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Palmerston North City Sectional District Plan Review

Proposed Plan Change 15A-H: A. RURAL ZONE AND RURAL SUBDIVISION

B. WIND FARMS AND LANDSCAPES

C. BOUNDARY CHANGE AREA (THE AREA FORMERLY WITHIN THE MANAWATU DISTRICT)

D. FLOOD HAZARDS

E. NORTH EAST INDUSTRIAL ZONE AND EXTENSION AREA

F. BRAEBURN INDUSTRIAL AREA (LONGBURN)

G. UTILITIES

H. AIRPORT ZONE

Summary of Decisions Requested from Original Submissions

& Copies of Original Submissions

APRIL 2015

Palmerston North City Council Proposed Plan Change 15A-H – Summary of Original Submissions DM 1252373

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PUBLIC NOTICE UNDER CLAUSE 7 OF THE FIRST SCHEDULE

OF THE RESOURCE MANAGEMENT ACT 1991 OF THE AVAILABILITY OF THE SUMMARY OF DECISIONS REQUESTED IN SUBMISSIONS TO:

PALMERSTON NORTH CITY SECTIONAL DISTRICT PLAN REVIEW:

PROPOSED PLAN CHANGE 15A-H In accordance with Clause 7 of the First Schedule of the Resource Management Act 1991, the Palmerston North City Council gives public notice that the summary of decisions requested by persons making original submissions to Proposed Plan Change 15A-H to the Palmerston North City District Plan are available for public consideration. The Council has received 91 original submissions on Plan Change 15A-H. Description of Proposed Plan Change 15A-H (Plan Change 15A-H) Plan Change 15A-H contains the following topic areas: A. Rural Zone and Rural Subdivision B. Wind Farms and Landscapes C. Boundary Change Area (the area formerly within the Manawatu District) D. Flood Hazards E. North East Industrial Zone and Extension Area F. Braeburn Industrial Area (Longburn) G. Utilities H. Airport Zone By topic area, the purpose of Plan Change 15A-H is summarised as follows: 15A Rural Zone and Rural Subdivision: A complete review of the Rural Zone provisions with a particular focus on rural-residential subdivision and the implementation of the Rural-Residential Land Use Strategy. Plan Change 15A proposes new resource management objectives and policies for rural subdivision and amends the rules and minimum lots sizes for rural subdivisions. 15B Wind Farms and Landscapes: The introduction of new planning provisions governing commercial and domestic-scale wind turbines and the spatial definition of the skyline of the Tararua Ranges and the Manawatu Gorge. 15C Boundary Change Area: Integration of the former Manawatu District Council boundary change area within the Palmerston North City District Plan. 15D Flood Hazards: A review of the Flood Protection Zone and the introduction of a Flood Prone Areas overlay, which represents those areas known to flood in a 200-year flood event. 15E North East Industrial Zone and Extension Area: A review of the existing North East Industrial Zone (NEIZ) provisions and a proposed 126 ha extension to the NEIZ which is supported by a Structure Plan and specific planning provisions. 15F Braeburn Industrial Area (BIA): A proposed 33 ha industrial extension at Longburn which is supported by site-specific planning provisions in the Industrial Zone.


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15G Utilities: A complete review of the Utilities Section of the District Plan which gives effect to relevant national planning directions and identifies the national electricity grid on the Planning Maps. 15H Airport Zone: A complete review of the Airport Zone and associated planning controls which protect and provide for the ongoing operation and development of Palmerston North Airport. The summary of decisions requested in the original submissions and the original submissions themselves, are available for inspection at the following locations when these facilities are open to the public: • The Customer Service Centre, Palmerston North City Council, Civic Administration Building,

The Square, Palmerston North;

• The Palmerston North Public Library, (NZ Pacific Zone, 2nd Floor) The Square, Palmerston North;

• Ashhurst Library, Cnr Cambridge Avenue and Bamfield Street, Ashhurst; • Linton Army Camp Library, Puttick Road, Linton. Information on Proposed Plan Change 15A-H, the original submissions received and the Further Submission Form are also available on the Council website: pncc.govt.nz. The Palmerston North City Council is now calling for Further Submissions in support of, or in opposition to, the submissions lodged on Proposed Plan Change 15A-H. Under clause 8 of the First Schedule of the Resource Management Act 1991, the following parties may make a further submission either supporting or opposing submissions made on this plan change: • any person representing a relevant aspect of the public interest; • any person who has an interest in the Proposed Plan Change that is greater than the interest

that of the general public has; and • the Palmerston North City Council itself. Further Submissions must be in writing in the form prescribed (Form 6) in the Resource Management Act 1991 or similar, including Further Submissions via e-mail. Further Submissions lodged by way of e-mail do not require a signature. Further Submission Forms are available from any of the facilities referred to above or the Council website: pncc.govt.nz. The closing date for making Further Submissions is 4pm, 24 April 2015. Further Submissions on the Proposed Plan Change must be lodged with the Council by one of the following options: Posted / Fax /Emailed to: or Delivered to: Team Leader – Governance and Support Team Leader – Governance and Support City Corporate City Corporate Palmerston North City Council c/- Customer Service Centre Private Bag 11-034 Palmerston North City Council PALMERSTON NORTH The Square, Fax No: (06) 355-4115 PALMERSTON NORTH Email: [email protected] Once the closing date for lodging Further Submissions has passed, the Council will convene hearings to consider submissions and further submissions that have been lodged and issue decisions on the matters raised. Anyone who has made a submission or further submission and who has indicated that they wish to be heard will have the right to attend the hearings and present their submission. On receiving notice of a decision on their submission, any person who disagrees with or is dissatisfied with the decisions made may refer the decision to the Environment Court for further consideration.


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IMPORTANT: Any person making a further submission on Proposed Plan Change 15A-H must serve a copy of their further submission on the person who made the original submission within five working days of lodging their further submission with the Council. Enquiries about Proposed Plan Change 15A-H can be made to the relevant Planning Officer listed below: Topic Contact Phone / Email A: Rural Zone & Subdivision B: Wind Farms & Landscapes C: Boundary Change Area D: Flood Hazards

Cynthia Ward (06) 356 8199 [email protected]

E: North East Industrial Zone & Extension Area

F: Braeburn Industrial Area (Longburn)

Jonathan Ferguson-Pye

(06) 356 8199 [email protected]

G: Utilities H: Airport Zone

Michael Duindam (06) 356 8199 [email protected]

Paddy Clifford, Chief Executive (for Palmerston North City Council) Dated in Palmerston North this day of 11th of April 2015


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INTRODUCTION The summary in Part I of this document has been prepared to assist the Council in meeting notification requirements under Clause 7 of the First Schedule of the Resource Management Act 1991. It has been prepared to assist those who may wish to prepare a further submission, or those preparing evidence or hearing evidence in respect of Proposed Plan Change 15A-H. Please note that a copy of the original submissions has been enclosed as Part II of this document. This summary does not replace the original submissions. Submissions are listed within the Summary of Submissions under the following header format:

Submissions typically have two parts: The Submission: Usually stating whether the submitter supports or opposes the plan

change either in whole or in part, and the reasons for that support or opposition.

Decision Requested: The action which the submitter requests the Council to take. MAKING A FURTHER SUBMISSION The following parties may make a further submission either supporting or opposing submissions made on this plan change:

• any person representing a relevant aspect of the public interest;

• any person who has an interest in the proposed plan change that is greater than that of the general public; and

• the Palmerston North City Council itself.

A further submission must be made by making a written further submission in general accordance with Form 6 of the Resource Management Act (Forms) Regulations 1991, or similar. A further submission can be made either supporting (in whole or in part), or opposing (in whole or in part) any original submission. A further submission cannot traverse any issue that is not covered by the original submission, but can give reasons for the support or opposition to the original submission. A copy of a further submission is required to be served on the original submitter within 5 working days of the further submission being made to the Council. A list of the submitter’s addresses is included in Part II of this document.

Submitter name

Joe Bloggs

Reference number allocated to the submitter

1

Indicates that this is an original submitter

SO


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List of Abbreviations

The following is a list of abbreviations used throughout the Section 32 Report: • BCA – Boundary Change Area

• CDP – Comprehensive Development Plan

• ILUPR – Palmerston North and Manawatu District Industrial Land Use Planning Review (May

2007)

• LGA02 – Local Government Act 2002

• MDC – Manawatu District Council

• NES – National Environmental Standard

• NEIZ – North East Industrial Zone

• NEIZ Extension Area – North East Industrial Zone Extension Area

• NPS - National Policy Statement

• NPSREG – National Policy Statement for Renewable Electricity Generation

• NZS – New Zealand Standard

• NZTA – New Zealand Transport Agency

• One Plan – Horizons Regional Council combined Regional Policy Statement, egional Plan

and Regional Coastal Plan

• ONFL – Outstanding Natural Feature and Landscape

• PNCC or the Council – Palmerston North City Council

• PPC15A-H – Proposed Plan Change 15A-F

• PPC15A – Rural Zone and Rural Subdivision

• PPC15B – Wind Farms and Landscapes

• PPC15C – Boundary Change Area

• PPC15D – Flood Hazards

• PPC15E – North East Industrial Zone and Extension Area

• PPC15F – Braeburn Industrial Area

• PPC15G – Utilities

• PPC15H – Airport Zone

• RLTS – Regional Land Transport Strategy (2010-2040)

• RMA or the Act – Resource Management Act 1991

• SDPR – Sectional District Plan Review


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PROPOSED PLAN CHANGE 15A-H: A. RURAL ZONE AND RURAL SUBDIVISION

B. WIND FARMS AND LANDSCAPES

C. BOUNDARY CHANGE AREA (THE AREA FORMERLY WITHIN THE MANAWATU DISTRICT)

D. FLOOD HAZARDS

E. NORTH EAST INDUSTRIAL ZONE AND EXTENSION AREA

F. BRAEBURN INDUSTRIAL AREA (LONGBURN)

G. UTILITIES

H. AIRPORT ZONE Part I – Summary of Submissions Submission Number

Plan Change Number

Relevant Section/s Submitter Address for Service Wishes to be heard

SO1 15A 15C

S7 Subdivision Appendix 2: Planning Maps

Bruce Peck Bruce Peck Projectwork 2008 Ltd 7 Harrisons Line RD10 PALMERSTON NORTH

Did not indicate

Submission: The submitter is opposed to the current drafting PPC15A. The submitter asks to give consideration to 0.5ha lot subdivision in the Lower Harrisons Line/Bunnythorpe Road area, on the basis that this land has minimal agricultural value. Page three shows subdivision plans in support of this submission. Decisions Requested:

1. R17.16.2.1(b)(iii): That Council considers 0.5ha subdivisions under plan change PPC15A.

2. Planning Map 9: That the land on the located on the corner of Harrisons Line and Ashhurst – Bunnythorpe Road be zoned to allow 0.5ha lot subdivision.

Submission Number

Plan Change Number


SO2 15E S12A Industrial Appendix 6: 15E Technical Reports

D C Morrison D C Morrison PO Box 4082 PALMERSTON NORTH

Did not indicate

Submission: The submitter is concerned with stormwater runoff in the North East Industrial Zone Extension Area. The submitter opposes the deletion of existing controls relating to wet industries and stormwater detention. The submitter supports in part the Stormwater Management and Mitigation Assessment Report in Appendix 6: 15E Technical Reports. The submitter is concerned about the following matters.

1. The lack of consideration for aluminium oxide runoff from Zincalume cladding. Pages 2-8 provide a factsheet and an article highlighting the damaging effects of aluminium oxide.

2. The loss of natural filtration, especially in Whiskey Creek. 3. A requirement to hold people responsible for notifying the public of chemical spills within a quicker timeframe. 4. Silt contamination from the existing North East Industrial Area.


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5. Clause 17 states a full assessment of available source control or retention techniques or measure is outside the scope of this report.

Decision Requested: 1. Appendix 6.7: That points 1-5 above be considered before a decision is made.

Submission Number

Plan Change Number


SO3 15A 15C

S9 Rural Zone Appendix 2: Planning Maps

Phillip T Ropiha Phillip T Ropiha 153 Tutaki Road RD10 PALMERSTON NORTH 4470

Did not indicate

Submission: The submitter is concerned that the exclusion from the Rural Residential Overlay restricts the submitter’s ability to subdivide into 1ha lots. The submitter opposes to 153 Tutaki Road being excluded from the Rural Residential Overlay in plan change PPC15A, on the basis that a minor part of the section is included on the fringe of the Outer Airnoise Zone. 153 Tutaki Road is adjacent to the Rural Residential Zone. Decisions Requested:

1. Planning Map 13: That 153 Tutaki Road be included in the proposed Rural Residential Overlay.

2. Planning Map 13: Allow 153 Tutaki Road to be subdivided into 1ha lots.

Submission Number

Plan Change Number


SO4 15A 15C


JP Ware Transport Ltd & JP Ware & Sons Family Trust

John & Tina Ware Bainesse RD7 PALMERSTON NORTH 4477

YES

Submission: The submitter opposes in part PPC15A and PPC15C, particularly R9.5.6(b) relating to hours of operation for J.P. Ware Transport Limited. The submitter believes that the performance standard is too restrictive to allow the operation of emergency vehicle recovery services from 31 Shirriffs Road, based on the following:

1. The submitter states that the performance standards for J.P. Ware Transport Limited are all the same in nature as those under the Industrial Zone, except for hours of operation.

2. The submitter notes that nearby businesses begin before 7am, and businesses with greater noise effects have less restrictions under R9.5.6(b).

3. The hours of operation restrictions prevent the washing of vehicles on Sundays. 4. The maximum 12 hour day is inconsistent with the maximum 13 hours permitted on their log books. 5. The site no longer operates drainage and roading services, leaving only transport and contracting services, which the submitter

states are more compatible with surrounding land use. 6. A rezoning to industrial would reduce the risk of subdivision in this area.

Decision Requested:

1. Planning Map 30: That 31 Shirriffs Road be zoned from Rural to Industrial. Alternatively, that R9.5.6(b) be amended to provide for unrestricted hours of operation for the land at 31 Shirriffs Road.


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Submission Number

Plan Change Number


SO5 15E S12A NEIZ Appendix 2: Planning Maps

Jane Richardson Jane Richardson 129 Richardsons Line RD8 PALMERSTON NORTH

Did not indicate

Submission: The submitter is opposed to the current drafting of PPC15E. The submitter’s property is currently for sale and the proposed plan change has deterred prospective buyers. The property is adjacent to the proposed North East Industrial Zone Extension Area. Decision Requested:

1. Planning Map 12: That 129 Richardsons Line be zoned North East Industrial. Alternatively, that compensation be paid to cover the loss in property value from PPC15E.

Submission Number

Plan Change Number


SO6 15C 15A 15H

S9 Rural Zone S13 Airport Zone Appendix 2: Planning Maps

David C Parham David C Parham 24 Logan Way Kelvin Grove PALMERSTON NORTH 4414

YES

Submission: The submitter is opposed to the current drafting of PPC15A, C, and H. The submitter requests that the “Ashhurst - Kelvin Grove – Bunnythorpe Triangle” be considered for urban development, including a village between Ashhurst and Whakarongo. The submitter is concerned about the Henderson area being removed from the Growth Strategy, and believes the boundary change and modern wastewater schemes could make this area viable for urban development. The submitter is concerned that Figure 13.1 Air Protection Surfaces is not adequately detailed to provide understanding to the general public, and that the area between Ashhurst, Kelvin Grove, and Bunnythorpe be reviewed for urban development. The submitter states that air surface contours similar to those used in Figure 20.7 of the operative plan are necessary for illustrating the take-off and approach and conical surfaces. The submitter states that areas where the conical surface is below the take-off surface, and ground to airspace clearances should be mapped. Pages 3-5 provide previous submissions around ease of use for map users. Decisions Requested:

1. Planning Maps 7,8,13,14: That the area between Ashhurst, Kelvin Grove, and Bunnythorpe are reviewed for urban development.

2. S9: That the Rural Residential Overlay is removed wherever possible.

3. That greenfield zones are created where appropriate.

4. Figure 13.1: That maps in PPC15H illustrate ground to airspace clearance for any applicable property, and any other restrictions to development as a result of take-off and approach surfaces.

Submission Number

Plan Change Number


SO7 15A 15B 15C

S7 Subdivision S9 Rural Zone

Rocky Renquist, Sustainable City Group

Rocky Renquist 14 Springdale Grove PALMERSTON NORTH 4410

NO

Submission: The submitter supports in part PPC15A-C. The submitter supports the protection of productive land through PPC15A. The submitter supports the protection of landscape amenity in PPC15B, whilst allowing for new wind farms. The submitter supports the generally positive approach to PPC15C.


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The submitter is concerned that domestic wind turbines will still be too costly to erect under R9.7.5, particularly due to the notification process involved. Decisions Requested:

1. R7.16.1.2(b)(i): That minimum lot sizes in the Rural Zone should be 20ha, with some exemption for intense horticulture.

2. R9.7.5: That domestic wind turbines become a non-notified controlled activity under PPC15A. Submission Number

Plan Change Number


SO8 15H S13 Airport Zone Clive A Harding

Clive A Harding 32 Apollo Parade Milson PALMERSTON NORTH

YES

Submission: The submitter is concerned about the lack of control over helicopter noise and safety effects on the Milson residential area. The submitter is opposed to the current drafting PPC15H. The submitter notes that there is no provision to prevent helicopters flying over Milson, allowing helicopters to use this noise-sensitive residential area for training exercises. Decision Requested:

1. S13: That all helicopters other than ambulance helicopters comply with take-off and approach zones identified in PPC15H. Submission Number

Plan Change Number


SO9 15A 15C


W B Holdsworth W B Holdsworth 30 North Street ASHHURST

Did not indicate

Submission: The submitter requests that 30 North Street, Ashhurst to be rezoned Residential. The submitter is opposed to the current drafting of PPC15A. The submitter suggests that 30 North Street is a more suitable location for residential growth in Ashhurst than locations considered in the Ashhurst Residential Growth Report, on the basis that:

1. Areas considered in the growth report are flood prone. 2. 30 North Street is flat and adjacent to PNCC services.

Decision Requested:

1. Planning Map 5: That 30 North Street, Ashhurst be rezoned from Rural to Residential in the next five years. Submission Number

Plan Change Number


SO10 15A 15C


Shireen A Schofield

Shireen A Schofield PO Box 5177 Terrace End PALMERSTON NORTH 4441

NO

Submission: The submitter supports the inclusion of 177 Tutaki Road in the Rural Residential Overlay and the retention of 1ha minimum lot areas. The submitter has recently obtained ownership of 177 Tutaki Road. Decisions Requested:

1. Planning Map 13: That 177 Tutaki Road remains in the Rural Residential Overlay.

2. R7.16.1.2(b)(ii): That the 1ha minimum lot area remains applicable to 177 Tutaki Road.


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Submission Number

Plan Change Number


SO11 15E S12A NEIZ David & Robyn Adam

David & Robyn Adam 153 Richardson Line RD8 PALMERSTON NORTH

YES

Submission: The submitter supports the extension of the North East Industrial Zone, based on positive effects on employment, rates revenue, and economic growth. Decision Requested:

1. S12A: That PPC15E is approved as soon as possible in its entirety. Submission Number

Plan Change Number


SO12 15A S7 Rural Zone Section 32 Report 1.1.22

Fran Harvey Fran Harvey 1180 Roberts Line RD8 PALMERSTON NORTH 4478

NO

Submission: The submitter opposes the 20ha minimum lot area for rural subdivision under R7.16.1.2(b)(i). The submitter notes that the subdivision of a 4ha lot of unproductive land would satisfy the requirements for residential growth without reducing the availability of productive agricultural land. Decision Requested:

1. R7.16.1.2(b)(i): That the 4ha minimum lot area for rural subdivision is retained under R7.16.1.2(b)(i). Submission Number

Plan Change Number


SO13 15A-H 15A 15G

S7 Subdivision S9 Rural Zone S23 Utilities Appendix 2: Planning Maps

Palmerston North City Council

Paddy Clifford Private Bag 11-034 Palmerston North

NO

Submission: The submitter supports in part PPC15A-H. The submitter requests that Section 7 and 9 of PPC15A have particular reference to the requirement to provide rural water supplies for firefighting, and recognise the New Zealand Fire Service Firefighting Water Supplies Code of Practise SNZ PAS 4509:2008. The submitter suggests that R7.16.3.1.(2) with respect to the Lot Area reference would be clearer by adding a ‘(b)’ to the rule reference, and contained said reference in brackets. The submitter recommends the rule reference reads as follows: “(2) Any subdivision which does not comply with the Controlled activity Performance Standards (R 7.16.1.2) for Existing Buildings, Lot Area (R 7.16.1.2 (b) (iii) only),…” The submitter requests that PPC15A-H refers to Council’s Engineering Standards for Land Development in a more generalised way so that a plan change is not required when the Council’s Engineering Standards for Land Development document is updated. Section 7.4 currently refers to the “Engineering Standards for Subdivision”, which needs to be updated to the current title for this document “Engineering Standard for Land Development”. The submitter suggests that PPC15G give consideration to the inclusion of cross references to other parts of the District Plan to ensure compliance with Sections 13, 17, and 22. The submitter notes that it is unclear how non-compliance with the Permitted Activity Performance Standards (g)-(j) are managed. The submitter recommends a review to ensure that there is an appropriate default rule for non-compliances with the performance standards within R23.7.1. The submitter notes that the Key to Planning Maps does not include specific notation for the Transmission Corridor (shown as a purple line on supporting Planning Maps). The submitter requests that a purple line needs to be added to the Key to refer to the Transmission Corridor. The submitter notes that the extent of the Rural Residential Overlay is incorrectly shown on the Index, with respect to Harts Road. The


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submitter recommends that the extent be consistent with Planning Map 39. The submitter notes that Planning Maps 48, 49, 50, & 52 were incorrectly scaled at 1:10,000 instead of 1:20,000. The submitter recommends replacing the printed maps (as the online maps have already been replaced) to the 1:20,000 scale to ensure the full extent of said maps is shown. The submitter requires a minor amendment to Planning Maps 27 & 33 to align the Rural Residential Overlay with the rural residential subdivision granted for Kingsdale Park Limited. The submitter notes that the Mangaone Stream Designation 85 is incorrectly zoned Rural instead of Flood Protection. The submitter recommends changing the underlying zoning to Flood Protection to allow a consistent approach to managing the Horizon’s stopbank system. Decisions Requested:

1. SS7 & 9: That Sections 7 & 9 of PPC15A include more specific references to the requirement to comply with The New Zealand Fire Service Firefighting Water Supplies Code of Practise SNZ PAS 4509:2008.

2. R7.16.3.1(2): That R7.16.3.1(2) be amended as follows: (2) Any subdivision which does not comply with the Controlled Activity Performance Standards (R 7.16.1.2) for Existing Buildings, Lot Area (R 7.16.1.2 (b) (iii) only),…

3. PPC15A-H reference to Council’s Engineering Standards for Land Development: That all references to the Palmerston North City

Council’s Engineering Standards for Land Development, within PPC15A-H be reviewed and/or deleted as appropriate.

4. S7.4: That the reference within S7.4 to Engineering Standard for Subdivision be replaced with Engineering Standard for Land Development.

5. S23: That S23 Utilities include cross references to other relevant parts of the District Plan, in particular Sections 13, 17, and 22.

6. R23.7.1: That an appropriate default rule exists for non-compliance with all Performance Standards within R23.7.1.

7. Key to Planning Maps, Index to Planning Maps, Planning Maps 48, 49, 50, 52, 27, 33, 12, 19: That the Planning Maps be amended as per the submission points above.

Submission Number

Plan Change Number


SO14 15A S7 Subdivision Rosemary Gear and 45 Others

Rosemary Gear 64 Moonshine Valley RD1 PALMERSTON NORTH

NO

Submission: The submitter is in support of R7.16.2.1(b)(ii) & supporting objectives & policies, Objective 3, and Policy 3.6, particularly in reference to subdivision in Moonshine Valley. A petition has been provided on pages three & four, identifying 45 individuals in support of this submission. The submitter has attached three further signatures in support of R7.16.2.1(b)(ii) & supporting objectives & policies, Objective 3, and Policy 3.6, particularly in reference to subdivision in Moonshine Valley. Decision Requested:

1. R7.16.2.1(b)(ii): That R7.16.2.1(b)(ii) & supporting objectives & policies, Objective 3, and Policy 3.6 are approved by Council. Submission Number

Plan Change Number


SO15 15H S13 Airportone Appendix 2: Planning Maps

Robert H Fraser

Robert H Fraser 41 Apollo Parade PALMERSTON NORTH 4414

Did not indicate

Submission: The submitter is opposed to the current drafting of PPC15H. The submitter is concerned about safety and noise impacts that single engine helicopters have on residential areas that they train above.


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Decisions Requested: 1. S13: That clarification around provisions for single engine helicopters operating over residential areas is made.

2. Planning Maps 12 & 19: That PPC15H include provisions to include single engine helicopters operating over Milson Avenue in a

“Red Zone”. Submission Number

Plan Change Number


SO16 15E S12A NEIZ Appendix 2: Planning Maps

Brian C Holmes Brian C Holmes 52 Setters Line RD8 PALMERSTON NORTH

YES

Submission: The submitter is concerned that the North East Industrial Zone Extension Area will adversely impact the rural amenity of 52 Setters Line. The submitter is opposed in part to PPC15E. The submitter owns rural property adjacent to the North East Industrial Zone Extension Area, and is concerned that they will have to drive through an industrial park to get to their property. The submitter’s house is 30 metres from the boundary shared with the North East Industrial Zone Extension Area, and is concerned that visual amenity will be reduced due to future industrial development. Decision Requested:

1. Planning Maps 6, 7, 12 & 13: That the area between Richardsons Line and the Mangaone Stream is rezoned from Rural to North East Industrial.

Submission Number

Plan Change Number


SO17 15A S7 Subdivision S9 Rural Zone

B J & C J Whitelock, John Whitelock and Others

B J & C J Whitelock, John Whitelock and Others 42 The Strand PALMERSTON NORTH

YES

Submission: The submitter supports in part Sections 7 & 9. The submitter commends the general thrust of changes and reference to the importance of the rural sector to the PNCC and the need for a disciplined approach to ensure the economic substance of this resource is fostered. The submitter seeks the inclusion of an overarching and deliberate statement in 9.1 Introduction, as follows:

‘It is an inherent responsibility that as custodians of the large rural sector within the PNCC confines, that a practical, supportive, disciplined and secure framework is applied to ensure there is business security aimed at fostering and assisting the economic substance of the region and that ecological and landscape features.’

The submitter supports paragraph 3 of 9.1 Introduction, Resource Management Issue 10, Objectives 1-4 and 7 and Policies. The submitter supports in part Rule 9.5.1(a). The submitter notes that farming excludes ‘intensive farming’ and queries whether a definition (of intensive farming) is required, e.g poultry, calf rearing – egg vs broiler. The submitter supports in part Rule 9.8.2 Explanation: The submitter notes the comments on rural matters in Rule 9.8.2 Explanation and seeks a reference in the Explanation to paragraph 3 in 9.1 Introduction, to illustrate the Council’s direction. The submitter supports the consideration of proposals for industrial activities on a case-by case basis. The submitter supports 7.2 Resource Management Issues. The submitter supports Policy 1.5 as a ‘useful benchmark’. The submitter supports in part Objective 3: The submitter queries if it is realistic to have just Class 1 and 2 land referenced in Objective 3. The submitter supports in part Policy 3.2 (a) Clause (iv): The submitter seeks the amendment of Clause (iv) to expand the reference to other soils i.e, add ‘and other soils’ after the words ‘soils’. The submitter opposes Rule 7.16.1.2 Performance Standards – Lot Area, Rule 7.16.1.2 (b)(i) & associated Explanation & Rule 7.16.4: The


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submitter requests that all references to 20 ha be deleted. The provisions undermines containment of rural residential subdivision, and the intention of avoiding further fracturing of the Rural sector within the City and is contrary to numerous PC 15A-H statements. The submitter supports in part Rule 7.16.1.2 (b) (iii) – Surplus Dwelling & Explanation: The submission states that subdivision to create small rural lot for a surplus house is commendable but 1 ha is not necessary in cases and 1-2 ha too large. Submits that subdivision (lot area) is approved by a registered engineer and that an interpretation of the reasoning for surplus farm houses, is provided in the Explanation for Rule 7.16.1.2 (b)(ii). The submitter neither supports or opposes Policy 4.2. The submitter queries the meaning of 20m wide in Policy 4.2. The submitter neither supports or opposes Rule 7.15.2.1 size in 7.15 Flood Protection Zone. The submitter queries the determination for horticulture 2 hectare lot. Decisions Requested:

1. The inclusion of an introductory statement in 9.1 Introduction as follows: ‘It is an inherent responsibility that as custodians of the large rural sector within the PNCC confines, that a practical, supportive, disciplined and secure framework is applied to ensure there is business security aimed at fostering and assisting the economic substance of the region and that ecological and landscape features.’

2. Retain paragraph 3 of 9.1 Introduction.

3. Retain Resource Management Issue 10.

4. Retain 3rd paragraph (pg 18) of Explanation for 9.3 Resource Management Issues.

5. Retain Objectives 1, 2, 3, 4, 7 and Policies within 9.3 Objectives and Policies.

6. Consider adding a definition of ‘Intensive Farming’ in Section 4 Definitions.

7. Retain first sentence of the Explanation for R 9.8.2 Sawmills & Rural Industries and also include a reference to the matters raised

in paragraph 3 of 9.1 Introduction, in the Explanation.

8. Retain 7.2 Resource Management Issues.

9. Retain Policy 1.5 of Objective 1.

10. Consider reference to other land classes within Objective 3, Bulletpoint 2.

11. In Policy 3.2 (a) clause (iv) insert after the word ‘soils’, the words ‘and other soils….’.

12. Delete all references to 20ha in R 7.16.1.2 Performance Standard (b) Lot Area (i) and associated Explanation; and R 7.16.4.

13. Retain Rule.7.16.1.2Performance Standard (b)(ii) but have the minimum lot area be determined by a registered engineer or the like.

14. Amend Explanation to R.7.16.1.2 (b) Performance Standards, to include an interpretation for surplus farm houses.

Submission Number

Plan Change Number


SO18 15E S12A NEIZ David K Severinsen David K Severinsen RD4 WAIPUKURAU 4284

YES

Submission: The submitter is concerned about access over the watercourse area to his property, as it may potentially land lock the balance of his property for development. The submitter does not state whether they are in support/neutral/opposition to PPC15E. The submitter suggests a smaller watercourse reserve area which would have less effect on landscape and buffer zone areas. Decision Requested:

1. S12A: To have a formal discussion on the ownership of the stormwater and watercourse reserve areas with the relative owners.


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Submission Number

Plan Change Number


SO19 15A 15C 15D 15G

S7 Subdivision S9 Rural Zone S22 Natural Hazards S23 Utilities S24 Designations

Radio New Zealand Limited

Gary Fowles PO Box 123 RNZ House, Level 2/155 The Terrace WELLINGTON 6011

YES

Submission: The submitter supports recognition of the effects of subdivision 7.1 Introduction, including effects on the safe & efficient functioning of network utilities and reverse sensitivity effects where new, sensitive land uses lead to constraints on exiting land use activities. The submitter supports the wording of the Explanation to Resource Management Issue 1. The submitter supports Resource Management Issue 5 and wording of the associated Explanation. The submitter generally supports the subdivision objectives and policies but is concerned that Section 7 doesn’t provide sufficient recognition of adverse reverse sensitivity effects arising from subdivision, particularly impacts on network utility operations. Seeks an additional Policy and Explanation under Objective 3 to ensure existing infrastructure is appropriately protected from subdivision and reverse sensitivity effects, at the time of subdivision consent, as follows:

“Policy 3.X Recognise the requirements of network utilities in subdivision design, and avoid adverse effects on existing network utilities, including reverse sensitivity effects.

Explanation Inappropriately designed or located subdivision may give rise to reverse sensitivity effects when new, sensitive, land uses lead to constraints on the carrying out of existing land uses. Recognising and preventing reverse sensitivity effects when planning for land use will provide for the continued efficient, affordable, secure and reliable operation and capacity of existing network utilities.”

The submitter supports in part Rule 7.16.1.2 Performance Standards. The submitter is concerned that changing land use in the vicinity of it’s site (such as residential use as a result of subdivision) could result in future residents or occupiers of the land seeking to constrain the operation of its facilities. The submitter seeks the inclusion of additional performance standards for permitted & controlled activities within Section 7, providing that subdivision proposals near the RNZ site are assessed as Restricted Discretionary Activities. It is submitted that a distance of 700 m is an appropriate threshold, and that the following new Performance Standard to Rule 7.16.1.2 (with a consequential amendment to R 7.16.2.3), is included:

“(x) Radio New Zealand Buffer Zone No subdivision shall be approved so as to result in a site for a new dwelling within 700m from a Radio New Zealand Limited’s radio transmission facility, identified on the district Plan map by designation site reference number 99”.

The submitter supports in part Section 9 Rural. The submission notes that RNZ owns & operates radio communication and telecommunication facilities from a site at Gillespies Line, Kairanga (Pt Lots 1 and 2 DP 7073). The site is designated in the Proposed District Plan (# 99) and the underlying zoning is Rural with a Flood Prone Areas overlay. The submission states that RNZ Ltd facilities are an integral part of RNZ’s national communications network, providing news and information to the public and performing a civil defence role. Radio is a key communication tool in the event of natural disasters. RNZ is designated as a Lifeline Utility under the Civil Defence Emergency Management Act 2002. The submitter seeks that the District Plan recognise and provide for RNZ activities and the continued operation, maintenance and improvement of RNZ’s national transmission network; recognise the critical contribution that infrastructure and network utility operations (such as RNZ’s transmission facilities) make to the social, economic and cultural well-being of Palmerston North and the region; and the appropriateness for such infrastructure and network utility operations to be located within the Rural Zone. The submitter is concerned that activities & subdivision in proximity to its transmitter site could have reverse sensitivity effects on the operation of transmission facilities. Reverse sensitivity effects are adverse effects that a new ‘sensitive’ landuse can have on existing activities, i.e they are effects caused by new development. The submitter supports paragraph 6 within the 9.1 Introduction referring to network utility operations. The submitter opposes in part the objectives and policies, in particular Objective 1. It is submitted that Objective 1 and policies, should clearly state that the protection of rural land includes the protection of existing network utility infrastructure, including a requirement to avoid possible reverse sensitivity effects. The submitter seeks the inclusion of a new policy under Objective 1 as follows:

“Policy 1.X: To protect existing network utility infrastructure in the rural zone from the adverse effects of unnecessary and/or unplanned urban expansion, including reverse sensitivity effects”.

The submitter supports the reference in the Explanation for Objective 1 to existing network utility infrastructure.


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The submitter supports intent of Objective 2 however notes that this Objective and its associated policies don’t recognise that network utility infrastructure constitute part of the physical resources of the area. Submits that a new policy and Explanation be included under Objective 2, as follows:

“Policy 2.X: To recognise that existing infrastructure is appropriately placed in the Rural Zone and provides a valuable service to the District and to provide for its continued operation.” Explanation “The requirement for new activities to accept existing amenity levels includes the requirement to avoid possible revers sensitivity effects. Network Utilities may have technical requirements or constraints that limit where they can be sited. Network Utilities may therefore be appropriately sited in the Rural Zone. Recognition of these constraints and protection of existing Network Utilities from reverse sensitivity effects will provide for the continued operation and maintenance of existing Network Utilities while ensuring the health and safety of the people and communities that they serve.

The submitter opposes in part Rule 9.5.1 Permitted Activities. It is submitted that amendments be made to Permitted Activities rules to provide for RNZ to use a back-up emergency generator at its site, in the specific event of a power failure. This ensures that radio transmission can continue in the event of power failure. Requests that Rule 9.5.1 Permitted Activities be amended to specifically provide for the use of the backup emergency generator, as follows:

“The following activities are Permitted Activities provided they comply with the specified Performance Standards: … (f) Use of the backup emergency generator at Radio New Zealand Limited’s radio transmission facility, identified on the District Plan Maps by designation site reference number 99.”

The submitter opposes Rule 9.5.5 Performance Standards – The submitter is concerned that residential buildings could be built near the RNZ transmitter without consideration of impacts on RNZ’s operations or potential impacts for residents of those buildings. The submitter states that a single new, sensitive, activity in proximity to RNZ’s site could also cause significant reverse sensitivity issues for RNZ. The submitter seeks to be informed of future building proposals in the vicinity of the RNZ site and given opportunity to make submissions on any such applications. The submitter requests that transmitters are given analogous treatment to wind turbines, as the categories of effects are the same with both having visual and sound impacts, and amendment to Rule 9.5.5 (b) (i), as follows:

“(b) Separation Distances (i) No residential building may be located less than:

… (d) 700 m from Radio New Zealand Limited’s radio transmission facility, identified on the District Plan Maps

by designation site reference number 99.” The submitter requests a new Discretionary Activity rule for Dwellings and Dependent Dwellings which do not comply with Rule 9.5.5(b)(i)(d) 700 m Separation Distance. The submitter supports Rule 22.8.1.1 which classifies non-habitable structures on production land as a Permitted Activity. The submitter states that its site meets the definition of a ‘non-habitable structure’ in Section 4: Definitions. The submitter supports 23.1 Introduction, particularly the specific identification of telecommunication and radiocommunication networks as network infrastructure within Palmerston North City and strongly supports the recognition of reverse sensitivity issues and the technical constraints facing network utility operators. The submitter supports the Resource Management Issues, in particular Issue 3 which recognises the potential for important network utility structures or activities to be adversely affected by the inappropriate location or intensification of activities that are sensitive to their effects. The submitter supports Policy 1.1 in particular recognition of the benefits of network utilities of regional or national importance and the inclusion of ‘telecommunications and radio communications facilities’ on the list of regionally or nationally important network utilities within Policy 1.1 The submitter generally supports Objective 2 and Policies 2.1-2.4. The submission strongly supports Policy 2.2 & 2.3 which recognises the importance of providing for the avoidance, remedy or mitigation of the potential for reverse sensitivity effects in important network utilities. The submission also states it is critical that the District Plan enables the operation, maintenance and upgrading of existing regionally of nationally important network utilities. Supports giving priority to avoidance of reverse sensitivity effects where practicable. The submitter supports Rule 23.7.1 being permitted activity status for the establishment, operation, maintenance and minor upgrade of telecommunications and radio communication lines, links, works and facilities. Seeks that the wording is retained, as notified. The submitter neither supports or opposes Appendix 2; Index to the Planning Maps. The submitter notes the colour coding on the Index to


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the Planning Maps doesn’t match the colours on the corresponding Planning Maps creating scope for confusion. Section 24 Designations; Appendix 24A: Table 1 Schedule of Designations (Existing Operative Designations) – The submitter supports the Designation at Gillespies Line but seeks the correction of the Designated Purpose of Designation 99 to reflect the wording of the original Notice of Requirement, as follows:“Radiocommunication, Telecommunication & Ancillary Purposes and land uses.” The submitter supports the identification of telecommunication and radio communication networks as network infrastructure within Palmerston North City under 23.1 Introduction. The submitter supports 23.2 Resource Management Issues, particularly Issue 3. The submitter supports recognition of the benefits of network utilities of regional/national importance. The submitter strongly supports the inclusion of telecommunications and radio communications facilities in the list of regionally or nationally important network utilities in 23.3 Objective 1 Policy 1.1. The submitter supports Objective 2 and associated policies, particularly Policy 2.2 and 2.3. The submitter supports the avoidance, remedy, or mitigation of potential reverse sensitivity effects, and the enabling of operation, maintenance and upgrading of existing regionally/nationally important network utilities. The submitter supports permitted activity status for the establishment, operation, maintenance, and minor upgrade of telecommunications and radio communication lines, links, works and facilities under Rule 23.7.1. The submitter strongly supports the recognition of reverse sensitivity and constraints facing network utility operators. The submitter opposes in part the reference (#99) in Section 24. The submitter is concerned that RNZ’s designation needs to be accurately carried over into of the District Plan. Decisions Requested:

1. Retain the 7.1Introduction, as notified.

2. Retain the Explanation for Resource Management Issue 1 as notified.

3. Retain Resource Management Issue 5 and Explanation, as notified.

4. Insert a new Policy and Explanation under Objective 3, as follows: “Policy 3.X Recognise the requirements of network utilities in subdivision design, and avoid adverse effects on existing network utilities, including reverse sensitivity effects. Explanation Inappropriately designed or located subdivision may give rise to reverse sensitivity effects when new, sensitive, land uses lead to constraints on the carrying out of existing land uses. Recognising and preventing reverse sensitivity effects when planning for land use will provide for the continued efficient, affordable, secure and reliable operation and capacity of existing network utilities.”

5. Add the following Performance Standard to Rule 7.16.1.2 (with a consequential amendment to R 7.16.2.3), as follows: “(x) Radio New Zealand Buffer Zone No subdivision shall be approved so as to result in a site for a new dwelling within 700m from a Radio New Zealand Limited’s radio transmission facility, identified on the district Plan map by designation site reference number 99”.

6. Retain paragraph 6 of the 9.1 Introduction, as notified.

7. Include a new policy in 9.3 Objectives & Policies, under Objective 1, as follows “Policy 1.X: To protect existing network utility infrastructure in the rural zone from the adverse effects of unnecessary and/or unplanned urban expansion, including reverse sensitivity effects”. And retain the reference to existing network utility infrastructure in the Explanation for Objective 1.

8. Insert new policy and Explanation under Objective 2, as follows: “Policy 2.X: To recognise that existing infrastructure is appropriately placed in the Rural Zone and provides a valuable service to the District and to provide for its continued operation.” Explanation “The requirement for new activities to accept existing amenity levels includes the requirement to avoid possible revers sensitivity effects. Network Utilities may have technical requirements or constraints that limit where they can be sited. Network Utilities may


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therefore be appropriately sited in the Rural Zone. Recognition of these constraints and protection of existing Network Utilities from reverse sensitivity effects will provide for the continued operation and maintenance of existing Network Utilities while ensuring the health and safety of the people and communities that they serve.

9. Include a new Performance Standard to Rule 9.5.5 (b)(i), as follows: “(b) Separation Distances No residential building may be located less than: … 700 m from Radio New Zealand Limited’s radio transmission facility, identified on the District Plan Maps by designation site reference number 99.”

10. Include a new Discretionary Activity rule in Rule 9.8 Discretionary Activities for Dwellings and Dependent Dwellings which do not comply with R 9.5.5(b)(i)(d) 700 m Separation Distance.

11. Retain Rule 22.8.1.1 as notified.

12. Retain 23.1 Introduction as notified.

13. Retain the 23.2 Resource Management Issues, particularly Issue 3, as notified.

14. Retain 23.3 Objective 1 and Policy 1.1 as notified.

15. Retain Objective 2 and Policies 2.2, 2.3 & 2.4 as notified.

16. Retain Rule 23.7.1 as notified.

17. Update either the Index to the Planning Maps or the Maps so the relevant colours match.

18. Correct the description of the designated purpose of the site (#99) in Section 24, to read as follows:“Radiocommunication,

Telecommunication & Ancillary Purposes and land uses.”

19. 23.1: That 23.1 Introduction is retained as notified.

20. 23.2: That 23.2 Resource Management Issues is retained as notified.

21. 23.3 Objective 1: That 23.3 Objective 1 is retained.

22. 23.3 Objective 1 Policy 1.1: That 23.3 Objective 1 Policy 1.1 is retained as notified.

23. 23.3 Objective 2: That 23.3 Objective 2 is retained as notified.

24. 23.3 Objective 2 Policies 2.2 & 2.3: That 23.3 Objective 2 Policies 2.2 and 2.3 are retained as notified.

25. R23.7.1: That Rule 23.7.1 is retained as notified. SubmisionNimber

Plan Change Number


SO20 15A S7Subdivision S9 Rural Zone

Ministry of Education

C/- Jessica Allan 93 Ingestre Street WHANGANUI

YES

Submission: The submitter supports 23.2 Resource Management Issues, particularly Issue 3. The submitter opposes Policy 3.2 as it unduly restricts the ability of the Ministry to best manage ongoing requirements for designated schools located in Rural Areas. The submitter requests the addition of a new sub-section to Policy 3.2, as follows:

“b)The subdivision of land associated with designated Ministry of Education sites is for the purpose of supporting either the acquisition or disposal of Crown land to ensure Schools can meet operational demands.”

The submitter opposes Rule 7.16.1.2 (b) Performance Standards for Controlled Activities – Lot Area, specifically an increase in the minimum


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lot area to 20 ha provides the following reasons: - It limits options relating to the ongoing management of schools owned in the Rural Zone, inn particular, the Ministry’s ability to make

property-related decisions around the implications of disposal (or acquisition) of land in Rural areas; - It reduces flexibility for the Ministry such as having to retain entire land parcels, and - It has potential cost implications on both Boards of Trustees and potentially the Crown, relating to the need to manage and maintain

land which is surplus to education purposes. The submitter requests that a new Performance Standard be added to Rule 7.16.1.2 (b),as follows:

“(iv) For the purpose of designated school sites and any subdivision relating to surplus or additional land requires, the minimum 20 ha lot size does not apply.”

Decisions Requested:

1. Add a new sub-section to Policy 3.2 as follows : “b) The subdivision of land associated with designated Ministry of Education sites is for the purpose of supporting either the acquisition or disposal of Crown land to ensure Schools can meet operational demands”. Or such relief that may give effect to this submission.

2. Add a new Performance Standard to R 7.16.1.2 (b) as follows: “(iv) For the purpose of designated school sites and any subdivision relating to surplus or additional land requires, the minimum 20 ha lot size does not apply. “ Or such relief that may give effect to this submission.

Submission Number

Plan Change Number


SO21 15A S7 Subdivision Appendix 2: Planning Maps

Jacobus J Van Vuuren

Jacobus J Van Vuuren 1418 Napier Road ASHHURST

NO

Submission: The submitter opposes Section 7.16 Rural Zone. It is submitted that Ashhurst South is ideally suited for development being close to water, sewerage and roading infrastructure and submits that this (area) be rezoned to allow for development and growth and make more affordable land available to develop near to town. The submitter requests that Council/planners consider subdivision sizes encompassing a mixture of lots varying between 2500m2 and 1 ha in Section 7.16 Rural Zone. Decisions Requested:

1. Rezone Ashhurst South to allow for development and growth.

2. That Council/planners consider subdivision sizes encompassing a mixture of lots varying between 2500m2 and 1 ha. Submission Number

Plan Change Number


SO22 15A-H S4 Definitions S6 General

The Oil Companies (Z Energy Ltd, BP Oil NZ Ltd, Mobil Oil NZ Ltd)

Mark Laurenson Burton Planning Consultants Ltd Level 1, 2-8 Northcroft St PO Box 33-817 Takapuna AUCKLAND 0740

YES

Submission: The submitter supports the definition of earthworks in S4, as it is consistent with the approach taken in the Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011). The submitter notes that Section 4 does not include a definition for Contaminated Land. The submitter suggests a definition that is consistent with the RMA. The submitter states that permitted thresholds in R6.3.6.1 such as proximity of earthworks to boundaries and depth of excavation are not generally relevant to tank removal/replacement activities due to the following reasons:

1. The tank pits are typically sheet piled to a depth of 6-8m. 2. The earthworks occur over a short period of time. 3. The ground is reinstated to the equivalent standard of surrounding ground.


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The submitter states that it is unclear whether R6.3.6.1(a-c)(ii) would apply only to finished ground levels or whether an excavation to this depth would trigger a resource consent if it will be backfilled to the pre-existing ground level. The submitter notes that excavations for petroleum tank removals/replacements are typically 4.5m in depth, therefore may require consent under these provisions. The submitter states that even landscaping within 3m of the boundary would necessitate consent under R6.3.6.1(a,c,d)(iii). The submitter states that there is no section related to contaminated land, or any reference to the requirements of the Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011) and its relationship with the District Plan. The submitter suggests a contaminated land chapter be included in the District Plan, and considers it necessary to include an explanatory statement around how the Council will hold and source information used to establish whether land is contaminated for the purposes of said NES. The submitter suggests that an appropriate policy framework be adopted within this chapter, particularly to guide applications considered for discretionary activity status under said NES. If a new policy framework is considered outside the scope of PPCA-H, then the submitter recommends a reference in S6.3 to the relationship between the NES and the District Plan, particularly 6.3.4. Decisions Requested:

1. Section 4: That the S4 definition of Earthworks is retained without modification. 2. Section 4: That the following definition for Contaminated Land is included in S4 as follows:

Contaminated Land means land that has a hazardous substance in or on it that – (a) has significant effects on the environment; or (b) is reasonably likely to have significant adverse effects on the environment.

3. R6.3.6.1: That R6.3.6.1(a)(ii), (b)(ii), and (c)(ii) is clarified in relation to the difference between existing and finished ground levels only or to any excavation of more than 1.5m depth irrespective of whether the ground will be reinstated to the pre-existing level.

4. R6.3.6.2: That R6.3.6.2 Exclusions from Earthworks Rule 6.3.6.1 is amended to include as follows: (vii) Earthworks for the replacement and/or removal of a fuel storage system as defined by the Resource Management Regulations 2011 (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health).

5. R6.3.6.2: That R6.3.6.2 Exclusions from Earthworks Rule 6.3.6.1 is amended to provide exemptions for minor earthworks, including new landscaping and boundary treatments.

6. S6: That S6 be amended to include a new section relating to contaminated land: Section 6.4 - Contaminated Land The National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health (NES) came into effect on 1 January 2012. The purpose of the NES is to ensure national consistency in the management of contaminated land. It includes national planning rules that direct that requirement for consent or otherwise for activities on contaminated or potentially contaminated land, and standardised methods for that establishment of numerical standards for contaminants in soils. This includes a national set of soil contaminant standards for 12 priority contaminants, and best practice guidelines for investing and reporting on contaminated or potentially contaminated land. An inability to meet the requirements of this standard, or the undertaking of particular activities in certain locations will result in the need for a resource consent. Reference should also be made to the Ministry of Environment website for a copy of these regulations, a user guide and documents incorporated by reference in these regulations. Reference must also be made to this Ministry of Environment website for the latest version of the documents incorporated by reference. Land known or likely to be potentially affected by soil contaminants are those sites recorded on a Contaminated Land Register held either by the Horizons Regional Council or Palmerston North City Council and/or those on the Hazardous Activities and Industries List (HAIL) contained in Appendix 4 of the National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health. Objectives: - There are no significant risks to human health posed by residual soil contaminant levels in land that has a history of land use

which may have resulted in contamination. Policies: - Ensure that before any development, redevelopment or change of land use on land that has a history of land use that may

have resulted in contamination, associated health risks are appropriately identified and managed. - Any change of land use, development or redevelopment on contaminated land ensures that any proposed management

controls, including remediation, pathway or receptor controls, will ensure the risks to human health are acceptable for the intended land use.


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Alternatively, that S6.3.4 be amended to include a cross-reference to the relationship between the National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health and the District Plan.

7. That PPCA-H is amended to include any such relief, including additions, deletions or consequential amendments necessary to give

effect to this submission as a result of the matters raised. Submission Number

Plan Change Number



Axis Estate Ltd & PMW Trustees Co Ltd

Colin Fink Kevin O’Connor & Associates 71 Pitt Street PO Box 600 PALMERSTON NORTH

YES

Submission: The submitter opposes Rule 7.16:Rural Zone in Section 7. The submitter notes there is no provision for ‘Integrated development’ in Rule 7.16, as identified in the Rural Residential Land Use Strategy (RRLUS) published by the Palmerston North City Council, June 2012. Seeks that specific objectives and rules are included within the Plan Change to accommodate the ability to undertake “Integrated Development”

The submitter opposes Planning Map 10. The Submitter requests that Council reassess the current (rural) zoning of Lot 2 DP 304100 & Lot 2 442236; Lot 3 DP 304100 and Lot 4 DP 304100, located on Planning Map 10 of Plan Change 15. Submits that this site is recognised as land being suitable for “Integrated Development” as identified within the RRLUS allowing for lots down to 2,500m2 – 1ha in area. This land is able to satisfy most of the criteria in that subject land (Specific Development Principles, Category C: Integrated Development):

‐ Is able to connect to an existing wastewater system ‐ Does not undermine the purpose of the Council’s Residential Growth Strategy ‐ Provides an alternative for those seeking rural residential living in close proximity to existing urban areas ‐ Council services were available to the site ‐ The site is near existing public transport routes

Decision Requested:

1. That specific objectives and rules be included within the Plan Change to accommodate the ability to undertake “Integrated Development”’ as identified within the RRLUS, published by the Palmerston North City Council in June 2012.

2. Reassess the current (rural) zoning of Lot 2 DP 304100 & Lot 2 442236; Lot 3 DP 304100 and Lot 4 DP 304100, located on Planning Map 10 of Plan Change 15.

Submission Number

Plan Change Number


SO24 15B S7 Subdivision S9 Rural Zone

Joseph Poff Joseph Poff 658 Pahiatua Track RD1 PO Box 514 PALMERSTON NORTH

YES

Submission: 15A The submitter opposes Plan Change 15A: The submitter states that PC15A is deeply flawed. The submission notes that: - Plan Change 15A restricts land available for development which is close to the City and on poor soils; - other cities are fast tracking the rezoning of rural land to enable housing development; - the wholesale elimination of an enormous area of land from the Rural Residential Overlay on poor quality soils, is absurd. - The intent of PC15A to protect Class A1 productive agricultural soils from subdivision and that much of the land proposed to be

removed from the existing Rural Residential Overlay, is not in this category. The submitter is outraged that the Planning Department has taken the extraordinary step of taking this proposed Plan Change to the Environment Court to obtain a ruling that it is legally binding before public consultation has even begun. The submission states that the Planning Department needs to be held to account for its destructive actions over the last 8 years where: 1. Despite a Council resolution mandating and financing a neutral participation in the Resource Consent Application for the City’s Turitea

Wind Farm, the Planning Department invested heavily in building a position of opposition which totally ignored the elected Councillors


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decision and directive. Not to mention damage done to the prospect of a $2M/annum passive revenue stream into the ratepayers coffers, because the Planning Department is clearly not concerned about the affordability of rates for the local population.

2. The unprecedented waste of ratepayers money spent harassing the Te Rere Hau Wind Farm through the Courts on behalf of individuals who make noise complaints in the misguided belief they should be compensated because they sometimes hear a wind turbine, further demonstrates the disconnect with reality within this department. The Wind Farm is operating within its consent and there is no need to waste ratepayers money in this way.

3. The Environment Court ruling applied for by the Planning Department further demonstrates that priority for the greater good and encouraging public participation in Policy Planning is not part of their current mandate. No wonder the region has fallen to the bottom of the national ranking for economic performance!

4. The Planning Department needs a major overhaul. The submitter queries why $1M ratepayers dollar/year is spent to attract investment through Vision and Destination Manawatu only to drive it away via a misguided Planning Department. The submitter notes the chance, with a new Mayor, that the City can regain (its) pre-Naylor positivity and become a place where people will want to come to live, invest, create jobs and opportunities. Hopes damage to City’s reputation can be repaired with good leadership and decision making going forward. It will take time and require changes in the Planning Department. 15B The submitter is opposed to the current drafting of PPC15B. The submitter is concerned that S9 does not adequately give effect to the National Policy Statement for Renewable Energy Generation, and that it will be more difficult to gain consent to build a wind farm. The submitter states that the district's economic performance will be adversely affected as a result of PPC15B. Pages 7 & 8 of this submission outline previous submissions relating to PPC15B. Pages 9-11 of this submission provide evidence in opposition to adverse health effects resulting from wind turbine exposure. The submitter is concerned that the Tararua Ranges Landscape Protection Area will prohibit any future windfarms development on the Tararua Ranges. Decisions Requested:

1. That PPC15A is reviewed.

2. That PPC15B be rejected.

3. That the PNCC Planning Department be overhauled, as there are elements of the department not suited to planning for a better future for Palmerston North, and that no further policy changes are made until this has been completed.

