Submission on Auckland Council's preliminary response to housing intensification

Central Government (together with the Opposition) have created legislation that requires all larger cities in New Zealand to allow more intensification of housing. Auckland Council have prepared a preliminary response and asked for public feedback. The following is my submission.

What do you think of our proposed walkable catchment of 1200 metres from the edge of the city centre?

My response: Do not support - I think it should be further

I encourage Council to extend the walkable catchment to 2400 metres (30 minutes) for the City Centre. I would also encourage the use of Business - Mixed Use Zone instead of a Terrace Housing and Apartment Buildings zone to allow greater mixed use.

For many, walking is the default mode of transport with the 2018 census noting that at least 10% of people living in the central suburbs already walking to work. This is despite the existing safety and pollution issues that many pedestrians face, which suggests that it could rise much higher if it was encouraged, enabled and supported by fit for purpose infrastructure. We also need to consider the positive impact of micromobility which is further reducing distances and helping connect public transport and active modes.  Limiting the catchment to 15 mins will significantly reduce the potential housing that could be developed near the city centre

What do you think of our proposed walkable catchment of 800 metres from the edge of the metropolitan centres?

My response: Do not support - I think it should be further

I encourage Council to increase the walkable catchments for the Metropolitan Centres in the isthmus (Newmarket, Sylvia Park) to 1600 metres (20 minutes) and 800 metres (10 minutes) for other Metropolitan Centres. Both Newmarket and Sylvia Park are vital commercial and retail centres that have good transport links, which can support greater growth.

What do you think of our proposed walkable catchment of 800 metres around rapid transit stops?

My response: Do not support - I think it should be further

I encourage Council to increase the walkable catchments for Rapid Transit Stops to 1600 metres (20 minutes) for Rapid Transit Stops. This is a relatively short distance to access frequent, reliable public transport and would enable much greater growth in areas that can support it. Retrofitting rapid transit into other parts of the city will always be complex and expensive, so we must better utilise what we already have and are planning to deliver. I strongly encourage Council to ensure that the definition of Rapid Transit in implementing the NPS-UD includes high bus priority areas.

I encourage Council to make use of the Business - Mixed Use Zone instead of a Terrace Housing and Apartment Buildings zone, in the first 200 metres of the Walkable Catchment of Rapid Transit stops. This will enable even greater, mixed use growth in these critical areas, moving us closer to the 15-minute neighbourhood. 

What do you think of our proposal to apply the Terrace Housing and Apartment Buildings Zone to residential areas up to around 400 metres from large town centres with high accessibility?

My response: Do not support - I think it should be further

I support upzoning adjacent to town centres - enabling people to live near town centres will reduce our transport needs and improve the wellbeing of residents. The pandemic has reminded us how important it is to have easy access to the essentials without needing to travel across town. I encourage Council to consider extending the upzoning to a distance of 800m around all Town Centres defined by Council as ‘large + high accessibility’, as well as all other town centres on the isthmus.

What do you think of our proposal to apply the Terrace Housing and Apartment Buildings zone to residential areas up to around 200 metres from small town centres or large local centres with high accessibility?
My response: Do not support - I think it should be further

I support upzoning adjacent to town and local centres. However, I encourage Council to extend the upzoning up to 400m around all Town Centres which have have high accessibility. While our city is growing, we still have an opportunity to build in 15-minute neighbourhoods through the use of mixed use zoning close to town centres.

What do you think of our proposal to include identified special character areas as a qualifying matter?

My response: Do not support – I do not think special character areas should be a qualifying matter

I fully support genuine moves to protect our history including listed Heritage buildings, but do not support the protection of entire suburbs simply because they are old.

While I appreciate that this is a complex issue with limited time and resources, the approach that Auckland Council has taken to identify these buildings is too broad, leading to perverse outcomes. While there are suburbs of Auckland that have a number of historic houses that deserve protection, claiming an entire suburb needs protection is disingenuous. While we must protect the important historical buildings, not everything that was built in these neighbourhoods needs automatic protection.

Special Character Areas relies heavily on the concept of collective value, failing to recognise the importance of place and building, and creating the impression that suburbs that are not protected are at risk. In reality we need a more nuanced approach, that recognises the need for our city to grow and develop, while respecting where we’ve come from. There are plenty of good examples in New Zealand and around the world, where historic buildings are redeveloped in a way that respects the past while enabling them to remain current.

Finally, the Special Character overlays are focused on the central suburbs - the areas with the greatest access to transport and existing amenities. We must make better use of our existing infrastructure, while we close the significant deficit seen across the city. 

What do you think of the proposed residential special character areas that we have identified?

My response: Do not support – I do not think special character areas should be a qualifying matter

As noted above, I fully support genuine moves to protect our history including listed Heritage buildings, but do not support the protection of entire suburbs simply because they are old.

Older homes were not built to modern standards of warmth and dryness, nor weather tightness. Replacing older homes and villas with modern apartments will radically improve quality of life for residents, offering warmer, drier and healthier living environments.

What do you think of the proposed business special character areas that we have identified?

My response: Do not support – I do not think special character areas should be a qualifying matter

As noted above, I fully support genuine moves to protect our history including listed Heritage buildings, but do not support the protection of entire suburbs simply because they are old.

Business zones need flexibility to adapt in order to provide for the needs of a growing local population. This includes providing for local shops and services, as well as apartment-style housing above.

What do you think of our proposal to include areas in Auckland with long-term significant infrastructure constraints as a qualifying matter?

My response: Other

I support the extremely limited use of infrastructure constraints where there is no other viable alternative. However, this cannot be used as an excuse and must be the option of last resort. I am deeply concerned that this is too open for abuse, given the poor state of the infrastructure in our city. There are few neighbourhoods that could claim they have no issues.

We know there are parts of Auckland where the infrastructure cannot cope with current demands, flooding streets and homes when there is heavy rain. Beaches become unswimmable as waste floods into our harbours. As our city continues to grow these issues continue to compound, increasing the risk of serious, long-term environmental damage. Watercare in particular has failed to identify, contain and resolve these issues, creating real concern that intensification will only lead to more issues. 

It should be noted that these aren't new concerns - in East Auckland, the Manukau City Council apparently had a moratorium on intensification due to the lack of infrastructure but decades later, little has been done to address the gaps. Council must take proactive action to address these infrastructure gaps while investing across the city to build capacity for growth. Retrofitting infrastructure is expensive, disruptive and unpopular - we must make better use of our existing infrastructure and ensure that all new developments include sufficient infrastructure to support the planned growth. Intensification in existing urban areas is a more efficient use of infrastructure, compared to greenfield development. Prioritisation of infrastructure funding between greenfield growth and brownfield intensification needs to be considered.

If this is included as a qualifying matter, Council must ensure that there is a strict and transparent process to ensure it is not abused. Areas that are identified as requiring limited development must have a robust plan developed to address the gaps, including timeframes and funding. Long-term and permanent use should be extremely rare and only where there is no other alternative.

Other qualifying matters

Do you have feedback on any other qualifying matters? (please be clear which proposal you are talking about)

I support the Stockade Hill viewshaft protection which was secured after a long, expensive battle by local residents. It should be noted that this was established under the previous zoning rules and it should be reviewed to ensure that the existing overlay will continue to protect the views of the Waitematā. 

I support the protection of viewshafts of cultural and spiritual significance to mana whenua in Tāmaki Makaurau.