Date:

Time:

Meeting Room:

Venue:

 

Tuesday 24 August 2021

9.30am

The Stevenson Room
Level One Franklin the Centre
12 Massey Ave
Pukekohe

 

Franklin Local Board

 

OPEN ATTACHMENTS

 

Attachments Under Separate Cover

 

 

ITEM   TABLE OF CONTENTS                                                                                         PAGE

 

12        Proposal to make a new Freedom Camping in Vehicles Bylaw

A.      Freedom Camping in Vehicles Statement of Proposal and Draft Bylaw August 2021                                                                                                                                3

14        Urgent Decision - Provide local board feedback for inclusion in Auckland Council’s submission on the Government Policy Statement on Housing and Urban Design

B.      Draft Auckland Council Submssion on the Government Policy Statement on Housing and Urban Design                                                                                103

15        Urgent Decision - Provide local board feedback for inclusion in Auckland Council’s submission on the Natural and Built Environments Act exposure draft.

B.      Draft Auckland Council submission on the Natural And Built Environments Acts draft                                                                                                                            141

18        Auckland Council Performance Report: Franklin Local Board March to June 2021

A.      Franklin Local Board March-June 2021 Work Programme update                   179



Franklin Local Board

24 August 2021

 

 

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Franklin Local Board

24 August 2021

 

 

363

DRAFT 13 July 2021Submission to the Ministry of Housing and Urban Development
In the matter of the Discussion Document on the Government Policy Statement on Housing and Urban Development
Auckland Council, July 2021

Mihimihi

 

Ka mihi ake ai ki ngā maunga here kōrero,

ki ngā pari whakarongo tai,

ki ngā awa tuku kiri o ōna manawhenua,

ōna mana ā-iwi taketake mai, tauiwi atu.

Tāmaki – makau a te rau, murau a te tini, wenerau a te mano.

Kāhore tō rite i te ao.

 

 

I greet the mountains, repository of all that has been said of this place,

there I greet the cliffs that have heard the ebb and flow of the tides of time,

and the rivers that cleansed the forebears of all who came those born of this land

and the newcomers among us all.

Auckland – beloved of hundreds, famed among the multitude, envy of thousands.

You are unique in the world.

 


 

 

AC new logo_horz_cmyk 

 


Ko te tāpaetanga o te Kaunihera o Tāmaki Makaurau

Auckland Council Submission                                                                             30 July 2021

 

Auckland Council Submission on the Discussion Document: Tuākī Kaupapa Here A Te Kāwanatanga Mō Te Whakawhanake Whare, Tāone Anō Hoki | Government Policy Statement on Housing and Urban Development

 

Submission to the Ministry of Housing and Urban Development

 

1          Introduction

1.1       Auckland Council is pleased to have the opportunity to submit on the discussion document: Tuākī Kaupapa Here A Te Kāwanatanga Mō Te Whakawhanake Whare, Tāone Anō Hoki | Government Policy statement on Housing and Urban Development (“discussion document”).

1.2       This submission represents the views of the Auckland Council group (the council), which includes Auckland Council, Auckland Transport, Eke Panuku Development Auckland (Eke Panuku), Watercare Services Limited (Watercare) and Auckland Unlimited. Input has also been received from the Independent Māori Statutory Board. 

1.3       The Chair and Deputy Chair of the Planning Committee, and a member of the Independent Māori Statutory Board, are designated signatories of this submission. The submission includes input from X Local Board(s), and their input is appended to this submission.

1.4       The council’s submission consists of discussion of the issues it considers most substantive, followed by responses to the questions set out in the discussion document. The substantive issues discussed are:

·      Auckland’s growth and urban form

·      Funding and financing challenges

·      Misalignment between Government policies and strategies

·      Partnering with Mana Whenua and Mātāwaka to deliver better Māori housing outcomes

·      Enduring partnership between local and central government

 

2          Tāmaki Makaurau Auckland Context

2.1       Auckland Council is a unitary authority and the largest local government agency in New Zealand. Its unique governance structure includes: a governing body focusing on region-wide strategic and regulatory directions; 21 local boards making decisions on local issues and representing Auckland’s diverse communities; council-controlled organisations (CCOs) who look after specific council assets, services or infrastructure; and an Independent Māori Statutory Board, which has a statutory responsibility to promote Issues of Significance to Māori (Mana Whenua and Mātāwaka) in Tāmaki Makaurau Auckland and to monitor Auckland Council’s performance in responding effectively to these. Auckland Council also works in partnership with mana whenua entities, who represent the interests, mātauranga and tikanga of mana whenua of Tāmaki Makaurau.

2.2       Auckland is home to one-third of New Zealand’s population, with 1.7 million people. Over the next 30 years, this could increase by another 720,000 people, potentially requiring another 332,000 to 384,000 dwellings and 263,000 jobs. The rate and speed of Auckland's population growth puts pressure on our communities, our environment, and our housing and infrastructure networks. It also means increasing demand for space, infrastructure, and services necessary to support this level of growth.

2.3       About one per cent of the total land area of Tāmaki Makaurau is Māori Land, while some 10 per cent of the Māori population in Tāmaki are Mana Whenua, the rest identifying as Mātāwaka. Nearly a quarter (23.4 %) of the total New Zealand Māori population live in Tāmaki.

2.4       Much of Auckland's appeal is based on the natural environment, but this is vulnerable to degradation from the impacts of human activities. Despite regulation and considerable effort, Auckland's environment continues to be affected by past decisions, Auckland's rapid growth and development, as well as threats such as climate change.

2.5       There are significant levels of socio-economic deprivation in Auckland, often in distinct geographic areas. Key drivers of this include unequal access to education and employment opportunities, along with high – and often unaffordable – housing costs. With the significant increase in the cost of housing in Auckland, the associated decline in home ownership levels is resulting in fewer Aucklanders being able to fully prosper and thrive.

2.6       The Auckland Plan 2050 recognises these pressures in identifying that to achieve the Auckland we want, we must address the three most important challenges of high population growth, ensuring prosperity is shared amongst all Aucklanders, and reversing environmental degradation. The challenge of mitigating the effects of, and adapting to, climate change is also becoming more urgent.

