Response to further information request Ministry of Education Notice of Requirement (200 & 252 Park Estate Road)

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1 21 Pitt Street PO Box 6345, Auckland 1141, New Zealand T: // F: E: info@beca.com // Auckland Council Private Bag Victoria Street West Auckland August 2018 Attention: Roger Eccles Dear Roger Response to further information request Ministry of Education Notice of Requirement (200 & 252 Park Estate Road) Thank you for your request for further information under section 92(1) of the Resource Management Act relating to the above notice of requirement (as received on 20 April 2018). Please see below our response to these requests. (1) School Catchment The integrated transport assessment (ITA) is predicated on the catchment for the primary school and ECE being predominantly to the south of Park Estate Road. After reviewing the ITA and notice of requirement (NoR) assessment of environmental effects (AEE), Council s consultant transport specialist (Terry Church from Flow Transportation Specialists (Flow)) considers that the ITA needs to address a larger catchment area and consequential transport effects. In support of this finding, Mr Church has made the following observations: Section 3.1 of the NoR AEE states the following: The Hingaia 1 sub precinct D comprises 117ha and will ultimately provide for up to 1,950 new dwellings. Ministry modelling indicates these new dwellings will ultimately be home to approximately 585 new primary aged students once all are complete From the above, a ratio of 0.3 students per dwelling can be deduced. Section 2.3 of the ITA notes that phase 1 of the Hugh Green Group (HGG) development will provide for approximately 250 lots surrounding the school site. Therefore, it is estimated that during the initial years of the school opening, only students will come from the catchment to the south of Park Estate Road. Given that the school is anticipated to have a starting roll of students (taken from Section 3.1 of the ITA), it is considered that the majority of students will initially come from a wider catchment area to the north and east (this outcome also appears to be acknowledged in Section of the NoR AEE which notes the establishment of northern road linkages to support future growth in the student roll). This wider catchment area is anticipated to include students from existing schools and residential housing presently within walking distance of the proposed school site, with Park Estate School being located approximately 700m away to the east. The application of a wider catchment area to the school will impact trip generation assumptions, assumed level of pick up and drop off trips, walking/cycling connectivity and the required upgrading of Park Estate Road. It is therefore requested that the ITA be reviewed in light of these findings, and

2 Page 2 further information provided which addresses the concerns raised in relation to the school s catchment area and consequential transport effects if the area extends to the north and east. The number of students that will enrol upon opening of the school will depend on a number of factors and therefore a conservative estimate was used, based on the Ministry s experience when opening schools in new urban areas. The ITA used an estimate of students to provide a worst case assessment of the potential traffic effects on opening. The Ministry agrees that it is likely that in the initial years after the school opening, approximately students will likely come from the catchment to the south of Park Estate Road. It is likely that the school will have a wider catchment in the future when the residential area to the north is developed and (in particular) connections are made to Park Estate Road. It is noted that the school is not relying on connections to the north to fill its roll. Catchment to the North At this stage there are no road or pedestrian connections to the north and, should this remain the case, this will reduce the attractiveness of sending students to the new school because of the inability to easily access the site without a circuitous route across the motorway and back. Further, Hingaia Peninsula School would be closer to the residential development to the north (which has existing road and pedestrian links) and parents may choose to send students to this school (and they would be in zone ). Further information on the school zone can be found at Catchment to the East Park Estate School is located on the opposite side of the motorway to the proposed site. This school serves the catchment to the east of the motorway. It is recognised that (as with the opening of any new school) there may be some families who currently attend (or would attend) Park Estate School that may choose to try the new school. However, it is not anticipated that this would result in a significant number of families from east of the motorway opting to travel further to attend the proposed new school and therefore the traffic effects on Park Estate Road will be low. There is a purchase agreement between the Ministry and HGG which will require HGG to upgrade and widen Park Estate Road fronting the school by December 2020 (and therefore before the school opens which is likely to be 2021 or later). A retention of payment is built into the agreement until this work has been undertaken. HGG has confirmed that it is unknown at this stage when the remainder of Park Estate Road, particularly to the east of the school, will be upgraded. It is anticipated that the timing of the upgrading of Park Estate Road will match the residential growth in the area. However, until the Park Estate Road upgrade occurs it is not expected that the school will generate much traffic from the east. (2) Assessment of traffic effects and accessibility of future road connections Mr Church acknowledges that Flow were responsible for the development and use of the traffic model and accepts that the 2031 traffic modelling accounts for a Primary school accommodating 700 students in the proposed location, with this outcome being based on the premise that all proposed roads in the Hingaia Precinct would be operational in Notwithstanding this, Mr Church also

