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JOINT TRANSPORT STATEMENT OF EVIDENCE FORMULTIPLE PARTIES
TOPICS 043/044 - TRANSPORT
16 JUNE 2015
IN THE MATTER of the Resource Management Act 1991 and the
Local Government (Auckland Transitional
Provisions) Act 2010
AND
IN THE MATTER of the Proposed Auckland Unitary Plan
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1. INTRODUCTION, QUALIFICATIONS AND EXPERIENCE
1.1 This is a joint statement prepared by the following qualified traffic
experts (in alphabetical order) on behalf of the listed submitters
(together the Key Retailers Group or "KRG"):
(a) John Burgess - The National Trading Company of New
Zealand Limited ("NTC") and The Warehouse Limited ("The
Warehouse").
(b) Brett Harries - Scentre (New Zealand) Limited ("Scentre"),
Harvey Norman Properties (NZ) Ltd and Harvey Norman
Stores (NZ) Pty Ltd ("Harvey Norman").
(c) Don McKenzie - Progressive Enterprises Limited
("Progressive").
(d) John Parlane - Kiwi Income Property Trust ("Kiwi").
1.2 A complete list of our relevant qualifications and experience is
attached as Appendix 1 to this statement.
1.3 Retail transport planning is an area in which we all have vast
knowledge and understanding. Our combined experience and
familiarity with planning for retail (in particular, supermarkets, large
format retail and shopping centres) has enabled us to help craft a
workable set of transport provisions for the Proposed Auckland
Unitary Plan ("Unitary Plan").
1.4 We consider the provisions proposed by the KRG will enable the
functional and operational viability of retail in Auckland.
Code of conduct
1.5 We confirm that we have read the Expert Witness Code of Conduct
set out in the Environment Court's Practice Note 2014. We have
complied with the Code of Conduct in preparing this evidence and
agree to comply with it while giving oral evidence before the Hearings
Panel. Except where we have stated that we are relying on the
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evidence of another person, this written evidence is within our area of
expertise. We have not omitted to consider material facts known to us
that might alter or detract from the opinions expressed in this
evidence.
Scope of Evidence
1.6 This statement addresses Chapters C1.2 and H1.2 of the Unitary
Plan.
Joint approach
1.7 Prior to the mediation sessions on C1.2 and H1.2, the KRG met
several times to agree a consolidated version of their proposed
changes to the transport provisions. Additional meetings were held
with Auckland Council ("Council") to endeavor to further narrow the
differences between the two groups. This included both formal and
informal expert conferencing between the traffic experts.
1.8 The KRG's consolidated relief was provided without prejudice to the
Council on 23 February 2015. Council provided its proposed trackchanges to C1.2 and H1.2 on 15 April 2015. Some areas of
disagreement were resolved through this process.
1.9 At the mediation sessions held on 23 - 24 April and 6, 14 - 15, 20 - 22
May 2015, the parties resolved further issues. However, throughout
the informal and formal mediation sessions, there remained a
fundamental disagreement between the KRG and the Council as to
the approach that should be taken to parking in the Unitary Plan;
specifically, whether the Unitary Plan should only specify maximum
parking rates, or whether it should also include minimum rates for
certain activities.
1.10 The Council's track changes, attached to the evidence of Mr Kevin
Wong-Toi are an improvement on the notified version, however, the
KRG still has a number of serious concerns, which are addressed in
this Joint Traffic Statement and in other evidence to be lodged on
behalf of the KRG. Consolidated relief sought by the KRG is set out in
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Appendix 2 to the Joint Planning Statement, which has been
prepared by the planners acting for various members of the KRG.
Additionally, the KRG members have provided individual corporate
evidence briefs. These statements should be read and considered
collectively.
2. EXECUTIVE SUMMARY
2.1 In our opinion, and for the reasons set out in this statement, the
Hearings Panel should accept the relief sought by the KRG, as set out
at Appendix 2 to the Joint Planning Statement.
2.2 The KRG's relief can be summarised as follows:
(a) We consider that 60 trips per hour is too low a trip generation
threshold for activities to become restricted discretionary and
this would lead to too many developments requiring
assessment reports from traffic engineers. We consider the
trip generation thresholds should be increased from 60 trips
per hour to 100 trips per hour.
(b) We oppose the Council's approach to imposing no car
parking minima in centres. This will lead to businesses being
developed with insufficient parking to cater for their own
needs, leading to excess demand on adjacent sites because
customers will simply choose to park at the closest available
carpark.
(c) The KRG is proposing a more balanced approach of keeping
minimum parking rates in centres while providing maximum
rates for some activities.
(d) In our opinion, the KRG relief should be accepted because it
reflects the reality of parking generated by retail activities in
centres. The use of minimum rates in centres would ensure
that the effects of each development are mitigated and avoid
the potential for cars generated by development to spill-over
into neighbouring properties and streets.
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(e) The KRG proposed amendments will allow for maximum
parking rates to be used where they could be effective in
reducing peak hour traffic flows.
(f) If a maximum rate is to be imposed, we suggest that this
should be at a maximum rate of 1/17m2 for supermarkets,
given the requirements of supermarkets for car parking.
(g) We consider that the proposed cycle parking rules should
reflect commercial realities and set realistically attainable
targets in order to ensure that achievement of the desired
goals is positively supported and affordable. The KRG isproposing somewhat reduced requirements for cycle parking
and end-of-trip facilities that still go well beyond what is
currently experienced, but remain realistic and affordable to
developers.
(h) We support the addition of flexibility to the Vehicle Access
restriction requirements to properly recognise existing access to
existing developments, and to enable future developability of the
sites served by those accesses. We therefore endorse the
Council track-change version of the proposed amendments and
additions to Rule 3.4.1 regarding vehicle access.
(i) We generally support the proposed rules regarding the number
of vehicle crossings, subject to a minor modification to the
wording of the provision for crossings to ‘all other sites’, and we
support the proposed deletion of Rule 3.4.2.3 which would
remove the requirement for access to be taken off local roads in
favour of arterial roads. However, we consider that greater
flexibility needs to be applied to the permitted maximum width of
vehicle crossings to better recognise the crossing capacity
demands of high traffic generators, and the swept path
requirements of various truck sizes.
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3. TRIP GENERATION / INTEGRATED TRANSPORT ASSESSMENTS
Trip Generation Table
3.1 The Unitary Plan has two separate but related rules requiring traffic
assessments and Integrated Transportation Assessments. In H1.2
Transport section 3.1 Table 1 sets out thresholds above which
activities located outside of centres would become restricted
discretionary and require a transport assessment. By contrast any of
these activities located within centres would not specifically require an
assessment in terms of traffic.
3.2 The Council's position is that these thresholds are based on the scale
of land use that would generate more than around 60 trips per hour.
There are some exceptions to this noted below.
3.3 We support the intention of the rule, ie setting a scale of development
below which no traffic assessment is specifically required by a rule in
the Unitary Plan. Small scale developments generate few trips and
there is often little scope to do anything meaningful other than
estimate traffic flows and recommend consent.
3.4 Where we differ from the Council is in how the thresholds have been
set. Specifically we consider that 60 trips per hour is too low a
threshold for activities to become restricted discretionary and in our
opinion this will lead to too many developments requiring assessment
reports from traffic engineers. We also do not support the thresholds
proposed by the Council that deviate from a direct calculation of trip
generation. We understand that the Council's position is that some of
the assessment criteria relate to other issues such as connectivity for
pedestrians and are not strictly related to trip rates. Our opinion is that
urban design issues such as connectivity should be addressed in the
appropriate section of the Unitary Plan and that this table should focus
specifically on the scale and intensity of development as it relates to
trip generation.
