This is a guest post by Stephen Davis. It was first published on City Beautiful on 30 September 2019.

Introduction

In my previous piece I talked about the proposal by the Ministry for the Environment (MfE) to direct local councils to allow for more intensification, through a device called a National Policy Statement. I said “If you want a New Zealand that grows up about growing up its cities, and responsibly provides for growth” that you should send in a submission on their proposal.

So this is a guide to making a submission, if you feel you want some help, and especially if you haven’t made a submission like this before. The discussion document is aimed more at planning professionals, local government officials, and other people with experience in the area. It’s not aimed at a general audience as much as some government consultations are.

But don’t be daunted. In this guide, I’m assuming you’re an interested and curious layperson, not a planning or development professional. If you’re a professional you don’t need my help.

In theory, a consultation like this is only looking for feedback and new ideas, but in reality it’s still very much a political process. Anything you say in support of sustainable density done well will help provide political support for these changes, even if you don’t think you’ve got the details exactly perfect.

What’s being proposed

The details of what’s being proposed are in the discussion document, and there’s a shorter summary version. The government’s press release sums up what the Government hopes to achieve. And some of the work relies on a research report from BECA.

There’s a couple of hundred pages of dry reading across all of that, so here’s the basics:

The Urban Growth Agenda

The proposal is part of a larger suite of policies the government is calling the Urban Growth Agenda. The Minister for the Environment sees that there are

a startling array of indicators in housing and urban development tells us we have a problem: severe housing unaffordability, falling home ownership, increased hardship and homelessness, increased household debt, intergenerational inequality, congestion, poor transport choice and urban pollution.

And concludes

It is clear our urban land and housing markets need to work better and be more competitive. We need to significantly increase the number and type of development opportunities in the market, and ensure future growth benefits our towns and cities.

The Government’s Urban Growth Agenda (UGA) is designed to deliver these changes. It takes a new approach to planning, based on the idea of making room for growth. The aim is to reduce car dependency, fix our broken system for funding and financing infrastructure, and see central government work more closely with local government, the private sector and communities.

This consultation is about one very specific but important part of that: a series of directions that central government will give to local councils about how to plan for growth under the RMA.

A very brief guide to the RMA

The consultation document assumes you know how planning is structured under the RMA, which put very simply (maybe too simply) is as follows. Everything in bold is a term with a technical definition in the RMA.

The goal of the RMA is sustainable management of the environment, and the environment is considered as a very broad term. The things that should be considered important are in Part 2 of the RMA, but central government and councils can also add other things they care about.

In order to do this sustainable management, central government draws up policy statements, environmental standards, and planning standards, and regional and district councils draw up a variety of plans in response. For urban development, the most important ones are the regional policy statement by the regional council and the district plan by the city or district council. Both of those include objectives and policies, and the district plan also includes rules.

The rules determine whether or not something is permitted: if it isn’t, it requires resource consent. If you do need resource consent, the rules, objectives, and policies are all used to decide whether resource consent should be granted, and what conditions should be imposed. The resource consent process will look at what effects the proposal has on the environment (broadly considered) and whether they are acceptable. For all but the largest property developers, they will be also looking to make sure that the resource consent isn’t notified, which means giving neighbours or the general public the chance to object and appeal. A notified resource consent could cost tens or even hundreds of thousands of dollars, and will add several extra months or potentially even years of extra delay – not to mention the good chance the consent will simply be declined. A consent that isn’t notified isn’t a secret – it just means that there’s no formal avenue for the general public to have a say.

The National Policy Statement on Urban Development

A National Policy Statement (“NPS”) is a device under the RMA by which central government gives instructions to local government about how to draw up their plans, and how to assess resource consent applications. An NPS can require councils to take certain things into account in drawing up plans. It can require plans to include objectives and policies, which in turn must be taken into account when deciding whether to grant resource consents. An NPS can forbid particular rules in a plan. It can require councils monitor and report on indicators (for example, a measurement of housing affordability).

The NPS in this case will be the National Policy Statement on Urban Development. There’s a lot of questions about how it will all look. I’ll go through them individually below.

The NPS also replaces an earlier NPS, the National Policy Statement on Urban Development Capacity. That didn’t include many directive parts for councils, but it did require some of the monitoring requirements. So for many councils they should already have or be collecting the evidence base they need to plan for growth.

But there are four main planks of this new NPS:

1. Future Development Strategy

Requires councils to come up with long term plans for where growth will happen, by both intensification and outward expansion, and identifying what infrastructure will be needed.

2. Making room for growth

Requires councils to allow growth both ‘up’ (intensification) and ‘out’ (sprawl), to a level sufficient to provide for future population growth. It will provide a definition of a “quality urban environment”, which will be what councils are trying to achieve. It will insist that councils allow for change in residential areas, and recognise the benefits of denser development as well, not just the drawbacks. The details could be left to councils, or there could be a certain minimum baseline of development allowed.

3. Evidence for good decision-making

Requires councils to monitor and report on supply and demand and prices for housing, to inform their planning decisions.

