Summary of Decisions Requested - Palmerston North City Council

Palmerston North City Sectional 

District Plan Review 

Proposed Plan Change 6: 

Whakarongo Residential Area 

Summary of Decisions Requested from Original 

Submissions 

& 

Copies of Original Submissions 

11 July 2013

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: 

SECTIONAL DISTRICT PLAN REVIEW 

PROPOSED PLAN CHANGE 6 – WHAKARONGO RESIDENTIAL AREA 

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 6 to the Palmerston North City District 

Plan are available for public consideration. The Council has received 18 original submissions to Plan 

Change 6. 

Proposed Plan Change 6 seeks to implement Council’s Residential Growth Strategy within the District 

Plan through the rezoning of land from Rural to Residential Zone to provide for the short to medium 

term greenfield residential growth of the City. The plan change also contains a comprehensive policy 

framework and structure plan to guide and manage development within what is being introduced as 

the Whakarongo Residential Area as set out in the Whakarongo Structure Plan. 

Both 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 Ashhurst Service Delivery Centre, Ashhurst Four Square Counter, 122 Cambridge 

Avenue, Ashhurst; 

The Palmerston North Public Library, The Square, Palmerston North; 

Branch Libraries: the Roslyn Library (Vogel Street); Awapuni Library (College Street); 

Highbury Library (Highbury Avenue), Palmerston North; 

the Ashhurst Library, corner Cambridge Avenue and Bamfield Street, Ashhurst; 

The Mobile Library; and 

Linton Army Camp Library, Puttick Road, Linton. 

Information on the Proposed Plan Change, the original submissions received and the Further 

Submission form are also available on the Council website: www.pncc.govt.nz. 

The Palmerston North City Council is now calling for further submissions in support of, or in 

opposition to, the submissions lodged to Proposed Plan Change 6. 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 that of the 

general public; and 

Palmerston North City Council Proposed Plan Change 6 – Summary of Original Submissions 

2

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: www.pncc.govt.nz. The closing date for making further 

submissions is 4pm, Friday 26th July 2013. Further submissions to the Proposed Plan Change 

must be lodged to the Council by one of the following options: 

Posted/Faxed/Emailed to: 

Team Leader – Governance and Civic 

City Corporate 

Palmerston North City Council 

Private Bag 11-034 

PALMERSTON NORTH 

Fax No: (06) 355-4415 

Email: submission@pncc.govt.nz 

or Delivered to: 

Team Leader – Governance and Civic 

City Corporate 

c/- Customer Service Centre 

Palmerston North City Council 

The Square, PALMERSTON NORTH 

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. 

IMPORTANT: Any person making a further submission to Proposed Plan Change 6 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 6 can be made to Daniel Batley, Policy Planner by phone on 

(06) 356 8199 or email daniel.batley@pncc.govt.nz. 

Paddy Clifford, Chief Executive 

for Palmerston North City Council 

Dated in Palmerston North this 11 th day of July 2013. 


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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 9. 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: 

S 

01 

Joe Bloggs 

Indicates 

that this is 

an original 

submitter 

Reference 

number 

allocated to the 

submitter 

Submitter name 

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. 


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Part I: Summary of Submissions to Proposed Plan Change 6: 

Whakarongo Residential Area 

Submission 

Number 

Submitter Address for Service Wishes to 

be heard 

S01 David C Parham 24 Logan Way 

Yes 

Palmerston North 4441 

Submission: 

Supports the Proposed Plan Change. 

Identifies that the plan change supports the submitter’s concerns about different residential categories and each having their own 

subdivision rules. 

Indicates specific support for the Objectives set out in Section 7A.3 and the concepts of Collector Roads and the railway underpass 

as indicated on the Structure Plan (Map 7A.1). 

Wastewater planning must consider the land added to the City through the Boundary Adjustment process including Ashhurst & 

Bunnythorpe. 

The new suburb must be appropriate for families to locate. 


That Council allows private schools and places of worship as normal development. 

That Council forbid commercial sexual services in the whole area. 

That Council include ‘decency’ clauses. 

That Council implement the plan change without undue delay. 

That Council fast-track the construction of the through collector road so that new residents can get a bus service. 

Submission 

Number 

S02 

Submission: 


be heard 

Palmerston North Airport Roy Bodell, Facilities Manager 

No 

Ltd 

PO Box 4384 

Palmerston North, 4442 

Supports the Proposed Plan Change. 

The comment under ‘Development under Air Noise Contours’ is contrary to world-wide experience of the effects of aircraft noise. Air 

noise is a measured reality and has international support. The present controls under the contours are correctly maintained in the 

Proposed Plan Change. 

Supports the comments contained in the Acousafe Noise Control Solutions technical reports. In particular the impact of ‘reverse 

sensitivity issues with regards to the Palmerston North Airport activities which cannot be fully overcome’ and the implications to the 

Airport and its users. 


That Council confirm the provisions in Plan Change 6 subject to the critical noise issues for the Airport. 

