BEFORE THE COUNCIL HEARINGS PANEL

IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER of a submission by Trices Road Rezoning Group on the Proposed Selwyn District Plan, Definitions Chapter (Submission no. 298)

STATEMENT OF EVIDENCE OF IVAN THOMSON ON BEHALF OF TRICES ROAD REZONING GROUP

6 August 2021

SUMMARY STATEMENT

1. The Trices Road Rezoning Group (TRRG) submissions 004 and 005 to the Proposed Selwyn District Plan (PSDP) seek amendments to the PSDP definitions of ‘Town Centre Network’ and ‘Activity Centre Network’. These two submission points complement submissions lodged on the Strategic Directions and Urban Growth Chapters and are aimed at recognising as a growing Township1.

2. TRRG is a group of six property owners with an interest in land adjoining the southwestern part of Prebbleton Township. TRRG has lodged several submissions on various parts of the PSDP as follows:

a) Rezoning of rural land at the southwestern part of Prebbleton to a combination of General Residential Zone (GRZ) and Large Lot Residential Zone (LLRZ); b) Inserting a new development plan (DEV-PR 3) to guide the implementation of the rezoning; c) Amending the Definitions of ‘Township Network’ and ‘Service Activity Centre’; d) Amending several policies in the Urban Growth (UG) chapter; and e) Amending the wording of Strategic Direction Objective SD-UFD-02.

3. TRRG have sought the addition (bold and underlined text) of the following amendments to the definitions of ‘Service Activity Centre’ and ‘Township Network’ as follows:

Service Activity Centres:

(b) ‘Provide goods and services to residents of the town as well as the wider rural area. However there will still be a reliance on the Key Activity Centres for larger scale businesses and more variety in retail and commercial activities. The Selwyn District has two Service Activity Centres being Prebbleton and West Melton. Prebbleton whilst a service activity centre is strategically located close to, and well connected to, Rolleston and Lincoln Key Activity Centres and the large and growing South West industrial and business areas. Given this strategic location it can support a wide range of commercial, industrial and residential activities, and a larger population (10 000 +) than anticipated for the secondary west Selwyn Key Activity Centres (i.e. Darfield and )’;

Township Network

(3) ‘Service Townships - West Melton, Prebbleton, Darfield and Leeston. Function is based on providing a high amenity residential environment and primary services to Rural Townships and surrounding rural area. Darfield and Leeston act as Key Activity Centres for the wider district Prebbleton whilst a service activity centre is strategically located close to, and well connected to, Rolleston and Lincoln Key Activity Centres and the large and growing South West Christchurch industrial and business areas. Given this strategic location it can support a wide range of commercial, industrial and residential activities, and a larger population (10 000 +) than anticipated for the secondary west Selwyn Key Activity Centres (i.e. Darfield and Leeston);’ and

I have attached the entire definitions in Appendix 1.

1 Refer to my evidence on the Proposed Selwyn District Plan, Strategic Directions Chapter

4. The reporting officer has recommended rejecting the TRRG submission. I consider there is merit in what TRRG is seeking to achieve and suggest an alternative approach that would provide the outcome sought in the submission. That approach is to recognise Prebbleton as a sub district centre in the Township Network alongside Lincoln, which will distinguish it from what I consider lower order Service Townships of Leeston, Darfield and West Melton.

5. TRRG lodged several further submissions supporting the Rolleston West Residential Ltd (RWRL), Iport, Rolleston Industrial Holdings Ltd (RIHL) and Hughes Developments to the extent these submissions were consistent with the relief sought by the TRRG and the interests of TRRG. These submitters sought the retention of Activity Centre and Town Centre Network definitions as notified. TRRG does not support this part of these submissions as it is not consistent with the relief they seek as outlined above. Also Jill Thomson (379.020) seeks amendments that could enable the Panel to make changes to or even revisit the Hierarchy. Such changes are also within the scope of the relief sought by TRRG which includes ‘Any consequential, further or alternative amendments to the PDP to be consistent with and give effect to the intent of this submission and the interests of the Submitter’.

