In the matter of: Proposed Auckland Unitary Plan

To: The Auckland Unitary Plan Independent Hearings Panel

Under the Resource Management Act 1991

Submitters: Terra Nova Planning Ltd 6620 & FS689, Grant Oliff FS 146

TOPIC 011 RPS RURAL ISSUES

Statement of Primary Evidence of by Dr Mark Bellingham 8 December 2014

INTRODUCTION

1. My name is Robert Mark Bellingham. I am a Senior Planner and Senior Ecologist with Terra Nova Planning Ltd.

2. I hold a PhD in Planning from Auckland University and I am a full member of the Planning Institute. I have been a practicing planning and ecological consultant for over 25 years. I have also lectured in Environmental Planning at Auckland and Massey Universities. I have served on the Ministerial Advisory Committees for the Review of Protected Area Legislation (1989-90) Oceans Policy (2002-4), and as an Auckland Regional Councillor.

3. I have read and agree to comply with the Environment Court’s Expert Witness Code of Conduct (Consolidated Practice Note 2006). This evidence is within my area of expertise, except where I state that I am relying on some other evidence. I have not omitted to consider material facts known to me that might alter or detract from the opinions expressed.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 SUMMARY STATEMENT

4. The Terra Nova Planning & Grant Oliff support the Federated Farmers Of NZ Inc. submission point (p.4, 2.2.1, bullet point 1) and submission point 3.29, in relation to rural subdivision in section 8 RPS Rural of the PAUP.

5. Mr Oliff owns land at 486 Waitoki Road, Wainui, which is identified in the Rural Hamlet Policy Area of the Auckland District Plan: Rodney Section.

6. Rural land makes up about 90% of the terrestrial area of the region, but most of the high productivity soils are in the south of Auckland.

7. Urban expansion has been the main driver for the loss of elite and prime soils from production in Auckland and this is continuing in the PAUP with the zoning of these areas in urban zones.

8. The Auckland Plan only proposed restrictions on rural subdivision in the Islands, Rural Coastal and Rural Production Zones.

9. The PAUP RPS Objective 8.1.3 seeks to protect rural areas from “inappropriate subdivision, urban use and development” and that is supported.

10. RPS Objective 8.3.2 seeks to prevent rural lifestyle subdivision over all zones, and in doing so precluding rural hamlets and appropriate subdivision in rural areas, including rural villages and this is in conflict with Chapter 8 of the Auckland Plan and with the PAUP Rural Objectives: 8.1.3, 8.2.1 and 8.3.1, all of which contemplate appropriate rural subdivision rather than a prohibition.

11. The PAUP, Section 32 report, and appendices provide no basis for countryside living threatening biodiversity and a weak case for a threat to productive soils.

12. Countryside living subdivision has been a significant tool in conserving biodiversity in the in the past 30 years and primary production has been the main cause of biodiversity decline.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 DOES RURAL SUBDIVISION THREATEN RURAL PRODUCTIVITY AND BIODIVERSITY? 13. Rural land makes up about 90% of the terrestrial area of the region, but very little has high productivity and this is mainly in the south of the region (Manukau-Papakura– Franklin) (S.32 Report, 2.35 – Rural Subdivision 1.6.1 “Most of the most productive land (elite and prime land, LUC classes 1-3 incl.) in greater Auckland is located in one consolidated area in the south, and almost all the LUC class 1 land in greater Auckland (and most of the LUC class 1 land in New Zealand) is located there.”

14. Council’s s.32 report, Appendix 3.35.4 (Rural Production Comparative Analysis Greenfield Study Areas – by Primary Focus) also shows that the more productive soils in south Auckland have 6 times the economic turnover and employment capacity of less productive soils in the north of the region.

15. Urban sprawl is the main threat to Auckland’s primary production capacity and this is well documented in Dr Curren-Cournane’s evidence and her technical report ( Technical Report 2013/0501).

16. Consistent with this, rural subdivision and consents for dwellings are concentrated around Pukekohe, Waiuku, Beachlands-Maraetai in the south, and Warkworth-, Omaha, Waimauku, Huapai-Kumeu, Riverhead, Dairy Flat and Paremoremo in the north (Attachment 1 - Figure 9.2 Auckland Plan 2012). Many of these areas are now in the new Future Urban Zones or urban zones (at the edge of the MUL) in the PAUP.

