BEFORE THE HEARINGS PANEL

IN THE MATTER of the Proposed Kapiti

Coast District Council Plan Review 2012

AND Submissions by Coastlands Shoppingtown Limited Submitter No. 218 and Further Submitter No. 55

BRIEF OF EVIDENCE OF MARK GRANT GEORGESON TRAFFIC

ON BEHALF OF COASTLANDS SHOPPINGTOWN LIMITED

5 September 2016

________________________________________________________________________________ Solicitors: Counsel Acting: Matthew McClelland QC/ Phernne Tancock D’Ath Partners Harbour Chambers Level 3 Harbour City Towers Level 10, Equinox House 29 Brandon Street 111 the Terrace PO Box 1078 PO Box 10 242 Wellington Wellington Phone: (04) 4990431 Phone: (04) 499 2684 Facsimile: (04) 4990662 Facsimile: (04) 4992705 Email: dathlaw@paradise.net.nz Email: Phernne.Tancock@legalchambers.co.nz

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BRIEF OF EVIDENCE OF MARK GRANT GEORGESON

(BE(Hons) CPEng, MIPENZ IntPE(NZ))

ON BEHALF OF COASTLANDS SHOPPINGTOWN LIMITED

1. INTRODUCTION

Qualifications

1.1. My full name is Mark Grant Georgeson. I am a Chartered Professional

Engineer and hold a Bachelor of Civil Engineering degree from the

University of Auckland. I am:

(a) a Member of the Institution of Professional Engineers NZ and

its specialist Transportation Group;

(b) an International Professional Engineer;

(c) a Member of the Institute of Transportation Engineers USA;

(d) a Member of the Institute of Public Works Engineering

Australia;

(e) a Member of the NZ Parking Association; and

(f) an Associate Member of the NZ Planning Institute.

Experience

1.2. For the last 24 years, I have worked as a traffic engineer with Traffic

Design Group Ltd, practising as a traffic engineering specialist

throughout New Zealand. I am a Director of the Company and

Manager of the Wellington office.

1.3. I am very familiar with the location, having lived in the Wellington

region for the same 24 years, and having been a routine visitor to the

Kapiti region. My familiarity of the town centre comes from a similarly

long record of involvement with Coastlands Shoppingtown Ltd

(“Coastlands”) and also with a number of land developments through

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the period of the last two decades, being part of my firm’s team

provision of transportation advice and design.

Background

1.4. My firm was directly involved in contributing to a submission on the

notified Kapiti Coast Proposed District Plan (PDP) back in 2012, on

behalf of Coastlands, whilst my colleague Ms Eliza Sutton provided

traffic evidence to Coastlands in respect of the Wharemauku Precinct

PPC72A Appeals. My firm has recently been involved in the

Coastlands Square and the Takiri Buildings projects.

1.5. In this matter, I have been asked by Coastlands to prepare and

deliver expert evidence at these Council hearings on both general

and specific traffic and transport related matters of the PDP that can

be considered to have an effect on Coastlands’ interests within Kapiti.

I have already presented evidence in respect of Chapters 2 and 11,

with the focus here on Chapter 6.

2. CODE OF CONDUCT

2.1. While not strictly necessary for Council hearings, I can confirm that I

have read the Expert Witness Code of Conduct set out in the latest

Environment Court Practice Note. I have complied with the Code of

Conduct in preparing this evidence and I agree to comply with it

while giving oral evidence.

2.2. Except where I state that I am relying on the evidence of another

person, this written evidence is within my area of expertise. I have not

omitted to consider material facts known to me that might alter or

detract from the opinions expressed in this evidence.

3. SCOPE AND STRUCTURE OF EVIDENCE

3.1. In this instance, I present my views and findings in respect of the

transportation-related provisions of the Chapter 6: Working

Environment matters of the Coastlands submission. I note here that

Chapter 6: Infrastructure matters are intrinsically linked to the

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provisions included within Chapter 11, in that together they set out the

wider transportation vision of the Plan and the framework of

assessment for new development.

3.2. My evidence here extends the evidence presented in respect of

Chapter 11 and closes out some traffic matters for which further

information and direction from Council was sought at the time. My

evidence provides:

(a) a summary of the original Coastlands submission on the PDP

Chapter 6 (Section 4);

(b) an outline of the broader traffic and transportation context

of the PDP, including particularly in respect to the traffic

modelling undertaken and the manner in which it informs

the proposed provisions (Section 5);

(c) reference to Mr Hansen’s evidence in respect of the inter-

relationship with Coastlands submission points on Chapter 6

and relief sought (Section 6); and

(d) a full review and assessment of the Section 42A (“s.42A”)

Report and recommendations regarding the PDP provisions

(Section 7).

3.3. I then present overall conclusions at Section 8.

4. COASTLANDS SUBMISSION ON PDP

4.1. The original submission by Coastlands on Chapter 6 of the PDP sets out

four main areas of interest with regard to traffic matters, as follows:

a) Structure Plan: set outs the history of its development along

with the context with roading connections and subsequent

modelling assessments;

b) Traffic Thresholds: the manner in which blanket traffic

generation thresholds are applied to all working environment

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zones without due consideration of the adjacent transport

environment, or regard for the centres hierarchy;

c) District Centre Zone: the Centres Hierarchy approach of

Chapter 6 Policies, which aims to provide for intensification

of activities within existing centres, and regulate

development outside of these;

d) Airport: provisions applied at the Airport with respect to levels

of development, associated traffic implications arising from

the expansion of the Mixed Use Precinct on the adjacent

road network, and the knock-on effect for transport

planning within the established centres.

4.2. With regard to the last matter, Coastlands expresses concern about

specific submission points made by KCAHL with respect to the impacts

that potential development could have on the performance of the

traffic network serving the Paraparaumu Town Centre, including on

Precincts A1 and A2 particularly given the level of existing congestion

and lack of capacity along Kapiti Road. I discuss Airport matters

more fully towards the end of Section 7 of my evidence.

5. TRAFFIC AND TRANSPORTATION CONTEXT

5.1. In my previous evidence on Chapter 11: Infrastructure, I provided an

overview of the particular traffic and transport context of the District

Plan, as it relates to the submissions made by Coastlands. I do not

repeat that detail here, but I do provide an overview of the traffic

modelling that has been undertaken to inform the PDP, below, which

has in turn assisted me to extend my Chapter 11 views in respect of

traffic thresholds.

Traffic Modelling

5.2. Whilst I am aware the Commissioners have specifically requested that

expert witnesses refrain from commenting on the most recent VISSIM

microsimulation modelling, as this is not yet complete, I thought it

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useful to set out an overview of the traffic modelling work undertaken

to date, and the way in which this modelling has, as I understand it,

informed the PDP.

5.3. Discussions held on 23 August 2016 between traffic experts

representing Council; NZTA; KCAHL; St Helier’s, and myself, provided a

briefing on the modelling history to date. The Minutes from that

meeting demonstrate significant frustration from submitters regarding

Council’s failings in properly assessing the current issues and forward

needs of the traffic network. In my view, there was a consensus of

opinion amongst participants that Council’s approach to assessing

these issues has been inadequate.