4. Processes for engaging on planning

This mostly means councils engaging with each other and with central government, rather than with the public. But there are also questions about engaging with Māori, both as mana whenua and otherwise.

Organising your submission

There are two ways to make a submission. You can use the online submission tool, which is what MfE would prefer you to do, and which may mean your submission is read more carefully. Or you can write your own document and email it to [email protected] If you write your own document, I would still recommend sticking to the format of the questions in the discussion document.

Your submission will be read through, once, quickly. But it will also be cut up into snippets, probably question by question, and this is going to be the main way it will be read: piece-by-piece, without much context. I would avoid anything that makes it hard for someone to leap in to your submission halfway through:

  • don’t put in lengthy introductions, summaries or appendices.
  • don’t refer back to other parts of your submission, even if means repeating yourself a bit.
  • don’t try to define big, novel concepts you think that the reader hasn’t heard of.
  • do use references and links to background information and evidence, if it’s from a reputable source (e.g. government, professional organisations, academia).
  • do use the terminology in the discussion document, even if it’s different to the terms you normally use.
  • do use examples from your personal experience, if you’ve got something relevant.

Answering the questions

The discussion document is not asking for all of your opinions about urban planning. MfE wants feedback on how to design a fairly specific set of regulations, some of which they have already suggested particular wording for in the discussion document, and others where there are some options they’re picking between. I would generally aim to stick to the questions asked.

However, some of the questions are fairly open ended. Feel free to suggest other regulatory tools (e.g. amendments to the Resource Management Act) that might help achieve the goals of Making Room for Growth.

Be sure to say whether or not you support each part of the proposal. If you use the online tool, you’ll be prompted for this. If you’re writing your own submission, ideally include this as the first sentence of your answer and using words like “I support” or “I do not support”. When there are options, for example in question 10, be clear which option you support. MfE is going to write a summary of the submissions, and for each question they are likely to say something like “most submitters support doing X” or “there was mixed support for X” or “most submitters opposed doing X”. This will be based on looking to see which box you checked, in the online tool, or whether you clearly say that you support (or oppose) each provision in your free-written submission.

But remember: you don’t have to talk about everything. Skip questions entirely, if you don’t think you’ve got anything to say on the topic. If you genuinely have no view either way, don’t feel like you have to make a decision on supporting or opposing something, or picking one option over another. It won’t detract from the rest of your submission, and could help it.

Question guide

I’m going to go through the questions individually: I’m going to suggest things to talk about, and why they’re important.

Using your own words will be most effective. If you’re going to copy and paste anyway, you could repeat quotes from the discussion document you agree with – there’s good material in the executive summary and the minister’s foreword.

1. Do you support a National Policy Statement on Urban Development that aims to deliver quality urban environments and make room for growth? Why/Why not?

  • Are there other tools under the RMA, other legislation or non-statutory tools that would be more effective in achieving a quality urban environment and making room for growth?

Strongly support. This is also the best place if you do want to say in general how important affordable housing and sustainable cities and transport are to you.

There’s lots of reasons why we need to deliver more housing, better located, and better designed – talk about any of them. Talk about yourself or people you know who’ve struggled with rents. Talk about any stories you’ve got where local councils have been unreasonable in preventing good quality developments. Talk about good examples of housing from overseas (or in NZ).

2. Do you support the approach of targeting the most directive policies to our largest and fastest growing urban environments? Why/why not?

  • Do you support the approach used to determine which local authorities are categorised as major urban centres? Why/why not?
  • Can you suggest any alternative approaches for targeting the policies in the NPS-UD?

Oppose. The NPS divides policies into those that apply to “all urban environments”, and those that only apply to “major urban centres”. For some of the requirements of the NPS like Future Development Strategies and monitoring, it’s a big expense for small councils and they should be exempt. But for the directive elements of the NPS, they are just as valuable in smaller cities as they are in big cities. Often small cities face the same problems, just on a smaller scale. All of the prescriptive parts of the NPS like the objectives and policies should all apply to all councils. Likewise, where rules are disallowed, they should be disallowed in all cities.

For a comparison, the previous NPS on Urban Development Capacity also included the councils that cover the urban areas of Whangarei, Rotorua, Gisborne, Napier-Hastings, New Plymouth, Palmerston North, Nelson-Tasman, Marlborough, and Dunedin, and at the very least these should remain included.

3. Do you support the proposed changes to future development strategies (FDSs) overall? If not, what would you suggest doing differently?

  • Do you support the approach of only requiring major urban centres to undertake an FDS? Would there be benefits of requiring other local authorities to undertake a strategic planning process?
  • What impact will the proposed timing of the FDS have on statutory and other planning processes? In what way could the timing be improved?

Support, although as above, the list of major centres that need a FDS should be expanded. The Future Development Strategy is key to making sure that whatever outward growth happens is well planned, but it’s important in figuring what investments and actions will be required to support residential intensification.

4. Do you support the proposed approach of the NPS-UD providing national level direction about the features of a quality urban environment? Why/why not?

