BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL IN THE MATTER of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010 AND IN THE MATTER of 017 RUB South STATEMENT OF REBUTTAL EVIDENCE OF JOY MARTHA LA NAUZE ON BEHALF OF AUCKLAND COUNCIL (PARAREKAU AND KOPUAHINGAHINGA ISLANDS - HINGAIA) 18 December 2015 1. SUMMARY 1.1 Having read the expert evidence from the witnesses on behalf of Karaka Harbourside Estate Limited (KHEL), and the rebuttal statements of evidence on behalf of Auckland Council's (Council) witnesses Shona Myers (ecology), Peter Kensington (landscape and visual effects) and Sarah Sinclair (coastal engineering), I am still of the opinion that Pararekau and Kopuahingahinga Islands should remain beyond the Rural Urban Boundary (RUB). 1.2 In my view, excluding Pararekau and Kopuahingahinga Islands from the RUB is the most appropriate method for achieving the objectives of the Regional Policy Statement (RPS) in the Proposed Auckland Unitary Plan (PAUP). Having regard to the evidence of the Council's other expert witnesses, the reasons for this include: (a) The Pararekau and Kopuahingahinga Islands have a unique coastal and non-urban character and this should be retained. Inclusion with the RUB and subsequent urban development would result in adverse effects on natural character, landscape and visual amenity values for this sensitive landscape. (b) The expansion of the RUB and urban development is likely to impact significantly on the ecological values Pararekau and Kopuahingahinga Islands, including the marine receiving environment. (c) The islands are an important sensitive environment culturally. (d) Relying on a single road access (two causeways) generates risk in the event that this access is not available in future. (e) The appropriate level of development on Pararekau Island was relatively recently considered by the Environment Court in a 2012 decision on the draft consent order for Private Plan Change 8 to Auckland Council District Plan: Papakura (PPC8). The provisions of PPC8 approved by the Environment Court demonstrate that Pararekau Island is not suitable for intensive urban development. 1 2. INTRODUCTION 2.1 My name is Joy LaNauze. I am a planner engaged by the Council to respond to submissions received on the notified Papuan to provide planning evidence in relation to submissions made on the southern RUB for Topic 017 RUB South (Topic 017). Those submissions relate specifically to the Hingaia area (incorporating Pararekau and Kopuahingahinga Islands). I have the qualifications and experience set out in my evidence-in-chief (EIC), which formed part of a Joint statement of evidence “Urban Edge-Flatbush, Howick- East Tamaki, Point View Drive, Mangere, Favona, Otahuhu and Hingaia” (co–written with Vrinda Moghe and Danni Briggs) dated 15 October 2015. 2.2 I confirm that this rebuttal statement of evidence has been prepared in accordance with the Code of Conduct for expert witnesses contained in the Environment Court Practice Note 2014. 2.3 In preparing this rebuttal statement I have read the evidence prepared on behalf of submitters on Topic 017 relating specifically to the Hingaia area. This rebuttal statement addresses various issues in that evidence. 3. SCOPE 3.1 This rebuttal statement addresses the evidence filed on behalf of Karaka Harbourside Estate Ltd (KHEL) (Submission 3644-1) in relation to the inclusion of Pararekau and Kopuahingahinga Islands in the RUB. 3.2 I note that the submitter has also made submissions and lodged evidence seeking the rezoning of the islands, and seeking amended precinct provisions. These submissions will be considered in Hearing Topics 080 Rezoning and Precincts (General) and 081 Rezoning and Precincts (Geographical Areas). 3.3 The submitter has lodged evidence from: P Brown (planning) D Scott (landscape) M Smith (Civil Engineering) S Lander (Geotechnical) J Dahm (Coastal Processes) 2 C Clarke (Stormwater) K Sky (Ecology) J Parlane (Transport) 3.4 The sub-groups or "themes" that will be addressed in this rebuttal statement in response to the submitter evidence include the following: (a) Strategic growth and RUB capacity/RPS (b) Rural and coastal landscape and amenity values (c) Ecological values (d) Heritage and cultural values (e) Coastal Hazards (f) Transport (g) Zoning of Kopuahingahinga Island under PPC8. 4. STRATEGIC GROWTH AND RUB CAPACITY/RPS Evidence 4.1 Mr Brown in his planning evidence on behalf of KHEL states in paragraph 1.1 of his evidence that inclusion of the islands within the RUB represents a sound approach to strategic growth planning and is an efficient use of a scarce physical resource. Mr Brown in paragraph 7.2 considers that the RUB change would enable the efficient provision of development capacity and land supply for residential growth. Analysis 4.2 As outlined in the EIC of Chloe Trenouth for Topic 016 RUB North/West (Topic 016) and Topic 017, she proposes to include a new policy in Chapter B2.1 of the PAUP to set out the criteria that needs to be applied when establishing the RUB. Part of the policy is to provide a clear defensible limit to urban expansion by aligning the location of the RUB with strong landscape features or physical boundaries such as the coastal edge, natural catchments or watersheds, and prominent ridgelines. 