BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARINGS PANEL

IN THE MATTER

of the Resource Management

Act 1991 and the Local
Government (Auckland
Transitional Provisions) Act 2010

AND
IN THE MATTER

of Proposed Auckland Unitary

Plan, Topics 043 (Transport
Objectives & Policies) & 044
(Transport Rules & Other)

STATEMENT OF EVIDENCE OF JOSHUA REUBEN ARBURY

ON BEHALF OF AUCKLAND COUNCIL PROPOSED AUCKLAND UNITARY PLAN, TOPICS
043 (TRANSPORT OBJECTIVES & POLICIES) & 044 (TRANSPORT RULES & OTHER)
2 June 2015

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1.

INTRODUCTION

1.1

My full name is Joshua Reuben Arbury. I hold the position of Principal Specialist
Infrastructure Strategy at Auckland Council, which is the lead transport technical expert
for the Council. I have been in this position since November 2014. Prior to this I was a
Principal Transport Planner for Auckland Council since January 2012.

1.2

I hold a Master of Arts (Honours) in Geography from the University of Auckland. I have
nine years experience in Planning, with the most recent three years focusing on
strategic transport planning. I am also an Associate member of the New Zealand
Planning Institute. Full details of my qualifications and relevant past experience are at
Attachment A to this evidence.

1.3

I am authorised by Auckland Council to provide evidence in relation to the strategic

background and justification of the approach taken to parking regulation in the
Proposed Auckland Unitary Plan (PAUP).

1.4

Over the past two and a half years I have had extensive involvement in the
development of the PAUP, as well as some involvement in the final stages of preparing
the Auckland Plan. My involvement in the Auckland Plan included reviewing the wording
of the transport chapter in February 2012 and providing advice in relation to some of the
Auckland Plan targets (e.g. public transport patronage targets). In relation to the PAUP,
I was involved in reviewing draft versions of the PAUP's Regional Policy Statements
transport section in 2012 and 2013, and providing feedback on drafts of this section to
ensure alignment between the PAUP and the Auckland Plan.

1.5

I have also been involved in preparation of the PAUPs provisions that relate to the
Rural Urban Boundary, including leading preparation of an appendix to the section 32
report about transport impacts of different RUB options. Finally and of most relevance to
this topic, I have been involved in the development of the PAUPs parking provisions,
ensuring alignment between these provisions, the intentions of the Auckland Plan and
the cost-benefit analysis requirements of section 32 of the RMA.

1.6

Outside my direct involvement in the PAUPs preparation, I have focused on ensuring

that the strategic direction of the Auckland Plan is given effect to through various more
detailed documents. As well as the PAUP, this has included providing input to an
updated version of the Integrated Transport Programme, which outlines a detailed
transport investment programme for Auckland for the next 30 years as well as leading
development of the Low Carbon Auckland strategic action plans transport section.

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1.7

I believe I have a detailed understanding of the relationship between land-use and

transport in Auckland, as well as understanding the role of planning controls such as
parking regulation on key strategic outcomes.

2.

CODE OF CONDUCT

2.1

I confirm that I have read the Code of Conduct for Expert Witnesses contained in the
Environment Court Practice Note and that I agree to comply with it. I confirm that I have
considered all the material facts that I am aware of that might alter or detract from the
opinions that I express, and that this evidence is within my area of expertise, except
where I state that I am relying on the evidence of another person.

3.

SCOPE

3.1

I have been asked to provide evidence in relation to Topics 043 (Transport Objectives &
Policies) & 044 (Transport Rules & Other) of the PAUP. My evidence focuses on the
transport objectives, policies and rules which relate to parking. In particular, my
evidence provides a strategic background to the approach the PAUP takes to requiring
or restricting parking for private vehicles, by discussing the following:

(a)

Auckland Plan strategic direction. This part of my evidence highlights the

connections between parking regulation and the transport and wider outcomes
that are sought in the Auckland Plan. This section also describes how these
outcomes give effect to the principles of the RMA.

(b)

Parking approach to achieve Auckland Plan outcomes. This part of my

evidence analyses the strategic benefits of the PAUPs approach to accessory
parking, in terms of reducing or removing parking minimums in certain
locations and implementing parking maximums in others.

