Urban Design Forum Aotearoa – Submission on the Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill
Read UDF’s full submission here
Hearing Friday 19.11.21
UDF’s slot: 11.20 am
Live and recorded feed is here:
https://www.facebook.com/environmentSCNZ/Â
Nine to noon Thu 18.11.21 just after 9am – panel discussion (many minutes)
Listen here:
https://www.rnz.co.nz/national/programmes/ninetonoon/audio/2018821042/concerns-over-fast-tracked-changes-to-urban-density-rules
Morning report Wed 17.11.21 around 8.50am – 3min
Listen here:
https://www.rnz.co.nz/national/programmes/morningreport/audio/2018820867/urban-designers-say-housing-density-law-change-is-flawed
17.11 RNZ Article quoting UDF
New housing density plan prompts criticism from various industries
https://www.rnz.co.nz/news/national/455893/new-housing-density-plan-prompts-criticism-from-various-industries
Three weeks ago, in late October, the government announced a new bill, Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill.
Labour and National have joined forces behind a radical new housing policy, the Housing Supply Bill, which they say will help address the housing crisis by allowing as many as 105,500 new homes to be built in less than a decade. (https://www.nzherald.co.nz/nz/politics/labour-and-national-join-forces-for-housing-crisis-fix-ending-decades-of-standoff/Z27M7UF7QFO4RMLNR7UQBQERZI/)
We have since looked closer into the Bill, the extent to which it applies, and the new set of residential standards that it mandates. The new Bill has no consideration of the urban design matters which we would normally expect to go hand in hand with such an intensification proposal to ensure quality urban places. A few points we have identified are:
- The Bill effectively rezones nearly all residential zones in Auckland, Wellington, Hamilton, Tauranga and Christchurch to medium density. It does so with a reductive set of blanket standards that cover only the most basic bulk and location
- While the press releases suggest the rules allow ‘up to three houses’ on most sites, due to no minimum site size requirement many more than three houses can be built on any size site. See David Hattam’s illustrated piece in https://urbandesignforum.org.nz/2021/11/rma-reform/rma-reform-bill/, up to 12m in height (4 storeys).
- The standards in the Bill are not sufficient to manage well-known challenges of providing intensive housing, which include ensuring residents have access to sunlight, privacy, safe pedestrian access, access to nature, and practical servicing and storage. In addition, the standards do not address matters such as the street interface, with the exception of a setback rule, which are vital to ensuring a well-functioning neighbourhood.
UDF’s Amendment Bill working group is currently finalising a submission. We share the key points below.   Please feel free to share, quote and/or support with your own submission. The closing date is 11.59 PM TUESDAY 16TH NOVEMBER.
- UDF supports intensification that generates sustainable urban areas. For this to occur intensification must occur in the right place, along transport corridors and in compact walkable neighbourhoods around city and suburban centres. Intensification around walkable neighbourhoods enhances and strengthens communities making them resilient to climate change and our changing economic environment. The proposed Bill is likely to disperse intensification where consolidation is needed.
- UDF does not support the Bill as it is currently drafted, because, while promoting intensification, it does not promote quality design. Both the purpose and the proposed set of standards have multiple gaps and issues that will create poor design outcomes. UDF is concerned that these will repeat poor development outcomes experienced in our larger cities (Tier 1 and 2) in the past. Broad legislative changes such as this Bill should be informed by the positive intensification and quality medium density mechanisms that are occurring now in our Tier 1 and 2 cities.
- UDF does not support the one size fits all blanket approach. To enable quality design, each city’s unique set of circumstances needs to be considered to form its new intensive residential identity and increase its quality of life. UDF considers the nature and type of intensification must respond to its context and be place based, to generate good quality urban design.
- UDF would support a national set of minimum standards if they ensure the creation of a liveable standard of urban housing capable of supporting people’s physical and mental well-being and that better addresses climate changes issues. UDF would also support further direction giving councils the ability to manage urban intensification in a more flexible and sustainable manner appropriate to local contexts.
We are pleased that a number of other submissions are being prepared in the urban design and development community. Acknowledging the short timeframe (submissions are due by end of Tuesday 16 November), we invite individuals to make submissions as well. We believe there is merit in some points to be made more than once. You can make a submission online:
https://www.parliament.nz/en/pb/sc/make-a-submission/document/53SCEN_SCF_BILL_116288/resource-management-enabling-housing-supply-and-other
Thank you for your work on this Ekin and colleagues; very grateful to be able to use this UDF work within our individual submissions. Nga mihi, Anna.
Kia ora Anna. It is heartening to see the engagement. We are aware of widespread agreement on the key issues and opportunities. Thank you for considering an individual submission.
Thanks so much for this timely reminder, Ekin. The Bill is clearly trying to solve housing supply issues with a sledgehammer. As you note, the Bill says little about environmental quality.