3.5 The KRG proposed approach is to increase the thresholds in each ofthe categories to reflect a development of 100 vehicles per hour. In
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our opinion that is a more appropriate intensity of traffic effects to
require a specific assessment of traffic capacity and safety.
Development below that scale could be expected to create less than
minor effects.
3.6 We have reached that view because these assessments would all be
carried out for development located outside of centres where usually
there is reasonable traffic capacity. In our opinion setting these
thresholds too low would lead to the situation where we are preparing
traffic assessments for very small developments outside of centres
where there is little congestion and not being required to assess large
developments within centres in the same manner, despite the
likelihood of significant congestion.
3.7 For that reason the KRG approach, as set out below in strikethrough
and underline, is preferred:
3.1 Trip Generation
1. In all zones, other than those listed in clause (iii) below,resource consent as a restricted discretionary activity is
required where:
...
(iA)
activities not identified in Table 1 requiring a controlled orrestricted discretionary land use activity consent in theapplicable zone and generating more than 60v/hr 100v/hr (anyhour) where there are no requirements for an assessment oftransport or trip generation effects in the applicable zone.
Table 1
Activity Council
Positon
KRG
Position
Reason
Residential Dwellings 60 100 units 1 veh/unit
Retirement 100 500 units 0.2 veh/unit
Visitor
Accommodation
60 100 units 1 veh/unit
Education Primary 100 167 students 0.6 veh/pupil
Secondary 200 333 students 0.3 veh/pupil
Tertiary 300 500 students 0.2 veh/pupil
Office Office 3000 5000 sqm 2 veh/100sqm
Retail Retail 1000 1667 sqm 6 veh/100sqm
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Drive through 200 333 sqm 30 veh/100sqm
Industrial Warehouse &
Storage
12000 20000 sqm 0.5 veh/100sqm
Other Industrial 6000 10000 sqm 1 veh/100sqm
3.8 The KRG position would in our opinion reflect the scale of out of zone
development that should be assessed and focus the rule on expected
traffic generation rather than the arbitrary limits contained in the
Council's current version.
Integrated Transport Assessments
3.9 Integrated Transport Assessments are required by Rule G1.4B of the
Unitary Plan. These assessments require a considerable amount of
additional material than the regular traffic assessments typically
carried out for developments. We agree with the position now
proposed by Council where these ITAs would only be required once
for a development, usually at a plan change stage.
4. CAR PARKING MAXIMUMS AND MINIMUMS
4.1 The Council's approach to carparking as set out in its evidence is to
limit carparking within the CBD, the CBD fringe and in Metropolitan
areas and Town Centres. This is a significant departure from the
previous District Plans in Auckland where parking was limited only
within the CBD but required within all other areas.
4.2 The Council seeks to limit parking through a series of maximum
parking rates set out in Tables 1, 2 and 3 of the Unitary Plan that
provide maxima based on activity types. A key point of the Council's
approach is the removal of minimum parking rates in these areas.
4.3 Outside of the CBD, the CBD Fringe, Metropolitan Centres and Town
Centres parking would still be required with minimum rates set out in
Table 4.
4.4 Within the Council's approach there are two distinct elements: firstly
the removal of minimum parking rates or the removal of therequirement to provide any parking at all; secondly the introduction of
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maximum parking rates in areas where maximum rates have never
been imposed in the past. We address these in turn below.
Removal of Minimum Rates in Centres
4.5 The removal of minimum rates means there would be no requirement
to provide parking on each site to cater for its expected parking
demand. In fact there would be no requirement for parking
whatsoever and so a development could be built without any parking
even if that development resulted in a significant or even severe
impact on parking on neighbouring sites or on adjacent streets. We
do not support this approach as in our opinion it is likely to result inadverse effects of development that will not be mitigated.
4.6 The most likely outcome of not requiring parking at all is that some
sites will be developed with insufficient parking to cater for their own
needs leading to excess demand on adjacent sites as users will
simply choose to park in the closest available carpark, often on a
neighbouring site. In effect the owners of the site with insufficient
parking will be able to "free ride" by externalising their effects at the
cost of their neighbours who have already paid for a parking area in
order to mitigate their own effects and support their own businesses in
accordance with the previous planning regimes. A similar parallel
situation is likely to occur where neighbouring streets will be used as
free parking for adjoining commercial activities. That in itself might not
be a problem but if the parking on that street is already used to
support existing activities then significant adverse effects could occur.
4.7 The Council appears to be taking a view that any adverse effects can
be managed through people installing barriers to their own carparks
and through Auckland Transport managing parking in neighbouring
streets through restrictions such as time limits, residents' schemes or
pricing. Our view is that this approach is naïve as it does not account
for the significant externalities, both positive and negative, that parking
can create.
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4.8 Parking represents a significant cost to a developer, both in terms of
the use of land and the cost of building the parking space. We know
that parking in town centres has a significant flow-on impact on
business, because good parking areas that provide adequate spaces
and are easy to use function as an anchor drawing people into a
centre. Parking enables high value activities such as specialty retail
and supermarkets to establish and remain viable. These activities in
turn allow for centres to develop and cater for multiple purposes.
Ironically it is the presence of parking that allows people to get out of
their car and walk around and remain in a centre for longer.
4.9 This anchoring effect is well understood by major retailers and our
involvement with these retailers has always focussed on providing the
correct number of parking spaces to serve a development as well as
designing a high quality layout that links easily to their shops. Over-
provision of parking has seldom been a problem as Auckland District
Plans have all included dispensation mechanisms to allow a
development to reduce the parking rate below the default rules where
the higher level of parking is not required. Our opinion is that these
dispensation assessment criteria in principle have allowed most
development to occur with the correct number of parking spaces
(although various refinements to the criteria themselves could usefully
be made).
4.10 We can quantify the benefits of parking by considering the simple fact
that most customers travelling to retail activities in centres use private
cars to access the site. Work carried out for Scentre at St Lukes
shows the following breakdown of transport mode share1:
1 Reported by Booz and Company, Public Transport: Westfield St Lukes Plan Change,
November 2008
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4.11 The important point to note here is that 82% of week day customers
arrived at St Lukes in private cars and 86% of weekend customers
arrived in private cars. In this example, even if bus usage doubled,
then 77% of people on weekdays, and 82% of people at weekends,
would still be reliant on cars to visit the shopping centre.
4.12 In contrast to the positive externalities of providing parking to support
activities and mitigate effects, inadequate parking can result in
significant negative externalities. For example an owner may have
invested a significant sum to build a carpark to accommodate their
own parking needs, and then be faced with neighbouring development
that occurs without adequate parking. In that situation, shoppers will
simply choose to park next door. When one development's parking
shortage results in parking problems for neighbouring sites that is anadverse effect. In effect the shortage of parking is transferred to
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others. If the Council's position is accepted then these parking
problems in centres are a potential effect of high probability.
4.13 One of the reasons advanced by the Council for removing parking
minima is that the land could better be used for other activities. Rules
requiring parking mean that the land owner is not able to maximise the
use of their land. We disagree with that position as, in our experience,
developers have few problems obtaining a dispensation for parking
when parking is not required or where fewer spaces are needed. In
the past we have all encountered Council officers who have insisted
on high parking rates where that level of provision is not warranted.
However in recent years we have noted that it is much easier to obtain
realistic dispensations. This process could be improved through
clearer assessment criteria and better training of Council staff to
ensure they understand that the parking minima are only a starting
point for an assessment. We do not support the removal of parking
rules to address what we consider to be a non-existent concern
regarding over-supply of parking.
