If twenty-thousand buildings across the city were determined to have exactly the same kind of character, few would try to claim that each and every one is “special”.
And yet, this is exactly what Auckland Council planners are doing.
The National Policy Statement on Urban Development (NPS-UD) is a document containing international best practices for developing affordable, accessible, and low-carbon cities, which directs the major local authorities to upzone to allow up to 6 story apartments near to important transit and employment centres.
It recognises that some of these areas won’t be suitable for this, introducing “qualifying matters” to discount them from development. This is mostly intended to minimise new construction in areas which might be vulnerable to things like natural disaster, although also keeping in mind areas which have existing cultural or historical value, such as particular sites of importance to Māori.
Auckland Council evidently has a more expansive and colonial idea of cultural or historical value, and the discussion around the NPS is now primarily a fight around whether to retain existing construction bans (called Special Character Areas) within the innermost suburbs constructed as the first wave of suburbanisation in the city, filled mostly with the villas and bungalows that were mass-produced to meet the growth of the city when thousands of immigrants came from Britain to start a new life here.
Although heritage protections are explicitly allowed by the NPS, the vast majority of villas and bungalows do not meet the threshold to be considered heritage – most of these buildings have been extensively modified, are found in other cities both in NZ & abroad, and are not important sites for notable people or historic events. Their only claim to ‘heritage’ is being old and being villas.
These areas are often quite pleasant – but this is mostly abundant mature tree canopy, lots of traffic calming measures, and the result of being built long before we started clearing massive amounts of our cityspace for the private automobile – producing a compact built form which is usually not allowed by the very rules that modern zoners seek to impose.
Unsurprisingly, none of this is included in the new definition of Special Character. In determining Special Character to be a qualifying matter, Council has produced the following:
It’s clear from the inclusion of “period of development”, “level of physical integrity”, and “architectural style” that Special Character has been designed to stealthily lower the bar for a preservationism that can’t be justified by traditional heritage protections.
But even more egregious is the inclusion of “scale” and “typology”. It is incoherent to say the existing scale or typologies is a reason to prevent the NPS-UD directed scale and typology, when the NPS-UD exists to change the scale and typology of places whose existing urban form is unfit to meet our climate, housing, and transport needs.
It is hard to see that what is being consulted on is legally consistent with the NPS-UD, let alone with the multitude of nationally significant crises in housing costs, climate emissions, or transport accessibility across the city. Especially as the qualifying matters are themselves qualified, as follows:
- Qualifying matters need to identify Specific Characteristics that makes the level of intensification required by the NPS and MDRS inappropriate in light of the national significance of urban development
- Heights and density more restrictive than the NPS catchment can only be imposed to the extent that it affects the characteristic in question
- Site-by-site evidence is required for qualifying matters, which includes justifying the extent of the area that it’s applied to, as well as the sites that it applies to
From these, it’s quite apparent that a number of their methods, some of which was discussed by Anna’s guest post last week, are wrong:
- “Special” is not specific, and therefore not something that can itself be a qualifying matter
- Character areas cannot have single family house zoning beneath the underlay, they need to be MHU/THAB (or equivalent in non-residential zones) with the overlay just regulating the characteristics that are identified as specific to the area
- Sites which are not determined to have a character dwelling on them cannot have special character protections on them
How should this work?
An approach which is both consistent with the NPS and interested in protecting the existing character of urban areas would have started by defining the specific physical characteristics that particular areas currently have. For example, many areas urbanised in the 1970s are characterised by brick and tile architecture – this may be a feature we decided to preserve in these areas. Rather than all-but banning construction, new apartments should be permitted where they respect those characteristics.
The under-construction Onehunga Mall Club is an example of how this could work – 6 stories of modern apartment will sit above a newly constructed row of shops with façade built in the form and material characteristic of the older shops in the town centre.
Under a more rational system to manage character, an overlay would define this particular style of shop frontage as being the specific characteristic which defines the Onehunga Town Centre, and new developments would be instructed to respect this, but otherwise apartment construction is permitted.
Of course for this to work well, there would need to be thought put into which characteristics we want to preserve – some architectural deisgns may look fine on a villa, but poor on an apartment. Similarly, many streets are sometimes improved by breaking up a characteristic to make the area more visually diverse.
In some exemplary cases of where all houses on a street conform to an architectural era, this approach may be indistinguishable from preservationism. For instance, McCullough Ave is a street in Mt Roskill which is entirely intact 1940s state houses, and villa streets like Cockburn in Grey Lynn have been largely untouched. Protecting a handful of streets like these would be inconsequential for housing supply, but allow them to be properly managed as an “urban museum” — spreading preservation as broadly across the city as possible means spreading thin the resources to keep these areas intact!
An approach to protecting character which enables housing is not just preferable, it’s necessary:
The National Significance of Urban Development
So maybe this produces a better outcomes – but why bother? Because qualifying matters cannot stifle the “national significance of urban development”, and the most significant change we need in Auckland’s urban form is to fill the housing donut. While only ~4% of residential land within the city sits under a special character overlay, almost the entire area that they sit over is where it makes the most sense to intensify. If we don’t open up these areas for apartments, then we’re condemning less-suitable locations to intensification, which will have less desirable effects upon climate and transport outcomes.
So this ended up taking a while. Based off the operative Unitary Plan, you've got four areas with >90% of land available for residential development covered by special character areas. pic.twitter.com/pP81cIKru7
— Rustie (@rustie5555) April 30, 2022
Thankfully, there is still time for Auckland Council to re-consider their approach. Today is the last day of Pre-Consultation on the NPS-UD plan change to be submitted in August, and the Coalition For More Homes has created a submission guide for anyone hoping to push us back in a pro-housing and pro-urban direction:
Use our submission guide via the following link to support our call for #MoreHomes in the right places.
— Coalition For More Homes (@morehomesnz) May 5, 2022