8040 fndc tifs and parking s32 - viastrada.nzviastrada.nz/sites/default/files/8040 fndc tr...

8040 FNDC Plan Change TIF and Parking

FAR NORTH DISTRICT COUNCILPLAN CHANGE

TRAFFIC INTENSITY AND PARKING

ViaStrada Ltd

STATUS: DRAFT

29 JUNE 2009

8040 FNDC TIFs and Parking

Background for s32 Report.

1 of 39

This document has been prepared for the benefit of Far North District Council. No liability is accepted by ViaStrada Ltd, any of its employees or sub-consultants with respect to its use by any other person.

Quality Assurance Statement

ViaStrada Auckland Ltd17 Huron StreetPo Box 33-020Takapuna 0740New ZealandPhone: (09) 929 4697Fax: (09) 929 4698 www.viastrada.co.nz

DateProject Manager:

Nigel Williams

Prepared by:

Nigel Williams2009-06-29

Reviewed by:

Hamish AndersonBernard Jacobsen

2009-06-29

Project Number:Project Name:StatusDate:

8040FNDC Plan Changes – TIFs and ParkingDraft29 June 2009

document.doc Date last saved 2009-07-07 08:08

http://www.viastrada.co.nz/



2 of 39

Table of Contents

INTRODUCTION 3

TRAFFIC INTENSITY FACTORS 3Terminology3How does the TIF Method work? 4Matters Considered when Traffic Intensity Threshold Crossed 9Plan Sections referring to TIFs 10

EXISTING OPERATIONAL ISSUES RAISED BY STAFF 16

POTENTIAL PLAN CHANGES 17Introduction 17Yard-based activities, Retail and Industrial. 18Service Stations 23Green dump 25Fire wood stockpile & point of sale 26Boat ramps and Launching facilities 27Golf Driving range 30House on Papakainga 31Notes to the TIF Table 33Terminology35Summary of Amendments 37

CONCLUSIONS 37

APPENDIX 1 – ZONE TIF VALUES 38

Table of FiguresFigure 1 Traffic Intensity Thresholds by Zone....................................................................11

Figure 2 Example showing Service Station with TIV = 300...............................................14

List of TablesTable 1 Application of Assessment Matters.......................................................................12

Table 2 Examples of ‘Type of Activity’ Tables....................................................................13




3 of 39

INTRODUCTION

1 The Council has asked us to review a number of traffic-related rules in the District Plan. The brief directs that we undertake:-

A review of all traffic intensity factors, relevant definitions and parking requirements in the Far North Partly Operative District Plan 2007,

A review of the usability and outcomes of use of traffic intensity factors.

Preparation of a section 32 (RMA) report.

2 This report presents our analysis of the deficiencies found in the plan in terms of the brief, and the changes we recommend to address these issues.

TRAFFIC INTENSITY FACTORS

3 The officers have indicated that there is a need to review and perhaps to increase the number of activities listed in the table in Appendix 3A Traffic Intensity Factors. In order to arrive at the ‘correct’ value of the Traffic Intensity Factors (TIFs) to be used for any new activities it is essential that we have a clear understanding of the way the value for TIFs has been arrived at, the way TIFs are used in the Plan, and the implications of the combined output of the TIF value in Appendix 3A and the TIF limits defined in the Plan’s zone rules.

4 We have not found the TIF approach being used in any other District Plan in New Zealand, and we have found only one other similar system in a Plan in the United States. Thus our discussion on the relative merits of the approach is all from ‘first principles’ rather than based on comparisons with other similar systems.

Terminology

5 The term Traffic Intensity Factor is used in the Plan in different ways.

6 For any particular activity, the Traffic Intensity Factor detailed in the table in Appendix 3A is multiplied by the floor area or other variable related to the activity to give a figure that could more properly be called the Traffic Intensity value. The resulting Traffic Intensity value is then compared with the Traffic Intensity threshold defined in each zone to determine the application’s status.




4 of 39

7 Thus there are three distinct numerical terms involved in arriving at the status of activities; the Traffic Intensity Factor; the resulting Traffic Intensity Value, and the Traffic Intensity Threshold against which the Value is compared.

8 In this report these three terms and their abbreviations (TIF, TIV and TITh) are used to identify the relevant numerical value. A possible amendment to this terminology is discussed below.

How does the TIF Method work?

9 The District Plan uses TIFs to determine the application status of an activity.

…The number of vehicles using a site (traffic intensity) is a significant effect of activities. There is a direct link between vehicle numbers and noise. Assumptions are made in this chapter about the typical traffic intensity of various activities as a basis for determining the application status of an activity…1

10 This is reinforced in Appendix 3:

The Traffic Intensity Factor (TIF) establishes a threshold for determining permitted activity status. It is a means of assessing the likely traffic effects from a particular new activity and is based on the average typical daily one-way vehicle movements for that activity.2

11 The statement in the Transport section refers to use of the TIFs as a basis for determining the overall application status (the Type of Activity as defined in s77B of the Act), while the statement in Appendix 3 also refers to the TIF as being a means of assessing the likely traffic effects.

12 The Appendix also notes that the TIF is based on the typical vehicle movements for that activity.

Objectives and Policies

13 The Plan Structure discussed in section 1.5.1 of the Plan notes:

…To manage the effects of activities within these environments, objectives and policies have been developed and zones are defined within each environment.

Zoning is used in this Plan as a means of identifying areas where the acceptability threshold of effects of activities is similar. For example residential areas have a different tolerance for noise, traffic and building bulk than industrial or rural areas…3

14 In the Urban Environment it is noted that for Residential zones:

1 15 TRANSPORTATION. 15.1 TRAFFIC PARKING AND ACCESS. Context.

2 APPENDIX 3A – TRAFFIC INTENSITY FACTORS

3 Clause 1.5.1




5 of 39

This zone enables the development of residential areas where the effects of activities permitted in the zone are compatible with sustainable development and with the existing character and amenity which is typically medium density residential living.

15 And for commercial and industrial zones:

…the effects of particular activities are generally compatible with the effects of other activities in the zone.

16 Thus the Plan’s structure indicates that each zone is expected to have a range of permitted activities that are generally compatible, and for which the acceptable effects are similar.

17 The following clauses from Part 15 – Transportation relate to the need for and use of rules to address the issues identified in the TIF assessment matters.

15 TRANSPORTATION 15.1 TRAFFIC, PARKING AND ACCESS CONTEXT …The number of vehicles using a site (traffic intensity) is a significant effect of activities. There is a direct link between vehicle numbers and noise. Assumptions are made in this chapter about the typical traffic intensity of various activities as a basis for determining the application status of an activity.

…

15.1.1 ISSUES 15.1.1.1 Activities in the District generate a significant amount of traffic and create the need for associated facilities such as parking and loading spaces, but these facilities can create or increase adverse effects on other activities.

15.1.1.3 Traffic access to property can interfere with traffic flow and can affect public safety.

15.1.1.4 In terms of the environmental effects of activities, traffic is often the most obvious. Consequently controls on the effects of traffic are central to the sustainable management of resources.

18 So 15.1.1.1 notes that traffic-related facilities can have adverse effects on other activities, and 15.1.1.4 notes that controls on the effects of traffic are central to the sustainable management of resources.

15.1.2 ENVIRONMENTAL OUTCOMES EXPECTED 15.1.2.2 Safe and efficient access within the District for pedestrians, bicycles and vehicles while minimising disruptions to the amenities of the surrounding environment.

19 This confirms that access (traffic) needs to be balanced with minimizing disruption to the amenities of the surrounding environment.

15.1.3 OBJECTIVES 15.1.3.1 To minimise the adverse effects of transport on the natural and physical environment.




6 of 39

15.1.3.5 To promote safe and efficient movement and circulation of vehicular, bicycles and pedestrian traffic.

20 The objectives thus seek to minimise the adverse effects of transport on the environment, and to promote safe movement.

15.1.4 POLICIES 15.1.4.1 That the traffic effects of activities be evaluated in making decisions on resource consent applications.

15.1.4.6 That the number, size, gradient and placement of vehicle access points be regulated to assist traffic safety and control.

21 Here the traffic effects of activities are to be evaluated in making decisions on resource consents, presumably in terms of the assessment matters for activities requiring resource consent.

22 From this it is apparent that the TIFs are based on an assumed typical value for the purpose of determining the application status of activities. The ‘assumed’ value may not accurately represent the actual traffic generation, but rather the value is used ‘to form a basis for determining the application status of an activity’.

ASSESSMENT CRITERIA

23 Part 11 of the Plan contains the Assessment Criteria for Traffic Intensity. These criteria are also repeated in generally identical form in the TIF rules for each zone and activity status throughout the Plan.

