Proposed District Plan The Visitor Accommodation Sub-Zone Please refer to Map 33 of the proposed District Plan. I draw your attention to the Visitor Accommodation Sub-Zone that faces on to Yewllet Cres and Lake Ave. This sub-zone was created to allow THC to build a hotel here many years ago when the government of the day was investing in Tourism and building hotels. The Hotel operation has long ago ceased and the sub-zone now houses a variety of activities that are housed mainly in buildings that formed part of the original hotel. The remaining boundaries of this sub-zone are bordered by a low density residential zone. There are a substantial number of residences along the north eastern boundary of this Visitor Accommodation Sub – Zone and their outlook, sunshine and in particular views and consequently property values have always been protected by a height restriction applied to this sub-zone. Please refer to Chapter 7, section 5.6.3 of the operative district plan. In particular paragraphs (iii) (a) (vii) and (b) (vi). This reads; - “The maximum height for buildings located within the Visitor Accommodation Sub-Zone located on Lake Ave, Frankton shall be 7 metres and in addition no building or part of any building shall protrude through a horizontal plane drawn at RL 343.50 masl (being 443.50m, Otago Datum)” (You will note that the same rule is applied to flat sites and sloping sites.) This rule was added to the district plan after the affected residents spent some considerable time and money to have the existing height restrictions reinstated when they realised that it had been omitted after the current district plan was written. We hope that the affected residents will not have to repeat the process again. The proposed District Plan appears to have no rules that govern building heights; setbacks etc. for this Visitor Accommodation Sub-Zone and any development is to be controlled only by those rules that apply to Low Density Residential Zones. Accordingly I submit that the current article 7.5.6.3 (iii) (a) (vii) in the operative District Plan be incorporated in any District Plan that is adopted by Council. Low Density Residential Zone Also with reference to Map 33 of the Proposed District Plan with reference to the low density residential zone, in particular the area known as “Old Frankton”. This is a very well established residential area with very few undeveloped sites remaining and many of the holiday style houses that were built in this area have been replaced with quality permanent residences. Many of these titles would be considered sloping by definition as prescribed in Chapter 2 of the Proposed District Plan. Under the proposed low density zone rules these properties will not be subject to any recession planes and only controlled by a 7 metre height restriction. Should the proposed new low density residential rules be adopted this would allow a seven metre wall to be built 2 metres from a boundary adjacent to an existing residence in the case of any new build or redevelopment in this area. This could potentially have a significant effect on outlook, privacy, views, sunshine and property values of existing dwellings. Because the existing properties were constructed to comply with the operative District Plan and the required setbacks, recession planes and height restrictions contained in those rules, it will be impossible for owners to mitigate any effects of any potential 7 metre walls built as part of any redevelopment. I note rule 7.2.2 of the proposed district plan states; “Objective;- Ensure protection of the amenity values in recognition of the zone’s lower intensity character, whilst providing for subtle and low impact change” With the proposed increase in density to allow one residential unit per 300m2 per net site area (Rule 7.5.6), and the proposed relaxation of the recession plans this would allow redevelopment that would have a significant impact on the amenity value of the zone and would appear to be in contradiction of the above objective. Redevelopment permitted as a result of the proposed rules changes will have a significant impact on the amenity value of existing properties with the loss of outlook, privacy, views and subsequent property values. The increase in housing density will also have an impact on noise, parking and traffic. All which are detrimental to the amenity value that the area currently enjoys. Any extra housing that will be built as a relaxation of the recession planes and density rules will be minimal in the “Old Frankton” area due to the area already well established and developed and therefore unlikely to achieve the Council objective to add infill housing. The net result can only result in a depreciation of amenity value. In order to keep the integrity and uniformity of this high value residential zone intact, it is my submission that the Council look to maintain the current rules as outlined in the Operative District Plan regarding setbacks, recession places and height controls for the Low Density Residential Zone of “Old Frankton” in particular. The same arguments would also be applicable to other high value residential areas that are already well established and fully developed. Overall it appears that the proposed Low Density Residential Zone Rules are a Clayton’s way of re-zoning to medium density residential, when, perhaps two types of Low Density Residential Zoning should be considered? It also appears to be a knee- jerk reaction to the current housing crisis. On a further note, any extra housing densities in existing areas must also impact on existing infrastructure and this should also be considered as part of the District Plan review. For example, extra housing equates to more parking and traffic etc., and should be considered as part of the Transport Plan.