INTRODUCTION

6. My full name is Ivan Thomson and I hold the position of Senior Planner with Aston Consultants. I have a Master's Degree in Urban and Regional Planning (M.Phil) from Reading University in England. I have 38 years’ post graduate experience in urban and regional planning, and I am a Fellow Member of the Planning Institute.

7. My experience includes 30 years at the Christchurch City Council including 12 years' involvement with preparation, hearings and appeals for the former Christchurch City Plan, four years leading an Area Plans programme, with the remainder of my time there being in a leadership/management role, including the Christchurch Replacement District Plan.

8. I confirm that I have read the Code of Conduct for Expert Witnesses contained in Part 7 of the Environment Court Practice Note 2014, and that I agree to comply with it. I also confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that express, and that this evidence is within my area of expertise, except where I state that I am relying on the evidence of another person.

9. The key documents I have used, or referred to, in forming my view while preparing this evidence are:

a) Selwyn 2031: District Development Strategy (2014). b) Proposed Selwyn District Plan Strategic Directions, Definitions and Urban Growth. c) Canterbury Regional Policy Statement (CRPS). d) National Policy Statement on Urban Development 2020 (NPS-UD). e) Quality Planning Website – Definitions. f) Selwyn 2031 – District Development Strategy. g) National Planning Standards.

PURPOSE AND SCOPE OF EVIDENCE

10. My evidence concerns the submission by the TRRG (no 0298) on the Definitions Chapter. I have tried to avoid unnecessarily repeating evidence previously presented as part of Strategic Directions and I refer the Panel to that evidence where appropriate. However, there is a clear relationship between the relief sought in that chapter which I will discuss below in paragraph 20.

11. The TRRG submission needs to be read as a whole and the changes sought to the objectives, policies and definitions are considered a prerequisite to securing the rezoning of the submitters’ land for residential purposes.

12. I have not considered the merits of the rezoning and have confined my evidence to whether the submissions on the Definitions have resource management merit in terms of higher-level documents and other relevant matters.

13. This evidence is concerned with ensuring that the two definitions submitted on accurately reflect the statutory framework established in higher level documents, that the provisions in the PSDP are internally consistent, and Prebbleton is appropriately recognised in the Township and Activity Centre Networks which will enable future planning for the township to be in accordance with its function and community expectations.

TRRG SUBMISSION ON DEFINITIONS

14. TRRG sought the following amendments to the Definitions Chapter: (refer to Appendix 1 for full definitions)

Submission point 004:

Amend the definition of Township Network as follows (a) …… (b) Service Townships

West Melton, Prebbleton, Darfield and Leeston Function is based on providing a high amenity residential environment and primary services to Rural Townships and surrounding rural area. Darfield and Leeston act as Key Activity Centres for the wider district. Prebbleton whilst a service activity centre is strategically located close to, and well connected to, Rolleston and Lincoln Key Activity Centres and the large and growing South West Christchurch industrial and business areas. Given this strategic location it can support a wide range of commercial, industrial, and residential activities, and a larger population (10 000 +) than anticipated for the secondary west Selwyn Key Activity Centres (i.e. Darfield and Leeston)

Submission point 005

Amend the definition of Activity Centre Network as follows:

1….

2… 3… Service Activity Centres provide goods and services to residents of the town as well as the wider rural area. However there will still be a reliance on the Key Activity Centres for larger scale businesses and more variety in retail and commercial activities. The Selwyn District has two Service Activity Centres being Prebbleton and West Melton. Prebbleton whilst a service activity centre is strategically located close to, and well connected to, Rolleston and Lincoln Key Activity Centres and the large and growing South West Christchurch industrial and business areas. Given this strategic location it can support a wide range of commercial, industrial, and residential activities, and a larger population (10 000 +) than anticipated for the secondary west Selwyn Key Activity Centres (i.e. Darfield and Leeston).

SUB REGIONAL CONTEXT: CANTERBURY REGIONAL POLICY STATEMENT (CPRS)

15. The PSDP Activity Centres Network gives effect to the CRPS centres hierarchy to the extent it recognises Rolleston and Lincoln as Key Activity Centres on Map A - together with Kaiapoi, Rangiora and Woodend in Waimakariri District, as below.