3.2

Within those headings, my evidence will also address key issues raised by submitters.
These include:
(a)

Retaining or removing parking minimums (with a focus on residential

activities);

(b)

3.3

Removing or limiting the application parking maximums;

In preparing this evidence I have relied upon a number of documents prepared by

Auckland Council (AC), Auckland Transport (AT), the NZ Transport Agency (NZTA),

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MRCagney (MRC), Flow Transportation Specialists (FTS) and other parties. The key
documents I have relied upon in relation to different parts of my evidence are outlined in
the table below:

Part of Evidence:

Key Documents/Information:

Strategic Context

Efficient Use of Land

Affordability

Urban Form

Modal Shift

Auckland Plan, 2012 (AC)

Unitary Plan Parking Standards: Number of Parking and
Loading Spaces Required, 2012 (FTS)
Auckland Plan, 2012 (AC)
The High Cost of Free Parking, 1997 (Dr Donald Shoup)
The Economic Impacts of Minimum Parking Requirements,
2012 (MRC)
Auckland Plan, 2012 (AC)
The High Cost of Free Parking, 1997 (Dr Donald Shoup)
Parking Requirement Impacts on Housing Affordability, 2014
(Todd Litman)
Parking requirements as a barrier to housing development:
regulation and reform in Los Angeles, 2013 (UCLA: ITS)
Unitary Plan Parking Standards: Number of Parking and
Loading Spaces Required, 2012 (FTS)
The Economic Impacts of Minimum Parking Requirements,
2012 (MRC)
The High Cost of Free Parking, 1997 (Dr Donald Shoup)
The High Cost of Free Parking, 1997 (Dr Donald Shoup)
The Economic Impacts of Minimum Parking Requirements, 2012
(MRC)

4.

SUMMARY

4.1

My overall expert opinion is that the wording of Topic 043 (Transport Objectives and
Policies) and 044 (Transport Rules and Other) of the PAUP, including the amendments
suggested by Mr Wong-Toi and attached as appendix C to his evidence-in-chief,
adequately addresses the current and future issues facing the transport network, gives
appropriate effect to the Auckland Plans strategic direction for transport and best meets
the purpose of the Act.

4.2

The PAUP provides for off-street parking through accessory parking (i.e. on-site parking
required or permitted in association with development on the same site) and nonaccessory parking (i.e. parking which is provided as the primary activity on the site
which may be available to the public). The management of accessory parking can
involve the application of parking maximums (i.e. a limit or cap on the amount of parking
provided) and parking minimums (i.e. a requirement to provide a minimum amount of
parking). Where maximums apply without a minimum there is no requirement to provide
any parking and conversely where minimums apply without a maximum there is no limit
on the amount of parking (in terms of the parking rule).

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4.3

The PAUP applies parking maximums with no minimums to the Metropolitan Centre,
Town Centre, Local Centre (other than those classified as Rural Satellite Centres),
Mixed Use, Terraced Housing and Apartment Buildings zones as well as the City
Centre Fringe overlay. All other zones retain minimum parking rates, with the exception
of office land uses which are subject to a maximum parking rule regardless of location
(with a more restrictive maximum applied in the City Centre and City Centre Fringe
Overlay). This region-wide approach to the application of parking maximums and
minimums is intended to support the efficient use of land, reduce development costs,
encourage better urban design outcomes, and support public transport.

4.4

The PAUP provides an opportunity to ensure that planning regulations in Auckland

address the key transport issues facing the region and are up to date and in line with
international best practice. Until relatively recently there was little international literature
focusing on the impact of parking regulations. However, in more recent times the
importance of parking regulations in shaping urban form and transport outcomes has
been highlighted by a number of international experts.

4.5

5.

My evidence is structured as follows:

(a)

Strategic case for parking regulation;

(b)

Achieving Auckland Plan outcomes through proposed approach to parking;

(c)

Summary and conclusions.

STRATEGIC CASE

Auckland Plan

5.1

The Auckland Plan (2012) sets out the 30 year spatial framework for the growth and
development of Auckland, supported by a vision to become the worlds most liveable
city. The Auckland Plan identifies a move to outstanding public transport within one
network as one of the six key transformational shifts which are needed to be made to
achieve the Auckland Plan vision, and sets a number of challenging targets, including:

Doubling public transport from 70 million to 140 million trips by 2022.

