Before the Auckland Unitary Plan Independent Hearings Panel

in the matter of

The Resource Management Act 1991 and the Local

Government (Auckland Transitional Provisions) Act
2010

and
in the matter of

Proposed Auckland Unitary Plan Topic 081 Rezoning

and Precincts (Geographic)

JOINT STATEMENT OF REPLY OF MATTHEW ARMIN LINDENBERG

AND AMELIA JOAN LINZEY
ON BEHALF OF HOUSING NEW ZEALAND CORPORATION
839, FS 3338

Joint Statement of reply of Matt Lindenberg and Amelia Linzey on behalf of

the Housing New Zealand Corporation

Dated:

17 March 2016

INDEX
INDEX ........................................................................................................... 2
INTRODUCTION ............................................................................................ 3
OVERALL CAPACITY....................................................................................... 4
CAPACITY BY HOUSING TYPOLOGY................................................................. 6
CAPACITY BY GEOGRAPHIC DISTRIBUTION ...................................................... 9
CAPACITY FOR LONG TERM DEMAND ........................................................... 11
EVIDENCE OF MR THOMPSON....................................................................... 14
CONCLUSION .............................................................................................. 15

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

JOINT STATEMENT OF REPLY OF MATT LINDENBERG AND AMELIA

LINZEY ON BEHALF OF HOUSING NEW ZEALAND CORPORATION
17 MARCH 2016

INTRODUCTION
1

Our full names are Matthew Armin Lindenberg and Amelia

Joan Linzey. We are both Planners and respectively hold
the positions of Associate, and Technical Director at Beca
Limited. We have the qualifications and experience set out
in our individual statements of evidence dated 14 November
2014, on the Regional Policy Statement (RPS) Topic 004
and dated 17 October 2014, on the RPS Topic 005 (including
Attachment A of those statements). We are providing a joint
statement rebuttal statement on behalf of Housing New
Zealand Corporation (the Corporation) in relation to Topic
081 (Rezoning and Precincts Geographic) of the Proposed
Auckland Unitary Plan (PAUP) particularly in response to
the evidence presented by Council, dated 02 March 2016.

We are familiar with the national, regional and district

planning documents relevant to the PAUP.

We have been engaged by the Corporation since 2013 to

provide planning advice on both the Draft and Proposed
Auckland Unitary Plan.

We have read the Environment Courts Code of Conduct for

Expert Witnesses, including amendments. We agree to
comply with this Code. We confirm that the issues addressed
in this statement of evidence are within our area of expertise
and we have not omitted to consider any material facts
known to us that might alter or detract from our opinions
expressed in this statement.

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

In making this statement, we rely on the economic rebuttal

statement of Mr Heath and Mr Osborne, prepared on behalf
of the Corporation and dated 15 March 2016. This rebuttal
statement responds to the following statements of primary
evidence (referred to in this statement collectively as
Councils Economic and Capacity Modelling Evidence, 02
March 2016 in this statement):
5.1

Mr Kyle Balderston Rebuttal, on behalf of Auckland

Council, dated 02 March 2016; and

5.2

Dr Doug Fairgray, on behalf of Auckland Council,

dated 03 March 2016.

Further to the request from Mr Fuller at the Hearing

presentation on 10 March 2016, we also provide some brief
comments on the statement of economics and property
market analysis prepared by Mr Adam Thompson, dated 9
March 2016, but refer to the rebuttal evidence of Mr Osborne
and Mr Heath in respect of this statement.

OVERALL CAPACITY
7

Recognising the issues and limitations identified by Mr Heath

and Mr Osborne, it is our opinion that the Economic and
Capacity Modelling Evidence from Council has usefully
provided a comparative test of the market feasible capacity
provided by the amended provisions proposed by Council
(and largely supported by Housing New Zealands evidence1)
of the Unitary Plan in respect of the Residential Zones.
Importantly, this assessment provides a comparative
assessment of the market feasible capacity as provided by
the notified provisions of the PAUP.

See evidence presented for Topics 059, 60, 61 and 62 relating to the Residential
Provisions of the respective residential zones of the Unitary Plan.

