Original Submission

We have made the following original submission document available on this website as a background information resource only. As such there are certain details which are not accurate to the current situation, such as the number of units being proposed.

This submission was lodged by MENRA in response to the original resource consent application by Glenstone Ltd in October 2001 to build 25 units
at 17 Kelly St. There were 135 submissions and all but 1 opposed.

SInce then, Glenstone has lodged a 2nd application - a new plan for 22 units, which can be granted without public notification and we are therefore unable to submit our opposition to Council.

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Contents

1. Introduction
2. Density
3. Earthworks
4. Flora & Fauna
5. Traffic
6. Historic Environment
   

Introduction

Application Number 01. 09274 has been lodged for resource consent as a "discretionary activity" under the provision of "innovative housing". The Mt.Eden North Residents Association Inc. has respectfully made this submission on behalf of its members; residents living in this locality and other concerned stakeholders. As affected or interested people and parties, we have been denied the consultative process which should inform any application made in the spirit of the decade old Resource Management Act. It is clear that those who are familiar with the Act are also adroit in taking a particular approach to interpreting its provisions. In this case the conceptual nature of "innovative housing" is open to liberal interpretation. The balance seems heavily weighted towards the developers needs above and beyond the concerns of an established community of ratepayers.

We have submitted our own analyses of the issues, which greatly affect our daily lives. These represent specifically those matters, as we have been able to address within the resource consent process.

Density

The District Plan, as an arbiter of land use control, states that zoning has the function of "grouping together areas of similar character in terms of land use and style of development".[Ret: Planning - Guide to Zoning - District Plan Isthmus Section].
The site at 17 Kelly Street has been zoned 7a in the District Plan, an anomaly within the surrounding historic built environment of the Residential I zone. This raises many issues with regard to the interface between the two zones and militates against our desire for more moderate change.
We have identified the most crucial factor in determining this up-zoning (on a site which has been occupied by the Crown during the last fifty years) to be the fact that this northern locality of Mt.Eden has been placed within the Western Strategic Growth Management Area. On our western flank we are bounded by the Dominion Road SGMA. The Western SGMA has been identified for priority release and is currently undergoing far reaching changes as a result of the densification strategies associated with managing growth in the Auckland region. There are many statistics, which attest to the effects of this level of intensification and the predominance of non-traditional housing which occurs at the densities, which are both, encouraged and permitted.
It is our contention that "innovative housing" has become, in a developer's lexicon, simply a euphemism for maximising profit by increasing site yield. Innovative housing opportunities in the District Plan mean here that the surrounding traditional land use pattern of 1 dwelling per site will became subservient to a proposal to accommodate 25 dwellings on site. This is a site which is under half a hectare in size (or 0.4558 ha). We are deeply concerned that the provisions of Rule 7.7.4 in the District Plan, while specific about the envisaged form and function of such "innovative housing" developments, do not provide a proper definition of what constitutes appropriately "large sites". The question of size becomes elastic and inconsistent; like beauty, very much in the eye of the beholder.
In the consultants report entitled Landscape Description and Visual Appraisal part 8.4.1, page 15; the Statement of evidence by Jan Woodhouse describes the site as "comparatively small" - in this instance an effort to minimise the visual impacts of the proposed development on the catchment area.

It is worthwhile noting also that the size of the site continues to work in the developer's favour. Because the site is under 1.0 hectare the proposed excessive excavation (as a land disturbing activity with associated environmental degradation) does not require any consents from the Auckland Regional Council because it is a Permitted Activity. Yet in April 1998 the Regional Growth Forum 'Survey of Regional Environmental Organisations' identified Mt.Eden as one of Auckland's traditional urban suburbs needing high levels of protection

We contend that the nature and extent of the proposed earthworks and consequent removal of historic and generally protected trees [along with density, parking, traffic, visual character, disruption, devaluation, debilitation of nearby dwellings etc.] will lead to adverse ecological effects harmful to the health and well-being of the existing community. In particular the cumulative effects associated with reverse sensitivity, defined by the Auckland Regional Council as the effects of activities sensitive to other activities in their vicinity resulting in constraints to the carrying out of those activities.

We believe that the assessment of effects submitted with this application is insufficiently detailed and therefore does not correspond to the scale and significance of the actual and potential effects that the activity may have on the environment.

Accordingly we wish the Council to adopt a cautionary approach and decline consent to this application

We also recommend that Council work to restrict the current provisions whereby District Plan Rules are open to liberal Interpretation and therefore vulnerable to opportunism. e.g. Innovative Housing

With due regard to Part II, Sections 5,6,7 and 8 of the Resource Management Act
and:
With especial regard to amendment (f) Section 6 of the principal Act, to reject the proposal in its entirety.

