FORM 3 SUBMISSION ON PROPOSAL CONCERNING NATIONAL POLICY STATEMENT ON URBAN DEVELPOMENT CAPACITY. Clause 3 of Schedule 1, Resource Management Act 1991

Transcription

1 FORM 3 SUBMISSION ON PROPOSAL CONCERNING NATIONAL POLICY STATEMENT ON URBAN DEVELPOMENT CAPACITY Clause 3 f Schedule 1, Resurce Management Act 1991 T: Minister fr the Envirnment and fr Building and Husing PO Bx AUCKLAND 1143 Submissin n: Name: Address: Prpsed Natinal Plicy Statement n Urban Develpment Capacity Queenstwn Airprt Crpratin (QAC) Queenstwn Airprt Crpratin c/- Mitchell Partnerships Ltd PO Bx 489 Dunedin This is a submissin n the fllwing prpsed natinal plicy statement (the prpsal): Prpsed Natinal Plicy Statement n Urban Develpment Capacity, ntified 2 June 2016 (the Prpsed NPS). 2. The specific prvisins f the prpsal that QAC s submissin relates t are: Definitin f Develpment Capacity Plicy PA3 Plicy PB4 Plicy PD2 Plicy PD3 Plicy PD9 3. QAC s Submissin is: 3.1 QAC perates the reginally and natinally significant Queenstwn Airprt, and the reginally significant Wanaka Airprt. 3.2 Queenstwn Airprt is the main airprt in the Queenstwn Lakes District and is the primary take-ff and landing pint fr much f the aircraft activity in the District. The Airprt accmmdates aircraft mvements assciated with scheduled, general aviatin and helicpter peratins. The Airprt acts as an essential gateway t the Queenstwn Lakes District and facilitates access t the District and ecnmic activity

2 2 in the lcal and reginal ecnmies. It is als a prvider f emergency services and is a lifeline utility under the Civil Defence Emergency Management Act 2002 (CDEM 2002). 3.3 Queenstwn Airprt is ne f the busiest airprts in the cuntry, serving bth dmestic and internatinal passengers t New Zealand s premier turist destinatin. The Airprt accmmdates in excess f 1.6 millin passengers fr the year ending May This represents a 17% increase in passengers frm the previus year. Queenstwn Airprt has experienced a sustained perid f grwth, with passenger numbers expected t increase ver the cming years as the District receives an increasing number f dmestic and internatinal visitrs. 3.4 Recent grwth prjectins have indicated that passenger grwth is set t cntinue, with 1.78 millin passengers prjected by 2025 and 2.57milln passengers by Based n the Ministry f Business, Innvatin and Emplyment turism frecasts and passenger number grwth rates, ttal turism spending is prjected t increase by between 3.4 per cent and 3.9 per cent per annum. This is expected t take the ttal turism spending facilitated by Queenstwn Airprt t between $1.1bn and $1.4bn. The n-ging ability f Queenstwn Airprt t functin and grw withut undue cnstraint is therefre f significant imprtance t the turism industry, bth reginally and natinally. 3.6 Queenstwn Airprt is managed by QAC. QAC is a netwrk utility peratr and a requiring authrity under sectin 166 f the Resurce Management Act 1991 (the RMA r the Act). The Airprt is the subject f designatins in bth the perative and prpsed Queenstwn Lakes District Plans. 3.7 It is frm this premise that QAC has prepared this submissin n the prpsed NPS. Reverse Sensitivity 3.8 The tpgraphy f the Queenstwn Lakes District cupled with its highly valued visual character means that there is limited land available fr urban develpment and expansin. As a result, Queenstwn Airprt, which is centrally lcated n Franktn Flats, is under increasing encrachment and develpment pressure frm surrunding urban activities. 3.9 As nted in paragraph 3.3, Queenstwn Airprt has experienced a sustained perid f passenger grwth which is expected t cntinue fr the freseeable future. It is therefre imprtant that QAC is able t respnd t this grwth, which in turn, will prvide fr the scial and ecnmic wellbeing f the cmmunity thrugh direct and indirect emplyment pprtunities and grwth in the turism market. 1 Based prjectins by Market Ecnmics Limited, set ut in the reprt Queenstwn Airprt: Mixed Use Zne, Ecnmic Assessment Nvember 2014.

