SUBMISSION BY DPS DEVELOPMENTS LIMITED ON PUBLICLY ... · ON PUBLICLY NOTIFIED PROPOSED PLAN CHANGE...

78 Second Ave, City, Tauranga 3110 I PO Box 324, Tauranga 3140 P +64 7 579 9747 1209 Hinemaru Street, Rotorua I PO Box 1027

554 Victoria Street, Hamilton I PO Box 112, Hamilton 3240 P +64 27 659 1641 [email protected] www.veros.co.nz

24 June 2020 SOUTH WAIKATO DISTRICT COUNCIL Private Bag 7 Tokoroa 3444 By email: [email protected]

SUBMISSION BY DPS DEVELOPMENTS LIMITED

ON PUBLICLY NOTIFIED PROPOSED PLAN CHANGE 1

(RMA Form 5)

1.0 INTRODUCTION

1.1 DPS Developments Limited (“the Submitter”) makes this submission on the Proposed Plan Change 1 (“PC1”) to the South Waikato District Plan (“the Plan”).

1.2 The Submitter is a potential development within the Kennedy Drive Growth Cell and the Business zone Growth Cell as well as the owner of other strategic properties within the Putaruru District.

1.3 The submission relates to proposed objectives, policies, and rule provisions for Putaruru Growth Cells 3 and 4 and proposed Designation D59. The Submitter strongly supports the intent of the proposed objectives and policies to rezone land for urban and industrial activity, however submits that the rule framework is overly restrictive, will limit development and is inconsistent with the purpose and principles of the Resource Management Act 1991.

1.4 The Submitter supports the proposed rezoning of the Rural Residential Growth Cell 3 to Residential and the rezoning of the full 40ha of Rural zoned land in Growth Cell 4 for industrial activities, and requests: (a) Minor amendments to proposed draft Plan provision in respect to Growth Cell 3. (b) Removal and minor amendments to the zoning, policy and rules in respect to Growth

Cell 4. (c) Removal of the proposed Designation.

2.0 GROUNDS FOR SUBMISSION

2.1 The Submitter supports or opposes the specific provisions set out in Section 4 of this document. In the absence of the relief sought being granted, the Submitter considered that PC1, as notified: (a) Results in inefficient and ineffective administration of the Plan; or

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VEROS PROPERTY SERVICES – SUBMISSION South Waikato District Counci l – DISTRICT PLAN CHANGE 1

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VEROS PROPERTY SERVICES

HAMILTON ROTORUA TAURANGA

(b) Is inconsistent with the purpose and principles of the Resource Management Act 1991 (“RMA”).

2.2 Without limiting the generality of the above, the specific reasons for the submission are set out in the following section.

3.0 OVERVIEW OF SUBMISSION POINTS

Rezoning

3.1 The overall purpose of PC1 to accommodate for growth in Putaruru with more residential properties for a range of housing options and an increase in business and industrial land, is supported.

3.2 The proposed location of areas for rezoning is supported, being in line with the Putaruru Strategic Growth Plan Rezoning will ensure Putaruru and South Waikato benefit from a growing population, and the improved vibrancy and economic development of Putaruru

3.3 In line with South Waikato District Council’s strategic assessment of the proposed growth plan for Putaruru, the Submitter requests inclusion in the Planning Maps (Map 22) of an addition Future Growth Area located between proposed Growth Cells 3 and 4.

Growth Cell 3

3.4 Support for rezoning from Rural-Residential to Residential.

3.5 Opposition to the District Plans provision of reserve contributions that are inconsistent with the proposed objectives and policies in valuing and recognising the contribution of biodiversity, linkages and walkways in contributing to recreation areas.

3.6 Support for objective and policy provisions encouraging integrated growth. This however needs to be implemented in an efficient and effective manner, recognising the value of Development Concept Plans (DCP) as masterplan documents, in line with current DCP provisions in the District Plan.

Growth Cell 4

3.7 Support for the rezoning of all the 40ha Growth Cell at once, to enable coordinated development planning of the growth area (as referenced under Clause 3.6.4 of the Section 32 Report).

