Submissions on the council’s 10-year budget and the 30-year Auckland Plan close tonight at 8pm. If you want to submit and haven’t yet, you need to get on to it now. Submitting is easy and you don’t need to submit on every question if you don’t want to. There is also the option of Generation Zero’s quick form.

With that in mind. Here’s what we’ve submitted.

10-Year Budget

What is your opinion on the proposal to introduce a regional fuel tax to help pay for improvements to the transport system?


The work done so far on the Auckland Transport Alignment Project shows a significant funding gap towards being able to deliver the significant improvements needed in transport across Auckland. Particularly for public transport and active modes.

We also believe that the council should consider keeping the interim transport levy to further help towards delivering an improve transport network. Auckland ratepayers have already become accustomed to paying this levy and the full political cost of implementing fuel taxes will be paid by Councillors regardless.

What is your opinion on this proposed targeted rate to speed up the delivery of cleaner harbours, beaches and streams?


Our harbours and beaches are critical to delivering quality of life for Aucklanders. As Auckland’s population continues to grow these areas will become even more important and so it is important we work to improve them as soon as possible.

What is your opinion on a proposed targeted rate to invest more to protect our environment?

Support Option B

Like with our harbours, our natural environment is critical to our quality of life

What is your opinion on this proposed rates increase?


Auckland Plan 2050

Question 3 – Affordable homes

Greater Auckland believes that the Auckland Plan 2050 lacks sufficient vision for building more homes and fixing Auckland’s housing shortage. The overall aim, “all Aucklanders deserve healthy, affordable homes with secure tenure in well-designed places, whether they own or rent their homes”, is positive, but it will not be achieved under the settings in the draft Plan.

Greater Auckland’s position on housing is more fully laid out at We strongly encourage the Council to read both the blog post and the comments that respond to it, as these represent engagement by Aucklanders with the Auckland Plan whether or not they have formally submitted.

Consistency with the Unitary Plan

As proposed, the draft Auckland Plan is a significant backdown on the Council’s housing aims.

The 2012 Auckland Plan laid out an explicit target of 400,000 more homes for Auckland over 30 years (2012-2041), with 60%-70% of them to be inside the old urban limits.

These overall targets, and the focus on intensification, fed into the Unitary Plan. We believe the strong housing focus from the 2012 Auckland Plan was critical for achieving the eventual form of the Unitary Plan – which allowed for significant new greenfields areas and, more importantly, substantial upzoning across much of the urban area.

Without the 2012 Auckland Plan, the Unitary Plan would have looked very different, and would have had much less upzoning. As a result, Auckland’s housing crisis would now be even worse. We are also cautious that future reviews of the Unitary Plan, infrastructure investments etc could be based off a weak draft Auckland Plan, and this could lead to underproviding for growth, a lack of future upzoning for intensification, or even downzoning relative to what is now allowed.

Recommendation: Retain an ambitious Auckland Plan so that the Unitary Plan can be equally ambitious, and so that Council adequately provides for growth.

Set Clear Housing Targets

The removal of housing (and other) targets from the Auckland Plan is a step backwards for accountability, and leads to a Plan which is often fluffy and vague. In most cases, it is not even clear what will be measured, let alone why there is any point in measuring it if there are no targets.

Recommendation: Auckland Council should set clear targets for what it wants to see happen in housing (and transport), insert those targets in the Auckland Plan, track progress against them, and update its strategy accordingly.

Acknowledging and Fixing the Housing Shortage

The 2012 Auckland Plan acknowledged a housing shortage which was starting to become evident at that time: “we already have a shortfall of about 10,000 homes, and current levels of house building are less than half the volume required”.

Auckland’s housing shortage has become much worse since 2012, with most commentators now estimating a shortfall of 40,000-50,000 homes. Despite this, the draft Auckland Plan is almost entirely silent on the shortage, and does little to set out targets for fixing it.