2.7       The Auckland Plan sets out Auckland’s ambition for housing and urban development in Tāmaki Makaurau. The current housing system does not work for many Aucklanders, and Auckland currently has one of the least affordable housing markets in the world. Growing numbers of Aucklanders are unable to afford to buy a home, rents are straining the budgets of many families, and the number of people who find themselves homeless or living in unsuitable accommodation has increased in recent years. Many Aucklanders live far from jobs and other facilities due to limited availability of affordable housing options. This trade-off between the cost of housing and proximity to jobs and facilities is a driver of spatial inequalities and social exclusion in Auckland.

2.8       The Auckland Plan recognises that holistic thinking and action is needed to change the system, and there are many factors that will need to be addressed if we are to achieve our vision of enabling Aucklanders to live in secure, healthy and affordable homes and have access to a range of inclusive public places. These factors include, but are not limited to:

·      the way we regulate land supply

·      the cost of new infrastructure for development and who pays for this

·      how and where urban development is initiated, and by whom

·      the use of innovative building approaches

·      productivity of the development and building sectors.

2.9       The need for this holistic thinking and action is becoming more and more urgent. The GPS comes at an important time for Auckland where there is a need to look to the future and ensure we can better provide places to work, live and play for generations of Aucklanders to come, while also addressing the significant environmental decline and challenges we are experiencing.

3    Submission – Substantive Points

3.1       The council supports the overall intent of the GPS-HUD, and a detailed response to the consultation questions is provided in the next section. Council would like to highlight the following five substantive points in particular.

Auckland’s growth and urban form brings challenges and opportunities

3.2       Over 1.7 million people currently live in Auckland, and the population is projected to reach 2.3 million by 2050. This growth rate is higher than the national average. To accommodate this growth, Auckland’s urban form and built environment will change significantly. This could mean 332,000 to 384,000 new homes, 263,000 new jobs, increased community services and facilities, and associated supporting infrastructure.

3.3       Auckland is following a quality compact urban form approach to growth to realise the environmental, social and economic benefits and opportunities this approach brings, such as:

·      It allows opportunities for more housing to be built around areas of activity and close to good public and active transport options

·      It improves the efficiency of the substantial investment required in infrastructure – such as transport, water and wastewater – and other services. This also results in the best asset management and infrastructure provision.

·      It means lower travel costs for people and businesses, increased agglomeration benefits, and localised place benefits.

·      It helps to protect our natural environment, reduce emissions, and maintain Auckland’s rural productivity by limiting urban sprawl.

3.4       Recent monitoring results indicate a significant uptake of intensification within the existing urban area in response to the Auckland Unitary Plan’s up-zoning. In the twelve months to April 2021, 66 per cent of development in Auckland took place through intensification and 13 per cent of new dwellings consented were located within 1000 metres of a rapid transit station. Dwelling consents for more intensive typologies such as apartments and townhouses are increasing at a faster rate than consents for standalone houses.

3.5       In our Development Strategy, we acknowledge that areas must be developed in a cost-effective and sustainable way. They also need to be vibrant places for communities who will live there, with a strong network of centres and neighbourhoods, easily accessible by public transport, walking and cycling. These areas also need to provide opportunities for employment, services, and social infrastructure facilities such as schools and hospitals, parks, sports fields, and community facilities.

3.6       As Auckland moves towards developing a more dense and intensified urban form, good quality urban design needs to be addressed at all scales of development. This includes the quality of the city structure, the urban form and function of places, the amenity of all public realm areas such as public places, spaces, and streets, as well as building and house design. The quality of city design is integral to how it functions, which affects our overall wellbeing. Good quality urban design contributes to making places sustainable, attractive, safe, accessible, equitable, desirable and enduring, thus helping to achieve “thriving communities”.

3.7       Council believes greater clarity and emphasis is needed in the GPS on a number of the issues raised above, including:

·      The importance of compact urban form in (1) enabling emissions reductions in urban areas and progressing towards the Government’s net zero emissions target and (2) maintaining vital areas of biodiversity and highly productive land.

·      The need for housing to be linked to local employment opportunities and good public and active transport options.

·      The importance of good quality urban design for all scales of placemaking, from the regional level to the level of individual sites. 

Funding and financing challenges mean complex choices need to be made

3.8       As Auckland’s population grows, we need to provide more services to more people. We need to ensure that there is enough infrastructure – such as roads, water and wastewater pipes, public transport, parks, community facilities and supporting social infrastructure – to accommodate growth. We also need enough infrastructure to support new business developments, as more people will need more places to work and do business. As Auckland grows, we will also need to spend more to mitigate the impacts of growth on the natural environment and the health of our waterways.

3.9       The council is working to maintain its level of investment in infrastructure to support the city’s and country’s economy, whilst simultaneously providing for future growth. However, our borrowings and revenue are currently highly constrained, and it will be difficult to take on new infrastructure priorities for most of the coming decade.

3.10     Local government has significantly fewer mechanisms available to it to raise funds than central government. For example, we can choose to raise rates, but this may cause financial hardship to our residents, particularly those on fixed incomes. Significant rates increases are likely to attract strong public opposition. We can also choose to increase our debt levels and sell or lease surplus properties. In our Ten-year Budget 2021-2031 we have used a combination of all of these tools to enable us to provide the investment into infrastructure, services and protecting our natural environment that Auckland urgently needs.

3.11     Central government has recognised the criticality of infrastructure funding and financing to achieving the housing and urban development outcomes it is seeking, and has started to address the infrastructure deficit through new tools such as the Infrastructure Funding and Financing Act and Housing Acceleration Fund. While these may be useful tools in certain circumstances, Council believes that infrastructure funding and financing needs a fundamental rethink.

3.12     Council considers it essential that the GPS include a stronger focus on the funding and financing challenges that need to be addressed in order to meet the vision and outcomes set out in the discussion document. The need for integrated spatial, infrastructure and funding plans which have a long-term focus should be recognised. The GPS needs to explain the complex choices that will need to be made when there is not enough money to pay for everything, how this complexity will be managed, and how choices and decisions around which outcomes are prioritised will be made. The GPS also needs to be clearer about whose role it is to coordinate and resolve the infrastructure funding and financing problem facing New Zealand.

