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IN THE MATTER
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IN THE MATTER
Page 1
INTRODUCTION
1.
2.
I have 13 years professional experience, including nine years in the traffic engineering
and transportation planning consultancy field in New Zealand.
I am an Affiliate
I have been employed by Flow for five years and before that I was a Senior
Transportation Consultant at Traffic and Transportation Engineers (T2) Ltd, where I was
employed for four years. Prior to this, I worked for the former Auckland City Council as
a Project Manager. A full description of my qualifications and relevant experience is
set out at Attachment A to this evidence.
4.
I have been assisting the Auckland Council (Council) in relation to the transport related
parts of the Proposed Auckland Unitary Plan (PAUP) since August 2011.
5.
I have read and understood the Code of Conduct for Expert Witnesses contained in the
Environment Court of New Zealand Practice Note 2014 and I have complied with the
Code in preparing this evidence. I can confirm that the issues addressed in this brief of
evidence are within my area of expertise and that I have not omitted to consider
material facts known to me that might alter or detract from my opinions.
SCOPE OF EVIDENCE
6.
Page 2
7.
My evidence addresses the traffic and transportation issues in relation to the proposed
rules regarding the supply of ancillary and non ancillary parking and loading spaces.
8.
b)
An overview of the proposed approach to and rationale for the parking and
loading supply rules proposed in the PAUP.
The maximum parking rate proposed for the City centre zone.
d)
e)
f)
g)
h)
SUMMARY
9.
In summary, I support the parking loading and supply rules outlined within Rule 3.2 of
the PAUP, including the amended provisions in Attachment C to Mr Wong Tois
evidence in chief.
An increase in the Gross Floor Area (GFA) threshold used to determine the
requirement for a loading bay for retail and industrial activities.
BACKGROUND
10.
In 2011 Flow was commissioned by Auckland Council to recommend standards for the
supply of parking and loading spaces for inclusion in the Unitary Plan. I acted as lead
transport planner and project manager for the life of the project.
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11.
In developing the standards summarised in the Flow report1 guidance was obtained
from:
a)
b)
A literature review of existing best practice with regard to parking and loading
supply rules, including studies already completed by the Legacy Councils and
international examples.
c)
The outcomes of a workshop held with Council officers who are experienced with
the application and outcomes of the existing parking and loading supply rules.
12.
At the same time, Transport Planning Solutions Ltd (TPS) was commissioned to
complete a similar piece of work for the Auckland City Centre, and outlined their
findings and recommendations in a report dated 25 January 2012.
13.
Further to the completion of both these pieces of work, Flow was then commissioned
to complete additional work on the parking rules proposed for the City centre fringe.
This work involved further consultation with officers from Auckland Council and
Auckland Transport and analysis of parking supply rule options specific to the fringe
area. The findings of this further work are summarised in the Flow report2 and are the
basis for the proposed rules of the City centre fringe overlay. Again, I was responsible
for the completion of this work.
14.
The reports completed by Flow and TPS were used as the base for developing the
parking and loading rules included in the draft PAUP. The Section 32 Analysis reports
prepared by Council on Accessory3 and Non Accessory parking4 for the PAUP outline
Councils decision making process.
15.
The recommended parking and loading supply rules developed following this review of
relevant material are consequently considered a robust set of default rules,
appropriate for inclusion in the Unitary Plan.
Unitary Plan Parking Standards: Number of Parking and Loading Spaces Required, January 2012, Ref
R1B120117
2
Unitary Plan Parking Standards: Auckland City centre Fringe, June 2012, Ref R1C120629
3
http://www.aucklandcouncil.govt.nz/EN/planspoliciesprojects/plansstrategies/unitaryplan/Documents/Sectio
n32report/2.9%20Accessory%20parking%20v2%202013-09-17.pdf
4
http://www.aucklandcouncil.govt.nz/EN/planspoliciesprojects/plansstrategies/unitaryplan/Documents/Sectio
n32report/2.38%20Non-accessory%20parking%20v2%202013-09-17.pdf
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
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16.
Flow was re-engaged by Council following the release of the draft PAUP and
subsequently reviewed a number of the early submissions, providing technical support
to Council prior to the release of the PAUP.
17.
Since the start of 2015 I have been working with Council with respect to reviewing the
submissions received, consultation and mediation with affected parties and preparing
position papers and evidence in support of the technical matters with respect to Topics
43 and 44.
The PAUP provides for off-street parking through accessory parking (i.e. on-site parking
required or permitted in association with development on the same site) and nonaccessory parking (i.e. parking which is provided as the primary activity on the site
which may be available to the public). The management of accessory parking can
involve the application of parking maximums (i.e. a limit or cap on the amount of
parking provided) and parking minimums (i.e. a requirement to provide a minimum
amount of parking). Where parking maximum rules apply without parking minimum
rules there is no requirement to provide any parking and conversely where minimum
parking rules apply without parking maximum rules there is no limit on the amount of
parking (in terms of the parking rule).
19.
A review of best practice literature5 reveals the removal of minimum parking rates and
the application of maximum parking rates are associated with the following benefits:
a)
Including Litman (2007) Parking Management Strategies, Evaluation and Planning, Victoria Transport Policy
Institute, Marsden (2006) The evidence base for parking policies a review , Journal of Transport Policy and
Shoup (1999) The Trouble With Minimum Parking Requirements, Transportation Research Part A Volume 33.
Page 5
b)
Encouraging the use of public transportation and walking and cycling through
reducing parking supply, allowing the true cost of parking to be realised and
encouraging intensification.
c)
Improving
housing
affordability
through
not
requiring
residential
e)
The above points are supported by the evidence of Joshua Arbury, Stewart Donovan
and Ian Munro.
20.
To help achieve the aims and objectives of the Auckland Plan6, the PAUP extends the
areas in which minimum parking rates are removed and maximum parking rates are
applied. This approach currently applies to the Central Area as well as to various
extents in recent plan changes to the Legacy District Plans including Massey North7 and
Hobsonville Village8. Other centres such as New Lynn9 and Newmarket10 applied
(reduced) parking minimums and maximums except on smaller sites where parking
minimums are removed.
21.
