The new National Policy Statement on Urban Development (NPS-UD) is out.
A quick read through prompts a few thoughts.
What happened to quality intensification?
The policy actively supports (enables) intensification close to main centres
and rapid transit routes, which is a big step from the previous statement
which was kind of agnostic about whether urban areas should go up or out.
But what happened to quality intensification?
I can't find a mention of quality urban design. I guess plans can still
address this. At least the NPS-UD doesn’t require bad design, but it would
have been helpful to have a reference to quality urban design.
Whereabouts?
Policy 3 ( c ) is the interesting policy. This requires that plans
'enable':
building heights of least 6 storeys within at least a walkable catchment
of the following:
(i) existing and planned rapid transit stops
(ii) the edge of city centre zones
(iii) the edge of metropolitan centre zones.
The references to rapid transit are all a bit loose and no doubt we
will spend hours debating what a walkable catchment means (it would
have been good if they specified a distance or a walking time); what
is 'planned' (how far in the future can we look) and what is a permanent
route (road or rail) that is largely separated from other traffic (is a
green painted bus lane that operates between 4 and 6pm sufficient?).
What does 'enable' mean:
Not much detail on what is meant by 'enable'. Enable a lot or not much? No
mention of what activity status should be used (is a restricted
discretionary status enabling? - depends on the extent of the discretion I
guess). Does enable mean permitted or controlled?
Subpart 6 – Intensification in tier 1 urban environments - says every tier 1
territorial authority must identify, by location, the building heights and
densities required by Policy 3.
Does the reference to building heights of at least 6 storeys imply some sort
of minimum height? Is a two storey terrace house OK in the area to be
identified for 6 storeys (or is that a waste of a scarce resource?).
And when a consent is lodged, I'm struggling to work out what the
following means:
Nothing in Policies 3 or 4 or this subpart precludes the consideration
(under section 104 of the Act) of any actual or potential effects on the
environment associated with building heights.
Unresolved trade offs.
The NPS's requirement to enable intensification close to city centres is
likely to set up a big battle in inner suburbs between the 'intensifiers'
and the 'retentionists' - those that wish to develop to 6 storeys or those
who wish to retain special character areas.
The policy allows for councils to opt out of the mandatory 6 storeys if one
of a number of 'qualifiers' is present. These qualifiers include
section 6 RMA matters (like heritage) but not section 7 matters like special
character.
There is a back door for special character to come into play - one of the
policies allows for consideration of specific characteristic that makes the
level of development directed by Policy 3 inappropriate in an area,
but the reduction has to be justified as to why that is inappropriate in
light of the national significance of urban development and the objectives
of this National Policy Statement; and include site-specific
analysis. No mean task.
The missing middle ring:
The shame of the policy is that it has stopped at the first 'ring' out from
the centre, it didn’t go the next step and say what should happen in the
'middle' ring suburbs (apart from where a rapid transit line intersects
these suburbs). Auckland has demonstrated the power of the removal of
density controls in the middle ring. This is likely to be a much more
powerful approach to intensification than what is proposed by the NPS (and
more likely to be market driven). So maybe the NPS could have simply
said: 'ditch the density control and the minimum parking requirement".
But again, good urban design is vital.
Infrastructure: who pays?
Policy 3.5 (availability of additional infrastructure) says that local
authorities must be satisfied that the additional infrastructure to service
the development capacity is likely to be available.
It is not clear if that policy could be used to slow or stop the
implementation of the intensification policy. If wastewater and stormwater
systems are not up to scratch (like the western Isthmus in Auckland) or
there is not enough open space in the areas where 6 storeys must be enabled,
are these matters sufficient reason not to enable intensification?
Who pays for the upgrades? Some new ratepayers in the area will help spread
costs, but it will not be enough to cover all the costs. Should suburban
residents subsidise the needed renovation and expansion of social and
physical infrastructure required? This 6 storey development will not be in
poor areas, they will be built for wealthy households (unless the units
built are very small).
