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Auckland 2040 Calls On Minister To Amend Housing Accord


For Immediate Release - 10 June 2013

Auckland 2040 Calls On Minister To Amend Housing Accord

Auckland 2040 says linking the Auckland Housing Accord to the notification of the draft Unitary Plan (DUP) will put pressure on the Council to ‘fast track’ the plan ignoring around 14,000 submissions.

The coalition has written to Housing Minister Nick Smith requesting that he reconsider tying the Accord to the DUP notification and providing an alternative solution. It’s concerned that Aucklanders have just had their first look at the DUP, invested considerable time in preparing submissions and that the planners won’t have the time to read, consider or adopt the suggestions.

Auckland 2040 spokesperson and planner Richard Burton says there are serious shortcomings in the DUP and it’s important that the Council is not forced to notify the Plan before it is ready.

“We do not believe that Auckland Council has the time or the resources to consider the large number of submissions received, to rethink the Unitary Plan and rectify the problems by the target notification date of 1 September. Much more time is needed to prepare a quality Plan.

“There’s also an easy solution that will take the pressure off the planners and make sure Aucklanders have not wasted their time making submissions. We suggest Council identify Special Housing Areas (SHAs) and then prepare Structure Plans. These will also ensure better quality housing,” said Richard.

The current Auckland Housing Accord makes no mention of requiring Structure Plans for SHAs which Auckland 2040 argues is a serious omission. It says that structure plans will avoid haphazard unplanned development by matching the level of development intensity to infrastructure capacity, including roads, waste water and other services. It would also integrate residential development with reserves, community facilities and schools. Community consultation is another component of a Structure Plan and would allow greater consideration of the interface between SHA’s and adjoining communities. Qualifying SHA Developments would then have to comply with the Structure Plan.

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“Requiring Structure Plans in the Accord legislation doesn’t need to be overly time-consuming. Auckland Council could quickly identify a number of SHAs and then commence planning. The other advantage of this approach is that neighbours and affected parties will have a say in the process. Without meaningful consultation and a right of appeal, the potential for abuse is high,” says Richard.

Auckland 2040 is a coalition of local non-political groups passionately concerned about the long- term implications of the draft Unitary Plan (DUP). It wants Auckland Council to ‘ReThink’ the Plan in order to balance intensification with infrastructure capability and urban character values. The group opposes random high density multi-story apartments haphazardly scattered throughout Auckland, poor planning and provision for infrastructure, and inadequate community involvement in the Plan. For more information go to http://auckland2040.org.nz/.

Additional Information

Auckland Housing Accord

Argued to be about increasing the supply and affordability of housing in Auckland, the Housing Accord is an agreement between Housing Minister Nick Smith and Auckland Mayor Len Brown. It’s designed to enable the creation of Special Housing Areas (SHAs) by Auckland Council with the approval of Government - areas where for example, high rise apartments which are consistent with the DUP, can be ‘fast tracked’. This streamlined process largely eliminates the rights of neighbours or affected parties to object and there is no right of appeal to the Environment Court.

In order to create the Auckland Housing Accord, the Government is granting itself extraordinary powers to change the Resource Management Act which according to the Law Society is “contrary to the rule of Law and good legislation principles”. The legislation is also being ‘fast tracked’ and was introduced under urgency with last month’s budget, with the Government only allowing 10 working days for consultation and submission. Select Committee hearings are currently in progress.

1. Housing Accord is linked to the public notification of the Unitary Plan, this will put pressure on the Council to notify the plan without adequate consideration of the issues raised in the feedback process.

2. The Special Housing Areas are not defined in terms of minimum land area, number of individual titles or land ownership. Selection of an SHA in one ownership will have vastly different consequences from an SHA covering many titles within the developed urban area. There is no limit to Council/Government selecting large areas of Auckland as SHA’s with minimal public consultation.

3. Successful development/redevelopment of significant areas of land can only be achieved after a comprehensive structure plan of the area. There is no requirement for structure planning in an SHA leaving the way for haphazard, uncoordinated development.