Submission 

Number 

S03 


be heard 

New Zealand Transport Cole O’Keefe, Resource Planner 

Yes 

Agency (NZTA) 

PO Box 1947 



5

Submission: 

Supports the overall intent of the plan change. 

NZTA is a Crown Entity which is required to undertake its functions in a way that contributes to an affordable, integrated, safe, 

responsive and sustainable land transport system. 

NZTA has a particular interest in Plan Change 6 as it has implications on how the state highway network is protected and managed. 

Supports the inclusion of reverse sensitivity provisions within the plan change. Also, the direction to encourage all modes of 

transport. 

Notes the inclusion of an indicative new intersection with SH3 (Napier Road) and states that approval for this would be required from 

NZTA. However, NZTA does not support its inclusion and prefers that the existing intersections with the state highway are utilised in 

conjunction with integrated internal local road connections. It is unknown whether the existing intersections have enough capacity to 

deal with the increased traffic flows, any remediation would have to be paid for from funding sources other than the National Land 

Transport Fund. 


That Council approves Plan Change 6 subject to the above amendments (or amendments to the same effect). 

Submission 

Number 

S04 

Submission: 


be heard 

Palmerston North City Paddy Clifford, Chief Executive 

Yes 

Council 


Palmerston North 

This submission relates to the specific provisions in the plan change that make reference to the ‘Whakarongo Residential Area’ and 

also seek amendment to those provisions relating to ‘Acoustic Insulation and Setbacks’. 

The submission seeks amendment of particular references to the ‘Whakarongo Residential Area’ changing the reference to 

‘Greenfield Residential Areas’. The changes will ensure that the provisions of the plan change are setup in a manner that not only 

address the Whakarongo area but also future greenfield areas such as the Winchester Street area in Ashhurst. Due to the overall 

framework of Plan Change 6 it will be necessary to maintain some references to the ‘Whakarongo Residential Area’ in certain 

instances. 

The provisions relating to ‘Acoustic Insulation and Setbacks’ provide no clear direction for activities that cannot comply with the 

specific requirements contained in the provisions. It is most appropriate for such non-compliances to be treated as non-complying 

activities in the Plan. 


That Council approve the necessary amendments required to give effect to the matters outlined with respect to amending the focus 

of the plan change from being solely focused on the ‘Whakarongo Residential Area’ to being more general and addressing 

‘Greenfield Residential Areas’ as a whole. 

That Council amend the ’Acoustic Insulation and Setbacks’ provision to ensure non-compliances with this are treated as noncomplying 

activities. 

Submission 

Number 


be heard 

S05 Eric Constantine 6 Tiller Close 


Did not 

indicate 

Submission: 

Supports, conditionally, Plan Change 6. 

Requests that Council purchases the land that it does not already own in the ‘Whakarongo Residential Area’ with sales of land 

restricted to first home buyers, by ballot only and with additional restrictions/conditions placed on the sections. 

Council should address air quality issues. 


6

Central Government should reinstate Housing Corporation loans for first home buyers. 


That Council purchase the remaining land in the ‘Whakarongo Residential Area’ that it does not currently own and place conditions 

on such land with respect to land ownership. 

That Council address air quality issues and the potential effects on the Whakarongo area. 

That Council urges Central Government to reinstate Housing Corporation loans for first home buyers. 

Submission 

Number 

S06 

Submission: 


be heard 

PN Industrial & 

Mr M J Slyfield 

Yes 

Residential Developments Stout Street Chambers 

Ltd (PNIRDL) 

PO Box 117 

Wellington 6140 

Indicates strong support for urban growth in Palmerston North, and agrees that a plan change is required to develop provisions that 

cater for the foreseeable urban growth needs of the City. 

The land area comprised of the Operative Urban Growth Area in combination with the Proposed Urban Growth Area, is an 

appropriate area in which better provisions for urban growth should be made. PNIRDL agrees that such provisions should include 

structure planning, a comprehensive policy framework and a restricted discretionary activity status for subdivision. 

Opposed to Plan Change 6 to the extent that it supports urban growth in the proposed area whilst reducing support for urban growth 

on PNIRDL’s land, and other land in the Operative Urban Growth Area. Considers that some, or all, of the Operative Urban Growth 

Area should continue to be supported in the District Plan as an area to accommodate urban growth. 

Council’s Residential Growth Strategy demonstrates that the options for urban growth that meet Council objectives and have regard 

to environmental constraints are very limited. Some or all of the Operative Urban Growth Area is as suitable for urban growth as (or 

more suitable than) the Proposed Urban Growth Area with regard to size and is supported by various technical assessments. 

Considers that undue weight has been given to the operative outer control zone in determining to delete the Operative Urban 

Growth Area from the Plan and in determining the northern boundary of the Proposed Urban Growth Area. The operative outer 

control boundary should not be used as a de facto zone boundary. 


