Addendum Agenda of Auckland Development Committee

Auckland Development Committee

03 December 2014

Proposed Auckland Housing Bond Guarantee

File No.: CP2014/27685

Purpose

1. The purpose of this report, which is based on the attached Economic Case Report prepared by Community Housing Aotearoa and TDB Advisory, is to identify the options available to council to enable more affordable housing in Auckland, consider the associated risks and to recommend a preferred option of an Auckland Housing Bond Guarantee.

Executive Summary

2. Quality urban living is a key focus of council and ensuring a supply of secure, healthy and affordable housing for Auckland is an urgent priority as outlined in the Auckland Plan and as further detailed in the Housing Action Plan approved by Council in December 2012.

3. The Housing Action Plan has a number of priorities and actions that provide direction for the way Council as regulator, facilitator, and advocate can address the affordable housing priorities, with Action 12 specifically providing for an investigation into pilot housing bonds.

4. Through the Auckland Housing Accord and Housing Accords and Special Housing Areas Act over 80 Special Housing Areas (SHAs) have been established. This has created a platform for enhancing housing affordability by facilitating an increase in land and housing supply. As well, affordability within neighbourhoods is enhanced by placing specific requirements on between 5 to 10% of developments of 15 or more lots/dwellings within the SHAs to be “affordable” with required price points in respect of “relative” or “retained affordability”.

5. “Retained” affordable housing is housing that is held by registered Community Housing Providers (CHPs) or Housing New Zealand. Retained affordable housing is determined by a household’s income (not being more than 120% of the median household income) and currently would mean houses being delivered at price points of approximately $360,000.

6. While a developer may select the “retained affordable” option there are cost barriers that impede CHPs being able to deliver such housing. This is a major difficulty within the supply chain as the Community Housing Provider sector has problems in accessing capital, as well as the terms associated with the supply of the capital due to perceived risks.

7. An opportunity exists for council to address this challenge via an Auckland Housing Bond Guarantee (AHB) which will create an Auckland Community Housing Fund and Agency, supported by a proposed council guarantee and that achieves the following: -

· maximum leverage for minimal investment and risk via a $6m guarantee (using existing funds from the Sustainable Development Fund as a contingent liability) that leverages $30m of new investment, initially from the philanthropic sector, that could enable some 200 affordable homes to be constructed;

· growing the capability and resources of the CHPs sector, identified as an impediment to supply. The provision of a guarantee helps to deliver an overall cost-effective financing solution that helps unlock investment for CHPs, with stability.

· transformation – providing early leadership, by offering a clear path for socially responsible investment delivering affordable housing. This leadership could become a game changer in the provision of affordable housing within Auckland and could be scaled up; and

8. It is noted that CHPs are registered via a Regulatory Authority established within Ministry of Business, Innovation, and Employment (MBIE). The role of the Regulatory Authority is to approve, register and monitor Community Housing Providers in receipt of Income Related Rent Subsidy (IRRS). This registration ensures that CHPs have, as their purpose, the provision of affordable housing and have been exclusively established for this purpose and any income is to be directed to this purpose.

The Economic Case informing this report suggests a housing bond guarantee is a minimal and low risk option for Council that can achieve the greatest overall financing and outcome gain.

Recommendation/s

It is recommended that the Auckland Development Committee:

a) receive the presentation on the option of establishing an Auckland Housing Bond Guarantee

b) endorse the principle of the provision of an Auckland Housing Bond Guarantee subject to e) below.

c) approve a maximum of $6m (sourced from the existing Sustainable Development Fund held by ACPL) in respect of the provision of a guarantee, for the period 1 July 2015 to 30 June 2018

d) approve a further sum of $200,000 as an initial loss pool allocation by way of a payment to a Community Housing Fund and Agency (CHF) prior to the 30 June 2015, such sum to be repaid by the 30 June 2018 subject to the terms of recommendation e) below.

e) delegate authority to the Chief Executive and Chief Finance Officer of the council and Chief Executive of Auckland Council Property Limited (ACPL) to conclude all the necessary arrangements in respect of the provision of the guarantee and initial loss pool subject to acceptable business terms, risks, governance etc. being concluded to council satisfaction.