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Increasing the proportion of all vehicular trips made by public transport into the city
centre during the morning peak from 47 to 70 per cent by 2040.

Increasing the proportion of people living within walking distance of frequent public
transport stops from 14 to 32 per cent by 2040.

Increasing non-car (walking, cycling and public transport) mode share in the
morning peak from 23 to 45 per cent of all trips by 2040.

5.2

Increasing annual public transport trips per person from 44 to 100 by 2040.

The transport system also contributes to a number of wider outcomes sought by the
Auckland Plan including, developing an economy that delivers opportunity and
prosperity for all Aucklanders and New Zealand, tackling climate change and increasing
energy resilience, create a stunning city centre with well-connected quality towns,
villages and neighbourhoods and to plan, deliver and maintain quality infrastructure to
make Auckland liveable and resilient.

5.3

Strategic transport modelling undertaken over a number of years (and detailed further in
my evidence on Section B3.3 of the Regional Policy Statement) highlights the following
key findings:

(a)

Different urban forms have a significant impact on transport outcomes,

including access to employment, access to major centres, exposure to
congestion and environmental externalities such as greenhouse gas
emissions.

(b)

In many cases different urban forms have a more significant impact on

transport outcomes than different levels of transport investment.

(c)

A compact urban form supported by investment to improve public transport

delivers a more efficient and effective transport network and better value for
money than an expansive urban form and a focus on additional roading
capacity.

5.4

In my opinion, the evidence provided by strategic transport modelling highlights the

benefits of a quality compact urban form, supported by variety of improvements to the
transport network (particularly including improvements to public transport), as best
delivering an efficient, effective and safe transport system. As my evidence highlights,
the way in which off-street parking is regulated has the potential to either support or
undermine achieving a quality compact urban form and the increased use of public
transport, walking and cycling.

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5.5

Directive 10.6 of the Auckland Plan addresses parking, and states Parking standards
and innovative parking mechanisms should take account of multiple objectives,
including the need to:

Facilitate intensive and mixed use developments within strategic locations

Improve housing affordability

Reduce development costs

Encourage use of public transportation

Optimise investments in public parking facilities, civic amenities and centre

developments

5.6

Foster safe, convenient and attractive walkable neighbourhoods

Paragraph 576 of the Auckland Plan provides further context to Directive 10.6 as
follows: Inappropriate regulations and inflexible standards can impact negatively on
good design. They impede the development of more intensive housing and mixed
developments. For example, at times traditional parking standards (minimum number of
car parking spaces) are imposed in areas where alternative options (parking buildings
or investment in public transportation) imply that such minimums are counterproductive
to delivering the goal of intensification, mixed use and affordability. The Auckland
Council intends to review its approach to parking, as part of the development of the
Unitary Plan

5.7

A review of legacy parking rules and standards contained within the operative District
Plans reveals that most of the Auckland region is currently subject to minimum parking
requirements. By potentially requiring a greater level of parking provision than a
developer would otherwise choose, parking minimums may undermine achieving some
aims of the Auckland Plan, such as intensification to help achieve intensive mixed use
developments, improving housing affordability, reducing development costs and
encouraging use of public transport. Chapter 13 Aucklands Transport highlights that a
change in parking strategy and standards is required to encourage intensification,
mixed-use development, more efficient use of land, and shifts to walking, cycling and
public transport.

5.8

As highlighted by Flow Transportation Specialists Recent plan changes have resulted

in the implementation of parking maximums in some town centres including Newmarket,
Sylvia Park, Orakei, Massey North and Hobsonville. Other plan changes have also
resulted in reduced minimum parking standards for particular activities, again

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predominantly around mixed use town centres1. These plan changes are more closely
aligned with the Auckland Plan, however, to enable transport and wider outcomes to be
realised this new approach to parking standards need to be implemented on a region
wide scale through the PAUP.
5.9

My evidence discusses the four main outcomes sought by Directive 10.6 in the
Auckland Plan of enabling growth and the efficient use of land, improving housing
affordability, modal shift towards public transport, walking and cycling, and the
creation of attractive neighbourhoods, with reference to how the PAUP parking
objectives, policies and rules contribute to each outcome.

