before the christchurch replacement district plan independent hearings … · 2015-05-01 · before...

GJC-291666-3-89-V1

BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN INDEPENDENT HEARINGS PANEL

IN THE MATTER of the Resource Management Act 1991 ('the Act') and the Canterbury Earthquake (Christchurch Replacement District Plan) Order 2014

AND

IN THE MATTER

the Christchurch Replacement District Plan: Proposal 15 (Commercial).

REBUTTAL EVIDENCE OF JAMES DICKSON LUNDAY ON BEHALF OF DANNE

MORA HOLDINGS LIMITED

(Submitter No. FS-1430)

Dated: 01 May 2015

1134 Danne MoraRebuttal: James Lunday with annexures

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INTRODUCTION

1 My full name is James Dickson Lunday.

2 My qualifications and experience are set out in my evidence in chief, dated 24

April 2015.

3 I have read the Environment Court's Code of Conduct and agree to comply

with it. I confirm that the issues addressed in this statement of evidence are

within my area of expertise.

4 The data, information, facts and assumptions I have considered in forming my

opinions are set out in the part of the evidence in which I express my opinions.

I have not omitted to consider material facts known to me that might alter or

detract from the opinions I have expressed.

SCOPE OF REBUTTAL

5 This rebuttal evidence responds to the evidence-in-chief of Jacobus (Kobus)

Marthinus Mentz, dated 24 April 2015 in particular his Figures 1-14.

Figures 1 to 2

6 In my opinion these figures fail to properly explain the wider context of the

proposed location of the Key Activity Centre (KAC) within the North Halswell

ODP. In particular:

• The figures ignore the council owned Douglas Clifford stormwater

basin immediately to the south of the TDS proposed ODP. This facility

is approximately 4.7 hectares in total and therefore represents a "void"

as Mr Mentz appears to use that term;

• The aerial used in figures 1 and 2 is outdated and therefore fails to

show the existing Aidanfield housing development on the north west

side of Halswell Road, development which is shown in his figures 3

and 4;


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• These figures fail to acknowledge the already zoned Meadowlands

Exemplar housing, which is partially shown in his figure 3 & 4;

• The figures do not identify Augustine Drive that connects to Nga Puna

Wai reserve, or the planned extension of Augustine Drive from

Halswell Road to Sparks Road; and

• Fail to recognise the proposed Nga Puna Wai regional sports hub (as

approved by the Council on 12 March 2015) which is to be located in

the area indicated by Mr Mentz as a void. Not only will this become a

heavily used centre for the south west but facilitate a new local traffic

circulation from McMahons to Augustine Drive.

7 The intention is to connect McMahon Road in Aidanfield with the new

Augustine Drive, via the sports hub, where it is intended to have a controlled

intersection at Halswell and Augustine.

8 The distance between the boundary of the proposed KAC and Nga Puna Wai

along Augustine Drive is approximately 250 metres (less than the length of the

Main Street) and is certainly a walkable distance. The proposed KAC will

therefore be highly accessible to the users of Nga Puna Wai, and vice versa.

9 Therefore, Nga Puna Wai and the proposed KAC operate as a major business

and community hub for the south west. The importance of the Augustine

connection should not be understated. Nga Puna Wai is a city wide facility – a

home for multiple sports, attracting participants and supporters.

10 I have produced a more complete contextual analysis and in my opinion, when

the missing context is considered, to use Mr Mentz’s phrase the CCC KAC is

in fact the "centre of gravity”.


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Figure 1. KAC context

Figures 3 and 4

11 The shape identified by Mr Mentz in his figure 4 is, in my opinion, artificial and

is not representative of the Outline Development Plan for the KAC. The

Centre is not wedged in the corner, rather it sits within a much larger wider

environment (see context plan above).

12 The arrows used by Mr Mentz in figure 4 are significantly shorter than the

equivalent arrows used by him in figure 3. If one were to use equivalent

arrows then they would extend into an existing residential catchment to the

north east. The arrows infer the KAC is only servicing Greenfield areas as opposed

to existing development areas and the wider south west catchment.

Figures 5 to 8

13 Figure 5 is redundant as it is outdated. It has been superseded in the

Caucusing Agreement.