That Council approve one of the following outcomes, or a combination of the following (to the extent the outcomes are 

complimentary to one another): 

- that Plan change 6 be put on hold 

- that PNIRDL’s land be incorporated into the Proposed Urban Growth Area 

- any alternative relief that enables PNIRDL’s land 

- that all parts of the plan change that propose deletion of Map 9.1 and related Urban Growth Path provisions be rejected 

That Council, if none of the above outcomes, or a combination of such, is possible, rejects Plan Change 6. 

Submission 

Number 


be heard 

S07 Beckford Partnership C/- Amanda Coats 

Yes 

Proarch Architects Ltd 

PO Box 1105 


Submission: 

Supports the overall intent of the plan change, however, in proposing land that abuts the State Highway, does not contain due 

consideration to a reduction of the speed limit for this piece of road. Has concerns about the flow-on effects of the vehicle activities 

generated by Plan Change 6 and their affect on the state highway. 


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That Council establish a 50km/hour speed zone for the length of rezoned residential frontage on State Highway 3. 

Submission 

Number 


be heard 

S08 RACE Inc Ryan Ayers, Race Inc 

No 

PO Box 52 


Submission: 

Own land within Council’s proposed City West Residential Area which was Council’s preferred option prior to liquefaction issues 

being identified in the area. Feels that more work should be completed on what is and is not acceptable for liquefaction risk before a 

piece of is disregarded. 

Decisions Sought: 

That Council reconsider the decision not to proceed with the City West Residential Area, or consider developing both the City West 

and Whakarongo areas. 

Submission 

Number 

S09 

Submission: 


be heard 

Manawatu-Wanganui Nic Peet, Group Manager Strategy & Regulation 

Yes 

Regional Council 

Horizons Regional Council 



Generally supports the intent of the plan change, the planned residential extension gives effect to Proposed One Plan (POP) Policy 

3-3A. 

POP Policy 10-1 requires Territorial Authorities to avoid or mitigate natural hazards in all areas and for all activities. There is a small 

area (at the end of the oxbow) identified as potentially inundated in a 200 year event. The plan change includes Objectives, Policies 

and Rules in the affected area however flood hazards are not consistently recognised. 

The presence of the oxbow is clearly identified on the Whakarongo structure Plan (Map 7A.1) however the associated rules only 

provide for the avoidance of residential development on unstable land. This does not provide for the avoidance of flood hazard. 

Supports the following specific provisions as they give effect to POP policies: 

- Rule 7A.5.2.1 

- Rule 7A.5.2.2 

- Objective 12 (Section 10) 

- Rule 10.7.3.2 

Supports the strong provisions throughout the plan change that support the integration of land use and transport. 


That Council identify the area shown as being inundated by a 200 year flood event on the Whakarongo Structure Plan (Map 7A.1), 

and either of the following: 

- development of new structures or activities are excluded from the area unless they are functionally necessary 

- provisions are included in the plan change that specifically recognise flood hazards and control subdivision and 

development within the floodable area 

That Council delete policies 3.2 (vi) & (vii) in Section 7A as they relate to activities that are the responsibility of Horizons. 

That Council amends Performance Standard (xiii) in Rule 7A.5.2.2 to include the avoidance and mitigation of flood hazards. 

That Council amends Performance Standard (c)(v) in Rule 7A.5.2.2 to clarify its purpose and that all sites must be connected to 

reticulated stormwater disposal services. 


8

That Council amends Rule 7A.5.2.2 Note 3 so that it is more useful and consistent with other District Plan notes. 

That Council clarifies the intent and need for Rule 10.7.1.5 Note 2 as currently the requirements are not located within a rule and will 

not be enforceable. 

Submission 

Number 


be heard 

S10 KiwiRail Holdings Ltd Deborah Hewett, RMA Advisor 

Yes 

(KiwiRail) 

PO Box 593 

Wellington, 6140 

Submission: 

The State Owned Enterprise responsible for the management and operation of the national railway network. 

Emphasises the need for any future pedestrian crossing of the railway to be grade separated. The structure plan shows a grade 

separated underpass, however it is difficult to assess whether the associated collector road is to be connected through the 

underpass. KiwiRail does not support ‘at grade’ crossings within the Whakarongo Residential Area. The submitter is also concerned 

that the inclusion of the collector road within the underpass may not be an economically viable option, however considers that its 

timely inclusion is imperative within the area. A mechanism is required to ensure that this is included as part of development, 

concerned with development proceeding in absence of the underpass. 

Seeks the integration of residential development with the rail corridor, in particular how the 40 metre setback area will be designed to 

achieve a high level of amenity. A rural to residential change can tend to have an adverse effect of the visual amenity of the rail 

corridor. This relates to fencing and also the potential effect of weed infestation. 

Supports the ‘Acoustic Insulation and Setbacks’ provisions and rule hierarchy for noise, seeks consistency between provisions, the 

structure plan and the existing District Plan and the provision for vibration effects. Consider the rule should apply to all new, altered 

or relocated buildings and not just habitable rooms. Identifies the need for inclusion of a noise standard to regulate ventilation 

systems. Supports the setbacks and buffer areas. 

