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S92 Response and our Concerns

Updated: Nov 15, 2023

21st August 2023 - Grant Eccles responded (Further Information Request) to the Resource Consent application (RC1598) for Teitei Drive under Section 92 (S92) of the Resource Management Act (RMA).


3rd November 2023 - Barker & Associates responded in part to the S92 notice (albeit later than the original 11 September deadline). We only received copy of this 13th November but have document the following comments and concerns. I would consider that if an independent planner looking at the consent is aware that the district plan and policies are not being followed (premeditated avoidance tactics), that it would be a requirement to ensure the applicant can and will comply. If they cannot comply, they should be submitting housing plans along with the resource consent to confirm all safety matters and consenting matters can be adhered to.


  1. Item 25 - Snowmass pathway. The claim that the existing 2m wide pathway is unsafe and under the 3m requirement for a shared access pathetic excuse. The walkway is gravel thus slow speed for both pedestrians and bikes. It has been safe for some 10+ years

    1. The original ~35m of the existing pathway is 2m wide and was donated by David Holland, developer of Snowmass. The excuse that the pathway is not wide enough to be a shared path doesn't take into account that the original ~35m from Snowmass end will remain 2m, retaining the so called unsafe width.

    2. If this plan goes ahead, kids will have to walk (1.5m wide walkway) across 7 new driveways that are unlikely to meet safety manoeuvrability or sighting requirements as per the district plan; this is a huge safety concern.

    3. The proposed walkway diversion suggests that bikes use the road as the speed limit will be 40km/h and the new walkway will be pedestrian only at 1.5m wide. This is of huge concern & unsafe for kids to travel to the park on their own, or ahead of parents, compared to the existing access and a major downgrade. People will be forced to traverse the "Ohakune Social Housing Project" which is a safety concern, both physically and via intimidation.

    4. During construction, the erection of Safety Fences for a build site, access will likely be limited to the walkway for an extended period of time. The only alternative access for Snowmass and surrounding residents would be walking next to a state highway where the pathway is on the opposite side of the road, this would require crossing a 70km/h SH49 or walking on an unsafe berm. As it stands, Rocky Mountain Chalets (42+ units) advises their guests to use the Snowmass walkway as the safest option and they have a gate leading onto Snowmass from the rear of their property.


  1. Isthmus drawing for the 18m wide road shows a 4m wide swale, this differs from the original consent drawings show a 3m swale, it still shows a very light radius. Reviews done by David Holland in the past have shown this could be as deep as 0.7-1.4m (conservatively) and would involved a U shape swale. See more details here

    1. The proposed street parking at 2.2m is shown to use gobi blocks, will these gobi blocks extend the full width of the berm (1.8m) to allow for moving trucks, delivery vans, etc?

  2. All new Isthmus drawings now show sidewalks away from the street and against the boundary of properties. Considering the concept drawings we have been provided showing houses being built as close as 1.6m from the boundary, people are literally going to be walking up against a building in some instances.

    1. Service Access such as Water Tobys are usually around 1.5m off the boundary, this would place the service access inside the footpath or if extended more than 1.5m, could be within parking space, thus access may be restricted from cars being parked over them. Considering low income housing often attracts multiple cars, often not working, this could restrict access to services indefinitely.

  3. No drawings show examples of driveways, due to density, the visibility could be impaired from planting in berms. We already know the district plan is not being followed with regards to safety requirements - See more details here

  4. The Isthmus drawing for 14m wide roads do not show a swale, we believe this to be a drafting error, either the parking will not exist, or the side berm will not. If the side berm is actually the swale (3.5m), this would put the deep cut, U shaped swale right on the boundary of properties on that side of the road, meaning access bridges would need to be built to each lot, along with culverts, making manoeuvrability difficult & access from properties to the sidewalk difficult. If the swale results in car parking (3m) being removed, access bridges would still be required and access to a pathway from lots across the road would require residents to cross the road, then use one of the bridges to access a pathway. This could be a major safety concern for a development where the intention is to force residents to use other modes of transport other than cars. The intention mentioned from the Todd Langwell <Todd@trafficplanning.co.nz> was to reduce the number of car parks due to "with social housing in which car ownership is low".

  5. I note that the attachment has no Isthmus drawing for 12m wide (rural) road, the very road the Snowmass residents are proposed to use with the walkway diversion. We would hope these will be questioned and provided.

  6. I note on Page 5, showing where the reserve is located, there is supposed to be a 14m wide (Secondary Route) road and a 12m wide Rural road as per the original concept master plan. The new proposed drawing shows 13.5m roads on either side of the reserve.