5.4. These discussions confirmed that the recent VISSIM microsimulation

modelling has not informed any part of the PDP traffic provisions,

despite first intentions. Instead, Council has indicated that the Kapiti

Traffic Model (“KTM”), which is developed in ‘SATURN’ (Simulation and

Assignment of Traffic to Urban Road Networks) software, has been

relied on to inform network capacity investigations and associated

infrastructure requirement decisions, with additional ‘checks’ of

intersection performance carried out using the ‘SIDRA Intersection’

software.

5.5. I note for the benefit of the Commissioners, that SATURN is a

macroscopic package used generally for modelling large traffic

networks (towns). Whilst it can take account of wider area re-routing,

this higher level modelling is by nature more coarse, making it less

effective at assessing localised changes to the network (such as the

proposed State Highway 1 revocation works and impacts along Rimu

Road), or accounting for detailed interaction and lane usage

between adjacent intersections, particularly along congested

corridors (such as Kapiti Road).

5.6. By contrast, SIDRA is a deterministic (i.e. reliant on mathematical

formulae) model used primarily for evaluating individual intersection

performance, based on capacity, and provides detailed

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performance measure outputs; the most commonly used being ‘Level

of Service’ (“LOS”), which is a measure of vehicle delay. Whilst SIDRA

provides a high level of detail with regard to localised intersection

operation, it cannot take account of interactions between adjacent

intersections or dynamic traffic patterns across the network, and relies

instead on discrete vehicle approach volumes inputted by the user.

Accordingly, this analysis tool has significant limitations in network

applications.

5.7. Microsimulation modelling packages such as VISSIM generally sit

between the high level and discrete intersection analysis packages

described above, providing a dynamic modelled network that can

adjust in response to congestion that arises during the peak periods,

when demand can exceed capacity on parts of the network. These

models can also take account of the interaction between individual

vehicles and adjacent intersections, and assess wider area re-routing.

Accordingly, micro-simulation packages such as VISSIM represent the

most sophisticated traffic modelling available, and can provide the

most robust analysis of network performance.

5.8. Council’s decision to commission a detailed VISSIM model of the

Paraparaumu town centre, first in 2015 and again in 2016, is in my

view, representative of the uncertainty associated with the limitations

of the SATURN and SIDRA analysis tools, for assessing both the current

network operation and performance, along with the future

performance in the wake of such planned projects as the SH1

Revocation, the Ihakara Street Extension, the Relief Road and further

intersection upgrades, including along Kapiti Road.

5.9. Logically, in my view, this uncertainty extends to the impact that

further development would have within the town centre; along Kapiti

Road; and at the airport. That is, there is currently no reliable traffic

modelling to test traffic additions and effects of continued

development.

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5.10. To that end, I confirm Council’s indication that network modelling has

not informed the traffic thresholds of the PDP. Rather, and in my

words, the proposed traffic thresholds appear to be arbitrary. I return

to this matter of traffic thresholds later in my evidence.

6. REVIEW OF SUBMISSION ON CHAPTER 6 AND RELIEF SOUGHT

6.1. I note that Mr Hansen provides a detailed summary of the individual

submission points raised by Coastlands, and there is no need for me to

duplicate these here.

7. REVIEW OF AND RESPONSE TO SECTION 42A REPORT

7.1. Through the remainder of my evidence, I provide a summary of the

assessment and recommendations set out in the s.42A Officers Report,

in response to the relevant issues raised in the Coastlands submission

on the PDP. I then provide return comment and assessment on the

recommendations, and the subsequent implications of these.

7.2. The remainder of this section of my evidence addresses, in turn:

(a) definitions;

(b) Structure Plan;

(c) District Centre zoning;

(d) traffic thresholds; and

(e) Airport provisions.

Definitions

7.3. The Coastlands submission raised a number of matters relating to

Chapter 6 definitions, including opposition to the KCAHL submission

requesting amendment to the definition of a Department Store, on the

basis that this request moves away from the specific agreements

reached under Plan Change 73 (Airport Zone).

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7.4. At Paragraph 125 of the s.42A Report, the Reporting Officer notes the

definition as included in the PDP is consistent with that settled as part

of PC73 as well as aligning with equivalent definitions in District Plans

elsewhere around the country. A recommendation to retain the

current definition included in the PDP is made. I confirm that this

appropriately addresses Coastlands concerns in respect to this

definition. I comment further on activity status concerning

Department Stores at the end of Section 7 in addressing Airport

Provisions.

7.5. The Coastlands submission requested some clarification on the

wording relating to Large Format Retail (“LFR”), which reads in the PDP

as if it relates exclusively to the Airport Mixed Use Precinct, which

could subsequently influence developers looking to establish such

activities outside of the Airport.

7.6. Paragraph 155 of the s.42A Report acknowledges Coastlands

concerns that the current wording within the PDP is confusing, and the

Officer recommends an amendment to make it clear that the LFR

definition applies District wide, along with an additional

recommendation that places specific limits on the nature of LFR

activities that can occur within the Airport Mixed Use Precinct. These

amendments fully address the Coastlands submission in respect of this

definition.

7.7. Coastlands opposes the PDP definition of Supermarket, requesting

that it be replaced with the McDermott Miller Retail Strategy (2006)

definition, which includes a floor area threshold of 1,000m² GFA, on

the grounds that this definition better captures the current trend

towards smaller ‘metro’ style supermarket stores.

7.8. Paragraph 199 of the s.42A Report addresses the Coastlands

submission with regard to a reduction in size threshold for supermarket

activities, but rejects it on the grounds that the 1,500m² GFA was

arrived at through the PC73 process.

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7.9. In a manner similar to other preference issues I point to later in my

evidence, this appears to be an airport-centric decision and does not

seem to give due consideration to the town centres. I return to the

matter of activity status of Supermarkets in the Airport Zone later in my

evidence.

District Centre Zone Structure Plan

7.10. As I have previously outlined in my Chapter 11 Infrastructure

evidence, understanding what form the District Plan proposes for the

District Centre, and where local roading infrastructure including new

routes will be located, is critical in achieving an integrated vision for

development of the town centre and crucial to ascertain the likely

effects of those activities. Council seeks to implement that vision in

the form of the District Centre Zone Structure Plan at Appendix 6.7.

7.11. Where Policy 6.11 references the District Centre Structure Plan (at

Appendix 6.7), Coastlands strongly opposes this Structure Plan on the

basis of the process through which it was introduced, the manner in

which it was developed (with little consultation with Coastlands), and

the impact it will potentially have on the Coastlands site. The

Coastlands submission sought to have this Structure Plan withdrawn

from the PDP.

7.12. Coastlands concerns about the Structure Plan are fully canvased in

the planning, urban design and legal submissions on behalf of

Coastlands. My evidence will address the traffic related concerns

only, but from a traffic perspective my views align with the comments

made by Mr Lunday.

7.13. Due to the fact that the s.42A Report recommends a revised Structure

Plan, I divide my comments into two categories, those relating to the

2012 notified Structure Plan (“2012 Structure Plan”) and those relating

to the revised structure plan being referred to by the Officer (“the

2016 Structure Plan”). I also refer to the Plan introduced in the SEV.

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2012 Structure Plan

7.14. The Coastlands original submission on the notified 2012 Structure Plan

sought to remove the location and form of the Boulevard shown on

the Structure Plan map, along with references to it within the PDP,

and further sought to have the term corner building marker deleted.

