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Why special housing areas were a real problem for Wellington

by Andy Foster
Frank McRae’s article on the City Council not rolling over eight special housing areas is chock full of errors.

He is however correct that the City needs more housing, especially because of rapid migration-driven population growth. I’ve long advocated for a national strategy on population growth and distribution. That is fundamental to sustainability and coherent planning. That’s the national challenge, while at a local level our challenge is to try to accommodate expected population growth without destroying the things that make Wellington such a great city. That requires the ability to robustly consider effects of proposed developments.

Where is Mr McRae wrong in his article? Well let’s start by saying that there seems to be an assumption that development only occurs in Special Housing Areas. (SHAs). SHAs almost certainly increase or speed up some development but let’s not overplay that. The fact is less than 1/3rd of consented sections and dwellings in the most recent period were in SHAs. For the period between 1 March 2017 and 16 July 2018, consents were issued for 1136 new sections and dwellings, with just 360 of them consented within SHAs. The rest were consented normally under the Resource Management Act (RMA).

Mr McRae says ‘SHAs do not provide carte blanche to developers’. If you read resource consent decisions (Erskine, Shelly Bay for example) it becomes absolutely clear that the existing planning rules are subjugated. The ‘Housing Accords and Special Housing Areas Act’ (HASHAA) which created SHAs is all about provision of housing. The values in the Resource Management Act regarding sustainable development are of lesser importance, followed by the District Plan and other still ‘lesser’ documents.

What is really frightening is the April 2018 judgement of the High Court on the Shelly Bay decision. This essentially says that because HASHAA put a limit on the maximum height allowed in SHAs at 6 storeys or 27 metres – all developments could therefore be expected to be allowed to go to that maximum level, regardless of the underlying height limit. From watching some of the Court of Appeal recently it is clear that the judges are giving thought to this. Take say a residential area like Johnsonville with a District Plan permitted height limit of 8 metres, what is being argued is that under HASHAA you should expect and allow developments of 27 metres. That was absolutely never the expectation of Council, and indeed we were assured that the District Plan would be fully taken into account when consents were considered.

It’s also become clear that if there are other non-residential values in an area – for example heritage – they can be swept away, trumped by housing provision. The Council when first entering into a Housing Accord, and I suspect even the author of the legislation, never anticipated that. So that made ‘rolling over’ an SHA over much of the Central City and Adelaide Road a real problem. Just think about the collection of heritage listed shops on the John Street corner as just one example.

I counted 37 heritage listed buildings within the proposed SHA for the Te Aro area.

The same is true of Open Space zoned land. The Shelly Bay SHA was specifically extended October 2015 to include a significant amount of Open Space B zoned land. Open Space B zoning is crystal clear – and I said this at the time – that buildings of any sort are absolutely not to be expected. That Open Space zoning in the District Plan had been established through submissions, hearings, appeals, but all of that was simply irrelevant when considered under HASHAA. In my view that is just plain wrong.

If you want to see what makes this even worse, have a look at the youtube coverage of the Council meeting of 8 April 2015 when the second group of SHAs including Erskine and Shelly Bay were approved (by split votes). We had been promised when the Council entered into a Housing Accord with the Government that there would be extensive consultation should any more SHAs be proposed. Here was the second lot (Tranche 2) – 16 SHAs proposed, but no consultation at all! You’ll see the coverage of officer presentation and responses to questions. Starting at 1 hr 31 the officer clearly states that Part 2 of the RMA would apply, the District Plan provisions would still apply and key urban design principles would still apply. At 1hr 42 he answers a question about not consulting and he says that ‘The sites that have been proposed in Tranche 2 are largely residential or areas that have been signaled for residential development so I would not expect that the public would be surprised that residential development might be considered on residential zoned land. I think in terms of consultation if we’d looked at a site for example where it wouldn’t have been the public expectation, rural zone, open space zone, you’d certainly expect extensive consultation.’

So a promise to consult when we entered into the Housing Accord in June 2014 had been discarded by April 2015. Here in April 2015 is the promise of ‘extensive consultation’ should a proposed SHA go into ‘for example’ Open Space zoned land. Just six months later that expectation (shall I say promise) was also abandoned.