The PAUP proposes extending the approach of removing minimum parking rates and
applying maximum parking rates to the Metropolitan centre, Town centre, Local centre
(other than those classified as Rural Satellite Centres11), Mixed Use, Terraced Housing
and Apartment Buildings (THAB) zones as well as the City centre fringe overlay.
Page 6
22.
Parking in excess of the maximum or below the minimum rate is allowed for in the
PAUP as a restricted discretionary activity.
23.
24.
The Metropolitan, Town centre, Local centre and City centre fringe areas have all been
identified for growth and intensification and have land use policies and rules enabling
this development.
proximity to the 2022 Frequent Services Network (FSN)12. The THAB and Mixed Use
zones are located in close proximity to the centres and have also been identified for
growth and intensification. It is for these reasons that these zones have been selected
for the removal of minimum and the implementation of maximum parking rates.
25.
In all other zones (ie all except the City centre, Metropolitan centre, Town centre, Local
centre (other than those classified as Rural Satellite Centres13), Mixed Use, THAB zones
as well as the City Centre Fringe overlay), the minimum parking rates have been
retained (albeit reduced) to reflect the fact that alternative transport options are not
necessarily available and increased density is not anticipated and to such an extent in
these zones.
26.
27.
This approach also provides some comfort to Auckland Transport that any resources
which may be required to manage on street parking can be concentrated in and
around centres.
12
Defined in the Auckland Regional Public Transport Plan (2013) as where public transport services will be
available in 15 minute frequencies between 7 am and 7 pm by 2022
13
Those being Helensville, Kumeu-Huapai, Pukekohe, Warkworth, Wellsford, Karaka, Kaukapakapa, Leigh,
Matakana, Riverhead, Snells Beach, Te Hana, Waimauku and Waiuku
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
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28.
The exception to the general approach is office activities, which are subject to a
maximum parking rule regardless of location (with a more restrictive maximum applied
in the City centre and City centre fringe overlay for reasons discussed below).
Maximum and minimum parking rates apply in all of the zones where other activities
are subject to minimum parking rates. This is to reflect the fact that trips generated by
office activities contribute significantly to travel during peak times and tend to be
easier to convert to public transport or walking and cycling trips. The rule aims to
avoid office activities locating away from centres in order to gain additional parking
and thus encourage office activities to locate adjacent to centres and therefore public
transport.
The maximum parking rates proposed are very similar to the minimum parking rates
included in the operative District Plans.
30.
A review of the existing District Plans reveals the current minimum parking rates are
very similar to rates provided in industry standard documents14.
These industry
documents are widely used to predict parking demand for different land use activities.
The rates provided are based on parking surveys undertaken in NZ, Australia and the
US, predominantly in the 1990s, and usually from suburban locations which provide
free parking15. These rates generally represent an average of between 85 % and 100 %
of regular peak on site parking demand recorded at these sites.
31.
Therefore, in theory, maximum rates proposed at these levels generally limit the
supply of parking to between 85 % and 100 % of peak parking demand.
32.
It is noted that general parking rates are only ever an average of parking demand
observed in particular surveys and the range of data can be large. As a result in many
cases the proposed rate will provide for significantly more or significantly less than
85 % of peak parking demand.
33.
However, as these rates are generally based on parking demand data from suburban
sites with free parking and little access to alternative transport options I consider the
14
Transfund New Zealand Research Report No 209, Trips and Parking Related to Land Use (2001 and updated
2012, NZ), The Roads and Traffic Authority (RTA), Guide to traffic Generating Developments, version 2.2 (2002,
Australia), The Institute of Transportation Engineers (ITE) Manual, Parking Generation (2004, US)
15
Austroads, 2008, Guide to Traffic Management, Part 11, Parking
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
Page 8
rates to provide a generous upper limit for land use activities located within or close
to centres. This allows developers to determine the most appropriate level of parking
for their land use activity, whist also providing protection from significant parking over
supply.
34.
The proposed maximum parking rates are slightly less restrictive (ie allow more
parking) than the current maximum rates included in Plan Change 14 and 15 for the
Hobsonville and Massey North town centres and Plan Change 196 for Newmarket. This
is as a result of consultation with stakeholder groups during the preparation of the
PAUP.
The less restrictive rates also reflect the fact that the
proposed maximum rates will be applied to a wide variety of centres throughout the
Auckland region, and therefore need to provide greater flexibility.
35.
The number of land uses for which parking rates have been included has also been
significantly reduced in the PAUP to simplify the rules as well as to reflect the fact that
the maximum rates are proposed to provide an upper limit to parking supply rather
than prescribe the number of parking spaces which should be provided for specific
activities.
36.
Overall, it is my opinion that the proposed maximum parking rates are likely to be
generous and will not significantly restrict parking supply for land use activities.
Where they are proposed, the Minimum parking rates are also based on the existing
rates included in the operative District Plans. As outlined previously, in most cases the
car parking rates included in the existing District Plans are based on the industry
standard rates which represent between 85 % and 100 % of regular peak parking
demands from suburban sites.
38.
Feedback from Council officers16 and my own experience gained from preparing and
assessing traffic impact assessments for resource consents, reveals that in some
locations this has resulted in either:
16
Feedback from Council officers in a workshop held in September 2011 and a subsequent meeting with
Angela Crang, Team Leader Consents Auckland Council
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
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a)
An oversupply of parking: for example cafes and taverns have been known to
lease parking in order to avoid a consenting process but the parking is not
required for the business to operate, or parking is provided but not well
utilised.
b)
c)
39.
Whilst the aims and objectives of the revised parking rates primarily relate to the
provision of parking in areas of growth and intensification, many are also relevant to
the region as a whole, specifically improving housing affordability, decreasing
development costs and encouraging active modes of transportation. It is therefore
considered that reducing minimum parking requirements outside of centres will also
support these aims and objectives.
40.
41.
The figure of 75 % has been selected on the basis that it reflects only a small increase in
potential demand for Auckland Transport to manage overspill effects (if any) on the
road network.
42.