3.8 Opposition to the proposed zoning as Business zone, the Submitter seeks an Industrial zoning, to better reflect the objectives sought by Council for industrial activities on the site, with appropriate limitation of retail and office activity as secondary to the industrial use.

3.9 Opposition to the over-prescriptive requirement for all development within Growth Cell 4 to be subject to Resource Consent for consideration of traffic generation and safety and efficiency on the road network, notwithstanding evidence within the Section 32 Report that “the level of traffic effects that are assessed as being supported by the network to 2038 is some 330vph”


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3.10 While accepting the need for potential upgrades at the Princes St / State Highway 1 intersection, it is submitted that in accordance with the RMA all adverse effects can be appropriately addressed through resource consent application under a Discretionary Activity status. The Non-Complying activity status is opposed and considered to be inconsistent with the proposed objectives and policies for the Putaruru Growth Cell 4.

Designation

3.11 Opposition to the proposed Designation for Road (D59) as it is not an efficient or effective means to provide for the road link between Putaruru Growth Cell 4 and Princes Street. The Submitter is the owner of the land subject to the proposed Designation, and as noted in the Section 32 Report, is a willing party who has interest in development of the Putaruru Growth Cell 4. Further the general area subject to the proposed Designation is already providing onsite access and located in line with typographical limitations onsite.

4 RELIEF SOUGHT

4.1 The submitter seeks the following decisions from the Council on the notified PC1 provisions:

(a) That the proposed provisions be retained, deleted or amended, as set out in the table below.

(b) Such further or other consequential or alternative relief as may be necessary to fully give effect to the matters raised and relief sought in this submission.

Change PC1 Amendment Support/ Oppose Comments Relief Sought

OBJECTIVES AND POLICIES

1 Replace Objective 4.2.7 – Objectives for the District’s Towns 4.2.7 To provide for outward expansion of the existing townships where the new areas can be efficiently serviced with network utilities and infrastructure including provision for cycling and pedestrians, where funding provision has been made, consistent with the projected demand for new building sites for housing and businesses.

Oppose The policy framework supports the establishment of a network of public reserves that serve neighbourhood. The District Plan recognises recreation areas as active and passive recreation including biodiversity corridors, park links and walkways (including those along water areas). It is therefore submitted under the District Plan that areas within a stormwater reserve that are set aside for biodiversity, linkages and walkways are adding to the reserve network and should be discounted accordingly from contributions.

Remove the words “with network utilities and infrastructure”. Recognise the provision of biodiversity, linkages and walkways as part of the reserve network, and reduction in contributions. Remove any reserve contribution requirements for business activities.

2 New Objective 4.2.10 – Objectives for the District’s Towns

Support The Submitter supports the integration and efficient

That this provision be retained as notified.


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4.2.10 To ensure that new urban development is efficiently serviced and integrated to mitigate adverse effects on existing network utilities and infrastructure.

servicing of new urban development.

3 New Objective 4.2.11 – Objectives for the District’s Towns 4.2.11 To ensure that staged subdivision or development in the Putaruru Growth Cells does not compromise the future use of those areas.

Support The Submitter supports the proposed objective for integrated growth.


4 Amend Policy 4.3.3 – Policies 4.3.3 Consolidate new residential development in the existing vacant, zoned and serviced land, and in the Putaruru Growth Cells identified by this Plan, in order to achieve the efficient use of existing network utilities and infrastructure.

Support The Submitter supports the proposed inclusion of development of Putaruru Growth Cells in achieving efficient use of resources.


5 New Policy 4.3.18 – Policies 4.3.18 Land within the Putaruru Growth Cells will not be developed for urban use until the provision of network utilities and infrastructure to service the land is secured through private developer agreements or other appropriate legal mechanisms.

Oppose The Submitter opposes this provision. It is not an efficient or effective way to implement Plan objectives. It is submitted that policy and rule provisions already provide for appropriate infrastructure, and that any alternative arrangements are able to be proposed and addressed at Development Concept Plan stage.

That this provision be removed or amended as notified.