24 The assessment criteria identified in s11.12 for all types of activity are:

11.12 TRAFFIC INTENSITY

(a) The extent by which the expected traffic intensity exceeds the threshold set by the Traffic Intensity Factor contained in Appendix 3A in Part 4 of the Plan.

(b) The time of day when the extra vehicle movements will occur.

(c) The distance between the location where the vehicle movements take place and any adjacent properties.

(d) The width and capability of any street to be able to cope safely with the extra vehicle movements.

(e) The location of any footpaths and the volume of pedestrian traffic on them.

(f) The sight distances associated with the vehicle access onto the street.

(g) The existing volume of traffic on the streets affected.

(h) Any existing congestion or safety problems on the streets affected.

(i) With respect to effects in local neighbourhoods, the ability to mitigate any adverse effects through the design of the access, or the screening of vehicle movements, or limiting the times when vehicle movements occur.

(j) With respect to the effects on through traffic on arterial roads, strategic roads and State Highways, any measures such as right-turn bays, flush medians, left turn deceleration tapers, etc. proposed to be installed on the road as part of the development to accommodate traffic turning into and out of the site.




7 of 39

(k) The extent to which the activity may cause or exacerbate natural hazards or may be adversely affected by natural hazards, and therefore increase the risk to life, property and the environment.

25 Variations in the form of the assessment matters include adding clauses in various zone rules:

In the Residential Zone, Commercial Zone, Industrial Zone, Rural Living Zone, Recreational Activities Zone, Coastal Living Zone, Coastal Residential Zone, Russell Township Zone:

(i) with respect to the effects on through traffic on arterial roads with more than 1000 vehicle movements per day, the extent to which Council’s “Engineering Standards and Guidelines” (2004) are met.

In the Rural Production Zone:(i) with respect to the effects on through traffic on roads with more than 1000 vehicle movements

per day, the extent to which Council’s “Engineering Standards and Guidelines” (2004) are met;

(j) effects of the activity where it is located within 500m of reserve land administered by the Department of Conservation upon the ability of the Department to manage and administer that land.

In the General Coastal Zone:26 No assessment criteria are identified for this zone, although TIF thresholds

are set for all types of activity4 in this zone; viz.; Permitted, Controlled, Restricted Discretionary, Discretionary and Non-Complying activities.

27 It is unclear from the Rules as to which set of assessment criteria should apply – those in the zone Rule, or those in s11.12. Likewise the variations to the assessment matters (the additional clauses noted above) appear to have fairly universal application. Thus a useful change to ensure consistency could be to add the ‘variations’ in form to all sets of the assessment criteria, and then to consider where in the interest of efficiency these assessment criteria should be located in the Plan.

28 It would seem most efficient to have only one ‘version’ of the assessment criteria and that should be located in part 11 of the Plan, under 11.12. The zone rules can thus be amended by the deletion of the ‘local’ versions and the inclusion of a reference to clause 11.12 (see below).

29 A similar set of assessment criteria are provided in respect of some activities in the Residential zone under 7.6.5.2.2 Scale of Activities. These assessment matters include:

(i) the siting of the building(s), decks and outdoor areas relative to adjacent properties in order to avoid visual domination and loss of privacy and sunlight to those properties;

(ii) the location and design of vehicular and pedestrian access, on site vehicle manoeuvring and parking areas and the ability of those to mitigate the adverse effects of additional traffic;

(iii) the extent to which hours of operation are appropriate in terms of the surrounding environment;

(iv) noise generation and the extent to which reduction measures are used;

4 RMA s77B Types of activities




8 of 39

(v) any servicing requirements and/or constraints of the site – whether the site has adequate water supply and provision for disposal of waste products and stormwater;

(vi) where a property is adjacent to a public reserve, the potential impacts on the public use and enjoyment of that reserve.

30 These assessment criteria in 7.6.5.2.2 cover similar issues to those provided for Traffic Intensity Factors including relative siting of activities, traffic, parking, hours of operation, noise, servicing and impacts on adjacent reserves. This suggests that some future review of the Plan could consider some rationalisation of these provisions.

31 Assessment Matter 11.12(a) refers to the extent by which the traffic intensity exceeds the threshold. It is the Traffic Intensity Value rather than the Traffic Intensity that exceeds the threshold. The Plan notes that the purpose of the TIF method is to determine the status of the activity.

32 Clause 11.12(a) also suggests that the threshold is set by the TIF contained in the appendix, whereas in fact the threshold is set in the zone rules.

33 This clause in the assessment matters is thus unhelpful and incorrect, and should be deleted.

34 This leads to the final recommended version of the assessment matters, and the following amendments:-

Delete all versions of the TIF assessment matters in the zone rules.

Insert reference to Part 12 Assessment Matters clause 11.12 Traffic Intensity Factors in all zone rules.

Replace 11.12 with:

11.12 TRAFFIC INTENSITY (a) The time of day when the extra vehicle movements will occur.

(b) The distance between the location where the vehicle movements take place and any adjacent properties.

(c) The width and capability of any street to be able to cope safely with the extra vehicle movements.

(d) The location of any footpaths and the volume of pedestrian traffic on them.

(e) The sight distances associated with the vehicle access onto the street.

(f) The existing volume of traffic on the streets affected.

(g) Any existing congestion or safety problems on the streets affected.

(h) With respect to effects in local neighbourhoods, the ability to mitigate any adverse effects through the design of the access, or the screening of vehicle movements, or limiting the times when vehicle movements occur.

(i) With respect to the effects on through traffic on arterial roads, strategic roads and State Highways, any measures such as right-turn bays, flush medians, left turn




9 of 39

deceleration tapers, etc. proposed to be installed on the road as part of the development to accommodate traffic turning into and out of the site.

(j) With respect to the effects on through traffic on arterial roads with more than 1000 vehicle movements per day, the extent to which Council’s “Engineering Standards and Guidelines” (2004) are met.

(k) The extent to which the activity may cause or exacerbate natural hazards or may be adversely affected by natural hazards, and therefore increase the risk to life, property and the environment.

(l) The effects of the activity where it is located within 500m of reserve land administered by the Department of Conservation upon the ability of the Department to manage and administer that land.

[Refer to Summary of Amendments, below.]

Engineering Standards and Guidelines35 The additional clause in the assessment matters referring to the Council’s

Engineering Standards and Guidelines (2004) (ES&G) comes into effect for non-permitted activities on roads carrying more than 1000 vehicle movements per day.

36 The ES&G has relevant sections covering Land Stability, Roads, Stormwater Drainage, Wastewater, Water supply and Reserves. The assessment matter clause restricts Council’s discretion to considering “...the effects on through traffic on arterial roads with more than 1000 vehicle movements per day…”.

37 Thus it would appear that the provisions of the ES&G can only be legitimately applied to issues relating to the effects of the activity on through traffic on arterial roads carrying more than 1000 vehicles per day. We do not see any need to alter this approach at this time.

Matters Considered when Traffic Intensity Threshold Crossed

38 The use of TIFs is a method of achieving the Objectives and Policies of the Plan. An inspection of the relevant Assessment Criteria finds that the matters addressed by TIFs can be grouped issue-specific categories as follows:-

Traffic engineering and traffic safetya) Existing volume of traffic on the streets affected.b) Existing congestion or safety problems on the streets affected.c) On arterial roads carrying more than 1000 vehicles per day, the

extent to which Council’s “Engineering Standards and Guidelines” (2004) are met to address the effects of the activity on through traffic.

d) The width and capability of any street to ... cope safely with the extra vehicle movements.




10 of 39

e) The location of any footpaths and the volume of pedestrian traffic on them.

f) Sight distances at the access.

Amenity/Neighbourhooda) Time of day of vehicle movements.b) Distance between where vehicle movements take place and any

adjacent properties.c) Effects in local neighbourhoods.

Other Matters a) The extent to which the activity may cause or exacerbate natural

hazards or may be adversely affected by natural hazards, and therefore increase the risk to life, property and the environment.

b) Effects of the activity where it is located within 500m of reserve land administered by the Department of Conservation upon the ability of the Department to manage and administer that land.

(Our emphasis)

39 The assessment matters refer to ‘the extent to which the activity may cause or exacerbate natural hazards…’ The term ‘activity’ covers any aspect of the proposal, not just traffic. Likewise the term ‘natural hazards’ is not explicitly defined in the Plan, and thus these assessment matters could be used to address any matter that may fit the layman’s interpretation of that term, including making provision for stormwater, slope stability, proximity to global warming induced sea level rise and any other matter considered relevant.