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

On the basis of the evidence of Mr Heath and Mr Osborne,

we support the distinction and commentary provided in the
evidence of Mr Balderston, between the Plan Enabled
capacity (the theoretical development level that is provided
for by the zoning pattern and associated provisions of the
Plan) and the Market Feasible capacity (the potential
developments assessed as commercially viable based on
current market conditions). We also concur with the
assessments made by Mr Balderston and Dr Fairgray that
the changes proposed by Council and other submitters
(including the Corporation) to the residential provisions have
increased both the theoretical and assessed market feasible
capacity, compared to the notified PAUP.

Based both on our planning experience, and on the

assessment and evidence of Mr Heath and Mr Osborne, we
consider there remains an issue in that it is from within these
two quanta of capacity that a smaller number of what
actually gets developed within the life of the PAUP will
emerge.

10

In our opinion, based on the nature of existing subdivision,

land tenure (which is highly fragmented), the nature of
existing capital development and other site constraints such
as typography or parcel configurations, the quantum of what
will actually be developed within the life of the PAUP from
what is both plan enabled and market feasible will be
notably less. Furthermore, we consider that in most cases
the change in existing urban areas will occur in incremental
stages or steps (e.g. there will be a number of relatively
sporadic smaller scale developments across existing urban
and suburban areas). We reach this conclusion both based
on our experience of developments seen in Auckland over
the last twenty years and recognising the dual role of housing
stock in Auckland as both a financial asset for landowners
but also a significant contributor to peoples wellbeing
Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence
Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

(providing for physical wellbeing through shelter but also

contributing to peoples sense of place, community cohesion
and identity).
CAPACITY BY HOUSING TYPOLOGY
11

Based on the evidence of Mr Heath and Mr Osborne, we

support the amendments made to the ACDC15 model which
provide for different housing typologies to be implemented on
a site if they are market feasible (notwithstanding that the
underlying zoning provides for a higher intensity use). We
consider this approach improves market reality in the
capacity assessment, in that denser developments (which
are more expensive to construct) are affordable on higher
value land (presuming that the existing capital development
is comparatively low), while lower density development will
be cheaper to build and be more likely to provide a greater
return on investment on land with lower land values.

12

On the basis of these modelling results, the evidence of Mr

Balderston and Dr Fairgray sets out the housing typologies
anticipated by the Plan enabled provisions and based on
the notified PAUP zonings. These results highlight what we
consider to be a significant issue for the evaluation and
effectiveness of the Unitary Plan, particularly based on the
Objectives and Policies of the Regional Policy Statement
(B2.1, B2.2, B2.3 and B2.4) that call for an increase in
housing choices.

13

Using the maximum return on investment results2 from the

modelling, it is our understanding that approximately 15% of
the identified 203,000 housing capacity will be taken up or

We rely on the evidence of Mr Osborne and Mr Heath that the result that filters for
maximum rate of return represents the most likely market response to
development opportunities afforded by the PAUP

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

provided through Apartment type dwellings. However, it is

important to note that a significant proportion of this capacity
(we estimate approximately 50% of this), is provided for in
the City Centre zone (Auckland CBD) and therefore less
through the wider geographically distributed Terrace
Housing and Apartment Buildings (THAB), Centre and
Mixed Use zones.
14

Overall, we understand that the capacity and uptake for the

terrace housing typology is estimated to be lower (less than
10% across the City) and that the majority of housing to be
provided as a single house typology (between 80 and 85%).
On this basis, it is our conclusion that while the zoning
provisions (e.g. the rules and development controls) for the
THAB zone appear to enable these more intensive housing
typologies (e.g. Apartment and/or Terraced dwellings),the
limited geographic extent of the zone (particularly in areas
market attractive to these typologies) is not sufficient to
provide the market sufficient opportunity for their update (as
discussed further below).

15

At the time of preparing the Section 32 report for the

Residential Zones, Council reported that the proposed
capacity provided for by the residential zones provide
information on how the provisions will play out spatially and
for each housing typology. At that time, the Section 32 report
identified that some 36% of capacity (approximately 83,200
additional dwellings) was provided for in the THAB zone3.
On the basis of this identified capacity, Council concluded in
their Section 32 that there were social and economic costs
associated with maintaining the status quo and comparative

Refer to Table 1: Residential capacity results by Unitary Plan Base Zone, on page 7,
of the Residential Zones Section 32 Report. It is acknowledged that the report did

quality that this was plan enabled capacity (rather than market feasible), though no
further qualification of the quantum was cited.

