Submissions on the Auckland Spatial Plan close on October 31st. I cannot stress how important this plan is in guiding Auckland’s future – as I outlined in more detail here. Auckland Council has put together quite a pretty video outlining the broad goals of the plan:


My submission is outlined below. I’m happy for people to use parts of the submission or use the ideas for inspiration. Just make sure your voice is heard.

Email your submissions to: theaucklandplan@aucklandcouncil.govt.nz

1.     Summary of submission:

My submission primarily focuses on land-use and transport matters. Therefore it primarily relates to Section D: Auckland’s High Level Development Strategy, Chapter 8: Urban Auckland, Chapter 9: Auckland’s Housing and Chapter 11: Auckland’s Transport. The main points the submission makes are as follows:

1.1.    Urban Auckland:

  • Without further detail on its suitability, Warkworth should not be included as a priority satellite centre due to its poor transport infrastructure (currently it has no public transport service at all) and its fragile surrounding environment.
  • The inclusion of Westgate and Sylvia Park as metropolitan centres is questioned. Both these centres have one dominant landowner and are developed (or will be developed) largely in the form of traditional shopping malls. This is not a metropolitan centre in the same way that Newmarket, New Lynn and Takapuna are.
  • A number of development corridors should be given higher priority, potentially instead of some of the broader development areas located near the urban periphery. These include:
    • Development along the Northern Busway (particularly around Akoranga and Smales Farm stations)
    • Development along the inner part of the Western Railway Line, especially once the City Rail Link project has been completed.
    • Development along the inner part of the Southern Railway Line, between Newmarket and Penrose, an existing major employment corridor.
    • Development along the inner parts of Great North Road and New North Road.

1.2.    Housing:

  • Greater clarification is needed to show how the goals will be implemented, particularly with regards to improving housing affordability.
  • An urban development agency, with the authority to acquire land to amalgamate sites, is necessary to ensure that intensification actually happens.
  • Development bonuses and/or relief from development/financial contributions should be provided to incentivise the provision of affordable housing.
  • Direction should be given to the Unitary Plan to ensure planning rules do not undermine the provision of affordable housing:
    • Focus on quality urban outcomes rather than fixed “minimum lot size” rules.
    • Allow provision of ‘granny flats’ in most parts of the urban environment.
    • Allow existing houses to be ‘split’ into units without the need for expensive consents.
    • Do not require excessive amounts of parking, which add to the cost of housing.
    • Ensure that land within areas proposed for intensification is not compromised through lower-density development (ie. have minimum development levels).

1.3.    Transport:

  • Principles for deciding which transport projects should be prioritised needs to be spelled out more clearly.
  • Puhoi-Wellsford road is not supported as a priority, because there are cheaper and more cost-effective alternatives.
  • Connections between transport decisions and other outcomes sought from the Auckland Plan need to be clarified. For example, the transport chapter proposes a large number of additional roading projects that may undermine attempts to reduce levels of CO2 emissions.
  • An additional Rapid Transit Line (probably in the form of a busway) should be placed along State Highway 16 to provide the northwest corner of Auckland with a Rapid Transit option and to support the development of Westgate.
  • Cheaper options to another road-based harbour crossing should be explored, such as building the rail tunnel first.

1.4.    Areas of support

Although my submission makes a number of suggested amendments to the Draft Auckland Plan, I generally support many of the key decisions that have been made in the formulation of the plan. In particular I support:

  • The high priority given to improving public transport
  • Creating a rural-urban boundary to ensure the provision of infrastructure to urban areas can be done efficiently and our natural environment protected
  • Strong initiatives to improve housing affordability and social equity

2.     Land-Use Planning (section D & chapter 8 )

This part of my submission relates to the land-use planning matters throughout the Auckland Plan, mainly issues relating to where and how Auckland should grow over the next 30 years. Fundamentally I support the High Level Development Strategy outlined in Section D of the Draft Plan – subject to a number of amendments to its details. In general, it is my opinion that making the amendments proposed will result in a plan that is more consistent and is more likely to achieve its broader goals (rather than disputing those broader goals).

