Kohi Neighbours Incorporated
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Comment on Kohimarama Comprehensive Care Retirement Village Application name Kohimarama Comprehensive Care Retirement Village EPA reference FTC000024 Applicant Ryman Healthcare Limited Comments due by 6 April 2021 Prepared by: Kohi Neighbours Incorporated 6 April 2021 1 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 Abstract The Kohimarama Comprehensive Care Retirement Village is a Referred Project under the COVID-19 Recovery (Fast-track Consenting) Act 2020. The applicant is Ryman Healthcare. This submission is in response to an Invitation to Comment received by Kohi Neighbours Incorporated from the Chair of the Expert Consent Panel for the Environmental Protection Authority (EPA). Submitted this 6th day of April, 2021 on behalf of Kohi Neighbours Incorporated _______________________ _________________________ Jeff Robertson Nik Nigro Chair Deputy Chair Kohi Neighbours Incorporated [email protected] 2 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 Contents: 1. Introduction 1.1. Kohi Neighbours Incorporated 1.2. Scope of Submission 1.3. Engaged Experts 1.4. Executive Summary 2. History, Documentation and Process 2.1. Introduction 2.2. History of the Site 2.3. CANENZ 2.4. Decision on AUP Rezoning Request 2.5. Limited Notification and Consultation 2.6. Errors in the Application 2.7. Omissions in the Application 2.8. Fast Track Consenting Process 3. Legal Submission 4. Comment on Urban Design, Planning and Landscape 4.1. Introduction 4.2. Urban Design and Landscape Assessment 4.3. Planning Report 4.4. Riparian Yard Controls 5. Comment on Architectural Design and Layout 5.1. Introduction 5.2. Site Layout and Circulation 5.3. Architectural Design 5.4. Doing it Right 3 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 6. Comment on Traffic and Parking 6.1. Introduction 6.2. Restrictions for School Peak Hours 6.3. Kohimarama Road Entrance – No Right Turn Out 6.4. Kohimarama Road Entrance – No Right Turn In 6.5. John Rymer Place Traffic Lights – Right Turn Arrow 6.6. Parking Restrictions – Offsite 6.7. Parking Management – Onsite 6.8. Access Design 6.9. Other Traffic Restrictions 7. Comment on Environment and Ecology 7.1. Introductions 7.2. Removal of Vegetation and Replanting 7.3. Light Pollution 7.4. Noise 7.5. Bird Habitat 8. Comment on Construction Activities 8.1. Introduction 8.2. Noise Standard 8.3. Work Hours and Restrictions 8.4. Noise Exceedances 8.5. Acoustic Barriers 8.6. Vibration 8.7. Noise Generating Equipment 8.8. Noise and Vibration Monitoring 8.9. Earthworks 8.10. Planting 4 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 8.11. Dust 8.12. Light Pollution 8.13. Containment of Activities 8.14. Consultation 9. Comment on Construction Traffic 9.1. Introduction 9.2. General Access Restrictions 9.3. Site Access for Worker Vehicles 9.4. Site Access for Standard Trucks 9.5. Site Access for Heavy Vehicles 9.6. Site Access for Concrete Trucks 9.7. Oversized Loads 9.8. Staging of Trucks 9.9. Temporary Traffic Management 9.10. Parking Restrictions – Offsite 9.11. Parking Management 9.12. Allum Street 9.13. Track-out of Dust and Dirt 9.14. Condition Assessment of Roads 9.15. Enforcement 9.16. Partial Occupancy During Construction 10. Summary and Conclusion 10.1. Summary 10.2. Conclusion 5 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 Appendices A. Kohi Neighbours Incorporated Member Addresses B. Site Concept Plan 2008 C. Legal Submission on Behalf of Auckland Council – Rezoning, 12 February 2016 (part only) D. S92 Further Information Request, Auckland Council, 24 November 2020 E. Legal Submissions by MinterEllisonRuddWatts F. Urban Design and Landscape Architecture Assessment by Richard Reid & Associates G. Planning Report by Civitas Planning Consultants H. Environmental Gerontology Assessment – Lori Nielson I. Eastern Bays Songbird Project Submission J. Submission from St Thomas's School Board of Trustees 6 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 1. Introduction 1.1 Kohi Neighbours Incorporated Kohi Neighbours group was established in September 2020 following publication of the details of Ryman Healthcare's proposed development for a Comprehensive Retirement Village at 223 Kohimarama Road and 7 John Rymer Place. It began as a loose-knit group of local residents desperate to have a forum to discuss their concerns about the development, and eager to engage with the community to find common ground around the issues that the development presented. Auckland Council called for submissions under a Limited Notification process, with submissions due 15 October 2020. Following this, and with a hearing scheduled for 15-18 