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EARTH WORKS

1. Resource consent is sought by the applicant to exceed the earthworks permitted under the Act.
2. In the Association's view the degree of excavation proposed is excessive and approval should not be granted. Attachment H of the application - the Earthworks Report, indicates that an area of 3,220 sq. metres is to be excavated to a depth of 1.6m, which will require excavation of some 5,152 cubic metres. This exceeds the permitted lOOM3 by more than 5,000M3 metres.
3. The submission and the report are silent on the bulking factor. A standard bulking factor in excavations removing similar material (volcanic scoria/rock) is 1.5. The actual material to be excavated and redistributed or removed off site will therefore be in the order of 7,728 Mt
4. In 2.1, the Earthworks Report reveals that "minor filling works around each unit will occur. We consider this is considerably more than minor. Plan A(--)005 in the submission documents illustrates that the total area of landscaped gardens surrounding the apartments is some 1 ,303 sq. If this area is to be raised 950mm, then 1.238 M3 of fill material will be required to achieve this.
5. The application has portrayed the development as one of superior quality constructed from quality materials. If the Applicant is consistent then it is reasonable to assume the rock and scoria filling used around each unit and the central garden area will need to be supplemented with good quality topsoil. The Application does not address the matter of topsoil being delivered on site and the additional truck movements this will generate.
6. The net bulked material needing to be removed from the site will be 6,228 M. That is 5152 M ( Attachment H, 2.0 ) less say, 1000 metres required for the "minor" filling work with a bulking factor of 1.5.
7. The traffic report included in the application records that the construction traffic will be up to 40 movements per day for four weeks. if it is assumed the project will operate on a six day week, then the potential number of truck movements removing excavated material alone, will exceed 1000. That is 1000 arriving and 1000 departing. Assuming a 10 hour working day, 40 truck movements per day equates to one truck arriving or departing every 7.5 minutes.
8. The construction effects are also considered in Harrison Grierson's report, which forms part of the application. Nowhere in that report is it stated that the effects of construction will be minor, let alone de minimus. To the contrary, the report states at para 2.3.2 that "significant construction traffic will be generated in order to dispose of the material offsite".
9. The property is situated close to Mt. Eden and the information supplied by the applicant indicates the area of excavation is made up predominantly of rock. Excavation of the extent proposed will have significant noise, dust and vibration effects. Notwithstanding this, there is no assessment of potential noise effects (other than a statement the contractor will be required to comply with the construction standards) and there is no discussion of any potential vibration or dust effects. Again, given that the level of noise, vibration and dust effects will be commensurate to the extent of excavation (which is significantly in excess of what is permitted as of right), it is impossible to see how the applicant can state that the noise, dust and vibration effects on the surrounding properties and their residents can be de minimus.
10. Given the composition of the area to be excavated it will be necessary to use impact rock breakers and possibly explosives to break up the rock. Considerable noise and ground vibrations are an inevitable by-product of the use of mechanical means to break rock or earth. A great deal of information has been accumulated locally and internationally on the nature of the effects of vibrations on structures and their inhabitants. Technical literature suggests that by and large, in built-up and established enclaves that any action that generates vibrations will have a detrimental effect on surrounding structures. Clearly, a responsible action and indeed, a requirement of Council should be that before and after studies be undertaken on adjacent buildings.
11. Excavation of rock is a hazardous activity. It is relevant to note that it was not a lack of material that caused the cessation of quarrying in Mt. Eden in the I980s. In 1999 Winstone Aggregates, the operators of the Three Kings Quarry established an indemnity scheme to protect 1,600 nearby residents from damage resulting from quarrying activities.
12. It is also relevant to note the recent case of a hospital development in Brightside Rd. Epsom, which entailed excavation of similar material. In this instance residents report they were patronised by the developer and seemingly many of the conditions were totally breached. Residents were subjected to substantial inconvenience and the vibration damage created by the earthworks and construction lead to substantial litigation, some of which still has not been resolved.
13. Similarly, The effect of continuous repetitious vibrations on the structures also impacts on the inhabitants of those structures whose health and safety will clearly be jeopardised if the development proceeds in its proposed form. It is our contention that no one appears to have addressed this most important matter and we put the Developer on notice that in the event the development proceeds, the Association intends to hold the developer accountable.
14. The Application in 6.5.b states that the Harrison Grierson report (Attachment H) addresses the site management measures to be undertaken. However this is not so. The Harrison Grierson report in 2.3.2 refers to various "issues of concern" that need to be allowed for by the contractor but no evidence or reassurance is provided in the Application to suggest site management procedures acceptable to the Council or the community will be adopted and adhered to.
15. With regard to the earthworks involved, the Application is virtually silent on the following site management and environmental protection measures.
· Heavy traffic Management
· Traffic safety
· Pedestrian Safety
· Hours of operation
· Damage to Council roading, footpaths and other utilities.
· Sediment and erosion control
· Dust control
· Vibrations

16. While the Earthworks Report in 2.3.2 refers to specific environmental protection measures that should be observed, the application is silent on the technical aspects of the construction of the boundary retaining walls which will contain the raised boundary yards. Nor is any reference given to measures that will need to be taken to prevent erosion or sediment loss on to neighbouring properties both during construction and in the future. The Harrison Grierson earthworks report also states in 1.0 that the proposed earthworks will after existing topography, thus influencing stormwater discharge from the site. While the matter of stormwater soakage is superficially addressed, the influence the raised boundary yards will have on the discharge of stormwater on to neighbouring properties has been ignored.
17. The earthworks proposed will of necessity result in a marked change in ground water seepage flows and run off patterns. The effect on existing fissures and piping in the strata cannot be calculated. We consider that for a mature established area such an unpredictable situation is untenable.
18. The plans ( A(--)007 ) submitted with the application show a variation of
100mm between the watershed and surrounding levels which appears to be in breach of Code NZ3604 which specifies a minimum of 150 mm variation to the RL.

