Before the Auckland Unitary Plan Independent Hearings Panel in the matter of The Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010 and in the matter of Proposed Auckland Unitary Plan Topic 079 Special Character and Pre-1944 Mapping PRIMARY STATEMENT OF EVIDENCE OF AMELIA JOAN LINZEY ON BEHALF OF HOUSING NEW ZEALAND CORPORATION 839, FS 3338 Primary statement of evidence of Amelia Linzey on behalf of the Housing New Zealand Corporation Dated: 22 December 2015 2 INDEX INDEX .......................................................................................................... 2 OVERVIEW STATEMENT ................................................................................. 3 INTRODUCTION ............................................................................................ 7 SCOPE OF EVIDENCE ..................................................................................... 8 PART A: THE SPECIAL CHARACTER OVERLAY ................................................ 12 USE OF THE OVERLAY ................................................................................. 12 USE OF THE OVERLAY AS A DETERMINANT FOR DENSITY ............................... 13 CHARACTER STATEMENTS ........................................................................... 15 PART B: PRE-1944 OVERLAY ....................................................................... 23 CONCLUSION ............................................................................................. 26 Amelia Linzey Statement of Evidence NZ1-11225045-Planning Evidence PAUP .docm, December 2015 3 STATEMENT OF EVIDENCE OF AMELIA LINZEY ON BEHALF OF HOUSING NEW ZEALAND CORPORATION 22 December 2015 OVERVIEW STATEMENT 1 My full name is Amelia Joan Linzey. I am a Planner and hold the position of Technical Director at Beca Limited. I am providing planning evidence on behalf of Housing New Zealand Corporation’s submissions (839, FS 3338) in respect of Hearing Topic 079 - Special Character and Pre-1944 mapping. 2 I provide this statement of planning evidence relying on, and not repeating, other evidence prepared on behalf of the Corporation in respect of the PAUP. In particular, this includes: 2.1 Evidence presented in respect of Topic 010, and 029/030 including my own evidence and the evidence of Mr Pearson in respect of historic heritage; 2.2 Evidence presented in respect of Topic 013, including my own evidence in respect of wider objectives of the PAUP including urban growth; 2.3 Evidence prepared for this Topic, including: (a) The heritage evidence of Mr Pearson; and (b) The economic evidence of Mr Heath and Mr Osborne. 3 The Corporation now has approximately 18ha directly affected by the revised special character overlay (increasing to approximately 30ha if consideration is given to the whole of a development site as being affected, rather than specific properties) and 37ha directly affected by the revised Pre-1944 Overlay (increasing to some 60ha if whole development sites affected are considered). This represents a very minor reduction in the extent of property affected Amelia Linzey Statement of Evidence NZ1-11225045-Planning Evidence PAUP .docm, December 2015 4 by the special character overlay, of only 3%1 but a decrease of 85% of the Pre-1944 overlay (though this amounts to a 75% reduction if whole development blocks affected are assessed). While this is a notable reduction in the extent of the Pre-1944 Overlay, the heritage overlays combined nonetheless represent a significant proportion of the Corporations housing stock (equating to 4% of sites directly affected and 6% if development sites are taken into consideration). 4 In summary, the key points addressed in my evidence are: In respect of the Special Character Overlay: 4.1 I am of the view that the revised spatial application of the Special Character overlay remains to be more appropriately a reflection of the amenity and built form context of these areas as compared to ‘historic heritage’ value. 4.2 I appreciate the identified amenity /built form characteristics of these areas and the value of these characteristics to residents. However in my view, it is more appropriate for these values to be reflected in zone provisions than as discrete overlay values that have primacy to the functional amenity values of these areas. On this basis I remain of the view that these overlays should not be the driving determinant of the land use and density controls. For these reasons, I do not support the proposed “blanket” approach to the underlying zoning of sites subject to the character areas as Single House. 