Chapter 8 Transportation Introduction 1. Chapter 8 of the PDP contains provisions concerning the development, maintenance and use of the transport network and associated activities. It recognises that the transport network is essential to the well-being of the district, but that it requires a large amount of resources and has the potential to cause adverse effects. 2. The Chapter contains one overarching objective which is to be implemented through six policies and a rule framework that manages activities within roads and rail corridors, vehicle accessways, vehicle crossings and car parking. 3. Chapter 8 also contains Appendix 8.1 which lists the road classifications for roads within the District, being: strategic arterial; district arterial; collector; and local roads. Access site lines, separation distances, vehicle crossing standards, construction standards, parking, loading and vehicle tracking curve standards are also specified in diagrams (Figures 8.1 to 8.17). Key Issues for Resolution 4. The submissions received on this Chapter generally support the objective and policy framework, and largely seek changes that relate to how these are implemented/achieved. This includes: - Whether the PDP should encourage cycling further by requiring a minimum level of cycle parking - Whether the roading classification in the PDP should be amended to align with NZTA s One Network Road Classification - Whether some activities should be exempt from the proposed car parking requirements Statutory Context 5. There are a number of other statutes, such as the Local Government Act 2002 and the Land Transport Management Act 2003 that impact on the way that the transport network is managed. The CRPS also contains policies that relate to the transport network. Of most relevance, Policy 5.3.8 seeks to integrate land use and transport planning in a way that promotes the safe, efficient and effective use of transport infrastructure and to manage the adverse effects from the development, operation and expansion of the transport system. Expert Advice 6. During preparation of the PDP, the Council engaged Novo Group to assess the on-site car parking requirements in the ODP. The review examined the operative rules, surrounding territorial authorities rules and best practice standards. Recommendations were then adopted into the PDP as appropriate. Planning Assessment 7. The approach taken to assessing submissions on Chapter 8 is a topic-based approach. 1
General Submissions across Chapter 8 or Whole of PDP 8. NZTA request a number of minor amendments to the proposed wording of Chapter 8 and the PDP in general. These largely relate to using consistent and up-to-date terminology and references to external agencies and legislation. I recommend that these are accepted on the basis that they improve the consistency and clarity of the provisions. The amendments are: - Replace references to Transit NZ or New Zealand Transport Agency or NZTA with NZ Transport Agency. - Replace references to Transit New Zealand Act 1989 with Government Roading Powers Act 1989. - Replace any reference to state highway or highway in lower case with upper case e.g. State Highway 1 (41.24). Objective and Policy Framework 9. Objective 8.1 reads: A safe and efficient transport network that services the current and future needs of all users. 10. Policy 8.4 reads: To require footpaths and cycleways in urban areas, and to encourage walkways and cycleways in rural areas, while maintaining the safety and efficiency of the road network. Submissions 11. Five submissions in support were made on Objective 8.1, and no submissions were received seeking changes. Similarly, there were only submissions in support of Policies 8.1 & 8.5, and no submissions at all on Policy 8.6. Submissions seeking changes to Policies 8.2 and 8.3 are related to wider issues and are assessed in the Cycle Parking and One Network Road Classification sections below. 12. NZTA supports the intention of Policy 8.4 to encourage walkways and cycleways, but considers that their provision needs to be balanced with the need for the existing network to be both safe and functional. My view is that the policy already provides this balance, but I consider that the use of the word functionality rather than efficiency would be more appropriate. This is because in my view, functionality better reflects the intent of the policy, and ultimately, maintaining the functionality of the network is overall part of ensuring the network is efficient, which is part of the overarching objective. Cycle Parking 13. Currently, there are no requirements in the PDP for the provision of cycle parking. The relevant policy is Policy 8.2, which reads: 2