17. I consider that the change in planning approach of identifying a 30 year window of future urban development will address most of this peri-urban development for quite

1 1 Curran-Cournane, F Vaughan, M Memon A and Fredrickson C (2013) Auckland’s elite and prime land: similar messages and continued trade-offs 54 years later. RIMU, Auckland Council. Technical report TR2013/050

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 some time. Much of the “urban creep” into rural areas in the Auckland region over the past decade may have been driven by the MUL.

18. On the issue of rural subdivision for countryside living threatening biodiversity; the only long-term research into biodiversity loss in rural areas in the Auckland Region has been my PhD research. I measured the change in indigenous vegetation at 780 forest areas in Rodney and I found that agriculture was consistently the major contributor to biodiversity loss over a 15 year period. Agriculture accounted for clearance of all or part of 239 (15%) of these forest areas, or 78% of the indigenous forest clearance recorded. From my observations this has continued but at a slower rate since the early 2000s.

16% 15.03%

12%

98 -

8% cleared 1983 cleared

4% 3.28% Indigenous vegetation Indigenous

0.83% 0.13% 0.07% 0.01% 0% pastoral plantation urban firewood lot sewage golf course farming forestry plant

Land use after forest clearance (n=780)

19. In contrast, countryside living in the former Rodney District and rural Waitakere City has been a significant contributor to biodiversity conservation and restoration of a significant area of indigenous forests and wetlands. This active conservation contribution by private landowners and incentivised by council, has balanced some of

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 the biodiversity losses from primary production and urban expansion in these districts. In Waitakere this has been through Reserve Act covenants and consent conditions.

20. The matters raised by Dr Seabrook-Davison in his evidence are almost entirely matters of a failure by councils to properly monitor the outcomes of their district plans, and I documented these council failures in Rodney and Waitakere in my PhD thesis. I did not find a failure with the plan mechanisms.

21. Dr Seabrook-Davison’s evidence refers to a report he prepared looking at 31 covenants in Puhoi and the level of covenant compliance2. I consider that his study is flawed on a number of grounds; firstly he sampled only 31 covenants of a total of 4,161 in Rodney (and another 1,444 similar covenants in Franklin) in one locality, rather than a random selection across the district or region. Secondly the higher non-compliance in the later Rodney covenants appears to relate to the council possibly granting consent for non- qualifying areas and a significant reduction in covenant monitoring in the past decade. In the 1990’s and early 2000’s a part-time officer inspected every covenant every three years along with any compliance complaints. I consider that this level of landowner engagement by the council led to the high level of covenant compliance that I am familiar with over most of the district.

22. The recommendations in Dr Seabrook-Davison’s report were to improve council processes and have a more collaborative process between council and landowners, and I agree with those. The issues identified in evidence (5.11-24) are all matters relating to the ability or inability of council to administer and resource the district plan. Dr Seabrook-Davison’s para. 5.17 about staff being over-whelmed by the uptake of covenants demonstrates that rural subdivision incentives for protecting biodiversity have been successful and have been an important tool for slowing biodiversity decline in Rodney.

2 M Seabrook-Davison 2011 Review of regulatory incentives for waivers on restrictions of rural land subdivision. Draft 4, Auckland Council.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014

23. The wide-scale application of these covenants (Attachment 2 - Figure I Seabrook- Davison 2011) shows their importance as a biodiversity conservation tool as there is very little biodiversity protected on Crown reserves or regional parks across Rodney. The contrast can be seen in Kaipara District which has had until recently rather weak regulatory controls and no incentive programmes for biodiversity conservation; there all of the previous district plan SNAs has been cleared to some extent from 1997-2011 and many had completely disappeared.

24. I consider the objectives and policies in B.8.3 will have no effect on the administrative and resourcing matters raised by Dr Seabrook-Davison in his evidence and his 2011 review of biodiversity incentives programmes in Auckland region. I consider that his conclusion 7.2 is wrong, as RPS objectives and policies are far removed from the implementation and administration of district rules.