Legislative context

5.10

The key aspects of the Act which I consider important in the setting of objectives,
policies and rules related to parking are the extent to which the provisions:
(a)

contribute to social, economic, and cultural well-being and to health and safety
(section 5)

(b)

avoid, remedy or mitigate adverse environmental effects (section 5)

(c)

support the efficient use and development of natural and physical resources
(section 7)

(d)

support the maintenance and enhancement of amenity values (section 7)

(e)

reflect the weighing up of costs and benefits, as well as their impact on

economic growth and employment (section 32).

5.11

As detailed throughout later sections of my evidence, there is growing recognition

(particularly articulated in the work of Donald Shoup, Todd Litman and the MRCagney
Section 32 report attachment) that the traditional approach to regulating parking has
created significant unintended effects. Reducing the extent to which the number of
parking spaces is determined by planning documents and instead, in most situations,
leaving that decision up to the market, appears to show significant benefits.

5.12

In essence, there is a balancing exercise to be undertaken that compares the impact on

wellbeing of requiring a higher or lower level of parking than the market would provide,
against any adverse environmental effects arising from this higher or lower level of
parking provision. It is my opinion that in most situations the wellbeing benefits from
removing or reducing parking minimums outweigh the adverse environmental effects of
spill over parking and therefore there is no justification for applying regulation in a way

Flow Transportation Specialists, 2012, Unitary Plan Parking Standards: Number of Parking and Loading Spaces Required.

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that would be binding and force a non-market outcome. This is outlined in more detail
in the evidence of Mr Stuart Donovan.
5.13

While in most situations there is greater benefit from letting the market determine the
level of parking provided, this is not the case in all situations. In my opinion the purpose
of the Act is better served by requiring either a higher or lower level of parking than the
market may provide, as follows:
(a)

In areas with high land-values, where growth is planned with greater access to
transport choices, a higher level of parking will create adverse impacts on
congestion and development potential that outweigh the benefits of providing
that parking. The use of parking maximums in these situations can help
maximise wellbeing and manage adverse effect.

(b)

In areas with lower land-values, where less growth is planned and where there
is less transport choice, the impact of requiring a higher level of parking on
wellbeing will be reduced. This means that the wellbeing benefits from not
requiring parking are more likely to be outweighed by the benefits of reduced
parking spillover. The use of parking minimums in these situations can help
improve wellbeing and manage adverse effects.

5.14

The extent to which parking maximums and minimums are binding (i.e. they force a
change compared to what would have happened in the absence of these rules) on
development will depend upon where the provisions are applied and their details (i.e. at
what rate and how easily an exemption can be obtained). In my opinion the provisions
have generally been carefully crafted to ensure they are binding in situations where the
benefits of regulating the number of parking spaces outweigh the disbenefits. Therefore
in my opinion the approach taken by the PAUP to parking is the most appropriate way
to achieve the purpose and principles of the Act.

Summary

5.15

Parking is an essential component of Aucklands transport system, where land-use and

transport integrate with each other and is a very significant land-use in its own right. The
regulation of parking has major implications on the ability of the region to accommodate
future growth and the desired quality compact urban form that is sought through
strategic documents.

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5.16

Legacy District Plan parking rules and standards reveal that most of the Auckland
region is currently subject to minimum parking requirements. This is in contrast to the
aims, outcomes and vision of the Auckland Plan, which state that parking standards
should help achieve mixed use developments, improve housing affordability, reduce
development costs and encourage the use of public transport, walking and cycling.

5.17

The next section of my evidence outlines how the PAUPs approach to parking aligns
with these key outcomes.

6.

PARKING APPROACH TO ACHIEVE AUCKLAND PLAN OUTCOMES

Introduction
6.1

This section of my evidence will evaluate the PAUP parking provisions in relation to how
they contribute to achieving the four key outcomes from Directive 10.6 of the Auckland
Plan:

6.2

Enabling growth and the efficient use of land

Improving housing affordability

Achieving modal shift

Supporting a quality built environment

Legacy parking rules and standards contained within District Plans focus heavily on
ensuring that developments provide sufficient parking on site to avoid creating the need
for parking on the street or on other sites (parking spillover). The main exception to this
approach is the City Centre, where a maximum parking approach exists.

