................................................................... 53
Altered Definition for REGIONAL AND DISTRICT OBJECTIVES AND POLICIES»
Chapter D: Zone objectives and policies»3 Business zones» Metropolitan Centre zone
(after inclusion of Super Metropolitan Centre) ....................................................................... 59

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Summary
1. I (Benjamin Ross)(the Submitter) am submitting to the Proposed Auckland Unitary
Plan as a private citizen.
2. I am seeking for the addition for a new zone to be inserted into the Proposed
Auckland Unitary Plan under the Business Zones (PART TWO, Chapter D.3). This
new zone would be called the Super Metropolitan Centre Zone.
3. The Super Metropolitan Centre Zone inserted would sit as PART TWO, Chapter
D.3.3 (between the City Centre Zone, and the existing Metropolitan Centre Zone)
causing the rest of the successive Business Zones to be moved down one place.
4. New objectives, policies, height controls and activity tables would accompany the
insertion of the Super Metropolitan Centre Zone into the Proposed Unitary Plan.
5. Manukau City Centre would be upgraded from a Metropolitan Centre as in the
Proposed Auckland Unitary Plan to this new Super Metropolitan Centre Zone.
6. “Residential Developable Capacity for Auckland. A Report on the 013 Topic Urban
Growth for the AUP Independent Hearing Panel by the 013 Expert Group” is
referenced in supporting case for the Super Metropolitan Centre Zone.
7. Purpose of the insertion of the Super Metropolitan Centre Zone was:
a. Acknowledging Manukau and Albany’s regional importance to Auckland and
inter-regional importance to the immediate surrounding regions (Waikato and
Northland).1
b. Facilitate Auckland Council’s desire in “Shaping a Business-Friendly City”
(see Council’s document on this at
http://www.scribd.com/doc/190821467/Shaping-a-Business-Friendly-City ).2
c. For the Manukau Super Metropolitan Centre; the new Objectives and Policies
acknowledging the social provisions (The Southern Initiative) in the Auckland
Plan.
8. Super Metropolitan Centre concept was worked from Auckland Council Property
Limited submission to the Auckland Plan.
9. Per the Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11
(except D3.2)3:
a. 6.2.1 Introduction, General Objectives and Policies, Centre, Mixed Use,
General Business and Business Park Zones. Benjamin Ross proposed a
higher order status for the regional centres at Manukau and Albany and
1

Unitary Plan Submission (1606-Benjamin Ross) page 6
Unitary Plan Submission (1606-Benjamin Ross) page 12
3
Evidence Bonis, Paragraph 10.9 Page. 43 suggests change in Council stance since mediation
2

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advised he had a detailed change prepared including all of the provisions that
would be applicable to these two centres. There was no support from any of
the parties.4
b. Comment [Med_Day1-37]: 1606 Benjamin Ross – sought a new Super
Metropolitan zone be applied to Albany and Manukau. Auckland Council does
not agree – Notified provisions do not elevate individual metropolitan centres
over others. Current framework enables enough potential/capacity.5

4
5

Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11 (except D3.2) Page 4
Mediation Joint Statement for Hearing Topics 051-054 Business, D3 to D3.11 (except D3.2 Page 34

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Topic 051Centres Zones

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Introduction
10. My name is Benjamin Ross and I am a resident residing in the Papakura Local Board
area, Southern Auckland.

11. My formal qualifications are a Bachelor of Arts in Geography and Political Studies
gained from the University of Auckland in 2010.

12. I have been a regular submitter and social commentator to various Auckland Council
and Auckland Transport documents including:
a. The Auckland Plan,
b. The Long Term Plan 2012-2022 and 2015-2025,
c. Regional Land Transport Plan,
d. Regional Public Transport Program,
e. Various Area Plans.

13. I have read evidence from Auckland Council or consultants hired by Auckland
Council on Topics 051(Centre Zones) of:
a. Jeremy Wyatt,
b. Matthew Bonis,
c. Trevor Mackie,
d. Susan Fairgray,
e. Michael Akehurst .

14. I have read the Interim Guidance pieces issued by the Independent Hearings Panel
released so far (as of August 1, 2015).

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

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Scope of Evidence
16. While the reason for the submission and evidence was provided in that submission to
support changes asked for, further evidence is given here to:
a. Further build on the evidence given in my submission written in February
2014.
b. Provide new evidence that has come out since the submission was written in
February, 2014.
c. Provide any clarifications needed from any confusion that may have arisen
since the submission was written.
d. Acknowledge or build on from any Interim Guidance given by the Independent
Hearings Panel (as of August 10, 2015).
e. Acknowledge, support, and/or rebut Council given evidence on and/or against
my submission, or amendments I sought to the Proposed Auckland Plan via
Mediation in which I attended.

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

Benjamin Ross. Primary Evidence

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Clarification sought by Auckland Council on their evidence given to
Topic 051 – Centres Zones
18. I have noticed an apparent contradiction between two sets of Council evidence on
Topic 051 – Centres Zones. The contradiction is around whether Metropolitan
Centres serve ‘Regional’ or ‘Sub Regional’ catchments.
a. Exhibit A6

b. Exhibit B7
Metropolitan Centre zone
11.10 There are 10 metropolitan centres, as contained in Attachment D. These
centres are based in different sub-regional catchments. They are identified as

6
7

Evidence Wyatt, Figure 1, Paragraph 11.2. Page 12
Evidence Wyatt, Paragraph 11.10. Page 13

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significant areas for growth and intensification and are second only to the city centre
in terms of scale and intensity. They are important public transport hubs for the
region and serve a wide range of activities including commercial, civic, community
and above-ground floor residential activities. Unlike other zones there are no GFA
restrictions on commercial activities as these zones are considered a primary
location for the commercial.
c. Exhibit C (as a note of comparison from the Regional Policy Statement):8
The RPS B3.1 Policy 1 seeks that metropolitan centres function as ‘commercial,
cultural and social focal points for the region, sub-regions and districts local
areas’. RPS B3.1 Policy 2, seeks that these centres provide for commercial
intensification, with RPS B3.1 Policy 4 establishing the range of activities
anticipated. The Auckland Plan identifies such centres as having strategic roles
within the region, a diverse range of activities including residential activities, and
good transport access as served by high frequency public transport.
d. Exhibit D (from my amendment sought at Mediation for Topic 051 – Centres
Zones):9

Policy 3 is submitted on by Mr Ben Ross (1602-02) seeking that Metropolitan
Centres should promote development as necessary to support a regional and
inter-regional catchment. The submission is opposed. Whilst a number of
Metropolitan Centres accommodate spending patterns from households located
at some distance, their scale and role within the urban form is not predicated on
providing capacity for regional and inter-regional catchments (the original Policy
Three which currently stands is:
3. Promote and manage the development of the metropolitan centres to provide
facilities and services necessary to support their surrounding sub-regional
catchment.10)

19. The clarification point(s) that I wish to be cleared by Auckland Council are the following:

8

Evidence Bonis, Paragraph 10.2. Page 41
Evidence Bonis, Paragraph 10.18. Page 46
10
Evidence Bonis, Paragraph 10.30. Page 48
9

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a. Clearly define in plain English for Lay Submitters “10: There are 10 metropolitan
centres, as contained in Attachment D. These centres are based in different
sub-regional catchments.”
b. How 21.a then conforms to RPS B3.1 Policy 1 that “seeks that metropolitan
centres function as ‘commercial, cultural and social focal points for the region,
sub-regions and districts local areas’.” Basically do the Metropolitan Centres in
functioning as focal points (or rather hubs) for the region et al. mean Metropolitan
Centres have regional catchments?
c. Is Policy 3 for the Metropolitan Centres (as mentioned above) contravening the
relevant Regional Policy Statement, and the role and function per The Auckland
Plan?
d. This then leads to a question that needs to be answered for clarification from the
Auckland Council to submitters on Topic 051 Centres Zones in whether Auckland
Council treats all ten Metropolitan Centres the same through their interpretation
on what a Metropolitan Centre is in the Proposed Auckland Unitary Plan and/or
the operative Auckland Plan? If so then one must question the reasoning behind
treating the Metropolitan Centres all the same. If not then this leads into my main
argument of separating the Metropolitan Centres out through the creation of the
Super Metropolitan Centre zone.

20. It should be noted that the answers from Auckland Council to the clarification points
above do have a consequence to evidence provided in this document.

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

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Points of Council Evidence being rebutted to Topic 051 – Centres
Zones
21. Through the course of Mediation on Topic 051 Centres Zones I sought to outline my
proposal for the Super Metropolitan Centre Zone relief into the Proposed Auckland
Unitary Plan per my submission. Auckland Council through the evidence of Matthew
Bonis replied as follows11:
a. 10.8 In his submission and during mediation Ben Ross (1602-02) sought the
application of a new ‘Super Metropolitan’ zone to Albany and Manukau. The zone
would comprise a new second tier centre, behind the City Centre, would have
greater height than the existing Metropolitan Centre zone provisions and would
make it clear that Albany and Manukau are the key northern and southern
centres respectively.
b. 10.9 As I understand the submission, the key point of difference between the
proposed zone and the Metropolitan Centre zone is unlimited height in the
former. In my view the Metropolitan Centre zone enables significant growth and
intensification above existing levels of development and also allows an unlimited
scope for commercial activities. If the Panel considers the height limits in the
Metropolitan Centre zone too restrictive then this can be amended, without the
need for a new zone. I do not consider that a new zone of the type described is
necessary at this stage of Auckland’s development.

c. 10.18 Policy 3 is submitted on by Mr Ben Ross (1602-02) seeking that
Metropolitan Centres should promote development as necessary to support a
regional and inter-regional catchment. The submission is opposed. Whilst a
number of Metropolitan Centres accommodate spending patterns from
households located at some distance, their scale and role within the urban form is
not predicated on providing capacity for regional and inter-regional catchments.