Better alignment between Government policies and strategies is needed

3.13     The GPS-HUD is the latest Government initiative that impacts on housing and urban development, and the discussion document notes that it is designed to be a system strategy that aligns government policy and activity that affects housing and urban development. In recent times, Council has responded to a range of initiatives, including the Government Policy Statement on Land Transport, Urban Development Act, National Policy Statements on Urban Development (NPS-UD) and Freshwater Management (NPS-FM), Infrastructure Funding and Financing (IFF) Act, Resource Management system review, Building for Climate Change programme, building system reform, draft National Policy Statements on Highly Productive Land (NPS-HPL) and Indigenous Biodiversity (NPS-IB), as well as consultations by the Climate Change Commission and the New Zealand Infrastructure Commission.

3.14     Council would strongly support the GPS-HUD being used to identify where misaligned policies are currently affecting the housing and urban development system, and to provide stronger direction on how to resolve these misalignments and manage the trade-offs that will inevitably be required between multiple outcomes.

3.15     Misalignments between the GPS-HUD and policies such as the NPS-UD, NPS-FM, NPS-HPL and NPS-IB will contribute to an unresponsive and inconsistent planning system and affect the delivery of aspirations in the GPS. For example:

·      Although climate change is both an objective and policy of the NPS-UD, these aims may conflict with other aspects of the NPS-UD such as requiring councils to allow for development moving ‘out’ as well as ‘up’. The NPS-UD requires local authorities to be ‘responsive’ to private plan changes for development in locations, or at times, not previously anticipated. This impacts the council’s ability to plan for future growth, align land use and infrastructure funding and provision, achieve a quality compact urban form, and mitigate and adapt to climate change.

·      The NPS-UD is silent on natural environment outcomes, but the GPS-HUD anticipates a role for urban development in restoring ecosystem health and improving biodiversity, water quality and air quality outcomes.

·      The GPS-HUD talks about avoiding unnecessary sprawl and protecting highly-productive land, yet the proposed NPS-HPL does not preclude development on highly productive land that has already been zoned future urban. In Auckland, highly productive land within future urban zones accounts for 5 per cent of the region’s productive land.

3.16     To be effective, there needs to be alignment between the GPS-HUD and the existing and anticipated future policies that will be used to deliver the vision and outcomes of the GPS-HUD. There is a risk that the GPS will say the right things at the strategic level, but that the policy and implementation underpinning the GPS will take a different approach that will work against the high-level outcomes.

3.17     Council suggests the integration of concepts such as Te Mana o te Wai and Te Oranga o te Taiao within the GPS. These concepts are central to existing and likely future resource management legislation and policy, and prioritise respectively water and environmental outcomes. Achieving the desired vision for the housing and urban development system will inevitably require trade-offs between multiple outcomes. The incorporation of Te Mana o te Wai and Te Oranga o te Taiao within the GPS-HUD would provide guidance on prioritisation of environmental wellbeing when trade-offs are required.

3.18     Finally, a number of government documents refer to Te Tiriti, partnerships with Māori, and Māori values and terms. It would be desirable of if all parties (in both central and local government) worked to a common Te Tiriti guidance document and practice standards.  For example, one suggestion within the Resource Management system review has been for a national policy statement on giving effect to Te Tiriti principles. It would be desirable if there were one document used across the resource management and urban development system. This document could guide reporting and regular independent review.

Partnering with Mana Whenua and Mātāwaka to deliver better Māori housing outcomes

3.19     Auckland Council is committed to collaborating with Māori to deliver on priority outcomes in Tāmaki Makaurau and to making a positive difference in the lives of whānau Māori. Ensuring that whānau Māori live in warm, healthy and safe homes, and that housing options meet the individual and communal needs of whānau in Tāmaki Makaurau, is a priority for council.

3.20     Māori in Tāmaki Makaurau have experienced housing stress over many years. Māori have higher than average rates of household crowding, lower than average rates of home ownership, and less stability due to higher than average rates of renting. Māori are more likely to live in damp and mouldy homes and are over-represented among people experiencing homelessness. A thorough investigation is needed to identify the specific systemic and underlying reasons as to why Māori disproportionately face housing issues, and a clear set of actions is needed to address them. 

3.21     The Auckland Plan sets out a number of ways that Māori housing outcomes could be improved, including:

·      Ensuring Māori have access to affordable housing initiatives to promote community health, whānau stability and Māori social wellbeing

·      Leveraging off the work that the community and Māori housing sector is already doing to create increased options and opportunities for housing for Māori

·      Ensuring regulatory and consenting processes are effective and responsive to Māori developers and iwi organisations

·      Tapping into the potential of Māori commercial enterprises, some of which are already playing a key role in delivering housing

·      Aligning housing initiatives in Tāmaki Makaurau with national Māori housing strategies and policies.

3.22     The Independent Māori Statutory Board (the Board) launched the Kāinga Strategic Action Plan in 2019 (developed collaboratively with key players in the sector), with an update and refreshed advocacy priorities approved by the Board in 2020. The Plan identifies several housing actions which have a high degree of alignment with the GPS-HUD, including: a focus on homelessness, emergency housing and transitional housing; supporting the iwi and Māori pathway as part of the Progressive Home Ownership scheme; and removal of Community Housing Regulatory Authority barriers to iwi and Māori housing providers.

3.23     According to the Board’s Kaitiakitanga Report for Tāmaki Makaurau 2019, Auckland Council-assisted papakāinga increased from three in 2012 to seven in 2018. The number of Māori organisations and trustees supported to achieve Māori housing and papakāinga development increased from 12 in 2015/16 to 17 in 2017/18. Information presented to the Wāitangi Tribunal in April[1] showed that of 52 community housing providers (registered by the Community Housing Regulatory Authority) in Aotearoa, 15 identified as Māori, four in Tāmaki Makaurau.

3.24     Nationwide, Māori providers have less than 4 per cent of the public housing held by community housing providers (CHPs) and funded by the Government’s Income Related Rent Subsidy (IRRS). Together, Kāhui Tū Kaha Limited and Whai Maia Charitable Trust hold most of this (330 houses out of the total of 463 held by registered Māori housing providers in New Zealand). There would appear to be significant scope to build on this in Auckland, particularly at a time when the Government has embarked on a major public housing construction programme in Auckland, with CHPs providing a significant share of the new homes. Not having registered CHP status may constrain Māori housing providers from delivering on other parts of the housing spectrum as well, including via partnerships with Kāinga Ora. It is therefore important that central and local government work with Tāmaki Māori on how to address their housing aspirations in implementation plans and identifying appropriate performance indicators.