25. The Council is proposing through the PAUP minimal incentives for biodiversity conservation for landowners and a strict but generally unenforceable (in rural areas) rules-driven regime. Landowners with large land holdings with significant biodiversity will be particularly penalised. Zakara Investments on Kawau Island for instance has the potential for 45 transferrable titles under the Operative Auckland District Plan: Rodney Section, but only 4 titles under PAUP. This situation is not atypical.

THE PROPOSED AUCKLAND PLAN PROVISONS

26. The Auckland Plan forms the strategic direction for Auckland for the next 50 years. The preeminent place of the Auckland Plan in the Council’s planning hierarchy is described in Part A:3.1 of the PAUP. This section of the PAUP states: “The RPS provisions in the Unitary Plan identifies and addresses eight issues of regional significance. These issues also reflect and implement Auckland Plan outcomes and priorities …”.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 27. The Auckland Plan’s strategic direction for Rural Auckland (Chapter 9, Strategic Direction 9) is to keep it productive, protected and environmentally sound. The two targets for this strategic direction are to limit rural subdivision in the Rural Production, Rural Coastal and Islands Zones to less than 10% between 2013-2020, and to increase the value from rural sectors by 50% by 2040. But the plan does not seek to prohibit rural subdivision in these zones. Nor does it place any specific limitations on rural subdivision growth in the Mixed Rural, Rural Conservation and Countryside Living zones, apart from those relating to versatile soils, reverse sensitivity and natural environment matters.

28. In defining this “Sustainable Balance between Environmental Protection, Rural Production and Activities Connected to the Rural Environment” (Priority 1, Ch. 9), some level of rural subdivision is clearly contemplated in all rural zones, but specifically less in the Rural Production, Rural Coastal and Islands Zones. For instance: 538_ This requires a balance between maintaining the distinct character of landscapes and settlements, while providing and increasing the services that rural and urban communities depend on. In practice, this sustainable balance means that we will:

 protect some areas from any future development  protect fertile soils from activities that reduce their productive potential  encourage and support productive enterprises and those that fit well in a rural context (not necessarily dependent on fertile soils)  treat cultural heritage and iconic features with the respect they deserve  encourage growth and urban development to be focused in satellite towns and rural and coastal towns, and discourage growth in other rural areas.

29. The only prohibitive directive in the Auckland Plan is: “avoid urbanisation of highly productive farmland and versatile soils where possible, and maintain adequate

separation between incompatible land uses” (Directive 9.5).

30. The pertinent issues of regional significance in the Auckland Plan are only directly addressed in the Rural issues (B.1.7), these are:

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 Rural Production To support a compact city form, and retain the values of our rural areas, we need to distinguish between activities that must have a rural location, those that will have a negative effect on rural values and those with more location flexibility. Rural Subdivision Further rural subdivision can result in loss of rural character and increased demand for new or upgraded physical and social infrastructure services such as stormwater, wastewater or public transport. This may lead to ad-hoc and unintended growth of new rural settlements. These issues in the Auckland Plan do not appear to contemplate a prohibition on rural or rural lifestyle subdivision, rather the place, nature and scale of appropriate rural subdivision needs to be identified.

31. Nowhere does the Auckland Plan propose a prohibition on rural subdivision across all of the rural zones of the nature of the PAUP RPS Objective 8.3.2. In fact, in Para.552 the Auckland Plan provides for small-scale growth of villages, where this does not necessitate additional infrastructure; “Some limited and scale-appropriate growth will, over time, also occur in smaller rural and coastal villages where it benefits those communities.”

32. The Auckland Plan contemplates getting the best value from infrastructure, but a significant number of rural villages (identified in the plan) are unserviced and have no public transport. In my opinion as long as growth is constrained, provides for on-site water collection and waste treatment, and avoids as far as possible highly productive farmland and significant areas of biodiversity, then it could be consistent with the low- growth rural directive of the plan.

33. The Auckland Plan also contemplates new rural settlement proposals, subject to spatial or structure planning (Directive 9.5).