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

benefits with the option of increasing intensification capacity

through provision of the THAB zones. We concur with that
assessment and in particular, we maintain the opinions
expressed in earlier evidence that increasing the provision for
different housing typologies (particularly the Terrace Housing
and multiple-unit housing typologies) in the Unitary Plan will:
15.1 Increase housing choices and ability for housing to
respond to changing family structures and demands
for the future population of Auckland;
15.2 Make good use of infrastructure planning and
investment which is based on intensification of the
existing urban form;
15.3 Provision for a mix of typologies will enable a broader
range of parties to participate in the housing market;
15.4 Focus change to areas where intensification can be
accommodated, while limiting change in areas of
significant resource values and/or environmental
constraint (e.g. the Single House Zone).
16

A key concern for us, as outlined in Table 4.2 of Dr Fairgrays

rebuttal statement, is that the currently feasible dwelling
capacity indicates a significant dominance of large, single
houses as the residential development topology to meet the
urban intensification capacity over the next decade (for
example, out of the suggested market feasible total of some
203,000 dwellings over the assessed planning period, the
majority; of these over 80%,are anticipated to be
large/medium houses4).

We note that we have used broad percentage references earlier in this evidence and
maintain that caution is needed to focus too specifically on the detailed numbers,
given the temporal nature of the market feasibility assessment and the overall
Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence
Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

17

On the basis of the above, we remain of the view that the

Plan, and particularly the quantum of higher density
residential zoning, does not provide sufficient opportunities
for the housing choices that are set out in the objectives and
policies of the Regional Policy Statement. As a result, the
PAUP zoning continues to provide for and enable the
development of significant amounts of large, single dwellings
throughout the inner and outer isthmus suburbs (recognising
that capacity of the inner suburbs is less due to the existing
development of these areas). Such an approach would
continue to lead to an inefficient use of urban land for
residential development, with the associated danger of
continuing to reinforce existing issues of housing affordability
by not providing for adequate choice and flexibility in terms of
residential typologies (particularly in relation to the spatial
application of the residential zones in the market attractive
areas of Auckland).

CAPACITY BY GEOGRAPHIC DISTRIBUTION

18

Again, using the modelling and capacity assessments of the

ACDC15 model presented by Mr Balderston and Dr Fairgray,
the outputs provide a distributional spread of residential
intensification provided for by the zoning and residential
provisions of the Unitary Plan. In particular, the maps
provided in Appendix A2 of Mr Balderstons evidence provide
a useful summary of the distribution of market feasible
capacity provided by the Unitary Plan, and Table 4.5 of the
evidence of Dr Fairgray usefully provides a geographic
summary of this capacity (based on the notified PAUP
zoning).

purpose of the modelling which is to enable the assessment and evaluation of

differences in development outcomes under various scenarios of the Unitary Plan (in

other words, it is a model established to test options, rather than predict or forecast
outcomes).

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

10

19

In Dr Fairgrays evidence, he cites (at Table 4.5, page 19)

that approximately 20% of capacity (some 41,800 dwellings
out of a total of 202,900) is within the Central Isthmus
suburbs / Local Boards (e.g. Waitemata, Eden-Albert, Orakei,
Puketapapa and Maungakiekie-Tamaki). However, it is our
estimation that just under half of this capacity is provided by
Apartment typology dwellings in the Auckland CBD (e.g. the
City Centre zone, within the Waitemata Local Board), and on
this basis, there is a significantly reduced quantum of
increased capacity being provided in this Central Isthmus
Suburbs part of the City (within the five local boards noted
above, outside the CBD, providing merely 10% of the total
remaining housing supply).

20

By comparison, this level of capacity (provided for by these

five Local Boards combined) is comparable to the residential
housing forecast to be provided by the Rural areas of the
region, over the same period. We are concerned that this
highlights a potentially significant lost opportunity for the
provision of residential intensification in these inner isthmus
suburbs, which generally benefit from high levels of
supporting amenities and infrastructure to support higher
density and more affordable living options for Aucklanders.