For reference, I include a graphic of this 2012 Structure Plan below.

7.15. By way of summary, the Coastlands original submission opposed a

number of traffic matters relating to the provisions and assumptions

contained within the 2012 Structure Plan, including:

• formalisation of existing private accessway routes through

Coastlands, which it assumes are ‘public roads’ - in some

instances these run through existing Mall structures;

• the location and alignment of the Relief Road (identified in the

above image as Boulevard), connecting Rimu Road with Kapiti

Road;

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• the impact of the Boulevard route through Precinct A2 and the

general prescriptive nature of it on the amount of useable land

within this site, which has significant impacts on the economic

viability of developing this precinct (Rule 6A.1.11/ Rule 6A.1.12);

and

• the responsibility of achieving the outcomes of the identified

roading connections being firmly placed on the land owner and

construction of these roads acting as a barrier on development

of the area (Rule 6A.1.12).

7.16. Coastlands sought to delete the provisions of the 2012 Structure Plan,

and revisit development of a plan which drew from consultation with

stakeholders, and incorporated the provisions of the PC72A Consent

Memorandum.

SEV Structure Plan

7.17. Paragraph 1845 of the s.42A Report notes that in response to

submissions received (including Coastlands) on the 2012 Structure

Plan, Council commissioned Beca to undertake a comprehensive

review. This review enabled further consultation during the period

2014-15, which led to development of the revised Structure Plan

included in the SEV. I provide a copy of this revised SEV Structure Plan

below.

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7.18. Whilst I observe that the SEV version makes a number of changes to

the 2012 Structure Plan, which addresses some of the concerns raised

in the original Coastlands submission, I note that the Officer’s

recommended Structure Plan (seen for the first time in the s.42A

Report) is different again. As such, I will not go into any detailed

analysis of this SEV Plan here, but will instead address in detail the later

2016 s.42A report recommended version, below as I understand that

that is the version that Council is now advancing.

2016 Structure Plan

7.19. From Paragraph 1845 of the s.42A Report, which draws on the advice

outlined within the February 2015 Beca review report, as well as that of

Council’s traffic experts, the Officer goes on to recommend an

updated version of the Structure Plan (which more closely resembles

the SEV version - but is different again). I include a copy of the

Officer’s recommended version of the Structure Plan below.

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7.20. This 2016 Structure Plan makes a number of related changes as

compared to the “2012 Structure Plan.” Specifically, there is a new

alignment for the Relief Road that connects Ihakara Street with Kapiti

Road. I note that the location of this road has changed several times

since the PDP was notified in 2012.

7.21. With respect to the related advice of Council’s traffic experts, which is

reported under Section 3 of the Memo included at Appendix 10 (of

the s.42A Report), it is reported that the:

“[2016] Structure Plan road network has been tested and found to

be satisfactory in traffic capacity terms and also in terms of other

requirements such as meeting funding criteria”.

7.22. I am not familiar with the technical assessments that support this

position, but note that it is on this basis that the Officer rejects

Coastlands submission to delete the Structure Plan, or start the process

over again, and concludes her assessment of the revised 2016

Structure Plan at Paragraph 1876 of the s.42A Report, by making the

following recommended changes to the wording of the Structure Plan

Appendix:

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“The Structure Plan provides for the development of a movement

transport network which will increase the connectivity through

and to the District Centre Zone. Because of the current lack of

connectivity in the District Centre Zone, traffic thresholds are

required at this time to manage traffic effects.

The Structure Plan also provides for a range of land use activities

which are appropriate within the Paraparaumu Sub-Regional

Centre. The location, scale and design of these activities are

managed through the rules and standards.”

7.23. I will provide some detailed discussion on the Officer’s assessment of

the Structure Plan in the following paragraphs, along with referencing

Mr Lunday’s evidence.

Assessment of Officer’s Recommendations on Structure Plan

7.24. Firstly, I note that the Officer’s recommendation to remove the

reference to Boulevard and corner building marker. However I note

that the Officer suggests replacing this with the term “desired road

connection ”. In my view, there is insufficient information at this point

to enable a proper assessment of the validity or otherwise of the

desired connector roads. In addition, this term does not provide any

certainty about the nature of the connection that is envisaged, either

in terms of capacity, function or amenity it is intended to provide.

7.25. Whilst Council’s traffic advisors in Section 3.10 of ‘Chapter 6 (Working

Environment) Traffic and Transport Issues Memo’ (“Memo Chap-6”)

indicate that these connections would be subject to the NZS4404.2010

Land Development and Subdivision Infrastructure design guidance, I

note this standard includes a broad range of roading carriageway

widths in accordance with the function they will serve. I do not

consider placing such restrictions on land and how it might be

developed with respect to costly and inhibiting roading infrastructure

is reasonable or fair.

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7.26. In assessing the Coastlands submission to re-start the 2012 Structure

Plan process, the Officer notes that the evolution of this 2016 Structure

Plan represents the culmination of a significant amount of planning

and consultation from Council, including key inputs such as the 2012

Urbanism+ assessment, alongside the more recent work including the

Town Centres and Connectors Transformation Project (“TCCTP”). The

Officer determines that it represents the most efficient and effective

method for managing development of the area and that it is

consistent with the Policies included in the PDP. I disagree.

7.27. The TCCTP is a Council initiative which aims to deliver stronger

planning visions that achieve better defined town centres, for both

Paraparaumu and Waikanae. Due to the delay in the PDP, this

process has overtaken the PDP, but the PDP does not appear to be

informed by the TCCTP, and cannot be because not all the work is

complete (for example the modelling on the Town Centre Network).

The TCCTP is a collection of projects, including Kapiti Road upgrade

(2015-17); SH1 Revocation (2015-18); Coastlands and Civic

connection project (2015-18); and Rimu Road main street and

streetscaping (2024-28). It is disappointing that there could not be a

consistent approach that properly informs the PDP.

7.28. There are also timing difficulties reconciling the outcomes of the

ongoing revocation work with the timeframes firstly for these hearings,

but also within the lifetime of the PDP. With regard to Rimu Road main

street, I note from the Long Term Plan that construction on this is not

scheduled to occur for 8 years until 2024 (at the earliest) and that

much of the timing for other funding and projects linked to this is

vague. It is not immediately obvious as to why this cannot be

undertaken earlier, particularly given that from a traffic perspective

this would seem to be a fundamental component of developing a

more traditional town centre. One possibility may be that Council

assumes that this cannot be undertaken until such time as the Relief

Road between Ihakara Street and Kapiti Road has been constructed,

as prior to this traffic flows on Rimu Road would be prohibitively high,

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impeding development of the desirably lower trafficked main street

environment sought. However based on the information to date it is

difficult to comment on the validity of that assumption.

7.29. I note that if this is the case, then this would appear to bring into

question the validity of the current SH1 Revocation design intent, as

constraining capacity on this route will serve to push more ‘through

traffic’ that does not need to visit the town centre, onto Rimu Road.