Recommendation: Acknowledge the housing shortage in the Auckland Plan, and set clear targets to reduce it over the next decade.

Set Ambitious Housing Targets

Auckland’s population is now projected to grow faster than it was in 2012, largely due to the migration boom.[1] In spite of this, the draft Auckland Plan shows much weaker growth in home building than the 2012 Auckland Plan.

We calculate that the 2012 Auckland Plan explicitly targeted 350,000 homes over 2018-2041. The draft Auckland Plan “anticipates” 263,000 homes in the same period, with no targets given. This figure is a reduction of 85,000, or 25%, from the previous explicit targets, with most of that reduction in the next decade – the same time when we should be trying to get on top of the housing shortage. This is not good enough for Aucklanders and more aspiration is needed.

We understand the NPS-UDC sets minimum levels of growth which councils must provide for, and that this level of growth is lower than what was adopted in the 2012 Auckland Plan. However, the NPS-UDC does not say that councils cannot provide for a higher level of growth. It does not give a reason for the Council to back down on its earlier ambition.

Furthermore, technical choices and projections extrapolate from our ‘current’ starting point – a starting point which most people see as already being 40,000-50,000 homes short. Because the projections extrapolate from the current situation, they imply that inroads will not be made into the housing shortage. This is a technical modelling issue and we would appreciate the chance to discuss this further with council staff.

We argue that projections are less useful at this time, especially household projections which rely on assumptions of ‘household size’. It is widely acknowledged that Auckland has a significant housing shortage and that many people aren’t living how they want, or even how they did in 2013 or 2006 censuses.

Recommendation: Target much higher rates of home building, especially in the next decade. Return to the targets in the original Auckland Plan, or include them alongside new (equally ambitious and ‘front-loaded’) targets.

Infrastructure and Intensification

The removal of home building targets, and the huge reduction in the number of homes the draft Plan “anticipates”, weakens the Council’s case for investing in infrastructure, or going to the government to ask for more infrastructure funding.

The 2012 Auckland Plan set clear housing targets, with targets both for how fast homes would be delivered (decades 1, 2, 3) and for the share of housing inside the old urban limits. The figures now provided in the draft Plan are much lower, much slower, and much less clear on the role of intensification. We calculate that the draft Plan implies just 195,000 homes inside the old urban limits where the 2012 Auckland Plan explicitly targeted up to 280,000, and did so over a shorter timeframe.

Removal of these targets is a threat to the ‘compact city’ approach, as expansions to the Rural Urban Boundary and the Council’s existing investment programme (SHAs, FULSS, structure plans etc) are likely to still facilitate most of the greenfields growth under the 2012 Auckland Plan, while the draft Plan backs down on the intensification-led growth.

Recommendation: Invest in infrastructure in the existing urban area to support at least 280,000 new homes as per the original Auckland Plan.

Question 4 – Moving easily around Auckland

Greater Auckland believes that the Auckland Plan 2050 lacks sufficient vision for how transport in the city will change over the life of the plan.

We feel that the general thrust and ideas behind the three directions and seven focus areas are correct, and the supporting text is generally positive. However, they are also somewhat vague and ambiguous, leaving outcomes open to interpretation by officials. This is likely to lead to council time and money wasted due to poor quality projects being unnecessarily progressed.

We believe the best way for the council to avoid this situation is by infusing the Auckland Plan 2050 with more explicit vision and goals for how transport should develop. This vision needs to be independent of the Auckland Transport Alignment Project as it should represent Auckland’s aspirations, not just what can be funded in the short term.

Having a more defined vision and set goals gives us something more concrete to aim for. It allows the council and public to assess options and ask ourselves if a proposal helps us towards that vision.

We have seen and heard some suggestions from council that targets should only be set where there is appropriate funding to achieve them. This is a fallacy. Whilst large projects and funding for them may dominate the discussion, a lot is able to be achieved towards those targets that doesn’t cost extra money. For example, how Auckland Transport set policy, or where elements in a street design are located.

