SECTION 32 REPORT Future Urban Growth

1 Executive Summary ...... 1

2 Introduction and Purpose ...... 2

3 Statutory and Policy Context ...... 3 3.1 Resource Management Act ...... 3 3.2 Statutory Planning Documents ...... 4 3.3 Regional Policy Statement ...... 6 3.4 Iwi Environmental Management Plans ...... 7 3.5 Other Legislation, Policy and Guidance Documents...... 9 3.6 Local Policies, Plans and Strategies ...... 10

4 Context, Research and Trends ...... 13 4.1 Operative District Plan Approach ...... 13 4.2 Other Methods ...... 22 4.3 State of the Environment ...... 22 4.4 Effectiveness of the Operative District Plan Approach ...... 28 4.5 Other Relevant Research/Documents ...... 29

5 Consultation ...... 30 5.1 General consultation ...... 30 5.2 Consultation with Iwi Authorities ...... 31

6 Key Resource Management Issues ...... 32

7 Proposed District Plan Provisions (Objectives, Policies and Methods/Rules) ...... 32 7.1 Strategic Objectives ...... 33 7.2 Objectives and Policies - Future Urban Zone (FUZ) ...... 34 7.3 Rules – Future Urban Zone ...... 35 7.4 Planning Maps - Future Urban Zone ...... 36 7.5 Objectives and Policies - Structure Plan Development Areas ...... 36 7.6 Rules – Structure Plan ...... 37 7.7 Definitions ...... 38 7.8 Planning Maps - Structure Plan Development Areas ...... 38

8 Approach to Evaluation ...... 38 8.1 Evaluation of Scale and Significance ...... 39 8.2 Explanation Summary ...... 39

9 Evaluation of Objectives ...... 41

10 Evaluation of Options to Achieve the Objectives ...... 44

11 Summary ...... 49

12 Appendices ...... 49

1 Executive Summary The population of the New Plymouth District is projected to grow to 106,100 people by 2048 (22,700 more people than live here today). To provide dwellings for these people, the District will need an additional 10,919 new dwellings (364 per annum for 30 years). A planned and cohesive approach to growth is required.

The effects based approach to urban growth in the Operative District Plan has created difficulties in effectively providing available land that is feasible for future development. In 2008, Council reviewed the District’s land supply under the Operative District Plan and adopted its Framework for Growth. This resulted in several plan changes to address growth pressures. Although this has provided for growth in places, the effects based planning regime has not effectively dealt with urban growth in a comprehensive manner.

The National Policy Statement for Urban Development Capacity (NPS-UDC) recognises the national significance of urban environments and provides direction to decision- makers on planning for urban environments. The NPS-UDC places a legal requirement on the Council to respond and provide zoned, feasible, serviced land to meet our projected population growth. The National Planning Standards 2019 provides clear direction on the growth framework District Plans must follow. This involves land identified for growth being safeguarded through Future Urban Zones and Structure Plan Development Areas put in place to ensure comprehensive development of these areas can occur.

The resource management issues relating to growth are: the provision of adequate land in the right location for growth; safeguarding this land for future urban growth and avoiding residential subdivision and development creep into the rural/Future Urban Development Overlay areas.

The key changes introduced for growth are:  The introduction of a Future Urban Zone to specifically recognise and identify suitable areas for residential and business (which includes industrial) growth in the medium to long term future. In line with the National Planning Standards, this zone will have specific objectives and policies that provide for the efficient urban growth of the District while ensuring adverse effects of unplanned urban growth are managed.  Zone specific rules, effects standards and assessment matters that provide a clear framework to manage urban growth and preventing activities from establishing in these areas that may affect the ability to develop the area for urban growth purposes in the future.  The introduction of Structure Plan Development Areas for identified zoned and serviced growth areas. Specific objectives and policies will ensure good quality subdivision and development outcomes, and that infrastructure is available to service these areas.  The requirement that Future Urban Zones are to be appropriately zoned, planned (i.e. an agreed structure plan in place) and serviced before it can be developed for urban use.

The proposed plan will improve urban growth outcomes by providing a strengthened approach to the identification and provision of adequate land for growth in the right location. This will be supported by a robust policy framework that will ensure comprehensive, high quality development can occur in these areas.

2 Introduction and Purpose This report contains a section 32 evaluation of the objectives, policies and methods relating to urban growth in the Proposed New Plymouth District Plan. It is important to read this report in conjunction with the section 32 overview report which contains further information and evaluation about the overall approach and direction of the District Plan review and Proposed District Plan.

The New Plymouth District is one of the fastest growing areas in New Zealand. Recent estimates predict that the District will continue to experience significant population growth over the coming years. Faced with such growth pressures it is essential that future urban growth is appropriately managed by providing adequate land for future urban growth, safeguarding this land for future urban growth and avoiding ad hoc development within Future Urban Zones.

The Proposed District Plan provisions have, therefore, been developed on the premise that the District is going to grow and the Proposed District Plan needs to manage the location of growth by safeguarding this land to enable future urban growth to occur.

Consolidating and directing the location of the growth of the district through managing future subdivision and development in areas that are available or maybe part of a future growth area, promotes the sustainable management of the district’s natural and physical resources. It is also is crucial to protecting and providing for high quality development and ensuring New Plymouth is an excellent place to live, work and play. To help achieve good quality subdivision and development outcomes in urban areas, areas need to be appropriately zoned (e.g. from Future Urban Zone to a residential or industrial zone), appropriate serviced and structure plans need to be in place before they these areas be developed for urban use.

This report sets out the statutory and policy context for urban growth, the key resource management issues, specific consultation and approach to evaluation on this topic to decide on the proposed provisions. The report also includes a review of the existing plan provisions and an evaluation of alternative methods to achieve the purpose of the Resource Management Act (RMA) in relation to the urban growth topic.

This Section 32 report covers the provisions in the Special Purpose - Future Urban Zone chapter, Development Areas Structure Plans and rezoning in the Proposed District Plan. The Proposed District Plan also contains a residential chapter, a rural chapter, and a subdivision chapter, which are related to, and have some overlap with the urban growth topic as these may be relevant to the development or subdivision of a property in an identified Future Urban Zone or Development Area Structure Plan. The evaluation for the other chapters are set out in the Section 32 evaluation report specific to each topic.

3 Statutory and Policy Context 3.1 Resource Management Act The Resource Management Act (RMA) sets out the functions of territorial authorities in Section 31. The key function for the district council is the establishment, implementation and review of objectives, policies and methods to achieve the integrated management of the effects of the use, development, or protection of land and associated natural and physical resources of the district. “Natural and physical resources’ includes natural landforms, buildings and structures. In particular, under Section 31 (2), the district council control of subdivision of land.

Section 6 of the RMA specifically requires that the Council recognise and provide for matters of national importance, including: a) The preservation of natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use and development.

Section 7 of the RMA requires the Council to have particular regard to the following matters: (a) Kaitiakitanga (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.

The above matters are relevant when considering future urban growth issues. There are structure plan development areas and Future Urban Zones that are adjacent to waterbodies. The protection of these waterbodies is an important function of the District Plan. Ensuring that the District Plan caters for efficient use and development of future urban growth areas through allocating the most appropriate land for Future Urban Zone/Structure Plan Development Areas is critical to ensure the efficient use and development of the other zones throughout the district (e.g. Rural Production Zone). The requirement for Structure Plan Development Areas for growth areas will help ensure the maintenance and enhancement of amenity values and the quality of the environment is able to occur.

Section 8 of the RMA requires the Council to take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi). Tangata whenua, through iwi authorities have been consulted as part of the District Plan review process. This feedback has informed the section 32 evaluation, and the obligation to make informed decisions based on that consultation is noted.

The above matters form the purpose of the RMA and are required to be considered as part of the Section 32 analysis.

3.2 Statutory Planning Documents

3.2.1 The National Policy Statement on Urban Development Capacity 2016 (NPS-UDC) The National Policy Statement on Urban Development Capacity 2016 (NPS- UDC) came into effect on 1 December 2016. It recognises the national significance of urban environments and provides direction to decision-makers on planning for urban environments. The NPS-UDC seeks to ensure there is sufficient development capacity for housing and business with a suite of objectives and policies to guide decision- making in urban areas.

The relevant objectives and policies place a requirement on local authorities to provide for urban growth. The NPS-UDC requires the Council to look at the district projected population growth and pre-empt market demand by unlocking and servicing land feasible for development.

New Plymouth District meets the NPS-UDC definition of a ‘high growth urban area’, meaning there will be high population growth in the New Plymouth District over the next ten years. The population is projected to grow from an estimated 83,400 in 2018 to 92,400 in 2028, and to 106,100 by 2048. This equates to growth of 22,700 (27.2%) people who will have a wide range of social, housing, environmental and economic needs.

The New Plymouth District projected population growth is outlined in Table 1 below1.

Table 1: New Plymouth District Population Growth based on NPS-UDC requirements

2018-23 2023-28 2028-33 2033-38 2038-43 2043-48

New Plymouth 83,400 92,400 96,300 99,800 103,000 106,100 District Population Growth

The NPS-UDC requires councils with high growth urban areas to provide sufficient development capacity to meet demand over a 30-year period, including 15-20% additional development capacity to ensure there is competition in the housing and business markets. Policy PA1 of the NPS-UDC sets out housing and business land development capacity that the council is required to provide in the short, medium and long-term:

1 New Plymouth District Housing and Business Development Capacity Assessment (June 2019)

Table 2: Policy PA1 of the NPS-UDC

Short term Development capacity must be feasible, zoned and serviced with development infrastructure. Medium term Development capacity must be feasible, zoned and either:  serviced with development infrastructure, or  the funding for the development infrastructure required to service that development capacity must be identified in a Long Term Plan required under the Local Government Act 2002. Long term Development capacity must be feasible, identified in relevant plans and strategies, and the development infrastructure required to service it must be identified in the relevant Infrastructure Strategy required under the Local Government Act 2002.

Policy PA1 directs local authorities to demonstrate within the District Plan that their short – long term development capacity is available. New Plymouth District has calculated its growth demand over a short, medium and long term and assessed it based on the existing industrial land in the current District Plan and percentage of this land that has been identified to be retained as part of the Proposed District Plan.

The vacant industrial land supply, the rezoning of land to residential, the Future Urban Zone and the Structure Plan Development Areas identified through this District Plan review process is intended to give effects to the requirements of the NPS-UDC.

3.2.2 National Planning Standards Released in April 2019, the purpose of the National Planning Standards (planning standards) is to improve consistency in plan and policy statement structure, format and content.

The standards were introduced as part of the 2017 amendments to the Resource Management Act 1991 (RMA). Their development is enabled by sections 58B–58J of the RMA. They support implementation of other national direction such as national policy statements and help people to comply with the procedural principles of the RMA.

The Proposed District Plan will give effect to the planning standards. Of particular relevance is the growth framework that District Plans must follow which includes:  Special purpose zone- Future Urban Zone and  Development areas- Structure Plan chapters

Special Purpose Zone- Future Urban Zone are “areas suitable for urbanisation in the future and for activities that are compatible with and do not compromise future urban use” and Development Areas are “a development area spatially recognises and manages areas where plans such as structure plans apply to determine future land use or development.”

The Future Urban Zone and Structure Plan Development Areas also use the standardised definitions commonly associated for growth provisions etc. See Section 7.7 of this report for further details.

3.3 Regional Policy Statement Under Section 75(3)(c) of the RMA, the District Plan must give effect to the Regional Policy Statement. The Regional Policy Statement (RPS) must also give effect to the NPS- UDC.