December 2020, it was decided by the resident group to pool resources and work together to obtain professional representation for the hearing. Kohi Neighbours became an Incorporated Society on 11 December 2020 (NZ Incorporated Societies Number 50055190). The primary purpose of the Society as described in its Constitution is to: Represent neighbours and community members impacted by the proposed Ryman Healthcare development of 223 Kohimarama Road and 7 John Rymer Place. Kohi Neighbours Incorporated (KNI) has maintained close links with the Mission Bay Kohimarama Residents Association (MBKRA) and has received support and advice from the Association. Due to the lead taken by KNI within the community, MBKRA has opted to play a supporting role whilst maintaining an interest in the process. Today, KNI has members from more than 60 addresses in the immediate community, and has received financial support from over 35 separate households. A list of member addresses is included in Appendix A. Our members reside both within the "invited" catchment of addresses and also in the surrounding neighbourhood. Our membership includes lawyers, architects, construction professionals, gerontologists, engineers, parents, grandparents, and other people passionate about the outcomes of the Ryman application. This submission has been created with their input. 7 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 1.2 Scope of Submission KNI has undertaken significant outreach within the community, via emails, letterbox drops, public meetings, presentations and discussions, in order to share information and understand the key concerns from our community members. Our intent is not to speak for each of our members, but to represent a general view of the issues. We have encouraged all persons invited by the EPA Expert Consenting Panel to make individual submissions based on their particular assessment of issues specific to their location. We therefore do not provide comment on every aspect of the development. This is not to say we do not put weight on the importance of these issues. We are satisfied that the following areas either require a high level of technical expertise and that the process of review and monitoring already underway is sufficient, or will be covered by residents in their individual submissions: Ground contamination Geotechnical Stormwater, sewer and utilities Water bore and groundwater extraction Stream ecology Archaeology The main focus of our community, and the topics we will provide comment on are in regards to the following: Urban Design, Planning and Landscape Architectural Design Traffic and Parking Environment and Ecology Construction Activities Construction Traffic 8 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 Under each of these topics we have provided analysis of the application and relevant reports, highlighting the issues important to the community. We have identified acceptable mitigations, or suggested conditions of consent should development proceed in any form. We wish to review and comment on any conditions being considered by the Panel if it intends to grant consent. 1.3 Engaged Experts The Kohi Neighbours Incorporated Society is represented by MinterEllisonRuddWatts, and has engaged the following experts: Richard Reid, Richard Reid & Associates – Urban Design, Landscape and Architecture; and Iain McManus, Civitas – Planning We have also incorporated an Environmental Gerontology assessment by Lori Nielson, a specialist in this field and a resident of John Rymer Place. Refer to the listed appendices for submissions from these experts. 1.4 Executive Summary Kohi Neighbours Incorporated has a strong member representation within the community surrounding the proposed Ryman development. The general comments and recommendations are: Development of the site is supported. A retirement village is an acceptable use of the site. The proposed buildings breach the Auckland Unitary Plan height standards to an unacceptable extent. The development results in a high level of visual dominance over many neighbouring properties, and at least a moderate impact on the wider community. The development does not suit the planned character of the area and presents as a wall of high-density development in a residential zone. Height reductions are required. 9 Kohi Neighbours Incorporated – EPA Submission – Ryman Kohimarama – 6 April 2021 The design of the development, including layout and form, impacts visual amenity for surrounding residents. Shadowing of adjacent properties, as well as shading within the site, is a major concern. Fundamental design issues prevent this from being a well-functioning environment for residents of the village. Amendments