  • Do you support the features of a quality urban environment stated in draft objective O2? Why/why not?
  • What impacts do you think the draft objectives O2–O3 and policies P2A–P2B will have on your decision-making?

Support, although this shouldn’t mean allowing or encouraging councils to go overboard adding expensive requirements for new housing that occupants might not want, or at least might not think are worth the cost – e.g. requirements for balconies, ground-level open space, or minimum unit sizes.

5. Do you support the inclusion of proposals to clarify that amenity values are diverse and change over time? Why/why not?

  • Do you think these proposals will help to address the use of amenity to protect the status quo?
  • Can you identify any negative consequences that might result from the proposed objective and policies on amenity?
  • Can you suggest alternative ways to address urban amenity through a national policy statement?

Strongly support. The use of amenity values in district plans at the moment is aimed at preserving the status quo, and supporting a very particular vision of how people should live.

Key points are:

  • amenity values are different for different people. One major example: some people really put a premium on having large outdoor spaces with a lot of sun, but other people have interests that mean they get outside away from home, and still other people have interests that happen inside.
  • amenity values do not necessarily come from your own home. You can get amenity from living in a suburb with good access to public parks, services, and a wide range of businesses.
  • amenity values change over time. There are a lot of hobbies like recreational car ownership and tending ornamental lawns that are less popular in 2019 than they were in 1979.
  • amenity values change as a suburb becomes denser. The things that are valuable in a suburb mostly made up of terraced housing and apartments is very different to what is valuable in a suburb mostly made up of detached houses on larger sections.

6. Do you support the addition of direction to provide development capacity that is both feasible and likely to be taken up? Will this result in development opportunities that more accurately reflect demand? Why/why not?

Strongly support. This is a pretty non-controversial change for the better – it just requires councils to be slightly more rigorous and thorough in their modelling work.

One important part of the proposal is that, predictions of demand should not be seen as a target for development capacity, they should be seen as a “bottom line”. It’s beneficial to have a lot of excess development capacity, particularly for intensification where there’s no real cost to having capacity that isn’t used.

7. Do you support proposals requiring objectives, policies, rules, and assessment criteria to enable the development anticipated by the zone description? Why/why not?

  • Do you think requiring zone descriptions in district plans will be useful in planning documents for articulating what outcomes communities can expect for their urban environment? Why/why not?
  • Do you think that amenity values should be articulated in this zone description? Why/why not?

Support. Current planning standards will require every city to use a standard “palette” of zones, with standard zone descriptions, but leave it up to those councils to determine the contents of the policies, objectives and rules of those zones. For example, there’s a “medium density residential zone”, which has the description:

Areas used predominantly for residential activities with moderate concentration and bulk of buildings, such as detached, semi-detached and terraced housing, low-rise apartments, and other compatible activities.

This proposal requires the contents to fit the description, but I think councils in practice would do that anyway, and would actually use different zones if they wanted to achieve different objectives. For example, if councils want to stop terraced housing, they’ll just do the obvious thing and make an area a “low density residential” zone, rather than try to have a zone that doesn’t do what it says on the tin.

On the other hand, if councils really do want to subvert the intent of each of the standard zones, they have more than enough latitude to do that, unless there’s firm direction about what each zone needs to include – for which see question 11.

8. Do you support policies to enable intensification in the locations where its benefits can best be achieved? Why/why not?

  • What impact will these policies have on achieving higher densities in urban environments?
  • What option/s do you prefer for prescribing locations for intensification in major urban centres? Why?
  • If a prescriptive requirement is used, how should the density requirements be stated? (For example, 80 dwellings per hectare or a minimum floor area per hectare).
  • What impact will directly inserting the policy to support intensification in particular locations through consenting decisions have?

Strongly support. This is probably the most important part of the NPS for the main cities, particularly Auckland and Wellington.

I would generally support a target being expressed in terms of people per hectare, as the best option. Failing that, floor area per hectare would be better, and dwellings per hectare would be the least desirable.

The problem with measuring density in terms of dwellings is that it makes assumptions about how people live that aren’t really true these days. There’s a lot more people living in one-person or two-person households, a lot more people flatting even past their early 20s, and at the other end a lot more larger and multi-generational households. But measuring dwellings treats all these as the same.

You also get two options for how this should be done:

  • The descriptive approach, which tells councils that they need to provide more capacity for intensification, but leaves the details up to council.
  • The prescriptive approach, which makes detailed requirements that councils must meet.

The prescriptive approach is clearly better. The thing to bear in mind is that cities have tended to agree with the theory of allowing intensification in inner suburbs, or outer suburbs well connected by public transport. But in practice, they’ve watered down the proposals to nothing through character and heritage restrictions, parking requirements, and onerous amenity standards. So adding the descriptive requirement wouldn’t change that, while the prescriptive approach will cut through a lot of those rules.

The prescriptive approach also needs to be tighly drawn with few exemptions, if it’s going to work. Councils will be under huge pressure to find or invent reasons to exempt particular areas from the prescriptive rules, and there’s a risk that these exemptions end up being widespread enough to render the theoretical higher zoning ineffective in most places, just as in the past.