As noted previously, any parking demand data is an estimate, based on the average of
the data available and there is always a margin of error when applying these averages
to specific sites. As a result, the proposed reduction in rates will not result in all land
Page 10
The reduction in the minimum rates is intended to provide increased flexibility to allow
developers to select the most appropriate parking provision for their site whilst
providing protection from a significant undersupply of parking. Therefore the rules will
allow developers to provide slightly less parking than currently, without the need to
apply for a consent.
44.
Whilst this was the general approach to selecting all rates, following the release of the
PAUP some further evidence was provided by submitters on various land use activities
which resulted in the amending of particular rates. This is discussed further later in
this evidence.
45.
The number of land uses has also been reduced to simplify the rules as well as to
reflect the fact that the minimum rates are intended to provide a lower limit to
parking supply rather than prescribe the number of parking spaces which should be
provided for specific activities.
46.
Overall, it is my opinion that the proposed minimum parking rates are appropriate as
they allow increased flexibility to developers whilst still providing protection from
significant negative effects of overspill parking in out of centre locations.
The PAUPs City centre parking rules continue the approach adopted in the operative
Auckland City District Plan Central area section of applying maximum with no
minimum parking rules.
48.
Analysis of the current City Centre transport conditions indicates that there is a need to
further manage the number of vehicles entering the city centre if additional growth is
to be achieved17. In addition, the City Centre Masterplan (2012) aims to create a more
people orientated environment for the entire City centre zone. As a result the overall
maximum parking rate needs to be reduced to limit increases in the total supply of
parking as the City centre grows.
17
City Centre Future Access Study, Auckland Transport and Auckland Council, 2012
Page 11
49.
The PAUP proposes to manage further increases in parking supply through applying a
blanket maximum parking rate of 1 per 200 m2 across the entire City centre zone. This
rate is very similar to rates used in the centres of Sydney, Melbourne, and Brisbane
which currently apply rates of 1 per 200 m2 or 1 per 250 m2 and much of the Auckland
City centre is already subject to this rate.
50.
In my opinion, this rate is appropriate given the anticipated development and the
accessibility of the City centre to alternative transport options.
This matter is
It is considered that the current methodology used in the operative District Plans of
requiring a minimum number of loading bays on the basis of the size of the site and
whether the activity handles goods or not is appropriate for the PAUP. As a result it is
proposed to require retail and industrial activities (which traditionally handle goods) to
require more loading bays than other activities which generally do not handle
significant amounts of goods. Two sets of loading rates are therefore proposed in the
PAUP.
52.
A review of industry best practice literature found limited guidance with regard to the
number of loading spaces required for a site. However, a review of the existing rates
provided in the operative District Plans for each geographical area reveal they are
similar but vary slightly, with Rodney District having the highest requirements.
53.
The feedback received from Council officers18 was that generally the requirements for
loading were appropriate with the exception of loading within town centres where it
was felt that further flexibility was required. This is consistent with my experience.
54.
As a result it was recommended that the general rates for loading spaces should
remain similar to the existing rates. In recommending a single rate for the Auckland
region, the lowest rate currently used was selected, which will result in a slight
reduction in loading requirements in the former Rodney District and Waitakere City
boundaries and little change in the other areas.
18
Page 12
55.
To recognise the fact that further flexibility is required with regard to loading in
centres, it was determined that small sites (specifically retail and industrial activities
less than 100 m2, and all other activities less than 5,000 m2) are not required to provide
a loading bay. It is noted that developers of these land uses are able to provide loading
if they wish, but that they do not have to apply for consent if they do not.
56.
This recognises the fact that small sites are generally located in centres where on street
loading or alternative arrangements may be more appropriate than an on site loading
bay. Further information on the provision of on street loading is outlined in the
evidence of Mr Scott Ebbett.
57.
During mediation, the threshold for retail and industrial activities to require loading
was increased from 100 m2 to 300 m2, to address retailers' concerns that the 100 m2
threshold was too low. In my opinion the 300 m2 threshold is acceptable as it
represents a retail activity of a size which in most cases will be able to operate with on
street loading without creating significant safety or operational effects. For retail
activities larger than 300 m2, I consider the loading operations and requirements
should be assessed on a case by case basis and therefore require a consent.
58.
Overall, in my opinion, the proposed approach for the loading provision rules is
appropriate as it continues to manage the potential negative effects of off site loading
through requiring large sites to require on site loading, whilst providing increased
flexibility to allow for situations where on street loading (or another arrangement) is
the most appropriate option.
Non accessory parking is defined in the PAUP as parking which is provided as the
primary activity on the site which may be available to the public.
60.
61.
Long stay non-accessory parking is non-complying in the city centre and city centre
fringe overlay and discretionary in the Metropolitan centre, Town centre, Local centre
and Mixed Use zones.
Page 13
62.
Short stay non-accessory parking is discretionary in all of the above zones and the City
centre fringe overlay.
63.
These proposals represent an increase in control on both short and long term nonaccessory parking from the operative District Plans. The purpose of this is to ensure
the supply of non accessory parking does not undermine the aims and objectives of the
proposed parking supply rules for accessory parking.
64.
In particular, the provision of long stay non-accessory parking is non complying in the
City centre zone and City centre fringe to align with Councils policy of maintaining the
supply of long term parking at a similar level to today to manage the negative effects of
congestion on the City centre environment and the capacity of the road network into
and out of the area (including through the City centre fringe).
This activity is
discretionary in other centres to recognise the fact that some further long stay parking
may be required to support growth in other centre locations but that this will need to
be managed in line with the particular characteristics of that centre.
65.
associated
with
congestion
(during
peak
and
inter
peak
times),
Overall, I consider the proposed activity status for non accessory parking to be
appropriate from a transport planning perspective.
As outlined previously, the PAUPs City Centre parking policy continues the approach
adopted in the operative Auckland City District Plan Central area section of applying
parking maximum with no minimum parking rules. However, parking rates for the City
centre have been simplified in that they are no longer differentiated by road type and
the overall maximum parking rate has been tightened to 1 per 200 m2 for the entire
Central city zone (i.e. less parking is permitted).
Page 14
68.
Submissions were received from some land owners within the City centre zone seeking
to retain the operative City centre parking controls based on road types which the
submitters are of the view represents a more fine grained approach to the provision of
accessory parking. These submitters are from owners of land located in areas which
are currently subject to maximum parking rates of 1 per 105 m2 or 1 per 150 m2. The 1
per 200 m2 GFA parking ratio is considered by these submitters to be too onerous and
does not take into account current and immediate future traffic and parking demands.