Recommendations
q Consent for the earthworks should not be granted.
q If the Council decides to allow the development to proceed then the Developer should be required to implement a detailed site management procedures plan covering the Issues raised in para. 15 above, such plan to be prior approved by the Council and acceptable to the Mt. Eden North Resident's Assn. Inc.
q The Developer should, at the Developers cost, be required to provide 'Before and After' reports for the buildings In the Immediate vicinity to provide a reference point for any future damage claims.
q The Developer be required to establish a Reserve Fund to provide financial assurance that any damage occurring to surrounding properties can be repaired through the fund to eliminate the type of issues experienced by the residents In Brightside Road.

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FLORA AND FAUNA

1. Significant trees are protected to ensure the ecosystems that have been created around them are maintained. To be protected, a tree must have reached maturity, by which time it will also have become an integral part of the local ecosystem and environment. Significant trees are protected because their removal will have a detrimental effect on the ecosystem and environment that the tree has helped to create. Allowing protected trees to be removed to make way for high-density housing defeats the very purpose of protecting them in the first place. To this end, all protected trees on the site should be retained.
2. Trees form an integral part of the landscape and contribute to the character of the neighbourhood visually, physically and spiritually.
3. These trees are an important, and increasingly scarce, habitat for native birds and other animals.
4. It will take ten to twenty years for the proposed new plantings to achieve the presence of the existing trees, and for the existing ecosystem and environment to rebuild. In the meantime, local residents will lose the amenity value the site offers.
5. The new plantings offer substantially less amenity value than is currently offered by the existing site. This will have an unacceptable impact on the benefits local residents receive from living in this neighbourhood.
6. The neighbourhood has many mature trees that impart a pleasant, leafy effect much admired by passers by. The area is popular with people from around the Ward who jog, cycle or walk with their children through the area because of the pleasant and quiet environment it offers.
7. The existing plantings blend well with mature plantings in the neighbourhood, contributing to the overall character.
8. The intensification of housing across the Ward, and the lack of landscaping and planting associated, makes the retention of these existing planting of vital importance.

PLANT LIST

A. Puriri (Vitex lucens) - It seems astonishing that one protected tree is to be saved when other trees, which enjoy an equally protected status, can be removed.
B. Washingtonia Palm (Washingtonia robusta) - A fantastic specimen and one of the largest in the Ward. The palm has significant street appeal and is much admired by residents and passers by. As a protected free it should not be removed.
C. Kentia Palm (Howes forsteriana) - An excellent specimen. A plant of this size and vigour is rare on the Auckland isthmus and is irreplaceable. For this reason, the palm should not be removed.
D. Kowhai (Sophora microphylla) -Typical of its genus with excellent form and shape. Significant to native bird life and is New Zealand's most magnificent flowering tree. The scarcity of this genus within the Mt Eden Ward lends us to believe this tree should not be removed.
E. Cherry Tree (Prunus campanulata) - This is a large specimen. It's canopy, and magnificent spring flowering lend to the streetscape and character of the area. As a protected tree, it should not be removed.
F. Bottlebrush (Callistemon viminalis) - The arching canopy of this tree forms a tunnel over the footpath creating a wonderful effect. It is a character feature of the street, and when in flower is enjoyed by residents and the local bird life. The character of the street will be irreparably altered if this protected tree is removed.
G. Jacaranda (Jacaranda mimosifolia) - Typical of its genus, this tree (the closest Jacaranda to the footpath) requires only remedial work to restore its integrity. Paired with the second Jacaranda, it is a feature of the neighbourhood, and as a protected tree it should not be removed.
H. Jacaranda (Jacaranda mimosifolia) - The second Jacaranda (furtlierest from the footpath) is a remarkable specimen of excellent size and maturity. A beautifully flowering plant, which gives immense, pleasure to residents, passersby and local wildlife. This is a protected tree and should not be removed.
I. Evergreen Magnolia (Magnolia grandiflora) - a large and mature tree which requires only minor remedial work to recover its shape, and otherwise is in excellent health. The tree is an important mature for the residents of neighbouring Merino Gardens. In flower, the tree is spectacular, adding significant character for the residents. It is a protected tree and should not be removed.
J. Pittosporums (Pittosporum tenuifolium) - These trees are of significant value to native bird life and screen the existing buildings from residents and passersby, contributing to the leafy effect of the neighbourhood. These trees are protected and should not be removed.