I think it is bizarre for Mr McRae to say there ‘would be nothing “undemocratic” about special housing areas established by a democratically elected central government and the vote of a democratically elected city council.’ On that logic Government and Council could do anything they liked without any democratic engagement at any time between elections. No way! In my opinion HASHAA is a deeply undemocratic piece of legislation from a Government that wasn’t really much given to community engagement. SHAs intentionally and completely undermine democratic processes allowing for the possibility of notification (however limited), and just as significantly they undermine the District Plan established by the Council through extensive democratic engagement and statutory submission processes.

Mr McRae is concerned that public notification ‘hands objection rights to every member of the public’. Well the fact is that a tiny proportion of proposals are notified.

In my view the number is too low. Nationally the last time I looked it was around 1%, and in Wellington a miniscule 0.8% of all applications were notified. Even 1 ½ to 2 % notification would pick up the most substantial cases. To be notified usually something has to be a significant departure from the policies and rules of the District Plan. Developers don’t like notification so they tend to try to avoid it, and the best way of doing that is to not depart too much from the District Plan, and critically to avoid, remedy or mitigate adverse effects. SHA status means that becomes an issue that can be pretty much brushed aside.

Mr McRae also says that only adjacent property owners can be notified under HASHAA. Correct. What that meant in the case of the Erskine SHA is that on a site which was heritage listed in its totality, and is occupied by two category one listed buildings (the highest category there is, by definition a “special or outstanding historical and cultural significance or value.” ), neither Heritage New Zealand Pouhere Taonga, or Save Erskine College Trust which has rare status as Heritage Protection Authority over a site, got a say in the consent application and non-notified decision was granted to demolish the main college building.

With the exception of the severely earthquake damaged Shed 35 on Centreport land (demolished with agreement of HNZPT) Erskine will be the first heritage listed building to be demolished since before the current District Plan was promulgated in 1994, With respect to Shelly Bay SHA status meant nobody got a say. That’s why you are seeing court action now. There are clearly a range of important issues that an RMA process would have had to address in a way the HASHAA process does not.

Mr McRae is also wrong when he says ‘the District Plan approach which, in practice, assumes that the city will retain its existing form and assesses potential developments against its impact on that’. Actually the RMA / DP process assesses developments not against what is currently in place, but against what the Plan allows for. So for example if I want to build a 50 metre tower in a location where the height limit is 48 metres, and the site is occupied by a 2 storey house, then the assessment of effects will be about the difference between 50 metres and 48 metres, not a comparison with the existing building. It is a long established national practice referred to as the ‘permitted baseline’ approach.

That means there is actually very substantial development capacity in the city. The challenge in many cases is whether developing the capacity is financially viable including being supported by infrastructure. That in part depends on the level of return developers seek. Council is doing a lot of excellent analysis on this, and on the areas we will seek to increase development capacity. However we will do this properly, engage with our community about where growth should and should not be accommodated, and then move to reviewing the District Plan to give effect to this. This is a huge piece of work and will involve major community engagement over an extended period. You will see a lot more on this soon.

I agree completely with Mr McRae about Adelaide Road being an ideal area for intensified housing. He is absolutely right that ‘It is a large area, on the fringe of the CBD on a high frequency bus route that may convert to light rail in the future.’ What he has missed is that the Council many years ago increased the height limits along Adelaide Road frontage to 18 metres as of right and 12 metres on a large area of properties behind the frontages.

What I suspect has held Adelaide Road back is firstly that the costs of development will be more or less the same as closer to the CBD, but properties will be less valuable. Secondly long planned transport and public space development (except Drummond Street) have not happened as they were originally linked with a Basin Reserve solution. Clearly this soon will be addressed as part of Let’s Get Wellington Moving. Thirdly Council has not yet established an Urban Development Agency to advance development, so it is entirely left to the private sector.
A bit further south on Constable Street a very fine and sustainable looking development of 56 units has just been granted consent – no SHA there.

I completely disagree with Mr McRae for all the above reasons when he states that SHAs ‘would enable the city to grow in the most sustainable way possible’. That is the very point. The RMA, which is absolutely founded in the ethos of sustainable development and resource use, is pushed aside by HASHAA’s sole focus on housing. In the words of Joni Mitchell :

They paved paradise
And put up a parking lot
With a pink hotel, a boutique
And a swinging hot spot
Don’t it always seem to go
That you don’t know what you’ve got
‘Till it’s gone
They paved paradise
And put up a parking lot

They took all the trees
And put them in a tree museum
And they charged all the people
A dollar and a half to see ’em
Don’t it always seem to go
That you don’t know what you’ve got
‘Till it’s gone
They paved paradise
And they put up a parking lot

There’s sustainability in a song. Good resource management is making sure that you understand what you have, what you value, and how adverse effects on those natural and built environmental values are properly considered. HASHAA in its design and even more so in its execution deliberately sets out not to do that.