22. Further noted from the evidence of Matthew Bonis (still on Topic 051)12:
a. 10.32 Both Ben Ross 1606-2 and T Greening 3371-22 seek the provision of
recognition of a new tier of centre which is the equivalent of the City Centre zone
(‘Primary Centres’) to be applied to a number of larger Metropolitan Centres
including Manukau Centre.

11
12

Evidence Bonis. Page 43
Evidence Bonis. Page 49

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b. 10.33 The relief is opposed; the notified hierarchy follows the approach
established in the Auckland Plan. The notified hierarchy seeks to create a
classification approach to centre management, where centres of equal form and
function can be grouped together in terms of both land use expectations and
associated public funding and transport initiatives. Such an approach is
consistent with the Council’s duty in terms of the integrated management of
physical resources.
c. 10.34 The addition of a further tier of centres that are equivalent to that of the city
centre is unjustified given the primacy of the Auckland CBD as the dominant
location for commercial employment, diversity of activities and economic activity.
Inserting a new classification between the city centre and metropolitan centres
would not aid in the clarity of land use provisions and likely blur the distinctions
between the centres hierarchy for no appreciable benefit.
d. 10.35 Lastly, it is not solely the size of the centre that dictates its placement in the
retail hierarchy, rather the role it plays in the community and the extent of the
catchment from which it attracts shoppers. In general terms bigger centres tend
to hold a higher position in the retail hierarchy compared with smaller centres,
however this is not always the case. In this instance the placement of Manukau
Centre (Greening / Ross) and Albany (Ross) as being metropolitan centres is
supported given their role and function.

23. I have also noted from the evidence of Trevor Mackie on behalf of Auckland Council in
regards to Urban Design Planning – Height Limits (still on Topic 051)13:
a. Metropolitan Centre unlimited height, increase height limit, reduce height
limit, retain
b. Submitter requests
i. 10.34. Submissions sought deletion of the height control or unlimited
height in the Metropolitan Centres. Reasons given are that: the taller
the better, by increasing the number of residences and reducing the
need for transport options with people living on or at their workplace;
the PAUP has effectively down-zoned from existing Business 3 zone
(inferred Takapuna), which will stifle development; we currently have
one of the least densely populated cities, to grow we need to focus on
building up, not out; we will not get the desired outcome for our city if
13

Evidence Mackie. Pages 25-26

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we bow down to the anti-development and anti-progress lobby groups;
and unlimited height is necessary for major satellite cities outside the
CBD. Patrick Fontein (6282-7) seeks acknowledgement that the
Metropolitan Centres have had their building height and development
potential reduced, and considers that the PAUP falls short of the
intensification targets.
ii. 10.35. Louis Mayo (4797-99) is seeking a 96m (24 storey) height limit
in the Metropolitan Centres. Cooper and Associates (6042-35) seek a
30 storey limit. Nationwide Properties Limited and Estate David
Berryman (1125-1) seek a reduction in the height limit to 50m. Other
submissions 27 seek retention of the notified provision for height, as
the zone reflects the operative plan provisions which enable a variety
of activity supporting the transport network. Hartwig Clasen (5219-46)
sought a reduction in height limits in the Metropolitan Centres except
for Newmarket, to avoid high rise buildings affecting the character and
living quality of Auckland.

c. Discussion
i. 10.36. In introducing the 72.5m height limit there is a reduction for part
of Takapuna, and for parts or all of other areas that had unlimited
height in the legacy plans. Takapuna Area C (or Sub-precinct C) had
theoretically unlimited height but was constrained by a floor area ratio
(gross floor area limited to 3.5 times the area of the site), HRB
controls applying from the nearest residential zone boundary, and
could have a tower footprint of only 40% of its site area. The proposed
Takapuna precinct controls theoretically allow unlimited height but
have a 6:1 FAR control. There are also constraints on height and
resource consents for tall structures in other centres. There has been
little uptake in the unlimited height provisions for Takapuna, Mangere,
Manurewa, Otara, Pakuranga, Papatoetoe, Te Atatu North, Albany,
Botany, Henderson, Manukau, Glen Eden and Highland Park. That is
not a reason on its own to introduce a height limit, as there have been
resource consent applications and a few taller buildings constructed.
The PAUP does not have a floor area ratio control limiting
development, and the height-in-relation-to-boundary control now only
Benjamin Ross. Primary Evidence

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applies up to 30m from a residential or public open space zone
boundary.
ii. 10.37. 72.5m as a zone-wide control is not particularly limiting in my
opinion, considering greater height is a restricted discretionary activity.
I consider it reasonable to assess potential effects of visual amenity,
bulk dominance and shading from the upper parts of such taller
buildings, individually as well as cumulatively as the centres grow, as
well as landscape and landmark effects.

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Recap of the Super Metropolitan Centre Zone Concept for the
Proposed Auckland Unitary Plan
24. Below is a brief recap of the Super Metropolitan Centre Zone concept proposal for the
Proposed Auckland Unitary Plan using existing material/evidence as of February, 2014
when my submission (#1606) was written. New evidence since then will be presented in
next sub-section.
a. Concept was generated from the historical geography of Manukau City Centre,
and ACPL’s Auckland Plan submission where they noted a different version of
Centre Hierarchies compared to what is in the operative Auckland Plan and
PAUP.
b. The Super Metropolitan Centre would sit as a tier between the City Centre and
the Metropolitan Centre in the Auckland Plan and PAUP.
c. The Super Metropolitan Centre recognises not all 10 Metropolitan Centres
geography wise are the same. ACPL’s original Auckland Plan submission and
further material gathered domestically and internationally support the original
ACPL point.
d. If the Super Metropolitan Centre were to be inserted into the Auckland Plan (and
by consequence the Unitary Plan) at first Manukau City Centre (currently a
Metropolitan Centre) would be elevated into the Super Metropolitan Centre tier.
Albany would also be the other candidate to be elevated into the Super
Metropolitan Centre tier depending on growth forecasts on the North Shore and
Rodney over the life of the Auckland Plan.
e. Super Metropolitan Centres serve a regional and even inter-regional catchment
compared to the sub regional catchment of a standard Metropolitan Centre Zone.
Manukau Super Metropolitan Centre would service all of Southern Auckland and
northern Waikato, Albany with north Auckland and Northland.
f.

Super Metropolitan Centres compliment the main City Centre rather than
compete. Also a sustainable argument owing to potential of remote offices being
establish thus leading to less demand on cross city transportation systems.

g. The lack of demand argument that has been touted is one I find underwhelming.
It is not the place of Council to determine demand but to facilitate any future
investment into a Centre within Auckland. E.g. if someone in 2020 wants to build
a 26 storey mixed use complex owing to demand in the Manukau Super
Metropolitan Centre then Council should enable it rather than disable it via the
Benjamin Ross. Primary Evidence

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proposed more restrictive Metropolitan Centre rules. The Super Metropolitan
Centre looks at a 50 year picture.
h. The Super Metropolitan Centre enables better realisation of the Section D four
high development strategies set in the Auckland Plan.

25. Extract from Auckland Council Property Limited and their submission to The Auckland
Plan14
a.

8.1 The Hierarchy of Town Centres
i. The conclusion of this report is that a form of hierarchy is beneficial.
ii. However, it is important that the debate on the hierarchy of Town
Centres does not distort the drive for the right results. The focus
needs to be on driving outcomes rather than settling hierarchical
arguments.
iii. It does help set public sector prioritisation and funding decisions. It
sets clear expectations for the market, which, in turn, will provide a
level of confidence.
iv. The critical aspect, however, is not to constrain the market because
beneficial initiatives don’t fit in with a preconceived hierarchy. From
the market’s perspective, it will focus on opportunities where there are
clear signals from Council as to where investment is targeted.
v. Figure 1 below outlines a proposed hierarchy of Town Centres.

14

http://www.aucklandcouncil.govt.nz/SiteCollectionDocuments/aboutcouncil/cco/aucklandcouncilproperty/tca
ndtpreporttoacpl.pdf

Benjamin Ross. Primary Evidence

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15

vi. It is important to note that the hierarchy for Town Centres is expressed
in terms of function only (i.e., the difference between Metropolitan
Centres and Town Centres), and should not be confused with the
investment priority for the Council. There are different drivers as to
whether the Council could and should invest its resources in various
Town Centres.

b.

8.3 Primary Centres
i. While there is some debate about whether Auckland legitimately
has two or three Primary Centres, the conclusion of this report is
that there are two centres – one to the South (Manukau) and one
to the North (Albany). These Primary Centres fundamentally

15

This is a new Town Centre Hierarchy category introduced by the Project Team and not recognised in the
Draft Auckland Plan
Figure 1 – Proposed Hierarchy of Town Centres
NB: Mega Centres have not been included in this hierarchy

Benjamin Ross. Primary Evidence

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complement the City Centre in servicing core parts of the region,
and reflect the linear geography of Auckland.

c.

8.3.1 Manukau
i. Manukau has traditionally been a strong area and has developed into
a major Primary Centre extensively servicing South Auckland.
ii. It would benefit from the overview of the City Transformation
Unit. The commitment and focus this brings is beneficial. It
sends a signal to the market that Council is committed to
continuing investment in order to strengthen Manukau.
iii. The key issues Council should focus on are:
I.

The significant opportunity the new rail link to Manukau City
Centre will provide. This should further boost the preference
for office location in this area.

II.

Opportunities to improve the walkability of the Centre and in
particular to connect the rail station to the Centre.

III.

A more sophisticated entertainment and retail offer.

IV.