40 Thus the TIF method is used to address a range of issues that extend significantly beyond pure ‘traffic’ matters.

Plan Sections referring to TIFs

41 The TIF for any new activity should be set in terms of the expected outcomes determined in the zone statements and Rules. The relevant Traffic Intensity Thresholds set in each zone are depicted in Figure 1.




11 of 39

Figure 1 Traffic Intensity Thresholds by Zone

42 Figure 1 shows the range of traffic intensity values that are employed as thresholds in the various zones. The figures making up this chart are taken from the individual zone Rules. These values are detailed in Appendix 2, below.

43 Note that there are no Traffic Intensity Thresholds defined for activities in the Conservation zone, and thus activities in that zone requiring resource consents will not have to address the TIF-related Assessment Matters.

44 For example the TITh for activities in the Residential zone is set at 20, after which activities becomes Restricted Discretionary activities; in other words the assessment matters are brought to bear on the application. A TITh of 20 allows effects equivalent to two residential units to arise before the threshold is crossed. Thus the TIFs for any other activities in this zone need to reflect the overall traffic, amenity, neighbourhood and other effects of about two residential units if some measure of compatibility and similarity is to be sustained within the zone.

45 The determination of appropriate thresholds to apply in each zone is an arbitrary one, based around the appreciation of the compatibility and similarity objectives of the zones (which sets a uniform threshold for each




12 of 39

zone) and the way in which the individual TIFs and hence TIVs reflect the relationship and the difference between the general effects of different ‘activities’.

46 So likewise the value of the TIFs for individual activities is largely arbitrary too, as the TIF has to not only reflect the likely traffic generation, but embody consideration of the other non-traffic values as well. The value of the TIF for a dwelling could equally effectively be set at 32, and the threshold for the Residential zone at 64; the same planning result would ensue.

Types of Activity47 In terms of the various thresholds used the following Table 1 identifies when

the TIF assessment matters are to be considered:

Table 1 Application of Assessment Matters

Types of Activity Assessment Matters applyPermitted Activity NoControlled Activity YesRestricted Discretionary Activity YesDiscretionary Activity YesNon-Complying Consideration not expectedProhibited Activity N/A

48 Once an activity crosses the lowest Traffic Intensity Threshold, then a resource consent application is required and except in the cases of Non-Complying and Prohibited activities the assessment matters will need to be considered. The assessment matters referred to for each type of activity are (with the variations discussed above) the same, and thus in terms of the consideration to be given in respect of TIFs, there is no change in the rigour of the assessment once a resource consent is required. So in most situations the threshold is significant only where an activity moves from Permitted to any activity type requiring that a consent be sought.

49 The Plan also uses other Rules to determine the activity status, such as those relating to residential intensity, building scale, setbacks and noise.

50 It is apparent then that the value of the TIF for an activity is an indication of the scale of activity at or beyond which the Council wants to see fuller investigation of the effects. The assessment is in terms of the TIF’s assessment matters. The determination of this threshold is largely a subjective matter, and thus, as noted above, the TIFs in Appendix 3, the Traffic Intensity Values calculated from those TIFs and the zone Thresholds form an arbitrary but internally consistent method for determining the activity status.




13 of 39

51 The same planning result of determining the activity status could be obtained by tabulating the scale of each activity against each zone and the required Type of Activity (RMA s77B). Table 2 shows two examples of this alternative method of achieving the same outcome using the present TIF threshold values set in the Plan.

Table 2 Examples of ‘Type of Activity’ Tables

Where:- Pmtd=Permitted Activity; Cont=Controlled Activity; LDisc=Limited Discretionary Activity; Disc=Discretionary Activity; NCom=Non-Complying Activity and Prhb=Prohibited Activity (RMA s77B)

52 This tabular approach would require repeating the activity list currently in Appendix 3 for each zone. It does have the advantage of removing any numerical calculation from the process of determining the type of activity and hence the degree of control the Council has. On balance we consider that the present approach where the factors are listed in Appendix 3 and the thresholds identified in each zone appears somewhat more efficient in terms of layout and should be persisted with.

53 However the approach considered in Table 2 does more clearly confirm the arbitrary nature of the decisions entailed in determining the Type of Activity.

54 From this it is apparent that the primary role of the TIF approach is to arrive at a reasoned method of considering which and what scale of activities can proceed without a resource consent, and which should seek resource consent and the more detailed consideration in terms of the TIF assessment matters which that process entails.


Residential Zone Type of Activity (RMA s77B)

Scale of Activity Pmtd Cont LDisc Disc NCom Phrb1 or 2 dwellings 3 or 4 dwellings More than 4 dwellings

Commercial Zone Type of Activity (RMA s77B)

Scale of Activity Pmtd Cont LDisc Disc NCom PhrbSupermarket less than 200sqm

Supermarket 200 to 400sqm

Supermarket over 400sqm



14 of 39

55 This in turn opens the possibility that there may be some activities that should be considered in terms of the assessment matters in particular zones, regardless of the likely ‘scale or intensity’ of that activity.

56 An example is a service station activity. Such an activity could be established in the residential zone in terms of 7.6.5.1.3 Scale of activities, as it is quite conceivable that a family plus no more than two others could operate a service station. In that instance the use of a unit-less TIF that is greater than the zone threshold may provide the required level of RMA involvement; for example a flat Traffic Intensity Value for Service Stations of 300 would see service stations crossing the discretionary threshold in all the residential zones, Non-Complying in the General Coastal Zone and being Controlled, Restricted Discretionary or Discretionary in all other zones. This approach is depicted in Figure 2

Figure 2 Example showing Service Station with TIV = 300

57 This method of setting a fixed Traffic Intensity Value for specific activities is useful in situations where the potential impacts of the activity are not strongly related to normal metrics such as floor areas or staff numbers, while the present current use of Traffic Intensity Factors that give rise to a variable Traffic Intensity Value is still a valid approach for most of the activities currently identified in Appendix 3A.

58 Should a particular activity be preferably not permitted in any zone, then the Rules should reflect this explicitly.

59 Note that the extent to which the TIV crosses the threshold has no bearing on the subsequent analysis of the effects of the activity. For example in terms of the TIF assessment matters, the time of day of traffic movements, the effect on neighbourhood, separation from other activities, impact on




15 of 39

natural hazards or access to or management of Department of Conservation land are not necessarily directly related to the assumed traffic volumes embodied in the TIFs. Thus the TIF does not need to (and many of the TIFs in appendix 3 do not) reflect the actual traffic generation of the activity, but rather it simply positions the particular activity along the scale of threshold values in relation to the status of activities across all the zones, as noted in Figure 1.

60 The overt acknowledgement of this disconnect between TIF and trip generation means that where relevant, the assessment of the actual traffic generation of the specific activity proposed in an application can then proceed free from the need to argue the correctness of the TIF, and can be advanced from first principles using other exogenous data and experience. In our view this will simplify the process of preparing and evaluating consent applications, as the applicant will not have the TIF to rely on as a ‘clean’ estimate of the traffic generation; a separate assessment of the expected traffic generation will be required, if necessary from first principles, and the Council can assess the traffic-related aspects of each application directly on its merits.

61 This disconnect between the TIFs in Appendix 3A and the actual traffic generation of activities should be clearly stated in the Plan. We recommend that the section 15.1 Transport - Context be amended by the insertion of a sentence at the end of the second paragraph:

Add to the end of the second paragraph in s15.1 Context:The resulting Traffic Intensity Factor or Traffic Intensity Value embodies elements of amenity and other considerations that go beyond the likely traffic generation alone, and thus these values should not be taken as an indication of the actual traffic generation of activities.


Summary of function of TIFS in the Plan62 The forgoing review of the background to the way TIFs are used in the Plan

has found that:

TIFs are used to give the Council the ability to control traffic and roading matters, amenity and neighbourhood matters, issues with natural hazards and the management and access to Department of Conservation land.

The Plan’s structure indicates that each zone is expected to have a range of activities that are generally compatible and for which the acceptable effects are similar.

Controls on the effects of traffic (presumably via TIFs) are central to the sustainable management of resources in the District.

The TIFs for individual activities are an ‘assumed’ value that is used to form a basis for determining the application status of an activity.




16 of 39

The determination of the Traffic Intensity Threshold for each zone is an arbitrary decision that achieves the ‘compatibility’ and ‘similar effects’ expectations of the Objectives and Policies.

The TIF approach is therefore an arbitrary but internally consistent method of evaluating the matters covered by the TIF’s assessment matters.

The TIF value determined for a particular activity has little or no bearing on the subsequent evaluation of the actual traffic effects of the activity.

The extent by which the Traffic Intensity Value exceeds the Threshold is not necessarily a useful indicator of the severity of the potential impact of the activity.