I would support the NPS giving an exhaustive list of which factors are allowed to be considered exemptions. I suggest the only exemptions permissible are:

  • Protecting genuine historic heritage, and taonga (such as wāhi tapu) of significance to Māori.
  • Protecting the coastal environment, wetlands, lakes, rivers, and significant areas of old-growth native vegetation, including protecting public access.
  • Avoiding areas with significant natural hazards, such as flooding, coastal inundation, and liquefaction.
  • Land subject to designations (e.g. protection for future infrastructure corridors), or reverse-sensitivity buffer areas for air pollution (such as near motorways and heavy industry).

In particular, it’s important that “character” not be a reason to avoid implementing the rules – until now this has been the single biggest barrier to well-located intensification in inner suburbs.

The burden of proof would also be put on council when making District Plans to prove, to the satisfaction of independent commissioners and the Environment Court, that the exemptions didn’t have a negative net impact on urban quality or development capacity.

9. Do you support inclusion of a policy providing for plan changes for out-of-sequence greenfield development and/or greenfield development in locations not currently identified for development?

  • How could the example policy better enable quality urban development in greenfield areas?
  • Are the criteria in the example policy sufficiently robust to manage environmental effects ensure a quality urban environment, while providing for this type of development?
  • To what extent should developers be required to meet the costs of development, including the costs of infrastructure and wider impacts on network infrastructure, and environmental and social costs (recognising that these are likely to be passed onto future homeowners and beneficiaries of the development)? What impact will this have on the uptake of development opportunities?
  • What improvements could be made to this policy to make development more responsive to demand in suitable locations beyond areas already identified for urban development?

Strongly oppose. This undercuts the Future Development Strategies. Councils are already directed to expand outwards under the Future Development Strategy, they should at least be able to use that Future Development strategy to plan how to do that outward expansion well.

10. Do you support limiting the ability for local authorities in major urban centres to regulate the number of car parks required for development? Why/why not?

  • Which proposed option could best contribute to achieve quality urban environments?
  • What would be the impact of removing minimums in just high- and medium-density, commercial, residential and missed-used areas, compared with all areas of a major urban centre?
  • How would the 18-month implementation timeframe impact on your planning processes?
  • What support should be considered to assist local authorities when removing the requirement to provide car parking to ensure the ongoing management of car parking resources?

Strongly support. I’ve written plenty about why parking minimums need to go. Again, you get several options. I would support option 2: removing parking minimums everywhere, but allowing maximums in areas where this can be supported by evidence.

I would also support extending abolition to all urban areas, not just major urban areas. In smaller centres, parking requirements don’t have as big a cost, but they’re still unnecessary.

It’s also important to go beyond just abolish the rules themselves. A lot of parking requirements aren’t imposed as rules, but as conditions of resource consents. I also suggest that:

  • The NPS include a mandatory policy for district plans, saying that increased competition for on-street and off-street parking cannot be considered an “effect”, and that the presence of carparking is not a form of amenity.
  • The NPS not allow the provision of parking to be considered as mitigation of negative effects on traffic.
  • The NPS disallow resource consent conditions requiring the provision of parking, or requiring existing parking to be kept.
  • The NPS insert a mandatory policy stating that on-street parking management and the design of public roads are the primary tools by which councils manage traffic effects.

The other question is about the timeframe. I don’t see any point for the 18 month delay. Councils will have fair warning of the introduction, and developers will still be allowed to build parking if they want. This should take immediate effect.

11. Do you think that central government should consider more directive intervention in local authority plans?

  • Which rules (or types of rules) are unnecessarily constraining urban development?
  • Can you identify provisions that are enabling higher-density urban development in local authority plans that could be provided for either nationally or in particular zones or areas?
  • Should a minimum level of development for an individual site be provided for across urban areas (for example, up to three storeys of development is a permitted activity across all zones)?
  • Given the potential interactions with the range of rules that may exist within any given zone, how could the intent of more directive approaches be achieved?

Support. In this case I do think the intervention should be limited to the major centres, but I would support being very prescriptive. The NPS should include a default set of policies, objectives, and rules for each zone. Councils would be able to add different rules if there is evidence supporting them, but they wouldn’t be able to make rules that are included more restrictive. For example, the “general residential” zone could include a height limit of 12 metres. Councils could raise the height limit to 16 metres, but they couldn’t lower it to 10 metres. On the other hand, councils could add rules on a completely different topic.

In general, I think the standard rules should include at least:

  • the land use activities included in each zone – residential zones must allow all residential forms, including multi-unit housing, boarding houses, and rental housing, and must allow small-scale neighbourhood services like dairies, takeaways, cafes, doctors’ offices, and churches. (There would be limits on how big they could be).
  • “bulk and location” standards – height limits, recession planes, site coverage, impervious coverage, front, side and rear yards, common wall rules, accessory building rules.
  • performance standards – things like noise limits, and opening hours for work-from-home activities

12. Do you support requirements for all urban environments to assess demand and supply of development capacity, and monitor a range of market indicators? Why/why not?