3 QAC has recently undertaken a cmprehensive plan change t establish an apprpriate management regime fr land use arund Queenstwn Airprt while prviding fr the predicted nging grwth f the Airprt until This land use management regime implements best practice land use planning in and arund airprts (as set ut in the New Zealand Standard fr Airprt Nise Management and Land Use Planning NZS6805: 1992), and prtects Queenstwn Airprt frm reverse sensitivity effects until Given the increasing develpment pressures experienced in Queenstwn, it is essential that any prpsed NPS des nt undermine this land use management apprach The Cnsultatin Dcument n the NPS states that: The tpic f reverse sensitivity is very cmplex. The fcus f the prpsed NPS is t further enable develpment capacity, and addressing reverse sensitivity wuld require significantly mre analysis than has been pssible QAC cnsiders that the tpic f reverse sensitivity is straightfrward, and is well understd in law. An NPS which seeks t enable develpment capacity must als address reverse sensitivity effects QAC des nt ppse the key bjectives f the NPS t encurage and enable urban develpment. Hwever, unless addressed and managed well, the Gvernment's desire t increase land supply t prmte husing thrugh instruments such as the NPS will create significant cnflict with established significant infrastructure It is critical that reverse sensitivity issues are recgnised and prvided fr in the NPS, s that urban grwth is discuraged frm lcating near airprts, and s that residential grwth des nt restrict the substantial ecnmic grwth, jbs and exprts that airprts prvide ur cities and regins Established airprts cannt readily mve, and new airprt sites clse t their ppulatin bases are very hard t create. It is therefre imprtant that existing airprt infrastructure is used efficiently (free frm additinal cnstraints) and future develpment ptins are maintained QAC cnsiders that the amendments set ut in Annexure A are required t ensure that the natinally significant infrastructure at Queenstwn Airprt is apprpriately recgnised and prvided fr in the prpsed NPS QAC cnsiders that in the absence f amendments t the prpsed NPS t address and give effect t the abve submissin pints and thse set ut in Annexure A: The prpsed NPS will nt prmte the sustainable management r efficient use and develpment f natural and physical resurces;

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5 5 Cntact Details: Attentin: Kirsty O Sullivan Telephne: kirsty.sullivan@mitchellpartnerhips.c.nz