6.3

A key consideration in the application of parking provisions is the extent to which

parking spillover is an adverse effect that needs to be managed to achieve the purpose
of the Act. In my opinion parking spillover in and of itself should not be considered an
adverse effect as for example on-street parking can have benefits from slowing down
vehicles through town centres improving safety and amenity. However, unmanaged
spillover parking may create adverse effects in some situations such as where onstreet parking impacts on the efficient, effective and safe operation of the transport
network or where spillover parking has an adverse effect on the economic prosperity of
businesses. There are a number of ways spillover parking can be managed, which are
explained in more detail in the evidence of Mr Scott Ebbert and Mr Stuart Donovan.

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Enabling growth and the efficient use of land

6.4

This section of my evidence focuses on the strategic benefits of reducing or removing

parking minimums from certain zones in order enable the efficient use of land. Parking
occupies land which may be more optimally used in another way. Better alignment of
land-use and transport is a key goal of the Auckland Plan, ensuring that land-use
planning decisions support transport goals, as well as ensuring transport decisions
support land-use planning goals.

6.5

The PAUP is proposing to reduce or remove parking minimums from certain zones (the
City, Metropolitan, Town and Local Centres, the City Fringe overlay, Terrace Housing,
Apartment Building zone, mixed housing urban and mixed use zones) to encourage and
enable development and intensification of existing urban areas, without placing a
requirement on developers to provide more parking than they would otherwise choose.
This approach allows the market (ie developers) to determine whether parking is
required and allows land that might be used for parking to be used for more productive
activities, ultimately resulting in higher densities.

6.6

The Auckland Plan highlights how Aucklands population is forecast to increase by

approximately one million people within the next thirty years. To facilitate this significant
level of growth it is important to develop a quality, compact urban city, which focuses on
intensification of exiting urban areas. The Auckland Plan seeks a 70/40 split between
intensification of existing urban areas and greenfield development. As noted above
(and explained in my evidence on Topic 012) notwithstanding the Auckland Plan, urban
intensification creates a range of transportation benefits.

6.7

To enable and achieve the level of intensification sought by the Auckland Plan, it is
important to make the most efficient use of developable land. In my opinion, minimum
parking requirements can be a considerable barrier to the type of intensification that is
necessary for Auckland to accommodate the proposed growth over the next thirty years
and to develop into a quality, compact city. By increasing the proportion of a site
required to be used for parking rather than actual development, on-site parking reduces
the potential development density.

6.8

MRCagneys economic assessment, which informed the parking Section 32 report,

notes that the primary impact of parking minimums is to reduce the space that is available
for accommodating future residents and commercial activities. The economic cost of
minimum parking requirements is therefore mainly an opportunity cost, in that they reduce

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the land and/or floor space available for other potential uses, rather than a financial cost
associated with the construction of parking itself.

6.9

The opportunity cost of requiring a greater level of parking than would otherwise be
provided impacts significantly on development potential. MRCagney assessed three
scenarios where parking minimums caused a 20%, 35% and 50% higher level of
parking provision that would have otherwise occurred. This analysis highlighted
foregone value of floor space of $57-$119m in the three study areas. Compared to the
relatively minor costs of a greater level of parking management (also detailed in the
MRCagney report), the opportunity cost of parking minimums is very significant. The
details of this analysis are outlined further in the evidence of Mr Donovan, including an
update of potential costs of parking management on private land.

6.10

Some submitters have questioned the appropriateness of reducing or removing parking

minimums, particularly in relation to parking overspill on to the street or other existing
off-street parking areas. Those submitters argue that parking overspill will have an
adverse effect on the operation of the transport system and potentially on the economic
wellbeing of some landowners.

6.11

While there may be some potential adverse environmental effects that arise from
parking spillover (assuming developers choose to provide less parking on-site than is
demanded), in my opinion these can be appropriately managed either by Auckland
Transport (for spillover on-street parking) or by private landowners through measures
such as restricting access to customers only or more actively managing off-street
parking on their land. The increased intensification of activity enabled by not applying
parking minimums will itself also mitigate these effects by supporting the increased use
of public transport, walking and cycling (see later sections of my evidence for more
detail on this).