7.30. Logically therefore, if more capacity is retained on SH1, then the

increase in traffic patterns as forecast in the KTM model for Rimu

Road, which to some extent underpin the Relief Road requirement,

may be somewhat misleading.

7.31. These issues around uncertainty with respect to the current and future

town centre transport network performance highlight the benefit of

having an appropriate transport network model that can inform these

inter-related projects, and take account of the changing traffic

patterns on Kapiti Road and within the District Centre. It is a pity this

has not occurred in time for the PDP.

7.32. In my opinion, whilst these uncertainties remain, there is limited value

in providing a Structure Plan which includes desired connector roads

that have not been subject to detailed modelling analysis, to test the

robustness and actual benefits delivered, as compared to alternative

network infrastructure arrangements that could be implemented.

Quite simply, I cannot be clear as to whether these routes will be

successful, or indeed if they are necessary, (or if they will even

properly manage the effects associated with development within the

precincts). As such, I question why they are being formalised in the

Plan at this point in time. As I see it, including these desired connector

roads in the Plan in advance of the modelling information, sets up an

inflexibility in the Plan which closes off the future opportunity to ensure

that new linkages are fit for purpose.

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7.33. Whilst the Relief Road modelling in the KTM indicates (at a coarse

level) it can provide significant relief to traffic congestion within the

District Centre, in my opinion there is a need for far more detailed

analysis to be undertaken to understand what ‘relief’ the road is

providing. For example, does it provide relief for the revoked SH1? or

Kapiti Road? or Rimu Road? or indeed development outside the

District Centre?

7.34. In lieu of more detailed traffic modelling necessary to test the

assumptions of the Structure Plan roading, I concur with Mr Lunday’s

evidence in putting forward the proposal that provides an ‘Outline

Development Plan’ that enables a more informed Structure Plan

process to be undertaken for the Precincts, at a time when the

detailed traffic modelling has been completed and is available, and

Council and landowners have a better appreciation of the likely

impacts of proposed changes to the traffic network.

7.35. In my opinion, it is critical that such doubts be addressed before

committing to a Structure Plan that will be adopted within the District

Plan, to avoid the lengthy and potentially embarrassing necessity for

a subsequent Plan Change (or alternatively stalling development

within the Town Centre for another ten years).

Responsibility for Structure Plan Infrastructure

7.36. Whilst Coastlands is generally supportive of the intent of Policy 6.16,

there is concern that its wording implies that developers need to

address connectivity and transport issues, before development can

occur.

7.37. Paragraph 952 of the s.42A Report addresses Coastlands submission

with the Officer partly acknowledging the concerns raised in terms of

fairness to developers, stating that:

“I agree that whilst the intent of the policy is generally sound in

that connectivity to and within centres is important, there are

some issues in terms of the practicality and feasibility of some of

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the principles, including that some of them are likely well be [sic]

beyond the control of a developer and what might be

achievable as part of a development.”

7.38. The Reporting Officer subsequently recommends the following

changes to Policy 6.16:

(S.42A report) Policy 6.16 – Connectivity to and within centres

Subdivision, use and development will be designed and located

to enhance connectivity and access to public transport, shops

and services and centres in general accordance with the

following principles:

a) logical effective and efficient transport routes and facilities

will connect new developments with the surrounding context;

b) public spaces and street will be provided designed to

support a range mix of land uses and activities;

c) the provision of transport routes and nodes will be designed

to integrated with adjoining land uses;

d) street connections will be provided to adjoining

neighbourhoods;

e) active modes and integration with public transport routes

and infrastructure will be provided for where it is appropriate;

f) missing transport links will be completed;

g) major traffic-generating activities and busy roads which

divideing centres or acting as a physical barrier to the

connectivity of a centre will be avoided; and

h) landmarks and transport nodes will be linked with strongly

well-defined pedestrian pathways where appropriate.

7.39. Whilst the addition of the word ‘general’ to the first paragraph of the

Policy wording assists in setting some context to the intent, Clause (f)

still suggests that in the case of the District Centre Structure Plan, there

remains an implied requirement on developers to provide and fund

desired connections that cross their land. I also note that Clause (g)

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could be viewed as discouraging major traffic generating activities

(when looked at in combination with Council’s proposed definition)

from locating in the town centre. I have discussed this issue in my

chapter 11 evidence and I would have expected that the roading

network should be capable of accommodating these Town Centre

type activities in the Town Centre (the very place they are expected

to occur).

7.40. To me, as I have referred to in my prior evidence for Chapters 2 and

11, such requirements mean that the PDP cannot facilitate its own

intentions, for consolidation of development and activity in the town

centre, as I will discuss more fully in the next section of my evidence.

Chapter 6 Approach – Centres Focus Approach and District Centre

7.41. Overall, Coastlands submission is generally supportive of the intentions

of Chapter 6, in particular Policy 6.1, Policy 6.2 and Policy 6.3 which,

through the adoption of the centres hierarchy, seek to encourage the

consolidation of activities within the existing centres, in line with the

Objectives of Chapter 6, and in particular enable development of a

more traditional town centre for Paraparaumu.

7.42. In my opinion, this centres hierarchy approach is consistent with good

transportation practice, particularly within the District Centre, such

that by enabling a greater concentration of activities means

development can be more efficiently served and supported by

appropriate transport infrastructure, including a roading network that

can accommodate anticipated activity within the centre; a high

quality walking and cycling network; and convenient public transport

connections, both locally through bus services, and regionally through

the rail services, which offer viable mode choice for trips other than by

private car.

7.43. I share the concerns of Coastlands other experts in particular Mr

Lunday and Messr’s Small and Copeland regarding the traffic effects

of dispersing retail in other areas, by making concessions to enable

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more extensive retailing to occur on St Helier’s land and at the Airport.

From a traffic perspective these concessions that disperse retail out of

the Paraparaumu Town Centre need to also be viewed as creating

an expectation amongst landowners of those properties that the

Council has identified as having new roads to support those activities

and / or to enable development of those areas to occur.

7.44. I note that dispersal of retail results in and also encourages an

inefficient roading network, as it changes the way in which road users

use the network and routes they take in an unpredictable way. It also

diminishes transport efficiencies and undermines public investment in

this infrastructure.

7.45. In this regard, continued development of the District Centre, including

through the likes of the recent Coastlands Square and the Takiri

Buildings resource consents, aligns with the principles of establishing a

greater agglomeration of activities, as anticipated by the PDP Policies

6.1-6.3, and the TCCTP, and in turn will desirably contribute to the

development of a more traditional town centre environment, which

Paraparaumu has to date not achieved.

District Centre Zoning Matters

7.46. The Coastlands submission opposes Policy 6.13, along with part of the

intention of Policy 6.4 and Policy 6.11, with respect to provisions in the

PDP that relate to land within the Ihakara Street West Precinct and the

Ihakara Street Industrial Zone, which have been isolated from the

adjacent A1 and A2 Precincts and allocated ‘Outer Business Centre

Zone’ and ‘Industrial Zone’, respectively. Coastlands also objects to

the introduction of this Outer Business Zone category, which is contrary

to the outcomes of PC72A.