Strongly support. This requirement already exists under the NPS on Urban Development Capacity, although not every council has completed their first report. But it is already having a positive effect on how councils plan.

13. Do you support inclusion of policies to improve how local government works with iwi, hapū and whānau to reflect their values and interests in urban planning?

  • Do you think the proposals are an appropriate way to ensure urban development occurs in a way that takes into account iwi and hapū concerns?
  • How do you think local authorities should be directed to engage with Māori who do not hold mana whenua over the urban environment in which they now live?
  • What impacts do you think the proposed NPS-UD will have on iwi, hapū and Māori?

14. Do you support amendments to existing NPS-UDC 2016 policies to include working with providers of development and other infrastructure, and local authorities cooperating to work with iwi/hapū? Why/why not?

This is a somewhat outside my area of expertise, so I’d welcome any comments you’ve got if you have anything to add: contact me here.

I would add that historically councils haven’t included Māori perspectives very well, and a lot of those decisions in the past have been uncriticially carried over into the present day, so working with Māori to have a look at current policies is just as important as looking at changes.

I also think the government needs to do more to get more Māori into the planning profession itself – at a lot of councils the planning staff is pretty uniformly pale.

15. What impact will the proposed timing for implementation of policies have?

In my view, there’s no reason to delay with the prescriptive requirements about inserting or forbidding particular policies, objectives, and rules in district plans. Particularly not the proposal to remove carparking requirements, which should take effect as soon as possible, and the policies about how to consider amenity values and the positive effects of residential density.

For the other requirements such as for new Future Development Strategies and Housing and Business Development Capacity Assessments I think these timeframes are reasonable.

16. What kind of guidance or support do you think would help with the successful implementation of the proposed NPS-UD?

You probably don’t need to answer this.

17. Do you think there are potential areas of tension or confusion between any of these proposals and other national direction? If so, please identify these areas and include any suggestions you have for addressing these issues.

You probably don’t need to answer this unless you also have a view on the related proposal for restricting development on highly productive land.

18. Do you think a national planning standard is needed to support the consistent implementation of proposals in this document? If so, please state which specific provisions you think could be delivered effectively using a national planning standard.

You probably don’t need to answer this.

Questions from Appendix 3

A1. Do you support the changes to the HBA policies overall? Are there specific proposals you do or do not support? What changes would you suggest?

A2. What do you anticipate the impact of the proposed polices (and any related changes) would be on planning and urban outcomes?

A3. Are the margins proposed in policies AP3 and AP12 appropriate? If not, what should you base alternative margins on? (eg, using different margins based on higher or lower rural-urban price differentials).

A4. How could these policies place a greater emphasis on ensuring enough development capacity at affordable prices?

A5. Do you support the approach of targeting the HBA requirements only to major urban centres? Why/why not?

You probably don’t need to answer any of these except for A3. I think the margins are too conservative: they should also include an allowance (in the short term only) for competition. There should be a big enough surplus of development sites to keep the price reasonably affordable.

Conclusion

I hope that helps. If you’ve got further questions email me at [email protected] or @ me on Twitter, @nzsd. I may update this guide depending on what feedback all you lot give me.

Submissions close at 5pm on 10 October. Use the online submission tool, which or you can write your own document and email it to [email protected]

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52 comments

        1. I should do but I don’t know if they would take much notice of my extreme views like all people should grow their own vegetables using home made compost and all farming should be rotational grazed pasture raising sheep, goats, deer and cattle with cropping only to be done when the farmer can prove he has increased soil carbon and fertility to a point where the crop could be grown with minimal inputs.

        2. Absolutely they need to hear those views, Royce. The current mainstream practices are destroying our ecology.

          What isn’t getting out into public understanding is the breadth of work into better methods. We don’t have to start from scratch. We’ve already signed up to agreements around increasing agricultural soil carbon, which require only minimal changes in practice, but how many people realise that?

          Meanwhile we have to stop the sprawl.

    1. The main rule should be: don’t make a rule unless it is absolutely necessary.
      Probably 99% of the rules the council planners come up with are not necessary. Height to boundary is probably the only one that is needed for residential development (and even with that they are way too conservative). All the other crap about parking and setbacks and site coverage and heritage and light and outdoor areas etc is unnecessarily telling people how they must live their lives (at their vast expense)

      1. Generally agree, but I’d add one about minimum permeable surface. It’s vital for managing storm water but is also a useful de facto rule for encouraging trees, gardens etc.

        1. I did consider that – but do you think without a rule people would be concreting everything? In general people like green space so I doubt it.

        2. I would agree with Jimbo plus Jezza. Only genuine negative neighbourhood effects like shading and stormwater/ flooding risk from loss of water permeable ground should be reasonable objections stopping housing/people coming to cities.

        3. Without a rule, people will be concreting everything. Not because they like concrete more than green space, but because the current standard form for development involves low rise and lots of driveway infrastructure. This is considered so sellable it’s become a truism – it’s the only thing most developers will consider.