Discussion

Strategic Context/Fit

9. In December 2012 Auckland Council approved the Housing Action Plan. The Housing Action Plan identifies 12 priorities and 32 actions, including Action 12, which is to investigate how Council could act as a guarantor for a pilot housing bond to facilitate start up loans for first home buyers or providers of secure affordable rental or leased accommodation administered by Community Housing Organisation schemes

10. Subsequently the Council and central government signed the Auckland Housing Accord in 2013, in accordance with the Housing Accords and Special Housing Areas Act with the following purpose: To enhance housing affordability by facilitating an increase in land and housing supply in certain regions or districts.

11. The council established the Housing Project Office to implement the Accord which involves the establishment of Special Housing Areas that have specific criteria around the provision of affordable housing.

12. The proposed AHB will contribute directly to the supply of affordable housing in the Auckland region, consistent with the Housing Action Plan (specifically Action 12), enable meeting agreed targets in the ACPL Statement of Intent and help achieve the Auckland Plan’s goal of housing all Aucklanders in secure, healthy and affordable homes. It is also consistent with the type of options (financing – reducing the cost of borrowing) identified in the McKinsey Global Institute Framework in its report “A blueprint for addressing the global affordable housing challenge” released in October 2014. It can also be seen to be complementary initiative supporting central government’s initiatives to grow the community housing sector.

Project Overview

13. A core challenge to the delivery of more affordable housing in Auckland is that current market circumstances are creating real challenges for supply, particularly by CHPs. This proposal provides support for CHPs, by utilising a range of support from:

· the activities of the Housing Project Office in requiring the provision of affordable housing within Special Housing Areas

· limited direct support from Council through the provision of a carefully structured guarantee and initial loss pool that limits risk; and

· philanthropic investors.

14. The Economic Case attached provides evidence that:

· A housing fund with guarantee instrument is a highly cost effective, low risk approach that will be valued by the investor market.

· Council’s role is filling a gap – it is not duplicating a role currently filled by any other entity in central government or the private or philanthropic sectors.

· This initiative could be a transformative game changer that will gain momentum and ultimately allow the ultimate withdrawal of council from the scheme if that is the desire.

15. The AHB arrangement delivers an overall efficient and low cost solution that enables the cost of support to be shared amongst the relevant parties in an open and transparent way, with risks identified and managed. Given the well-documented unaffordability of housing in Auckland, there is an opportunity for Council to provide a well-structured, limited intervention into the market for the foreseeable future.

16. Cost estimates indicate this should be efficient and feasible. The provision of a $6 million guarantee by Council based on a 20% shared loss arrangement is estimated to have an expected annual cost to Council of less than $100,000, and very low probabilities for being called on. This is the preferred path forward, subject to negotiations between Council the CHF entity and investors, combined with the provision by Council of some $200,000 initial redeemable equity. This equity would provide the new CHF with an initial loss pool that would be expected to be repaid after several years of successful operation

17. The Economic Case looks at any intervention in terms of a market context. It assesses relevant risks and mitigation strategies, and develops costed options for dealing with them. In seeking to enable more affordable housing there are a number of options that council can take in terms of its level of involvement and the degree of acceptable risk and return from such activity. In this respect:

· Direct intervention in the market requires significant capital and exposes the council to specific development and project risk

· The extent of capital expended, the limits placed on the guarantee and risks associated therewith reflect a low risk approach that levers additional capital from external sources.

· As detailed in the attached Economic Case, the provision of a guarantee helps to deliver an overall cost-effective financing solution that helps unlock investment for CHPs, with stability. The arrangement has been structured so as to achieve the greatest overall financing and outcome gain while not imposing significant costs or risks on the Council.

Options Identified

18. On the basis of initial assessments, the following short-listed options were selected for further analysis:

· Option one: take no further action beyond the specification of retained affordable housing limits within Special Housing Areas;

· Option two (preferred): Council provides a guarantee (on a pilot basis limited to $6m) to enable capital to be secured by way of bonds through a specifically established Community Housing Funding entity. (This contribution by council is further extended later in this report with a possible $200,000 initial redeemable equity contribution);

· Option three: Council provides capital as an investor in a specifically established Community Housing Funding entity;

· Option four: Council invests directly in a retained affordable housing project or requires a more direct intervention from ACPL in this regard, including council providing additional funding for this activity. This will be in addition to current expectations of ACPL.

19. Currently it is expected that the pilot guarantee scheme could lever up to $30m over 3 years from investors that could be applied to delivery of retained affordable housing.

20. Analysis of these options, detailed in the attached Economic Case, determines that Option 2 is the preferred option from a council perspective.