The Taranaki Regional Policy Statement (RPS) does not have specific direction on urban growth but the ‘sustainable urban development’ objective, policies and methods are relevant:

Sustainable Urban Development  SUD Objective 1 To promote sustainable urban development in the Taranaki region.  SUD Policy 1 To promote sustainable development in urban areas by: (a) Encouraging high quality urban design, including the maintenance and enhancement of amenity values. (b) Promoting choices in housing, work place and recreation opportunities (c) Promoting energy efficiency in urban forms, site layout and building design (d) Providing for regionally significant infrastructure (e) Integrating the maintenance, upgrading or provision of infrastructure with land use (f) Integrating transport networks, connections and modes to enable the sustainable and efficient movement of people, goods and services encouraging travel choice and low-impact forms of travel including opportunities for walking, cycling and public transport (g) Promoting the maintenance, enhancement or protection of land, air and water resources within urban areas or affected by urban activities (h) Protecting indigenous biodiversity and historic heritage, and (i) Avoiding or mitigating natural and other hazards.

The RPS also states that territorial authorities may wish to consider the following methods:

SUD Method 5 Include in district plans or resource consents, provisions or conditions that address sustainable urban development issues including among others: (a) Objectives, policies, methods, rules and performance standards controlling land use, development and subdivision (b) Building and development controls or criteria (c) Esplanade reserves or strips or access strips.

SUD Method 11 Generally promote good planning, building design and urban design that give effect to the New Zealand Urban Design Protocol (2005) including the strategic integration of local, regional and national infrastructure and land use.

3.4 Iwi Environmental Management Plans For the purposes of the District Plan Review, Iwi Environmental Management Plans must be taken into account under Section 74 (2A) of the RMA. The following Iwi Environmental Management Plans are relevant (albeit in various in various stages):

3.4.1 Taiao, Taiora: An Iwi Environmental Management Plan for the Taranaki Rohe (2018). This plan was lodged with Council in 2018. Taiao, Taiora is a document for Taranaki Iwi to guide and inform decision making by the Iwi. It is structured into five sections, reflecting the interrelated natural systems. Taiao, Taiora sets out issues, objectives and policies. Urban Growth is referred to as urban growth and development. The section on Papatuanuku (the land) includes the following relevant issue and objective:

Issue 9. Poorly designed subdivision and development can lead to unsustainable and inefficient land use, destruction of wāhi tapu and other important sites …

Objective 5. The whenua will be cared for by Taranaki Iwi and others for mutual, reciprocal benefit for the whole community. Taranaki Iwi are seen as leaders in sustainable living and sustainable land management on our whenua;

Taiao, Taiora clearly states that the Taranaki Iwi will not support any subdivision and development that adversely impacts the important cultural values associated with landscapes of importance to Taranaki Iwi (hapū, marae/pā). Taiao, Taiora has been taken into account in the review of the urban growth for the district and incorporated into the provisions for the Future Urban Zone and Structure Plan Development Area Chapters.

3.4.2 The Maniapoto Iwi Environmental Management Plan (Ko Tā Maniapoto Mahere Taiao) (2016) The degradation of the mauri and wairua of the environment and the decline and loss of indigenous flora and fauna is a concern for Maniapoto. There are increasing pressures on resources from agriculture, tourism, forestry, industry and urban activities. Maniapoto are not opposed to development, however, they consider the historic cost to the environment to be unacceptable. The parts of the plan that are relevant to urban growth is that they would like to avoid unsustainable and inappropriate land use practices. There is a chapter on urban planning and development which is relevant to growth and they would like to see urban planning and development provide for the environmental, economic, social and cultural needs of Maniapoto.

This Plan is still under revision and has not been lodged with Council.

3.4.3 Ngati Mutunga Iwi Environmental Management Plan (2014 update) includes The plan has a chapter on subdivision, development and land use which is relevant to growth and future urban zone/development areas chapter of the proposed District Plan. Under this chapter an Objective seeks To encourage well planned development that avoids adverse effects on our cultural values, protects the environment and provides a great quality of life for everyone – now and in the future. This Plan is still under revision and has not been lodged with Council.

3.4.4 Tai Whenua, Tai Tangata, Tai Ao, Te Atiawa Iwi Environmental Management Plan (2019). This is a document for Te Ātiawa Iwi to guide and inform decision making by the iwi. This document is in draft and Council has provided feedback on the document. It is structured into five chapters, then schedules and appendices reflecting the interrelated natural systems. It also sets out the iwis resource management issues, objectives and policies. Tai Whenua Tai Tangata, Tai Ao Te Atiawa iwi includes the following issues and objectives which are relevant to urban growth.

Issue TTAN4: Inappropriate subdivision and development can generate effects on Te Ātiawa values.

The objectives and policies to address this issue within the rohe of Te Ātiawa are:

Objectives  Ob. TTAN4.1 the interests, values and protection of wāhi tapu/wāhi taonga, urupā and sites of significance to Māori are provided for in the process and design of subdivisions.  Ob. TTAN4.2 Acknowledge and provide for Te Ātiawa values and the expressions of our narrative in the built form and landscaping.  Ob. TTAN4.3 Water, stormwater and waste water solutions are co-designed with Te Ātiawa to ensure Te Ātiawa values associated with waterbodies impacted at the time of subdivision are protected and enhanced.  Ob. TTAN4.4 Acknowledge and provide for Te Ātiawa cultural landscapes in the built design to connect and deepen our ‘sense of place’.

Policies  Pol. TTAN4.2 Require regional council and district councils to consider cumulative effects and future land uses when assessing applications to subdivide.  Pol. TTAN4.3 Require regional council and district councils to engage at Plan Change stage, where plan changes are required to enable subdivision, to identify potential effects on wāhi tapu/wāhi taonga, urupā and sites of significance to Māori and Te Ātiawa cultural values.  Pol. TTAN4.15 Encourage retaining the natural landform and topography within the subdivision.  Pol. TTAN4.16 Encourage and support Te Ātiawa, as a property developer, to set the highest possible standard of best practice for residential land developments in the rohe.

Tai Whenua Tai Tangata, Tai Ao Te Atiawa iwi Environmental Management Plan 2019 clearly states that the Te Kotahitanga O Te Atiawa Taranaki Iwi will not support any subdivision and development that adversely impacts the important cultural values associated with landscapes of importance to Te Atiawa (hapū, marae/pā). Tai Ao Te Atiawa has been taken into account in the review of the urban growth for the district and incorporated into the provisions for the Future Urban Zone and Structure Plan Development Area Chapters.

3.5 Other Legislation, Policy and Guidance Documents Other legislation and regulations that are relevant to the Urban Growth Section that have been considered in preparing the Proposed Plan, are:

3.5.1 Local Government Act 2002 (LGA) Sections 14(c), (g) and (h) of the LGA are also of relevance in terms of policy development and decision making: (c) when making a decision, a local authority should take account of— (i) the diversity of the community, and the community's interests, within its district or region; and (ii) the interests of future as well as current communities; and (iii) the likely impact of any decision on the interests referred to in subparagraphs (i) and (ii): (g) a local authority should ensure prudent stewardship and the efficient and effective use of its resources in the interests of its district or region, including by planning effectively for the future management of its assets; and (h) in taking a sustainable development approach, a local authority should take into account— (i) the social, economic, and cultural interests of people and communities; and (ii) the need to maintain and enhance the quality of the environment; and (iii) the reasonably foreseeable needs of future generations

As per Part II of the RMA, the provisions emphasise a strong intergenerational approach, considering not only current environments, communities and residents but also those of the future. They direct a future focussed policy approach, balanced with considering current needs and interests. The provisions also emphasise the need to take into account social, economic and cultural matters in addition to environmental ones.

Section 102 of the LGA requires the Council to adopt a policy on development contributions. Residential development increases pressure on the capacity of the Council’s infrastructure (roads, sewers, stormwater, water and open space) and service delivery and can result in the need to upgrade existing and/or develop new infrastructure and services. Through it’s Long Term Plan, Council sets development contributions at appropriate levels to ensure that the costs of growth are paid for by those who create the demand for the additional infrastructure and services.

3.5.2 Regional Economic Development Tapuae Roa–Make Way for Taranaki: Taranaki Regional Economic Development Strategy, August 2017 (Tapuae Roa) is a culmination of work undertaken by the district councils and regional council of Taranaki in partnership with Ngā Iwi o Taranaki. It is designed to feed into the Long-Term Plans of all the councils in the region, and influence public and private sector investment decision‐making on future activities.

Specific ‘enablers’ targeted for acceleration in the document that are relevant to the Future Urban Growth topic include:  Major hard infrastructure: infrastructure that provides access – sea port, airport, roads and broadband

 Major sector supports: sector‐related infrastructure that supports growth – science, research, and technology, plus accessibility and connectivity  People based capability, liveability. Providing an adequate amount of Future Urban Zone land for future General Residential and Industrial land to support growth and provide opportunities is critical to urban improvement and the delivery of Tapuae Roa.

3.5.3 Other legislation and regulations:  Building Act 2004  NZS4404 Land Development and Subdivision Infrastructure and NPDC Local Amendments, which contains detailed technical and engineering requirements and guidance on ‘low impact design’ solutions and storm water management  National Policy Statement for Electricity Transmission

3.6 Local Policies, Plans and Strategies

3.6.1 New Plymouth District Strategic Framework The vision for the New Plymouth Strategic Framework is Building a Lifestyle Capital (He Whakatutu Haupu Rawa Hei Ahua Noho). The community outcomes this will achieve are: Putting people first (Aroha kit e Tangata), Caring for our place (Manaaki whenua, manaaki tangata, haere whakamua) and Supporting a prosperous community (Awhi mai, Wāhi atu, tatou katoa).

The New Plymouth District Blueprint first adopted in June 2015 is a 30-year spatial plan that provides eight key directions for Council. This key direction relevant to the Special Purpose-Future Urban Zone and the Structure Plan Development Areas is:  Growth/Te Wahakatipuranga - Cohesive growth that strengthens the city and smaller settlements

The key direction acknowledges the significance of growth and the need to provide for future growth. Determining the appropriate locations for growth will contribute to all the community outcomes and highlights the need for a pragmatic, solutions-focused District Plan that accommodates and provides for growth into the future through the provision of adequate land supply in appropriate locations.

3.6.2 Housing and Business Capacity Assessment (June 2019) As noted above, the National Policy Statement – Urban Development Capacity requires councils with high growth urban areas to provide sufficient development capacity to meet demand over a 30-year period, including 15-20% additional development capacity to ensure there is competition in the housing and business markets.

The Council has recently prepared a Housing and Business Development Capacity Assessment (HBA) which is a detailed analysis of housing and business growth across the New Plymouth District, based on current and future levels of demand, supply and development capacity. Required every three years, the HBA provides a robust, comprehensive and frequently-updated evidence base that has been used to inform and guide development capacity and planning decisions in the district. This HBA has informed and provided background data for New Plymouths growth story.

The HBA has drawn the following conclusions regarding residential development capacity which is relevant to our growth story:  The Operative District Plan provides enough residential plan-enabled feasible capacity in the district in the short and medium term. Without the inclusion of the Future Growth Areas there is not sufficient capacity for the long term. Further refinement has been undertaken on the growth areas through the District Plan Review.  There is enough plan-enabled and feasible capacity in the district to meet demand for housing in the short, medium and long term, provided the proposals that were set out in the Draft District Plan are progressed.  Combined, the Operative and Draft District Plans will provide a maximum capacity for between 12,400 and 21,000 new dwellings. Slightly more than half of these dwellings are feasible to build in the current market conditions. When the 15-20 per cent margin required by the NPS-UDC is included, the residential capacity provided in the Operative District Plan falls short by 3,900 dwellings. However the urban growth areas indicated in the Draft District Plan provides sufficient long term capacity, with an excess capacity of 2,000 dwellings.

The HBA has drawn the following conclusions regarding Industrial development capacity:

 Industrial employment growth projections to 2048: New Plymouth’s net industrial employment base is forecast to increase at a steady net growth rate over the forecast period, by just over 4,400 employees from the 2018 base figure (10,750). Average growth projections are for 140 new industrial employees per annum, bringing the total district industrial employment base to nearly 15,210 by 2048.