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 THE MARCH 2013 DRAFT AUCKLAND UNITARY PLAN PROVISONS 34. These directives and priorities from the Auckland Plan were then translated into the March 2013 Draft Unitary Plan, where the Rural Objectives at that time were: Objectives 1. Rural areas are a significant contributor to the wider economic productivity of Auckland.

2. Rural communities undertake rural production and other activities that support them while rural character is maintained.

3. Auckland’s rural areas outside the RUB, and rural and coastal towns and villages, are protected from inappropriate subdivision, urban use and development.

COUNCIL CHANGES TO THE MARCH 2013 DRAFT AUCKLAND UNITARY PLAN PROVISONS

35. Pages 54-56 of the Section 32 report outline the process for reviewing the draft AUP and incorporating appropriate feedback.

36. At the 3 July 2013 workshop of the Auckland Plan Committee the matter of rural subdivision as a prohibited activity was on the agenda points (Item 1, bullet point 5) “Change activity status of rural subdivision from prohibited to non-complying or discretionary”. But rural subdivision was not prohibited in the legacy plans or the March 2013 draft of the AUP and it is unclear how this agenda point eventuated. The interim directions from the committee made no reference to rural subdivision being prevented or to changing the activity status to a prohibited activity.

37. The directives from that workshop addressed situations where rural subdivision would be allowed, subject to various activity statuses and conditions. Council then ratified these directives at its meeting of 28 July 2013, but there is no directive approved in the minutes of that meeting to prevent or prohibit rural subdivision.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 PROPOSED AUCKLAND UNITARY PLAN September 2013

38. My examination of the documents show that the PAUP has changed significantly from the draft Unitary Plan, in that it has introduced a significant number of restrictions and prohibitions on the development of rural land. This appears to be beyond what was contemplated in the Auckland Plan and from the public record, beyond what the Auckland Plan Committee agreed to in its deliberations on the submissions to the Draft UP from the public, local boards and Council staff.

39. This has been further complicated by the lack of clarity between rural-residential growth and urbanisation in the PAUP and the RPS sections 2 & 8. The type of rural growth contemplated in Terra Nova’s and Mr Oliff’s submissions is rural-residential and small non-serviced rural villages that cluster residences to provide a more efficient use of rural land (including that in the Countryside Living Zone), while minimising effects on productivity, rural character and landscape. This concept within the legacy plans in Rodney, Manukau and Franklin appears to have escaped the purview of the PAUP.

40. In an attempt to understand the logic behind the PAUP RPS policies I compared the Auckland Plan Unserviced Villages from the rural villages classification (Auckland Plan Table 9.1) against those identified in the PAUP, as these are where my clients’ interests lie. I found that fourteen unserviced rural villages (from the Auckland Plan) are in various rural zones, including the five unserviced coastal villages in the Waitakere Ranges rural conservation zone, and not in the Rural and Coastal Villages zone.. Another seven unserviced rural villages have other rural zonings (Attachment 3).

41. I can only conclude that rural-residential living in clustered rural hamlets or unserviced rural villages was overlooked in the development of the PAUP. While there has been considerable attention focused on urban intensification in the MUL, at one end of the urban-rural planning spectrum and high intensity rural productivity at the other end, planning for small rural communities appears to have been forgotten. This is

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 accentuated by the fact that although the RPS policies appear to provide for growth of rural villages, but those in the north of the region (where two-thirds are located), have almost no growth capacity provided in the PAUP:

20 18 16 14 12 10 Total 8 Growth capacity 6 4 2 0 Villages North Villages South

Growth Capacity in Unserviced Villages (north & south of metropolitan Auckland)

42. In my view RPS Objective 8.3.2 and the associated policies in B.8.3 appear to have been crafted without reference to the Auckland Plan directives and priorities. It appears to be entirely out of context and it confuses and perverts the intent of the PAUP and the Auckland Plan as it introduces significant conflicts with other RPS Objectives and Policies, and Regional and District Objectives, Policies and Rules.

