This is a guest post by Anna Michels. Anna is an Urban Designer at HUE in Tāmaki Makaurau.
Auckland Council has released its proposed changes to the Auckland Unitary Plan in response to Central Government directions under the National Policy Statement on Urban Development (NPS-UD) and incorporating the Medium Density Residential Standard (MDRS) within the Enabling Housing Supply and Other Matters Bill that was passed at the end of 2021.
A major discussion point of the proposed Unitary Plan changes has been the subject of Qualifying Matters which allow councils to avoid intensifying areas otherwise earmarked for up zoning under central government mandates. Some of these Qualifying Matters are outlined in the NPS-UD, but councils also have the ability to propose their own.
One of the additional Qualifying Matters that Auckland Council is proposing is Special Character Areas (SCA). Any Qualifying Matter must provide robust evidence as to why it should be included. To justify the inclusion of SCAs as a Qualifying Matter under the NPS-UD, Auckland Council has proposed that any SCA must have a high percentage of individual character-defining properties.
Auckland Council assessed existing properties with a special character overlay on six criteria, and each property needed to score a 5 or 6 to be considered character-defining. For an existing SCA to be retained, the character-defining properties in these Special Character areas have to make up either 75% of total properties within a walkable catchment or 66% of total properties outside of a walkable catchment. (In the NPS-UD, larger upzoning is mandated within walkable catchments from rapid transit stops, city and metropolitan centre zones.)
These percentage thresholds appear to also have been created by council. No information has been released about how or why those thresholds were chosen.
Just like many other matters within the proposed plan change, Auckland Council’s approach seems to have been to spend a lot of time figuring out how to get around the main objectives of the NPS-UD, rather than focusing on meaningful city building. The Auckland Council Methodology on assessing Special Character Areas is a good example of this.
Although Auckland Council hasn’t released its methodology, the likely process is easy to work out by looking at the mapped outputs it has created in the official GIS viewer.
What was Auckland Council’s Methodology for determining Special Character Areas?
On Thursday (28/04/2022), Auckland Council uploaded the SCA Residential Findings Reports which show the individual property grades for all dwellings within any current SCA. This information is used to calculate the percentage thresholds that determine whether SCAs should be retained or removed.
Council’s internal process for reviewing the SCAs seems to be something like this:
One: dwellings are assessed and graded
Each individual dwelling within existing Special Character Areas is assessed and graded from 0-6. The basis of how this grading is created or what property features align with each grade is not publicly available yet. The assessment was started as field surveys, but completed as desktop studies using aerial photographs and Google Streetview. The gradings are recorded within the Residential Findings Reports and can be found here: https://akhaveyoursay.aucklandcouncil.govt.nz/housing
Two: concentration of highly graded properties is calculated
Following this, the percentage of individual properties scoring either 5 or 6 within an existing SCA is calculated. SCAs can be as large as 300+ homes or as small as 5 homes. The existing SCA boundaries are legacies from pre-Unitary Plan planning processes. They carried through into the Unitary Plan, and it’s these boundaries that are being assessed in this process.
The released Auckland Council documents state that rear or vacant properties have been excluded from the total number of properties within a SCA, even if they fall within SCA boundaries. This has an effect on the data accuracy of the percentage calculations.
If the percentage of individual properties scoring either 5 or 6 within a SCA is found to be above either 75% within a walkable catchment or 66% outside of a walkable catchment, the original SCA extent is retained.
Three: SCAs are removed or retained
This is really where the story should end. Auckland Council has fulfilled its mandate to assess each individual special character property and determine whether it is part of a larger character-defining area. If the methodology were to end there, there would be a lot less SCA retained than what the preliminary response maps show.
However, Auckland Council appears to have taken another step, which dramatically changes the outcomes.
Four: SCA boundaries get re-drawn
If the percentage of individual properties scoring either 5 or 6 is found to be below either of the 75% or 66% thresholds, the SCA boundaries are adjusted to create a percentage that fits within the necessary parameters. This smaller area is now classified as a new sub-area SCA.