4.14 Part of the argument advanced by the Council appears to be that even
if a significant demand for parking is likely to be created by a
development then it should be the developers' choice whether they
mitigate their effects by providing for that demand, or choose not to
provide parking. We strongly disagree with that position. We
acknowledge that providing parking comes at a cost to developers.
So does every other mitigation measure required under the RMA and
the Unitary Plan. Our advice is that the efficiency arguments
advanced against parking minima are no different to what could be
mounted against rules requiring storm water mitigation, daylight rules
or protection of view shafts. The important point is that parking, in
areas where car access is paramount, is a resource that needs to be
sustainably managed. Requiring parking to be provided is the best
way to ensure a major parking shortage does not occur, a shortage
that would have serious adverse effects on a wide area.
4.15 The Council has promoted the removal of minima and the use ofmaxima in centres in part to try and reduce car use. We support that
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general approach in the CBD where public transport use is high and
where significant future investment in public transport is already
scheduled. We do not consider that approach is appropriate in
metropolitan centres and town centres as these areas are highly
reliant on private cars. Indeed one of the well documented effects of a
parking shortage is that it can lead to much longer trips and an
increase in traffic congestion.
4.16 If shoppers find they can no longer drive to their most convenient town
centre as there is no longer parking provided then a few might choose
to change mode but many more will simply drive to a more distant,
less convenient centre to do their shopping (as long as it provides
parking). That situation in Auckland would not only result in longer
trips but because of our congested network those drivers are likely to
pass through more congested intersections resulting in higher delays
to other drivers than would be necessary had they been able to find a
convenient carpark at their preferred location.
4.17 Similarly if drivers choose to try and park in local streets where
parking is in short supply or on neighbouring sites where the parking is
now overloaded, then the result will be an increase in local traffic
congestion. Evidence of this effect has been widely documented in
the USA where it has been estimated from sixteen studies that as
many as 30% of all congested downtown trips are due to people
looking for parking.2 Surveys establishing this include one in
Manhattan3 where 28% of drivers were cruising for parking and
another survey in Brooklyn4 showing 45% of traffic on one street was
there specifically looking for a parking space to become free.
4.18 In our view removing minimum parking rates in centres, particularly for
retail activities, is unlikely to result in a reduction in traffic. On the
contrary it is more likely to result in local traffic congestion,
2 D Shoup, Free parking or free markets, Retrieved from
http://www.accessmagazine.org/articles/spring-2011/free-parking-free-markets/3 Schaller Consulting, Curbing Cars: Shopping, Parking and Pedestrian Space in SoHo,
December 2016 retrieved fromhttp://www.transalt.org/sites/default/files/news/reports/soho_curbing_cars.pdf
4 Transport Alternatives, No Vacancy- Park Slope's Parking Problem And How to Fix It,February 2007, retrieved fromhttp://www.transalt.org/sites/default/files/news/reports/novacancy.pdf
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overloading of adjacent streets and parking areas, and longer
distance trips. All of these impacts are adverse transportation effects
that are likely to be significant.
Impact on intensification
4.19 If parking is no longer easily available at some metropolitan and town
centres, despite the fact that the vast majority of Aucklanders use
private cars when they go shopping, then those centres that have
parking will become increasingly more successful than those centres
that do not. That has implications for the intensification goal of the
Unitary Plan. As transport professionals we are unanimous in oursupport for public transport and for cycling and walking, but we know
from our experience that these are all minor modes when it comes to
shopping trips. Our advice is that the very goal of intensification of
centres could be at risk if adequate provision is not made for what is
currently and likely to remain the major transport mode.
4.20 If parking is fully catered for outside of centres, but problematic within
centres, then we consider that developers will choose to make a non-
complying application to locate outside of centres.
Management of Parking
4.21 Throughout our discussion with Council experts they have put forward
the claim that any potential adverse effect on neighbouring sites can
be mitigated by the neighbours themselves controlling access to their
own parking area. The Council position appears to be that if retailers
with parking do not want cars associated with adjacent activities
coming into their site then it is simply a matter of installing barrier arms
or warning signs to keep them out.
4.22 That approach can work for offices and premises that do not have a
significant level of public activity. But at retail centres and large format
stores with carparks it is impossible to tell when a car enters whether
the driver and passengers are customers at your shops or your
neighbours' development. For example we know that WestfieldHenderson already has people using their carpark who are visiting the
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nearby offices of Auckland Transport (premises that were built
specifically by Waitakere City Council with a limited number of parking
spaces).
4.23 Warning signs only work if they are enforced and if the parking owner
is actually prepared to have cars towed away. The Countdown
Supermarket on the corner of Quay Street and Tangihua Street near
Britomart is a good example of a carpark that is commonly used by
visitors to other activities. But because it is so difficult to identify
errant parkers and because towing away one of your own customers
is a potential public relations disaster, it is seldom that the operator
can actually effectively keep non-customers out.
4.24 Barrier arms and ticket systems can be installed and this is done
where parking costs are higher such as at Two Double Seven in
Newmarket. However this means you then have to charge your own
customers for parking which is a disincentive for them to visit your
shops. Discounts for people who hold receipts from your shops are
also problematic as many shoppers do not know in advance if they will
actually find something to buy. But they do know in advance that you
will charge them for parking. The other problem we have encountered
with this type of customer discount is that people might use your
parking to visit neighbouring activities, then simply buy a low cost item
such as a sandwich on their way out. Kiwi have encountered this very
issue at the Hamilton City carparking building adjacent to Centre
Place.
4.25 In some cases it will not only be the owners of neighbouringcommercial development that will be adversely affected by the
removal of parking minimums. Many residential streets located near
to centres already experience heavy on-street parking on business
days. That might not be a problem where houses have been built with
adequate off street parking for residents and visitors. However in
many older areas and areas where more recently town houses have
been built, on-street parking is used to meet some of the existing
residential parking needs. Even in newer areas, where houses havebeen built, with two parking spaces each, subdivision rules have
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required on-street parking specifically to cater for visitors. If these
spaces then get filled due to neighbouring commercial development
that has been allowed to occur without mitigating its effects then there
will be an effect on residential amenity.
4.26 In some older areas houses were built prior to the widespread use of
cars and there is no chance of providing off-street parking. Similarly,
as residential intensification occurs under the Unitary Plan, new
residential developments are resulting in fewer carparks. Losing on-
street parking will have a severe adverse impact on these residents.
Pricing of Parking
4.27 An implicit assumption of the Council's position appears to be that
parking in and around centres should all be priced. Certainly they
must be expecting the removal of parking minima to result in greater
pressure on on-street parking. The Auckland Transport Parking
Strategy released in April 2015 suggested that when parking in streets
regularly exceeds 85% occupancy at peak times, time limits will be
introduced and, when these fail to work, pricing will occur. We
consider that will be inevitable in many places if significant
development occurs without parking.
4.28 Pricing of parking in existing shopper centre carparks is a different
matter. Charging for parking is likely to have the same impact on
customers as charging for access to the front door would. Retail
shops work by attracting people in to look at the goods that are for
sale. We have all had extensive experience working for both major
retailers and on Main Street projects for local shopping centres. The
key issue we are often faced with is making it as easy as possible for
as many people as wish to come to the centre and browse. The
models we use in transport planning predict people's preferred
destination based on the total cost of travel. If parking is charged at
one centre and free at another that is likely to have an impact on both
traffic distribution and on the success of the centre. We know that
customers are sensitive to parking charges.
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4.29 This impact of parking costs has been demonstrated by surveys in
Sydney of transport elasticities5 and cross-elasticities as shown in the
table below. While these relate to CBD parking buildings we would
expect similar results in Metropolitan Town Centres.