3 Page 3 notes that a 2021 development scenario for Hingaia was subject to traffic modelling, and this assumed the school had a roll of 300 students and the presence of 200 dwellings in the Hingaia Area (to be constructed by the HGG). Although these assumptions are consistent with land use outcomes detailed in the NoR, they were based on the premise of Hinau Road being extended to connect Park Estate Road and Kahanui Drive. As there s presently no mechanism to ensure that this connection is in place by 2021, the school s opening has the potential to generate additional traffic within the local road network to the east of SH1, rather than connecting with Hingaia Road (via Kahanui Drive and Hinau Road) to the north. Section and 2.6 of the ITA also highlight the necessity of the Hinau Road extension being in place when the school opens in It is therefore requested that the ITA be reviewed in light of the above findings, and further information provided which addresses the cited 2021 traffic modelling outcomes and consequential transport effects if the Hinau road extension connecting Park Estate Road and Kahanui Drive is not in place when the school opens in 2021 (note: the requested information should also address policy 6 for the Hingaia 1 Precinct which requires subdivision and development to be staged to align with the co-ordinated provision of infrastructure, including transport). Advice note: Council is aware that that there is a reluctance from the current owners of land which would accommodate the proposed Hinau Road extension to provide this connection until such time that Park Estate Road is upgraded. As such, the timeframe associated with bus routes and connectivity with the wider strategic network is uncertain. The opening date of the primary school is subject to change and will be in response to the pace of development in the surrounding area. While not mentioned in the NoR, the Ministry does request an extended lapse period of 10 years to give effect to the designation for this reason. It is agreed that any future northern connections to Park Estate Road will be led by developers or by Auckland Transport (by way of designation) and the timing of the connections are not known at this stage. It is anticipated that these will match the residential growth in the area. In the interim, until the northern connections are made it is not expected that the school will generate much traffic from the north. As noted above, the school roll is likely to be less in this scenario as properties to the north will not be able to directly access Hinau or Kahunui Road, thereby reducing the attractiveness of enrolling. The school can still open without the connection to Hinau or Kahunui Road and will serve the area to the south and immediately to the east (west of State Highway 1 that is internal trips within the local network). It is noted that further discussions with Mr Church (post s92 letter being issued) transpired in which it was agreed that the 2021 modelling assumptions referred to above assumed a connection with Park Estate Road and Kahanui Drive only (not Hinau Road). (3) Upgrading of Park Estate Road The ITA assumes that Park Estate Road will be upgraded but the NoR does not provide a mechanism to ensure that this occurs. This is essential infrastructure for the school, particularly in relation to walking and cycling facilities for students. There would be significant safety effects if the school opened in the absence of Park Estate Road being upgraded to provide walking and cycling facilities for students.

4 Page 4 It is therefore requested that the ITA be reviewed in light of the above findings, and further information provided which confirms that Park Estate Road will be upgraded when the school opens in Advice note: The Park Estate Road cross section provided at Figure 2-5 of the ITA is not legible and a legible cross-section should be provided for review. There is a purchase agreement between the Ministry and HGG which requires HGG to upgrade and widen Park Estate Road fronting the school by December 2020 (and therefore before the school opens in 2021 or possibly later). As a minimum, the upgrade of Park Estate Road will provide a 21m wide legal road comprising two lane carriageway with a low design speed, a separated cycle lane and a footpath on the southern side of Park Estate Road. For the balance of Park Estate Road this will be led by developers of the surrounding land which the school is designed to serve. The proposed school is in response to the development of this area. If there is no residential development (and consequential upgrade of Park Estate Road) there will be no need to develop the school until a later date. The extended NoR lapse period of 10 years reflects the need for flexibility in response to any delays to residential development in the area. Please find below the cross section for Park Estate Road provided from HGG. (4) Pedestrian connectivity and safety

