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BEFORE THE HEARINGS PANEL FOR THE QUEENSTOWN LAKES PROPOSED DISTRICT PLAN IN THE MATTER of the Resource Management Act 1991 AND IN THE MATTER of Hearing Stream 12 Upper Clutha Annotations and Rezoning Requests REBUTTAL EVIDENCE OF GARTH JAMES FALCONER ON BEHALF OF QUEENSTOWN LAKES DISTRICT COUNCIL URBAN DESIGN 5 May 2017 Barristers & Solicitors S J Scott / C J McCallum Telephone: +64-3-968 4018 Facsimile: +64-3-379 5023 Email: sarah.scott@simpsongrierson.com PO Box 874 SOLICITORS CHRISTCHURCH 8140

TABLE OF CONTENTS 1. INTRODUCTION... 1 2. SCOPE... 1 3. JILL CORSON FOR VARINA PROPRIETY LTD (591)... 1 4. IAN GREAVES FOR VARINA PROPRIETY LTD (591)... 7 Attachment A: Topography, built form and town centre area for Wanaka and the town centre area for Queenstown

1. INTRODUCTION 1.1 My full name is Garth James Falconer. I am a director of, and have been employed by Reset Urban Design since 2008. 1.2 My qualifications and experience are set out in my statement of evidence in chief for Hearing Stream 6 dated 14 September 2016. 1.3 I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and that I agree to comply with it. I confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that I express, and that this evidence is within my area of expertise except where I state that I am relying on the evidence of another person. 1.4 References to [CBX] are to the Council's Bundle of Documents (CB) dated 10 March 2017. 2. SCOPE 2.1 I did not provide evidence in chief for this hearing. My rebuttal evidence is provided in response to the evidence of Ms Jill Corson and Mr Ian Greaves for Varina Propriety Ltd Submission (591). 2.2 Attachment A shows the topography, built form and town centre area for Wanaka, as well as the town centre area for Queenstown. 3. JILL CORSON FOR VARINA PROPRIETY LTD (591) 3.1 Ms Corson has filed urban design evidence, on behalf of Varina Propriety Ltd, in relation to two areas on the eastern edge of the town centre: (a) Site 1, area shown in Figure 1 of Ms Corson's evidence along Brownston and Russell Streets. The submitter proposes that the notified Medium Density Residential Zone (MDR) along with the Wanaka Town Centre Transition Overlay (TCTO), be rezoned Town Centre Zone; and 29226431_2.docx 1

(b) Site 2, being the block bounded by McDougal/Brownston/ Upton streets by the Wanaka Camping Grounds, where the submitter requests that the notified Low Density Residential zone (LDR) be rezoned MDR zone with a visitor accommodation overlay. 3.2 My evidence focuses mainly on Site 1 3.3 Ms Corson describes Site 1 in paragraphs 11 to 13 of her evidence and Site 2 in paragraph 23. I agree with her descriptions of the sites. Site 1 3.4 Having read Ms Corson's evidence I do not believe the site analysis is thorough enough in order to justify the rezoning in the manner sought by the submitter. The following are areas that I consider should be addressed. 3.5 The underlying topography of the area, which features the base of a Chalmers Street hill and Bullock Creek in the middle of the relatively short section from the Ardmore Street roundabout to Pembroke Park, has a strong bearing on the Town Centres layout (refer to Attachment A Figure 1). Fundamentally there is a substantial change in level along Brownston Street with an uphill section that includes Russell Street and a drop in elevation towards Bullock Creek and Helwick Street. Broadly this contour change forms a natural transition from the residential uphill to flatter topography of the town centre. 3.6 An analysis of the built form of the area shows that the northern side of Brownston Street is only partially built up to the edge (see Attachment A Figure Two). Large setbacks are present including several car parks, a car yard, and several motels. There is only a small section of buildings fronting the street in the block between Helwick and Dungarvon Streets. In general the activities in this area are not very lively and has a 'back of house' feel. 29226431_2.docx 2