This redrawing of boundaries to get a desired outcome can be seen on a small scale with SCAs that lose a handful of homes on the fringe, or on a large scale with SCA of 300+ homes that are cut up into three sub-area SCAs.
This methodology creates two major issues that have huge impacts on the built form outcome for Auckland, and seem to be a clear attempt to undermine the goals of the NPS-UD and MDRS directives.
The two key issues with Council’s method
First issue: how do rear lots fit into SCAs?
The first issue created by Auckland Council’s methodology is the obvious statistical data discrepancy. The exclusion of rear lots from the percentage calculation creates higher percentages of character-defining individual dwellings within an SCA. This matters because it can push SCAs above the percentage threshold needed for retention.
If an area has 20 homes and 10 of those are character defining, then the percentage is 50% of the total. This is too low to meet the 66% threshold. However, if five of the total lots are rear lots and excluded from the calculation, 10 character-defining properties out of a total of 15 homes suddenly becomes 66% and the original SCA extent is retained.
Preliminary Response – Example 1:
The property mix in the example SCA is 48 dwellings scoring a 5 or 6 grade out of a total of 98 lots. This results in 49% of properties scoring a grade of 5 or 6. This is below the required percentage to retain the SCA.
However, because the rear lots are excluded in Auckland Council’s calculations, the total number of properties within this SCA is reduced from 98 to 61. The reduction in the overall number leads to the character-defining properties becoming a larger percentage of the total. Therefore the percentage of properties scoring a grade of 5 or 6 as calculated with the AC methodology is 79%.
This now meets the percentage threshold for the SCA to be retained with its original extent.
For statistical accuracy, percentage calculations should include rear properties to provide a real sense of the abundance of high-quality special character dwellings within the SCA boundary. If rear properties are not statistically considered, they should also be excluded from the SCA overlay. Currently, even if rear lots are excluded from the calculation they still receive a SCA overlay, which limits their ability to develop.
Below: a couple of examples of the high-quality special character on the street front in the Example 1 area – and the more recent rear-property structures that would be preserved in amber under the SCA.
Second issue: who decides where SCA boundaries are?
The second issue is the redrawing of Special Character Area boundaries to create ‘sub-area SCAs’. Changing SCA boundaries to change the percentage of character-defining individual dwellings in a SCA essentially sacrifices a few houses on the outskirts of the area to retain as many as possible within the cluster of sub-areas..
The principle is the same as with the exclusion of rear lots. If you reduce the total number of homes that the character defining ones are spread amongst, the saturation increases. This is reflected in the percentage, and the outcome is the retention of otherwise excluded Special Character Areas.
Preliminary Response – Example 2:
The image below shows the original boundary of this SCA outlined in blue. The property mix is 32 dwellings scoring a 5 or 6 grade out of a total number of 58. Even when applying AC’s method of excluding rear lots, the calculation in this area only achieves 64% character defining homes, which does not meet the percentage threshold required to retain the SCA.
Therefore, Auckland Council has reduced the SCA extent. The new boundaries are shown in yellow. AC has called these instances a ‘sub-area SCA’.
The property mix has now been changed to be 26 dwellings scoring a 5 or 6 grade out of a total number of 38. The new sub-area SCA outlined in yellow is now considered to have 68% character defining homes and can be retained as a SCA.
By readjusting the boundaries and reducing the total number of lots that character defining homes are spread across, an increase in the overall percentage is achieved. This means a Special Character Area overlay that would’ve otherwise been removed now meets the set percentage threshold and is retained, but with slightly reduced extents.
Adjusting SCA boundaries to achieve a property mix that has the right percentage would be a time-consuming process considering that Auckland currently has 21,000 homes with Special Character overlay.
Below: examples of lesser character-defining housing that will be preserved in the proposed adjusted SCA for the area in Example 2.
A focus on character at the expense of the city’s future
With the focus on assessing Special Character areas, there hasn’t been much of a conversation about the built outcome we want for Auckland in the future, and what best-practice city building would look like.
From this vantage point, it looks like Council’s process has been designed to retain the greatest number of Special Character Areas and the largest number of properties within them.
There is a clear focus through the proposed plan change on zoning what is existing, rather than following the main central government objective of a future-focused planning approach.