 Industrial land demand to 2048: Using the employment growth projections, the amount of industrial land required to meet long term demands is calculated to be 193ha. The vacant industrial land within the Operative District Plan is 191.8ha. There is a shortfall of plan-enabled capacity within the industrial sector in the long term. Ensuring sufficient capacity to meet demand for 193ha of industrial land, will require zoning of additional.

 There are potential issues with the concentration of available industrial land located in the Bell Block/Waiwhakaiho area to the east of New Plymouth in the long term. A portion of current vacant zoned land identified back in 2018 has already been developed in Waiwhakaiho and Bell Block, therefore some of this land is now unavailable for future industrial use.

 The location of the industrial land available. Just under 10ha of the current vacant land is identified in Inglewood and Waitara. This is not the best location in regards to State Highway/port and employment access.

3.6.3 NPDC Development and Financial Contributions Policy (27 June 2018) A development contribution is a levy collected under the LGA 2002 to ensure any development that creates additional demand on council infrastructure contributes to the additional cost created. The policy explains how the Council will use development contributions and also summarises the financial contribution provisions of the District Plan as required by section 106(2)(f) LGA 2002. The current policy was developed as part of the Council's Long-Term Plan 2018-2028 and was approved by the Council on 27 June 2018.

3.6.4 Framework for Growth 2008 and Land Supply Review The Land Supply Review was initiated in 2006 in response to economic and household growth occurring at that time. The review aimed to address the supply of residential and employment land in New Plymouth/Bell Block and in those other towns which currently have residential zoning and the potential to grow.

The Framework for Growth document (2008) represents the outcomes of the Land Supply Review and set out the recommended growth direction for urban expansion within the New Plymouth District. It was based on growth for twenty years from 2007 – 2027. The calculations and growth forecasting was based on growth at the time of 2008 and equated to 2,800 new households being constructed in the ten year period from 1998 to 2008. This forecast predicted the demand of 250 – 300 new homes being required each year. This demand forecast included assumptions around 80% being in urban areas and a large number being infill development within existing residential areas.

The Land Supply Review considered all options for residential expansion that would meet criteria for compact towns. The Discussion and Options Papers published in 2007 presented the best options for growth in each area. Table 3 below shows the Framework for Growth areas.

Table 3: Framework for Growth future growth areas

Growth Areas Framework for Growth recommendation

South West of New Plymouth  Approximately 90 hectares – being areas E1 and E2. (short to medium term) This is land includes Cowling Road across to Frankley Road and up to Patterson Road.  A 2 hectare area on Barrett Road - being Area D  18.5ha of land rezoned by the private plan change by Hawkswood Park Ltd.

New Plymouth east to Bell Block  105 hectares – being Area Q. This area of land (short to medium term) includes land within Bell Block between Wills Road and Airport Drive. New Plymouth east (long term)  350 hectares of land – being Areas K, L and S. This land is within Smart Road and extends south from the New Plymouth urban boundary. Employment land (medium  76 hectares of land – being Area N. This area is term) between Egmont Road and Henwood Road on the southern side of State Highway 3.

Growth Areas Framework for Growth recommendation

Waitara  7 hectares of land – being Area A. This land is the north eastern portion of Armstrong Avenue.  62 hectares of land – being Area B. This land is north of Bayly Street. Onaero  3.5 hectares of land – being Areas B and C. This land is on the northern end of Onaero Beach Road. Lepperton  No areas were recommended in Lepperton as there is sufficient zoned land available for residential development. Egmont Village  7 hectares of land – being Area B2. This land is identified to the west of Egmont Road within Egmont Village. Inglewood  19 hectares of land – being Areas A, B and C. This land is located between Miro Street and Marie Street. Okato  13 hectares of land – being Areas C. This area of land is the north eastern edge of Okato.

The Framework for Growth concluded that the next steps involved undertaking plan changes to rezone the land in the identified growth areas above. Some of these plan changes have been undertaken or identified as Future Urban Development Areas and incorporated into the Operative District Plan. These areas are shown on a map in Appendix 1.

3.6.5 Infrastructure Strategy 2018-2048 (IS) The Infrastructure Strategy identifies significant infrastructure issues the New Plymouth District is likely to face over the next 30 years. The Infrastructure Strategy is not a budget, rather it takes a long term view of the infrastructure and services our communities will need over time and how we might provide them. The Infrastructure Strategy addresses transportation, recreation and open space, water supply, wastewater, stormwater and solid waste. The Infrastructure Strategy has included and planned for infrastructure within the Future Urban Zones and the Structure Plan Development Areas.

4 Context, Research and Trends 4.1 Operative District Plan Approach

4.1.1 Context The existing District Plan became operative in August 2005. As described in the Overview Report, the Operative Plan is an effects based plan and standards are used within each Environment Area (i.e. zone) to determine what is appropriate based on the character and amenity values that the community seeks to protect, as opposed to listing activities that are permitted, or are subject to some type of consent application.

Since the start of the 2000s New Plymouth in particular began to experience growth, predominately in the form of a residential housing “boom”. Urban growth has been experienced in the following ways:  Greenfield subdivision of existing zoned areas;

 Infill within existing zoned areas; and  Plan Changes on the fringes of the city and townships on rural land to facilitate residential and industrial development  Subdivision of rural land i.e. small lot subdivision to cater for lifestyle or residential housing on rural zoned land.

The area that has experienced the greatest urban growth in the form of new subdivision has occurred in the east of New Plymouth City, towards Bell Block.

Demand to accommodate additional growth has placed pressure on rural land in close proximity to existing urban areas and development. In some instances, there is pressure on rural land close to the urban centres to accommodate additional growth through creation of lifestyle properties, expanding urban boundaries, and providing for other commercial and industrial activities

4.1.2 Plan Changes Throughout the lifetime of the Operative District Plan, private and Council initiated plan changes have underpinned the Plan’s urban growth framework. A common theme of these plan changes is the desire to change the zoning to cater for growth.

In particular, Plan Changes 15, 17 and 20 have involved rezoning large areas of rural land to residential and the insertion of Structure Plans to the Operative District Plan. This signals that outward expansion has been a focus of the Operative District Plan.

What has been evident in the District plan Review is that the Operative District Plan is not equipped to cater for current or future growth, and as a result, it has been changed regularly over the past 14 years by Council and/or through private plan changes.

A summary of the growth related plan changes (since 2005) is provided below.

Plan Change 2 (Private) – Rezone Egmont Road Site (Operative 2009) This Plan Change rezoned land from Rural Environment Area to Industrial C Environment Area. 12.5 hectares was rezoned on land located east of Egmont Road, north of the Marton-New Plymouth railway line and south of State Highway 3 at Bell Block. This is the only Plan Change that rezoned land for Industrial Use.

Plan Change 9 (Private) – Rezoning Carrington Road/ Huatoki Street to Residential A Environment Area (Hawkswood Structure Plan) (Operative 2008) This Plan Change rezoned land from Rural Environment Area to Residential A Environment Area. The land is located south of Huatoki Street and west of Carrington Road, Vogeltown, New Plymouth. The total land area was 18.587 hectares.

Plan Change 15 (Council) – Future Urban Development (FUD) Overlay into the District Plan (Operative 2013) The purpose of this plan change is to earmark and safeguard land for future urban development. This Plan Change added a Future Urban Development Overlay, including associated objectives, policies and rules, to provide a level of control to land use activities and subdivision within, and land use activities adjacent to, the future urban growth areas.

The areas included in the Plan Change were identified by the Council’s Framework for Growth (2008), Oakura Structure Plan (2006) and Urenui Structure Plan (2006) including Bell Block Area Q (Wills Road to Airport Drive), New Plymouth Area N (Egmont Road to Henwood Road), New Plymouth Areas S, K and L (Smart Road), Waitara, Oakura, Okato, Egmont Village, Onaero, and Urenui.

Plan Change 17 (Council) – Rezoning of Waitara Area A to Residential A Environment Area (Waitara Area A Structure Plan) (Operative 2014) This Plan Change rezoned part of the Rural Environment Area on Armstrong Avenue, Waitara to Residential A Environment Area. A Waitara Area A structure Plan was included that identified indicative roads and indicative pedestrian links/routes; a preferred esplanade reserve along the eastern and western boundaries of the Tangaroa Stream. Specific policies and rules were included relating to the areas to be rezoned.

The Plan Change also added a general Structure Plan objective and policy framework to Issue 23 to guide future Structure Plans.

Plan Change 18 (Council) - to rezone Inglewood land from Karo Park to the Kurapete Stream Residential A Environment Area (Operative 2013) This Plan Change rezoned parts of the Rural Environment Area between Karo Park and the Kurapete Stream and Karo Park Open Space B Environment Area, Inglewood, to Residential A Environment Area; amend, add and remove Indicative Local Roads within and adjacent to the areas rezoned to Residential A Environment Area; and add Preferred Esplanade Reserves along both banks of an unnamed tributary of the Waiongana Stream, both banks of the Waiongana-iti Stream, and both banks of the Kurapete Stream

Plan Change 20 (Council) - to rezone Area Q from Wills Road to Airport Drive Residential A Environment Area (Area Q Structure Plan) (Operative 2015) This Plan Change rezoned approximately 100 hectares between Wills Road and Airport Drive, Bell Block from Rural Environment Area to Residential A Environment Area; and applied the Future Urban Development (FUD) Overlay to Area R. A detailed Structure Plan, and associated policies were put in place that managed the indicative roading and pathway network and esplanade reserves. The Structure Plan also identified key infrastructure requirements. A staging plan was included in the Structure Plan to reflect the infrastructure and land-use constraints associated with the areas future development.

Plan Change 25: Rezoning of Rural Environment Areas on Cowling Road, Tukapa Street and Frankley Road, New Plymouth to Residential A Environment Area (Operative 2011) This Plan Change rezoned parts of the Rural Environment Area on Cowling Road, Tukapa Street and Frankley Road to Residential A Environment Area. The Plan Change also added indicative roads and indicative pedestrian links/routes to the areas rezoned; added a preferred esplanade reserve along the eastern boundary of the Mangaotuku Stream and updated the ponding area and flood detention areas and spillways overlays in the rezoned area.

Smaller plan changes were as follows:  Plan Change 22 (Council) Rezoning of Residential and Open Space Environment Areas on Ainslee Street, Adam Lile Drive and Winstone Place, New Plymouth (operative 2010)  Plan Change 25 (Council) To rezone areas on Cowling Road, Tukapa Street and Frankley Road, New Plymouth from Rural to Residential A Environment Area (operative 2011)  Plan Change 26 (Council) To rezone land at 387 and 389 Devon Street West from Open Space B Environment Area to Residential A Environment Area (operative 2011)  Plan Change 47 (Council) Minor amendments to Area Q structure Plan (operative 2018)

Plan Change 21 intended to rezone land in Area N from Rural to Industrial C. Investigations were undertaken, but there were challenges with developing the areas as a whole due to land constraints.

There has been two recent applications for Private Plan Changes2 in the towns of Oakura and Waitara that are currently being processed. These Private Plan Changes seek to rezone land from rural to residential within or in proximity to areas identified for Future Urban Development in the Operative District Plan.

4.1.3 Operative District Plan Provisions The Operative District Plan is an effects-based plan. This means that the plan is based around environmental effects rather than the activities that generate them. The ‘Management Strategy’ of the Operative District Plan identifies the following issues relating growth in the district.

 Issue 1A: The adverse effects of activities on the future rezoning and development of areas identified as Future Urban Growth Areas. Issue 1A specifically addresses the protection of Future Urban Growth Areas and ensuring that those areas are not impacted by development that may impact the ability to comprehensively develop these in the future. The issue does not address the role and function of existing zoned residential areas available for residential development.

 Issue 23: The need to comprehensively plan for future urban development. This issue identifies the importance of having a comprehensive plan for future growth areas that are rezoned and the importance of structure plans as a tool to achieve this.

Sitting under Issue 1A and 23 are a suite of Objectives, Policies and Rules for future urban growth areas and structure plans. These are considered separately below.

2 Private Plan Changes 48 and 49.

Future Urban Development Overlay The Operative District Plan objectives and policies for the Future Urban Development Overlay are outlined below.

