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Plan Change 120 (PC120) - Make Your Submission
Disclaimer: The information on this page is provided for general guidance only and does not constitute legal or professional advice. Any submission made to Auckland Council is the responsibility of the individual submitter.

Anyone can make a submission. If you made a submission during the earlier PC120 process, it remains valid. However, if you wish to comment on the newly proposed amendments, you may make a further submission.

Please note:
Your name, contact details and submission will be publicly available. Auckland Council may use Artificial Intelligence (AI) to assist with reviewing and summarising submissions. To make a valid submission, you must provide your full name, contact details and all required information requested by Auckland Council.

URGENT: Submissions for PC120 close on 24 September 2026

Choose How You Want to Submit

A: Online (Recommended)

B: Email

C: Post

 

A: To complete the Auckland Council online submission follow these instructions:

 

Click on the link below:
PC120 Submission Form

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Complete your:

  • Full name

  • Email address (preferred)

  • Contact phone number (optional)

  • Address 

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Recommended Responses

First PC120 submission: Option 1

I request PC 120 (and/or proposed amendments) is*: Approved with the changes I/we requested

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Copy the Submission Text

For the section:

"I seek the following decision from the Council on the plan change and the proposed amendments"

Copy and paste the text below:

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This submission relates to the Flood Plain and Coastal Inundation hazard overlays applied to Gulf Harbour under PC120, and the consequential natural hazard and zone changes and Land Information Memorandum (LIM) notations arising from those overlays. The submitter's overarching concern is that the hazard overlays currently rely on regional, non-site-specific modelling for the Flood Plain, rather than site-specific analysis that reflects Gulf Harbour's as-built environment and, in the case of Coastal Inundation, an internally inconsistent climate change and sea level rise.

 

Copy the Reasons for Your Views

For the section:

"The Reasons for my Views Are"

Copy and paste the text below:

 

Submission Point 1: Flood Plain - Gulf Harbour

Decision Sought

Amend the Flood Plain overlay as it applies to Gulf Harbour by requiring that the extent and classification of the Flood Plain be verified through detailed, site-specific hydrologic and hydraulic modelling.

Pending completion of that assessment:

  • Amend PC120 to identify the Gulf Harbour Flood Plain overlay as requiring further site-specific verification; and

  • Review and, where necessary, amend the Flood Plain overlay and associated natural hazard provisions for Gulf Harbour following completion of that verification. 

Reasons

  • The Flood Plain extent is derived from the Rural Rapid Flood Hazard Assessment (RRFHA), applied to the 1% annual exceedance probability (AEP) event. The RRFHA is a regional screening-level tool rather than a site-specific hydraulic model. 

  • The model does not appear to account for the performance of Gulf Harbour's purpose-built stormwater infrastructure, which was designed to manage runoff for the development.

  • Auckland Council's own methodology states that detailed hydrological modelling has not been conducted and recommends verification using manual calculations or a detailed model when assessing flood risks in specific areas. 

  • The modelling outputs are being used to determine hazard classifications, zoning implications and LIM notations for individual properties, making a higher level of technical assessment appropriate. 

  • Existing stormwater infrastructure should be properly assessed before significant planning consequences are applied to affected properties. 

Submission Point 2: Coastal Inundation - Gulf Harbour

Decision Sought

Amend PC120 and its supporting documentation to:

  • Clearly identify the climate change scenario, sea level rise assumption and forecast year.

  • Publicly explain and reconcile differences between the Coastal Inundation mapping shown in PC120 and the Auckland Council Flood Viewer.

  • Ensure the Coastal Inundation overlay is supported by clear and consistent documentation regarding assumptions, methodology and forecast period. 

Reasons

  • The PC120 Map Viewer and Auckland Council Flood Viewer appear to use different sea-level-rise assumptions for the same area. 

  • Different Council mapping tools showing different inundation extents can make it difficult for property owners to understand their actual risk exposure. 

  • If different mapping tools serve different purposes, that explanation should be clearly stated in the plan change documentation. 

  • Mapping assumptions, methodologies and forecast periods should be transparent, consistent and easy for property owners to understand. 

