Before the Auckland Unitary Plan Independent Hearing Panel Submission 5566 & Further Submission 3168

In the matter of: Submissions on proposed plan under s123 of the Local Government Act (Auckland Transitional Provisions) Act 2010 and under cl 6 of Schedule 1 of the Resource Management Act 1991 – Proposed Auckland Unitary Plan – 30 September 2013

And: Auckland Council

Local Authority

And: Tram Lease Ltd, Viaduct Harbour Holdings Ltd & Viaduct Harbour Management Ltd

Submitters

Topic 020 Viewshafts Supplementary Evidence of Robert Pryor

Dated: 15 April 2016

2

SUPPLEMENTARY EVIDENCE OF ROB PRYOR

TOPIC 020 VIEWSHAFTS

Introduction

1.1 My full name is Robert James Pryor. I hold a Bachelor of Science degree in Psychology from Otago University (1980) and a post-graduate Diploma of Landscape Architecture from Lincoln University (1984). I am a registered member of the New Zealand Institute of Landscape Architects and I have the qualifications and experience set out in my professional CV in Appendix 1.

1.2 I have over 30 years’ experience undertaking landscape assessments for clients in both the public and private sectors on a wide variety of major projects within a range of landscape settings.

Expert Witness Code of Conduct

1.3 I confirm that I have read the Expert Witness Code of Conduct set out in the Environment Court's Practice Note 2014. I have complied with the Code of Conduct in preparing this evidence and I agree to comply with it while giving oral evidence before the Hearings Panel. Except where I state that I am relying on the evidence of another person, this written evidence is within my area of expertise. I have not omitted to consider material facts known to me that might alter or detract from the opinions expressed in this evidence.

Scope of Evidence

1.4 My evidence is given in support of the submissions and further submissions made by Tram Lease Ltd, Viaduct Harbour Holdings Ltd & Viaduct Harbour Management Ltd (Submitters) regarding Topic 020 Viewshafts in the proposed Auckland Unitary Plan (Plan).

1.5 I will address the evidence filed by Council regarding this topic.

1.6 My evidence will address:

(a) The outcomes of the Expert Caucusing that has occurred for Topic 020 between August 2015 and March 2016.

Pryor – Topic 020 Evidence 3

(b) My position with regards to the relief sought by the Submitters with respect to the status of Viewshaft A13.

(c) An index of previous evidence that I have prepared that relates to this Topic.

(d) An index of evidence (previous and current) that I have relied on that relates to this Topic.

(e) I have previously filed a statement of evidence on behalf of the Submitters in respect of the Volcanic Viewshafts.

Outcomes of Expert Caucusing

1.7 The hearing for Topic 020 was adjourned in July 2015. The Independent Hearings Panel subsequently arranged for Expert Caucusing to be undertaken by the experts for any interested parties. The Panel issued a “Procedure for further assessment of viewshafts and Height Sensitive Areas” on 21 August 2015.

1.8 I have attended the caucusing sessions on behalf of the Submitters.

1.9 In relation to Volcanic Viewshafts, the landscape expert caucusing involved the landscape experts assessing the landscape values associated with each of the 87 Volcanic Viewshaft and recording our individual or collective position on each. Where disagreement existed between experts, our respective views were recorded.

1.10 The outcomes of the above are set out in the Joint Statement of Expert Witnesses on Topic 020, dated 29 March 2016.

1.11 My position on the outcomes of the Expert Caucusing (as recorded in the Joint Statement) in respect of the status of Viewshaft A13, and the provisions of the Plan that relate to volcanic viewshafts, is set out below.

Viewshaft A13

1.12 The Submitters presented a comprehensive set of expert evidence as part of the Topic 020 hearing in June 2015. This evidence presented a unified position with respect to building height and the floor of Viewshaft A13, as these relate to their landholdings in Mt Albert.

1.13 The extensive visual analysis undertaken by the Submitters visual experts is that (irrespective of the presence of the Viewshaft) the Submitters properties in Mt Albert can readily

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sustain (and are appropriate for) a building height of up to 31m, which has been sought as a suitable and sustainable outcome that is appropriate for the context of these properties, and the urban intensification objectives of the Plan.

1.14 In respect of the expert caucusing, the positions of the landscape, economic and planning experts were recorded (in summary form) in the “Combined Analysis” document (Attachment D to the Joint Statement). Attachment B to the Joint Statement contains the values statements for each Volcanic Viewshaft prepared by Mr Stephen Brown.

1.15 In respect to the Attachment B series, it is important to record that Mr Brown prepared the Viewshafts Assessment sheets for Expert Caucusing and that these reflect his views. While the landscape experts are in general agreement about the ‘cone’, ‘view’ and ‘origin point’ attribute descriptors to the extent that we have examined them, we are not in agreement with the ‘summary’ and ‘evaluation’ columns for a number of the viewshafts as outlined in in our joint witness statement Attachment D. It is therefore misleading to refer to the Attachment B series as a ‘Joint Statement by Landscape Experts’ as it solely reflects the views expressed by Mr Brown.

1.16 As recorded in the Combined Analysis document, myself and the other landscape experts (Ms Rachel de Lambert, Mr Shannon Bray and Mr Dennis Scott) do not agree with Mr Brown’s ‘regionally significant’ status of Viewshaft A13, on behalf of Auckland Council.