69.
The graduated maximum parking rates in the operative District Plan are based on the
maximum capacity of the road network during peak periods, average vehicle
occupancy and predicted public transport mode share calculated over 20 years ago.
The difference between the existing vehicle numbers and theoretical capacity of the
road network was used to calculate the maximum number of additional long stay
parking spaces which could be accommodated on the road network at that time.
70.
This rate was not applied uniformly across the area but five road types were used to
provide differentiation between the number of accessory car parks permitted for a
particular site (ranging from between 1 per 105 m2 to 1 per 200 m2 or none on Type 1
roads). The road types are based on the roading hierarchy and whether the roads are
located in identified pedestrian orientated areas or non pedestrian orientated
areas. The road types are illustrated in Figure 1 overleaf.
Page 15
71.
As can be seen from Figure 1, much of the central core of the existing central area is
already subject to a zero parking rate (Type 1 Roads) or a maximum parking rate of 1
per 200 m2 (Type 2 roads). These include roads which were then highly trafficked
and/or had a high public transport or pedestrian function. Roads with a maximum
parking rate of 1 per 150 m2 (Type 3 roads) include those which 20 years ago were
considered to be the main traffic distributors into and out of the central area including
much of Nelson Street, Hobson Street, Greys Avenue, Quay Street, Beach Road,
Mayoral Drive and Greys Avenue. Roads subject to a maximum rate of 1 per 105 m2
(Type 4 Roads) include those areas on the outskirts of the central area which at that
time were primarily undeveloped (for example Cook Street depot, Quay Park and the
Page 16
Viaduct) and therefore were granted a less restrictive parking rate to encourage
development19.
72.
Today, many of the roads into the City centre are considered to be at capacity and
there is a limited ability to provide additional vehicle capacity on the city centre road
network20. The City Centre Masterplan includes no planned roading upgrades which
increase private vehicle capacity into the City centre. As a result the principle of basing
the proposed parking rates on spare capacity on the road network is no longer
appropriate.
73.
The Auckland City Centre Masterplan indicates that by 2041 the number of employees
in the City centre will grow from around 90,000 people to between 145,000 and
160,000 people21. However, due to the existing road network capacity constraints, the
number of vehicles entering the City centre will be the same as today. Therefore,
growth in person trips will need to be accommodated through increased vehicle
occupancy and other modes such as public transport, walking and cycling. For example
the Auckland Plan (2012) aims to increase the proportion of all vehicular trips made by
public transport into the City centre during the morning peak from 47 % to 70 % by
2040.
74.
The provision of too much readily available parking not only results in more people
choosing to drive to the City centre (which will extend the peak periods of congestion)
but also increases congestion within the centre itself, making public transport, walking
and cycling less attractive options. This again works against the Auckland Plan mode
share targets.
75.
In addition, the Auckland City Centre Masterplan (2012) places emphasis on making
the City centre a desirable destination and a pedestrian friendly and attractive place to
walk around22. A high number of vehicles conflicts with this aim as it reduces the
amenity of the area, increases pollution and can increase pedestrian safety issues.
76.
Details included in the City Centre Masterplan also indicate that the existing Road
Types on which the current maximum parking rates are based on are no longer
19
Number of Parking and Loading spaces required for the City centre, TPC, 25 January 2015, plus further
discussions with TPC in May 2015
20
City Centre Future Access Study, Auckland Transport and Auckland Council, 2012
21
Auckland City Centre Masterplan, 2012, page 47
22
Auckland City Centre Masterplan (2012), Outcome 1 and Outcome 6
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
Page 17
relevant. For example the plan states that Quay Street (which is currently classified as
a Type 3 road and therefore one of the less restrictive parking rates) will progressively
change over the life of the plan from a car dominated road to an important meeting
and greeting place and a world class waterfront boulevard23. As a result encouraging
more cars into this area based on the role of Quay Street is no longer seen as
appropriate.
77.
Similar plans are also described in the Masterplan for Hobson and Nelson Street. It is
also noted that these plans are in addition to the already implemented streetscape
improvements to roads such as Fort Street, Federal Street and OConnell Street, which
are also subject to less restrictive parking rates in the current road type hierarchy.
78.
Improvements to public transport in the last 20 years have also resulted in all of the
city centre having excellent access to public transport.
In addition, planned
improvements (such as the City Rail Link) combined with the existing and planned
walking and cycling improvements will increase this accessibility further.
79.
Overall, the approach of graduating the parking rates based on the existing Road Types
is no longer seen as appropriate as the PAUP does not map or indicate a road hierarchy
in the City centre (reflecting acceptable levels of traffic volumes on different roads).
In my opinion, the current levels of congestion on the road network, recent and
planned improvements to public transport and the streetscape improvements outlined
in the City Centre Masterplan result in the existing Road Types now being irrelevant
and there is now a need to treat the City centre as one zone.
80.
Given the information outlined above, Councils parking strategy for the City centre
proposes that the number of long stay parking spaces located within the City centre
should remain at roughly the same level as today, even with the planned growth in
place. To achieve this, the supply of accessory parking for new developments needs to
be further restricted. It is therefore proposed to adopt the most restrictive current
parking rate used in the central area and use this for the entire City centre. The
exception is Type 1 Roads and the newly developed Shared Zone streets on which no
additional parking will be permitted.
23
Page 18
81.
Accommodating an additional 65,000 employees24 at one car parking space per 200 m2
GFA would increase the total GFA in the City centre by around 1.04 million m2
(assuming 16 m2 per employee25). This allows a maximum of an additional 5,200
ancillary parking spaces. Even assuming that some of these parking spaces would be
allocated as visitor parking (ie not used for travel during peak times), this amount of
additional traffic into the City centre will not be able to be accommodated within the
traditional peak periods.
82.
83.