Figure 1: CRPS Map A including proposed Change 1 Future Development Areas (orange) Key Activity Centres identified by a star; priority greenfield business land blue; priority greenfield residential land green; existing urban area grey.

16. In terms of the CRPS Prebbleton appears to be a Neighbourhood Centre by default.

Objective 6.2.5 Key activity and other centres: Support and maintain the existing network of centres below as the focal points for commercial, community and service activities during the recovery period:

1. The Central City 2. Key Activity Centres 3. Neighbourhood centre

17. The CRPS only defines Key Activity Centres and the Central City. The Principal Reasons and Explanation to the Objective notes that ‘the role of neighbourhood centres is also recognised for the service role they play to local communities and as a location for appropriate business development.’

CRPS Objective 6.2.6 Business land development provides: … 3. New commercial activities are primarily directed to the Central City, Key Activity Centres, and neighbourhood centres;

I note however that CRPS Objective 6.2.2. Urban form and settlement pattern encourages:

(5) sustainable and self-sufficient growth of the towns of Rangiora, Kaiapoi, Woodend, Lincoln, Rolleston and Prebbleton, and consolidation of the existing settlement of West Melton

[my emphasis underlined].

18. This suggests to me that Prebbleton is a higher order settlement than West Melton in terms of the CRPS, and the PSDP is required to give effect to this.

PROPOSED SELWYN DISTRICT PLAN STRATEGIC FRAMEWORK

19. Township and Activity Centres Networks play an important part in influencing and making provision for distribution of population and commercial activity in Selwyn District through the higher order Objectives and Policies in the PSDP. For Greater Christchurch, these networks need to be considered alongside other settlements in the subregion.

20. The Strategic Objectives and Policies (below) are dependent on the two networks being ordered according to their potential role in meeting the needs of Selwyn District’s people and communities including Christchurch.

21. The Township and Activity Centre Networks provide the bridge between the Strategic Objectives and the zoning framework for townships and the commercial zones and rules. There needs to be a clear line of sight between the strategic framework, the extent and type of land use zoning and the rules that apply to those zones. I am not convinced that the following framework does this clearly, but it highlights the importance of the two Networks and their associated hierarchies. I have highlighted the relevant text in italics.

Strategic Objectives and Policies

• SD-DI-05: Selwyn’s hierarchy of activity centres are the preferred location for shopping, leisure, cultural, entertainment, and social interaction experiences in accordance with their anticipated role within the Activity Centre Network, • SD-UDF-01 Urban growth is located only in or around existing townships and in a compact and sustainable form that aligns with its anticipated role in the Township Network, while responding to the community’s needs, natural landforms, cultural values, and physical features • UG-02 Townships maintain a consolidated and compact urban form to support: the role and function of each urban area within the District’s Township Network and the economic and social prosperity of the District's commercial centres;

Urban Growth Policies

• UG P7 The form and scale of new urban areas support the settlements’ role and function within the District’s Township Network, • UG P13 {Any new residential growth area within the Greater Christchurch area shall only occur where} 2. A HDCA and FDS identify a need for additional feasible development capacity for the township and … • UG P14 {Any new residential growth area outside the Greater Christchurch area shall only occur where}: 1. There is a demonstrated need for additional development capacity within the township, • UG P15 The type, scale and function of new commercial areas are consistent with the Activity Centre Network and support mixed use activities, • UG P16 The type, scale and function of new commercial areas are consistent with the Activity Centre Network, including supporting mixed use activity in the Town Centre Zone; • UG P17 i. Support housing choice, increase the availability of affordable housing and enable economically resilient and diverse commercial centres, including by providing mixed use activities in Key Activity Centres’ or Local Centre Zones; ii. Achieve higher residential densities in and around Key Activity Centres, Town Centres, Core Public Transport Routes and in locations where there is safe and convenient access to public transport and public transport facilities;

Zone Statements

The Selwyn District’s 'Commercial and Mixed-Use Zones' are those areas which are the focal points for the District’s commercial and community needs. They include the Town Centre Zone, Local Centre Zone, Neighbourhood Centre Zone, and Large Format Retail Zone. These zones are intended to operate as an Activity Centre Network, with activities and development within each zone aligning with the role and function set out in the Township Network (my emphasis underlined).