4. Request explanations into the four points raised as to the rationale and cost to ratepayers around Wind Farm planning on Page 5

of this submission. Submission Number

Plan Change Number


SO25 15A


Matthew Currie Matthew Currie 22 Centennial Drive PALMERSTON NORTH

YES

Submission: The submitter generally supports Plan Change 15A.

The submitter supports Rule 7.16.1.2 (b)(i), the 20 ha minimum lot size on productive land. The submitter states that as an intensive vegetable producer he has been concerned for many years about the relatively unproductive 4 ha blocks.

The submitter opposes in part Rule 7.16.1.2 (b)(ii): The Submitter is concerned about subdivision of surplus dwellings. It is submited that where there is single or multiple existing dwellings on a title of land, that these be able to be subdivided as both single or multiple dwellings on one new title, or multiple dwellings on each their own title. Also submits that 1ha is too large and the minimum should be 0.5ha, to allow more land to remain in productive use. Cites 191 Te Matai Road as an example showing how the 0.5 ha minimum lot size is desirable. A map (attached) shows two dwellings which are located very close together and could be subdivided either with one title for each dwelling, or two dwellings on a single title.

The submitter supports in part Rule 7.16.2.1 (b)(iii) Rural Residential Overlay Area 1 ha Lot Area: The submitter supports rural residential sections but with a reduced minimum lot size of 0.5 ha. The submission notes that families choosing to live in a rural residential (area) are wanting more space to suit their lifestyle, but because of the 1 ha minimum lot size often end up with more space than required. These


24

families have made a choice that sections of 0.1 ha or less in the Residential Zone are not large enough for their needs. However to go from a 0.1 ha or less to a 1 ha section (10 x the size) is more than required.

The submitter opposes R9.8 Rules: Discretionary Activities: The submission notes that the establishment of a place of worship is a ‘Non-complying Activity’ in the Rural Zone and submits that this be changed to Discretionary Activity (Unrestricted) to match the requirements for Places of Worship in the Residential Zone.

Decision Requested: 1. Amend Section 7.16 so that where there are surplus existing dwellings that these are able to be subdivided both as multiple

dwellings on a new title, or multiple dwellings each on their own title.

2. Amend Rule 7.17.1.2 (b)(ii) to allow the subdivision of surplus dwellings on a minimum 0.5 ha lot.

3. Amend Rule 7.16.2.1(b) (iii) Rural Residential Overlay Area to allow rural residential lots with a minimum size of 0.5ha.

4. Change the establishment of Places of Worship in the Rural Zone from ‘Non-complying’ to ‘Discretionary Activity (Unrestricted)’. Submission Number

Plan Change Number


SO26 15A

Appendix 2: Planning Maps John R Wycherley John R Wycherley 11 Worcetser Street ASHHURST

YES

Submission: The submitter opposes Planning Map 9 and rural zoning of Lot 2 DP 469977. The submitter is concerned that there is an urgent need of smaller block sizes in Ashhurst. The submission states that there is nothing available and submits that Council takes serious consideration to make rural residential areas in Ashhurst. The submitter also states that he has family that may have to be cared for in the near future and seeks that his site (Lot 2 DP 469977) be bought into rural residential.

Decisions Requested: 1. That Council takes serious consideration to making areas of rural residential in Ashhurst.

2. That my site (Lot 2 DP 469977) be bought into rural residential.

Submission Number

Plan Change Number


SO27 15A 15C 15E

S7 Subdivision S9 Rural Zone S19 Institutional S12A NEIZ S12 Industrial

New Zealand Fire Service Commission (NZFS Commission)

Claire Fell C/- Beca Ltd PO Box 3942 WELLINGTON 6140

YES

Submission: The submitter supports in part Plan Change 15A – The submission states that the NZFS Commission has responsibility under the Fire Service Act 1975 to provide for structural firefighting activities in a safe, effective and efficient manner; and that it monitors development occurring under the RMA 1991 to ensure that appropriate consideration is given to fire safety. The submitter notes that the risk of fire represents a potential effect of low probability but high potential impact. The submitter is concerned about the provision of a water supply, and access to this supply, to enable the NZFS to operate effectively and efficiently. The submission notes that this is best achieved through compliance with the New Zealand Standard for the provision of a firefighting water supply, known as the New Zealand Firefighting Water Supplies Code of Practice SNZ PAS 4509:2008 (the NZFS Code). This code sets out standards for firefighting water supply and access and applies to both reticulated and non-reticulated water supply systems.

The submitter supports RM Issue 5 and the associated Explanation (5th paragraph) in Section 7 which explains the requirement for firefighting supplies in Rurally zoned areas.


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The submitter supports the retention of Policy 2.8(1) and Policy 2.8 (2) in Section7.3 as it enables the NZFS to have readily available water and access to this water, and enhances the effectiveness and efficiency of their operations.

The submitter supports in part, the addition of Policy 3.1(2) which ensures that the stated matters of subdivision of rural land into allotments of 20 ha, are provided for. The submitter recommends that this Policy include on-site firefighting water supply as a matter to be provided for in this type of development. It is submitted that on-site firefighting water supply is essential as large lot rural subdivisions are generally non-reticulated and a fair distance from fire stations. The following amendment to Policy 3.1(2) is sought:

‘2. Adequate provision must be made on-site, for water supply, waste disposal, stormwater drainage, the disposal of sewerage, firefighting water supply (in accordance with SNZ PAS 4509:2008), and the supply of electricity, where residential occupancy is proposed.’

The submitter supports the retention of Policy 7.7(Napier Road development area) within Chapter 7 as it ensures that NZFS has readily available water and access to this water, and enhances the effectiveness and efficiency of their operation.

The submitter supports the retention of Rule 7.7.1(Residential Zone) in Section 7.3. The submission notes that 3.5 metres is enough space in urban areas for fire trucks to access the property however, it does not allow for manoeuvrability around the truck where access is confined. Also notes in the large majority of urban developments, access to the property can be gained from the road verge.

The submitter supports the retention of Rule 7.8.1 and Rule 7.8.1.2 (d)(ii) (a): ‘(a)All new lots must have sewer, stormwater and water supply services that are connected to essential services’. This rule ensures all new lots have a reticulated water supply ensuring that NZSFS has readily available water and access to this water, enhancing the effectiveness and efficiency of their operation.

The submitter supports the retention of Rule 7.9.1 and Rule 7.9.1.2 (d)(ii) (a): ‘(a)All new lots must have sewer, stormwater and water supply services that are connected to essential services’. This rule ensures all new lots have a reticulated water supply ensuring that NZFS has readily available water and access to this water enhancing effectiveness and efficiency of their operation.

The submitter supports in part Rule 7.9.2.1 Performance Standards (a) (iii) North East Industrial Zone Extension Area. It is submitted that a provision for fire-fighting water supply be added to the information required to be provided in the Scheme Plan for developments in the North East Industrial Extension Area to ensure that development occurring as a part of this Scheme Plan is protected against fire, as well as the surrounding properties. The submitter requests Rule 7.9.2.1 Performance Standard (a)(iii) be amended as follows:

“(iii) A Development Scheme Plan, describing the proposed site planning and design. This will include the following: … (k) How firefighting water supply will be provided (in accordance with SNZ PAS 4509:2008).”

The submitter supports retaining Rule 7.10.1 (d)(ii)(a) (a) for the Institutional Zone. The submission states that this Rule as a Matter of Control, ensures all new lots have a reticulated water supply and also that NZFS has readily available water and access to this water, enhancing the effectiveness and efficiency of their operation.

The submitter supports retaining Rule 7.16.1 and Rule 7.16.1.2 Performance Standard for Controlled Activities (c)(i) for the Rural Zone. This rule, as a Matter of Control, ensures all new lots have access to the properties which are wide enough to allow for a fire appliance. This rule will enhance the efficiency of the NZFS operation.

The submitter opposes in part Rule 7.16.1.2 Performance Standards. The submitter recommends the addition of a new Performance Standard (h), to provide consistency with the policies of the chapter which mention firefighting provisions; as follows:

(h) – Provision of Firefighting Water Supply All rural subdivision must be provided with a water supply for firefighting in compliance with SNZ PAS 4509:2008. Other methods may be adopted subject to the written approval of the New Zealand Fire Service.

The submitter supports in part Rule 7.16.2.1 Assessment Criteria (b) & Explanation, in particular the inclusion of the Explanation and Performance Standards for development within the Aokautere Rural Residential Areas and Moonshine Valley. However, it is submitted that it is important to include the provision for fire fighting water supply as part of the assessment criteria under (b) On-site Services, to align with the overarching policies of the plan for the provision of fire fighting water supply. The submitter requests that part (b) of the Assessment Criteria be amended as follows:

“(b)On-site Services …


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(ii)The extent to which the water, wastewater, and stormwater and firefighting water supply (in accordance with SNZ PAS 4509:2008) is appropriately managed within the subdivision to ensure the protection of rural residential development from any adverse impacts.’”

The submitter supports in part Rule 7.16.3.1(2). The submitter considers that if a Controlled Activity is unable to meet the requested new Performance Standard relating to Fire fighting Water Supply (Rule 7.16.1.2 (h)), that Rule 7.16.3.1 needs to be amended. The following amendment is sought:

‘(2) Any subdivision which does not comply with the Controlled Activity Performance Standards 9R 7.16.1.2) for Existing Buildings, Lot Area (R7.16.1.2(iii) only), Access, Esplanade Reserves, Intensive Farming Buffer Zone, provisions of firefighting water supply (Rule 7.16.1.2 (h))and Road, is a Discretionary Activity.

The submitter supports the retention of Rule 9.5.2 Production Forestry Performance Standards (a) Planting Notice and clause (v) regarding the provision for firefighting water supply.

The submitter supports in part Rule 9.5.5 Dwelling and Accessory Buildings. The submitter seeks that a new provision (h) be added to the Performance Standards of Rule 9.5.5 to ensure dwellings and accessory buildings within the Rural Zone are compliant with the NZFS Code of Practice, whether it be through full compliance with the Code or other method of compliance with written agreement from the NZFS. The recommended Performance Standard (h) is highlighted below:

‘(h) Provisions for Firefighting Water Supply Dwellings must be provided with a water supply for firefighting in compliance with SNZ PAS 4509:2008. Other methods may be adopted subject to the written approval of the New Zealand Fire Service.’

The submitter opposes in part Rule 9.6.2 Relocated Dwellings. The submitter requests a consequential amendment to Rule 9.6.2 Relocated Dwellings Performance Standard (i) to reflect the change requested above regarding the inclusion of (h) Provision for Firefighting Water Supply to ensure relocated dwellings within the Rural Zone are compliant with the NZFS Code of Practice, whether it be through full compliance with the Code or other method of compliance with written agreement from the NZFS. The submitter recommends that Performance Standard (i) of 9.6.2 be amended to read:‘(i) Compliance with the Performance Standards in Rule 9.5.5 (a)-(h).’

The submitter opposes in part Rule 9.6.3 Dependent Dwelling Units Performance Standard (iv) – The submitter requests a consequential amendment to Rule 9.6.3 to reflect the change requested above regarding the inclusion of (h) Provision for Firefighting Water Supply, to ensure dependent dwellings within the Rural Zone are compliant with the NZFS Code of Practice, whether it be through full compliance with the Code or other method of compliance with written agreement from the NZFS. The submitter recommends Performance Standard (iv) of Rule 9.6.3 be amended to read:‘(iv) Other – Compliance with the Performance Standards in Rule 9.5.5(b)(i)(c), (c), (d), (c),and (g) and (h).’ The submitter opposes in part Rule 9.7.1 Restricted Discretionary Activity – Dwellings and Accessory Buildings. The submitter seeks to make firefighting water supplies a matter of Restricted Discretion, if the Permitted Standards for dwellings and accessory buildings cannot be complied with. This will allow any non-permitted activity to take account of the provision for firefighting water supply, which the submitter states is as an essential component of rural development, given the greater distances of rural buildings from fire stations. The submitter requests that Rule 9.7.1 be amended as highlighted below:

‘ Dwellings and Accessory Buildings not complying with Permitted Activity Performance Standards for height and separation distance and water supplies for fire fighting (excluding Performance Standards R 9.5.5 (b)(i)(c) and activities prohibited by R 9.10.1): … are Restricted Discretionary Activities with regard to:

• Provision of water supplies for fire fighting purposes

Assessment Criteria … (d) The degree of compliance with SNZ 4509:2008 and whether any consultation with the New Zealand Fire Service has been undertaken.’

The submitter supports Rule 12A.4.1 Permitted Activities – Performance Standards: (m) Essential Services in Section 12A - North East Industrial Zone. In particular, the submitter supports R 12A.4.1(m)(i) requiring all development within this industrial area to be connected to


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the reticulated supply. This ensures that future development within the new industrial area will have firefighting water supply available at times enabling NZFS to efficiently and effectively operate in the case of an emergency. The submitter opposes in part Rule 12A.6.2 Restricted Discretionary – North East Industrial Zone Extension Area; Assessment Criteria. The submitter requests the addition of firefighting water supply as a Matter of Restriction for assessment, under the essential services section of the rule. This will ensure significant developments give consideration to the risk of fire on their development, as well as the impact of fire on the surrounding buildings. The submitter requests the amendment of Rule 12.6.2 Assessment Criteria (k) Essential Services, to include a new assessment criterion, as follows:

“(k) Essential Services … (x) The provision of firefighting water supply in accordance with SNZ PAS 4509:2008 or as otherwise approved by the New Zealand Fire Service.”

The submitter opposes in part Policy 5.3 in Section 12: Industrial Zone (Braeburn Industrial Area). The submitter seeks that fire fighting water supplies be considered as a part of planning for services within the Braeburn Industrial Area. It is submitted that having firefighting water supply as a part of this policy will ensure firefighting supplies are considered as a part of the development phase, and protection of the development from the risk of fire. The submitter requests that Policy 5.3 is amended as outlined below:

“Policy 5.3 To require as a matter of priority at the time of the first development that planning for water, wastewater, and stormwater, and Fire Fighting water supply services is considered for the entire development of the Braeburn Industrial Area.”

The submitter opposes in part Rule 12.8.5 – Braeburn Industrial Area Performance Standard (a)(viii) – The submitter requests a Performance Standard (a)(viii) to support the requested amendment to Policy 5.3 above. Submits that Rule 12.8.5(a) (viii) be amended, to include the following standard:

‘(viii) Availability of infrastructural network servicing provision, including how the proposed infrastructure (roading, water, wastewater, and stormwater, and firefighting water supply in accordance with SNZ PAS 4509:2008) will provide for future staged development of the Braeburn Industrial Area.’

The submitter supports the inclusion of the Bunnythorpe Fire Station under S19.2 Resource Management Issues. The submitter supports Rule 12A.4.1(m)(i), as it will ensure that future development within the NEIZEA will have firefighting water supply available at all times to enable the New Zealand Fire Service to respond to emergencies efficiently and effectively. The submitter requests a minor change to the wording of R12A.4.1. The submitter requests the addition of a new Assessment Criterion under R12A.6.2 to ensure that significant developments give thought and consideration to the risk of fire on their development as well as the impact of fire on the surrounding buildings. The submitter requests the amendment of S12 Policy 5.3 to ensure that firefighting water supply is considered as part of the development phase. The submitter requests the amendment of R12.8.5(a)(viii) to support the amendment requested for S12 Policy 5.3. Decisions Requested:

1. Include Resource Management Issue 5 and paragraph 5 of the Explanation within Section 7.2, as notified.

2. Retain Policy 2.8 (1) and Policy 2.8(2) of Section 7.3 Objectives & Policies.

3. That Policy 3.1(2) of Section 7.3 Objectives & Policies, be amended as follows: ‘2. Adequate provision must be made on-site, for water supply, waste disposal, stormwater drainage, the disposal of sewerage, firefighting water supply (in accordance with SNZ PAS 4509:2008), and the supply of electricity, where residential occupancy is proposed.’

4. Retain Policy 7.7 of Section 7.3 Objectives & Policies.

5. Retain Rule 7.7.1 of Section 7.7: Residential Zone.

6. Retain Rule 7.8.1 and Rule 7.8.1.2 (d) (ii) (a) in Section 7.8: Business Zones.

7. Retain Rule 7.9.1 and Rule 7.9.1.2 (d)(ii) (a) in Section 7.9: Industrial Zone and North East Industrial Zone.


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8. That Rule 7.9.2.1 Performance Standard (a)(iii) be amended as follows:

“(iii) A Development Scheme Plan, describing the proposed site planning and design. This will include the following: … (k) How firefighting water supply will be provided (in accordance with SNZ PAS 4509:2008).”

9. Retain Rule 7.10.1 and Rule 7.10.1.2(d)(ii)(a) (a) in Section 7.10:Institutional Zone.

10. Retain Rule 7.16.1 and Rule 7.16.1.2 Performance Standard (c)(i) in Section 7.16: Rural Zone.

11. Add a new Performance Standard (h) in Rule 7.16.1.2 Performance Standards, as follows:

“(h) – Provision of Firefighting Water Supply All rural subdivision must be provided with a water supply for firefighting in compliance with SNZ PAS 4509:2008. Other methods may be adopted subject to the written approval of the New Zealand Fire Service.”

12. Retain the Performance Standards of Rule 7.16.2.1 and the Explanation for development within the Aokautere Rural Residential Areas and Moonshine Valley.

13. Amend part (b) of the Assessment Criteria in Rule 7.16.2.1 Restricted Discretionary Activity, as follows: “(b)On-site Services … (ii)The extent to which the water, wastewater, and stormwater and firefighting water supply (in accordance with SNZ PAS 4509:2008) is appropriately managed within the subdivision to ensure the protection of rural residential development from any adverse impacts.”

14. That Rule 7.16.3.1 be amended, to recognise the new Controlled Activity Performance Standard (h) in Rule 7.16.1.2, as follows: ‘(2) Any subdivision which does not comply with the Controlled Activity Performance Standards 9R 7.16.1.2) for Existing Buildings, Lot Area (R7.16.1.2(iii) only), Access, Esplanade Reserves, Intensive Farming Buffer Zone, provisions of firefighting water supply (Rule 7.16.1.2 (h))and Road, is a Discretionary Activity.

15. Retain Rule 9.5.2 Performance Standard (a) Planting Notice and Clause (v).

16. That a new Performance Standard (h) be added to Rule 9.5.5, as highlighted below: ‘(h) Provisions for Firefighting Water Supply Dwellings must be provided with a water supply for firefighting in compliance with SNZ PAS 4509:2008. Other methods may be adopted subject to the written approval of the New Zealand Fire Service.’

17. That Performance Standard (i) to Rule 9.6.2, be amended to read:‘(i) Compliance with the Performance Standards in Rule 9.5.5 (a)-(h).’

18. That Performance Standard (iv) of Rule 9.6.3 be amended to read ‘(iv) Other – Compliance with the Performance Standards in Rule 9.5.5(b)(i)(c), (c), (d), (c),and (g) and (h).’

19. That Rule 9.7.1 be amended as highlighted below: ‘ Dwellings and Accessory Buildings not complying with Permitted Activity Performance Standards for height and separation distance and water supplies for fire fighting (excluding Performance Standards R 9.5.5 (b)(i)(c) and activities prohibited by R 9.10.1): … are Restricted Discretionary Activities with regard to:

• Provision of water supplies for fire fighting purposes

Assessment Criteria … (d) The degree of compliance with SNZ 4509:2008 and whether any consultation with the New Zealand Fire Service has been undertaken.’

20. Retain Rule 12A.4.1 Permitted Activities Performance Standard (m) Essential Services, Clause (i).


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21. Requests the amendment of Rule 12.6.2 Assessment Criteria (k) Essential Services, to include a new assessment criterion, as follows: “(k) Essential Services … (x) The provision of firefighting water supply in accordance with SNZ PAS 4509:2008 or as otherwise approved by the New Zealand Fire Service.”

22. Retain the reference to the Bunnythorpe Fire Station within 19.2 Resource Management Issues of the Institutional Zone.

23. R12A.4.1: That R12A.4.1 Permitted Activities – Performance Standards be amended as follows: Unless otherwise specified as acontrolled activity, the following are permitted activities provided that they comply with the relevant performance standards conditions and provided the land is not a Scheduled North East Industrial Zone Site:…

24. R12A.6.2: That R12A.6.2 Restricted Discretionary Assessment Criterion (k) be amended as follows: (k) Essential Services… (x) The provision of firefighting water supply in accordance with SNZ PAS 4509:2008 or as otherwise approved by the New Zealand Fire Service.

25. S12 Policy 5.3: That S12 Policy 5.3 be amended as follows: To require as a matter of priority at the time of the first development that planning for water, wastewater, and stormwater and Fire Fighting water supply services is considered for the entire development of the Braeburn Industrial Area.

26. R12.8.5(a)(viii): That R12.8.5(a)(viii) be amended as follows: (viii) Availability of infrastructural network servicing provision, including how the proposed infrastructure (roading, water, wastewater, and stormwater, and firefighting water supply in accordance with SNZ PAS 4509:2008) will provide for future staged development of the Braeburn Industrial Area.

Submission Number

Plan Change Number


SO28 15A 15C 15E 15H

Appendix 2: Planning Maps Appendix 8.8 S13 Airport

Brian Green Properties (PN) Ltd

Paul Thomas Environmental Management Services PO Box 29024 WELLINGTON 6443

YES

Submission: The submitter opposes Planning Map 14 and specifically the rural zoning of 24 ha fronting Kelvin Grove & Stoney Creek Road (land owned by submitter). The submission states that this land was assessed as being suitable for urban growth, but for the 55 dB(A) noise contour, which is now shown to be inaccurate (AirBiz Report). On this basis the submitter considers the contours should be amended (at least along the lines of the AirBiz contours), and only a small part of the area is affected by air noise, and that his land be considered for appropriate development options. In the context of Plan Change 15A, it is submitted that an appropriate approach is to include the (Green) land in the rural residential overlay that adjoins this land to the north or other more intensive development options which may also be appropriate.

The submitter supports Planning Map 39 and specifically the extension of the Overlay in Valley Views Road (between Pacific Drive & Turitea Road) - The submitter supports the extension of the rural residential overlay in this area. The submitter owns land in the area and intends to develop it for rural residential activities.

The submitter supports Rule 7.16.2.1(b) Minimum Lot Area, specifically the minimum lot size for the Aokautere Rural Residential Area of 5,000m2 excluding lots for access, utilities or reserves. Further submits that this lot size is appropriate for the 24 hectares of (Green) land fronting Kelvin Grove Road & Stoney Creek Road referred to above. The submitter requests Rule 7.16.2.1(b)(i) be amended as underlined below:

(i) In the Aokautere Rural Residential Area and the part of the Rural Residential Overlay located south of Kelvin Grove Road/Stoney Creek Road – 5,000m2, excluding lots for access, utilities or reserves.’

Or other wording that achieves the same affect.


30

The submitter opposes Planning Map 30 and rural zoning of 34 Works Road, Longburn. The submitter requests that 43 Works Road, Longburn is rezoned industrial, as part of it is already zoned industrial and it forms a 5.7ha wedge of land between Longburn and land zoned Industrial. The submitter states that this land would be suitable for industrial activities that fit within surrounding industrial land use. The submitter opposes in part the Airport Zone. The submitter notes that the review of the air noise contours does not adopt the contour identified by the updated modelling. The submitter considers that the modelling assumptions are inaccurate and inappropriate. It is also noted that the contours are used to justify making dwellings within the contours a Prohibited Activity, which is considered unjustified given the submitter considers that the most accurate contours have not been adopted. The submitter supports Rule 13.4.6.2. The submitter notes that the existing rule in the plan has not been complied with by the Airport company. The submitter supports in part Rule 12A.7.2. The submitter notes that the Explanation to this Rule makes it clear that the concern is about the timing of upgrading the road network in relation to the Extension Area. The submitter requests that Rule 12A.7.2 be amended to state “Any activity (including roads) in the Extension Area….’ Decisions Requested:

1. That the (Green) land shown blue on the plan (attached) be zoned rural with rural residential overlay or other more intensive development options (Planning Map 14).

2. Retain the extension of the rural residential overlay in the Valley Views Road area (between Pacific Drive & Turitea Road) (Planning Map 39).

3. Retain Rule 7.16.2.1 (b)(i) the minimum lot size for the Aokautere Rural Residential Area of 5,000m2 excluding lots for access,

utilities or reserves.

4. That Rule 7.16.2.1(b)(i) be amended as underlined below: (i) In the Aokautere Rural Residential Area and the part of the Rural Residential Overlay located south of Kelvin Grove

Road/Stoney Creek Road – 5,000m2, excluding lots for access, utilities or reserves.’ Or other wording that achieves the same affect.

5. Amend Rule 12A.7.2 to state as follows: ‘Any activity (including roads) in the Extension Area….’ or other wording that achieves the same affect.

6. Planning Map 30: That the balance of 43 Works Road not already zoned Industrial be zoned to Industrial.

7. Appendix 8.8: That the noise contour data, assumptions and modelling be independently peer reviewed. That the most accurate noise contours be adopted in the District Plan, and as a minimum are amended to those shown on page 47 of the Air Biz report. In the event that this is not accepted, then a wholly different approach to the objectives and policies and rules relating to airport noise would be necessary to enable development within the contours on land that is not at risk from long term noise effects.

8. Retain Rule 13.4.6.2 Airport Noise Management Plan.

9. R13.4.5.1: That Rule13.4.5.1 be deleted and replaced with a discretionary activity rule that enables specific noise effects to be considered in each case.

Submission Number

Plan Change Number


SO29 15A 15D 15B

S7 Subdivision S22 Natural Hazards Appendix 2: Planning Maps S9 Rural Zone S4 Definitions

Paul A Cole Paul A Cole 378 Waughs Road RD5 FEILDING

YES

Submission: The submitter opposes in part Section 7: Subdivision; specifically 7.16.1 Rules Controlled Activities – The Submitter considers the proposed District Plan should allow for subdivision boundary adjustments to be Controlled Activities. Boundary adjustments are a form of subdivision where no additional titles are created and are regularly undertaken in support of legitimate farming activities. Any effects arising from this type of subdivision are generally considered to be minor as no additional titles are created, the only change often being the ratio of land owned by the two applicants. It is submitted that a rule be included in the District Plan to allow boundary adjustments to be undertaken in the Rural Zone, which results in no new titles, to be a controlled activity.


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The submitter supports in part Rule 7.16.1.2(b)(i). The submitter notes the basis for the 20 ha minimum lot area is to maintain the Regions’ class 1 versatile soils in productive usage. The submission states that: - the proposed plan does not contain a map showing the extent of these soils and submits that a map showing the extent of these soils

within the region should be included within the District Plan. - the proposed minimum lot size of 20ha is excessively large and the majority of rural subdivisions won’t meet this standard as many lots

within the Region are already smaller than the proposed 20 ha minimum lot area as a result of fragmentation which has occurred. It is submitted that the 4 ha minimum area be retained for all but the class 1 elite soils that the District Plan seeks to protect.

- the proposed District Plan should encourage further subdivision of lots (under 20 ha), in preference to larger more economic lots. For example, the subdivision of a 4ha hobby farm into 4 lifestyle blocks should be considered in preference to subdivision of a 16 ha farm into four 4ha hobby farms, so as to meet demand for lifestyle properties but prevent further fragmentation of the high quality soils. Submits that further subdivision be considered in areas where fragmentation into hobby farms has already occurred, in preference to further subdivision in areas where fragmentation has not occurred.

The submitter supports in part Rule 7.16.2.(b) (ii) – The submitter considers that the minimum lot area for a surplus dwelling should be reduced to the minimum to support on-site wastewater treatment and minimise the amount of productive land is lost to rural residential development. Also, there should be no maximum area as this limits future use of the property solely to rural residential usage. It is submitted that such a rule will also lead to issues as to the definition of what is considered to be a surplus dwelling. In addition there are cases where what started out as a dwelling has been converted to a more agricultural use and these structures should be encompassed by this rule. The submitter opposes the current drafting of PPC15D. The submitter notes a discrepancy between the modelled extent of flood hazard for a 1 in 200 year event shown in Planning Map 1 (specifically in relation to 378 Waughs Road), and the modelled extent for the same area shown in the map produced by Horizons Regional Council (Page 5 of this submission).

The submitter requests that ‘micro scale wind turbines’ be considered as a Permitted Activity in the Rural Zone, with a specific performance standard in relation to separation distance to the boundary. The submitter states that there is a clear desire for sustainable power generation, and a Permitted Activity status would promote the use of renewable energy in accordance with government policy. The submitter states that the cost of obtaining resource consent for micro scale wind turbines would act as a disincentive. The submitter requests a separate definition for micro scale wind turbines.

Decisions Requested: 1. That a rule be included in the District Plan to allow boundary adjustment subdivisions, which results in no new titles, to be

undertaken as a controlled activity in the Rural Zone. 2. Planning Maps: That the District Plan includes a map identifying areas of high quality class 1 soils. 3. That the 20 ha minimum lot area be reduced to the current 4 ha minimum where the property does not contain class 1 soils (Rule

7.16.1.2(b)(i)). 4. That further subdivision be considered appropriate in rural areas where fragmentation into hobby farms has already occurred, in

preference to further subdivision in areas where fragmentation has not occurred. 5. That Rule 7.16.1.2 (b) (ii) be amended to allow for the subdivision of a surplus dwelling with a minimum lot area, which is defined

by the properties ability to effectively treat wastewater and that the maximum lot area be removed. 6. That that the definition of surplus dwelling be expanded so that it is clear what is considered to be a surplus dwelling ((Rule

7.16.1.2(b)(ii)). 7. Planning Map 1: That Planning Map 1 be amended to show the flood extent for a 1 in 200 year event according to Horizons

Regional Council's model. 8. R9.7.5: That micro scale wind turbines be provided for as a Permitted Activity, with a performance standard in relation to separation

distance from the boundary. 9. S4: That a new definition for micro scale wind turbine be included in S4 Definitions.

Submission Number

Plan Change Number


SO30 15A Appendix 2 :Planning Maps 33, 39 & 40

Ngawai Farms Limited

Ngawai Farms Limited 291 Turitea Road, RD2 PALMERSTON NORTH

NO

Submission: The submitter supports Planning Maps 33, 39 & 40, specifically the proposed rural residential overlay on land owned by Ngawai Farms Ltd. Identifier No. 531932 part Section 268, 292, 293 Town of Fitzherbert.

Decision Requested: 1. That Palmerston North City Council support rural residential subdivision on land owned by Ngawai Farms Ltd.


32

Submission Number

Plan Change Number


SO31 15A S7 Subdivision Appendix 2: Planning Map 30

Albert A & Jane S Van Der Zwan

Albert A & Jane S Van Der Zwan 60 Harts Road, RD2 Turitea PALMERSTON NORTH 4474

YES

Submission: The submitter supports the proposed rule change described in Rule 7.16.2.1.

The submitter supports in part Planning Map 30 and the rural residential overlay. The submitter requests that the overlay (Oram Drive to Harts Road) be extended to include 60 Harts Road (2 ha) to enable future subdivision of their property. A Location Plan of 60 Harts Road and proposed Site Plan is attached in the submission at pg 4 & 5.

It is submitted that the proposed overlay is appropriate as the property is prone to frequent high winds which makes horticulture and agriculture use not a viable use. it is further submitted that the land is predominantly ‘Tokomaru Clay’ and not suitable for horticulture or agricultural use - it cracks and dries out in summer months and is ‘puggy’ and retains water in winter.

A recent subdivision of an adjoining property cited the unsuitability of the land as farm land as a reason for allowing that activity. The submission states that they have resided at 60 Harts Road for approximately 7 years and as age advances, their intention is to build a single storey house to remove the need to climb stairs and move into town.

Decision Requested: 1. That the overlay of the proposed residential rule change be extended to our property to enable us the opportunity to subdivide our

property situated at 60 Harts Road, RD 2 Turitea Palmerston North. Submission Number

Plan Change Number


SO32 15A S7 Subdivision Planning Map 30

Paul E Wycherley Paul E Wycherley 1478 Napier Road ASHHURST

YES

Submission: The submitter opposes 7.16 Rural Zone; specifically Ashhurst South zoning. The submitter states there is a need for a development with section sizes 2,500m2 – 10,000m2 and notes that this makes for an impressive street as seen in Cambridge/Hamilton. The submitter suggests that a clause could be included especially where Council infrastructure is available. The submission also notes there is a need to be able to subdivide off a small area of land (in the rural zoning) to a family member, e.g parents/son/daughter.

The submission states that Ashhurst South would provide for the abovementioned needs. This area has Transit Approval, Council infrastructure (sewage and water, class 3 soils), and is non-floodable. It wouldn’t set a precedent as very few blocks have a main sewer pipe running through them. The submission notes the legality of the sewer pipe needs to be tidied up and that the Riverside Walkway was allowed to go through their land in good faith that the Council would rezone our land. Submits that it fits into the Integrated Development clause identified in the Rural/Residential Land Use Strategy. The submission states that Ashhurst South Area is in close proximity to the main tourist attraction of Manawatu, which is the Gorge Walk and is within walking distance to the Domain, Manawatu River and easy driving to Linton Camp, Ohakea Airbase and Massey University.

Decisions Requested: 1. Recognise the need to enhance Ashhurst area for its prosperity and the tourism factor.

2. Provide for a motel to meet the tourism market.

3. Provide an area of medium size sections, these being 2,500m2 – 10,000m2.

4. Include a clause especially where Council infrastructure is available.

5. Provide for the need to subdivide a small block to a family member.

6. That Ashhurst South have a rural/residential overlay on it to meet growing tourism developments like cycle ways, and to provide an

area for a motel.


33

Submission Number

Plan Change Number


SO33 15E

S7 Subdivision S12A NEIZ

Argosy Property Limited

Sue Simons Berry Simons, Environmental Law PO Box 3144 Shortland Street AUCKLAND 1140

YES

Submission: The submitter is concerned about the scale and rate of expansion provided for by PPC15E. The submitter opposes the expansion as they do not consider rezoning new land for industrial use is required. However, if the NEIZ expansion is to proceed, then a staged approach is more appropriate. The submitter’s view of the plan change in its present form is as follows: - It does not represent sound resource management principles and practices - It does not represent the most appropriate means of achieving the objectives of the Plan or the purpose of the Act The submitter notes that the proposed expansion is to occur without any evidence to support the need for the expansion or the availability of infrastructure to service the expansion at the proposed rate. The submitter is the owner of land situated within the current NEIZ and states: - There is 62.3 hectares of NEIZ land that is currently available for sale and or development - Notes the uptake of industrial land is slow and estimates uptake of current NEIZ land is at a rate of 3 to 4 hectares per annum Decisions Requested:

1. S12A: That the expansion of the NEIZ be removed or staged to reflect the current and projected rate of uptake of industrial land.

2. Such other and further relief as may be necessary to address the issues raised in the submission.

Submission Number

Plan Change Number


SO34 15A-H 15H

S13 Airport Zone Palmerston North Airport limited

David Lanham Palmerston North Airport Limited First Floor, Terminal Building Airport Drive PO Box 4384 PALMERSTON NORTH 4442

YES

Submission: The submitter supports or supports in part the following provisions in S13:

• Objective 1 and supporting Policies 1.1 – 1.6 • Objective 3 and supporting Policies 3.1-3.5 (with reservations that amenity standards must be balanced with Civil Aviation security

requirements in terms of the airside of the Airport Drive). • Objective 4 and supporting Policies 4.1 and 4.2.

The policy elements that the submitter opposes or opposes in-part include the following provisions in S13:

• Resource Management Issue 2 (opposed in part), on the basis that they do not consider that the adverse effects of activities within the Airport Zone on the City’s established business zones is a significant resource management issue.

• Objective 2 is opposed in part because the submitter does not consider that commercial distribution effects on the established Business Zones is a significant matter of concern.

• Policy 2.1 is not opposed, but the submitter states that they must be able to respond to changing aviation and airport security requirements without the need to change the District Plan or to apply for consent. The submitter considers that how the business functions within its zone needs also to respond efficiently and rapidly to changing business demands and it should not be prevented from doing so by the District Plan.

• Policy 2.3 is opposed because the submitter considers they are the only authority in a position to judge whether or not activities require airport access.

• Policy 2.5 is opposed because while some activities may not be ancillary to airport operations in a direct way, they may provide important support to those businesses which are directly ancillary. The submitter considers that a balanced business community is an essential element for the Airport Zone if the Airport is to be successful in a business sense.


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The submitter supports the following methods unreservedly: • R13.4.1.3 Temporary Training Activities and related Performance Standards • R13.4.1.4 Construction, External Alteration of and Addition to Buildings and Structures and related Performance Standards. • R13.4.1.5 Roads • R13.4.2.1 Streetscape Design, its related Performance Standards, Determination Clause and Assessment Criteria. • R13.4.2.2 Non-notification. • R13.4.2.3 Activities which do not comply with the Performance Standards for Permitted Activities, Determination Clause and

Assessment Criteria (with the exception of (f) Ancillary Retail and Ancillary Office Activities). • R13.4.2.4 The Construction, External Alteration or addition to a building or structure which does not comply with the Performance

Standards for Permitted Activities, Determination Clause and Assessment Criteria. • R13.4.3.4 Temporary Military Training Activities which do not comply with the Permitted Activity Performance Standards,

Determination Clause and Assessment Criteria. • 13.4.4.1 Airnoise Control, Determination Clause and Assessment Criteria. • R13.4.4.2 Sound emissions. • R13.4.5.1 Airnoise Contour. • R13.4.5.2 Runway End Protection Areas. • R13.4.6.1 Sound Emissions in the Airport Zone. • R13.4.6.2 Airport Noise Management Plan. • R13.4.7.1 Airport Protection Surface.

The submitter opposes or opposes in part the following methods under S13:

• The exclusion of service stations, offices and new terminal activities in R.13.4.1.1 • The performance standards for retail, takeaway bars, licensed premises and commercial service activities being limited to the

Airport’s terminal building. • Office and retail activities needing to be ancillary. • The requirement for a 10 metre wide set-back on either side of Airport Drive as part of the Comprehensive Development Plan. • The Comprehensive Development Plan, as it may reduce flexibility to react rapidly with changes to development plans when

required to meet commercial market needs and any Civil Aviation Authority mandated requirements. • Trees or other aesthetic treatments which might compromise security requirements such as fencing, and vegetation known to

attract birds. • R.13.4.2.6 Retail, Takeaway Bars and Commercial Service Activities with a gross floor area less than 100m². The submitter

considers that this should be a permitted activity rather than a restricted discretionary activity. The submitter also considers that if a resource consent is required, the “distributional effects on established business zones” should not be a criterion.

• R13.4.3.2 Retail Activities, Takeaway Bars and Commercial Service Activity with a gross floor area over 100m² being a Discretionary Activity.

• R13.4.3.3 Non-Ancillary Office Activities as a Discretionary Activity. The assessment criteria are also opposed. • Accommodation Motels and Residential Centres (excluding those prohibited by R13.4.5.1) as a discretionary activity.


1. That all references to Airnoise be expressed as one word rather than two in the District Plan.

2. S13.3 Objective 1 & Policies 1.1-1.6: That S13 Objective 1 and supporting Policies 1.1-1.6 be retained.

3. S13.3 Objective 3 & Policies 3.1-3.5: That S13 Objective 3 and supporting Policies 3.1-3.5 be retained.

4. S13.3 Objective 4 & Policies 4.1 & 4.2: That S13 Objective 4 and supporting Policies 4.1 and 4.2 be retained.

5. S13.2 Resource Management Issues: That S23 Resource Management Issue 2 does not identify the adverse effects of activities within the Airport Zone on the City’s established business zones as a significant Resource Management Issue.

6. S13.3 Objective 2: Remove reference to commercial distributional effects on the established business zones from S13 Objective 2.

7. S13.3 Policy 2.1: Retain S13 Policy 2.1.

8. S13.3 Policy 2.3: Delete S13 Policy 2.3.


10. R13.4.1.3: Unreservedly support R13.4.1.3.


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25. R13.4.1.1: That Retail, Takeaway Bars, Licensed Premises, Commercial Service Activities, Accommodation and Service Stations be listed as permitted activities in the Core Airport Precinct and not be confined to the Terminal Building.

26. R13.4.1.1 & R13.4.1.2: That Office and Retail Activities should not have to be ancillary under R13.4.1.1 and R13.4.1.2. 27. R13.4.2.1: The CDP requirement under R13.4.2.1 be opposed.

28. R13.4.2.3(f): That R13.4.2.3(f) be opposed.

29. R13.4.2.6: That R13.4.2.6 be opposed.




33. R13.4.3.3: That accommodation motels and residential centres be provided for as Permitted Activities in the Airport Zone, rather

than a Discretionary Activity

34. That if the relief sought is not available for some technical reason the submitter requests that amendments be made to like effect. Submission Number

Plan Change Number


SO35 15A S7 Subdivision S9 Rural Zone Appendix 2: Planning Maps Appendix 3: 15A Technical Reports

Bruce & Marilyn Bulloch

Bruce & Marilyn Bulloch 128 Cook Street West End PALMERSTON NORTH 4410

NO

Submission: The submitter supports Plan Change 15A and Appendix 15A; and specifically the objective to retain the more productive land for agricultural purposes and provisions in the plan relating to subdivision of rural land.


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Decision Requested: 1. Retain the provisions relating to subdivision of rural land.

Submission Number

Plan Change Number


SO36 15G 15H

S13 Airport S23 Utilities

Airways Corporation of New Zealand

Sara Cook C/- Opus International Consultants Ltd Level 4, The Square Centre 478 Main Street PALMERSTON NORTH

YES

Submission: The submitter supports the Objectives, Policies and Rules of PPC15H and PPC15G.

Decisions Requested: 1. S23.1, Policy 3.8, & R23.7.1(viii). Retention of the S23.1, Policy 3.8, R23.7.1(viii). 2. R23.7.1 & R23.12.1: Seeks clarification that restrictions on the placement of utility structures exempts navigational aids and

beacons, in relation to performance standard (a)(v) of Rule 23.7.1 (viii) and Rule 23.12.1. 3. That Policy 1.6 is supported. 4. That Objective 4 and Policy 4.1 is supported. 5. That R13.4.1.1(b) Permitted Activities is supported. 6. That R13.4.5.2 Runway End Protection Areas is supported. 7. That navigation aids and beacons be exempted from R13.4.7.1 Airport Protection Surface. Policy 1.6 covers this, but it is not

reflected in the rule. The submitter seeks clarification on this matter.

Submission Number

Plan Change Number


SO37 15A Appendix 2: Planning Maps Tutaki & StoneyCreek Roads

Friederike E Lugt Friederike E Lugt 659 Stoney Creek Road RD10, PALMERSTON NORTH

YES

Submission: The submitter opposes the Planning Maps and rural zoning of the Tutaki Road and Stoney Creek Road area. The submitter proposes that the Rural Residential Overlay on Tutaki Road be extended at the north/east end past Tutakarae Road through to Richardson Line paper road (comprising 5 x 50 acre lots closest to Stoney Creek Rd). The submission states the following summary reasonings: ‐ Not the best use – 20 ha is an uneconomic unit for this low fertility land. Greater intensity housing would be a better option. ‐ Drop in property values – The change to minimum 20 ha lot size takes away subdivision rights held under MDC, potentially having a

negative effect on property. ‐ Location – Close to retail centres, hospitals, school, key industrial areas and bus services. ‐ Market Demand –Significantly more desirable than lifestyle blocks on the other side of the bridge. Few lots available as virtually all of

the Orakei/Tutakarae sites have been sold and built on. Sites on the other side of the bridge have often been heavily discounted to achieve sales. With developed lifestyle blocks generally being cheaper people may be hesitant to put money into an area if they can’t see they can get it back.

‐ Context – Good fit. Would bring additional benefits to what else is being proposed for the area. ‐ Increased harmony within the neighbourhood – encourage and support the development of the emerging community. ‐ Low Impact – Minimal burden on other ratepayers. Required infrastructure already exists. ‐ Low risk – this area is on a terrace and didn’t suffer from flooding in the 2004 flooding, made-up of clay with iron pan and natural

existing run-offs. ‐ Sustainability ‐ Wider community benefit ‐ New pre-school/early learning centre has been permitted to be built by PNCC – There is provision and demand for development in the

region. Decisions Requested:

1. That the Rural Residential Overlay on Tutaki Road be extended at the north/east end past Tutakarae Road through to Richardson Line paper road.

2. That PNCC approve 1 hectare lots or smaller for lifestyle or residential.


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Submission Number

Plan Change Number


SO38 15A S7 Subdivision S9 Rural Zone Planning Maps

Ashley Farms Ltd Lindsay & Marion Ashley 588a Stoney Creek Road RD10 PALMERSTON NORTH 4470

NO

Submission: The submitter opposes PC15A, specifically the subdivision rules applicable to their property at 588a Stoney Creek Road. The submitter considers that clay country is not suited for first class farming land. It is submitted that their property is better suited for subdivision into smaller lifestyle blocks. Decision Requested:

1. That the subdivision rules remain as they are now or to be eased, not made more restrictive. Submission Number

Plan Change Number


SO39 15A S7 Subdivision S9 Rural Zone Appendix 2: Planning Map 30, 32, 24

Philip H Pirie Philip H Pirie Pirie Consultants 168 Grey Street PO Box 10050 PALMERSTON NORTH

YES

Submission: The submitter opposes PC15A, R 7.16 Rural Zone and Rule 7.16.1.2 (b) (i) and (ii). The submitter is concerned that the review persists with the retention of minimum lot sizes and increases that size to 20ha. It is submitted that the reference to minimum lot sizes be deleted and that procedures similar to the MDC District Plan be adopted; that references to surplus houses be deleted, that all subdivisions are Controlled Activities where meeting Performance Standards and that all subdivisions not meeting the Performance Standards are Discretionary Restricted Activities.

The submitter opposes the Rural Residential Overlay on the Planning Maps. The submitter notes the proposal severely limits the extent of land available for rural residential development, that most of the area is already developed or planned for development and the restriction will increase land prices due to an inevitable land shortage that will develop. The submission states the current zoning for rural residential is over land that is not high quality. The proposed minimum lot size of 20 ha will effectively stop the subdivision of land in those areas which are not within the rural residential overlay.

The submission notes that the colours on the Planning Maps and the key do not correspond.

The submitter opposes the Flood Protection Zoning on Planning Map 30. The submission notes that the extent of the Flood Protection Zone at the end of Shirriffs Road, is incorrect and requests that it is corrected.

The submitter opposes in part Planning Map 32 and the rural zoning of land between Pacific Drive and Moonshine Valley. The submitter requests that Council rezone a parcel of Rural Zone land located between the Residential Zone land of Pacific Drive and the Moonshine Valley land, to residential, as it is landlocked and only accessible from the Residential Zone land. The submission notes that a submission has already been made to Council about rezoning this parcel of rural land and that full details are contained in other correspondence with Council.

The submitter opposes in part Planning Map 24 and rural zoning of land located between No. 1 Line, Rongotea Road and Pioneer Highway. The submitter requests that all of the Rural Zone land bounded by No. 1 Line, Rongotea Road and Pioneer Highway be re-zoned to Residential. The submission states that this land is in the process of a private plan change process, and the details are already provided to Council.

The submitter opposes Rule 7.17.1.1 Flood Prone Land in Section 7. The submission states that subdivisions within the zone do not require consideration as it is the land use that has the potential to affect flood waters. It is submitted that subdivision in this Zone should not be treated any differently to Rural Zone and that section 7.17 is deleted entirely and the provisions are included in the Rural Zone.

The submitter opposes Rule 7.17.1.2 & Rule 7.17.1.3 National Grid Corridor and Substations. The submitter notes that subdivision does not affect these assets but rather it is the landuse. It is submitted that this section subdivision in this zone should not be treated any differently to


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Rural Zone that section 7.17 is deleted entirely and the provisions are included in the Rural Zone. The submitter also notes that the Corridors are not defined on the planning maps and that a definition as to determination, be included.

The submitter opposes Rule 9.5.5 (b)(i)(c) Dwellings and Accessory Buildings. The submission states that it is a choice by an landowner for the siting of a dwelling new a wind turbine and that the rule immediately creates a non-compliance for any rural development that has occurred and not yet built upon. It is submitted that the rule be deleted entirely.

Decisions Requested: 1. In S 7Subdivison, 7.16 Rural Zone:

- delete the reference to minimum lot sizes and adopt procedures similar to the MDC District Plan; - delete references to surplus houses; - have all subdivisions as Controlled Activities where meeting Performance Standards. - have all subdivision not meeting the Performance Standards as Discretionary Restricted Activities.

2. Retain the existing zoning or delete and introduce the subdivision procedures of the Manawatu District Council.

3. Correct the Key so as to correlate with colours on Planning Maps.

4. Correct the extent of Flood Protection Zone at the end of Shirriffs Roads, on Map 30.

5. Rezone ‘landlocked’ rural land between the Residential Zone land of Pacific Drive and Moonshine Valley land, to Residential

(Planning Map 32).

6. Re-zone the rural land at No. 1 Line, Rongotea Road and Pioneer Highway to Residential (Planning Map 24).

7. Delete Section 7. 17 All Zones/Rule 7.17.1.1 Flood Prone Land entirely and include the provisions in the Rural Zone.

8. Delete Section 7.17 All Zones/Rule 7.17.1.2 & Rule 7.17.1.3 National Grid Corridor and Substations, entirely. Define the National Grid Corridors on Maps and include definition as to determination.

9. Delete Rule 9.5.5 (b)(i)(c) entirely.

Submission Number

Plan Change Number


SO40 15A-H 15A 15D

S4 Definitions S9 Rural Zone S13 Airport Zone S22 Natural Hazards Rules Chapters in All Zones

New Zealand Defence Force

Sara McMillan Tonkin & Taylor PO Box 2083 WELLINGTON 6140

YES

Submission: The submitter generally opposes the provisions in PC15A-H relating to Temporary Military Training Activities undertaken by New Zealand Defence Force. The submitter opposes the definitions for Minor and Extended Temporary Military and Extended Military Training Activities. The submission states that there is no resource management reason to have separate definitions to manage military training activities in the Rural Zone. It is submitted that one definition would simplify management of these activities in the Rural Zone; and simplify rules. The submitter suggests using the term ‘Temporary Military Training Activities’ and including a new definition in Section 4 as follows: Temporary Military Training Activity – A temporary military activity undertaken for defence purposes. Defence purposes are described in s5 of the Defence Act 1990. Submits that this is generally consistent with the definition included in other district plans nationwide.

The submitter opposes in part Rule 9.5.8 Minor and Extended Temporary Military Training Activities. The submitter supports (existing rule) Rule 9.6.8, which is a permitted activity rule for Minor and Extended Temporary Military Training Activities (TMTAs). The submission states: - NZDF may need to undertake TMTA’s outside of the Linton Military Camp within the Rural Zone & by including a permitted rule in the

Rural Zone, PNCC is able to control the effects of such an activity through the use of appropriate Performance Standards. - NZDF considers that live firing of weapons, firing of blank weapons, firing of blank ammunition, single or multiple explosive events

should be included as a permitted activity subject to performance standards, as these are integral to TMTAs.


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- NZDF seek flexibility to undertake these activities as required utilising various situations and locations. Staging training activities in varied locations is essential as NZDF personnel may be deployed to a range of locations around New Zealand and the world.

- TMTA’s may be infrequent, though will occur in the district throughout the life of the Plan. - Undertaking training is a requirement of the Defence Act. It is considered inefficient and ineffective to require NZDF to obtain consents

for an activity that is temporary and generally results in de minimis effects. - NZDF is engaged in a nationwide exercise to achieve consistency in the management of TMTA’s across District Plans. The NZDF

project of national consistency is in line with the Governments proposed second phase of reforms, which will focus on nationwide templates and the strengthening of national planning tools.

The submitter opposes in part Rule 9.5.8. The submitter seeks that Rule 9.5.8 be amended to include live firing of weapons, firing of blank ammunition, single or multiple explosive events as a permitted activity.

The submitter proposes that new permitted activity noise standards related to military training activities be included in the District Plan. The submitter requests that TMTA’s (including the live firing of weapons, firing of blank ammunition, single or multiple explosive events) be provided as Permitted Activities if standards are met, OR as Controlled Activities if standards are not met. The submission states that NZDF commissioned professional acoustic advice from an acoustical consultant experienced with the measurement and assessment of noise associated with military training and based on this advice NZDF developed a set of conservative noise control permitted activity standards which they are seeking to have included in proposed district plans nationwide. The submission notes that the proposed standards separate TMTA’s into four categories, with each source having a different set of permitted standards, allowing for a more comprehensive and appropriate method for controlling noise from TMTA’s. For weapons firing and explosives the proposed standard is separation distances between the activity and any sensitive receivers. The submission notes that where the required setbacks from the noise activity can’t be met, and the noise level exceeds the specified decibel levels, that activity would not be undertaken at that location (or a resource consent obtained). The submitter considers this approach protects noise sensitive activities while enabling NZDF to undertake important training activities and the proposed noise standards are more appropriate, effective, easier to understand and assess compliance with.

The submitter opposes the deletion of Permitted Activity Rule 22.8.1.2 & Controlled Activity Rule 22.8.2.1 relating to temporary military training activities because: - TMTAs are temporary by nature, - Do not typically involve the construction of permanent buildings or structures that may alter flood risk, - Could relate to training for flood emergencies, - Are not inconsistent with Policy 9-2(b) of the Horizons Regional Council Operative One Plan, which includes an exemption where there

is a 'functional necessity' for the activity to occur, and - Are restricted despite Rule 22.7.1.1(v) permitting non-habitable structures on production land. The submitter considers the effects of

non-habitable structures within the Flood Protection Zone to be far greater that effects from TMTAs. The submitter suggests that permitted activity rules for temporary military training activities in all zones would be appropriate, as they can be undertaken in any zone in the district, and it is appropriate that these activities can be undertaken lawfully. The submitter states that obtaining resource consent for TMTAs is inappropriate. The submitter supports proposed Rule 13.4.1.3 in part, but would like the rule amended to include the live firing of weapons, firing of blank ammunition, single or multiple explosive events as a permitted activity in the Airport Zone, and in all zones of the District Plan. Decisions Requested:

1. Remove distinction between Minor Temporary Military Training Activities and Extended Temporary Military Training Activities from the Rural Zone (and the rest of the Plan).

2. Replace the separate definitions for Minor and Extended Temporary Military Training Activities with the term ‘Temporary Military Training Activities’ and include the following Definition in Section 4 of the Plan: “Temporary Military Training Activity – A temporary military activity undertaken for defence purposes. Defence purposes are described in s5 of the Defence Act 1990.”

3. Provide for TMTA’s (including the live firing of weapons, firing of blank ammunition, single or multiple explosive events) as Permitted Activities if standards are met, OR as Controlled Activities if standards are not met.

4. S22: That Temporary Military Training Activities be provided for in the Flood Protection Zone and Flood Prone Areas as permitted activities.

5. R13.4.1.3: That R13.4.1.3 be amended to include the live firing of weapons, firing of blank ammunition, single or multiple explosive


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events as a permitted activity.

6. All Zones: That Temporary Military Training Activities are explicitly provided for as a permitted activity in all zones of the District Plan.

Submission Number

Plan Change Number


SO41 15G S4 Definitions S23 Utilities

Chorus New Zealand Limited

Mary Barton PO Box 632 WELLINGTON

YES

Submission: The submitter considers that some of the associated rules are: (a) unreasonably restrictive in the manner in which telecommunication and radio communication facilities are provided for in relation to the actual and potential environmental effects of activities; and (b) unclear, uncertain or unworkable. Decisions Requested:

1. S4: Delete the S4 definitions of Aerial, Antenna and Antenna Dish and replace with the following: Antenna: means the part of a radiocommunication facility or telecommunication facility used or intended for transmission or reception, including dishes, panels and aerials (i.e. an array of wires, rods or tubes), They include the antenna mounting and ancillary components such as radio frequency units, amplifiers, controller boxes, or similar devices, but not any supporting mast or similar structure

2. S4: An amendment to the S4 definition of Mast, as follows:

means any mast, pole, tower or similar structure designed to carry aerials or antennae dishes antennas to facilitate radiocommunication or telecommunication….