The rate of 1 per 200 m2 is very similar to the maximum rates used in Melbourne,
Sydney and Brisbane, all of which have maximum parking rates of between 1 per
200 m2 and 1 per 250 m2 in their CBD areas and much of the Auckland City centre is
already subject to this maximum rate. Therefore the proposed rate is not, in my view,
significantly onerous and represents a balance between addressing the existing and
future traffic capacity issues, the aims and objectives of the City Centre Masterplan and
the needs of individual businesses.
84.
It is acknowledged that the Wynyard Quarter and Port Precincts have their own
parking standards to address site specific access limitations and capacity constraints
and, in the case of Ports, a specific and unique land use and transport situation.
However, these rates have been determined following significant transport planning
analysis. If submitters consider that additional parking on top of that proposed in the
PAUP is required and can be accommodated then they can apply for this parking as a
restricted discretionary activity consent, the effects of which can be assessed at that
time.
24
Assuming a total of 155,000 people are employed in the City Centre by 2041, being a figure between
145,000 and 160,000 people as determined in the Auckland City Centre Masterplan, 2012
25
Zoltan Moricz, 2009, Statement of Evidence from the Auckland City Council Plan Change 235 hearing, CBRE,
2
states that the average office space per worker in the Auckland CBD in 2008 was around 16 m
Page 19
85.
Overall, based on the evidence available, I consider the maximum parking rate
proposed for the City centre zone is appropriate for all of the City centre zone.
As outlined above, minimum parking rates are not proposed for residential activities
located in the City centre, Metropolitan centre, Town and Local centre, Mixed Use and
THAB zones, as well as the City Centre Fringe parking overlay. In all other residential
zones, minimum parking rates apply, with the Mixed Housing Urban zone being subject
to both minimum and maximum parking rates.
87.
Submissions were received regarding the removal of minimum parking rates from
residential zones and specifically the Mixed Housing Suburban and the Mixed Housing
Urban zones. The majority of submissions relate to the impact of minimum parking
rates on housing affordability.
88.
As outlined previously, the approach used in the PAUP has been to concentrate the
removal of minimum parking rates on areas where intensification is proposed and
where alternative transport options are available or will become increasingly available
as intensification occurs.
89.
Through mediation, the minimum parking rate in the Mixed Housing Suburban Zone
and all other areas was reduced to one parking space for all dwelling sizes. In my
opinion, the reduced minimum is an appropriate balance between the benefits of
removing minimum parking rates, the relative level of intensification associated with
these zones and the likely alternative transport options available away from centres.
90.
The arguments for the removal of minimum parking rates in the Mixed Housing Urban
Zone are stronger than the Mixed Housing Suburban zone given the relatively higher
level of intensification associated with this zone. However, as with the Mixed Housing
suburban zone, there are risks associated with the complete removal of minimum
parking rates due to the location away from centres.
91.
Following a review of the submissions, the transport case team reconsidered the
proposed rates for this zone. On balancing the issues, it was determined to remove
minimum parking rates for studio dwellings, but retain minimum rates for all other
Page 20
A submission has been received outlining the effects that garages and car-parking can
have on special character areas. The Special Character (heritage) case team is
proposing to amend the underlying zone minimum car parking requirements to help
retain or enhance special/historic character values.
discussed with the Special Character team is to not have a parking requirement (i.e. no
minimum) for Special Character sites less than a certain site area to support the
outcome of maintaining and enhancing the coherency and special streetscape
character of the historic parts of Auckland. From a transport planning perspective,
much of the special character overlay is located in areas around centres and therefore
this approach is unlikely to result in any significant concern.
93.
Overall, I consider the extent of residential areas in which minimum parking rates have
been removed is appropriate from a transport planning perspective and represents the
transitional approach of the PAUP parking standards as a whole.
Submissions were received on removing the proposed minimum parking rates from
activities located within some of the Special Purpose Zones including the Tertiary
Education, Healthcare facility and Major recreational facilities.
95.
96.
Some of the land located in these Special Purpose zones is located adjacent to centres
and on the FSN and as such alternative transport options may be available. However,
there are exceptions to this and there is no requirement for any future zoned land to
provide alternative transport options.
97.
In addition there is a wide range of activities, some of which are very large, which are
permitted within these zones which can have varying levels of intensification and
characteristics influencing parking demands.
Page 21
98.
It may be appropriate for some of these activities located within these zones to provide
less parking than the minimum rate but in my opinion these issues are best analysed
on a case by case basis. As a result I consider the Auckland wide parking rates should
apply as a default rate with further analysis undertaken at the precinct level to
determine an appropriate parking rate as required on a case by case basis.
Neighbourhood Centres
99.
Consideration has been given to the removal of minimum rates from the
Neighbourhood Centre zone as it is acknowledged that in some locations there may be
benefits associated with the ensuring efficient use of land.
For example in
102.
Submissions have been received seeking the removal of minimum parking rates from
Warkworth and Pukekohe due to the size of these towns, planned growth and the
urban design benefits associated with their removal.
103.
I note that both Warkworth and Pukekohe have been identified for growth in the
Auckland Plan. However, these towns have different characteristics to the majority of
the Centres in Auckland as they predominantly serve surrounding rural areas. Whilst
both towns have some public transport options, neither town is anticipated to be part
of the FSN by 2022, and the majority of the surrounding rural areas will have no
26
Those being Helensville, Kumeu-Huapai, Pukekohe, Warkworth, Wellsford, Karaka, Kaukapakapa, Leigh,
Matakana, Riverhead, Snells Beach, Te Hana, Waimauku and Waiuku
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
Page 22
alternative to private vehicles. For this reason I consider that the existing proposal of
maintaining minimum parking rates should remain in these centres.
Taverns
104.
Submissions were also received requesting the removal of minimum rates from taverns
for the reason that minimum parking rates may encourage drink driving. I am not
aware of any evidence which explicitly links minimum parking rates to encouraging
drink driving. However, on further review of the evidence, it was determined that the
land use of taverns could be classified under standard food and beverage retail. This
results in a reduction in the minimum parking rate proposed, which in my opinion is
appropriate.
106.
In my opinion there is a particularly strong case for the proposed removal of minimum
parking rates for residential activities within these zones due to both the intensification
proposed and the accessibility to alternative transport options.