6 ANNEXURE A Submissin Table

7 Prvisin Submissin Psitin Reasn fr submissin Relief Sught 3 INTERPRETATION Develpment capacity means in relatin t residential and business land, the capacity f land fr urban develpment t meet demand, taking int accunt the fllwing factrs: the zning, bjectives, plicies, rules and verlays that apply t the land; and the prvisin f adequate infrastructure, existing r likely t exist, t supprt the develpment f the land, having regard t the relevant prpsed and perative reginal plicy statements, reginal plans and district plans; and any relevant management plans and strategies prepared under ther Acts. Oppse and amend Objective OA1 states: T supprt effective and efficient urban areas that enable peple and cmmunities t prvide fr their scial, ecnmic and cultural wellbeing. Airprts are a critical part f prviding effective and efficient urban areas. If residential develpment is prvided withut prtecting the airprt activities that supprt a vibrant, effective and efficient urban area, then Objective OA1 will nt be met. Residential develpment will jepardise the substantial ecnmic and scial benefits that airprts bring, nt nly t cities and twns, but t the surrunding regin and cuntry as a whle. The amendments prpsed will ensure that reverse sensitivity effects are managed, while prviding sufficient develpment capacity fr residential and business demand. Amend the definitin as fllws: Develpment capacity means in relatin t residential and business land, the capacity f land fr urban develpment t meet demand, taking int accunt the fllwing factrs: the zning, bjectives, plicies, rules and verlays that apply t the land; and the prvisin f adequate infrastructure, existing r likely t exist, t supprt the develpment f the land, having regard t the relevant prpsed and perative reginal plicy statements, reginal plans and district plans; and any relevant management plans and strategies prepared under ther Acts.; and the need t manage reverse sensitivity effects n significant infrastructure. 6 POLICIES PA3 Oppse and amend Objective OA1 states: Amend the Plicy as fllws: When cnsidering the effects f urban develpment, decisin-makers must: Recgnise and prvide fr the cntributin that urban develpment will make t the ability fr peple and cmmunities and future generatins t prvide fr their scial, ecnmic and cultural wellbeing. Prvide sufficient develpment capacity, whilst maximising the psitive effects f develpment, and minimising the adverse effects f develpment. Have particular regard t the psitive effects f urban develpment at a natinal, reginal and district scale, as well as its lcal effects. T supprt effective and efficient urban areas that enable peple and cmmunities t prvide fr their scial, ecnmic and cultural wellbeing. Airprts are a critical part f prviding effective and efficient urban areas. If residential develpment is prvided withut prtecting the airprt activities that supprt a vibrant, effective and efficient urban area, then Objective OA1 will nt be met. That residential develpment will jepardise the substantial ecnmic and scial benefits that airprts bring, nt nly t cities and twns, but t the surrunding regin and cuntry as a whle. The amendment prpsed will ensure that reverse sensitivity effects are managed, while prviding sufficient develpment capacity fr residential and business demand. When cnsidering the effects f urban develpment, decisin-makers must: Recgnise and prvide fr the cntributin that urban develpment will make t the ability fr peple and cmmunities and future generatins t prvide fr their scial, ecnmic and cultural wellbeing. Prvide sufficient develpment capacity, whilst maximising the psitive effects f develpment, and minimising the adverse effects f develpment, including ptential reverse sensitivity effects n significant infrastructure. Have particular regard t the psitive effects f urban develpment at a natinal, reginal and district scale, as well as its lcal effects. PB4 In carrying ut the assessments required under plicy PB1, lcal authrities must cnsult with infrastructure prviders, cmmunity and scial husing prviders, the prperty develpment sectr and any ther stakehlders as they see fit. Oppse and amend Airprts fall under the definitin f "infrastructure" in the NPS which includes "transprt" and "passenger transprt services". QAC supprts plicy PB4 which requires lcal authrities t cnsult with infrastructure prviders when carrying ut the Husing and Business Land Assessments and develping the future land release and intensificatin strategy, subject t amendments. Hwever, the inclusin f the phrase "as they see fit" culd be misinterpreted t Amend the Plicy as fllws: In carrying ut the assessments required under plicy PB1, lcal authrities must cnsult with infrastructure prviders, cmmunity and scial husing prviders, the prperty develpment sectr and any ther stakehlders as they see fit. 1

8 2 mean that cuncils need nly cnsult as they see fit, and as such shuld be deleted. Cuncils must talk t airprts abut land assessments which take int accunt land in r arund airprts, and particularly in an airprt's effects area. Airprt peratrs must be cnsulted with by lcal authrities at the utset t ensure effects n their peratins are adequately taken int accunt by lcal authrities in the implementatin f the NPS. QAC als cnsiders that lcal authrities will need clear guidance frm the Ministry as t hw lcal authrities will identify infrastructure prviders t cnsult. PD2 A lcal authrity must cnsider all ptins available t it under the Act t enable sufficient develpment capacity t meet residential and business demand, including but nt limited t: Changes t plans and reginal plicy statements, including changes t: Objectives, plicies and rules, zning and the applicatin f thse in bth existing urban and undevelped areas; Activity status; Prvisins abut the ntificatin f applicatins fr resurce cnsent; Existing verlays, r the intrductin f verlays which enable develpment; and Make them simpler t interpret. Cnsenting prcesses that are custmer-fcused and crdinated within the lcal authrity; and In granting cnsent, the cnditins f cnsent impsed. Oppse and amend Plicy PD2 prmtes a number f "respnsive planning" ptins in rder fr lcal authrities t prvide fr sufficient develpment capacity. Plicy PD2 requires lcal authrities t cnsider all ptins available t it under the RMA t enable sufficient develpment capacity t meet residential and business demand, including changes t ntificatin prvisins and existing verlays. There is a risk that the changes lcal authrities make t the ntificatin prvisins f their district plans and reginal plicy statements in rder t enable sufficient develpment capacity, pursuant t plicy PD2, will result in situatins where parties wh are affected lse ut n the pprtunity t participate. Airprt peratrs need t stay vigilant t applicatins fr cnsent t establish sensitive activities like residential dwellings in their effects areas. An airprt's ability t be invlved in these resurce cnsent prcesses culd be significantly curtailed if changes are made t plans that reduce the ntificatin f resurce cnsent applicatins that culd ptentially affect an airprt's peratins. In additin, the NPS's prmtin f amendments t existing verlays and intrductin f new verlays in rder t enable sufficient develpment capacity is f cncern. Airprt peratrs have had extensive invlvement in the develpment f varius planning instruments in rder t prtect their current peratins and prvide capacity fr develpment f future peratins. Effects areas arund airprts, which include cntrls t manage land uses within areas subject t aircraft nise, ften take the frm f verlays. Amend the Plicy as fllws: A lcal authrity must cnsider all ptins available t it under the Act t enable sufficient develpment capacity t meet residential and business demand, including but nt limited t: Changes t plans and reginal plicy statements, including changes t: Objectives, plicies and rules, zning and the applicatin f thse in bth existing urban and undevelped areas; Activity status; and Prvisins abut the ntificatin f applicatins fr resurce cnsent; Existing verlays, r the intrductin f verlays which enable develpment; and Make them simpler t interpret. Cnsenting prcesses that are efficient custmer fcused and crdinated within the lcal authrity; and In granting cnsent, the cnditins f cnsent impsed. An NPS which des nt take int accunt reverse sensitivity effects and prmtes limiting ntificatin, r changes t effects area verlays, will nly exacerbate the grwing issue that airprts are already facing in trying t prtect their peratins frm reverse sensitivity effects. It will undermine airprts' vital air nise bundaries, and encurage peple t live in areas which are nt