3. S4: Amend the S4 definition of Minor Upgrading to include telecommunication networks, as follows:

means, in respect of network utilities, an increase in the carrying capacity, efficiency or security of electricity and associated telecommunications lines networks, utilising the existing support structures or structures of a similar scale, intensity and character, and includes but is not limited to:

4. S4: Amend the S4 definition of Minor Upgrading to include the following additional items:

- The replacement of any antenna on an existing mast or other support structure with a new one provided the new antenna

does not exceed the maximum dimension of the antenna, or the diameter where it is a dish antenna, by more than 20%, and the overall height of the facility to which the antenna is attached does not increase.

- An increase in the height of replacement poles in road reserve by a maximum of 1m for the purpose of achieving road controlling authority clearance requirements provided that the permitted zone height is not exceeded; and/or the replacement of an existing pole in road reserve within 2m horizontal distance of the existing.

5. S23.1 Introduction: The deletion of words linear infrastructure and the addition of the term network utilities in S23.1 Introduction. 6. S23 Resource Management Issue 1: Retention of S23 Resource Management Issue 1, as currently drafted.

7. S23 Resource Management Issue 2: Amend S23 Resource Management Issue 2 as follows:

The actual and potential need to manage the adverse effects on the environment resulting from the establishment, operation, maintenance and upgrade of network utilities and associated infrastructure, while recognising that not all adverse effects may be able to be avoided, remedied or mitigated due to their technical and operational constraints.

8. S23 Resource Management Issue 2 Explanation: Amend paragraph 2 of the Explanation of S23 Resource Management Issue 2 as

follows: Network utilities comprise a wide range of structures with varying degrees of impact on the environment. As well as impacting upon visual amenity, the establishment, operation, maintenance and upgrade of network utilities can lead to other adverse effects…..on public health and safety. The Plan seeks to manage the adverse effects while recognising that in some cases some level of


41

adverse effect will need to be accepted in recognition of the necessity of the works and their technical and operational requirements.

9. That the phrase “establishment, operation, maintenance and minor upgrading” be replaced throughout Section 23 with

“Construction, operation, maintenance including repair and replacement and upgrading” or similar wording.

10. S23.3 Objective 1 & Policy 1.1: Retain S23 Objective 1 and Policy 1.1.

11. S23.3 Policy 2.1: Amend S23 Policy 2.1 as follows: To permit the operation, maintenance and upgrading of existing regionally or nationally important network utilities that result in minor or less than minor adverse effects. Where such works or activities can be carried out without significantly changing the character, intensity or scale of the adverse effects associated with them.

12. S23.3 Policy 2.2: Amend S23 Policy 2.2 as follows:

To enable the operation, maintenance and upgrading of existing regionally or nationally important network utilities and the establishment of new regionally or nationally important network utilities, provided that the adverse effects are avoided, remedied or mitigated to the extent practicable, having regard to…

13. S23.3 Policies 2.1 & 2.2: To make changes to the Explanation for S23 Policies 2.1 and 2.2, as necessary to reflect the submitter’s

amendments.


15. S23.3 Policy 3.2: Amend S23 Policy 3.2, as follows: To ensure that network utilities associated with new land development are designed, located, developed, constructed upgraded, operated and maintained in accordance with the Council’s Engineering Standards for Land Development.

16. S23.3 Policy 3.4: Amend S23 Policy 3.4, as follows:

To require the placement of new network utilities unless: • There are natural or physical features or structures or technological and operational constraints that makes underground placement

impracticable or unreasonable; • They are of a temporary nature and required for emergency purposes or critical events; they are of a nature that can only operate

above ground; and • In the case of lines

(i) They are to provide a customer connection utilising an existing support pole in any zone; and/or (ii) they traverse any Rural Zone or roads within the Rural Zone.


18. R23.7.1: Amend R23.7.1 Permitted Activities as follows:

The establishment, operation, maintenance and minor upgrade of any of the following…are permitted activities provided that these comply with the relevant performance standards listed herein. (iii) New T telecommunications and radiocommunication lines, links, works and facilities not otherwise provided in item (iv) below.

19. R23.7.1: Insert new item to R23.7.1 Permitted Activities as follows:

(xii) Maintenance and minor upgrading of telecommunication and radiocommunication facilities, subject only to compliance with performance standards (g), (h) and (i) as applicable.

20. S4 & R23.7.1: Either:

(i) Delete the definition of Utility Structure in S4; and (ii) Add the following to the end of Rule 23.7.1 performance standard (a) (i): In the case of a telecommunication cabinet located on a building, the zone height or height recession plane does not apply.


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Or, alternatively, (i) delete the definition of Utility Structure in S4; and (ii) delete Rule 23.7.1 performance Standard (a) (i) in its entirety.

21. R23.7.1: Amend R23.7.1 performance standard (a) (iii) to provide for Masts up to 25m in the Rural Zone.

22. R23.7.1: Amend R23.7.1 performance standard (a) (iv) to provide an additional allowance of 3m.

23. R23.7.1: Amend R23.7.1 performance standard (d) (i) as follows:

New lines shall not be located above ground except: (a) where lines traverse any Rural Zone, or roads within this zone … (c) where lines are to provide temporary links, connections or services, they may be above ground for up to three consecutive months in any 12 month period; and (d) to provide a customer connection utilising an existing support pole.

24. R23.7.1(f): Amend the Note to plan users associated with R23.7.1(f) as follows:

In relation to Rule 23.7.1(f) Tthe mountings of any antenna and any ancillary components, (including radio frequency equipment or similar devices such as amplifiers and controller boxes) shall not be included in the measurement of each antenna provided that radiofrequency unit or similar device is smaller in area or diameter than the antenna itself…

25. R23.7.1: Amend R23.7.1 performance standard (i) (a) with respect to radio frequency fields to provide consistency with the wording

under the Non Complying rule R23.11.1, and certainty as to what is applicable (by removing reference to “guidelines”)

26. R23.9.1(iii): Amend R23.9.1 (iii) so it also includes the ‘area’ of antennas as follows: Diameter or area standards for Aerials, Antennas, and Antenna Dishes

Submission Number

Plan Change Number


SO42 15G S4 Definitions S23 Utilities

Spark New Zealand Trading Limited

Graeme McCarrison Spark New Zealand Trading Limited Private Bag 92028 Auckland 1010

YES

Submission: The submitter supports, supports in part, opposes and opposes in part a number of the provisions related to PC15G. Decisions Requested:

1. S4: Delete the definitions of Aerial, Antenna and Antenna Dish and replace with the following:

Antenna: means the part of a radiocommunication facility or telecommunication facility used or intended for transmission or reception, including dishes, panels and aerials (i.e. an array of wires, rods or tubes), They include the antenna mounting and ancillary components such as radio frequency units, amplifiers, controller boxes, or similar devices, but not any supporting mast or similar structure

2. S4: Amend the S4 definition of Mast, as follows: means any mast, pole, tower or similar structure designed to carry aerials or antennae dishes antennas to facilitate radiocommunication or telecommunication….

3. S4: Amend the S4 definition of Minor Upgrading to include telecommunication networks, as follows: means, in respect of network utilities, an increase in the carrying capacity, efficiency or security of electricity and associated telecommunications lines networks, utilising the existing support structures or structures of a similar scale, intensity and character, and includes but is not limited to:


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4. S4: Amend the definition of Minor Upgrading to include the following additional items: The replacement of any antenna on an existing mast or other support structure with a new one provided the new antenna does not exceed the maximum dimension of the antenna, or the diameter where it is a dish antenna, by more than 20%, and the overall height of the facility to which the antenna is attached does not increase.

5. S23.1 Introduction: The deletion of words linear infrastructure and the addition of the term network utilities in paragraph 3 of theS23.1 Introduction, as per Page 4 of this submission.

6. S23.2 Resource Management Issue 1: That S23 Resource Management Issue 1 be retained as drafted.

7. S23.2 Resource Management Issue 2: Amend S23 Resource Management Issue 2 as follows: The actual and potential need to manage the adverse effects on the environment resulting from the establishment, operation, maintenance and upgrade of network utilities and associated infrastructure, while recognising that not all adverse effects may be able to be avoided, remedied or mitigated due to their technical and operational constraints.

8. S23.2 Resource Management Issue 2 Explanation: Amend paragraph 2 of the Explanation of Issue 2 as follows:

Network utilities comprise a wide range of structures with varying degrees of impact on the environment. As well as impacting upon visual amenity, the establishment, operation, maintenance and upgrade of network utilities can lead to other adverse effects…..on public health and safety. The Plan seeks to manage the adverse effects while recognising that in some cases some level of adverse effect will need to be accepted in recognition of the necessity of the works and their technical and operational requirements.

9. S23: That the phrase establishment, operation, maintenance and minor upgrading be replaced throughout S23 with Construction, operation, maintenance including repair and replacement and upgrading or similar wording.

10. S23.3: Retain S23 Objective 1 and Policy 1.1.

11. S23.3 Policy 2.1: Amend S23 Policy 2.1 as follows: To permit the operation, maintenance and upgrading of existing regionally or nationally important network utilities that result in minor or less than minor adverse effects. Where such works or activities can be carried out without significantly changing the character, intensity or scale of the adverse effects associated with them.

12. S23.3 Policy 2.2: Amend S23 Policy 2.2 as follows: To enable the operation, maintenance and upgrading of existing regionally or nationally important network utilities and the establishment of new regionally or nationally important network utilities, provided that the adverse effects are avoided, remedied or mitigated to the extent practicable, having regard to…

13. R23.3 Policies 2.1 & 2.2: To make changes to the Explanation for S23 Policies 2.1 and 2.2, as necessary to reflect the proposed submitter’s amendments.


15. S23.3 Policy 2.3: Amend S23 Policy 3.2, as follows:

To ensure that network utilities associated with new land development are designed, located, developed, constructed upgraded, operated and maintained in accordance with the Council’s Engineering Standards for Land Development.

16. S23.3 Policy 3.4: Amend Policy 3.4, as follows: To require the placement of new network utilities unless: - There are natural or physical features or structures or technological and operational constraints that makes underground

placement impracticable or unreasonable; - They are of a temporary nature and required for emergency purposes or critical events; they are of a nature that can only

operate above ground; and - In the case of lines


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(i) They are to provide a customer connection utilising an existing support pole in any zone; and/or (ii) they traverse any Rural Zone or roads within the Rural Zone.



19. R23.7.1: Amend R23.7.1 Permitted Activities as follows:

The establishment, operation, maintenance and minor upgrade of any of the following…are permitted activities provided that these comply with the relevant performance standards listed herein. (iii) New T telecommunications and radiocommunication lines, links, works and facilities not otherwise provided in item (iv) below.

20. R23.7.1: Insert new item to R23.7.1 Permitted Activities as follows: (xii) Maintenance and minor upgrading of telecommunication and radiocommunication facilities, subject only to compliance with performance standards (g), (h) and (i) as applicable.

21. R23.7.1(ix): Amend R23.7.1(ix) to specifically include telephone kiosks.

22. S4 and R23.7.1: Either: (i) Delete the definition of Utility Structure in Section 4 Definitions; and (ii) Add the following to the end of R23.7.1 performance standard (a) (i): In the case of a telecommunication cabinet located on a building, the zone height or height recession plane does not apply. Or, alternatively, (i) delete the definition of Utility Structure in Section 4 Definitions; and (ii) delete R23.7.1 performance Standard (a) (i) in its entirety.

23. R23.7.1: Amend R23.7.1 performance standard (a) (iii) to provide for Masts up to 25m in the Rural Zone and Institutional Zone.

24. R23.7.1: Amend R23.7.1 performance standard (a) (iv) to provide an additional allowance of 3m.

25. R23.7.1(f): Amend the Note to Plan Users associated with R23.7.1(f) as follows: In relation to Rule 23.7.1(f) Tthe mountings of any antenna and any ancillary components, (including radio frequency equipment or similar devices such as amplifiers and controller boxes) shall not be included in the measurement of each antenna provided that radiofrequency unit or similar device is smaller in area or diameter than the antenna itself…

26. R23.7.1: Amend Rule 23.7.1 performance standard (i) (a) with respect to radio frequency fields to provide consistency with the wording under the Non Complying rule R23.11.1, and certainty as to what is applicable (by removing reference to guidelines).

27. R23.9.1(iii): Amend R23.9.1 (iii) so it also includes the ‘area’ of antennas as follows:

Diameter or area standards for Aerials, Antennas, and Antenna Dishes


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Submission Number

Plan Change Number


SO43 15A 15B

S4 Definitions S5 Information Requirements S7 Subdivision S9 Rural Zone S23 Utilities Appendix 2:Planning Maps

Mighty River Power Miles Rowe PO Box 445 Hamilton 3240

YES

Submission: The submitter supports in part PC15 A-H. It is submitted that there is a significant policy context which relates to PC15A-H, which is attached to the submission

The submitter opposes the phrase ‘renewable energy generation activities’ used throughout the plan change and requests that it be replaced with either ‘renewable electricity generation activities or ‘the use of Renewable Energy Resources,’ as is appropriate to the context.

The submitter supports definitions for Mast and Meteorological Activities in S4. Submits that it is appropriate that both definitions include reference to wind resource investigations so that the District Plan’s Utility provisions cover these activities and structures. Requests that the definitions in Section 4 for Mast and Meteorological Activities be retained without change.

The submitter supports definition of Renewable Electricity Generation Activities/Facilities in S4. The submission notes that the term is defined differently to the National Policy Statement for Renewable Electricity Generation (NPS REG’s). It also notes that infrastructure for the conveyance of electricity, from the point of generation (i.e the transmission of distribution lines and support structures) falls under the Utilities provisions of the District Plan. The submitter requests that this definition is retained in the same or similar form.

The submitter supports definition of Renewable Energy Resources in S4 and seeks that it is retained in the same or familiar form.

The submitter opposes definition of ‘separation distance’ in S4 and seeks that it be amended. The submission notes that the existing definition refers only to outer walls of buildings and boundaries of a site. The submitter is concerned that the Plan Change doesn’t provide guidance or clarity on how the windfarm separation distance is to be measured. As the Wind Farm separation distance standards refers only to subdivision and buildings, it is submitted that any definition needs to capture both new and proposed building sites. In addition, the Wind Farm Separation Distance should apply to any consented wind turbine site. The submitter requests that the definition of ‘Separation Distance be amended as follows:

“Separation Distance means the distance from the outer wall of a building to: (a) The outer wall of another building; (b) The boundary of a site

In the case of a Wind Farm Separation Distance, it means the distance from the outer wall of a propose building, or the edge of an identified building site shown on a scheme plan, to the outer wall of a wind turbine tower or the closest edge of a consented wind turbine site.

In the case of hazardous…’ Or that a new definition for ‘Wind Farm Separation Distance’ is provided with the same meaning.

The submitter opposes in part the definition of Wind Farm definition. The submitter generally supports the definition subject to resolution of the issue with the way this term is applied to Rule 9.8.6. The submitter understands that these activities are not intended to be covered or controlled by the Wind Farm rule in Plan Change 15 and is covered by the general utilities and earthworks rules of the proposed plan change. If this is the case, it is appropriate for the definition to reflect this. The submitter states it would be appropriate to explicitly exclude substations, switchyards or any associated switching gear, earthworks and roading from the definition, for clarity. If the definition is not amended it has the potential to cause unnecessary confusion regarding the application of rules. The submitter seeks the definition of Wind Farm be amended as follows:

“Wind Farm means turbines other than a Domestic Wind Turbine used to generate energy from the wind, and includes: • Pylons or towers that support turbines


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• Ancillary buildings and structures on the Wind Farm Site • Community-scale wind farms.

A The term Wind farm excludes earthworks and roading, transmission lines, substations, switchyards or any switching gear, and infrastructure associated with transmission lines.”

The submitter supports definition for Wind Farm Site. The submission notes that it includes not only land parcels where there are turbines or other ancillary buildings, but also land parcels where a land agreement has been entered into or written agreement has been obtained relating to the wind farm activity. In combination with the Wind Farm rules, this definition will ensure appropriate setbacks between the wind farm and sensitive activities.

The submitter opposes 5.4 (o) Special Information Requirements for Wind Farms; Clause (ii) 2nd bulletpoint & Clause (iii) in S5 Information Requirements: The submitter opposes this provision and states: - the Noise & Landscape Assessments required to be provided with a wind farm application are generally consistent with the matters

listed in the Assessment Criteria for Discretionary Activity Rule Rule 9.8.6. However, it is unclear what ‘Skyline Assessment Report’ means or how it differs from clause (ii) relating to an ‘assessment of landscape and amenity effects including cumulative visual effects’. The submitter requests the requirement for a skyline report be deleted.

- The Social Impact Assessment required by Clause (iii) is not consistent with the criteria in Rule 9.8.6 nor specifies the matters to be addressed by the Social Impact Assessment. The submission notes that a Social Impact Assessment can be useful where a proposal may have a significant impact on demographics eg schooling or other social issue however, results can be less useful or constructive where a community is pre-conditioned to a type of development, ie windfarms in Palmerston North. It is submitted for example, that a Social Impact Assessment was not undertaken for the Turitea Wind Farm consent nor was one requested or commissioned by the Board of Inquiry before it granted the consent.; Social Impacts Assessments can be expensive to prepare and would be required on every wind farm proposal other than a domestic wind turbine. The submitter considers that this Assessment is not warranted or justified.

The submitter requests that the information requirements in Section 5.4(0) be replaced with the following: “In addition to the information required for a land use resource consent in Section 5.4(a) to 5.4(e), any resource consent application for a wind farm must include an assessment of environmental effects which addresses the Assessment Criteria in Rule R9.8.6.”

Or, in the alternative, amend or delete clause (ii) and (iii) of Section 5.4(o) as underlined: “(ii) Landscape Assessments prepared by an appropriately qualified landscape professional, including:

• Assessment of Landscape and Amenity Effects, including cumulative visual effects and any adverse visual effects on the characteristics and values of the Tararua Ranges Landscape Protection Area.

• A Skyline Assessment Report including a statement as to whether the proposed development will affect the whole/part of the Tararua Ranges Landscape Protection Area and whether or not its characteristics and values are protected.

(iii) A Social Impact Assessment Report prepared by an appropriately qualified professional.” The submitter opposes in part Section 7.1 Introduction, specifically ‘The effects of Subdivision’ (pg 83). The submitter seeks a minor change to the list of effects of subdivision on pg 83, so the final bullet point makes reference to ‘consented’ as well as existing land use activities. This would give effect to the explicit direction in Policy D of the NPS REG and Policy 3.2 of the RPS (see appendix 1) and be consistent with the proposed District Plan rules. It is submitted that the final bullet point in the list of the effects of subdivision (page 83) be amended as follows:

• Reverse sensitivity effects where new sensitive land uses lead to constraints on existing or consented land use activities.”

Or that a new bullet point be added that specifically deals with reverse sensitivity effects on existing or consented renewable electricity generation activities.

The submitter opposes Resource Management Issue 7.2.1 as it doesn’t appear to cover the full range of matters which are subsequently addressed in the Explanation to the Issue. It is submitted that the Explanation should reference reverse sensitivity effects on consented renewable electricity generation activities, as well as existing activities, to give effect to the explicit direction in Policy D of the NPS REG and


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Policy 3-2 of the RPS (See Appendix 1) and consistency with the proposed District Plan Rules. The submitter requests amendments to Issue 7.2.1 and the Explanation as follows:

Issue 7.2.1 “Unless subdivision is controlled it will Uncontrolled subdivision can lead to the unsustainable use of land, and other resources, including infrastructure and renewable energy resources. particularly With regard to rural land, where inappropriate land fragmentation will reduce the overall productive capability of rural areas and result in the loss of versatile soils for use as production land.” Explanation for Issue 7.2.1:

• Management of reverse sensitivity effects associated with complaints from new sensitive land uses located in proximity to consented renewable electricity generation activities or any existing, lawfully established activities or operations.

The submitter opposes in part 7.2. Resource Management Issue 5 & paragraphs 3, 4,& 6 of Explanation. It is submitted that the Explanation to Issue 7.2.5 should make specific reference to the potential reverse sensitivity effects on windfarms including consented as well as existing windfarms, to give effect to the explicit direction in Policy D of the NPS REG and Policy 3-2 of the RPS (See Appendix 1) and be consistent with the proposed District Plan Rules. It is noted that the restricted area for the Rural Residential Overlay, outlined in the 3rd paragraph of the Explanation, will serve to reduce the potential for reverse sensitivity issues on windfarms in addition to farming and horticultural enterprises. The submitter supports the 4th paragraph but notes the last sentence, dealing with reverse sensitivity issues being ‘avoided or mitigated at the time of subdivision consent through the imposition of conditions or decline of consent’, is applicable to all reverse sensitivity effects dealt with in the 3rd, 4th and 6th paragraph. It is submitted that 3rd, 4th and 6th paragraphs of the Explanation for Resource Management Issue 5 , be amended as follows:

“The District Plan makes specific provision for rural-residential subdivision use of on some of the City’s less versatile rural land to meet satisfy a demand for rural living, and to help reduce pressure to subdivide higher quality land, for residential purposes. An Overlay for rural residential subdivision identifies areas suitable for rural residential development, to avoid a proliferation of rural residential activities throughout the Rural Zone and reverse sensitivity issues for farming and horticultural enterprises and Wind Farm activities. Reverse sensitivity effects are also recognised in the Plan in relation to the Palmerston North Airport and other significant regional and district infrastructure and nearby residential activities (including such activities in the Rural Zone). Reverse sensitivity issues should be avoided or mitigated at the time of subdivision consent through the imposition of conditions or the decline of consent. … Similarly, Network utilities and Renewable Electricity Generation Facilities are often located in the rural environment on account of their special technical and locational requirements. Recognition of operational requirements at the time of subdivision consent, and in setting conditions on subdivision applications, will protect existing network utilities and existing or consented renewable electricity generation facilities from reverse sensitivity effects, provide for their continued reliable and secure operation and ongoing maintenance, while ensuring the health and safety of the people and communities that they serve. In all cases reverse sensitivity issues should be avoided or mitigated at the time of subdivision consent through the imposition of conditions or the decline of consent.

In addition to the above change, MRP submit that paragraph 6 be relocated in front of before paragraph 5 so that all paragraphs dealing with reverse sensitivity effects are dealt with together.

The submitter opposes Objective 3 in Section 7.3. The submitter is concerned that the list of matters included in the Objective doesn’t include reverse sensitivity effects despite the fact that policies associated with the Objective address this matter i.e, Policy3.1(h) (relating to setbacks from transmission), Policy 3.2(a) (iii) & (viii) & Policy 3.5(n). The submitter seeks that a bullet point be added to Objective 3, to include an explicit reference to reverse effects, as follows: “Avoids reverse sensitivity effects.”

The submitter opposes Policy 3.1 in Section 7.3. The submitter considers Policy 3.1 should specifically address potential reverse sensitivity effects on windfarms as this would provide an appropriate policy link to the windfarm separation distance performance standard contained in subdivision rules and give explicit policy direction in Policy D of the NPS REG and Policy3-2 of the RPS. It is submitted that a new clause (1) (i) be added to Policy 3.1 which reads: “(i) setbacks from existing or consented wind turbine sites for subdivision for new residential dwellings. The submitter opposes Policy 3.2 and considers it should specifically address potential reverse sensitivity effects on windfarms. This would give effect to the direction in Policy D of the NPS REG and Policy 3-2. The submitter seeks an amendment to Policy 3.2, to include Clause


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(a)(iii) which reads:“(iii)the subdivision and subsequent development will not result in significant adverse effects on the operation and viability of any adjoining farm, forestry or horticultural activity, or other lawfully established land-based activity, or existing or consented Wind Farm;” The submitter opposes Policy 3.4. The submitter is concerned that it should specifically address potential reverse sensitivity effects on windfarms. This would provide a policy link to the wind farm separation distance performance standard in the subdivision rules and give effect to the direction in Policy D NPS REG. The submitter seeks an amendment of Policy 3.4, to include Clause (b) which reads as follows:

“(b) the subdivision layout and design of the allotment will avoid, remedy or mitigate the potential for adverse effects on the environment, including reverse sensitivity effects.”

The submitter opposes the Explanation to Policies 3.1-3.4. It is submitted that the Explanation to Policies 3.1-3.4 be amended to provide a clear link to the wind farm separation distance which follows. The submitter requests the addition of a paragraph to the Explanation to Policies 3.1-3.4, as follows:

“Subdivision can create adverse reverse sensitivity effects on electricity and windfarms. These effects are to be managed through the use of performance standards requiring that building sites are setback from these important physical resources.”

The submitter opposes Policy 3.5 in Section7.3 which relates to subdivision within identified rural residential areas. The submission notes that Clause (n) requires that it be demonstrated that reverse sensitivity effects on existing land use activities can be avoided or adequately mitigated. It is submitted that this requirement be extended to ‘consented’ wind farms as well - to give effect the direction in Policy D of the NPS and Policy 3-2 of the RPS and be consistent with the wind farm separation distance standards in the Proposed Plan Change. The submitter seek the following amendment to clause (n) of Policy 3.5:

(n) Actual and potential reverse sensitivity effects in relation to existing land use activities, including existing strategic infrastructure and network utilities, existing or consented Wind farms, activities allowed by zoning, or areas anticipated for urban growth, are avoided or can be adequately mitigated.

The submitter opposes in part the Explanation to Policy 3.5. While MRP supports the 4th paragraph in principle, the submitter considers the reference should be to ‘renewable electricity generation activities’ it is quite specific to windfarms - rather than a broader reference to the use of renewable energy. The submitter seeks the 4th paragraph be amended by replacing the phrase ‘renewable energy generation activities’ with ‘renewable electricity generation activities’.

The submitter supports Objective 3 & Policies 3.1-3.6 in Section 7.4 Methods. The submitter supports the Method for Objective 3 and associated policies as they provide a framework for assessing resource consent applications for subdivision in rural areas, including addressing reverse sensitivity effects. The submitter seeks that Objective 3 & Policies 3.1-3.6 is retained.

The submitter opposes 7.6.3 Environmental Results Anticipated. The submitter is concerned that a specific reference to the avoidance or mitigation of reverse sensitivity effects associated with subdivision be included within the Environmental Results Anticipated, given the policies, explanations and rules addressing reverse sensitivity effects, including the use of separation distances. It is submitted that 7.6.3 Environmental Results Anticipated be amended to read:“3. The significant adverse effects, including reverse sensitivity effects, of land development are avoided or mitigated.” The submitter supports Rule 7.16.1.2 (b)(i) Lot Area – The submitter supports this Performance Standards as a means to avoid fragmentation of rural land and ad hoc development of rural residential activities in inappropriate locations. The submitter seeks the retention of the minimum lot area at 20ha in Performance Standard in Rule 7.16.1.2 (b)(i).

The submitter opposes Rule 7.16.1.2 Performance Standard (g). The submission notes that while the submitter supports the intent of the standard, it is submitted that the standard be amended to clarify that the separation distance:

a. applies to all consented wind turbines whether they have been constructed or not; and b. only applies to that portion of a proposed lot on which a dwelling is proposed to be built.

The present standard could be interpreted to only apply to exiting turbines (and not unbuilt consented turbines) and arguably to the whole of a proposed lot within 1.5km of a wind turbine. Neither possible interpretation in considered appropriate. The submitter requests that Performance Standard (g) of Rule 7.16.1.2 be amended as follows:

(g) No rural subdivision shall be approved, so as to which would enable result in a site for a new residential dwelling to be located within 1.5kn of any existing or proposed wind turbine for which resource consent has been granted. on a site for which a Wind Farm resource consent has been granted.


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The submitter supports the Explanation to Performance Standard Rule 7.16.1.2 (g). It is submitted that it is appropriate and therefore should be retained.

The submitter supports Rule 7.16.2.1, the associated Assessment Criteria & Explanation. IThe reduction in the area of the Rural Residential overlay is supported as a means to avoid fragmentation of rural land and ad hoc development of rural residential activities in inappropriate locations. The submitter also specifically supports the Restricted Discretionary Activity Rule 7.16.2.1 for subdivision in Rural Residential Areas and Rural Residential Overlay, and in particular, the matters listed under the Rule for ‘reverse sensitivity effects’, and ‘effects on Strategic Infrastructure and physical resources of national, regional or district importance, including the National Grid’. Also supports the matters for which discretion is restricted and Assessment Criteria for Rule 7.16.2.1

The submitter supports Rule 7.16.3.2 - Discretionary Activity Rule for Subdivision in the Tararua Ranges Landscape Protection Area. The submitter supports the proposed approach to company lease subdivision and considers this approach is appropriate as this type of subdivision is very unlikely to create new development rights and therefore need not be covered by the specific Tararua Ranges Landscape Protection Area subdivision rule. It is submitted that Rule R7.16.3.2 be retained without amendment.

The submitter opposes the Explanation to Rule 7.16.3.1 & Rule 7.16.3.2 . The submitter understands that Council intends subdivision which fails to comply with Controlled Activity Performance Standard of Rule 7.16.1.2 (g) for Wind Farm Separation Distance to be a Non-Complying Activity. It is submitted that this intent is not clear from the proposed Plan provisions, including the Explanation to Rule 7.16.3.1 & Rule 7.16.3.2. It is submitted that the Explanation be amended to ensure clarity and that the Discretionary Activity Rules do not apply to subdivision which does not comply with Performance Standard Rule 7.16.1.2 (g). The following amendment is suggested: “The provision of this Discretionary Activity Rule will ensure that rural subdivisions which do not comply with the Controlled Activity Performance Standards (other than lot area and wind farm separation distance Performance Standards) are…”

The submitter opposes Section 7.16.4– Non-Complying Activity Rule; R 7.16.4.1 & Explanation. It is submitted that it is not clear from the proposed Plan provisions, including the Non-Complying Rules in Rule 7.16.4.1 & Associated Explanation, that a subdivision which fails to comply with Controlled Activity Performance Standard Rule7.16.1.2 (g) for wind farm separation is a Non-Complying Activity. MRP seeks the following amendments to Rule 7.16.4.1 (3) and paragraph 3 of the Explanation:

(3) Any subdivision which does not comply with the Controlled Activity Performance Standards for Lot Area (Rule 7.16.1.2 (b) (i) and (ii) and Wind Farm Separation Distance (Rule 7.16.1.2(g)), is a Non-Complying Activity. Explanation to R7.16.4.1, (paragraph 3): Provision of this non-complying activity Rule enables Council to evaluate subdivision applications with undersized lots and/or building sites within 1.5 km of wind turbines on its merits, and set conditions appropriate to its future use and development and to avoid, remedy or mitigate any adverse effects on the environment.

The submitter opposes 9.1 Introduction. The submitter is concerned that it doesn’t recognise the significant renewable energy resource within the Rural Zone and the functional, operational and logistical requirements for windfarms to locate in this Zone. Recognition in the Introduction would give. The submitter seeks the addition of the following paragraph, or similar to Section 9.1 of the District Plan, to give appropriate effect to the NPS-REG and the RPS:

“The Rural Zone in the City contains significant renewable energy resources (particularly wind energy). Locating renewable electricity generation facilities in the Rural Zone is an appropriate response to this resource. It is also appropriate taking account of the functional, logistical and operation requirements of renewable electricity generation facilities. Notwithstanding this, decisions on the location and design of renewable electricity generation facilities within the Rural Zone must be made in a manner which avoids, remedies or mitigates adverse environmental effects.”

The submitter generally supports the Resource Management Issues listed in Section 9.2 and Explanation. Submits that the phrase ‘noise sensitive activities’ in Issue 14 is too narrow and doesn’t reflect the range of matters which new activities may be sensitive too. The submitter seeks that the word ‘noise’ be removed from this Issue 14. The submitter alas states that Issue 16 is weighted in favour of rural residential development and gives the impression that rural residential development may be the preferred land use activity in the Tararua Ranges. It is submitted that Issue 16 be amended to acknowledge that Wind Farms have the potential to result in adverse effects on rural residential development. The submitter generally supports the Explanation for 9.2 Resource Management Issues, subject to deleting the word ’noise’ in paragraph 5 consistent with the change sought for Issue 14.


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The submitter opposes in part Objective 1 and associated Policies in Section 9.3 and the Explanation; 2nd paragraph. The submission notes that the submitter generally supports Objective 1 and its associated Policies as they look to control Rural Zone subdivision, particularly rural residential subdivision so that it does not occur in an ad hoc and uncontrolled manner. However, the submitter seeks an amendment to the second paragraph of the Explanation to the Objectives and Policies, to recognise the need to control development in relation to existing or consented Wind Farms and give effect to the explicit direction in Policy D of the NPS REG and Policy 30-2 of the RPS. The following amendment to the 2nd paragraph of the Explanation for Objective 1 and Policies is sought: “Unrestricted rural residential development within the Rural Zone would have significant adverse effects on primary production activities, rural character, landscape and amenity, existing or consented wind farms and existing network utility infrastructure….”

The submitter opposes Policy 3.5 in particular the first part of Policy 3.5 relating to Outstanding Natural Features and Landscapes as it is overly restrictive in the context of Objective 3 and not consistent with the RPS. The submission states that MRP generally accepts intent of Policy 3.5 to avoid significant adverse visual effects on regionally Outstanding Natural Features and Landscapes but notes that management of Outstanding Natural Features and Landscapes is addressed under Objective 7 & needn’t be addressed under Objective 3 as well. The submitter is concerned with the second part of Policy 5.3 relating to ‘significant amenity landscapes in the Tararua Ranges and its foothills’ and ‘landmark features’ and that ‘significant amenity landscapes’ and ‘landmark features’ have not been identified in the District Plan, nor have the characteristics and values of these landscapes and features. Further, It is unclear what the Policy seeks to control in the way of adverse visual effects. The submitter has a similar concern with the Assessment Criteria for Wind Farm Rule 9.8.6. The submitter notes that Policy 3.5 is a new Policy and that the Explanation for Objective 3 and policies (including proposed changes to the Explanation) is unrelated to the matters addressed in Policy 3.5. It is submitted that Policy 3.5 be amended to apply more generally to the adverse visual effects of development to provide a better fit for Objective 3. The following amendment to Policy 3.5 is sought:

“3.5 To avoid significant adverse visual effects of renewable energy generation activities on regionally Outstanding Natural Features and Landscapes and To control adverse visual effects of development on the remainder of the Skyline of the Tararua Ranges and on the significant amenity landscapes in the Tararua Ranges and its foothills, in particular and the landmark features of including Te Mata Peak and Te Mata-Kaihinu Ridgeline.”

The submitter opposes Objective 7 & Policies 7.1 & 7.2. It is submitted that the regional ONFL values listed by the region and intended to be spatially defined in District Plans, be restricted to the highest ridges and hilltops. The submitter seeks that the Tararua Ranges Landscape Protection Area be modified to give effect to the Horizons One Plan and appropriately reflect the intent of Objective 7 to recognise regional ONFL, by excluding the lower and mid flanks of the Tararua Ranges. It is also submitted that the Tararua Ranges Landscape Protection Area should not include the consented windfarm environment, particularly turbine locations which contradict the identification of the areas as a regional ONFL. MRP seek the deletion of Objective 7 & Policies 7.1 & 7.2 unless the Tararua Ranges Landscape Protection Area (Map 9.1) is modified to meet the regionally outstanding threshold of the highest ridgelines and hilltops (excluding the lower and mid flanks of the Tararua Ranges), as well as excluding the consented Wind farm environment.

The submitter opposes in part Policy 7.3 in Section 9.3 and the associated Explanation. MRP submits that Policy 7.3 needs amendment to give effect to Policy 6-6 of the Horizons One Plan (RPS). In particular it is the significant adverse cumulative effects on the characteristics and values on the ONFL that are to be avoided. The submission also notes that Assessment Criterion (h) for Wind Farms Rule R9.8.6 refers to the ‘values and characteristics of the Tararua Ranges Landscape Protection Area. MRP submits that the matter which should be avoided are not structures having ‘potential to cause’ significant adverse cumulative effects, but those that will ‘result in such’ effects. MRP also submits that references to renewable energy generation activities in the Policy be changed as per its general Plan Change submission. The following amendment is sought:

“7.3 To avoid further development of renewable energy electricity generation activities and other major structures that have the potential to cause will result in significant adverse cumulative effects on the characteristics and values of the Tararua Ranges Landscape Protection Area (Map 9.1).”

It is also submitted that further clarity is required as to the meaning of ‘further development’ in Policy 7.3. This is not addressed in the Policy itself nor the Explanation, leaving it open for interpretation. It is submitted that the upgrade and replacement of infrastructure associated with renewable electricity generation facilities be excluded from the meaning of further development. Amend the Explanation which follows Policy 7.3 by adding the following paragraph:

“Policy 7.3 uses the phrase further development. For the purposes of this policy, and in relation to Wind Farms, this means the development of Wind Farms beyond the footprint of those for which resource consent has already been granted as at [insert plan notification date]. The phrase also excludes the maintenance, replacement and upgrade of these consented Wind Farms provided


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that adverse effects on the landscape values of the Tararua Ranges Landscape Protection Area are the same or similar in character, intensity and scale.”

The submitter opposes in part Objective 8. While MRP generally supports Objective 8 and related policies it falls short of giving effect to the NPS-REG and Horizons One Plan by failing to recognise the national significance of renewable electricity generation activities. The submission notes the focus of the Objective is on ‘renewable energy development’ but not on its use, which encompasses maintenance and upgrade activities. It is submitted that this doesn’t align with the statements in the Explanation for the Objective and Policies. It is submitted that Objective 8 be amended to be consistent with the intent of the Explanation and give effect to the NPS REG and the Horizons One Plan as follows: “To recognise and provide for the benefits and national significance of renewable energy use and development and the importance of the City’s renewable energy resources to long term sustainability.”

The submitter supports and opposes in part, Policy 8.1 to 8.4 & Explanation. The submitter supports the intent of Policy 8.1 but states it is unclear what is meant by ‘appropriate’ renewable energy generation activities, particularly given national and regional documents deem the activity to be appropriate e.g, the NPS REG, The New Zealand Energy Efficiency and Conservation Strategy, the New Zealand Energy Strategy and the Horizons One Plan. It is submitted that the word ‘appropriate’ be removed from Policy 8.1. The submitter supports Policies 8.2 and 8.3 in their current form but submits that Policy 8.4 be included as a Policy to implement Objective 9, as it directly addresses the adverse effects of renewable electricity generation activities. MRP submits that a new policy is required to give effect to the NPS REG and Horizons One Plan to address the national, regional and local benefits of renewable electricity generation and provide an appropriate framework for Assessment Criteria 9.8.6 (a). The submitter supports the Explanation for Objective 8 and associated policies (other than parts of the Explanation for Policy 8.4 which should sit in the Objective 9 and policies), and submits that they are retained.

The submitter opposes in part Policies 9.1 & 9.2 & associated Explanation. While the submitter generally supports Objective 9 it is submitted that the reference to ‘renewable energy generation activities’ be changed to ‘renewable electricity generation activities’. The submission also notes that 4th paragraph of the Explanation refers to offsetting measures or environmental compensation where residual environmental effects of renewable electricity generation cannot be avoided, remedied or mitigated and that this matter is not specifically addressed in Objective 9 or policies. The submitter considers this direction is important and should be a policy in its own right. It is submitted that the following additional policy is included: “To take account of proposed offsetting measures or environmental compensation when considering applications for renewable electricity generation activities where there are residual environmental effects that cannot be avoided, remedied or mitigated.” The submitter also seeks the amendment of 2nd or 3rd paragraphs of the Explanation for Objective 9 and policies. as follows:

“The District Plan provides for the replacement or repowering of Wind Farms as a Restricted Discretionary Activity and all other Wind Farms as a Discretionary Activity within the Rural Zone. These Discretionary Activity consent category allows Council to either decline a resource consent application, or grant consent and impose conditions in order to avoid, remedy or mitigate adverse effects on the environment. The Restricted Discretionary Activity and Discretionary Activity rules includes specific assessment criteria to guide Council’s consideration of applications for a Wind Farm to enable a and they will be subject to a full and rigorous assessment. The replacement or repowering of Wind Farms that do not meet the Performance Standards will be considered as Discretionary Activities, while all other Wind Farms that do not meet the Performance Standard will be considered as Non-Complying Activities.”

The submitter opposes the Permitted Activity Rule 9.5.3 for Home Occupations as it is uncertain whether the rule applies to Farm/Homestays or Bed and Breakfast activities. If it does apply to such activities, it is submitted that the Rule should include the ‘Wind Farm Separation Distance’ Performance Standard, as such activities will be potentially sensitive to Wind Farms the same as dwellings are. It is submitted that R 9.5.3 be amended by including a new performance standard as follows:

“(l) Separation Distances Home Occupations involving accommodation activities must be located not less than 1.5 km from the location of any wind turbine for which resource consent has been granted, whether the wind turbine has been constructed or not.”

The submitter opposes in part R 9.5.5 Permitted Activity for Dwellings & Accessory Buildings & Explanation. The submitter supports inclusion of the Wind Farm Separation Distance standard, as it is an appropriate means of implementing the proposed objectives and policies of PC 15, related ‘reverse sensitivity’ provisions in the RPS and the NPS REG. It is submitted that the Performance Standard and the 2nd paragraph of the Explanation be re-drafted to clarify that the separation distance applies to all consented wind turbines, not just those that have been consented. The following amendment to Performance Standard (b)(i)(c) of Rule 9.5.5, is sought:


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(a) “1.5 km from the location of any wind turbine for which resource consent has been granted, whether the wind turbine has been constructed or not on a site for which a wind farm consent application has been granted.”

An amendment to paragraph 2 of the Explanation for R 9.5.5 is also sought, as follows: “The separation distance for residential buildings from an existing or consented wind turbine is intended to ensure….” The submitter supports 9.6.2 Controlled Activity for Relocated Dwellings, in particular the Wind Farm Separation Distance Standard. It is submitted that this Performance Standard is an appropriate means of implementing the proposed objectives and policies of PC 15, and related ‘reverse sensitivity’ provisions in the RPS and NPS REG.

The submitter supports 9.6.3 Controlled Activity for Dependent Dwelling Unit in particular the Wind Farm Separation Distance Standard. It is submitted that this Standard is an appropriate means of implementing the proposed objectives and policies of PC 15, and related ‘reverse sensitivity’ provisions in the RPS and the NPS REG.

The submitter supports the Restricted Discretionary Activity Rule 9.7.1 for Dwellings or Accessory Buildings not complying with Permitted Activity Performance Standards, as it provides necessary clarity, by the explicit exclusion of activities not complying with Performance Standard 9.5.5 (b)(i) (c) from Rule 9.7.1.

The submitter opposes the Restricted Discretionary Activity Rule 9.7.2 for Home Occupations not complying with Permitted Activity Performance Standard. It is submitted that it is unclear whether the Home Occupation rules apply to Farm/Home Stays or Bed and Breakfast Activities (as with Rule 9.5.3). If the rules do apply to such activities the Permitted Activity rule should include the ‘Wind Farm Separation Distance’ Performance Standard and that Rule 9.7.2 should retain discretion for Council to consider reverse sensitivity effects on consented Wind Farms. It is submitted that Rule 9.7.2 be amended and a new Assessment Criterion be included, as follows:

“Home Occupations not complying with Permitted Activity Performance Standards are a Restricted Discretionary Activity with regard to:

• Effects on Adjoining Rural Environments • The Safe and Efficient Operation of the Roading Network • Reverse sensitivity effects on consented Wind Farms”

Add the following Assessment Criteria: “(e) The extent to which reverse sensitivity effects on consented Wind Farms are avoided, remedied or mitigated.”

The submitter opposes Restricted Discretionary Activity Rule 9.7. The submitter notes that: - that the current rule framework doesn’t fully implement the policy framework established under Policies 8.1 and 9.1. In particular, the

Discretionary Activity Rule 9.8.6 applies to all Wind Farm activities whether it is an existing or proposed Wind Farm, the replacement of turbines or the repowering of turbines.

- the rule framework is overly restrictive, and not in accordance with NPS REG and - does not give recognition to the existing environment created by existing or consented Wind Farms. The submitter seeks that a new rule be provided for Replacement and Repowering of Wind Farms as a Restricted Discretionary Activity. This will ensure Council gives full effect to the existing or original consented wind farm activity and does not frustrate the ability of the wind farm developer to make changes to their existing consented wind Farm where a range of effects have already been considered. The following new Restricted Discretionary Activity Rule in Section 9.7, including Performance Standards, Assessment Criteria and Explanation, is sought:

“R 9.7.X Replacement or Repowering of Wind Farms

Replacement or Repowering of Wind Farms are a Restricted Discretionary Activity, with regard to: • On-site location of structures • Landscape and visual effects • Construction noise effects • The safe and efficient operation of the roading network • Earthwork effects • Effects on aviation, navigation and existing network utilities • Ecological effects


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• Any change in effects between the original existing or consented Wind Farm and the Replacement or Repowered Wind Farm

Performance Standards

(i) The Replacement of existing or consented wind turbines where the number and height of turbines is not increased and any replaced turbines remain within the area of the original consented wind turbine sites on the Wind Farm.

(ii) The Repowering of existing wind turbines where

A. turbines are not located within 700 m of the boundary of an adjacent property, unless the application is lodged with a consent form signed by the owner or occupier of the adjacent property, and

B. the number of turbines is not increased.

Determination Clause

In determining whether to grant consent and what conditions to impose, if any, Council will in addition to the City View Objective in section 2 and the Rural Zone objectives and policies, assess any application in terms of the following assessment criteria to the extent that there is a change in effects between the original existing or consented Wind Farm and the Replacement or Repowered Wind Farm.

Assessment Criteria

(a) The contribution of the Wind Farm to achieving renewable energy targets. (b) The locational requirements of the Wind Farm and any logistical or technical practicalities associated with Wind

Farm development, upgrade, operation or maintenance. (c) The assessment, measurement and control of noise in accordance with New Zealand Wind Farm Noise Standard

(NZS 6808:2010 Acoustics – Wind Farm Noise). (d) The management and control of construction noise using the provisions of NZS 6803: 1999 Acoustics –

Construction Noise. (e) The management of landscape and visual impacts, including the location, design, appearance and concentration of

structures on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline, the Tararua foothills, Te Mata Peak and Te Mata-Kaihinu Ridgeline, rural character and visibility from neighbouring residences and public places.

(f) The extent to which the replacement and repowering of turbines will contribute to significant adverse cumulative visual effects on the characteristics and values on the Tararua Ranges Landscape Protection Area.

(g) Ecological impacts, including impacts on water bodies, indigenous flora and fauna, avifauna and their habitats. (h) Impacts of earthworks and modifications of natural landforms, including impacts on water quality and proposed

remedial and mitigation measures. (i) Impacts on archaeological or heritage sites, features and items, or any sites of special significance to tangata

whenua. (j) Impacts on the amenity values of the surrounding environment, including a consideration of aviation navigation

lighting, and turbine shadow glare or flicker. (k) Construction traffic impacts on the road network, including the nature and extent of vehicle movements, access,

management and mitigation measures, safety and levels of service. (l) The extent to which geotechnical hazards or other physical environmental factors are addressed in the application,

the measures employed to avoid, remedy or mitigate geotechnical matters and land stability impacts of the proposal, and the extent of compliance with best engineering and design practice and codes.

NOTES TO PLAN USERS:

1. The 700 m setback performance standard (ii) does not require the agreement of an adjacent property owner where the adjacent property is not within the boundaries of the Palmerston North City Council.


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Explanation

Policy 8.1 of the District Plan recognises the need for the investigation, development, operation, maintenance and upgrade of new and existing renewable electricity generation activities. In addition Policy 9.1 of the District Plan recognises the appropriate and well-designed upgrades of existing and consented renewable electricity activities. The “upgrade” activities in this context has the same meaning as the One Plan and means “bringing a structure, system, facility or installation up to date to improve its functional characteristics, provided the upgrading itself does not give rise to any significant adverse effects, and the character, intensity and scale of any adverse effects of the upgraded structure, system or facility or installation remain the same or similar.

The Replacement or Repowering of wind turbines on an existing or consented Wind Farm is consistent with this policy direction to ensure the Wind Farm remains functional and efficient, including addressing improvements in available technology between the time of a consent being granted and construction given the long lead times for Wind Farm development.

The replacement of existing or consented wind turbines applies to situations where the number and height of turbines is not increased. This enables turbines to be replaced with a different turbine make or model where effects, including noise effects, are the same or similar in character, intensity and scale as the existing or consented turbines.

The repowering of existing wind turbines applies to situations where turbines are replaced with larger and more efficient turbines, potentially resulting in an increase in the scale of effects. This enables the wind farm to be repowered resulting in improved efficiency or increased generation output. Due to the potential change in scale of effects, the repowered wind farm is subject to the 700 m setback from adjacent properties to address the actual or potential noise effects of the repowered turbines.

The Restricted Discretionary Activity status for this Rule enables the application to be examined on a case-by-case. At the same time, it provides discretion to not reconsider any effects that were adequately dealt with at the time of considering the original consent application and where there is minimal or no changes in the scale of effects concerned.”

The submitter considers a new Discretionary Activity rule is required where any replaced or repowered wind turbines don’t comply with the Performance Standards for the proposed Restricted Discretionary Activity Rule R9.7.X. (The reasons are noted in their submission on Section 9.7). This rule will ensure Council gives full effect to the existing or original consented wind farm activity and does not frustrate the ability of the wind farm developer to make changes to their existing consented Wind Farm where a range of effects have already been considered. The submitter requests that the following new Discretionary Activity Rule in Section 9.8, including Assessment Criteria and Explanation, be added:

“R 9.8.X Replacement or Repowering of Windfarms that do not comply with the Restricted Discretionary Activity Performance Standards in R9.7.X, are a Discretionary Activity”.

The submitter further requests that new Assessment Criteria be added for the new Discretionary Activity Rule R 9.8.X that is consistent with the Wind Farm Assessment Criteria for Rule 9.8.6, subject to relief in Mighty River Power’s submission for amendment or deletion to the Wind Farm Assessment Criteria. The submitter seeks the following Explanation to be included:

“Explanation The rule applies only to the Replacement and Repowering of the Wind Farm and only where the activity is unable to comply with the Performance Standards set out in the Restricted Discretionary Activity Rule. This enables the Replacement and Repowering of wind turbines to be examined on a case by case basis due to complexities in the activities and the assessments involved. At the same time, it provides discretion to not reconsider any effects that were adequately dealt with at the time of considering the original consent application and where there is minimal or no changes in the scale of effects concerned. This rule gives effect to section 7(j) of the RMA which requires Council to have particular regard to the benefits derived from the use and development of renewable energy and the National Policy Statement for Renewable Electricity Generation which directs that District Plans to have particular regard to the logistical or technical practicalities associated with developing, upgrading,


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operating or maintaining renewable energy generation activities.”

The submitter opposes Rule 9.8.4 Community and Leisure Facilities, Tourist Facilities, Education Facilities and Early Childhood Facilities and submit that the assessment critieria include reverse sensitivity effects, including such effects on consented wind farms. The submission states that this is appropriate given the potential sensitivities covered by the rule to activities in the Rural Zone, and in particular wind farms. The submitter seeks the addition of Assessment Criterion (l) to Rule 9.8.4 as follows:

“(l) The extent to which reverse sensitivity effects, including those on consented wind farms are avoided, remedied or mitigated.”

The submitter opposes Rule 9.8.6. The submission notes: ‐ While MRP supports the provision for new wind farms as a Discretionary Activity, it is submitted that a change is needed to Rule 9.8.6 to

reference the new rules proposed by MRP relating to the replacement or repowering of Wind Farms. ‐ The submitter has concerns with the two Performance Standards attached to the Discretionary Activity Rule 9.8.6. In relation to

Performance Standard (i) it accepts the Tararua Ranges is an outstanding landscape but submits it is important that Council provides for renewable energy activities in situations that give effect to the NPS REG. A Discretionary Activity status will allow Council to assess a proposal on its merits taking into account factors as the quality of the wind resource in the locality, appropriateness of development in the context of the ONFL, such as significant adverse cumulative effects on the characteristics ad values of the ONFL. MRP also submits that there is no discussion in the Explanation about the Performance Standard (i). MRP opposes the use of the phrases ‘Wind Farm Site’ and ‘Wind Farm’ in the Performance Standards and submits the Standards should apply to Wind Turbines instead, as this is the specific effect causing aspect of Wind Farm. The proposed restrictions (triggering non-complying activity status) shouldn’t apply to either ‘Wind Farm’ or ‘Wind Farm Site’ as these terms include significant areas where there are no turbines or will not be physically altered by the development of a Wind Farm.

‐ The submitter notes in the case of Performance Standard (ii) that the 700 m buffer is measured from a wind turbine site where the noise effect is generated. This provides greater certainty for the developer & the community, and is easier for Council to administer. It is further submitted that the trigger for non-complying activity status should be the location of the turbines and not other components of the Wind Farm. Notes that the use of the phrase ‘Wind Turbine’ is consistent with the Porirua City District Plan on which the proposed provision is based and which has been tested by the Environment Court.

‐ The submitter supports the Notes to Plan Users associated with R 9.8.6. The submitter seeks the following amendments to Rule 9.8.6:

“Wind Farms, other than those provided under R9.7.X and R9.8.X, are Discretionary Activities.” … “Performance Standards (i) The Wind Farm site must not be inside the Tararua Ranges Landscape Protection Area (Map 9.1).

(ii) Wind turbines The Wind Farm must not be located within 700 m of the boundary of the Wind Farm site with an adjacent property, unless the application is lodged with a consent form signed by the owner or of occupier of the adjacent property.”

Explanation (amendment to the final sentence of the paragraph 3)

” and hence an application for a Wind Farm seeking to establish wind turbines within the 700 m setback area, will be assessed as a Non-complying Activity.’”

The submitter opposes in part the Assessment Criteria for Rule 9.8.6; specifically criterion (g), (h), (i), (j) & (n). While most of the Assessment Criteria are acceptable some criterion require further clarification or amendment, or should be deleted. For example, Assessment Criterion (g) should be deleted as it is unclear what the term ‘safeguard and contingencies’ means; The word ‘appropriate’ in Assessment Criterion (h) should be deleted, as the assessment matters refer to the management of the proposals impact; The references to ‘significant amenity landscapes’ and ‘landmark features’ within Criterion (h) and (j) should be removed as these have not been identified in the District Plan, nor have the characteristics and values of these landscapes and features and therefore it is not clear what Policy 3.5 and the Wind Farm Assessment Criteria seeks to control, in the way of adverse visual effects; Assessment Criterion (i) should be amended consistent with Policy 7.3 which refers to ‘significant adverse cumulative effects on the characteristics and values of the Tararua Ranges Landscape Protection Area’. It is submits that the Assessment Criteria should not require an assessment of matters not covered by the policies or expand beyond what the policy is seeking to achieve; The phrase ‘consideration of any environmental disturbance’ in Assessment Criterion (n) should be removed as it is unclear what it means and how it differs from the other listed criteria. The following specific amendments are sought to Assessment Criteria (g),(h), (i), (j) and (n) for Rule R9.8.6:


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- Delete Assessment Criterion (g) relating to safeguards and contingencies - Amend Assessment Criterion (h) as follows:

“(h) The appropriate management of landscape and visual impacts, including the location, design, appearance and concentration of structures on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline,significant amenity landscapes in the Tararua foothills, Te Mata Peak and Te Mata-Kaihinu Ridgeline, rural character and visibility from neighbouring residences and public places.”

‐ Amend Assessment Criterion (i) as follows: “(i) The significant cumulative visual effects of the proposal on the characteristics and values on the Tararua Ranges Landscape Protection Area. and consented Wind Farms (including a consideration of the relationship between the various Wind Farms), with particular regard to the effects of additional turbines on views of the Tararua Skyline along its entire length and potential for visual saturation of the skyline landscape with Wind Farm turbines extending across the full extent of the Tararua Ranges.”