Seeks clarification regarding Designation site reference numbers. 

Supports underlying zoning of the rail corridor. 

Considers provision of road names and scale on the structure plan would be help in understanding the boundaries of the 

Whakarongo Residential Area. 

Seeks clarification of the purpose of the railway underpass. 

Identifies a need for a further ‘Resource Management Issue’ to be included in the plan change that relates to the effect of 

development on existing land transport networks and the urban design of associated setback areas. 

Supports policies relating to separation from significant infrastructure as it retains the amenity of residential development and 

prevents reverse sensitivity effects. However, considers an amendment necessary to include noise sensitive activities and ensure 

subdivision design prevents adverse impacts on the safe and efficient operation of rail and transport networks. 

Seeks that the design of the underpass is integrated with the creation of allotments through subdivision. Does not support new at 

level crossings. Seeks that any new at level crossing is a prohibited activity to signal the importance of grade separation. 

Seeks the inclusion of reverse sensitivity issues within the Residential Section of the District Plan via the plan change. This would 

need to include noise and vibration effects that may arise from noise sensitive activities on the efficient operation of the rail network. 

Identifies a need for a clearly defined and measureable setback from the terrace escarpment. 

Notes that ‘noise’ needs to be included as a matter for consideration within the plan change. Supports a restricted discretionary 

criterion relating to reverse sensitivity effects on the rail network. 

Supports the Issue, Objective and Policies in the plan change that relate to noise. 

Seeks an amendment to ensure the rail network is included in consideration of commercial activities within the area. 

Supports the changes to section 9 – Rural Zone. 


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Notes that there is no transportation section included as part of the plan change. 


That Council confirm the pedestrian access and collector road are to be grade separated. 

That Council confirm the approach (funding and responsibility fro development) to develop the underpass. 

That Council introduce a policy and provisions that recognise and require the provision of an underpass. This should introduce a 

mechanism to trigger the requirement for the underpass. 

That Council develop further the urban design context for the rail setback and corridor to achieve amenity commensurate with the 

wider Whakarongo Residential Area and include KiwiRail as an affected party. 

That Council delineate the 40m buffer from the edge of the nearest rail track either side of the rail designation boundary. 

That Council clarify the designation references and amend accordingly to match the relevant designations and amend the Requiring 

Authority reference. 

That Council retain the underlying zoning as Residential. 

That Council add road names and a scale to the structure plan. 

That Council specify the purpose of the underpass. 

That Council add a new ‘Resource Management Issue’ to address transport networks and amend existing Issue 7 to the same 

effect. 

That Council retain Policy 2.6 in Section 7A.3 and amend it to include noise sensitive activities. 

That Council amend R 7A.5.2.1(1) to include the provision of an underpass. 

That Council include level crossings of the railway as a prohibited activity. 

That Council include a new objective and associated policies within the Residential Section (s10.3) to address reverse sensitivity 

and vibration issues. 

That Council amend R 10.7.1.5(c)(iii) to include a defined and measurable setback for the escarpment edge. 

That Council amend R 10.7.1.5(c)(iv) to alter the 30m setback to 40m and include noise sensitive activities. 

That Council amend R 10.7.1.5(e) to include ‘noise’ in the heading. 

That Council amend R 10.7.1.5(e)(ii) to replace ‘living rooms’ with ‘habitable rooms’ to ensure plan continuity and also specifically 

add dwellings and noise sensitive activities. 

That Council add additional text to R 10.7.1.5(e)(iii) to include habitable spaces; all new, altered or relocated buildings used for noise 

sensitive activities; noise from ventilation systems; and, vibration. 

That Council add a new rule to Section 10 addressing effects associated with vibration from the rail corridor. 

That Council add ‘Noise, Acoustic Insulation and Setbacks’ to the performance conditions for the Restricted Discretionary Rule in 

Section 10. Also, include KiwiRail to be considered as an affected party and associated assessment criterion to accompany the 

inclusion of noise as a matter of discretion. 

That Council retain the new Issue to be included in Section 7.2 and Objection 8 and policies 8.1-8.4. 

That Council amend R 10.8.2.2 to include consideration of the rail network and integration of commercial activities with transport 

setbacks. 

That Council add a new policy to Section 9, Objective 1 that avoids rural land adjoining or within the vicinity of land identified for 


10

future urban growth from being fragmented. 

That Council include a new Restricted Discretionary Activity requiring all roads or access ways out onto James Line or Stoney Creek 

Road to be setback a minimum 30m from the rail corridor. 

That Council retain R 10.7.1.5(c)(iv) & (e)(ii) relating to setbacks and buffer areas. 

Submission 

Number 


be heard 

S11 KOA Limited Lisa Poyton, KOA Ltd 

Yes 

PO Box 600 


Submission: 

Supports the plan change to the extent that it allows for the future residential growth of Palmerston North in a planned and integrated 

manner. 