To ensure that the roading network within urban areas is sufficiently wide to provide adequate space for on-street parking, walkways, cycleways, open space character, services, and amenity planting. Submissions & Discussion 14. CDHB support Policy 8.2 but seeks that cycle parking is included in the definition of Policy 8.2. Related to this change, CDHB seek that this is implemented through adding a new rule requiring minimum cycle parking requirements, suggesting the use of cycle parking requirements from the proposed Christchurch City Replacement District Plan. CDHB further seeks that a new assessment criterion is added that requires a Travel Demand Analysis is used to determine the expected provision of cycle parks and on-site car parks and to allow for car parking offsets where more than the minimum number of cycle parks are provided. 15. My view is that these changes are not appropriate in the context of the Hurunui District. While I accept that the provision of cycle parking is one way to encourage active transport modes, my view is that in itself does not mean it is not appropriate to require it. The Townships in the District are small and entirely different in character to Christchurch City. The commercial areas in these Townships are also largely established, meaning that cycle parking would be provided in a sporadic way only where a new or altered development took place. Cycling in Hanmer Springs is already common, and I am not aware of any issues arising from cycle parking not being required through the ODP provisions. 16. Overall, my view is therefore that requiring minimum cycle parking standards would not be efficient or necessary in order to achieve a transport network that services the current and future needs of all users. This does not interfere with the ability for individual developers to choose to provide cycle parking, or the Council s ability to provide public cycle parking if there is demand for doing so. Further, I consider that while in some cases the provision for car parking may be able to be offset by cycle parking, it will not be appropriate in all instances and therefore should not generally be allowed through the assessment criterion. Recommendation 17. Retain Policy 8.2 without amendment. One Network Road Classification 18. There are a number of provisions in the PDP that relate to the classification for roads within the District. This includes Appendix 8.1 which sets out the current roading classifications, which fall into the following four categories: strategic arterial; district arterial; collector road; and local roads. 19. The relevant policy is Policy 8.3, which reads: 3
To develop a functional classification of roads and use it as a basis for determining adjacent land use, vehicle access and traffic management controls, road maintenance and improvement programmes, based on the intended function of each road. Submissions and Discussion 20. NZTA supports the intention of Policy 8.3 but seeks that it is amended to provide reference to the One Network Road Classification (ONRC). They agree that a functional classification of roads is valuable in achieving the district s transportation objectives. They state that their ONRC has been developed, in consultation with local authorities, to address this issue and therefore consider it could be incorporated into the PDP to help achieve the success of the policy. This would also necessitate a revision of the roading classification categories in the PDP and consequential amendments to all related rules and appendices. 21. I have two main concerns with this request. The first is that while NZTA has stated that they can provide information on classification criteria to confirm the appropriate categories, this is as far as they have gone in terms of identifying how the ONRC might apply in the District. In my view, there is difficulty, even if such criteria were provided, in expecting the Hearings Panel to undertake this classification. My second concern is that my understanding is that the roading classifications are used for much broader purposes than the PDP, and therefore changing them within the PDP would have a much wider effect on things like asset management planning. My view is that if the Council s asset staff move to the ONRC system, it would then be appropriate to update the PDP to align with this. However I do not consider it appropriate to pre-empt this, and make changes to the PDP that could potentially force a change in asset management planning. Recommendation 22. Retain Policy 8.3 and Appendix 8.1. Permitted Activities 23. Rule 8.4.2 provides for activities within roads or rail corridors, or vehicular access to and from roads as permitted activities, provided they meet the standards in Rule 8.4.3. Subject to the standards, activities within roads that are permitted are limited to those associated with the development, use and maintenance of the roading network (Rule 8.4.2.1). Submissions & Discussion 24. MainPower seek that Rule 8.4.2.1 is amended to include any activity within the road associated with the installation, maintenance, repair, replacement or upgrading of utilities. They consider it appropriate to recognise these activities within the rule. While I agree in principle that utilities within the road should not require consent under the provisions in this Chapter (and note that they will still be subject to standards in other chapters), my view is that the amendment is not necessary as 8.4.2.1(a) already allows for any activity associated with the use of the roading network, and this would include utilities that use the network. 4