3.25     We support the GPS’s emphasis on implementation, reporting and a three-yearly review. It is important that there is regular reporting on housing outcomes for Māori, providing up-to-date information on:

·      How Māori are distributed along the housing continuum from home ownership to homelessness

·      Housing quality, security of tenure and related outcomes

·      The number and scale of Māori housing providers, their projects, assets, aspirations and barriers

·      The size of land made available for Māori housing and numbers of houses built.

3.26     The council and the Board strongly support a more active role for government in partnering with Māori to respond to the systemic changes needed to improve Māori housing outcomes and are pleased to see the Te Tiriti response to iwi and Māori housing aspirations that the GPS-HUD has sought to embrace. The integration and application of the Māori and Iwi Housing Innovation framework for action (MAIHI) framework across all sectors will be critical to successful outcomes for Māori. We recommend that MAIHI performance indicators be developed and reported by region and form part of regular integrated reporting of the GPS’s three-yearly review. 

3.27     Council and the Board would welcome greater partnership with government to better deliver on Māori housing and urban development outcomes in Tāmaki Makaurau. Consistent with the GPS, this would include Government taking the lead in enabling Tāmaki Māori housing providers, land leasing options and Kāinga Ora jointly delivering housing programmes with local Māori communities.

An enduring partnership between local and central government to deliver better housing outcomes

3.28     Central and local government both play key roles in the provision of public and social goods for the residents of Auckland and so Council supports the inclusion in the GPS-HUD discussion document of “genuine and enduring partnerships” and the pursuit of “meaningful and real relationships” with local government as one of the four ways of working.

3.29     The real-life context for national strategies and policies is always locally-specific.  The scale and complexity of Auckland means the challenges we face, and our relationship with central government, are different from other local authorities around New Zealand. Within the Auckland region, the social, economic, environmental and cultural wellbeing of communities also varies greatly. Council is very well placed to understand and enable – and often deliver – what is needed to improve the wellbeing of Auckland’s communities.  We understand the connections between urban design, infrastructure investment, economic activity, the environment, housing, and social wellbeing as they play out in our diverse communities. This contextual understanding of our people and places means it is essential for central government work collaboratively with Council to achieve the outcomes set out in the GPS-HUD.

3.30     Council has a history of forming good partnerships with government on critical housing and urban development issues, including through mechanisms such as the Auckland Housing Programme and Joint Work Programme on Housing and Urban Development, and this provides a strong foundation for close cooperation. But we believe this cooperation and collaboration can, and must, be improved if we are to achieve the vision and outcomes set out in the GPS-HUD and in the Auckland Plan.

3.31     There are always opportunities to improve our ways of working – for example ensuring greater communication, sharing of information, use of common data and evidence, and joint engagement with stakeholders where appropriate.

3.32     However, fundamentally, Council believes that to get the best wellbeing outcomes for our communities, there needs to be a change in how infrastructure and services get delivered, including funding mechanisms. The partnership between central and local government needs to be underpinned by integrated spatial, infrastructure and funding plans which have a long-term focus. Agencies such as Kāinga Ora in particular, need to work collaboratively with Council on their spatial priority developments from the early stages of strategic planning, right through to delivery. Decisions also need to involve local communities. Integrated spatial plans should enable communities, and the infrastructure required to support them, to be planned efficiently and effectively, leading to better outcomes.  

3.33     Council also believes that the success of these spatial plans and partnership with government more generally depends on a holistic, systems approach across all government agencies – not just those directly involved in housing and urban development. For the outcomes in the GPS to be achieved, government agencies need to be better at working together and recognising the interconnected nature of the issues set out in the GPS. For example, we cannot prevent and reduce homelessness, without also looking at the welfare system, healthcare, and training and employment.

4    Specific matters: discussion document questions

Do you agree with the proposed vision and outcomes? Is there anything else that should be included?

4.1       The Auckland Plan 2050 recognises the importance of thinking strategically about how the housing system can provide secure, healthy and affordable homes for all Aucklanders. We are pleased to see the Government adopting a multi-decade outlook and setting a clear vision and direction for the housing and urban development system in New Zealand through the GPS-HUD.

 

4.2       Auckland Council supports the overarching vision set out in the GPS-HUD that “everyone in Aotearoa New Zealand lives in a healthy, secure and affordable home that meets their needs, within a thriving, inclusive and sustainable community”. This vision aligns well with the vision set out in the Auckland Plan 2050 Homes and Places outcome that “Aucklanders live in secure, healthy, and affordable homes, and have access to a range of inclusive public places”.

Thriving Communities

4.3       Council supports the focus on thriving communities, and the broad definition of thriving communities set out in the discussion document. Auckland needs thriving communities that are connected, resilient, sustainable and inclusive if we are to achieve the outcomes set out in key strategic documents - the Auckland Plan 2050, Te-Tāruke-ā-Tāwhiri: Auckland’s Climate Plan, Kia Ora Tāmaki Makaurau: Māori Outcomes Performance Measurement Framework, and the Independent Maori Statutory Board’s Schedule of Issues of Significance to Māori. With its wide-ranging sphere of influence and responsibility, the council has an important part to play in achieving the thriving communities outcome.

4.4       Council strongly supports a focus on reducing emissions through sustainable urban form and good quality urban design, public transport services and active transport networks. Urban form is a powerful enabler of emission reductions in urban areas. Achieving a quality compact urban form in Auckland is critical to New Zealand achieving its required emissions reductions. As noted above, however, there appears to be a lack of alignment and consistency in policy documents such as the NPS-UD with this ambition to reduce emissions through good urban form. It is not clear how the GPS will address this.

4.5       We support the statement that communities should grow within environmental limits and urban development should restore ecosystem health. It is not clear from the discussion document, however, what these environmental limits are, how they will relate to the limits that are proposed to be included in the new Natural and Built Environments Bill, or how success will be measured. Auckland Council has developed, and is continuing to develop, clear targets around climate change, waste, urban ngahere, and water efficiency.  We recommend that all Crown-delivered housing should meet or exceed these targets to support the growth of new communities within environmental limits.