Submission Point 3: Natural Hazard and Zone Changes of Gulf Harbour Properties

Decision Sought

Following the reassessment sought in Submission Points 1 and 2:

  • Review the Flood Plain and Coastal Inundation overlays applying to Gulf Harbour.

  • Review any associated natural hazard classifications.

  • Review any consequential zoning, precinct, overlay or planning map provisions.

  • Amend PC120 maps and provisions as necessary. 

Reasons

  • The final assessment documentation should clearly identify the climate change scenario adopted, the associated sea level rise and rainfall assumptions, and the forecast years used.

  • This information should be transparent and consistent across all Council hazard mapping tools. 

  • Where hazard overlays affect zoning or development controls, any significant changes to those overlays should be reflected in associated planning maps and provisions.

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I request PC 120 (and/or proposed amendments) is*: Approved with the changes I/we requested

 

Also add the PDF file GHMVRA Supporting Information

 

Attend a hearing
Do you wish to be heard in support of your submission?
This is up to the individual
Would you consider presenting a joint case at a hearing if others have made a similar submission?
Select “If others make a similar submission, I will consider presenting a joint case with them at a hearing”. This will be a GHMVRA case.

 

Declaration


I declare I could/could not gain an advantage in trade competition through my submission
Select I “could not” if the plan change's effect is not about business rivalry.


Are you directly affected by an effect of the subject matter of this submission that:- adversely affects the environment; and does not relate to trade competition or the effects of trade competition.


Select Yes if the plan changes effect on your property impacts you and your concern is not about trade competition.


Acknowledge by taking part in this public submission process that your submission (personal details including names and addresses will be made public) as required by law.


Acknowledge that the council may use AI to assist with reviewing and summarising submissions.


FINISH
You should receive an email confirmation within 30 minutes after you click the Finish button. Please check your spam or junk folder, if necessary. If you do not receive the email, enter your submission again.

 

B: To Complete an Email Submission follow these Instructions:


Email your submission to:
unitaryplan@aucklandcouncil.govt.nz

Subject: Plan Change 120 Submission

Submission Text

My Submission

This submission relates to the Flood Plain and Coastal Inundation hazard overlays proposed for Gulf Harbour under PC120.

I am concerned that the proposed hazard overlays may not accurately reflect Gulf Harbour's existing stormwater infrastructure and may rely on assumptions that require further review before being used to affect individual properties, planning controls and LIM records.

Flood Plain Mapping

Decision Sought

I request that Auckland Council:

1. Require detailed, site-specific hydrological and hydraulic modelling for Gulf Harbour.
2. Identify the current Flood Plain overlay as requiring further verification until that work is completed.
3. Review and amend the Flood Plain overlay and associated planning provisions once the detailed assessment has been completed.

Reasons

The current mapping appears to be based on regional modelling rather than detailed site-specific assessment.

Existing Gulf Harbour stormwater infrastructure may not be fully reflected in the modelling.
Property-specific flood hazard designations should be supported by detailed local analysis.
Existing infrastructure should be properly considered before planning controls and LIM notations are applied.

Coastal Inundation Mapping

Decision Sought

I request that Auckland Council:

1. Clearly identify the climate change scenario, sea level rise assumptions and forecast year used.
2. Explain any differences between the PC120 maps and the Auckland Council Flood Viewer.
3. Ensure all mapping is supported by clear and consistent documentation.

Reasons

Different Council mapping tools appear to show different inundation extents.
Property owners should be able to clearly understand what assumptions are being used.
Mapping should be transparent, consistent and easy to understand.

Planning Controls

Decision Sought


Following any reassessment of the hazard overlays, I request that Auckland Council:

1. Review the Flood Plain and Coastal Inundation overlays.
2. Review associated natural hazard classifications.
3. Review consequential zoning, precinct, overlay or planning provisions.
4. Amend maps and provisions where necessary.

Reasons

Planning controls should be based on the most accurate hazard information available.
Any changes to hazard overlays should be reflected in related planning controls.
Regulatory controls should remain proportionate to the hazard identified.

Please submit before 24 September 2026

A: Online Submission

Use the Auckland Council portal for the fastest filing. Please consult our instructions before starting.

