More or less planning?
It is good to see the consultation document start to take a more comprehensive look at urban environments, rather than the previous Statement's focus on capacity. But it is a bit hard to tell if the NPS is asking for more or less urban planning. According to the consultation document cities are under preforming. Rising urban land prices, unaffordable housing, homelessness, rising household debt, traffic congestion and flat lining productivity all seem to be blamed on poor urban planning. This is quite a list. I'm surprised that climate change isn't added to the mix.
Of course, consistent with the narrative of the past few years, the problem is seen to be that urban land markets are being held back from preforming their 'duty' to efficiently tackle these problems. How so many problems have been shifted from being their own problem to being an urban planning problem is a bit of a mystery, but I guess its not unexpected when so many of the underlying problems are so complex and seemingly difficult to rectify. Easier in this case to blame something else for the lack of progress.
For example, is lack of affordable housing really an urban planning problem? Isn't it, at root, a 'housing' problem (as it was back in the 30s and 50s and 70s) that needs its own set of tools, some of which can be planning related. A lack of affordable housing is a market failure, not a planning failure. The State pulled back its interventions that supported affordable (not social) housing supply in the 1980s, so it really needs to find a new set of tools, rather than hope for some sort of market fix. The Kainga Ora Homes and Communities bill hints at some tools. Inclusionary zoning may be one such tool that shapes market behaviour through the planning system.
Where is the monitoring?
Any evidence of monitoring and analysis informing the revised NPS? For example have all the efforts made to provide more land for housing over the past five or so years (think Special Housing Areas) really made that much difference to house prices? Maybe the steep rises have been pulled back, one possible road block to supply may have been removed etc etc. But where is the analysis? One research paper (see note 1) suggests that Special Housing Areas increased land prices, not reduced them. "The results indicate that the creation of the SHA generated an average price increase of approximately 5%, and more generally that affordability did not improve, but rather worsen". In short, landowners banked the speedier consenting benefits of being a Special Housing Area, rather than passing these onto homeowners. Should we be surprised? Perhaps the faster supply of lots and houses helped, but even then, this is hard to see. I know SHAs are history, but they are emblematic of the depth of analysis sitting behind so much of the NPS-UD.
Poor policies around housing, transport and productivity are all going to manifest themselves in sub optimal urban environments. Fixing the sub optimal urban environment is not going to be easy if you have to push up hill against a bunch of forces pushing the other way. It would be helpful if the document could spell out the imperfections and inconsistencies within and between housing, transport and productivity policies in their own right and then line these up with urban planning to better sort out the causal relationships. This should lead to better targeted policies.
The only feedback loop seems to be some form of self-confirmation that planning continues to be too slow and cant work out necessary trade offs and choices.
Having said all that, I am happy to make the obligatory admission that better urban planning is a good thing. In some cases, this may mean 'less' planning, in other cases 'more' planning. The NPS-UD helps a bit with some aspects of better urban planning.
Up versus out?
At least the NPS-UD makes a positive lean towards going up (intensification) rather than out. Previous versions always left the choice up to local councils. It is good to see that the proposed policies on intensification are much more formed than those about leap frog urban expansion. This suggests a subtle but important re focusing of effort by central government (and I presume, input of the Greens). But this is a case where to get less planning in place, it probably is necessary to do more planning. The proposed policies on intensification are fairly blunt and unsophisticated. They may well generate a backlash that is much larger than what they were designed to overcome.
Somethings come to mind:
- P6A provides no definition of high density, yet this is the mandatory policy
- The definition of what is high density in P6C are fairly open ended
- Why stop at 'high density'?
- Does high density mean high rise?
- Not much about quality urban design?
- What about heritage areas, special character, volcanic viewshafts and all those other pesky constraints. Do they still stand or does the NPS override these due to it being a national policy?
- Are high density residential developments going to be open to submissions and appeals?
- The areas listed in P6A where high density should be enabled cover most of the city - for example areas with a 'high-demand for housing" . This would apply to all of Auckland, I would have thought.
Medium density residential zone means areas used predominantly for residential activities with moderate concentration and bulk of buildings, such as detached, semi-detached and terraced housing, low-rise apartments, and other compatible activities.
High density residential zone means areas used predominantly for residential activities with high concentration and bulk of buildings, such as apartments, and other compatible activities.
I know that there is a good intention sitting behind the intensification policies, but you do wonder.
The odd thing is the tie back to capacity, feasibility and affordability. If capacity and feasibility was the issue, then most intensification would occur in areas of high land values (think the eastern sea board of Auckland), but even then feasibility is often 'marginal' as most landowners are canny enough to know what houses will sell for and therefore what their land is worth. But nevertheless I'm sure plenty of intensification would occur in areas with high amenity. But these areas are often not well served by public transport, so congestion would probably get worse. The process of redevelopment is likely to see social mix reduce as older and cheaper housing gets replaced by new, more expensive housing.
Most communities seek to spread intensification around, but in a clustered way; often into places were it is not 'feasible', at least in the short to medium term. The intensification policies of the revised NPS seem to be a tacit recognition that planning is not all about commercial feasibility. Urban planning, coupled with infrastructure investment, can swing the market. But swinging the market takes time: critical mass around transport nodes needs to build, coupled with large investments on public transport. All doable, but it needs the right planning environment.
Is the capacity provided by the intensification polices going to count towards the capacity bottom lines, or is it some sort of over and above?
If affordability was the aim, then the Policy Statement should have talked about intensification in more general terms, such as across the board 'infill' rather than high density redevelopment around transport nodes. Affordability is greatest in far flung suburbs where transport costs are highest and it is easy to plonk a new unit on the back of an existing section. Not flash, but affordable.
Getting the balance right between today's and tomorrow's feasibility, affordability and public investment in infrastructure is not easy and requires a decent dose of spatial planning. I wonder if that is where the policy should have focused more. A more proactive, higher level push for plans to promote intensification first may yield more benefits.
Quality and quantity
It is also pleasing to see a reference to quality urban environments. But there is no definition as such of what quality urban environments mean. There is a list of qualities in Objective O2, but these read more like functionalities, rather than qualities. The associated policies are silent on what quality means. They appear to lapse back into making the urban land market work more efficiently. More housing choices seems to what quality boils down to. Cant see the NIMBYs being placated by these provisions.
The two policies on amenity are equally perplexing. It is helpful to talk about changing amenity, but like existing amenity, future amenity needs to be defined and spelled out, otherwise any thing may add or detract from 'future' amenity, just as it may add to or detract from 'current' amenity.
In fact you could say that quality has taken a backward step under the NPS-UD. The current NPS UDC at least had words like the following (PA3):
When making planning decisions that affect the way and the rate at which development
capacity is provided, decision-makers shall provide for the social, economic, cultural
and environmental wellbeing of people and communities and future generations, whilst
having particular regard to:
This has been trimmed back to P2A:
When making planning decisions that affect urban development and the way and rate at which development capacity is provided, local authorities must have particular regard to:
If the NPS-UD is serious about intensification, then it seriously needs to tackle quality urban design. The Statement's once over lightly treatment of 'urban quality' is a major weakness.
Car parking (and urban trees)
Car parking appears to have joined urban trees as something we should not (and now can't) worry about. I think on-site car parking requirements have largely had their time, but somehow I don't think this will get passed the suburbanites, while the big commercial players will still offer heaps of car parking.
http://www.knowledgeauckland.org.nz/assets/publications/Price-effects-voluntary-affordable-housing-program-Bucaram-Fernandez-Sanchez-May-2018.pdf