14 Figure 6 does not represent the 26.7 ha sought in TDS’s ODP and figure 20

which illustrates 31.9ha. Our CAD calculation of his master plan shows


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GJC-291666-3-89-V1 /13 Page 5/13

78,000m2 of footplate. That would amount to an inefficient 29% coverage. If

this same footplate was applied to the smaller 17.3 hectare ODP, the

coverage increases to a still acceptable 45%. I do not consider all activities at

ground level desirable for the Centre.

15 Mr Mentz introduces in figure 6 artificial “large” and “small” KAC options.

These do not correlate with the Council ODP shape or with TDS's larger ODP

shown in figure 20. I consider these are not helpful in determining the KAC

catchment. We have redrafted the KAC's shown in figure 20 to provide a

correct and transparent comparison between the Council’s 17.3 hectare and

the 31.9 hectare ODP identified in Mr Mentz’s figure 20.

16 The corrected catchment diagrams show the CCC KAC delivers 28ha of

potential medium density residential land, whilst the TDS ODP delivers

19.9ha.

Figure 2. Revised Catchment diagrams (*refer to appendix for full size)


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Figure 3. Revised Catchment diagrams with CCC ODP (*refer to appendix for full size)

17 I have emphasised the areas rather than the potential number of households

as there is some uncertainty around what final density may occur. For

example, there is flexibility around the residential intensification target of 15

households per hectare i.e landowners may choose to develop to a higher

density Equally, 30 households per hectare medium density housing "in or

near" KAC's is not required in the Proposed Replacement District Plan.

Figures 9 to 11

18 The location of the Transport Interchange is an indicative feature only within

the ODP. The final location of the Interchange will be determined after

discussions with, amongst others, Environment Canterbury, the Christchurch

City Council and NZTA.


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GJC-291666-3-89-V1 /13 Page 7/13

19 The location indicated in figure 9, in my opinion, would be too remote to fit into

the wider transport (public) network, particularly with the creation of Nga Puna

Wai sports complex which will be serviced by public transport.

20 Given the strong pedestrian flows likely between the KAC and Nga Puna Wai,

supported by a signalised intersection at Augustine Drive providing a safe and

legible crossing point, it is my opinion the Interchange is more likely to be in a

northern location.

Figure 12

21 The Common Ground design used by Mr Mentz for his analysis is an early

indicative design only and is out of date. I have supplied our latest indicative

design in my evidence in chief.

22 In Mr Mentz’s evidence he questions the practicality of irregular block and

building shapes. In my opinion, irregular shapes and non-orthogonal grids

create a better opportunity to provide for all the elements of good place-

making. As well illustrated in the Rouse Hill development mentioned by Mr.

Mentz, irregular shapes facilitate more built form variety and interest that in

turn helps place making, and supports increased legibility and way finding.

Figure 13

23 Mr Mentz has used an out of date conceptual plan in Figure 13 instead of the

Council ODP. The movement system in the Council ODP is based on an

inner and outer circulation route, intersected by a lower car

movement/pedestrian orientated Main Street. Bus traffic, car access and

parking manoeuvres around the core pedestrian orientated mixed use town

centre core. The movement network facilitates development of all land owners

sites and minimises the amount of land taken up by roads.

24 The TDS larger KAC framework also appears not to reflect their ODP (figure

20). There is a very strong reliance of their Main Street attracting traffic, based

on a theory that retail will only work in a heavily trafficked area. I dispute this,

I also dispute that their movement system would encourage cars to use the

Main Street. Access to the Main Street does not give access to the car parks.


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GJC-291666-3-89-V1 /13 Page 8/13

25 The main entry to the Main Street from either the proposed Halswell southern

entry(s) or Augustine Drive is complex and not legible. The road layout has

no understandable hierarchy, no real centre or core, and a very poor internal

circulation network. It would involve building a large road network to unlock all

the land owners and does not appear to recognise the complexities of staging

development and land ownership. It is land hungry.

26 Mr Mentz's roading network is over-complex and will not deliver a mixed use

walkable environment, has poor visibility and a Main Street that will attract

neither foot traffic nor cars.

Figure 14 & 15

27 In figure 14 Mr Mentz proposes a possible master plan for the TDS ODP.

Again this doesn't appear to represent the TDS ODP presented in figure 20.

Figures 14 & 15 are presumably intended to demonstrate his views on town

making opportunities and community, civic and public realm objectives. He

does not appear to take into account Councils current intentions to retain the

library, swimming pool and other sporting facilities outside the current KAC.