FAUNA

I. The existing trees (both protected and unprotected) form an important part of the local ecosystem. Their removal would irreparably damage this ecosystem and the habitat of the native birds that rely on these plants for nourishment and protection.
II. A number of these trees are rare within Mt Eden Ward, and their removal would seriously threaten the local bird population.
III. Increasing visitors to Mt Eden and the intensification of housing within the Ward have forced more native birds into this tree-lined neighbourhood. Since ESR have vacated the site, native birdlife has increased significantly, and residents fear this will be permanently destroyed by the level of construction proposed for the site.
IV. The following birds depend on the native (and currently protected) plants on the ESR site:
· Tui's
· Native Wood Pigeons
· Fantails
· Barbary Doves
· Kingfishers
· Waxeyes
V. Tui's and Waxeyes feed on nectar from the two Kowhai trees and the Puriri tree.
VI. Wood Pigeons are attracted to the area by the fruit of the Puriri, which is a staple of their diet.
VII. The nectar and fruit of the Callistemon attract many varieties of birds.
VIII The berries of the Washingtonia Palm provide sustenance to many local birds.
IX The berries of the Kentia Palm are a sought after food of many birds.
X The flowers and berries of the Pittosporum are attractive to many birds.

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TRAFFIC

Current Situation

Parking and traffic congestion are already major issues for residents in Kelly St, Grayson Lane and Edenvale Cres. Most, however, will agree that these issues come with deciding to live in this tranquil historic area. The essence of the current problems in the street comes down to the fact that the houses were built in an era when cars were rare, let alone 2 - 3 cars per property. In fact, the few garages on the street are too narrow to accommodate modern cars.

Many of the houses have no off-street parking at all, while others have parking for only one car. When there are visitors coming into the street, residents must frequently park some distance from their houses.

Traffic is currently mainly the cars of residents and their visitors. As the streets are narrow and either one way or narrowed by chicanes allowing traffic to move in only one direction at a time, the level of traffic is close to its maximum.

Even though the population in the area is relatively stable, being such an established area, residents continue to notice a steady increase in the number of cars in the neighbourhood. This is in keeping with the findings of the Regional Growth Forum, April 1998, where it states in the discussion Document Entitled No Or Slow Growth "car ownership and use is in creasing at approximately twice the rate of population growth."

Impacts of the Development

Visitor Parking:
The developer's application proposes the provision of 5 car parks for visitors. This is deemed to be beyond the requirements of current District Plan. However, the recently released report to the Smart City Governing Committee dated 5 September 2001 and entitled the Residential Design Guide for Development in the Strategic Growth Management Areas, recommends that visitor and service parking should be incorporated into developments such as is being proposed at 17 Kelly Street. On Page 54 of the report, it recommends that 0.5 parking spaces per unit (rounded up to nearest whole number) and service delivery spaces at a rate of 1 space for every 10 units should be allowed for.

As parking is already at a premium in the neighbouring streets because of the historic nature of the area, we recommend that the provision of visitor and service delivery parking in the any residential development should be in line with the recommendations of the report to the Smart City Governing Committee; that being 13 visitors parks and 3 service delivery parks.

Access to the Development from Edenvale Cres:
Although the proposed development plans that all traffic should enter and exit the development via Kelly St, pedestrian access to and from Edenvale Ores remains for town houses situated on the western boundary of the development. It is therefore likely that some residents and visitors will elect to park their cars in Edenvale Ores and walk through to the new properties. The likelihood of this will further increase with the development of Dominion Rd into the major arterial route into the city from the South-Western Motorway. Any increase in parked cars on Edenvale Cres will make it close to impossible for Edenvale Ores residents to find parking in close location to their property in the evening and weekends.
Any increase in traffic in Edenvale Cres will further add to the traffic problems in Wynyard Rd. Residents are already working with Council to introduce speed bumps or chicanes to reduce the speed of the increasing number of cars using their street.

It is therefore recommended that pedestrian entrances to townhouses on the western boundary should be removed to discourage access to the site from the Kelly St. and Edenvale Cres. cul-de-sacs.

Parking In Kelly St & Edenvale Cres:
The Developer's application omits to mention that the western boundary to the development is to Kelly St as well as Edenvale Cres. The division between these roads is a built-up garden, which is designated Open Space 2. There is angle parking in this narrow cul-de-sac section of Kelly St and cars must back-out from these parks to the turning bay in Kelly St as there is no other area in which to turn.
This parking is essential for residents of numbers 14-16 Kelly St as they have no off-street parking and all these spaces are full after work hours.

Parking in the area on the other side of the area designated 0S2 on Edenvale Cres is also at a premium after work hours as most of these residents also have insufficient off-street parking to accommodate their household's cars.