21. In addition to the investment objectives, the following assessment criteria (critical success factors) have been identified as relevant for screening the options:

· The number of retained affordable houses built;

· Ability to leverage additional funding and support;

· Likelihood of long term durability and assurance that affordable housing is effectively managed;

· Cost to council, including indirect/non-financial council costs of supervision, complexity of involvement;

· Risks to council including balancing risks with funders/providers;

· Timescale - current pressures mean that rapid delivery of affordable housing is valuable, particularly within the window of the Housing Accord

22. The main factors driving discrimination between the options are the extent to which council prefers to manage down the cost of its involvement and any associated delivery/project specific risks. Option 2 in particular provides, on this initial examination, a strong combination of low costs to Council, maximising leverage of additional capital coupled with the maximum likelihood of engaging a wide range of established CHPs - supporting the prospect of effective and transformational/enduring social housing outcomes. As such it emerges as a clearly preferred choice, leaving open the potential for council to inject additional funding directly if it desired.

Bonds and Guarantee Overview

23. The above diagram indicates the process and role of council in the AHB scheme:

· Council offers a limited guarantee to a maximum of $6m

· Community Housing Funding Agency raises funds by way of bond issue – likely around $30m in this pilot

· CHF issues loans to approved CHPs and projects

· CHPs draw down on loan to fund land purchase and development costs

· CHPs either sell down homes to approved buyers, who raise the necessary funds by way of traditional mortgage, or the property is held by the CHP by way of shared equity or as rental stock – either way the CHP replaces the CHF loan with retail bank finance

· CHPs then repays loan to CHF and the cycle repeats

24. A newly established Community Housing Funding (CHF) entity would develop a pool of funds sourced through Auckland Housing Bonds (up to $30m) that would be made available to Community Housing Providers (CHPs) to build affordable housing. Auckland Housing Bonds would be offered to philanthropic investors and supported by a guarantee provided by the Council (limited to $6M).

25. The CHF would provide funds to CHPs at rates below current market rates, enabling them to buy land either made available through the 5% Retained Affordable Housing requirements in Special Housing Areas or other suitable land, and build homes. The CHF would be repaid when homes were completed, expected to be within two years of initial borrowing by CHPs from CHF. The funds would be applied by the CHPs for land acquisition, fees, land and building development. The ultimate benefit of the guarantee to the houseowner could be around $6,000-$8,000 per dwelling which is the saving passed on by the CHP.

Role of Council

26. It should be noted that Council’s involvement is strictly in the provision of the guarantee, council is not involved in the operations of the CHF, tenant management etc. However, Council will, prior to the provision of the guarantee and through the implementation phase detailed below, establish the clear parameters associated with the provision of the guarantee and the way in which risks will be managed/mitigated.

27. The council’s role is solely one of guarantor and possibly initial equity provider, but the entity would be independently governed and managed, with some reporting role to council on progress and any emerging guarantee risks.

Source of Council Funds

28. Council currently has a Strategic Development Fund that is a loan fund available for “transformational” projects which is administered by ACPL. While a proposed housing bond guarantee does not strictly fit within the requirements of the Fund it meets the transformational objective of the fund. Currently the fund has been established to be self-sustaining with loans repaid. In this case there is not a loan but a contingent liability recorded within council’s financials, and the risk to that contingent liability is minimal.

The $6m loan provision and possible initial $200,000 redeemable equity contribution fits within the financial capabilities of this fund which is approximately $100m over 10 years or $10mp.a. on average.

CHF - Financial and Operations Overview

29. The following are the financial and operations considerations of the CHF:

· Operational model

· The process of capital raising

· Requirements and terms associated with the council guarantee

· Start-up implications – establishment of a loss pool of $200,000, initial source of start-up costs of $100,000 and initial operational funding estimated at $100,000 (The latter two not sourced from council)

30. The attached Economic Case provides detail in this respect. There is no expectation of council having any role in the funding and operations of the CHF. The detailed implementation plan will consider the future of the CHF post the council guarantee and include options to wind it up or preferably continue the operations with/without any guarantee.

Business Case (Council Guarantee)

31. The Economic Case provides a sound platform for the council to consider the proposal to provide a limited guarantee of $6m and initial redeemable equity of $200,000 as a start-up loss pool thereby providing necessary certainty and impetus to and initiating the establishment of the CHF. This section considers the implications for council.