Generally supportive of the measures being introduced to bring about comprehensive subdivision designs and better urban design 

outcomes intended to create pleasant places for future residents to live. 

Concerned with the onerous amount of information that is required to be provided in support of any future subdivision and the 

associated costs of gathering this information and of possible reviews of the information. Therefore, the likelihood of sections in this 

area being able to provide ‘affordable housing’ will be less. 

Identifies a lack of information surrounding the future servicing of the sites and consider that some guidance should be provided by 

Council with regards to likely servicing paths. 

Contends that more information is required through the subdivision process and can foresee a number of issues arising which will 

potentially frustrate future subdivision. 

Recognises the addition of a restriction on the length of cul-de-sacs and identifies that the standards do not indicate how this length 

is to be measured. Understands the context that has brought about this restriction but considers 50m to be too short because of the 

cost of roading versus the number of dwellings to be served and considers this will result in a proliferation of right-of-ways and rear 

sections. 

Considers that the terms ‘road carriageway’ and ‘rail corridor’ will need to be better defined. 

Supportive of more public open space within the City, but seeks clarification over who will pay for such areas. 

Notes the cul-de-sac head proposed adjacent to Whakarongo School and considers this to be sub-optimal in terms of connectivity. 

Notes the discussion on relinquishing the cemetery designation within the residential area and seeks clarification as to whether there 

is any plan to designate elsewhere and whether the Public Works Act requirements have been taken into account. 

Notes no information about development levies has been included in the plan change. 


That Council approves the plan change subject to the matters raised in the submission. 

Submission 

Number 


be heard 

S12 Allan R Fenwick PO Box 204 

Yes 

Marton 

Submission: 

Considers the plan change to have many desirable objectives. 

Has concerns in relation to the level of work completed to ensure the costs associated of development do not preclude affordable 

housing. 

Considers the overall area of the growth area as not being very large for the future growth of the City and that prospective home 


11

owners will have little choice on where they can build. The proposal forces home owners to one area of the City which may not be 

convenient and result in substantial travel costs and additional traffic effects. 

Considers that focusing solely on Whakarongo instead of allowing both City West and Whakarongo appears short-sighted. 


That Council assures that the costs of stormwater drainage and managing natural hazards can be achieved at a cost in kepping with 

providing affordable housing. 

That Council confirm that the land being rezoned is adequate for Palmerston North’s development in the short to medium term and 

that future home owners will have sufficient choice available to them. 

Submission 

Number 


be heard 

S13 Ashmore Trust C/- Lisa Poyton, Kevin O’Connor & Associates 

Yes 

PO Box 600 


Submission: 

Supports the plan change in general terms and considers the rezoning as a logical extension of the residential area and expects the 

future development to complement the existing pattern of development. 

Outlines that the plan change does not appear to contain any calculations with regards to the expected volume of stormwater runoff 

for the area and the corresponding required size of any detention structures and how any increase in the flow of stormwater is to be 

mitigated. No details are given as to where the stormwater is to discharge to, if the intention is for excess stormwater to be 

discharged into the Napier Road Residential Area there will be an effect on the stormwater detention structures designed for this 

area. 

The plan change area will require servicing however the plan change does not detail how the area is intended to be serviced, in 

particular with regard to reticulated services. There also is no indication as to whether there is capacity within the existing 

infrastructure to service the whole plan change area, or whether these are to be staged. 

Seeks assurance that any future services to be installed in the bottom terrace of the Napier Road Residential Area will only be 

required to be provided at the size required to service that area only and that any increase in capacity required will not be installed at 

the submitters cost. 

The submitter has made a significant investment into developing housing in the Rosalie Terrace, Napier Road Residential Area 

area. 


That Council undertakes the work necessary and provides details on how any stormwater detention areas would operate. If the 

Council does not require the additional work prior to the plan change becoming operative the submitter seeks that Council includes 

an additional matter of discretion with regard to ‘hydraulic neutrality’. 

That Council amends the structure plan, or a second page be added, to show the indicative location of extensions to the reticulated 

network, and the pipe sizes required to service the proposed subdivision. 

Submission 

Number 

S14 

Submission: 


be heard 

Ormond Lawson Currie & C/- Lisa Poyton, Kevin O’Connor & Associates 

Yes 

Janice Currie 

PO Box 600 


Supports the plan change in general terms to rezone the area identified from Rural to Residential Zone. 

Considers access to the submitter’s site will be restricted due to it being ‘landlocked’ with access being dependent on the link roads 

being constructed. This restricts the submitter on when it can be developed by when either of the neighbouring blocks are 

developed. If such landowners do not develop this would leave the site virtually undevelopable. Designating the roading corridors 

could be a solution enabling Council to acquire the land and construct the roads via development levies which could then be 


12

eimbursed by once the sites are developed. 

