Update – September 14th
We submitted the Newtown Residents’ Submission on the Proposed District Plan on Monday 12th September. Here is a copy.
This plan, which is open for submissions until Monday September 12th, is the penultimate stage of the creation of a new District Plan for Wellington. The final stage will come next year when the hearings about the submissions have concluded and the District Plan Hearings Commissioners have reported back to Wellington City Council. After the resolution of any appeal processes the PDP will become the operative District Plan. It is important to note that submitters have no right of appeal to the Environment Court on parts of the plan related to housing intensity, and it is expected that these will be in force by the end of 2023.
From 2017-2019 there were the Our City Tomorrow and Planning for Growth consultations, which led to the conclusion that the city should grow ‘up not out’ – that is, increased density in the inner city. We were in agreement with this, and have long advocated for increasing density along the ‘growth spine’ of Adelaide Rd and Riddiford St.
The draft Spatial Plan was developed in 2020, which led to the final Spatial Plan in 2021 and the draft District Plan towards the end of 2021. The push for increased density was given extra momentum when the Government released the National Policy Statement on Urban Development in 2020 (NPS-UD) which decreed that City Councils in ‘tier 1’ cities must enable at least 6 storey developments within ‘walkable catchments’ of the edge of the centre city and town centre zones, as well as from the stops on mass rapid transit routes. All of the subsequent plans allowed for wide spread high density developments in inner city suburbs, including Newtown, Mt Cook and Berhampore.
These requirements for intensification were extended further when the Resource Management (Enabling Housing Supply and Other Matters) Amendment Act 2021 added the rule that 3 houses of 3 storeys can be built on any section, so long as the total coverage is no more than 50%.
The only decision making powers that local councils have about these Government directives is that there can be ‘qualifying matters’, which are described in clauses 3.31, 3.32 and 3.33 of the NPS-UD, found on p26 of this PDF of the Policy. Qualifying matters allow Councils to modify the required building height or density. Wellington City Council has agreed to do this by designating ‘character precincts’ where a resource consent would still be required for the demolition of pre-1930s dwellings and new building heights are restricted to 11m – i.e. 3 storey buildings. Auckland City Council is also considering including other matters, such as view shafts and significant ecological areas, but they are still at an earlier stage of their District Plan process.
There has been considerable debate in Council about the extent of the character precincts and the extent of the ‘walking catchments’. Another contentious issue is whether or not the Johnsonville train counts as ‘mass rapid transit’; most recently the Council decided that it doesn’t, because of its limited single track capacity. The Proposed District Plan contains the final decisions of WCC about these matters. In the current operative District Plan all pre 1930s dwellings in inner city suburbs need a resource consent for demolition, and in the PDP the ‘character precincts’ reduce this to less than 30% of the previous protections. Elsewhere demolition is permitted and the allowed building heights are 21m – i.e. 6 storeys – or, for those areas of Newtown and Berhampore that are outside the ‘walkable catchment’, 14m – i.e. 4 storeys. The walkable catchment in the Draft District Plan was 15mins walking, which was reduced to be 10mins in the PDP. If or when Lets Get Wellington Moving decides on mass rapid transit through Newtown to Island Bay the ‘walkable catchment’ will also be measured from the MRT stops, increasing the area of the high density zones.
We expect that there will be a variety of submissions on the PDP, both to increase and to decrease both the character precincts and the walking catchments – depending on whether the submitter wants to maximise the land available for development, or believes that it is possible, with good planning, to create enough new developments to meet the housing need for the foreseeable future without allowing random developments through the whole area.
The Newtown Residents’ Association is in the latter camp. Ever since the NPS-UD was released we have been saying that this is a blunt instrument that doesn’t take local conditions into account. The amount of land that has been designated for high or medium density development is deliberately much bigger than is actually necessary, with some suggestions that only 14% of this land will actually be developed. This isn’t good news for the existing community, as this leaves 86% of the neighbourhood severely compromised. 4-6 storey developments amongst low rise homes will inevitably have damaging effects on existing homes, due to dominance, loss of privacy, loss of sunlight, and wind effects. We have made several submissions about this during the various iterations of the plan, with almost no effect. However there was one matter which the Council agreed to, and that is to have some shade protection for open space parks, such as Carrara Park and Mercy Park.
It is important to know that we are not against increasing housing and housing density. Instead we are for planning about where well designed multi unit developments are best situated. There are some good examples of this among the housing provided by Wellington City Council and Kāinga Ora – the 8 storey Newtown Park Apartments are in a good position, the Regent Park Apartments are exemplary and the new Kāinga Ora development being built in Owen St fits well into its environment. There was a whole plan developed by local architects Red Design demonstrating how 2,000+ new homes could fit within the Newtown suburban centre, which has been described previously in this website – see here – this entry also includes a link to our original 2019 submission to Planning for Growth, when we were a lot more optimistic about planned development. It could be contrasted with our most recent submission to the Draft District Plan.
We will submit to the PDP along the same lines as our previous submissions. This time, for the hearings next year, we will be gathering evidence and expert witnesses to back up our concerns. It is important to make submissions about aspects of the plan which you approve of, as well as those you would like to change, so we will be in favour of continuing character precinct protections and the reduced walking catchments. We also think the shade protection for open space parks mentioned above, which is found in the PDP section on standards for high Density Residential Zones – standard SR3.4 – needs strengthening so that it doesn’t just apply to buildings directly adjacent to a Park – buildings across the street can also cast a lot of shade.
The Wellington City Council web page about the Proposed District Plan is extremely informative and gives a lot of information about how to make a submission. There is a particular format to follow so look at this carefully. There is also access to a free independent planner who will answer your questions and can assist with your submission. Contact Friend of submitter, Emily Bayliss, at firstname.lastname@example.org or call 027 803 0080.
For visual aides to understanding the Proposed District Plan there is a recorded webinar on youtube https://www.youtube.com/watch?v=d6FS84DPHkU
and also a slide show, originally a presentation to LIVE WELLington by Adam McCutcheon from Wellington City Council.
Remember – you only have until 12 September to make your submission.