Yesterday, Auckland Council revealed some of the work it has been doing in response to the National Policy Statement for Urban Development (NPS-UD), the government’s attempt to coerce councils into enabling more urban intensification, particularly up to 6 stories, around transit nodes to improve housing affordability.
Historically, attempts to intensify become henfights over whether a single development is suitable, while missing the bigger picture of well-functioning cities and housing affordability. The NPS-UD takes a more reasonable approach of gaining democratic agreement over a common sense principle: that there should be more housing in transit- and job-rich areas. Then, the amount of housing that can be targeted to those areas can be done by technocratic rules, rather than fighting with NIMBYs with every tiny step.
The work shown off yesterday specifically provides updates on how Council will respond to two of the most important parts of the NPS: walkable catchments and qualifying matters. In simple terms, the walkable catchments are the areas within jobs and transit, and qualifying matters are the reasons we might not want to maximise development capacity for a given site. The walkable catchments are defined by:
Regional policy statements and district plans must enable building heights of least 6 storeys within at least a walkable catchment of the following:
(i) existing and planned rapid transit stops
(ii) the edge of city centre zones
(iii) the edge of metropolitan centre zones;
This is particularly important to get right in the case of Auckland, as our post-Unitary Plan building boom has largely missed the inner suburbs, despite those having the best access to transit and jobs.
Everywhere except the villa belt. pic.twitter.com/YAqcmtJITu
— Timmy (@gallicist) November 9, 2020
Unfortunately, it seems the Auckland Council planners have taken many years of taking beatings from NIMBYs to heart (much like their Wellington City Council counterparts, whose watering down of their NPS was shot down by councillors last week), and have produced a plan which follows the NPS by word, but not by intent.
Planners have taken purposefully narrow interpretation of the definitions to vastly undermine the capacity of housing that could be produced by the new plan, particularly by sabotaging rapid transit routes and catchments.
The NPS defines rapid transit as:
any existing or planned frequent, quick, reliable and high-capacity public transport service that operates on a permanent route (road or rail) that is largely separated from other traffic
Architect of the NPS-UD, Phil Twyford, explicitly stated that this definition was chosen as a broader definition of rapid transit than is used by transit agencies, which should include some routes which run just in bus lanes.
And yet, rather than even just considering ATAP’s presented Rapid Transit Network as the RTN for NPS-UD, the planners have dialled it back further, saying that the Onehunga line doesn’t have the frequency to constitute a rapid transit node, and that ferries don’t run on road or rail. Bizarrely, they are claiming that Dominion Road Light Rail is not a ‘planned’ project as it’s not funded in the RLTP, despite nearly $2bn earmarked for City Centre to Māngere.
Importantly, it also ignores one of the most effective public transport investments that Auckland Transport has made in the last decade: the isthmus’ New Network for buses which operate on a relatively comprehensive network of T2, T3, and Bus Lanes on Auckland’s arterials, which are only set to improve with it’s planned Connected Communities program. Great North Road, New North Road, Sandringham, Dominion Road, Mt Eden Road, Manukau, and Great South Road should handily qualify under that definition of rapid transit, if not the rest of the frequent network such as Tāmaki Drive and Remuera Road.
One of the most significant parts of today’s paper was how big they’re looking at making the catchments for new housing, which would be shrunk based on “modifying factors” such as steep inclines (ie, most of Auckland).
City centre – around 15 minutes / around 1200m from the edge of the City centre zone
• Metropolitan centres – around 10 minutes / around 800m from the edge of the
Metropolitan centre zone
• RTN stops – around 10 minutes / around 800m from existing and planned RTN stops.