Ihakara Street West Precinct

7.47. This area of land, located to the west of Rimu Road and straddling

Ihakara Street (which includes land immediately abutting Precinct A2,

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as well that on the opposite side of Ihakara Street), was included

within the provisions of PC72A.

7.48. The s.42A Report responds to Coastlands concerns regarding the

PDP’s allocation of an Outer Business Centre Zone, at Paragraph 907,

noting that including this land within A2 would be inappropriate on

grounds of traffic related constraints. The Officer subsequently makes

the following recommendation to the wording of the Plan:

“Policy 6.13 – Outer Business Centre Zone

c) limited retail activities will be limited to provided for in the

Paraparaumu North Gateway Precinct and Ihakara Street West

Precinct where they demonstrate they will not have adverse

effects on the role, function and vitality of centres; …”

7.49. The Officer’s recommendations therefore do not alleviate Coastlands

concerns with regard to the way in which development of this land,

which was provided for under the Wharemauku Precinct, has now

been isolated into a more restrictive zoning category. There are in my

view no new traffic reasons to isolate it. I support the comments

made by Mr Lunday that the current and future use of this area should

be retail. From a transport perspective locating these activities in this

area in close proximity to the core parking and public transport is

better than dispersing activities throughout the wider traffic network.

7.50. The Environment Court in PC72A confirmed that this area should be

included in Precinct A2. I have not seen any detailed discussion from

Council’s traffic experts as to why this has now been omitted. I note

that Mr Wignall participated in traffic conferencing and gave

evidence in respect of the PC72A appeal and advised Council

regarding the settlement of the Coastlands appeal. At that point he

was supportive of the inclusion of this area within what is now Precinct

A2.

23

Ihakara Street Industrial Zone

7.51. Paragraph 861 of the s.42A Report responds to Coastlands concerns

with regard to the land north of Ihakara Street, immediately adjacent

to Precinct A1, and notes that this land is currently zoned

Industrial/Service within the Operative Plan. Drawing direction from

the economic research, which supports limiting the area zoned for

retail/commercial uses, and suggests that there is an adequate supply

for these uses out to 2033 (inclusive of Precinct A2) within the District

Centre, the Officer recommends retaining the Industrial zoning for this

land, as included in the PDP.

7.52. Coastlands notes its concerns have therefore not been addressed,

and in light of the fact that this land has in part been developed more

recently (within recent years) for retail and commercial purposes,

rather than industrial, and includes established vehicle links through to

A1, the PDP presents an inconsistency with this land use and adjacent

interconnected activity use. There is in my view no traffic reason to

have this land excluded from the District Centre.

Traffic Thresholds

7.53. Coastlands original submission raised a number of concerns

regarding provisions within the PDP that relate specifically to vehicle

generation thresholds, for development within the Working

Environment. I set out and describe these below, extending the

evidence I presented in relation to Chapter 11.

Wharemauku Precinct

7.54. I note that subsequent to the Environment Court hearings for PC72A,

specific provisions were agreed to between Council and Coastlands

with regard to development of the Wharemauku land, including

traffic generation thresholds, that were subsequently adopted within

the Operative Plan as follows:

24

Rule D.3.1.3 (A) (v) Discretionary Activities

The following shall be Restricted Discretionary Activities:

…Retail Activity within the Wharemauku Precinct generating over

200 vehicle movements per hour (in any hour)

When assessing applications for the above, the Council’s

discretion is limited to the following matter:

• The traffic effects of the proposal on the road network.

7.55. The Coastlands original submission raised a number of concerns that

relate specifically to the Wharemauku Precinct, and associated

restrictions on development with regard to traffic generation.

7.56. Specifically, Coastlands initial submission opposed Rule 6A1.7, where

it differs from the Consent Memorandum for Plan Change 72A

(“PC72A”) - now the Operative Plan - in placing constraints on

vehicle movements for Permitted Activities to (and from) Precinct A2,

of less than 100 vehicles per hour (“vph”), until such time as key

elements of the Structure Plan in Appendix 6.7 are in place.

7.57. The Coastlands submission on the PDP sought relief to revert to the

agreed vehicle generation rates as set out in the Consent

Memorandum for PC72A, and to remove the reference to a

requirement for the key elements of the Structure Plan to be in place

in advance of development of higher traffic generating

developments.

Reason for the 200vph threshold in PC72A

7.58. The 200vph threshold in the Wharemauku Precinct came about as a

result of relief agreed with Council to settle Coastlands appeal of

PC72A. Coastlands notice of appeal sought that the traffic trigger

be amended to provide a different mechanism, because the initial

rule restricted development until such time as the Western Link Road

was constructed (the construction and operation of the Western Link

25

Road was the only trigger in the rule). Due to the delay between the

Commissioners decision (2007) and Council adopting the Decision

(2012) - at the time that Coastlands appealed the decision - the

plans for the Western Link Road had been scrapped and there was

no obvious replacement (the Expressway route had not yet been

proposed or confirmed). Coastlands appeal at that time essentially

sought removal of reference to a trigger that no longer existed and

prevented any serious development of the Wharemauku Precinct

land.

7.59. As settlement to its appeal, Coastlands accepted as a compromise

position the 200vph trigger on A2 as an interim position to enable it to

develop some of the site, while the Expressway and Town Centre

issues were worked through, with the expectation that these wider

network issues would be resolved. It did not envisage this to be a

permanent threshold (i.e. to apply in the next generation District Plan

or for that matter that the PDP would adopt this threshold and seek

to also make it applicable to Precinct A1 (which currently has no

traffic threshold in the Operative Plan). The comments of Council’s

traffic experts, that Coastlands has “agreed to this threshold” are

misleading. Just because Coastlands accepted a 200vph trigger on

A2 (under PC72A) - in order to enable some development while the

traffic network issues were resolved, it did not “accept” or “support”

the same trigger applying to its existing operations at A1.

7.60. By way of providing some background, the traffic threshold of

200vph was developed site specifically for A2 with the Greenfield LFR

type development that was anticipated to occur within PC72A, on

the basis of being more enabling for lower traffic generating

activities.

7.61. In this manner, this threshold would give Council more control over

the higher traffic generating activities, whilst providing some certainty

for developers as to what activities would trigger the restricted

discretionary activity status, as an interim solution to otherwise stalling

26

development due to reference to the Western Link Road, which by

that time was never going to be built.

7.62. Paragraphs 1127-28 of the s.42A Report respond to Coastlands

concerns with regard to these traffic thresholds, noting that the

Officer does not consider there has been any significant changes in

desired outcomes since PC72A was adopted, that would warrant a

more stringent control on the vehicle thresholds. With respect, this

fails to appreciate the circumstances in which that threshold was

proposed. At Paragraph 1132 the Reporting Officer’s assessment

goes on to state that:

“…during the PC72A appeal proceedings… A traffic generation

threshold for new development in the Wharemauku Precinct area

was therefore agreed, with restricted discretionary status applying

to substantive developments (i.e. those above the 200 vehicles in

any hour generation threshold). This approach was supported by

Council’s transport advisor for the appeal hearing, Mr Don

Wignall, who considered it to be adequate safeguard to ensure

adverse effects on the transport network from development could

easily be avoided, remedied, or mitigated.”