- Delete Assessment Criterion (j) relating to visual effects. - Amend Assessment Criterion (n) as follows:

“(n) Impacts on the amenity values of the surrounding environment, including a consideration of any environmental disturbances, aviation navigation lighting, and turbine shadow glare or flicker.”

The submitter opposes in part Discretionary Activity Rule 9.8.7 - New Dwellings and Accessory Buildings, Dependent Dwelling Units, Relocated Dwellings, Education and Early Childhood Facilities located within 1.5 km of a wind turbine, on a site for which a Wind Farm resource consent has been granted. While the submitter supports the Rule including Assessment Criteria (d) relating to reverse sensitivity effects, it submits (that as a result of a consequential change to its earlier submission point), it is submitted that the title of the activity rule needs to be clarified that it applies to activities within 1.5km of consented turbines, notwithstanding whether they have been constructed or not. The amendment sought is as follows:

“R 9.8.7 New Dwellings and Accessory Buildings, Dependent Dwelling Units, Relocated Dwellings, Education and Early Childhood Facilities located within 1.5 km of a wind turbine, for which resource consent has been granted, whether the wind turbine has been constructed or not, on a site for which a Wind Farm resource consent has been granted, are Discretionary Activities.”

The submitter opposes the Explanation for Non-Complying Activity Rule 9.9.3 and seeks removal of the reference to the Performance Standard for the Tararua Ranges Landscape Protection Area, as a consequential amendment to their submission on Rule 9.8.6. The following amendment to the Explanation for Rule 9.9.3 is sought:

“Explanation It is necessary that Council undertake a full and comprehensive effects assessment of a proposed Wind Farm that does not comply with the Discretionary Activity Performance Standards relating to including a Wind Farm which seeks to locate within, or partially within, the confines of the Tararua Ranges Landscape Protection Area, as well as the consideration of impacts on surrounding properties and residences, to ensure that the objectives and policies of the District Plan are fulfilled, with respect to achieving the sustainable management of the natural and physical resources of the Rural Zone.

The protection of Outstanding Natural Features and Landscapes from inappropriate subdivision, use and development is required under Section 6 (a) and (b) of the RMA. The attributes, characteristics and values of these Outstanding Natural Features and Landscapes are of such significance to warrant Council to strictly control Wind Farm developments in the Tararua Ranges Landscape Protection Area, hence the Non-Complying Activity status. This activity categorisation is consistent with the regional landscape policy 7-7 of the One Plan (Manawatu-Wanganui Regional Council).”

The submitter opposes in part Map 9.1, specifically the spatial extent of the Taraua Ranges Landscape Protection Area. It is submitted that the regional ONFL values listed by the Region (Schedule G, Table G1 of the Horizons One Plan) and intended to be spatially defined in District Plans, be restricted to the highest ridgelines and hilltops. The submitter requests that the TRLPA be modified to exclude the lower and mid flanks of the Tararua Ranges as this gives effect to the Horizons One Plan and appropriately reflects the intent of Objective 7 to recognise the regional ONFL. It is further submitted that the TRLPA be modified to exclude the consented windfarm environment, particularly turbines, which contradict the identification of the areas as a regional ONFL.

The submitter opposes Chapter 23 to the extent that it does not adequately provide for utilities or utility providers, except where it is a network utility or a network utility operator. Specific areas of concern noted are: ‐ The title for Chapter 23, which has changed from ‘Utilities’ to ‘Network Utilities’. MRP submits that is not a network utility operator under


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the RMA and is unable to operate under the designation procedures in the RMA with respect to its electricity provisions and transmission activities, necessary to link renewable electricity generation activities to the National Grid or end users.

‐ Section 23 –Introduction. The submitter is concerned that the Introduction focusses only on network utilities and network utility operations and submits that he Introduction be expanded to include a discussion on other electricity transmission activities, particularly those that are not deemed to be a network utility.

‐ Section 23.2 Resource Management Issues, 23.3 Objectives and Policies and Section23.4 Methods. The submitter is concerned that these sections only deal with network utilities and associated activities. Supports the general intent of the Objectives and Policies provided that Sections 23.2, 23.3 7 23.4 are expanded to address the establishment, operation, maintenance and upgrading of electricity transmission activities that are not deemed to be a network utility.

‐ Rules – The submitter generally supports the rules in Chapter 23 which provide for electricity transmission activities, in particular Rule 23.7.1 (i), R 23.7.1 (xi), R 23 10.1 (i).

The submitter requests that the title of Chapter 23 be amended to ‘Utilities’ or ‘Network Utilities and Electricity Transmission’ and that Sections 23.1, 23.2, 23.3 & 23.4 be amended to address the establishment, operation, maintenance and upgrading of electricity transmissions activity, that are not deemed to be a network utility. The submitter requests that Permitted Activity Rule 23.10.1 (i) and Rule 23.7.1 (xi), and Discretionary Activity Rule 23.7.1(i) be retained.

The submitter supports the District Plan Maps, specifically the reduced Rural Residential Overlay. The submitter supports the reduction in the area of the Rural Residential Overlay as a means to avoid fragmentation of rural land and ad hoc development of rural residential activities, in inappropriate locations. This will ensure that potential adverse reverse sensitivity effects on wind farms (amongst other effects) can be avoided, and would give effect to Policy D of the NPS REG and to Policy 3-2 of the RPS. The submitter seeks that the reduced area for the Rural Residential Overlay on the District Planning Maps be retained without amendment.

Decisions Requested: 1. Provide additional support in the policy and rules framework of PC15A-H to better provide for existing and new renewable

electricity generation facilities and any consequential amendments required as a result of general and specific relief requested in the submission points.

2. Replace the phrase ‘renewable energy generation activities’ to either ‘renewable electricity generation activities or ‘the use of Renewable Energy Resources,’ as is appropriate to the context.

3. Retain the Section 4 Definitions for Mast and Meteorological Activities without change.

4. Retain the Definition of Renewable Electricity Generation Activities/Facilities in the same or similar form.

5. Retain the Definition of Renewable Energy Resources in the same or familiar form.

6. Amend the definition of ‘Separation Distance, to read: “Separation Distance means the distance from the outer wall of a building to:

(a) The outer wall of another building;

(b) The boundary of a site.

In the case of a Wind Farm Separation Distance, it means the distance from the outer wall of a propose building, or the edge of an identified building site shown on a scheme plan, to the outer wall of a wind turbine tower or the closest edge of a consented wind turbine site.

In the case of hazardous…’

Or provide a new definition for ‘Wind Farm Separation Distance’ with the same meaning.

7. Amend the definition of ‘Wind Farm’ as underlined, or similar: “Wind Farm means turbines other than a Domestic Wind Turbine used to generate energy from the wind, and includes:

• pylons or towers that support turbines • ancillary buildings and structures on the Wind Farm Site • Community-scale wind farms.


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A The term Wind farm excludes earthworks and roading, transmission lines, substations, switchyards or any switching gear, and infrastructure associated with transmission lines.”

8. Retain the definition of ‘Wind Farm Site’ in same or similar form.

9. Replace the information requirements in Section 5.4(0) with the following: ‘In addition to the information required for a land use resource consent in Section 5.4(a) to 5.4(e), any resource consent application for a wind farm must include an assessment of environmental effects which addresses the Assessment Criteria in Rule R9.8.6.’ Or, in the alternative, amend or delete clause (ii) and (iii) of Section 5.4(o) as underlined: (ii) Landscape Assessments prepared by an appropriately qualified landscape professional, including:

Assessment of Landscape and Amenity Effects, including cumulative visual effects and any adverse visual effects on the characteristics and values of the Tararua Ranges Landscape Protection Area. A Skyline Assessment Report including a statement as to whether the proposed development will affect the whole/part of the Tararua Ranges Landscape Protection Area and whether or not its characteristics and values are protected.

(iii) A Social Impact Assessment Report prepared by an appropriately qualified professional.”

10. Amend the final bullet point in The Effects of Subdivision’ list, on page 83 as underlined: “Reverse sensitivity effects where new sensitive land uses lead to constraints on existing or consented land use activities.”

Alternatively, add a new bullet point that specifically deals with reverse sensitivity effects on existing or consented renewableelectricity generation activities.

11. Amend Resource Management Issue 7.2.1 so it reads as follows: “Unless subdivision is controlled it will Uncontrolled subdivision can lead to the unsustainable use of land, and other resources,including infrastructure and renewable energy resources. particularly With regard to rural land, where inappropriate land fragmentation will reduce the overall productive capability of rural areas and result in the loss of versatile soils for use as production land.”Amend final bullet point in the Explanation for Resource Management Issue 7.2.1, as underlined

Management of reverse sensitivity effects associated with complaints from new sensitive land uses located in proximity to consented renewable electricity generation activities or any existing, lawfully established activities or operations.

12. Amend the 3rd, 4th and 6th paragraphs of the Explanation for Resource Management Issue 7.2.5 as follows: “The District Plan makes specific provision for rural-residential subdivision use of on some of the City’s less versatile rural land to meet demand for rural living, and to help reduce pressure to subdivide higher quality land, for residential purposes. An Overlay for rural residential subdivision identifies areas suitable for rural residential development, to avoid a proliferation of rural residentialactivities throughout the Rural Zone and reverse sensitivity issues for farming and horticultural enterprises and Wind Farm activities.

Reverse sensitivity effects are also recognised in the Plan in relation to the Palmerston North Airport and other significant regionaland district infrastructure and nearby residential activities (including such activities in the Rural Zone). Reverse sensitivity issues should be avoided or mitigated at the time of subdivision consent through the imposition of conditions or the decline of consent.

…

Similarly, Network utilities and Renewable Electricity Generation Facilities are often located in the rural environment on account of their special technical and locational requirements. Recognition of operational requirements at the time of subdivision consent, and in setting conditions on subdivision applications, will protect existing network utilities and existing or consented renewable electricitygeneration facilities from reverse sensitivity effects, provide for their continued reliable and secure operation and ongoing maintenance, while ensuring the health and safety of the people and communities that they serve.

In all cases reverse sensitivity issues should be avoided or mitigated at the time of subdivision consent through the imposition of conditions or the decline of consent.


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In addition to the above change, Relocate paragraph 6 before paragraph 5 so that all paragraphs dealing with reverse sensitivity effects are dealt with together.”

13. Add a further bullet point to Objective 3, in Section 7.3 as follows: • “Avoids reverse sensitivity effects.”

14. Add a new clause (1) (i) to Policy 3.1 in Section 7.3 as follows: (i) “setbacks from existing or consented wind turbine sites for subdivision for new residential dwellings.”

15. Amend Policy 3.2, Clause (a)(iii) in Section 7.3 as follows: “(iii) the subdivision and subsequent development will not result in significant adverse effects on the operation and viability of any adjoining farm, forestry or horticultural activity, or other lawfully established land-based activity, or existing or consented Wind Farm;”

16. Amend Clause (b) to Policy 3.4, in Section 7.3 as follows: “(b) the subdivision layout and design of the allotment will avoid, remedy or mitigate the potential for adverse effects on the environment, including reverse sensitivity effects.”

17. Amend Clause (n) of Policy 3.5 in Section 7.3 as follows:

“(n) Actual and potential reverse sensitivity effects in relation to existing land use activities, including existing strategic infrastructure and network utilities, existing or consented Wind Farms, activities allowed by zoning, or areas anticipated for urban growth, are avoided or can be adequately mitigated.”

18. Amend the 4th paragraph of the Explanation to Policy 3.5 by replacing the phrase ‘renewable energy generation activities’ with ‘renewable electricity generation activities’.

19. Retain the statement in Section 7.4 Methods: Objective 3 & Policies 3.1-3.6 in same or similar form.

20. Amend 7.6.3 Environmental Results Anticipated as follows: “3. The significant adverse effects, including reverse sensitivity effects, of land development are avoided or mitigated.”

21. Retain the minimum lot area at 20ha in Performance Standard in R 7.16.1.2 (b)(i).

22. Amend Performance Standard (g) of Rule 7.16.1.2 as follows:

“(g) No rural subdivision shall be approved, so as to which would enable result in a site for a new residential dwelling to be located within 1.5kn of any existing or proposed wind turbine for which resource consent has been granted. on a site for which a Wind Farm resource consent has been granted.”

23. Retain the Explanation for Performance Standard (g) of Rule 7.16.2.1 in same or similar form.

24. Retain Rule 7.16.2.1, including the matters for which discretion is restricted and the Assessment Criteria, in same or similar form.

25. Retain Rule 7.16.3.2 without amendment.

26. Amend the Explanation to Rule 7.16.3.1 & Rule 7.16.3.2, as follows (or similar): “The provision of this Discretionary Activity Rule will ensure that rural subdivisions which do not comply with the Controlled Activity Performance Standards (other than lot area and wind farm separation distance performance standards) are…”

27. Amend Rule 7.16.4.1(3) as underlined, or similar: “(3) Any subdivision which does not comply with the Controlled Activity Performance Standards for Lot Area (Rule 7.16.1.2 (b) (i) and (ii) and Wind Farm Separation Distance (Rule 7.16.1.2(g)), is a Non-Complying Activity.” Amend paragraph 3 of the Explanation to Rule 7.16.4.1, as underlined: “Provision of this non-complying activity Rule enables Council to evaluate subdivision applications with undersized lots and/or building sites within 1.5 km of wind turbines on its merits, and set conditions appropriate to its future use and development and to avoid, remedy or mitigate any adverse effects on the environment.”


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28. Add the following paragraph, or similar to Section 9.1 Introduction, of the District Plan:

“The Rural Zone in the City contains significant renewable energy resources (particularly wind energy). Locating renewable electricity generation facilities in the Rural Zone is an appropriate response to this resource. It is also appropriate taking account of the functional, logistical and operation requirements of renewable electricity generation facilities. Notwithstanding this, decisions on the location and design of renewable electricity generation facilities within the Rural Zone must be made in a manner which avoids, remedies or mitigates adverse environmental effects.”

29. Retain the proposed Resource Management Issues in Section 9.2, except for the amendments to Issue 14 & Issue 16, as follows: “14. The need to protect Wind Farms from reverse sensitivity effects associated with noise sensitive activities establishing in the surrounding rural environment.” “16. The Tararua Ranges are a significant wind energy resource for renewable electricity generation and the development of Wind Farms in this area has the potential to result in adverse effects on limit the use and development of rural land in close vicinity for rural residential development.”

Retain the Explanation for 9.2 Resource Management Issues, except for the amendment to paragraph 5. as follows: “…However, there is a need to manage reverse sensitivity effects from noise sensitive activities seeking to locate in close proximity to consented Wind Farms.”

30. Retain Objective 1 and its associated Policies, or similar provisions. Amend 2nd paragraph of the Explanation for Objective 1 and Policies as follows: “Unrestricted rural residential development within the Rural Zone would have significant adverse effects on primary production activities, rural character, landscape and amenity, existing or consented wind farms and existing network utility infrastructure….”

31. Amend Policy 3.5 as follows (or similar): “3.5 To avoid significant adverse visual effects of renewable energy generation activities on regionally Outstanding Natural Features and Landscapes and To control adverse visual effects of development on the remainder of the Skyline of the Tararua Ranges and on the significant amenity landscapes in the Tararua Ranges and its foothills, in particular and the landmark features of including Te Mata Peak and Te Mata-Kaihinu Ridgeline.”

32. Delete Objective 7 & Policies 7.1 & 7.2 unless the Tararua Ranges Landscape Protection Area (Map 9.1) is modified to meet the regionally outstanding threshold of the highest ridgelines and hilltops (excluding the lower and mid flanks of the Tararua Ranges), as well as excluding the consented Wind farm environment.

33. Amend Policy 7.3 as follows: “7.3 To avoid further development of renewable energy electricity generation activities and other major structures that have the potential to cause will result in significant adverse cumulative effects on the characteristics and values of the Tararua Ranges Landscape Protection Area (Map 9.1).” Amend the Explanation which follows Policy 7.3 by adding the following paragraph: “Policy 7.3 uses the phrase ‘further development.’ For the purposes of this policy, and in relation to Wind Farms, this means the development of Wind Farms beyond the footprint of those for which resource consent has already been granted as at [insert plan notification date]. The phrase also excludes the maintenance, replacement and upgrade of these consented Wind Farms provided that adverse effects on the landscape values of the Tararua Ranges Landscape Protection Area are the same or similar in character, intensity and scale.”

34. Amend Objective 8 as follows: “To recognise and provide for the benefits and national significance of renewable energy use and development and the importance of the City’s renewable energy resources to long term sustainability.”

35. Amend Policy 8.1 to 8.4 & Explanation for Objective 8 as follows: “8.1 To provide for the investigation, development, operation, maintenance and upgrade of appropriate new and existing renewable electricity energy generation activities.”


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‐ Retain Policies 8.2 and 8.3 in the same or similar form.

‐ Move Policy 8.4 so that it sits under and implements Objective 9.

‐ Add a new Policy, as follows:

“When assessing a resource consent application for renewable electricity generation activities Council shall recognise and provide for the national, regional and local benefits of renewable electricity generation activities in relation to climate change, security of electricity supply, and social, cultural and economic well-being.”

‐ Retain the Explanation for Objective 8 and associated policies without change, other than part of the Explanation for Policy 8.4 which should sit in the Explanation for Objective 9 and policies.

36. Retain Objective 9, Policy 9.1 & 9.2 as proposed or similar. Insert the following additional policy: “To take account of proposed offsetting measures or environmental compensation when considering applications for renewable electricity generation activities where there are residual environmental effects that cannot be avoided, remedied or mitigated.” Amend the 2nd or 3rd paragraphs of the Explanation for Objective 9 and policies as follows: “The District Plan provides for the replacement or repowering of Wind Farms as a Restricted Discretionary Activity and all other Wind Farms as a Discretionary Activity within the Rural Zone. These Discretionary Activity consent category allows Council to either decline a resource consent application, or grant consent and impose conditions in order to avoid, remedy or mitigate adverse effects on the environment. The Restricted Discretionary Activity and Discretionary Activity rules includes specific assessment criteria to guide Council’s consideration of applications for a Wind Farm to enable a and they will be subject to a full and rigorous assessment. The replacement or repowering of Wind Farms that do not meet the Performance Standards will be considered as Discretionary Activities, while all other Wind Farms that do not meet the Performance Standard will be considered as Non-Complying Activities.”

37. Amend Rule 9.5.3 by including a new performance standard (l) as follows: “(l) Separation Distances Home Occupations involving accommodation activities must be located not less than 1.5 km from the location of any wind turbine for which resource consent has been granted, whether the wind turbine has been constructed or not.”

38. Amend Performance Standard (b)(i)(c) of Rule 9.5.5, as follows: (b)“1.5 km from the location of any wind turbine for which resource consent has been granted, whether the wind turbine has been constructed or not on a site for which a wind farm consent application has been granted.”

Amend the 2nd paragraph of the Explanation for R 9.5.5 as follows: “The separation distance for residential buildings from an existing or consented wind turbine is intended to ensure….”

39. Retain Rule 9.6.2 and Performance Standard 9.6.2 (i), or similar.

40. Retain Rule 9.6.3 and Performance Standard 9.6.3 (iv), or similar.

41. Retain Rule 9.7.1 particularly the exclusion of activities not complying with Performance Standard 9.5.5 (b)(i)(c).

42. Amend R 9.7.2 as follows: “Home Occupations not complying with Permitted Activity Performance Standards are a Restricted Discretionary Activity with regard to: • Effects on Adjoining Rural Environments • The Safe and Efficient Operation of the Roading Network • Reverse sensitivity effects on consented Wind Farms”


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Add the following Assessment Criteria: “(e) The extent to which reverse sensitivity effects on consented Wind Farms are avoided, remedied or mitigated.”

43. Add a new Restricted Discretionary Activity Rule in Section 9.7, including Performance Standards, Assessment Criteria and

Explanation as follows: “R 9.7.X Replacement or Repowering of Wind Farms Replacement or Repowering of Wind Farms are a Restricted Discretionary Activity, with regard to:

• On-site location of structures • Landscape and visual effects • Construction noise effects • The safe and efficient operation of the roading network • Earthwork effects • Effects on aviation, navigation and existing network utilities • Ecological effects • Any change in effects between the original existing or consented Wind Farm and the Replacement or Repowered

Wind Farm

Performance Standards (i) The Replacement of existing or consented wind turbines where the number and height of turbines is not increased and

any replaced turbines remain within the area of the original consented wind turbine sites on the Wind Farm.

(ii) The Repowering of existing wind turbines where A. turbines are not located within 700 m of the boundary of an adjacent property, unless the application is lodged

with a consent form signed by the owner or occupier of the adjacent property, and B. the number of turbines is not increased.

Add a new Determination Clause & Assessment Criteria for the new Restricted Discretionary Activity Rule R 9.7.X, as follows:


In determining whether to grant consent and what conditions to impose, if any, Council will in addition to the City View Objective in section 2 and the Rural Zone objectives and policies, assess any application in terms of the following assessment criteria to the extent that there is a change in effects between the original existing or consented Wind Farm and the Replacement or Repowered Wind Farm.

Assessment Criteria

a) The contribution of the Wind Farm to achieving renewable energy targets. b) The locational requirements of the Wind Farm and any logistical or technical practicalities associated with Wind Farm

development, upgrade, operation or maintenance. c) The assessment, measurement and control of noise in accordance with New Zealand Wind Farm Noise Standard (NZS

6808:2010 Acoustics – Wind Farm Noise). d) The management and control of construction noise using the provisions of NZS 6803: 1999 Acoustics – Construction Noise. e) The management of landscape and visual impacts, including the location, design, appearance and concentration of structures

on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline, the Tararua foothills, Te Mata Peak and Te Mata-Kaihinu Ridgeline, rural character and visibility from neighbouring residences and public places.

f) The extent to which the replacement and repowering of turbines will contribute to significant adverse cumulative visual effects on the characteristics and values on the Tararua Ranges Landscape Protection Area.

g) Ecological impacts, including impacts on water bodies, indigenous flora and fauna, avifauna and their habitats. h) Impacts of earthworks and modifications of natural landforms, including impacts on water quality and proposed remedial and

mitigation measures. i) Impacts on archaeological or heritage sites, features and items, or any sites of special significance to tangata whenua.


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j) Impacts on the amenity values of the surrounding environment, including a consideration of aviation navigation lighting, and turbine shadow glare or flicker.

k) Construction traffic impacts on the road network, including the nature and extent of vehicle movements, access, management and mitigation measures, safety and levels of service.

l) The extent to which geotechnical hazards or other physical environmental factors are addressed in the application, the measures employed to avoid, remedy or mitigate geotechnical matters and land stability impacts of the proposal, and the extent of compliance with best engineering and design practice and codes.

NOTES TO PLAN USERS:

1. The 700 m setback performance standard (ii) does not require the agreement of an adjacent property owner where the adjacent property is not within the boundaries of the Palmerston North City Council.”

Add a new Explanation for the new Restricted Discretionary Activity Rule R9.7.X as follows:

“Explanation

Policy 8.1 of the District Plan recognises the need for the investigation, development, operation, maintenance and upgrade of new and existing renewable electricity generation activities. In addition Policy 9.1 of the District Plan recognises the appropriate and well-designed upgrades of existing and consented renewable electricity activities. The “upgrade” activities in this context has the same meaning as the One Plan and means “bringing a structure, system, facility or installation up to date to improve its functional characteristics, provided the upgrading itself does not give rise to any significant adverse effects, and the character, intensity and scale of any adverse effects of the upgraded structure, system or facility or installation remain the same or similar”.

The Replacement or Repowering of wind turbines on an existing or consented Wind Farm is consistent with this policy direction to ensure the Wind Farm remains functional and efficient, including addressing improvements in available technology between the time of a consent being granted and construction given the long lead times for Wind Farm development.

The replacement of existing or consented wind turbines applies to situations where the number and height of turbines is not increased. This enables turbines to be replaced with a different turbine make or model where effects, including noise effects, are the same or similar in character, intensity and scale as the existing or consented turbines.

The repowering of existing wind turbines applies to situations where turbines are replaced with larger and more efficient turbines, potentially resulting in an increase in the scale of effects. This enables the wind farm to be repowered resulting in improved efficiency or increased generation output. Due to the potential change in scale of effects, the repowered wind farm is subject to the 700 m setback from adjacent properties to address the actual or potential noise effects of the repowered turbines.

The Restricted Discretionary Activity status for this Rule enables the application to be examined on a case-by-case. At the same time, it provides discretion to not reconsider any effects that were adequately dealt with at the time of considering the original consent application and where there is minimal or no changes in the scale of effects concerned.”

44. Add a new Discretionary Activity Rule in Section 9.8, including Assessment Criteria and Explanation, as follows: “R 9.8.X Replacement or Repowering of Windfarms that do not comply with the Restricted Discretionary Activity Performance Standards in R9.7.X, are a Discretionary Activity”

‐ Add new Assessment Criteria for the new Discretionary Activity Rule R 9.8.X that is consistent with the Wind Farm Assessment Criteria for R9.8.6, subject to relief in Mighty River Power’s submission for amendment or deletion to the Wind Farm Assessment Criteria.

‐ Add a new Explanation for the new Discretionary Activity Rule R9.8.X as follows: “Explanation The Rules applies only to the Replacement and Repowering of the Wind Farm and only where the activity is unable to comply with the Performance Standards set out in the Restricted Discretionary Activity Rule. This enables the replacement and repowering of wind turbines to be examined on a case by case basis due to complexities in the activities and the assessments involved. At the same time, it provides discretion to not reconsider any effects that were adequately dealt with at the time of considering the original consent application and where there is minimal or no changes in


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the scale of effects concerned.

This rule gives effect to section 7(j) of the RMA which requires Council to have particular regard to the benefits derived from the use and development of renewable energy and the National Policy Statement for Renewable Electricity Generation which directs that District Plans to have particular regard to the logistical or technical practicalities associated with developing, upgrading, operating or maintaining renewable energy generation activities.”

45. Add an additional Assessment Criterion (l) to Rule 9.8.4 as follows:”(l) The extent to which reverse sensitivity effects, including those on consented wind farms are avoided, remedied or mitigated.”

46. Amend Rule 9.8.6 as follows:”Wind Farms, other than those provided under R9.7.X and R9.8.X, are Discretionary Activities.”

47. Amend the Performance Standards in Rule 9.8.6 as follows: “Performance Standards (i) The Wind Farm site must not be inside the Tararua Ranges Landscape Protection Area (Map 9.1). (ii) Wind turbines The Wind Farm must not be located within 700 m of the boundary of the Wind Farm site with an adjacent property, unless the application is lodged with a consent form signed by the owner or of occupier of the adjacent property.”

48. Amend the final sentence of the 3rd paragraph of the Explanation as follows: ‘ and hence an application for a Wind Farm seeking

to establish wind turbines within the 700 m setback area, will be assesses as a Non-complying Activity.’

49. Retain the Notes to Plan Users associated with Rule 9.8.6. 50. Amend or delete Assessment Criteria (g),(h), (i), (j) and (n) for Rule 9.8.6, as follows:

- Delete Assessment Criterion (g) relating to safeguards and contingencies - Amend Assessment Criterion (h) as follows:

“(h) The appropriate management of landscape and visual impacts, including the location, design, appearance and concentration of structures on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline,significant amenity landscapes in the Tararua foothills, Te Mata Peak and Te Mata-Kaihinu Ridgeline, rural character and visibility from neighbouring residences and public places.”

‐ Amend Assessment Criterion (i) as follows: “(i) The significant cumulative visual effects of the proposal on the characteristics and values on the Tararua Ranges landscape Protection Area. and consented Wind Farms (including a consideration of the relationship between the various Wind Farms), with particular regard to the effects of additional turbines on views of the Tararua Skyline along its entire length and potential for visual saturation of the skyline landscape with Wind Farm turbines extending across the full extent of the Tararua Ranges.”

- Delete Assessment Criterion (j) relating to visual effects. - Amend Assessment Criterion (n) as follows:

“(n) Impacts on the amenity values of the surrounding environment, including a consideration of any environmental disturbances, aviation navigation lighting, and turbine shadow glare or flicker.”

51. Amend the title of the Discretionary Activity Rule 9.8.7, as follows:

“R 9.8.7 New Dwellings and Accessory Buildings, Dependent Dwelling Units, Relocated Dwellings, Education and Early Childhood Facilities located within 1.5 km of a wind turbine, for which resource consent has been granted, whether the wind turbine has been constructed or not, on a site for which a Wind Farm resource consent has been granted, are Discretionary Activities.”

52. Amend the Explanation for Rule 9.9.3 as follows: “Explanation It is necessary that Council undertake a full and comprehensive effects assessment of a proposed Wind Farm that does not comply with the Discretionary Activity Performance Standards relating to including a Wind Farm which seeks to locate within, or partially within, the confines of the Tararua Ranges Landscape Protection Area, as well as the consideration of impacts on surrounding properties and residences, to ensure that the objectives and policies of the District Plan are fulfilled, with respect to achieving the sustainable management of the natural and physical resources of the Rural Zone.

The protection of Outstanding Natural Features and Landscapes from inappropriate subdivision, use and development is required


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under Section 6 (a) and (b) of the RMA. The attributes, characteristics and values of these Outstanding Natural Features and Landscapes are of such significance to warrant Council to strictly control Wind Farm developments in the Tararua Ranges Landscape Protection Area, hence the Non-Complying Activity status. This activity categorisation is consistent with the regional landscape policy 7-7 of the One Plan (Manawatu-Wanganui Regional Council).”

53. Modify the Tararua Ranges Landscape Protection Area in Map 9.1, to meet the regionally outstanding threshold of the highest ridges and hilltops as well as excluding the consented windfarm environment.

54. Amend the title of Chapter 23 to ‘Utilities’ or ‘Network Utilities and Electricity Transmission’.

55. Amend Sections 23.1, 23.2, 23.3 & 23.4 to address the establishment, operation, maintenance and upgrading of electricity transmissions activities that are not deemed to be a network utility.

56. Retain Permitted Activity Rules R23.10.1 (i) and R23.7.1 (xi), including Performance Standards in the same or similar form.

57. Retain Discretionary Activity Rule R23.7.1 (i) in the same or similar form.

58. Retain the reduced area for the Rural Residential Overlay on the District Planning Maps without amendment. Submission Number

Plan Change Number


SO44 15G S1 General Introduction S4 Definitions S5 Information Requirements S6 General S7 Subdivision S9 Rural Zone S13 Airport Zone S23 Utilities

Federated Farmers Manawatu-Rangitikei Province

Coralee Matena PO Box 945 PALMERSTON NORTH 4440

YES

Submission: The submitter generally supports PC15A-H, its tone, the Section 32 report and proposed District Plan sections with regard to the rural sector.

The submitter commends provision of the Interactive Map as a useful tool to view proposed provisions and understand how these impact on individual land lots and suggests that the Interactive Map be adapted as provisions are finalised and made accessible as a future reference tool.

The submitter seeks that better information is made available with regard to soil types. With reliance on soil type criteria for zoning and subdivision, good quality and accurate mapping of soils within the PNCC boundary should available to land owners. It is submitted that PNCC provide access to soil maps and other soil information for ratepayers, possibly through the provision of the interactive map tool.

The submitter seeks that PNCC take proactive measures where possible to avoid, mitigate and manage reverse sensitivity effects of new subdivision and residential development on existing land use activities, particularly those of a rural nature.

The submitter recommends the District Plan provisions provide necessary flexibility for land owners to make subdivision decisions that are in the best interest of owners, and fit better with the intent of the District and wider Regional Plans (for example with regard to soil class and long term productivity).

The submitter requests that future residential or industrial ratepayers make ongoing financial contributions to drainage and flood schemes to ensure this infrastructure is capable of meeting the needs of development without adversely effecting surrounding landowners

The submitter recognises the need for the District Plan to give effect to Regional Plan changes, with regard to Wind Farms and Landscapes and Flood Hazards, and the recent boundary change.

The submitter supports in part the 2nd paragraph of Section 1.1.3 Demographics in Section 1 The General Introduction. The submitter suggests identifying primary production as a key employment growth sector in ‘Economic Growth’ to reflect the increase in rural and industrial activity under PNCC's jurisdiction from PPC15C. The following amendment is sought: The six five key sectors which are expected to contribute the most to employment growth in the City over the next 25 years are: healthcare


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and social assistance; retail trade, accommodation and food services; logistics (transport, warehousing, and wholesale trade); public administration and safety; and professional, scientific and technical services; and primary production (on farm and processing).” The submitter supports in part 1.3.2 Land Use Strategies of Section 1.3.2 Relationship with Other Plans, Strategies and Policies. The submitter suggests that 1.3.2 Land Use Strategies should be expanded so that individual Land Use Strategies are described in greater detail, such as in section 1.1.20 of the Section 32 Report for PPC15A-H. The following amendment is proposed:

“Land Use Strategies The Council prepares and updates land use strategies that manage future growth within the City such as Residential, Industrial, Rural-Residential and Retail development. The Rural-Residential Land Use Strategy seeks, first and foremost to protect the economic viability of Palmerston North’s rural economy taking into account social, economic and environmental drivers. It provides direction as to how the projected demand for rural living will be managed over a ten-year planning period in an integrated manner.”

The submitter neither supports or opposes the definition of Rural Industry in Section 4: Definitions. The submission notes that ‘rural industry’ is defined in the District Plan and submits that ratepayers that meet this definition (farmland ratepayers) are not impacted by zoning changes and/or rate increases. The submitter opposes in part 5.5 Subdivision Consents (a) (xxvii). The submitter suggests that there are people suitably experienced to produce a Rural Productivity Report (under 5.5 Subdivision Consents xxvii) that may not have a qualification in agricultural science or rural economics. The submitter states that PNCC can make an assessment of credibility at the time of the report. The following amendment is sought:“(xxvii) …a Rural Productivity Report, which is prepared by a person PNCC considers suitably qualified and experienced in agricultural science and / or rural economics, which…” The submitter supports the retention of rural activities in activities listed under R6.2.6.2 Exclusions from Noise Control Rules. The submitter supports retaining the exclusion of rural activities (d) from noise rules in the Plan. The submitter supports the retention of rural activities as an exclusion from R6.3.6.1, and the explanation reference to the nature of earthworks considered as a normal permitted activity resulting in less than minor effects. The submitter supports in part The Effects of Subdivision – The submission notes the addition of bullet points to the effects of subdivision. The submitter supports addition of the bullet point relating to reverse sensitivity, as reverse sensitivity matters are a real consequence for members and wider rural land owners. The submitter encourages Council to take practical steps to manage reverse sensitivity before they arise, eg via the consent process. The submission notes the effects of residential subdivision in the Rural Zone, particularly higher density residential areas, has consequential effects on farmers in terms of rates, due to pressure on rateable values. The addition of a new bullet point to the ‘The Effects of Subdivision’ is sought, to reflect flow on economic consequences of subdivision with regard to rates on existing land owners: • “The economic consequences of subdivision to existing land owners as a result of higher land prices in rural areas and the subsequent

increase in rates.”

The submitter supports in part Resource Management Issue 1 & Issue 3; and Explanations – The submission notes the expansion of the Explanation for Issue 1 to recognise RMA and Regional Council provisions. The submitter supports sustainable land use and commitment to retaining Class 1 and 2 versatile soils for use as production land and submits the activity status in the District Plan should provide for these soils and then less versatile soils, as appropriate. The FF submission notes the statement regarding ad-hoc rural residential subdivision and submits this is achieved via the distinctions in the Plan between intensified development (via rural residential overlay) and wider Rural Zone. FF supports text regarding compliance with PNCC Engineering Standards and Regional Council requirements for on-site domestic wastewater treatment in rural areas. The Submission notes developments have effects on surrounding areas and careful management is required to avoid possible flow on effects. The submission states that future residential or industrial ratepayers, where appropriate should make ongoing financial contributions to drainage and flood schemes to ensure this infrastructure meets the needs of development without adversely effecting surrounding areas. The submission notes reference to reverse sensitivity effects associated with complaints from new land uses locating in proximity to existing lawfully established activities. FF recommends that the list of subdivision controls (pg 86) include the following bullet points: • “Differentiation of activity class to reflect the nature of class 1 and 2 soils • Management of development effects of rural residential subdivision to surrounding landowners • Management of reverse sensitivity effects caused by new land uses located in proximity to existing lawfully established activities or

operations”

The submitter supports in part Resource Management Issue 4 and Explanation – The Submission notes the additional text in Issue 4 to recognise the unique character of soils in the Flood Protection Zone and specific reference to horticultural activities. The submitter


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considers this should be widened to include agricultural activities, for clarity and to reflect what is proposed in the District Plan. The following amendment is proposed to the paragraph beginning ‘The Flood Protection Zone…,’: “…smaller lot subdivision is provided for as a Restricted Discretionary Activity in the Flood Protection Zone for horticultural and agricultural activities, subject to…’”

The submitter supports Objective 3 regarding subdivision of land and building in rural areas, particularly: • Retaining the productive capability of rural land • Protecting Class 1 and 2 versatile soils as productive land • Providing for rural residential development on land with less versatile soil.

The submitter opposes Policy 3.1 and 3.2 for the subdivision of rural land into allotments 20 ha or more. It is submitted that the 20 ha ‘one size fits all’ approach is not practical and doesn’t support the District Plan objectives for the subdivision of rural land and wider needs of rural communities and future rural subdivision residents. The following issues are identified: - no distinction between class 1 and 2 soils in the Rural Zone; - impracticality of the assumption that Rural Residential Zone will provide the necessary space for urban sprawl into the Rural Zone;

impacts on the livelihood of farming; - contradiction of Proposed District Plan provisions. It is submitted that the reference to a 20 ha lot minimum in proposed policies 3.1 and 3.2 are deleted. The submitter supports Objective 5 and the proposed the requirements for the North East Industrial Zone, particularly the requirement for a Comprehensive Development Plan for each stage of subdivision. The submission notes members concerns about developments in the NEIZ and flow on effects/consequences on surrounding land uses. The submitter seeks that Objective 5 is retained as written.

The submitter supports Objective 8 & Policy and the proposed requirements for the Braeburn Industrial Area. The submission reiterates members concerns about effects of development and flow on effects/consequences for surrounding land uses. The submission also notes that the statement in the Explanation: ‘with respect to water, wastewater and stormwater, the Braeburn Industrial Area is likely to be self-serviced and not connected to the Council’s reticulated network’. It is submitted that this is an essential requirement and that the Policy be amended to provide certainty to the self-sufficient nature of the Braeburn Industrial Area. The following text is proposed: 1. “With respect to water, wastewater and stormwater, the Braeburn Industrial Area will may is likely to be self-serviced and not connected

to the Council’s reticulated network.”

The submitter opposes 7.5 Principal Reasons: 3, 4, 9 & 10. It is submitted that Reasons 3, 4, 9 & 10 need highlighting in terms of the decisions that Council is making with regard to the proposed provisions in the Plan for rural subdivision and that the proposed rules better align with the Reasons, as proposed.

The submitter supports in part Rule 7.16.1.1 Controlled Activities. The submitter recommends that ‘reverse sensitivity effects’ is added to the list of Performance Standards for R7.16.1.1 Controlled Activities.

The submitter supports proposed Rule 7.15.2.1 in the Flood Protection Zone to accommodate horticulture, cropping and grazing activities. It is submitted that the Explanation be amended to clarify that the scope of subdivision is for agricultural as well as horticultural activities. The submitter seeks the Explanation to Rule 7.15.2.1 be amended as follows:

“This rule is included within the District Plan to provide for horticulture and agriculture activities… The 2 hectare minimum lot area recognises and gives due regard to the current pattern and intensity of horticultural and agricultural land use activities and meets the specific needs of the horticultural and agriculture sector, for smaller horticultural and agricultural blocks, while facilitating further use of the City’s most versatile soil resources.”

The submitter supports in part R7.16.1.1 Controlled Activity. The submitter requests that reverse sensitivity effects is added to the list of Performance Standards for Controlled Activities (Rule 7.16.1.1), to align with the objectives and policies outlined in the District Plan and the matters in respect for Rule 7.16.2.1.

The submitter opposes R 7.16.2.1(b)(i) – Lot Area and the increase in the minimum lot area from 4 ha to 20 ha. It is submitted that a ‘one size fits all approach’ 20 ha minimum is a crude means of protecting productive land and providing for different approaches to different soil types and likely to have the reverse effect of requiring rural landowners to subdivide larger sections, therefore areas of more versatile soil. It is submitted that for consistency and to align with the direction of the Regional Council, a distinction in minimum lot sizes should also apply to the Rural Zone dependent on the versatility and soil type. The submission notes the Explanation for Rule 7.16.1.2 refers to the importance of rural subdivision to rural enterprise, specifically the establishment of new economic activity, enterprise and farm consolidation. The submitter


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requests that the District Plan continue to ensure provisions are enabling and dont negatively affect future economic abilities of rural livelihoods and surrounding communities.

The submitter supports R 7.16.2.1(b)(ii) to provide for the subdivision of land to accommodate a current surplus dwelling as a Controlled Activity. It is submitted that by providing for this, Council is ensuring that family can co-locate on the farm and continue to operate as a family business, and maintain the historical nature of rural communities. The submitter is concerned that a minimum lot area of 1 ha is too large and that the minimum lot size of 1 ha as proposed for existing dwellings and requests it is deleted and the provisions allow for lot sizes up to 2 ha.

The submitter opposes Rule 7.16.4.1 (3). It is submitted that the Non-complying activity status for subdivision consents outside of the Controlled Activity permissions (R 7.16.1.2 (b)) doesn’t align with the intent of the District Plan in Objective 3 of 7.3 Objectives and Policies. It is submitted that a Restricted Discretionary Activity status enables Council to make decisions to consent the subdivision provided they are aligned with the intent of the objectives and policies of the Plan, and is consistent with the activity status of other activities in the District Plan. It is further submitted that to ensure consistency with national legislation, the RMA test that best aligns to these activities is Restricted Discretionary. The submitter opposes the default non-complying status of activities that are not assigned a status elsewhere.

The submitter supports Rule 7.17.1.2 Any Subdivision in the National Grid Subdivision Corridor and submits that Rule 7.17.1.2 is retained as written.

The submitter supports Rule 9.5.5 Dwellings and Accessory Buildings (excluding those prohibited by R 9.10.1) in particular Performance Standard (e). The submitter supports the permitted status of a second dwelling on properties over 20ha and the graduated approach where the number of dwellings permitted depends on the size of the property. It manages density of dwellings in the Rural Zone while providing more houses for larger properties. The submitter supports retaining Performance Standard (e) as written as a guide to the number of dwellings permissible on subdivision lot; provided the Rural Zone minimum lot sizes are amended to 8 ha for Class 1 and Class 2 versatile soils, and 4 ha for less versatile soils.

The submitter supports Rule 9.11.1 Noise & the Explanation. The submission supports the reference in Explanation to R 9.11.1 that rules are intended to provide for normal agricultural activities which controlling noise from a range of other activities which also exist in the area e.g, home occupations. The submitter also supports references in the plan to mitigating reverse sensitivity effects and reference to excluding normal agricultural activities from rural noise rules. The submitter seeks that Rule 9.11.1 and the supporting Explanation is retained as written.

The submitter supports Section 13: Airport Zone. The submission notes that the provisions regarding this asset and supporting infrastructure are of economic benefit to the primary industries and the wider PNCC economy.

The submitter support Section 23 Utilities and supports the proposed provisions for subdivision within the National Grid Corridor, and network utility provisions regarding earthworks in the national grid (noting that business as usual farming activities are permitted and/or exempt). The submitter recommends that PPC15G recognise the adverse effects that network utilities can have on land owners. The submitter states that adverse effects of network utilities on farming needs to be managed, and that landowners are acknowledged as enablers of electricity transmission by providing the land as a platform for infrastructure.

The submitter supports in part Resource Management Issue 2. The submitter seeks that Resource Management Issue 2 be amended to recognise as the actual and potential effects of network utilities on land owners, via the following amendment:

“2. The actual and potential adverse effects on the environment and landowners resulting from the establishment, operation, maintenance and upgrade of network utilities and associated infrastructure.”

The submitter supports R23.7.3(c). The submission notes that c) any agricultural or horticultural activity within the National Grid Yard that is not specified as a Non complying activity in Rule 23.11.2 is a permitted activity. The submitter seeks that Rule 23.7.3 c) be retained as written. Decisions Requested:

1. That PNCC make available better information with regard to soil types and/or provide access to soil maps and other soil information for ratepayers, possibly through the provision of the interactive map tool.

2. That PNCC take proactive measures where possible to avoid, mitigate and manage reverse sensitivity effects of new subdivision

and residential development on existing land use activities, particularly those of a rural nature.


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3. That District Plan provisions provide necessary flexibility for land owners to make subdivision decisions that are in the best interest of owners, and fit better with the intent of the District and wider Regional Plans (for example with regard to soil class and long term productivity).

4. S1.1.3: That 1.1.3 Economic Growth is amended as follows: The six five key sectors which are expected to contribute the most to employment growth in the City over the next 25 years are: healthcare and social assistance: retail trade, accommodation and food services; logistics (transport, warehousing, and wholesale trade); public administration and safety; professional, scientific and technical services; and primary production (on farm processing).

5. S1.3.2: That 1.3.2 Land Use Strategies is amended as follows: The Council prepares and updates land use strategies that manage future growth within the City such as Residential, Industrial, Rural-Residential and Retail development. The Rural-Residential Land Use Strategy seeks, first and foremost, to protect the economic viability of Palmerston North's rural economy, taking into account social, economic and environmental drivers. It provides direction as to how the projected demand for rural living will be managed over a ten-year planning period in an integrated manner.

6. 5.5 xxvii: That 5.5 Subdivision Consents xxvii is amended as follows: … a Rural Productivity report, which is prepared by a person PNCC considers suitably qualified and experienced in agricultural science, and/or rural economics, which …

7. R6.2.6.2(d): That Rule 6.2.6.2(d) is retained without modification.

8. R6.3.6.2(vii): That Rule 6.3.6.2(vii) is retained without modification.

9. The addition in Section 7.1 Introduction of a new bullet point to ‘The effects of subdivision’ to reflect flow on economic consequences of subdivision with regard to rates on existing land owners, as follows: • “The economic consequences of subdivision to existing land owners as a result of higher land prices in rural areas and the

subsequent increase in rates.” 10. That the list of subdivision controls (pg 86), include the following bullet points:

• “Differentiation of activity class to reflect the nature of class 1 and 2 soils • Management of development effects of rural residential subdivision to surrounding landowners • Management of reverse sensitivity effects caused by new land uses located in proximity to existing lawfully established

activities or operations”

11. That the paragraph beginning – The Flood Protection Zone, in the Explanation to Resource Management Issue 7.2.4, is amended as follows: “…smaller lot subdivision is provided for as a Restricted Discretionary Activity in the Flood Protection Zone for horticultural and agricultural activities, subject to…’

12. That the following objectives (part of Objective 3) regarding subdivision of land and building in rural areas, are retained:

• “Retaining the productive capability of rural land” • “Protecting Class 1 and 2 versatile soils as productive land” • “Providing for rural residential development on land with less versatile soil.”

13. Delete the reference to a 20 ha lot in proposed Policies 3.1 and 3.2.

14. That Objective 5 is retained as written.

15. That the Policy related to Objective 8 is amended to provide certainty to the self-sufficient nature of the Braeburn Industrial Area e.g “With respect to water, wastewater and stormwater, the Braeburn Industrial Area will may is likely to be self-serviced and not connected to the Council’s reticulated network.”That the proposed rules better align with the proposed Reasons 3, 4, 9 & 10, within Section 7.5 Principal Reasons.

16. That the proposed rules better align with the Proposed Reasons 3, 4, 9, & 10 in Section 7.5 Principal Reasons.


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17. That ‘reverse sensitivity effects’ as added as a Performance Standard for Rule 7.16.1.1 Controlled Activities.

18. That the references in Section 7.15 to horticultural activities be widened to include agricultural activities, including Rule 7.15.2.1 and the Explanation to Rule 7.15.2.1 as follows:

“This rule is included within the District Plan to provide for horticulture and agriculture activities… The 2 hectare minimum lot area recognises and gives due regard to the current pattern and intensity of horticultural and agricultural land use activities and meets the specific needs of the horticultural and agriculture sector, for smaller horticultural and agricultural blocks, while facilitating further use of the City’s most versatile soil resources.”

19. That reverse sensitivity is added to Performance Standard for Rule 7.16.1.1 Controlled Activities.

20. That the current minimum lot size of 4 ha is maintained as a Controlled Activity for subdivision in the Rural Zone.

- That to give effect to the direction of the Regional Council regarding the protecting versatile soils, a minimum lot size of 8 ha is provided for type 1 and 2 soils as a Controlled Activity in the Rural Zone.

- That Rule 7.16.2.1 (b) (i) is retained as written provided lot sizes are amended to 8 ha for class 1 and 2 versatile soils and 4

ha for less versatile soils.

21. That Rule 7.16.1.2 (b) (ii) is amended to delete the reference to 1 ha minimum and instead the provision allows for lot sizes up to 2 ha.

22. That any subdivision which does not comply with the Controlled Activity Performance Standards for lot area (Rule 7.16.1.2(b)) are provided for as Restricted Discretionary Activities, rather than Non Complying Activities as currently proposed.

23. That Rule 7.17.1.2 is retained as written.

24. Retain Performance Standard (e) for Rule 9.5.5 as written.

That Rule 6.2.6.2.1. d) is retained as written provided the rural zone minimum lot sizes are amended to 8 ha for class 1 and 2 versatile soils, and 4 ha for less versatile soils.

25. That Rule 9.11.1 and the supporting Explanation is retained as written.

26. Retain the provisions of the Airport Zone.

27. Retain the proposed provisions for subdivision within the National Grid Corridor and network utility provisions regarding earthworks in the National Grid.

28. Amend Resource Management Issue 2 to recognise as the actual and potential effects of network utilities on land owners, via the following amendment: “2. The actual and potential adverse effects on the environment and landowners resulting from the establishment, operation, maintenance and upgrade of network utilities and associated infrastructure.”

29. R23.7.3(c): That R23.7.3(c) is retained without modification.


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Submission Number

Plan Change Number


SO45 15A 15B

S4 Definitions S5 Information Requirements S7 Subdivision S9 Rural Zone Appendix 2: Planning Maps

Trustpower Limited Laura Marra Private bag 12023 Tauranga Mail Centre 3143 TAURANGA

YES

Submission: PC15A The submitter opposes the definition of Renewable Energy Generation Activities/Facilities. They request the definition be deleted and replaced with the following wording:

“Renewable Energy Generation Activities/Facilities means electricity generation activities or facilities that utilise renewable energy resources, including activities or facilities where electricity is generated from wind, solar, hydro, geothermal, and biomass energy sources. Has the same meaning as defined by the National Policy Statement for Renewable Electricity Generation 2011. “

The submitter supports the definition of Wind Farm with amendment as follows: “Wind Farm means turbines other than a Domestic Wind Turbine used to generate energy from the wind, and includes:

• Turbines, including support pylons or towers that support turbines • ancillary buildings and structures on the Wind Farm Site such as substations, maintenance buildings and communication

equipment • Community-scale wind farms.

A Wind Farm excludes transmission lines and associated infrastructure associated with transmission lines external to the Wind Farm.”

The submitter opposes Clause (iii) Social Impact Assessment Report of (o) Special Information Requirements for Wind Farms in Section 5.4 Land use Consents, and submits that the Clause (iii) be deleted.

The submitter supports 9.1 Introduction and seeks an amendment to paragraph 6, as follows. “Network utility operations and renewable electricity generation facilities and activities are also located in the rural environment, often due to their operational requirements and the location of natural and physical resources in the District. Likewise, Ddevelopment in close proximity to network utilities requires careful management…”

The submitter supports Resource Management Issue 1. The submitter seeks the following amendment:

• The effects of urban growth and the possible intrusion of urban development into rural areas, resulting in the loss of productive land, and disruption to rural communities and the need for further network infrastructure.”

The submitter supports Resource Management Issue 13. The submitter seeks the following amendment. “13. The need to recognise and provide for the significant benefits of existing and future renewable energy generation activities and associated infrastructure (at commercial and domestic scales), whilst avoiding, remedying or mitigating adverse effects.”

The submitter opposes Resource Management Issue 15 and seeks that it be deleted.

The submitter supports Resource Management Issue 16 with amendments, as follows: “16. The Tararua Ranges are a significant wind energy resource for renewable electricity generation and the development of Wind Farms in this area has the potential to limit the use and development of rural land in close vicinity for should be balanced against the demands on rural land for rural residential development.”

The submitter supports Resource Management Issue 18 with amendment, as follows

“18. The need to avoid Inappropriate use and development has the potential for significant adverse cumulative effects on the values and characteristics of the Tararua Ranges and the Manawatu Gorge regionally Outstanding Natural Features and Landscapes.”


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The submitter supports Policy 1.3 with amendment as follows: “1.3 To ensure that the urban conversion of the land proceeds in an orderly manner and that existing rural activities, including windfarms, are not adversely affected by the introduction of more sensitive activities in the rural environment.”

The submitter supports Explanation for Objective 1 (and related policies) with amendments, as follows.

“… Unrestricted rural residential development within the Rural Zone would have significant adverse effects on primary production activities, rural character, landscape and amenity, and existing network utility infrastructure and renewable electricity generation facilities (including maintenance and upgrading work). It may also place restrictions on the introduction of new network utilities and other infrastructure that may be required in the future. To avoid sporadic rural residential subdivision and development and protect the productive capability of the City’s versatile Class 1 and 2 soils and rural based infrastructure, the Plan identifies specific locations where rural residential activities can be suitably accommodated, (refer to the Planning Maps). The Plan intentionally directs rural residential development away from the City’s versatile soils, and is consistent with the Council’s Rural Residential Land Use Strategy, which seeks to see high quality rural land within the City retained for productive purposes.”

The submitter supports Explanation for Objective 2 (and related policies) with an amendment to the1st paragraph of the Explanation, as follows.

“It is important that rural land continues to be used in a way which ensures that the productive potential of the land can be maintained, and that other existing activities can continue to operate is maintained in a sustainable manner. However, the wide range of activities which occur in the rural area can sometimes produce a range of adverse effects which must be addressed if there are not to be negative effects on the rural environment….”

The submitter supports Objective 3 with an amendment, as follows.

“Objective 3 To enhance maintain the quality and natural character of the rural environment.”

The submitter opposes Policy 3.5 and seek that it be deleted in its entirety

The submitter supports Objective 4 with an amendment as follows. “Objective 4 To recognise and enhance the diversity of the rural community by encouraging a range of activities that are compatible with, or are required to locate in, the rural environment.”

The submitter supports Policy 4.3 with an amendment, as follows. “4.3 To allow a range of other activities where their adverse effects can be avoided, remedied or mitigated.”

The submitter supports the Explanation for Objective 4 with the following amendments:

“While much of the rural area is devoted to large scale rural land uses such as farming and forestry, there are a wide variety of other activities which rely on natural and physical resources in rural areas and contribute to the maintenance of land and the diversity of the rural community. These other activities include Wind Farms, small engineering works, schools, community halls, recreational activities, home occupations, veterinary clinics, animal boarding establishments, nurseries, roadside stalls, and garden centres. While tThese activities are valuable parts of the rural community, and which often also serveing not only local communities urban communities but in some cases contribute to services on a regional or national scale. it is important that there are controls over any adverse environmental effects which they may produce. However, The existence of these activities also helps to make the rural community a sustainable community, in that services are offered in close proximity thereby reducing travel costs and time.it avoids extended energy inefficient journeys to use the business, recreational and leisure facilities which are provided in the urban area. However, it is important that there are controls over any adverse effects which they may produce.”

The submitter supports Policy 7.2 with amendment. “7.2 To control manage new land use and development within the Tararua Ranges Landscape Protection Area (Map 9.1) to protect so that the characteristics and values of the Tararua Ranges and the Manawatu Gorge Outstanding Natural Features and Landscapes are maintained.”


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The submitter supports Policy 7.3 (proposed to be re-numbered 7.4) with amendments, and the addition of a new Policy 7.4, as follows.