6 New Policy 4.3.19 – Policies 4.3.19 Each Putaruru Growth Cell shall be developed and serviced to provide sufficient capacity in network utilities and infrastructure for the scale and density of residential and or business development anticipated for the entire growth cell.

Oppose The Submitter is opposed to the intent of the proposed policy in providing additional services than needed for a staged development. This requires significant upfront investment that is not feasible, nor necessary given proposed the objective to ensure overall integration in services and design for a catchment.

Remove the words “anticipated for the entire growth cell”.


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7 New Policy 4.3.20 – Policies 4.3.20 Ensure that new subdivisions within Putaruru Growth Cells do not compromise their efficient servicing, or their integration with the existing urban area as new neighbourhoods.

Support

The Submitter supports the proposed inclusion of development of Putaruru Growth Cells in achieving efficient use of resources.


8 New Policy 4.3.21 – Policies 4.3.21 Ensure that activities within Putaruru Growth Cell 4 do not cause adverse safety, efficiency, and capacity effects on the operation of the SH1/Princes St intersection.

Support

The Submitter supports the proposed inclusion of policy direction to ensure the safe and efficient operation of the road network. The means to achieve this policy however is not supported and submitted in opposition below.


ADMINISTRATION 9 New Clause under 8.1 –

Information Requirements for RMA Applications 8.1.3 Subdivision Consent Applications 8.1.3b) Putaruru Growth Cells b) In addition to any relevant matters listed in 8.1.3a) above, a Development Concept Plan (DCP) shall be submitted with all subdivisions for a subject site that is wholly or partly within a Putaruru Growth Cell. A DCP shall show: i)… – xii)…

Oppose

This clause has been included as an information requirement for Subdivision Consent Applications. It is onerous and requires significant upfront detail for what is considered in the Section 32 report as a more flexible approach than a structure plan. Also referenced in the Section 32 report is the District Plan’s current use of DCP’s for Rural Residential subdivisions. However, unlike this notified provision, the Rural Residential provision is appropriately included as a Standard for compliance as a Controlled Activity (Rule 10.3.1a)iii) and Rule 10.7.3). The provision under Rule 10.7.3b)i) – v) reflect the nature of a “Concept Plan” without the requirement for significant detailed analysis and reporting. The provision as notified imposes significant risk and will inhibit development. Notwithstanding the cost and upfront invest required, the

That this provision be removed as notified.


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rigid process of compliance with the approved and significantly detailed DCP will require numerous variations and consenting requirements as changes are made to accommodate design, market conditions and site requirements across the life of a development programme on land zoned for ongoing growth.

10 New Rule under 8.3.1 – Reservation of Control – Controlled Activity Land Use Applications. 8.3.1j) j) In assessing applications for controlled activities within Putaruru Growth Cell 4 shown on the Planning Maps, the matters in respect of which Council has served its control are: i)… - vi)…

Support

The Submitter supports provision of matters of control for proposed Putaruru Growth Cell 4.


11 New Rule under 8.3.2 – Reservation of Control – Controlled Activity Subdivision Applications. 8.3.2pa) pa) In relation to subdivision of land within any Putaruru Growth Cell, the degree of compliance with any Development Concept Plan prepared for the Growth cell concerned.

Support

The Submitter supports provision of Council’s reservation of control in general compliance with any Development Concept Plan.


12 New Rule under 8.3.3 – Matters where discretion is restricted – Restricted Discretionary Activities. 8.3.3ae) ae) In assessing applications for activities within Putaruru Growth Cell 4 shown on the Planning Maps (GC4) that do not comply with Rule 22.4.11d) because they would result in a cumulative increase in

Support The Submitter supports provision of Council’s restricted assessment of the cumulative increase in vehicle movements at the intersection.



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vehicle movements to and from GC4 at the Princes St/SH1 intersection of more than 200 vehicle movements in any given peal hour, the matters in respect of which Council has restricted its discretion are: i)… - vi)…

13 New Rule under 8.3.3 8.3.3t) t) In assessing applications for activities within Putaruru Growth Cell 4 shown on the Planning Maps that do not comply with Rule 22.4.12 relating to water supply and/or wastewater disposal, the matters in respect of which the Council has restricted its discretion are: i)… - v)…

Support The Submitter supports provision of Council’s restricted assessment.