5 Page 5 Section 5.4 of the ITA discusses that the School Design Concept Plan will capture pedestrian crossings of Hinau Road and Park Estate Road. Pedestrian crossing facilities about these locations is supported as they are in keeping with the Hingaia Precinct policies, however these only provide safe crossing points to catchment areas east and north of the school, rather than south and west of the school (being the catchment assumed in the ITA). Mr Church considers that a safe crossing facility should also exist about the southern boundary road of the school, therefore ensuring a safe route exist for students living in the southern catchment of the school. This requirement should be captured within the School Design Concept Plan, and in Mr Church s view, to exclude this would be inconsistent with policy 5 for the Hingaia 1 Precinct. In addition to identifying a safe crossing facility along the proposed school s southern road boundary road Mr Church has recommended that the School Design Concept Plan address the relationship between future bus stops along the bus route shown on the Hingaia 1 Precinct Plan and proposed pedestrian crossings. Given that the proposed Hinau Road extension is anticipated to have high daily traffic volumes, Mr Church has also queried whether the proposed pedestrian crossings should be zebra crossings rather than kea crossings, with zebra crossings providing safe crossing locations outside the school peak periods (noted that kea crossings could utilise the zebra crossings during school peak periods). It is therefore requested that the ITA be reviewed in light of the above findings, and further information provided which identifies how pedestrian crossings will be provided so that they re consistent with policy 5 for the Hingaia 1 Precinct. The Ministry agrees with the need for a pedestrian crossing facility on the road along the southern boundary of the school site to provide a safe route for the catchment to the south of the school. The Ministry is willing to include a pedestrian crossing on the southern boundary road as a matter to be included in the School Design Concept Plan, provided at the Outline Plan stage. As stated in Section of the ITA the type of pedestrian crossing, the design and location should be agreed with Auckland Transport at the Outline Plan stage. The Minister of Education has no control over the design of the road and therefore any condition setting out obligations on the Minister are inappropriate. These matters will be resolved through engagement with Auckland Transport as part of the development of the master plan and then the Outline Plan process. The Ministry supports addressing the relationship between any future bus stops along Park Estate Road and a proposed pedestrian crossing on Park Estate Road for the school within the School Design Concept Plan. The location of any bus stops will take into consideration the most recent Auckland Transport guidance including Transport Design Manual - Urban Roads and Streets Design Guide. This guidance acknowledges that for bus stops to safely and effectively serve the community, pedestrians must be able to safely cross the road. It will therefore be desirable to locate the bus stop in close proximity to the pedestrian crossing proposed for the school on Park Estate Road. Access to driveways and local roads would also need to be considered along with the spacing between bus stops and intersections. Notwithstanding this, the location of the bus stop will be on a public road, which is outside of the control of the Minister and will need to be further discussed and approved by Auckland Transport. (5) School Pick-Ups and Drop-Offs Section of the NOR AEE suggests that the majority of drop off and pick-ups will be undertaken on Hinau Road given that this is to be the main pedestrian access to the school.

6 Page 6 While Mr Church agrees that a lot of pick-ups and drop-offs occur on-street, he also recommends that a pick-up and drop off facility within the proposed school site should be established. The pickup and drop off facility should also allow for the tracking of buses used for school events. This therefore provides an on-site facility that relieves pressure from the surrounding road network, assists in minimising conflicts between children and vehicles (noting the function of Hinau Road) and recognises that indented parking bays on the surrounding roads are to serve the wider development and are not guaranteed for school use. It is therefore requested that the ITA be reviewed in light of the above findings, and further information provided which identifies how an on-site pick-up and drop-off facility may be accommodated within the proposed school site (note: feedback has been received from Auckland Transport which indicates their opposition to any off-site pick up and drop off facility. Mr Church has also noted that the use of any on-street parking for pick-up and drop-off would be dependent on obtaining approval from Auckland Transport). Mr Church has also noted that the cross section for Hinau Road (shown in Figure 2-4 of the ITA) needs to allow for right turn manoeuvres (noting the role of Hinau Road) and because of this, indented parking bays about the vehicle access may not exist. Mr Church has therefore requested that the road cross section be reviewed and if necessary, amended to provide for vehicles to turn right when exiting the school. Advice note: The Hinau Road cross section provided at Figure 2-4 of the ITA is not legible, and a legible cross-section should be provided for review. The Ministry accepts that proposed Pick-Up and Drop-Off (PUDO) arrangements for the primary school and ECE will include a combination of a dedicated on-site PUDO facility and informal on-street parking. The Ministry agrees that providing an on-site PUDO facility will reduce the reliance on on-street parking and ensure on-street spaces are available for non-school use. However, it is recognised that on-street parking on local streets will also have a role to play for pick-up and drop-off as parents may choose to utilise these if it is convenient. This is particularly so on a site like this which has multiple road frontages. The site is sufficiently sized (almost 3ha) to provide an on-site PUDO facility for the primary school and the Outline Plan will identify the location of such a facility. The master planning of the site has not yet been undertaken; however, initial investigations have established that there is flexibility and the potential option of accommodating a PUDO facility along the boundary with either Hinau Road or the local road along the southern boundary. The ability of buses to use the PUDO facility for school events will be considered as part of the traffic impact assessment (recognising this will be a more infrequent event), which will be submitted as part of the Outline Plan. The requirement for the road cross section to be reviewed and, if necessary, amended to provide for vehicles to turn right when exiting the school has been discussed further with Mr Church. It transpires that Mr Church was referring to right turning vehicles entering the school rather than exiting the school. The Ministry is not responsible for the delivery of the Hinau Road extension. However, the Ministry and HGG are parties to an agreement which imposes on HGG an obligation to construct the Hinau Road extension to certain minimum specifications which will ensure the road outside the school is suitable for school use. Further discussions on the design of the cross-section of the road could include a right turning bay.