Furthermore, some focus areas leave only limited courses of action available, yet council appear to be afraid to state what that means in real terms. For example, “Focus Area 1: Make better use of existing transport networks, including a greater focus on influencing travel demand” means we need fewer people driving and more using more spatially efficient modes of transport like PT and active modes. However, the plan shies away from saying this.

There are many examples from other international cities that the Auckland Council can reference for how this can be done. One of the better, recent examples is the Mayor of London’s Transport Strategy. In clear, easy to understand language it sets out what the vision is and why it’s needed. For example

Policy 1

The Mayor, through TfL and the boroughs, and working with stakeholders, will reduce Londoners’ dependency on cars in favour of active, efficient and sustainable modes of travel, with the central aim for 80 per cent of all trips in London to be made on foot, by cycle or using public transport by 2041.

Recomnendation: As mentioned earlier in the submission, the language used in the plan generally positive. There are also five measures (below). These measures seem appropriate and so an easy solution would be to add explicit targets to them. For example, what is the use of public transport and active modes we’re aiming for.

  • Measure 1: Access to jobs
  • Measure 2: Traffic congestion
  • Measure 3: Use of public transport, walking and cycling
  • Measure 4: Household transport costs
  • Measure 5: Deaths and injuries from transport network

Another measure that should be considered as part of transport include the level of emissions

More detail can be found at

Question 7 – Shaping our growth

Greater Auckland recognises the desire by the council to develop significant notes at Albany, Westgate and Manukau. However, we are concerned about trying to force growth to these areas which have less overall market desirability. This is in large part due to their location near the edges of our urban area which limits which limits potential employment catchments.

We note that Manukau has been expected to become a significant node for over 30 years and Albany for over 20 years. Both still require significant development if they are to truly succeed. It is unclear that there will be any significant change in this over the coming 30 years. Furthermore, given the similarities, we question how Westgate will end up with a significantly different result.

If these areas are to succeed, they will need a step change in the provision of transport, urban design and housing provision. For example, Westgate will urgently require a rapid transit connection along State Highway 16 and Albany will likely require a significant change to it’s street network that is more conducive to an urban typology.

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  1. Watch for the trick question on 10 yr plan Environment targeted rate. Option A and Option B are both less than enough. I recommend Option C – Other with call to fully fund the programme (about $60 instead of $47).

    1. Yes, this was flagged at a Have Your Say event too. I thought the figure required was $66 to fully fund the programme – in any case, that’s what I put.

  2. Do submissions actually have any meaningful effect on the outcome that is the 10 year budget and 30 year plan? I always get the feeling that dissenting views are simply ignored and the whole submissions exercise is a sham

    1. Mike, I sent your question to a lawyer “specialising in local government and environmental legal and consultancy services”. His reply was:

      “In my experience, well directed and thoughtful submissions do have an impact … and having those backed up with a number of shorter supporting submissions adds to that.

      While we are all tested at times, we are privileged to live in a democracy – and having our say is a way of participating and keeping that democracy alive.”

    2. Mike, I submitted on the Unitary Plan on behalf of a large commercial/industrial business association and we won two significant changes. Our strategy at that time was to work with the Independent Hearings Panel and Council Officers to determine as far as possible a consensus on what best worked for our local area whilst maintaining uniformity with the overall framework of the plan.

      I believe this approach was better received and therefore gave a better result than more adversarial NIMBY responses from other submitting groups. We also received detailed explanations from Council on their rationale on points where we didn’t agree which we were able to communicate back to our members and in turn gain broad (although not universal) acceptance of Councils position.

      I realise this is a different Plan and a different process but based on my personal experience GA are adopting the correct measured approach and by doing this can gain wins.

  3. I was frustrated to see that the plan is long on platitudes and short on detail.

    I hope that the cost reflected the output and that the author(s) are suitably ashamed of their work.

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