25. Winstones seek that the Chapter is amended to reflect its submission points with respect to transporting aggregates, and more specifically seek that mineral extraction activities are permitted. It is not clear to me what changes are sought to the Transportation provisions as they relate to their wider submission points with respect to transporting aggregates. As such I am unable to assess the appropriateness of any changes relating to this topic. In terms of providing for the transportation of aggregates as a permitted activity, I note that the rules in the Chapter already provide for this, subject to compliance with the conditions in Rule 8.4.3. This is because under Rule 8.4.2.1, activities within the road that relate to the use of the road network are permitted (subject to the conditions). Accessways 26. Rule 8.4.3.2 sets out the conditions that vehicle access to local or collector roads generating up to 100 equivalent car movements per day must meet in order for the activity to be permitted. This includes standards (a)(vi) and (b)(v) requiring a setback from the corner of road intersections for any new vehicle crossing, outside or within urban areas respectively. Rule 8.4.3.3 sets out the minimum access way and roading requirements for private right-of-ways and roads. Submissions & Discussion 27. Ngāi Tahu Farming seek that construction activities are exempt from these requirements on the basis that Rule 3.4.3.16 in the Rural Chapter, relating to vehicle movements, exempts those associated with construction and the amendment sought would ensure consistency. My view is that the rules have slightly different purposes. The Rural rules relate to the control of vehicle movements to and from a site from the point of view of both road safety and amenity effects associated with vehicle movements, such as noise, dust and vibration. The vehicle access standards in the Transportation Chapter are more focussed on safety and efficiency of the road network. While the effects of vehicle movements from construction activities on amenity is temporary (and hence the exemption in Rule 3.4.3.16), damage to the road could be sustained during construction if there is no appropriate vehicle access constructed. However, I consider that this needs to be balanced against the costs of requiring an access be established for every single construction activity. In this regard I note that provision of a complying vehicle access is also generally required at the time of subdivision, to ensure that one is in place prior to building on new lots occurring. This means that most construction activities are likely to make use of a complying access. Taking this into account, on balance I consider that the exemption is appropriate. 28. KiwiRail seek that the setback from road intersections is extended to level crossings, seeking a 30m setback from level railway crossings in both rural and urban areas. KiwiRail note that while level crossing accidents are rare, they are severe, and in order to minimise potential safety issues associated with the location of new vehicle crossings in proximity to level crossings, seek a minimum separation distance. I note that in the case of rural areas, the 30m setback sought is consistent with that required from intersection, but in urban areas, the setback from 5
intersections is only 15m. In my view, a setback from a railway crossing for new vehicle accesses is appropriate to ensure the safety and efficiency of the road network. However, given the close proximity of development in urban areas and the low speed environment, I do not consider a greater setback of 30m is justified. As such, I recommend that a setback from level crossings is consistent with that for intersections. I note that where a crossing is proposed within this setback distance, it can be considered on a restricted discretionary basis under Rule 8.4.4.1(b). 29. KiwiRail seek that an additional condition is added to Rule 8.4.3.3 to require all existing and new accesses and roads that cross an operational rail network via a level crossing to be maintained in accordance with sight triangles that are provided in Appendix 1 to their submission, also seeking that this is added into the PDP as a new appendix. My understanding of the sight triangles is that they seek to control buildings and structures located within areas near level crossings, in order to achieve clear visibility near crossings. I have a number of concerns about the standards proposed, the first of which is that I do not understand how the sight triangles relate to private right-of-ways and roads, as these are not buildings or structures. KiwiRail do not appear to have sought that buildings and structures be restricted within these areas through the zone-based standards in Chapters 3 & 4 of the PDP and I do not see how they can be applied to rights-of-way and roads. Further, the standard proposed seeks to require that existing accesses are maintained in accordance with the sight triangles, and my understanding is that existing accesses have existing use rights while they remain the same or similar in scale and character and as such district plan rules cannot require existing activities to be upgraded to meet a new standard. For all of these reasons I consider the standard sought is unclear and unworkable. 