3.7 In terms of capacity for growth the town centre of Wanaka is large relative to its population with most retail and commercial activity situated close to the lakefront. Figures 3 and 4 in Attachment A shows that the Wanaka town centre is approximately the same as that of Queenstown's traditional town centre. There also appears to be plenty of gaps and redevelopment sites within the existing town centre. 3.8 Ms Corson at paragraph 15 notes that there is the potential threat of competition from the planned Three Parks "Town Centre". However the planning framework for the 100ha Three Parks development is for mixed use, primarily to cater for larger formatted commercial and is not being referred to as a "Town Centre" nor I understand is zoned as such. In addition, Objective 5 of the Three Parks Zone provides: The establishment of a Commercial Core which complements and does not compromise the function, viability, and vitality of the Wanaka Town Centre. 3.9 I agree with Ms Corson at her paragraph 19 (p6) that Brownston Street has a core arterial function that links the Cardrona entrance with that of Cromwell. I also agree with Ms Corson s characterisation of the southern side, being that it is "weakly contained by low rise residential buildings largely introverted first established as holiday accommodation set well back from road boundary" (paragraph 20) and also that there has been little capital investment, stating that "the large sections with simple dwellings seem poised for redevelopment" (paragraph 21). 3.10 However, in my view the comparison Ms Corson makes between Brownston Street and Upper Ardmore Street as an "urban boulevard and lakeside entrance" (her paragraph 72) is not in my view tenable as the latter runs directly to the lake and is historically the town s main street. 3.11 Neither do I consider Russell Street should be considered as part of, or in the same way as, Brownston Street. It is separated from the bulk of Brownston Street by a substantial level change and it is a 29226431_2.docx 3

different type of street; shorter more residential in character, with established gardens, and far less vehicle movements. Admittedly there are a number of properties used for light commercial such as dentists and motel type accommodation though they appear to support the residential character and low levels of activity. I believe it is a stretch to propose that Russell Street should be zoned as an area of town centre development in order for it to extend to Ballantyne Street. I also consider it a stretch to call the Police and Fire Stations "Civic nodes". Ms Corson's Review of Proposed District Plan Provisions 3.12 Ms Corson acknowledges the purpose of the TCTO Objective 8.2.12 as "enables non residential development forms which support the role of the Town Centre and are sensitive to the transition with residential uses" (her paragraph 34) and that Policy 8.2.12.3 allows for some variances in site coverage, setbacks, and parking based on high urban design (her paragraph 35). 3.13 I understand that in the reply version of the MDR chapter Policy 8.2.13.3 was deleted and Council's recommendations are Policy 8.2.9.3 [CB8]: Ensure the amenity of adjoining residential properties outside of the Wanaka Town Centre Transition Overlay is protected though design and application of setbacks and to mitigate dominance, overshadowing, and privacy effects. 3.14 This recommended policy represents further refinement and addresses concerns for appropriate transition to residential. 3.15 However, Ms Corson believes that the "rules of the MDR underlay would determine the predominant characteristics of the TCTO and not the objectives and policies" (paragraph 36). 3.16 I agree that the form of development would be more spacious with the setbacks and other rules that are in place, although that doesn t necessarily mean it will be essentially residential in character or 29226431_2.docx 4

provide a less desirable street frontage or quality of development. The current provisions that also allow residential on the ground floor and on site carparking are part of a more flexible zone than the Town Centre. 3.17 Ms Corson has quite a different vision for Brownston Street (referring to her 2012 study see Figure 1 of her evidence) and proposes built form either side from Upper Ardmore to Pembroke Park (paragraph 24) "in a sequence of elegant urban precincts defined by two to three stories of commercial style buildings established on the street boundary of both sides of the carriageway and used for a mix of commercial, residential and visitor accommodation purposes". This proposed street scene shows town centre-like illustrations (refer figure 2 p10) featuring a contained built edge to the street edged with parallel parking, street trees and pedestrian thresholds/ traffic calming. 3.18 To achieve this vision Ms Corson argues that the Town Centre provisions supported by the Wanaka Town Centre Character Guidelines (2011) (Guidelines) will provide a more integrated building form and a built edge to the street (paragraph 39). 3.19 Whilst the Guidelines are only applicable to the Town Centre, they do include a typical cross section along Brownston Street with a setback on the southern side though Ms Corson strongly disagrees with this vision: "this introverted development on the southern side of Brownston Street would create a more sterile, inhospitable environment for people travelling along Brownston Street. It would also create a lesser degree of visual balance and enclosure" (paragraph 42, subtitle p16). 3.20 My reading of the Guidelines cross section is less extreme. The streetscape is similar with the same features, lights and trees balanced across the street. The built form is also of a similar two level scale with the northern side slightly higher stud height. The slightly increased setback notes an intended gradual transition and does not greatly diminish the spatial definition of the street. In my 29226431_2.docx 5