  7. Where are residents supposed to put rubbish and recycle bins; these would either need to be placed in the parking spaces or proposed planting berms or in the street its self which wouldn't be wide enough. It should be considered that recycling and rubbish is likely to blow into these deep cut swales


  1. Point 2 states seasonal factors should not be considered as the environment is getting warmer, to quote "Warmer weather periods are growing and the window when weather may affect active modes are reducing". I believe the traffic engineer was talking about snow days, they have not taken into consideration the major rain events and flooding that has been occurring. Consider normal population of around 1200, then peak occupancy of the town grows to 11-12k people, the carrot park use is important.

    1. With the growing popularity of mountain biking and the new tracks being built up the mountain, this will likely draw more and more families to visit during the summer period.

    2. I note the comment also states "social housing in which car ownership is low", this is an untrue and was Mr Nottage (Watch the clip here) stated we have the second worst car to family ratio and that some properties have 3 or 4 cars on their front lawn and that not all of them are going.

      1. If there is a lack of parking, this could cause issue for delivery vans, moving trucks etc, as they would have to stop in the street, holding up traffic. Forcing a population to use other modes of transport is not possible and a terrible oversight.

    3. I note the admittance to only supporting a single car park for some lots, this goes against all the OIA's to date where we have asked for clarification and they have said every lot will have 2 parkings.

    4. Considering Ohakune has no forms of public transport and no GP, people have to have a car to obtain medical access by visiting other towns.

    5. With many jobs being farm related, cycling on state highways to jobs is not acceptable and unlikely to occur. Most retail or restaurants jobs are seasonal.

  2. Point 3, I make the same comment as above, with the addition of new cycle tracks and more and more summer tourists, this needs to be taken into account that carrot park will get busier.

    1. Carrot park is often busy until sundown, this extends in summer as daylight is extended.

    2. Considering visitors use the carrot park even in the rain or snow, it must be assumed that traffic will still be high and grow as the town expands, there are some 300 residential lots in consent or planning The same can be said for people living in the proposed Teitei development, if it's raining, they are more likely to use a car, than walk or use other modes of transport.


  1. We have not been provided with the number of parking spaces, we have asked since July, thus they cannot make this assessment "The proposed subdivision will increase the available parking supply". This is thus a false statement.

  2. We are concerned, with the lack of parking (1 for some lots) that carrot park parking may be used for residents as overflow, thus using public resources (carrot park) for private use, reducing visitor capacity from cars parked long term in the carrot park. This will then require time limits placed and enforcement policies at a cost to ratepayers, something we've seen difficult and discussed at numerous council meetings.

  3. Who Pays for the right hand turn bay proposed on SH49 to Teitei, RDC or KO? Is this a cost to rate payers?

  4. The wetland / paper road will clearly be a huge cost to rate payers if the proposed stage 2/3 go ahead, else traffic will just come in via the existing Teitei and be a mess. Another big potential cost to ratepayers.

  1. A health centre is noted on Page 12, I dont believe there is a GP located here and when questioned in the past, Raetihi is the only health service and its overloaded. I believe this is a Ngāti Rangi based health service - https://www.healthpoint.co.nz/mental-health-addictions/mental-health-addictions/ngati-rangi-community-health-centre-kaupapa/

  2. Page 18 & 19 clearly show the non complying activities of the district plan, rules & policies.

  3. Page 5 clearly says "on-street parking along both sides of the carriageway" which will not be possible on both sides of carriageways on any proposed street configurations.

  4. Page 11 clearly states "Also, if a development provides limited parking, the use of other modes is likely to be higher". As mentioned before, you cannot force this upon residents and this will cause huge conflicts and animosity or feuds with neighbours, which could result in violence/verbal abuse in a low income/social subdivision. It also causes concern for delivery or moving trucks having to hold up traffic and park in the road.

  5. Page 18 clearly states car parking rules as "Complies" when they have admitted that this will not be the case and some lots will only have 1 parking space, which is against the transport policy rules, so this should be "Non Complying"


NZTA provide conditional approval under Section 95E of the RMA. They raise concerns around access and traffic and the limitations of parking and suggest. They also highlight

  1. the master plan demonstrates two carparks for each lot proposed in stage 1, suggesting two car ownership rates. This does not align with the reduced car ownership rates argued by the applicant.

  2. Despite ongoing discussions between Waka Kotahi and Traffic Planning Consultants Ltd (TPC), there has been no agreement reached in terms of the speed environment at the intersection, or the anticipated vehicle numbers resulting from the proposal. However, Waka Kotahi notes that the applicant has volunteered to upgrade the intersection to include a right-hand turn bay. Waka Kotahi consider the upgrade is sufficient to safely allow for all vehicles to safely use the intersection and in particular for residents of the development to turn-right onto Teitei road, particularly during peak hours

  3. The applicant has explored the option of access via Raetihi Ohakune Road to the west as requested by Waka Kothi and have deemed that option unsuitable for stage one due to the paper road being unformed



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