2.1.    Quality Compact City Approach

I support Auckland’s future development being based around the concept of a “Quality Compact City”. The Future Land Use and Transport Planning Project undertaken by the former Auckland Regional Council in 2010 assessed three different development options for Auckland. It made the following key observation about the cost of servicing different development patterns with infrastructure:

The compact scenarios utilise current infrastructure more efficiently, thus reducing the need for additional infrastructure investment. Transport infrastructure costs are greatest, with the expansive scenario requiring the greatest additional investment in the transport network. The expansive scenario would require additional road infrastructure worth approximately $31.4 billion compared with around $15 billion for the compact scenarios. Yet despite the additional investment in transport infrastructure, the expansive scenario provided the worst accessibility compared with the compact scenarios.

Furthermore, a focus on a compact city approach helps protect Auckland’s rural environment and helps reduce Auckland’s ecological footprint through reducing car dependency and creating more energy efficient environments.

The Quality Compact City Approach will, however, constrain the amount of developable land and therefore will inevitably push up land prices. This has the potential to conflict with the Auckland Plan’s desire to improve housing affordability unless significant steps are taken to ensure housing supply can be significantly boosted (in a way that has been unable to happen over the past ten years) through urban intensification.

So while I do support the Quality Compact City Approach, it is utterly essential that an adequate supply of housing is provided if there is to be any hope of improving Auckland’s housing affordability. The previous Auckland Regional Growth Strategy was inadequate in achieving this outcome as its implementation was very poor.

2.2.    The Location of Development Areas

Maps D1 and D2 highlight development areas where intensification is suggested will occur. The maps also show the location of areas where greenfield development will be investigated.

As an overarching comment, I am concerned that the location of many of the development areas does not match up with where demand currently exists, or is likely to exist in the future, for intensification. As per above, it is essential that intensification actually happens in Auckland if housing affordability is to be improved, therefore it is necessary for a greater level of alignment between where the Auckland Plan envisages intensification and where there is a market demand for intensification. Simply put, if there is no market for intensification in an area, then it will not happen, housing supply will not be increased and house prices will continue to go up (and thereby the pressure for urban sprawl will increase).

Generally, demand for intensification will exist in places where land values are highest – because to capitalise on those land values it becomes viable to invest in getting more units on each site. The map below shows land values across Auckland: This map indicates the places where intensification is most likely to be economically feasible. These are the city centre and its immediate surrounding suburbs, the central isthmus and coastal areas to the north and east of the city centre.

Suitability for intensification also relates to other issues, such as heritage constraints and the location of transport (and other) infrastructure. Combining these matters leads to the following locations being obvious priority areas for intensification:

  • The City Centre, with care taken with regards to effects on heritage.
  • Takapuna (already proposed as a metropolitan centre)
  • The City fringe area, particularly in areas with less heritage constraints such as along Great North Road, New North Road, around Newmarket and the inner parts of Dominion and Mt Eden Roads.
  • Onehunga (proposed as a town centre)

The map above clearly highlights that proximity to the city centre is a key factor in determining land values. This means that intensification is most likely to be attractive to the market the closer to the city centre the particular site is.

Significant infrastructure projects outlined in the Draft Auckland Plan are likely to change the map above once completed. For example the City Rail Link will bring sections of western isthmus within a much shorter train trip of the city centre, likely resulting in a boost to land values and thereby an increase in the market viability of intensification.

While ‘corridors’ are proposed in Map D2, along a number of arterial roads in the inner isthmus, these development corridors are generally planned to be developed later on in the life of the Auckland Plan. If these corridors are market-attractive, then it may make sense for development along them to be prioritised to a greater extent, especially ahead of development in the outer parts of Auckland’s urban area.

Overall, I propose a number of amendments to Maps D1 and D2 in relation to the proposed “Development Areas”:

  • There should be a greater focus on areas that are market-attractive, lacking in heritage constraints and are well served by existing infrastructure (especially public transport infrastructure). Less development, or development that happens at a later stage, in more peripheral areas that have relatively poor transport infrastructure. This would result in the following changes:
  • More (and sooner) development proposed in the following areas:
    • Great North Road between Karangahape Road and Grey Lynn shops
    • New North Road between Eden Terrace and Kingsland
    • Great South Road between Newmarket and Penrose
    • The Western Line rail corridor between Avondale and Mt Eden stations (both in advance of the City Rail Link and more particularly once it has been constructed)
    • Around stations on the Northern Busway, particularly Akoranga and Smales Farm station, which are closest to the city centre
  • Development directed away from (and/or delayed) the following areas:
    • Warkworth as a satellite centre (because of its heritage constraints, its poor transport infrastructure and its peripheral location)
    • Area 5, Kaipatiki – until congestion issues relating to Onewa Road have been resolved (if this is possible).
    • Area 8, Whau – until a Northwest Busway along State Highway 16 has been constructed providing improved public transport access to the northern part of this area. New Lynn should still be prioritised as a metropolitan centre because of the significant investment which has occurred in its infrastructure.
    • Area 11, Central South – until other investments have boosted land values to the point where redevelopment is market-attractive. Until such a time it seems unlikely that intensification will occur here, unless led by Housing New Zealand Corporation.
    • Area 13, South – for the same reasons as area 11 above

More detail is necessary to clarify the size of the proposed satellite centres – whether they are envisaged to grow by 50%, 100% or more throughout the period of the Auckland Plan.

2.3.    Areas for Greenfield Investigation

I support the relatively limited extent of the areas for greenfield investigation. As noted above, to ensure Auckland’s rural environment is protected and to ensure efficiencies with infrastructure provision, it is necessary for most development to occur within the existing urban limits.

I do have some concerns about whether 25% of Auckland’s growth can be accommodated within the relatively small areas identified, further detail on this matter is probably necessary to ensure that there is some certainty the areas for Greenfield investigation will not get much bigger. Further detail is required about the extent of greenfield development envisaged to occur in each of the satellite centres.

If greenfield development is to occur, then I think Map D2 indicates the most appropriate places for this development to occur.

3.     Housing (chapter 9)

This part of my submission focuses on chapter 9 of the proposed plan, although there are clearly links with chapter 8, as land-use planning regulations will need to be amended in order to achieve the goals of chapter 9.

As noted above, I support the ‘big picture’ goals of the Auckland Plan in relation to housing. Housing has become increasingly unaffordable for Aucklanders over the past decade in particular, leading to the potential for enormous inter-generational inequity, with many people who did not own a house by 2000 potentially never being able to do so, because prices have increased so much more than average income.

A key part of making housing more affordable is to increase its supply. Therefore I support the target to increase dwelling construction to 10,000 a year by 2013.

I do think that “Priority 1: increase housing supply to meet demand” needs to be more directive about how this will be achieved. In particular, it should give direction to the future Unitary Plan to have planning rules that promote housing affordability and the easier construction of residential intensification. For example, the Unitary Plan could be required to consider the following matters:

  • Focus on quality urban outcomes rather than fixed “minimum lot size” rules.
  • Allow provision of ‘granny flats’ in most parts of the urban environment.
  • Allow existing houses to be ‘split’ into units without the need for expensive consents.
  • Do not require excessive amounts of parking, which add to the cost of housing.
  • Ensure that land within areas proposed for intensification is not compromised through lower-density development (ie. have minimum development levels).

While I support “Priority 4 – improve housing affordability”, once again I think it needs to be more directive to future planning documents about how this will be achieved. Many cities overseas provide developers with bonus floor area, in return for the provision of affordable housing units. A bonus system, or other similar planning regulations, should be analysed to encourage a much more detailed and focused approach to matching up land-use regulations with housing affordability.

4.     Transport

I support the Auckland Plan’s strong focus on improving Auckland’s public transport system. As the opening night of the Rugby World Cup most clearly illustrated, it is the poor quality of the city’s public transport which holds Auckland back from becoming a truly world class city.

4.1.    The need to prioritise:

As an overall comment, I think that the Auckland Plan risks not being able to achieve its transport goals by not making difficult decisions about which projects should proceed and which projects should not. While the wording of the Plan wishes to create a significant shift away from Auckland’s car dependency, a number of exceedingly expensive (and disruptive) roading projects are proposed (beyond those already approved):

ProjectCost
Puhoi-Wellsford$1.4 billion
Neilson Street east-west link$1.25 billion
State Highway pinch-points$1.2 billion
Airport road access improvements$730 million
Additional Waitemata Crossing$5.3 billion (up to)
Port-Grafton Gully connection$1 billion
Total$10.88 billion

This level of expenditure on roading projects will not only have the opportunity cost of reduced funding available for other transport projects, but is also likely to undermine many of the Auckland Plan’s transport goals: especially goals of increasing non-car peak trips and increasing public transport modeshare.