I do completely agree with Mr McRae about the importance of being a compact city. That is essential to sustainability. Over my time, the Council has done a lot to encourage denser urban form. That’s included allowing mixed use activity and not compelling carparking provision in the Central City and Suburban Centre/Business zones which have been spectacularly successful. It also meant dialing back on rural ‘deferred urban areas’, and creating the Outer Green Belt through extensive land purchase to provide a clear edge to the city. I’d note for him that in fact four of the eight rejected SHAs were greenfields, the other 4 were brownfields, so a bit mixed on the compact city front.

He is wrong to say that the District Plan is 18 years old and therefore out of date. I have already acknowledged above that increased population growth is putting more pressure on everything including planning, and that we are going to review the Plan in totality. However he should have noted that since 2000 we have been undertaking rolling review of parts of the Plan and most of it has been updated once already. There have been no less than 94 Plan Changes and Variations since 2000. All are listed on Council’s website. The most significant change was the review of both the Centres/Business Areas (Plan Change 73) and Residential (Plan Change 72) parts of the Plan which together cover most of the city. They were notified in 2009 and made operative in 2014.

There are things that I do think need reform in respect of the RMA.

In my view, the RMA forces Councils as consent authorities to deal with consent applications as they come in. That does lead to often reactive and piecemeal approaches to planning, but at least it allows consideration of effects. All the messing around with the Act, mostly under National Governments, has all been about making consenting easier and quicker. I think anyone who has paid any attention would be well aware that our ‘clean green’ image is more spin than substance.

We have a long way to go. What we need is better results. They last a long time. HASHAA is far worse in all these regards. At least the RMA’s heart is in the right place.

13 comments:

  1. Patrick Morgan, Cycling Action Network, 30. August 2018, 11:15

    Thanks for setting out the case against a rollover of SHAs, Andy.
    It puzzles me why Adelaide Road has been so unloved. With a positive LGWM on the horizon, this should change. There’s loads of low-value buildings there crying out for development into mid and high density housing + retail + offices, supported by light rail and bike lanes.

     
  2. Guy M, 30. August 2018, 12:05

    Thanks Andy, for the article, and thanks Patrick, for the excellent question over Adelaide Road. My gut feeling is that Adelaide Road needs a bit of a helping hand along the way. Patrick – I’m certainly hoping you’re right about a positive outcome for LGWM – there’s still no indication what they are doing or which way they are going to swing.

    In the same way that Victoria St in the CBD/Te Aro fringe was helped along the way by an injection of WCC funds into the new roading layout – and the subsequent 2 or 3 substantial new apartment buildings by Stratum, I’d suggest that the WCC need to inject some action, strategy, and money into the Adelaide Road corridor. The last part I could find about this on the WCC website was from 2012 – and the framework for this area is from 2008. Ten years and no action – surely WCC can do better than that.

    In my mind, this would take the form of: a framework for the roading requirements, with central lanes for Light Rail, wide footpaths, separate cycle-lanes, and one lane each way for buses – and one lane each way for cars. Then secondarily, a masterplan for how the intensification of housing might work. A height limit of 18m as of right would allow six stories – ie ground floor light commercial, and 5 floors of medium density housing. You’ll need to get Stratum back (or another reasonable quality developer) in to do the first, demonstration block. No parking needed – they can all walk or take the bus or tram to work.

    But if a positive example is not made first, then the crappy developers will seep in instead, letting it become an avenue of shame, like the new developments along Taranaki St (clustered around Wigan St). So – we look once more to WCC for leadership in this area!

     
  3. Tony Jansen, 30. August 2018, 13:19

    Fantastic response Andy. A credit to your long standing career in the Council as well as your ability to absorb large amounts of detail and present this in an easy to understand format. If only more of your colleagues were as community focussed and eloquent as you. A pity you are not in my ward, you’d get my vote every time.