Where an activity that may be allowed in terms of the TIFs should not occur in a zone, then this should be explicitly stated in the zone’s Rules.

The terminology relating to the use of the expression: ‘Traffic Intensity Factor’ should be reviewed to reduce ambiguity.

The disconnect between TIF and actual traffic generation should be explicit; the value assigned to the TIF is to determine where the activity should lie in the continuum of the set of thresholds already defined for each zone in regard to the Type of Activity.

The sole purpose of the TIF approach is to determine the application status of the activity, in terms of the RMA Type of Activity (s77B)

EXISTING OPERATIONAL ISSUES RAISED BY STAFF

63 Council Staff who administer the Far North District Plan have provided feedback on operational issues they have encountered with the current version of the Plan.

64 The officers have reported that there are a number of activities that have been applied for (or undertaken) where TIFs were difficult to calculate, or the results of the calculation of the Traffic Intensity Value have not yielded a value that led to appropriate consideration of the effects of the activity. These activities and issues included: Green dump Golf driving range Boat ramps, where the TIF doesn't differentiate as to width of ramp while

the parking standards do. Fire wood stockpile & point of sale, where there is no building on the

site, and hence the calculation of the Traffic Intensity Value based on floor area does not yield any value.

Heavy machinery hire sales and similar activities that appear to have a low number of visitors compared to usual hire centre.

Some contractors yards where the TIF is based on floor area whereas the affects of the activity are more likely to relate to the size of yard and the number of workers in the yard.




17 of 39

Activities with small floor areas working through TIFs based on Gross Floor Area (GFA) present problems under the current regime. Some activities do not have any buildings on-site. Likewise some activities have an indoor and an outdoor component and at present only the indoor component.

Other difficulties are recreational facilities (golf range an example) where the numbers are based on the number of people to be catered for. Doesn't take into account those waiting to also use facility (movie cinema complex an example).

Lack of consistency between Appendix 3A (Traffic Intensity Factors) and Appendix 3C Parking Spaces Required.

Some activities are based on the number of employees. This presents difficulties with monitoring and enforcement.

Lack of commercial activities listed and lack of definitions in the plan to differentiate between commercial and industrial uses.

Houses on Papakainga. Situations where for a site containing several potential lots or tenancies

the Traffic Intensity Value for the site is taken up to the zone’s Traffic Intensity Threshold by development on some of the lots or tenancies, leaving the remaining lots or tenancies unable to develop at all without a resource consent.

65 The matters are evaluated in the following sections.

POTENTIAL PLAN CHANGES

Introduction

66 This section considers the deficiencies identified with the operation of the Plan by the Council’s staff and by our review of the Plan in relation to Traffic Intensity and Parking matters.

67 In this section the terms Traffic Intensity Factor (TIF), Traffic Intensity Value (TIV) and Traffic Intensity Threshold (TITh) are used. Note that in some cases the proposed amendment suggests that a single-value Traffic Intensity Value is being proposed, rather than a variable Traffic Intensity Factor.

68 The first matter considered here relates to the general definition and scope of retail and industrial activities and to yard-based activities. This item leads to new definitions and approaches that have application for later sections.




18 of 39

Yard-based activities, Retail and Industrial.

69 The Council has found some difficulties with activities that occupy yard spaces for part or all of the activity, because the TIF and parking requirements in the Plan are generally based on Gross Floor Area (GFA) of buildings. The result can be that an activity similar to other building-based activities can establish without providing parking, or addressing the matters entailed in the TIF’s assessment matters.

70 While the most obvious situations where this can arise are with activities like firewood yards, agricultural equipment, motor vehicle and boat sales and hire and contractors yards, the same issues arise with any activity when the ‘activity’ occupies land areas outside buildings. This can include outdoor areas of restaurants and bars, places of assembly, garden centres, building supply outlets and industrial activities. In all these cases the TIF and parking requirement needs to be based on some other metric instead of or in addition to the building area.

71 The Plan’s definition of GFA is:

GROSS FLOOR AREA The sum of the gross area of the several floors of all buildings on a site, measured from the exterior faces of the exterior walls, or from the centre lines of walls separating two buildings, or in the absence of walls, from the exterior edge of the floor and includes: (a) elevator shafts, stairwells and lobbies; (b) interior roof space providing headroom of 2.4m or more whether or not a floor has been laid; (c) floor spaces in interior balconies and mezzanines; (d) floor space in terraces (open or roofed), external balconies, breezeways or porches if more than 50% of the perimeter is enclosed, except that a parapet not higher than 1.2m or a railing not less than 50% open and not higher than 1.4m shall not constitute an enclosure. (A 'breezeway' is a roofed outdoor area); (e) all other floor space not specifically excluded.

The gross floor area of a building shall not include: (i) uncovered steps; (ii) required off-street parking and/or loading spaces (including manoeuvring areas, access aisles and access ramps); (iii) vehicular unloading/loading areas and machinery rooms.

72 Variation 86 to the Christchurch City Plan saw the inclusion of the following definition in that Plan:-

Yard based suppliermeans any retail activity selling or hiring products for construction or external use (which, for the avoidance of doubt, includes activities such as sale of vehicles and garden supplies), where more than 50% of the area devoted to sales or display is located in covered or uncovered external yard or forecourt space as distinct from within a secured and weatherproofed building. For the purpose of this definition, areas of a site providing rear access and all other areas devoted to customer, staff and service vehicle access and parking (including parking driveways) are not to be




19 of 39

included in the extent of yard area devoted to sales or display. Drive-in or drive-through covered areas devoted to storage and display of construction materials (including covered vehicle lanes) will be deemed yardspace for the purpose of this definition.

and..

Retail activitymeans the use of land or buildings for displaying or offering goods for sale or hire to the public and includes, but is not limited to, restaurants food and beverage outlets, trade suppliers, yard based suppliers, service stations, second hand goods outlets and foodcourts.

and..

Gross leasable floor area (GLFA )means the total sum of any floor areas (within the external walls for buildings or boundary for outdoor areas) designed or used for tenant occupancy but excluding:• common lift wells and stairwells, including landing areas;• common corridors and halls (other than foodcourt areas);• common toilets and bathrooms;• any parking areas required by the Plan;

and for the purposes of calculating carparking requirements, in addition to the exclusions above, the following shall also be excluded:• common seating areas, including food court seating areas;• lobby areas in cinemas.

(Our emphasis)

73 This group of definitions suggests a useful method of identifying and assessing parking and traffic intensity for developments where the activity has a small building footprint, and a significant proportion of the activity is generated from the yard rather than from the building. This approach can be extended to include non-retail activities, such as contractor’s depots where the building footprint is a small or non-existent part of the total area involved in the activity.

74 Accordingly we recommend that the first paragraph of the definition of GFA in the Plan be amended by the addition of the words: ‘or boundary or other limit of the defined extent of the activity for yard-based activities’, to read:

GROSS FLOOR AREA The sum of the gross area of the several floors of all buildings on a site, measured from the exterior faces of the exterior walls, or from the centre lines of walls separating two buildings, or in the absence of walls, from the exterior edge of the floor or from the site boundary or other limit of the defined extent of the activity for yard-based activities and includes:

(a) Etc..




20 of 39

75 The following definitions of Industrial activity, Retail activity, Food and Beverage Outlet and Yard-based supplier should be added to the Definitions:

INDUSTRIAL ACTIVITYmeans the manufacturing , assembly, packaging, wholesaling or storage of products or the processing of raw or natural materials, produce or animals and other ancillary activities.

RETAIL ACTIVITYmeans the use of land or buildings for displaying or offering goods for sale or hire to the public and includes, but is not limited to, food and beverage outlets, trade suppliers, yard based activities, service stations, second hand goods outlets and foodcourts.

FOOD AND BEVERAGE OUTLETmeans the use of land or buildings primarily for the sale of food and/or beverages prepared for immediate consumption on or off the premises to the general public. It includes restaurants, taverns, cafes and takeaway bars, and excludes supermarkets.

YARD-BASED ACTIVITYmeans any activity which is located in covered or uncovered external yard or forecourt space as distinct from within a secured and weatherproofed building. For the purpose of this definition, areas of a site providing rear access and all other areas devoted to customer, staff and service vehicle access and parking (including parking driveways and service station forecourts) are not to be included in the extent of the yard-based activity. Drive-in or drive-through covered areas devoted to storage and display of construction materials (including covered vehicle lanes) will be deemed yardspace for the purpose of this definition.


76 The effect of these definitions will be to see a reduction in the range of items listed in the TIF and Parking tables in Appendix 3.