Not unsupportive of having a walkway on the upper terrace area, however it is considered that it would be better if this was to be 

located adjacent the railway corridor. Considers that it would be more efficient to use the railway setback area rather than having the 

walkway cut through private property and would also be a logical connection to public open spaces. The average lot sizes are 

considered difficult to meet on the upper terrace of the submitter’s site when the rail setback is taken into account let alone the 10m 

escarpment setback. 

Considers that the railway has potential to generate noise that will affect future dwellings, an acoustic fence is requested to be 

allowed regardless of the location of any future walkway. 

The submitter’s site contains part of the stormwater detention area (oxbow), the implications of this are not clearly set out in the plan 

change and there is no comprehensive stormwater management plan that details the volume of water that any pond are will need to 

contain. Considers that due to the bottom terrace being in multiple ownership that careful planning and management will be 

required, therefore these issues need to be clarified. Questions who will be required to develop the stormwater infrastructure. 

Notes that there is no detail about how the area is to be serviced within the plan change and whether there is capacity available for 

its development. 

Noted that there has not been a preliminary geotechnical investigation of the subject site with regard to site stability, instead 

investigations have been focused on liquefaction risk. Considers that if this is to take place after the plan change is approved that 

this is too late. 

Noted that some site contamination assessments have been completed as part of the plan change which signalled levels were 

below the threshold for residential development. However, there is a potential ‘hotspot’ of contamination with regard to landfill gas 

migration. If migration has taken place then this could eliminate approximately 10% of the plan change area. It is also noted that an 

engineer is required in the plan provisions to comment on potential contamination, considers that a environmental scientist would be 

more appropriate to complete this. 

Notes that the existing traffic is busy and will only get busier following the completion of the plan change and that no traffic 

assessments have been included within the plan change. 


That Council clarify its intention with regards to the status of the walkway and that is be relocated to within the railway setback area. 

That Council amends R 10.7.1.5(c)(iv) and (e)(i) to allow a residential building within the 30m setback area for the railway and the 

40m setback for the state highway upon provision of acoustic mitigation to meet the internal noise standards. 

That R 10.7.1.5(g)(i) be amended to allow 1.8 high acoustic fencing within the railway setback area within the submitters site. 

That Council clarify the location and extent of servicing required for the residential area to be developed and the ownership of this 

infrastructure. 

That Council ensure that the plan change area is sufficiently stable for residential development and that a full geotechnical report be 

undertaken by Council to determine this and to confirm whether the 10m escarpment setback is appropriate. It is considered that the 

completion of this will negate the need for Policy 3.2. 

That Council undertakes full investigations with regards to potential ‘hotspot’ contamination to ensure the land is suitable for 

residential development. 

That Council undertakes a full traffic assessment to confirm the effect of increased traffic on the existing transport network and 

implements traffic calming measures with a view of promoting traffic safety. 

That Council designate the indicative collector road up to the boundary of the submitter’s site. 

Submission 

Number 


be heard 

S15 Paul G Robinson 545 Napier Road 


No 


13

Submission: 

Submitter’s property will no longer have direct access onto the state highway and will be cut in two by the proposed indicative 

collector road and neighbourhood centre. 

Considers a loss of privacy will result from the changes and possible encroachment onto the submitter’s land from the proposed 

walkway. Stock on the submitter’s property will be less protected. 

Notes compensation in regard to land values. 


That Council conduct more direct consultation with affected land owners. 

Submission 

Number 


be heard 

S16 Philip H Pirie PO Box 10050 

Yes 


Submission: 

The proposed plan change rules do not provide for a Controlled Activity category for any subdivision except for utilities. Having all 

subdivisions defined as Restricted Discretionary Activities does not provided certainty for any applicant and incurs unnecessary 

costs for applicants. 

Considers the policies to be unnecessarily restrictive and to incur unnecessary costs and supplicates exiting processes. Also, 

consent notices for foundations are not required except for unusual circumstances. The design of earthworks and re-contouring is 

not the sole realm of a ‘registered engineer’, other experts such as surveyors are appropriately trained. 

The proposed subdivision matters to be considered are unnecessarily detailed and require extensive reporting at the time of 

resource consent and are macro considerations that would already have been completed as part of rezoning the land. Considers 

that all specific matters can be dealt with as conditions of consent. 

Considers there to be no justification for minimum and maximum lot sizes and that the average lot size will ensure that there is not a 

proliferation of undersized or oversized lots. This does not provide for subsequent densification. As adequate provisions exist for 

bulk and location, there is no need for a minimum lot size. When calculating the average lot size, there is no preclusion of public 

land. 

Considers the restricted length of cul-de-sacs to be impractical. Such roads will be uneconomical to construct and does not provide 

sufficient frontage to lots. This will result in an increase of rear lots and there is no definition as to how a cul-de-sac is to be 

measured. Also, inappropriate as not in accordance with desires of future residents who prefer to live on quiet streets. 

Considers the requirement for landowners to provide access to adjoining property as land theft by stealth. 