opinion, the cross section shown in the Guidelines is an appropriate urban design outcome for Brownston Street. 3.21 Ms Corson also perceives the existing zoning will provide for a limited guarantee of development quality as "there appears to be a lack of guiding vision for the TCTO and without clear direction of purpose urban design outcomes for not only individual developments but also the wider town centre and entry precincts will be compromised" (her paragraph 49). 3.22 I suggest that the requirement for high quality urban design for applications that have variance already present in the MDR (TCTO) zone provisions will stimulate good development and should be extended to all applications in this zone. 3.23 Ms Corson also warns that there will be more traffic interactions with more vehicle crossings under a MDS zoning than if Site 1 were zoned Town Centre and that will "diminish the continuity and integrity of the built form and public interface" (her paragraph 51). With the limited number of lots within the transition overlay fronting Brownston street from an urban design perspective I cannot see this as being a major issue, as the crossings already exist. And there are a number of existing premises such as Cinema Paradiso that feature onsite access and parking arrangements that positively support the street environment. 3.24 Ms Corson also suggests a greater setback of 5m, a rear service lane, and screen fencing and planting to separate from adjacent residential (paragraph 55). These provisions would work to compensate and create a building form that is further setback from the residential boundary from the existing setback provisions of 2m.. 3.25 However it is not clear how a service lane is to be formed, or what it benefits. Considering there are multiple lots in different ownership, forming a service lane may be difficult and the presence of cars and delivery vehicles would not make for a good transition to residential. 29226431_2.docx 6

3.26 The submission also mentions the greater enhancement of Bullock Creek by way of the submitter's proposed rezoning of Site 1 though it is not detailed how this will be achieved. 3.27 The submission does not explicitly cover how Russell Street would be developed though the assumption is for an extension of the vision for Brownston Street even though the spatial dimensions and character are quite different. 4. IAN GREAVES FOR VARINA PROPRIETY LTD (591) 4.1 Mr Ian Greaves filed planning evidence for Varina Propriety Ltd in relation to the notified MDR-TCTO. 4.2 Mr Greaves' paragraph 26 identifies the key issue as being whether the built form enabled by the MDR-TCTO zoning or by the TCTO zone is more appropriate. He contends that the MDR-TCTO zoning will result in poorly designed and inefficiently laid out commercial development and that, as a result, key commercial and visitor accommodation development may be pushed to outlying areas. I do not consider that the built form resulting from the MDR-TCTO zoning will necessarily result in poor quality development. 4.3 For example, the current MDR provisions allow a 7m building height whereas the Town Centre provisions allow 8m at the eave and 10m at the ridge. Allowing for 3m for each storey, I believe that 7m limit can easily provide for a two storey building form. Although I note that this height limit can constrict the roofline, especially the pitched gable form that efficiently sheds rainfall and is characteristic of the Central Otago area. 29226431_2.docx 7

4.4 In paragraph 32 (p13) Mr Greaves believes that without mandatory requirement for reference to the Guidelines and the urban design panel, the design of buildings in the TCTO will not be subject to sufficient rigour. Whilst this may be true it does not follow that they will result in poorly designed buildings (paragraph 26 p10). Garth James Falconer 5 May 2017 29226431_2.docx 8

Attachment A LAND N KEY Waterway 5m Contours Approximate extent of 1999 flood 300m 295m Lake Wanaka 280m 290m Bullock Creek 285m Brownston Street 300m Figure 1 BUILT FORM N KEY Buildings Brownston Street Figure 2

WANAKA N Figure 3 QUEENSTOWN N KEY Reserve / Open Space Extra wide Road (20m+) Wide Road (15m-20m) Medium Road (10m-15m) Lane (1.5m-10m) Waterway (daylighted) Figure 4