77 The intensity of activities contained in buildings on sites is generally significantly higher than the intensity of activity in the yard areas. For example a car sales yard will have the office, servicing and grooming services within the building, while the yard is utilised for display of vehicles for sale or hire. In a contractors yard, similarly the office building will contain higher numbers of staff and be the focus for visitors, while the yard will contain vehicles and materials. Thus both the TIF and the parking requirement for the yard-based activities could be significantly less than that for the same activity in a building.

78 To ensure a consistent treatment of these activities in relation to TIFs and parking requirements, a check of the present TIFs and Parking requirements has found that only minor changes to the resulting Traffic




21 of 39

Intensity Values and parking requirements will result if the Yard-based areas of these activities are rated at 50% of the TIF and parking requirement of the equivalent activity within a building. Accordingly the TIF table should include:

Yard-based activities: TIF is 50% of the equivalent activity in a building.

(This requirement should be inserted at the top of the TIF table)[Refer to Summary of Amendments, below.]

79 This will see a number of changes to Appendix 3A Traffic Intensity Factors. The categories of Shops (Including TAB) / Shopping centres, Supermarkets, Garden or Hire Centres, Building Supply Outlets, Service Stations, Restaurants, Bars, Cafes and Fast Food outlets, Vehicle sales, repair and service are all subsumed into the one category of Retail activities

Delete to following activities and associated TIFs:Shops (Including TAB) / Shopping centresSupermarketsGarden or Hire CentresBuilding Supply OutletsService StationsVehicle sales, repair and serviceRestaurants, Bars, Cafes Fast Food outlets,

80 This category should adopt the TIF for Shops of 70 per 100sqm GFA.

Add:Retail activities: 70 per 100sqm GFA

81 Likewise the categories of Industrial Units, Distribution Centres, Bulk Warehousing, Contractor’s Depots, Port/Sea terminal are all subsumed into the one category of Industrial activities.

Delete:Industrial UnitsDistribution Centres Bulk WarehousingContractor’s DepotsPort/Sea terminal

82 This category should adopt a TIF of 4 per 100sqm GFA.

Add:Industrial activities: 4 per 100sqm GFA





22 of 39

Parking Requirement83 For Retail activities the present parking requirements range between 1

space per 10sqm for cafes, restaurants and bars through 1 per 25 for general retail activities to 1 per 100sqm for garden centres and hire centres.

84 A feature of zones where these activities are permitted is that in many cases over the life of the building floor space is used sequentially for a range of activities with varying parking requirements. This can lead to either a limit on the ability of a building to accommodate another activity, or the need for a resource consent where additional required car parking be readily provided.

85 While when viewed in isolation it is important for each activity to provide ‘its share’ of the parking supply in an area, when viewed over the area of a zone the objective is that there is sufficient parking provided to address the areas parking demands, allowing that some activities will have spare parking for visitors to use, and others may not. In any area where there is more than one activity visitors are inclined to park in one car park and visit several activities, and thus the parking supply (and benefits) are shared within the area among all activities in the locality. Accordingly it is efficient to establish a single parking requirement that covers as wide a range of potential activities as possible.

86 Our observations of the parking conditions in the District during peak and off-peak times suggest that in some locations there may be times when parking demand significantly exceeds supply, however it is likely that this condition arises because of the historic situation where a proportion of the existing retail and industrial floor space does not provide the Plan’s parking requirement, rather than any inadequacy of the Plan’s requirement.

87 In most areas the levelling of the parking requirement to a uniform rate as proposed here will not give rise to any adverse effect on the street, and will facilitate simple changes of activity within buildings without requiring resource consent for often trivial non-compliances.

88 Likewise for Industrial activities it is often difficult to difficult to distinguish between manufacturing, warehousing and storage activities at the time of development, and the nature of building required for manufacturing and warehouse/storage activities is essentially the same. Under the present rules for a manufacturing activity to be established in a building constructed as a warehouse or storage facility would require either the provision of one additional parking space per 100sqm of GFA or more usually a resource consent to dispense with the additional parking required because there is no space available on the site for more parking. This is an inefficient situation. The definitions proposed above see the amalgamation of these activities into a format that allows free exchange of the most common types of activities found in industrial areas, without requiring resource consents in




23 of 39

relation to parking supply. This will significantly simplify the consent and enforcement processes, while allowing property owners to readily alter tenancies from warehousing to industrial without having to alter the site’s parking provision.

89 We recommend the adoption of a parking requirement that is mid-range between that currently in the plan for industrial (1 space per 50sqm, i.e 2 spaces per 100sqm) and warehousing activities (1 per 100sqm) of 1.5 spaces per 100sqm.

Industrial activities: 1.5 spaces per 100sqm GFA[Refer to Summary of Amendments, below.]

90 Accordingly we would recommend that the parking requirement for the yard component of yard based activities be 50% of that set for the same activity (for example ‘retail’) in buildings.

Yard-based activities: 50% of the parking requirement for the relevant building based activity.

(This requirement should be placed at the top of the Parking Spaces Required table.)


Service Stations

91 If the approach suggested above is followed, then the assessment of the TIF for a service station would entail considering the TIF for the Retail Activity component in the building. As discussed above, any likely size of building on a new service station site is likely to require resource consent.

92 The present TIF for service stations is 500 per 100sqm GFA. With this TIF any service station with more than 40 square metres a resource consent will be required in every zone. For a service station to be a permitted activity in the Living, Residential or Township zones it would have to have less than four square metres. Thus it is apparent that the Plan expects most new service stations will have to apply for a resource consent.

93 The traffic generation and potential amenity and other effects of service stations are not reliably determined by floor area, number of pumps or other on-site metrics. In good market conditions a station may attract up to 4% of the passing traffic stream, however this value is highly dependant on the proximity of other competing sites, traffic volumes and even by management and pricing policies.




24 of 39

94 Because service stations entail the movement of tankers, heavy goods vehicles and light vehicles sensible provisions should be made for access, on-site circulation and parking, and at the same time the potential amenity and neighbourhood impacts should be recognised on a case-by-case basis.

95 While service stations are appropriate in industrial and commercial zones they can give rise to interference with other nearby activities should inadequate provision be made for queuing or on-site manoeuvre for larger vehicles. Thus it appears appropriate that the TIF assessment matters are considered for all service station applications. Accordingly the recommended TIV is:

Service Stations: TIV= 500[Refer to Summary of Amendments, below.]

96 This value sees service stations being Discretionary in all the Living, Residential and Township zones, in the Recreational zone and in the Rural Production and Minerals Zones, and Controlled in the Commercial and Industrial zones.

97 Because the Conservation zone does not set TIF thresholds for any activity, a service station without any building (for example a Truck Stop type site) could be established in that zone as a Permitted activity.

Parking requirement98 The present parking requirement is: 1 space per 35sqm GFA of shop plus 2

for every 3 employees on site at any one time.

99 Council officers have indicated that they have had difficulty determining staff-based parking requirements. Minimum staff requirements for service stations over a fairly wide range of pump volumes and retail sales are between one and four staff, with the higher number being reached when administration staff are working. Thus the staff parking requirement could be replaced with a fixed minimum, while visitors are catered for by the present floor space based requirement. The proposed TIV will see all new service stations being considered as Controlled or Discretionary activities, and thus the detail of parking requirements can be further addressed in the course of the resource consent application.

100 For consistency it would be preferable if the parking requirement for service stations relied on the parking requirement for retail activities. Thus we do not believe that a separate parking requirement is needed for service stations, provided they are included in the definition of Retail Activity. (See above). This would see a parking requirement of 4 spaces per 100sqm GFA being required, compared with the present value of 1 space per 35sqm GFA (about 2.8 spaces per 100sqm) plus an allowance for staff. The result of this amendment will see the number of parking spaces




25 of 39

provided for service stations being similar to that achieved with the present rule.

101 Accordingly the reference to Service Stations may be removed from Appendix 3C – Parking Spaces Required.

Delete from Appendix 3C – Parking Spaces Required:

Service Stations[Refer to Summary of Amendments, below.]

Green dump

102 While a green dump could be considered as a Yard-based activity, doing so has the potential to give rise to Traffic intensity Values that place undue limitations on their establishment. Accordingly a separate TIF and parking requirement is appropriate. Small green dumps can be established in industrial or commercial areas with minimal impact, while larger facilities should require resource consent to ensure that the wider traffic and amenity issues are thoroughly addressed.

103 Accordingly it is appropriate to determine the activity type based broadly on the scale of the activity. The recommended Traffic Intensity Values (TIV) are:

Add to Appendix 3A – Traffic Intensity Factors:Green dumps up to 1000sqm site area: TIV=150Green dumps over 1000sqm site area: TIV=550


104 These values see the green dump being a Discretionary Activity at any scale in the Living, Residential and Township zones, Restricted Discretionary in the Rural Production zone and Non-Complying in the General Coastal Zone. Smaller dumps will be permitted in the Minerals, Recreational, Commercial and Industrial Zones, while larger dumps will either be discretionary (in the Minerals, Recreational and Industrial zones) or Restricted Discretionary in the Commercial zone.

