Monday 27 July 2020

The new NPS-UD

The new National Policy Statement on Urban Development (NPS-UD) is out.
Image result for 6 storey building - paris

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.