4.30 The elasticities show the effect of a 1% cost in parking. In all cases
an increase in parking cost results in less people travelling to that
area. In fact more people choose not to go there than actually choose
to change to public transport, as shown in the bottom two rows of the
table.
4.31 Care needs to be exercised using cross-elasticities like these as they
relate to very specific surveys carried out in different conditions to
ours. However the general pattern that more people would avoid a
trip to that centre than would choose to use public transport is likely to
hold true. In fact given the lower level of public transport at most of
our centres outside the CBD and the fact that shoppers have a higher
choice in destination, we would expect the trend to be even more
pronounced. Based on our analyses we do not consider pricing
parking at a centre to be a realistic way of improving transport
outcomes.
4.32 Not only will pricing a shopping centre carpark result in less people
visiting that centre, the more important issue for the major retailers is
that they have no way of keeping out non-customers ie those visiting
the development that has been built next door without parking. We
believe that it is this simple fact that has been missed by the Council's
5 Demand elasticity is a measure of how much the quantity demanded will change if
another factor changes.
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advisor Mr Donovan. He has made the assumption that parking is
excludable and rivalrous and therefore a private good not subject to
the so called 'free rider' problem.6 Parking is excludable only in a very
narrow economic definition that you can exclude people who do not
pay to be there (see the table below). But our clients are not carpark
operators seeking to maximise the revenue of their parking. They are
shopping centre owners and retailers who use the parking only as a
means of attracting customers to their stores. Assuming that the
parking in these shopping areas is an excludable good treats these
parking spaces as if they are owned by a parking business whom is
indifferent to who actually uses the spaces.
4.33 A barrier arm can exclude people who have not paid but there is no
practical way to exclude only those people who are not going to visit
the shops that the carpark was built to serve. In that sense the
commercial parking may be a private good but shopping centre
parking operates more like a common good. The important point
here is that the parking exists to serve a specific store or integrated
shopping centre, it is neither private parking nor is it public parking
available for anyone to use.
4.34 The Council's position has assumed that large format retailers and
shopping centre owners are operators of commercial parking buildings
rather than integrated businesses who focus on attracting customers
for their own retailers.
6 Evidence of Stuart Donovan, on behalf of Auckland Council, at paragraph 7.4.
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Public demand to build parking
4.35 Finally we would like to comment on where we believe this policy will
take us if it is approved. In our experience, people do not like parking
shortages. They do not like paying for something that was free in the
past and they particularly do not like finding that the shopping centre
or shop they are familiar with and where they fulfil their needs is no
longer accessible or convenient. In our experience both as engineers
and as advisors to local government, such an outcome would lead to
complaints. It seems to us that if these rule changes result in parking
shortages in many town centres as we expect will occur, then it is
inevitable that the Auckland Council will come under intense pressure
to start building public parking areas to alleviate the problem. That
would mean the parking demand created by private business will have
been externalised and made into a cost to the community.
4.36 We have all been involved in parking studies for local authorities and
we all consider that it will be inevitable that removing minimum parking
rates in centres outside the CBD will result in pressure to build new
parking facilities. We note that the Auckland City Council was still
building carparking structures7 in the CBD to respond to demand in
2002 some 15 years after parking limits were brought in.
Minimum rates relief
4.37 In relation to minimum parking rates in centres, the KRG seeks the
following:
For all retail, including supermarkets and food and beverage,
a minimum rate of 1/30m2.
For a new category "commercial services", a minimum rate of
1/30m2 and a maximum rate of 1/20m2.
4.38 The suggested minimum rate of 1/30m2 is considered by the KRG to
be a reasonable but fairly lenient rate when compared with the typical
minimum rates of 1/17m2 and 1/20m2 contained in the Operative
7 Notices of Requirement to add floors to both the Victoria St and Downtown carpark
were confirmed in 2002 and constructed shortly after.
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District Plans in Auckland and the minimum 1/25m2 rate now
proposed in the Unitary Plan for areas outside Centres. This rate of
1/30m2 will ensure that all retail and commercial service activities at
least go some way to providing a level of car parking to meet their
needs, and so minimise the detrimental effects on those activities
(such as supermarkets and department stores) that do provide a
reasonable level of parking even under the maximum parking rate
controls. In all other areas (Development Control 3.2, Table 4), a
minimum parking rate of 1/25m2 is applied to all general retail
activities (including food and beverage), and the KRG supports this.
The Council is now proposing that Large Format Retail (excluding
supermarkets and department stores) should be separately identified
in the Neighbourhood Centre and other zones with a minimum parking
rate of 1/45m2, and we consider this to be a more reasonable rate for
LFR. We also note that "commercial services" are identified as a
separate group with a minimum parking rate of 1/25m2, consistent with
the above proposal for Centre zones.
Maximum rates
4.39 The Council's position is that maximum rates for parking (permitted
parking) should apply to activities located in the CBD, CBD fringe,
Metropolitan Centres, Town Centres and Local Centres. Activities
other than offices would be subject to minimum parking rates (required
parking) outside of the centres. Offices would be subject to maximum
parking regardless of where they are located.
4.40 We support the concept of maximum rates for the CBD, although wedo not consider a blanket rate of 1 space per 200 m2 for all of the
CBD to be the best way of achieving that. (John Parlane will address
this matter in a separate statement.)
4.41 We also support the application of maximum parking rates for offices
regardless of where they are located, as in our opinion it is regular
commuter trips that are best able to be catered for by public transport,
and removing as many of these trips as possible from general traffic in
the peak periods is supported.
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4.42 We believe the Council is wrong in only applying maximum rates to
retail in the centres outside the CBD as private cars are currently and
likely to remain the predominant form of transport to shops in these
centres. Ms Joyce has expressed the opinion that "the proposed
rates are generous and will not significantly restrict parking supply for
land use activities."8 We disagree that the rates are generous.
4.43 Parking for retail activities cannot be set at an overall average
because shopping centres and large format retail typically generate
different levels of parking demand at different times. Even if people
wanted to use public transport to go to the shops, peak times for
shopping centres and large format retail occur at weekends and on
public holidays when public transport services are often at reduced
levels. Most shops experience their regular peak customer demand in
the early afternoon on Saturdays and Sundays with extreme peaks
occurring at times such as Boxing Day.
4.44 There is also the problem of transporting purchases home.
Supermarkets in particular tend to be located in shopping centres or
on arterial roads at sites with a generous parking area. The
overwhelming majority of customers drive to the supermarket in order
to load their car with groceries regardless of how good public transport
services in the area are.
4.45 There is little direct link between public transport services and the
success of shopping areas and for that reason we do not support the
imposition of maximum rates on retail activities outside the CBD.
4.46 One of the justifications for maximum rates advanced by the Council
advisors in our discussions is that maximum rates prevent too much
parking being provided. In our experience developers have every
reason to get the level of parking right as each additional parking
space has a significant cost. There are also times when a developer
provides sufficient parking to cater for the development and their
expected future extension as it is often cheaper to build a full structure
8 Mairi Joyce statement of evidence paragraph 36.
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at the outset rather than extend later. Maximum parking rates would
prevent that type of future proofing.
4.47 Another potential problem with maximum parking rates for retail is that
shopping centre owners and other retailers will experience higher
parking demand if their neighbours do not build sufficient spaces.
They could then be prevented from increasing the size of their own
carpark to meet overall demand as the maximum rates are based on a
calculation of their own floor area and do not take into account the
neighbouring land use activities creating the demand.