        4. There are some councils that currently don’t have an impervious surface rule (e.g. Wellington), they rely on site coverage and density restrictions to try to indirectly produce the same result. I think it’s not really in the spirit of the RMA: rules should be targeted at the specific environmental effect that they’re trying to address.

          Many rules (particularly bulk and location standards) are in reality just there to enforce a particular aesthetic style and stop affordable forms of housing, even if they’re theoretically justified in terms of effects on neighbours. Tightening up on the rational links between the high-level objectives and the actual rules would help to get rid of a lot of this sort of thing.

        5. Stephen what would be good to establish at high level is neighbours refusing more neighbours coming to city neighbourhoods does not protect city amenity and should not be considered as such by the RMA. That people co-locating near people is the rationale of cities -co-location is what gives cities amenity. Without co-location there would be no trade, employment, spread of knowledge, access to specialities etc.

        6. Brendon I would argue that the RMA should not include amenity at all. If you are lucky enough to have an amenity (such as copious off street parking) and it is then taken away from you, that’s just plain old bad luck isn’t it?

        7. Brendon: yes, I agree, and the proposal to give new definitions for “amenity values” and “quality urban environment” support that attitude.

          I think the bigger problem is that we end up with high-level policies that are good, but by the time they’ve gone through the chain of different planning documents down into rules, the original intent has been lost and the rules end up being the same old conservative bullshit.

        8. What an utter load of nonsense Heidi – developers don’t create truisms by only providing low rise buildings with lots of driveway infrastructure. They provide what the market demands although are constrained by development rules. Where zoning allows high density development, then this is what occurs (do you see any single houses developed on CBD sites), where zoning allows low rise development then this is what occurs (once again do you see single houses built on Mixed Use zoned land). You actually have a very poor understanding of the market and how it operates, don’t blame developers for the shape of the city, the city is shaped by the zoning rules and the demand for particular forms of housing at any one time. When there is demand for apartments then the market meets those demands and sites are virtually always developed to their highest and best use.

  1. There is something flawed about this process. Who has the time to submit on all this? I have hit my submission ceiling.
    And will this rule making process of chopping up every issue in piecemeal manner lead to a fatally compromised outcome?
    This submission process also seems to be relitigating democratic outcomes. The housing crisis was a major issue in the last election. The outcome of the election wrt housing is the public want houses to be easier to build.
    A public house building submission process on a NPS -Urban Development Strategy should be clearly asking for feedback on the range of options that would achieve that outcome.
    The further the process gets away from this technical task the more flawed the process will become.
    For the record people co-locating near people is the underlying rationale of cities. Rules therefore that inhibit people co-locating near people decrease amenity. I do not support those rules.
    Rant over – I might save myself some time and submit this…

    1. Yes. We probably need a Consultation Commission; consultation is preventing work that has an already-consulted direction in the spheres of safety, increasing transport mode choice, sustainability and planning. NZ has embraced consultation as the route to retention of the status quo.

      However, I’m still going to submit.

      1. I will submit too. And I will add this death by consultation process that the Ministry of the Environment have set up risks creating a status quo bias despite the clear democratic mandate from voters from the last election being that the status quo wrt housing is unacceptable.

      2. Here’s a brain wave I’ve put about 15 seconds thought into, was going to be tongue in cheek but maybe it could work:
        Perhaps we don’t need elected governments but some mega committee that we all submit on every issue. Very detailed public views through to action being the aim. We could all vote on 2-3 committee members on each area of speciality. It’s a bit like the EU I guess with a huge rule book. Each year the committee vote on the leader from within the committee members.
        There could be the national & local level layers of the same structure.

    2. To be fair, this consultation isn’t exactly aimed at the general public. The primary intended audience is people who deal with the RMA regularly. And they are consulting on a fairly technical level of detail. My own submission includes feedback on those sorts of technical things, which I didn’t mention above.

      The reason I think people should make a submission is because there will be a lot of political pushback against this, and it will be useful to show that there’s also people who support it.

      1. To expand slightly – I do think it’s valuable for RMA users to get consulted on exactly how this is done, although I agree that we don’t need further consultation on whether it is done.

  2. Do you support the Minister riding rough-shod over a Unitary Plan that hasn’t even become fully operative?
    Do you support central government dictating to communities what rules they can and can’t have?
    Looks like I will only be supporting Labour for one term this time. Last time I voted for Aunty Helen until some dickhead wanted to limit how much water goes through my shower head.

    1. Can someone explain to me why it hasn’t become fully operative yet? It’s already apparent that it was way too conservative.

      Why do you think we can get people willingly acting in the best interests of the next 7 generations without rules? We are surrounded by antisocial behaviour that is fucking up the future, including many things that this NPS could set right.

      1. We have rules Heidi, rules that the community worked on and reached compromises on. This NPS process is a power grab by central government that will discard the shared result we have. It will ultimately fail as the next government will feel empowered to use the same process to inflict their right wing views on us. Meanwhile the well-meaning people on this website will all wonder how NZ ever became so partisan and polarised.