4.6       Council recommends that “planning for and investing in changing infrastructure needs” may be better expressed as an adaptive approach to infrastructure provision in response to changing pressures and needs. This would encourage a broader approach to long-term infrastructure planning.

4.7       Council notes that there is no explicit reference in this outcome to addressing inequity. The definition of thriving communities could be interpreted as weighted towards individual needs or a narrowly defined geographic area. We need to ensure that our thriving communities are integrated as part of the broader region to help mitigate the potential for creating inequities.

Wellbeing through housing

4.8       Council supports a focus on wellbeing through housing in the GPS. The link between housing and wellbeing has been widely documented over the years. The condition of homes, insecure tenure, and wider neighbourhood characteristics all have a considerable effect on Aucklanders’ physical and mental health and wellbeing.

4.9       Council considers that cultural wellbeing needs to be better addressed in the GPS given the growing diversity of our communities.

4.10     Council would strongly support the focus of the “Wellbeing through housing” section being broadened to recognise the importance of places, spaces and ecosystems - and not just housing - to people’s wellbeing.

·      Parks, playgrounds, streets, town centres and other places and spaces have a key role in Aucklanders' mental and physical health as they are places for activity and recreation. Public places can provide respite for those who feel isolated or experience stress or safety issues at home. Public places where people can interact and connect have always been important and will continue to be vital to Aucklanders’ sense of belonging and wellbeing. As we are moving towards more intensive housing development outcomes, the importance of how all public realm areas contribute to community wellbeing is critical.

·      Ecosystems, urban forests and/or planted green public spaces improve community wellbeing when provided within a walkable catchment to housing and places of work. The contribution of well-functioning ecosystems to people’s wellbeing is well recognised in national environmental directions such as Te Mana o te Taiao - the Aotearoa New Zealand Indigenous Biodiversity Strategy.

Partnering for Māori housing and urban solutions

4.11     The council supports the government’s commitment to partner with Māori and to invest in Māori-driven housing and urban solutions. We support a Te Tiriti response to Iwi and Māori housing aspirations, which the GPS-HUD has sought to embrace.

4.12     The government needs to play a more active role in partnering with Māori to respond to the systemic changes needed to improve Māori housing outcomes, which are currently in crisis. The integration of the MAIHI framework across all sectors will be critical to successful outcomes for Māori. 

4.13     It is positive to see the discussion document laying out how Kāinga Ora will engage and partner with others, including Māori. This partnership role will need to be well-resourced, implemented and monitored.

4.14     Collaboration will be critical to the success of this outcome. Partnership approaches need to be tailored to leverage off each other’s strengths. For example, the Auckland Council Māori Housing Unit supports Māori organisations to develop housing on Māori and general land by advising Māori landowners and developers through the development process and acting as a single point of contact within the Council. The Papakura Marae kaumatua housing project and Te Mahurehure Marae Kāinga Atawhai housing project are good examples of Council, Te Puni Kōkiri and MHUD collaborating to contribute to planning, building and development led by Māori communities.

An adaptive and responsive system

4.15     Council supports the desire for an adaptive and responsive system, but this also needs to be a system that delivers a quality urban environment.

4.16     Council notes that the use of adaptive and responsive appears to be heavily weighted towards response to growth pressures. Alignment with the vision of the GPS-HUD would encourage that these adaptive and responsive principles are considered in a more balanced way so that long-term environmental, resilience, equity, and urban outcomes are not lost in the pursuit of short-term growth targets.

Gaps in vision and outcomes

4.17     Council considers that the explanation of the vision set out in the document (page 30) could include more context. In particular, we would like to see it be more explicit and inclusive about the diversity of people in communities. The housing crisis in Auckland is being experienced most acutely by lower income and vulnerable communities, including Māori, Pacific people, and other minority and marginalised groups, such as persons with disabilities, single parents (particularly single mothers), young people and children, and those living in poverty.

4.18     To be effective, there needs to be alignment between the GPS-HUD and the existing and anticipated future policies that will be used to deliver the GPS. From an environmental perspective, Council suggests integration of concepts such as Te Mana o te Wai and Te Oranga o te Taiao across the GPS outcomes. These concepts are central to existing and likely future resource management legislation and policy, and place the health of freshwater and the environment above all other considerations.

4.19     Council notes that there is direction to Kāinga Ora later in the document to avoid development in areas with increasing exposure to hazards.  We recommend that natural hazards are also included in the GPS vision and outcomes, with avoidance of existing as well as increasing hazards as a principle for urban development, in order to apply to all considerations under this GPS.

Do you agree that the proposed focus areas will help us realise the outcomes we want to see? What else should be the focus?

4.20     Council generally agrees that the proposed focus areas provide the appropriate setting for the planned outcomes.

4.21     Council considers that there is scope to include a separate focus area on the natural environment and climate. At the moment, natural environment and climate considerations are part of the ‘supporting resilient, sustainable, inclusive and prosperous communities’ focus area. While we recognise that natural environment, climate and social and economic wellbeing considerations are inherently connected, the role of housing and urban development in the delivery of climate change outcomes (such as adaptation, mitigation or resilience) and natural environment outcomes (such as biodiversity, water quality, waste generation and ecosystem health) is significant. The existing housing and urban development system has played a significant role in observed environmental degradation in Auckland and the GPS-HUD, together with new and anticipated environmental legislation, provide good opportunities to change that. Because of this, Council considers that the natural environment and climate could be afforded its own focus area distinct from other important considerations, such as the inclusivity and prosperity of communities.

4.22     Council would support more explicit consideration of urban land uses other than residential in the focus areas. We would like to see more attention given to the role of business and industry land uses, open space zones, and the wider suite of urban land uses, and their importance in a well-functioning, efficient urban built form.

4.23     Council notes that a critical piece of work will be the development of implementation plans for the actions underpinning the focus areas. These implementation plans need to be developed in partnership, have a long-term view, and have appropriate funding and financing solutions underpinning them. They also need to include agreed measurable targets or indicators to clearly identify whether progress is being made on the outcomes and focus areas set out in the GPS.