7.3 To recognise the presence of existing land use activities and development within the Tararua Ranges Landscape Protection Area and manage any adverse effects that may arise from their continued operation, maintenance and upgrade.

7.34 To avoid control new subdivision, land use and further development of renewable energy generation activities and other major structures that may have the potential to cause significant adverse cumulative effects on the Tararua Ranges Landscape Protection Area (Map 9.1).

The submitter supports the Explanation for Objective 7 with the following amendments. “Explanation Landscapes are an important issue for the City as they provide identity and a sense of place. The Tararua Ranges is the most significant and highly visible landscape within the City, and is subject to development pressure from many rural based activities, but particularly from Wind Farm developments.

Council is required to recognise and provide for the protection of Outstanding Natural Features and Landscapes from inappropriate subdivision, use and development, as a matter of national importance (s 6(b) of the RMA).

The Tararua Ranges and the Manawatu Gorge are identified in the Manawatu-Wanganui Regional Council’s One Plan as regionally Outstanding Natural Features and Landscapes, having characteristics, values and qualities which warrant their protection and appropriate management. A full description of these regionally Outstanding Natural Features and Landscapes and the underpinning evaluation, using the criteria established in the One Plan (Schedule F), is provided in the report entitled Landscape Management Strategy Palmerston North.

This objective and associated policies gives effect to the RMA and higher order planning instruments by giving explicit recognition to the landscape significance of the Tararua Ranges and the Manawatu Gorges within the District Plan.

The visual and landscape values of the Tararua Ranges Landscape Protection Area is afforded the highest level of landscape protection within the District Plan and this provides the basis for regulating the effects of new development. In cases where development and land use activities are already established within the Tararua Ranges Landscape Protection Area, the District Plan anticipates that there will be times when maintenance and upgrading of facilities, building and infrastructure will be required and depending on the scale of the work involved will assess such works as part of a restricted discretionary resource consent process.

The District Plan anticipates that new Aactivities like renewable energy developments which may wish to establish in the Tararua Ranges Landscape Protection Area and could result in changes to the characteristics and values of these regionally Outstanding Natural Features and Landscapes. In such cases, Council will require a rigorous assessment through a restricted discretionary resource consent process.

The District Plan provides for Wind Farms as a Discretionary Activity within the Rural Zone, provided they are located outside of the Tararua Ranges Landscape Protection Area, shown on Map 9.1 and comply with a 700 m separation distance from adjacent boundaries with properties that do not form part of a Wind Farm site.”

The submitter supports Objective 8 with the following amendment. “Objective 8 To recognise the local, regional and national benefits of renewable energy development and the importance of the City’s renewable energy resources to long term sustainability.”

The submitter supports with Policy 8.1 with the following amendment: “8.1 To provide for the investigation, development, operation, maintenance and upgrade of appropriate new and existing renewable energy generation activities.”

The submitter supports Policy 8.2 with an amendment as follows:

“8.2 To protect existing and consented renewable electricity generation activities from reverse sensitivity effects arising from the establishment of noise sensitive activities in close proximity.”

The submitter supports the Explanation for Objective 8 with the following amendments.


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“Explanation

The benefits of renewable energy developments are considerable. As a clean fuel source, Wind Farms do not rely on fossil fuels to operate and do not generate greenhouse gases or other pollutants. They are sustainable and cost efficient.

In New Zealand the demand for energy continues to grow and the contribution of renewable electricity generation in meeting that demand is notable. Development that increases renewable electricity generation capacity have positive environmental effects that span locally, regionally and nationally.

Council is required to have particular regard to the benefits to be derived from the use and development of renewable energy under section 7(j) of the RMA.

In addition and as a matter of national importance, Council must also give effect to the National Policy Statement for Renewable Electricity Generation Activities (NPSREG) which sets out an objective and policies to enable the sustainable management of renewable electricity generation.

Provision is made in the Manawatu-Wanganui Regional Council’s One Plan which requires that the District Plan have regard to the benefits of infrastructure (including their establishment, operation, maintenance and upgrading) as a matter of national importance and also increases the use of renewable energy in the region.

This objective and associated policies recognise the national significance of the development and maintenance of renewable energy resources under the RMA and gives effect to the National Policy Statement for Renewable Electricity Generation Activities (NPS REG). In giving effect to the NPS REG, the District Plan rules address renewable energy resources to the extent that they are applicable in the Rural Zone – namely wind and solar. Policy 8.4 recognises the City’s wind energy resource and the locational, logistical and technical practicalities of developing renewable electricity generation activities, consistent with Policies B and C1 of the NPS REG. are significant regional infrastructure).

This objective and polices also implements the Manawatu-Wanganui Regional Council’s One Plan, which identifies renewable energy generation activities as significant regional infrastructure and facilitates the appropriate upgrade of existing renewable electricity generation activities.”

The submitter supports Policy 9.2 with an amendment as follows. “9.2 To ensure that new renewable electricity generation activities are located, designed, constructed and operated to avoid, remedy or mitigate significant adverse effects that are more than minor on the rural environment and outstanding natural features and landscapes.”

The submitter supports the Explanation for Objective 9 with amendments, as follow: “Explanation This objective and associated policies recognise that renewable electricity generation activities (particularly Wind Farms and other major structures)s have the potential to cause significant adverse effects on the environment, particularly in terms of landscape character and environmental qualities, noise and traffic, views and rural amenity values. The potential for adverse effects to be generated and the inability of some renewable electricity generation activities like Wind Farms to be able to internalise or substantially mitigate some of those effects, means that such activities may be inappropriate in some rural locations. The District Plan acknowledges that in most cases renewable electricity generation activities (particularly Wind farms and other major structures) are most appropriately located in the Rural Zone. This I due to the presence of natural and physical resources, operational requirements and where the activity is less likely to impact on more sensitive activities such as residential housing. However, the location of Wind Farms in the Rural Zone can have the potential to cause adverse effects on the environment, particularly in terms of landscape character and environmental qualities, noise and traffic, views and rural amenity values.

For this reason, Tthe District Plan seeks to manage any potential adverse effects and provides for new Wind Farms as a Discretionary Activity and changes/upgrades to existing wind farms as Restricted Discretionary Activities within the Rural Zone. The Discretionary Activity consent category allows Council to either decline a resource consent application, or grant consent and impose conditions in order to avoid, remedy or mitigate adverse effects on the environment. The Discretionary Activity rule includes specific assessment criteria to guide Council’s consideration of applications for a Wind Farm and they will be subject to a full and rigorous assessment.


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Wind Farms that do not meet the Performance Standard will be considered as Non-Complying Activities.”

The submitter supports Rule 9.5.1 (activities) with the addition of the following activity: (f) The operation, maintenance and minor upgrading of existing Wind Farms. For the purpose of Rule 9.5.1 the operation, maintenance and minor upgrading of existing Wind Farms means carrying out repairs and maintenance works to turbines and associated infrastructure which is of a similar sale, intensity and character, and is necessary to meet on-going operational requirements. Maintenance and minor upgrading works includes but is not restricted to turbine and blade replacement, on-going access, monitoring and control systems, refitting, wind monitoring and site security.

The submitter supports Rule 9.5.5 Performance Standard (b) (i) (c) with an amendment, as follows. “(i) No residential building may be located not less than:

(a) 10 metres from a front boundary; (b) 5 metres from any other boundary. (c) 1.5 km from the location of any existing wind turbine or any wind turbine on a site for which a Wind Farm resource consent application has been granted.”

The submitter supports Rule 9.6.2 Relocated Dwellings Performance Standards with the addition of a new Performance Standard (iv), as follows.

“(vi) Separation Distance No new dependant dwelling unit may be located less than 1.5km from the location of any existing wind turbine or any wind turbine on a site for which a Wind Farm resource consent has been granted.”

The submitter opposes in part Section 9.6 Controlled Activities and submits that a new Controlled Activity Rule is inserted for Repowering of Existing Wind Farms, as follows.

“R 9.6.5 Repowering of Existing Wind Farms

Repowering of existing wind farms are a controlled Activity, with regard to: • On-site location of structures and separation distances • Landscape and visual effects • Construction noise effects • Earthworks effects • Effects on aviation, navigation and existing network utilities

For the purposes of Rule 9.6.5, Repowering means the replacement if turbines have reached the end of their economic life with update turbine technology to continue to make best use of the available energy resource.


In determining what conditions if any to impose, Council will, in addition to the City View objectives in section 2 and the Rural Zone objectives and policies, assess any application in terms of the following assessment criteria:.

Assessment Criteria

a) The mitigation of potential landscape and visual impacts b) To avoid, remedy or mitigate the effects of construction traffic on the roading network c) To avoid, remedy or mitigate the effects of construction noise on amenity values. d) To avoid, remedy or mitigate the effects on aviation, navigation and exiting network utilities.

Explanation

The District Plan recognises that established Wind farms in the Rural Zone will require ongoing maintenance as part of day to day operation. From time to time existing wind turbines may be repowered which may result in new or relocated infrastructure.

This rule gives effect to section 7 (j) of the RMA which requires Council to have particular regard to the benefits derived from the use and development of renewable energy and the National Policy Statement for Renewable Electricity Generation which directs


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that District Plans have particular regard to the logistical or technical practicalities associated with developing, upgrading, operating or maintaining renewable energy generation activities.”

The submitter supports Rule 9.8.6 – Wind Farms with an amendment, as follows. “R 9.8.6 New Wind Farms New Wind Farms are Discretionary Activities. New Wind Farms under Rule 9.8.6 must comply with the following Performance Standards: …”

The submitter supports Rule 9.8.6 – Wind Farms Performance Standard (i), with amendments as follows.

(i) The new Wind Farm site must not be inside the Tararua Ranges Landscape Protection Area (Map 9.1).”

The submitter supports Rule 9.8.6 – Wind Farms Performance Standard (ii), with the following amendment: “(ii) The new Wind Farm must not be located within 700 m of the boundary of the Wind Farm site with an adjacent property, unless

the application is lodged with a consent form signed by the owner orf occupier of the adjacent property.”

The submitter supports in part Rule 9.8.6 – Wind Farms Assessment Criteria (g) and submits that Assessment Criteria (g) be amended to better explain what is meant by “safeguards and contingencies”.

The submitter supports Rule 9.8.6 – Wind Farms Assessment Criteria (h) with amendments, as follows. “(h) The appropriate management mitigation of potential landscape and visual impacts, including the location, design, appearance

and concentration of structures on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline, significant amenity landscapes in the Tararua foothills, rural character and visibility from neighbouring residences and public places.”

The submitter supports Rule 9.8.6 – Wind Farms Assessment Criteria (i), with amendment as follows.

(i) The cumulative visual effects of the proposal and consented Wind Farms (including a consideration of the relationship between the various Wind Farms), with particular regard to the effects of additional turbines on views of the Tararua Skyline. along its entire length and potential for visual saturation of the skyline landscape with Wind Farm turbines extending across the full extent of the Tararua Ranges.”

The submitter requests the following: 1. That full effect is given to the NPSREG, and that there are no conflict between plan provisions and the NPSREG. 2. That a more robust policy framework is adopted to protect existing Wind Farm Site from reverse sensitivity and other activity effects. 3. That provision for the on-going maintenance, upgrading and development of Wind Farms and associated infrastructure is made. 4. Better recognition of existing Wind Farms in the Tararua Ranges. Decisions Requested:

1. That the definition for Renewable Energy Generation Activities/Facilities in Section 4 Definitions is deleted and replaced with the following wording: “Renewable Energy Generation Activities/Facilities means electricity generation activities or facilities that utilise renewable energy resources, including activities or facilities where electricity is generated from wind, solar, hydro, geothermal, and biomass energy sources. Has the same meaning as defined by the National Policy Statement for Renewable Electricity Generation 2011. “

2. That the Definition for Wind Farm in Section 4 Definitions is amended, as follows: “Wind Farm means turbines other than a Domestic Wind Turbine used to generate energy from the wind, and includes:

• Turbines, including support pylons or towers that support turbines • ancillary buildings and structures on the Wind Farm Site such as substations, maintenance buildings and communication

equipment • Community-scale wind farms.

A Wind Farm excludes transmission lines and associated infrastructure associated with transmission lines external to the Wind Farm.”

3. That the (o) Special Information Requirements for Wind Farms, specifically relating to (iii) Social Impact Assessment Report is deleted.


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4. That the 6th paragraph of 9.1 Introduction is amended, as follows:

“Network utility operations and renewable electricity generation facilities and activities are also located in the rural environment, often due to their operational requirements and the location of natural and physical resources in the District. Likewise, Ddevelopment in close proximity to network utilities requires careful management…”

5. That Resource Management Issue 1 is amended as follows: “The effects of urban growth and the possible intrusion of urban development into rural areas, resulting in the loss of productive land, and disruption to rural communities and the need for further network infrastructure.”

6. Amend Resource Management Issue 13 to read: 13. “The need to recognise and provide for the significant benefits of existing and future renewable energy generation activities and associated infrastructure (at commercial and domestic scales), whilst avoiding, remedying or mitigating adverse effects.”

7. Delete Resource Management Issue 15.

8. Amend Resource Management Issue 16 to read: 16. The Tararua Ranges are a significant wind energy resource for renewable electricity generation and the development of Wind Farms in this area has the potential to limit the use and development of rural land in close vicinity for should be balanced against the demands on rural land for rural residential development.”

9. Amend Resource Management Issue 18 to read: “18. The need to avoid Inappropriate use and development has the potential for significant adverse cumulative effects on the values and characteristics of the Tararua Ranges and the Manawatu Gorge regionally Outstanding Natural Features and Landscapes.”

10. That Policy 1.3 of Objective 1 is amended as follows: “1.3 To ensure that the urban conversion of the land proceeds in an orderly manner and that existing rural activities, including windfarms, are not adversely affected by the introduction of more sensitive activities in the rural environment.”

11. That the proposed new 2nd paragraph of the Explanation for Objective 1 is amended as follows:

“… Unrestricted rural residential development within the Rural Zone would have significant adverse effects on primary production activities, rural character, landscape and amenity, and existing network utility infrastructure and renewable electricity generation facilities (including maintenance and upgrading work). It may also place restrictions on the introduction of new network utilities and other infrastructure that may be required in the future. To avoid sporadic rural residential subdivision and development and protect the productive capability of the City’s versatile Class 1 and 2 soils and rural based infrastructure, the Plan identifies specific locations where rural residential activities can be suitably accommodated, (refer to the Planning Maps). The Plan intentionally directs rural residential development away from the City’s versatile soils, and is consistent with the Council’s Rural Residential Land Use Strategy, which seeks to see high quality rural land within the City retained for productive purposes.”

12. That the 1st paragraph of the Explanation for Objective 2 (and related policies) is amended, as follows: “It is important that rural land continues to be used in a way which ensures that the productive potential of the land can be maintained, and that other existing activities can continue to operate s in a sustainable manner. However, the wide range of activities which occur in the rural area can sometimes produce a range of adverse effects which must be addressed if there are not to be negative effects on the rural environment….”

13. That Objective 3 be amended as follows: “Objective 3 To enhance maintain the quality and natural character of the rural environment.”

14. That proposed Policy 3.5 is deleted in its entirety.


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15. That Objective 4 is amended as follows: “Objective 4 To recognise and enhance the diversity of the rural community by encouraging a range of activities that are compatible with, or are required to locate in, the rural environment.”

16. That proposed Policy 4.3 is amended as follows: “4.3 To allow a range of other activities where their adverse effects can be avoided, remedied or mitigated.”

17. That the Explanation for Objective 4, is amended as follows: “While much of the rural area is devoted to large scale rural land uses such as farming and forestry, there are a wide variety of other activities which rely on natural and physical resources in rural areas and contribute to the maintenance of land and the diversity of the rural community. These other activities include Wind Farms, small engineering works, schools, community halls, recreational activities, home occupations, veterinary clinics, animal boarding establishments, nurseries, roadside stalls, and garden centres. While tThese activities are valuable parts of the rural community, and which often also serveing not only local communities urban communities but in some cases contribute to services on a regional or national scale. it is important that there are controls over any adverse environmental effects which they may produce. However, The existence of these activities also helps to make the rural community a sustainable community, in that services are offered in close proximity thereby reducing travel costs and time.it avoids extended energy inefficient journeys to use the business, recreational and leisure facilities which are provided in the urban area. However, it is important that there are controls over any adverse effects which they may produce.”

18. That proposed Policy 7.2 is amended as follows: “7.2 To control manage new land use and development within the Tararua Ranges Landscape Protection Area (Map 9.1) to protect so that the characteristics and values of the Tararua Ranges and the Manawatu Gorge Outstanding Natural Features and Landscapes are maintained.”

19. That a new Policy 7.3 be inserted and proposed Policy 7.3 (to be re-numbered 7.4) is amended, as follows: 7.3 To recognise the presence of existing land use activities and development within the Tararua Ranges Landscape Protection Area and manage any adverse effects that may arise from their continued operation, maintenance and upgrade.

7.34 To avoid control new subdivision, land use and further development of renewable energy generation activities and other major structures that may have the potential to cause significant adverse cumulative effects on the Tararua Ranges Landscape Protection Area (Map 9.1).

20. That the proposed Explanation for Objective 7 and Policies be amended, as follows: “Explanation Landscapes are an important issue for the City as they provide identity and a sense of place. The Tararua Ranges is the most significant and highly visible landscape within the City, and is subject to development pressure from many rural based activities, but particularly from Wind Farm developments.

Council is required to recognise and provide for the protection of Outstanding Natural Features and Landscapes from inappropriate subdivision, use and development, as a matter of national importance (s 6(b) of the RMA).

The Tararua Ranges and the Manawatu Gorge are identified in the Manawatu-Wanganui Regional Council’s One Plan as regionally Outstanding Natural Features and Landscapes, having characteristics, values and qualities which warrant their protection and appropriate management. A full description of these regionally Outstanding Natural Features and Landscapes and the underpinning evaluation, using the criteria established in the One Plan (Schedule F), is provided in the report entitled Landscape Management Strategy Palmerston North.

This objective and associated policies gives effect to the RMA and higher order planning instruments by giving explicit recognition to the landscape significance of the Tararua Ranges and the Manawatu Gorges within the District Plan.

The visual and landscape values of the Tararua Ranges Landscape Protection Area is afforded the highest level of landscape protection within the District Plan and this provides the basis for regulating the effects of new development. In cases where development and land use activities are already established within the Tararua Ranges Landscape Protection Area, the District


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Plan anticipates that there will be times when maintenance and upgrading of facilities, building and infrastructure will be required and depending on the scale of the work involved will assess such works as part of a restricted discretionary resource consent process.

The District Plan anticipates that new Aactivities like renewable energy developments which may wish to establish in the Tararua Ranges Landscape Protection Area and could result in changes to the characteristics and values of these regionally Outstanding Natural Features and Landscapes. In such cases, Council will require a rigorous assessment through a restricted discretionary resource consent process.

The District Plan provides for Wind Farms as a Discretionary Activity within the Rural Zone, provided they are located outside of the Tararua Ranges Landscape Protection Area, shown on Map 9.1 and comply with a 700 m separation distance from adjacent boundaries with properties that do not form part of a Wind Farm site.”

21. That proposed Objective 8 be amended to read as follows: “Objective 8 To recognise the local, regional and national benefits of renewable energy development and the importance of the City’s renewable energy resources to long term sustainability.”

22. That proposed Policy 8.1 be amended as follows: “8.1 To provide for the investigation, development, operation, maintenance and upgrade of appropriate new and existing renewable energy generation activities.”

23. That proposed Policy 8.2 be amended as follows: “8.2 To protect existing and consented renewable electricity generation activities from reverse sensitivity effects arising from the establishment of noise sensitive activities in close proximity.”

24. That the proposed Explanation for Objective 8 and Policies is amended, as follows: “Explanation The benefits of renewable energy developments are considerable. As a clean fuel source, Wind Farms do not rely on fossil fuels to operate and do not generate greenhouse gases or other pollutants. They are sustainable and cost efficient. In New Zealand the demand for energy continues to grow and the contribution of renewable electricity generation in meeting that demand is notable. Development that increases renewable electricity generation capacity have positive environmental effects that span locally, regionally and nationally.

Council is required to have particular regard to the benefits to be derived from the use and development of renewable energy under section 7(j) of the RMA.

In addition and as a matter of national importance, Council must also give effect to the National Policy Statement for Renewable Electricity Generation Activities (NPSREG) which sets out an objective and policies to enable the sustainable management of renewable electricity generation.

Provision is made in the Manawatu-Wanganui Regional Council’s One Plan which requires that the District Plan have regard to the benefits of infrastructure (including their establishment, operation, maintenance and upgrading) as a matter of national importance and also increases the use of renewable energy in the region.

This objective and associated policies recognise the national significance of the development and maintenance of renewable energy resources under the RMA and gives effect to the National Policy Statement for Renewable Electricity Generation Activities (NPS REG). In giving effect to the NPS REG, the District Plan rules address renewable energy resources to the extent that they are applicable in the Rural Zone – namely wind and solar. Policy 8.4 recognises the City’s wind energy resource and the locational, logistical and technical practicalities of developing renewable electricity generation activities, consistent with Policies B and C1 of the NPS REG. are significant regional infrastructure).

This objective and polices also implements the Manawatu-Wanganui Regional Council’s One Plan, which identifies renewable energy generation activities as significant regional infrastructure and facilitates the appropriate upgrade of existing renewable electricity generation activities.”


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25. That proposed Policy 9.2 be amended as follows: “9.2 To ensure that new renewable electricity generation activities are located, designed, constructed and operated to avoid, remedy or mitigate significant adverse effects that are more than minor on the rural environment and outstanding natural features and landscapes.”

26. That the proposed Explanation for Objective 9 be amended as follows: “Explanation This objective and associated policies recognise that renewable electricity generation activities (particularly Wind Farms and other major structures)s have the potential to cause significant adverse effects on the environment, particularly in terms of landscape character and environmental qualities, noise and traffic, views and rural amenity values. The potential for adverse effects to be generated and the inability of some renewable electricity generation activities like Wind Farms to be able to internalise or substantially mitigate some of those effects, means that such activities may be inappropriate in some rural locations.

The District Plan acknowledges that in most cases renewable electricity generation activities (particularly Wind farms and other major structures) are most appropriately located in the Rural Zone. This I due to the presence of natural and physical resources, operational requirements and where the activity is less likely to impact on more sensitive activities such as residential housing. However, the location of Wind Farms in the Rural Zone can have the potential to cause adverse effects on the environment, particularly in terms of landscape character and environmental qualities, noise and traffic, views and rural amenity values.

For this reason, Tthe District Plan seeks to manage any potential adverse effects and provides for new Wind Farms as a Discretionary Activity and changes/upgrades to existing wind farms as Restricted Discretionary Activities within the Rural Zone. The Discretionary Activity consent category allows Council to either decline a resource consent application, or grant consent and impose conditions in order to avoid, remedy or mitigate adverse effects on the environment. The Discretionary Activity rule includes specific assessment criteria to guide Council’s consideration of applications for a Wind Farm and they will be subject to a full and rigorous assessment.

Wind Farms that do not meet the Performance Standard will be considered as Non-Complying Activities.”

27. That permitted activity Rule 9.5.1 be amended to insert the following activity: “(f) The operation, maintenance and minor upgrading of existing Wind Farms. For the purpose of Rule 9.5.1 the operation, maintenance and minor upgrading of existing Wind Farms means carrying out repairs and maintenance works to turbines and associated infrastructure which is of a similar sale, intensity and character, and is necessary to meet on-going operational requirements. Maintenance and minor upgrading works includes but is not restricted to turbine and blade replacement, on-going access, monitoring and control systems, refitting, wind monitoring and site security.”

28. That Rule 9.5.5 (b) (i) (c) be amended as follows: “(i) No residential building may be located not less than:

(a) 10 metres from a front boundary; (b) 5 metres from any other boundary. (c) 1.5 km from the location of any existing wind turbine or any wind turbine on a site for which a Wind Farm resource consent application has been granted.”

29. That a new Performance Standard (vii) be inserted under Rule 9.6.2 as follows: “(vi) Separation Distance No new dependant dwelling unit may be located less than 1.5km from the location of any existing wind turbine or any wind turbine on a site for which a Wind Farm resource consent has been granted.”

30. That a new Controlled Activity Rule 9.6.5 is inserted as follows: “R 9.6.5 Repowering of Existing Wind Farms

Repowering of existing wind farms are a controlled Activity, with regard to: • On-site location of structures and separation distances • Landscape and visual effects • Construction noise effects • Earthworks effects


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• Effects on aviation, navigation and existing network utilities

For the purposes of Rule 9.6.5, Repowering means the replacement if turbines have reached the end of their economic life with update turbine technology to continue to make best use of the available energy resource.


In determining what conditions if any to impose, Council will, in addition to the City View objectives in section 2 and the Rural Zone objectives and policies, assess any application in terms of the following assessment criteria:.

Assessment Criteria

a) The mitigation of potential landscape and visual impacts b) To avoid, remedy or mitigate the effects of construction traffic on the roading network c) To avoid, remedy or mitigate the effects of construction noise on amenity values. d) To avoid, remedy or mitigate the effects on aviation, navigation and exiting network utilities.

Explanation

The District Plan recognises that established Wind farms in the Rural Zone will require ongoing maintenance as part of day to day operation. From time to time existing wind turbines may be repowered which may result in new or relocated infrastructure.

This rule gives effect to section 7 (j) of the RMA which requires Council to have particular regard to the benefits derived from the use and development of renewable energy and the National Policy Statement for Renewable Electricity Generation which directs that District Plans have particular regard to the logistical or technical practicalities associated with developing, upgrading, operating or maintaining renewable energy generation activities.”

31. That proposed Rule R 9.8.6 be amended as follows: “R 9.8.6 New Wind Farms New Wind Farms are Discretionary Activities. New Wind Farms under Rule 9.8.6 must comply with the following Performance Standards: …”

32. That Rule 9.8.6 Performance Standard (i) be amended as follows: “(i)The new Wind Farm site must not be inside the Tararua Ranges Landscape Protection Area (Map 9.1).”

33. That Rule 9.8.6 Performance Standard (ii) be amended as follows: “(ii)The new Wind Farm must not be located within 700 m of the boundary of the Wind Farm site with an adjacent property, unless the application is lodged with a consent form signed by the owner orf occupier of the adjacent property.”

34. That Rule 9.8.6 Assessment Criteria (g) be amended to better explain what is meant by “safeguards and contingencies”. 35. That Rule 9.8.6 Assessment Criteria (h) be amended as follows:

“(h) The appropriate management mitigation of potential landscape and visual impacts, including the location, design, appearance and concentration of structures on the values and characteristics of the Tararua Ranges Landscape Protection Area and views of the Tararua Skyline, significant amenity landscapes in the Tararua foothills, rural character and visibility from neighbouring residences and public places.”

36. That the plan provisions are amended to ensure the following points are achieved. 1. That full effect is given to the NPSREG, and that there are no conflict between plan provisions and the NPSREG. 2. That a more robust policy framework is adopted to protect existing Wind Farm Site from reverse sensitivity and other activity effects. 3. That provision for the on-going maintenance, upgrading and development of Wind Farms and associated infrastructure is made. 4. Better recognition of existing Wind Farms in the Tararua Ranges.


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37. That any other relief, including additions, deletions or consequential amendments necessary as a result of the matters raised in this submission are adopted.

Submission Number

Plan Change Number


SO46 15A-H 15A 15C 15D 15G

S4 Definitions S6 General S7 Subdivision S9 Rural Zone S22 Natural Hazards S23 Utilities S24 Designations

Transpower New Zealand Limited

Rhedyn Law C/- RMG, PO Box 10170 The Terrace WELLINGTON 6143

YES

Submission: The submitter supports the general intent of PPCA-H insofar as it aims to implement the National Policy Statement for Electricity Transmission and Regional Policy Statement. Some refinements are considered necessary to ensure the NPSET and RPS are implemented successfully. The submitter supports the rolling over of the Bunnythorpe substation designation 101 into Table 1 Schedule of designations. The submitter supports in part non-habitable structures on production land being a permitted activity under R22.8.1.1(i). The submitter suggests the removal of reference to production land because some of the relevant land of their interest to the submitter may not be classified as production land.


1. That PPC15A-H gives full effect to the National policy Statement for Electricity Transmission 2008. 2. That PPC15A-H gives effect to the Horizons Regional Policy Statement as it relates to the management of effects on the effective

operation, maintenance and development of the National Grid. 3. That PPC15A-H protects the National Grid from adverse effects (including reverse sensitivity) of subdivision, land use and

development in proximity ton electricity transmission infrastructure. 4. S4: Amend S4 definition for Line, as follows:

Has the same meaning as defined in Section 5 of the Telecommunications Act 2001 and includesor the definition of ‘line’ in section 2 of the Electricity Act 1992.

5. S4: Amend S4 definition for Mast, as follows: means any mast, pole, tower or similar structure designed to carry aerials or antennae dishes to facilitate radiocommunication, telecommunication, electricity transmission and wind resource investigation and meteorological monitoring.

6. S4: Amend S4 definition for Minor Upgrading, as follows: means, in respect of network utilities, an increase in the carrying capacity, efficiency or security of electricity and associated telecommunications lines, utilising the existing or replacement support structures or structures of a similar scale, intensity and character, and includes: (i) the addition of circuits and conductors; (ii) the reconductoring of the line with higher capacity conductors; … (vi) the bonding of conductors; … (viii) support structure replacement within the same location as the support structure that is to be replaced including tower replacement or within the existing alignment of the transmission line National Grid corridor or pole replacement in adjacent footings; … Minor upgrading shall not include: (i) any increase in the voltage of the line unless the line was originally constructed to operate at the higher voltage but has been operating at a reduced voltage; or (ii) any increase in any individual wire, cable, or other similar conductor to a diameter that exceeds 35mm; or the bundling together ror any wire, cable, or other similar conductor so that the bundle exceeds 43mm in diameter; or (iii) the addition of any new circuits, lines or utility structures where this results in an increase in the number of new lines or utility structures. Note: The Resource Management (National Environmental Standards for Electricity Transmission Activities) Regulations 2009 applies to all existing National Grid Transmission Lines that were operational, or able to be operated, on 14 January 2010

7. S4: Amend the S4 definition of National Grid, as follows:


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The assets used or owned by Transpower NZ Limited as defined in the National Policy Statement on Electricity Transmission 2008 and includes transmission lines and cables, stations and sub stations and other works used to connect grid injection points and grid exit points to convey electricity throughout the North and South Islands of New Zealand.

8. S4: Amend the S4 definition of National Grid Yard, as follows: means: The area located 12 metres in any direction from the outer edge of a National Grid support structure; and The area located 10 metres either side of the centreline of an overhead 110kV National Grid line on single poles; or The area located 12 metres either side of the centreline of any overhead National Grid line on pi poles or towers….

9. S4: Amend S4 definition of Sensitive Activities (National Grid), as follows: For the purposes of Rule 23.9.2 and Rule 23.11.1 means the following activities around the National Grid high voltage transmission lines: community houses, dwellings and dwelling units, early childhood facilities, residential centres, retirement villages, schools and hospitals.

10. S6.3 Policy 1.2: An amendment to S6 Policy 1.2, as follows: 1.2 To avoid, remedy, or mitigate any adverse effects on the environment from earthworks on:

• Natural Land Form; • Landscape Values; • Visual Amenity Values; • Adjoining Properties; • Natural Hazards and Processes • Effects on the National Grid

11. S6.3: That S6 be amended to include a new Policy 1.3 and explanation, as follows:

1.3 To manage earthworks activities so that: a. adverse effects of earthworks on the National Grid are avoided; and b. the operation, maintenance, upgrading and development of the National Grid is not compromised by earthworks

Explanation The objective and policies take the approach that earthworks are often essential as part of land development. However, earthworks activity may also result in a range of adverse effects. The objective and policies identify that earthworks should be limited where potential exists for adverse effects to occur, to enable consideration of the relevant matters. The National Policy Statement on Electricity Transmission sets out matters which must be given effect to by the District Plan. Among other matters, this includes the need to manage adverse effects of activities (such as earthworks) on the ongoing operation, maintenance, upgrading and development of the National Grid.

12. R6.3.6.1(e): Introduce an additional performance standard under R6.3.6.1(e), as follows: (iii) not compromise the stability of any National Grid support structure.

13. R6.3.6.1: Make an amendment to the explanation for R6.3.6.1, as follows: … National Grid – earthworks near the National Grid lines can cause risks to people nearby, and or damage the lines. Earthworks near transmission line support structures can compromise the structural integrity of overhead National Grid lines. Maintaining a 12m setback from the support structures maintains a physical area to enable operation, maintenance, upgrade and development activities to occur, as required by Policy 10 of the National Policy Statement on Electricity Transmission.

14. R6.3.6.2: Insert an exemption clause related to R6.3.6.1(e) to R6.3.6.2 Exclusions from Earthworks Rule 6.3.6.1, as follows: R 6.3.6.2 Exclusions from Earthworks Rule 6.3.6.1 Earthworks associated with the following activities shall be exempted, except as specified in (vii) below, from the requirements of R6.3.6.1 of this Plan: (i) Earthworks associated with the maintenance of farm tracks, fences and fence lines, the cultivation of land, harvesting of crops, and the clearing of drains as part of Horticultural and Agricultural activities on production land. … (iv) With respect to Rule 6.3.6.1(a)(ii) and Rule 6.3.6.1(b)(ii) only, earthworks as part of foundations for a dwelling or a swimming pool are exempted from the 1.5 height restriction. This exemption applies only to a cut made below the existing ground level, and for a distance of 2m surrounding the foundation (when measured in plan view). Exemptions from R 6.3.6.1 (e) (vii) With respect to R 6.3.6.1(e)(i) only, the following exemptions apply:


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(i) vertical holes not exceeding 500mm in diameter provided the holes are: a. at least 1.5m from the outer edge of a National Grid pole support structure or stay wire; or b. are a post hole for a farm fence or horticultural structure and are more than 5m from the visible outer edge of a National Grid tower support structure foundation

(ii) Earthworks for a network Utility within a transport corridor, as part of a transmission activity, for electricity infrastructure, or for commercial scale electricity generation. (iii) Earthworks undertaken as part of agricultural or domestic cultivation, or repair, sealing, or resealing of a road, footpath, driveway or farm track. (iv) Earthworks associated with the maintenance of farm tracks, the cultivation of land, harvesting of crops, and the clearing of drains as part of Horticultural and Agricultural activities on production land; (v) Earthworks undertaken as part of the repair, sealing or resealing of a road, footpath, or driveway.

15. R6.3.8.1: Make a minor amendment to R6.3.8.1 to fix a clerical error and to give reference to proposed performance standard in R6.3.6.1 (e)(iii), as follows: R 6.3.78.1 Non-Complying Activities Any earthworks that do not comply with the Permitted Activity Performance Condition R 6.3.6.1 (e)(ii) or Condition R 6.3.6.1 (e)(iii) shall be Non-Complying Activities.

16. S7.1 Introduction: Make an amendment to the list of the effects of subdivision in S7.1 Introduction, as follows: The effects of subdivision include: The loss of productive land through urbanisation and inappropriate rural development …. Effects on the safe and efficient functioning operation, maintenance, upgrading and development of network utilities, such as the National Grid. …

17. S7.2: Amend the explanation to S7 Resource Management Issue 1, as follows: Explanation The RMA mandates Council to incorporate provisions in District Plans to assist in achieving sustainable land use and to avoid, remedy or mitigate the adverse effects of use, development on natural and physical resources land, including the protection of land. … As subdivision provides a framework for development, the District Plan subdivision controls, need to have regard to:

• Retaining the productive capability of land and soil resources; … • The need to manage the adverse effects of new subdivision, use and development on the safe and efficient operation,

maintenance, upgrading and development of the National Grid.

18. S7.3: Amend S7.3 to include a new Policy 2.12, as follows: 2.12 To manage the effects of subdivision on the safe, effective and efficient operation, maintenance, upgrading and development of the national Grid by ensuring that: 1. National Grid Yards and National Grid Corridors are identified in the Plan to establish safe buffer distances for managing subdivision and land use development near electricity transmission lines and support structures; 2. sensitive activities and large-scale structures are excluded from establishing within National Grid Yards; 3. subdivision is managed within National Grid Corridors to avoid subsequent land use from restricting the operation, maintenance, upgrading and development of the National Grid; and 4. changes to existing activities within a National Grid Corridor or National Grid Yard do not further restrict the operation, maintenance, upgrading and development of the National Grid.

19. S7.3: Amend the methods statement to reflect the proposed new Policy 2.12 in S7, as follows: Objective 2 and Policies 2.1 to 2.12 Policies 2.1 to 2.12 which have been derived from Objective 2…. …. 2.1 to 2.10 and the Council will have regard to its contents when imposing conditions on subdivision consents. Policy 2.12 gives effect to the National Policy Statement on Electricity Transmission. The policy is implemented through rules and other methods that manage subdivision proposals in proximity to the National Grid. Collectively, those methods provide for the efficient use of land within the identified National Grid Corridors without enabling sensitive activities or structures that would inhibit the operation, maintenance upgrade or development of transmission lines or support structures and access to these National Grid assets.


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20. S7.6: Make a consequential amendment to the Environmental Results Anticipated in S7.6, as follows:

7. Adverse effects from subdivision and associated development on the National Grid will be avoided and the operation, maintenance, upgrading, and development of the electricity transmission network is not compromised.

21. R7.17.1.2: Minor amendments to R7.17.1.2, as follows: R 7.17.1.2 Any Subdivision Within the National Grid Subdivision Corridor Any Subdivision within the National Grid Subdivision Corridor identified on the Planning Maps shall be a Restricted Discretionary Activity… … Note to Plan user: 1. In addition to the above…. 2. In order to establish safe… 3. Rules relating to earthworks activities within the National Grid Yard are set out in Section 6 – General (Earthworks) of the District Plan, and the National Grid Subdivision Corridor is defined in Section 4 – Definitions.

22. R7.17.1.2: Minor amendment to R7.17.2.1, as follows: R7.17.2.1 Any Subdivision that Does Not Comply with Performance Standard (a) of R7.17.1.2, shall be a Non-Complying Activity

23. R22.8.1.1(i): That R22.8.1.1(i) be amended as follows: (i) Non-habitable structures on production land.

24. S24 Table 1: That the Bunnythorpe substation be retained without modification as designation 101 under S24 Table 1 Schedule of Designations.

25. R23.7.3, R23.9.2 and 23.11.2: That rules related to managing buildings in close proximity to the National Grid (R23.7.3, R23.9.2 and 23.11.2) be located within zone-based Chapters, rather than just the Utilities Section. If this relief is not granted, it is requested a note or other cross reference to relevant Utilities Rules should be inserted into relevant zone-based Chapters.

26. Amend section 23.1 Introduction, as follows:

This section of the District Plan contains the provisions that relate to network utilities and associated infrastructure within Palmerston North City and include water supply and distribution systems, irrigation systems, sewerage and trade waste reticulation and treatment systems, stormwater drainage systems, telecommunication and radiocommunication networks, and theelectricity linestransmission network, and natural gas high pressure transmission and reticulation networks. … With respect to activities related to the transmission of electricity, the Council is required to give effect the Resource Management (National Policy Statement on Electricity Transmission) Regulations (NPSET) which came into force was gazetted in 2008. It applies to activities associated with the establishment, operation, maintenance and upgrade of the National Grid. The overarching objective of the NPSET is to… The Council is also required to give effect have regard to the Resource Management (National Environmental Standard for Electricity Transmission Activities)Regulations 2009 (NESTA), which sets out the controls for an activity that relates to the operation, maintenance, upgrading, relocation, or removal of an existing electricity line. The rules make explicit reference to those circumstances in which the NESETA overrides the provisions of the District Plan, and also indicates, where applicable, which regulations of the NESETA should be referred to. Both the NPSET and NESETA apply to the assets owned or operated by Transpower New Zealand Limited only. … It is also important to recognise that due to technical or operational constraints it is not always possible to avoid, remedy or mitigate the adverse effects associated with the establishment, operation or maintenance of linear infrastructure. In these some instances, adverse effects can often best be mitigated through the route and site selection process. The Plan includes provisions to manage adverse effects resulting from the establishment, operation, maintenance, and upgrade and development of network utilities and associated infrastructure, as well as providing a means to recognise and acknowledge the benefits that network utilities have. This section of the Plan applies to Network Utility Operators who do not wish, or are unable, to operate undermake use of the designation procedures under the RMA. The provisions may, however, also be used by Council to help assess any notices of requirement for new designations in conjunction with Section 24 – Designations. Network utilities are often lineal and traverse many parts of the City, and often across multiple zones. For this reason, the provisions in this section apply to network utilities throughout all zones of the city. Rules from other sections of the Plan do not


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apply to network utilities managed in this section, unless stated otherwise.

27. S23.2: Amend S23 Resource Management Issue 3, as follows: 3. The operation, maintenance, andupgrade and development of regionally or nationally importantsignificant network utility structures or activities can be adversely affected by the inappropriate location or intensification of activities that are sensitive to their effects.

28. S23.3: Amend S23 Objective 1 and Policy 1.1, as follows: Objective 1 To recognise the benefits of network utilities of regional or national importancesignificance to social and economic well-being by providing for the establishment, operation, maintenance, and upgrading and development of existing network utilities of regional or national importancesignificance. Policies 1.1 To recognise the following as regionally or nationally importancesignificant network utilities within the City:

i. Facilities for the generation of more than 1MW of electricity… ii. The National Grid; and iii. The electricity distribution and transmission…

29. S23.3: Amend S23 Objective 2 and Policies 2.1, 2.2 and 2.3, as follows: Objective 2 To provide for the operation, maintenance and, upgrading and development of existing network utilities of regional or national importance and the establishment of new regionally or nationally important network utilities. Policies 2.1 To permit the operation, maintenance and, upgrading and development of existing regionally or nationally important network utilities where such works or activities can be carried out without significantly changing the character, intensity or scale of the adverse effects associated with them. 2.2 To enable the operation, maintenance and upgrading of existing regionally or nationally important network utilities and the establishment of new regionally or nationally important network utilities, provided that the adverse effects are avoided, remedied or mitigated, to the extent practicable having regard to… 2.3 to avoid, or as appropriate remedy or mitigate as far as reasonably possible, the potential for any reverse sensitivity effects on regionally or nationally important network utilities from incompatible new subdivision, use or development occurring under, over or adjacent to regionally or nationally important network utilities.

30. S23.3: Insert a new Policy 2.5 to S23, as follows: 2.5 To notify owners or managers of network utilities of regional or national importance of consent applications that may adversely affect the resources they own or manage.

31. S23.3: Amend S23 Policy 3.4, as follows: 3.4 To require the placement of network utilities underground unless:

• There are natural or physical features or structures, or technological andoperational and economic constraints that makes underground placement impracticable or unreasonable…

32. S23 Explanation: Amend the Explanation to the Objectives and Policies of S23, as follows:

Explanation Network utilities from an essential part of the City’s physical resource and provide for the community’s social, cultural and economic wellbeing. Failing to adequately provide for network utilities may result in the desired level of wellbeing and quality of life not being achieved in the City. … Objective 2 seeks to ensure that the operation, maintenance and upgrade of existing, and the establishment of new regionally and nationally important network utilities are provided for in the City. Policies 2.1 and 2,.2 provides for operation, maintenance and upgrade whilst managing the adverse effects of such work, within a decision-making framework that allows the national, regional and local benefits of sustainable, secure and efficient network utilities, including the National Grid, to be recognised and provided for. Some of these benefits include… The location of inappropriate new subdivision, use or development of land in proximity to existing regionally or nationally important


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network utilities has the potential to compromise the efficient operation, maintenance and upgrade of such networks and has the potential to compromise the safety of the community. This can reduce the benefits of that network utility, and adversely affect the safety and amenity values of the community… Policy 2.4 recognises the importance of the National Grid and seeks to protect the continued operation and functioning of that network. The Policy provides for the establishment of setback distances for sensitive activities new subdivision ad development in relation to the national Grid as the principle mechanism by which potential adverse effect (including reverse sensitivity effects) can be appropriately managed in order to ensure the safe, secure and efficient use and development of regionally and nationally important network utilities and the safety and amenity values of the community… …Policies 3.5 and 3.6 encourage network utility operators to employ methods that will contribute to the reduction of adverse impacts arising from the installation, establishment and operation of network on residential and visual amenity, and promote the efficient construction and installation, and on-going maintenance and upgrade of network utilities. The policies also recognise, however, that co-location is not desirable or feasible in all instances. Policy 3.7 seeks to ensure that the Council’s provisions in respect of network Utilities that cross-jurisdictional boundaries are consistent with provisions in other Districts…

33. S23: Correct typographical errors relating to the notation KV, which should be kV.

34. R23.7.1: Amend the mast height under Performance Standard (a) Height (iii) of R23.7.1 Permitted Activities so that the maximum height in Conservation and Amenity Zones is 20 metres.

35. R23.7.1: Delete Performance Standard (d) Undergrounding of Lines and Pipes under R23.7.1 Permitted Activities.

36. R23.7.1: Amend Performance Standard (i) Radiofrequency Field Exposure of Rule 23.7.1 Permitted Activities, as follows: (i) Radiofrequency Field Exposure Network utilities shall comply with the following standards: (a) Network utility that transmit radiofrequency fields or emit electromagnetic fields shall comply with the relevant New Zealand guidelines or legislation: (b) Network utilities that emit electric and magnetic fields shall comply withbe based on the International Commission on Nonionising Radiation Protection (ICNIRP) Guidelines.

37. R23.7.3: Amend R23.7.3, as follows: R 23.7.3 Activities within the National Grid Yard Within the National Grid Yard, the following activities are Permitted Activities: 1. In existing urban areas: (a) The operation, maintenance or, upgrading or development of network utilities that are also permitted activities under R 23.7.1, or are permitted by the NES for Electricity Transmission or the NES for Telecommunication Facilities; (b) Under National Grid Conductors (wires)

(i) On existing urban sites the following buildings and structures are permitted within the National Grid Yards; a. An accessory building for a sensitive activity that is under 2.5m high and 10m² in area; or b. Building alterations and additions to an existing building that do not involve an increase in the

building height or footprint; or c. A building not associated with a sensitive activity; or d. A fence less than 2.5m high; or e. Network Utilities within a transport corridor or any part of electricity infrastructure that connects to the

National Grid. (ii) All buildings or structures permitted by (a) must comply with at least one of the following conditions:

a. A minimum vertical clearance of 10m below the lowest point of the conductor associated with National Grid lines; or b. Demonstrate that safe electrical clearance distance required by NZECP34:2001 are maintained under all National Grid line operating conditions.

(c) Around National Grid support structures (i) Buildings and structures shall be at least 12m from a National Grid support structure unless it is a:

a. Network Utility within a transport corridor or any part of electricity infrastructure; or b. Fence less than 2.5m high and more than 5m from the nearest support structure.

2. In all other areas: (a) The operation, maintenance, upgrading of development of network utilities that are also permitted activities under R 23.7.1, or are permitted by the NES for Electricity Transmission or the NES for Telecommunication Facilities;


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(b) Under National Grid Conductors (wires) (i) On all sites within any part of the National Grid Yard any buildings and structures must:

a. If they are for a sensitive activity, not involve an increase in the building height or footprint where alterations and additions to existing buildings occur; or b. Be a fence less than 2.5m high; or c. Be network utilities within a transport corridor or any part of electricity infrastructure that connects to the National Grid; or d. Be an uninhabitable farm building or structure for farming activities (but not a milking/dairy shed (excluding ancillary structures), PSAS Structures, or intensive farming buildings); or e. Be an uninhabited horticultural building or structure other than a commercial greenhouse or intensive farming building.

(ii) All buildings or structures permitted by a) must comply with at least one of the following conditions: a. A minimum vertical clearance of 10m below the lowest point of the conductor associated with National Grid lines or; b. Demonstrate that safe electrical clearance distances required by NZECP34:2001 are maintained under all National Grid line operating conditions.

(c) Around National Grid support structures (i) Buildings and structures shall be at least 12m from a National Grid support structure unless it is a:

a. Network utility within a transport corridor or any part of electricity infrastructure that connects to the National Grid. b. Fence less than 2.5m in height and more than 5m from the nearest support structure. c. Horticultural structure between 8m and 12m from a single pole support structure that:

i. Meets the requirements of the NZECP34:2001 for separation distances from the conductor; ii is no more than 2.5m high; iii. is removable or temporary, to allow a clear working space 12 metres from the pole when necessary for maintenance and emergency repair purposes; and iv. Allow all weather access to the pole and a sufficient area for maintenance equipment, including a crane.

d. A horticultural structure where Transpower has given written approval in accordance with clause 2.4.1 of NZCEP34:2001 to be located within 12m of a tower or 8m of a pole support structure.

(a) The establishment of network utilities within a transport corridor, part of a transmission network or electricity infrastructure that connects to the National Grid; (b) Any agricultural or horticultural activity that is not specified as a non-complying activity in R23.11.2; (c) Any building less than 10m² Gross Floor Area and less than 2.5m high provided that it is setback at least 12m from the outer visible edge of a transmission line support structure. (d) Fences less than 2.5m in height that comply with NZECP34:2001 (e) Commercial scale electricity generation (f) Horticultural structure between 8m and 12m from a pole support structure that:

(i) Meets the requirements of the NZECP34:2001 for separation distances from the conductor; (ii) is no more than 2.5m high (iii) is removable or temporary, to allow a clear working space 12 metres from the pole when necessary for maintenance and emergency repair purposes; and (iv)Allow all weather access to the pole and a sufficient area for maintenance equipment, including a crane.

(g) A horticultural structure where Transpower has given written approval in accordance with clause 2.4.1 of NZECP23:2001 to be located within 12m of a tower or 8m of a pole support structure.

38. 23.11.2: Amend Rule 23.11.2 Activities within the National Grid Yard, as follows: R 23.11.2 Activities within the National grid Yard The following are non-complying activities within the National Grid Yard: (i) Any Building or structure, or addition to a building or structure for a sensitive activity (unless as permitted by R 23.7.3(c)); (ii) Any change of use to a sensitive activity or the establishment of a new sensitive activity; (iii) Any building or structure that does not comply with permitted activity rule R 23.7.3;


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(iv) Dairy/milking sheds or buildings (excluding associated ancillary structures) intensive farm buildings, PSA1 structures and commercial greenhouses; (v) Any Hazardous Facility 1Pseudomonas syringae pv. actinidiae (psa) is a bacterium that can result in the death of kiwifruit vines.

39. R23.12.1: Amend Rule 23.12.1 Prohibited Activities, as follows: R23.12.1 Prohibited Activities The following activities are prohibited activities: …. (ii) Any utility structure that impinges within the take-off climb surfaces or the approach surfaces for the main sealed runway (known as 07/25), transitional side surfaces or the horizontal and conical surfaces above the airport (refer to Figure 13.1).…

40. That the Planning Map Legend be amended to add a notation and label for National Grid electricity transmission lines.

41. That Planning Maps 2 and 39 be amended to display the area shown on proposed Maps 23.1 and 23.2, along with notation text directing plan users to Rule 23.9.2.

42. That further information be provided to indicate whether or not the area affected by the prohibited activities proposed by the plan

change includes the National Grid.

43. If the National Grid is included within the spatial area referred to in relief point 10 above, that the proposed prohibited activities for utility structures include an omission for National Grid structures.

Submission Number

Plan Change Number


SO47 15A S7 Subdivision S9 Rural Zone Appendix 2: Planning Maps

Heritage Estates Ltd

Amanda Coats C/- Proarch Consultants 306 Church Street PALMERSTON NORTH

YES

Submission: Plan Change 15A - The submitter opposes the Planning Maps 24 & 30 and specifically the rural zoning of Pioneer City West Ltd’s land, between No 1 Line & Pioneer Highway, as it does not give effect to Council’s documents, and is therefore not considered to give effect to sustainable management. The submission notes:

1. their Private Plan Change application (PCB) has been accepted by Council under clause 23(2)(b) Schedule 1 of the RMA 1991 & submissions on PDB are expected to be heard in the next few months.

2. Rural zoning doesn’t reflect Council’s policy documents, including Rural Residential Land Use Strategy 2012, Residential Growth Strategy 2010, Residential Growth Discussion Document 2009, PNCC Sustainable City Strategy 2010.

3. Council’s resolution of 12 October 2009 which states the Anders Road & Racecourse sites (known as City West) “be identified as the preferred locations for future residential growth in the City” and the 2011 resolution to defer the rezoning of City West area to residential zone, in favour of Whakarongo, in the wake of Canterbury earthquakes and draft geotechnical reports.

4. that the Pioneer City west site has been through a statutory consultation process and adopted by Council, and omitting to give effect to these documents through the promotion of the Plan Change, is contrary to the principles of sustainable management.

The submitter supports in part Policy 1.2 and submits that Policy 1.2 should expressly recognise the status of City West as the next growth area, now that Whakarongo has been zoned. The submitter seeks that Policy 1.2 is amended as follows:

“1.2 To avoid ensure that subdivision activity for urban purposes outside existing urban areas other than as part of the planned City West growth area. only occurs following an appropriate assessment of all environmental effects.”

The submitter supports Policy 3.5(c) with amendment. It is submitted that Policy 3.5(c) should expressly recognise the status of City West as the next growth area now that Whakarongo has been zoned. The submitter seeks the following amendment to Policy 3.5 (c):

“3.5 To enable the subdivision of rural land into small allotments for rural-residential purposes in the areas identified for that purpose on the Planning Maps, where it is demonstrated that: …


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(c) The subdivision does not compromise the Council’s urban growth plans and Strategies to provide for a growth area at City West;

…”

The submitter supports in part Policy 1.1. It is submitted that Policy 1.1 should expressly recognise the status of City West as the next growth area now that Whakarongo has been zoned, and seeks that the Policy 1.1 be amended as follows:

“1.1 To protect rural land at City West as it that has been identified in Council strategies as potentially suitable for future urban growth.”

The submitter opposes Rule 7.16.1.2.(b)(i) Performance Standards – Lot Area and submits that the 4 ha site size be reinstated. The submission notes:

- PC 15A fails to provide for subdivision into sites of under 20ha for rural sites that don’t contain, or contain only small portion, of elite (class 1 and II) soils.

- the blanket 20 ha rule is overly restrictive in terms of site size for properties where it can be demonstrated that the potential for productive use on the site is reasonably constrained.

- Submits that the 4 ha site size be reinstated for sites which contain soils that can be demonstrated as not elite.

The submitter supports in part Rule 23.7.1 Performance Standard (d ) Undergrounding of Lines or Pipes. The submitter supports the ability to be able to be underground existing lines as a permitted activity but seeks, for clarity, that Performance Standard (d) (i) be reworded as:”(i) Lines shall be buried below not be located above ground except:

The submitter support sin part Rule 6.3.6.1(e)(i). The submitter is concerned that proposed new rule 6.3.6.1(e)(i), relating to earthworks within the National Grid Yard, could preclude undergrounding of electrical lines as a Permitted Activity due to restrictions on earthworks over 300mm in depth and within 12 metres of any National Grid Support Structure. The submitter seeks an amendment to allow for the undergrounding of electrical lines within the National grid Corridor as a Permitted Activity when the consent of Transpower has been expressly given for the works.

The submitter seeks the District Plan Map Key be amended to include the Transpower high voltage power lines and in relation to the City Boundary Line.

Decisions Requested: 1. That Plan Change 15A be declined, as it does not give effect to Council’s own policy documents, and is therefore not considered to

give effect to sustainable management. In the event that the Plan Change is not declined that Pioneer City West be zoned residential, in accordance with Council resolutions. In the absence of Residential Zoning that the land that is the subject of PCB be expressly excluded from PC15 and the PC15 Plan Maps are amended accordingly.

2. Amend Policy 1.2 as follows: “1.2 To avoid ensure that subdivision activity for urban purposes outside existing urban areas other than as part of the planned City West growth area. only occurs following an appropriate assessment of all environmental effects.”