The need to promote a residential base within Manukau City
Centre. It is this mix of office and residential use which will give
Manukau a 24-hour urban lifestyle.

V.

It is recognised that the reverse sensitivity aspects of the
airport flight path do complicate residential opportunities.

VI.

Support the social policy initiatives and approach reflected in
the broader Manukau Community and the opportunities the
Manukau City Centre derives to support these policies.

d.

8.3.2 Albany
i. Albany is a centre with ‘good bones’ but with little soul.
ii. It needs a more sophisticated approach to create a heart for the
Centre.
iii. Albany needs a robust, strategic rethink. It is in danger of becoming a
large dispersed centre. If the ‘heart and soul’ of Albany is to be
created, then this requires careful thinking and probably a small range
of works and actions which will build a sense of place and community
at Albany.

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iv. There is significant opportunity to leverage off the Albany Mega
Centre, Westfield Shopping Centre, the park, and North Harbour
Stadium.
v. Connecting the transport hub to the Centre is a key requirement.
vi. Implementing the North Harbour Stadium Master Plan and the broad
range of complementary uses is advocated.
vii. There is a need to create a residential population, to create the 24hour city.
viii. The constraints of the previous significant area of leasehold land
tenure in Albany, and current unrealistic price expectations by some
landowners, needs to be recognised. Whilst the land has recently
become freehold, it is too expensive for the market to be attracted to.
This may take some time to unwind and for the land tenure and pricing
to adjust to the realities of a new business cycle and environment
resulting from the GFC.

e.

2.1.2 Auckland Hamilton Growth Corridor
i. Over the next 20+ years, the corridor that links Auckland and Hamilton
will provide a strong opportunity to harness economic growth in the
north of the Waikato and the south of Auckland regions.
ii. As a continuation of Section 2.1.1, it is suggested that this growth
corridor and the Provincial Towns located in this corridor are a critical
element of Auckland’s growth strategy. This corridor should be
strongly and formally recognised in the Auckland Plan. It provides the
basis for a future “conurbation” encompassing South Auckland and
North Waikato regions.
iii. Auckland’s economic and population growth must have an interest in,
and relationship with, the Waikato and its primary agriculture base as
it is so essential to the New Zealand economy. Auckland needs to
recognise the opportunity that Auckland’s proximity to the Waikato, as
the engine room of New Zealand’s leading industry of international
scale and quality (i.e., dairy, agriculture and biotechnology), will
provide in the future. There is significant opportunity for Auckland in
the economic involvement, support and servicing of this industry.

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iv. Auckland will benefit from this (as will the Waikato) in economic
returns as much as in the opportunity that such a corridor presents to
accommodate future growth in the South Auckland/Northern Waikato
“super region”.
v. The significant existing investment in rail, road and broadband
infrastructure between Auckland and Hamilton also offers significant
opportunity for Provincial Centre development along this major
transport corridor. Further investment in this corridor may yield large
gains for Auckland and relieve pressures elsewhere within the system.
The relative merits of leveraging this infrastructure against alternate
transport and economic investment is at least worthy of consideration
in the next 2-5 years.
vi.

There is a significant opportunity to provide both residential and
business land and to accommodate a material number of businesses
and residents over the next 20-30 years.

vii. Pokeno and areas south of Bombay are considered to be attractive to
the market and the southern growth corridor should consider carefully
the impact and importance of such areas.
viii.

With the main New Zealand market and economy located in Auckland
and to the south, vacant land supply south and the connections to
primary transport make the Auckland-Hamilton corridor a critical factor
that warrants recognition and close consideration in the future.

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Clarification against evidence provided by Matthew Bonis (Topic
051) (on behalf of Auckland Council) in regards to Miscellaneous
Requests for the Metropolitan Centres16
26. On pages 49 and 50 of the evidence provided by Matthew Bonis on behalf of
Auckland Council, Mr Bonis stated that:
a. 10.32 Both Ben Ross 1606-2 and T Greening 3371-22 seek the provision of
recognition of a new tier of centre which is the equivalent of the City Centre zone
(‘Primary Centres’) to be applied to a number of larger Metropolitan Centres
including Manukau Centre.

27. In clarifying the what Mr Bonis has said in his Point 10.32 ((26a) of this document) in
regards to my original submission to the Proposed Auckland Unitary Plan
a. My submission (1606-2) called for a new hierarchy to be placed into the
Proposed Auckland Unitary Plan. This new hierarchy is named the Super
Metropolitan Centre
b. Prior to the PAUP submission I had written pieces and presented numerous
times to Auckland Council on elevated Manukau City Centre to the same
hierarchy as the main City Centre as listed in the Auckland Plan
c. However, the then proposed elevation of Manukau to the same as the main
City Centre was received coolly
d. Subsequently the Super Metropolitan Centre concept was created and to be
proposed as a new hierarchical spot in the Business Zones of the Proposed
Auckland Unitary Plan. The Super Metropolitan Centre Zone would be
inserted in between the City Centre Zone and the Metropolitan Centre Zone.
The Super Metropolitan Centre would have its own unique Objectives and
Polices inside the Proposed Auckland Unitary Plan
e. In refuting Mr Bonis’s 10.32 specifically I have not sought the provision of
recognition of a new tier of centre that is equivalent to the main City Centre
Zone. What I have sought is a creation and recognition of a new tier of centre
that while is in between the City Centre and the Metropolitan Centre, the
Super Metropolitan Centre. As stated above in (27d.) the Super Metropolitan
Centre contains its own Objectives and Policies albeit blended from both the
original City Centre and Metropolitan Centre zones.
16

Evidence Bonis. Pages 49-50

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i. Where Mr Bonis might have thought “Primary Centres” has come from
in creating the new tier of centre could have been from Auckland
Council Property Limited submission to the Auckland Plan in 201117.
ii. Again in ACPL’s submission a Primary Centre was (and would be
inserted between the Metropolitan Centre and City Centre): While
there is some debate about whether Auckland legitimately has two or
three Primary Centres, the conclusion of this report is that there are
two centres – one to the South (Manukau) and one to the North
(Albany). These Primary Centres fundamentally complement the City
Centre in servicing core parts of the region, and reflect the linear
geography of Auckland.18
iii. Continuing with ACPL’s Auckland Plan submission a Primary
Centre19 is a Primary Commercial, employment and cultural hub at a
regional scale. While Metropolitan Centres contains important retail,
employment and residential function at a sub-regional scale
iv. Thus it would be ACPL’s Auckland Plan submission providing the
foundation to the Super Metropolitan Centre concept in my submission
to the PAUP. It would also provide the basis of refuting Council
evidence through this document.
f.

Points 10.33 through to 10:35 of Mr Bonis’s evidence on the Miscellaneous
Requests will be rebutted in the next subsections where applicable.

17

http://www.aucklandcouncil.govt.nz/SiteCollectionDocuments/aboutcouncil/cco/aucklandcouncilproperty/tca
ndtpreporttoacpl.pdf
18
Per footnote 15
19
Primary Centre would foundation to the creation of the Super Metropolitan Centre concept in my
submission

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New evidence in support of my submission in seeking to insert the
Super Metropolitan Centre Zone into the Proposed Auckland
Unitary Plan
Opening Remarks
28. Since the submission was written in February 2014 new information, commentary
and projects from both Auckland and abroad (including overseas) have come about.
That new information will be added into this subsection; both new supporting
evidence for the Super Metropolitan Centre, and to further rebut Council evidence
against the Super Metropolitan Centre.

29. To start this off I am going to provide this following article from the Sydney Morning
Herald written in May this year. The reason being as it illustrates what our closes
competitor Sydney is up to given they have got their Sydney Plan20 under way. The
article will also lay down the foundation of why I believe Auckland Council is actually
being timid especially towards the Metropolitan Centres given what our Australian
cousins are doing and also that we are meant to be a Business Friendly City21
30. The

rise of Parramatta: ‘Once in a lifetime opportunity’ 22

May 23, 2015. Melanie Kembrey and Matt Wade – Sydney Morning Herald

As its colonial heritage testifies, Parramatta has been a big part of Sydney’s past.
Now there’s growing recognition of how vital Parramatta will be to the city’s future.
A marker of Parramatta’s emerging economic clout came this week when a $2
billion proposal to rejuvenate its commercial hub took a major step forward. Plans for
Parramatta Square were first mooted more than two decades ago but demolition
work is now approved and there are hopes the project will be completed by 2019.
The redevelopment has been billed as “western Sydney’s Martin Place” and will be
one of Australia’s biggest urban renewal projects. At least five civic, residential and
20

http://www.strategy.planning.nsw.gov.au/sydney/
https://www.scribd.com/doc/190821467/Shaping-a-Business-Friendly-City
22
http://www.smh.com.au/nsw/the-rise-of-parramatta-once-in-a-lifetime-opportunity-20150522-gh7eg3.html
21

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commercial towers will rise around a large public domain adding 150,000 square
metres of high-end commercial office space that will accommodate more than
18,000 workers, students and residents on any given day.
Parramatta Lord Mayor, Scott Lloyd, said the renewal project was a “once in a
lifetime opportunity” and the Premier, Mike Baird, praised the council for taking plans
for Parramatta Square forward.
“The NSW Government has identified Parramatta as our second CBD … it will play a very
significant role in providing employment and housing opportunities that are essential for
Sydney’s global competitiveness,” he said.

Why is Parramatta so important?
There’s a lot riding on Parramatta’s transformation. The western Sydney economy
has traditionally relied heavily on manufacturing, a sector weakened by global
economic forces, and jobs growth in the region has lagged behind other parts of the
city recently. The traditional commercial centres of western Sydney, especially
Parramatta, need to adapt if they are to attract and keep the high quality knowledge
industries where future jobs growth is likely to be strongest.
Baird, who is also the minister for western Sydney, says the future of the city and the state
are tied to Parramatta.