21

The inner isthmus suburbs also benefit from the investment

in, and provision of, existing and planned infrastructure
(transport, water and wastewater, open space and social /
community services and facilities). In our view the growth
and spatial form of development provided for by the current
zoning pattern of the Unitary Plan, fails to make efficient and
effective use of these existing physical resources
(infrastructure investment) and this demonstrates that it is
fundamentally counter to the goal of achieving a quality
compact urban form.

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

11

22

On the basis of the above, we remain of the view (as

expressed in earlier evidence) that the geographic
application of zoning of the PAUP provides insufficient
capacity for growth in areas which are considered (by virtue
of their proximity to services, facilities, transport and
employment5) suitable for intensification. As such, we are of
the opinion that there is a high risk that it will not deliver on
the objectives of providing for growth in a quality compact
urban form or to meet the objectives of a plan that enables
greater housing opportunities to facilitate improved housing
affordability (RPS B2.1, Objectives 1-4 and Policies 1-5).

CAPACITY FOR LONG TERM DEMAND

23

Dr Fairgrays evidence presents a summary of the capacity

forecasts based on supply and demand dynamics,
particularly focused over the next ten years (out to 2026).
While we accept that the Plan and Plan review period is
based on ten years, we consider it is important to consider
the pipeline of urban capacity over a longer time period
(particularly in light of the Auckland Plan, which provides a
spatial plan for Aucklands growth and development through
to 2040).

24

In particular, we note the various references within Councils

Section 32 topic report for 2.1 Urban Form and Land Supply
which highlight the need for this longer-term view:
The land supply provisions of the Unitary Plan are intended
to accommodate residential and business growth in Auckland
over the next 30 years, in a way that meets aspirations for a
quality compact city with the major share of growth occurring
within the existing metropolitan urban area.

Particularly in relation to B2.1 of the RPS Providing for growth in a quality compact
urban form, Policy 2.

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

12

This evaluation addresses:

Unitary Plan provisions that ensure the transition over

30 years to a quality compact Auckland, focused on
achieving the Auckland Plans aspiration of 70
percent of new dwellings within the existing urban
area, defined by the 2010 Metropolitan Urban Limit
(MUL), with flexibility to accommodate up to 40
percent of new dwellings outside the existing urban
area (2.1 Urban form and land supply section 32
evaluation for the Proposed Auckland Unitary Plan,
page 2).

If the [operative] RPS already contains objectives, policies

and methods for a quality compact urban form and a 20-year
capacity requirement, it could be asked why these provisions
are not simply carried over into the Unitary Plan. The
[operative] RPS pre-dates the Auckland Plan. Unlike the
[operative] RPS, the Unitary Plan, in keeping with the
Auckland Plan, takes a 30-year outlook using the RUB and
providing for sufficient urban zoning in existing urban areas
to achieve longer term targets by location and time.

A long-term and integrated approach with clear land supply

targets and sequenced release is considered necessary in
order to sustainably manage urban growth in Auckland,
whilst avoiding and managing its adverse effects (2.1 Urban
form and land supply section 32 evaluation for the
Proposed Auckland Unitary Plan, page 7).

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

13

25

A key concern for us, as outlined in Table 4.2 of Dr Fairgrays

rebuttal statement, is that the currently feasible dwelling
capacity indicates a significant dominance of large, single
houses as the residential development topology to meet the
urban intensification capacity over the next decade (for
example, out of the suggested market feasible total of some
203,000 dwellings over the assessed planning period, some
170,000 are anticipated to be large/medium houses).

26

In addition to the potential costs we have identified in this

approach in the first section of this statement, we are also
concerned that the forward pipeline for future residential
capacity is at risk. In other words, where does the next 10 or
20 years of capacity go it this first 10-year period is
dominated by lower density suburban infill in the outer
isthmus suburbs? We are concerned that any approach in
the PAUP which seeks to provide for only the first 10-15
years of anticipated capacity through to 2026 may create an
unintended consequence of creating areas of lost
opportunity for the next 10-15 year period.

27

This geographic distribution of the growth forecasts and the

future capacity issues from Councils ACDC15 model appear
inconsistent with the growth and demand forecasts used by
infrastructure providers over the longer time horizons.

