UDF Submission for Going for Housing Growth: Calling for Feedback

UDF Aotearoa’s Resource Management (RM) Working Group has prepared a draft submission for the Going for Housing Growth Pillar 1 consultation. We are now calling for member feedback on the key eight points listed below, by midday Friday 22 August.

Please offer any direct feedback for amendment, inclusion or exclusion of the content in the points being made – rather than general thoughts, for this exercise.


To give your feedback

Please copy the point you are wanting to give feedback on into the body of your email, with your additions or other adjustments to the existing draft text.

Then please send your feedback to manager@urbandesignforum.org.nz as soon as possible.


Focus of the submission

The UDF submission focuses on the first question of the consultation document: What does the new resource management system need to do to enable good housing and urban development outcomes?

We decided to focus on this question when the status of the consultation changed from being a last step of an NPS-UD revision to an early step to inform the new system generally.

Q1. What does the new resource management system need to do to enable good housing and urban development outcomes?

1. Have a positive vision.

The Planning system needs to define positive outcomes of what is a well-functioning environment. So far we understand the vision for the resource management system to be a lightly regulated one. It is not clear what vision the light regulation is aimed at.

We suggest that regulation should be a tool for achieving a vision. It is problematic
when a tool replaces a vision.

Without a vision success is limited to being plentiful and cheap without providing for individual and community wellbeing, in fact risking harm to health and social cohesion.

2. Include quality as the inseparable partner to large quantity.

The experience of our members would suggest that quality is a key factor to attract long-term investment. Growth can only happen if there is investment, and investors invest when they see return, i.e. a thriving center or hub where people want to live and/or open business.

3. Include provision and quality of public realm as a key urban element for common
good.

The consultation material is silent on the status of public space and common good in society. Well-used, pleasant and safe public and semi-public space is a corner stone of successful urban environments.

4. Encourage co-ordination and collaboration to facilitate economic efficiencies.

For example setbacks are quite inefficient, but are needed where you don’t know what is going to happen next door. Sprawl is inefficient (ie. when you take commercial activities and spread them out randomly across the city so you have to make a separate journey for everything).

5. Implement standardisation at the national level with allowance for flexibility for context-specific application that doesn’t reduce capacity.

Set out well-defined and agreed principles for flexible application that allows for innovation and local adaptation.

6. Provide certainty and create confidence through vision and clear spatial plans with
indicative timelines.

If anything goes everywhere it leads to uncertainty for developers/investors and archives the opposite what is intended to achieve. Long-term spatial planning is a key to provide certainty that ensures coordination between the many players.

7. Require structure planning for greenfield development specifically including community infrastructure such as schools and health facilities, green infrastructure such as open spaces and integrated high amenity stormwater as well as hard infrastructure such as roads and underground infrastructure.

Without social infrastructure as investment, no growth will sustain long-term viability. Social, green and hard infrastructure are crucial to be planned, funded and sustained in a coordinated manner.

We look forward to further proposals under Pillar 2 towards funding and financing models which are needed to make growth viable in reasonable timeframes.

8. Planning and urban design solves real world issues and the analysis of the impacts of reduction of this aspect is lacking.

There are significant benefits alongside costs associated with achieving good urban design outcomes. It is unrealistic to claim that removing urban design, visual or spatial amenity has no cost. Growth and the economy overall requires ‘quality’ to thrive.

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UDF Aotearoa – Resource Management Working Group
David Hattam (Christchurch), Ekin Sakin (Christchurch), Eva Zombori (Auckland), Graeme Scott (Auckland), Jade McFarlane (Christchurch), Jeremy Butler (Nelson).

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