6.12

The very large scale of benefit from enabling the more efficient use of land and the
strategic importance of enabling growth and intensification in areas with good access to
public transport and centres (where parking minimums are lowered or not applied) in my
opinion outweighs the costs and disbenefits from requiring a higher level of parking
management. My opinion on this issue is significantly informed by the cost-benefit
analysis undertaken by MRCagney and detailed further in Mr Donovans evidence. A
summary of the cost-benefit analysis is included below:

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6.13

While the analysis is fairly broad brush, with caveats explained further in the document
itself, the disbenefits of applying minimums in areas of higher land value where growth
is anticipated to occur outweigh the benefits by a significant degree. These conclusions
make sense to me at a broad level, due to the very high value of land in many parts of
Auckland and the significant amount of land that parking uses up. I can clearly see the
large disbenefits to a developer from having to use very valuable land for parking
instead of floorspace, when they would prefer to do otherwise.

6.14

Therefore on balance there is strong evidence to not apply parking minimums (or to
reduce them from current rates) in areas where land values are high and intensification
is intended, to enable the efficient use of land.

Housing affordability

6.15

This section of my evidence outlines how removing or reducing parking minimums from
certain zones can improve the affordability of housing.

6.16

Aucklands housing crisis is well documented and is often attributed to an under-supply

of housing, a lack of housing choice and declining affordability. Housing affordability is a
critical problem for Auckland. The Auckland Plan states that Over the last 20 years,
house prices in Auckland have increased at a greater rate than household incomes.
Several factors influence housing affordability, including the cost of land, materials and
construction or labour.

6.17

The current District Plan approach of requiring parking in most areas is an additional
cost that developers must factor in when deciding if a site is an attractive development
opportunity. Extensive research undertaken by Donald Shoup and Todd Litman found
that minimum parking requirements drive up the costs of land and redevelopment.
Litman calculates that based on typical affordable housing development costs, one

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parking space per unit increases a developer's costs by approximately 12.5%, and two
parking spaces can increase costs by up to 25%.2
6.18

Research by the University of California Los Angeles, Institute of Transportation Studies

found "when parking requirements are removed, developers provide more housing and
less parking, and also that developers provide different types of housing: housing in
older buildings, in previously disinvested areas, and housing marketed toward nondrivers. This latter category of housing tends to sell for less than housing with parking
spaces."3

6.19

The MRCagney Section 32 report attachment references a number of further studies

that examine the relationship between parking requirements and housing affordability.
Some of these studies take a ground up approach, examining different building
prototypes, land costs, construction costs, parking costs, the number of units and the
associated rental yields. Key findings of these studies highlight the impact of parking
requirements as both pushing up construction costs through adding the cost of building
the parking, and/or reducing the number of units across which that parking construction
cost can be spread across (by requiring land to be used for parking rather than
additional floor space).

Parking Requirement Impacts on Housing Affordability, 2014 (Todd Litman)

University of California, Los Angeles, 2013, Parking requirements as a barrier to housing development: regulation and reform
in Los Angeles.
3

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6.20

By removing or reducing parking minimums, there is also a reduction in compliance cost

that may be able to be passed on in the form of more affordable housing. Resource
consent applications, including the cost of obtaining specialist reports to support any
application for reducing the level of on-site parking provided, can add many thousands
of dollars of cost with this cost ultimately being passed on in the price of dwelling.

6.21

In summary, in my opinion removing or reducing parking minimums will support the

provision of affordable housing. This is due to a combination of lower construction
costs, the ability to use land more efficiently in providing higher intensity development
typologies, and a reduction in compliance cost.

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Supporting a quality built environment

6.22

This section of my evidence briefly outlines how requiring parking impacts on achieving
a quality built environment, as sought in the Auckland Plan and other strategic
documents. Some further detail on this matter is outlined in the evidence of Mr Ian
Munro.

6.23

The impact of parking on achieving a quality built environment is discussed in a Flow

Transportation Specialists attachment to the Section 32 report4. This report highlighted
areas throughout Auckland, such as Manukau City Centre and Albany Town Centre,
where parking is the predominant land use, resulting in a range of untoward effects on
urban form, urban vitality and transport patterns.

6.24

As already discussed, the MRCagney economic analysis report highlights how parking
minimums contribute to a fragmented, low density urban form by assuming that large
amounts of parking should be provided on individual properties. This undermines urban
amenity and the relative attractiveness of other transport modes, especially walking.