Overlay Objectives Policies Future 1a To ensure that 1A.1 Activities within the Future Urban Urban activities within and Development OVERLAY should be located and Development adjacent to the Future undertaken in a manner that does not have Overlay Urban Development any actual or potential adverse effects on the OVERLAY do not future rezoning and subsequent development adversely affect the ability of land identified as a FUTURE URBAN to rezone and GROWTH AREA. subsequently develop 1A.2 Subdivision of land within the Future areas identified as Urban Development OVERLAY should be FUTURE URBAN GROWTH located and undertaken in a manner that does AREAS. not have any actual or potential adverse effects on the future rezoning and subsequent development of land identified as a FUTURE URBAN GROWTH AREA. 1A.3 Activities within the RURAL ENVIRONMENT AREA should be undertaken in a manner that does not have any actual or potential adverse effects on the future rezoning and subsequent development of adjacent FUTURE URBAN GROWTH AREAS as identified by the Future Urban Development OVERLAY.

Objective 1A seeks to protect areas for future urban development. Policies 1A.1 and 1A.2 seek to manage and control the type and scale of activities occurring within the Future Urban Development Overlays.

Rules apply to control the location of Intensive pig and poultry farming activities, industrial, business, commercial, community and residential activities and hazardous facilities. Rules also ensure that future development and subdivision does not compromise the ability of the area to be re-zoned for urban use in the future.

As these areas are an overlay the underlying rural zoning and associated policy framework and rules also apply.

Policy 1A.3 seeks to manage activities in the Rural Environment Area that are incompatible with urban use locating in close proximity to Future Urban Growth Areas.

Specific rules in the Rural Environment Area relate to intensive pig and poultry farming activity and/or industrial activities. Consideration is given to whether they will compromise the areas ability to be developed for urban use.

Future Urban Development overlays, were identified through the Framework for Growth and Oakura and Urenui Structure Plans in the following locations:

Future Urban Development Overlay Area of land New Plymouth Area N (Egmont Road to Henwood Road) 76 hectares New Plymouth Areas S, K, and L (Smart Road) 350 hectares Waitara 62 hectares Ōākura 76.6 hectares Okato 13 hectares Egmont Village 7 hectares Onaero 3.5 hectares Urenui 15.6 hectares

These are included on the Planning Maps and the above objectives, policies and rules apply.

Areas for Future Urban Development (Structure Plan Areas) The Operative District Plan objectives and policies identifies the following objectives and policies that apply to Areas for Future Urban Development (Structure Plan Areas):

Overlay Objectives Policies Future 23 That land identified for 23.1 To control the design and layout of future Urban future urban use is urban areas through structure plans to allow Development comprehensively planned for the comprehensive development of the Overlay and to facilitate an integrated area by ensuring: a) The type, location and Bell Block approach to land density of the development is suitable for the Area Q and development while site; b) Infrastructure is provided in a co- Waitara Area addressing site specific ordinated manner by considering location, type A Structure issues to provide for and staging; c) The development considers Plan accessible, connected, topography and minimises changes to Overlays efficient, liveable landform; d) That the constraints are identified communities and coherent and managed to ensure resilient and safe urban spaces. communities. e) Interfaces with surrounding land-uses are assessed and adverse effects are mitigated; f) Open space, parks and esplanade reserves or strips are provided for; g) Connectivity and accessible urban form is provided for; and h) That special features are recognised and that those features of particular significance are protected. 23.2 To ensure stormwater within the Waitara Area A structure plan area is discharged into low impact designed stormwater systems to minimise the environmental impact, including the impact on cultural values. 23.3 To control the number and location of additional VEHICLE ACCESS POINTS in part of the Waitara Area A structure plan area to ensure pedestrian safety.

Overlay Objectives Policies 23.4 To provide a safe and efficient ROAD TRANSPORTATION NETWORK through the control of the number and location of VEHICLE ACCESS POINTS onto Airport Drive and Devon Road (SH3) within the Bell Block Area Q Structure Plan area to: a) Ensure that new VEHICLE ACCESS POINTS to Airport Drive south of Parklands Avenue are appropriately managed to ensure the safety and efficiency, and the sustainable management of the road network; b) Ensure that new VEHICLE ACCESS POINTS to Airport Drive north of Parklands Avenue are avoided as far as is practicable; and c) Ensure that existing VEHICLE ACCESS POINTS to Devon Road (SH3) are closed where alternative road access is available upon significant redevelopment of the properties identified as SH3 restricted access along Devon Road. d) Strongly encourage the development of new ROADS in general accordance with the Bell Block Area Q Structure Plan. 23.5 To ensure landowners, developers and contractors are aware of the requirements of the Heritage New Zealand Pouhere Taonga Act 2014 and/or other national legislation relating to archaeological sites with respect to development and subdivision in the Waitara Area A Structure Plan and the Bell Block Area Q Structure Plan. 23.6 To ensure that subdivision and development within the New Plymouth Airport 50dBLdn noise contour as shown on the Bell Block Area Q Structure Plan considers the potential for reverse sensitivity adverse effects with respect to noise from the New Plymouth Airport through implementing appropriate remedial measures to protect the long term safety, efficiency, operation, maintenance and upgrading of the New Plymouth Airport as infrastructure of significance to the region. 23. 7 To ensure that subdivision and development within proximity to Devon Road SH3 considers the potential for reverse sensitivity adverse effects with respect to noise from the Devon Road SH3 through implementing appropriate remedial measures to protect the long term safety, efficiency, operation, maintenance and upgrading of the Devon Road SH3 as infrastructure of significance to the region.

The intent of these provisions is to provide for growth in a comprehensive and structured way.

Policy 23.1 requires the use of structure plans to guide the design and layout of future urban areas. Policies 23.2-23.7 are specific policies to address particular areas within structure plans.

Structure Plans A structure plan is a tool used to guide the development or redevelopment of an area by defining the future development and land use patterns, areas of open space, the layout and nature of infrastructure (including transportation links), and other key features and constraints that influence how the effects of development are to be managed3.

The structure plans contained in the Operative District Plan use a map to represent the proposed layout, features, character and links for the area being developed. The maps do not typically go into such detail as to define individual lot boundaries or the physical form of buildings and structures. Some of the structure plan maps, plans or representations are supported by text explaining the background to the issues that initiated the structure plan and the approaches to manage those issues, such as specific policies.

In the Operative District Plan, Structure Plans have been developed for:  Egmont Road Industrial C Environment Area Structure Plan (Appendix 28).  Hawkeswood Structure Plan Area (Appendix 29).  Waitara Area A Structure Plan (Appendix 30).  Bell Block Area Q Structure Plan (Appendix 31).

These are described as follows:

Hawkeswood Structure Plan More commonly referred to as “Fernbrook”, this area has been developed on the southern boundary of New Plymouth. The origins of the structure plan were borne out of a resource consent for a residential subdivision in the Rural Environment Area. To ensure a comprehensive approach to the development of this land a Private Plan Change application to rezone 18.587 hectares of rural land was progressed. This included a structure plan indicating how the area should be developed with an indicative roading layout and site specific issues to be addressed. A limitation of this structure plan is that it lacks specific provisions that add weight to enforce the structure plan map.

Egmont Road Structure Plan This was a private plan change to rezone some of the Rural Environment Area between Egmont Road and the State Highway from Rural Environment Area to Industrial. This structure plan includes a structure plan map showing how the site should be developed with an indicative roading layout and site specific issues addressed. The Structure Plan, include some specific provisions but was limited in what could be applied to add weight to the structure plan map.

3 https://www.qualityplanning.org.nz/node/1135

Waitara Area A Structure Plan This Plan Change rezoned seven hectares of land from rural to residential in the north eastern portion of Armstrong Avenue and became operative in 2014. 90% of this area has been developed, with the remaining stages underway. This area had a detailed structure plan map, guidance and objectives, policies and rules behind it. This structure plan has achieved good environmental outcomes with the overall design and layout of the development. However, there have still been some lessons learnt from this process regarding early and on-going engagement with Tangata Whenua.

Bell Block Area Q Structure Plan The Bell Block Area Q Plan Change rezoned 107 hectares (749 dwellings) from Rural to Residential. The Structure Plan identified three stages to recognise infrastructure constraints and land-use conflicts. Stage 3 includes a prohibited activity status limiting residential development until planned roading upgrades occur ie: (Airport Drive is realigned), which also facilitates consideration to the rezoning of Area R.

Since the Plan Change became operative the Council has constructed a sewer and water main and a pump station to service the area. Not originally planned for in the Long Term Plan this work has now unlocked Stages One and Two for residential development. This infrastructure timing misalignment saw a lag in development.

Plan Change 47 minor amendments to the Bell Block Area Q structure plan has enabled some residential development in stage 2 (up to 30 dwellings). This plan change became operative February 2018. Recent implementation of this structure plan has seen significant input by Puketapu hapu to recognise their relationship to this area. Similar to Waitara Area A earlier engagement in the structure plan development process would see more seamless involvement of hapu through structure plan development.

The level of detail included in the Bell Block Area Q structure plan deals with a number of issues that were not included in the Operative District Plan strategic framework at the time it was developed. This raises the issue that the management strategy around structure plans and what they are trying to achieve needs to be strengthened within the Proposed District Plan so that they meet best planning practice around structure plans.

4.1.4 Rules The underlying Environment Area rules still apply to properties located within Structure Plans Area. Specific overlay rules that apply include:  Particular rules that manage the particular characteristics relative to the structure plan i.e. indicative roading requirements, access, cultural values etc.  Discretionary activity for activities not in accordance with the structure plan;  Subdivision (i.e. minimum allotment size) to be managed by the underlying zone parameters.  Zone specific minimum allotment size and other development controls unless the overlay provisions provide greater restrictions.

4.2 Other Methods In addition to the Operative District Plan regulatory approach, the Council uses the following other methods in relation to managing urban growth.

4.2.1 New Zealand Technical Standards NZS4404 Land Development and Subdivision Infrastructure (and NPDC Local Amendments) provides local authorities and developers with criteria for design and construction of land development and subdivision infrastructure, including earthworks and geotechnical requirements and incorporates up-to-date design principles such as low impact design principles.

4.3 State of the Environment One of the District Plan’s most important roles is planning the way the District is shaped (where people live) and the way people get around it. This means prioritising and managing future growth so that the community will know the expectations around how we will grow, and the supporting infrastructure requirements so that informed investment decisions can be made.

4.3.1 Population growth in the District The New Plymouth District is growing and has been subject to growth over the past decade. The New Plymouth urban area is one of New Zealand’s fastest growing districts. Between the 2006 and 2013 census, the district’s population grew from 68,901 to 74,187 (a 7.7% increase).

Figure 1: Population Growth in the New Plymouth District.

The population is expected to continue to grow. The population projections in figure 2 below retain Statistics NZ’s medium projection for births and deaths, but use the high projection rate for net migration. This methodology reflects improving economic circumstances resulting in job creation and inward migration patterns, (based on existing migration trends continuing).

120,000

110,000

100,000

90,000

80,000

70,000

60,000

50,000

40,000

2018 2023 2028 2033 2038 2043 2048 2013 Low

Figure 2: New Plymouth District Population Projections4

The key driver of population growth in New Plymouth has been, and is forecast to continue to be, people moving from other parts of New Zealand and overseas.

The district’s population is expected to continue ageing, with the greatest increase occurring in the 65 and over age group. By 2048, nearly 30 per cent of the total population will be aged over 65. An increased ageing population has resulted in greater demand for rest homes and retirement villages and for smaller housing options.

There will be high population growth in the New Plymouth District over the next ten years. Projections estimate the district’s population will grow from 83,400 in 2018 to 92,400 to 2018 and to 106,100 by 20485. This equates to 1000 more people in the District per year.

Building consent development for the past 25 years shows a period of dwelling growth from 2001 until 2006, and another period of growth from 2011 to 2017.