14 New Rule under 8.3.4 – Additional Matters of Control and Restricted Discretion 8.3.4u) u) Where subdivision affects land wholly or partly within a Putaruru Growth Cell shown on the Planning Maps: i)… - viii)…

Oppose This control proposes consideration of the Development Concept Plan, appropriate building areas, management of reserve sensitivity and provides for the imposition of consent notices (specifically for GC4 in respect to traffic generation). The guidance provided by the proposed matters over which Council has reserved control are supported. In respect to reverse sensitivity the s32 report appropriately concludes that it is not relevant for GC4 given the adjoining zones and activities. This is supported. It is though submitted that proposed reverse sensitivity clause 8.3.4iv) clearly references that it is applicable only to those Growth Cell areas that have been identified in the Planning Maps as bordering a

That this provision be amended as notified.


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“Reverse Sensitivity Mitigation” boundary. Opposed is the provision for Council to impose Consent Notices for Growth Cell 4 in respect to traffic generation when the District Plan will already provide this notice through proposed rules without the need for restrictions to be imposed on titles.

15 New Rule under 8.4 – Assessment Criteria for Discretionary Activities 8.4.11A Discretionary Activities in Putaruru Growth Cell 4 a) Retail activities, places of Assembly and other activities which are discretionary activities in the Putaruru Business zone with Putaruru Growth Cell 4 shown on the Planning Maps, since they are not controlled activities under Rule 22.3.2A, should: i) Mitigate any adverse effects on the Princes St/SH1 intersection, as demonstrated by an Integrated Traffic Assessment prepared by a suitably qualified and experienced person, taking into account the level of traffic generated by other land use which has been lawfully established or granted consent to establish in the Growth Cell. This mitigation could include funding physical improvements to the intersection. ii) Complement rather than detract from the retailing and other activity in the Putaruru Town Centre zone.

Support The Submitter supports provision of Discretionary Activity Assessment Criteria for proposed Putaruru Growth Cell 4.


DEFINITIONS 16 Building Platform

Replace definition of “Building Platform”

Support The proposed amendment updates reference to the Regional Infrastructure Technical Specifications (RITS).



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RESIDENTIAL ZONE 17 New Rule under 10.4 – Standards

– Residential Zones1 10.4.1c) All habitable building sites shall be at least 0.5m above the 1% AEP design flood level.

Oppose The Submitter supports the design of residential buildings to provide for flood protection, however a minimum 0.5m freeboard above the 1% AEP is opposed.

That this provision as notified, be amended to: All habitable building sites shall be at least 0.5m above the 2% AEP design flood level.

18 New Rule under 10.5 – Subdivision Standards – (including Business and Industrial Zones) 10.5.4A Provision of New Road to Putaruru Growth Cell 4 (Business) a) Any subdivision creating new allotments within Putaruru Growth Cell 4 shown on the Planning Maps shall provide access to those allotments by way of a new legal road from Princes Street, constructed to the standard set out in RITS.

Oppose The Submitter opposes the provision of a single access to Putaruru Growth Cell 4,

That this provision removed as notified.

PUTARURU BUSINESS ZONE 19 Amend Provision 22.1 Zone

Statement 22.1 This Zone comprises vehicle orientated retail and commercial activities and light industrial development all located around the town centre. It applies to Putaruru Growth Cell 4 (GC4) to the south of Princes Street and three groups of properties on the edge of the town’s housing area, at Pit Street, Grey Street and adjacent to the SH1 bridge over the Oraka Stream. The Putaruru Business Zone provides for a mixture of activities including which, with the exception of Putaruru Growth Cell 4 include large format retail

Oppose It is submitted that the proposed limitation of office and retail use is more aligned to Industrial activities and performance standards. Industrial activities are permitted in the Business zone excluding offensive trades. An Industrial zone would allow these activities but within a managed and buffered environment (such as existing setback and fencing mitigation), not dissimilar to Industrial zoning adjoining Residential zoned land in Tirau. Putaruru Growth Cell 4 is in vicinity to existing Industrial

That this provision be amended as notified.