30. Fire Service consider that it is necessary that access suitable for firefighting appliances is provided in order to gain access to both the water supply and the source of the structural fire. They state that a fire fighting appliance requires access which is 4 metres in width and 4 metres in height, with a gradient that does not exceed 16%, as specified in the NZFS Code. As such they seek that Rule 8.4.3.3 is amended to require that where any onsite supply for firefighting is provided, access must comply with the dimensions in the New Zealand Fire Service Firefighting Water Supplies Code of Practice SNZ PAS 4509:2008. Similarly, they seek that the minimum carriageway width (contained in Table 8.1) for a private right of way or road servicing 1-4 lots is increased from 3m to 4m. I consider that access to water supply for fire fighting is part of achieving a safe transport network, and therefore I agree with the amendment sought by Fire Service to increase the minimum carriageway width in Table 8.3 to 4m. While I accept that there are some additional costs associated with providing a wider carriageway, I consider that these are outweighed by the benefits of ensuring adequate access for fire fighting appliances. However, based on the advice of HDC s Consents Engineer, my understanding is that access to onsite firefighting water supplies is only required in the Rural Zone, as fire fighting water in urban areas is not located on properties but instead via fire hydrants located in road reserve. As such I recommend that the proposed widths are retained within Settlements but increased within the Rural Zone. Based on the advice of HDC s Consents Engineer, as a consequence of this change, the legal width required should be increased to 5.5m in order to allow 1.5m for services etc beyond the formed carriageway. He has also advised that the legal width for 5-6 lots should be increased to 7m to also provide for a minimum of 1.5m beyond the formed 6
carriageway and the Settlements legal width increased to 4.5m for the same reason. While I agree with this in principle I have concerns that it may be beyond the scope of submissions. 31. However, I have some concerns about adding the additional standard sought by Fire Service which refers to an external document, and the inability to weigh up the full costs of the additional requirements this might impose, as well as the potential inconsistencies this standard would have with the currently proposed standards. For example, I note that it appears that the Code requires that the surface be sealed, whereas the standards otherwise proposed in Rule 8.4.3.3 would not require sealing where access is provided off metalled (rather than sealed) road. Similarly, the Code requires that in general the roading gradient should not exceed 16%. I do not consider reference to in general to be appropriate for reference in a permitted activity rule and again note that this is potentially inconsistent with standard (v) that allows for the right-of-way or private road in a rural area to be a steeper grade than 1:5, provided it is formed and sealed. Recommendation 32. Amend Rule 8.4.3.2(a)(vi) as follows: (vi) New vehicle crossings must be at least 30 m from a level railway crossing, and the corner of an intersection with two or more carriageways except where the access is onto a side road which joins either a strategic or district arterial road, then the distance must comply with Distance M in Table 8.1 and Figure 8.2. 33. Amend Rule 8.4.3.2(b)(v) as follows: (v) New vehicle crossings must be a minimum of 15 m from a level railway crossing, and the corner of an intersection of two or more carriageways except where the access is onto a side road which joins either a strategic or district arterial road then the distance must comply with Distance M set out in Table 8.1 and Figure 8.2; 34. Amend Table 8.3 as follows (noting that some of these recommendations are subject to scope): Table 8.3 Width standards for private right-of-way & private roads No. of actual or potential lots Legal width 1-4 (Within Settlements) 4.05 m 3.0 m 1-4 (Within Rural Zone) 5.5 m 4.0 m 5-6 6.5 7.0 m 5.5 m Carriageway or seal width Car Parking 35. Rule 8.4.6 sets out when the standards for on-site car parking apply, which generally relate to where a new activity is established on a site, there is a change of activity or a building is substantially changed. Rule 8.4.7 then sets out the requirements for on-site car parking. Rule 7
8.4.8 states that any activity that does not meet the on-site car parking standards and is not otherwise specified as a restricted discretionary activity, is a discretionary activity. Submissions & Discussion 36. The Oil Companies note that the way the rules are drafted does not explicitly state that car parking is a permitted activity, provided the standards in Rule 8.4.7 are met. They seek that Rule 8.4.6 is amended to explicitly state that car parking is permitted provided it meets the standards. I note that the layout of the rules in Chapter 8 differ from those in other chapters, where usually all permitted activities are listed under one rule, all permitted activity standards under the next rule, then all controlled activities and so on. In this case, what is intended to be the permitted activity standards for car parking are not included under Rule 8.4.3 and instead follow the discretionary activity rule (8.4.5). However there is then another discretionary activity rule (Rule 8.4.8). I agree with the submitter that there is a need to explicitly permit parking, and recommend that this is achieved by moving the car parking rules so that they align with the permitted rule (8.4.2) and the standards are contained under Rule 8.4.3. While this is slightly different to what was sought by the submitter, it ultimately has the same effect and in my view makes the Chapter much easier to follow and more consistent with the structure of the whole PDP. 37. The Oil Companies also seek that Rule 8.4.6 (now recommended for inclusion in Rule 8.4.3) is amended to avoid ambiguity and misinterpretation, as they are concerned that currently the rule requires parking to be reassessed if a building is reconstructed. They consider that this has the potential to undermine existing use rights under section 10 of the RMA, and argue that reconstruction of a building or alterations should only require a reassessment of parking where the gross floor area is being increased. I agree with the submitter that it is where the scale of the activity on site increases that the parking should be reassessed and therefore recommend their submission is accepted. 