22. I consider that these strategic provisions in the PSDP promote a strong direction to decision makers in the development capacity to be enabled is distributed to towns across the District. It is fundamentally important that the Township and Activity Centres Networks are appropriately structured to ensure that growth is allocated, not only to where the demand is, but also to where other national, regional and district objective are met, such as land use -transport integration.

23. The CRPS recognises Prebbleton as a higher order township than West Melton in terms of the Greater Christchurch settlement strategy and therefore, at least within the Greater Christchurch context, Prebbleton should be ascribed more importance in the Township network to assist the achievement of the District’s overall strategic direction.

SECTION 42A REPORT.

24. Ms Tuilaepa recommends rejecting the proposed amendments as it is ‘not necessary to elaborate on the role of Prebbleton and West Melton as part of the Township Network given that the text indicates the placement of each township within the hierarchy of Townships’. I can understand her reasoning because in this case the proposed wording seems to be suggesting an exception could be made for Prebbleton within the definition, which is not reflected in any policy or rule.

25. The issue for the submitter however is that there appears to be nowhere else in the Plan where the composition of the two networks can be submitted on. Jill Thomson (379-020) in reference to the notified Definition has submitted that ‘this level of detail is inappropriate within a definition. Much of this should be in the description at the beginning of the relevant chapters and form objectives and policies. The definition would also be better if it listed the types of centres and the definitions of those were included as separate entries. Policy should not be hidden in a Definition (my underlining)’. I agree with her assessment. I consider the hierarchies form the basis of the entire settlement strategy for the District.

KEY ISSUE

26. I consider the issue being raised by TRRG is whether Prebbleton has been correctly positioned in the two hierarchies, not whether the township should be better or specifically recognised in the Definitions. Cross boundary influences are increasingly placing development pressure on Prebbleton due to its proximity to the South Hornby and South Halswell industrial areas, the Southern Motorway and the major cycle route connecting Prebbleton to inner Christchurch.

ASSESSMENT

27. Both networks are based on the Selwyn District Development Strategy 2014. I consider it unlikely that the assumptions used by that document to develop the two Networks, including the population projections used, were able to fully anticipate the effects of such matters as the population shift that followed the Canterbury Earthquakes, impact of Covid 19, or the effect the Southern Motorway has had on township growth in Selwyn since 2014.

28. In my observation, over the past seven or eight years Prebbleton has become more closely associated with South West Christchurch and now performs a different function from the others in its category: i.e. Leeston, Darfield and West Melton. Its function is no longer servicing the surrounding rural environment but providing houses for the Christchurch market in the same way as Halswell does. The two TRRG submission points recognise the recent growth and changing role of Prebbleton in terms being part of the southwest urban growth area across the territorial boundary with Christchurch City.

29. Prebbleton’s role is no longer that described in the Township Network definition. While there continues to be a focus on providing a high amenity residential environment it does not provide ‘primary services to Rural Townships and surrounding rural area’. As an Activity Centre its role as described in the definition still applies to a degree, the Key Activity Centres it relies on increasingly being Christchurch orientated (e.g. North Halswell) rather than Lincoln or Rolleston.

30. Service Townships, as they have been defined in Selwyn 2031, have a population range at 2031 of between 1,500 - 6,0002. However, according to the Council’s most recent projections, Prebbleton’s population is projected to increase from its current population of 4977 reach 6900 by 2031 and is projected to reach the service town threshold of 6000 in 2025-263.

31. Table 1 below compares Prebbleton with the other principal townships in terms of forecast employment4 and population.

Table 1 Township Towns Activity Towns Commer Pop. Pop Employment Status Centre cial zone Threshol forecast growth Status ds 2031 forecasts 2031 District Rolleston Key AC Rolleston, TCZ 12000+ 27700 (R) 1567 Centre Lincoln, TCT Darfield TCZ and Leeston. Sub District Lincoln Key AC 6-12000 10550 1012 Centre Service West Service AC Prebbleton LCZ 1.5-6000 2762 WM 116 WM Townships Melton, and West 6900 PB 197 PB Prebbleton, Melton 4120 DAR 321 DAR Darfield and 2950 LEE 251 LEE Leeston Rural Rural Rural AC Not Township Townships - specified Arthur’s Pass, Coalgate, , ,

2 Selwyn 2031 Selwyn District Development Strategy page 33. 3 Selwyn District Growth and Demand 2021, Appendix 1: Population / Household / Dwelling Tables. 4 Selwyn District Growth and Demand 2021, Appendix 3. Rural Not Township specified

PB = Prebbleton, WM = West Melton, DAR= Darfield, LEE = Leeston.