3. Amend Policy 3.5(c) as follows: “3.5 To enable the subdivision of rural land into small allotments for rural-residential purposes in the areas identified for that purpose on the Planning Maps, where it is demonstrated that: … (c) The subdivision does not compromise the Council’s urban growth plans and Strategies to provide for a growth area at City West; …”

4. Amend Policy 1.1 as follows: “1.1 To protect rural land at City West as it that has been identified in Council strategies as potentially suitable for future urban growth.”


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5. That the rule providing for the subdivision of Rural sites that do not contain elite soils into 4 hectare block is reinstated.

6. That Rule 23.7.1Performance Standard (d) (i) be reworded for as follows:

“(d) Undergrounding of Lines and Pipes (i) Lines shall be buried below not be located above ground except: …’

7. Amend Rule 6.3.6.1(e)(i) relating to earthworks within the National Grid Yard to allow for undergrounding of electrical lines within the National Grid Yard as Permitted Activity, when consent has been expressly given for the works.

8. Amend the Key to the Planning Map to include Transpower’s high voltage power lines and in relation to the City Boundary Line. Submission Number

Plan Change Number


SO48 15A-H 15B

S4 Definitions S6 General S7 Subdivision S9 Rural Zone

Meridian Energy Limited

Andrew Feierabend PO Box 2146 104 Moorhouse Avenue CHRISTCHURCH 8140

YES

Submission: The Submitter considers that:

1. The proposed provisions of PPC 15B fail to enable wind generation as anticipated by the National Policy Statement for Renewable Electricity Generation and associated planning instruments;

2. The non-complying activity status proposed for wind farms (triggered by the arbitrary 700m setback requirement and location within the Tararua Ranges Landscape Protection Area) fails to have regard to environmental effects, is not the most appropriate method to achieve the objectives and policies of PPC15B, and fails to achieve the purpose of the RMA;

3. The arbitrary reverse sensitivity setback of 1.5km does not properly take into account NZS6808:2010 Acoustics – Wind Farm Noise with respect to sound level contours and fails to meet the requirements and purpose of the RMA;

4. The proposed provisions for new wind energy generation facilities under Rule 9.8.6 (requirement for spatial setback or adjacent owner/occupier written approval defaulting to non-complying activity status) is inconsistent with the approach taken to reverse sensitivity to protect wind energy generation facilities (where affected party approval of the generator is not required and consent is not required as a non-complying activity);

5. Discretionary activity status for wind farms is sufficient and provides a robust assessment framework that more appropriately satisfies the RMA’s requirements and purpose.


1. S4: That the S4 definition of Wind Farm be amended to clarify that setback requirements relating to wind turbine noise do not apply to ancillary buildings and structures.

2. S4: That the S4 definition of Wind Farm Site be deleted from the Plan.

3. R6.2.6.2(1)(e): That R6.2.6.2(1)(e) is updated to refer to the 2010 Standard. Alternatively, that R9.11.1 is amended as follows: Sound emissions from any activity in the Rural Zone (excluding sound emissions from Minor and Extended Temporary Military


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Training Activities controlled by Rule 9.5.8 (d)(i) and (ii) and sounds generated by Wind Farms controlled by Rule 9.8.6) when measured at or within the boundary of any land zoned for residential purposes or at or within the boundary of any land in the Rural Zone (other than land from which the noise is emitted or a road) shall not exceed the following:…

4. S9 Objective 8 & Policies 8.1, 8.2, & 8.4: That Objective 8 and Policies 8.1, 8.2, and 8.4 of S9 are retained.

5. R9.8.6(i): That R9.8.6(i) is deleted.

6. R9.9.3: That R9.9.3 is deleted.

7. R9.8.6(ii) That R9.8.6(ii) is deleted.

8. R9.5.5(b): That R9.5.5(b) is amended as follows:

(b) Separation Distances (i) Any No residential building shall may be located not less than: (a) less than 10 metres from a front boundary; (b) less than 5 metres from any other boundary; (c) 1.5 km within a 40 dB LA90(10min) sound level contour, calculated under NZS6808:2010 Acoustics - Wind Farm Noise from the location of a wind turbine on a site for which a Wind Farm resource consent application has been granted.

9. Any similar or consequential amendments necessary to give effect to the submission points. Submission Number

Plan Change Number



Deborah A Sparkes Deborah A Sparkes 286 Millricks Line RD2 PALMERSTON NORTH 4472

NO

Submission: The submitter opposes Plan Change 15A Rural Zone and Subdivision - that will only allow for a minimum lot size of 20 ha on all rural land in the Palmerston North City Council area.

The Submitter is concerned there is no PNCC definition of the word ‘production’ in Council documentation relating to the Plan Change. The submitter notes there are a number of ways of measuring land production and interpretation could relate to the number of animal offspring born, stock units per hectare, gross lot income, gross lot surplus, kg/DM/Ha (amount of animal feed that can be grown/Ha), kg fibre (sheep. alpaca or goat). Kg/meat/ha, $/ha. Need to better clarify what the intent is.


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The submission states that Council has little understanding of the 10 acre/4 ha block/lot needs and wants of the people purchasing these lots and believes the minimum lot area for a rural subdivision shouldn’t be increased from 4 ha to 20ha, and that 4 ha lots should continue to be allowed. The submitter notes 3 distinct requirements for lifestyle blocks and makes observations in regards to productivity. The submitter considers the statement of “little evidence of productive activities occurring on rural lots with a minimum lot size of 4 ha”, is erroneous and misleading.

The submitter is concerned that the removal of 4 ha rural subdivision will mean people wanting animals will be unable to enjoy this lifestyle and that families should be able to develop a lot and build their own house, if they wish to do so. The submitter notes existing stock will not meet all demands and market needs and this change needs to consider the longer term as well as short term needs. The submitter has been advised by people in the trade that there is a shortage of undeveloped 4 ha lots.

The submitter notes intentions that Council wish to preserve good productive land for dairy support and is not arguing in regards to Class 1 and 2 Soils but rather areas of low productive capacity such as poor Class 2 (Tokomaru Soils) and Class 3 soils or less is maintained. The submitter refers to a presentation by Alan Palmer in relation to the Horizons One Plan submissions that stated the need to retain highly productive Manawatu silt Loam soils – class 1 and 2, while Tokomaru soils are low value for food production.

The submitter contends that Council have minimal understanding of the practicality and capacity of 1ha lots.

Decision Requested: 1. The minimum lot size for rural residential is not increased from 4 ha to 20 ha on all rural land in Palmerston North City Council area

Submission Number

Plan Change Number


SO50 15A 15C 15F

S4 Definitions S7 Subdivision S9 Rural Zone S12 Industrial

Fonterra Co-operative Group Limited

C/- Ian Johnson Environmental Management Services PO Box 1307 HAMILTON 3240

YES

Submission: The submitter generally supports the direction of PC15A-H subject to a number of minor amendments. Fonterra owns and operates an existing dairy factory at Longburn and owns the land proposed to be rezoned to Braeburn Industrial Area (BIA) by PPC15E. The submitter notes PPC15C proposes to apply a new framework of industrial zone provisions, the details of which were originally developed to manage industrial activities within the urban area of the City rather than large scale manufacturing sites in the rural area. The approach of the submission has been to fine-tune the framework of the Industrial Zone provisions to respond to the resource management issues existing at Longburn. The submitter states that the BIA is intended to be retained in single ownership, and developed for additional dairy related industrial activities to support those existing at Longburn. Operationally, activities are to be integrated with the existing factory and this has a significant bearing on the infrastructure requirements and internal management of the site. The BIA will in effect be an expansion of the existing factory site and will be subject to the same operational constraints in terms of security, health and safety. These characteristics distinguish the BIA from other parts of the Industrial Zone in the City. Unlike other parts of the City, infrastructure requirements are to be provided, held and maintained by Fonterra, recognising that development is likely to be staged. The submitter also raises concerns that the Rural Zone section of the Plan needs give added prominence to the need to protect rural production and associated activities against reverse sensitivity effects. Decisions Requested:

1. S4: Amend clause (e) of the definition of Dairy Related Industrial Activities to replace the reference to network utilities with infrastructure.

2. S4: Amend the definitions section to include an additional definition for “Sensitive Activities” as follows:

means the following activities: community houses, dwellings and dwelling units, early childhood facilities, residential centres, retirement villages, schools, hospitals, marae, public building, church or recreational area.


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3. S7 Objective 8 Explanation: Amend the Explanation to S7 Objective 8 by deleting the last sentence.

4. R7.16.1.2: That R7.16.1.2 be retained as notified.

5. 9.1 Introduction: Amend the second sentence to read: It is important that the District Plan recognises this, and the particular resource management issues which face farmers and their supporting activities. In particular the District Plan needs to ensure that new development within or adjoining rural areas does not increase the likelihood of reverse sensitivity effects.

6. 9.2 Resource Management Issues: Amend Issue 10 to read: Recognition of the potential for rural activities to adversely affect urban activities, particularly residential activities, conflict between activities at the urban/rural interface.

7. 9.3 Objectives and Policies: Include a new objective and policy regarding the need to protect rural production activities and supporting activities from reverse sensitivity effects.

8. R9.5.5(b)(i): Permitted Activity Rule 9.5.5 Dwellings and Accessory Buildings: Amend performance standard R9.5.5(b)(i) to read: No residential building or other sensitive activity may be located less than… 25m setback from any other boundary.

9. R9.5.5(b)(iii): Amend performance standard 9.5.5(b)(iii) to read:

Accessory buildings not intended to house animals, except where they are used for a sensitive activity, shall be located not less than 3 metres from a boundary.

10. R9.5.5(b) Amend performance standard 9.5.5(b) to include an additional clause as follows: Any sensitive activity shall be located not less than 150m from any existing effluent pond or land used for wastewater disposal.

11. R9.5.5: Amend the explanation associated with Rule 9.5.5 to include the following:

The separation distances for sensitive activities will ensure that rural production and supporting activities are protected against reverse sensitivity effects.

12. The submitter supports the category change of Education and Early Childhood Facilities from Controlled to a Discretionary activity.

13. R9.7.1 Dwellings not Complying with Permitted Activity Performance Standards: Amend the rule to include the following matter of discretion and associated assessment criteria respectively: Potential for reverse sensitivity The potential for reverse sensitivity effects on adjoining activities.

14. R9.8.4: The submitter supports the change in activity status to Discretionary for Community and Leisure, Tourist, Education, and Early Childhood Facilities. The change is viewed as appropriate given the potential for these activities to give rise to reverse sensitivity effects.

15. 12.1 Introduction: Amend to refer to major dairy manufacturing activities at the existing Longburn site and note that the BIA is to be

provided with private infrastructure as follows: Major dairy manufacturing and processing are located at Longburn where they are supported by strategic transport infrastructure. The activities occupy a single site straddling Reserve Road. The Braeburn Area provides additional …


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The restricted discretionary classification of development… Infrastructure provision is to be privately provided and maintained and will be to a standard that meets the operational requirements of the dairy related industrial activities.

16. 12.2 Resource Management Issues: Insert an additional paragraph before the penultimate paragraph in of the explanation as follows: Dairy manufacturing and processing activities are located at Longburn where they are supported by strategic transport infrastructure. These activities have developed alongside residential activities. The location of activities within the site and appropriate boundary treatment has enabled the successful co-location of these neighbouring activities.

17. 12.3 Objectives and Policies: Amend the explanation associated with Objective 1 to recognise Fonterra’s site at Longburn as follows: The Industrial Zone at Longburn includes major dairy manufacturing and processing activities being undertaken on an extensive site and being supported by private infrastructure. The site straddles an existing road and is adjacent to the NIMTR which is directly connected to on-site processing activities. Significant investment has been made in infrastructure and activities on the site. The objective and policy framework aims to enable the continued efficient use of this infrastructure for regionally significant economic activity.

18. S12 Policy 4.1: The submitter is concerned the policy places significant constraints on continued development within the Longburn site with no obvious community benefit. The submitter requests the following amendment to Policy 4.1: Where practicable, having regard to the functional and operational requirements of an activity, proposals should To require any activity or building development within the Industrial Zone to contribute to the visual enhancement and amenity of the industrial area.

19. S12 Objective 5: The submitter seeks the following amendment: To enable development of dairy related industrial activities within the Braeburn Industrial Area to occur in a co-ordinated manner, ensuring that the servicing requirements of the entirety of the Area are identified prior to development, planning for services is considered at the earliest stage of development, while ensuring that adverse effects on other activities in the vicinity are avoided, remedied or mitigated.

20. S12 Policy 5.3: Delete the following words from the policy: To require as a matter of priority at the time of the first development that planning for water, wastewater and stormwater services is considered for the entire development of the Braeburn Industrial Area.

21. S12 Objective 5 Explanation: Existing site topography and location of buildings may mean that some aspects of service provision in the BIA are unable to be integrated with existing infrastructure. The submitter seeks the following amendments to the second bullet point and the last paragraph of the explanation associated with Objective 5: The potential for integrating infrastructure provision with the existing Longburn site is considered A piecemeal approach to the development is not appropriate but staged development is acceptable.

22. R12.6.1(b) Parking: The rule imposes requirements that would significantly constrain activities at the Longburn Dairy Manufacturing Site and the BIA. The submitter seeks the following amendment to R12.6.1(b): (c) The requirements of Rule 12.6.1(b)(i), (a) and (ii) shall not apply to the Longburn Dairy Manufacturing Site or within the Braeburn Industrial Area.

23. Rule 12.6.1(c) Outdoor Storage: The submitter considers the rule inappropriate in context of the Longburn Dairy Manufacturing Site and the BIA and requests the rule be amended as follows: (iv) The requirements of Rule 12.6.7(c),(i),(ii) and (iii) shall not apply to the Longburn Dairy Manufacturing Site or within the Braeburn Industrial Area.


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24. R12.6.1(h) Servicing and Loading Hours: The submitter considers the rule inappropriate given the 24 hour operation of the existing

Longburn Dairy Manufacturing Site and the expected 24 hour operation of the BIA. The submitter requests the following: This Rule shall not apply within the Longburn Dairy Manufacturing site or within the Braeburn Industrial Area.

25. Rule 12.6.1: The submitter requests a new site specific parking performance standard as follows: Parking within the Longburn Dairy Manufacturing Site and the Braeburn Industrial Area shall be provided at a rate of 1 space per on-site employee and 6 visitor spaces. Car parking requirements can be met on each site separately, or combined to serve both sites.

26. Rule 12.6.1(m) BIA: Amend clause (iii) that refers to compliance with Rules 12.6.1 (a) to (m) to include new (n) parking as follows: Compliance with Rule 12.6.1 (a) to (n)

27. R12.6.2(d) Landscape Amenity: In the context of the Longburn Dairy Manufacturing site this rule would necessitate excessive areas of planting where the site currently provides screening from neighbouring residential sites with a 1.8 metre high fence. Amend the rule as follows: This rule shall not apply to the Longburn Dairy Manufacturing Site. At this site, any outdoor storage area visible from any site in the Residential Zone shall be screened from view by either a close boarded fence or wall of not less than 1.8m height, or dense planting of vegetation capable of providing a screen of at least 1.8m height.

28. R12.6.2.(g) Parking: The submitter requests new Rule 12.6.2(g) be amended as follows: This rule shall not apply to the Longburn Dairy Manufacturing Site. R12.6.1(g)(i) Activities at the Longburn Dairy Manufacturing Site shall comply with the standards set out in Rule (reference the standard set out in submission point 22).

29. The Comprehensive Development Plan (CDP) will identify the general location and scale of activities and appropriate treatment of site boundaries to address visual amenity issues arising from proposed buildings. R12.6.2(k) BIA Minor Alterations & Additions: Amend the permitted gross floor area or footprint in (k)(i)(a) and (k)(ii)(a) from 500m2 to 10,000m2.

30. R12.8.5 BIA: Matters that are restricted for discretion require amendment to provide focus on the effects that are assessed, remove duplications and delete matters that are the subject of Regional Council control. The submitter requests the following amendments to the list of assessment criteria: Layout, design and scale Delete from the list: Landscape Amenity; Hydraulic Neutrality with regards to stormwater; and Those matters described in Section 108 of the Resource Management Act

31. R12.8.5 BIA: Some aspects of the CDP cannot be determined with precision, it is more appropriate to amend some of the terms to

ensure there is flexibility in how matters are to be addressed. Amend as follows R12.8.5(a)(i): … Comprehensive Development Plan that indicates details the design layout and servicing …

32. R12.8.5 BIA: Performance standards (a)(i) and (ii) should be combined to provide a more concise description of the matters to be addressed. Replace (a)(i) and (ii) with the following:


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The general arrangement of activities and circulation routes and connectivity with adjoining industrial land.

33. Rule 12.8.5 BIA: amend performance standard (a)(v) to read: The location of any stormwater detention area.

34. R12.8.5 BIA: CDP performance standard (a)(vii) requires the location of internal landscape planting areas to be shown. This requirement is incompatible with the operational requirements of dairy manufacturing activities. The submitter requests performance standard (a)(vii) be deleted.

35. R12.8.5 BIA: The submitter seeks performance standard (a)(viii) to be amended to ensure there is no confusion with the District Plan definition of network utilities. Amend performance standard (a)(viii) by deleting the word network.

36. R12.8.5 BIA Assessment Criteria: R12.8.5 (a) sets out assessment criteria that will be applied to the CDP. In clause (iii) reference to public spaces includes the NIMTR corridor. Landscaping of this corridor is not practicable. The focus of landscaping provisions should be on the external boundaries of the BIA. Amend assessment criteria (a)(ii) bullet points 1 and 2 as follows: - A coherent internal road layout or circulation route that connects logically and efficiently to the surrounding adjoining Industrial

Zone. - Infrastructure can be provided sufficient to ensure the entire Braeburn Industrial Area can be is appropriately connected and

serviced in a way that enables future staged development. The submitter also notes that stormwater discharges are regulated by the Regional Council and requests that assessment criteria (ix) be deleted.

37. R12.8.5 BIA Assessment Criteria (b): The submitter requests the title of assessment criteria under (b) and the content of (b)(iv) are amended as follows: Layout and Design Scale The extent to which the proposed development contributes to a road layout or an internal circulation route that connects logically and efficiently to adjoining Industrial Zone land, and whether planned development integrates with adjoining industrial activities.

38. R12.8.5 BIA Assessment Criteria (c): The submitter considers that detailed proposals for landscape treatment is only required for the eastern and southern boundaries of the BIA. Furthermore, all activities will be subject to extensive operational and regulatory requirements relating to food processing. Requirements for internal landscaping within the BIA will conflict with operational and regulatory requirements. The submitter requests an amendment to the title of assessment criteria (c), an amendment to the content of (c)(i) and the deletion of (c)(ii) as follows: (c)(i) The extent to which the development provides on-site landscaping to the eastern and southern boundaries of the BIA that

avoids or mitigates the actual or potential adverse effects on surrounding residential properties, public spaces, and the Longburn township.

(c)(ii) The extent to which on-site landscaping establishes an attractive appearance and establishes conditions of visual interest and amenity within the development and the wider area.

39. R12.8.5 BIA Assessment Criteria (d): The submitter notes that the CDP requires the identification of areas suitable for large scale

buildings and boundary landscaping measures that will mitigate effects on land in the vicinity. The submitter requests an amendment to the title of assessment criteria (d), and amendment to the content of (d)(i) and (ii) as follows: (d) Buildings and Structures: External Design and Appearance Effects on Surrounding Residential and Rural Areas (d)(i) Whether the design and appearance of any building or structure is in keeping with and complements the intended industrial

character of the Braeburn Industrial Area. The extent to which the scale, form and appearance of a building is determined by


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operational and functional requirements. (d)(ii) The extent to which buildings and structures are located and designed to avoid dominating surrounding rural and residential

zoned land areas with highly visible large blank walls. (d)(v) The extent to which any component of a building or structure that visibly extends above others and is prominent in external

views is formed or modelled to avoid visual dominance, and to contribute positively and coherently to articulation of the skyline.

40. R12.8.5 BIA Assessment Criteria (e): The submitter notes operational requirements of the manufacturing site and the technical requirements of the Regional Council will determine whether innovative or low impact treatment options are available in regards to stormwater. The submitter requests the deletion of assessment criteria (e)(ii). (e)(ii) The extent to which innovative and or low-impact stormwater design is integrated where appropriate and geo-technically feasible.

41. R12.8.5 BIA Assessment Criteria (f): The location of industrial activities in the BIA will be constrained by specific functional requirements and health, safety and hygiene regulations. All these aspects have a significant bearing on the location of car parking areas. The submitter requests an amendment to assessment criteria (f)(iii) as follows: (f)(iii) The extent to degree to which the car parking layout is functional, safe and convenient, having regard to the operational,

functional and regulatory requirements affecting dairy manufacturing sites accessible from building entrances.

42. R12.8.5 BIA (g): Section (g) sets out the criteria to be applied to Natural Hazards. Assessment criteria clause (g)(iii) refers to stormwater management having to achieve hydraulic neutrality. The submitter considers the term “hydraulic neutrality” to be ambiguous. The matter is more appropriately regulated under the terms of the Regional Plan. The submitters requests that assessment criteria (g)(iii) be deleted: (g)(iii) The extent to which the proposed stormwater approach will ensure hydraulic neutrality.

43. R12.8.6 Non-Notification BIA: The proposed regulatory framework provides a level of detail and certainty that there is no necessity for a proposal to be subject to notification. The submitter supports the non-notification Rule 12.8.6.

44. Figure 20A.1: The submitter supports the retention of Transportation Section Figure 20A.1 insofar as it shows the status of Reserve Road as a local road.

45. The submission explains the intention of the BIA is to provide for the expansion of the submitter’s existing dairy industrial activities at Longburn. Requested amendments seek to establish consistency in some performance standards that relate to both sites. To provide clarity regarding the extent of land that is subject to these performance standards the submitter requests to amend planning maps to define a “Longburn Dairy Manufacturing Site.”

Submission Number

Plan Change Number



Kevin O’Donnell Holly Jenkins Kevin O’Connor & Associates 71 Pitt Street PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter supports in part Rule 7.16.1.2(b)(i) Performance Standard – Lot Area. It is submitted that sites under 20 hectares be assessed as Restricted Discretionary Activities instead of automatically becoming Non-complying Activities in the decision on Plan Change 15.

The submitter opposes Rule 7.16.1.2(b)(ii) Performance Standard – Lot Area – for a surplus dwelling. The submitter believes the 1 hectare minimum lot area requirement results in productive land being lost, as the surplus dwelling usually has an existing fence boundary around the dwelling and are able to comply with existing building requirements, therefore the land just sits around the dwelling and goes unused.


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Submits that the matter be further considered in decision on Plan Change 15.

The submitter neither supports /opposes 7.16 Rural Zone. The submission seeks that section sizes are able to be reduced in rural areas, where appropriate, to 5,000 m2, provided that they are still able to connect to services.

The submitter supports in part 7.16 Rural Zone. It is submitted that Plan Change 15A allow for controlled residential development to occur at the edge of the city in sites that have been zoned rural. The submission notes that many of the sites on the borderline of these residential/rural areas are small lots which are able to be developed for residential purposes that are keeping with the surrounding environment.

Section 7: Subdivision; 7.17 All Zones; R 7.17.1.1 Notes to Plan Users 1 - The submitter notes that Rule 7.17.1.1 and associated Notes to Users 1 includes a reference to Map 22.8, which was not able to be found and therefore was unable to provide comment on it.

The Submitter neither supports or opposes the provisions in Section 9: Rural Zone. The submitter seeks that commercial activities are allowed to be undertaken at strategic sites. The submitter supports the idea of Council selecting areas within the Plan Change that stand out as sites that could be developed to provide for a commercial activity without creating the need to completely rezone the site or area.

Decisions Requested: 1. To have the above subdivision matters, considered in decision on Plan Change 15.

2. That Council select areas in the Rural Zone that stand out as sites that could be developed to provide for a commercial activity,

without creating the need to completely re-zone the site or area. Submission Number

Plan Change Number


SO52 15A S7 Subdivision Appendix 2: Planning Map 7

Jeremy J Lind Jeremy J Lind 671 Stoney Creek RD10 PALMERSTON NORTH 4471

Did not indicate

Submission: The submitter opposes Planning Map 7 and the rural zoning of 671 Stoney Creek. While the submitter understands and supports the principal reason for the classification - to protect further development on productive farmland - it is noted that the land in the Stoney Creek/Tutaki Roads area are Perch-Gley Pallic soils which are poor soils for farming i.e, heavy clay, prone to being excessively wet in winter and dry in summer, not particularly fertile. Submits that a rural residential zoning permitting subdivision down to 1 ha is logical. The submission notes the following additional points in support:

‐ Proximity to the City ‐ Current subdivision ‐ Direction of development ‐ Current zoning under the Manawatu District Plan

Decision Requested:

1. That a rural residential zoning permitting subdivision down to 1 ha lots be applied to 671 Stoney Creek Road. Submission Number

Plan Change Number



Dean Gregory Sparkes

Dean Sparkes 286 Millricks Line RD2 Linton PALMERSTON NORTH

YES

Submission: The submitter opposes Plan Change 15A Rural Zone and Subdivision - that will only allow for a minimum lot size of 20 ha on all rural land in the Palmerston North City Council area.

The submitter is concerned there is no PNCC definition of the word ‘production’ in Council documentation relating to the Plan Change. The submitter notes there are a number of ways of measuring land production and interpretation could relate to the number of animal offspring born, stock units per hectare, gross lot income, gross lot surplus, kg/DM/Ha (amount of animal feed that can be grown/Ha), kg fibre (sheep.


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alpaca or goat). Kg/meat/ha, $/ha. Need to better clarify what the intent is.

The submission states that Council has little understanding of the 10 acre/4 ha block/lot - needs and wants of the people purchasing these lots -and believes the minimum lot area for a rural subdivision shouldn’t be increased from 4 ha to 20ha, and that 4 ha lots should continue to be allowed. The submitter notes 3 distinct requirements for lifestyle blocks and makes observations in regards to productivity. The submitter considers the statement of “little evidence of productive activities occurring on rural lots with ‘a minimum lot size of 4 ha’, is erroneous and misleading.

The submitter is concerned that removal of 4 ha rural subdivision will mean people wanting animals will be unable to enjoy this lifestyle and that families should be able to develop a lot and build their own house, if they wish to do so. The submitter notes existing stock will not meet all demands and market needs, and this (plan) change needs to consider the longer term as well as short term needs. The submitter has been advised by people in the trade that there is a shortage of undeveloped 4 ha lots.

The submitter notes Council’s intention to preserve good productive land for dairy support and is not arguing in regards to Class 1 and 2 Soils; rather areas of low productive capacity such as poor Class 2 (Tokomaru Soils) and Class 3 soils or less is maintained. The submitter refers to a presentation by Alan Palmer in relation to the Horizons One Plan submissions, that stated the need to retain highly productive Manawatu silt Loam soils – class 1 and 2, while Tokomaru soils are low value for food production.

The submitter contends that Council have minimal understanding of the practicality and capacity of 1ha lots.

Decision Requested: 1. That the minimum lot size for rural residential is not increased from 4 ha to 20 ha on all rural land in Palmerston North City Council

area. Submission Number

Plan Change Number


SO54 15B S7 Subdivision S9 Rural

New Zealand Wind Energy Association

Eric Pyle PO Box 553 Ground floor, 114 The Terrace WELLINGTON

YES

Submission: The submitter opposes PPC15B, stating that it does not adequately reflect the NPSREG. Decision Requested:

1. That PPC15B be amended so that it gives proper effect to the NPSREG.

Submission Number

Plan Change Number


SO55 15A 15D 15G

S4 Definitions S7 Subdivision S9 Rural Zone S22 Natural Hazards S23 Utilities Appendix 2: Planning Maps

Pioneer City West Ltd

Paul Thomas Environmental Management Services PO Box 29024 WELLINGTON 5034

YES

Submission: The submitter opposes the zoning of PCB land as rural on the Planning Maps and seeks the provisions sought in PCB, be adopted by PC15. The submission notes that all relevant information on PCB is on the Council website at: http://www.pncc.govt.nz/yourcouncil/consultations-initiatives-and-projects/closed-consultations/sectional-district-plan-review-private-plan-change-b-pioneer-city-west-limited-consultation-closed/; the adoption of PCB through this plan change is in accordance with Council’s Residential Growth Strategy; and there is no basis for City West not to proceed in accordance with the Residential Growth Strategy and it should have been actioned in PC15.

The submitter supports Policy 1.2 in Section 7, with amendment. It is submitted that Policy 1.2 should expressly recognise the status of City West as the next growth area, now that Whakarongo has been zoned. The submitter seeks the following amendment:

“1.2 To avoid ensure that subdivision activity for urban purposes outside existing urban areas other than as part of the planned City West growth area. only occurs following an appropriate assessment of all environmental effects.”


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The submitter supports Policy 5.3(c) with amendment. It is submitted that Policy 3.5(c) expressly recognise the status of City West as the next growth area now that Whakarongo has been zoned. The submitter seeks the following amendment to Policy 3.5 (c):

“3.5 To enable the subdivision of rural land into small allotments for rural-residential purposes in the areas identified for that purpose on the Planning Maps, where it is demonstrated that: … (c) The subdivision does not compromise the Council’s urban growth plans and Strategies to provide for a growth area at City West; …”

The submitter supports Policy 1.1 of Section 9 with amendment. It is submitted that Policy 1.1 should expressly recognise the status of City West as the next growth area now that Whakarongo has been zoned. The submitter seeks the following amendment.

“1.1 To protect rural land at City West as it that has been identified in Council strategies as potentially suitable for future urban growth.”

The submitter opposes the change of approach to subdivision in the Rural Zone (Section 7.16 Rural Zone), particularly the undue emphasis on protecting Class 1 and 2 soils in relation to determining areas suitable for rural residential development. The submitter seeks that all matters in the Plan Change which relate to these issues are deleted and the operative provisions are retained.

The submitter is concerned with the definition of Flood Prone Areas. The submission notes the definition in Section 4:‘means the areas spatially defined on the planning maps’ and yet the reports and plan provisions make it explicit that ‘flood prone areas’ relate to land inundated by a 1 in 200 year flood event. It is submitted that the definition of Flood Prone Area be amended to refere s[pecifically to land inundated in a 1 in 200 year flood event (0.5% AEP event). The submitter states that the flood prone area relating to part of PPCB shown in Planning Map 24 has not been identified by professional reports as part of the PPCB documentation. The submitter notes that drainage from the area relating to PCB has been studied and will be incorporated into stormwater management strategies (likely to include a detention structure) to mitigate flood risk. The submitter supports in part Rule 23.7.1(d) Undergrounding of Lines or Pipes. The submitter supports the ability to be able to be underground existing lines as a permitted activity, but seeks for clarity, that Performance Standards (d) (i) be reworded as: “(i) Lines shall be buried below not be located above ground except: ‘

Decisions Requested: 1. That PC15 be amended to incorporate PC B as publically notified.

In the event that this is not accepted, the land included in PCB should be expressly excluded from PC15 and the Plan Maps amended accordingly, as PC B has been notified, submissions lodged and will shortly proceed to a hearing.

2. S7.3 Policy 1.2: That S7 Policy 1.2 be amended, as follows: Policy 1.2 To avoidensure that subdivision activity for urban purposes outside existing urban areas other than as part of the planned City West growth area. Only occurs following an appropriate assessment of all environmental effects.

3. Amend Policy 3.5(c) as follows:

“3.5 To enable the subdivision of rural land into small allotments for rural-residential purposes in the areas identified for that purpose on the Planning Maps, where it is demonstrated that: … (c) The subdivision does not compromise the Council’s urban growth plans and Strategies to provide for a growth area at City West; …”

4. S9.3 Policy 1.1: That S9 Policy 1.1 be amended, as follows: Policy 1.1 To protect rural land at City West as it has been identified in Council strategies as potentially suitable for future urban growth.

5. R23.7.1: That the operative rural subdivision provisions be retained and the provisions of PC15 which focus on protecting Class 1 and 2 soils in relation to determining areas suitable for rural residential development, be deleted.

6. That Performance Standard (d) or Rule 23.7.1 be amended, as follows: (d) Undergrounding of Lines and Pipes (i) Lines shall be buried below ground exceptLines shall not be located above ground except:


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7. S4: That the definition of Flood Prone Area be amended to refer specifically to land inundated in a 1 in 200 year flood event (0.5% AEP event).

8. Planning Map 24: That the flood overlay area relating to the PPCB site be removed from Planning Map 24.

Submission Number

Plan Change Number


SO56 15A-H 15A 15C 15D 15E 15F 15G 15H

S4 Definitions S7 Subdivision S9 Rural S20 Transportation S24 Designations S22 Natural Hazards S12A NEIZ S12 Industrial S13 Airport Appendix 2: Planning Maps

Manawatu-Wanganui Regional Council (Horizons)

Lisa Thomas Private Bag 11-025 Manawatu Mail Centre PALMERSTON NORTH

YES

Submission: The submitter notes that the Operative Horizons One Plan has been renumbered. The submitter requests that cross-references to the One Plan be updated. The submitter notes that the Regional Land Transport Strategy will expire, being replaced with the Regional Land Transport Plan by 30 June 2015. The submitter supports the recognition of renewable energy activities through S9 Objective 8 and supporting policies. The submitter states that the definition of Network Utilities does not recognise the facilities for the generation of more than 1MW of electricity and its supporting infrastructure as regionally or nationally significant physical resources (as in Policy 3-1(a)(i) of the One Plan). The submitter suggests that this recognition be included within policies supporting S9 Objective 8. The submitter notes that policies in S7 that allow subdivision provided they do "not create significant adverse effects on the characteristics and values of regionally Outstanding Natural Features and Landscapes…", but that it is unclear whether this constitutes avoidance where practicable, or allows for mitigation or remediation where avoidance is not practicable. The submitter supports the recognition of renewable energy activities through S9 Objective 8 and supporting policies. The submitter supports the policy and rule framework for the protection of regionally significant natural features and landscape in PPC15A-H. The submitter seeks a clearer alignment between the provisions to protect the TRLPA across the District Plan and One Plan Policy 6-6. The submitter supports S9 Policy 7.1 and Map 9.1, as they partially give effect to One Plan Policy 6-6. The submitter supports S9 Policy 7.3 as it is consistent with Policy 6-6(a) of the Horizons One Plan. The submitter notes that there is no equivalent policy direction in S7. The submitter notes that S9 Policy 3.5 does not provide for the avoidance of effects other than visual effects or for the mitigation of visual effects, if avoidance is not reasonably practicable. The submitter notes that S9 Policy 9.2 does not establish that as far as reasonably practicable the effects should be avoided. The submitter states that overall these provisions do not give full effect to One Plan Policy 6-6 and may not provide sufficient guidance in assessing resource consent applications because they do not provide for the avoidance of significant adverse cumulative effects on the TRLPA, and do not clearly outline avoidance as far as reasonably practicable and mitigated/remedied if avoidance is not practicable. The submitter indicates that R9.8.6 covers water quality and biodiversity matters already addressed by Horizon's functions. The submitter considers R20.3.5.1 & Appendix 20 Roading Hierarchy to be generally aligned with the Regional Land Transport Plan. The submitter notes that aligning the Plan's roading hierarchy with the NZTA's One Network Road Classification is important. The submitter supports the introduction of new access standards for arterial and collector roads in the Boundary Change Area, particularly S20 Objective 1, Policy 2.4, and R20.3.9.1.


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The submitter requests the extension of Horizons designations to include existing flood protection assets within the boundary change area under PPC15C, to enable their on-going maintenance and to provide certainty to plan users of their location and when One Plan R17-15 will apply. The submitter notes that the exact location of Horizon's assets have not been surveyed, and width information for stop banks within the District are not available. The submitter notes that the planning maps in PPC15C do not differentiate between existing and proposed designations. The submitter is concerned that the double-line used for representing Horizons' assets is confusing to plan users because it is an inconsistent approach with PPC10 and that it gives the impression that there are stop banks on both sides of a waterbody in cases where there is only one. The submitter seeks to ensure that the proposed designations shown on planning maps are consistent with information supplied to PNCC and Horizons asset maps. The submitter supports the approach taken in R7.17.1.1. The submitter opposes the second Note to Plan Users under R17.7.1.1, as this divests decision-making power to Horizons Regional Council with regards to subdivision. The submitter suggests a 'Note to Plan Users' under R9.5.5 referring them to R22.7.3.1 with respect to buildings, structures and activities within the Flood Protection Zone, and to R22.8.2.1 with respect to occupied structures within Flood Prone Areas. The submitter supports R22.7.1.1 and 22.8.1.1 providing for non-habitable structures on production land except within the Flygers Line Floodway as a permitted activity. The submitter notes that these provisions may allow non-habitable structures to locate on land adjacent to significant numbers of habitable buildings, increasing the risks of effects arising. The submitter supports R22.7.3.1, as it is consistent with One Plan Policy 9-2(a). The submitter generally supports R22.8.2.1. The submitter is concerned that consideration needs to be given to what standards and assessment criteria will apply to occupied structures and activities in areas outside of the Flood Prone Areas that are not yet modelled as at risk to flooding. The submitter supports R22.8.2.1(a), as it is consistent with One Plan Policy 9-2(d)(i). The submitter states that R22.8.2.1(b) does not recognise that other combinations of flood depth and velocity may still be considered "safe." The submitter has attached a figure illustrating the velocity and depth relationships for determining safe wading limits on page 39 of this submission. The submitter generally supports the assessment criteria under R22.8.2.1. The submitter opposes the reference to "protection for the site" with respect to flood hazard mitigation measures under R22.8.2.1 Assessment Criteria (ii) and (iii), stating that flood hazard mitigation does not achieve protection for the site, but rather reduces the risk to people and property from flood hazard. The submitter considers the use of the word "or" between "0.5% AEP or (1 in 200 year)..." under R22.8.2.1 Assessment Criteria (ii) unnecessary as a 0.5% AEP event equals a 1 in 200 year flood event. The submitter suggests the removal of the last sentence of the Explanantion and the first Note to Plan Users under R22.8.2.1, and the second paragraph of the Explanation under R22.8.3.1, as these provisions divest decision-making power to Horizons Regional Council with regards to subdivision. The submitter suggests the removal of the second paragraph of the Explanation under R22.8.3.1, as these provisions divest decision-making power to Horizons Regional Council with regards to subdivision. The submitter suggests the inclusion of the Flygers Line Floodway designation in the Explanation under R22.7.3.1. The submitter supports the following parts of PPC15E:

1. Supports growth of the NEIZ and the proposed structure plan. 2. Supports proposed S12A Policy 5.5 which seeks to avoid road access from the NEIZ Extension Area to Railway Road. 3. Supports proposed S12A Policy 3.5 which seeks to ensure the adverse effects of stormwater runoff in the NEIZ Extension Area

are mitigated on-site. 4. Supports proposed S12A Policy 3.9 which seeks to ensure an integrated approach to the provision of stormwater management

that recognises the capacity of existing systems and natural drainage patterns within the NEIZ Extension Area, 5. Supports proposed S12A Policy 3.10 which requires the use of sustainable urban drainage systems and low-impact design

systems throughout the NEIZ Extension Area. 6. Supports proposed S12A Policy 3.12 that requires development in the NEIZ Extension Area to comply with Structure Plan 7.2 to

ensure an integrated and sustainable pattern of development. The submitter supports these policies as they will ensure that additional stormwater flows from the NEIZ Extension Area into the Mangaone Stream catchment will not exacerbate flooding of other properties.


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Supports proposed changes to Objective 5 and new Policies 5.4 to 5.11 in Section 7 of the Plan (Subdivision).

Supports the requirement that all subdivisions in the NEIZ Extension Area comply with Structure Plan 7.2. Particularly the requirement that:

1. Gully areas be retained for stormwater detention. 2. For detention areas to be in place in advance of development. 3. Sustainable urban drainage systems and low impact design systems be used throughout the NEIZ Extension Area. 4. Supports the requirement to prepare a CDP for each stage of subdivision. This will be beneficial in ensuring additional stormwater

generated by the NEIZ Extension Area is able to be treated and detained on-site without exacerbating flooding downstream. This approach will ensure compliance with One Plan (Discharge of Stormwater) Rule 14-18.

5. The submitter supports the stormwater approach laid out in R12A.6.2 performance standards (f)(i) to (iii) and assessment criteria (d)(i) and (ii). This support is contingent on 100% mitigation of the 1% AEP plus climate change storm, as per NZS4404:2010.

6. The submitter notes that they are currently upgrading Mangaone Stream flood protection assets, locations include Setters Line north of the airport, Flygers Line stopbanks, and Benmore Avenue. It is important that stormwater from the NEIZ Extension Area does not compromise the standard of flood protection being provided in these locations.

The submitter supports the requirement for a CDP for the BIA, particularly in relation to the requirement for the CDP to address proposed road layout or circulation routes, and design and connectivity with other land. In relation to the strategic direction of the RLTP, improved connectivity to key strategic routes north-south and west-east of the region is highlighted as a priority.

Supports proposed Objective 5 and its associated policies within Section 12 (Industrial Zone). Particularly the direction to plan for services at the earliest stage of development to ensure services proceed in a coordinated and integrated manner.

Supports the requirement for a CDP prior to development within the BIA. The approach will be beneficial to ensuring stormwater is appropriately treated and detained so as not to exacerbate flooding of other property.

The submitter supports assessment criteria (e)(ii) of proposed Rule 12.8.5, which requires the consideration of innovative and or low-pact stormwater design where appropriate.

The submitter raises concerns regarding the calculated stormwater detention pond volumes in the plan change servicing report and notes that hydraulic neutrality must be maintained for discharges to the Taonui Basin.

Any new or upgraded on-site wastewater disposal systems will need to be designed in accordance with the “Manual for On-site Wastewater Disposal Systems Design and Management” (Horizons Regional Council, 2010) and comply with relevant standards of the One Plan. If One Plan performance standards cannot be met then a resource consent will be required.

The submitter will only be able to confirm whether a resource consent is required for the discharge of wastewater or stormwater once more information has been provided on what development is proposed for the site. In some instances stormwater and wastewater discharge is provided for as permitted activity in the One Plan. For this reason the submitter requests the second note to plan users that accompanies Rule 12.8.5 be deleted. The submitter requests that the note be replaced with a general reference that directs applicants to seek advice from the Regional Council in relation to any additional resource consents that may be required for a proposed development. Decision Requested:

1. That cross-referenced One Plan provision numbers are updated to reflect the Operative One Plan.

2. That cross-references to the Regional Land Transport Strategy be replaced with cross-references to the Regional Land Transport Plan.

3. S9 Objective 8 and supporting policies: That the recognition given to renewable energy activities through S9 Objective 8 and supporting policies be retained.

4. S9 Objective 8 supporting policies: That the policies supporting S9 Objective 8 be amended to give recognition to wind generation

facilities as physical resources of regional or national significance.

5. S9 Policy 7.1 & Map 9.1: That S9 Policy 7.1 and Map 9.1 be retained as drafted.


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6. TRLPA: That clarification is sought on how significant adverse cumulative effects in the TRLPA (other than renewable energy and

major structures) and all types of significant adverse effects on the TRLPA from all activities are provided for in the Plan.

7. That the Plan indicates a clear direction around the avoidance of significant adverse effects (other than significant cumulative effects) as far as practicable being preferred to mitigation or remediation.

8. R9.8.6: That R9.8.6 Wind Farms be amended as follows:

(k) Ecological impacts, particularly impacts on the Turitea Reserve and Arapuke Forest Park, water bodies, and impacts on indigenous flora and fauna, avifauna and their habitats. (l) Impacts of earthworks and modifications of natural landforms, including impacts on water quality and proposed remedial and mitigation measures.

9. S20 Objective 1, Policy 2.4 & R20.3.9.1: That S20 Objective 1, Policy 2.4 and R20.3.9.1 be retained without modification.

10. S24 Table 1: That the Further Details column for Designation 85 be amended to include the following Note to Plan Users:

One Plan Rule 17-15 requires resource consent for activities on stop banks and on land between artificial waterways or the bed of a river, and 8 metres inland of the landward toe of the stop bank where such activities may affect the integrity and function of the City's flood protection. These activities include: the planting of trees and shrubs; new buildings or other structures, or extensions to existing buildings or structures; new fences; land disturbance including excavation and deposition of clean-fill; and the upgrade, reconstruction, alteration, extension, removal or demolition of any structure maintained by the Regional Council for the purpose of flood control. If property owners propose to carry out any activity on a property that contains or is adjacent to a designated flood protection asset it is recommended that they first contact the Manawatu-Wanganui Regional Council to confirm any consent requirements.

11. Planning Maps: That Horizons' new designations be displayed in the same way as Horizons' existing designations in PPC10, and

PNCC Officers work with Horizons staff to refine this representation.

12. S20: That the new access standards for arterial and collector roads in the Boundary Change Area be retained as drafted. In particular, the submitter requests the retention of the following: - S20.3 Objective 1 - New Policy 2.4 - Changes to R20.3.9.1 to ensure traffic generated does not impact on the efficiency and safety of adjoining major and minor arterial routes.

13. R7.17.1.1: That the second Note to Plan Users under R7.17.1.1 Subdivision within Flood Prone Areas be deleted.

14. R9.5.5: That R9.5.5 Dwellings and Accessory Buildings be amended to include a Note to Plan Users referring to R22.7.3.1 with

respect to buildings, structures and activities within the Flood Protection Zone, and to R22.8.2.1 with respect to occupied structures within Flood Prone Areas.

15. R22.7.1.1 & R22.8.1.1: That R22.7.1.1 Permitted Activities and R22.8.1.1 Permitted Activity be amended to include a performance

standard similar to the following: Non-habitable structures on production land must not divert the flow of flood water into existing occupied structures and activities. The submitter notes that consequential amendments to the rule stream and the definition of Occupied Structures and Activities would be required.

16. R22.7.3.1: That R22.7.3.1 Non-Complying Activities be retained as drafted.

17. That a new general rule be included similar to the following:

R 22.8.2.2 Restricted Discretionary Activity 1. Any new occupied structure or activity, or any increase in the scale of an existing occupied structure or activity, within an area that has been assessed as likely to be inundated during a 0.5% AEP (1 in 200 year) flood event Are a Restricted Discretionary Activity with regard to:


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- Flood Hazard Avoidance or Mitigation - Functional Necessity - Placement of New Critical Infrastructure Provided it complies with the Performance Standards and Assessment Criteria specified in Rule 22.8.2.1.

18. R22.8.2.1(a): That R22.8.2.1(a) be retained as drafted.

19. R22.8.2.1(b): That R22.8.2.1(b) be amended as follows: b. Access between occupied structures and an identified safe area, where safe evacuation may be carried out (preferably ground that will not be flooded), must not be inundated greater than 0.5m above finished ground level with a maximum water velocity of 1.0 m/s in a 0.5% AEP or ("1 in 200 year") flood event, or some other combination of water depth and velocity that can be shown to result in no greater risk to human life, infrastructure or property.

20. R22.8.2.1: That R22.8.2.1 Assessment Criterion (ii) be amended as follows: ii. the extent to which specific flood control measures or flood hazard mitigation measures will achieve protection for the site mitigate flood hazard to the occupied structure or activity in a 0.5% AEP (1 in 200 year) flood event.

21. R22.8.2.1: That R22.8.2.1 Assessment Criteria (iii) be amended as follows: 1. Whether the proposed ownership of, and responsibility for maintenance of, the flood hazard mitigation measures, including the certainty of the maintenance regime, will achieve protection for the site mitigate flood hazard to the occupied structure or activity in a 0.5% AEP (1 in 200 year) floor event.

22. R22.9.2.1 Explanation: That the last sentence of the Explanation for R22.8.2.1 be deleted.

23. R22.8.2.1 Note to Plan Users: That the first Note to Plan Users under R22.8.2.1 be deleted.

24. R22.8.3.1 Explanation: That the last sentence of the Explanation for R22.8.3.1 be deleted.

25. R22.8.3.1 Explanation: That the second paragraph of the Explanation for R22.8.3.1 be deleted.

26. R22.7.3.1 Explanation: That the Explanation of R22.7.3.1 be amended as follows: In respect of these activities within the Flygers Line Floodway designation, the written consent of the Manawatu-Wanganui Regional Council will be required.

27. S7 Policies 3.5, 3.9, 3.10, 3.12 & 5.5: The submitter requests the retention of S7 Polices 3.5, 3.9, 3.10, 3.12 and 5.5 as drafted.

28. S7 Objective 5 and associated Policies 5.4-5.11: The submitter requests the retention of S7 Objective 5 and associated Polices 5.4

to 5.11 as drafted.

29. R12A.6.2(d)(i): The submitter requests the following amendments to stormwater assessment criteria in R12A.6.2 (d)(i) as follows: The extent to which proposed on-site stormwater retention and detention measures ensure hydraulic neutrality is achieved in the 1% AEP plus climate change storm, as per NZS4404:2010 and that there is no increase in stormwater effects on surrounding areas.

30. R12.8.5: The submitter requests the retention of stormwater assessment criteria (e)(ii) of R12.8.5.

31. S12.8.5: The submitter requests the second note to plan users that accompanies R12.8.5 be deleted and replaced with the

following: Resource consent for wastewater discharge and stormwater discharge to land will be required from the Manawatu-Wanganui Regional Council. Advice should be sought from the Manawatu-Wanganui Regional Council in relation to any additional resource consents that are


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required for the proposed development.

32. S23: That the submitter’s support for Section 23 be noted.

33. S13: That the submitter’s general support for Section 13 be noted.

34. R13.4.5.2: That clause (i) of R13.4.5.2 be amended as follows:

i. any new building or other structure, or any utility, as defined in this plan (excluding roads, rail, additions or extensions to existing dwellings, accessory buildings, and navigational aids for aircraft and activities undertaken by or on behalf of the Regional Council for the purpose of flood control within the Taonui basin Floodway as defined in Schedule J of the One Plan);

35. Planning Maps 6, 12, 13 and 19: That PNCC ensures that additionally generated stormwater from the Airport Zone does not materially compromise the standard of flood protection being provided in the following locations:

- Setters Line north of the Airport (Planning Maps 6, 12 and 13)

- Flygers Line stopbanks (Planning Maps 6 and 12); and

- Benmore Avenue (Planning Map 19).

36. S13: That additional rules and performance standards be included in S13 of the District Plan to control stormwater discharges from activities, new buildings and new hardstand areas to achieve hydraulic neutrality in the 0.5% AEP design storm.

Submission Number

Plan Change Number


SO57 15A S4 Definitions S7 Subdivision S9 Rural Zone S23 Utilities

Horticulture New Zealand

Chris Keenan PO Box 10-232 WELLINGTON

YES

Submission: The submitter generally supports Section 9: Rural. The submitter supports the general approach to ensure land is available for high value production, such as horticulture. The submitter states that the clear identification of potential for reverse sensitivity and provisions to manage it are critical to enabling rural production activities. The submission notes the references to versatile soils or class 1 and 2 soils throughout the Plan Change and that there is no definition for versatile soils or versatile land in the Plan. It is submitted that the reference should be to Class 1 and 2 land rather than soils, as the classifications are based on the NZ Land Resource Inventory which is based on more than the components of soil ie the nature of land & climate. A focus on soil means that important components of the land are not included; and it takes more than soil to have a rural production system. So all components need to be provided for.

The submission notes that the Plan Change seeks to ensure that rural character is retained. The submitter seeks a definition for rural character that is inclusive, describes the nature of the environment anticipated in the rural environment and which provides a clear direction to assist in assessing activities that seek to locate in the rural area. The submitter seeks a definition for ‘rural character’ be included, as follows:

“Rural character includes the following elements: a) High ratio of open space relative to the built environment; b) Significant areas of vegetation in pasture, crops, (including support structures) forestry and/or indigenous vegetation; c) A rural working production environment; d) Presence of farmed animals; e) Noises, smells and effects associated with the use of rural land for a wide range of agricultural, horticultural and forestry

purposes; f) Low population densities relative to urban areas; g) Existence of some narrow and/or unsealed roads; h) General lack of urban infrastructure.”

The submitter supports in part Rule 9.5.5.Dwellings and Accessory Buildings; Performance Standard (b) Separation Distances (i)(b). The submitter notes that residential activities located near rural production activities have the potential to create reverse sensitivity effects and submits that the 5 m separation distance on side and back boundaries is not sufficient to avoid, remedy or mitigate such effects. The


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submitter seeks larger setbacks from the boundary for dwellings, so that the potential for reverse sensitivity is reduced. This is particularly important where there is high value production undertaken and there is potential for reverse sensitivity complaints. The submitter requests the following amendment to Rule 9 5.5 Performance Standard (b) (i) (b): ‘No residential building may be located less than 15 metres from any other boundary.’

The submitter supports the deletion of the controlled activity rule for education and early childhood facilities and listing as a Discretionary Activity in Rule 9.8.4. This (assessment criteria?) is supported, in particular, the need to consider effects on existing lawfully established productive rural activities. The submitter seeks the retention of Education and Early Childhood Facilities in Rule 9.8.4 and Assessment Criteria j) and k).

The submitter generally supports Rule 6.2.6.2 Exclusions from Noise Control Rules. The submission states that there should be a specific exclusion in a) for aircraft undertaking agricultural aviation activities, which is part of farming. eg spraying or applying fertiliser. The submitter supports exclusion d) for rural activities. The submission also notes there is no definition for rural activities but reference is made to Rule 9.6.1 & Rule 9.6.2. The submission states that as a result of renumbering, this reference should be made to Rule 9.5.1 and Rule 9.5.2.

The submitter supports Rule 6.3.6.2 (i). The submission notes that cultivation and harvesting of crops as part of horticultural and agricultural activities are included in exclusion (i) and this is supported. The submitter seeks that Rule 6.3.6.2 (i) be retained.

The submitter generally supports Section 7 and the approach to ensure land is available for high value production, such as horticulture. The submission states that the clear identification of potential for reverse sensitivity and provisions to manage it, are critical to enabling rural production activities.

The submission notes the references to versatile soils eg Resource Management Issue 7.2 (i) Objective 3 & Policy 3.3 throughout the Plan Change and that there is no definition for versatile soils or versatile land in the Plan. It is submitted that the reference should be to Class 1 and 2 land rather than soils, as the classifications are based on the NZ Land Resource Inventory which is based on more than the components of soil ie the nature of land & climate. A focus on soil means that important components of the land are not included; it is submitted that it takes more than soil to have a rural production system. So all components need to be provided for.

The submitter supports in part Objective 3. The submitter supports the approach in Objective 3 in that it considers the productive capability of the land and also rural character. It is submitted that the reference should be to retaining’ versatile‘ land which gives effect to the RPS, and not ‘protecting’ as this is fairly absolute. There should also be a bullet point regarding reverse sensitivity and a definition of rural character. The following amendments are sought:

‐ Amend Objective 3 and the associated Bullet Point 2, to read:“Retains Class 1 and Class 2 versatile land for use as production land.”

‐ Retain Bullet Point 8 but include a definition of rural character, as sought in the earlier submission point in 1.2 of their submission. ‐ Add an additional Bullet Point: ‘Avoids potential for reverse sensitivity.’

The submitter opposes in part R ule 7.16 Performance Standards this provision. The submitter requests that the potential for reverse sensitivity effects on rural production activities is considered as an assessment criteria for all subdivision in the Rural Zone. . The submitter supports in part Policy 1.1 ii, in Section 23.3. The submission states that as the National Grid is proposed to be defined in Section 4 Definition that Policy 1.1 ii need only refer to “The National Grid” providing all the appropriate components of the National Grid are included in the definition. The following amendment is sought:

“ii. The National Grid and electricity distribution and transmission networks defined as the system of transmission lines, sub-transmission and distribution feeders (6.6kV and above) and all associated substations and other works to convey electricity;”

The submitter supports the provisions in Rule 23.7.3 particularly (h). The submitter seeks the retention of Rule 23.7.3 (c), (g) & (h). Decisions Requested:

1. Amend all references to ‘Class 1 and 2 soils’ or ‘versatile soils’ in Section 9 to ‘Class 1 and 2 land’ or ‘versatile land’.