38. Winstones seek that mineral extraction activities are excluded from parking provisions, because of the typical size of the site and nature of operations. I note that there are a number of other activities within the District that would also be typically large in size and do not consider there is anything particular about mineral extraction activities that necessitates their exclusion from the requirements. In particular, it is not clear how excluding these activities would implement Policy 8.5 which requires on-site parking to provide for the needs of any activity. 39. MainPower seeks that unstaffed utilities and unstaffed commercial scale and community scale energy activities are exempted from the requirement for on-site car parking. In my view this is different from what is sought by Winstones because where these facilities are unstaffed, there is not a need for parking associated with everyday operations. In addition I note that many utilities are likely to be designated and therefore will not be subject to car parking requirements in any case. As such, I consider the exemption is appropriate. 40. MOE seek that the on-site car parking standards pertaining to the educational category are deleted. They consider that the proposed standards are excessive, particularly the requirement for Primary Schools, and do not consider it efficient or appropriate to increase the level of hard areas for car parking ahead of essential education property needs. In my opinion it would not 8
be appropriate to delete the standards, as this would not implement Policy 8.5 in terms of ensuring that on-site parking is provided for the needs of this type of activity. Deletion of the category in its entirety would also mean that there would be no standards for pre-schools or daycare centres. With regard to schools, I note that the majority of schools are in any case designated, and therefore not subject to the rules in the PDP. In my view, if the standards are demonstrated more clearly to be excessive, it would be more appropriate to reduce the ratio of parks required. Deleting the category in entirety is, in my view, not an appropriate approach and would be inefficient and ineffective at implementing Policy 8.5 and ultimately achieving Objective 8.1. 41. HDC consider that the current wording of the on-site parking requirements for Business activities is unclear, in that it is not clear whether the requirement for Plus 1 per 2 employees applies only in the Business Zone in Hamer Springs, or to all business activities. They seek that it is explicitly added so that it applies to any business activity. In my view this is appropriate and reflects the current approach in the ODP. 42. The Oil Companies seek that the discretionary activity rule which applies where the on-site car parking standards are not met, should be amended so that these are considered as a restricted discretionary activity. In my opinion, a restricted discretionary status is appropriate where the effects of an activity are well-known and can be easily captured in matters of discretion. I note that those matters of discretion proposed by the Oil Companies are limited to (a) Location, size and design of parking areas; (b) Access to parking areas; (c) Scale, management and operation of an activity as it relates to demand for parking. In my view, there are a number of other matters that these do not cover, including: whether a reduction in car parking area is appropriate when considering the activity on site (i.e. is the parking sufficient to meet anticipated demand); the extent and use of on-street parking in the vicinity of the site (or other public parking); the potential effect on the roading network from flow-on effects of less parking space on site (including the appropriateness of queuing space). In my view, the rule sought by the submitter is too narrow and does not allow for a complete assessment of on-site parking. As such, my view is that the discretionary status should be retained as this is more appropriate to implement Policy 8.5 and achieve Objective 8.1. Recommendation 43. Amend Rule 8.4.2 as follows: 8.4.2 Permitted activities The following activities are permitted activities, provided they comply with the Standards in Rule 8.4.3: 4. On-site car parking 44. Move Rules 8.4.6 and 8.4.7 so that they are included under Rule 8.4.3 (Conditions for permitted activities). 45. Amend Rule 8.4.6 (now under 8.4.3) as follows: 9