The removal of
As outlined previously, the removal of minimum parking rates will not result in all
developments providing insufficient parking. The intention is to provide increased
flexibility to let developers determine the most appropriate parking rate for residential
developments. I would expect that in areas where on-street parking is constrained
developers will still wish to provide some on-site parking where this will be desirable
for future owners.
Page 23
108.
Specific concern has been raised by residents located within the City centre fringe
overlay. Competition for on street parking is high in areas such as Freemans Bay due
to heritage properties having a low supply of on site parking, the mixed use nature of
development and the proximity of the area to the City centre, all of which result in a
demand for commuter parking.
109.
It is considered that this on street parking resource can be managed to be used more
efficiently through the use of Comprehensive Parking Management Plans (CPMPs) and
tools such as Residents Parking Permits. This is discussed further in the evidence of Mr
Scott Ebbett. It is noted that these areas are also well served by public transport and
have good walking and cycling access to the City centre and surrounds.
The main reason for objections to the removal of minimum parking rates for other
activities, such as retail and office activities in Centres, Mixed Use and the THAB Zones
again relate to concerns regarding parking overspill effects.
111.
For existing residents, concerns relate to the ability for them to be able to use the on
street parking. There is particular concern in areas where there is already a high
demand for on street parking due to character housing having limited off street parking
and/or due to the proximity to offices such as in Mixed Use Zones or areas surrounding
the City centre. For Business Associations or members of the Key Retailers Group,
concerns relate to users of surrounding land uses parking in their private car parking
areas which they provide for customers, as well as concerns regarding surrounding
communities objecting to their developments due to increased competition for on
street parking.
112.
113.
For business owners or owners of large retail activities, the concern relates to the
potential for people to utilise their private car parking areas, affecting their businesses.
I agree that there is potential for the increased demand for on street parking to result
in people parking in neighbouring private car parks which are accessible by the public
Page 24
(such as supermarket car parks etc), although I am not aware of any evidence as to the
extent of this problem or how it impacts on business.
114.
For owners of private car parking areas there may be an increased need to manage this
parking resource through similar measures as proposed by Auckland Transport, such as
implementing time restrictions or introducing a charge. It is noted that this is currently
done at some of the larger shopping centres in Auckland (for example Newmarket).
LIMIT APPLICATION OF MAXIMUM PARKING RATES TO THE CITY CENTRE AND FRINGE
115.
A number of submission points were received from key retailers and businesses
seeking amendments to limit the application of parking maximum rules to areas well
serviced by public transport with a high proportion of peak period commuter trips
which they consider to be limited to the City centre and City centre fringe. A variation
was also proposed to only apply maximums to the City centre and apply minimums and
maximums to other areas to recognise that most activities will generate some parking
demand and that some of this demand should be met on site so that parking
requirements are not externalised (to adjacent streets and surrounding sites).
116.
The reasons provided for the objection to the general introduction of maximum
parking rates mainly relate to a concern that a reduction in on site parking will result in
an increased demand for on street car parking and other private parking areas. This is
covered in the above section.
117.
However, in addition to this, the Key Retailers Group has also submitted that maximum
parking rates should not apply to retail activities as the majority of trips to retail are
currently, and will continue to be made by, private vehicles. The submissions state
that it is not appropriate to manage parking supply to retail activities as trips made to
these land use activities generally occur outside of the peak times and therefore do not
contribute to peak hour congestion. As a result the submissions seek that retail
activities are only subject to maximum parking rates in the City centre Zone and the
City centre fringe overlay.
118.
I agree that private vehicle trips are currently the predominant transport mode for
retail trips and that many retail trips occur outside of peak times. However, I do not
support the opinion of the submitters that alternative transport options to private
vehicles are not suitable for trips to retail activities. Whilst some retail activities (for
Page 25
example bulky goods stores) may require private vehicle use in certain circumstances,
it is noted that options around on line shopping mean that it is no longer a
requirement.
119.
I also consider there is significant potential for an increase in walking, cycling and
public transport travel to retail activities for the following reasons:
a)
Auckland, car ownership is lower. For example parts of the Auckland City
Centre up to 60 % of households do not own a car, in Newmarket the figure is
15 %, in Freemans Bay 14 % and Parnell 9 %. By implication, these households
access retail activities without the use of a private vehicle.
b)
A number of submissions were received on the parking rates for specific land used
activities and locations. This includes a reduction in the proposed minimum parking
rates for industrial activities, warehousing and storage (currently classed with industrial
activities), industrial activities in general, large format retail, residential dwellings and
other activities based on specific locations. There were also submissions requesting
specific rates for additional land use activities such as supermarkets, dog day care
centres, drive through facilities, retail when attached to service stations and schools
when located within places of worship.
27
28
Land Use Impacts on Transportation, Victoria Public Transport Institute, Todd Litman et al, April 2015
See Evidence presented by Don Munro for the Regional Policy Statement B3.3 Transport, October 2014
Page 26
121.
Increases in the proposed minimum and maximum rates were also requested for
residential units, retail, town centres and care centres, due to concerns with overspill
parking effects in the surrounding residential streets. An increase in the maximum rate
was also requested for offices proposed for the City Centre Fringe Overlay.
122.
As outlined previously, the proposed minimum and maximum rates for different
activities generally reflect a reduction in parking requirements from those included in
the operative District Plans. There has also been a significant reduction in the number
of activities proposed, with the aim of simplifying the proposed rules and providing
increased flexibility. Generally, where it was considered there is insufficient best
practice evidence for a separate parking rate for a land use classification, it has been
removed.
123.
For land use activities which are considered to be quite specialised or which may be
subject to location specifics which may influence parking demand, it is considered that
the current approach of a general parking rate is appropriate. However, based on the
submissions received, I further considered the proposed parking rates for warehousing
and storage, sports and recreation activities, large format retail and supermarkets.
Further details are provided in the following sections.
Submissions were received from industrial land activities and in particular warehousing
and storage land uses indicating that the proposed minimum parking rate was too
onerous. For warehousing and storage, I agree that the evidence indicates a reduced
rate for this type of industrial activity is appropriate, due to the fact they these facilities
tend to have a large GFA but attract few trips. The minimum rate has therefore been
reduced from 1 per 50 m2 to 1 per 100 m2 or 0.7 per full time employee whichever is
the lesser. For other industrial activities the existing rate is proposed to remain as 1
per 50 m2 or 0.7 per full time employee whichever is the lesser.