Many of the projects listed above have the potential to generate significant adverse environmental effects. This has the potential to undermine many of the principles outlined in Box 11.1 – especially those that seek to create a balance between movement and place.

4.2.    Which projects to prioritise:

It is clear that the Auckland Plan needs to make some tough decisions about which transport projects it wishes to prioritise, particularly if it becomes difficult to find additional funding sources. To ensure that the prioritisation process is done effectively, there should be a number of clear principles included in the Auckland Plan (which link back to the goals the plan is trying to achieve) that help this process.

The transport targets in the Auckland Plan (page 159) are supported, but need further elaboration in the surrounding text of the Plan to make it clearer that projects will be prioritised according to their contribution to these goals. It is noted that the targets generally fit into three categories:

  • Improving alternatives to private vehicle travel
    • Target 1:  increasing non-car trips in peak period to 37% by 2040
    • Target 2: increasing PT modeshare to the city centre to 69% by 2040
    • Target 5: have 80% of growth centres on the RTN or QTN network by 2040
  • Reducing congestion for freight traffic
    • Target 4: 20% reduction in peak time congestion for freight by 2040
  • Improve road safety:
    • Target 3: no more than 40 deaths and 288 serious injuries in 2040

These goals give very strong direction that the Auckland Plan’s project prioritisation should be based around placing far more emphasis on public transport improvements than has happened in the past. It is notable that there are no targets relating to general traffic, which means the Plan wishes to focus on other matters to a greater extent.

Given the focus of the Auckland Plan’s transport targets, it is surprising to see so many roading projects proposed – up to $11 billion of projects as outlined in the table earlier in this submission. There are also some key public transport projects which have been missed out from the Plan. Specific comments on projects are outlined below:

Projects that should be given a lower priority:

  • The Puhoi-Wellsford road should not be a priority for the Auckland Plan because it does not contribute to achieving the Plan’s transport targets and may well undermine its land-use aspirations by encouraging more urban sprawl. Many of the problems faced along this route could be resolved through safety upgrades and a Warkworth bypass – measures that should be prioritised.
  • The Neilson Street east-west link should be assessed with greater rigour before becoming a priority project. While a roading upgrade along this route would help achieve Target 4 (as it is a very busy freight route) there may be much less expensive ways to reduce congestion for freight than a fully-blown motorway. Any motorway to motorway connection with State Highway 20 is likely to be unconsentable, as previous proposals to upgrade the Neilson interchange with SH20 were declined consent.
  • Many of the State Highway pinch-point projects should also be assessed with greater rigour to determine their cost-effectiveness and contribution to the Auckland Plan targets before being included as high priority projects. Motorway widening tends to only induce further traffic, rather than ease congestion (most of Auckland’s widest motorways are also its most congested), while other projects such as a SH18-SH1 connection seem unnecessary except to “look nicer” on a map. The Auckland Plan should split out each project included in this bundle to ensure they are cost-effective and contribute positively to the plan’s targets – as some will and some won’t.
  • While Airport Road Access improvements are necessary to support growing visitor numbers and a growing employment node at the airport, they should be undertaken in a way that’s integrated with public transport improvements in the area. For example, the grade separation of SH20A from Kirkbride Road should make provision for a future Airport Railway Line.
  • An additional Waitemata Harbour Crossing is completely unnecessary in the timeframe of the Auckland Plan, as traffic across the Harbour Bridge has been falling over the past five years. The current proposed crossing adds traffic capacity between Akoranga and the city centre, but nowhere else on the motorway network – this will only encourage more cars into the city centre (completely undermining the City Centre Master Plan and Target 2 of the Auckland Plan). A rail only crossing option should be looked at as a cheaper alternative.
  • The Port-Grafton Gully project is likely to help benefit freight, but once again its significant cost should be analysed properly before the project is included as a priority. At-grade upgrades to The Strand and Stanley Street may be able to provide most of the benefits of a fully grade-separated solution, at a fraction of the price.

