NEW ZEALAND QUEENSTOWN LAKE DISTRICT COUNCIL
IN THE MATTER OF THE QUEENSTOWN LAKES
DISTRICT COUNCIL DISTRICT PLAN and
IN THE MATTER OF THE WANAKA PROPOSED
MEDIUM DENSITY RESIDENTIAL ZONE
Medium Density Residential Zone 8.
INTRODUCTION
It is proposed to establish a Medium Density Residential Zone for residential development at increased densities primarily “to accommodate residential land uses, enhance residential amenities, supporting an adjoining town centre and not to impact on the primary role of the zone to provide housing supply”.
It is proposed that zone controls will “ensure reasonable amenity protection”.
An incentive is proposed for sustainable building design “to ensure practical and timely realisation of housing supply”.
It is pr oposed that visitor accommodation within the zone will be “sensitively designed with regard to its setting and to protect the privacy and amenity of guests and nearby residential users”.
These submissions are primarily but not exclusively in relation to the proposed Wanaka Medium Density
Residential Zone.
The Submitter notes that the proposals state that they will provide “a positive contribution to the environment through urban design solutions which complement and enhance local character, heritage and i dentity”.
The Proposals also state that “the mass of building shall be broken down through variation in facades and materials, roof form, building separation and recessions or other techniques to reduce the dominance on part of streets, parks, and neighbouring properties”.
Our submission is that while the goals of the plan may be admirable, there appears on the one hand to be little indication in the District Plan as to how this might be achieved. On the other hand, areas of the
District Plan proposals are demonstrably in direct conflict with these objectives; the glaring example, being the highly aggressive recession planes of 8.5.6 and minimum boundary set backs in 8.5.8.
It is submitted that clearly significant further work and amendment of the plan will be needed to meet the plan objectives noted.
DETAILS :
At 8.2.3.1 reference is made to non-notification and variation of resource consent applications where building form and design is able to achieve certification of a minimum 6 star level using the NZ Green Building Council Home Star tool.
No clear basis for this provision is given, specifically why a sustainable building should be able to achieve these special privileges. For example, in relation to the minimum size dwelling under
8.5.5. This provision appears to be significantly open to a result diametrically opposed to the plan objectives. There also appears to be little or no justification for it. For example, potential issues could arise in parking 8.2.1 2, building coverage 8.5.4, density 8.5.5 and in particular in the treatment of recession planes and minimum boundary set backs 8.5.6 and 8.5.8.
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At 8.2.7.4., a proposal for reduction in parking requirements where a site is located within 400 metres of either a bus stop or the edge of a town centre zone appear to be, on the contrary, destined to reduce amenity values and oppose the other objectives of the zone purpose noted above in relation to 8.1. In the Medium Density Residential Zone, on-street parking is already a significant issue, for example in heavy street private and rental car parking adjacent to accommodation providers, obstructive parking in cul de sacs, and the like. It ia submitted these effects are the antithesis of “enhancing amenity values” for residents wishing to park themselves, and for visitors seeking parking without being preyed on by enforcement authorities attempting to deal with the problems this proposal will cause.
To allow a “short cut” and unlimited activity based on a compliance unconnected with density or reduced dwelling size appears potentially contrary to plan objectives and poorly concieved.
8.5.5 Density. It is proposed that the maximum site density shall be one residential dwelling or unit per 250sqm net site area. This appears reasonable. H owever, the proposal that ”this rule shall not apply where the development can achieve specification to a minimum 6- star level using the NZ Green Building Council Home Star rule” is not. It begs the question of, what density does apply? None? Clearly further work is required here. This provision is simply open to litigation and developments contrary to the objectives of the zone purpose which Council may fail to be able to control. It is submitted that this provision is wholly inappropriate. It is noted that there is a provision for a 6 year window however, again there appears to be no nexus for this whatsoever.
It is submitted that over a 6 year period, significant and irreparable damage the amenity value in the proposed zone could occur, in particular, the amenity value of residential users through issues as inappropriate densities, parking, shading, noise, air quality etc. It is submitted that there appears to be no benefit to Council or the community for such a provision to exist in the plan.
It is most strongly submitted that the density exemption provisions under 8.5.5 be reconsidered, in particular in the light of the fact that the area or proposed to be zoned as medium density is essentially almost exclusively a residential zone. It is submitted that the reference to the Home
Star tool creates a potential disadvantageous removal of development control in the hands of
Council.