28 He refers to Rouse Hill as an example of good design. He says that his TDS

design is based on similar principles. Having just recently visited Rouse Hill for

the purposes of providing this evidence I cannot agree with his conclusion.

Rouse Hill does demonstrate good design but has a completely different form

and mix of uses not reflected in the TDS proposal.

29 There is a depth of research and literature about successful place making

(Sitte, Christopher Alexander, Gordon Cullen, Rob and Leon Krier et al).

Urban design theory and best practise divide areas into positive and negative

spaces, agree that containment of space, permeable connections, small grain

block patterns, a relationship of height to width of space and a compact

walkable environment that contains 24hr activities (mixed use), the major

elements of place making. These elements are not found in the TDS master

plan.

30 I have used Nollie diagrams to assess space qualities and permeability of

Nollie of Rouse Hill Centre in comparison to the TDS proposal. You see a

contrast in the pattern of built to unbuilt space between the two. Mentz’s


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GJC-291666-3-89-V1 /13 Page 9/13

master plan has large grain buildings, low level of permeability, has negative

spatial forms and is so large and poorly integrated that it is not conducive to a

24hrs mixed use walkable environment.

31 Given Mr Mentz’s criticism I include a Nollie of an indicative master plan

design for a KAC within the Council ODP , a design which is more reflective of

Rouse Hill.

Figure 4. Nollie comparisons


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GJC-291666-3-89-V1 /13 Page 10/13

32 The TDS design appears to be based on a ‘Big Box’ development. In my

opinion the layout will create a poorly functioning Main Street environment.

Stripping their design back to its basic elements and core drivers is

represented in a simple diagram.

Figure 5. TDS design framework

33 The layout has 4 large ‘boxes’ that front to large car parks providing ‘first

encounter’ access, with limited connection to the Main Street. The Main

Street has been formed by leaving the rear of the big boxes with smaller retail.

This may or may not happen. The major retailers of the size indicated –

supermarkets, the Warehouse, Harvey Norman, Bunnings, Placemakers to

name some – are all destinations. They have little regard for specialty retail. I

do not believe that approach will deliver a Main Street environment that will

work.

34 The Master Plan in figure 14 does not in my opinion satisfy the policies and

objectives of the KAC. It fails to deliver quality urban design outcomes:


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GJC-291666-3-89-V1 /13 Page 11/13

• Policy 15.8.2.4 - the large centre does not promote an efficient use of

land or achieve a compact urban form. This is a large sprawling, car-

focussed destination retail complex, where the focus on big box,

delivering over 78,000m2 illustrated at grade and an over-provision of

parking, as a result of each big box requiring its own standalone

parking space.

• Has a low level of legibility to access the Centre by car or foot.

o Has a small left in, but not left out, access to the centre from

Halswell Road.

o No access from Aidanfield Drive, and;

o Proposes a new entry that is not part of the ODP in addition to

Dunbars Road

• The first entry off Augustine Drive takes you to a cul-de- sec, The

second entry leaves you with two choices:

o Access to car parks (with no visual access to car parks) or;

o Drive down Main Street with no access to car parking

• Big box and other anchor stores access from major at-grade car parks.

There is limited reason to access the main street with a low level of

permeability.

• The civic square is compromised by the Main Street bisecting it. It is

over-sized, is not fronted by active uses and is at the fringe of the

Centre. There is no requirement for a Market Square in the ODP. It

creates two competing Squares.

• The road layout and parking creates an inefficient use of land

• Residential is relegated to the main entry corner. The core retail has

no residential in it. The safety of the area is compromised after retail

hours.

• The scale, distances and impediments of car parks make this a hostile

walking environment.


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GJC-291666-3-89-V1 /13 Page 12/13

• The Centre is not legible for pedestrians, traffic or passing traffic – the

Main Street has no visibility from surrounding roads

35 The LURP and RPS, and Chapter 15, envisage a mixed use area – which in

urban design terms means having apartments on top of, and within the

Centre. The Mentz design does not, and would not, achieve this. The nature

and form of the movement network, parking and design of Main Street

relegates this to a destination Centre with no urban place making as exhibited

in traditional Centres or expected in the District Plan’s policies for North

Halswell KAC.