“This is a great state, Parramatta is a great city, and the future of both is heavily
connected,” he said on one of his many stops in western Sydney during this year’s
state election campaign.
Tim Williams, chief executive of lobby group the Committee for Sydney predicts the
city’s future will be determined in its west.
“Sydney’s structure is challenging. We’ve got this rather constrained CBD on the far
east of our city but about two million people live west of Parramatta,” he says. “The
next big step in Sydney’s transformation is to do Parramatta comprehensively and

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well … the city needs Parramatta to be an economic powerhouse, a second
economic pole.”
While Sydney’s CBD remains the nation’s most valuable economic location,
modelling by consultancy PwC shows Sydney’s economic centre of gravity - the point
around which economic output is evenly balanced – is nine kilometres west of the
central business district and drifting north-west. That drift underscores the growing
importance of economic clusters inland from the CBD. PwC’s analysis of Sydney’s
local areas showed the Parramatta-Rosehill area generated more than $7.6 billion in
2012-13 and was growing at a faster rate than both the CBD and North Sydney. It’s
estimated that more than 20 per cent of Australia’s Top 500 companies now have a
presence in Parramatta’s CBD.
PwC’s economics director, Rob Tyson, said the growing recognition of Parramatta’s
importance – signified by urban developments such as Parramatta Square – could
be a “tipping point” in realising the huge potential of western Sydney.
“All of our research and economic analysis in the past points to the fact that
Parramatta is becoming increasingly important in the whole tapestry of Sydney’s
economic network,” he said.
Baird has declared Parramatta the “infrastructure capital of the world” because of the
investment planned in the region. He points to a $26 billion pipeline of spending on
road and rail projects in western Sydney – almost one in every two dollars allocated
for state transport infrastructure. That includes Australia’s biggest road project,
WestConnex, and its biggest public transport project, the North-West Rail Link. The
pipeline grew last year when the Abbott Government announced a new airport will be
built at Badgerys Creek.
Baird argues the sheer volume of infrastructure spending in store for western Sydney
has attracted the attention of the world’s leading infrastructure players and they see
great opportunity in the region over the next decade.

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The rest of the west
The push to strengthen Parramatta as Sydney’s second commercial hub has been a
catalyst for economic change across western Sydney. David Borger, the Western
Sydney director of the Sydney Business Chamber, says the rise of Parramatta
has provided other regional cities with a road map for their own development. No
longer content to wait for organic growth, a range of cities have followed in
Parramatta’s footsteps and are actively embarking on major urban renewal projects
and re-branding campaigns.
"The new model for leadership in western Sydney is that you've got to take risks and
you've got to be entrepreneurial for the city because, if you don't, you're going to be
left behind," says Borger.
"These are places that cannot sit there and just coast on their natural strengths.
They have to actually get out there and be hungry."
Liverpool has an urban rejuvenation plan called "Building Our New City" which
includes an "eat street", a revitalised mall and new "gateways" to create a sense of
arrival in the city. Mayor Ned Mannoun said the decision to build the international
airport at Badgerys Creek had been a game changer and it is now positioning itself
as the capital of south western Sydney and as the "Airport city". In a city where eight
storey buildings have been the norm, construction has now started on the first 30
storey building. Cr Mannoun said that during the next 10 years no other Australian
city will gain as much infrastructure as Liverpool.
"We are very strongly positioning ourselves to become Sydney's third major city,"
Cr Mannoun said.
"We want to be known as the city that builds things and is home to all the related
industries that build things – engineering, constructing, consulting, and planning. We
want to become the city of urban design."

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To the north west of Liverpool, Penrith also has a grand plan. It has embraced the
slogan "Penrith is Here" and is pushing itself as the "capital of the New West" on the
premise that Sydney's eastern CBD is a global hub and Parramatta its "central city."
Like Liverpool, Penrith plans to revamp its city centre and in the process bring an
extra 10,000 jobs and 5,000 dwellings to the area. Penrith Council has shifted
its policy position on Badgerys Creek airport and now supports the project in the
belief that it is better to be "inside the tent" to gain access to resources.
Mayor Ross Fowler said Penrith residents want a city that is bold.
"Penrith has always had its own separate identity to the rest of western Sydney.
We've probably evolved over the last 30 years from a proud country town to now a
very proud city," he said.
Western Sydney Leadership Dialogue chairperson Chris Brown said Parramatta was
the "older brother" influencing and inspiring the rest of western Sydney,
"Parramatta is the beach head which has given the decision makers in the city a
confidence about moving jobs, money and office space to western Sydney and now
there is an opportunity for the others, like Liverpool, to come through and say they
want a slice of that action as well," Mr Brown said.
"With Parramatta dominating central Sydney, Liverpool dominating the south west
and Penrith dominating the outer west, there are nodes around which the
government can build."
The transport challenge
A Committee for Sydney report released last month said much more attention should
be given to the "east-west spine" of Sydney between the CBD and Parramatta. It
called for a much faster and more frequent heavy rail connection on the existing line
that connects the CBD and Parramatta so the two economic hubs can be more
closely linked.

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"The analogy is with the old financial centre of London and the new one created in
Docklands at Canary Wharf, which did not succeed until a public transport link was
created," the report said.
"This enabled a business person to get from one to the other in less than 15 minutes
with services so speedy and frequent that they didn't have to know the timetable."
As well as a high speed rail to link Sydney's dual CBDs, there is a need for improved
public transport connections between the various commercial centres in western
Sydney.
The government is currently considering which of four light rail routes will be built
around Parramatta, with the hope of eventually delivering a light rail network around
western Sydney. The four routes are Parramatta to Macquarie Park via
Carlingford, Parramatta to Castle Hill via Old Northern Road, Parramatta to
Bankstown, and Parramatta to Sydney Olympic Park and Strathfield/Burwood.
While there is no hint of when a decision will be revealed, construction on a route
was due to start in this term of government and the different commercial centres are
lobbying hard for their causes.
Parramatta Council has proposed a route from Westmead to Epping, which would
link centres to the north, east and west of Parramatta CBD, such as the Westmead
health precinct, Parramatta Stadium and UWS's Rydalmere and proposed
Parramatta Square campuses.
Parramatta Mayor, Cr Scott Lloyd, says it will make Parramatta the new Central
station and provide a spine that would allow for future light rail expansions
to Macquarie Park, Castle Hill and Olympic Park.
The jobs challenge
Greater Western Sydney is one of Australia's biggest regional economies, with
annual output of nearly $100 billion, but job creation in the region has been dwarfed
by population. About 200,000 people leave western Sydney each day for work and
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that daily migration could swell to 400,000 by mid-century unless jobs growth in the
region improves. The movement of so many workers to and from western Sydney
puts huge pressure on the city's transport networks and is a major drag on the
economy.

31. Parramatta as the second Central Business District (or City Centre) is a major
initiative being undertaken by the local authorities in Greater Sydney and the New
South Wales State Government. The initiative is set out in the Sydney Plan which is
the equivalent of our Auckland Plan (notwithstanding Sydney being more ambitious
arguably).

The Sydney Plan vs The Auckland Plan and Proposed Auckland Unitary Plan
32. I am going to copy over extracts of The Sydney Plan23 relevant to the debate and
seeking of the relief of the insertion of the Super Metropolitan Plan into the Proposed
Unitary Plan

33. It is to acknowledge first that while The Auckland Plan is the overarching master
document (framework) that inevitability guides the Proposed Auckland Unitary Plan
the Auckland Plan is a non-statutory document. Given that, and the fact city evolution
is fluid it can be argued that the Auckland Plan is already obsolete to both the City
(Auckland’s) needs and current development trends. Thus Council should not be
opposing any alterations to the Auckland Plan if hierarchical changes come through
from the Proposed Auckland Unitary Plan as a result if the changes are backed by
solid evidence.

34. Thus in setting the Proposed Auckland Unitary Plan (which will last 30-years) we as a
City need to make sure per the Resource Management Act 1991 the Plan is as
enabling as possible while still meeting its obligations under the Act. Thus I argue
without the Super Metropolitan Centre concept the Proposed Auckland Unitary Plan
23

http://www.strategy.planning.nsw.gov.au/sydney/

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– Business Zones is a disabling document as the PAUP does not actually recognise
adequately the different geographies of our Metropolitan Centres. Consequently
(again) I rebut 10.33 and 10.34 of Matthew Bonis’s evidence24 against the seeking of
the insertion of the Super Metropolitan Centre into the Proposed Auckland Plan.

35. Below is the introduction to the Sydney Plan. Given that the Auckland Plan is meant
to frame the Unitary Plan comparing both to the Sydney Plan and how it will frame
Sydney’s development would be helpful:
a. INTRODUCTION
b. Sydney is an iconic global city and it is growing.
c. Sydney is currently home to over four million people living in communities as
different as Cabramatta, Manly and the Blue Mountains. Each has its own
identity but collectively they enrich the life and character of Sydney.
d. Sydney is a global city, the premier city in Australia and the economic capital
of the country. What happens in Sydney is important to the rest of the nation
because of its impact on jobs, the economy and our capacity to produce
goods and services that are in demand around the world.
e. Sydney’s strong economy, skilled labour force, spectacular natural
environment and relaxed lifestyle have made our city the envy of other cities
around the world.
f.