Ensure that more affordable houses are being built

4.24     Council strongly supports a focus by government on increasing the supply of housing across the housing spectrum, and particularly on ensuring that more high-quality, affordable houses are built in Tāmaki Makaurau. Auckland’s future economic and social prosperity will be underpinned by its ability to provide secure and healthy housing that people can afford to own or rent. Auckland Council is taking a leadership role to increase the supply of, and access to, affordable housing as part of the Auckland Council and Government Auckland Housing and Urban Growth Joint Programme. To support this, in 2020 Council approved an Affordable Housing Forward Work Programme focused on Council’s key policy and regulatory powers.

4.25     Council believes that additional tools and approaches will be needed to deliver affordable housing in Auckland, and these need to be addressed in the GPS. Enabling the use of inclusionary zoning through legislative change would provide councils with another tool to ensure housing ownership is achievable for more of those who would otherwise struggle to buy. Council supports moves to increase build-to rent-developments and would like to see the Government facilitate greater investment into this sector. We welcome the recent greater provision of social housing in Auckland and would urge further investment in both state housing and community housing providers.

4.26     Building more homes will also require an enduring system for infrastructure funding and financing to be put in place.

·      The extent of the current infrastructure funding and financing issue is alluded to in the discussion document, but Council is of the view that it is not articulated as strongly as it needs to be. Infrastructure also appears to refer to ‘new’ infrastructure, but the ability to pay for maintenance, renewals and operation of existing infrastructure is equally as important.  

·      Council does not agree with the view expressed in the document that “many councils are unable to pay for the infrastructure required to support increased housing supply at the pace needed because they are reaching their debt limits, their ratepayers are unwilling or unable to pay, and they lack all the necessary tools and incentives to shift behaviour.” This needs to be articulated differently. While some shift in behaviour may be required on the part of communities, council and central government, the fundamental issue is rather a lack of system for infrastructure financing and funding in New Zealand to allow growth to occur successfully.

·      A fundamental rethink of infrastructure provision is required if we are to achieve the outcomes set out in the discussion document. Discussion of infrastructure funding and financing in the GPS needs to be expanded to include:

·   Bolder thinking - the Infrastructure Funding and Finance Act may be a useful tool in the medium to long term in some situations, but is unlikely to address the infrastructure funding challenges in the short term.

·   A new way to fund and finance infrastructure is needed – both capex and opex

·   A stronger statement about what a new business-as-usual for infrastructure funding and financing would look like.

·          Council would like to see the GPS recognise more strongly the importance of the joined-up approach that is needed between central and local government, infrastructure providers, and Crown agencies around infrastructure provision. At present this is discussed in terms of conversations and relationships but for the GPS to be successful, the joined-up response needs to be strong, with an effective system and decision-making.

·          A central and long-term view of planned infrastructure will play an important role in coordinated work to achieve the vision of the GPS. However, it is important that a managed infrastructure pipeline accommodates a dynamic-adaptive approach to planning for the infrastructure needs of our current and future communities. This would mean the pipeline would have frequent review and the ability to process new information/projections. This approach would reduce the risk of locking in infrastructure solutions now that may not be optimal in the long-term.

4.27     Council questions the assumption under this outcome that we need to “free up more land”. It is not clear, and no evidence is provided on, what “freeing up more land” refers to, what amount “more” would be, or who would pay to free up that land. Auckland already has a significant amount of zoned land and enabled development capacity. If freeing up more land refers to outward greenfield expansion, this would appear to run contrary to the outcomes the rest of the GPS seeks to achieve and have a significant impact on the ability to deliver infrastructure to achieve the desired outcomes in the GPS. 

4.28     Council strongly believes that increasing the supply of affordable housing should not come at the expense of environmental outcomes such as waste generation or water quality, or creating sustainable urban development and thriving communities. Affordable housing needs to be close to public transport, community facilities and services, and have good access to employment.

4.29     Council would like to see greater consideration in the GPS of transport costs as part of housing affordability. Household transport costs are inextricably linked with housing location. The cost of living in a particular house includes not just the cost of purchasing or renting that house but also the on-going cost of travelling to and from that house. Achieving more affordable housing in locations with poor or expensive transport choices would offset some, if not all, of the affordability savings and undermine the ability to achieve the vision and outcomes of the GPS.

4.30     Council supports better alignment between local and central government in decisions on land use, transport and other infrastructure. Council’s in-depth knowledge of our communities, infrastructure and local context are a critical element in the delivery of the outcomes and vision set out in the GPS.  Decisions in these areas should be aligned with investment decisions.

4.31     Finally, Council considers that this focus area needs to better address the competitiveness of the building supplies sector. While the cost of building materials themselves is not the main problem when it comes to the cost of construction (land and associated infrastructure are the largest cost components of residential housing development), it is a contributor. If competition issues in the sector are tackled, this may have some impact on housing affordability in the medium to long term.

Provide homes that meet people’s needs

4.32     As noted above, Auckland will likely require another 332,000 to 384,000 dwellings over the next 30 years. Not only do we need more good quality housing to be built, but we must also ensure that a range of housing types and sizes are built across the region. We need to build more apartments, including for individuals and large families, and townhouses, of different sizes and price points. Other examples could include intergenerational, papakāinga-style, and communal, or co-housing. This will reflect the fact that Aucklanders’ lifestyles and housing preferences are changing. For example, there has been positive take-up of terraced housing and apartments that are close to transport corridors and nodes in recent years.

4.33     Council is pleased to see language such as “accessible” in relation to housing. Auckland Council has long been an advocate for the improvement of accessibility in New Zealand homes. However, we consider that there is a lack of clarity and consistency in the use of the term “accessible” throughout the discussion document. Accessible appears in relation to housing at times, and at other times is completely absent. In some circumstances, accessible is referring to access to jobs or transport, but not necessarily that the transport itself is accessible to disabled people. Council would like to see better definitions of the term and more consistency in how it is used throughout the GPS. Council would also like to see more evidence of the need for accessible housing presented in the GPS. This need is most pronounced amongst disabled people, Māori, Pacific people, older adults, and those with lower incomes. If adequate evidence around this need is not clearly stated, there is a risk that the issue will not be adequately addressed. 