CONCLUSION

36 Having looked at the evidence prepared by Mr Mentz and analysed his

diagrams, and offered accurate and corrected analysis of these, I see no need

to change the location, size or shape of the KAC to accommodate a Centre of

the size indicated by TDS. In my substantive evidence I have demonstrated

how the Centre can be achieved.

37 In this rebuttal, I have included an indicative master plan to further show one

way of achieving this. I believe the Council KAC ODP is sufficiently adaptable

and flexible to absorb a number of variations of this design. It can achieve this

in a compact form with the majority of parking at grade – or like most other

centres, there can be a blend of at grade and covered parking. It delivers a

pedestrian focussed Centre without putting the same design demands on

neighbouring properties

38 The draft master plan is not a retail mall as TDS witnesses infer will be the

only outcome for a KAC within the Council ODP. A mall provides solely for

retail spaces and other commercial services, relegating residential to the

fringe of the mall and does not incorporate residential above. The attached

master plan shows how to provide regular shaped footplates for large format

retail which is accessed from the Main Street and in close proximity car parks.

In accordance with the LURP and the RPS, the design facilities a residential


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GJC-291666-3-89-V1 /13 Page 13/13

environment within the centre. This is achieved through good urban design

within 17 hectares.

39 TDS have proposed a larger KAC than anticipated by CCC. Mr Mentz and Mr

Cullen try to justify a larger KAC based on Aidanfield Road being the main

entry long term and hence being the centre of activity, and a design that

anticipates a dominance of ‘Big Box’ retailers.

40 Their contextual analysis misrepresents the Council KAC, located as part of

an existing and developing environment. The size of TDS land holding has

driven the Mentz design resulting in it not being compact or walkable in

nature.

James Lunday

01 May 2015


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client:

© CopyrightThe concepts & information contained on this plan are copyright of Common Ground Studio Ltd. Use or copying of the information on this plan without written permission of Common Ground Studio Ltd constitutes an infringment of copyright.

T (+64) 9 302 2200 www.cgstudio.co.nzAuckland Studio: L3 Queens Arcade, 17-21 Customs Street East, Auckland, NZ

Disclaimer: This plan has been prepared on behalf of and for the client. Common Ground Studio accepts no liability or responsibility in respect upon this plan by any third party.

Client

drawn

revproject

drawing

drawingpath

Project Name

Pedestrian Catchment TDS Combined PlansBy checked

Scale

project task

scale

date 1/1/11

Do not scale drawings. Verify all dimensions on site.

date bydetails

rev

name

size A#

By

P# T# DM-6 Afile.vwxPath

0 20 40 60 80 100 m

0 100 200 300 400 m

Halsw

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Hendersons Road

Augustine Drive

Aidenfield Road

Main

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Douglas CliffordStormwater Basin

KAC

400m

400m

No m

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300m

KAC boundary - Masterplan

KAC boundary - ODP

KAC CATCHMENT ANALYSISTDSL ALTERNATIVE MASTERPLAN / ODP

KAC - Masterplan/ODP 26.7 / 31.9 ha

Residential intensification 24.5 / 19.9 ha

Residential - existing 6.0 ha


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client:




Client

drawn

revproject

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Project Name

Pedestrian Catchment CCC ODPBy checked

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date 1/1/11


date bydetails

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size A#

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Halsw

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Hendersons Road

Augustine Drive

Aidenfield Road

Mai

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Douglas CliffordStormwater Basin

KAC

400m

400m

No

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300m

KAC CATCHMENT ANALYSISCCC ODP

KAC area 17.3 ha

Residential intensification 28.0 ha

Residential - existing 18.5 ha


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MENTZ Nolli

CCC KACIndicative Masterplan Nolli

RousehillTown Centre Nolli


page 17 of 20

78,000M2 TOTAL FOOTPLATE


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Community

Housing

Parking

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Carpark

Big Box Big Box

Big BoxBig Box

Sleeve Sleeve

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Entry to Carpark

Front

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Front Back Front

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client:




Danne Mora Holdings Ltd

drawn

revproject

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Proposed North Halswell KAC Framework

KAC - Concept MasterplanSW checked

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date 28/4/15


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11020 - 11 11 KAC-E-12 AKAC Masterplan-Roads&Landscape.vwxPath

0 100 m

0 250 500 m


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