A sign of Sydney’s prosperity is that it’s growing – its economic output and its
population. By 2031, Sydney’s economic output will almost double to $565
billion1 a year and there will be 689,000 new jobs.2 In the next 20 years,
Sydney’s population will grow by 1.6 million people, with 900,000 of this
population growth occurring in Western Sydney(3).

g. It’s clear that Sydney’s population is growing much faster than it did over the
last 20 years (see Figure 1). To meet the needs of a bigger population, we
need a plan to manage growth – how to accommodate the 664,0004 new
homes that we will need, how to provide the conditions for growth in jobs, how
to create places that people will enjoy living in and to protect our unique
natural environment.
h. Sydney needs a plan that outlines how to:

24

Evidence Bonis, Pages. 49-50

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i. make it easier for Sydney’s residents to move between their homes,
their jobs, the centres where they shop and use local services, and
their open spaces;
ii. make a wider variety of housing available to suit the changing makeup of the population – more than one million people will be over the
age of 65 years and almost the same number under the age of 15
years by 2031;5
iii. deliver new infrastructure which supports our community as it grows,
and strategic infrastructure that also strengthens the economy; and
iv. recognise our highly prized environment – the harbour, the coast, our
mountains, parks and open spaces – and how to safeguard these
places.
i.

A Plan for Growing Sydney is the Government’s plan to achieve these things.
It’s an action plan focused on bringing all stakeholders together with a
common purpose – to develop a competitive economy with world-class
services and transport; to deliver greater housing choice to meet our
changing needs and lifestyles; to create communities that have a strong
sense of wellbeing; and to safeguard our natural environment.

j.

Planning where people will live and work across Sydney, and how these
places are connected to each other, will influence Sydney’s long-term
success and the standard of living our communities will enjoy. It is critical not
to repeat the mistakes of the past – dispersed housing growth that resulted in
a sprawling and poorly connected city, complicated by unique geographic
constraints. Planning for Sydney’s inevitable population growth has never
been more important.

k. THE PLAN
l.

The Government’s vision for Sydney is: a strong global city, a great place to
live.

m. To achieve this vision, the Government has set down goals that Sydney will
be:
i. a competitive economy with world-class services and transport;
ii. a city of housing choice with homes that meet our needs and
lifestyles;
iii. a great place to live with communities that are strong, healthy and well
connected; and
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iv. a sustainable and resilient city that protects the natural environment
and has a balanced approach to the use of land and resources.
n.

o. This Plan sets out actions that will deliver these goals for Sydney. Each goal
has a number of priority areas (directions which provide a focus for the
actions). The actions include:
i. accelerating urban renewal across Sydney at train stations, providing
homes closer to jobs;
ii. growing a more internationally competitive Sydney CBD;
iii. growing Greater Parramatta as Sydney’s second CBD;
iv. transforming the productivity of Western Sydney through growth and
investment;
v. enhancing capacity at Sydney’s Gateways – Port Botany, Sydney
Airport and Badgerys Creek Airport;
vi. delivering the infrastructure that is needed;
vii. promoting Sydney’s arts and culture, tourism and entertainment
industries;
viii. protecting our natural environment; and
ix. managing long-term growth.

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p. The Plan includes a new approach to delivery with the establishment of the
Greater Sydney Commission – a dedicated new body with responsibility to
drive delivery of the Plan.
q. A Plan for Growing Sydney applies to the Sydney Metropolitan Area – 41
Local Government Areas from Pittwater in the north to Wollondilly in the south
and Blue Mountains in the west

36. As one can gather from the Sydney Plan Introduction above, Sydney is facing the
same pressures as Auckland as well as the same opportunities into 204125.
However, the key difference between Auckland and Sydney (who will undertake their
own spatial planning (laying down the zones)) is Sydney recognises its different
geographies with its Centres (like Parramatta) where Auckland treats its ten
Metropolitan Centres (in which also have different geographies) the same according
to 10.33 of Mr Bonis’s evidence on behalf of Auckland:
a. 10.33 The relief is opposed; the notified hierarchy follows the approach
established in the Auckland Plan. The notified hierarchy seeks to create a
classification approach to centre management, where centres of equal form
and function can be grouped together in terms of both land use
expectations and associated public funding and transport initiatives. Such an
approach is consistent with the Council’s duty in terms of the integrated
management of physical resources.

37. The ultimate point being in this evidence document to the Independent Unitary Plan
Hearings Panel that eight26 of our Metropolitan Centres have similar (not equal) form
and function while two do not thus require separate hierarchal. Those two being
Albany and Manukau City Centre and them both being elevated into the new Super
Metropolitan Centre tier as proposed in my submission.

Parramatta as Sydney’s Second City Centre/Central Business District
38. Again while Sydney is being very bold in pushing Parramatta to the same City Centre
status as Sydney’s main City Centre in the east my own submission (1606) is not
seeking the same for Manukau City Centre in Auckland.

25
26

Auckland Plan
Westgate, Henderson, New Lynn, Newmarket, Takapuna, Botany, Sylvia Park and Papakura

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39. However, what is being attempted with Parramatta through the Sydney Plan can be
translated into Manukau City Centre (at the minimum with Albany also being elevated
preferable) being pushed into a higher hierarchy (the Super Metropolitan Centre)
given that the geographies of Sydney and Auckland, Parramatta and Manukau are
similar.
40. Below is what the Sydney Plan has outlined for Parramatta in becoming the second
Central Business District of Sydney complementing the main Central Business
District:
41. SYDNEY’S COMPETITIVE ECONOMY
a. Our plan for a competitive economy with world-class services and transport
b. Sydney is Australia’s financial and economic capital.
c. Forty-five per cent of the top 500 Australian companies are based in NSW (1),
and a major proportion of these are based in Sydney. This puts Sydney in the
same league as other international cities − including cities in Asia − that
compete as a destination for global capital.
d. Sydney drives around 70 per cent of New South Wales’ total economic
output2 and over one-fifth of the nation’s Gross Domestic Product (GDP)(3). It
ranks above Singapore and Hong Kong in terms of economic output (4).
e. Within a decade, our neighbours in Asia will account for around half of our
global economic output, opening up opportunities for our industries and
business. Efficient infrastructure, strong centres that attract investment,
competitive international gateways, access to a deep pool of skilled labour,
and a liveable city with high standards of living will allow Sydney to take
advantage of this growth in Asia. These are the preconditions for innovation
and increased productivity.
f.

Capitalising on these opportunities will require good planning. Land use
planning impacts on a city’s economic performance and is a factor influencing
firms’ locational decisions on how easily they can move goods and services to
market and access labour. Land use planning can help industries foster
innovation and sustain economies of scale. It can also affect how efficiently
infrastructure can be delivered.

g. A Plan for Growing Sydney is a plan to sustain strong growth for Sydney,
improve its productivity and competitiveness, and foster higher living
standards.

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h. The Plan makes the intensive development of strategic locations across
Sydney a priority, including the Sydney CBD, the Global Economic Corridor,
Greater Parramatta and Sydney’s Gateways – the port and airports. Growth
in these locations will sustain and expand the economy and support more
jobs closer to where people live.
42. Direction 1.2: Grow Greater Parramatta – Sydney’s second CBD
a. Greater Parramatta is Sydney’s western CBD. Located close to the
demographic heart of the Sydney Metropolitan Area, its scale and mix of
commercial, health and education facilities make it a centre – a CBD – of
metropolitan significance.
b. The 2011 Census revealed that Greater Parramatta is diversifying with growth
in knowledge industries and increasing numbers of more highly qualified
people working in Parramatta. Employees with a bachelor or higher degree
increased by almost 26 per cent11 between the last two censuses.
c. Greater Parramatta will continue to grow in significance to Sydney. This will
require a critical mass of investment and greater diversity of activities in
Greater Parramatta. As Greater Parramatta attracts more jobs there will be
further incentive for other firms to move to the area.
d. The new University of Western Sydney campus tower, situated in the core of
Parramatta’s CBD is forecast to be home to over 10,000 students in
2017(12). This will increase the diversity of activities and enhance the social
and economic prosperity of Parramatta.
e. The core elements for growing Greater Parramatta include:
i. integrating the precincts within Greater Parramatta and connecting the
centre to the wider community and other centres through the proposed
Parramatta Light Rail initiative;
ii. continuing to grow the commercial core as the central focus of
business activity; and
iii. encouraging growth across a range of employment types.
f.

To fulfil its role, Parramatta also needs expanded arts, culture and
entertainment activities to increase its appeal as a dynamic and diverse place
to work, live and play. Development of a Parramatta arts and cultural precinct
is addressed in Action 3.4.2 in Goal 3.

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g. ACTION 1.2.1: Grow Parramatta as Sydney’s second CBD by connecting
and integrating Parramatta CBD, Westmead, Parramatta North,
Rydalmere and Camellia
h. Greater Parramatta has the potential to reach 100,000 jobs over the next 20
years (13). The Government will work with Parramatta City Council to build an
expanded Greater Parramatta by incorporating Westmead, Parramatta North,
Rydalmere and Camellia.
i.

The Government will work with Parramatta City Council to:
i. grow Greater Parramatta by connecting and integrating the precincts
which provide jobs, goods and services including Parramatta CBD,
Westmead, Rydalmere, Parramatta North and Camellia with the
existing commercial core.

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j.

k. ACTION 1.2.2: Grow the specialised health and education precincts at
Westmead and Rydalmere
l.

Westmead Health Precinct is Sydney’s most significant concentration of
biotechnology, pharmaceutical and medical device companies. These
companies are well located to access Western Sydney’s growing population
and labour force. Investment in the precinct will support jobs growth and
recognise the important health contribution the precinct makes to Sydney.

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m. Opportunities to grow knowledge jobs by building on the strengths of the
University of Western Sydney at Rydalmere will make a valuable contribution
to Greater Parramatta’s diversity and strengths.

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n.