Mixed messages over greenfields
The cost / benefit analysis that accompanies the policy statement is
actually quite helpful when it comes to greenfields, noting that benefits
for housing affordability can be quickly lost due to a range of costs.
This subtlety, however, seems to have got lost in the actual policy.
There is reference to the benefits of out-of-sequence development.
At the same time there is the need for certainty over infrastructure
provision and while I may be reading things wrong, the implication seems to
be Councils have to line up all the funding?
What happens if the critical infrastructure is government delivered (eg
motorway extensions or new rail lines?), or where the user should
pay?
What to do about climate change?
The opportunity has been taken to add a bit in about climate change.
Objective 8 says New Zealand’s urban environments should support reductions
in greenhouse gas emissions; and be resilient to the current and
future effects of climate change.
Sounds good. The policy to implement this objective:
Policy 1: Planning decisions contribute to well-functioning urban
environments, which are urban environments that, as a minimum:
support reductions in greenhouse gas emissions; and
are resilient to the likely current and future effects of climate
change.
So the objective and the policy are the same, which is not very helpful.
This smacks of a quick add-on at the end of the process. This is a shame,
given how important climate mitigation and adaptation are to urban
areas.
The importance (or not) of lots of capacity
As with the previous NPS, the focus of the statement is really on capacity
for housing. It is not a holistic or integrated statement about urban
development.
The focus on capacity is understandable, but perhaps it's hoped for benefits
are over stated?
Nowhere is there an acknowledgement of capacity already provided by plans.
The NPS cost/benefit study, for example, seems to have a blank spot when it
comes to the moves already made in Auckland to increase capacity. I guess
the capacity is in the wrong spot. Capacity has always increased overtime.
That’s the purpose of plan reviews and consents. Granted, past reviews
haven’t been bold enough; perhaps the planners have been bold, but not the
politics.
The focus on capacity that is feasible and that is likely to be taken up
tends to narrow long term urban development options, not open them up. Does
the housing capacity to be provided in response to Policy 3 count as
feasible and likely capacity (even through 6 stories is probably not
feasible or likely in many places?).
Sitting behind the NPS is a great deal of interest in the elasticity of
supply of housing. House prices have gone up a lot (well land prices have),
but housing production has apparently been sluggish. If only more houses
were built, prices may stabilise. Why is supply more inelastic than in the past?
There must be a constraint, goes the standard response. But is it that
simple. Housing supply has become more inelastic over time. Is that because
of boom and bust migration and economic patterns making 'over' supply more
risky than in the past; the rise of housing as an asset meaning demand is
set by the performace of other asset classes, not population growth; or is
it the reduction in the number of traditional builders building a single
speck house and the rise of various barriers to entry for new players into
the housing development market, especially if more houses are going to be in 'groups' like terraces and apartments ?
Finally, and I think importantly, there is a bit of a density paradox at
play in most NZ cities. The wealthy like to live close to the centre, not
further out. This is different from most American cities which tend to have
low income inner cores and wealthy suburban outer rings. Inner city areas
should be densely developed to provide cheap housing options. But wealthy
households can consume quite a bit of land and floorspace, as well as
benefit more than others from quicker commutes, so they look for good
amenities, good proximity and substantial amounts of open space, and are
happy to pay high prices for these attributes. In most NZ cities,
inner city suburbs are favoured spots for a range of households than can bid
high for these properties, and once in, they don’t want too much to
change.
Our inner suburbs stopped developing at the two to three storey stage, they didnt
revelop into the six storeys of Europe (which has a longer set of urban redevelopment waves). I don’t think an NPS is going to
make that picture much different. Yes there will be some patches that can
and should redevelop, but to make it all work, there is going to be quite a
bit of shifting around of people and activities. What needs to be freed up
first is the places that activities and households that get displaced (or
which need to be displaced) can relocate to. That is the real planning
task.
