Submission to Auckland Council on Plan Change 78 on housing intensification
PLAN CHANGE 78 ON HOUSING INTENSIFICATION – SUBMISSION BY REMUERA HERITAGE INC TO AUCKLAND COUNCIL
29 SEPTEMBER 2022
Remuera Heritage is an incorporated society that was established in 2007 and has approx 100 members. The society’s purpose is to:
- Share Remuera’s past and present
- Promote and protect Remuera’s heritage character
- Research, collect and conserve pictorial and written records and stories
- Gather oral histories
- Foster awareness and appreciation of Remuera’s natural and cultural heritage
Remuera Heritage holds regular events and participates in Auckland Council’s annual Heritage Festival to celebrate and share our city’s rich heritage. We send out a regular monthly newsletter and have a content-rich website about Remuera buildings, places and people www.remueraheritage.org.nz
Remuera Heritage Inc seeks the following decisions to be made by Council:
- The inclusion of all the Special Character Areas in Remuera currently in the Auckland Unitary Plan (AUP) as Special Character Areas (SCAs) in the Proposed Plan Change.
- In particular, the inclusion of the following properties and/or areas as Special Character areas in the Proposed Plan Change: Sub-areas should be extended or created in Arney Road, 172-251 Remuera Road, Victoria Avenue, Lucerne Road, Market Road, Pere Street, Pukeora Avenue and 682-738 Remuera Road, Benson Road, Kelvin Road, Martin Avenue, Garden Road and Seaview Road.
- Recognition that Remuera has several adjacent ‘isthmus types A, B, & C’ which Council do not consider together in scoring e.g., Remuera Isthmus B and Ohinerau/Mt Hobson should be considered together collectively and combined.
- Inclusion of ‘rear lots’. Also excluded are houses of special and heritage character down driveways, rights of way or on a ‘rear lot’. With the sloping topography of Remuera, however, many are visible from other roads and houses, including Ohinerau Mt Hobson. If these score a 4 or a 5 or 6, they should be included in the scoring for SCAs.
While Council has correctly included Special Character Areas as a qualifying matter, it has not carried forward the part of the Special Character Area in Remuera that is currently contained in the Unitary Plan as Character and Heritage Areas.
- Wrongly set a threshold of “high quality” in deciding which Special Character Areas it has carried forward ;
- Wrongly concluded that this Special Character Area is only of “high quality” if 66% of the properties within it have scored 5 or 6 on its scale, when 4 “character supporting” should also be included;
- Applied an incorrect and/or inadequate methodology and/or used incorrect and/or inadequate criteria in assessing the value of properties within this Special Character Areas;
- Wrongly excluded from consideration a number of properties in this Special Character Areas because it has incorrectly applied its methodology in scoring them;
- Wrongly applied the methodology it has adopted in determining that this area should not be included as a Character and Heritage Area.
- Has used the scoring method not so much to assess the special or distinctive character of houses but to reduce the number of them.
Taken together, these errors mean that this area, which should be protected from insensitive and inappropriate development, is now unprotected.
The failure of the proposed Plan Change to include and protect this areas:
- Is contrary to the purpose of the Resource Management Act 1991 as set out in Section 5 and Part II.
- Does not recognise and provide for the protection of historic heritage from inappropriate subdivision, use, and development as required by S6 (f) of the Act.
- Fails to have particular regard and/or sufficient regard to the matters set out in Section 7 of the Act, and in particular S7:
(b) the efficient use and development of natural and physical resources:
(c) the maintenance and enhancement of amenity values:
(f) maintenance and enhancement of the quality of the environment:
(i) the effects of climate change.
- Will have significant adverse effects on the environment, and in particular on the people in and around the area and their community, on the amenity values in the area excluded and on the social, economic, aesthetic, and cultural conditions which are affected by those matters.
- Is not required to give effect to the requirements of the Resource Management (Housing and Other Matters) Amendment Act 1991 or of the National Policy Statement – Urban Development, because the Plan Change with this Special Character Area included as a qualifying matter would provide more than enough capacity for Auckland’s future housing needs for the foreseeable future.
6. The so-called non-contributing factors e.g. walkable catchments, are made up by Auckland Council and have nothing to do with special character or heritage. Vegetation, ecological areas, green spaces and trees, safe community spaces, infrastructure, amenities and volcanic viewshafts all have a role to play in the scoring and count too for special character. Any assessment should look at the collective values of an area. All Special Character Area Overlays (SCAs) should be reinstated in all areas of Remuera.
7. Housing development has been allowed to creep up the side of Ohinerau Mt Hobson. The Tupuna Maunga Authority has said that “for more than a century, they (the maunga) were administered by city and borough councils that allowed some to be destroyed and houses to be built on others…few people were aware of their deep cultural, historical, geological and archaeological significance.” (NZ Herald, Maunga Authority delivers on co-governance, 29 April 2022 paywalled).
8. The Auckland Unitary Plan allows for the addition of approx. 900,000+ houses across Auckland in the next 30 years. Only 2.6% of Auckland houses are covered by a Special Character Area overlay. 700 of these were in Remuera but most were removed! Remuera Heritage asks:
- That the Special Character Area overlay be reinstated in Remuera. Multiple examples of houses falling within this are attached.
- That the Auckland Unitary Plan be reviewed in 2025, as was originally intended when the AUP was introduced in 2015.
- Auckland Council should ensure government is aware of and agrees to the contentious parts of the NPS-UD being deferred for due and properly conducted research and decision-making until the 2025 review of the unitary plan. Auckland deserves to be consulted by the government about its future.