1 It is noted that while Plan Change 1 is specific to proposed Growth Areas, this change to proposed to apply across all Residential Zones.


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premises, building supply firms and garden centres, car yards, service stations, supermarkets and a range of commercial and light industrial premises. Retail activities and other traffic-intensive activities are not provided for within Putaruru Growth Cell 4, due to their potential impact on the safety and efficiency of the Princes St/SH1 intersection. Restrictions are placed on the water supplied to, and wastewater disposed from, new industries in Putaruru Growth Cell 4 due to the limitations of Putaruru’s bulk services to cater for industrial growth.

zoned land, located on the eastern side of the State highway, on the outskirts of the town, as opposed to being located like existing Business zones around the town centre.

20 Amend Provision 22.2 Anticipated Environmental Results 22.2 A predominantly vehicle orientated commercial and light industrial environment, except in Putaruru Growth Cell 4, which will cater predominantly for industrial activities

Oppose While there is support for the policy direction that Putaruru Growth Cell 4 caters predominantly for industrial activities, it is submitted that the an Industrial Zone, and current zone provisions in the District Plan, would be a more aligned approach to provide for industrial activities within the proposed Putaruru Growth Cell 4.

That the amendment to this provision as notified, be removed

21 Amend Rule 22.3.1 Permitted Activities 22.3.1 The following are permitted activities in the Putaruru Business Zone except within Putaruru Growth Cell 4 shown on the Planning Maps.

Oppose It is submitted that there should be provision for permitted industrial activities within the Putaruru Growth Cell 4.

That the amendment to this provision be removed, as notified.

22 New Rule 22.3.1A 22.3.1A Permitted Activities in Putaruru Growth Cell 4 The following are permitted activities in the Putaruru Business Zone within Putaruru Growth Cell 4 shown on the Planning Maps, provided they comply with the

Oppose It is submitted that there should be provision for permitted industrial activities within the Putaruru Growth Cell 4, consistent with proposed objectives and policies, in support of development occurring and enabling through performance standards appropriate environmental

That this provision, as notified, be amended to provide for intensification of farming activities, subject to any additional infrastructure/buildings not hindering the future and intended longer-term use of the land for industrial activities.


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Performance Standards set out in Rule 22.4 below: a) Farming activities lawfully

established on the land concerned as at 20 May 2020.

mitigation, including road safety. Council has a range of other administrative tools to enable and manage data collection of cumulative traffic generation without the need for a controlled activity status for all activities. In respect to the proposed provision of lawfully established farming activities operating as a permitted activity, this is already assured as existing use rights under the RMA. It is submitted that this provision should be expanded beyond existing use rights to enable efficient land use and recognise the objective of the rezoning to provide for long-term growth. In this regard it is submitted that the rule should provide for intensification of farming activities, subject to any additional infrastructure/buildings not hindering the future and intended longer-term use of the land for industrial activities.

23 New Rule 22.3.2A 22.3.2A Controlled Activities in Putaruru Growth Cell 4 The following are controlled activities in the Putaruru Business Zone within Putaruru Growth Cell 4 shown on the Planning Maps provided they comply with the Performance Standards set out in Rule 22.4 below: a) Industrial Activities, except

those listed in Appendix H – High Impact Industrial Activities.

b) Ancillary offices of, and retailing ancillary to, permitted

Oppose It is submitted that the policy direction for industrial activities within the Putururu Growth Cell 4 are greater aligned to an Industrial Zone. Further, the Submitter supports a restriction on stand-a-alone retail and office activity but submits that the size of these areas is dependent of the natural and overall scale of the industrial activities, particularly associated office space. It is submitted that the existing Industrial Zone rules are more aligned to enabling industrial

That this provision be removed, as notified


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Industrial Activities provided that the GFA of this office and retailing space shall together: i) Not exceed 10% of

the GFA used for industrial purposes on the same site, or

ii) Not exceed 50 square metres in GFA,

Whichever is the lesser. c) Modifications, alterations and

additions to an existing dwelling on the same site.

d) Veterinary Services e) Caretakers accommodation f) Emergency Service Facilities g) Farming activities not lawfully

established on the land concerned as at 20 May 2020, except for the establishment of intensive farming activity.

business activity while managing effects. Specifically, ancillary offices are provided, and associated retail is restricted to a more reasonable scale, such as 10% of GFA.