6.25

Dr Donald Shoup also discusses the relationship between parking rules and urban
design outcomes. He argues that minimum parking requirements determine what can
be built on a site, what it looks like, and how much it costs. Minimum parking
requirements have transformed many residential streets into garage scape where the
only obvious way to enter a building is with an electronic garage-door opener. Planners
initially designed parking requirements to serve buildings. Architects now design
buildings to serve the parking requirements.5

6.26

The impact of minimum parking requirements on achieving many of the quality built
form outcomes envisaged by the Auckland Plan and the PAUP are, in my opinion,
profound. Many of the high quality walkable centres (e.g. Ponsonby Road, Mt Eden
Village, Kingsland) that exist in Auckland are only possible because they were
constructed before parking minimums came into existence, or because parking
dispensations have been acquired. In contrast, many of the developments in more
recent times (e.g. Manukau city centre, Lunn Avenue, Wairau Park) that have
contributed to a poorer quality urban form have had their design largely dictated by
parking minimums.

6.27

Requiring on-site parking is likely to have a particularly significant impact on achieving

quality urban form outcomes for smaller sites, because there is less ability to

4
5

Flow Transportation Specialists, 2012, Unitary Plan Parking Standards: Number of Parking and Loading Spaces Required.
The High Cost of Free Parking, 1997 (Dr Donald Shoup)

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reconfigure the site to accommodate parking without compromising street frontage

quality. The access and manoeuvring space per carpark is also likely to be greater for
smaller developments, further undermining the ability to achieve quality urban form
outcomes.

Achieving modal shift outcomes

6.28

This section of my evidence outlines the benefits of implementing parking maximums in

certain zones as well as the benefits of removing parking minimums in other zones in
order to achieve modal shift (from private vehicles to public transport, walking and
cycling) outcomes and targets included in strategic documents such as the Auckland
Plan.

Parking maximums

6.29

Parking maximums are proposed in the City, Metropolitan, Town and Local Centres
zones, the City Centre Fringe Parking overlay, THAB and Mixed Use zones. Several
submitters are seeking to remove parking maximums (in conjunction with retaining
minimums) or to reduce the application of parking maximums (e.g. maximums only in
the City Centre and City Centre Fringe). Parking maximums have been in place in the
City Centre since the 1990s.

6.30

The purpose of applying a parking maximum rule is to create a ceiling for the amount of
parking that can be provided by new developments, which leads to environmental
benefits from preserved open space, limited impervious surfaces, more attractive and
pedestrian-friendly urban design, increased affordability and improved design flexibility.
In addition, the disincentive to single occupant car use created by limiting parking
availability encourages use of alternatives such as public transport, cycling, walking and
carpooling. Consequent reduction in private car use may improve mobility by reducing
congestion, providing additional capacity for pedestrians, cyclists or buses and improve
air quality.

6.31

The price and availability of parking is a key determinant of transport demand and mode
choice. For example, as part of preparing the City Centre Future Access Study 2012,
some adjustments to modelling inputs were made to the proportion of people travelling
into the city centre who would be likely to pay for parking. Increasing this proportion
from 30% to 50% resulted in 3,000 fewer modelled private vehicle trips into the city

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centre at peak times6 (from 23,000 down to 20,000 in the modelled year of 2021). As
noted in my evidence on section B3.3 of the PAUPs Regional Policy Statement, it is
important for the PAUP to support a modal shift towards public transport as a key part
of minimising any adverse effects of growth on the performance of Aucklands transport
network.

6.32

Economic analysis of the impact of parking maximums on the performance of the

transport network was undertaken by MRCagney in the development of the parking
provisions7. The analysis was very high level, as it is often difficult to assume the
difference between the amount of parking that would be provided with and without
parking maximums. What the analysis did show is that if parking maximums led to a 5%
reduction in the supply of parking across Auckland, this could generate approximately
$140 million of congestion relief benefits over the course of 30 years. The analysis
noted that this benefit would need to be weighed against any disbenefit to developers
from not being able to choose the level of parking provided, but certainly indicated a
material benefit arising from such a regulation.

6.33

Fewer car parking facilities can result in more efficient use of land and help support the
wider suite of travel demand management measures that are used to manage demand
for travel where concentrations of growth and development are planned. Parking policy
in the PAUP seeks to recognise the potential to serve a greater range of journeys by
public transport and alternative modes within a framework of standardising region-wide
parking provisions.