It has been noted that during business hours an increasing number of commuters are parking for the day in Kelly Street and to some extent in Edenvale Crescent and using bus transport along Mt Eden Road to and from the city, thus creating the daytime parking problems seen in other areas.
In addition, the small businesses housed in the historic buildings on the northern corner of Kelly St. and Mt. Eden Rd occupy a number of kerbside spaces in Kelly St during the day. This scarcity of road parking was recognised by previous occupants of the premises at 17 Kelly St. (NECAL & ESR), and led to the development of further parking facilities on the 17 Kelly St. site.
The application proposes an additional new traffic crossings plus separate pedestrian entry/exit paths into the development from Kelly St. The new eastern traffic crossing (2.5mtrs) appears to ingress at the point at which the road narrows to 5.1 mtrs at the junction with Mt. Eden Rd. It is also in the same vicinity as a street light, two manholes, and rock walled planting structures designed to improve the environmental quality and urban amenity values associated with the past road closure of Kelly Street. The creation of an additional new traffic crossing in the locations shown on the plans submitted will undermine these values and will significantly reduce the number of parking spaces currently available in Kelly Street.

It is therefore recommended that the Council implement resident only parking areas in Kelly St and Edenvale Cres.

Traffic Movement in Kelly St.:
It should be noted that the traffic impact assessment prepared by Bryce Hall to support the Developer's application was prepared after ESR had vacated the site and therefore takes no account of traffic from that area.
The report uses statistics for Mt. Eden Rd. traffic flows taken early December 1999. These are now almost 2 years out of date and take no account of increases since then, including the impact of the large high density developments on and around Enfield St. to the north-east. The first stage (83 dwellings) of this development did not open until mid-2000.

The report states on Page 4 that traffic flows in Kelly St during the peak hour will increase from 30 vehicles per hour to 50 vehicles per hour - or a 67% increase. It states that this increase is within the traffic carrying capacity of Kelly St and its intersection with Mt Eden Road. It also states that the street has a kerb to kerb width of 8.9 metres.
However, it does not take into account that the entry to Kelly St is very narrow, being 5.1 m at the entry from Mt Eden Road, and that current residents of Kelly St are finding it increasingly difficult to turn onto Mt Eden Road as traffic volumes on this road increase. The street also narrows again to 5.1 metres at the western end.

Residents therefore anticipate that queues would form on Kelly St as cars waited their turn to move out onto Mt Eden Road.
The inverse will also apply in the afternoon peak-hour as vehicles try to turn into Kelly St.

Waste disposal and recycle vehicles already refuse to access bins in the Kelly St. cul-de-sac, and there is concern that emergency vehicles could encounter access problems.

It is therefore recommended that the plans for the development be altered to have all traffic enter and exit the site directly from Mt Eden Rd therefore avoiding major adverse effects on the surrounding neighbourhood.

Traffic During Construction:
The traffic impact assessment prepared by Bryce Hall states a maximum number of 40 truck movements per day during the excavation period. Given the problems already experienced by residents at the Mt Eden Rd corner this increase in large vehicles moving into and out of the site in a narrow street can be expected to cause considerable delays and disruption.

It is also difficult to see how all construction traffic can be located on site when the proposed excavation area is within 20 metres of the site boundary.

It Is recommended that the Council bring forward its plan to widen Mt Eden Road at the intersection with Kelly St to make provision for a turning lane into Kelly St to assist with the Increasing traffic volume in the area.

Pedestrians

Current Situation

While many residents of Kelly St. and Edenvale Crescent use their vehicles to commute to and from work there are also those who work in the city or university who use public transport. These, along with children walking to and from school result in considerable pedestrian movement in the morning and late afternoon, The streets are used as a shortcut from streets to the west such as Wynyard and View Rds through to Mt. Eden Rd. During the day there are parents with pre-school children, residents from the Edenvale Rest Home, crocodiles of children from the neighbouring pre-school and the Ficino school and people in the area who work from home studios or offices constantly using the area. After school and in weekends children cycle, skateboard and play ball in the cul-de-sacs. It is a pedestrian-high friendly environment.

Impacts of the Development

One of the factors impacting on safety, particularly child safety, is traffic volume. Pedestrian injuries are the leading cause of death in NZ children between the ages of 1-14 years. A study has shown that them is a strong association between increasing risk of injury to child pedestrians and increasing traffic volumes. In addition, a high level of kerbside parking is also associated with greater risk of injury. (Nemec, 1998)
(Ret Regional Growth Strategy June 1998, Social Infrastructure Impacts of Urban Growth]
Mt. Eden has experienced a significant increase in working age groups (aged 25-49 years) and is experiencing a corresponding increase in cbildren aged less than 15 years. (Auckland City, Strategic Development Group, Auckland City's People, Dec. 1997)

The increase in traffic volume in both Kelly St. and Edenvale Cres. generated by the development will impact on the safety of pedestrians, particularly young children. There is a high probability that visibility for both pedestrians and vehicles will be impeded by the retaining walls, which are a necessary feature of the excavation proposals. It will also have serious effects on the social infrastructure of the area.