105 It is noted that the rules for the Recreational and Conservation zones only determine the nature of the activity as associated with the zone purpose where a building is constructed5. Thus it is possible that a small green dump without any building could be established as a Permitted activity in these zones.

Parking requirement

5 Recreational zone 9.6.5.1.1 Purpose of Buildings and Conservation zone 9.7.5.1.1 Purpose of Buildings




26 of 39

106 The parking requirement for Green dumps is determined by staff numbers and the likely arrival and service rates of customers rather than by the site area. Since these are specific to each site’s capacity and location in relation to potential users the parking provision should be determined as part of the consideration of effects covered in the resource consent applications. For smaller dumps a minimum number of spaces should be required to provide for staff and a small number of visitors to protect adjoining properties from adverse effects of unnecessary on-street parking.

107 Accordingly it is recommended that the minimum parking requirement for Green Dumps is:-

Add to Appendix 3CParking Spaces Required: Green Dumps: 4 spaces per site.


108 As noted above for most new sites the parking needs will be able to be considered as part of the resource consent.

Fire wood stockpile & point of sale

109 These retail operations are appropriate in the Industrial, Commercial and Mineral zones, and to a degree in the Rural Production zone. As with Green dumps the use of the general retail TIF could give rise to the activity being placed in an inappropriate activity class, and thus a separate classification may be appropriate.

110 For example a typical 1.5 hectare site considered as a Retail activity at the suggested TIF of 4 per 100sqm x 50% as a Yard-based activity would have a TIV of 300. In the Industrial, Commercial, Recreational and Minerals zone 200 is the threshold above which resource consent is required. Since these activities are appropriate within these zones it appears that a variable TIF is not the best method to employ for this activity, and the following approach is preferred.

111 Because of the relatively large area of land involved compared to a shop-type retail activity they present as low density traffic generators, and thus the potential traffic issues are able to be accommodated in zones where retail or industrial activities are permitted, subject to compliance with the Plan’s general rules relating to access.

112 The recommended TIV is:

Add to Appendix 3A Traffic Intensity Factors:Fire wood stockpile and point of sale: TIV = 150.




27 of 39


113 This makes the activity a Discretionary Activity at any scale in the Living, Residential and Township zones, Restricted Discretionary in the Rural Production zone and Non-Complying in the General Coastal Zone. The activity will be permitted in the Minerals, Recreational, Commercial and Industrial Zones.

114 It is noted that the rules for the Recreational and Conservation zones only determine the nature of the activity where a building is constructed6. Thus it is possible that a firewood stockpile and point of sale without any building could be established as a Permitted activity in these zones under either the general yard-based approach, or with this preferred TIV method.

115 The car parking requirement for this activity has to ensure that all loading and parking associated with the activity occurs on the site. The land area of the activity can be quite variable in relation to turnover and traffic activity. The nature of the activity usually entails working aisles around firewood stockpiles and bins that provide useful informal parking areas, and in some cases the ‘point of sale’ is mobile within the yard, and so the transaction does not occur at any fixed location.

116 A minimum provision of parking is required to ensure that the formal staff and visitor parking needs of the activity can be met. Accordingly the recommended parking requirement is:

Add to Appendix 3C Parking Spaces RequiredFirewood stockpiles with point of sale: 4 spaces per site.


Boat ramps and Launching facilities

117 The present TIF for boat ramps is 200 per ramp. The parking requirement for boat ramps is 15 spaces per three metres width of ramp, while the TIF standard does not define the boat ramp in terms of its width.

118 If the TIF is taken at it’s face value of meaning that any boat ramp regardless of its width has a TIF or 200, then boat ramps are Permitted activities in the Industrial, Commercial, Minerals, and Recreational zones; Restricted Discretionary activities in the Rural Production zone, and Discretionary in all the Living, Residential and Township zones.

6 Recreational zone 9.6.5.1.1 Purpose of Buildings and Conservation zone 9.7.5.1.1 Purpose of Buildings




28 of 39

119 In the General Coastal zone the TIF of 200 per ramp means boat ramps are automatically a Non-complying activity which, in view of the zones proximity to the coast, seems a somewhat incongruous situation for boat ramps as an activity.

120 In the General Coastal Policy 10.4.7 and the supporting Issues and Objectives the establishment of land-side facilities to support marine activities is confirmed as appropriate provided adequate supporting services and facilities are provided.

121 Roads serving coastal areas where launching is possible are frequently constrained in terms of carriageway dimensions and opportunities for providing road-side parking and manoeuvre areas. Thus it is important that new boat ramps and launching facilities generally are well designed to support the Plan’s expected environmental and traffic safety and efficiency outcomes. Thus the expectations of the Plan confirm that boat ramps and launching facilities generally are appropriate activities in the zone, subject to ensuring that they address issues that are already defined in the assessment matters. Thus the appropriate activity type for these facilities would be either as Controlled or Restricted Discretionary activities.

122 In some situations a boat ramp may only be for the benefit of an adjacent private property or business such as a boat shed on a site containing a private dwelling, or a ramp or launching facility serving a commercial activity such as a commercial boat building, fishing or aquaculture activity. In such cased consideration of the boat ramp application in terms of the TIF assessment matters is not necessary as there are no off-site land-side effects. However ramps for general public use, and marinas and ‘private’ boat ramps and launching facilities for ferry services, yacht and boat clubs should be considered. This distinction is made in the proposed definitions.

123 Since both the potential scale of the boat ramp facility and the ability of the facility to be integrated into the adjacent roading system and neighbourhood amenity are variable on a case-by-case basis it is appropriate that all such facilities are subject to some consideration by way of resource consent. However we do not believe that it is appropriate or necessary to limit the scale or occurrence of such facilities by imposing a TIF of 200 and hence conferring a Non-Complying status on them in the General Coastal zone.

124 Accordingly we suggest that the practical approach is to set a single value for any boat ramp or launching facility that ensures an appropriate level of planning consideration. The recommended TIV is:

Add to Appendix 3A Traffic Intensity Factors:Public Boat Ramps and Launching Facilities: TIV=100.





29 of 39

125 This TIV sees the activity considered as a Permitted activity in the Industrial Commercial, Recreational and Minerals zones. It would be a Discretionary Activity in all Living, Residential and Township zones. As far as we are aware there are not any locations where these zones abut relevant water bodies, and hence it is unlikely that any boat ramps will be built in these zones.

126 The proposed TIV would make the activity a Restricted Discretionary Activity in the Rural Production zone, and a Discretionary Activity in the General Coastal zone.

127 If on reflection it is considered that this activity should only have a Restricted Discretionary status in the General Coastal zone, then this could status could be imposed directly by a rule in the General Coastal zone under 10.6.5.3 Restricted Discretionary Activities, viz.:-

Add to 10.6.5.3 Restricted Discretionary Activities:(e) The activity is a public boat ramp or launching facility.


128 If this latter approach is adopted, then there would not be a requirement for a TIF.

129 A new definition should be included in the Plan to support either the TIF or the activity status rule approach (above):-

Add new definition:PUBLIC BOAT RAMP OR LAUNCHING FACILITYA man-made ramp, slip, rail or other facility such as a crane or cradle used to convey water-craft to and from water. This definition excludes facilities where there is no public access to the ramp from the land-side and where use of the facility is effectively limited to no more than two adjacent residential sites or to one or more industrial activities where the ramp or facility is an intrinsic part of the function of the premises.


Parking Requirement130 The parking requirement for Boat Ramps appears to be appropriate, and

the only amendment is to amend the term to refer to ‘Public Boat Ramp or Launching Facility’.

Amend Appendix 3C Parking Spaces Required Replace phrase “Boat Ramp” with: Public Boat Ramp or Launching Facility


131 The Discretionary Activity status conferred by the recommended TIV gives the Council the ability to consider the parking demand of the activity in terms of the relevant assessment matters, particularly 11.12 (h) ‘Any




30 of 39

existing congestion or safety problems on the streets affected’. Lack of adequate on-site parking for a boat ramp can give rise to adverse congestion and safety effects on the street and thus the Discretionary status allows the detail of parking supply to be considered in each case.

Golf Driving range

132 Golf driving ranges require significant areas of land, and are thus unlikely developments in residential, living or township zones. The traffic generation is generally modest; about 2 trips per hour per tee, and thus they are not particularly offensive in terms of the ability of the District’s roads to carry the traffic, but as always proper design of accesses is important.

