Before the Proposed Unitary Plan Independent Hearings Panel

Topic 016: Changes to Rural Urban Boundary (RUB) North/West

In the matter of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010

And

In the matter of the Proposed Auckland Unitary Plan

STATEMENT OF EVIDENCE of Brooke James Macdonald Dales on behalf of Timothy Hay (Submission #2849)

BJMD: Page 1 Statement of Evidence of Brooke James Macdonald Dales

1 Introduction

1.1 My name is Brooke Dales. I am a Director/Planning Consultant at DCS Limited (DCS), a private planning consultancy based in Auckland. I hold a Bachelor of Planning from the University of Auckland.

1.2 I have approximately twenty one years’ experience in the planning profession in , including ten years in local government and eleven years in the private sector. I have lived and worked in Auckland throughout this time and have worked extensively within the .

1.3 I have extensive experience as a planning professional over a wide range of work areas, including project planning and management, assessments of environmental effects, Resource Management Act statutory approvals, policy and plan development, community consultation and regulatory best practice, development and delivery.

1.4 I have been engaged by Timothy Hay to provide planning advice and assessment of the Proposed Auckland Unitary Plan Provision, in particular, as they relate to Mr Hay’s property at 23 Fosters Road, and in terms of My Hay’s submission #2849.

1.5 The Hay submission seeks that the western edge of the Kumeu-Huapai area RUB be moved as it relates to the Hay property to provide an appropriate buffer between rural and urban zones.

1.6 My evidence assesses the resource management issues in respect of the location of the Rural Urban Boundary (RUB) in the Kumeu-Huapai area in relation to the Hay property.

2 Code of Conduct

2.1 I have read the Code of Conduct for Expert Witnesses in the Environment Court Practice Note 2014. I agree to comply with this Code of Conduct. I have considered the relevant resource management matters required to be considered in relation to the location of the Rural Urban Boundary (RUB) in the Kumeu- Huapai area in relation to the Hay property. I confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that I express, and that this evidence is within my area of expertise.

3 Scope of Evidence

3.1 The scope of my evidence is limited to the Hay submission which seeks changes to the location of the Rural Urban Boundary (RUB) in the Kumeu-Huapai area in relation to the Hay property.

4 Hay Submission #2849

4.1 The Hay submission seeks that the western edge of the Kumeu-Huapai area RUB be moved as it relates to the Hay property to provide an appropriate buffer between rural and urban zones.

4.2 My evidence supports the Hay Submission and accordingly does not support the current (notified) location of the western edge of the Kumeu-Huapai area RUB for the reasons detailed in the Hay submission and in summary:

BJMD: Page 2 . The current boundary does not provide an appropriate buffer between rural and urban zones/uses.

. The current boundary does not appropriately relate to the physical characteristics of the local environment.

. The current boundary means that the Hay property will be “sandwiched” between a future urban zone to the east and Foster Road to the west with mixed rural zone further to the west.

5 Changes Sought

5.1 My evidence generally supports the recommended change to the western edge of the Kumeu-Huapai area RUB detailed in the Joint Statement of Evidence (Planning – West Auckland Fringe) as detailed in the map showing the proposed change in Appendix E of that evidence with a further change proposed in the marked plan shown as Annexure BJMD 1 to my evidence. This is proposed as the first preference.

5.2 In my opinion, this further amendment provides for a more appropriately sized and consistent buffer from the rural production zone fronting the western edge of Foster Road, transitioning to the Mixed Rural zone on the eastern edge of Foster Road to the ridgeline to the east (providing a clear topographical marker) with the future urban zone commencing further to the east. It is also recommended that RUB follow cadastral boundaries from the top of the ridge down the slope to the interface with SH16 rather than sharply turning west (as proposed the Council evidence) to link up with the Matua Road boundary.

5.3 I concur with the reasons for the boundary change detailed in the Council evidence and in my opinion these will continue to apply with following the further amendment suggested in my evidence. The reasons stated are:

. The ridgeline forms a more suitable defensible RUB than the floodplain that the notified RUB is based on;

. The reduced RUB provides a more effective rural buffer between Kumeu- Huapai and ;

. The reduced RUB better splits urban and rural uses into separate visual catchments and limits conflict between adjoining land uses;

. The reduced RUB will result in an area with slope stability issues being removed from within the RUB;

. The reduction of the RUB will not undermine the APDS and the 70:40 growth split under the compact city approach; and

. The reduced RUB performs best in the s32AA analysis in Attachment D (of the Council evidence).

5.4 The boundary change proposed by the Council evidence almost meets the relief sought in the Hay Submission by ensuring that the Hay property is comfortably contained within the Mixed Rural zone and not “sandwiched” between a future urban zone to the east and Foster Road to the west with mixed rural zone further to the west. The further amendment in the marked plan shown as Annexure BJMD 1 to my evidence will fully meet the relief sought in the Hay Submission.

BJMD: Page 3 5.5 My evidence further supports as a second preference, if the recommended change to the western edge of the Kumeu-Huapai area RUB detailed in the Auckland Council Joint Statement of Evidence (Planning – West Auckland Fringe) is not supported, that the western edge of the Kumeu-Huapai area RUB be moved further to the west to at least the edge of Foster Road so that the Hay property is wholly contained within the future urban area.

5.6 The two preferences and key considerations are demonstrated graphically by Mr Hay in Annexure BJMD 2 to my evidence.

BJMD: Page 4 ANNEXURE BJMD 1

Proposed Further Amendments to RUB

BJMD: Page 5

ANNEXURE BJMD 2

Two Preferences and Key Considerations

BJMD: Page 6 SUBMISSION

Foster Road November 2015

1 SITE AND LOCATION

CORNER OF SH16 AND FOSTER ROAD

Foster Road November 2015

2 SITE CURRENTLY BOUNDED BY TWO SIGNIFICANT ROADS - SH16 AND FOSTER ROAD - RURAL AMENITY OF SITE IS ACHIEVED BY ITS EASTERN INTERFACE

KEY SH16 and Foster Road

Foster Road Rural amenity of site is achieved by November 2015 its Eastern interface 3 WITH PROPOSED RUB TO EAST OF PROPERTY- SITE WILL BE ‘FENCED’ FROM ANY RURAL AMENITY

Foster Road November 2015

4 RUB NEEDS TO RESPOND TO THESE CONDITIONS

OPTION ONE: MOVE RUB FURTHER TO EAST TO ALLOW SUFFICIENT DIMENSION BETWEEN FOSTER ROAD / SH16 FOR RURAL AMENITY TO BE ACHIEVED

Foster Road November 2015

5 OPTION TWO - ALIGN RUB TO FOSTER ROAD

- FOSTER ROAD, AN ESTABLISHED BOUNDARY, BECOMES THE RUB BOUNDARY

- 23 FOSTER ROAD CAN BE ZONED FUTURE URBAN AND IS NOT CAUGHT IN NO MAN’S LAND

Foster Road November 2015

6 - OPTION TWO IS CONSISTANT WITH RUB BEING A ROAD BOUNDARY SOUTH OF SH16, AS INDICATED ABOVE.

Foster Road November 2015

7