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o. The Government will:
i. expand and build on the existing strengths of the Westmead Health
Precinct by improving public spaces and renewing the precinct;
ii. encourage higher education facilities to develop Rydalmere as
Western Sydney’s premier university precinct;
iii. facilitate improved public transport, cycling and walking connections
between Westmead and Rydalmere through the Parramatta CBD,
iv. investigate improved connections to Macquarie Park, and investigate
options to enhance a Parramatta City Ring Road; and
v. grow knowledge jobs in Western Sydney and encourage innovation by
investigating the potential for a new business park.
p. Initial investigations for the business park will focus on the NSW
Government’s land near the University of Western Sydney at Rydalmere and
the proposed Parramatta Light Rail.
q. ACTION 1.2.3: Renew Parramatta North to create a vibrant mixed-use
precinct
r.

UrbanGrowth NSW has been directed by the Government to transform and
revitalise a precinct which is home to some of the State’s and indeed
Australia’s most-important heritage locations and assets, including Australia’s
first farm and water mill, Parramatta Female Factory and the Old King’s
School. The 146 hectare parcel of Government-owned land on the banks of
the Parramatta River – the Parramatta North Heritage Precinct – will be a
focus for urban renewal.

s. UrbanGrowth NSW will:
i. deliver around 6,000 new homes and 2,000 new jobs as part of the
transformation of the precinct;
ii. examine opportunities to adaptively re-use the heritage buildings for
potential community, cultural and commercial uses; and
iii. upgrade parkland and open space, and restore the Parramatta
riverbank and create a river walk towards Lake Parramatta.

43. Although Sydney is four times bigger in terms of population than Auckland, the
geographies of Sydney and Parramatta are similar to that of Auckland and Manukau.

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44. The accompanying table illustrates the similarities of the geographies of Manukau
and Parramatta:
Parramatta
Education

University of Western
Sydney: 10,000
students by 2017

Arts, Culture and
Entertainment

Sydney Plan states
Parramatta to expand
arts, cultural and
entertainment
29
offerings
Western Sydney

Nearby Industrial
Complexes/Areas
Immediate
population
catchment
Knowledge
Industries:

Western Sydney
including ‘Greater
Parramatta’

Current Transport
Infrastructure

Heavy Rail,
Motorways, Ferry, Bus
Transit Ways, Arterial
Roads
Light Rail, improved
cycling and walking
connections

Education, Health

Future Transport
Infrastructure
Opportunities
Place in relative City

Second City Centre
complementing main
Sydney City Centre

Manukau
MIT and AUT South
campuses: 1800
27
FTE as of 2015. 5,000
28
FTE by 2020
A more sophisticated
entertainment and retail
30
offer . Te Papa North
campus proposed
Wiri, Airport, East
Tamaki, Highbrook,
Takanini, Drury South
31
Southern Auckland

Health and Science,
Food and Nutrition,
Technology and
Enterprise, and Human
and Social Development
Heavy Rail, buses,
Motorways, Arterial
Roads
Manukau Transport
Interchange (delayed),
walking and cycling
connections especially
to Manukau Station
Metropolitan Centre
under Auckland Plan
and Proposed Auckland
Unitary Plan.
Proposed for new Super
Metropolitan Centre
zone concept

27

Full Time Equivalent (Student)
http://voakl.net/2015/07/21/south-auckland-the-cotinued-rising-jewel-in-aucklands-crownbetterauckland/
29
See 42.f of this document
30
See 25.c.III of this document
31
Southern Auckland defined from Otahuhu at Portage Road south to the border with the Waikato
28

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45. Thus 10.34 of Mr Bonis’s evidence against a further tier of Centres in the proposed
Unitary Plan32 in my opinion is redundant for two reasons:
a. Again the Super Metropolitan Centre was not designed to lift a Metropolitan
Centre to the level equivalent of the main City Centre Zone. The Super
Metropolitan Centre sits as an independent hierarchy although its objectives
and policies are blended from both the City Centre Zone and the Metropolitan
Centre Zone. However, that said given the unique geography, form and
function (including social function such as Manukau being part of the
Auckland Plan Southern Initiative33) of the Super Metropolitan Centre(s) the
Objectives and Policies do incorporate specifics such as:
i. For Manukau Super Metropolitan Centre: Support for the social policy
initiatives and approach reflected in the broader Manukau Community
and the opportunities the Manukau City Centre derives to support
these policies34
b.

The Super Metropolitan Centre like Parramatta as Sydney’s second Central
Business District is designed to be complementary to their respective main
City Centres not compete against it. Again this is due unique geographies of
the Super Metropolitan Centres like Parramatta on offer and should be
utilised to full potential. In regards to blurring distinctions between a Super
Metropolitan Centre and the City Centre, if that is going to happen that is
because a Metropolitan or Super Metropolitan Centre has evolved over time
to act more like the City Centre Zone. If that does happen let it and plan
around it. But from what Council is saying in 10.34 it seems they are trying to
shimmy or rather box the Centres into artificial boxes set by the Unitary Plan
rather than allowing a Centre to evolve naturally (if it does).

In regards to placing height limits onto the Metropolitan Centres
46. Matthew Bonis on behalf of Auckland Council stated:
a. 10.9 As I understand the submission, the key point of difference between the
proposed zone and the Metropolitan Centre zone is unlimited height in the
former. In my view the Metropolitan Centre zone enables significant growth
and intensification above existing levels of development and also allows an
32

Point 22.c – Page 11 of this document (quoted)
https://www.scribd.com/doc/269098570/SNAP-Southern-Intitiative
34
Page 55 – Object 6
33

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 41

unlimited scope for commercial activities. If the Panel considers the height
limits in the Metropolitan Centre zone too restrictive then this can be
amended, without the need for a new zone. I do not consider that a new
zone of the type described is necessary at this stage of Auckland’s
development.
47. Trevor Stewart Mackie on behalf of Auckland Council stated:
a. Metropolitan Centre unlimited height, increase height limit, reduce height limit,
retain
b. Submitter requests
i. 10.34. Submissions sought deletion of the height control or unlimited
height in the Metropolitan Centres. Reasons given are that: the taller
the better, by increasing the number of residences and reducing the
need for transport options with people living on or at their workplace;
the PAUP has effectively down-zoned from existing Business 3 zone
(inferred Takapuna), which will stifle development; we currently have
one of the least densely populated cities, to grow we need to focus on
building up, not out; we will not get the desired outcome for our city if
we bow down to the anti-development and anti-progress lobby groups;
and unlimited height is necessary for major satellite cities outside the
CBD. Patrick Fontein (6282-7) seeks acknowledgement that the
Metropolitan Centres have had their building height and development
potential reduced, and considers that the PAUP falls short of the
intensification targets.
ii. 10.35. Louis Mayo (4797-99) is seeking a 96m (24 storey) height limit
in the Metropolitan Centres. Cooper and Associates (6042-35) seek a
30 storey limit. Nationwide Properties Limited and Estate David
Berryman (1125-1) seek a reduction in the height limit to 50m. Other
submissions 27 seek retention of the notified provision for height, as
the zone reflects the operative plan provisions which enable a variety
of activity supporting the transport network. Hartwig Clasen (5219- 46)
sought a reduction in height limits in the Metropolitan Centres except
for Newmarket, to avoid high rise buildings affecting the character and
living quality of Auckland.
c. Discussion
Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 42

i. 10.36. In introducing the 72.5m height limit there is a reduction for part
of Takapuna, and for parts or all of other areas that had unlimited
height in the legacy plans. Takapuna Area C (or Sub-precinct C) had
theoretically unlimited height but was constrained by a floor area ratio
(gross floor area limited to 3.5 times the area of the site), HRB
controls applying from the nearest residential zone boundary, and
could have a tower footprint of only 40% of its site area. The proposed
Takapuna 1 precinct controls theoretically allow unlimited height but
have a 6:1 FAR control. There are also constraints on height and
resource consents for tall structures in other centres. There has been
little uptake in the unlimited height provisions for Takapuna, Mangere,
Manurewa, Otara, Pakuranga, Papatoetoe, Te Atatu North, Albany,
Botany, Henderson, Manukau, Glen Eden and Highland Park. That is
not a reason on its own to introduce a height limit, as there have been
resource consent applications and a few taller buildings constructed.
The PAUP does not have a floor area ratio control limiting
development, and the height-in-relation-to-boundary control now only
applies up to 30m from a residential or public open space zone
boundary.
ii. 10.37. 72.5m as a zone-wide control is not particularly limiting in my
opinion, considering greater height is a restricted discretionary activity.
I consider it reasonable to assess potential effects of visual amenity,
bulk dominance and shading from the upper parts of such taller
buildings, individually as well as cumulatively as the centres grow, as
well as landscape and landmark effects.
d. Conclusion
i. 10.38. In my opinion the 72.5m height development control should be
retained in Metropolitan Centres. In some cases it will be overridden
by overlay or precinct height provisions, or by restricted activity
resource consent for taller buildings.
48. In regard to Mr Bonis’s evidence above in point 48.a I will address it in two parts. The
part in bold I will address at the end as I conclude this evidence document up. The

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 43

part in non-bold I will address here alongside Mr Mackie’s evidence (point 48).
49. Yes I agree with Mr Bonis on his point35that the Metropolitan Centres do enable
significant growth and (in theory) unlimited scope for commercial activities. The two
key differences between the Super Metropolitan Centres and the Metropolitan
Centres are geography and the Objectives and Policies which reflect the
characteristics of the Super Metropolitan and Metropolitan Centres.
50. Where Mr Bonis states “If the Panel considers the height limits in the Metropolitan
Centre zone too restrictive then this can be amended, without the need for a new
zone36”, looking at the evidence Mr Mackie provided on behalf of Council in regards
to height for the Metropolitan Centres37, I take a neutral position on whether the
Independent Unitary Plan Hearings Panel decides to lift any height restrictions on the
eight Metropolitan Centres not proposed to become Super Metropolitan Centres38.
Again for absolute certainty my neutrality is framed around those two key differences
between the Super Metropolitan Centre and the Metropolitan Centre.
51. However, I do urge caution where Mr Bonis in Point 52. (in italics) did state “without
need for a new zone” as while the Super Metropolitan Centres do call for unlimited
height the entire concept around the Super Metropolitan Centre is just not around
height. Again the Super Metropolitan Centres have different geographies thus
different Objectives and Policies better suited to them. Two examples of those
(different) Objectives/Policies only found with the Super Metropolitan Centres39:
a. To serve as complementary to the main City Centre Zone in servicing core
parts of the region (Manukau serving Southern Auckland and arguably the
northern Waikato, and Albany in time serving the North Shore, Rodney and
Northland), as well as reflecting the linear Geography from Auckland.
b. For Manukau Super Metropolitan Centre: Support for the social policy
initiatives and approach reflected in the broader Manukau Community and the
opportunities the Manukau City Centre derives to support these policies

35

Evidence Bonis, Paragraph 10.9, page. 43
As above
37
Evidence Mackie, Paragraphs 10.34 – 10.37, pages. 25-26
38
Manukau City Centre, and Albany are proposed in my submission (1606) to become the two Super
Metropolitan Centres
39
Benjamin Ross 1606. Page. 39
36

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 44

52. Those social policy initiatives would be (as of current) the Auckland Plan’s second
transformational directive: The Southern Initiative.