1 As a result of Council’s proposed uplifting of the Heritage Area in Jordan Ave (with consequential transfer to a Character overlay), this results in increase in the area impacted by the Overlay of 0.6%, if whole development sites are considered affected. Amelia Linzey Statement of Evidence NZ1-11225045-Planning Evidence PAUP .docm, December 2015 5 4.3 I consider that if both the ‘zone’ and ‘additional control’ (i.e. overlay) approach is to be retained (rather than embedding characteristics in the zone or creating a new zone) it is important that the specific matters of development control are recognised as such. The work done on the provisions and assessment matters in respect of Topic 029 (with Council) made significant progress on this. However, I maintain my position that the tools used need to distinguish that the outcome of control is how change happens not if change happens. 4.4 Notwithstanding these overarching concerns I consider that, on the basis of Mr Pearson’s review, the following ‘sub’ areas have been identified as not displaying the amenity/ built character values as set out in the associated character statement prepared by Council: (a) Northcote Character Statement: Northcote (Onewa Road, Waimana Avenue, Bruce Street, Belle Vue Avenue); (b) Isthmus A Character Statement: Freemans Bay (Hepburn Street, Anglesea Street and Tahuara Street as well as the site of the multi-unit flats on corner of Franklin/England, Ryle/ ood and England/Ryle); (c) Isthmus B Character Statement: One Tree Hill (Massey Avenue, Kawau Road, Te Kawa Road, Waiohua Road), Meadowbank (Meadowbank Road, Bonnie Brae Road, Macpherson Street), Otahuhu (Jellicoe Street, Beatty Street), Sandringham (Kiwitea Street, Lambeth Road), Three Kings (Donald Crescent, Clehom Avenue, Bridgman Avenue, Fearon Avenue, Denbeigh Avenue, Mount Roskill Road, Radnor Road); and Amelia Linzey Statement of Evidence NZ1-11225045-Planning Evidence PAUP .docm, December 2015 6 (d) Onehunga (Cardwell Street), given a character statement could not be identified in Council’s evidence. 4.5 There are several of the Corporation’s sites that I accept display the identified amenity/ built character values of the Councils’ character statement. However, for the following sites I consider that the costs associated with protecting these values outweigh any benefit derived from protecting the built form amenity. These areas include: (a) Isthmus B Character Statement: Mt Albert (Burnside Avenue, Verona Avenue); (b) Isthmus C Character Statement: Three Kings (Scout Avenue, McCullough Avenue). 4.6 In respect of other areas identified by Council, I restate that the position that these areas be identified for their ‘character value’ is on the basis that they are being managed for built form/ amenity (and in particular streetscape amenity) and not historic heritage protection. 5 In respect of the Pre-1944 Overlay: 5.1 I remain concerned with the Council’s approach for an interim protection of the Pre-1944 Overlay, particularly in light of the evidence of Council (Ms Rowe and others) where Council indicates that the effect of the overlay as interim protection will also result in interim ‘down-zoning’ (to Mixed Housing Suburban or Single House zones), until such time that Council has prepared a Plan Change. It also appears that at the time of a future Plan Change, these areas would likely be subject to further ‘down-zoning’ (e.g. to Single House Zone). Amelia Linzey Statement of Evidence NZ1-11225045-Planning Evidence PAUP .docm, December 2015 7 5.2 I do not support the proposed interim down-zoning of sites subject to the Pre-1944 Overlay for the following reasons: (a) Down-zoning is being proposed in areas I consider to be particularly suitable for residential intensification (e.g. in close proximity to centres and public transport networks); (b) I do not believe that sufficient evidence has been presented to evaluate the costs of down-zoning these areas against the benefit of protecting areas that have a potential value as character areas; and (c) As such I am concerned that the approach unreasonably predetermines the outcome of what Council are seeking to achieve in any future Plan Change and creates potential obfuscation of the potential costs of the future overlay and down-zoning that may be proposed. 5.3 I consider that the more normal and appropriate approach in such circumstance would be to undertake a Plan Change to these areas in a transparent planning process that assesses the costs of down-zoning in these areas relative to the benefits. For these reasons I maintain my opinion that the Pre-1944 overlay should be withdrawn. INTRODUCTION 6 My full name is Amelia Joan Linzey. I am a Planner and hold the position of Technical Director at Beca Limited. I have the qualifications and experience set out in my statement of evidence, dated 17 October 2014, on the Regional Policy Statement (“RPS”) Topic 005 (including Attachment A