Letter to The Environment Committee

by John Watson, Greg Sayers, Sharon Stewart, Wayne Walker and Christine Fletcher

Submission on Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill

We thank the Environment Select Committee for the opportunity to provide feedback on its inquiry on the Resource Management (Enabling Housing Supply and Other Matters) Amendment Bill (the Bill). We make this submission as individuals and as current Auckland Councillors opposed to this Bill.

In the first instance we have concerns that the Bill would enable development across urban Auckland and in a number of rural settlements at densities far beyond those anticipated in the Auckland Plan development strategy or planned for in the Long-term Plan. We believe that if enacted in its current form, providing the required physical and community infrastructure would be difficult if not impossible.

The Auckland Unitary Plan has already enabled capacity for over 900,000 dwellings in residential zones alone (approximately 650,000 of which have been assessed commercially feasible), without the need for the proposed MDRS. There has been no acknowledgement in the Bill of the fact that it was only a relatively short time ago that Auckland went through the implementation of the Unitary Plan, a process that resulted in a significant increase in the intensification of the Auckland region.

In this respect Auckland already has a well-considered, evidence-based, community endorsed growth strategy that supports housing choice and density close to centres and public transport.

 Moreover considerably more capacity for housing, particularly around the city centre, Auckland’s 10 metropolitan centres and stops on the Rapid Transit Network, and in other areas with high accessibility to jobs, goods and services will be further enabled under the current provisions in the NPS UD.

In our view there is a very real concern that a poor quality of development could be enabled under the MDRS. This would affect the quality of amenity for prospective renters and purchasers of these properties alike and would also have significant adverse impacts on adjacent properties to the development.

According to the advice we have received from officers, the standards appear to be based on the council’s three-storey Mixed Housing Urban zone, with more permissive controls (e.g. the ability to build the third storey considerably closer to adjacent properties, together with considerably smaller outlook and outdoor living court requirements). Recent monitoring of the quality of development occurring in the Mixed Housing Urban zone in Auckland indicates that some of the controls in this zone should be made less permissive rather than more permissive as proposed in this Bill.

In this respect too little consideration in this Bill has been given to the significant impacts including sunlight, shading, privacy, heritage, and other amenities currently required. Once again the feedback we receive in relation to Auckland’s Unitary Plan is that current legislation is already too permissive. There is a high prospect that developers will remove mature vegetation completely, excavate to produce flat sites, engineer significant retaining and build as close as possible to boundaries; all to achieve the highest yield and minimise building costs. Further to this there does not appear to have been any analysis of the possible increase in carbon emissions brought about by the Bill and the associated unsustainability of encouraging more development virtually everywhere across the region – particularly including locations such as Auckland’s many peninsulas such as Whangaparaoa, Te Atatu, Snells Beach, Awhitu and others that are already at the limits of sustainability. There is also the matter of promoting development in areas that will be increasingly subject to inundation.

This Bill does not adequately address the real issues of housing affordability and supply. We doubt whether it will significantly impact housing affordability and in this respect we note the research findings of Kay Saville-Smith whose analysis  has shown the dramatic decrease in capital assistance from central government to low cost new builds since the late 1980s, the effect of which has been to drastically reduce the supply of low cost housing over the last three decades. It may well be that rather than making houses more affordable that the Bill will have the opposite effect because it will escalate property values which reflect development potential that this Bill significantly enhances.

Finally we would question the appropriateness of the proposed decision-making role of the Minister for the Environment under the ISPP, specifically the manner in which under the ISPP, if the council rejects a recommendation of the panel, the Minister for the Environment makes a final decision that cannot be appealed (other than via judicial review).

We would request the opportunity to speak to this submission and to provide further information if we consider it appropriate at the time.

Yours sincerely

John Watson, Greg Sayers, Sharon Stewart, Wayne Walker and Christine Fletcher