Notes that the plan change encourages landscaping however does not provide any details on the type of landscaping Council will 

accept or who will be responsible for the maintenance of it. Furthermore, there is no provision for any reimbursement of costs by 

Council to the developer. 

Details have not been provided of Council’s expectations of where services are to be connected and how servicing is to be 

achieved. Provisions for innovative stormwater management as a first choice have also not been included. 

The plan change identifies two natural hazards being terrace slope and flooding and the submitter considers that the proposed flood 

avoidance measures exceed the current District Plan and will unnecessarily increase development costs. 

Considers the separation distance requirement for the siting of buildings to be too restrictive and limits building size on smaller lots. 

Notes that an inconsistency is created for accessory buildings compared to dwellings. Considers there to be no engineering basis for 

the terrace/oxbow setback nor any planning justification for the setback from the railway tracks. 

Limiting the number of dwellings per site does not provide for a range of development and investment options for landowners, 

should be focused on standalone buildings used for living irrespective of their size. 

Considers the provision of insulation and a setback is unnecessary for both the State Highway and the railway, acoustic insulation 

has not been required for any dwellings adjacent the railway in the past. 


14

Considers there to be no basis for retaining the present on-site amenity requirements which now excludes verandas, conservatories 

and potentially shade sails and decks which are all well-established features of living areas. No reason for restricting the position of 

accessory buildings, particularly where they have the same function as parts of the dwelling. 

Considers the fencing requirements to unnecessarily restrict a landowner’s right to construct a fence. 

Notes that policies 8.2 and 8.3 (s7) do not define ‘residential nature’ and have the potential to prevent any subdivision of rural land 

for lifestyle purposes. No clarification of which areas of rural land are of concern. 

Considers the area identified in Map 9.1 as being appropriate for urban development and should be retained and protected for future 

development. 

Notes that there is no detail on the upgrading of the surrounding roading network and who is to be responsible for these costs. Notes 

that there is provision for an underpass within the residential area however no provision for underpasses James Line or Stoney 

Creek Road despite a significant increase in traffic, current rail crossings are below standard. 

Notes that there is no detail about the impositions of development contributions for the area, development contributions are a 

significant cost for developers and given the extensive servicing for this area need to be investigated and provided for scrutiny. 

Concerned that this has potential to be contrary to providing affordable housing and considers it critical to establish true economic 

costs. 

Notes that the proposal does not consider the effects upon other areas of the City for residential development and imposes a regime 

of rules which is not in accordance with nearby recent developments. It appears to be an attitude that the area is the only part of the 

City suitable for residential development and the preferred option of all residents. The proposal needs to reflect that this is one area 

of a number of growth areas in the City and retain the option of development above the cemetery and not actively discourage 

development at other locations such as Cloverlea, Longburn, Ashhurst and Aokautere. 


That Council creates a Controlled Activity category with performance conditions as per the current subdivision rules. 

That Council amend policies 3.2 and 3.3 (s7A) to remove the standard requirement for consent notices being placed on all lots and 

be placed only on those lots that require specific design and remove references to ‘Registered Surveyor’ and replace with ‘Suitably 

Qualified Professional’. 

That Council amend the specific details in R 7A.5.2.2(a) to only those matters of a general nature with conditions being imposed 

upon the consent as and when appropriate. 

That Council delete references to minimum and maximum lot sizes and includes a provision to exclude public land when calculating 

the average lot size. 

That Council include a provision that ensures the average lot size does not apply when there is not any increase in the number of 

titles being created, and for situations of densification the average lot size be assessed with regard to the entire subdivision that 

initially created the lots rather than the area involved with the current application. 

That Council define how a cul-de-sac is to be measured and provide for cul-de-sacs up to a maximum length of 300m and ensure 

that pedestrian access is available to nearby public areas where the length is over 200m. 

That Council remove restrictions applying to cul-de-sacs and rear sites. 

That Council provide details of reimbursement to developers when providing access for the benefit of adjoining properties. 

That Council provide details of plantings and landscaping acceptable to Council, including extent, location, type and who is 

responsible to maintain it. 

That Council provide details of where Council connection points are proposed and if Council is to install services to these positions. 

Also, to include a statement that developers are only responsible for the size of services for their development and provide a timeline 

and costs of how services are to be provided to ensure orderly economic development. 

That Council determine the building line setbacks for the terrace. 


15

That Council amend the details for stormwater management to conform with NZS 4404:2010 and provide for innovative stormwater 

management as a first choice. 

That Council retain the existing District Plan residential separation distance requirements with some amendments. 

That Council accurately define the setback line at the top and bottom of the escarpment. 

That Council delete the railway setback requirement. 

That Council remove the limit of one dwelling per lot and create a new regime for notional lots to ensure amenity is achieved 

irrespective of the number of dwellings per lot. 

That Council delete R 10.7.1.5(e) in its entirety. 

That Council delete R 10.7.1.5(f) in its entirety and retain the existing operative R 10.7.1.1(e). 