7.63. In taking the advice of the Council’s Traffic expert, the Reporting

Officer recommends re-instating the 200vph threshold adopted as

part of the PC72A for Precinct A2, within the PDP as follows:

(S.42A Report) Rule 6A.1.7 (Retail, commercial and residential

activities in Precinct A1 & A2)

7. Retail,

commercial and

residential

activities in

Precincts A1 and

A2.

1. Any Retail activities

within Precinct A2, that

adjoins Rimu Road and/or

is opposite or adjacent to

the Wharemauku Stream

reserve, shall have a

maximum ground level

27

retail floor space of 500m²

1A. Any retail, commercial

or residential activity in

Precinct A2 shall be limited

to the generation of less

than 200 vehicle

movements in any hour

until the proposed link

road from Kapiti Rd to

Ihakara St is operational,

and a desired road

connector (as identified in

the Structure Plan in

Appendix 6.7) connects

into Precinct A2.

7.64. I confirm that the recommendation addresses Coastlands concerns

in part in respect that the traffic thresholds in Precinct A2 (only)

should in the very least reflect those agreed in PC72A - being 200vph,

and I am pleased to see that the Officer has now recommended this.

However from a traffic perspective, I hold my original view expressed

in Chapter 11 that these thresholds are still low and restrictive for town

centre activities, particularly in A1. Ideally, network needs and issues

should be resolved to enable a less restrictive threshold.

7.65. Coastlands still has major concerns and is strongly opposed to the

remaining parts of this Rule. It is strongly opposed to restricting traffic

to 200vph until such time as the desired connector roads are

constructed and link from Ihakara Street to Kapiti Road is operational.

There does not appear to be a strong link between the ‘desired road

connections’ and mitigating traffic effects from A2, and I have

already expressed my concerns regarding the Relief Road and the

Rimu Road main street (the timing, location and funding of which

28

Coastlands has no control over). The proposed wording in Rule

6A.1.7, to require specific town centre roading infrastructure to be

provided before higher traffic generating activities (of over 200vph)

can be established in Precinct A2, is essentially writing another trigger

back into the Plan, which is similar to the reference to the Western

Link Road that the Coastlands PC72A appeal only removed in 2015.

7.66. Paragraphs 1132-33 of the s.42A Report provides an assessment of

Coastlands opposition to this part of Rule 6A.1.7, and describes that

as the Officer understands it, Rule 6A.1.7 goes a step further by

signalling that once the key transport infrastructure is in place, the

effects of new development on the transport network will be

adequately accommodated. In providing the recommended

wording amendments included in the table above, the Officer

concludes by stating:

“These amendments provide part relief for submission concerns,

and also help increase its clarity and certainty.”

7.67. In my opinion this does not provide clarity, but rather leaves a

significant degree of uncertainty with regard to the likes of the

proposed development of Coastlands Square Stage 2 (in Precinct

A2), which could under these provisions be reliant on Council

constructing the Relief Road prior to approving the Stage 2 consent.

This represents serious doubt for the developers.

7.68. Whilst the Structure Plan has been described as providing the

required ‘road map’ for achieving further concentration of

development within the District Centre, the lack of any confirmed

timeframes for delivering key roading infrastructure makes provisions

in the PDP such as Rule 6A.1.7 onerously inhibitive, rather than

enabling, as sought by the Chapter 6 Centres Hierarchy Policies.

7.69. In my opinion, the traffic threshold trigger for Restricted Discretionary

activities of 200vph on its own can, in the interim, be viewed as an

appropriate mechanism for assessing the impacts of development

29

within A2, and determining appropriate mitigation. This would

enable consideration of effects, under the Outline Development

Plan, until such time as a Structure Plan is advanced (as discussed by

Mr Lunday).

Traffic Thresholds Elsewhere in the Working Environment – Precinct A1

and District Wide

7.70. Coastlands submission 218.42, under the general matters of Chapter

6, opposed the application of the major traffic activity threshold to

Precinct A1, on the grounds that the 200vpd traffic threshold

definition would effectively require every development activity within

A1 and the Paraparaumu Town Centre to undergo a detailed

transport assessment, in the manner I referred to in my evidence for

Chapter 11. That is, Coastlands sought relief to re-instate in the very

least the PC72A provisions (i.e. 200vph) over areas A1 and A2 (I again

note that for A1 this is incredibly restrictive).

7.71. At present (in the Operative Plan) Precinct A1 is zoned

Commercial/Retail. In such zones, the major traffic activities trigger

only applies where development accesses directly onto either a

State Highway or a Limited Access Road (“LAR”). Accordingly,

development within A1 that accesses onto Rimu Road (which is not

classified as a LAR) is not subject to the major traffic activities trigger,

meaning there are no current traffic generation thresholds for

developments within this precinct. As noted in my discussion for

Chapter 11, I believe that Council should not seek to impose a

threshold on activities in A1, rather Council should be trying to

encourage development in this area (historically development has

occurred in this area and the Council has assessed consents without

the need for such a restrictive trigger).

7.72. In the ‘Review of Transport Matters Raised in Submissions on Chapter

11’ (“RTMRS Chap-11”), Mr Wignall and Mr Trotter provide

recommendations on the traffic thresholds for ‘major traffic

activities’, that apply Plan wide, which effectively provide the

30

mechanism for determining when a detailed transportation

assessment is required. I set out these recommended definitions, as

they appear in the Chapter 11 s.42A Report, below:

(S.42A report) Major Traffic Activities means any activity which

generates or attracts more than:

• 200 vehicle movements per day in Centres, retail and work

Zones or Industrial Zone except for access onto major (strategic or

major community connector) roads, or

• more than 100 vehicle movements per day in any other zone

and for accesses onto major (strategic or major community

connector) roads.

7.73. Council’s traffic experts set out the rationale behind revising the 2012

PDP thresholds, to the recommended thresholds in the definition

above, at Section 2.6 of the RTMRS Chap-11 ‘technical memo’,

where they concede that the activity thresholds, as notified, were

“conservative”, and that there is justification for revising the rates

upwards on the grounds that there has not been universal

application, because, ‘they are so low in comparison to any

conventional definition of high traffic generation.’ I continue to hold

my view that a trigger of 200vpd is inappropriate for the Town Centre,

particularly in A1.

7.74. Section 2 of the technical memo goes on to describe the application

of the revised 200/100vpd thresholds within the working zones, stating

that ‘in practice 200vpd is very unlikely to be generated in the vast

majority of activities and circumstances.’ However, the graph

provided in that memo at Figure A.1 indicates that even very small

activities are shown to exceed the threshold. For example a CBD

shopping activity greater than 357m² GFA, would trigger the 200vpd

threshold, and therefore require a detailed transportation

assessment. This would mean that almost every consent activity in

31

this area would need to be treated as discretionary and require a

traffic impact assessment.

7.75. In my opinion there appears to be a significant discord between the

traffic thresholds that have been applied to activities across the

Working Environment; firstly with respect to adjacent Precincts A1

and A2, and secondly with respect to what has been recommended

in Mr Wignall’s advice for the Airport Zone, which I describe in more

detail later in my evidence.