24 Amend Rule 22.3.3a) Restricted Discretionary Activities – Putaruru Business Zone 22.3.3a) a) Any activity listed in Rules 22.3.1 or 22.3.2A

Support Support for a Restricted Discretionary activity status for activities not meeting the performance standards.

That the provision be retained as it relates to a Restricted Discretionary Activity status.

25 Amend Rule 22.3.5 Non-Complying Activities 22.3.5c) and d) c) Activities within Putaruru Growth Cell 4 shown on the Planning Maps (GC4) that result in a cumulative increase in vehicle movements to and from GC4 at the Princes St/SH1 Intersection of more than 330 vehicle movements in any given peak hour, taking into account the level of traffic generated by the other land uses which have been lawfully established or granted consent to establish in the Growth Cell. d) Intensive farming activities.

Oppose The Submitter opposes a Non-Complying activity status. The land is proposed as a Growth Cell to support economic development via industrial activities to the town. A Non-Complying Activity creates greater uncertainty and indicates that activity intended in the Growth Cell is out of zone. It is submitted that a Discretionary Activity status manages Council’s and NZTA’s concerns while enabling effects assessments and appropriate consideration of mitigation needed. It is further submitted that the location of the Growth Cell

That the provision 22.3.5c) be removed, as notified. That the provision be provided for as a Discretionary Activity.


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provides opportunity for design and mitigation solutions, including intersection upgrades, contributions, using existing accesses and opportunity for transportation via rail with construction of the siding.

26 Amend Clause 22.4 Performance Standard for Permitted and Controlled Activities 22.4.11 Scale of Activity and Access 22.4.11c) c) Activities accessing a local road, except for activities within Putaruru Growth Cell 4 shown on the Planning Maps, shall not result in an increase in traffic that exceeds 200 vehicle movements in any given peak hour. d) Activities within Putaruru Growth Cell 4 shown on the Planning Maps (GC4) shall not result in a cumulative increase in vehicle movements to and from GC4 at the Princes St/SH1 Intersection of more than 200 vehicle movements in any given peak hour. Compliance with this rule shall be demonstrated by an integrated Traffic Assessment (ITA) prepared by a suitably qualified and experienced person, taking into account the level of traffic generated by other land use which has been lawfully established or granted resource consent to establish int eh Growth Cell. The ITA shall include a record of the outcomes from consultation with NZTA relating to the proposal’s potential traffic and safety effect on the State highway network and the SH1/Princes Street intersection.

Oppose It is submitted that Council is attempting to removal all risk rather that manage risk through District Plan provisions, as provided for under the RMA. The principle of the High Risk Intersection Guide, also specifically guides that safety is about risk management not complete risk removal. The submitter therefore supports the recommendation of Council’s consultant Traffic Engineer that the District Plan can provide “a suitable baseline of permitted development without introducing any unnecessary analysis burden that may stifle development”. In response to NZTA’s concerns, the Section 32 report refers to correspondence during Council’s engagement on the draft plan. Of note at page 60 of the section 32 Report is reference to NZTA’s position that short term safety treatments can be implemented in order to mitigate safety concerns at the SH1/Princes St intersection prior to the 330 vehicle movements per hour being reached. It is advised that lowering the speed limit in the area would provide appropriate mitigation, however NZTA have not considered this work a priority. As per the Section 32 Report it is submitted that Council is able to address speed management

That the amendments be removed, as notified.


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and that this is a priority prior to consideration of any restrictions imposed under the RMA.

27 New Rule 22.4.12 22.4.12 Wastewater and Water Limitations – Putaruru Growth Cell 4 Activities within Putaruru Growth Cell 4 shown on the planning Maps shall not result in: a) An increase in wastewater

discharged to Council’s reticulated network that would cause the total amount of wastewater discharged from the Growth Cell to exceed 108 cubic metres per day, or

b) An increase in demand on Council’s reticulated water supply network that would cause the water supply demand from the Growth Cell to exceed 120 cubic metres per day.

