The draft national planning standards that are out for comment are a curious thing.
The purpose of having national standards is not really clear to me. The MFE website says the following:
Currently, plans and policy statements prepared under the RMA are inconsistent with each other and slow and costly to prepare. They can be hard to understand, compare and comply with. This is because councils have generally developed their plans and policy statements independently of each other and without a common structure and format as a reference point.The other side of the coin, that diverse landscapes, environments and communities should mean tailor made plans does not get mentioned. Neither does the innovation that arises from much experimentation of different formats and approaches. Surely we need to speed up the innovation process (try, succeed / fail, learn, try again ) rather than slow things down?
What do the draft standards tell us about urban planning in the the mid 2020s (given that is how long the standards will take to work their way through the system).
Top of mind is the nag that the standards will fossilize the late 20th century approach to planning and resource management and slow the pace of innovation. Not many look back at the 1954 model town and country planning regulations as being the high point. But perhaps some do. If planning stopped at that point, there may not have been the creep seen since. Equally, many important developments around landscapes and environmental enhancement may not have proceeded. So all depends upon
your perspective.
I wonder if the real purpose of the standards is not to make plans easy to compare or navigate. Are the Standards more to do with what should be in and what should not be in plans, with the emphasis on the later? Some parts of the standards could be said to be helpful, in that plans have to explicitly tackle some issues; plans cant dodge them any longer. The requirements to be explicit about tangata whenua issues and aspirations, for example. Same comment could be made about Outstanding Landscapes or urban capacity. But do we need a standard to do this? Didn't there use to be a Schedule setting out what plans should do?
The bigger question is what the standards leave out, or will stop from being included in plans in the future. Being a rigid formula that cant be changed, it is almost like the standards have introduced by stealth an 'anti Section 6' into the RMA - "it is a matter of national importance that plans must not recognise and provide for the following (unmentioned) things....."
How do the standards get updated? What if someone comes up with a brilliant new zone through some sort of fantastic consultative, collaborative process - the Minister has to approve it? So much for devolution of decision making.
The standards feel like they come from the ‘good housekeeping’ school of planning - "when putting the washing away socks and undies go in the top two draws, T shirts next draw down, then sports gear, then jeans and other trousers in the bottom draw". Just stick to keeping things nice and tidy, easy.
Not much about inclusive, sustainable urban environments. Nothing about the next urban age.
On the positive side, the Standards may well just end up driving the development of more placed-based, better calibrated local area plans. The district plan standard allows for ‘precincts’, so I guess the way out of the straight jacket of the set zones is to call everything ‘Precinct XYZ or Precinct ABC’. Effectively the Auckland Unitary Plan is a bunch of precincts masquerading as a zone-based plan. This may mean more complex and hard to understand plans, but then for every action there is a reaction, so what do you expect.
A few more detailed thoughts.
Regional Policy Statements
Where is the urban “bit”? Under special topics?
Given that managing urban growth, including coordination with infrastructure, is a regional council function, and one central to Auckland, Wellington and Canterbury Regions (and even Otago these days), you would think an RPS would be allowed (even required) to have a chapter on urban growth management. Perhaps it is all dealt with under the National Policy Statements section - NPS UDC.
District Plans
How many layers to a plan?
The standards provide for 7 'spatial' tools (zones, overlays, precincts etc). This allows for plenty of flexibility in format, which in practice is likely to make plans 'incomparable' with one another.
Having said that, the layers seem to get tied to certain things. Overlays can only deal with district wide matters, by the looks of things. This seems a bit restrictive. If you want some sort of layer that cuts across two or three zones (like a road corridor that traverses residential and commercial areas) where there is scope to free things up, how do you do that? Is that a Precinct? Why can Precincts only be used where two or more provisions are amended?
What is not mentioned is the relationship between the layers - do some layers trump other layers for example? Despite best efforts, there is always overlap with these layers and the Auckland Unitary Plan is replete with confusing relationships between layers. It is often not clear if overlays and precincts replace zone provisions, or are in addition to them, for example. If the layers pull in different direction, what gives?
More district-wide matters?
Having a bunch of district wide matters is one way to simplify a number of zones and precincts. The list of matters set out in the Standards feels too limited:
- Where does ‘transport’ - parking and access and all that - fit in?
- Urban design? Some plans experimented with a single urban design ‘code’ (or set of principles / criteria) that all zones referred back to as relevant, rather than repeat material through each zone.
- Same idea was applied to Crime Prevention Through Environmental Design in a number of plans.
- What about if the Plan has an affordable housing requirement in it, that applies across the zones?
- And what about if plans introduced some sort of city-wide green building standard to help improve energy efficiency, reduce green house gas use, minimise waste and manage stormwater on-site?
- Does wind assessment for taller buildings have to be repeated in each zone that allows for buildings over 20ms in height?
- And what about 'character' areas - not historic heritage as such, but areas with recognized character that is worth managing. Or is this a 'precinct' matter. I get a bit lost.
Pick and mix zones
The zone standards are odd creatures. The residential zones refer to density, when the real issue is built form. Height of buildings may be a better metric than density. The purpose statements refer to ‘suburban’ and ‘urban’ character. Yikes.
What happens if a community want a 'bush living', 'coastal settlement' or 'inner-city' residential zone, something a bit more evocative of the purpose of the zone. I guess you could add some words after the most relevant standard zone to get around this. Is there anything stopping a plan saying: Residential ( xyz ) zone?
At some point in the not too distant future, I think building height and form will start to be set out in a block-by-block way, yet activities will be managed area or city-wide. Do we need just one residential zone to manage activities, but room for a range of spatially defined built form outcomes that are a lot more nuanced than four zones?
Same idea for commercial zones - do the range of activities in commercial zones vary that much? What does vary is built form. By the way, I notice that there is no zone for 'large format retail' AKA big boxes. This may be a blessing in disguise. Perhaps that wave of development has blown through. A similar comment can be made about 'Business Parks'.
What to do when the plan goes quiet?
Of course the real ‘meat on the bones’ are not in the Standards. What the built form could be or should be for a residential or commercial zone is not set out, for example. Most importantly is the task of assessing developments that step outside the standards for a zone - what is acceptable / appropriate in the context of the site and the environment, what is not appropriate? Increasingly plans are opening up this 'discretionary' space, but not providing much guidance on how much is too much. To me this is where a standard, if there is one, should head.
Back to 1954 Regulations
Having said that nobody wants to go back to the 1954 model regulations, interestingly these regs did have some components which are now considered 'innovative':
The Residential A zone allowed for:
(a) Dwelling houses;
(b) Semi-detached houses;
(c) Apartment houses containing not more than two household units.
The above pretty much covers the normal building typologies with a similar outcome.
Apartments with more than two household units and terrace houses with up to 6 units with rear vehicle access were conditional. This allowed for site by site assessment.
Did they knew about urban design back in 1954 (with terraces having to have rear access!)?
Height for all residential buildings was limited to 30 feet or 9 metres. Height was the defining characteristic of the zone, not density as such.
In the Residential A zone non-residential buildings like churches could go to 40ft or 12 metres.
A bit of variety of height is not a bad thing - 3 storeys can sit easily beside 2 storeys. I think corner sites could take taller buildings.
The Residential B zone allowed for dwelling houses, semi-detached, terrace and apartments. Apartments could go up to 104 ft - 31 metres as a conditional use.
The B zone set a range for heights - a permitted height and a maximum height. Having a discretionary range is quite a good idea, I think
The maximum height was quite substantial. Did they know about urban capacity issues back in 1954?