     
  4. Frank McRae, 30. August 2018, 17:01

    1. “Where is Mr McRae wrong in his article? Well let’s start by saying that there seems to be an assumption that development only occurs in Special Housing Areas.”
    What? This is a strange assumption that I never made. I didn’t say development only occurs in SHAs. I just said that it is easier to develop those areas with an SHA in place than it is without one.

    2. “Mr McRae says ‘SHAs do not provide carte blanche to developers’. If you read resource consent decisions (Erskine, Shelly Bay for example) it becomes absolutely clear that the existing planning rules are subjugated.”
    That’s not what carte blanche means. The developers still had to go through a consent process. You even said the words above ‘resource consent decisions’.

    3. “It is bizarre for Mr McRae to say there ‘would be nothing “undemocratic” about special housing areas established by a democratically elected central government and the vote of a democratically elected city council.’ On that logic Government and Council could do anything they liked without any democratic engagement at any time between elections.”
    I still maintain that a provision put in place by two different levels of elected government, that gives adjacent landowners objection rights, is democratic. Giving every cross armed member of the public a veto over all development is not a foundational principle of democracy.

    4. “Mr McRae is concerned that public notification ‘hands objection rights to every member of the public’. Well the fact is that a tiny proportion of proposals are notified. In my view the number is too low. Nationally the last time I looked it was around 1%, and in Wellington a miniscule 0.8% of all applications were notified.”
    These numbers don’t take into account developments that never proceed because the likely cost of public notification puts people off from applying for consent in the first place.

    5. “Mr McRae is also wrong when he says ‘the District Plan approach which, in practice, assumes that the city will retain its existing form and assesses potential developments against its impact on that’.”
    I said ‘in practice’. It is true. In practice the district plan approach places a heavy weight on assessing development against its effect on the status quo.

    6. “That means there is actually very substantial development capacity in the city.”
    There is not.

    7. He is wrong to say that the District Plan is 18 years old and therefore out of date.
    Ok fair cop I was wrong here. Some parts of the District plan are 18 years old and some are 9 years old. They only date back to the start of the Obama presidency. Luckily the world hasn’t changed since then.

    8. “I disagree with Mr McRae … when he states that SHAs ‘would enable the city to grow in the most sustainable way possible’.”
    These SHAs make it easier to develop in inner city areas. This is more sustainable than the alternative of pushing development outside of Wellington City to the regional fringes.

    Finally – that Joni Mitchell song sucks and it is appropriate that it is an anthem for people who are committed to opposing progress.

     
  5. Traveller, 30. August 2018, 18:00

    I love that sad and true Joni Mitchell song …

     
  6. Ben Schrader, 30. August 2018, 18:41

    The SHAs might have been a boon for developers (certainly for Ian Cassels), but in restricting the public’s right to appeal poorly-conceived housing developments, they’re fundamentally undemocratic and their passing is to be celebrated.

    Good urban design comes from wide consultation and getting the public on side. If Adelaide Road had been an SHA then we would have likely ended up with another Shelly Bay-type fiasco. We now have a chance to do something really imaginative that both respects the area’s past and takes it forward in a sustainable way.

    (Incidentally, I recently saw a 1940s plan of northern Adelaide Road rebuilt with Modernist flats, so the idea of its medium density redevelopment has been around for a while – just never acted on.

    And I like the Joni Mitchell song Frank. I don’t oppose progress, but it needs to be a shared rather than a singular vision.

     
  7. Noddy, 31. August 2018, 1:15

    Sorry Andy. I am not persuaded. You have stated that SLAs accounted for 360 of 1136 recent residential building consents and therefore it doesn’t matter – just over 30% of the total. So in effect you are happy to see the numbers of new residential consents fall by more than 30% at a time of housing shortages when house prices and rents are going through the roof and young people are being priced out of the city. I think your priorities are wrong.

     
  8. Andy Foster, 31. August 2018, 7:29

    Thank you Patrick, Guy, Tony, Traveller and Ben all for your really positive responses.

    Frank, I agree you didn’t say development only occurs in SHAs. However you did use several different ways to say it was very very difficult under the RMA. I agree we hear of developments where the RMA process is challenging. Sometimes it is hard to understand why, at other times it is clear. However the whole purpose of your article was to bemoan Council rejecting rolling over 8 SHAs for a final year. Fundamentally you have overstated the significance of SHAs in providing additional housing. We’ve seen only 1/3rd of new dwellings and sections have come in SHA areas. SHAs have undoubtedly sped up some housing development. However in some cases they have overridden the District Plan and permitted development to occur that otherwise would not have, because of significant adverse effects. The two cases I’ve focused on most are Shelly Bay and Erskine.