The following standards for on-site car parking apply where: (a) An activity is established on a site; or (b) There is a change of activity; or (c) A building is constructed or the floor area of a building substantially reconstructed, altered or added to. The standards do not apply to unstaffed utilities, unstaffed community scale energy activities or unstaffed commercial scale energy activities. 46. Amend Business Category in on-site parking requirement table as follows: 1 per 45m 2 GFA and outdoor retail area (including all display areas but excluding the forecourt areas of service stations), except where a building is designed to accommodate eating purposes or drinking alcohol then parking will be 1 per 4 licensed or design customer capacity (whichever is the greater) excluding in the Business Zone in Hanmer Springs. Plus 1 per 2 employees. In the Business Zone in Hanmer Springs where a building is designed to accommodate eating purposes or drinking alcohol then parking will be 1 per 8 licensed or design customer capacity (whichever is the greater). Plus 1 per 2 employees. Assessment Criteria 47. Rule 8.5 provides a series of assessment criteria that are split into those pertaining to: traffic generation; activities in road reserve; parking standards; access for rural selling places; and property accesses. Assessment criterion 8.5(a)(i), which relates to traffic generation, reads: Any adverse effects in terms of noise and vibration from vehicles entering or leaving the site or adjoining road, which is incompatible with the noise levels acceptable in the area Submissions 48. NZTA seeks that the criterion is amended to include information on what the acceptable noise and vibration levels referred to are, as they state that it is not clear what level of noise or vibration an activity would have to create to not meet this. In my view the criterion is indicating that the existing level of noise in an area, as well as the permitted baseline under the relevant noise standards should be considered in the consent process. The criteria in the PDP are generally worded along these lines, providing direction on the matters that should be considered, rather than providing a checklist that an activity must meet in order for consent to be granted. Therefore, to stipulate a level of noise or vibration would, in my view, be more appropriate to include in a standard rather than an assessment criterion. I therefore recommend the criterion is retained without amendment. Figures 49. There are a number of figures in Chapter 8 which are linked to the rules within the Chapter and set out requirements for various activities, e.g. vehicle crossing standards. Figure 8.13 sets out 10
the manoeuvring parking space dimension requirements and includes a table which shows varying requirements based on the angle of the park, from 90 degrees to a parallel park. Submissions & Discussion 50. MOE seek that Figure 8.13 is deleted and replaced with Rule A1.2.17 of the ODP. They note that while the proposed table simplifies the requirements, it has removed an element of choice for plan users. I note that the operative table is much more complex and provides a range of different car park widths for each varying degree of car park. In my opinion, the proposed table is a simplified and streamlined version that will assist in encouraging greater consistency in design of car parks. In my view this is more appropriate than the more complex operative table and is easier for plan users. As such I recommend retaining Figure 8.13. Definitions 51. Equivalent car movement per day and vehicle movement are defined separately in the PDP as follows: Equivalent Car Movement per day Is averaged over a year and is defined as follows: 1 car to and from the property = 2 equivalent car movements 1 truck to and from the property = 6 equivalent car movements 1 truck and trailer to and from the property = 10 equivalent car movements. Vehicle movement means the movement of motor vehicles onto or off a site over a 24 hour day, averaged over any one week (seven days). Submissions & Discussion 52. G Mitchell requests deletion of both definitions, or alternatively that these definitions are combined. I note that equivalent car movements are used to estimate traffic types and quantities over an extended period, and are used to determine the appropriate vehicle crossing requirements. A vehicle movement, on the other hand, relates to short term quantities of traffic and is used in rules that seek to control the combined impacts of vehicles crossing at a single point over a short period. Deleting both definitions would not assist in implementation of the rules to which the definitions relate and as such would reduce the efficiency and effectiveness of the rules in helping to achieve a safe and efficient transport network. Combining the definitions is similarly inefficient and ineffective, as the rules to which the definitions relate are seeking to manage different matters. Therefore, I recommend that both definitions are retained as notified. However I note that Rule 8.4.4.1(a) refers to equivalent vehicle movements and as this is not defined, I recommend it is amended to equivalent car movements so that it is clear and consistent with the other rules. Recommendation 53. Retain definitions for Equivalent car movement per day and vehicle movement. 11
54. Amend Rule 8.4.4 as follows: The following activities are restricted discretionary activities: The creation of any new property vehicle crossing, or the use of existing vehicle crossings for a new activity (including the relocation of such vehicle crossings), for activities in which an excess of 100 equivalent vehicle car movements per day are generated; 12