SECTION 32 REPORT TO THE SEPTEMBER 2013 PROPOSED AUCKLAND UNITARY PLAN

43. I have examined the Section 32 report and the relevant appendices are within the scope of my expertise. In my experience, most of the justification for a significant change of policy in the PAUP from the legacy plans relating to rural land use and rural subdivision are a product of poor implementation of legacy plan provisions, a general absence of plan and consent monitoring, and some poorly crafted legacy district plans

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 provisions. I consider that the pairing of discretionary rural subdivision with biodiversity protection in Rodney District has been reasonably successful over the 30 years it has been in place, and particularly with the plan changes that came through with the Rodney DP 2002.

44. I have reviewed the information in the appendices that has been used to develop this part of the S.32 report. It is does support the need to provide protection for the region’s more productive land but it does not provide any causative link between the loss of rural productivity or highly productive rural land with rural subdivision practices in the Auckland region.

45. The change to a general prohibition on rural subdivision and minimal incentives for biodiversity and landscape conservation appear to be a change in philosophical approach, rather than one supported by the evidence in the S.32 Report and any rigorous analysis of the changes that have come from the provisions in the Rodney and Franklin district plans, which cover about 70% of rural Auckland.

FEDERATED FARMERS’ SUBMISSION POINT TO THE PAUP

46. The Federated Farmers’ submission proposes that the provisions for rural subdivision are too restrictive (p.4, 2.2.1, bullet point 1) and specifically in 3.29, pp. 24-26 that the PAUP should better provide for rural subdivision. Section 3.29 also identifies that the PAUP RPS effectively prohibits rural subdivision, although allowing for some rural subdivision at the same time.

FURTHER MATTERS IN THE PAUP RPS 8 RURAL ENVIRONMENT

47. The matter of controls on rural subdivision in the RPS is in sections 8.1 and 8.3. I will address those parts that are affected.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 Preventing rural subdivision

48. There is an assumption in the PAUP that rural subdivision is and has had adverse effects on rural productivity, and the protection of natural values.

49. The Introduction to Section 8 and the explanations frame the context of sections 8.1 – 8.3 and they are reasonably consistent with the Council’s strategic direction for Rural land (Auckland Plan) except for the following matters;

Preventing growth of rural settlements

a. The introduction to 8.1 (Para. 1) seeks to redefine rural land to mean zoned outside the RUB or the Coastal and Rural Village and Town Zone, yet a number of rural villages are in Rural Zones (Attachment 3). In my view this assumes that rural villages and smaller towns are nodes of “urban expansion and non-rural activities” rather than an essential and predominant part of the economic and social under- pinning of rural production and rural communities.

b. An examination of recent Special Housing Areas shows that this Council/Government initiative has placed new urban expansion on prime and elite land and this is consistent with the history of urban expansion in Auckland. This has been documented by Council staff3 where in the past decade 70-80% of urban expansion has been on Auckland’s most versatile soils. From my examination of the Auckland Plan village locations, there is very little prime and elite land that might be affected by the small-scale growth that is occurring around the region’s smaller rural villages.

c. At the other end of the scale, Section 3 of the RPS – Urban Growth focuses on a quality compact urban form and is framed around providing efficient and

3 Curran-Cournane, F Vaughan, M Memon A and Fredrickson C (2013) Auckland’s elite and prime land: similar messages and continued trade-offs 54 years later. RIMU, Auckland Council. Technical report TR2013/050

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 affordable infrastructure and public transport to metropolitan Auckland and the larger towns and serviced villages. I support that approach, but the scale and nature of urban growth in those locations is completely different for instance, to the 21 house rural hamlet at Bird’s Beach in the central Kaipara (40km from and 107km from here). A one-size fits all does not work and I consider that a sound planning approach needs to plan for many of the small serviced and unserviced rural villages as part of rural Auckland, rather than a tenuous extension of metropolitan Auckland.

d. My contention that these small unserviced settlements in rural areas have fallen through the cracks is clearly illustrated in the Urban Growth part of the RPS wherein Objective 2.5.2 states:

Growth within un-serviced villages is contained within their urban zones existing at September 2013.