4.3 In line with this policy, I consider that the islands should be excluded from the RUB because they are physically distinct from the mainland. They are also an important sensitive environment visually, environmentally, and culturally. 3 4.4 Dr Douglas Fairgray on behalf of the Council states in his evidence-in-chief for Topics 016 and 017, that the RUB as notified contains sufficient land for the anticipated urban growth. 4.5 I consider therefore that the inclusion of Pararekau and Kopuahingahinga Islands within the RUB is not required for RUB capacity purposes. 5. RURAL AND COASTAL LANDSCAPE AND AMENITY VALUES Evidence 5.1 Mr Brown considers in his evidence on behalf of KHEL in paragraph 1.1 that the rural and coastal character of the islands, and the landscape and amenity values which arise from that character are not of such significance to warrant restrictions on urban development. The landscape character of Pararekau Island is also addressed in the evidence of Dennis Scott on behalf of KHEL who expresses the view that KHEL's proposal to urbanize the island will not have any significant adverse visual effects. Analysis 5.2 In reliance on the EIC and rebuttal statement of evidence of Peter Kensington on behalf of the Council, I disagree with Mr Brown and Mr Scott, and consider that these matters are of such significance that they do warrant restrictions on urban development. 5.3 Mr Kensington specifically states in his rebuttal evidence that he has not changed the opinions expressed in his EIC, and he remains of the opinion that, from a landscape and visual effects perspective, no change should be made to the proposed RUB location in the PAUP in relation to Kopuahingahinga and Pararekau Islands, Hingaia. This is as a result of his view that: (a) from a landscape and visual effects perspective, it would be inappropriate to include the Islands within the RUB (and rezone them as Residential Mixed Housing Urban or Residential Single House) because the consequential urban development would result in adverse effects on natural character, landscape and visual amenity values for this sensitive coastal landscape. 4 (b) Pararekau Island is not physically part of the mainland – it is an island connected to the mainland via a causeway with Kopuahingahinga Island located in between – and it has a uniqueness that should be respected The island’s uniqueness will be reinforced by having a less intensive zoning than the mainland. (c) Pararekau Island has a unique and sensitive coastal open space character which is differentiated from the mainland because it is an island. (d) it is appropriate to retain Pararekau Island as a landscape feature and provide for a new land use (countryside living) that is less developed than the mainland and which retains more of an open space character (albeit remaining in private ownership for the most part) alongside rehabilitation through planting and the provision of public access to the coastal edge. 6. ECOLOGICAL VALUES Evidence 6.1 Ms Sky in her ecological evidence on behalf of KHEL suggests that all of the potential adverse effects of urban development on Pararekau Island that she identifies could be appropriately addressed through a consenting process for a Mixed Housing development. 6.2 For example, Ms Sky considers in paragraph 74 of her evidence that potential adverse effects associated with discharges to the marine environment can be addressed through the development of best practice erosion and sediment control plans for earthworks and the design of best practice stormwater management for any future development. 6.3 I note that while Ms Sky addresses ecological issues on behalf of KHEL, Mr Brown does not refer to ecological values or Ms Sky's evidence in his planning evidence. Analysis 6.4 I consider that the ecological values of the islands, especially Kopuahingahinga, are a key reason to exclude the islands from the RUB. In my view, the lack of consideration of these values is a significant omission from Mr Brown's planning evidence about why the Pararekau and Kopuahingahinga Islands should be included within the RUB. 5 6.5 These ecological values of Pararekau and Kopuahingahinga Islands are addressed in detail in Shona Myers' rebuttal evidence on behalf of the Council. She notes that, of the two islands, Kopuahingahinga has the most significant ecological values, with native lizards and threatened plants recorded. Ms Myers also states in her rebuttal evidence that there are significant marine habitats on the edges of the islands, with intertidal feeding habitat for wading birds and estuarine saltmarsh habitat.