4.34     Council supports the focus on increasing the supply of homes that meets people’s needs as our demographics change.

·      Auckland’s population is ageing. The ability to find suitable and affordable housing in Auckland is not always straightforward for older people. The available housing stock often does not meet their needs – 59 per cent of adults over the age of 65 have at least one impairment, which greatly increases the need for accessible housing. The percentage of people reaching retirement with no mortgage has been dropping in recent years, and the costs of owner-occupied and private and social rental housing are increasing. Also, the overall quality of the housing stock is poor, particularly the quality of rental stock, which has both health and safety implications.

·      Auckland's Māori and Pacific populations will continue to have relatively younger age structures due to their higher birth rates. Māori and Pacific peoples have seen no increase in home ownership over the past 30 years, something that has traditionally provided households with both a secure home and greater intergenerational wealth. If Māori and Pacific peoples are to enjoy the security of tenure, social mobility and levels of wellbeing in line with other groups, their poor housing outcomes cannot continue. In addition to the partnership approach with Māori to improve Māori housing outcomes, Council welcomes the action around implementation of the Pacific Housing Strategy to improve the housing outcomes of Pacific People.  

·      Multi-generational households are increasing across all ethnic groups, driven by various demographic, social and financial reasons such as people marrying later, cultural traditions, childcare arrangements, caring for elderly and so on. Many Māori and Pacific aspire to have inter-generational living. There is a real need to build larger houses, look at new models of ownership and design, and cater for the social wellbeing needs of multi-generational households.

4.35     Council supports the focus on improving housing quality. Cold and damp housing, including in our state housing stock, is a serious issue, affecting the health and wellbeing of many Aucklanders. Council is pleased to see a focus not just on the quality of existing dwellings, but also on sustainable design and construction of new dwellings which will be important not just for health and wellbeing outcomes, but also to support the move to a low-carbon, climate resilient future.

4.36     Council would welcome greater recognition in this focus area on peoples’ needs more broadly, particularly within the scope of access to urban ngahere, public and private green spaces or public open spaces.

4.37     We would also like to see more emphasis in the actions on the role of the Building Act and Building Code in improving wellbeing through housing.  For example, the Building Act is where accessible housing needs to be addressed, and where improvements can be made to minimum building standards to help improve the quality of housing.

Support resilient, sustainable, inclusive and prosperous communities

4.38     Council supports the aspirational outcomes that are identified in this focus area, such as climate change resilience, improved biodiversity, better public transport and active transport links and local economic development. These outcomes are generally well aligned to the Auckland Plan and Council objectives.

4.39     Council would like to see this focus area given stronger policy direction, allowing it to be given sufficient weight when balanced with the other focus areas.

·      Rather than “support”, this focus area could be reworded as “ensure resilient, sustainable, inclusive and prosperous communities”, which would signal the importance of this focus area, and encourage it to be considered alongside the provision of new, affordable, fit-for-purpose housing, and taking care that the communities created are fit-for-purpose too. Currently, Council considers that the wording is not robust enough to adequately achieve the GPS-HUD vision, particularly the second half of that vision around “a thriving, inclusive, and sustainable community.”

·      Council anticipates that when faced with pressures of developers wanting to provide residential development in unsustainable locations, this focus area would lose out to others with stronger, more directive language. Council regularly faces challenges with private plan change requests and resource consent applications proposing residential and urban land-uses on highly productive land and in poorly connected rural locations, residential development in areas strategically planned for business uses, and urban development in areas of significant environmental value, where resulting environmental degradation would be significant. To allow these to continue, and not provide rigorous policy support to push back on such proposals, would critically undermine the vision set out in the GPS-HUD.

4.40     Council notes that the proposed outcomes in this focus area do not align with existing delivery vehicles, such as the NPS-UD, which is silent on natural environment outcomes. Actions supporting this focus area must consider how implementation mechanisms can be aligned to effectively deliver on the desired aspirations. Actions also need to better link to the desired outcomes – for example Council would support a more explicit action around restoring water quality and biodiversity.

4.41     Council strongly supports the recognition that addressing climate change requires urgent investment in better transport options (including more walking, cycling, and public transport) and better urban land use to accelerate development in the places that increase access and reduce travel times. We agree that homes need to be constructed in well-designed communities built around public transport and active transport networks, allowing reduced private vehicle use and promoting mode shift, with good access to employment. Staging and sequencing is key here to ensure development happens in the right place at the right time that ensures alignment with planned and funded infrastructure.

4.42     Council supports this focus area recognising the importance of developing strong, thriving and resilient local economies. To support the focus on ensuring communities are connected to jobs, council recommends the inclusion of a specific action around supporting local employment and better access to employment.  Auckland Council’s Economic Development Action Plan 2021-2024 includes an action around developing a consistent economic development planning approach to Auckland’s identified urban growth locations and new economic areas. 

4.43     Council would also like to see more of a focus in this section on building affordable, low-carbon homes. Although de-carbonisation is mentioned, there are no clear directions on reducing embedded carbon within infrastructure and housing or the materials used. Truly sustainable, zero-carbon communities need to think about the life cycle of materials utilised and the embedded carbon values of the construction, combined with zero or low emission targets.

4.44     There is minimal acknowledgement in the discussion document of the significant amount of waste generated from housing construction and demolition activities, and associated environmental, cultural, social and economic costs. In terms of construction, Council’s own research indicates that practices such as over-ordering are commonplace – for example each new house built is estimated to generate, on average, around four tonnes of waste with discarded materials valued at $31,000. These are materials the homeowner pays for but neither sees nor gets any benefit from. Actions that promote the avoidance and reduction of waste during housing construction and demolition should be explicitly incorporated within this focus area, as well as through Kāinga Ora’s role to “manage its functions and operations to mitigate and adapt to the effects of climate change”.

4.45     Council would like to see additional actions in this focus area:

·          an action highlighting the importance of, and giving weight to, sound strategic land use planning in the form of spatial plans, structure plans and land supply strategies. To prevent an “intensification at all costs” approach, weight needs to be given to prioritising and implementing robust strategic planning.

·          a more explicit action around restoring water quality and biodiversity.