That Council delete R 10.7.1.5(g) in its entirety. 

That Council redraft policies 8.2 and 8.3 in Section 7 of the District Plan to clearly state that the concern relates to normal residential 

development in rural area rather than relating to lifestyle development. Also, to define the extent of rural areas that require this level 

of protection. 

That Council delete the entire amendment to Section 9 and maintain provision for future urban growth as shown on Map 9.1. 

That Council provide detailed planning, timeline, identification of responsibilities and costs of how roading and the rail underpasses 

are to be provided to ensure orderly and economical development. 

That Council, prior to continuing consideration of the plan change, provide full details of development contributions to be charged to 

determine the economic viability of the proposal. 

That Council amend the plan change to state that the area is one option for the extension of the residential area of the City and 

retain the option for land above the cemetery. Remove references and inferences that the area is the only viable option. 

Submission 

Number 


be heard 

S17 Peter B Wealleans 514A Albert Street 

Yes 


Submission: 

Questions whether the Council, when it made its decision to proceed with the Whakarongo area, considered all the relevant costs 

and access problems associated with the area and has the area been compared the cost structure of the area to other land available 

which is better situated to all City services. 

Questions whether there has been sufficient land made available for a diversity in housing affordability. 


That Council submit the overall costs of the Whakarongo residential development compared to other available residential land. 

Submission 

Number 

S18 

Submission: 


be heard 

Mr Robert Brownrigg & Mrs 42 James Line, RD10 

Yes 

Susan Blewitt 


Fundamentally support the proposed plan change, however there is a proposed possible road/right-of-way shown as running 

through the submitter’s property to which is opposed. 

Notes that their understanding was that the road shown was to enable possible access to the small strip of land above the 

escarpment which is part of the property at 529 Napier Road. Consider that once the escarpment and railway setbacks are taken 

into account that only a small piece of land is available to be developed and serviced by the proposed road. Also, that the inclusion 

of the road to service a small piece of land would compromise further the ability to develop the submitter’s land. 


16

Notes the proposed terrace escarpment setback and indicates an intention to engage the services of an engineer to confirm if the 

land is stable and would support residential development within 4 meters of the boundary above the escarpment. 


That Council removes the proposed right of way through 42 James Line. 

That Council, subject to a geotechnical report, grant permission to build within a safe distance from the escarpment which may be 

less than 10m. 

That Council provide more information on the proposed walkway that is shown on the structure plan. 


17

Part II: Submitter Address List & Copies of Original Submissions 

Submitter Address List 

Submitter 

number 

Name Address Support/ 

Oppose 

SO1 David C Parham 24 Logan Way 

Support 


SO2 Palmerston North Airport Roy Bodell, Facilities PO Box 4384 

Support 

Ltd 

Manager 

Palmerston North, 

SO3 NZ Transport Agency Cole O’Keefe, Resource 

Planner 

4442 

PO Box 1947 

Palmerston North, 

4440 

SO4 Palmerston North City 

Council 

Paddy Clifford, Chief 

Executive 



SO5 Eric Constantine 6 Tiller Close 


SO6 PN Industrial & 

Mr M J Slyfield 

PO Box 117 

Residential 

Stout Street Chambers Wellington 6140 

Developments Ltd 

SO7 Beckford Partnership C/- Amanda Coats, 

Proarch Architects Ltd 

SO8 RACE Inc Ryan Ayers, Chief 

Financial Officer 

SO9 Manawatu-Wanganui Nic Peet, Group Manager 

Regional Council 

Strategy & Regulation 

PO Box 1105 


PO Box 52 



Manawatu Mail Centre 


S10 KiwiRail Holdings Ltd 

(KiwiRail) 

Deborah Hewett, RMA 

Advisor 

PO Box 593 

Wellington 6140 

S11 KOA Limited Lisa Poyton PO Box 600 


S12 Allan R Fenwick PO Box 204 

Marton 

S13 Ashmore Trust Lisa Poyton, Kevin 

PO Box 600 

O’Connor & Associates Palmerston North 

S14 Ormond Lawson Currie C/- Lisa Poyton, Kevin PO Box 600 

& Janice Currie 

O’Connor & Associates Palmerston North 

S15 Paul G Robinson 545 Napier Road 


S16 Philip H Pirie PO Box 10050 


S17 Peter B Wealleans 514A Albert Street 


S18 Mr Robert Brownrigg & 

42 James Line, RD10 

Mrs Susan Blewitt 


Generally 

Support 

Does not 

State 

Support 

Support/ 

Oppose 

Generally 

Support 

Oppose 

Generally 

Support 

Generally 

Support 

Generally 

Support 

Does not 

State 

Generally 

Support 

Generally 

Support 

Does not 

State 

Does not 

State 

Does not 

State 

Generally 

Support 

Hearing 

Yes 

No 

Yes 

Yes 

Not stated 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

Yes 


18

Copies of Original Submissions 


19

Summary of Decisions Requested - Palmerston North City Council

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