Proposed approach by KRG
4.48 Notwithstanding those concerns, the KRG is proposing a more
balanced approach of retaining minimum parking rates in centres
while providing maximum rates for some activities.
4.49 In our opinion, the KRG relief should be accepted because it reflects
the reality of parking generated by retail activities in centres. The use
of minimum rates in centres would ensure that the effects of each
development are mitigated and avoid the potential for cars generated
by development to spill over into neighbouring properties. The
Council has assumed that this can be avoided with barriers and signs.
In our view that is simply naïve.
4.50 The KRG's proposal will allow for maximum parking rates to be used
where they could actually be effective in reducing peak hour traffic
flows. Sites located in the CBD and office activities across the city
generate trips that can, and in our view should, be catered for in the
first instance by public transport. In contrast public transport is not the
predominant means of accessing retail activities outside the CBD. In
our opinion maximum rates are the wrong method of addressing the
impacts of these retail activities. Minimum rates would ensure that
adverse effects are appropriately avoided, remedied and mitigated.
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5. PARKING RATES FOR SUPERMARKETS
5.1 Within the general group of "retail" activities, supermarkets have their
own specific characteristics in terms of particularly high levels of traffic
generation and parking demand, and therefore should be specifically
acknowledged as a particular type of retail in terms of appropriate
parking rates. The KRG seeks the addition of a new separate car
parking category for "supermarkets" within the retail group of activities.
5.2 The main characteristics of a modern supermarket from a
transportation perspective are that supermarkets attract large volumes
of customers, who make regular visits to purchase significantquantities of groceries and other household items. Whilst cross-
shopping (and therefore shared trips) can and should be encouraged
wherever possible, the fact remains that a large proportion of
supermarket shopping trips are and will continue to be sole-purpose
trips.
5.3 The need to transport large quantities of goods between the
supermarket and (generally) home means that the private vehicle is
realistically the only practical alternative for many grocery shopping
trips, and the use of public transport or walking and cycling is typically
not a feasible option. Depending on the particular type and location of
the supermarket, varying proportions of customers can and will make
smaller purchases and travel by other modes (public transport,
walking, cycling), but the underlying characteristics of most
supermarkets do involve the private vehicle. Realistically, this is
unlikely to change in the foreseeable future.
5.4 As a result, supermarkets generate high levels of parking demand,
and the provision of customer car parking that is readily available at all
times is fundamental to supermarket operation. Whereas customers
of many retail activities may be able to use "shared" parking
opportunities (and indeed in many situations should be encouraged to
do so), the simple need to utilise shopping trundlers for large
quantities of groceries means that car parking must be provided as
close as possible to the supermarket. Imposing maximum parking
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rates without recognising the particular characteristics and needs of a
supermarket can have a serious impact on the convenience, operation
and viability of that supermarket and, whilst avoiding the over-
provision of parking will be appropriate in many circumstances, under-
providing short term customer parking for supermarkets can seriously
affect the operation and viability of the supermarket.
5.5 The Council currently proposes (Development Control 3.2, Table 3) a
maximum parking rate of 1 space/20m2 GFA for all retail other than
food and beverage, on sites within the City Centre Fringe overlay and
Metropolitan Centre, Town Centre Local Centre, Mixed –Use and
Terrace Housing and Apartment Buildings ("THAB") zones. This is a
generic approach to all retail in general, and makes no recognition of
any specific characteristics of supermarkets.
5.6 Within the "retail" group of activities, the parking rates sought by the
KRG are as follows:
For general retail, excluding supermarkets, retain a maximum
rate of 1/20m2 as currently proposed by the Council.
For supermarkets, introduce a maximum rate of 1/17m2.
5.7 The intention of seeking the slightly higher maximum rate for
supermarkets of 1/17m2 is to provide a small degree of flexibility for
applicants to ensure that the full car parking provision can be made to
ensure that supermarket customer demand is met under differing
circumstances.
5.8 In the statement of evidence of Ms Mairi Joyce on behalf of the
Council, some data on parking rates at existing supermarkets is
provided9 from which Ms Joyce concludes that "based on the
evidence available I am comfortable that the proposed rates for
general retail (being a maximum of 1 per 20m2 in the Centre, Mixed
Use and THAB zones) provides a range in which the current parking
demands for supermarkets and discount department stores can be
accommodated."
9 Paragraph 132, Table 1.
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5.9 We too have put together some data on a sample of existing NTC
supermarkets, as set out in the table below.
Recently Developed and Propo sed New World Superm arkets
New World GFA SPACES RATE
Papakura 3081 156 1/19.8
Howick 3093 163 1/19.0
Orewa 2967 143 * 1/20.8
Kumeu 2852 173 1/16.5
Te Puke 2678 138 1/19.5
* 40 of 183 spaces legally assigned to Council public parking
5.10 The supermarkets included in the above table have been chosen as
being recently approved or developed New World stores in the
Auckland area, therefore illustrating the current general trend in
supermarket parking provision. Whilst it is acknowledged that there
are numerous supermarkets in Auckland that do provide lower parking
rates (for whatever reason), the table demonstrates that a parking rate
of at least 1/20m2 is the level of parking currently being provided at
new, modern supermarkets, in which case a 1/20m2 maximum rate
would be too low for these supermarkets. All but one of the stores
would comply with the 1/17m2 maximum rate sought by KRG, which
illustrates that this would be a realistic but not excessive maximum
rate for providing supermarket car parking.
5.11 It is noted that for a supermarket of 3,000m2
(a fairly typical size formodern New World supermarkets), the worst-case scenario of
allowing a maximum rate of 1/17m2 rather than the generic 1/20m2
could potentially result in an additional 26 parking spaces (moving
from 150 spaces to 176 spaces). In the context of a wider transport
environment this is unlikely to have a significant detrimental effect, but
it could have a very noticeable beneficial effect on the operation and
viability of the supermarket.
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5.12 In discussing the rationale for maximum parking rates, Ms Joyce
states:10
…I consider the rates to provide a generous "upper limit" forland use activities located within or close to centres. Thisallows for developers to determine the most appropriate levelof parking for their land use activity, whilst also providingprotection from significant parking over supply.
5.13 Then when discussing the rationale for minimum parking rates, Ms Joyce
states that:
the reduction in the minimum rates is intended to provideincreased flexibility to allow developers to select the mostappropriate parking provision for their site whilst providingprotection from a significant undersupply of parking…
5.14 Clearly Ms Joyce appreciates the importance of allowing developers
some flexibility to select the most appropriate parking provision for
their particular site and activity, but the reluctance of the Council to
acknowledge any different type of retail such as a supermarket
appears to revolve around the desire to reduce the number of land
uses for which parking rates have been included in the Unitary Plan to
simplify the rules.11
5.15 In terms of oversupplying or undersupplying car parking for their
customers, our experience is that supermarket operators are very
conscious of avoiding the unnecessary costs associated with
providing large areas of car parking that might not be needed, but are
equally conscious of ensuring that sufficient car parking is provided to
meet all demand. Both of these scenarios have a significant effect on
the viability of the supermarket, as discussed in the evidence of
Angela Bull on behalf of NTC.12
We consider that the provision of aspecific parking rate for supermarkets (maximum rate of 1/17m2) will
provide the necessary flexibility to achieve viable and efficient
supermarkets, with minimal overall additional impact on surrounding
areas or activities.
5.16 The desire to retain some degree of flexibility (specifically the 1/17m2
maximum rate for supermarkets) will become increasingly important
10 At paragraph 33.11
At paragraphs 35 and 45.12
At paragraph 21.