32. In terms of population, Prebbleton is significantly larger than the other two towns in its group although it is not anticipated that Prebbleton will expand its job base as much as the others. This is likely to be because of its close proximity to Christchurch City’s major employment areas.

33. However, if Prebbleton is to be ‘encouraged’ to become more self-sufficient, in accordance with the CRPS Policy 6.2.2, further local employment opportunities, including appropriately zoned land should be considered. There is already a considerable amount of development underway or planned which will provide local employment opportunities including: - • Somerset retirement village on the former Springs Road Meadow Mushrooms site in central Prebbleton (underway); • Ashford BUPA retirement village in Tosswill Road (recently completed); • new commercial development in Springs Road (underway) and on vacant commercially zoned land to the rear of the existing centre (planned), as illustrated on the signboards below.

However, further business growth is constrained by the lack of suitably zoned land. Currently there is no industrial zoned land at Prebbleton and a minimal amount at Lincoln (12 ha) although I note there are submissions seeking to fill this gap (157, 394, 462).

34. In terms of the Activity Centre Network there could be a case to consider Prebbleton to be at least on par and probably above Darfield and Leeston in the hierarchy. In terms of the sub - regional hierarchy it could arguably be seen as a long term KAC, although there are already two KAC’s in the south part of Christchurch City at Halswell and Hornby. The key point is that Prebbleton has become part of Christchurch City’s south west growth area and serves a different function to virtually all other Selwyn settlements.

35. Further evidence of this function is contained in trip data produced by Waka Kotahi and reproduced below as Figures 2 which compares Prebbleton with Leeston5. It shows Prebbleton has strong connections with Lincoln because of the educational and to some extent, employment opportunities located there. Prebbleton is in the Lincoln High School Zone, not Rolleston College. But Prebbleton’s main economic interaction is with South West Christchurch, with other significant destinations being Lincoln, the Central City and Airport. A fair portion of Prebbleton residents (just under 20%) work locally, at Prebbleton. By comparison Leeston’s travel to work patterns are more diffuse and tend to be more localised.

5 https://commuter.waka.app/

Figure 2 Prebbleton Employment Destinations (the darker the circles, the more trips to that area)

Figure 3: Prebbleton Education Destinations.

Figure 4: Leeston Employment Destinations

Figure 5. Leeston Education Destinations RELEVANCE TO TRRG’S OTHER SUBMISSIONS.

36. I have previously presented evidence to the Panel on Strategic Directions SD-UDF-02 seeking that at least sufficient capacity be provided in each township. In that evidence I sought a slight change of wording from that used in the submission so that it referenced the township network. I note that in his Section 42A Report Mr Love has recommended rejection of the proposed wording. Also, in the context of the Urban Growth Chapter, Mr Baird has recommended the amended wording sought by TRRG be rejected and gave reasons why. I will respond to that matter in my Urban Growth evidence, but I want to re-emphasise what I regard as important and integral links between the TRRG submissions on Definitions and those on Strategic Directions and Urban Growth.

CONCLUSIONS

37. In my opinion Prebbleton is not appropriately recognised for its role and function in the Township and possibly the Activity Centre Networks. However I accept that the additional wording proposed in the respective definitions could add to what is already quite a lengthy definition and may not be the best approach.

38. If the Panel considers that the requested amendments to the definitions are not in keeping with the purpose of definitions, and have merit in principle, the relief sought by the submitter would be met in part by recognising Prebbleton as a Sub District Centre in the Township Network. It may also be appropriate to consider a corresponding change to the Activity Centre Network, subject to further retail analysis.

APPENDICES

APPENDIX 1: PROPOSE SELWYN DISTRICT TOWNSHIP AND ACTIVITY CENTRE NETWORKS