Traffic Threshold Discord between Precinct A1 and A2

7.76. In looking first at the District Centre Precincts, the s.42A Report

recommends adopting the PC72A traffic generation thresholds of

200vph for activities within Precinct A2, which is supported by Mr

Wignall, who notes that such traffic threshold provisions will enable

Council to ensure development does not generate adverse effects

on the network. I would suggest this represents a significant

contradiction between the agreed rationale for activities in Precinct

A2, for which recommended traffic thresholds are given in the s.42A

Report as 200vph, whilst adjacent activities in Precinct A1 are subject

to a far more restricting 200vpd.

7.77. In my opinion, the recommended traffic thresholds provided for

Precinct A1 under the major traffic activities definition, should be

further reviewed in terms of their appropriateness to achieve the

objectives of the town centre development intensification. In the

absence of any evidential basis, there does not appear to me to be

any traffic reason for the approach being advanced by Council in

the PDP – when the Operative Plan does not control activities in this

way. In my view it is arbitrary at best.

7.78. In truth, it is difficult to suggest exactly what level of the traffic

threshold (that triggers requirement for a detailed transport

assessment) is appropriate, with the current lack of understanding as

to how the network around the District Centre is performing at

32

present, or will perform in the next 12-24 months following completion

of M2PP and the SH1 Revocation.

7.79. In this regard, I provide some commentary on the modelling that has

been undertaken to date, by way of providing some insight into

expected growth in the District Centre over the next 10 years.

Traffic Threshold Discord with Forecast Town Centre Growth Modelling

7.80. In referring to the SATURN traffic modelling that has been undertaken

in Kapiti over the last decade, for the purpose of informing various

strategic roading projects such as the Western link Road and M2PP, I

refer here to the modelling relating to the Paraparaumu Town

Centre, undertaken to inform the SEV Structure Plan.

7.81. In reviewing the information provided by Council at the end of

August 2016 relating to inputs that underpin this modelling, it is still

unclear to me as to exactly what assumptions have been made. In

assuming that the trip generation rates for the Paraparaumu Town

Centre (reported in the spreadsheet M2PP Sensitivity Testing – Trip

Generation_V1; provided by Council via email on 26 August 2016) for

each of the forecast 2016 and 2026 years represent composite

growth (i.e. allows for 50% additional traffic only), then this

information indicates significant development growth in the town

centre within this 10-year time frame.

7.82. In quantifying what this growth is, a forecast uplift in vehicle trips

to/from the town centre in the order of 3,700 (additional) trips during

the peak hours is indicated. Based on this modelling, the quantum of

peak hour trip growth can be expected to equate to some 24,000

additional vehicle movements per day, travelling either into or out of

the town centre (although I note that in reality a proportion of these

traffic movements would already be using the road network within

the town centre).

33

7.83. In my opinion, this scale of anticipated development is seriously

inconsistent with the PDP permitted activity traffic generation

thresholds of just 200vpd.

7.84. As can be appreciated, these trip generation thresholds do not

therefore align with the objectives and policies of the PDP, and in

particular the intent of the Centres Hierarchy approach, with regard

to enabling intensification of development within the District Centre.

7.85. I would suggest therefore that in order to achieve the desired

increase in town centre activity, a more enabling approach to

assessing traffic effects be applied to those areas where particular

growth is anticipated by the PDP. Again, and on the basis of these

modelling assumptions, there does not appear to me to be any

reason for diverting from the provisions of the Operative Plan.

Airport

7.86. Coastlands made a number of submissions with respect to the PDP

Objectives and Rules that relate to activity at the Airport. I discuss

development thresholds and prohibited activities here.

Development Thresholds within the Airport Zone

7.87. The Coastlands submission included support for retaining a number of

Rules relating to the Airport Zone, including Rule 6G.2 ‘Controlled

Activities’; Rule 6G.3 ‘Restricted Discretionary’; Rule 6G.4

‘Discretionary’; and Rule 6G.6 ‘Prohibited Activities’, in that these are

consistent with the intent of the Proposed Plan to limit retail activities

outside of the existing centres.

7.88. By way of providing some background to these activity status Rules, I

note that as part of the original Airport Masterplan work undertaken in

2006/07, a number of development thresholds were established for

the purposes of informing PC73 based on traffic modelling

assessments. As a result of these investigations, a series of

development thresholds were identified at 43,050m² and 62,500m²,

34

that required transport infrastructure to be in place, whilst a further

development threshold of 102,900m² would trigger the need for a

comprehensive transport assessment to be completed, prior to any

further activity being established.

7.89. I note that these thresholds were considered an essential safeguard to

maintaining network performance (at an acceptable level of

service), in the vicinity of the Airport. These thresholds were based on

the limited type of retail activities that PC73 allowed to be developed

at the Airport. These excluded supermarkets and department stores

(typically very high traffic generating activities). At the very least,

these thresholds would need to be reconsidered if these restrictions

were removed as the relationship between the activity and the

threshold would alter significantly.

7.90. KCAHL has made a submission on the PDP to largely remove these

development thresholds (relating to Rule 6G.2, 3, 4, 6), and to relax

restrictions on the type of activities that can be established within

these thresholds (i.e. enabling higher traffic generating activities to be

developed). Coastlands further submission on the PDP opposed these

changes, for the same reasons that its original submission supported

retaining the current Rule provision, as described above.

7.91. The s.42A Report addresses the KCAHL submission at Paragraph 1752,

noting that the submitter has not included any traffic assessment

material to support the request. The Officer has then drawn on the

advice of Council’s expert transport advisors in evaluating the

submission - I provide a summary of their assessment as follows.

7.92. In the absence of substantiating traffic assessment evidence to

support the Airport’s submission, I am aware that Council has recently

undertaken its own additional modelling using SATURN and SIDRA (in

July 2016), to assess the effects of enabling higher traffic generating

activities within the Airport Mixed Use Precinct, and to assess the

applicability of the development thresholds that have been carried

over from the Operative Plan, into the PDP.

35

7.93. Disappointingly, in my view, this modelling has focussed on

development at the Airport, and not holistically on development

within the town centres (as a key part of the related network), as

sought by the PDP outcomes.

7.94. Notwithstanding what appears to be a counter-intuitive approach to

the traffic analysis that informs the PDP, I can make reference to the

Memo ‘Chapter 6 (Working Environment) Traffic and Transport Issues’

(“Traffic Memo Chap-6), dated 10 August 2016. It sets out the

modelling analysis and conclusions. Within this report, Mr Wignall

advises that the development thresholds identified during PC73 are

still appropriate, and should remain in the PDP to enable assessment

of effects on the traffic network arising from the incremental

development at the airport.

7.95. I note that Mr Wignall’s assessment has included a review of the need

(or not) to retain development thresholds that require specific physical

infrastructure to be in place, before development of the next phase

within the Mixed Use Precinct can occur.

7.96. This review concludes by recommending that in light of the change in

the transport environment that has occurred since PC72A was

granted, in respect of the Western Link Road being replaced with the

M2PP expressway, the “thresholds should be retained for transport

assessment purposes only – rather than being tied to specific physical

infrastructure”.