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into the future. As development within or close to centres continues to
intensify, in line with the overarching objectives of the Unitary Plan,
land will become increasingly scarce and costly, and this is likely to
encourage supermarket operators to design smaller stores that will
have to serve increasing customer numbers within any given
catchment. Even acknowledging the general desire and opportunities
within centres for encouraging the use of public transport, walking and
cycling, the result is likely to be higher customer numbers and higher
parking demand, resulting in higher parking rates to meet that
demand. Building the additional flexibility that is sought by the KRG
into the Unitary Plan Development Controls will take account of these
future trends. The Council's aim of generally reducing the amount of
parking that can be provided by other developments and activities
(see below) can only exacerbate these increasing pressures on
supermarket parking.
6. CYCLE PARKING
Background
6.1 The Unitary Plan introduces for the first time in Auckland,
requirements for cycle parking, and end-of trip facilities such as
showers and changing areas, ("cycle facilities"). Cycle facilities did
not feature in any of the legacy district plans. In this regard then, the
Unitary Plan is essentially starting from a zero base.
6.2 The inclusion of requirements for cycle facilities follows from the
strategic directions set in the Auckland Plan, wherein one of the goals
is to deliver by 2040 a transport system capable of doubling the
proportion of non-car trips made in the morning peak. This means
that cycling, as a non-car mode, will have to play its part in achieving
this target. Cycling currently accounts for 1.5% mode share in
Auckland during the morning peak, and about 1% mode share for all
travel to work.13 This means that the provision of cycle networks and
13 Statistics NZ – New Zealand Household Travel Survey: Travel to work for the
Auckland Metropolitan Urban Area – 3 year moving average.
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cycle facilities will be necessary to achieve this doubling of cycle use
over the next 25 years.
6.3 However, while there is KRG support for the goal of increased cycle
use, the means of achieving that goal has to be appropriate. Without
derogating from the enthusiasm and passion of Auckland Transport's
and Auckland Council's cycling advocates, their enthusiasm must be
tempered by commercial realities and realistically attainable targets in
order to ensure that achievement of the desired goals is positively
supported and affordable.
6.4 In this regard, we note from the evidence of Ms King
14
that cycleinfrastructure in Auckland is a work in progress. Development of
Auckland's cycle network is still in its early stages, and the Auckland
Plan has a set target to have the Auckland Cycle Network completed
by 2030.
6.5 We also note from her evidence that by far the greatest impediment to
cycling in Auckland is currently the safety implications of using the
existing road network.15 This means that in order to get meaningful
traction in terms of encouraging greater cycle use, ongoing upgrading
of the cycle network must take priority.
6.6 In the evidence of Mr McLean16, he notes that there is currently little
quantitative research either in New Zealand or overseas, which looks
at the demands for cycle parking. Mr McLean therefore looks to what
Christchurch and Hamilton have adopted for their district plans as his
yardstick for Auckland, despite the significant spatial, geographic and
climatic differences between those two cities and Auckland (as has
been discussed in more detail in the KRG Joint Planning evidence).
6.7 The key points to be made with respect to the above comments are
that:
(a) The Unitary Plan is starting from a zero base with regards
requirements for cycle facilities.
14 Evidence of Kathryn King, Page 4.15
Evidence of Kathryn King, Pages 9 and 10.16
Evidence of Christopher McLean, Page 27.
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(b) The current major impediment to cycle use is not a lack of
provision for workplace cycle facilities but rather the safety (or
lack of) for cyclists using the current road network and the
difficulties associated with cycling given Auckland's
topography.
(c) It is going to take Auckland Transport some significant time to
complete its ongoing development of a safe cycling network
as planned.
(d) There is virtually no empirical basis for adoption of the cycle
parking rates that are proposed in the Unitary Plan.
6.8 Yet despite these constraints, the Unitary Plan seeks to impose at the
outset what the KRG considers to be almost utopian requirements for
cycle facilities, which will come at a significant cost to developers.
6.9 At the other end of the scale, it could be reasonably argued that there
is in fact no need for the mandatory provision of cycle facilities, since
the market will dictate demand for these facilities. As cycling as a
travel mode becomes more popular and ingrained, pressures will
come on employers, building owners and developers to provide the
facilities that the occupants seek. Developers would be incentivised
by the reduced costs associated with cycle parking versus car parking,
and by value premiums associated with being able to provide what the
market seeks.
6.10 A good example of how this has worked in practice is in the
development of green-star rated buildings. It is not mandatory for a
developer to build green buildings, but they are doing so because they
can achieve a value premium by providing what owners and tenants
increasingly want to have.
6.11 Realistically, the answer to the provision of cycle facilities probably sits
somewhere between mandatory provision right now of what we would
eventually all like to see one day in the world's most liveable city,
versus free market drivers.
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6.12 Accordingly, the KRG is proposing somewhat reduced requirements
for cycle parking and end-of-trip facilities that still go well beyond what
is currently experienced, but still remain realistic and affordable to
developers.
Office Cycle Parking
6.13 The Unitary Plan as notified seeks office cycle parking on the basis of:
(a) 1/100 m2 GFA for visitors (short-stay).
(b) 1/300 m2 GFA as secure (long-stay).
6.14 Subsequent to notification, the visitor (short-stay) cycle parking
requirement was increased by Council to be:
(a) 1 space + 1/1,000 m2 GFA.
6.15 The long-stay cycle parking remained at:
(a) 1 space/300 m2 GFA.
6.16 With regards the visitor (short-stay) cycle parking, Mr McLean17
justifies the parking rates on the basis that it:
… is considered fair and takes into account the significantscale of some office buildings in Auckland, particularly in theCBD.
6.17 As a basis of determining visitor cycle parking in Auckland, this seems
particularly thin. It would seem that this rate has been proposed on
the basis of what seems "about right".
6.18 In order to gauge just what this rate means in reality, and building
upon Mr McLean's reference to CBD offices, we have examined as a
test example, the Vero Centre on Shortland Street in Auckland City.
The Vero Centre has been chosen because it already provides a
significant area for cycle parking within the building (this cycle parking
area being reasonably secure within the parking structure and
immediately adjacent to lifts). The Vero Centre has a gross floor area
17 Evidence of Christopher McLean, Page 6.
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of 68,900 m² GFA. It is understood that existing visitor cycle use
amounts to the occasional cycle courier. Yet if the Unitary Plan visitor
cycle parking requirement is applied, it would have to provide 70 cycle
spaces for visitors. While this is just one example, it does clearly
serve to demonstrate that there is a gaping disconnect between
aspiration and likely reality.
6.19 Accordingly, the KRG proposes a less onerous, but nevertheless still
aspirational visitor cycle parking rate as follows:
1,000m² GFA
1 plus 1 per 3,000 m² GFA
6.20 The recommendation of nil parking for small offices recognises that
most such offices will have little or no ability to physically provide on-
site visitor cycle parking.
6.21 Tying the above rates back to the Vero Centre example would still
require 24 visitor cycle parking spaces to be provided. In the context
of the occasional cycle courier that presently visits the building, this is
still clearly aspirational.
6.22 The Unitary Plan requirement for long-stay cycle parking at one space
per 300m² has been determined on the assumption that one
employee in 20 will ride a cycle to work, (each employee typically
occupies 15 m²).
6.23 Again, reverting to the Vero Centre example, where ample cycle
parking is available, and showers etc. are provided within a
gymnasium within the building (and on some of the tenanted office
floors of the building), one space for 300 m² for staff would produce a
staff cycle parking requirement of 230 spaces. This total compares to
several recent observations of actual cycle parking demand which
reveals existing demands that have varied between 18 and 23 spaces
(as shown in the photograph below).