        1. Where is your proof of that Heidi? We have only started using the AUP so we don’t really know how effective it will be yet.
          One thing for certain is that Fred Hayek was right when he said the road to serfdom starts when a group of well meaning people get together and decide the world would be better if good people like themselves made all the decisions.
          In all seriousness it is rare for the Labour party to alienate me but these people have managed it in 2 years.

        2. We need a city that is more compact, yet with a small ecological footprint – so more permeable ground, and more trees, etc. That means going up, and not paving everything for driveways.

          But in the inner west, the limitations on intensification are so extreme that if a compact city is in any way achieved, it won’t be thanks to much happening in those suburbs – it will be through other suburbs taking all the necessary development. But take one step out from these inner west suburbs, say Pt Chev. There intensification is also restricted over large areas in order to preserve their draughty bungalows. Yet the AUP didn’t guarantee developers in the GNR corridor would get an easy ride: developments have been opposed by neighbours on the basis of insufficient parking (we’re not talking Daisy levels here, we’re still talking substantial parking) so the developments have fallen over. This means the only development that is happening is where individual sites in the more residential areas are receiving the typical pave-everything low rise crap.

          With appropriate high density along the GNR prevented, the low rise development that ruins our green infrastructure is being added two or three houses at a time. That adds up to a really inefficient work stream, resulting in a bigger construction traffic load, increasing danger for local kids who face construction trucks and huge utes driven fast in their streets for their entire childhood.

          We can do better. We can share the load between all inner suburbs. And we can allow it to be high density, in order to leave a greener legacy, while impacting current generations less.

          Meanwhile, the heritage areas of the inner west prevent solar panels being installed or chimneys being removed. In what way does that prepare for the future?

        3. “We need a city that is more compact, yet with a small ecological footprint – so more permeable ground, and more trees, etc.”

          The trick there is that those demands are mutually exclusive, you can’t make a city both compact and with a small ecological footprint unless you put your blinkers on and only look at what is directly in front of you and not to the side.

          If you want green infrastructure you need space, so squeezing multiple single story houses onto a single section does make it compact but leaves no space for rain gardens or trees. But put those 3 houses on top of each other and on the same size section and you’ve reduced your impervious area to a 3rd and you now have plenty of space for trees and rain gardens.

          From your complaints over those developments on GNR, the locals are justified in their concern over carparks. If we go back to my example of those 3 houses on a section, if those 3 houses then get turned into 10 apartments, with each of those apartment owners having 1-2 cars yet there now being less space for them to park than before, how do you think that is going to improve the urban environment? In all likely hood you’ve gone from 6 cars being parked on private property to 10-20 cars being parked on footpaths and berms making it much more dangerous to be a pedestrian or cyclists.

          Sure you can hope and dream that only people who hate cars will move into those apartments, however that’s just simply ignoring human nature or the demands of society.

        4. Heidi any changes that are needed should be decided by the city not by Wellington. It is simply daft to think the same standards should apply nationally to solve a local issue. The problem we have is the current government think they have all the answers but can’t understand that they don’t even know what the problem is. For my part I simply blame the Greens because it is just too much for me to think my Labour party could be this arrogant.
          Last week I dropped an armload of groceries at a rural Four Square because I forgot my bag, that was the moment I knew I would vote the other way to get rid of this appalling coalition. Three years of National is the cure.

        5. The trouble is, miffy, the city is plagued with an undemocratic electoral system and with regressive officials choosing what they uphold and what they make a fuss about. We have local board members who think – as just one example – that a 3-storey zoning like Business – Local Neighbourhood Centre is too much development, and isn’t enough to preserve the “character” of the Upland Rd shops. Like the needs to retain heritage are greater than the needs of people to have housing or to have shorter travel distances.

          The reason Wellington has to be involved is that at the very local level, people don’t act to ensure equity, international commitments or ethical considerations are upheld. And at the city level, we’re stuck with officials running roughshod over the existing plans.

        6. I promise you Heidi having Wellington veto stuff or impose their will will not solve anything. It will just mean that local issues become a football at the national level. The current people down there think they know best, but their record so far is dismal. They are running a massive surplus because they are too incompetent to actually do the stuff they were supposed to do. Now they want to bugger up planning as well by removing local input. At least National give back tax cuts when they don’t spend, this lot is not spending and they are still collecting money. Same with Auckland, we are paying a fuel tax that isn’t being used for its purpose.
          These NPS’s are their reaction to their own inability to build houses, yet the rules that stopped them are all the crazy shit they have supported for years like a Council that doesn’t control its own providers, ridiculous stormwater costs, pointless assessments, development levies, and all the other nonsense that has made building simply unaffordable. Land is available, sites are available but no one can actually make a dollar out of building.
          Governments all have a use by date and this lot went off faster than most.

        7. I share some concerns but still hold out hope that politicos well-trained in naught but politics will acquire substance. Somehow.

          Where I think you’re wrong is in “At least National give back tax cuts when they don’t spend, this lot is not spending and they are still collecting money. Same with Auckland, we are paying a fuel tax that isn’t being used for its purpose.”