2. Include a definition for ‘rural character’ in Section 4 Definitions, as follows: “Rural character includes the following elements: i) High ratio of open space relative to the built environment; j) Significant areas of vegetation in pasture, crops, (including support structures) forestry and/or indigenous vegetation; k) A rural working production environment;


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l) Presence of farmed animals; m) Noises, smells and effects associated with the use of rural land for a wide range of agricultural, horticultural and forestry

purposes; n) Low population densities relative to urban areas; o) Existence of some narrow and/or unsealed roads; p) General lack of urban infrastructure.”

3. Amend Performance Standard to Rule 9.5.5 (b) (i) (b) Separation Distance to read as follows:

“No residential building may be located less than 15 metres from any other boundary”’

4. Retain Education and Early Childhood Facilities in Rule 9.8.4 and Assessment Criteria j) and k).

5. Amend Rule 6.2.6.2 1 (a) by adding ‘including aircraft undertaking agricultural activities.’ Update and amend Rule 6.2.6.2 1 (d) to refer to Rule 9.5.1 and Rule 9.5.2.

6. Retain Rule 6.3.6.2 (i).

7. Retain consideration of reverse sensitivity effects as part of subdivision criteria in Section 7.

8. Include a definition for versatile soils or versatile land in the Plan (Section 7) Amend all references to ‘Class 1 and 2 soils’ or ‘versatile soils’ to ‘Class 1 and 2 land’ or ver

9. Amend Objective 3 and the associated Bullet Point 2, as follows: “Retains Class 1 and Class 2 versatile land for use as production land.”

- Retain Bullet Point 8 but include a definition of rural character, as sought in the earlier submission point in 1.2 of their submission (page 3).

- Add an additional Bullet Point, as follows: ‘Avoids potential for reverse sensitivity.’

10. Ensure that the potential for reverse sensitivity effects on rural production activities is considered as an assessment criteria for all subdivision in the Rural Zone.

11. Amend Policy 1.1 ii in Section 23 Utilities, as follows: “ ii. The National Grid and electricity distribution and transmission networks defined as the system of transmission lines, sub-transmission and distribution feeders (6.6kV and above) and all associated substations and other works to convey electricity;” Ensure all the components of the National Grid are included in the definition for National Grid. In Section 4 Definitions.

12. Retain Rule 23.7.3 (c), (g) & (h). Submission Number

Plan Change Number


SO58 15A 15B


Dorothy M Alley Dorothy M Alley 45 Atawhai Road PALMERSTON NORTH

Did not indicate

Submission: The submitter supports the original submission from Joseph Poff (SO24). The submitter opposes the proposed changes in the District Plan. Decision Requested:

1. No specific decision requested.


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Submission Number

Plan Change Number


SO59 15A 15C 15D 15E 15F 15G

S4 Definitions S6 General S7 Subdivision S9 Rural Zone S10 Residential Zone S12 Industrial Zone S12 NEIZ S19 Institutional Zone S22 Natural Hazards S23 Utilities S24 Designations

Powerco Mark Laurenson Burton Planning Consultants Ltd Level 1, 2-8 Northcroft Street PO Box 33817 Takapuna Auckland 07040

YES

Submission: The submitter has expressed support for a number of matters related to Plan Change 15A-H. They have also requested a number of amendments related to S6 General, S7 Subdivision, S9 Rural, S10 Residential, S12 Industrial, S12A North East Industrial Zone, S19 Institutional and S23 Utilities. The submitter supports the S4 definitions for Critical infrastructure, Essential Services and Minor Upgrading. The submitter supports the rolling over of Designations 102-104 into S24 Table 1 Schedule of Designations. The submitter states that the approach taken around the application of S22 to Network Utilities and Critical Infrastructure is unclear. The submitter supports S22 Policy 1.2, as it allows for minimisation of flood risk and does not seek avoidance in all circumstances. The submitter supports S22 Policy 2.1 in principle, but suggests that it be amended to relate to avoiding, mitigating or remedying hazard effects as opposed to the hazard itself. The submitter states that there is no reference to critical infrastructure under R22.7.3.1, but notes that the rule appears to be applicable to critical infrastructure based on the Explanation and the Council's S32 Report. The submitter states that matters of control, performance standards and assessment criteria under R22.8.2.1 relate to critical infrastructure, but the rule itself does not appear to relate as critical infrastructure is not 'an occupied structure'. The submitter states that having any new activity require restricted discretionary activity consent under this R22.8.2.1, whether permanent structures are involved or not, is onerous. Decisions Requested:

1. S4: That the S4 definition of Critical Infrastructure be retained without modification.

2. S4: That the S4 definition of Essential Services be retained without modification.

3. S4: That the S4 definition of Minor Upgrading be retained without modification.

4. R6.3.6.2(ii): Reconsider the need for clause (ii) of R6.3.6.2 Exclusions from Earthworks Rule 6.3.6.1, in light of the Note to Plan Users regarding the application of the earthworks rules to network utility operators. In the event the Council chooses to retain clause (ii), amend it to exempt trenching and backfilling ancillary to maintenance, upgrade and removal, as well as installation, of utilities and services from the requirement to comply with R6.3.6.1, as follows: (ii) Trenching and backfilling ancillary to the installation, maintenance, upgrade and removal of utilities and services, including effluent disposal fields, and water and effluent tanks, provided there is no change to the existing ground level.

5. S7.2 Resource Management Issue 1 Explanation: Amend the Explanation to S7 Resource Management Issue 1 to recognise that intensification of existing sensitive land uses as well as new sensitive land uses may lead to reverse sensitivity effects, as follows: Management of reverse sensitivity effects associated with complaints from intensification or new sensitive land uses located in proximity to existing, lawfully established activities or operations.

6. S7.2 Resource Management Issue 5 Explanation: Amend the final paragraph of the Explanation to S7 Resource Management Issue 5 to recognise that reverse sensitivity effects are only one of a range of potential adverse effects on network utilities, as follows:


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Network utilities are often located in the rural environment on account of their special technical and locational requirements. Recognition of operational requirements at the time of subdivision consent, and in setting conditions on subdivision applications, will protect existing network utilities from adverse effects, including reverse sensitivity effects, provide for their continued reliable and secure operation and ongoing maintenance, while ensuring the health and safety of the people and communities that they serve.

7. S7 policy 2.10: That S7 Policy 2.10 be retained without modification.

8. R7.7.1.2(e), R7.7.2.2(a) and R7.1.1.2(d): Retain without modification the subdivision performance conditions for controlled and / or

restricted discretionary activities in each of the Residential, business, Industrial & North East Industrial and Institutional zones (Residential Zone R7.7.1.2(e) and R7.7.2.2(a); Business Zone and Institutional Zone R7.1.1.2(d)) which require the provision of essential services for connection within 30 metres of the nearest point of the land being subdivided and encourage consultation with network utility operators, as follows: Performance Conditions for Discretionary Activity (Restricted) (a) Essential Services All essential services must be available for connection within 30 metres of the nearest point of the land being subdivided. NOTE TO PLAN USERS: It is advised that the applicant contact the appropriate power, telecommunication and gas companies to determine the feasibility of connecting to their services.

9. S7.17: Include the following advice notes in Section 7.17 All Zones to alert plan users to the requirement for compliance with NZECP34:2001 and the Tree Regulations in relation to all electricity lines: Note to Plan Users The New Zealand Electrical Code of practice for electrical safe distances (NZECP 34:2001) contains restrictions on the location of structures and activities around electricity lines. Compliance with this code is mandatory. Compliance with this plan does not ensure compliance with NZECP34:2001. The electricity line operator can be contacted for advice for any activities around the electricity network. Vegetation to be planted near electricity lines should be selected and/or managed to ensure that it will not result in that vegetation breaching the Electricity (Hazards from Trees) Regulations 2003. To discuss works, including tree planting, near any electrical line, contact the line operator.

10. S9 Objective 1 and Policies 1.1-1.5: That S9 Objective 1 and associated Policies 1.1-1.5 be retained.

11. SS9, 10, 12, 12A & 19: Include advice notes in each of SS9, 10, 12, 12A, and 19 of the PPC15A-H to draw attention to the need for compliance with NZECP34:2001 and the Tree Regulations; in order to appropriately avoid, remedy or mitigate potential adverse effects of inappropriate subdivision, use and development on Powerco’s electricity sub-transmission and distribution network; and to give effect to the policy framework of the One Plan and District Plan, as follows: NOTE TO PLAN USERS The New Zealand Electrical Code of practice for electrical safe distances (NZECP 34: 2001) contains restrictions on the location of structures and activities around electricity lines. Compliance with this code is mandatory. Compliance with this plan does not ensure compliance with NZECP34:2001. The electricity line operator can be contracted for advice for any activities around the electricity network. Vegetation to be planted near electricity lines should be selected and/or managed to ensure that it will not result in that vegetation breaching the Electricity (Hazards from Trees) Regulations 2003. To discuss works, including tree planting, near any electrical line, contact the line operator.

12. S22: That a Note to Plan Users be included in S22 similar to the following: The natural hazards rules apply to critical infrastructure but not to other network utilities. Network Utilities are specifically addressed in Section 23 of the Plan.

13. S22 Policy 1.2: That S22 Policy 1.2 is retained as drafted.

14. S22 Policy 2.1: Amend S22 Policy 2.1 to focus on avoiding, remedying or mitigating the effects of natural hazards rather than avoiding, remedying or mitigating the hazard itself, which will not generally be possible, as follows:


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To exclude development on hazard-prone land where the effects of the hazard on the proposed development cannot be effectively avoided, remedied or mitigated.

15. R22.7.3.1: Amend R22.7.3.1 to clarify that the rule applies to critical infrastructure, as follows: Any new building, structure or activity, including new critical infrastructure, or any increase in the scale of any existing building, structure or activity within the Flood Protection Zone (including the Flygers Line Floodway shown on Map 22.7) which is not provided for as a Permitted Activity, Discretionary Activity or a Prohibited Activity shall be a Non-Complying Activity.

16. R22.7.1.1: Amend R22.7.1.1 to specifically permit the operation and maintenance of existing critical infrastructure in the Flood Protection Zone, as follows: R 22.7.1.1 Permitted Activities The following activities are Permitted Activities: (x) The operation and maintenance of existing critical infrastructure.

17. R22.8.2.1: Amend R22.8.2.1 to clarify that the rule applies to critical infrastructure, as follows: R22.8.2.1 Restricted Discretionary Activity (1) Any new occupied structure or critical infrastructure activity, or any increase in the scale of any existing occupied structure or critical infrastructure activity, within a Flood Prone Area identified on the Planning Maps are is a Restricted Discretionary Activity with regard to: - Flood Hazard Avoidance or mitigation - Functional Necessity - Placement of New Critical Infrastructure

18. S23.1: Retain the introduction to S23, as well as the approach of having a standalone utilities chapter in the District Plan.

19. S23.2: Retain S23 Resource Management Issues 1 and 2 and the associated Explanation to those issues in Utilities without modification.

20. S23.2: Amend S23 Resource Management Issue 3 of and the final paragraph of the explanation to recognise that inappropriate development may result in a range of adverse effects on network utilities, not just reverse sensitivity effects. This could be achieved by making the following changes or changes to the same effect: 3. The operation, maintenance and upgrade of regionally or nationally important network utility structures or activities can be adversely affected by the inappropriate location or intensification of activities that are sensitive to their effects. As well as the potential for network utilities to have adverse effects on the environment, other activities can have adverse effects, including reverse sensitivity effects, on network utilities. Inappropriate subdivision, use and development may result in adverse effects on network utilities and / or restrict access to such network utilities including the ability to undertake maintenance or upgrade work. Reverse sensitivity can occur when sensitive activities, such as residential activities, schools, hospitals or places of worship, locate near to, or intensify by, existing network utilities and constrain the operation or expansion of those utilities. An example would be the intensification of residential land use near to existing high voltage power lines. This may mean that the local, regional or national benefits of important network utilities is compromised.

21. S23.3 Objective 1 & Policy 1.1: That S23 Objective 1 and Policy 1.1 be retained without modification.

22. S23.3 Objective 2 & Policies 2.1 and 2.2: That S23 Objective 2 and Policies 2.1 and 2.2 be retained without modification.

23. S23.3 Policy 2.3: Amend S23 Policy 2.3 Utilities to recognise that incompatible subdivision, use or development may result in a range of adverse effects on network utilities, not just reverse sensitivity effects, as follows: 2.3 To avoid, or as appropriate remedy or mitigate, the potential for any adverse effects, including reverse sensitivity effects, on regionally or nationally important network utilities from incompatible new subdivision, use or development, occurring under, or adjacent to regionally or nationally important network utilities.

24. S23.3 Objective 3 & Policies 3.1-3.3 & 3.5-3.9: That S23 Objective 3 and Policies 3.1 to 3.3 and 3.5 to 3.9 be retained without modification.


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25. S23.3 Policy 3.4: Amend S23 Policy 3.4, as follows: 3.4 To require the placement of network utilities underground unless: There are natural or physical features or structures, or technological ad operational constraints that makes underground placement impracticable or unreasonable; They are of a temporary nature and required for emergency purposes or critical events; They are of a nature that can only operate above ground; In the case of lines, they traverse any Rural Zone or roads within the Rural Zone; They are existing network utilities.

26. R23.7.1: Amend Rule 23.7.1 to also provide for the removal of the listed network utilities as a permitted activity, as follows: The establishment, operation, maintenance,and minor upgrade and removal of any of the following…

27. R23.7.1(i): Amend Rule 23.7.1(i) to clarify that it applies to the support structures and associated ancillary equipment associated with electricity lines, as follows: … (iii) Transformers,and lines (including support structures) and ancillary equipment for conveying electricity at a voltage up to and including 110kV.

28. R23.7.1: Amend Performance Standard 9a)(i) (to R23.7.1) to clarify that support structures, as well as overhead lines, are exempt from the height and height recession plan requirements of the underlying zone, as follows: (a) Height (i) All above ground utility structures, except lines (including support structures), masts, aerials, antennas and their brackets or attachments, must comply with the maximum height control and any height recession planes for any zone in which they are located. The height recession plane shall not apply to the boundary of a road, road reserve, or service lane.

29. R23.7.1: Amend Performance Standard (d)(i)(b) (to R23.7.1) to allow for the replacement of existing support structures by adopting the definition of ‘minor upgrading’ included in Section 4 as it relates to overhead lines, rather than the definition of ‘upgrading’ currently used in the performance standard, as follows: (d) Undergrounding of Lines and Pipes (i) Lines shall not be located above ground except: a. where lines traverse any Rural Zone, or roads within this Zone.

b. where they involve the maintenance, repair, replacement and minor upgrading of existing overhead lines. Upgrading in this context means an improvement, increase in capacity or improved security provided that only existing support structures are utilised. c. where lines are to provide temporary links, connections or services, they may be above ground for up to three consecutive months in any 12 month period.

30. R23.7.1: Make appropriate changes to ensure above ground equipment ancillary to the gas distribution network, such as district regulator stations, gas measurement systems and pressure reducing stations are provided for as a permitted activity, with no requirement to be located underground. This could be achieved by making changes to R23.7.1(v) and Performance Standard d(ii), as follows, or to the same effect: R23.7.1 (v) Pipes for the distribution (but not transmission) of natural or manufactured gas at a gauge pressure not exceeding 2000 kilopascals and necessary incidental equipment, including household connections,and compressor stations, district regulator stations, gas measurement systems and pressure reducing stations located either above or below ground. Performance Standard (d) Undergrounding of Lines and Pipes (ii) All pipes for network reticulation shall not be located located abovebelow ground, except that this requirement does not apply to:

(a) incidental equipment associated with the distribution (but not transmission) of natural or manufactured gas at a gauge pressure not exceeding 2,000 kilopascals.

31. R23.7.1: Amend Performance Standards (g) Reinstatement (to R23.7.1) and (b) Reinstatement (to R23.7.2) to clarify that reinstatement to previous ground conditions will not always be practicable on completion of work, as follows: Where the construction or maintenance of a network utility involves disturbance to the ground, at the completion of the work the


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ground shall be reinstated to the condition of the surrounding area existing prior to commencement of the work.

32. R23.7.1: Retain the remainder of the Performance Standards to R23.7.1 (b) noise; (c) lighting; (e) building size; (f) aerials and antennas; (h) cultural and heritage sites; (i) radiofrequency field exposure; and (j) setbacks without modification.

33. R23.7.2: Retain R23.7.2 without modification.

34. R23.7.3(a): Amend R23.7.3 (a) to provide for the operation, maintenance and upgrade of network utilities permitted by both R23.7.1 and R23.7.2 and retain R23.7.3(b), as follows: R 23.7.3 Activities within the National Grid Yard Within the National Grid Yard, the following activities are Permitted Activities:

(a) The operation, maintenance or upgrading of network utilities that are also permitted activities under R23.7.1, R23.7.2 or are permitted by the NES for Electricity Transmission or the NES for Telecommunication Facilities;…

35. R23.8.1(a): Retain Rule 23.8.1(a) without modification.

36. R23.9.1: Retain Rule 23.9.1.

37. R23.9.2: Amend Rule 23.9.2 to exempt permitted network utilities from the requirement to obtain restricted discretionary consent to

establish or be altered within 100m of the Turitea (Linton) National Grid Substation and 23m of the Bunnythorpe National Grid Substation. This could be achieved by making the following amendments or to the same effect: R 23.9.2 Construction and alteration of buildings and structures within 100mof the Turitea (Linton0 National Grid Substation and 25m of the Bunnythorpe National Grid Substation is a Restricted Discretionary Activity with regard to: (a) The extent to which the development may adversely affect the efficient operation, maintenance, upgrading and development of the substation; (b) The extent to which the proposed design and layout of the development enables appropriate separation distances between future sensitive activities, development and the substation; (c) Any other measures proposed to avoid or mitigate potential adverse effects, including reverse sensitivity effects, on the substation; and (d) The risk of electrical hazards affecting public or individual safety and the risk of property damage. Except that R23.9.2 does not apply with respect to: (a) The operation, maintenance or upgrading of network utilities that are also permitted activities under R23.7.1, R23.7.2 or are permitted by the NES for Electricity Transmission or the NES for Telecommunication Facilities; (b) The establishment of network utilities within a transport corridor, part of a transmission network or electricity infrastructure that connects to the National Grid.

38. R23.10.1: Retain R23.10.1 to the extent that it provides for the construction, operation, alteration or addition to electricity substations and any other utility structure or activity not otherwise listed as permitted, controlled or restricted discretionary.

39. S24 Table 1: That designations 102, 103, 104 are retained in S24 Table 1 Schedule of Designations without modification.

40. That any other such relief, including addition, deletions or consequential amendments necessary to give effect to this submission as a result of the matters raised is adopted.

Submission Number

Plan Change Number


SO60 15C 15F

S4 Definitions S20 Transportation S24 Designations S12 Industrial

KiwiRail Holdings Ltd Rebecca Beals Wellington Railway Station PO Box 593 WELLINGTON 6140

YES

Submission: The submitter opposes the S4 definition of Minor Upgrading, as it does not cover the maintenance and upgrading of the rail network. The submitter supports the discussion around rail and reverse sensitivity effects in 20.1 Introduction.


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The submitter notes that there are no provisions relating to the operation, maintenance and upgrade of the rail network in S20, despite S20 being specifically referenced as addressing the rail network. The submitter notes that S24 Table 1 Schedule of Designations is showing existing designation information as new text, so is taking the opportunity to seek that the requiring authority New Zealand Railways Corporation is changed to KiwiRail Holdings Limited. The submitter supports S12 Objective 5, Policy 5.5 and the associated explanation that seeks ensure development of the BIA occurs in an integrated manner. The submitter is particularly supportive of development in the BIA being subject to a CDP which ensures access and connectivity to the existing Longburn Dairy Manufacturing Site is considered. The submitter supports proposed restricted discretionary Rule 12.8.5 performance standard (a), CDP, and assessment criteria (a), CDP, and (b), Layout and Design for the reasons discussed in the paragraph above. Decisions Requested:

1. S4: That the S4 definition of Minor Upgrading is amended as follows: Minor Upgrading (for the purpose of Section 23 – Network Utilities) Means, in respect of network utilities, an increase in the carrying capacity, efficiency or security of electricity and associated telecommunications lines the network utility, utilising the existing support network utility structures or structures of a similar scale,...

2. S20.1: That 20.1 Introduction be retained as notified. 3. That policy provisions and rules related to the operation, maintenance and upgrade of the rail corridor and associated support

infrastructure are inserted as necessary.

4. S24 Table 1: That S24 Table 1 Schedule of Designations is amended to change the requiring authority from New Zealand Railways Corporation to KiwiRail Holdings Limited.

5. S12 Objective 5 & Policy 5.5: The submitter requests that S12 Objective 5 and Policy 5.5 be retained as notified.

6. R12.8.5: The submitter requests that Rule 12.8.5 performance standard (a) and assessment criteria (a) and (b) be retained as notified.

Submission Number

Plan Change Number


SO61 15B S4 Definitions S5 Information Requirements S6 General S7 Subdivision S9 Rural Zone Appendix 2: Planning Maps

New Zealand Windfarms Limited

Vicki Morrison-Shaw C/- Aitkins Holm Majurey Level 19, 48 Emily Place AUCKLAND 1010

YES

Submission: The submitter opposes the S4 definition of High Amenity Area for the following reasons:

1. The definition is discriminatory towards wind farm noise as opposed to noise in general. 2. High amenity areas put unusually stringent noise limits on permitted activities or activities already covered in the Plan. 3. Rural Zone noise rules allow more noise from rural activities than currently allowed for wind farms. 4. These areas are designed to protect areas with low background noise, however there is no evidence to suggest that all rural residential land exhibits low background noise. 5. There are existing wind farms operating close to proposed rural residential land. 6. There is insufficient evidence to support proposed rural residential areas.

The submitter opposes the reference to community scale wind farms under the S4 definition of Wind Farm as the submitter states that it is ambiguous and unnecessary. The submitter recommends that the S4 definition of Wind Farm Site be amended, as the submitter is concerned that it will confuse plan users.


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The submitter supports the intention of PPC15B but is concerned that some changes may have unintended effects for consented wind farms. The submitter supports the removal of the rural residential overlay from the submitter's site. The submitter opposes the rural residential overlay areas to the north-west of its site, stating that there is insufficient evidence to suggest that this area is appropriate, particularly from a noise perspective. The submitter supports the provisions in S4, S5 and S9 specific to Domestic Wind Turbines, as they are considerably different to Wind Farms. The submitter opposes the requirement for a social impact assessment with a Wind Farm consent application, as social impacts will be considered in noise, traffic, and landscape assessments required. The submitter supports the deletion of reference to the 1998 Noise Standard from R6.2.6.2 Exclusions from Noise Control Rules. The submitter recommends that the reference should be replaced with NZS6808:2010 to clarify to plan users the management of Wind Farm noise via said standard. The submitter opposes the 1.5km setback in for R9.5.5, as it does not consider the background noise effects on the affected property or how much noise is actually received at the affected property. The submitter notes that NZS6808:2010 suggests that reverse sensitivity should be controlled using noise contours. The submitter supports the introduction of issues, objectives, policies, rules and assessment criteria in S9 to manage Wind Farms, but suggests that some of these provisions need to be clearer in displaying the Plan's relationship with the NPSREG, One Plan, and other high order planning documents. The submitter states that it is not appropriate to single out renewable energy development in the Explanation to S9 Policies. The submitter opposes S9 Issue 17 as it repeats part of Issue 18. The submitter opposes S9 Policy 3.3, as it is inconsistent with the One Plan's approach in Policy 6-6 of avoiding cumulative effects and avoiding other types of effect as far as reasonably practicable. The submitter states that S9 Policy 3.3 does not recognise existing effects arising from consented Wind Farms or that the NPSREG directs consideration of environmental compensation or offsets where effects cannot be avoided. The submitter opposes S9 Policy 7.3, as it is not consistent with the One Plan with respect to residential subdivision. The submitter states that the word appropriate in S9 Policy 8.1 is vague and uncertain. The submitter states that the use of appropriate and well-designed in S9 Policy 9.1, as it is vague, uncertain and unnecessary. The submitter states that reference to existing activities and existing effects in S9 Policy 9.1 is covered by the reference to consented activities. The submitter states that the explanation of activity status type under S9 Objective 9 is unnecessary. The submitter states that the words and they will be subject to a full and rigorous assessment in the Explanation under S9 Objective 9 is unnecessary and implies a less rigorous assessment of discretionary activities elsewhere in the Plan. The submitter states that the explanation of activity status type under R9.7.5 is unnecessary. The submitter states that R9.8.6(i) needs to be amended to refer strictly to new Wind Farms requiring consent, as existing Wind Farms seeking consent for upgrade works and variations to existing consents should not be required to comply with this standard. The submitter opposes the R9.8.6(ii) and related note 2, as the use of the 700m setback in Porirua may not imply that such a limit is appropriate here. The submitter opposes R9.8.6(f), as the matters are already covered by R9.8.6(e). The submitter opposes R9.8.6(g), as the effects are already covered by R9.8.6(d). The submitter opposes the phrase with Wind Farm turbines extending across the full extent of the Tararua Ranges in R9.8.6 Assessment Criterion (i), as the occurrence of visual amenity effects is dependent on the specific nature of the proposal. The submitter opposes the phrase environmental disturbance in R9.8.6(n), as it is ambiguous and any relevant effects will be covered elsewhere.


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The submitter recommends that another assessment criterion be included under R9.8.6 addressing the positive effects of Wind Farm development beyond R9.8.6(a), such as employment and flow on economic effects. The submitter notes that the Explanation under R9.8.6 does not require reference to the 35dBL limit, as reference to NZS6808:2010 is sufficient. The submitter notes suggests the deletion of paragraphs 3 and 4 of R9.8.6 Explanation, or if the 700m setback is retained then the Explanation be amended to clearly reflect that non-complying consent is only required if written consent is not obtained and to refer to the national boundary of a dwelling as opposed to a site boundary. The submitter suggests that R9.8.7 be amended to delete reference to accessory buildings, as such buildings can include activities that are not noise sensitive. The submitter suggests that R9.8.7 be amended so that the activity status of these activities is non-complying rather than discretionary, because such noise sensitive activities should be discouraged from locating near consented Wind Farms to avoid reverse sensitivity effects and this activity status would be more consistent with the approach taken for the 700m setback under R9.8.6(ii). The submitter opposes the reference to including predicted wind farm noise levels in R9.8.7(c), as noise is covered by R9.8.7(b). The submitter states that the general noise rule 9.11 needs to clarify that Wind Farm noise is not required to comply, as it is governed by R9.8.6. Decisions Requested:

1. S4: That the S4 definition of High Amenity Area be deleted.

2. S4: That the S4 definition of Wind Farm be amended to remove reference to Community scale windfarms.

3. S4: That the S4 definition of Wind Farm Site be amended as follows: Wind Farm Site Means all contiguous land parcels where any of the following apply: Wwind turbines, support structures, and ancillary buildings and structures that occupy the land:. - A land agreement for nominated land parcels has been entered into with the landowner for the wind farm activity; - Any other written agreement has been obtained from the landowner that expressly relates to the wind farm activity.

4. Appendix 2: Planning Maps: That the rural residential overlay be deleted in its entirety.

5. S5(o)(iii): That S5(o)(iii) Social Impact Assessment for Wind Farms be deleted.

6. R6.2.6.2: That R6.2.6.2 Exclusions from Noise Control Rules be amended include reference to NZS6806:2010, as per Page 15 of

this submission.

7. S7 & 9: That further work be done to confirm whether a setback distance is more appropriate to other methods. That R9.5.5(b)(i)(c) and associated Explanation be deleted, as per Page 24 of the submission. Alternatively, that the following be amended: 1. That the heading in 7.6.1.2(g) be changed to Separation distance from Consented Wind Farm Turbines to clarify that the setback applies to residential activities. 2. That the second sentence of the Explanation be amended to clarify that the rule is focused on avoiding reverse sensitivity effects on consented wind farms, as opposed to wind farm noise. 3. That the second paragraph of the Explanation under the performance standards for 9.5.5 be deleted, as the submitter states that it is factually incorrect.

8. S9.3 Policy 8.1: That the word appropriate be deleted from S9 Policy 8.1, as per Page 21 of this submission.

9. S9.3 Policy 9.1: That the phrase appropriate and well-designed be deleted from S9 Policy 9.1, as per Page 22 of the submission.

10. S9.3 Policy 9.1: That the phrase existing activities and existing effects be deleted from S9 Policy 9.1, as per Page 22 of the

submission.

11. S9.3 Objective 9: That the sentence in S9 Objective 9 Explanation starting with The Discretionary Activity consent category… be deleted, as per Page 22 of this submission.

12. S9.3 Objective 9: That the phrase and they will be subject to a full and rigorous assessment. be deleted from the Explanation of S9 Objective 9.


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13. R9.7.5 Explanation: That the sentence in R9.7.5 Explanation starting with A restricted discretionary consent process… be deleted, as per Page 27 of this submission.

14. R9.8.6(i): That R9.8.6(i) be amended to refer only to new Wind Farm Sites, as per Page 28 of this submission.

15. R9.8.6(ii) Note for Plan Users 2: That R9.8.6(ii) and Note for Plan Users 2 be deleted. Alternatively (but not preferably), that R9.8.6(ii) apply to the notional boundary, as opposed to the site boundary.

16. R9.8.6(f): That R9.8.6(f) be deleted.

17. R9.8.6(g): That R9.8.6(g) be deleted.

18. R9.8.6: That R9.8.6 Assessment Criterion (i) be amended to delete 'with Wind Farm turbines extending across the full extent of the Tararua Ranges', as per Page 29 of this submission.

19. R9.8.6(n): That R9.8.6(n) be amended to delete reference to environmental disturbances.

20. R9.8.6: That R9.8.6 be amended to include a new Assessment Criterion: (r) The positive effects of Wind Farm development.

21. R9.8.6 Explanation: That R9.8.6 Explanation is amended to remove reference to the 35dBL limit, as per Page 30 of this submission. That R9.8.6 Explanation is amended to remove paragraphs 3 and 4, as per Page 30 of this submission. Alternatively (but not preferably), that R9.8.6 Explanation be amended to clarify that non-complying consent is only required if written consent is not obtained, and also refer to the setback applying to the notional boundary of a dwelling.

22. R9.8.7: That R9.8.7 be amended to delete reference to accessory buildings, as per Page 31 of this submission.

23. R9.8.7: That R9.8.7 be amended to make activities under this rule a non-complying activity, as per Page 31 of this submission.

24. R9.8.7(c): That 9.8.7(c) be amended to delete the phrase including predicted wind farm noise levels, as per Page 31 of this submission.

25. R9.11: That R9.11 be amended to clarify that Wind Farm noise is governed by R9.8.6 rather than R9.11.

26. That such other changes as are necessary to give effect to this submission are made.

Submission Number

Plan Change Number


SO62 15A 15D

S4 Definitions S7 Subdivision S9 Rural S22 Natural Hazards

Higgins Aggregates Limited

Andrew Bashford Good Earth Matters Consulting Ltd 56 Queen Street Private Bag 1268 PALMERSTON NORTH 4440

YES

Submission: The submitter is concerned the PPC15A-H places obstacles in the way of new quarries in aggregate-rich locations and that reverse sensitivity is not recognised for existing quarries. This is despite Horizons One Plan’s Chapter Five recognising the region’s economic benefit from the use of gravel resources. The submitter states that they have experienced difficulties in the past with activities regarded as Earthworks. The submitter supports in part the intent of performance standard 7.15.2.1(1)(a) to avoid occupied structures from being established within the Flood Protection Zone. The submitter opposes the definition of Occupied Structure insofar as it includes places of work. The submitter has and will require future site offices and other structures in the Flood Protection Zone which are occupied for work related activities. The submitter therefore requests that the reference to work be removed from the definition of Occupied Structure or Activity. The submitter supports bullet point eight under S7.1 Introduction - The Effects of Subdivision. The submitter supports the following wording under the Explanation of 7.2 Resource Management Issue 1:


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... Management of reverse sensitivity effects associated with complaints from new sensitive land uses located in proximity to existing, lawfully established activities or operations. In relation to the explanation of 7.2 Resource Management Issue 4, the submitter notes that Te Matai Road area is also a significant gravel extraction and processing asset. The submitter supports the following wording under the Explanation of 7.2 Resource Management Issue 5: Reverse sensitivity effects are also recognised in the Plan in relation to the Palmerston North Airport and other significant regional and district infrastructure and nearby residential activities (including such activities in the Rural Zone). Reverse sensitivity issues should be avoided or mitigated at the time of subdivision consent through the imposition of conditions or the decline of consent. The submitter is concerned that the definition of Production Land excludes land used for the ‘mining of minerals’, meaning that quarrying is not considered to be production land. The submitter requests that the recognition of quarrying activities on production land be provided for within the Plan objectives and policies, particularly within Objective 3 and Policies 3.2(a), 3.2(a)(vi) and 3.3. The submitter supports Policy 3.5(n) and the recognition of reverse sensitivity under Policies 3.2(a)(iii). The submitter requests that quarrying activities be included under R7.15.2.1(1). The submitter requests that Quarrying Activities be included under performance standards 7.16.1.2(e) and 7.16.2.1(e). The submitter supports Assessment Criteria 7.16.2.1(a)(iii) in relation to reverse sensitivity. The submitter considers that the mention of industries based on natural resources such as gravel within S9.1 Introduction insufficiently recognises the industry. The submitter requests that quarrying activities be provided for within the policies under Objective 2. In relation to Policy 2.1, the submitter is concerned that it is unlikely that the effects of quarrying activities on versatile soils can be avoided, remedied, or mitigated, yet this is often where the aggregate resource is located. The submitter requests that there be explicit provisions relating to reverse sensitivity from dwellings establishing near existing quarrying sites. The submitter requests that Quarrying be provided for as a Restricted Discretionary Activity in the Rural Zone, rather than a Discretionary Activity. The submitter states that the effects of quarrying are well known and a limited matters such as noise, dust, visual effects, and vehicle movements. The submitter opposes Assessment Criteria (i) under R9.8.3, requesting that is be deleted. The submitter states that aggregate sources often coincide with Class 1 and 2 soils and it is often not possible to retain the productive capability of the land for typical agricultural uses. The submitter requests that Quarrying be considered a Restricted Discretionary Activity under R22.7.2.1(i), with the extent to which any exacerbation of flooding hazard associated with neighbouring sites is avoided, remedied, or mitigated being an additional Assessment Criterion. The submitter requests that Concrete Manufacturing be reinstated as a Discretionary Activity under R22.7.8.2.1(ii), as the submitter states: 1. There does not appear to be any good reason for escalating the activity status to non-complying. 2. There is a need for concrete manufacturing to be undertaken near its source to reduce double handling and transportation costs. 3. Batching plants are non-habitable structures and flood risk is managed accordingly for these sites. Decisions Requested:

1. S4: That the sentence Earthworks does not include Quarrying be included in the S4 definition of Earthworks, as per Page 7 of this submission.

2. S4: That the reference to work be removed from the definition of Occupied Structure or Activity.

3. S7 Objectives and Policies: That the recognition of quarrying activities on production land be provided for within the Plan objectives and policies, particularly within S7 Objective 3 and Policies 3.2(a), 3.2(a)(vi) and 3.3.

4. R7.15.2.1(1): That quarrying activities be included under R7.15.2.1(1).

5. R7.16.1.2(e) and R7.16.2.1(e): That R7.16.1.2(e) and R7.16.2.1(e) be amended as follows:

(e) Intensive Farming and Quarrying Buffer Zone

No Rural Residential subdivision shall be approved so as to result in a site for a new dwelling within 500 metres of any land or buildings associated with an existing intensive farming or existing intensive pig farming or existing quarrying operation.


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6. S9.1 Introduction: That S9.1 be amended to include the following:

Other industrial-type activities also occur in the rural environment, such as aggregate extraction, which is critical to the functioning of the District.

7. S9 Policy 2.1: That S9 Policy 2.1 be amended as follows:

To enable primary production activities and other associated rural based land uses, such as quarrying, to function efficiently and effectively in the Rural Zone, while minimising To avoid, remedy or mitigate the adverse effects of activities on land of high productive capability and versatile soils.

8. R9.5.5(b)(i): That an additional clause (consistent with performance standards 7.16.1.2(e) and 7.16.2.1(e)) be included under R9.5.5(b)(i) as follows:

(b) Separation Distances (i) Any No residential building shall be located not less than:

(a) 10 metres away from a front boundary; (b) 5 metres from any other boundary. (c) 1.5km from the location of any wind turbine on a site for which a Wind farm resource consent application has been

granted. (d) 500 metres from any existing quarry site or site for which a quarrying resource consent application has been granted.

9. R9.8.3: That Quarrying be regarded as a Restricted Discretionary Activity in the Rural Zone.

10. R9.8.3: That Assessment Criteria (i) be deleted from R9.8.3.

11. R22.7.2.1(i): That Quarrying Activities be considered a Restricted Discretionary Activity in the Flood Protection Zone.

12. R22.7.8.2.1(ii): That Concrete Manufacturing Activities be considered a Discretionary Activity in the Flood Protection Zone.

13. That any consequential amendments are made to give effect to this submission. Submission Number

Plan Change Number


SO63 15E S7 Subdivision S12A NEIZ S23 Utilities

Vector Gas Limited Gill Robertson Vector Limited Private Bag 2020 NEW PLYMOUTH 4342

YES

Submission: The submitter has requested a number of changes to Plan Change 15A-H. Changes relate to alignment with the One Plan, and amendments to S7 Subdivision, S23 Utilities and S12A North East Industrial Zone. The submitter is concerned that subdivision provisions for the NEIZ Extension Area do not provide development standards or assessment criteria for the subdivision of land in proximity to gas transmission pipelines within the NEIZ Extension Area.

Third party interference is one of the main risks to the safety and integrity of underground pipelines. The submitter generally supports the Resource Management Issues identified in the NEIZ but would like a statement providing for the ongoing operation and maintenance of existing infrastructure.

Decisions Requested: 1. S7.1: Amend bullet point 6 in The Effects of Subdivision in S7.1 Introduction to read as follows:

The effects of subdivision include:…

Effects on the safe and efficient functioning of network utilities, particularly existing Regionally Significant Infrastructure such as the National Grid.…

2. S7.3 Policy 3.1(h): Amend S7 Policy 3.1(h) to incorporate gas transmission pipelines as follows:

To enable the subdivision of rural land into allotments of 20 hectares or more, where the following matters have been recognised and provided for:…

(h) setbacks from high voltage electricity transmission lines and gas transmission pipelines.

3. R7.9.2.1(a)(iii): The submitter requests the insertion of an additional performance standard into subdivision R7.9.2.1(a)(iii) as follows:


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(k) Evidence of consultation with Vector Gas Limited ensuring that the gas transmission pipeline corridor is adequately protected from interference.

4. R7.9.2.1(a): The submitter requests the insertion of an additional assessment criteria into subdivision R7.9.2.1(a) as follows: (xi) The extent to which the proposed subdivision provides for the ongoing operation and maintenance of the gas transmission pipeline.

5. S23.3 Policy 3.5: Amend S23 Policy 3.5 to read as follows:

To encourage the co-location of structures and sharing of network utility channels and corridors, where this is operationally feasible, to enable the efficient construction, installation, operation, upgrading and maintenance of network utilities, and to reduce their potentially adverse visual effects on the environment.

Subject to this amendment the submitter recommends that the Objectives and Policies in S23 PPC15G are adopted in a form that retains their current intent and balance.

6. R23.7.1: That R23.7.1 be amended to provide for the operation, maintenance and minor upgrading of a gas transmission pipeline and associated facilities and seeks the following insertion in R23.7.1:

R 23.7.1 Permitted Activities…

(vi) The operation, maintenance and minor upgrade of pipelines and incidental equipment for the transmission of natural gas.…

7. R23.10.1: That R23.10.1 be amended so that the establishment, installation and construction of all gas transmission pipelines and associated facilities be provided for as a Discretionary Activity by amending R23.10.1 as follows:

R 23.10.1 Discretionary Activities

Excluding the operation, maintenance, and minor upgrading of gas transmission pipelines and the operation, maintenance, upgrading, relocation or removal of existing transmission lines specified in regulation 4 of the Resource Management (National Environmental Standards for Electricity transmission Activities) Regulations 2009, and covered by that NES; the construction, operation, alteration or addition the following structures are Discretionary Activities throughout the City:

8. R23.7.1(g): That the Reinstatement Performance Standard in R23.7.1(g) be amended as follows:

(g) Reinstatement

Where the construction or maintenance of a network utility involves disturbance to the ground, at the completion of the work the ground shall be reinstated as close as practicable to the condition existing prior to commencement of the work in consultation with any affected parties.

9. Appendix 2: Planning Maps: That the gas transmission pipelines be included on the Planning Maps as Regionally Significant Infrastructure.

10. S12A.2: The submitter requests a new issue be included in S12A.2 NEIZ Resource Management Issues as follows:

14. The need to minimise potential for conflicts such as reverse sensitivity with existing gas infrastructure resources and other regionally significant infrastructure.

11. R12A.4.1: The submitter requests the insertion of an additional performance standard in permitted activity R12A.4.1 as follows: (o) Proximity to Gas Transmission Pipeline

No buildings, structures or trees / plants are located within 20m of a gas transmission line. Extent of earthworks: Whether the necessary safeguards are in place to ensure that adequate protection of the pipeline is in place, including whether an adequate depth of cover is maintained over the pipeline or excessive loading over the pipeline. It is recommended that there is no cut / fill over the gas pipeline unless written consent from the network utility operator has been obtained.

12. That all consequential/detailed amendments to give effect to the above are effected.


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Submission Number

Plan Change Number


SO64 PC15A-H S4 Definitions S9 Rural Zone

House Movers Section of NZ Heavy Haulage Assn (Inc)

Rowan Ashton Stuart Ryan, Barrister PO Box 1296 Shortland Street AUCKLAND 1140

YES

Submission: The submitter opposes Rule 9.7.3 and proposed treatment of relocated buildings as a Controlled Activity. It is submitted that the activity classification does not reflect the Central Otago decision. The submission states:

- The proposed rule doesn’t expressly provide for removal (from site) and re-siting (within a site) of buildnigs. These activities should be expressly provided as Permitted Activities, and

- It does not meet the aims of the Resource Management Act:: - The classification of removal, re-siting and re-location of building is inconsistent with/contrary to S 5 of the RMA, and

Part 2 of the Act , generally. - It is inconsistent with sustainable management to require resource consent for removal, re-siting and relocation of

buildings, but to provide for new buildings as a Permitted Activity. - Relocation of buildings is an affordable housing. Construction option and consistent with sustainable management

by providing for the recycling and reuse of materials. Activity classification should take into account the positive effects from activities.

- Controls on the removal, re-siting and relocation of buildings in the proposed plan are not necessary to assist Council to carry out its duties.

- Controls on the removal, re-siting and relocation of buildings in the proposed plan do not meet s 32 criteria of RMA. - Controls in the plan on the removal, re-siting and relocation of buildings are inconsistent with the criteria in S 75 and

76 of the Act. - Controls in the plan on the removal, re-siting and relocation of buildings are not proportionate to controls on new

dwellings and building in the plan. - In practical terms, any potential adverse effect on amenity values from building relocation is remedied after an initial

establishment period. The same establishment period is present whenever a new dwelling is constructed, and whereas the council has not generally promoted similar controls for new dwellings.

- The proposed plan fails to apply the decision of the Environment Court in New Zealand Heavy Haulage Association Inc v The Central Otago District Council (Environment Court, C45/2004, Thompson EJ presiding).

- The proposed Plan does not recognise the transaction costs of not expressly exempting relocation and removal of buildings from any requirement to obtain neighbour approval.

- The submitter pleads the reasons given by the Court in New Zealand Heavy Haulage Association Inc v The Central Otago District Council.


1. Rewrite the rural section, its policies and objectives, rules, methods and reasons to reflect the reasons for this submission.

2. Delete all provisions (including objectives, policies, rules, assessment criteria and other methods and reasons) on removal, re-siting, and relocation of buildings in the rural section, the definitions section and elsewhere.

3. Amend the Definitions section of the Plan to accord with the trade practice and usage so as to distinguish between activities of removal, re-siting, and relocation of dwellings and buildings.

4. Recognise in the objectives, policies and rules, and methods of the plan the need to provide for the coordination between Building Act and Resource Management Act, to avoid regulatory duplication.

5. Expressly provide in the proposed plan (whether in definitions or in the activity rules) for the demolition and removal and re-siting of buildings as a permitted activity in all areas and zones, except in relation to any scheduled identified heritage buildings, or any property established conservation heritage precinct.

6. In the event that demolition and removal and re-siting of buildings is not a permitted activity (as provided for in paragraph 11 above), then as a default rule, provide for relocation of dwellings and buildings no more restrictively than a restricted controlled activity, provided that such application be expressly provided for on a non-notified, non- service basis.

7. Replace policy provisions relating to relocated dwellings and buildings (either by rewriting the plan, or alternatively, by deleting the relevant sections and replacing the provisions in each section or zone of the plan, as is appropriate) with objectives, policies, rules,


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assessment criteria, methods, reasons and other provisions which expressly provide for relocation of buildings as “permitted activities’ in all zones/areas, so as to achieve performance standards no more restrictive that provide for in paragraph 15 below.

“Relocation of Buildings Relocated buildings are permitted where the following matters can be satisfied:

a) Any relocated building can comply with the relevant standards for Permitted Activities in the District Plan; b) Any relocated dwelling must have been previously designed built and used as a dwelling; c) A building inspection report shall accompany the building consent for the building/dwelling. The report is to identify all

reinstatement work required to the exterior of the building/dwelling; and d) The building shall be located on permanent foundations approved by building consent, no later than [2] months of the

building being moved to the site. e) All work required to reinstate the exterior of any relocated building/ dwelling, including the siting of the building/ dwelling

on permanent foundations, shall be completed within 12 months of the building being delivered to the site.”

8. As a default rule, in the event that relocation of a building/dwelling is not a permitted activity (as provided for in paragraph 18 and 19 above) due to non-compliance with performance standards, provide for relocation of dwellings and buildings no more restrictively than a restricted discretionary activity (provide that such application be expressly provided for on a non-notified, non-service basis) subject to the following assessment criteria (to to the same or similar effect):

“Restricted Discretionary Activity (on a non- notified, non-service basis) Where an activity is not permitted by this Rule, Council will have regard to the following matters when considering an application for resource consent: i) Proposed landscaping; ii) The proposed timetable for completion of the work required to reinstate the exterior of the building and connections to

services; iii) The appearance of the building following reinstatement.”

9. Delete any provisions for a performance bond or restrictive covenants for the removal, re-siting, and relocation of dwellings and

buildings.

10. Make any consequential amendments to give effect to this submission, including such amendments as required to the provisions, definitions, other matters, rules, objectives, policies and reasons of the proposed plan to give appropriate recognition to the positive effects of removal;, re-siting, and relocation of dwellings and buildings, in accordance with the reasons for this submission, and the relief sought as a whole.

11. Suggested drafting to give effect to this submission is attached as Schedule 1 and a suggested pre-inspection report is attached as Schedule 2.

Submission Number

Plan Change Number


SO65 15B S7 Subdivision S9 Rural Zone Appendix 2: Planning Maps

Maurice R Alley Maurice R Alley 45 Atawhai Road PALMERSTON NORTH

NO

Submission: The submitter opposes 494 and 514 Pahiatua Track not being included in the Rural Residential Overlay. The submitter states that there is no explanation for this exclusion, given that the topography, elevation, and access in the same to neighbouring properties within the overlay. The submitter opposes the Wind Farm provisions under PPC15B for the following reasons: 1. Wind Farm noise is not heard at the submitter's property at 494 Pahiatua Track, within 1km of the nearest turbine. 2. Adverse health effects resulting from wind turbines are due to the "nocebo effect". The submitter has included a web-link to literature which supports the submitter's statement on Page 2 of this submission. 3. The designation of outstanding natural features is subjective, with landscape architects disagreeing in the assessment of these features. 4. Surveys have shown that most Palmerston North residents enjoy the sight of turbines on their skyline, with very few objections. 5. The submitter states that they have to obtain consent for a wind turbine, when their neighbour can place an "ugly barn and wrecked cars in my full view with impunity." 6. The submitter states that PNCC has a responsibility to promote local sustainable energy development and fight climate change.


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1. Planning Map 40: That 494 and 514 Pahiatua Track is included in the Rural Residential Overlay.

2. Planning Map 40: That allowance is made for 494 and 514 Pahiatua Track to install wind turbines.

3. SS7 & 9: That PPC15B be re drafted to promote wind energy in light of this submission.

Submission Number

Plan Change Number


SO66 15A-H Proarch Consultants Ltd

Amanda Coats 306 Church Street West PO Box 1105 PALMERSTON NORTH 4440

YES

Submission: The submitter opposes aspects in PPC15A-H which are likely to make Resource Consent processes under the plan wording more onerous, costly and complex in delivery for their current and future clients. The submitter is concerned about the servicing of newly zoned land, economic effects and visual effects of PPC15A-H. Decision Requested:

1. 15A-H: That PPC15A-H is worded to avoid onerous, costly and complex resource consent processes, and achieves sustainable management.

Submission Number

Plan Change Number



Peter H Allen Peter H Allen 324 Ngahere Park Road RD2 PALMERSTON NORTH 4472

YES

Submission: The submitter opposes the change in the minimum rural subdivision lot size from 4ha to 20ha under Rule 7.16.1.2(b), as it will affect the submitter’s right to subdivide their property at 324 Ngahere Park Road. The submitter states that the property’s contours would lend itself to subdividing the property into two approximately 2ha lots. The submitter states that the traffic effects of one extra dwelling within the current lot at 324 Ngahere Park Road would be nil, as it is intended for use by the submitter’s son who already resides on-site. Decision Requested:

1. Planning Map 45, Rule 7.16.1.2(b) and Rule 7.16.2.1: That the submitter’s right to subdivide 324 Ngahere Park Road into two titles is preserved.

Submission Number

Plan Change Number


SO68 15H S13 Airport Zone Appendix 2: Planning Maps

William M Kelly & Diane H Simpson

William M Kelly & Diane H Simpson 134 Midhurst Street RD10 PALMERSTON NORTH

YES

Submission: The submitter opposes the inclusion of their property at 134 Midhurst Street in the Runway End Protection Area. Decisions Requested:

1. Planning Map 13: To not impose the Runway End Protection Area on 134 Midhurst Street.

2. S13 Map 13.2: If the Runway End Protection Area is imposed, that the submitter be compensated for the loss of property rights through either compensation paid or the property being purchased.


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Submission Number

Plan Change Number


SO69 15A-H 15E

S7 Subdivision S12A NEIZ

Pita & Helen Kinaston

Pita & Helen Kinaston 824A Roberts Line RD8 PALMERSTON NORTH 4478

YES

Submission: Currently the area is zoned rural and fits with the values the submitter sought when purchasing their property in this location. The submitter is concerned that the rural amenity of the area will be totally changed by the proposed industrial rezoning.

The submitter does see how objectives and policies of the NEIZ (Objective 5 and Policy 5.2) that seek to ensure adverse effects on rural amenity values of the area will be avoided or mitigated by the proposal.

The submitter is concerned about increased road traffic and resultant noise having an adverse effect on rural residents. The plan change does not against this effect.

The submitter feels the proposed buffer zones of 10 metres are insufficient to provide visual amenity for surrounding rural properties.

The submitter is concerned about the increase in noise levels during the construction phase of development from both construction and from increased road use by construction companies.

The submitter’s property is potentially affected by all the stormwater from the proposed industrial area. The plan change is unclear as to how stormwater will be managed. There is the potential for inappropriate management of stormwater and an adverse impact on the stream that runs through the submitter’s property.

The submitter notes that new Rule 12A.6.2(h), Servicing and Loading Hours, restricts loading to between 6am and 10pm if an industrial activity is within 80 metres of an existing dwelling. This does not fit with the current amenity of the area.

Essential services assessment criteria (k) in Rule 12A.6.2 makes no mention of wastewater or water services being offered to nearby rural properties. Decisions Requested:

1. PPC15A-H: The submitter requests the Council to not go ahead with the plan change.

2. S12A: The submitter requests buffer zones of 25 to 50 metres, depending on how close a dwelling is to an industrial development. If for example a dwelling is within 100 metres of an industrial boundary a 50 metre buffer zone would be required and 25 metres if the boundary was more than 100 metres from a dwelling.

3. As a potential off-set for the loss of amenity values the submitter requests that Council’s reticulated wastewater and water services

are offered to nearby rural properties.

4. R12A.10.1: In respect of noise R12A.10.1, the submitter requests that the measure of noise should be from the boundary fence of a dwelling not at the notional boundary which the rule states is 20 metres from the dwelling.


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Submission Number

Plan Change Number


SO70 15A-H 15B

S9 Rural Zone Appendix 2: Planning Maps Appendix 4.2 Section 32 Report

John & Kathy Love

John & Kathy Love 132 Greens Road RD2 PALMERSTON NORTH 4472

YES

Submission: The submitter is concerned that the level of detail and analysis of benefits and costs in the Section 32 Report is inadequate and cannot be relied upon for decision-making. The submitter is concerned that this is also the case in some of the technical reports. The submitter rejects PPC15B. The submitter states that general set back rules in relation to Wind Farms do not take into account the variables that are different in each application, particularly affected parties, their reasons for opposing/supporting the proposal, opponent's location relative to the proposal, topography, turbine specifications, wind conditions, and expert evidence. The submitter states that despite the 1.5km and 700m setback rules, a Wind Farm may still be approved as a Non-complying activity, providing no certainty to neighbouring properties. The submitter states that since 2000 the District Plan identified that Wind Farms were to be assessed on their individual merits. The submitter states there are no legal cases supporting the approach that the 1.5km setback rule has taken with regards to mitigating reverse sensitivity effects. Conversely, the submitter states that there are no provisions addressing reverse sensitivity effects of quarrying and yet there have been many legal challenges to quarries in New Zealand. The submitter states that there is ample evidence to suggest that people are willing to live within 1.5km of turbines. The submitter states that the 1.5km setback rule is a method for restricting residential development in the rural area rather than a method for mitigating reverse sensitivity effects. The submitter states that the old Motorimu site is the only possible Wind Farm Site left in the Rural Zone. The submitter states that there is no need for greater direction in the District Plan if "a full and comprehensive assessment of a proposed Wind Farm" is undertaken under R9.10.3. The submitter states that R9.8.6 is negative. The submitter suggests that R9.8.6 Assessment Criteria (n) and (o) should be change to (a) and (b). The submitter suggests that the District Plan should highlight possible areas likely for Wind Farms, to avoid surprises for landowners. The submitter states that there is no supporting evidence for the inclusion of the submitter's land on Planning Maps 45 and 49 and the Waters' land beside Turitea Road in the ONL Boundary in Appendix 4.2 Landscape Management Palmerston North City 2013 Report. The submitter states that theses landscapes are man-made and not outstanding. The submitter notes that part of their land is already protected by a QEII Trust Covenant. Decisions Requested:

1. R9.5.5(b)(i)(c): That R9.5.5(b)(i)(c) is deleted from the Plan.

2. R9.9.6: That Assessment Criteria (n) and (o) under R9.9.6 be moved to (a) and (b).

3. Appendix 2: Planning Maps: That areas where Wind Farms are possible to develop are identified under the Plan.

4. Planning Maps 45 & 49: That part of the submitter's land not protected by a QEII Trust Covenant be removed from the ONL boundary.