Oppose The Submitter opposes the proposed limits on the provision of water and wastewater discharge.

That this provision be removed or amended, as notified

28 New Rule 22.4.13 22.4.13 Provision of New Road to Putaruru Growth Cell 4 (Business) a) Any development of the land within Putaruru Growth Cell 4 shown of the Planning Maps for a permitted activity shall provide access to the activity by way of a new legal road from Princes Street, constructed to the standard set out in RITS.

Support The Submitter supports the provision of future access to Growth Cell 4 via Princes Street.

That this provision be retained, as notified

29 Putaruru Residential Zone New Rule 23.3.1 23.3.1p) p) Farming activities lawfully established on the land concerned as at 20 May 2020.

Oppose Lawfully established farming activities are pursuant to Section 139 of the RMA are already assured as existing use rights, without the need to for a permitted activity provision included including in the District Plan.

That the amendment to this provision as notified, be removed


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PLAN APPENDICES AND PLAN MAPS 30 New Designation D59 to Appendix

A Schedule of Designations D59 Designation

Oppose The Section 32 Report assesses the proposed designation as the best option for securing future road access to Growth Cell 4 via Princes Street. The analysis has not appropriately given sufficient weight to the existing situation or Council’s future options if needed to manage risk. Firstly, the subject properties of the proposed designation already utilise the general designation area for access. It is an established access and driveway that’s location has been determined in part due to existing topography. It is unlikely this existing vehicle access will be modified for buildings. The sites as noted in the Section 32 Report are also owned by a willing party who has interest in development of the Growth Cell. If the situation changes in the further, Council is able to register its intent to designate the area, without the need to initiate a plan change. Further, the Section 32 Report advises of Council’s intent to require new Development Contributions in order to fund the estimated $900.000 LTP project that would otherwise by vested in Council, without capital works, land value negotiations and recovery of funding via Development Contributions.

That this designation be removed, as notified

31 Planning Maps 3, 18 and 22-23 Amendments to zoning of identified properties on Planning Maps 3, 18, and 22-23

Oppose Support for rezoning of Growth Cell 3 to Putaruru Residential. Support for the rezoning of all 40ha of Putaruru Growth Cell 4, with amendment to Industrial Zone.

That the notified Planning Maps be amended, including Industrial Zone for GC4 and an additional Future Growth area.


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Opposition to Designation for Roading, D59 proposed on Planning Maps 20 and 22. Corrections were required to Map 22 as part of notification. In particular the “Extent of Urban Growth Cell” key as follows (strike through to be removed / bold to be added):

- Land to be re-zoned from Putaruru Business Rural Residential to Putaruru Residential

- Land to be re-zoned from Rural to Residential Putaruru Business

Location of the proposed Designation D59 is missing from notified Map 22. In line with South Waikato District Council’s strategic assessment of the proposed growth plan for Putaruru, the Submitter requests inclusion in the Planning Maps (Map 22) of an addition Future Growth Area located between proposed Growth Cells 3 and 4.

5 PROCEDUAL MATTERS

5.1 The Submitter could not gain an advantage in trade competition through this submission.

5.2 The Submitter wishes to be heard in support of this submission.

5.3 The Submitter would consider presenting a joint case with any party seeking similar relief.

5.4 The Submitter agrees to participate in mediation or other alternative dispute resolution, and would be pleased to discuss the content of this submission with Council staff, if required.


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Michael Kemeys Rebecca Perrett Development Director Date: 24 June 2020 Principal Planner Date: 24 June 2020 On behalf of DPS Developments Limited Address for Service: DPS Developments Limited C/- Veros Property Services PO Box 89 Second Avenue TAURANGA 3110 Attention: Michael Kemeys Telephone: 027 569 7449 Email: [email protected]

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SUBMISSION BY DPS DEVELOPMENTS LIMITED ON PUBLICLY ... · ON PUBLICLY NOTIFIED PROPOSED PLAN CHANGE...

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