4. There is no provision for public input in the selection of SHA’s and minimal public input in assessing Qualifying Developments. Without meaningful consultation and no right of appeal the potential for abuse of this process is very high

Hon Dr Nick Smith

Dear Sir

Re: Auckland Housing Accord

Auckland 2040, an organisation representing Aucklanders opposed to unplanned, haphazard intensification plans in the Auckland Unitary Plan, recently met with Paul Goldsmith, National MP. The purpose of the meeting was to discuss our concerns and to better understand the nature of the proposed Housing Accord.

A major concern for Auckland 2040 is the linking of the Accord to the formal public notification of the Unitary Plan. This will put pressure on the Council to notify the Unitary Plan before it is ready. We believe that we have identified serious shortcomings in the Plan and that a rethink of the intensification proposals is warranted. I should note we are not opposed to intensification but believe the draft Unitary Plan lacks focus, coordination and staging. Uncoordinated, haphazard development is not only bad for the communities in which it occurs but makes efficient redevelopment of land and planning for infrastructure virtually impossible. We do not believe that the Auckland Council has the time or resources to consider the large number of submissions received and to rethink the Unitary Plan to remedy its serious shortcomings by the target notification date of 1st September.

Allowing sufficient time for the Unitary Plan to be reconsidered would obviously also have the effect of delaying implementation of the Housing Accord, something that I am sure the Government would not favour. The Government needs to seriously consider whether linking the Accord to the notification of the Unitary Plan is in fact necessary. However, irrespective of whether the Accord is linked to the Unitary Plan or not, there is a serious omission in the Accord in that it does not require the structure planning of SHA’s prior to development.

The Accord presupposes that Council and Government agree on areas to be “designated” Special Housing Areas (SHA’s). There is no size limit to an SHA but to achieve the government’s objectives of freeing up land for development they would need to be substantial in size. It is also presumed but not stated that SHA’s would be under the control of one or a few landowners working together. It is vital that such areas be structure planned to ensure that development occurs in a logical and economically effective manner. At present the Accord contains no reference to any requirement for structure planning. There is a requirement for a “Qualifying Development” to have “sufficient and appropriate Infrastructure” but this is on a development by development basis. A structure plan covering the whole SHA should by contrast consider what level of intensification can be supported by the existing level of infrastructure and whether upgrades to infrastructure are economically viable. It would also assess the proposed density of development, where it should occur and linkages with reserve areas, community facilities etc. The interface with the road network and adjoining areas, outside the SHA should also be considered. Community consultation would ensure that the views of residents in the area were adequately considered. It should be noted that structure planning is not necessarily a time consuming process. Even with community consultation a competent structure plan can be developed in a timely manner.

Hobsonville is a good example how good moderate density development can be achieved through a structure plan process. Qualifying Developments would be required to comply with the structure plan. A number of SHA’s could be identified as quickly as possible and structure planning commence as soon as practicable.

It would not be difficult for Council to prepare a set of agreed principals governing the preparation of a structure plan for an SHA. These principals could be an appendix to the Housing Accord. The outcome of the structure planning process should be as good if not better than could be achieved under the Unitary Plan process either by resource consent or plan change. Any approved structure plan could be subsequently incorporated into the Unitary Plan.

I should note that the above assumes the SHA’s will involve land with one or at most a handful of owners. Major problems would occur if an SHA covered land in many titles each with separate ownership. In this case, it is virtually impossible to achieve a coordinated comprehensive redevelopment. Instead you get scattered haphazard redevelopment. Amalgamation of sites becomes very difficult and land speculation occurs. This degrades the existing housing stock and significantly reduces the extent of intensification that can occur. In this case the only effective way of achieving intensification is for Council to undertake a structure planning exercise and then have the powers necessary to compulsorily aggregate land and undertake the redevelopment. That process, I am sure you will agree, is fraught with difficulties and is why significant brownfields redevelopment will be very difficult to achieve.

If the structure planning approach outlined above was adopted, the Housing Accord implementation date need not be linked to the notification of the Unitary Plan. This has the dual benefit of addressing the housing shortage in a more timely manner while allowing time for the Council to rethink the provisions of the Unitary Plan in light of public feedback.

ends

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