Page 27
126.
I do not have access to any specific additional data regarding car parking demand for
sports and recreational activities in Auckland. The proposed rate for club rooms
(currently a minimum of one space per five people the facility is designed to
accommodate plus 12.5 spaces per hectare of land used for organised sport and
recreation) represents an overall reduction in minimum parking rates from the current
operative District Plans. The existing rates vary according to location but generally
require one parking space per three or four people the facility is designed to
accommodate for the club room. The requirement for the playing fields is in line with
the current Isthmus District Plan which requires 12.5 spaces per hectare for medium
intensity activities.
127.
Feedback was sought from Councils Sports Field Technical Working Group who agreed
that some sports field users are utilising public transport and cycling to training and
competition games at the weekend, although the vast majority of users are still driving
to and parking at facilities. Concerns were raised regarding potential on street parking
issues around parks with neighbours being affected should minimum parking rates be
reduced significantly. This may become an issue in out of centre locations where
Auckland Transport does not specifically manage parking overspill effects.
128.
In my opinion, the proposed parking rates, which include some reduction from the
existing, are appropriate given the evidence available.
Submissions were received from operators of some large format retail stores which
traditionally sell bulky goods, that the proposed minimum parking rate of 1 per 25 m2 is
too onerous. I have reviewed the evidence available and agree that a minimum rate of 1
per 45 m2 is appropriate, given the large GFA required to support these types of stores.
Submissions have been received from other large format retailers such as
supermarkets and discount department stores (for example the Warehouse) who are
concerned with the proposed maximum rate of 1 per 20 m2 will not let them provide
sufficient parking for their needs.
131.
The concerns raised by the Key Retailers Group were recognised during the
development of the parking rates. In particular, to recognise the fact that some retail
Page 28
uses are less suited to public transport trips than other land uses (such as offices or
educational facilities which generate a higher number of commuter trips), the
maximum rate for general retail was increased from 1 per 25 m2 to 1 per 20 m2.
132.
Following the submissions, I have reviewed some available data29 with regard to
parking supply and peak parking demand for a number of retail categories including
shopping centres and discount departments stores (as outlined in the following tables).
Table 1: Examples of Information From Supermarket Consents
Supermarket in Mangere
Land Use
Parking
The Warehouse
The Warehouse
Source
NZ Trips
Database
133.
and
It is noted that the proposed maximum parking rate only applies in centres, where
alternative transport options are available and will become increasingly available as
intensification occurs. Based on the evidence available I am comfortable that the
29
Taken from consent applications and supporting traffic impact assessments provided by Auckland Council
and industry standard documents
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
Page 29
proposed rates for general retail (being a maximum of 1 per 20 m2 in the Centre, Mixed
Use and THAB zones) provides a range in which the current parking demands for
supermarkets and discount department stores can be accommodated.
Offices in the City Centre and City Centre Fringe Area
134.
Submissions have been received on the proposed rate for offices in the City fringe area,
which are proposed to be a maximum of 1 per 60 m2, as opposed to a maximum of 1
per 200 m2 in the City centre and a maximum of 1 per 30 m2 in all other zones.
135.
The reason for the more restrictive rate in the fringe area relates to the aims and
objectives of the City fringe office overlay. The objective of the overlay is to provide
opportunities for substantial office activities in the Mixed Use zone and the Local
centre zone in areas surrounding the city centre, recognising their proximity to the city
centre and availability of excellent public transport services.
136.
137.
During early consultation on the development of the parking rates there was also
concern expressed by Council officers regarding the large difference in parking rules
between the maximum parking rates included in the City centre and the existing
minimum parking rates which are operative in the fringe areas. The concern relates to
the possibility that allowing significantly more parking in the fringe area will deter
office development in the City centre. It is also noted that many of the roads accessing
the City centre run through the city fringe area, resulting in the capacity of the road
network also being a concern in the fringe. It was therefore determined that there was
a need to apply a graduated approach to reflect the uniqueness of the fringe area due
to its close proximity to the City centre.
138.
In considering the most appropriate maximum rate I note that the existing minimum
parking rate for office activities in this area is 1 per 40 m2. Plan Change 196 reduces
this minimum to 1 per 60 m2 for Newmarket, which is located within the fringe area.
Given the PAUP objective of increasing intensive office and residential activities in the
Page 30
fringe and the existing and planned improvements to public transport services
(particularly the City Rail Link), I consider a maximum rate of 1 per 60 m 2 provides a
good balance between meeting these aims and objectives and allowing office activities
to provide sufficient parking for their needs.
139.
It is noted that the difference between the maximum rate of the City centre (being 1
per 200 m2) and the proposed rate of 1 per 60 m2 is still large (albeit a reduction from
the existing). However, on balance I consider a more onerous rate than a maximum of
1 per 60 m2 may not be appropriate in some areas of the fringe. Although these areas
have excellent access to public transport, they are generally less accessible than the
City centre zone.
Residential
140.
With regard to residential activities, the submissions relate mainly to increasing the
supply of parking to limit overspill parking effects in the surrounding residential streets
through either removing/increasing the maximum rate in the Mixed Housing Urban,
THAB, Mixed use and centre zones, or increasing the minimum rates in all other
residential zones. A submission has also been received regarding the application of
maximum parking rates for the Single House zone in the City centre fringe parking
overlay.
141.
As discussed previously, the proposed rates aim to meet the aims and objectives of the
Auckland Plan and RPS provisions, in particular housing affordability, increased density
and the increased use of non-car modes.
142.
It is my opinion that the removal of minimum parking rates for residential dwelling in
the THAB, Mixed Use and centre zones is a key policy to enable the PAUP to achieve
these aims and objectives. The reduction in minimum rate for residential dwellings in
all other areas is also considered to be an important element of the proposal. I
therefore do not recommend any change to these rules.
143.
Page 31
The maximum parking rates proposed (being one parking space for studio and one bed
units and two spaces for dwellings with two bedrooms or more) are not considered
onerous, given they are only to be applied in areas with good access to public
transport. The proposed maximum parking rates in these locations again act as a
safety net to ensure the desired level of intensification and mode shift is achieved in
these locations.