126

Submission Number

Plan Change Number


SO71 15A 15C 15D 15E

S7 Subdivision S12A NEIZ S22 Natural Hazards Appendix 2: Planning Maps

FJ & Estate of B Setter/Frederick J Setter

FJ & Estate of B Setter/Frederick J Setter 718 Rangitikei Line RD5 PALMERSTON NORTH

YES

Submission: The submitter opposes R7.16.1.2(b)(i), as they are concerned that a 20ha lot area minimum is too restrictive. The submitter owns a 19ha lot and is concerned that they would not be able to subdivide it into smaller lots. The submitter raises an issue concerning stormwater run-off from the proposed NEIZ Extension Area to the Mangaone Stream. The submitter asks who is going to be responsible for the Watercourse Reserve Areas after buildings are finished? The submitter opposes the identification of 718 Rangitikei Line as flood prone land. The submitter notes that Horizons has confirmed that an upgrade of the Mangaone Stopbanks during the financial year 2015-2016 is planned to protect this property to at least a 1 in 200 year flood event. Decisions Requested:

1. R7.16.1.2(b)(i): That R7.16.1.2(b)(i) be amended to reinstate the 4ha minimum lot area.

2. S12A: The submitter requests doing away with the detention areas (Watercourse Reserve Areas) and leaving stormwater management to the developer to present a plan.

3. Planning Map 12: That 718 Rangitikei Line be declassified from flood prone land after Horizons' Mangaone Stopbank upgrades are

complete. Submission Number

Plan Change Number


SO72 15A 15B 15E

S9 Rural Zone S12A NEIZ

Anne J Milne Anne J Milne 63 Sutherland Road RD9 PALMERSTON NORTH 4479

YES

Submission: The submitter supports S9 Policies 3.1-3.5 and associated provisions, as they recognise the importance of the City's production soils. The submitter also supports these policies applying to the boundary change area. The submitter supports Alison Mildon's (SO77) original submission relating to PPC15B. The submitter states that tighter rules for Wind Farms to protect the skyline, amenity values, and avoid cumulative effects are necessary. The submitter supports any moves to control runoff from the NEIZ, specifically S12A Policies 5.8-5.11. The submitter states that any added stormwater to the Mangaone Stream has downstream effects on other landowners. Decisions Requested:

1. S9 Policies 3.1-3.5: That S9 Policies 3.1-3.5 and associated provisions are retained.

2. PPC15B: That consideration is given to Alison Mildon's (SO77) submission relating to Wind Farm and landscape issues.

3. S12A Policies 5.8-5.11: That S12A Policies 5.8-5.11 be retained.


127

Submission Number

Plan Change Number



Selwyn Wycherley Selwyn Wycherley 1338 Napier Road ASHHURST

YES

Submission: The submitter requests the inclusion of Ashhurst South (Planning Map 10) in the Rural Residential Overlay, as the submitter states that it is close to amenities, is class three soil, is easy to develop and service, has attracted the interest of a motelier, and would fit within the village area of Ashhurst. The submission notes that sewer lines and a river walkway were allowed to be developed through the submitter’s land through the goodwill of the owner. Decision Requested:

1. Planning Map 10, Rule 7.16.1.2(b) and Rule 7.16.2.1: That Ashhurst South be included in the Rural Residential Overlay. Submission Number

Plan Change Number



John W Stephenson John W Stephenson 111 Henaghans Road Whakarongo, RD10 PALMERSTON NORTH 4470

YES

Submission: The submitter opposes the 20ha minimum rural subdivision lot size proposed under Rule 7.16.1.2(b), as the submitter states that it is too restrictive. The submitter states that this is especially in the case of the area bounded by Henaghans Road, Handersons Line, Hazelhurst Line and Stoney Creek Road, where the land is in current proximity to consented lifestyle bocks and is class three soils. The submitter requests that That the area bounded by properties on the Henaghans Road, Hendersons Line, Hazelhurst Line, Stoney Creek Road (excluding the Stoney Creek flood plain) be included in the Rural Residential Overlay, as it is compatible with the thinking around PPC15A. The submitter provides annotated photos on Pages 4-5, and previous submissions, maps, and expert evidence on Pages 6-15 of this submission. Decision Requested:

1. Planning Maps 8 & 14, Rule 7.16.1.2(b) and Rule 7.16.2.1: That the area bounded by properties on the Henaghans Road, Hendersons Line, Hazelhurst Line, Stoney Creek Road (excluding the Stoney Creek flood plain) be included in the Rural Residential Overlay.

Submission Number

Plan Change Number


SO75 15A S7 Subdivision S9 Rural Zone Appendix 2: Planning Map 20

Matthew Ellingham – Matvin Property Ltd

Holly Jenkins Kevin O’Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter opposes Planning Map 20 and the rural zoning of their property (4.8731 ha) located at the corner of Napier Road and Roberts Line. It is submitted that the land be rezoned to Local Business or alternatively, the land is specified as a rural site where local business activities are a Discretionary Activity. The submitter states that rezoning the land as local business or similar would allow for possible future development of a commercial nature, on the site. It is submitted that the site would continue to fit into the surrounding environment. It is noted that within the immediate vicinity of the site, along Napier Road, there are already a number of different activities being carried out eg, residential, landscaping company and a large garden centre. The submission notes that under the District Plan rules for land zoned as Local Business, commercial activities are a Discretionary Activity, however, commercial activities are considered non-complying in the rural zone.


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It is submitted that Council could consider this strip of rural land along Napier Road as orphan from the other mixed zones in the area, and rezone appropriately. It is further submitted that rezoning this land to local business is appropriate due to the small area of land further up Roberts Line (Countdown site) which is similar to that of the subject site, in that the surrounding area are mostly residential and industrial. Decision Requested:

1. Rezone 1 Roberts Line PT Lots 1-3 of Sec 418 Town of Palmerston North, from Rural to Local Business, or have the site specifically established for local business as a discretionary activity.

Submission Number

Plan Change Number


SO76 15A Appendix 2: Planning Map Stu Waters Holly Jenkins Kevin O’Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter supports the inclusion of the front 43ha of their land at 266 Turitea Road being included in the Rural Residential Overlay. The submitter requests that the remaining 48ha at 266 Turitea Road be included in the Rural Residential Overlay, as that portion of the site has the same topography, access, and soil type as the front 43ha portion. The submitter has included maps of the land in question on Page 4 of this submission. The full inclusion of 266 Turitea Road as Rural Residential would allow for a comprehensive design of the overall area to be implemented. Decision Requested:

1. Planning Map 39, Rule 7.16.1.2(b) and Rule 7.16.2.1: That the remaining 48ha at 266 Turitea Road not currently included in the Rural Residential Overlay be included in the Rural Residential Overlay.

Submission Number

Plan Change Number


SO77 15A 15B

S4 Definitions S7 Subdivision S9 Rural Zone Section 32 Report

Alison M Mildon Alison M Mildon 346 Millricks Line RD2 PALMERSTON NORTH

YES

Submission: The submitter states that S4 requires a definition for 'Significant Amenity Landscape'. The submitter supports S7 Objectives 2-4 and 7 and associated policies, and S9 Objectives 1-2 and associated policies, as they highlight the protection of productive units of land for local, regional, and national significance. The submitter is concerned that there is no rule of equal distance to R9.5.5(b)(i)(c) and R7.16.1.2(g) to protect landowners from proposed Wind Farms. The submitter is concerned that adverse environmental effects from Wind Farms on people is not adequately addressed under 9.2 Resource Management Issues, as people form part of the environment. The submitter is concerned that issues arising from future energy technologies other than Wind Farms are not being addressed under S9.2. The submitter is concerned that S9.2 Resource Management Issue 13 assumes significant benefits from renewable energy generation activities, when this may not always be the case. The submitter is concerned that S9.2 Resource Management Issue 14 is not clear whether it is referring to existing and proposed Wind Farms, or just existing. The submitter supports S9 Objective 1 and associated policies, as it is important that sustainable units of productive land are protected from non-productive activities. The submitter supports S9 Objective 2 and associated policies. The submitter supports S9 Objective 3.


129

The submitter suggests that amendment to Policy 3.5 is required to give effect to the meaning and intent of One Plan Policy 6-6. The submitter states that Wind Farms being a Discretionary Activity on Te Mata Peak and the Te Mata-Kaihinu Ridgeline under R9.8.6(j) is a misinterpretation of One Plan Policy 6-6. The submitter states that this should be a non-complying activity. The submitter states that the use of the word 'within' must not be used in provisions where significant adverse cumulative or other adverse effects could be produced from developed located outside mapped boundaries. The submitter supports S9 Objective 4. The submitter states that Policy 7.2 is intended to protect the values and characteristics of the TRLPA regardless of the source of the adverse effect, so suggests that the word 'within' be removed from Policy 7.2. The submitter recommends that paragraph 5 of S9 Objective 7 Explanation needs to be amended to change 'is' to 'are' after ‘visual and landscape values of the Tararua Ranges Landscape Protection Area’. The submitter is concerned that paragraph 6 of S9 Objective 7 does not adequately give effect to One Plan Policy 6-6, as it allows Wind Farm development located outside the boundaries of the TRLPA regardless of whether the development will create adverse effects within the TRLPA. The submitter supports S9 Objective 9 & associated policies. The submitter supports R9.7.5. The submitter supports R9.8.2. The submitter suggests the addition of 'or part thereof' after 'Wind Farm Site' under R9.8.6(i) to enhance the clarity of this performance standard. The submitter is concerned that S2.3.27 of the Section 32 Report does not adequately reference the "expert advice" used to substantiate the 700m setback rule under R9.8.6(ii). The submitter states R9.8.6(ii) is a crude measure, as the effectiveness of this setback is dependent on the height of the turbine. The submitter notes that wind turbines are not a homogenous height and are becoming increasingly taller, making the 700m setback negligible. The submitter states that under R9.8.6(ii) a proposed turbine could be located less than 700m from a consenting landowner, or be placed just over 700m from the boundary of a neighbouring non-consenting property. The submitter suggests that a new Assessment Criterion be included under R9.8.6 to require the applicant to cover decommissioning costs for unused wind turbines, and methods to ensure that there is money to cover these costs should the company go into receivership. The submitter notes that the test wind towers erected by the Motorimu Wind Farm applicant are still in place years after the surrender of their consent. The submitter states that the ratepayer should not be responsible and applicants should not be allowed to clutter the environment. The submitter states that R9.9.3 is not fully consistent with Policy 6-6. The submitter suggests that paragraph two of R9.9.3 Explanation be amended to clarify that development beyond the TRLPA that has significant adverse cumulative and other effects on the characteristics and values of the TRLPA would not meet the Performance Standards and become a non-complying activity. Decisions Requested:

1. S4: That S4 be amended to include a definition for 'Significant Amenity Landscape'.

2. S7.3 Objectives 2-4 & 7 & associated policies, & S9.3 Objectives 1-2 & associated policies: That S7 Objectives 2-4 and 7 and associated policies, and S9 Objectives 1-2 and associated policies are retained.

3. PPC15B: That a rule requiring a proposed Wind Farm to locate no closer than 1500m from an existing residence or residential site

is adopted under PPC15B.

4. S9.2 Resource Management Issues: That S9.2 includes Resource Management Issues addressing: 1. Adverse effects of turbines. 2. Adverse effects of associated transmission network infrastructure (poles, pylons and cables). 3. Effects of Wind Farm development on visual and aural amenity, health and well-being. 4. High costs (not just financial) to individuals and ratepayers to fix or fail to fix poor outcomes of planning decisions. 5. 'The potential adverse effect arising from the exploration, investigation, installation, operation, upgrading or decommissioning of energy related facilities and associated transmission networks.'

5. S9.2 Resource Management Issue 13: That S9.2 Resource Management Issue 13 be amended to read as follows:

The need to recognise and provide for the significant benefits of renewable energy generation activities (at commercial and


130

domestic scales) where benefits would be significant, whilst avoiding, remedying or mitigating adverse effects.

6. S9.2 Resource Management Issue 14: That S9.2 Resource Management Issue 14 be amended to insert the phrase existing and consented before Wind Farms.

7. S9.3 Objective 1 and associated policies: That S9 Objective 1 and associated policies are retained.

8. S9.3 Objective 2 and associated policies: That S9 Objective 2 and associated policies are retained.

9. S9.3 Objective 3: That S9 Objective 3 is retained.

10. S9.3 Policy 3.5: That S9 Policy 3.5 be amended to insert the phrase values and characteristics of before regionally Outstanding Natural Features and Landscapes.

11. R9.8.6(j): That Wind Farms on Te Mata Peak and the Te Mata-Kaihinu Ridgeline under R9.8.6 Assessment Criterion (j) be

escalated to non-complying activity status.

12. Section 32 Report: That notes 1-10 (on Page 6-7 of this submission) be appended to the Section 32 Report, specifically: P.94 2.3.26; P.96 2.3.36; P.98 7.16.3.2; P.102 2.3.59; P.104 7.16.3.2; P.213 Effectiveness; P.223 C.; P.227 B.; P.324 Policies Evaluation of Efficiency and Effectiveness; P.328-9; P.551 5.3.10.

13. S9.3 Objective 4: That S9 Objective 4 is retained.

14. S9.3 Policy 7.2: That S9 Policy 7.2 reads as follows:

7.2 To control land use and development within the Tararua Ranges Landscape Protection Area (Map 91.) to protect the characteristics values and values characteristics of the Tararua Ranges and the Manawatu Gorge Outstanding Natural Features and Landscapes [Tararua Ranges Landscape Protection Area (Map 9.1)].

15. S9.3 Objective 7 Explanation: That S9 Objective 7 Explanation paragraph 5 is amended to read as follows: The visual and landscape values of the Tararua Ranges Landscape Protection Area is are...

16. S9.9: That Wind Farm development in the Rural Zone located outside of the TRLPA that are creating significant adverse effects or other effects on the values and characteristics of the TRLPA be considered a non-complying activity.

17. S9.3 Objective 9 & associated policies: That S9 Objective 9 & associated policies be retained.

18. R9.7.5: That R9.7.5 Domestic Wind Turbine is retained.

19. R9.8.2: That R9.8.2 Sawmills and Rural Industries is retained.

20. R9.8.6(i): That R9.8.6(i) is amended to insert or part thereof after Wind Farm Site.

21. S32 Report & R9.8.6(ii): That the Section 32 Report clarify the supporting evidence for R9.8.6(ii).

22. R9.8.6(ii): That a proportional setback rule that addresses turbine height replace R9.8.6(ii).

23. R9.8.6: That R9.8.6 be amended to include a new assessment criterion addressing the decommission costs and responsibilities of the applicant.

24. R9.9.3 Explanation: That paragraph two of R9.9.3 Explanation is amended to include reference to the fact that development

beyond the TRLPA that has significant adverse cumulative and other effects on the characteristics and values of the TRLPA would not meet the Performance Standards and become a non-complying activity.


131

Submission Number

Plan Change Number



Kevin O’Donnell Holly Jenkins Kevin O’Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter owns 25ha of land at the end of O'Donnell Road (Lot 2 DP 412114 and part of Lot 6 DP 324360), shown on Planning Map 12 and Page four of this submission. The submitter requests that the submitter's land remain zoned Rural, but those lots less than 20ha are able to be further subdivided as a Discretionary Activity provided they meet certain provisions. The submitter states that this subdivision would not be inconsistent with the smaller rural and residential properties in proximity to the site. The submitter states that their land is classed at 2-3, which are not optimal for rural activities. Decisions Requested:

1. Planning Map 12: That Lot 2 DP 412114 and Lot 6 DP 324360 be retained as Rural Zone land.

2. S7.7.3: That lots smaller than 20ha in the Rural Zone be provided for subdivision as a Discretionary Activity, provided they meet the following provisions: 1. All access standards 2. Air noise contours 3. Flood mitigation 4. Cannot be Class 1 soils 5. Comply with the One Plan 6. 5000m2 of 11 degree land 7. Must be within 3km of residentially zoned land, and 8. Is not subject to any future urban growth strategies.

Submission Number

Plan Change Number



Alpha Corporation Holly Jenkins Kevin O’Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter requests that the non-flood prone portion of 609 Rangitikei Line, identified on Page 4 of this submission, be rezoned Residential. The submitter states that the subject land is Class 2-3 soils, not optimal for rural activities. The submitter states that residential lots on this land would not be inconsistent with the residential and small rural lots adjacent to the site. The submitter states that if this rezoning request is beyond the scope of PPC15A-H, then they request a rule that provides for subdivision for residential purposes as a Discretionary Activity for the subject land. Decision Requested:

1. Planning Map 19 & S7.7.3: That the 9ha section of 609 Rangitikei Line identified on Page 4 of this submission is rezoned residential. Alternatively, that subdividing the subject land for residential purposes is provided for as a Discretionary Activity.

Submission Number

Plan Change Number



Gavin Terry Holly Jenkins Kevin O’Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

YES

Submission: The submitter owns 6.5ha of land at Lot 1 DP 32009 BLK VI Kairanga SD, shown on Planning Map 12 and Page 4 of this submission. The submitter requests that the submitter's land be rezoned Residential. If this is outside of the scope of PPC15A-H then the submitter requests that the submitter's land be included in the Rural Residential Overlay. If these requests are both considered inappropriate then the submitter requests that a rule is included to provide for lots less than 20ha in the Rural Zone to be further subdivided as a Discretionary Activity provided they meet certain provisions. The submitter states that this subdivision would not be inconsistent with the rural and residential properties in proximity to the site. The submitter states that their land is classed at 2-3, which are not optimal for rural activities.


132

Decision Requested: 1. Planning Map 12 & S7.7.3: That Lot 1 DP 32009 BLK VI Kairanga SD identified on Page 4 of this submission is rezoned

Residential. Alternatively, that the subject land is included under the Rural Residential Overlay. Alternatively, that lots smaller than 20ha in the Rural Zone be provided for subdivision as a Discretionary Activity, provided they meet the following provisions:

1. All access standards 2. Air noise contours 3. Flood mitigation 4. Cannot be Class 1 soils 5. Comply with the One Plan 6. 5000m2 of 11 degree land 7. Must be within 3km of residentially zoned land, and 8. Is not subject to any future urban growth strategies.

Submission Number

Plan Change Number


SO81 15A-H Appendix 2: Planning Maps Shannon & Co. Ltd Tom Shannon 1630 Napier Road RD1 PALMERSTON NORTH

YES

Submission: The submitter owns 100ha at the entrance of the Manawatu Gorge, within Planning Maps 10 & 16. The submitter requests that a unique zone be developed to recognise this site's strategic significance for connecting the Manwatu Gorge, Te Apiti, and "the Park". The submitter has aspirations for using the site as a regional tourism hub for the Gorge area. The submitter notes that the site shares its boundary with DoC, Horizons, and NZTA, and includes 20ha of regenerative native forest, 20ha of woodlots, and the rest is used for ecological pasture. Decision Requested:

1. Planning Maps 10 & 16: That the Council engage with the submitter and other relevant stakeholder to include the submitter's land in a new zone or overlay developed for strategic ecological tourism development in the Te Apiti Area.

Submission Number

Plan Change Number


SO82 15A 15B


Jill White Jill White 276 Aokautere Drive RD1 PALMERSTON NORTH

YES

Submission: The submitter supports S7 Objective 3, bullet points 1 Retains the productive capacity of rural land and 2 Protects class 1 and class 2 versatile soils for use as production land, Resource Management Issue 2, and Objective 2 Policy 1. The submitter states that these provisions are indicative of the importance of the retention of versatile class 1 and 2 soils for production purposes. The submitter opposes R9.9.3 as it would not lead to the protection of ONFL as required under S6(a) and (b) of the RMA, and is inconsistent with One Plan Policy 7-7 and S9 Policy 7.2. Decisions Requested:

1. S7 & S9: That aspects of the Plan that deal with the importance of protection of class 1 and 2 versatile soils for production purposes are retained.

2. R9.9.3: That R9.9.3 be opposed.


133

Submission Number

Plan Change Number


SO83 15A 15B 15F 15H

S4 Definitions S7 Subdivision S9 Rural Zone S13 Airport Zone

Bruce Wilson Bruce Wilson 276 Aokautere Drive RD1 PALMERSTON NORTH

YES

Submission: The submitter cannot see any reason why the use of the word “dairy” is used in (b)(c) & (d) of the S4 Definition of Dairy Related Industrial Activity, and not included in (a) of the Definition. The submitter notes that the spelling of “hangers” under the Definition of Core Airport Precinct is incorrect. The submitter recommends the amendment of the Definition of Mass Assembly of People under Section 4 to indicate that this Definition only applies to the Runway End Protection Area, and not the City at large. The submitter supports the approach taken in S7 and S9 for protecting the productive capacity of the City's versatile soils. The submitter states that the use of the word 'will' in S7 Policy 2.8.5 may confuse plan users. The submitter suggests that more explicit wording in Policy 2.8.5 would be more appropriate. The submitter states that the proposed 1.5km setback distance under R7.16.1.2(g) may meet most people's needs, but notes that some Ashhurst residents in the 2007-10 period experienced effects from the Te Apiti turbines over a greater distance. The submitter states that they expect that there will be conflict between S9 Objective 7 and Objective 8 and 9 when commercial interests are at stake. The submitter notes that R9.8.6(ii) has a typo: "owner of occupier". The submitter states that the occupier should be entitled to sign a consent agreement instead of the owner if that person has a contractual right of use for at least 24 months from the date of the consent application. The submitter opposes R9.9.3 The submitter suggests a new rule R9.10.3 that proposed Wind Farms within the TRLPA are considered Prohibited Activities. The submitter states that the yellow line representing the TRLPA under Map 9.1 would not protect anything. The submitter states that if the TRLPA is the area between the yellow line and the City boundary to the east of this line, then it is not explicit enough on Map 9.1, nor in any other part of PPC15A-H. The submitter recommends the inclusion of a reference to Section 4 Definition to Core Airport Precinct under Section 13.1 bullet point 1, to avoid confusion around the meaning of Core Airport Precinct. Decisions Requested:

1. S4 Definitions: That S4 be amended to include the term “dairy” in clause (a) of the Definition of the phrase Dairy Related Industrial Activity.

2. S4 Definitions: That the S4 definition of Core Airport Precinct is amended to correct the spelling of “hangers” to “hangars”. 3. S4 Definitions: That S4 be amended to indicate that the Definition of Mass Assembly of People only applies to the Runway End

Protection Area, and not to the City at large. 4. S7 & S9: That the Issues, Objectives and Policies under S7 & S9 are retained and not pared back from the proposed position. 5. S7.3 Policy 2.8.5: That S7 Policy 2.8.5 be amended to read as follows:

In rural areas, properties will be supplied with water and fire safety requirements met from property owners and/or occupiers must make their own provision for water collection and storage for household, horticultural, stock and fire safety requirements by the use of rainwater tanks, bores, wells or specially constructed storage tanks.

6. R7.16.1.2(g): That the adequacy of the 1.5km setback distance under R7.16.1.2(g) is confirmed at the Hearing. 7. S9.3 Objectives: That S9 be amended to state that Objective 7 has priority over Objectives 8 and 9. 8. R9.8.6(ii): That the typo owner of occupier under R9.8.6(ii) be fixed. 9. R9.8.6(ii): That the equity of the owner is protected from capricious behaviour in a consent agreement by a short-term occupier. 10. S9.10: That S9 be amended to include a new rule:

R 9.10.3 No Wind Farm site must be inside the Tararua Ranges Landscape Protection Area (Map 9.1), or R 9.10.3 No further Wind Farm site…

11. S9 Map 9.1: That the full dimensions of the TRLPA on Map 9.1 are made clear. 12. S13.1 Introduction: That S13.1 is amended to make reference to the Definition of Core Airport Precinct.


134

Submission Number

Plan Change Number


SO84 15A 15B


Sarah L Taylor Sarah L Taylor 72 Greens Road PALMERSTON NORTH 4472

YES

Submission: The submitter supports the 20ha minimum lot area under R7.15.1.2(b)(i) in principle, however requests that properties less than 20ha that have more than one dwelling remain under the existing 1ha ruling. The submitter states that this would provide certainty for those property owners who may want to subdivide the two properties in the future and would reduce the time and financial costs involved in seeking consent. The submitter opposes the 1.5km setback under R9.8.7. The submitter states that commercial wind turbines should not be closer that 3km from a dwelling. The submitter states that there are enough places available for wind turbines without being close to dwellings. The submitter states that cost alone cannot be used to justify putting the rural environment and people's health at risk. The submitter states there is insufficient long term data on the health effects of wind farms to justify wind farms that close to housing. The submitter cites a recent article highlighting the health effects of wind turbines. Decisions Requested:

1. R7.16.1.2: That R7.16.1.2 be amended to provide for lots less than 20ha with more than one dwelling to subdivide under the existing 1ha rule.

2. R9.8.7: That the Council ensure that wind farm and landscape provisions do not allow dwellings to be within 3km of a wind turbine. Submission Number

Plan Change Number

Relevant Section/s

Submitter Address for Service Wishes to be heard

SO85 15H S13 Airport Zone

Peter J Learmonth & Kathryn J Learmonth

142 Midhurst Street RD10 PALMERSTON NORTH

Yes

Submission: The submitter opposes the inclusion of their property at 142 Midhurst Street in the Runway End Protection Area. The submitter considers that it would seriously devalue their land and hinder any future sale. The submitter also notes that they have two titles and that this gives them the option of building a lifestyle home on it, but that they want this confirmed. It is also stated that in the event of fire or earthquake, losing the existing house, cattery and kennels buildings on one of the titles they would not be able to re-build, and that this would make their land valueless. Decision Requested:

1. R13.4.5.2 and Map 13.2: If the Runway End Protection Area is imposed, that the submitter be compensated for the loss of property rights through either compensation paid or the property being purchased and leased back to the submitter.

Submission Number

Plan Change Number


SO86 15E S7 Subdivision S12A NEIZ

Hercoe Family Trust John Hercoe 265 Richardsons Line RD8 PALMERSTON NORTH

YES

Submission: The submitter supports PPC15E. Decision Requested:

1. PPC15E: The submitter requests the Council to apply all legal due process to advance and complete the proposed plan change.


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Submission Number

Plan Change Number


SO87 15A-H 15A 15C 15E 15F 15H

S4 Definitions S6 General S7 Subdivision S9 Rural Zone S17 Cultural and Natural Heritage S20 Transportation S24 Designations S12A NEIZ S12 Industrial Zone S13 Airport Zone

New Zealand Transport Agency

Cole O’Keefe PO Box 1947 PALMERSTON NORTH 4440

YES

Submission: The submitter supports the overall intent and direction of PPC15A-H. The submitter supports the additional wording under the S4 definition of Official Sign, as it provides further clarification to plan users. The submitter supports R6.3.6.2(vii)(iv). The submitter supports the replacement of 'Transit New Zealand' with 'New Zealand Transport Agency' throughout PPC15A. The submitter supports the additional bullet point recognising the effect that subdivision can have on the safety and efficiency of the transport network. The submitter supports the additional bullet points recognising reverse sensitivity effects on Pages 83-84. The submitter requests the amendment to Resource Management Issue 5 Explanation paragraph 4 to delete the following: '...at the time of the subdivision consent through the imposition of conditions or the decline of consent.' The submitter states that it is more practical to ensure appropriate mitigation in particular for state highway reverse sensitivity effects through the use of performance standards. The submitter supports the Access Management Structure Plan Tool under R7.16.1.2 and S7 Policy 2.2.3. The submitter supports the avoidance of upgrading a road unless it is in the economic interest of the City and will not compromise the efficient functioning of infrastructure networks under Policy 3.2(a)(vii). The submitter supports the recognition that reverse sensitivity effects on strategic infrastructure should be avoided or adequately mitigated under S7 Policy 3.5(n). The submitter supports paragraph 5 of S7 Policy 3.5 Explanation, specifically in relation to protecting the future function of strategic transport networks. The submitter recommends including state highway networks into paragraph 4 of S7 Policy 3.5 Explanation, to recognise that inappropriately located or designed activities near existing state highway networks can result in reverse sensitivity effects. The submitter supports bullet points 5 and 8 under R7.16.2.1 for recognising reverse sensitivity and the effects on the safe and efficient operation of the road network. The submitter supports the recognition of reverse sensitivity effects for permitted and lawfully established activities in the Rural Zone under R7.16.2.1 Assessment Criterion (a)(iii). The submitter supports criteria that ensures that subdivision does not impact on the safety and efficiency of the transport network as well as promoting alternative modes of transport, such as R7.16.2.1 Assessment Criterion (a)(vii). The submitter supports the recognition of the safe and efficient functioning of State Highway and Limited access Roads under R7.16.2.2 bullet point 2. The submitter supports the consideration of whether alternative legal access to a public road exists under R7.16.2.2 bullet point 4, as it is the Transport Agency's preference that access is gained from the local road network if available. The submitter supports the reference explaining Limited Access Roads and required written approval process from the Transport Agency where allotments require access from the State Highway, under R7.16.2.2 Note to Plan Users 4 & 5. The submitter requests that the


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reference to the Transit New Zealand Act 1989 is updated to the reference to the Government Roading Powers Act 1989. The submitter supports the 10m setback provision under R9.5.2(b) bullet point 2, specifically in terms of protecting the safety of transport network. The submitter supports the provision requesting identification of access points and projected number of traffic movements per day under R9.5.2(c)(i) and R9.5.2(c)(ii). The submitter supports the minor wording amendments to R9.7.2(c). The submitter supports the R9.7.3 Explanation in relation to the importance of maintaining the safety and efficiency of the roading network and permission required from NZTA. The submitter supports the recognition of the safe and efficient operation of the roading network under R9.7.4 bullet point 2, and ensuring that any adverse effects of traffic associated with the activity are avoided, remedied or mitigated under R9.7.4(c). The submitter requests the addition of the following wording after 'The need to protect Wind Farms' under S9.2 Resource Management Issue 14: '…and the State Highway Network'. The submitter states that there is a need to protect the State Highway Network from reverse sensitivity effects. The submitter requests additional wording to recognise the need to manage reverse sensitivity effects for existing state highway networks in paragraph 5 of 9.2 Explanation. The submitter supports the last sentence of 9.2 Explanation paragraph 3 which recognises that rural residential development should be located carefully to avoid reverse sensitivity effects for existing land use activities. The submitter requests a new Performance Standard for any new Protected Premises and Facilities (e.g. new dwelling, alteration to a dwelling, Marae or education facility) in the Rural Zone to recognise the Acousafe Rural Noise Report's recommendation that new noise sensitive activities should be noise insulated where the building is within 80 metres of the State Highway, and setbacks where the building is within 40 metres of the State Highway. The submitter acknowledges the inclusion of Reference 96 Railway Bridge Foundations in Appendix 17A. The submitter supports S20.2 Resource Management Issue 7. The submitter supports S20.3.3 paragraph 4, as it recognises the Transport Agency's role. The submitter supports S20.3.3 paragraph 5, as it recognises the importance of the RLTP. The submitter supports paragraph 2 of R20.3.9.1(a) Note to Plan Users, acknowledging permission from the RCA is required for any construction of a vehicle crossing and intersection. The submitter supports bullet point 2 of R20.3.10.1 having regard to safe traffic management to and from the site. The submitter supports PNCC's Access Management Structure Plan tool under R20.3.10.1(d). The submitter supports reference to the Limited Access Roads in Note to Plan Users 4 (P. 453) and Appendix 20.7. The submitter supports the inclusion of the One Network Road Classification in Note to Plan Users 5 (P. 453), but suggests removing the term 'New Zealand Transport Agency's' to the note. The submitter suggests removing the term 'New Zealand Transport Agency's' to Note to Plan Users 5 (P. 453), as the One Network Road Classification has been implemented by the Roading Efficiency Group. The submitter supports the inclusion of all sections of the State Highway network now within the City's Boundary. The submitter supports the replacement of 'Transit' to the 'New Zealand Transport Agency'. The submitter requests that the section of State Highway 54 designation which is now within the PNCC boundary is rolled over into the existing Transport Agency State Highway designation Reference 15 in S24 Table 1. The submitter supports the extension of the North East Industrial Zone and corresponding provisions that protect strategic transport network and which are consistent with the Joint Transportation Study. The submitter supports S12 Policy 5.4 and R12.8.5 Assessment Criteria (a)(vi) and (f)(i), as these provisions ensure the mitigation of impacts on the safe and efficient operation of State Highway 56.


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The submitter supports R12.8.5 having regard to the safe and efficient operation of the road network. The submitter supports R12.8.5 Assessment Criteria (a)(xii) requiring a traffic impact assessment to be undertaken. The submitter supports R12.8.5 Assessment Criteria (a)(xiii) requiring a statement of the process undertaken to obtain the Transport Agency's written approval. The submitter supports R13.4.5.2(i) in relation to the exclusion of roads which prohibit new structures in the Runway End Protection Area. Decisions Requested:

1. S4: That the S4 definition of Official Sign is retained as notified.

2. R6.3.6.2(vii)(iv): That R6.3.6.2(vii)(iv) is retained as notified.

3. PPC15A: That the replacement of Transit New Zealand with New Zealand Transport Agency throughout PPC15A be retained as notified.

4. S7.1 Introduction: That bullet point 7 of S7.1 on Page 83 is retained as notified.

5. S7.1 Introduction: That S7.1 bullet points 7 (Page 83) and 11 (Page 84) are retained as notified.

6. S7.3 Resource Management Issue 5: That paragraph 4 of S7 Resource Management Issue 5 Explanation be amended to delete

the following: …at the time of the subdivision consent through the imposition of conditions or the decline of consent.

7. S7.3 Policy 3.2(a)(vii): That S7 Policy 3.2(a)(vii) is retained as notified.

8. S7.3 Policy 3.5(n): That S7 Policy 3.5(n) is retained as notified.

9. S7.3 Policy 3.5: That paragraph 5 of S7 Policy 3.5 Explanation is retained as notified.

10. S7.3 Policy 3.5: That paragraph 4 of S7 Policy 3.5 Explanation is amended to insert , state highway network before …and noise

sensitive activities, like residential dwellings and schools.

11. R7.16.2.1: That bullet points 5 and 8 under R7.16.2.1 is retained as notified.

12. R7.16.2.1: That R7.16.2.1 Assessment Criterion (a)(iii) is retained as notified.

13. R7.16.2.2: That R7.16.2.2 bullet point 2 be retained as notified.


15. R7.16.2.2 Note to Plan Users 4: That R7.16.2.2 Note to Plan Users 4 is amended to make reference to the Government Roading Powers Act 1989 rather than the Transit New Zealand Act 1989.

16. R9.5.2(b): That R9.5.2(b) bullet point 2 is retained as notified.

17. R9.5.2(c)(i) & R9.5.2(c)(ii): That R9.5.2(c)(i) and R9.5.2(c)(ii) be retained as notified.

18. R9.7.2(c): That R9.7.2(c) be retained as notified.

19. R9.7.3: That R9.7.3 Explanation is retained as notified.

20. R9.7.4: That R9.7.4 bullet point 2 and R9.7.4(c) be retained as notified.

21. S9.2 Resource Management Issue 14: That S9 Resource Management Issue 14 be amended to read as follows:

The need to protect Wind Farms and the State Highway Network from reverse sensitivity effects associated with noise sensitive activities establishing in the surrounding rural environment.


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22. S9.2 Resource Management Issues: That paragraph 5 of S9.2 Explanation be amended as follows: …there is a need to manage reverse sensitivity effects from noise sensitive activities seeking to locate in close proximity to consented Wind Farms and existing strategic infrastructure such as the State Highway network.

23. S9.2 Resource Management Issues: That paragraph 3 of S9.2 Explanation be retained as notified.

24. S9: That S9 be amended to include a new Performance Standard for any new Protected Premises and Facility in the Rural Zone:

1) New PPF's shall not be located within 40 metres of the edge of the nearest traffic lane of any state highway or within 40 metres of any state highway designation that does not contain an existing state highway. 2) Within 80 metres of the edge of the nearest traffic lane of any state highway or within 80 metres of any state highway designation that does not contain any existing state highway, any new PPFs or any alteration to a PPF beyond 10% of the existing gross floor area, shall be designed and constructed to comply with the following design sound levels: a) Road-traffic noise inside all habitable spaces: 40 dB LAeq(24h) b) Road-traffic noise in all other PPFs: No greater than the recommended maximum design guidelines in AS/NZS 2107:2000. 3) If windows to habitable spaces are required to be closed to achieve the design sound levels in rule 2, the building shall be designed and constructed with a ventilation system to achieve the following: a) A quantity of air shall be provided to achieve the requirements of Clause G4 of the New Zealand Building Code. At the same time as meeting this requirement, the sound of the system shall not exceed 30 dB LAeq(30s) when measured 1 m away from any grille or diffuser. b) Either: air conditioning shall be provided; or a high air flow rate setting shall provide at least 15 air changes per hour (ACH) in the principal living space and at least 5 ACH in all other habitable spaces. c) At the same time as meeting the above requirement in b), the sound of the system shall not exceed 40dB LAeq(30s) in the principal living space and 35 db LAeq in all other habitable spaces, when measured away from any grille or diffuser. d) The internal air pressure shall be no more than 10 Pa above ambient air pressure due to the mechanical ventilation. e) Where a high air flow rate setting is provided, the system shall be controllable by the occupants to be able to alter the ventilation rate with at least three equal stages up to the high setting. 4) A design report prepared by an acoustics specialist shall be submitted to the [manager/officer], City Council, demonstrating compliance with Rules 2 and 3, prior to construction of any PPF or alteration to a PPF beyond 10% of the existing gross floor area, within 80 metres of the edge of the nearest traffic lane or any state highway or within 80 metres of any state highway designation that does not contain an existing state highway. The design shall take into account future permitted use of the state highway; for existing roads by the addition of 3 dB to existing measured or predicted levels. [PPF - Protected Premises and Facilities defined as a house, school, Marae) as per NZS 6806] [Habitable space to be defined in the plan as per Building Code].

25. S20.2 Resource Management Issue 7: That S20.2 Resource Management Issue 7 be retained as notified.

26. S20.3.3: That paragraph 4 of S20.3.3 be retained as notified.

27. S20.3.3: That paragraph 5 of S20.3.3 be retained as notified.

28. R20.3.9.1(a) Note to Plan Users: That paragraph 2 of R20.3.9.1(a) Note to Plan Users is retained as notified.


30. R20.3.10.1(d): That R20.3.10.1(d) be retained as notified.

31. Appendix 20A & Appendix 20.7: That Note to Plan Users 4 on Page 453 and Appendix 20.7 are retained as notified.

32. Appendix 20A: That Note to Plan Users 5 on Page 453 be amended to remove reference to the New Zealand Transport Agency, as per Page 9 of this submission.

33. That the plan provisions are amended to ensure points 1-4 are achieved.

34. S12.3 Policy 5.4 & R12.8.5: That S12 Policy 5.4 and R12.8.5 Assessment Criteria (a)(vi) and (f)(i) are retained as notified.


139

35. R12.8.5: That R12.8.5 is retained as notified.

36. R12.8.5: That R12.8.5 Assessment Criteria (a)(xii) is retained as notified.

37. R12.8.5: That R12.8.5 Assessment Criteria (a)(xiii) is retained as notified.

38. R13.4.5.2(i): That R13.4.5.2(i) be retained as notified.

39. That any other relief, including additions, deletions or consequential amendments necessary as a result of the matters raised in this

submission are adopted.

Submission Number

Plan Change Number



Starter Plants Ltd Thomas E Welsh & J M Welsh 325 College Street PALMERSTON NORTH

YES

Submission: The submitter requests that the properties on the West side of Turitea Road, between the Old West Road intersection and Harts' Road intersection be included in the Rural Residential Overlay. The submitter states that their site (126 Turitea Road) is subject to consent notice RM1343 prohibiting a dwelling on the property. The submitter states that they are only using 50% of the land area as a nursery, and would like to use the rest for a dwelling for themselves and another for their nursery manager. The submitter states that they are the only property using the land for commercial agricultural enterprise, with the surrounding landowners considered as "hobby farmers". The submitter supports the inclusion of rural land up to Greens Road being included in the Rural Residential Overlay, as the land is close to urban amenities. The submitter suggests that the minimum lot size under R7.15.1.2 be increased for pastoral producers, whilst retaining the minimum lot size for intensive horticulture. Decisions Requested:

1. Planning Map 39: That the properties on the West side of Turitea Road, between the Old West Road intersection and Harts' Road instersection be included in the Rural Residential Overlay.

2. R7.15.1.2: That R7.15.1.2 be amended to increase the minimum lot size for pastoral producers only.

Submission Number

Plan Change Number


SO89 15A S9 Rural Zone New Zealand Defence Force


YES

Submission: The submitter opposes in part Rule 9.5.8 Permitted Activity for Minor and Extended Temporary Military Training Activities. It is submitted the noise standards be replaced with those in Attachment 1, to control noise effects from Temporary Military Training Activities. (Refer to Submission 89 for Attachment 1). Decision Requested:

1. Adopt the NZDF noise standards for the control of the noise effects from Temporary Military Training Activities.


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Submission Number

Plan Change Number


SO90 15A 15C

S7 Subdivision S9 Rural Zone Planning Map 5

Sandra K Hey Sandra K Hey 31 Pohangina Road RD10 PALMERSTON NORTH

NO

Submission: The submitter opposes the proposal to increase the minimum lot size for rural subdivision from 4 ha to 20 ha, in particular the application to the small area between North Street Ashhurst to David Road). It is submitted that this area be allocated to rural residential status. The submission notes: - the area is already physically a rural residential area - further subdivision of existing lifestyle blocks to smaller rural properties would not reduce any rural economic viability as these are

already hobby properties. - The neighbourhood is perfectly suited to the type of rural residential living in Aokautere, Polson Hill, Moonshine Valley road area - A category of rural residential would enhance the exit from Ashhurst at North Street It is submitted that North Street to David Road area could be a special area of small lifestyle properties, creating a sought after are to live and a tranquil buffer between town and country. It is submitted that it would be a shame to brutalise this area into squares of suburban sprawl (as per residential expansion of the town). It would destroy the ’constable-like’ sweetness of this spot. It is submitted that it would be equally an uncomfortable fit to place productive agricultural zoning to this locality – which is already far from it.. Decision Requested:

1. To revise the zone of the area of Pohangina Road from North Street to David Road to rural residential. Submission Number

Plan Change Number



Stephen Hopcroft & Lancaster Properties Ltd

Stephen Hopcroft & Lancaster Properties Ltd 22 Fitzherbert East Road Aokautere, RD1 PALMERSTON NORTH 4471

YES

Submission: The submitter opposes the rural zoning in relation to properties at 538, 566 and 588 Aokautere Drive. The submitter opposes Rule 7.16.1.2 – 20 ha minimum lot area. The submitter opposes Policy 3.2 (reference to 20 ha/Map 26) The submission states that these properties are very high and value class 1 soils. It is submitted that there is no way to provide a worthwhile farming return off these properties, in this locality, in 20 ha lot areas and that a far better asset to the city is 1.5 – 2 ha lots. Decision Requested:

1. That the City allows the opportunity for people to economically own small areas of class 1 soils and intensively operate agricultural enterprises and homes.


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Part II – Submitter Address List & Copies of Original Submissions

Submitter Address List

Submitter Number Name Address

Support/Oppose

Hearing

SO-1 Bruce Peck

Projectwork 2008 Ltd 7 Harrisons Line RD10 PALMERSTON NORTH

Oppose

NOT STATED

SO-2 D C Morrison PO Box 4082 PALMERSTON NORTH

Oppose in Part

NOT STATED

SO-3 Philip T Ropiha

153 Tutaki Road RD10 PALMERSTON NORTH 4470

Oppose NOT STATED

SO-4

JP Ware Transport Ltd & JB Ware & Sons Family Trust

John and Tina Ware Bainesse RD7 PALMERSTON NORTH 4477

Oppose in Part

Yes

SO-5 Jane Richardson

129 Richardsons Line RD8 PALMERSTON NORTH

Oppose NOT STATED

SO-6 David C Parham

24 Logan Way Kelvin Grove PALMERSTON NORTH 4414

Oppose

Yes

SO-7 Sustainable City Group

Rocky Renquist 14 Springdale Grove PALMERSTON NORTH 4410

Support in Part

No

SO-8 Clive A Harding

32 Apollo Parade Milson PALMERSTON NORTH

Oppose

Yes

SO-9 W B Holdsworth 30 North Street ASHHURST

Oppose NOT STATED

SO-10 Shireen A Schofield

PO Box 5177 Terrace End PALMERSTON NORTH 4441

Support

No

SO-11 David & Robyn Adam

153 Richardson Line RD8 PALMERSTON NORTH

Support

Yes

SO-12 Fran Harvey

1180 Roberts Line RD8 PALMERSTON NORTH 4478

Oppose

No

SO-13 Palmerston North City Council

Paddy Clifford, Chief Executive Private Bag 11-034 PALMERSTON NORTH

Support in Part

No

SO-14 Rosemary Gear and 48 Others

64 Moonshine Valley RD1 PALMERSTON NORTH

Support

No

SO-15 Robert H Fraser 41 Apollo Parade PALMERSTON NORTH 4414

Oppose NOT STATED

SO-16 Brian C Holmes

52 Setters Line RD8 PALMERSTON NORTH

Oppose in Part

Yes


142


Support/Oppose

Hearing

SO-17

B J & C J Whitelock, John Whitelock and Others

42 The Strand PALMERSTON NORTH

Support in Part

Yes

SO-18 David K Severinsen RD4 WAIPUKURAU 4284

Neutral Yes

SO-19 Radio New Zealand Limited

Gary Fowles - Transmission Manager PO Box 123 RNZ House, Level 2/155 The Terrace WELLINGTON 6011

Support

Yes

SO-20 Ministry of Education

C/- Jessica Allan - School Property Officer, Education Infrastructure Service 93 Ingestre Street WHANGANUI

Oppose

Yes

SO-21 Jacobus J Van Vuuren

1418 Napier Road ASHHURST

Oppose No

SO-22

The Oil Companies (Z Energy Ltd, BP Oil NZ Ltd, Mobil Oil NZ Ltd)

Mark Laurenson, Senior Planner Burton Planning Consultants Ltd Level 1, 2-8 Northcroft St PO Box 33-817, Takapuna AUCKLAND 0740

Support in Part

Yes

SO-23

Axis Estate Ltd & PMW Trustees Co Ltd

Colin Fink - Kevin O'Connor & Associates 71 Pitt Street PO Box 600 PALMERSTON NORTH

Oppose

Yes

SO-24 Joseph Poff

658 Pahiatua Track, RD1 PO Box 514 PALMERSTON NORTH

Oppose

Yes

SO-25 Matthew Currie 22 Centennial Drive PALMERSTON NORTH

Support in Part Yes

SO-26 John R Wycherley 11 Worcester Street ASHHURST

Oppose Yes

SO-27 New Zealand Fire Service Commission

Claire Fell, Planner C/- Beca Ltd PO Box 3942 WELLINGTON 6140

Support in Part

Yes

SO-28 Brian Green Properties (PN) Ltd

Paul Thomas, Director Environment Management Services Ltd PO Box 29024 WELLINGTON 5034

Support in Part

Yes

SO-29 Paul A Cole

378 Waughs Road RD5 FEILDING

Oppose

Yes

SO-30 Ngawai Farms Limited

291 Turitea Road RD2 PALMERSTON NORTH

Support

No

SO-31 Albert A & Jane S Van Der Zwan

60 Harts Road, RD2 Turitea PALMERSTON NORTH 4474

Oppose

Yes

SO-32 Paul E Wycherley 1478 Napier Road ASHHURST

Oppose Yes

SO-33 Argosy Property Limited

Sue Simons, Partner Berry Simons, Environmental Law PO Box 3144, Shortland Street AUCKLAND 1140

Oppose

Yes


145


Support/Oppose

Hearing

SO-34 Palmerston North Airport Limited

David Lanham First Floor, Terminal Building Airport Drive PO Box 4384 PALMERSTON NORTH 4442

Support in Part

Yes

SO-35 Bruce & Marilyn Bulloch

128 Cook Street West End PALMERSTON NORTH 4410

Support

No

SO-36 Airways Corporation of New Zealand

Sara Cook, Intermediate Planner C/- Opus International Consultants Ltd Level 4, The Square Centre 478 Main Street PALMERSTON NORTH

Support

Yes

SO-37 Friederike E Lugt 659 Stoney Creek Road, RD10 PALMERSTON NORTH

Oppose Yes

SO-38 Ashley Farms Ltd

Lindsay & Marion Ashley 588a Stoney Creek Road RD10 PALMERSTON NORTH 4470

Oppose

No

SO-39 Philip H Pirie

Pirie Consultants 168 Grey Street PO Box 10050 PALMERSTON NORTH

Oppose

Yes

SO-40 New Zealand Defence Force


Oppose

Yes

SO-41 Chorus New Zealand Limited

Mary Barton, Environment Planning & Engagement Manager PO Box 632 WELLINGTON

Oppose in Part

Yes

SO-42 Spark New Zealand Trading Limited

Graeme McCarrison Private Bag 92028 AUCKLAND 1010

Support in Part

Yes

SO-43 Mighty River Power

Miles Rowe, Environmental Advisor PO Box 445 HAMILTON 3240

Support in Part

Yes

SO-44

Federated Farms Manawatu-Rangitikei Province

Coralee Matena, Senior Policy Advisor-Manawatu PO Box 945 PALMERSTON NORTH 4440

Support in Part

Yes

SO-45 Trustpower Limited

Laura Marra, Lead Environmental Advisor Private Bag 12023 Tauranga Mail Centre 3143 TAURANGA

Support in Part

Yes

SO-46 Transpower New Zealand Limited

Rhedyn Law C/- RMG, PO Box 10170 The Terrace WELLINGTON 6143

Support in Part

Yes

SO-47 Heritage Estates Ltd

Amanda Coats C/- Proarch Consultants 306 Church Stret PALMERSTON NORTH

Oppose in Part

Yes


144


Support/Oppose

Hearing

SO-48 Meridian Energy Limited

Andrew Feierabend, Statutory & Compliance Strategy Manager PO Box 2146 104 Moorhouse Avenue CHRISTCHURCH 8140

Support in Part

Yes

SO-49 Deborah A Sparkes

286 Millricks Line RD2 PALMERSTON NORTH 4472

Oppose

No

SO-50

Fonterra Co-operative Group Limited

Ian Johnson, Environmental Consultant Environmental Management Services Ltd PO Box 1307 HAMILTON 3240

Support in Part

Yes

SO-51 Kevin O'Connor and Associates

Holly Jenkins, Planner 71 Pitt Street PO Box 600 PALMERSTON NORTH 4440

Support in Part

Yes

SO-52 Jeremy J Lind

671 Stoney Creek Road RD10 PALMERSTON NORTH 4471

Oppose NOT STATED

SO-53 Dean Sparkes 286 Millricks Line, RD2 PALMERSTON NORTH 4472

Oppose Yes

SO-54 New Zealand Wind Energy Association

Eric Pyle, Chief Executive PO Box 553 Ground floor, 114 The Terrace WELLINGTON

Oppose

Yes

SO-55 Pioneer City West Ltd

Paul Thomas, Director Environmental Management Services PO Box 29024 WELLINGTON 5034

Oppose

Yes

SO-56 Horizons Regional Council

Lisa Thomas, Coordinator District Advice Private Bag 11-025 Manawatu Mail Centre PALMERSTON NORTH

Support in Part

Yes

SO-57 Horticulture New Zealand

Chris Keenan, Manager-Natural Resources & Environment PO Box 10-232 WELLINGTON

Support in Part

Yes

SO-58 Dorothy M Alley 45 Atawahi Road PALMERSTON NORTH

Oppose NOT STATED

SO-59 Powerco

Mark Laurenson, Senior Planner Burton Planning Consultants Ltd Level 1, 2-8 Northcroft St PO Box 33-817, Takapuna AUCKLAND 0740

Support in Part

Yes

SO-60 KiwiRail Holdings Ltd

Rebecca Beals, Senior RMA Advisor Wellington Railway Station PO Box 593 WELLINGTON 6140

Support in Part

Yes

SO-61 New Zealand Windfarms Limited

Vicki Morrison-Shaw, Senior Associate C/- Atkins Holm Majurey Ltd Level 19, 48 Emily Place PO Box 1585, Shortland Street AUCKLAND 1010

Oppose in Part

Yes


145


Support/Oppose

Hearing

SO-62 Higgins Aggregates Limited

Andrew Bashford Good Earth Matters Consulting Ltd 56 Queen Street Private Bag 1268 PALMERSTON NORTH 4440

Oppose in Part

Yes

SO-63 Vector Gas Limited

Gill Robertson, Land Management Coordinator Private Bag 2020 NEW PLYMOUTH 4342

Oppose

Yes

SO-64

House Movers Section of NZ Heavy Haulage Assn (Inc)

Rowan Ashton, Counsel Stuart Ryan, Barrister PO Box 1296 Shortland Street AUCKLAND 1140

Oppose

Yes

SO-65 Maurice R Alley 45 Atawahi Road, PALMERSTON NORTH

Oppose No

SO-66 Proarch Consultants Ltd

Amanda Coats, Director 306 Church Street West PO Box 1105 PALMERSTON NORTH 4440

Oppose

Yes

SO-67 Peter H Allen

324 Ngahere Park Road RD2 PALMRSTON NORTH 4472

Oppose

Yes

SO-68 William M Kelly & Diane H Simpson

134 Midhurst Street RD10 PALMERSTON NORTH

Oppose

Yes

SO-69 Pita & Helen Kinaston

824A Roberts line RD8 PALMERSTON NORTH 4478

Oppose

Yes

SO-70 John & Kathy Love 132 Greens Road, RD2 PALMERSTON NORTH 4472

Oppose Yes

SO-71

FJ & Estate of B Setter/Frederick J Setter

718 Rangitikei Line, RD5 PALMERSTON NORTH

Oppose

Yes

SO-72 Anne J Milne

63 Sutherland Road RD9 PALMERSTON NORTH 4479

Support

Yes

SO-73 Selwyn Wycherley 1338 Napier Road ASHHURST

Oppose Yes

SO-74 John W Stephenson

111 Henaghans Road Whakarongo, RD10 PALMERSTON NORTH 4470

Oppose

Yes

SO-75 Matthew Ellingham-Matvin Property Ltd

Holly Jenkins, Planner Kevin O'Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

Oppose

Yes

SO-76 Stu Waters

Holly Jenkins, Planner Kevin O'Connor & Associates Ltd PO Box 600 PALMERSTON NORTH 4440

Support in Part

Yes

SO-77 Alison M Mildon

346 Millricks Line RD2 PALMERSTON NORTH

Support in Part

Yes

SO-78 Kevin O'Donnell

Holly Jenkins, Planner Kevin O'Connor & Associates Ltd PO Box 600 PALMERSTON NORTH

Oppose

Yes


146


Support/Oppose

Hearing

SO-79 Alpha Corporation


Oppose

Yes

SO-80 Gavin Terry


Oppose

Yes

SO-81 Shannon & Co. Ltd

Tom Shannon 1630 Napier Road, RD1 PALMERSTON NORTH

Neutral

Yes

SO-82 Jill White 276 Aokautere Drive, RD1 PALMERSTON NORTH

Support in Part Yes

SO-83 Bruce Wilson 276 Aokautere Drive, RD1 PALMERSTON NORTH

Support in Part Yes

SO-84 Sarah L Taylor 72 Greens Road PALMERSTON NORTH 4472

Support in Part Yes

SO-85 Peter J Learmonth & Kathryn J Learmonth

142 Midhurst Street, RD10 PALMERSTON NORTH

Oppose Yes

SO-86 Hercoe Family Trust

John Hercoe 265 Richardsons Line, RD8 PALMERSTON NORTH

Support

Yes

SO-87 New Zealand Transport Agency

Cole O’Keefe, Senior Planning Advisor PO Box 1947 PALMERSTON NORTH 4440

Support in Part

Yes

SO-88 Starter Plants Ltd

Thomas E Welsh and J M Welsh, Co-Directors of Starter Plants Ltd 325 College Street PALMERSTON NORTH

Oppose

Yes

SO-89 New Zealand Defence Force

Sara McMillan, Tonkin & Taylor PO Box 2083 WELLINGTON 6140

Oppose

Yes

SO-90 Sandra K Hey 31 Pohangina Road, RD10 PALMERSTON NORTH

Oppose No

SO-91

Stephen Hopcroft & Lancaster Properties Ltd

22 Fitzherbert East Road Aokautere, RD1 PALMERSTON NORTH

Oppose

Yes


147

Copies of Original Submissions

palmerston north city sectional district plan review · pdf filerelevant national planning...

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