133 Driving ranges are not inappropriate in Rural Production, Recreation, Commercial or Industrial zones, and thus the value set for them should reflect this. In commercial and industrial areas the low density of the driving range within the fabric of the zone would offset most potential traffic difficulties. The traffic characteristics are similar to a bowling alley, for example.

134 The recommended TIV is:

Add to Appendix 3A Traffic Intensity Factors:Golf Driving Ranges: TIV = 300


135 This value sees driving ranges being discretionary in all the Living, Residential and Township zones and in the Rural Production and Minerals Zones, Controlled in the commercial and industrial zones and Restricted Discretionary in the Recreational zone.

136 Because the Conservation zone does not set TIF thresholds for any activity, a golf driving range without any building could be established in that zone as a Permitted activity.

Parking requirement137 The parking requirement of driving ranges is determined by staff numbers

and by the arrival rate and duration of stay of players. At peak capacity, when every tee is in use, the parking requirement will be one space per tee, plus spaces for staff, plus an allowance for turnover of the car park (new players arriving while others are still leaving). Generally driving ranges operate well below capacity, and thus a parking requirement of one space per tee will provide a reasonable degree of satisfaction while accepting that there will be times when the parking demand may exceed supply.

138 The recommended parking requirement is:




31 of 39

Add to Appendix 3C Parking Spaces Required:Golf Driving Ranges: 1 space per tee


House on Papakainga

139 Approximately 19% of land in Far North District is Maori land. Currently Northland’s three District Councils are developing a unified approach to the provision of papakainga housing7. Thus there is considerable scope for the establishment of housing for Maori on papakainga, and if possible the approach taken by Far North District Council should not preclude integration with the ‘unified’ approach being considered.

140 The present TIF is 7 per unit or house. There is no explicit parking requirement for papakainga housing defined in Appendix 3C Parking Spaces Required, and so in terms of Note 2 to Appendix 3C the ‘most appropriate’ parking requirement is that set for Standard Residential units or for Home Unit/Town House of 2 spaces per unit.

141 There is no specific reference to housing for Maori or papakainga housing in the Living or Recreation / Conservation Environment. In the Rural and Coastal Environments the Plan provides for papakainga housing as a Controlled activity with a minimum of 3000sqm of land directly associated with each dwelling for its exclusive use8. The Council’s control relates to the number of dwellings, the location and standard of access and screening and planting. The Plan also provides for integrated development of land for papakainga housing9 in the Rural and Coastal Environments as a Discretionary activity.

142 There is no Traffic Intensity Threshold set in these zones relating to Controlled activities, and so any application for papakainga housing cannot be considered in terms of the TIF-related assessment matters.

143 Thus as it stands, there is no need for a TIF for papakainga housing, because there is no threshold set in the relevant zones to assess the resulting Traffic Intensity Value against. The activity status is determined by the zone rules as a Controlled activity for papakainga housing generally or as a fully Discretionary activity for integrated developments.

144 For developments conforming to the rules for Controlled activities in the Rural and Coastal environments the location and standard of access is Controlled, and thus the most likely adverse traffic-related affect is

7 The Northern Advocate. 13 May 2009 – Unified policy for Maori housing.8 8.6.5.2.2, 10.6.5.2.1 PAPAKAINGA HOUSING, etc9 8.6.5.4.2, 10.7.5.4.3 INTEGRATED DEVELOPMENT, etc




32 of 39

addressed. Integrated developments involving papakainga housing are Discretionary activities, and in that process full consideration can be given to both access and car parking arrangements. We believe this is an appropriate level of control for this activity, and no specific TIF is required.

145 Accordingly we recommend that the TIF for papakainga housing be removed from Appendix 3A.

Delete from Appendix 3A Traffic Intensity FactorsPapakainga Housing


Parking Provision146 At present the default parking requirement for a dwelling on papakainga is 2

spaces per unit. While we do not have any statistical information relating specifically to vehicle ownership on papakainga sites, the parking requirement does seem relatively high.

147 For individual applications as Controlled activities each dwelling has to have at least 3000sqm of land available for it’s exclusive use. This area is sufficient to accommodate any vehicles that may be associated with the dwelling. It is important however, that some provision is made for on-site parking to ensure that a development does not have to or seek to rely on on-street parking to meet its parking demand.

148 We feel that an overall parking provision of one space per two dwellings would be sufficient for papakainga housing, and thus propose the following parking requirement.

Add to Appendix 3C Parking Spaces Required:Papakainga housing: 1 space for the first unit plus one space per 2 additional units.


149 The Discretionary status of Integrated Housing would allow a more refined appreciation of the parking needs of larger developments, including the possibility of grouping parking supply in areas remote from the dwelling locations.

150 The removal of the TIF for papakainga housing, and the reduction in the parking requirement should support Plan’s expectations for the provision of papakainga housing, while the planning controls relating to Controlled and Discretionary activity status will ensure adequate consideration of the traffic-related affects of this activity. This comparatively minimalist approach to regulating the traffic-related effects of papakainga housing is




33 of 39

intended to compliment the current development of a unified approach to this activity among Councils in Northland.

Notes to the TIF Table

151 The Notes to APPENDIX 3A TRAFFIC INTENSITY FACTORS of the Plan provide information on how to use the TIF tables to calculate the required values. Notes are intended to clarify and explain the rules, but they do not have any regulatory force in themselves. These notes do contain some provisions that should usefully be defined as Rules. The existing notes are reproduced below, and those portions that have a regulatory function and could best be phrased as Rules are underlined.

Note 1: The Traffic Intensity Factor (TIF) does not apply to, or limit, existing activities and does not limit future increases in traffic generation from a site unless: (a) this is the subject of a condition in a resource consent; or (b) the effect of an increase in traffic is such that the scale, intensity, or character of the activity

changes, in which case existing use rights no longer apply.

152 This note defined when the TIF applies and under what circumstances existing use rights cease to apply. It should be recast as a Rule under 15 Transportation, 15.1.6 Rules:-

Add:15.1.6.1 Traffic Intensity FactorsThe Traffic Intensity Factor (TIF) method does not apply to, or limit, existing activities and does not limit future increases in traffic generation from a site unless:

(a) this is the subject of a condition in a resource consent; or (b) the effect of an increase in traffic is such that the scale, intensity, or character of the activity changes, in which case existing use rights no longer apply

Delete Note 1 from Appendix 3A Traffic Intensity Factors, and re-number remaining notes.

Renumber existing subsequent clauses 15.1.6.1 to 15.1.6.3 and sub-clauses.


Note 2: A TIF has been worked out for a limited number of activities. If there is no TIF in Appendix 3A for the activity that is being considered, the TIF for the activity in Appendix 3A that is closest in scale, intensity and character to the activity being considered must be used.

153 This note determines the TIF for activities that are not specifically identified in the table. This should have the force of a Rule. This approach makes it compulsory for applicants to find another activity in the TIF table that is




34 of 39

‘closest’ to the activity being considered. In many situations where non-standard activities are being considered, this approach can lead to incongruous situations where obviously ‘wrong’ values are adopted under the force of this requirement.

154 The role of the TIF and the associated thresholds defined in the zone rules is to determine the activity status, which in turn leads to either assessing the proposal in terms of the TIF assessment matters, or not. It does not matter what the Traffic Intensity Factor of some undefined activity actually is; it only matters whether the activity should be assessed in terms of the TIF assessment matters, or not.

155 On balance, it would appear prudent that any activity that does not clearly relate to an activity listed in the TIF table should be considered to be a Restricted Discretionary Activity.

156 Our recommendation is that a Rule be added to the Transport section requiring that where an activity is not found in the TIF table, then that activity should be considered as a Restricted Discretionary Activity with the Council’s discretion limited to the matters listed in the TIF assessment matters.

Add to 15.1.6.2 Restricted Discretionary Activities:-(e) The activity is not found in Appendix 3A Traffic Intensity Factors, in which case the assessment matters contained in the assessment matters specified in 11.12 Traffic Intensity Factors shall be considered.


Note 3: Having established the TIF for a particular activity from Appendix 3A, reference must be made to the rules for the zone in which the activity is to be located. The rules state the TIF for the zone. If the TIF for the particular activity, as listed in Appendix 3A , is less than the TIF for the zone, the activity is permitted. If it is up to 100% greater than the permitted TIF for the zone, the activity is a restricted discretionary activity. In considering a restricted discretionary application, the Council will restrict the exercise of its discretion to the consideration of those matters listed under Assessment Criteria 10.10.12 (refer Part 2, Environment Provisions ). If, however, the TIF for the activity is more than 100% above the permitted TIF for the zone, the activity is a full discretionary activity.