9 3 suitable fr residential uses. QAC als has cncerns regarding references t "custmer fcused" cnsenting prcesses in plicy PD2. This is an ambiguus term which culd be misinterpreted by lcal authrities. A mre apprpriate term is "efficient". PD3 Lcal authrities must cnsider the fllwing respnses: In the shrt term, further enable develpment thrugh custmer-fcused cnsenting prcesses and, where apprpriate, amending the relevant plans. In the medium term, amending the relevant plans and plicy statements t prvide mre develpment capacity. In the lng term, prviding a brad indicatin f the lcatin, timing and sequencing f develpment capacity in rder t demnstrate that it will be sufficient Oppse and amend QAC als has cncerns regarding references t "custmer fcused" cnsenting prcesses in plicy PD3. This is an ambiguus term which culd be misinterpreted by lcal authrities. A mre apprpriate term is "efficient". Amend the Plicy as fllws: Lcal authrities must cnsider the fllwing respnses: In the shrt term, further enable develpment thrugh efficient custmer-fcused cnsenting prcesses and, where apprpriate, amending the relevant plans. In the medium term, amending the relevant plans and plicy statements t prvide mre develpment capacity. In the lng term, prviding a brad indicatin f the lcatin, timing and sequencing f develpment capacity in rder t demnstrate that it will be sufficient PD9 In develping this strategy, lcal authrities must: Oppse and amend Airprts fall under the definitin f "infrastructure" in the NPS which includes "transprt" and "passenger transprt services". PD9 In develping this strategy, lcal authrities must: Be infrmed by the Husing Assessment and Business Land Assessment required under plicy PB1; Take int accunt the views f infrastructure prviders, land wners, the prperty develpment sectr and any ther stakehlders as they see fit; and Have particular regard t plicy PA1. QAC supprts plicy PD9 which requires lcal authrities t cnsult with infrastructure prviders when carrying ut the Husing and Business Land Assessments and develping the future land release and intensificatin strategy, subject t amendments. Hwever, the inclusin f the phrase "as they see fit" culd be misinterpreted t mean that cuncils need nly cnsult as they see fit, and as such shuld be deleted. Cuncils must talk t airprts abut land assessments which take int accunt land in r arund airprts, and particularly in an airprt's effects area. Airprt peratrs must be cnsulted with by lcal authrities at the utset t ensure effects n their peratins are adequately taken int accunt by lcal authrities in the implementatin f the NPS. Be infrmed by the Husing Assessment and Business Land Assessment required under plicy PB1; Cnsult with and Ttake int accunt the views f infrastructure prviders, land wners, the prperty develpment sectr and any ther stakehlders as they see fit; and Have particular regard t plicy PA1. QAC als cnsiders that lcal authrities will need clear guidance frm the Ministry as t hw lcal authrities will identify infrastructure prviders t cnsult.