7 Page 7 The Ministry suggests that an assessment of the safety of right turning manoeuvres from Hinau Road into the school could be a matter to be addressed as part of a traffic impact assessment to be prepared by a suitably qualified traffic engineer and/or transportation planner, to be provided at Outline Plan stage. Hinau Road will be the subject of further design at the Outline Plan stage and will be dealt with at the Engineering Plan Approval stage. It is acknowledged that this could involve the removal of parking bays. In response to the Advice Note above, the Hinau Road cross section is shown below. (6) Cycle Parking Provision Advice note: Noting the emphasis that the Hingaia 1 Precinct provisions have on walking and cycling, and the infrastructure being included on the surrounding network (separated cycle lanes), Mr Church is of the view that secure cycle provision should be based on a mode share assessment, as shown in Table 4 of the ITA and not on the AUP-OIP minimum standards. The mode share assessment suggests that the cycle provision will be in the order of spaces to account for a student mode share of 9% (63 spaces) plus staff. A condition requiring the higher provision is recommended. The Ministry agrees that the provision of cycle/scooter parking should be based on demand. The Ministry will provide an appropriate number of cycle/scooter parking upon the opening of the school with further provision

8 Page 8 determined through the School Travel Plan process. A School Travel Plan is a live document prepared for every school which assesses and encourages how students should travel to school. This is modified over time in response to growth and change at the school. While cycle parking provision will not be based on minimum AUP-OIP standards, demand will be monitored on a continuing basis through the School Travel Plan. The site is large enough to accommodate cycle parking (e.g. 50 spaces) plus further provision as determined by the School Travel Plan process. The provision and location of cycle parking will be included in the Outline Plan. (7) Soil contamination assessment Council s contaminated land senior specialist (Andrew Kalbarczyk) has noted that the preliminary site investigation submitted in support of the NoR application is dated May 2015, and based on an assessment of the site undertaken in Consequently, Mr Kalbarczyk considers that the assessment provides inadequate information on the current contamination status of the proposed school site. It is therefore requested that a preliminary site investigation (PSI), specific to the proposed school site, be provided which assesses its current contamination status and enables Council to adequately assess present soil contamination effects (note: the PSI should be prepared by a suitably qualified and experienced contaminated land practitioner, in general accordance with Contaminated Land Management Guidelines, No.1, Ministry for the Environment (revised 2011). The Ministry recognises that it is required to assess its proposal under the National Environmental Standard for Assessing and Managing Contaminants in Soil, and apply for any resource consents found to be required under these Standards prior to earthworks commencing which may be a number of years away. However, the Ministry will undertake this as a separate process to the Notice of Requirement. It does not consider that the provision of an updated Preliminary Site Investigation is necessary in order to process the Notice of Requirement. We anticipate that these matters of clarification will be sufficient to enable the notice to proceed to notification as per the assessment by Council officers. If you require any other information please let me know. Yours sincerely Alex Strawbridge Senior Planner on behalf of Beca Limited Direct Dial: alex.strawbridge@beca.com

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