B: Email Submission

You can also download the document, fill it out, and email it directly to the Council planning department.

C: Post Submission

Print and sign the documents, then post them to Auckland Council. Ensure you allow time for delivery.

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Disclaimer:

The information, guidance, recommended responses and submission wording provided on this website are supplied by the Gulf Harbour Marine Village Residents' Association Inc (GHMVRA) for general information purposes only. This material is intended to assist residents who wish to make a submission on Plan Change 120 (PC120). It does not constitute legal, planning, engineering, property, financial, or other professional advice. Each resident is responsible for reviewing the information provided, making their own assessment of the issues, and deciding whether to make a submission and what views to express. Residents may amend, add to, or delete any part of the suggested submission wording. While GHMVRA has taken reasonable care in preparing this material, GHMVRA, its committee members, officers, volunteers and representatives make no representations or warranties as to the accuracy, completeness, suitability, or currency of the information provided and accept no liability for any loss, damage, cost or expense arising from reliance on this material. Residents requiring legal, planning, engineering, valuation or other professional advice should seek independent advice appropriate to their individual circumstances. By using this information, you acknowledge that any submission made to Auckland Council is your own submission and remains your sole responsibility.

The Gulf Harbour Marine Village Residents Association (GHMVRA) has the following concerns: 
 
Flood Plain Modelling:
The reliance on Rural Rapid Flood Hazard Assessments to determine properties in the Flood Plain. This method largely ignores our purpose built and consented stormwater infrastructure.
 
GHMVRA supports the use of more detailed, site-specific hydraulic and hydrological modelling, to ensure flood risks are accurately assessed and future planning decisions are based on the best available information.
 
Climate Change Scenario:
The use by Council of a worst-case climate change scenario (SSP5-8.5) that has been retired as implausible from the next UN Intergovernmental Panel on Climate Change (IPCC) Assessment Report.
 
Sea Level Rise:
The use of a predicted 2 metre sea level rise that looks beyond the year 2150, to determine present-day property Coastal Inundation designations.
Also there is an inconsistency between the Auckland Council Flood Viewer maps that use a 1 metre sea level rise.
 
Map Transparency:
The PC 120 Flood Plain and Coastal Inundation maps do not explicitly state the climate change scenarios envisaged or the years in the future they reflect.
 
LIM Clarity:
Property LIMs must clearly distinguish between current risks and possible future risks for the next century.
GHMVRA believe there should be a policy reconsideration of the property rules that took effect on 3 November 2025, based on updated site-specific modelling.
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Current Status
Several submissions have been made to Auckland Council raising concerns about the Gulf Harbour floodplain mapping and requesting more detailed modelling.
The PC120 process is still underway, and Aucklanders will have further opportunities to participate before final decisions are made.
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Expected Timeline
 
The anticipated process is:
 
July 2026
  • Auckland Council's Policy, Planning and Development Committee will consider feedback from Local Boards and Mana Whenua (iwi).
  • The Committee will then decide whether changes should be proposed to PC120.
     
September 2026
  • Auckland Council is expected to publicly notify an updated version of PC120, including any proposed amendments.
  • A new public submission period will open.
  • All Auckland residents will be able to make submissions, regardless of whether they participated in the earlier consultation.
  • Existing submissions will remain valid and continue to be considered.
     
Mid-2027
  • An Independent Hearings Panel will hold hearings on submissions.
  • The Panel will make recommendations to Auckland Council.
  • Auckland Council will then make its final decisions on PC120.
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Further Information
PC120 MAP VIEWER
GHMVRA Presentation to Local MP and Board
GHMVRA Member Letter
Comprehensive list of affected properties
Mouse Instructions for PC120 Map Viewer
Touch Screen Instructions for PC120 Map Viewer
Climate Change Scenarios
Guidelines for Stormwater Runoff Modelling
Regionwide Rural Rapid Flood Modelling Report May 2023
Understanding Auckland's Regional Flood Maps
Resource Consent - Stormwater Management and Golf Course Irrigation Feb 1995
Letter from Minister Watts - use of climate change assumptions in council planning
Local Boards and Mana Whenua MOM
GHMVRA August 2026 Flyer

 
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