Some more thoughts on the replacement to the RMA and the possible role of urban design in the new Act. A central feature of the reform panel's report on the RMA is the call for 'urban quality'. Does the call for urban quality not place urban design in the centre of the action?
- The Victorian city and its densely packed housing close to polluting industry. The planning response: separate out land uses and control housing density
- The post war city of motorways, suburbia and subsidised sprawl - response: better protect the natural environment (streams, bush, landscapes), develop sub regional hubs, structure planning
- The post industrial city of the late 20th Century of infill, redevelopment, gentrification and consumerism - heritage zones, design controls, tree protection, view shafts, mixed uses (which is where urban design started to come into focus).
The interesting thing is how each wave has added layers of response onto previous layers. Is the panel’s call for urban quality a further iteration of this trend of addition, or is it a replacement of accumulated layers?
But either way are quality urban environments what we need to respond to today’s urban pressures and issues? Constrained supply of housing and too many road blocks to urban redevelopment are seen to be the pressures of the day, pushing up house prices. In one view, in response market forces should become more prevalent in the determination of land use location, density and mix. This will help ensure sufficient and adequate supply of housing, apparently. The call then goes out to make sure it is quality development - where ever and what ever it is. This will keep the NIMBYs at bay. But does 'quality urban environments' sound like a very middle class aspiration?
But why do we think market processes will not deliver quality. And what happened to overall urban functionality, equity and long term efficiency?
I'm a bit worried that the RMA reforms will play out along a simple dichotomy:
Better protect the natural environment, but loosen up on the urban areas.
People like simple solutions and this one always sounds fair and balanced. More rules and intervention in one sphere, but less in another.
But loosen up in the urban sphere? Loosen up may be right for some circumstances. It is time to have a look at the accumulated layers, and perhaps remove some, but new layers need to be developed to deal with future issues.
The trick to any RMA reforms will be in defining the limits of planning in an urban context. There are defined principles to limit market processes as they relate to the natural environment (bottom lines, fair allocation within limits, managing use of public resources), but come to the urban environment and there are much less clear cut boundaries. The RMA attempted to control urban planning by limiting intervention to the management of externalities. But that never limited constant calls for more planning to control and promote outcomes. Defining the role of urban planning has to involve some sort of consensus on how far it can go. The call for ‘quality’ is a simplistic response to this need, and will lock debate about urban planning into a very narrow field.
In previous posts I have looked at urban design and how it relates to plans developed under the Resource Management Act. Urban design has come along way in the past 20 years, but has struggled to find a ‘home’ under the RMA. This is because the qualities and characteristics of urban environments that support social and economic well being are much wider than just managing negative externalities. They are also much wider than a simple notion of 'quality'. Good urban environments are complex:
- People’s interactions with the built environment is physical, emotional and cerebral
- Interactions are both positive and negative.
- They tend to be small-scale, cumulative and accumulate
- The public-private interface is critical
- Open space, mixed uses, housing choices, connectivity are all critical to well functioning urban environments.
If anything, todays urban pressures are all about addressing a narrowing of urban choices (the downsides of a more market - or less government - approach?). Equity is being eroded, long term consequences are being downplayed and choices narrowed as private space takes over from public space. There is a growing concentration of urban resources in fewer and fewer hands and a longer tail of people and neighbourhoods being left behind. The old technique of a strong public sector to counterbalance the pressures of a strong private sector no longer works. Calls for more competition to help rein in the concentration of private interests and improve market-based choices tends to see concentration increase, rather than get dispersed. More housing supply is not translating into more supply of modestly priced housing, for example.
How do these thoughts match up with the proposed replacement RMA? Lets start with the purpose:
(1) The purpose of this Act is to enhance the quality of the environment to support the wellbeing of present and future generations and to recognise the concept of Te Mana o te Taiao.
Wellbeing is wide ranging:
In this Act wellbeing includes the social, economic, environmental and cultural wellbeing of people and communities and their health and safety.
Promotion of quality urban environments sounds like a more comfortable starting point for management of urban environments than avoidance and mitigation of adverse effects. Depends on the outcomes of course. But can a quality urban environment deliver a healthy and safe urban environment for all, for example? Is the reference to 'quality' too confining? Shouldn't a safe and healthy urban environment that can be enjoyed by all be an objective in itself? So too with housing choice and affordability.
To achieve the outcome, the review report on the RMA suggests a shift towards outcomes.
(2) The purpose of this Act is to be achieved by ensuring that:
(a) positive outcomes for the environment are identified and promoted;
(b) the use, development and protection of natural and built environments is within environmental limits and is sustainable; and
(c) the adverse effects of activities on the environment are avoided, remedied or mitigated.
The obvious problem is that positive outcomes are to be ‘promoted’ while negative effects are avoided or mitigated. Avoidance and mitigation are a lot more definitive terms than ‘promotion’. How are positive outcomes to be ‘promoted”? Promotion involves some sense of active facilitation, but perhaps no more than some marketing. Are positive outcomes to be promoted by enabling them to occur, but not requiring them?
But then, what is a positive outcome? Is it an improvement over the current state? Is more choice a positive outcome?
What is meant by the word 'environment'?
(3) In this Act environment includes–
(a) ecosystems and their constituent parts;
(b) people and communities; and
(c) natural and built environments whether in urban or rural areas.
So promotion of positive outcomes can include something positive for a community? Is a shared sense of place/identity through the coherent design of the built environment a positive outcome (like a Special Character Area, but then dont these special character areas lock up supply options?).
To assist in achieving the purpose of this Act, those exercising functions and powers under it must provide for the following ‘outcomes’:
(f) enhancement of features and characteristics that contribute to the quality of the built environment;
(g) sustainable use and development of the natural and built environment in urban areas including the capacity to respond to growth and change;
(h) availability of development capacity for housing and business purposes to meet expected demand;
(i) strategic integration of infrastructure with land use.
So does promotion of environments that support urban well-being get reduced to "lots of capacity for ‘quality’ development?".
I think this bit of the possible Act needs serious consideration.
There needs to be some form of definition or explanation of features that contribute to the functionality of the built environment, of which quality is one aspect. This is very wide ranging, spanning from sense of safety to aesthetics with everything in between.
The built environment is also a vast space covering public, private and semi public/private spaces. Should the reference to qualities be more confined to the public components of the built environment (streets, open spaces, public buildings) or perhaps to the public areas and their interface with private spaces?
There is a danger that the more comprehensive attempts to incorporate positive outcomes become, the less defined the outcomes become and less support is provided to their incorporation. The alternative is to take up the language of bottom lines and limits and say that developments in urban environments should incorporate some basic features that support quality public environments and do not detract or reduce these values.
And by the way, the strategic integration of infrastructure provision with land use and development has to be linked to funding arrangements. Structure plans and rezonings should only be advanced after infrastructure needs, costs and funding obligations have been determined and agreed. Otherwise, there is not going to be any 'integration'.