    I think you are nitpicking about your term ‘carte blanche’. You are correct developers still need consent, but the fundamental thing about HASHAA is that it completely changes the process and often the outcomes of a resource consent. The sustainability principles of the RMA, and District Plan protections, often fought for by communities over many years, are subjugated to the provision of housing. Adverse effects are much more permissible. The Court of Appeal Shelly Bay case focused on S34 of HASHAA (the consenting process), and heard the argument that this means the more houses provided the greater the adverse effects that should be allowed. Critically the High Court found, and lawyers at the Court of Appeal argued, that because HASHAA allows SHAs up to 27 metres in height, therefore all consents under HASHAA should be able to go to 27 metres, regardless of the underlying zoning. This is absolutely fundamental, and something Council never contemplated and did not mean. With that case law, if you lived in a SHA, you could do nothing if a 6 storey building were proposed next door.

    That isn’t a big deal in the Central City where higher buildings are expected – though sweeping away heritage protection is. However of the 34 SHAs agreed at various stages by Council just two were zoned Central Area, two are on the fringe of the Central Area (Adelaide Rd and Arlington with 12-18 metre height limits), 14 are broadly suburban and have District Plan height limits of 8 – 11 metres, and seven are northern suburbs greenfields (again 8 metres). SHAs consequently have a lot less benefit than you suggest for densification. If we could truly rely on the RMA and District Plan to have significant weight, then rolling over some of those SHAs could have been contemplated. However the assurances we received from officers about this have proved completely hollow. The current case law is the Shelly Bay High Court decision. Now the awaited decision of the Court of Appeal on this matter will prove pivotal.

    I note Frank you don’t dispute that less than 1% of consents in Wellington were notified. However you say ‘these numbers don’t take into account developments that never proceed because the likely cost of public notification puts people off from applying for consent in the first place’. That is true, but I’m fine with that. In my experience if something is likely to be notified it is because it is considered to have significant adverse effects. It might appear to take longer, but I think it is good that proposers re-think proposals to reduce those effects, and that in general is what they do, change the proposal, which means of course they still can undertake a revised development.

    You have reiterated that the District Plan ‘places a heavy weight on assessing development against its effect on the status quo’. Again I point you to the ‘permitted baseline’ test. Under the RMA development proposals are assessed against what is allowed on a given site, not against what is there at the moment. That does mean there is significant development capacity in the city. We will however need more because of predicted population growth. Council is testing feasible capacity across every property in the city at the moment. This is a key building block in determining how much additional capacity we need to create through reviewing the District Plan in toto. That is a huge job, which we will start consulting on in the next few months. We will do that strategically, in consultation with our communities, and considering the things we value and wish to protect in our city, not by the stroke of an SHA pen.

    Finally, I really don’t like the sound of your democracy Frank. Just because a Government or Council is elected that doesn’t mean they should be able to do what they want. Can I say have ‘carte blanche’? The fundamental premise of HASHAA is deliberately anti-democratic. It is about ensuring that nobody gets a say – unless you live right next door – then just maybe, and little good it will do you. Two doors away – sorry; seriously concerned about safety on a road you cycle or walk several times a week – sorry; Heritage protection agency wanting to have a say on really important heritage buildings – sorry; something really genuinely important to your community or city – no, sorry again. Perhaps we will have to agree to differ on that.

     
  9. Farmer Bill, 31. August 2018, 8:54

    I can see a Manor Park development of thousands of units all within a golf buggy ride (or electric bike ride) to the currently under-utilised Manor Park Golf Course and $50 million SH58/SH2 road interchange.

     
  10. Andy Foster, 31. August 2018, 9:14

    Thanks Noddy but no, you cannot interpret the numbers that way. The fact that 360 dwellings out of 1136 were consented under HASHAA does not mean they could not or would not or should not have been consented under the RMA.