53. I will as a reference paste in below an excerpt from the Impacts of Planning Rules,
Regulations, Uncertainty and Delay on Residential Property Development report for
the Treasury and MBIE written in December, 2014 by the Motu Economic and Public
Policy Research unit40. The excerpt is on height rules having possible impacts on the
cost of development.
Table 2: Cost Impacts of Planning Rules and Regulations* Rule and
Regulations
Increase in Cost per Dwelling1
Apartments
Building height limits

$18,000 to $32,000

Subdivisions
See note 2

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.

54. 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).41 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
40

https://www.scribd.com/doc/253323001/The-Impacts-of-Planning-Rules-Regulations-Uncertainty-andDelay-on-Residential-Property-Development
41
I have read the Interim guidance text for Topic 020 Viewshafts - released 17 July 2015

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 45

development in which the capacity was reduced by 0%, it required the
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.

55. Given that per the 013 RPS Urban Growth - Expert Conference Outcome Report Residential Developable Capacity for Auckland report42 said that the Proposed
Auckland Unitary Plan as it stands would only allow 11%43 of the 400,000 proposed
dwellings needed in the operative Auckland Plan, and that if you look on the maps of
that report (page 66 (of 69) onwards) only Takapuna Metropolitan Centre was
deemed viable or rather “ready” for residential development. The other nine
Metropolitan Centres were deemed not viable to undertake residential construction
and it has to be asked is the Proposed Auckland Unitary Plan causing that situation?

42

https://www.scribd.com/doc/272429202/013-RPS-Urban-Growth-Expert-Conference-Outcome-ReportResidential-Developable-Capacity-for-Auckland
43
Page 5 of the report as linked on footnote 42

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

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Final Remarks
56. Finally I go back to the comment from Mr Bonis (point 48.a) that I had placed in bold:
“I do not consider that a new zone of the type described is necessary at this
stage of Auckland’s development.”

57. As I see it Auckland Council needs to be very specific on two aspects of that quote
for sake of clarity now and for the future of Auckland.
a. Does the Council support the Super Metropolitan Centre Zone concept
(regardless of timing)?
b. As for timing when would Council consider the Super Metropolitan Centre
necessary as part of Auckland’s development?

58. Given that
a. the Proposed Auckland Unitary Plan falls short in enabling enough capacity
for residential dwellings over the life of the Plan and
b. the potential Albany and Manukau City Centre a Super Metropolitan Centres
to not only help fulfil the realisations on the Auckland Plan but remedy some
of the development capacity shortfalls noted in this document.

59. If the Panel does believe a Super Metropolitan Centre zone should be inserted into
the Proposed Auckland Unitary Plan, may it please the Panel in lieu of Points 58 and
59 above and the evidence provided in this document that an Expert Conference
should be facilitated. The expert conference would between mutual parties work
through the details including development and notification controls for the Super
Metropolitan Centre ready for Council consideration.

Benjamin Ross
August 11, 2015

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Topic 051Centres Zones

Page 47

Attachment A
Updated Activity Table (I.3.1.1) as a result of mediation on Topic 051 Centres Zones
Activity

Super
Metro
Centre
Zone

Activities not provided for

Metro
Centre
zone

Town
Centre
zone

Local
Centre
zone

Neighbourhood
Centre zone

Mixed
Use zone

General
Business
zone

Business
Park zone

NC

NC

NC

NC

NC

NC

NC

NC

Dwellings

P

P

P

P

P

P

NC

NC

Conversion of a building
or part of a building to
dwellings, visitor
accommodation
or boarding houses

RD

RD

RD

RD

RD

RD

NC

NC

Retirement villages

D RD

DP

DP

D

D

DP

NC

NC

Supported residential

P

P

P

P

P

P

NC

NC

P

P

P

P

P

P

NC

RD

Commercial services

P

P

P

P

P

P

P

P

Commercial sexual

P

P

P

P

P

P

D

NC

services
Conference facilities

P

P

D

D

D

D

D

D

Department stores

P

P

P

RD

NC

D

RD

NC

Drive-through
restaurant facilities

RD P

RD

RD

RD

D

P

P

NC

Entertainment

P

P

P

D

D

P

P

NC

facilities
Food and beverage

P

P

P

P

P

P

P

P

Funeral directors’

P

P

P

P

D

P

D

NC

premises
Garden centres

P

P

P

D

NC

D

RD P

D

Marine retail

P

P

P

D

NC

D

RD P

D

Motor vehicle sales

RD

P

P

D

NC

D

RD P

D

Offices up to 500m²

P

P

P

P

P

P

P

P

Accommodation

care
Visitor accommodation
and
boarding houses
Commerce

GFA per site tenancy

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 48

Activity

Super
Metro
Centre
Zone

Offices greater than

Metro
Centre
zone

Town
Centre
zone

Local
Centre
zone

Neighbourhood
Centre zone

Mixed
Use zone

General
Business
zone

Business
Park zone

P

P

P

NC D

NC

D

D

P

P

P

P

P

P

P

D

D

P

P

P

P

D

D

D

500m² GFA per site
tenancy
Retail up to 200m2

GFA per site tenancy
Retail exceeding 200m2 P
per tenancy and up to
450m²
GFA per site tenancy
Retail greater than

P

P

P

RD

NC

D

RD P

D

450m² GFA per site
tenancy
Service stations

D

D

D

D

D

D

D

NC

Storage and lock-up

D

D

D

NC

NC

D

P

D

facilities
Supermarkets up to
P
2000m² GFA per tenancy

P

P

P

NC

D

D

NC

Supermarkets
P
exceeding 2000m2
per tenancy and up to
4000m² GFA per site
tenancy
Supermarkets greater
P
than 4000m² GFA per
site tenancy

P

P

RD

NC

D

D

NC

P

P

RD

NC

D

NC

NC

Trade suppliers

RD

P

P

D

NC

D

RD P

D

Artworks

P

P

P

P

P

P

P

P

Care centres

P

P

P

P

P

P

D

P

Community facilities

P

P

P

P

D

P

P

D

Education facilities

P

P

P

P

D

P

PD

D

Emergency services

D

D

D

D

NC

D

D

D

Healthcare facilities

P

P

P

P

P

P

D

D

Hospitals

D

D

D

NC

NC

D

D

NC

Justice facilities

P

P

P

D

NC

D

D

D

Recreation facility

P

P

P

P

D

P

P

D

Tertiary education
facilities
Industry

P

P

P

RD

D

P

D

D

Community

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 49

Activity

Super
Metro
Centre
Zone

Metro
Centre
zone

Town
Centre
zone

Local
Centre
zone

Neighbourhood
Centre zone

Mixed
Use zone

General
Business
zone

Business
Park zone

Artisan industries

P

P

P

P

P

P

P

P

Industrial activities

NC

NC

NC

NC

NC

NC

P

NC

Industrial laboratories

P RD

P

P

P

NC

P

P

P

Light manufacturing

RD

P

P

P

NC

P

P

P

and servicing
Repair and

RD

P

P

P

P

P

P

P

maintenance services
Waste management

NC

NC

NC

NC

NC

NC

NC

NC

facilities
Warehousing and

RD

P

P

P

NC

P

P

P

P

P

P

P

D

P

P

D

New buildings

RD

RD

RD

RD

RD

RD

RD

RD

Demolition of buildings

RD C

RD C

P

P

P

P

P

P

Alterations to building
facades that are less
than:
- 10 25 per cent of its
total surface area, or
2
- 15m² 25m

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

RD

RD

RD

RD

RD

RD

RD

RD

storage
Mana Whenua
Marae complex
Development

whichever is the lesser

Additions to buildings
that are less than:
- 10 25 per cent of the
existing GFA of the
building, or
- 250m²
whichever is the lesser
Internal alterations to
buildings
Additions and
alterations to buildings
not otherwise provided
for

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 50

Attachment B
Updated Building Height Table (I.3.4.2 Table 1) as a result of mediation on Topic 051 (Centres
Zone)

Table 1

Zone

Total building height Occupiable building

Additional height for

height

roof form

Super Metropolitan Centre

Unlimited

Unlimited

-

Metropolitan centre

72.5m

72.5m

-

Town Centre

As shown on the Additional Zone Height Control layer on the planning

Local centre

maps
18m

16m

2m

Neighbourhood centre

13m

11m

2m

Mixed use

18m

16m

2m

General Business

16.5m

16.5m

-

Business Park

20.5m

20.5m

-

Benjamin Ross. Primary Evidence

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Attachment C
Unitary Plan Map Changes – Manukau and Manukau City Centre Area