Guarantee Structure

32. The structure of the guarantee is detailed in the attached Economic Case. Whilst options are presented the final details of these will be part of the implementation phase and the necessary terms and risks associated with the guarantee provision will be negotiated between the council and the CHF.

Guarantee Cost

33. The first cost is the recognisable cost of maintaining access to funding if the full guarantee was called upon. The cost could be constructed a number of ways however the expected annual interest cost is approximately $60,000.

34. NZ banks do provide performance bonds/guarantees against residential property development projects. The market price estimates received are 1% to 2%. The 1% value should be seen as a floor (being a minimum price); it seems no matter how low the risk a minimum “cost” of 1% is the lowest value that Banks are prepared to sell their credit worthiness. So, for reasonable commercial reasons there is simply a minimum price that risk is transferred at. In this project the implied “cost” of $60,000 for the guarantee seems a reasonable point to cost the council guarantee into the business case.

35. Financial implications of the provision of the guarantee and $200,000 redeemable equity are:

· Strategic Development Fund policy would need to be modified (Currently a loan fund) to permit its use for this purpose

· Cost of guarantee ~$60k pa for 3 yrs. (it would be part of normal liquidity requirements)

· The guarantee disclosed in the financial statements

· Capital contribution of $200,000 not budgeted for 2014/15 and has an interest of $11k-$17k per annum for 3 yrs. The full amount is expected to be returned after 3 yrs.

Risk Mitigation

36. The Economic Case details the risks and mitigation associated with those risks that the CHF would undertake. These assessments are valuable in offering the council insight into the concurrent risks that the council is required to consider that will determine the terms and conditions associated with the provision of the guarantee.

37. While it is envisaged that these details will be determined through the implementation stage the following are indicative of the mitigation measures that would form part of those discussions: -

· An appropriate operating structure and governance arrangement for the CHF entity

· Adequate start-up working capital for the CHF entity

· Robust assessment processes and requirements for approving loans to borrowers

· Appropriate lending criteria and terms

· Appropriate terms for the issue of the Housing Bonds by the CHF

· Agreed reporting relationship to council on CHF activities including loan book, exposure, defaults etc.

Implementation Plans – Next Steps

38. It is envisaged that the CHF will be operational and capable of issuing loans by 1 July 2015 and in order to achieve this Community Housing Aotearoa (CHA) will complete the detailed CHF business implementation plan following the Auckland Development Committee decision which will then enable:

· CHA Council to endorse the CHF business plan by 15 December 2014

· Conceptual review of the proposal by the lead investor/s by the end 2014

· Implement CHF business plan commencing January 2015 – Source start-up funding, capital raising strategy, formalise details and arrangements with Council etc.

· Board recruitment process starts in early 2015

· Negotiate operational agreements for services early in 2015

· Confirm investors for first $7.5m tranche

· Launch CHF

Conclusion

39. The proposal to provide a guarantee that will enable the establishment an Auckland Housing Bond Fund and Agency is assessed as the optimum level of risk and capital approach to be undertaken by council to enable the delivery of affordable housing within Auckland consistent with strategies adopted by council.

40. Council approval in principle is sought to the offer of a guarantee (on terms set out in this report) and an initial redeemable equity contribution of $200,000. This commitment would allow CHF’s proposers to approach key potential lenders to further cement support for the whole proposal. Once this was achieved (expected to be early in 2015) formal detailed documentation would be drawn up (expanding on the indicative terms sheets included in Economic Case) and funding drawn down.

Local Board Views and Implications

41. This report outlines a proposal and funding structure to enable greater availability of affordable housing in Auckland. Local Boards will continue to be engaged with on affordable housing options for their communities and be key contributors to the SHA process.

Maori Impact Statement

42. This report outlines a proposal and funding structure to enable greater availability of affordable housing in Auckland. Maori are disproportionately impacted by a lack of affordable housing supply, including Papakainga development. This proposal will create further opportunity and choice in respect of more affordable housing options.