Example: A motel with 6 units has a TIF of 18 (refer to Appendix 3A). If it is proposed in the Residential Zone, which has an allowable TIF of 20, it is, in terms of traffic intensity, a permitted activity.

157 This note defines generally how the TIF values are used to arrive at the application status of activities. The description of the thresholds is at variance with that contained in the specific zone rules.

158 The note also refers to the Assessment Criteria in clause 10.10.12, whereas these criteria are now in Chapter 11, clause 11.12.

159 Accordingly to remove this ambiguity and the reference error it would be best to remove the portions of this note that are underlined.




35 of 39

Replace Note 3 (to be re-numbered) with:- Note 3: Having established the Traffic Intensity Value for a particular activity from Appendix 3A, reference must be made to the rules for the zone in which the activity is to be located. The rules state the Traffic Intensity Threshold for the zone.

Example: A motel with 6 units. The Traffic Intensity Factor (TIF) is 3 per unit, giving a Traffic Intensity Value (TIV) of 18 (refer to Appendix 3A). If the activity is proposed in the Residential Zone, which has an allowable Traffic Intensity Threshold (TITh) of 20, then the activity is, in terms of the traffic intensity method of determining the activity status, a permitted activity.


160 The removed items are repeated relevant zones, and so this amendment does not detract from the Plan’s control of activities.

Note 4: A vehicle travelling to a site = one vehicle movement. A vehicle travelling to a site and then leaving to go elsewhere = two vehicle movements.

161 This is a relevant note.

Note 5: Where there is more than one activity on a site the TIF is calculated separately for each activity, then added together. This not only applies where there are two or more new activities proposed, but also means that if an existing activity on a site has a TIF of, e.g. 20, and the zone permits a TIF of 40, any new activity may have a TIF of 20 before it is subject to a resource consent .

162 Note 5 raises the issue of the priority of development rights. We are aware of a case where a developer has created a multi-lot subdivision, and sold a number of lots to others, leaving some lots in his control undeveloped. New Permitted activities on the other lots have taken the available Traffic Intensity Value up to the zone threshold, leaving the original developer having to apply for a resource consent to develop anything on his land.

163 While technically this is in accordance with the intention of the Plan, there is currently no mechanism by which a developer can pre-assign Traffic Intensity Values to lots and thus to preserve some as-of-right development potential for all lots in the development.

164 Resolution of this matter would entail detailed consideration of the implications for the efficient use of resources and other matters that are beyond the scope of this current work. Accordingly we recommend that the Council should prepare a separate report to address this matter in due course.

165 In the mean time this note can remain, subject to the required re-numbering.




36 of 39

Terminology

166 It is helpful to review the terminology used in the Plan relating to TIFs. Appendix 3A contains a table which defines a Traffic Intensity ‘Factor’ for each activity.

167 As noted above, for any particular activity, this Traffic Intensity Factor is multiplied by the floor area or other variable related to the activity to give the Traffic Intensity value. The resulting Traffic Intensity value is then compared with the Traffic Intensity threshold defined in each zone to determine the application’s status. Thus there are three distinct numerical terms involved in arriving at the status of activities; the Traffic Intensity Factor; the resulting Traffic Intensity Value, and the Traffic Intensity Threshold against which the Value is compared.

168 The Plan uses the term Traffic Intensity Factor for all three of these figures10. In some places in the Plan this use of the same term for the different figures can give rise to potential ambiguity in understanding the intent of the Plan.

169 Further, as discussed above, the TIF method merely provides a way of determining the application’s status, and need not relate directly or solely to the traffic generation of the activity. Thus it may be more appropriate to refer to ‘Activity’ Intensity rather than to ‘Traffic’ Intensity.

170 In the broad context of land uses, the term ‘Traffic Intensity’ generally refers to the number of vehicle movements per area of land or floor area. So for example a dwelling on 500 square metres of land has the same ‘intensity’ per area of land as three similar dwellings on a 1500 square metres of land.

171 As employed in the Plan, however, the single dwelling will have a Traffic Intensity Value of 10 and hence be a permitted activity in the Residential zones. The development containing three dwellings each on the same area of land as the one dwelling, will have a Traffic Intensity Value of 30 and thus will exceed the TIF threshold for the zone (20) and require resource consent. The same issue arises with a 100 square metre shop and a 300 square metre shop in the Commercial zone. In both examples the ‘intensity’ of the activity per unit of area is the same, it is the overall ‘ scale’ of the activity (how big the activity is in relation to other activities) that has changed.

172 The Resource Management Act s3 refers to the ‘…scale, intensity, duration or frequency of effects’ and s88(2) (b) the ‘...scale and significance of the effects..’ In relation to TIFs, the word: ‘intensity’ could more appropriately be termed: ‘scale’.

10 As Traffic Intensity Factor: ”A TIF has been worked out for a limited number of activities.” As Traffic Intensity Value: “A Motel with 6 units has a TIF of 18.” As Traffic Intensity Threshold: “The Traffic Intensity Factor for a site in this zone is 20 daily one way movements.”




37 of 39

173 Thus it would be more appropriate for the word ‘Traffic’ to be replaced by the word ‘Activity’ and the word ‘Intensity’ by the word ‘Scale’. This would then give rise to the replacement of the term Traffic Intensity Factor, Value and Threshold with Activity Scale Factor, Value and Threshold respectively.

174 We note that the Plan has rules that relate to Residential Intensity11 Scale of Activities12 and Traffic Intensity13. Accordingly to replace the term ‘Traffic Intensity’ with ‘Activity Scale’ may cause confusion, however adopting the term ‘Traffic Scale’ would at least better declare what is meant by the currently used term: ‘Traffic Intensity’.

175 Accordingly we would recommend that:

The terminology in the Plan relating to Traffic Intensity be replaced by the term Traffic Scale, and the term Traffic Intensity Factor be replaced by the terms Traffic Scale Factor, Traffic Scale Value and Traffic Scale Threshold, as the context dictates.


Summary of Amendments

176 To be completed…

CONCLUSIONS

177 To be completed…

~

11 e.g. Rule 7.6.5.1.2 Residential Intensity12 e.g. Rule 7.6.5.2.2 Scale of Activities13 e.g Rule 7.6.5.2.6 Traffic Intensity




38 of 39

APPENDIX 1 – ZONE TIF VALUES

7.6 RESIDENTIAL ZONETIF value for Permitted Activities 20TIF Value for Restricted Discretionary Activities 40TIF Value for Discretionary Activities >40

7.7 COMMERCIAL ZONETIF value for Permitted Activities 200TIF value for Controlled Activities 500TIF Value for Restricted Discretionary Activities >500

7.8 INDUSTRIAL ZONETIF value for Permitted Activities 200TIF value for Controlled Activities 500TIF Value for Restricted Discretionary Activities >500TIF value for Discretionary Activities >500

8.6 RURAL PRODUCTION ZONETIF value for Permitted Activities 60TIF value for Controlled Activities 60TIF Value for Restricted Discretionary Activities 61 to 200TIF value for Discretionary Activities >200

8.7 RURAL LIVING ZONETIF value for Permitted Activities 20TIF value for Controlled Activities 20TIF Value for Restricted Discretionary Activities >20 to 40TIF value for Discretionary Activities >40

8.8 MINERALS ZONETIF value for Permitted Activities 200TIF Value for Restricted Discretionary Activities 200TIF value for Discretionary Activities >200

9.6 RECREATIONAL ACTIVITIES ZONETIF value for Permitted Activities 200TIF Value for Restricted Discretionary Activities >200 to 400TIF value for Discretionary Activities >400




39 of 39

9.7 CONSERVATION ZONENo reference to TIFs

10.6 GENERAL COASTAL ZONETIF value for Permitted Activities 30TIF value for Controlled Activities 30TIF Value for Restricted Discretionary Activities 30TIF value for Discretionary Activities 120TIF value for Non-Complying Activities >120

10.7 COASTAL LIVING ZONETIF value for Permitted Activities 20TIF value for Controlled Activities 20TIF Value for Restricted Discretionary Activities >20 to 40TIF value for Discretionary Activities >40

10.8 COASTAL RESIDENTIAL ZONETIF value for Permitted Activities 20TIF Value for Restricted Discretionary Activities > 20 to 40TIF value for Discretionary Activities > 20 to 40

10.9 RUSSELL TOWNSHIP ZONETIF value for Permitted Activities 20TIF Value for Restricted Discretionary Activities >20 to 40TIF value for Discretionary Activities > 40

~


8040 fndc tifs and parking s32 - viastrada.nzviastrada.nz/sites/default/files/8040 fndc tr...

Documents