The laws of geometry dictate that a doubling of the radius of a circle equates to a quadrupling of its area. This means its important to make sure that the radii chosen are as generous as feasibility possible to enable as much housing as possible. Unfortunately, the planners have taken a different view:
A more common approach in public transport planning, and one similar to that put forward
by the Ministry for the Environment in guidance on the NPS UD, is to determine and apply a
walkable catchment that caters for most people. It is proposed to base walkable catchments
in Auckland on a distance the average person will walk to access a centre or RTN stop
While this seems reasonable on face value, it’s incoherent. The “average person”, or the median/50th percentile does not represent “most people”! By definition, half the population would be more inclined to walk more than the average person. While it’s not reasonable to try encapsulate the walking distance of every individual, missing half the population is not a good basis for public policy. A more realistic conception of ‘most people’ would look at the 85th percentile of demand, which is the figure typically used in urban planning when considering, for instance, parking minima.
In 2013, Council produced a survey of how people were accessing the rapid transit network. While the average walking distance for the Median user was ~800 metres (~10 minutes), the average walking distance for the 85th percentile user was ~1700 metres (20+ minutes)!
It’s also important to note that these are the distances people walk when factoring in the “modifying factors”, so if planners really want to optimise around the median pedestrian, then should be looking more towards a base figure of 1000-1200m.
One of the biggest barriers which has prevented new homes being built in the inner suburbs during the Unitary Plan has been “special character controls”. These are often conflated with heritage controls, but are in fact distinct. Heritage is protected by the RMA, aiming to prevent destruction of particular buildings which have unique cultural value.
Special character, on the other hand, is about protecting the “vibe” of a entire neighbourhoods by freezing them in time, making redevelopment all-but-illegal. It’s difficult to see how this is a worthwhile thing to do during an unprecedented housing shortage.
But Council seems to disagree, as they are getting ready to send out surveyors wandering through the streets to rate all 30,000 properties under special character controls across Auckland as low, medium, or high character. Those deemed low or medium falling within catchment will seemingly have their protections eliminated. This could be very positive or very negative, depending on how these ratings are undertaken, but it’s hard to be optimistic given their approach to date.
One small win is that the council has not mentioned the “pre-1944 demolition controls”, which are a blanket protection on all old houses. They will likely drop this altogether, as it would have been very hard for the council to justify under the new steep evidentiary requirements for qualifying matters.
Completely missing from today’s paper is what “building heights of least 6 storeys” actually means for residential development inside these catchments. While the Unitary Plan offers the Terrace Housing and Apartment Building Zone (THAB), which has an explicit height limit of 6 stories, it also has other rules which impose more restrictive height limits in most circumstances.
Most notably, height-in-relation-to-boundary rules mean that few buildings can even touch the stated height limit of 16 metres without a 26 meters wide site. A 10 meter wide 6-storey apartment would need to be sitting on a 36m site! This zone will do little for the majority of sites in these catchments which sit at around 12-16 meters wide.
Council will either have to look at revising THAB, adding a new higher-density residential zone, or looking to the zone currently enabling the kind of development NPS seeks to encourage: Mixed Use Zone, which has already produced many beauties in the slivers of Grey Lynn where they’re allowed.
The paper ends with some strong claims about emissions:
The urban form of cities directly affects the level of emissions they generate. It also affects the level of exposure it’s residents and businesses have to the effects of climate change. Land use and urban form are one of the most significant drivers of emissions given their long-lasting impact. Land use decisions undertaken now will lock in growth patterns that will be very hard and expensive to undo in the future.
Some of the relative impacts of the types of intensification sought by the NPS UD are described below:
- Density – increased density is associated with reduced energy use and emissions, both within and between cities.
- Proximity to the city centre – households closer to the centre of a city tend to have shorter trip lengths and greater mode share, and therefore generate a lower level of transport emissions.
- Proximity to rapid transit – households closer to rapid transit tend to drive less.
- Access to jobs – proximity to jobs has been found to be one of the strongest predictors of household vehicle travel.
Hopefully all councillors who claim to care about carbon emissions, especially after being forced to swallow a miserable 1% reduction in the RLTP, will push back against the planners’ tepid NPS response like their Wellington counterparts.