4 Housing and Business Capacity Assessment. NPDC June 2019

450 Residential Environment Area Rural Environment Area 400 350 300 250 200 150 100 50

1996 2010 1994 1995 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2011 2012 2013 2014 2015 2016 2017 1993

Figure 3: Residential Building Consents by Environment Area

Alongside this there is a general trend of households getting smaller, with an assumption of 2.62 people per household applied. This information assists with understanding future dwelling demand in the District.

Based on forecast population growth and household size approximately 364 dwellings per year will be required to house the growing population in the District.

4.3.2 Residential growth locations Residential growth within the New Plymouth urban area remains primarily infill development, complemented by greenfield and more recently brownfield subdivision and development.

Infill housing relates to new development within an existing suburb of older houses. In New Plymouth District, it typically includes one or more dwellings built behind, in front of, or beside an existing dwelling. It also includes two or more dwellings built where an original house has been removed or demolished.

In terms of greenfield development, the focus for residential growth has been in New Plymouth city and Bell Block. The Bell Block area (Bell Block Area Q and around Wills Road, Parklands) is the main growth area within the New Plymouth City boundary. Bell Block has a high proportion of undeveloped residential land. This eastward growth trend is likely to continue, particularly in the short to medium term and with the residential zoning of Area Q. The growth to the east of the City has required the extension of infrastructure networks, for transport, water and waste water. Future Urban Development Area (Area R) represents the potential future eastern extent of the urban boundary.

Greenfield growth has also occurred on the southern boundary of New Plymouth city in areas of undeveloped residential land, particularly around Highlands Park, Vogeltown, (Fernbrook), Ferndale, Hurdon (Area E) and Whalers Gate. These existing zoned areas are generally serviced through existing infrastructure, although water and wastewater upgrades are required to service some areas in Hurdon.

There has also been greenfield subdivision and development in the Districts towns and smaller settlements. Following the rezoning of Waitara Area A there has been an increase in subdivision and development with Waitara, with this area now fully consented for development. Growth rates in Inglewood and Oakura remain steady, although there has been recent growth pressure in Oakura and Waitara, which are both subject to private plan change processes to rezone land for residential purposes.

A more recent trend has seen older industrial sites in New Plymouth converted to residential use. For example the Robert Stone and Cambrian sites on Carrington Street. This has provided the opportunity for residential growth within the urban boundary, close to community services and facilities.

Another trend has been a disproportionate number of dwellings in the Rural Environment Area, suggesting outward expansion.

There has also been an increase in the number of building consents in other environment areas over the past two years (ie: mainly on industry land). This is consistent with the overall District Plan trend of out of zone activities.

Future Urban Development Areas have also been subject to growth. 25 building consents have been issued for new dwellings in Future Urban Development Areas in the last 5 years. It is important that expansion in these areas does not hinder the ability to comprehensively plan and develop these areas for residential in the future growth.

Summary Understanding growth patterns has been a key focus of the District Plan Review. In summary residential development patterns within the New Plymouth urban area remains primarily infill development, complemented by greenfield subdivision mainly in Bell Block and on the southern boundary of New Plymouth city and more recently brownfield subdivision and development.

What has been revealed through this analysis is that greater consideration and spread of land-supply is required throughout the District to ensure that a compact and planned urban layout can be sustained.

4.3.3 Industrial growth locations Growth in New Plymouth’s industrial sector over the last two decades has been high. The sector’s employment base rose from 7,593 in 2000 to around 10,455 in 2017. This represents a 42% increase in people employed in industry in the District.

Geographically, the eastern side of New Plymouth near Bell Block, Glen Avon and Paraite is where industrial activity is most concentrated. This area is highly desirable, reflecting its prime location for road transport links. Direct access to State Highway 3 and 3A provides efficient transport both north and south from the District and region.

There are also concentrations of industrial zoning near Port Taranaki, and industrial employment in central New Plymouth (with many businesses operating from older central city industrial premises, reflecting older District Plan zonings). Waitara,

Inglewood and Egmont Village have ‘healthy’ industrial employment bases and zoned land given the size of their communities.

As discussed in Section 3.6.2, it is acknowledged that there is an imbalance between the eastern and western sides of New Plymouth in terms of zoned industrial land. However, good transport links are critical to industrial success, while the western side of New Plymouth has direct access to the Port and rail terminal, it does not have direct access to the main north-south arterial of State Highway 3, whereas the eastern side of New Plymouth does.

In analysing industrial land supply outlined in the findings of the Housing and Business Development Capacity Assessment and through zone monitoring, the District Plan Review has concluded that there is a sufficient amount of land zoned (and to be zoned) to meet the long term supply of industrial activities. The current eastern city bias and will be a consideration in identifying future industrial zoning in the long term.

4.3.4 Development outside the urban boundaries (also addressed in the Residential Section 32 report). Over the last decade there has been a disparity between the provision and market demand for residential development that has created pressure for Council to grant residential type subdivisions on rural land. On occasions, this has led to an ad hoc urban form and provision of infrastructure networks. Sprawling infrastructure networks are generally acknowledged to result in greater financial costs (capital and lifecycle) when compared to higher density infill in established urban areas.

Development of greenfield land at the periphery of urban areas has not proven effective in terms of meeting people’s needs or protecting the rural production zone. There are a considerable number of properties located throughout the District that have been subdivided resulting in fragmentation of land that is neither suitable for typical suburban residential living, nor useful or viable for ongoing rural production purposes. In addition, there has been little control over the effect of activities located at or near the boundaries between urban and rural areas of the District. Growing awareness of the effects of both rural and residential activities on adjoining land users (reverse sensitivity), and the adverse impact on rural land from residential activities has made the effective separation of activities important.

Uncontrolled urban expansion is likely to adversely affect rural land as it limits options for future rural production use and increases the potential for conflict between incompatible activities. It can also result in disconnected neighbourhoods and place pressure on existing infrastructure compromising both residential and rural amenity values.

A key observation of the District Plan Review is that there have been cases where plan changes that have involved rezoning rural land to residential have enabled subdivision and development that do not achieve quality outcomes in terms of layout and design. This has not only compromised the subdivision itself, it has impacted on the ability to provide for growth in the wider area. Examples include the proliferation of cul-de-sacs and right of ways and staged subdivision that has no connectivity to neighbouring streets. This is symptomatic of narrow planning considerations at a site specific level, as opposed to a wider structure plan approach.

To combat ad hoc expansion, it has become increasingly evident that there is a need to consolidate urban boundaries. The approach taken in the review has been to ensure that appropriate mechanisms are put in place to ensure that the land identified for growth is in the right location and secondly to ensure it is planned and well laid out. Strengthened subdivision provisions, design guidance, adequate residential zoned land, the identification of Future Urban Zone and the use of Structure Plans is seen as a key way to achieve this.

4.3.5 Land supply and capacity for future urban growth In order to support a growing population land availability for housing and business (industrial) development is necessary. The Council’s analysis on business land supply through the Housing and Business Capacity Assessment 2019 (HBCA) and the District Plan Review has concluded that there is sufficient business land to meet our projected population growth. Therefore the primary focus of this report and urban growth analysis is on residential growth. Industrial growth is addressed in the Industry section 32.

The HBCA has assessed both the Operative District Plan and the Draft District Plan. This assessment indicates that the Operative District Plan has enough plan- enabled capacity (including oversupply requirements of the NPS-UDC) to meet the short (0-3 years) and medium (3-10years) term requirements. The Draft District Plan has enough plan-enabled capacity to meet long-term requirements (10-30 years) of growth demand.

However, for the purpose of the HBCA the Operative District Plan assessment is only based on residentially zoned land and does not consider Future Urban Development Areas. Emphasis was not placed on the Future Urban Development Areas for the Operative District Plan assessment as these were under review and would not be practically put in place in the short and medium term.

The assessment places more weight on the Draft District Plan in the long term and included a full assessment of supply. The Draft District Plan is mostly aligned with the Proposed District Plan except for the refinement of further Future Development Areas and the inclusion of additional areas for rezoning (increasing medium term supply). It is noted that this information will need to be updated once the Proposed District Plan continues through its process.

The Proposed District Plan takes this supply a step further and ensures that we will met the long term (10-30 years) supply of land for growth and earmarks these as Future Urban Zones (previously identified as overlays).

It is noted that the Draft District Plan has significantly refined the Future Urban Growth, particularly within the small townships. An initial assessment indicated that many of these areas would not be able to be feasibly developed and are not in keeping with the current levels of development and infrastructure planning in these communities.

Table 4: Sufficiency of Housing Capacity to meet demand

Demand Projected Growth + Operative District Draft District Plan (dwellings) dwelling NPS Plan Growth margin Plan- Feasible Plan- Feasible enabled capacity enabled capacity capacity capacity Short Term 1,159 1,391     2018-21 Medium Term 2,541 3,050     2021-28 Long Term 5,634 6,479 2028-48     Total 9,334 10,919 12,388 6,719 20,951 12,991

The assessment shows that there is enough plan-enabled and feasible capacity to meet demand for housing in the short, medium and long term in the Draft District Plan.

4.4 Effectiveness of the Operative District Plan Approach The Operative District Plan manages adverse effects on the environment through bulk and location controls, particularly at zone boundaries, and some issues surrounding traffic and transport.

Since it became Operative, the current District Plan has attempted to address growth issues with the addition of Future Urban Development Overlay and Structure Plan Overlays through plan changes. However, this has not gone far enough to address all the growth issues as discussed below.

The key implementation issues that are being experienced with the Operative District Plan Growth provisions are summarised in the table below.

Issue Comment Response Issue 1 Give effect to the New Plymouth District being Ensure adequate land NPS- UDC and provide identified as a high growth supply in areas of greatest sufficient land supply area under the NPS-UDC, demand. Provide enough the District Plan needs to land for residential and provide sufficient zoned and industrial growth to meet the feasible land available to short, medium and long term meet the NPS-UDC demands of the district. requirements. Also identify and provide Provide adequate land in Future Urban Zone land to the right location for future safeguard areas for future urban growth. growth in the long term. Issue 2 There is residential Increasing pressure for Provide greater policy subdivision and subdivision and out of zone direction focused on development creep into the activities on the urban fringe consolidating urban Rural Environment Area and of New Plymouth. boundaries. into Future Urban Limits options for the future Provide Future Urban Zones. Development Areas. rural production use, increases the potential for Enable infill development.

Issue Comment Response conflict between incompatible activities. Can create disconnected neighbourhoods and place pressure on existing infrastructure compromising both residential and rural amenity values. Issue 3: Comprehensive Misalignment with timing Better integration between development outcomes and demand for District Plan and have not occurred. development and delivery of Infrastructure Planning to infrastructure. ensure projects where Failure to provide an necessary are included in overarching cohesive the Long Term Plan/ development plan for future Infrastructure Strategy to urban growth areas, leads to provide Council funding for ad hoc development, that necessary infrastructure. doesn’t achieve quality Provide clear policy direction urban form, connectivity, that structure plans are and protect site specific required before land can be natural/cultural features. developed. Issue 4: Location and size Future Growth Areas Refine Future Growth Areas of Future Growth Areas located in smaller district to better reflect growth in the settlements are very large smaller New Plymouth and don’t reflect actual District settlements. projected growth patterns Review the location of areas and infrastructure planning. within Future Growth Areas Consideration to Future for Proposed District Plan. Urban Growth in western New Plymouth city is required.

4.4.1 Summary of effectiveness of Operative District Plan approach The implementation issues with the Operative Plan should be resolved so that the Proposed Plan gives effect to the NPS-UDC, provide greater direction on the outcomes expected, and can achieve high quality urban growth subdivision and development in the district.

4.5 Other Relevant Research/Documents The following documents have also been used as background data for the growth analysis of the district:  District Plan Review: Environments: New Plymouth Retail Economic Assessment by Property Economics July 2016 and  District Plan Review: NP Industrial Land demands by Property Economics July 2016.