6.34

MRCagneys economic analysis that supported the section 32 report evaluated the
impact of applying parking maximums in Auckland City Centre. The study found that the
City Centre would now be home to approximately 1,200 more car-parks than currently.
Assuming resource costs of $50,000 per car-park, this equates to a potential resource
cost saving of $60 million since 20087. This highlights the potential economic benefits
associated with expanding the areas subject to a maximum parking rate, as well as
wider outcomes associated such as environmental and liveability benefits.

6.35

While the benefits of introducing maximum parking rates are clear, there are some
concerns that restricting parking supply in certain locations can impact on the economic
vitality of a development within the area. Attempts to use parking policies, especially
supply limitation policies, as a travel demand management (TDM) tool, depend on there
being good alternatives to access goods, services and other opportunities. For

6
7

NZ Transport Agency (2012) City Centre Future Access Study Parking Charges in ART3 modelling
MRCagney Pty Ltd. (2013) The Economic Impacts of Parking Requirements in Auckland

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example, limiting parking at one retail location that is similar to in its attributes to a
number of other locations may simply result in shopping trips being diverted to those
other locations.
6.36

The PAUP responds to this concern by tailoring the parking maximum rates to the
activity, in particular applying parking maximums for retail activities at a rate very
unlikely to be binding.

6.37

The parking maximum approach as outlined in the PAUP is consistent with many other
international cities. For example, in central Sydney applies parking maximum rates for
all land use activities based on access to public transport and services. In London, the
application of parking maximums (following the removal of parking minimums) led to a
46% reduction in the level of parking provided for new developments7.

6.38

In my opinion the selective application of parking maximums is appropriate, given the

benefits that arise to Auckland from achieving modal shift towards public transport,
walking and cycling. Importantly, the parking provisions of the PAUP are carefully
constructed to ensure that any limiting of parking supply is appropriate given the
location and specific activity. For example, the maximum parking rates on retail activity
are generous, acknowledging the current and likely future predominance of private
vehicle travel for this activity.

6.39

Furthermore, in areas outside the city centre the parking maximums have been set at a
rates that is less likely to be binding, (for example allowing a much greater provision of
parking per square metre of floorspace for office activity), which reflects the lower
availability of alternative transport options in these suburban locations, compared to the
city centre.

Parking minimums

6.40

Minimum parking requirements can be understood as a regulatory intervention that

seeks to increase the supply of parking above what would be provided by new
developments if they were free to choose themselves. Economic theory presented by
MRCagney suggests that an increase in the supply of parking will cause parking prices
to be lower than what they would be otherwise. Hence, minimums tend to result in more
parking at a lower price.

6.41

Therefore, parking minimums effectively act as a hidden subsidy for those who choose
to use private vehicles. By requiring a level of parking provision to cater for a high
proportion of peak demand, the cost of parking is internalised, potentially resulting in

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higher rents, lower wages or higher prices for goods and services whether or not a
private vehicle is actually the mode of travel used. Removing or reducing minimum
parking requirements will either remove or reduce this hidden subsidy, leading to a
more efficient overall transport system and contributing to the greater use of public
transport, walking and cycling sought in the Auckland Plan.
7.

CONCLUSION

7.1

My evidence above focuses on two key matters of relevance to Topic 043 (Transport
Objectives and Policies) and 044 (Transport Rules and Other) of the PAUP: the
strategic context and the strategic transport and wider outcomes that the parking rates
and standards are intended to contribute towards.

7.2

Overall, I consider that the PAUPs approach to minimum and maximum parking
requirements to be consistent with Directive 10.6 of the Auckland Plan (and the
Auckland Plan generally). Further, it is my opinion that, in relation to the matters above,
the wording of Topic 043 (Transport Objectives and Policies) and 044 (Transport Rules
and Other) of the PAUP best meets the purpose of the Act.

Joshua Reuben Arbury

2 June 2015

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Attachment A

Career Summary:

Auckland Council
Principal Specialist Infrastructure Strategy

2014-Current

Auckland Council
Principal Transport Planner

2012-2014

Heritage New Zealand

Heritage Advisor Planning

2009-2012

Resource and Environmental Management Ltd. 2006-2009

Consultant Planner

Qualifications:

Auckland University Master of Arts (Hons.) Geography 2006

Auckland University Bachelor of Arts
2003

Memberships: Associate Member of the New Zealand Planning Institute

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