          I’m not yet convinced that they aren’t slowly chipping away at barriers, and that the resistance within the establishment hasn’t been at least as much of a reason for inaction as incompetence. Spending money is still happening – eg public transport money is funding sprawl intersections on SH20B while bus services are cut. And what role has Treasury had in the public’s understanding of the situation:

          https://i.stuff.co.nz/national/politics/116076628/phil-twyford-hits-back-at-treasury-for-misleading-wrong-briefings-that-leave-out-billions-of-spending

          With the future we face, and given the past we are emerging from, with its miserly approach to funding infrastructure, any funds we can’t spend because the establishment is digging its toes in, we’re far better off reducing debt. I know all the reasons it seems stupid, but I’m too conservative 🙂 to not see the advantage of our country being immune to austerity measures.

        8. “And at the city level, we’re stuck with officials running roughshod over the existing plans.”

          These officials will just happen to be in Wellington now…

          And more to the point it’s hardly the case that Wellington has its head screwed on better than Council. If anything, all signs point the other way.

          The problem is the way very local consultations happen. Which is to say that consultations aren’t seen as unrepresentative case studies but, instead, representative results. The case studies should be the flavour that informs representative surveys… you can take all the ones that are opposed and say, “Well, these 66% submissions probably the reasons why 22% of people didn’t want this”… which should lead to, “How can we adjust the plans to ameliorate those concerns without abandoning everything the plan is?”

          Handing the power over a third of the country to the entire country seems a recipe for disaster if the other 2/3 have an uncaring to contemptuous relationship with the 1/3. Especially when that exists in a context where Auckland’s Council will still bear the electoral costs of these decisions in Wellington (in large part because any screw ups that Wellington makes in Auckland are moderated by that additional 2/3).

          It is the wrong solution to the part of the right problem. The role of Wellington should stop at the direction, “Be intense, be compact and watch your flanks.” But it doesn’t… it goes further than that and it specifically directs sideways expansion.

          I mean, it would probably give developers confidence. Convince the right MPs (perhaps even officials) and you can just dive in. Which is all good if the developers want compact developments and so does the government. But that’s not all developers and it’s not Phil “corridor to Hamilton” Twyford, let alone the National caucus.

        9. “eg public transport money is funding sprawl intersections on SH20B”

          What? Are you complaining about the intersection to the park n ride facility? Oh of course, car parks.

        10. “it goes further than that and it specifically directs sideways expansion.”

          Big problem, of course. What solutions do you see, Whirlsler?

        1. Are you saying that someone asking a question is “antisocial behaviour that is fucking up the future”

    1. My Grandad jumped out a plane in Arnhem in 1944, that was during a WAR! He’d be turning in his grave to think there are people out there that actually think there is a war on areas to leave a metal box!!! Haha, get a grip mate!

  3. This NPS is flying under the radar but it’s potentially very powerful. I submitted yesterday, mainly in support but with a few amendments.
    I suggested the exemptions for intensifying around centers should only be Section 6 RMA matters. Along the lines of what Stephen says.
    Submit!!!!

    1. Yeah, if you want to be technical, in my own submission I suggested the only exemptions be designations, reverse sensitivity buffers, where land isn’t zoned for residential at all (e.g. open space, industrial, and institutions), and for section 6(a) and (d) through (h). The reason for dropping (b) and (c) is the risk of misuse, e.g. excessive volcanic viewshafts. Where Significant Natural Areas and Outstanding Natural Landscapes are worth protecting in their own right, the response should be proper open space zoning.

      1. However, I’m about to write about a case where the (very well connected by public transport) land is zoned special purpose, and a new large carpark is planned, adding to the 1300+ already there. This will induce traffic, creating danger not just for the special purpose zone visitors, but for all the suburbs nearby. Instead of being made into a carpark, that area should be rezoned for housing.

        So I wouldn’t leave the land that’s not zoned residential out of it.

  4. I sit back in my chair, in my $79,000 affordable house on a 1200sqm section, and observe from afar Aucklanders arguing over how to enable minor adjustments in house prices from unaffordable $800,000 to slightly less unaffordable $750,000 on tiny 300sqm sections with no privacy.

    WAKE UP!!!

    Pack your bags and get out, like tens of thousands of kiwis do every year. Damn, there’s more kiwis leaving Auckland than going there.

    You can bitch and moan and fight decade after decade for what you want, and will unlikely have, OR you can go straight to where the end result is already delivered.

    Truely affordable housing, zero congestion, no air pollution, community-centered livable places already exist. Just go to one.

    1. Geoff, you realise that the market price for housing in Taumaranui is below replacement value simply because there is no demand to live there. It’s only an oversupply empty houses leftover from when the population was much larger.

      If people followed your advice there wouldn’t be a glut of spare houses and they wouldn’t be cheap. You’re situation is effectively a kind of arbitrage, and it seems to be doing very well for you. If that is the lifestyle you want you appear to have found how to get it cheap and easy. But surely you realise that it’s only effective as an exception, it doesn’t work if many people do it.

  5. Geoff, I can buy a tent and live for free in a Forest and not have the satisfying well paid job that I have if I want..I really don’t see your point?

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