Submissions have been received regarding the activity status of non accessory parking
in the City centre and City centre fringe area. The relief sought is to lessen the activity
status of non-accessory long term parking from non complying to discretionary or
restricted discretionary.
146.
As outlined previously, the parking strategy for the City centre proposes that the total
number of long stay (both ancillary and non ancillary) parking spaces located within the
City centre should remain at roughly the same level as today, even with the planned
growth in place. This is because long stay non accessory parking induces more private
vehicle travel into the centre.
147.
To achieve this, the supply of accessory parking for new developments needs to be
further restricted. The restriction of additional non accessory long stay parking is also a
key element of this approach.
148.
The restriction of long stay non accessory parking in the City centre fringe area is also
considered a key element of this approach as many of the arterial routes running into
and out of the City centre run through the fringe area. Therefore additional traffic on
these routes will result in increased congestion and an extension to the peak
congestion periods.
149.
In addition, the proximity of the fringe area to the central city means that controlling
long stay accessory parking in the fringe area is also important due to its potential
30
Land Use Impacts on Transportation, Victoria Public Transport Institute, Todd Litman et al, April 2015
Page 32
impact on the mode share targets for the City centre. People driving to the fringe and
then walking or catching the bus from there is not a desirable outcome as it does not
relieve congestion on the main arterial routes into the city centre or enable
intensification in the city fringe area.
150.
151.
This is of particular importance in the City centre and City centre fringe due to the
levels of existing congestion already being experienced. Acknowledging that provision
of short stay parking is intended for visitors who are less likely to travel in the peak
periods, an additional assessment was completed by Flow31 to understand the capacity
of the network in the interpeak periods.
152.
This assessment reveals that some increase in traffic flows can reasonably be
accommodated during the interpeak on some streets, although the traffic flow profiles
on other streets are already somewhat flatter, meaning there is limited capacity for
increases in traffic flow during the interpeak periods. Additional congestion during the
interpeak periods can have significant negative effects on business trips around the city
during the day, as well as people visiting the centres for entertainment etc.
153.
In my opinion, it is therefore prudent to ensure that Council has significant control over
the future locations of any additional short term parking, to ensure any wider negative
effects (on top of the more localised effects) can be assessed and managed.
154.
It is noted that special zones or precincts can provide a different activity status for a
specific site or location which may include non-accessory parking. This process allows
for an activity status for non-accessory parking to be determined which is informed by
31
Technical Note: Future Traffic Flows in the Auckland City Centre, Flow Transportation Specialists, 26 April
2012
Evidence of Mairi Joyce FINAL - 26271780 v 1.DOCX
Page 33
My evidence addresses the traffic and transportation issues in relation to the proposed
rules regarding the supply of ancillary and non ancillary parking and loading spaces.
156.
Overall, I support the proposed parking and loading supply rules including the
amendments made outlined in Attachment C to Mr Wong-Toi's evidence in chief.
Mairi Joyce
2 June 2015
curriculum vitae
Mairi Joyce
Associate
MA HONS (Geog)
MEngSt (Transportation)
Committee Member of the IPENZ Transportation Group
Affiliate member of IPENZ
Areas of Expertise
Career Summary
Professional History
MJ CV 150529
Developing recommendations for the parking provision rules for the Proposed Auckland Unitary Plan
(PAUP). This work involved research into international best practice, analysis into current practice in
New Zealand and the development of parking and loading supply rules for the PAUP (2011 and 2015)
Completion of the North West Sub Regional Area Plan (Sub RAP) study investigating the transport
implications of potential growth in the north western area of Auckland. Work included analysing results
from traffic modelling completed in SATURN as well as assessment of walking, cycling and public
transport requirements (2015)
Peer review of ITAs prepared for various Special Housing Areas in Auckland (2015 and ongoing)
Peer review of Christchurch City Council ITA Guidelines (2014)
Peer review of various resource consent applications for Auckland Transport. Providing advice of traffic
generation, parking and access issues (2014 and ongoing)
Completion of the Burns Avenue Corridor Study to develop concept designs for the future layout
including consideration of anticipated growth around Takapuna, capacity and safety issues and provision
for pedestrians and cyclists. This work includes using outputs from the Auckland Transport Burns
Avenue Paramics model (2013)
A discussion paper on the applicability of the UK Manual for Streets (MfS) and its applicability to the
management of the Auckland Road network. This work was completed for Auckland Transport and
included a review of the MfS guides and analysing how the guidance relates to the management and
development of the road network in the Auckland region (2011)
Design of multiple pedestrian crossing facilities for Auckland Transport as part of the Safety Around
Schools programme. This work includes investigation work such as transport surveys (all transport
modes) and the development of concept designs through the provision of preliminary designs to take
forward to construction (2012 and ongoing)
An assessment of walking and cycling accessibility to the Sylvia Park town centre to illustrate a
methodology for assessing accessibility to all town centres within the AMETI corridor. This project
included walkability audits, GIS analysis and community consultation, the results of which were used to
generate a set of short, medium and long term recommendations to increase accessibility (2010)
An analysis of required walking and cycling facilities on the local road network following the
implementation of a cross harbour walking and cycling facility on the proposed additional Auckland
harbour crossing. This work involved the creation of a cycling and walking demand estimation tool and
identification of recommended facilities (2010)
Completion of a Regulatory Strategy for assessing resource consent applications for parking in the
Auckland CBD (2010)
Team Leader for NZTA Road Infrastructure Safety Assessments (RISA) in Opotiki and Kaipara. Works
involve completing three days of road safety assessments throughout the sealed rural network as part of
a team of auditors, compiling and analysing data and presenting findings to the Road Controlling
Authority (2008-2009)
Traffic advice for the proposed Plan Change at Ruakaka racecourse in Northland. The Plan Change aimed
to allow the development of the racecourse whilst maintaining the equestrian land use. The work
included participation in a workshop with key stakeholders, traffic modelling using the regional TRACKS
model outputs and SIDRA Intersection, assessment of trip generation and access and parking
arrangements and liaison with NZTA and the local roading authority (2010)