Projects that should be considered for inclusion:

  • A Northwest Busway along State Highway 16 should be included in the Auckland Plan to help support Westgate as a priority Metropolitan Centre. Without this project, Westgate risks becoming extremely auto-dependent in the future, undermining the goals of the Auckland Plan.
  • Further detail on the implementation of high quality bus corridors (or light-rail where appropriate) throughout Auckland, giving effect to the Quality Transport Network.

All the roading projects highlighted above may also undermine targets in the Auckland Plan relating to other matters, such as reducing CO2 emissions and limiting urban sprawl. A key purpose of the Auckland Plan is to ensure better integration across Council activities, but the current proposed list of transport projects is inconsistent with this goal – by undermining both the targets in the transport chapter and other targets throughout the Auckland Plan.

4.3.    Transport Principles:

There have been some changes to the transport principles from the Auckland Unleashed discussion document to what is outlined in Box 11.1. One key principle outlined in Auckland Unleashed that has not been carried forward into the Draft Auckland Plan is the need to be adaptable. This oversight is considered unfortunate, as we should build transport systems which are resilient and robust to change over time: whether that change be sudden shocks, new technologies or long-term shifts.

Increasing oil scarcity and the need to dramatically reduce CO2 emissions are two examples of global issues which require the decision-making process about which transport projects to prioritise to keep the need for adaptability in mind.

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9 comments

  1. Your dedication to improving Auckland never fails to impress me. Cannot help but feel that public participation such as this (and your blog in general) is the grease the keeps our liberal democratic machine chugging along.

    Some comments:
    1. Warkworth – I disagree with your position, even if I acknowledge the difficulty in serving it with public transport. I cannot help but feel that Rodney’s beautiful beach-side settlements (Matakana, Snells Beach, Tawharanui Peninsula, Goat Island will continue to grow, irrespective of whether public transport is available. This growth really needs a service centre – such a role would ideally filled by Warkworth. Just note that in the absence of Warkworth, people from these areas will have to travel further to access the goods/services they require. So it’s really a choice between long vehicle trips or short vehicle trips, rather than vehicle trips versus public transport.

    2. Replace “do not require excessive amounts of parking” with “do not require parking.”

    3. You need to provide a reference for the map of land values ;).

    4. Everything else looks fine.

    1. On Warkworth, I agree that some level of growth is probably desirable – we shall wait and see what level of growth being a “satellite centre” really means. I worry that Warkworth’s designation as a priority satellite centre will be used as justification for the holiday highway.

    2. Hi Stu – Where did you get the data from? Some of the values seem low IMHO i.e. the 0-97 category means less than $100,000 for a quarter acre section in much of outer suburban Auckland.

      Cheers, Chris H

  2. With regard to the timing of upzoning,why dont they just do it all everywhere at the start. The political uncertainty associated with “potential” upzoning will keep house prices higher than would otherwise be the case. After all they are planning on having the RUB locked in from the start, so the upzoning should be locked in very early as well.

    I agree with what you are saying though that they cant expect intensification in areas where there is no demand. I would note however that the map is a bit coarse. The land value pattern is also likely a result of the “flatness” of the land as well as the market conditions. E.g. in Birkenhead lots of people have large bush clad backyards which arent worth much because they would be so difficult to develop as they are steep gullies. But there is evidently plenty of demand for intensification around Highbury etc.

  3. Excellent! Thanks for doing this.

    Some comments re Section D and its relationship with the sections of the Plan it’s intended to guide.

    The Development Strategy is intended to describe how the strategic direction and objectives in the Plan will be achieved. This will be guided, according to section D, by specific policies throughout the Plan. Contrary to what is stated, there are no policies in the Plan. E.g. last sentence in pt. 166_, “The Plan contains policies (see Chapter 8, 10 and 12) to ensure such lands are released for growth and development through a staged approach)”. However, in Chpts 8,10, and 12 they are not there, as there are none in the whole Plan. Priorities are not policies. This is important b/c the policies agreed to by Council will play a critical role how Council implements regional place based development and projects.

  4. Nice work, easy to read and logical….it will be fascinating to see how the Council deals with upzoning…potentially it could reduce land values, which most politicians would run a mile from….

  5. The proposed flyover from the port to Grafton is the most alarming of the roading projects. Is it really necessary to expand port container handling capacity and get rate and tax payers to pay $1bn for the elimination of 4 sets of traffic lights?

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