Attachments

No.	Title	Page
a View	HPO NZCHF Business Case	15
b View	TDB NZHFC Operating Model	59

Signatories

Authors

Allan McGregor - Manager SHA Masterplanning

Andrew John - Funding Manager

Authorisers

Ree Anderson - Project Director for Housing

Dean Kimpton - Chief Operating Officer

Roger Blakeley - Chief Planning Officer

Auckland Development Committee

03 December 2014

Productivity Commission Inquiry: Using Land for Housing

File No.: CP2014/26638

Purpose

1. The purpose of this report is to:

(a) note that work has begun on Auckland Council’s submission to the Productivity Commission’s Using Land for Housing issues paper; and

(b) authorise the Committee Chair, Deputy Chair to approve the Council submission on the issues paper; and

(c) outline the proposed process for developing the submission and Auckland Council’s involvement in the subsequent steps of the inquiry.

Executive summary

2. The Minister of Finance, Minister of Housing, Minister for Local Government and Minister for the Environment have instructed the Productivity Commission to undertake an inquiry into Using Land for Housing. The Ministerial terms of reference for the inquiry are available as Attachment A to this report

3. The Productivity Commission has started the Using Land for Housing inquiry by releasing an issues paper. A copy of the issues paper is available as Attachment B to this report.

4. There is an opportunity for Council to make submissions to the Productivity Commission on the issues paper (due 23 January 2015) and subsequent draft report anticipated to be released in May 2015 with submissions closing in July 2015.

5. The inquiry is very wide ranging, and in order to respond to it staff need to engage widely across the council group. The timeframes for responding to each of the inquiry papers are short relative to the potential scope of the work council needed to do to prepare its responses.

6. Due to the constrained timeframes in which to make a submission on the issues paper, it is proposed that the Committee Chair and Deputy Chair be delegated authority to sign off the final submission on the issues paper prior to it being submitted to the Productivity Commission by 23 January 2015.

7. The Commission’s final inquiry report, which will make recommendations to government on ways to improve performance in areas such as processes for urban land supply, including infrastructure provision and funding, governance and engagement with the community, will be released on 30 September 2015.

Recommendation/s

That the Auckland Development Committee:

a) receive the ongoing Productivity Commission Using Land for Housing issues paper. The issues paper is available as Attachment B to this report.

b) authorise the Committee Chair, Deputy Chair to approve the final council submission on the issues paper.

c) note that the council committee will be invited to input into subsequent stages of the inquiry including the draft report.

d) note that staff will report back to the Committee as the inquiry progresses and that the final submission to the issues paper will be circulated to all committee members once finalised.

e) request that this report be circulated to all local boards and the Independent Māori Statutory Board for their information.

Comments

8. The Minister of Finance, Minister of Housing, Minister for Local Government and Minister for the Environment have instructed the Productivity Commission to undertake an inquiry into Using Land for Housing. The Ministerial terms of reference for the inquiry are available as Attachment A to this report.

9. The Productivity Commission has released its issues paper on its Using Land for Housing inquiry. A copy of the issues paper is available as Attachment B to this report.

10. The issues paper is the first step in the inquiry, and will lead to the development of a report to government, which the Commission will consult on before finalising its report and recommendations. Both the government and Auckland have clearly indicated that resolving issues in the housing market is a high priority.

Scope of Using Land for Housing inquiry

11. The purpose of the Commission’s inquiries are to look at “whether the laws, regulations, institutions and policies that affect New Zealanders’ productivity can be improved”. The terms of reference for the Using Land for Housing inquiry make it clear the government expects this inquiry to build on and expand the Commission’s recommendations from its previous Housing Affordability inquiry.

12. The main conclusion of the Housing Affordability inquiry was that housing affordability is a multi-faceted issue and requires a multi-faceted approach to identifying the drivers of the problem/s and possible responses. Key recommendations from the Housing Affordability inquiry included:

· the need for councils to prioritise the release of greenfield and brownfield land for residential development

· the need for councils to ensure their planning policies and procedures support more efficient land use

· the expectation that Councils review their regulatory processes to improve speed and simplicity, and take steps to reduce cost and uncertainty

· the need to consider opportunities to improve the performance of building consent authorities and the construction sector’s productivity

· the need to review the government’s (then current) approach to social housing

· the need to consider broader options for Māori housing including identifying key service delivery agents and options for better co-ordinating collaborative responses by Māori, public services, financial institutions and whānau.

13. The Using Land for Housing inquiry will examine the by-laws, processes and practices of local planning and development systems to “identify councils that are making enough land available to meet housing demand and processes that could be adopted more widely”. It will include an examination of practices and approaches in New Zealand and also overseas. For the purposes of the inquiry, local planning and development includes:

· the legislative framework governing land use, the planning and funding of transport infrastructure and services, and the planning and funding of infrastructure needed to make land viable for housing

· the rules, plans, policies and pricing regimes used by local authorities to give effect to these legislative frameworks, and

· the internal processes used by local authorities to carry out their responsibilities, rules and policies.