5 Consultation 5.1 General consultation Extensive consultation was undertaken as part of this District Plan Review process with key stakeholders and the local community. Refer to the General Overview Section 32 report for details on the methods that were used to carry out that consultation. Feedback from consultation relevant to urban growth is summarised as follows.

There has been general support for providing a cohesive approach to growth in the District Plan.

5.1.1 Future Urban Growth Areas A number of Future Urban Growth Areas, (currently called Future Urban Development Areas in the Operative Plan) will be retained in the Proposed District Plan.

All landowners where there is a change in the urban growth areas have been informed through letters and where possible discussions with Council officers. The main interests in the Future Growth Areas is understanding the timing of the potential release of land, and in many cases wanting to accelerate this timing.

There has also targeted consultation with the Community Boards regarding local growth planning. On request of the Inglewood Community Board further work to investigate the potential for future growth areas was undertaken. It was found that Inglewood has enough residentially zoned land to meet demands and that the current zoned land was most appropriately located. The Community Board have concerns about the availability of this zoned land. Council staff will continue to monitor land availability in Inglewood.

5.1.2 New structure plan areas Areas that have been identified as most suitable for rezoning from rural to residential as part of the District Plan review have been subject to targeted consultation with landowners in those areas to seek feedback. No landowners indicated that they were opposed to the rezoning process but a number had questions on process and implication on their land use.

There have been on-going discussions with impacted landowners on the extent of areas and the relevant provisions that will apply. Residual concerns from landowners are considered site specific matters and general support of the structure plan area remain for all landowners.

Following the release of the Draft District Plan an individual landowner proposed rezoning land in the Frankley/Cowling Growth Area. As a result an additional Structure Plan Area has been included for consideration and consultation in the Proposed District Plan.

5.2 Consultation with Iwi Authorities The Nga Kaitaki group is made up of iwi representatives from iwi/hapu of the district and was formed to provide feedback to the Council as part of the District Plan review. The group is resourced with an independent planner to provide professional development. The Nga Kaitaki group identified key areas of concern and have a particular interest in urban growth and development.

The comments from Nga Kaitiaki on the Draft Plan (2016), including some comments on the effectiveness of the Operative District Plan, are summarised below:  Current draft objectives do not include process type provisions to guide the identification and management of future urban growth, including the active engagement of tangata whenua which is considered necessary, particularly if these provisions are designed to influence private plan changes/structure planning processes.  Ngā Kaitiaki recommend that additional requirements are added to this policy on what structure plans should include: 1. Collaboration with Tangata Whenua in the structure planning of areas; 2. Removal of the wording ‘where appropriate’ following references to Te Aranga principles; 3. Recognition of the relationship of Tangata Whenua with the area (including ancestral lands); 4. The identification and protection of Tangata Whenua values and interests in an area (including historic heritage, biodiversity, waterbodies etc.); and 5. Recognition that Tangata Whenua are the only persons who can identify their rights and values in future growth areas around the District.  Ngā Kaitiaki is supportive of the draft plan framework where explanations, methods and other non-statutory wording has been removed. It is essential that this framework extends to structure plans for FUG to ensure that important elements identified (e.g water body values or sites of significance) are secured by Objectives, Policies or Rules that influence subsequent resource consent and monitoring/enforcement processes. (Waitara Area A is an example where some important elements were not protected as provisions of the structure plan).

Nga Kaitiaki provided feedback on the Draft District Plan (2016) Future Urban Zone and structure plan development areas chapters. The feedback from Nga Kaitiaki was considered during redrafting of the provisions and consequent amendments to the provisions were made. In particular, the proposed provisions comprise:  The addition of a strategic objective that provides direction on how the district grows and recognises the relationship of tangata whenua to land.  A trigger has been added to the Future Urban Zone and Structure Plan Development areas chapters for tangata whenua to be involved in the future urban growth areas/structure process from the outset where there are water bodies/stormwater concerns which link into cultural values and SASM.  Identification of cultural values associated with SASM within rezonings and Future Urban Zones/Structure Plan Development Areas.  Amendments to the structure plan development area provisions to include wording suggestions for involvement in structure plans to ensure cultural values are identified at the beginning of the process.

The comments received on the Draft District Plan (2016) informed the redrafting of the provisions and were reflected in the amendments to provisions in the updated Draft District Plan released for further public comment in 2018.

There has been discussion with specific hapu around the development of structure plan areas to ensure cultural values are captured. Oropuriri and Bell Block Area Q has had involvement from Puketapu hapu throughout the process. Initial discussions were had with Ngati Te Whiti over the Carrington and Junction Structure Plan areas.

6 Key Resource Management Issues The New Plymouth District’s population is projected to growth to about 106,100 people by 2048 (22,700 more people than live here today). To accommodate this growth, the district will need an additional 10,919 new dwellings (or 364 new dwellings per annum) over the next 30 years.

Providing enough zoned land for future urban growth is a key measure of sustainable management and influences how people and communities provide for their social, economic, and cultural well-being and for their health and safety (Section 5(2) RMA).

The resource management issues for growth in the New Plymouth district are as follows:  There needs to be adequate land, in the right location for Future Urban Growth that prevents the outward expansion of the urban boundaries: It is crucial for the Council to plan ahead by providing zoned, serviced and feasible land for residential and industrial development. It is important that this land is appropriately located to reduce urban sprawl and to ensure that the district remains an affordable and desirable place to live, work and play.  Safeguarding land that is identified for Future Urban Growth: It is critical that land identified as preferred for future urban growth, is protected from inappropriate land-use and/or development patterns that will compromise the future development of the land.  Failure to provide an overarching cohesive development plan for growth areas: In absence of comprehensive structure plans ad hoc development and subdivision has been occurred leading to disconnected development patterns and degradation for cultural and natural features.

7 Proposed District Plan Provisions (Objectives, Policies and Methods/Rules) The proposed provisions are set out in the Future Urban Zone and Structure Plan Development Areas of the Proposed District Plan. These provisions should be referred to in conjunction with this evaluation report.

The structure of the Operative District Plan is somewhat complex and difficult to understand in regards to how urban growth is to be managed. The District Plan Review has set out to make a number of changes to the structure of the plan chapters in order to:  Make the Plan more accessible to the community.  Improve the legibility of the Plan and facilitate better decision making processes.

 Address the main gaps and flaws in the existing growth provisions, taking practical steps to fill gaps, remove redundancies and generally streamline provisions to ensure the Proposed Plan can be implemented efficiently.  Place a stronger focus on objectives and policies as these provide the decision making framework for resource consent applications.  Simplify the provisions by providing separate, tailor-made provisions for individual zones.  Simplify the rule structure, using a traffic light system to quickly identify activity statuses as well as creating a logical flow through the different activity types.

The Proposed District Plan provisions have been drafted to include an activity based framework to allow the rules to consider the appropriateness of an activity looking to establish in the Future Urban Zone.

Urban growth residential capacity will be provided through the following areas within the District:  Existing undeveloped residential zoned areas in the short and medium term;  Encouraging infill within existing residential areas e.g. large back yards where new houses or town houses can be built (short, medium and long term); (This is assessed in the Residential Section 32 report.  Identifying and reviewing southern growth areas in the New Plymouth city in the short and medium term;  Rezoning pockets of existing rural land on the edges of urban areas to residential e.g. development areas and greenfield subdivision (short and medium term); (this is assessed in the Residential Section 32 report).  Site redevelopment and building conversions for town housing and low-rise apartment living in centres zones (short, medium and long term); (this is assessed in the Residential section 32 report).  Earmarking rural land as a Future Urban Zone for future growth (long term)

7.1 Strategic Objectives The strategic objectives chapter contains high level strategic objectives and policies that the remainder of the plan must be consistent with. The relevant parts of the strategic objectives to future urban growth is the overarching topic of urban form and development.

The relevant strategic objectives for growth are UFD-13 and UFD-14. UFD-13 aims to ensure the district grows in a cohesive, compact and structured way. This outlines the considerations when determining the location of future growth. Then UFD-14 seeks to ensure there is sufficient land to meet the short, medium and long-term housing and business demands of the district and outlines the preferred locations for this growth as: 1. In existing undeveloped residential areas in the short-term. 2. In Bell Block and the residential southern growth areas of New Plymouth City in the short to medium-term. 3. In the Smart Road growth area as required in the long-term.

4. In areas identified in rural towns and centres to build viable and strong communities; and around Egmont Road and the airport for future industry land.

7.2 Objectives and Policies - Future Urban Zone (FUZ) The activity status and technical standards for Future Urban Zone are generally being retained (albeit simplified and streamlined). However, the Proposed Plan will contain greater policy direction and emphasis on achieving high quality integrated development in a planned and structured manner. This aims to avoid incompatible activities in the Future Urban Zone, avoiding subdivision creep on urban boundaries and providing connectivity, integration of natural features and landforms, and low impact design solutions.

The Future Urban Zone replaces the Future Urban Development Overlay under the Operative District Plan. This meets the requirements of the National Planning Standards that defines the Special Purpose Zone- Future Urban Zone are “areas suitable for urbanisation in the future and for activities that are compatible with and do not compromise future urban use”.

The Future Urban Zone applies to land that has been identified as being suitable for urbanisation in the future. The purpose of this zone is to safeguard, protect and earmark this land for future urban growth.

When the land is required, it will need to be rezoned to facilitate development (e.g. residential or industrial zone). Through the rezoning process a structure plan will be required to ensure the area can be comprehensively developed.

Until required for urban development land within this zone may be used for typical rural activities such as agricultural, pastoral and horticultural activities. Larger scale and industrial activities are to be managed and/or avoided to ensure the activities occurring within the zone are compatible with and do not compromise potential future urban uses.

The Future Urban Zone provides the long term land supply for the District.

In summary the proposed objectives and policies provide a framework to:  Maintain the predominant rural character of the FUZ.  Clearly signalling that the Future Urban Zone is the preferred location for urban growth to meet the District’s medium and long term housing and industrial needs.  Clearly signalling that it is not the proposed District Plans intention for urban growth to occur within the FUZ by stating that before urban growth occurs the FUZ needs to be rezoned and comprehensively planned by a structure plan.  Ensuring activities within and adjacent to the identified FUZ do not compromise the ability to develop the area for urban growth purposes.  Allow existing agricultural, pastoral, horticultural and low density rural living activities to continue (some of what was previously allowed under the previous Rural Environment Area).  Ensure that any structure plan prepared for the purposes of enabling Future Urban Zone land to transition into urban zoned land, provides for comprehensive, coordinated and efficient development which addresses specific matters.

7.3 Rules – Future Urban Zone

7.3.1 Permitted activity rules provide for the following, subject to effects standards:  Agricultural, pastoral and horticultural activities  Residential activities  Residential unit  Minor residential unit  Maori purpose activities  Rural produce retail  Petroleum prospecting  Leisure activities  Home business  Residential visitor accommodation

7.3.2 Discretionary activity rules provide for the following:  Sport and recreation activities  Community facilities  Camping grounds

7.3.3 Non-complying activity rules relate to all other activities, including:  Multi-unit developments  Retirement villages  Visitor accommodation  Primary production activities  Rural industry  Industrial activities  Retail activities  Business service activities  Commercial service activities  Educational facilities (except kohanga reo, cultural education and research facilities)  Petroleum exploration activities  Petroleum production activities  Rural transport activities  Large scale renewable electricity generation activities

The effects standards cover bulk and location, setbacks, shelter belts, maximum number of residential units, and maximum gross floor area. The other chapters in the Proposed District Plan that are relevant to the FUZ are the subdivision and earthworks chapters.

7.4 Planning Maps - Future Urban Zone An assessment of the areas identified in the Operative District Plan as Future Urban Development Overlay have been assessed alongside the NPS-UDC requirements, infrastructure planning commitments and local community needs. These assessments (refer to Appendix 2 for further description) have formed the basis for the areas included in the Future Urban Zone, as follows:  Okato (area being reduced).  Area N (reduced due to the Oropuriri Structure Plan are being rezoned).  Area R (retained with no change).  Waitara East (reduced).  Smart Road Areas (K, S and L) (retained with no change).  Ranfurly Street, Waitara (new).  Frankley Cowling (new).  Ōākura West (retained with no change).  Junction Street (Stage 2) (new).  Ōākura South (no change).