    So for example the day that the SHAs expired we received applications for several hundred greenfields sections in the Northern suburbs. The areas in question are expected to be developed, in the way proposed by the applications and would have been consented under the RMA too. There was a financial benefit to the developers by virtue of associated Council decisions to do this under HASHAA. (eg ratepayer effective support by forgoing / delaying fees) Will it speed up actually building houses on those sections? No, the pace will undoubtedly be in response to the market – ie how fast they sell.

    However I was clear that in some cases SHAs can and have resulted in developments not likely to be permitted under the RMA. However that is for very good reasons as we have discussed. Developments would need to be of a different nature and scale to protect the built and natural environmental values on those sites. So yes we all agree that SHAs were creating more housing but not to that degree.

    The other point is that if the High Court decision holds SHAs could indeed have created more development capacity. We could have had 27 metre/6 storey buildings all over the city. That is not what we envisaged at all, and I just have this feeling that it would have gone down very badly indeed.

     
  11. Noddy, 31. August 2018, 10:53

    In response Andy.
    Point 1: You are of course correct that some of the consents granted in the SHAs might have been granted anyway. Equally it is likely that some would not, because the risk of the nimby wars would have deterred developers from even applying, and even those that did happen would have taken a lot longer. I do not accept your inference that the SHAs have not made a difference.
    Point 2: I believe you are exaggerating the significance of the “27 metre” Court decision. You claim that this could have resulted in “27 metre/6 storey buildings all over the city”. I do not buy that argument. Firstly for that to happen the whole city would have to be a SHA which it plainly isn’t. Secondly, economics! Building at that height is bloody expensive and is only ever going to happen where there is evidence of strong demand for that style of housing in a locality. There is no evidence of such demand in the green fields and suburban SHAs so it is simply never going to happen – the Court ruling is in reality no more than an interesting hypothetical rather than a real and present threat that you have painted it as. In the central SHAs and possibly maybe in Adelaide Road there is and I am not sure why that height of development would be a problem in those places.

     
  12. Frank McRae, 31. August 2018, 11:27

    “We’ve seen only 1/3rd of new dwellings and sections have come in SHA areas.”
    Amazing. “only” one third of new development has been in the tiny portion of the city with an SHA and you’re dismissing the significance of that?

     
  13. Andy Foster, 1. September 2018, 8:06

    Hi Noddy – in reply to your Point 1, no I don’t think there would have been ‘nimby wars’ at all in respect to most of the developments consented under HASHAA, had they instead have been consented under the RMA. That is precisely because for the most part they were expected, allowed under RMA and almost certainly would have been processed on a non-notified basis. However there would most certainly have been ‘nimby wars’ over some of them, and that is again precisely because under the RMA they would have been non compliant and had significant adverse effects. This is not about people just being difficult, but about people or organisations wanting the opportunity to address real impacts on their neighborhood, on heritage or on the wider environment.

    I do agree with you that we would be unlikely to see 27 metre towers popping up around the city. However that is to our surprise allowed for /expected under current case law. Looking through the list of those 34 SHAs, there are several where such development is entirely conceivable. We’ve got a lot of much taller towers in Thorndon for example so the economics did work there at the time. In some cases it might even be a good thing, in others it wouldn’t be. Key point is they should go through proper process and assessment of effects. That is a fundamental flaw of HASHAA.

    Peter – let’s leave aside your taking of one sentence in isolation, and that I was not dismissing the importance of 1/3rd of the housing consented. I’ve already – again – noted above that the majority of that 1/3rd would have been consented anyway without issues under the RMA, and what should have happened with significantly non-compliant proposals. However your stressing that ‘only’ 1/3rd of the new development occurred in ‘the tiny portion of the city with an SHA’ does warrant response. You are clearly implying that because a ‘tiny portion’ of the city produced almost 1/3rd of new dwellings that proves the impact of SHAs. I am actually surprised the number was as low as 1/3rd. The SHA areas included all of what has been for years been the fastest growing parts of the city. Te Aro is by far the fastest growing area. The entire northern growth area, the two suburbs (Jville and Kilbirnie) that we formerly ‘labelled areas of change’, and a host of handpicked areas with development potential and expectation. With or without SHA status these would have been expected to contribute a very large percentage of development. I am surprised it was as low as 1/3rd in that most recent 15 month period.

    Fundamental point again. The city is growing. We will provide capacity to accommodate that growth, but we will do it properly, strategically, and in consultation with the communities of Wellington. I would welcome both of your contributions at that time.

    Regards Andy