Pollution

The ambient air quality in Mt Eden is among the poorest in the country, and C02 levels are of particular concern. [Ret: Proposed Auckland Regional Plan: Air, Land and Water]
Motor vehicles are the largest contributors to air pollution in the region and a significant source of stormwater contaminants. They are also responsible for localised noise pollution and as an effect of land use activities can impact adversely on the amenities of an area in terms of dust, dirt, fumes and visual intrusion.

The developers proposal would allow for upwards of 50 more vehicles within an area bordered on three and a half sides by narrow Local Roads and Residential 1 dwellings.

Along with the increased number of cars, the major concern for local residents is that air pollution and noise will increase from cars travelling along Mt Eden Rd. Currently, the thick bamboo fence on Mt Eden Rd and trees on the site itself helps to reduce the noise and filter the air. Under the proposed development, the boundary trees will be removed and replaced with a 3m high solid fence which will only serve to add to the noise and air pollution for residents as traffic noise will deflect off the walls and the height will slow the dispersion of traffic fumes

Both during and after construction the degree of pollution caused by increased traffic volume and underground parking would be "noxious, dangerous, offensive or objectionable to such an extent that it... is likely to have an adverse effect on the environment" [Ref: Resource Management Act, Part Ill section 1 7a]

It is therefore recommended that the height of the fence be reduced to 2m at maximum and that alternate fencing to better reduce traffic noise in the surrounding neighbour be introduced into the plans for the Mt Eden Road boundary, If the bamboo hedge is to be replaced.

Conclusions

Although the development at 17 Kelly St seems to meet with the Councils objective of having increased Intensity of developments near main transport systems, this development seeks to use a small local road for access.

Kelly St. and Edenvale Cres are classified as Local Roads, the function of which is to provide for property access. As has been shown above, these narrow roads are already stretched to capacity by the Residential 1 area, which they currently serve. The applicant's proposal seeks to capitalise on the amenity environmental and streetscape values of a Residential 1 area.

The increase in traffic movement and parking which would be generated by the proposed development of 25 units with associated on-site parking for 55 vehicles plus the roadside parking for visitors cannot be accommodated by the Local Roads.

The effects on the amenity values of the neighbourhood in terms of a functioning and safe environment are considerably more than minor.

It is therefore recommended that the development should not proceed. Or, should It proceed, that all entrances and exits to and from the site should be located on the Mt Eden Rd boundary, thus conforming to the purpose of the zoning and avoiding major adverse effects on the Special Character Residential 1 surrounding area.

RECOMMENDATIONS
In summary, the recommendations from the parking & traffic section of the submission are:
1. It is recommended that the development should not proceed.
2. Should It proceed, all entrances and exits to and from the site should be located on the Mt Eden Rd boundary, thus conforming to the purpose of the zoning and avoiding major adverse effects on the Residential I surrounding area.
3. As parking is already at a premium in the neighbouring streets because of the historic nature of the area, 13 visitor parks and 3 service delivery parks should be incorporated into the plan
4. Council should implement resident only parking areas in Kelly St and Edenvale Cres.
5. Pedestrian entrances to townhouses on the western boundary should be removed to discourage parking In the Kelly St. and Edenvale Cres. Cul de sacs and reduce traffic usage of Wynyard Rd which Is already an issue for residents.
6. Council should bring forward its plan to widen Mt Eden Road at the intersection with Kelly St to make provision for a turning lane into Kelly St because of the Increased traffic in the area.
7. To reduce pollution, the fences surrounding the development should be reduced to 2m at maximum and that an alternate fencing solution, which absorbs noise, be found for the Mt Eden Road boundary if the bamboo hedge is to be replaced.

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HISTORIC ENVIRONMENT

THIS PART OF OUR SUBMISSION RELATES TO THE SPECIAL CHARACTER AND HERITAGE ISSUES RELEVANT AND MEANINGFUL TO THE RESOURCE CONSENT APPLICATION NO. AO. 01.09274

AUCKLAND VALUES ITS PAST. ACTS IN THE PRESENT AND CREATES THE FUTURE [Mission Statement - Auckland City Annual Plan 2001 I 02]