Reference Map

Renaming the Residential and Business Zones in Manukau and Manukau City Centre
Relief Sort

Super Metropolitan Centre Zone

Map

Replaces existing Draft Unitary

Reference

Plan Zone

A

Metropolitan Centre

Note:

Other changes sought in above map will be covered in Topics 080 and 081

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

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Attachment D
Relief sought to be inserted into the Proposed Unitary Plan (as part of my original
submission 1606-2)

D.3.3 Super Metropolitan Centre zone
Zone Description
The Super Metropolitan Centre is the second highest in the centres hierarchy after the City
Centre zone. While the City Centre zone recognises the pivotal role in Auckland’s present
and future successes, the Super Metropolitan Centre can also play such a future pivotal role.
More intensive than a Metropolitan Centre in development and catchment but less so than
the City Centre Zone, the Super Metropolitan Centre will act as smaller scale complementary
regional hub and international centre in: business, learning, innovation, industry,
entertainment, retail and hospitality, culture and urban living.
To improve the vibe of the Super Metropolitan Centre environment the zone permits a wide
range of activities to establish in most parts of the SMC. The zone also manages activities
that have the potential to adversely affect the amenity of the Super Metropolitan Centre. The
Unitary Plan enables the second greatest level of development in terms of height and floor
area to occur in the Super Metropolitan Centre (behind the City Centre zone). Within the
Super Metropolitan Centre (Manukau and Albany) itself, development potential is
concentrated in the core central business district. Development potential reduces towards
the respective ridgelines (e.g. Redoubt Hill) and transitions to lower heights towards its
surrounding flanks (e.g. bordering Papatoetoe, Manurewa/Browns Road, Wiri and Auckland
International Airport.
The Super Metropolitan Centre zone manages the scale of development in order to protect
important sunlight admission to parks and public spaces, and significant views to the
volcanic cones and other landmarks. The significant height and scale of buildings in SMC
increases their visibility from many places, affecting the quality of both public and private
views at local and citywide scales. In addition to managing the scale of development, the
zone manages the quality of building design to ensure new buildings successfully integrate
with the SMC’s existing built form and public realm to create an attractive and recognisable
skyline.

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

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The Super Metropolitan Centre makes an important contribution to our sense of
identity whether it is international, national, regional or sub-regional in sense identity
construction.
A Super Metropolitan Centre does have comparisons also with the lower order Metropolitan
Centres in acting as hubs for a wide range of activities including commercial, leisure, high
density residential, cultural, community and civic services – but also including tourism
activities. Super Metropolitan Centres development and activities are more intense level than
an existing Metropolitan Centre but not as intense as a City Centre Zone as mentioned
above.
In further reinforcement to the urban-scape of the Super Metropolitan Centre while still
recognising its higher order hierarchy, the SMC again must have some street frontages
within the zone are subject to a Key Retail Frontage or General Commercial Frontage
overlay. Key retail streets are the focal point of pedestrian activity within the centre. General
commercial streets play a supporting role. Development fronting these streets is expected to
reinforce this function. Rules for the overlay are incorporated in the zone rules. New
development within the zone requires resource consent in order to ensure that it is designed
to a high standard which enhances the quality of the centre’s public realm. This recognises
that the Super Metropolitan Centre is a blend of the higher order City Centre zone owing to
sense of identity and greater intensity of development, production and catchment; as well as
the lower order Metropolitan Centre zone in the fact an SMC still will act as the “sub
regional” (as well as wider regional) “place” as well.
In saying that a Super Metropolitan Centre is viewed as a complementary City Centre area
in-lieu of the existing City Centre Zone by some as part of their sense of identity attached to
the SMC.

Objectives
1. To serve as complementary to the main City Centre Zone in servicing core parts of
the region (Manukau serving Southern Auckland and arguably the northern Waikato,
and Albany in time serving the North Shore, Rodney and Northland), as well as
reflecting the linear Geography from Auckland.44*

44

See Golden Triangle Note on page: 43

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Topic 051Centres Zones

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2. The Super Metropolitan Centre is an attractive place to live, work and visit with a 24hour vibrant and vital business, entertainment and retail areas.
3. Development in the Super Metropolitan Centres is managed to accommodate growth
and the second greatest level intensity of development in Auckland (the City Centre
Zone being the first) and New Zealand while respecting its surrounding physical
geography features such as hills, volcanoes, streams, lakes and harbours
4. A hub of an integrated regional (and inter-regional)*45 transport system is located
within the Super Metropolitan Centre and the Super Metropolitan Centre is
accessible by a range of transport modes.
5. Key retail streets are the focal point of pedestrian activity, with identified general
commercial streets supporting this role. Malls continue to act as centre anchor points
but are retrofitted to incorporate functionality with the surrounding Super Metropolitan
Centre rather than operating in their isolation away from the wider surroundings of
the Super Metropolitan Centre as they are now
6. For Manukau Super Metropolitan Centre: Support for the social policy initiatives and
approach reflected in the broader Manukau Community and the opportunities the
Manukau City Centre derives to support these policies

Policies
Land use and development activities
1. Provide for a wide range and diverse mix of activities that enhance the vitality,
vibrancy and amenity of the city centre including:
a. commercial and residential activities
b. arts, entertainment, events, civic and community functions
c. high-quality visitor experiences, visitor accommodation and associated
services
d. learning, teaching and research activities, with a particular concentration in
the learning precinct.
2. Enable a significant and diverse residential population to establish within a range
of living environments and housing sizes.

45

See Golden Triangle Note on page: 43

Benjamin Ross. Primary Evidence

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3. Enable the significant concentration of office activity in Auckland (behind the City
Centre Zone) to locate in the Super Metropolitan Centre by providing an environment
attractive to office workers.
4. Provide for a wide range of retail activities throughout the Super Metropolitan
Centre while maintaining and enhancing the vitality, vibrancy and amenity of core retail
areas within the Super Metropolitan Centre and centres outside of the Super Metropolitan
Centre. In particular:
a. enable small-scale, niche retail to occur throughout the Super Metropolitan
Centre
b. Encourage supermarkets and department stores within metropolitan
centres by recognising:
i. the positive contribution these activities make to centre viability and
function, and
ii. Designs that positively contribute to the streetscape and character
of their surroundings, having regard to the functional requirements of these
activities.
c. avoid large department stores and integrated retail developments locating
outside the core retail area where they would adversely affect the amenity, vitality
and viability of core retail areas within the Super Metropolitan City Centre and/or
centres outside of the Super Metropolitan Centre.
5. Support the development of public transport, pedestrian and cycle networks and
the ability to change transport modes.
6. Identify and encourage specific outcomes in areas of the Super Metropolitan
Centre that relate to:
a. distinctive built character; and/or
b. concentration of particular activities; and/or
c. activities that have specific functional requirements; and/or
d. significant transformational development opportunities.

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7. Use framework plans to encourage comprehensive and integrated development of
key development sites or precincts in the Super Metropolitan centre.
8. Recognise the reverse sensitivity effects of the airport flight path can complicate
(but not inhibit entirely) residential developments within the Manukau Super Metropolitan
Centre.

Super Metropolitan Centre form
9. Enable the tallest buildings and the greatest density of development to occur in the
core Super Metropolitan Centre district (subject to overlays such as the flight path).
10. Manage adverse effects associated with building height by:
a. requiring building height and development densities to transition down to
neighbourhoods adjoining the Super Metropolitan Centre
b. protecting sunlight to identified public open spaces and view shafts
c. requiring the height and form of new buildings to respect the surrounding
physical geography form of the Super Metropolitan Centre and the existing
established or proposed character of precincts
d. managing the scale and form of buildings to avoid adverse dominance
and/or amenity effects on streets and public open space.
11. Maximise light and outlook around buildings.
12. Encourage public amenities to be provided within developments where possible,
including publicly accessible open space, works of art and through-site links.

Public realm
13. Require building and development of the highest quality that contributes to the
city centre’s role as an international centre for business, learning, innovation, entertainment,
culture and urban living.
14. Require building frontages along identified public open spaces and streets to be
designed in a way that provides a sense of intimacy, character and enclosure at street level.
Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 57

16. Enable high quality and interconnected public open spaces that are accessible
and provide spaces for recreational opportunities, facilities and events.

Other
17. Recognise the importance of particular streets identified on the Key Retail and
General Commercial Frontage overlay as primary places for public interaction:
a. by requiring buildings with frontages to these streets to:
i. provide greater ground floor heights to maximise building
adaptability to a range of uses
ii. avoid blank walls
iii. provide easily accessible pedestrian entrances.
b. and in addition, require building frontages subject to the Key Retail
Frontage overlay to:
i. maximise glazing
ii. erect frontages of sufficient height to frame the street
iii. provide weather protection to pedestrians
iv. avoid new vehicle crossings.
18. In the terms of the Manukau Super Metropolitan Centre: Recognise and facilitate
the fact that the Manukau Super Metropolitan Centre is the “commercial” hub supporting the
southern Auckland industrial complex in: Wiri, Takanini, Drury South, Glenbrook, East
Tamaki, as well as the rural sector of Southern Auckland and northern Waikato

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Altered Definition for REGIONAL AND DISTRICT OBJECTIVES AND POLICIES»
Chapter D: Zone objectives and policies»3 Business zones» Metropolitan Centre zone
(after inclusion of Super Metropolitan Centre)

D.3.3 Metropolitan Centre
D.3.4 Metropolitan Centre

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 59

Benjamin Ross. Primary Evidence

Topic 051Centres Zones

Page 60