7.5 Objectives and Policies - Structure Plan Development Areas The Proposed District Plan has five Development Areas within urban zones which have been identified as areas that are suitable for rezoning for urban use. Structure Plans apply to these areas.

The purpose of structure plans is to ensure areas within the Future Urban Zone transition successfully and efficiently into urban areas and that all the effects of development are assessed and addressed in advance of development occurring. The level of analysis and detail required in each structure plan should correspond with the type and scale of development. The Proposed District Plan states a structure plan should contain and address the following: 1. The type, location and density of the development is compatible with the planned urbanisation of the Development Area. 2. The activity will result in conflict with existing and planned future activities as the area transitions to an urban area. 3. There are opportunities for the provision of business and retail activities, which are complimentary to the planned urbanisation and will serve the needs of the new community. 4. The area's topographical, natural and physical characteristics, constraints and opportunities have been integrated into the overall design and layout of the activity. 5. Any risks from natural hazards to people, property and the environment will be exacerbated and/or acceptable. 6. The natural values, historic heritage values and scheduled features within the Development Area are maintained and/or enhanced. 7. The activity provides and/or will not constrain, limit or compromise the provision of: a. Adequate, coordinated and integrated infrastructure to meet the planned urban needs of the area.

b. Connected transport networks that allow ease of movement to, from and within the Development Area. c. Integrated and accessible open space networks, parks and esplanade strips. 8. Address any adverse visual effects so that they can be appropriately avoided, remedied or mitigated through screening, planting, building design, siting, and the retention of existing vegetation. 9. Whether staging is appropriate to ensure development occurs logically and achieves good urban form. 10. Any impacts on any cultural, spiritual and/or historical values, interests or associations of importance to tangata whenua, and the outcomes of any consultation with tangata whenua in particular with respect to mitigation measures and/or the incorporation of mātauranga māori principles into the design and development of the activity.

The purpose of structure plans has been the main driver behind the objectives and policies for this chapter.

In summary the proposed objectives and policies provide a framework to:  Allow activities that are permitted in the underlying zone and that are in accordance with the Structure Plan Development Area.  Manage activities that are potentially inconsistent with the Structure Plan Development Area and the role, function and predominant character of the underlying zone and only allow such activities to locate within the Development Area where criteria can be demonstrated.  Avoid activities that are not in accordance with the Structure Plan Development Area, unless criteria can be demonstrated.  Ensure that activities are in accordance with the Structure Plan Development Area having regard to specific criteria to control the matters which a structure plan contains and addressed.  Require that activities within and adjacent to the Development Area do not compromise the ability to develop the area in accordance with the Structure Plan Development Area.

7.6 Rules – Structure Plan

7.6.1 Permitted activity rules provide for the following, subject to effects standards:  Activities (excluding subdivision) that are permitted or controlled activities in the underlying zone where the activity is in accordance with the Structure Plan; and all Effects Standards are complied with.  Subdivision of an land within the Structure Plan Development Area where the subdivision is a controlled activity in the underlying zone; the design and layout of the subdivision is in accordance with and gives effect to the Structure Plan; the subdivision complies with all relevant Effects Standards in the subdivision chapter for the underlying zone; and all DEV2 Effects Standards are complied with. Note this rule also has a discretionary and non-complying component to it.

7.6.2 Discretionary activity rules provide for the following:  Activities that are not otherwise provided for in this table.  Subdivision of land within a structure plan area has a discretionary component.

Non-complying activity rules relate to all other activities, including:  The subdivision is a non-complying activity in the underlying zone or under any rule in an Overlay Chapter.

Note each structure plan development area then contains specific effect standard rules to address specific matters within that structure plan area. An example of this is that the Carrington Structure Plan Development Area has a rule around restrictions for access points and new roads onto Atkinson Road.

7.7 Definitions To help clarify the intent of the provisions, manage activities or align with the National Planning Standards new definitions have been introduced; for example agricultural, pastoral and horticultural activities (NPDC Proposed Plan definition), building activities (NPDC Proposed Plan definition), residential unit (Planning Standards definition), primary production activities (Planning Standards definition) etc. Generic District Plan- wide definitions such as height, site, site access etc are also applicable to the Future Urban Zone.

7.8 Planning Maps - Structure Plan Development Areas In line with the National Planning Standards, Development Areas are areas that “spatially recognises and manages areas where plans such as structure plans apply to determine future land use or development.”

Structure plans essentially operate like an overlay and ensures comprehensive development within the Junction, Carrington, Oropuriri and Patterson Structure Plan Development Areas. The Bell Block Area Q structure plan development area has been carried over from the Operative District Plan with only minor edits.

The following are the Structure Plan Development Areas for the Proposed District Plan:  Bell Block Area Q Structure Plan Development Area (existing with minor edits).  Junction Structure Plan Development Area (new).  Carrington Structure Plan Development Area (new).  Oropuriri Structure Plan Development Area (new).  Patterson Structure Plan Development Area (new).

Details on each structure plan development area can be found in Appendix 2.

8 Approach to Evaluation Section 32(1)(a) of the RMA requires that this report contain a level of detail that corresponds with the scale and significance of the environmental, economic, social and cultural effects that are anticipated from the implementation of this proposal.

The section of the RMA requires that:  New proposals must be examined for their appropriateness in achieving the purpose of the RMA.  The benefits and costs, and risks of new policies and rules on the community, the economy and the environment need to be clearly identified and assessed.  All advice received from iwi authorities and the response to the advice needs to be summarised.  The analysis must be documented, so stakeholders and decision-makers can understand the rationale for policy choices.

8.1 Evaluation of Scale and Significance

Minor Low Medium High Degree of change from the Operative Plan  Effects on matters of national importance  Scale of effects – geographically (local,  district wide, regional, national). Scale of effects on people (how many will  be affected – single landowners, multiple landowners, neighbourhoods, the public generally, future generations?). Scale of effects on those with specific  interests, e.g., Tangata Whenua Degree of policy risk – does it involve  effects that have been considered implicitly or explicitly by higher order documents? Does it involve effects addressed by other standards/commonly accepted best practice? Likelihood of increased costs or  restrictions on individuals, communities or businesses.

8.2 Explanation Summary In summary:  The degree of change from the Operative District Plan is medium, considering that new areas of land are being identified to be structure planned and rezoned and or identified as Future Urban Zone. The activity status and technical standards for Future Urban Zone throughout the District are generally being retained (albeit simplified and streamlined), however, there is greater policy direction and emphasis on achieving high quality integrated development in a planned and structured manner. This aims to avoid incompatible activities in the Future Urban Zone, avoiding subdivision creep on urban boundaries and providing connectivity, integration of natural features and landforms, and low impact design solutions.  The geographic scale of effects applies to specifically the areas within a Future Urban Zone or a structure plan area. The geographic scale of these areas is relatively low in the context of the district. However, the growth strategy will

provide for a more connected and cohesive district and will have wider implications.  The landowners within or adjacent to the areas being rezoned and or identified as Future Urban Zone will be specifically affected by these changes. The rezoning for individual landowners will not affect their current land use but economic benefits are likely to be realised if and when they chose to develop their land. Land owners within the Future Urban Zone may result in some tighter subdivision and development controls but these controls are not likely to affect the majority of land owners and their current land use.  The wider community and tangata whenua are likely to be affected positively by the proposal as it is expected to result in improved urban growth outcomes, creating high quality urban environments for people to live, work and play.  A framework is being put in place to incorporate Maturanga Māori principles (Kaupapa Māori Framework) into the Proposed District Plan. This is positively because it will help guide development within Future Urban Zones and Structure Plan Development Areas.  The proposed Future Urban Zone and Structure Plan Development Area provisions will give effect to the NPS-UDC and part 2 of the RMA, and the National Planning Standard 2019  The proposed Future Urban Zone provisions are considered to be in accordance with best-practice.

Overall, it is considered that the scale and significance of the proposal is medium. The level of detail in this report corresponds with the scale and significance of the environmental, economic and cultural effects that are anticipated from the implementation of the Future Urban Zone and Development Area provisions.

9 Evaluation of Objectives

Existing Objective(s) Appropriateness to achieve the purpose of the Act

Objective 1A: To ensure that activities within and Objective 1A specifically deals with the FUD areas and seeks to manage activities within adjacent to the Future Urban Development Overlay and adjacent to the FUD areas. This objective deals with managing activities within a FUD do not adversely affect the ability to rezone and area until such time as the land is required for urban growth and provides a clear subsequently develop areas identified as future framework to manage activities occurring in a FUD area prior to rezoning and urban growth areas. development occurring. This objective addresses to some extent the resource management issues of safeguarding the identified land for future urban growth and Objective 23: That land identified for future urban use is comprehensively planned to facilitate an integrated therefore can be carried over into the Proposed District Plan. The key limitation of this approach to land development while addressing site objective is that it only relates to FUD areas and does not provide any protection to specific issues to provide for accessible, connected, Structure Plan Areas. efficient, liveable communities and coherent urban spaces. The objective does not direct a structure plan before development can be undertaken, allowing for residential development and creep that can compromise a comprehensive approach to urban development. Therefore one of the key resource management issues is not being meet by ensuring a comprehensive approach to growth in these areas.

Providing adequate land for future urban growth is another key resource management issue that the Objectives in the Operative District Plan do not fully address. In the absence of a specific objective that directs the need for adequate land supply the Operative District Plan does provides some land for future urban growth. This land was identified under a different planning regime back in 2007 and does not deliver on wider district plan outcomes such as ensuring a contained urban boundary and compact urban form.

Objective 23 seeks to ensure that future growth areas are comprehensively planned. This objective has been mainly interpreted to relate to the development of Structure Plans to inform rezoning proposals. The objective is specifically directing structure planning requirements prior to subdivision and or development occurring. This objective seeks to ensure that a comprehensive approach to development is taken within structure plan areas.

Proposed Objective(s) Appropriateness to achieve the purpose of the Act FUZ-01 The Future Urban Zone is the preferred The purpose of the RMA is to promote the sustainable management of natural and physical location for urban growth and is managed to ensure resources by managing the use, development and protection of physical resources in a the District's medium and long term housing and way which enables people and communities to provide for their social, economic and industrial needs are provided for. cultural well-being. Under Section 7(c) and (f), this includes the maintenance and FUZ-02 Until rezoning for urban growth purposes enhancement of amenity values and the quality of the environment, which council shall occurs and the area to be rezoned is have particular regard to. comprehensively planned by a structure plan: 1. urban growth is avoided within the Future Urban The proposed objectives clearly express the outcomes anticipated by the plan in relation to Zone areas; and the FUZ and Development Areas Structure Plans and specifically address the three 2. the Zone is predominantly used for agricultural, resource management issues identified in this report (providing adequate land for Future pastoral and horticultural activities and low density Urban Growth, safeguarding land for Future Urban Growth and avoiding ad hoc rural living activities. development of the Future Urban Zone).