The Mt. Eden North Residents Association Inc. represents a geographic community of both residents and stakeholders.
Bounded at the northern end of the ward by Shaddock St. and Boston Rd. the entrance to this neighbourhood is defined by the railway overbridge, and fans westwards in a broad arc toward Dominion Road. Along the western side of Mt. Eden Rd, - Akiraho St., Sylvan Ave and Kelly St. still conform to a pattern dictated by the obdurate basalt landscape and the natural obstacles it presented - such 'blind alleys' and narrow lanes were early on considered to be one of the less admirable features of the district for the kind of access constraints they presented, then as now.
This is an area which resonates with historical associations which connect us to our past; indeed authenticated as such by its status as a special character heritage zone of [ residential '1]. Characterised by small lots and primarily one story dwellings; this is a zone where significant restraints, in terms of stringent building restrictions are applied.
This zone is intended to retain the historic form and pattern of subdivision, buildings and streetscapes in Auckland's earliest established residential neighbourhoods. [District Plan Isthmus Section] A significant provision of the Resource Management Amendment Act under Section 6 of the principal Act is the protection of historic heritage from inappropriate subdivision, use and development.
It is also acknowledged that special character represents something deeper too than merely a template for colonial aspirations and identity. The cultural meanings evoked in heritage are further defined as:
A repository of accumulated significance.
A cultural legacy deemed worthy of preservation.
A resource in matters of history, architecture, community associations, rarity value and high degree of environmental amenity.
ICOMOS [New Zealand Charter for the Conservation of Places of Cultural Heritage Value] provides definitions of meanings and intent thus:
Preservation as meaning maintaining a place with as little change as possible and
conservation as meaning the processes of caring for a place so as to safeguard its cultural heritage value.
Here, then, we have a community respecting and valuing the accumulated significance and cultural legacy, which contribute to a meaningful identity. Much of this ethos is visible in the huge investments of time, energy and money property owners have traditionally expended toward maintaining, rehabilitating and enhancing traditional dwellings.
Presiding over, and further defining, our true 'sense of place' is the iconic imprint of Maungawhau on our environment and history.
Before amalgamation the Borough of Mt.Eden was essentially proactive in assuring and defining the history record. A number of publications based on borough archives, photographic sources and oral histories preserve and attest to that significance.
These publications are a detailed record of an district dominated by its archaeological and geological proximity to the highest volcano on the isthmus; firstly, its pre-European significance as one of the most important cone pa; secondly, its subsequent subdivision by government authorities into rural landowning blocks intended for settler farmers; thirdly, its desirable location on the 'outskirts' of 'town' which led to consequent intensive subdivision for residential purposes. Collateral damage to the stonefields (which once distinguished this area of the pa as gardens where extensive agricultural production of kumara and fern-root took place) began almost immediately. In 1848 Kyber Pass was formed by blasting the spur of Mt.Eden. Suffice to say that numerous indignities wreaked havoc on the indigenous landscape so that today:
Of Auckland's 34 volcanic cones, 17 have been protected, but 10 have been completely destroyed and the remainder have been modified to a greater or lesser extent.
In the metropolitan area over 50% of pa have been extensively modified or destroyed. Of the original 8000 ha of stonefield areas, less than 200 ha are still in existence.
Not only was the immediate area seen as a resource to be plundered for the wider community, especially in terms of quarrying for road construction [for instance Parnell obtained most of the gravel for its roads from Mt.Eden quarries] but the northern part of the borough remained open to exploitation as each successive shift in the inevitable progress associated with colonisation occurred. Today, the landmark, iconic shot tower is the only trace left of the Colonial Ammunition Company, which had been established since 1885 on the northern slopes. Although protected under the Historic Places Act, the context for its continued preservation for the benefit of future generations seems increasingly compromised by new forms of land use.
By 1900 the dispersal of businesses and jobs into the suburbs began to occur on a large scale. In close proximity to this neighbourhood, separated only by Mt. Eden Rd. a heavy industrial sector was initiated when the Henderson and Pollard timber treatment plant moved here in 1904. Locally, this only served to facilitate the unsympathetic discord between the industrial and commercial landscape on the eastern side of Mt. Eden Rd and the domestic scale of the residential environment on the western side of the road. Still, in the booming post-war culture, a company which manufactured coreboard advertised as "Royal Flush" might well have justified their business development too as "highly innovative in that it brings a fresh breath of locale compatible quality " (Stephen F Havill - P21 of Application)
Even so, there is an awareness now concerning the numerous instances of environmental degradation where remnants of the recent industrial past at this northern end have left a legacy of pollution and toxic contamination. The 'severance' effect of having Mt.Eden Rd between did nothing to ameliorate the excessive noise levels, the air polluting emissions or the leachate of hazardous substances into the site and its surrounding environs.
Many established residents have already had the experience of living through an era of extensive and prolonged abuse of their immediate environment. It is worth noting, in this regard, that the introduction to the Resource Management Amendment Bill admonishes local authorities to seek and adopt models of best practice and further warns that councils that do not make sufficient progress in this regard are answerable to their own communities.

Valuing the past what does this mean?