7.97. Mr Wignall goes on to state that “it has not proved possible to define

the timing and nature of infrastructure required in the time and

resources available”. To me, this presents significant doubt as to the

basis and rationale for these conclusions.

7.98. Even then, by way of comparison, the traffic generation assumptions

in the SATURN modelling referred to previously identified peak hour

trips to / from the Airport of 2,750 at 2026; being of a similar quantum

to the number of forecast trips to / from the town centre in the same

36

assessment year. Drawing from these comparisons, I find it difficult to

understand how Council arrives at a very different traffic outcome for

the Airport compared with the town centre environment.

7.99. In advocating the approach to be adopted within the PDP for

development at the Airport, wherein traffic assessments are required

at the identified PC73 thresholds (i.e. 43,050m²; 62,500m²; and

102,900m²), at Section 2.8-2.9 of the Memo Chap-6, Mr Wignall states

that:

“the alternative would appear to be every resource consent will

potentially require an in depth transport assessment, which

admittedly is an alternative but an extremely wasteful and costly

one, in terms of developer costs and Council resources. It is also

potentially very unfair on an individual developer who happens to

trigger the need for a major investment”.

7.100. As I have outlined in my previous Chapter 11 evidence, this is exactly

the situation that emerges elsewhere in the Paraparaumu Town

Centre in response to the 200vpd threshold requirement. I do not see

why such restrictions can be regarded as valid in the Town Centre,

where development is to be encouraged, but not at the Airport

(particularly given that many of the same network difficulties emerge).

If the effects of development at the Airport are such that Council’s

advisers are concerned about the effects arising from the Airport’s

current thresholds, (i.e the traffic environment can no longer

accommodate these) then that in my mind is sufficient reason for a

more restrictive assessment threshold to be imposed in the Plan. There

is no presumption that the position in the Operative Plan should

continue, particularly if it places pressure on the local traffic network

which is unsustainable and results in the imposition of incredibly

restrictive 200vpd thresholds within the Paraparaumu Town Centre (in

an effort to manage that).

7.101. That said, the Council Reporting Officer has since confirmed that the

200vpd major traffic activity threshold would take priority over the

37

higher level Airport development thresholds, triggering the need for a

Transport Assessment if the proposed activity generates more than

200vpd. To me, that aligns logically with the PDP’s centres direction.

7.102. I support the belts and braces approach in terms of the 200vpd Major

Traffic Activity and Airport thresholds, both applying and believe this is

justified given the vunerability of the network and the sorts of capacity

issues being experienced. I also suggest that if the thresholds are

retained that these should refer to the need to provide infrastructure

being considered as part of an ITA when development reaches those

levels as it enables a check on the cumulative strain type effects of

smaller applications on the traffic network including congestion,

safety, eroding capacity and degradation of performance.

Airport Zone Prohibited Activities

7.103. From a traffic perspective the way in which activities are defined in a

District Plan are very important. Activities such as LFR, Department

Stores and Supermarkets (including metros) are generally very car

reliant and generate high levels of traffic. The change in location (or

new offer) of these activities in the district can almost overnight

significantly change the way in which people move about the local

traffic network and the routes they choose to use. A new

Supermarket, LFR or Department Store (or a combination of all three)

will significantly influence local traffic patterns as motorists change

their previous shopping habits and routes in order to travel to and

from new shopping destinations.

7.104. In terms of the submission to remove the 1,500 m2 cap at the Airport,

the cap is necessary because it is one of a combination of measures

that the Plan uses to prevent full size Supermarkets from becoming

established at the Airport. In my view, a key reason relates to the

traffic and network effects that locating a high generating traffic

activity would have within the existing network.

38

7.105. It is this combination of reasons, that led Council’s traffic advisors to

recommend that Supermarkets and Department Stores remain

prohibited activities, as described in detail in the Memo Chap-6

(Annex 2), which has tested the impact of higher traffic generating

activities on the adjacent network using the KTM model (July 2016).

However this advice has been ignored by the Officer.

7.106. In his assessment, Mr Wignall concludes (pg. 21) that the effect of

enabling higher traffic generating activities to be established within

the Airport Mixed Use Precinct would result in “reducing the

operational levels of service substantially”. This would result in an

earlier erosion of network capacity (in an already vulnerable network)

than has to date not been anticipated, particularly with regard to the

M2PP Expressway, triggering the need for major additional traffic

infrastructure ahead of the previously identified development

thresholds (i.e. at 43,050m²) and causing significant effects on the

wider network, including the Paraparaumu Town Centre.

7.107. I note that on this basis, it is therefore unclear why the Reporting

Officer has then gone on to recommend an amendment to Rule

6G.4.2 and Rule 6G.6.2, which proposes allowing Department Stores

as a non-complying activity at the Airport, and Supermarket as a

Discretionary activity, against the advice of Council’s traffic experts.

7.108. In my opinion, Mr Wignall has highlighted exactly what would happen

if higher traffic generating activities were to take hold in the Airport

Zone Mixed Use Precinct, which not only would erode capacity on the

adjacent network sooner, but also render the agreed development

thresholds as redundant, as these were based on the lower trip

generation rates of activities that were provided for under PC73,

which specifically did not anticipate Supermarkets and Department

Stores.

7.109. In my view, and in support of the Council’s traffic experts, I strongly

recommend retaining the prohibited activity status for the Airport

Mixed Use precinct for two reasons; firstly, to protect the traffic

39

network around the M2PP and Kapiti Road from a loss of capacity

that would be brought about by the higher traffic generating

activities, that would be enabled at the Airport if the prohibited

activity status is removed; and secondly with regard the wider traffic

implications that will arise if the Mixed Use Precinct is developed into a

centre in its own right, and the consequential effects on traffic re-

distributions through the District that have not been anticipated or

planned for.

40

8. CONCLUSION

8.1. Advancing the traffic evidence that I have already presented in

relation to Chapters 2 and 11, I focus in this Chapter 6 evidence on

the following matters:

(a) Structure Plan;

(b) District Centre outcomes;

(c) traffic thresholds; and

(d) Airport provisions.

8.2. As an overall summary of the evidence presented, I find that, as

currently proposed, the provisions of the PDP have traffic

shortcomings in the sense that there is significant mis-alignment

between the high-level outcomes sought in terms of District Centre

development and the related traffic rules and standards.

8.3. Specifically, it is in my view that:

(a) there cannot be any certainty regarding the need for and

appropriateness of the roads defined by the 2016 Structure

Plan;

(b) there is a mismatch in the traffic thresholds between the

District Centre, and elsewhere, and within the District Centre

itself;

(c) there is no evidence to suggest there is a need for very tight

controls on development traffic in the District Centre; and

(d) there is good transportation reasons for retaining the activity

status at the Airport, as proposed by the PDP, with traffic

assessment thresholds commensurate with other non-District

Centre zones in the district.

41

8.4. Overall, I am of the view that with the right supporting traffic analysis,

an appropriate transportation outcome can be realised both in terms

of infrastructure and land use, but at this stage am of the opinion that

the provisions of the PDP that I have described cannot be carried

forward in the manner suggested by the Reporting Officer.

Mark Grant Georgeson

5 September 2016