28

The Joint Statement of Evidence of Mr Cribbens, Mr Wrenn

and Mr Winter (Transport), on behalf of Auckland Council for
Hearing Topic 080 makes reference to Aucklands future
transport conditions, including reference to the Auckland
Regional Transport (ART3) modelling. The ART3 model
itself is discussed in more detail in the EIC of Mr Arbury, on
behalf of Auckland Council, in relation to Hearing Topic 012
(dated 13 October 2014). On the basis of this evidence, we
understand the ART3 model, which considers a 30-year time
horizon, was used to test various land use and transport
Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence
Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

14

scenarios to inform the development of the Auckland Plan.

This 30-year horizon applied by the ART3 model to test landuse scenarios as part of the Auckland Plan development
played a key role in supporting the adoption of a quality
compact city approach for the Auckland Plan, which the
PAUP is now attempting to implement.
29

We further cite the evidence of the NZ Transport Agency,

filed 14 March 2015, which supports the above
considerations.

30

On the basis of the above, review, we conclude that the lack

of sufficient zoning for appropriate urban intensification of the
inner-suburbs has potentially significant social, economic,
environmental and cultural costs that have not been
appropriately considered; both in terms of the provision of
infrastructure and in the forward pipeline of residential supply
expected by the longer term (30 year) growth forecasts of the
Auckland Plan.

EVIDENCE OF MR THOMPSON
31

Further to the direction of Mr Fuller at the presentation of the

Corporations evidence, 10 March 2016, we have undertaken
a review of the evidence of Mr Thompson. In the main, we
defer to the evidence of Mr Heath and Mr Osborne in respect
of that economic evidence. However, we would like to clarify
one minor matter from that statement, given its potential
weight in the Panels consideration.

32

We consider that the quote and reference by Mr Thompson

of Mr Nunns post to transport blog should be qualified in
two respects. Firstly, we understand that Mr Nunns is not
Auckland Councils consultant economist in respect of the
residential zoning topics (as alluded to in Mr Thompsons
statement), though we note he has provided independent
expert evidence for Council on the business topics and on
Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence
Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

15

the economic impact of the residential zoning provisions

(Topics 59, 60, 62 and 63).
33

Secondly, and more notably, Mr Nunns commentary

provides a personal view specifically in response to the issue
of Councils decision in late February to withdraw its
evidence in respect of out-of-scope zone changes proposed
in the Councils expert evidence (January 2016). On the
basis of this context, we question their relevance to the
issues of further residential rezoning of Future Urban Zone
areas.

CONCLUSION
34

From a planning perspective, the evidence of Mr Balderston

and Dr Fairgray exemplifies a number of concerns we have
raised in respect of the Proposed Unitary Plan, both in
respect of zoning provisions and in respect of the geographic
distribution of those zones. We therefore remain of the view
that:
34.1 While the modelling demonstrates there is more likely
to be sufficient capacity for the 10-year period of the
Unitary Plan, the distribution of this capacity is not
geographically appropriate and therefore not
consistent with the Compact Urban Form vision of the
RPS;
34.2 The capacity does not provide for the RPS objectives
of a mix of typologies diversity of housing options,
with a strong dominance in supply of Single Houses;
34.3 As a result of the above, we remain concerned that the
forecasts of market feasible capacity do not provide
sufficient housing opportunities for a broader range of
parties to participate in the housing market and this will

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016

16

reduce the effectiveness and efficiency of the Plan in

responding to the RPS issues of housing affordability;
34.4 We are concerned that there is significant risk to the
longer term (30-year) pipeline of urban capacity, with a
reliance on short-term infill capacity at the expense of
longer term opportunities to intensify the City and
achieve the Auckland Plan vision; and
34.5 The capacity and pattern of growth does not accord
with the infrastructure planning that has been planned
to support growth which represents a potentially
significant cost that has not been appropriately
considered in the evaluation of costs and benefits for
the PAUP.

Matt Lindenberg and Amelia Linzey

17 March 2016

Matt Lindenberg and Amelia Linzey Joint Statement of Rebuttal Evidence

Joint Rebuttal Evidence PAUP 081.doc, 17 March, 2016