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6.24 There is, then, a substantial disconnect between what happens now,
and what the Council track-change version proposes. This ten-fold
disconnect is substantially greater than the target doubling of cycle
use as proposed by the Auckland Plan.
6.25 The KRG considers that a more appropriate rate to apply to office
long-stay cycle parking is one space per 600 m2. Tying this back to
the Vero Centre example still results in a requirement for 115 spaces,
which is clearly still hugely aspirational (representing a growth
significantly greater than the goal of doubling cycle use as set by the
Auckland Plan), but at least it is slightly more realistic and affordable.
6.26 With regards the issue of cost, one of the arguments forwarded in
support of the notified version cycle parking rates is that cycle facilities
are cheap to provide18. However, in this Vero Centre example, the
space and infrastructure costs of accommodating 70 visitor cycle
spaces plus 230 staff cycle spaces, totalling 300 cycle spaces, would
be substantial, especially if only ever partially utilised.
Retail Cycle Parking
6.27 The Unitary Plan as notified seeks retail cycle parking on the basis of:
18 Evidence of Christopher McLean, Page 5.
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(a) Food and beverage:
(i) Visitors: 350m2 – 1 per 350m2
(ii) Long Stay: 1 per 200m2 GFA
(b) All other retail:
(i) Visitors: 500m2 – 1 per 350m2
(ii) Long Stay: 1 per 300m2 GFA
6.28 Following mediation, the rates for retail cycle parking were modified to
those now proposed in the evidence on behalf of council. They are as
follows:
(a) Food and beverage:
(i) Visitors: 350m2 – 1 per 350m2
(ii) Long Stay: 1 per 300m2 GFA
(b) All other retail:
(i) Visitors: 5,000m2 – 1 per 750m2
(ii) Long Stay: 1 per 300m2 GFA of office
6.29 The modified cycle parking rates for food and beverage in the Council
track-change version are acceptable to the KRG.
6.30 The modified cycle parking rates for all other retail in the Council
track-change version are also acceptable to the KRG. Just by way of
a litmus test, a 6,000 m2 large format retail store would be required to
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provide 8 visitor cycle spaces; and the 42,500 m2 St Lukes shopping
centre would be required to provide 57 visitor cycle spaces (where
they currently provide 13). These visitor cycle parking totals for all
other retail are therefore considered to be aspirational but realistic.
End-of-Trip Facilities
6.31 The notified version of the Unitary Plan contained very detailed and
prescriptive requirements for cycle end-of-trip facilities (i.e. in terms of
where cycle parking is to be located, how cycles are to be made
secure, etc.) which applied to offices, education facilities and
hospitals.
6.32 Following mediation, many of those prescriptive elements of end-of-
trip requirements have been deleted, which the KRG considers
appropriate.
6.33 However, the Council is still proposing in evidence prescriptive
requirements relating to showers, changing rooms and clothing
storage areas. While the rates proposed are not unacceptable, the
KRG is of the view that is it unnecessary for the Unitary Plan to be
prescriptive about showers and changing rooms in new buildings, and
that this is better left to building developers, owners and tenants to
determine. The KRG therefore considers that these requirements
should be deleted.
6.34 The end-of-trip facilities have now been clarified as applying only for
staff use, and to new buildings. With regard the latter, the intention is
that they would not apply retrospectively to existing buildings.19
This
is fully supported by the KRG.
7. LOADING
7.1 The loading requirements are set out in Development Control 3.2,
Table 7.As an outcome of mediation, the Council proposes to increase
the threshold above which a loading space is required for retail and
19 Evidence of Christopher McLean, Page 9.
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industrial activities from 100m2 to 300m.220 () We agree that this now
represents a more realistic level below which an activity should still be
able to operate with on-street loading without affecting the transport
environment.
7.2 The KRG supports the remainder of the loading requirements.
8. DESIGN OF PARKING AND LOADING AREAS
8.1 As an outcome of mediation, the Council proposes some minor
changes to the car parking design standards (Table 8), as outlined in
the evidence of Karl Hancock (paragraphs 57-62).
8.2 Particular changes include clarification that these are minimum
standards; provision of a separate set of parking dimensions for
parking areas that are intended for use only by regular users (eg staff,
residents); and inclusion of "retail" within "all other activities" to better
reflect the loading requirements for those retail activities (rather than
applying the "industrial" standard).
8.3 The KRG supports the amended parking design standards.
9. ACCESS
9.1 In the notified Unitary Plan, the access rules are provided to:
(a) enable a safe and efficient interface between a development
site and the frontage roadway;
(b) to protect the operations of adjacent intersections and
motorway interchanges, and arterial roads; and
(c) to limit, discourage or control vehicle crossings within certain
high pedestrian area, and / or to provide for continuity of
building frontages.
20 Evidence of Mairi Joyce, paragraph 57.
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9.2 With regard the latter point, the access objectives and policies as
notified, used prescriptive language that required the ‘avoidance’ of
vehicle access to and from sites subject to either a:
(a) Vehicle Access Restriction – general within the City Centre
zone; or
(b) Key Retail Frontage (Zone controls, Building frontage maps)
overlay in the Metropolitan Centre, Town Centre and Mixed
Use zones,
and restriction on vehicle access to and from sites subject to a:
(c) General Commercial Frontage (zone controls, Building
Frontage maps in Metropolitan Centre).
Town Centre and Mixed Use Zones
9.3 Following mediation there was agreement on replacement of the word
‘avoid ’ as being overly prescriptive in the context of the activity status
that applies. The language agreed at mediation which we consider to
be more appropriate is now:
(a) ‘Restrict or manage’ site access adjacent to intersections or
motorway interchanges, or onto arterial roads.
(b) ‘Discourage’ access across the Vehicle Access Restriction-
General in the City Centre Zone.
(c) ‘Limit ’ access across the General Commercial Frontage in
Metropolitan Centre, Town Centre and Mixed Use zones.
9.4 It is noted with regard the latter that in the objectives and policies,
Policy 23 retains the words “to and from sites subject to the…”,
whereas in previous clauses these words have in Council's evidence
been replaced with the words “across the…”. This appears to be an
oversight in Policy 23, and it is recommended that Policy 23 be
amended accordingly. This would recognise that there are
circumstances where not all frontages to a site are subject to vehicle
access restrictions, in which case access could be taken from the
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unrestricted frontage(s) without conflicting with the reason(s) that the
restriction has been placed on the other frontage(s).
9.5 The Council now proposes additions to the activity table to recognise:
(a) Permitted activity status for existing crossings servicing
activities where a Vehicle Access Restriction applies.
(b) Restricted Discretionary status for use of an existing crossing
where a Vehicle Access Restriction (General in the City
Centre Zone or Key Retail Frontage) applies in relation to
new development or redevelopment.
(c) Restricted Discretionary status for the situation where a new
crossing is established where a Vehicle Access Restriction
(General in the City Centre Zone or Key Retail Frontage)
applies, and the new crossing is to enable the relocation or
amalgamation of an existing crossing(s).
9.6 These proposed additions are appropriate from a traffic engineering
perspective, as the impacts on pedestrians along the frontage, and /or the impact upon the continuity of buildings along the frontage, are
both addressed.
9.7 In relation to Vehicle Access Restrictions on Key Retail Frontages
which was subject to a blanket non-complying activity status without
exceptions in the notified Unitary Plan, the Council has neglected to
consider the fact that there are numerous existing developments that
have their only vehicle access across the Vehicle Access Restriction,
and have no other access options available. This clearly means there
would be no opportunity to either change the nature of the activity that
the access serves, or to modify access even if the modification meant
a net improvement to access conditions (for example, by way of
amalgamation of two existing crossings into one new crossing).