FUZ-03 The predominant rural character of the The growth objectives enable communities to provide for their social, economic and cultural Future Urban Growth zone is retained, which well-being by ensuring urban growth is directed into locations that ensure a compact and includes: cohesive urban form. This will ensure the health and safety of the community by having 1. low density built form with open space between better quality, connected living environments. buildings; The objectives will allow for a comprehensive approach to growth so that more integrated 2. a diversity of topography and land quality, outcomes are achieved. Assessed against the other matters in Section 7 this will lead to including land without significant rural production values and/or versatility;  more efficient use of resources/infrastructure and achievement of long term economic, social and environmental outcomes by aligning growth and infrastructure planning 3. a general absence of urban infrastructure; (Section 7 (b), (g) and (i)). 4. rural roads with low traffic volumes;  Improved amenity values and improvements to the quality of the environment as places 5. areas of vegetation, natural features and open are more connected, accessible, compact and better designed. (Section 7 (c), and (f). space. FUZ-04 Activities within and adjacent to the identified These proposed objectives give effects to the National Policy Statement on Urban Future Urban Zones do not compromise the ability to Development Capacity and will ensure the district develops in a cohesive, compact and develop the area for urban growth purposes. structured way to ensure that sufficient land is supplied to meet the community's short, medium and long-term housing and industrial needs. Further the proposed objectives give

Proposed Objective(s) Appropriateness to achieve the purpose of the Act effect to the specific policies included in the RPS relating to Infrastructure and the Built Environment. The below objectives are for all DEV1, DEV2, DEV3, DEV4 and DEV5. Further the Development Area objectives will maintain and enhance amenity values and DEV2-01 Urban development is enabled within the the quality of environment through requiring structure plans and prepared and that Structure Plan Development Area, provided it occurs development and subdivision is undertaken in accordance with these structure plans. in accordance with the Structure Plan for the area. DEV2-02 Infrastructure is provided in an integrated, The objectives will sustain the potential of physical resources for current and future efficient and comprehensive manner to meet the generations, and maintains and enhances amenity values and quality of the environment. planned needs of the Development Area. In light of the above, the proposed objectives are considered appropriate in achieving the purpose of the RMA in relation to supplying land for future urban growth and managing DEV2-03 Activities within and adjacent to the the development of and activities and development within the Future Urban Zone. Development Area do not compromise the ability to develop the area in accordance with the Carrington Structure Plan. Summary The proposed objectives will achieve the purpose of the RMA as they are a clear statement of intent that defines the expectations for urban growth within the District. It provides certainty as to the outcomes that are considered to be appropriate under the District Plan provisions. The proposed objectives achieve the purpose of the RMA as they recognise the social and economic contribution that identifying and providing land for future urban growth provides for the district. The proposed objectives for FUZ and Development Areas also provide increased certainty regarding the clear outcomes anticipated under the Proposed District Plan provisions and align with contemporary planning practice applied around the country and the National Planning Standards 2019.

Evaluation of Alternative Options Appropriateness to achieve the purpose of the Act

Do nothing This option would hinder decision makers when assessing resource consent applications as they would have little guidance on what outcomes are expected. It would also fail to properly provide land for growth and development of the district in a cohesive manner and would not allow the growth needs of the community to be met. This option would not deliver on the requirements of section 7 a, d, e and f of the RMA. This approach could adversely affect the environment and is unlikely to achieve the purpose of the RMA. Summary It is not recommended that this option is proceeded with.

10 Evaluation of Options to Achieve the Objectives

Options to achieve the Benefits Costs Efficiency and Risks of acting/not District Plan objectives Effectiveness acting relating to (urban growth) Option A: Proposed  Provides zoned, serviced  Slight change in focus This approach is effective The risk of acting on these approach and feasible land from the Operative and efficient as it would provisions is that whilst the available to meet the District Plan with new allow urban growth within Council has identified the  Urban growth specific New Plymouth Districts structure plan areas and the New Plymouth District key resource management chapter in District Plan. growth demands in the Future Urban Zone to meet the district’s issues and considers that  Specific objectives and short – long term. areas identified. increasing demand. this approach is most policies to require land  Gives effect to the  Stronger emphasis on This approach addresses effective to achieve the to be structure planed ‘sustainable urban subdivision and current issues, in particular objective, it has received prior to rezoning and development’ policies of development needing to providing zoned, serviced limited feedback from the or subdivision and the RPS. occur in a and feasible land available community (including local development occurring. engineers or surveyors) on  Gives effect to short to comprehensive planned for residential development  Rules to ensure this matter. long-term requirements approach, reduces in the immediate future. subdivision and under the NPS-UDC. flexibility for developers. Ensuring any out of zone Not acting may mean that development occurs in subdivision and the current implementation accordance with a  Promotes a structure development requires a issues with the Operative Structure Plan or does plan as an effective tool structure plan to ensure a Plan approach continue not affect the ability to for rezoning of an area. comprehensive planned and incrementally result in develop and urban  Certainty for developers either the ability to achieve

Options to achieve the Benefits Costs Efficiency and Risks of acting/not District Plan objectives Effectiveness acting relating to (urban growth) growth area in the  Better quality subdivision approach will avoid ad hoc the requirements of the future. design, connectivity, and development. NPS-UDC or a loss of  Identification and associated This option is considered to amenity values and quality rezoning of three neighbourhood and be the most efficient and of the environment. southern growth areas community effective to achieve the Overall, it is considered for residential environments which objectives. that there is sufficient development through results in economic and information to act, and comprehensive social benefits for new that risks of not acting are structure plans to meet residents. outweighed by the benefits New Plymouth’s short- of acting. term growth demand.  Rezoning and identification of urban growth areas in the southern and western pockets of the New Plymouth City.  Retention of existing structure plan and urban growth areas in the Operative District Plan to ensure the District’s short – long term growth demand is met. Option B: Status quo  Plan users and  Continue to not provide Monitoring shows that the The risk of acting on these approach landowners are familiar adequate zoned, existing approach is not status quo provisions is  Retention of Operative with current provisions, serviced and feasible effectively or efficiently that: Plan approach set out in resulting in reduced land available to meet achieving the purpose of  The current policy Section of this report. costs in understanding the New Plymouth’s the RMA. framework lacks detail and complying with the growth demand. and specific direction on

Options to achieve the Benefits Costs Efficiency and Risks of acting/not District Plan objectives Effectiveness acting relating to (urban growth)  Retain existing structure Urban Growth Area  Cannot give effect to Due to limited policy management of urban plan and future urban section of the plan. the NPS – UDC. guidance and lack of growth; development areas in the  Continue to see ad hoc zoned, serviced and  The availability of zoned Operative District Plan. subdivision and feasible land available the land does not meet the development occurring District Plan fails to meet urban growth demands out of zone. the growth demands of the of the District; District.  Not achieving connected  The rules are not planned subdivision and Further, the lack of effectively being development that direction in the plan leads implemented, are not protects site specific to inconsistent decision- well-integrated with characteristics. making and lack of control design and infrastructure over certain activities.  Due to all of the above guidance, and/or factors, there is greater Therefore, this option is Council’s ability to potential for a reduction not considered to be the manage certain effects is in amenity values and most efficient, effective or limited. quality of the appropriate option to The ineffectiveness of the environment. achieve the objectives. current planning framework is demonstrated in Section 3.2 of this report, and is no longer considered to be ‘best practice’. It is considered that the risk of acting on these provisions outweighs the risk of not acting. There is sufficient information not to act on this approach. Option C: Proceed with  Developers can continue  Continue to see ad hoc Monitoring shows that the The risk of acting on these growth areas and new to undertake subdivision subdivision and existing approach is not proposed provisions is zoned areas without a and development in a effectively or efficiently that:

Options to achieve the Benefits Costs Efficiency and Risks of acting/not District Plan objectives Effectiveness acting relating to (urban growth) structure plan manner similar to the development occurring achieving the purpose of  The proposal would lead requirement Operative District Plan out of zone. the RMA. Not continuing to to adverse effects on the  Urban growth specific approach.  Not achieving connected use structure plans as a environment; chapter in District Plan.  Developers may achieve planned subdivision and management tool for urban  The proposal would growth areas will not  Specific objectives and greater yield where no development that create ad hoc achieve the purpose of the policies to manage structure plan is protects site specific subdivision that is not RMA and lead to potential urban growth but no required. characteristics. consistent with best greater adverse effects requirement to  Gives effect to the  Potential loss of site practice planning. than the existing approach. structure plan areas. ‘sustainable urban specific areas of It is considered that the Therefore, this option is  No specific rules development’ policies of cultural, ecological or risk of acting on these not considered to be the managing the growth the RPS. recreational importance. provisions outweighs the most efficient, effective or risk of not acting. There is of large urban growth  Gives effect to short to  Lack of integrated appropriate option to sufficient information not to areas rezoned for long-term requirements holistic planning. achieve the objectives. act on this approach. development. under the NPS-UDC.  Due to the above factors, there is greater potential for a reduction in amenity values and quality of the environment. Option D: Proceed with  Provides zoned land  The Council’s This proposed approach The risk of acting on these rezoning growth area in available to meet the infrastructure in the shows that at the current proposed provisions is line with those areas New Plymouth Districts immediate future could time the Councils that: identified in the growth demands in the not support additional infrastructure could not  The proposal would lead Framework for Growth. short – long term. subdivision and support development in to the inability to development growth in these proposed locations.  Urban growth specific  Certainty for developers subdivide and develop those areas proposed Therefore, the rezoning of chapter in District Plan. in the growth direction zoned land in the the Council are heading e.g. Smart Road and these areas is not absence of the required  Specific objectives and down. Frankley Cowling Area. effectively or efficiently infrastructure; policies to require land achieving the purpose of  These areas are large  The proposal continue to to be structure planed the RMA and this option is areas and would open create a urban growth prior to rezoning and or not considered to be the

Options to achieve the Benefits Costs Efficiency and Risks of acting/not District Plan objectives Effectiveness acting relating to (urban growth) subdivision and up large areas of zoned most efficient, effective or land supply issue with development occurring. land exceeding the appropriate option to the inability to provide growth demands of the achieve the objectives. zoned, serviced and  Rules to ensure District. feasible land to meet the subdivision and urban growth of the development occurs in  Cannot give effect to District. accordance with a the NP- UDC as the land Structure Plan or does cannot be appropriately It is considered that the not affect the ability to serviced. risk of acting on these develop and urban provisions outweighs the growth area in the risk of not acting. There is future. sufficient information not to act on this approach.  Identification and rezoning of growth areas. Quantification Section 32(2)(b) requires that if practicable the benefits and costs of a proposal are quantified.

Given the assessment of the scale and significance of the proposed changes above it is considered that quantifying costs and benefits would add significant time and cost to the s32 evaluation processes. The evaluation in this report identifies where there may be additional cost(s), however the exact quantification of the benefits and costs was not considered necessary, beneficial or practicable.

Summary The above table has demonstrated that Option A is the most appropriate method for ensuring that urban growth results in sufficient zoned, serviced and feasible land to meet the District’s urban growth needs, is an efficient use of land, achieves patterns of development that reflect good quality community environments, are compatible with the role, function and predominant character of the area, and minimises any adverse effects on the environment. Therefore, a revised approach as set out in Option A is proposed

11 Summary This evaluation has been undertaken in accordance with Section 32 of the Act in order to identify the need, benefits and costs and the appropriateness of the proposal having regard to its effectiveness and efficiency relative to other means in achieving the purpose of the RMA. The evaluation demonstrates that this proposal is the most appropriate option as:  The objective and policies provide direction and certainty to plan users on the outcomes expected for urban growth within the FUZ and Structure Plan Development Areas chapters. There is a focus on reinforcing the role and function and character of the FUZ to ensure that the zones integrity and character is maintained through development and that any activities that have the potential to impact this have their effects appropriately managed. Another focus is to ensure that development within a FUZ is avoided until the area is rezoned and a structure plan is in place. With structure plans there is a focus on ensuring that development and/or subdivision is undertaken in accordance with the structure plan development areas.  The proposed changes identify adequate land to meet the districts short, medium and long term growth demands. The focus here then switches to safeguarding this land for future urban growth.  The rule framework ensures activities occur in accordance with structure plans and that development and subdivision is managed in these areas.  The rule framework also ensures that appropriate discretion is placed on any out of zone activities within the FUZ to ensure that any reserve sensitivity matters are minimised and managed.  The policy framework also specifies the requirements of what a structure plan should address and include.

Overall, it is considered that the set of preferred provisions is the most appropriate given that the benefits outweigh the costs, and there are considerable efficiencies to be gained from adopting the preferred provisions. The risks of acting are also clearly identifiable and limited in their extent.

12 Appendices Appendix 1: Map showing the location of the Future Urban Development Overlay Areas Appendix 2: Future Urban Growth Areas Assessment