8.2.7.4. It is submitted that this proposal to allow a reduction in parking requirements where a site is located within 400m of either a bus stop or edge of a town centre zone, if adopted, will merely create significant further on-street parking and a direct loss of amenity values in direct conflict with the objectives of the plan. Almost no residents or visitors to Wanaka now or will in the foreseeable future, predominantly use public transport to arriving in Wanaka. Wanaka is a remote destination with little if any mass transport infrastructure Accordingly such a provision will merely shift responsibility for parking into the streets, exacerbating what is already an issue around accommodation zones. This could also potentially also be compounded by relaxation of density requirements, should building fit within the relatively relaxed provisions of the Home Star tool noted above. It is submitted that this provision should be seen as misconceived. It should be reconsidered.
The proposed Medium Density Residential Zone also includes in the main significant areas of current residential development. The boundaries of the proposed zone will tend to encourage commercial development or non-residential development of significantly higher density than is currently, with significant amenity loss to the residential users, and ultimately also to visitors; to say little of parking and other related losses. Whilst it appears that some expansion of a zone is to some extent appropriate adjacent the commercial center, it is submitted that it is preferred to have more stringent significant controls to retain the amenity value of the area, particularly as it progresses eastward toward the characteristically Wanaka scenic Cardrona Moraine, Bullock
Creek, upper Helwick Street and East Tenby Street regions. Existing developments allowed by
Council under the present criteria appear to sit reasonably well with residential users. it is submitted that in the identified area at least, there is no strong requirement for change.
8.5.6. Recession planes. The current recession plane requirement is up 2.5 metres and in at 25 degrees. The proposed Medium Density Residential Zone recession planes can only be described as extremely aggressive!
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8.5.6.1. Northern boundaries; 2.5 metres and 55 degrees!
8.5.6.2. Western and Eastern boundaries; 2.5 metres and 45 degrees!
8.5.6.3. Southern boundaries; 2.5 metres and 35 degrees. It is submitted that such recession planes can only lead to a very significant loss of amenity value to any neighbouring users and will seriously leave exposed or fail to protect the privacy and amenity of residential users and guests, directly in conflict with the plan objectives.
At 8.5.6.5 it is additionally proposed that the above recession planes do not apply to site boundaries adjoining the town centre zone, fronting the road o r a reserve or park”. The question remains as to what does apply? This will obviously also depend on the definition of “a park” or “a reserve” ; also and most properties “front the road”? It is submitted that 8.5.6 requires significant rework, a reduction of the highly aggressive Recession planes and reconsideration of
8.5.6.5 to more appropriate, or a significant reduction in the area of the zone where such an exemption could apply, taking specifically into account the amenities value of the residential users and visitors in the areain accordance with the proposed objectives.
It is noted that despite low sun angles encountered in the region which originally justified the up
2.5 metres and in at 25 degree recession planes, the highly aggressive recession planes proposed are significantly more aggressive than residential zones in the northern latitudes of
New Zealand, where sun angles are significantly higher.
CONCLUSIONS
The Medium Density Residential Zone proposal is supported by the submitters, except where indicated in the foregoing, where through reasons of either the proposed boundaries of the zone, through the provisions relating to density 8.5.5, recession planes 8.5.6 and in relation to parking
8.2.7.3 and 8.2.7.4, conflict with the objectives of the zone purpose of 8.1, and will adversely impact on the primary role of the zone to provide housing supply whilst ensuring reasonable amenity protection and protecting the privacy and amenity of guests and residential users.
It is submitted that the Home Star Tool as is proposed in 8.2.3, 8.2.5 is prone to abuse and forced unhappy compromise and should be abandoned.
It is submitted that the proposed area for the zone; which is essentially a part of the traditional and historical Wanaka town precinct requires sensitive care in its development so as to preserve actual character of the precinct which gives Wanaka its identity.
It is hoped by the submitters that while of nececity focussing upon the negative aspects of the plan are seen as constructive and of assistance in enabling further reconsideration, adjustment of the plan and its boundaries of the zone, to areas where sensitivities identified may avoid conflict with the plan objectives and have less impact on the amenity value for residential users in the manner outlined.
The submitter requests the opportunity to be heard in respect of this matter if an opportunity arises and would be pleased to provide additional background comment or clarification in respect of this submission if required, on request.
Trustee – Philip Thoreau
Full & Bye Family Trust
1 Tenby Street
Wanaka philip@thoreau.co.nz
22 October 2015
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