1.17 Myself and the other landscape experts all consider that the viewshaft is neither of regional nor local significance, and should therefore be deleted.

1.18 We all agree that the cone is not sufficiently significant, memorable or dominant in this view to command the attention of motorway users, and as such is not ‘iconic’. We consider that it retains little volcanic resemblance and appears contiguous with the surrounding residential slopes. Quarrying in the past has removed 13m from its crest and destroyed the terraces. The extensively vegetated slopes with interspersed built development have hidden all of the cone’s landform and distinctive volcanic shape. The cone is not the natural focus of attention in the diverse view.

1.19 The significance of the cone from this distance, in excess of 6.8km away, is derived from its silhouette against the wider panoramic Auckland skyline including Maungawhau and Maungakiekie, which it is viewed in association with. The juxtaposition of the three cones continues as one travels in an easterly direction along the northwestern motorway towards the CBD.

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1.20 The integrity of the view is also compromised by the surrounding landscape context and detractors in the view including the motorway lanes and infrastructure including median barriers, overhead transmission wires, signage and vehicles and trucks travelling at high speed.

1.21 I therefore do not consider that the view protected by Viewshaft A13 qualifies as a regionally significant view. While the maunga itself is regionally significant as a component of the Auckland isthmus cone field, the viewshaft has been compromised to such a degree that brings into question its status. Mt Albert is not a clearly legible and visually distinctive volcanic cone from this viewpoint.

1.22 I, along with the other landscape experts also consider that the cone does not achieve ‘local significance’ due to the lack of any real local audience, given the transient location within the motorway corridor and lack of any context of resident population / viewers.

1.23 With regards to all of the above, I consider that the deletion of Viewshaft A13 is the most appropriate outcome.

Index of my previous evidence

1.24 As set out above, I have previously filed evidence on behalf of the Submitters, which relates to Volcanic Viewshafts. My position as set out in my previous evidence has not changed as a result of the expert caucusing.

1.25 My previous evidence that I rely on is as follows:

(a) “Topic 020 Volcanic Viewshafts, Evidence of Robert James Pryor” dated 8 June 2015, on behalf of the Submitters.

Index of other evidence relied on

1.26 In reaching my position on the outcomes of the expert caucusing, and on the status of Viewshaft A13 and the provisions related to the management of Volcanic Viewshafts in the Plan, I have relied on the evidence filed by other experts on behalf of the Submitters, namely:

(a) “Topic Topics 020, 054, 069 & 078 Volcanic Viewshafts, Building Height & FAR, Evidence of Andrew Anderson” dated 8 June 2015.

(b) “Topics 020, 054, 069 & 078 Volcanic Viewshafts, Building Height & FAR, Evidence of Michael Foster” dated 8 June 2015.

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(c) “Topics 020, 054, 069 and 078 Volcanic Viewshafts, Building Height and FAR Controls, Evidence of Clinton Bird” dated 8 June 2015.

(d) “Topics 020, 054, 066, 069 & 078 Volcanic Viewshafts, Building Height & Far Controls, Rebuttal Evidence of Michael John Foster for Tram Lease Limited” dated 19 June 2015.

(e) “Topic 020 Volcanic Viewshafts, Evidence of Robert James Pryor”, dated 15 April, 2016.

Rob Pryor

15 April 2016

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APPENDIX 1: CV

Robert James Pryor

Qualifications Bachelor of Science Degree (Psychology) – Otago University (1982) Diploma of Landscape Architecture – Lincoln University (1984) Registered Member, New Zealand Institute of Landscape Architects Member, Resource Management Law Association Member, Urban Design Forum

Background 1996 – on : Director, LA4 Landscape Architects, Auckland 1993 – 1996: Landscape Architect, LA4 Landscape Architects, Auckland 1989 – 1993: Director, Bannatyne Pryor Associates, Wellington 1984 – 1989: Landscape Architect, Wellington City Council, Wellington

Skills and Experience Rob has over thirty years experience as a practicing landscape architect, including five years as Landscape Architect for Wellington City Council and four years as director of the Wellington consultancy Bannatyne Pryor Associates. He has been involved in a wide variety of local authority, public and private sector work. He has been involved in a wide variety of local authority, public and private sector work and has had a longstanding involvement in landscape assessments, visual and landscape effects assessments, reserve management planning and precinct planning and urban design projects.

Rob specialises in landscape and visual effects assessments and has been involved in a number of large infrastructure projects, roading developments, marine farms and large scale commercial development including the North Shore Wastewater Treatment Plant, Mangere Wastewater Treatment Plant, Waikato River Water Source, Regional Prisons – site selection, marine farms, subdivisions and telecommunications facilities. This work has also included providing advice on landscape treatment and mitigation measures to reduce any adverse visual and landscape effects of development.

Rob has been involved in a number of Plan Change applications and peer reviews of landscape impact assessments and is very familiar with the Resource Consent and appeals process having prepared numerous applications for North Shore City, Auckland City, Waitakere City, Taupo District, Far North District, Whangarei, Marlborough and Taupo District Council’s.

He has prepared evidence for and appeared before numerous Council, Environment Court and Board of Inquiry hearings in relation to landscape, visual and amenity effects on the environment.

Fields of Special Competence Landscape and Visual Effects Assessment Landscape Planning and Design Urban Design Open Space and Recreation Planning Contract Documentation Contract Administration Project Management Expert Witness

Pryor – Topic 020 Evidence