9.8 By way of example of the frequency with which existing crossings
would become non-complying under the notified rules, an examination
has been made of the Newmarket 1 Precinct which is in the area
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outlined below. Within this area there is approximately 1510 m of
General Commercial Frontage within which there are 22 crossings,
and 2975 m of Key Retail Frontage within which there are 29 existing
crossings that would immediately become non-complying, and for
which no alternative access exists.
9.9 Flexibility on how the crossings for these sites are managed over time,
and flexibility with regards the ability to undertake redevelopments on
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those sites, is important and sensible in order to maintain the ongoing
viability and vitality of those sites.
9.10 Accordingly, we strongly support the addition of flexibility to the
Vehicle Access Restriction requirements to properly recognise existing
accesses to existing developments, and to enable future
developability of the sites served by those accesses.
Proposed Rules
9.11 Based on the discussions above, we therefore endorse the track-
change version proposed amendments and additions to Rule 3.4.1
regarding vehicle access.
Width and Number of Vehicle Crossings
9.12 The Council track-change version contains some amendments to
Table 13 which specifies the number of permitted vehicle crossings.
9.13 When considering the maximum number of vehicle crossings, an
amendment has been made to apply the rates to site frontages, rather
than to the site as a whole. This reflects the fact that some sites havemultiple frontages with potentially quite independent access
implications.
9.14 Table 13 also implicitly acknowledges that larger sites can also
accommodate multiple vehicle crossings on the same frontage,
provided that they are adequately separated to ensure no interactive
effects between the crossings.
9.15 Accordingly, those parts of a site subject to a Vehicle Access
Restriction under clauses 3.4.1.2 and 3.4.13, and a General
Commercial Frontage (zone controls, Building Frontage Maps), will
now be permitted up to one vehicle crossing per 50 m of frontage or
part thereof (compared to one overall as required by the notified
provisions); and all other sites will be permitted up to one crossing per
25 m of frontage or part thereof, (compared to two overall as notified).
9.16 With regard to the latter however, while for ‘all other sites’ , the change
from a maximum of two crossings to one per 25 m of frontage was
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agreed by the traffic experts during mediation, upon further reflection it
is apparent that this will materially disadvantage smaller sites
(residential in particular), where two crossings are either desirable or
necessary – for examples to achieve a pair of one-way entry and exit
crossings, or to achieve crossings to separately accessed parking
areas.
9.17 Accordingly, we recommend a small alteration to the provision for the
maximum number of vehicle crossings per road frontage of the site for
‘All other sites’, to be:
Either two crossings per frontage; or one per 25 m of frontageor part thereof.
Access for Non-Arterial Roads
9.18 The Council track-change version proposes the deletion of Rule
3.4.2.3 which (as notified) required that where a site has frontage to
both an arterial road and a non-arterial road, the vehicle crossing must
be on the non-arterial road.
9.19 We fully support deletion of this rule. Mandating the use of a non-
arterial frontage for access in favour of an arterial frontage has the
potential to introduce unintended consequences, most particularly the
drawing of large volumes of development-related traffic into local
areas. This problem would become greatest in residential areas.
9.20 Further, in a broader transportation sense, it can often be a much
more efficient solution to manage large traffic volumes directly to and
from an arterial road. A Town Centre shopping centre or a large
school are good examples of activities where access is usually best
managed from an arterial frontage, rather than drawing large traffic
flows into non-arterial (potentially residential) roads that are probably
less able to accommodate the generated traffic demands.
9.21 Rule 3.4.1.3d requires a Restricted Discretionary assessment of any
access proposed across an arterial road frontage. This incentivises
the easier route of providing access via the non-arterial road frontage
(if the choice is available). However, for developments that may be
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better suited to arterial road access, that option will remain available,
albeit by way of a restricted discretionary assessment.
Vehicle Crossing and Vehicle Access Widths
9.22 Table 15 in 3.4.3.2. of the Council track-change version provides
some small adjustments to some vehicle crossings and vehicle access
widths for some zones. These proposed modifications to the table go
at least some way to achieving a better balance between the vehicle
manoeuvring requirements of users, versus the amenity requirements
of passing pedestrians.
9.23 This is further assisted by the proposed note to Table 15, which
applies to the maximum two-way width of crossings in General
Business, Business Park or Industrial zones, and which states that a
maximum width of 9 m is permitted where the crossing needs to
accommodate the tracking path of large heavy vehicles.
9.24 However, there are still some deficiencies in the table that in our
opinion do not adequately address the actual and practical needs of
users of the vehicle crossings. In this regard, we consider that theUnitary Plan still retains an unnecessary emphasis on pedestrian
amenity when considering the design of vehicle crossings, whereas
the primary design consideration should be to achieve the purpose of
the crossing, which is to move vehicles to and from the roadway. It is
fully accepted that the amenity of any pedestrians on the frontage
footpath must be properly considered, but not at the expense of an
ineffectual and inefficient means of accommodating manoeuvring
vehicles.
9.25 For examples, the crossing widths as currently proposed do not take
account of high traffic generators such as schools and retail
developments; nor do they fully take into account the manoeuvring
requirements of large trucks (even notwithstanding the note to the
table).
9.26 With regard the former, a two-way access to a high traffic generator
almost inevitably needs sufficient width to accommodate an entry
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lane, and separate right and left turning exit lanes. These lanes
cannot be accommodated within either a 6m or 7m crossing width.
Indeed a 6m crossing width is only just able to comfortably
accommodate both an entering and exiting vehicle, as illustrated
below.
9.27 While the two passing cars can be accommodated, it is tight. What
this means is that a crossing of this width will have only a limited
capacity to meet the demands of a high traffic generator.
9.28 If a crossing has inadequate capacity due to insufficient width, then it
substantially increases the potential for on-site and off-site congestion
and queuing, which in turn markedly decreases pedestrian safety and
amenity.
9.29 Rather, and as noted, a high traffic generator requires an crossing of
sufficient width to simultaneously accommodate an entering vehicle,
and separate left and right turning exiting vehicles. In order to
accommodate these turns, separate left turn and right turn exit lanes
are required, and hence a crossing width of around 9m is necessary to
accommodate all these manoeuvres.
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9.30 This is illustrated in the diagram below. If a high traffic generator is
unable to separately provide for left and right turning exit manoeuvres,
severe on-site congestion is likely. This becomes even more relevant
if some form of access control becomes necessary to manage parking
within the site.
9.31 Further, the note to Table 15 which is intended to enable 9 m
crossings if large trucks are to be accommodated, is fine for small
trucks and / or one-way crossings. Larger vehicles, and/or crossings
intended to accommodate the two-way flow of trucks, will require
more. The diagram below shows the swept path requirements for an
11m single unit truck (larger delivery truck).
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9.32 As can be seen, with this generic layout, at least a 10m width is
necessary to enable trucks to turn in and out. Wider crossings again
are necessary to accommodate articulated trucks. The point to be
made is that when designing for high traffic volumes or larger vehicles,
minimum standard dimensions are rarely going to produce the
optimum access solution.
9.33 Accordingly, we recommend some modifications to the table, firstly to
recognise the crossing capacity demands of high traffic generators
such as supermarkets, retail complexes, schools, etc ( where in
considering high traffic generators, we recommend reference to those
activities that trigger the trip generation thresholds in Table 1); and
secondly to recognise the swept path requirements of various truck
sizes.
9.34 For the former, we recommend that a third row be added within the
access width requirements for each of “Centres, Mixed Use and all
other zones not listed below”, and “General Busine