14. The inquiry excludes a review of the role and purpose of the Resource Management Act (RMA) and the Building Act (and related processes governing the assessment and processing of building consent applications). It also excludes changes to the ownership of local authority infrastructure assets. It does however include consideration of the funding and governance of local infrastructure assets and provisions of the RMA and Building Act which could be changed without fundamentally altering the role or purpose of those Acts.

15. At the conclusion of its Using Land for Housing inquiry, the Commission is expected to make recommendations to government designed to drive improvement in four main areas. These areas are:

· policies, strategies, outcomes and processes for urban land supply, including the provision of infrastructure

· governance, transparency and accountability of the planning system

· funding and governance of water and transport infrastructure

· involvement and engagement with the community.

16. The key topics covered by the questions in the issues paper are directed at:

· evaluating the planning and development system

· producing a comparative analysis of councils’ performance

· identifying the impacts of key legislation, planning and accountability measures

· assessing the performance of the planning system processes and rules

· understanding the impacts of the approvals processes

· identifying issues related to the provision of infrastructure for housing

· identifying other factors influencing the supply of development capacity.

17. Auckland Council should expect the Commission’s inquiry recommendations will propose specific changes to the status quo to try and speed up the release of land supply and remove obstacles or barriers to development. As the Commission’s inquiry progresses, staff and councillors are likely to get a better understanding and indication of its approach and its likely recommendations.

Next Steps

Managing our response to the issues paper

18. Submissions on the issues paper close on 22 December 2014. However, Auckland Council has received an extension to 23 January 2015. Council staff from across the organisation and CCO’s have formed a working group to develop a draft submission for consideration by elected representatives.

19. Staff are seeking the Committee’s support for a working group of Committee members to work with staff on developing Auckland Council’s submission to the inquiry issues paper. We anticipate holding a workshop with the political working group on 19^th December. The Committee’s agreement to delegate authority to the Chair and Deputy Chair of the Auckland Development Committee to authorise the release of Council’s response to the issues paper is also sought.

20. Subject to the Committee’s approval of a political working group and requested delegations, the key milestones for our response to the inquiry issues paper are:

Milestone	Due Date
Issues paper distributed for initial consultation	14 November
Draft paper circulated to all councillors, IMSB, Local Boards for feedback	12 December
Feedback and responses from councillors, IMSB, Local Boards	Midday 18 December
Proposed political working group workshop	Workshop 19 December
Draft paper to political working group	15 January
Final report to political working group and for sign-off by Chair and Deputy Chair	20-22 January
Report back to Auckland Development Committee post provision of submission to the Productivity Commission	TBC (next available Committee meeting)

Proposed approach to remainder of inquiry

21. Staff also propose using the political working group to provide input during the remaining stages of the inquiry.

22. The Commission’s draft inquiry report is to be released in May 2015. Submissions will close by July 2015. The Commission’s final inquiry report will be released by 30 September 2015.

Consideration

Local board views

23. Local chairs have been provided with a copy of the Using Land for Housing issues paper and a brief summary of it and have been invited to provide feedback or comment to be incorporated as our response is developed. Staff understand Local Board chairs are agreeable to this approach.

Māori impact statement

24. IMSB have also been provided with a copy of the Using Land for Housing issues paper and a brief summary of it and have also been invited to provide feedback or comment to be incorporated as our response is developed. Staff are also seeking guidance from Te Waka Angamua on managing any wider Māori consultation as the inquiry develops.

25. It is noted that there are a number of initiatives underway as part of the Housing Act Plan and also under the new housing legislation (HASHAA) to improve housing opportunities for Māori. These include establishing a joint agency group to provide integrated advice on Māori housing developments and investigating opportunities to include Māori land in Special Housing Areas. Such initiatives can be conveyed to the Productivity Commission who has specifically enquired about the way in which housing for whānau on Māori land can be enhanced.

Consultation

26. As this inquiry is open to public submissions, no other specific public consultation is planned in developing either our response to the issues paper or any responses to the Commission’s draft and final reports.

Other Implications

27. At this stage, the project will be completed using existing resources. If we become aware of any significant financing or resourcing implications or any legal implications we will update the Committee.