To our community it certainly means recognition from Council of our concerns and remedial action to avoid further despoilment of the historic landscape. Also to identify and accord protection to such values which remain intrinsic to our sense of well being and relatedness to our environment.
Far example, on the southern boundary of the site at 17 Kelly Street there is a dry stone wall. Glenstone Ltd proposes to excavate 4500 cubic metres within 2am of the site boundary, and to raise the existing ground level 950mm.This will de-stabilise the existing structure of the wall to such an extent it will be highly probable that it would be considered beyond conservation, preservation or even restoration. The cumulative effect of such a scale of activity will not reflect adaptation of the landscape, but rather, desecration and dismemberment.
Such walls, over a hundred years ago, were once a significant aspect of the farming landscape and emblematic of this community. During the late 1 800s this northern locality witnessed the first residential subdivisions created from such rural estates. First of these was Captain du Moulin's 'Sunnyside', after which Sunnyside Rd - now Edenvale Crescent - was named. Houses in this street, including numbers 2-20 and 1-15 are all listed in the 1981 Proposed Borough of Mount Eden District Scheme as fulfilling historic criteria. Possibly because they are all representative examples of sturdy early colonial cottages built around this time. Their nearness to the local Kauri Timber Company meant that quality heart kauri was mostly used in their construction. To accommodate this new land grab, the great roading drives of the past demolished many of the dry stone walls to expedite access through the borough. However many of the new roads created through residential subdivisions were all anchored by similar walls; artisanal techniques used to define the width and direction of roads in the darkened landscape. Just such a wall is still in existence along the whole of the road boundaries of Marino Gardens.
Built in 1938 on the site of the previous Winstone family home at the corner of Esplanade Road and Mt.Eden Road, these apartments reflect the early pre-war use of concrete for building purposes. It was considered avant-garde enough at the time to receive, for the architect, the Gold Medal from the NZ Institute of Architects. Across on the other corner of Mt.Eden and Esplanade is the landmark 'cupola' which distinguishes the same building which once housed Woods & Company, a grocery store. A local dairy continues to ply the same trade. At the entrance to Kelly St. is an impressive example of late 19th century architecture, which was once the local bakery with the bakers house nearly attached at 1 Kelly Street. The ovens still exist within, although a later annex has been built where there was once a courtyard for the horse and cart. It has since been converted to the premises of a manufacturing jeweller House of Bond.
Another architectural connection worthy of mention, in respect of this area, is the little known fact that in the immediate post war years, when an imported modernist ethos was attempting to re-invigorate NZ architecture, the initial founders of the Architectural Group met in 1946 at 24 Brentwood Avenue Mt. Eden to sign their constitution. Their subsequent work is well known, and acknowledged today in buildings all over the Isthmus. Unfortunately, their ideas were not utilised by the Health Department during the 50's era - otherwise we may have seen a significant desire to preserve the current buildings at 17 Kelly St. which were specially built by the Government to house the Auckland Dental Clinic Training School. The dental nurses who attended the Training School were housed in the Health Department hostel in Ngauruhoe St., which is now The Auckland Metropolitan College - known familiarly to most Mt. Eden residents as Metro.
No early development seems to occur, particularly in Mt Eden, without the significant presence of religion. Defined as a heritage area, we also accept the vital connection to an historic preponderance of churches in our midst. They remain as concrete expressions of communities in action as embodied in the unique Society of Friends [Quakers], which has resided at their present address on the corner of Sylvan Ave and Mt.Eden Road since 1910. This is a dedicated community, which continues to promote pacifism and the guiding precepts of a moral, ethical and social conscience.
Also on the western side of Mt.Eden Road is situated the historic church of St. Barnabas, and on the corner of View Road and Esplanade Road is the austere St. James PresbyterIan, now revitalised by a Cook Island Community. They may not live here, having been displaced by gentrification etc. but they still worship here. On the opposite corner at 27 Esplanade is the former Bethesda Old People's Home with the magnificently preserved historic homestead still there. This site too, has been revitalised recently by a change in purpose. It is now a much-cherished educational environment for The School of Philosophy's foundational Ficino School.
Esplanade Rd. is also infamous for its concentration of 'sausage flats' which developers built without constraint during the late 1960's and early 70's. Some twenty of these blocks of fiats and multi-story units are located along this road alone. Such densification was perceived as anomalous, even then. A stable, quiet residential neighbourhood became increasingly vulnerable to the problems always associated with such 'ghettoes' ie. inadequate open space and a transient population. Often cheaply constructed, they reflect an impoverished aesthetic coherence and blighted social strategies.
Much contextual evidence of history and tradition is to be found within this western axis of the area known as Mt. Eden North. Such heritage issues have largely been ignored or seriously down-played by Glenstone Ltd, the Wellington based applicant of the proposal. Perhaps this is not surprising, since old enmities between Wellington and Auckland are hardly conducive to comprehending and respecting a 'sense of place' which is not your own. In Growing Our City Through Livable Communities 2050 (Adopted June 2000 ) Auckland City states the first tenet of The Central Principles as:
The Environmental Protection principles identify areas of the City, which are inappropriate for further development. Growth will be restricted where there are identified environmental constraints and special amenity issues in order to protect essential and valued resources, maintain public health and safety and preserve heritage areas.
Is this meaningful communication or simply empty rhetoric formulated by governance?
If the latter, it is not surprising that this community should wish to voice their public concern - loud and clear. Auckland City must be aware that such concern exacts its own price in terms of compounding fear, eroding confidence and elevating levels of mistrust toward Council strategies. Accordingly we wish the Council to refuse consent to this application and furthermore:
To restrict the provisions whereby District Plan Rules are open to liberal interpretation and therefore vulnerable to opportunism e.g. Innovative Housing
and:
With due regard to Part II, Sections 5, 6, 7' and 8 of the Resource Management Act

and:
With especial regard to amendment ( f) Section 6 of the principal Act, to reflect the proposal in Its entirety.

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