But many rural villages have no growth capacity and a number have no urban zone (as they are in rural zones).

e. The PAUP has not taken into account non-urban zoned rural villages or what defines a rural settlement or a village? This is fundamental to planning for rural villages or hamlets, and in the long-term are sustaining rural communities that underpin the rural economy and rural environment.

f. The deletion of this introductory sentence (Rural land is defined as land outside the RUB and the limits to the rural and coastal towns and villages.) would provide a more consistent context to section 8 of the RPS and the three parts of section 8.

Rural-residential growth adversely effecting rural production

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 g. The Explanation and Reasons sections draws a link between countryside living and loss of rural production. These seem to be matters of urban (or rural) myth, as this is not supported with any evidence in the Council’s Section 32 report to the PAUP.

h. From my experience with rural landowners, including many of Terra Nova’s clients, those with productive rural enterprises in countryside living areas and close to urban areas, usually subdivide in such a way to preserve their ability to continue using the best soils and sites. We have seen this along Rosebank Rd, Te Atatu, Henderson, Lincoln Rd, Mangere and many other locations where glasshouses, vineyards, vegetable growing and orchards continue in urbanised areas. These rural remnants are finally squeezed out by high rates as land values climb, not any incentives or pressures from district planning. The objectives and policies in the RPS provide a sufficient framework for minimising the loss of significant productive areas from rural-residential uses.

CONCLUSION

50. The general prohibitions on rural subdivision including spread out countryside living, clustered rural hamlets or unserviced rural villages in the Proposed Auckland Unitary Plan are unnecessary, so long as the objectives and policies for protecting production land and biodiversity are appropriate.

51. I wish to draw the Panel’s attention to Attachment 5 (final 2 pages) of the Mediation Joint Statement for Topic 011. I consider this statement is consistent with the Council’s strategic direction in The Auckland Plan, rather than the PAUP.

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham DECEMBER 2014 ATTACHMENT 1

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham OCTOBER 2014 ATTACHMENT 2

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham OCTOBER 2014 ATTACHMENT 3

Unserviced villages Unserviced villages in the Auckland Plan PAUP Zone in the Auckland Plan PAUP Zone Ardmore Airport Whangateau Coastal & Rural Village Awhitu Central Coastal & Rural Village Coatesville Countryside Living Baddeleys Beach Coastal & Rural Village Dairy Flat Future Urban Big Bay Coastal & Rural Village Brookby Mixed rural Buckletons Bay Coastal & Rural Village Taupaki Mixed rural Campbells Beach Coastal & Rural Village Pollock Rural coastal Grahams Beach Coastal & Rural Village Cornwallis Rural Conservation Hunua Coastal & Rural Village Huia Rural Conservation Kaipara Flats Coastal & Rural Village Parau Rural Conservation Kaukapakapa Coastal & Rural Village Piha Rural Conservation Leigh Coastal & Rural Village Bethells (Te Henga)* Rural Conservation Matakawau Coastal & Rural Village Ararimu Rural production Muriwai Coastal & Rural Village Makarau Rural production Orere Point Coastal & Rural Village Tomarata Rural production Orua Bay Coastal & Rural Village Wainui Rural production Pakiri Coastal & Rural Village Clevedon Single House Paremoremo Coastal & Rural Village Whitford Single House Port Albert Coastal & Rural Village Claris Hauraki Gulf Islands Puhoi Coastal & Rural Village Medlands Omiha Hauraki Gulf Islands Sandspit Coastal & Rural Village Onetangi Hauraki Gulf Islands Scotts Landing Coastal & Rural Village Orapiu Hauraki Gulf Islands Shelly Beach Coastal & Rural Village Ostend Hauraki Gulf Islands Tapora Coastal & Rural Village Palm Beach Hauraki Gulf Islands Te Hana Coastal & Rural Village Port Fitzroy Hauraki Gulf Islands Te Toro Coastal & Rural Village Surfdale Hauraki Gulf Islands Waiau Pa Coastal & Rural Village Te Hihi Hauraki Gulf Islands Wainui Coastal & Rural Village Tryphena Hauraki Gulf Islands Waitakere Coastal & Rural Village Whangaparapara Hauraki Gulf Islands

TOPIC 011 RPS RURAL EVIDENCE OF Dr Mark Bellingham OCTOBER 2014