·          an action that focuses on supporting places as they evolve and change in response to climate change, demographic shifts, technological advances and changes to Auckland’s urban form. Any investment in new or existing community services infrastructure needs to ensure assets are adaptative and flexible to respond to changing customer preferences and the dynamic nature of communities.

Invest in Māori-driven housing and urban solutions

4.46     Council welcomes the partnership approach being taken with Māori and we support a Te Tiriti response to Iwi and Māori housing aspirations that the GPS has sought to embrace. A critical piece of work will be the development of implementation plans for the programmes that will underpin this approach. For all sectors, this will require the building of capacity and capability, a willingness to see systemic change, and integration across all organisations involved. 

4.47     Council would like to see greater recognition in the GPS-HUD of the need for systemic change across not just government housing and urban development agencies and local government, but also across social sector agencies (such as the Ministry of Education, Ministry of Corrections and District Health Boards) to address many of the structural and systemic issues/barriers that have culminated in Māori being disproportionately positioned at the lower end of the housing spectrum.

4.48     Council is concerned at the risk of a disconnection between what central and local government ‘place-based’ spatial priorities are, and what Māori consider to be priority areas. For example, less than 1 per cent of land in Auckland is Māori land. The majority of this is located on the regional periphery or is island-based with limited infrastructure. These areas will potentially be viewed as low priority due to location and development scale, yet are critical to Māori. This disconnect may limit access to development opportunities and resources. This issue will need to be explored in the implementation plans falling out of the GPS-HUD and MAIHI approach.

4.49     Māori-driven housing needs to also embrace and include remote rural communities. There is an assumption that Māori Freehold Land (MFL) is for new kāinga developments, for those returning to the whenua, and ignores the fact that many do reside on Māori Freehold Land in substandard housing in New Zealand’s rural communities. In the Auckland region and across rural New Zealand, there are housing quality and equality issues for Tangata Whenua – Haukinga and Ahi kaa residing on Māori Freehold Land, living in traditional communities. Access to housing upgrades is needed. There are major barriers to access the appropriate funding, raising capital, and consent to reside on their lands.

4.50     As noted in our commentary on substantive issues, Council would like to see more discussion in the GPS-HUD on the role of Māori housing providers and how government will support building capability in the sector. In Auckland, Kāinga Ora building consent activity constitutes approximately 8-10 per cent of housing activity each month. This suggests that Kāinga Ora cannot produce sufficient housing on its own to deliver on the GPS-HUD outcomes proposed unless it forms partnerships with the private sector and others, including Māori housing providers.

Prevent and reduce homelessness

4.51     Data from 2018 shows that there were over 18,000 people homeless (living without shelter, in temporary accommodation or sharing temporarily, or living in uninhabitable dwellings such as garages and sheds) in Tāmaki Makaurau.

4.52     In 2017, Auckland Council agreed that homelessness should be “rare, brief, and non-recurring” and has placed homelessness high on its agenda. We therefore support the focus on preventing and reducing homelessness in the GPS-HUD.

4.53     Council is supportive of the National Homelessness Action Plan. The objectives of the plan closely align to the objectives agreed by Council in 2017. Council is supporting the plan by coordinating regional collaboration, participating in government projects, and changing and improving Council operations to achieve better outcomes for people who are homeless.

4.54     The first COVID-19 lockdown occurred after the release of the National Homelessness Action Plan. During the lockdown, extensive support was offered to people who were homeless, including provision of motel accommodation and wraparound support. Ensuring a path from emergency accommodation to stable, secure long-term housing with wraparound services to deal with causes of homelessness such as mental health and addiction is critical. Council is pleased to see recognition of the importance of these services in the discussion document.

Re-establish housing’s primary role as a home rather than a financial asset

4.55     Council welcomes a focus on ensuring that the housing market responds to housing need rather than investment priorities. The Auckland Plan recognises that the right to adequate housing is a basic human right for all Aucklanders.

Do the proposed ways of working reflect the approach that is required from government?

4.56     Council agrees that the proposed ways of working generally reflect the approach that is required from government.

Place-based approaches

4.57     Council supports the recognition that place-based approaches are appropriate, as a one-size-fits-all solution will not work. The scale and complexity of Auckland means the challenges we face, and our relationship with central government, are different from other local authorities.

4.58     Council strongly believes that place-based approaches need to be innovative and move us away from business-as-usual activity to new models and ways of working. Doing what we have always done, or making small changes around the edges, will not solve Auckland’s housing crisis or deliver the social, environmental, economic or cultural outcomes council and government are seeking.

4.59     Innovative place-based approaches will be particularly important if we are to address existing inequity issues in Auckland. Communities need tailored solutions that work for them in each place, and solutions will need to be targeted and developed collaboratively to meet their needs. One way of doing this is to look for opportunities to retain and enhance place-based planning through District/Unitary Plans as part of achieving a well-functioning urban environment.

4.60     It will be important to consider the scale at which ‘place-based’ approaches are used. This is particularly important when it comes to the planning and provision of infrastructure. For example, Tāmaki in Auckland is a ‘place’, but the infrastructure network that serves it extends Auckland-wide.

4.61     Government agencies – particularly Kāinga Ora – need to work collaboratively with Council on their spatial priority developments from strategic planning through to delivery, as councils often have the legacy and contextual understanding of the places where change is going to happen. This is not about duplicating work, but rather utilising the resources and expertise of both organisations and working better together to achieve agreed outcomes. Working with the private development community will also be key as they must be a viable contributor to providing affordable housing in Auckland.

4.62     Council supports the naming of the housing and urban development focus areas in Auckland that have been agreed through the Auckland Urban Growth Partnership and are reflected within the Auckland Transport Alignment Project and Regional Land Transport Plan. We support the continuation of this Partnership as a collaborative approach to integrating infrastructure and land use planning. These focus areas must, however, be considered in the broader context of the region to avoid creating inequities and undermining broader outcomes.

Genuine and enduring partnerships

4.63     Council supports the recognition in the GPS-HUD that implementation requires government to collaborate and partner with others with key roles, including local government as one of the four ‘ways of working’. Effective partnership with government is essential to Auckland’s future. Council and government have a history of forming good partnerships on critical issues, including through mechanisms such as the Auckland Housing Programme and Joint Work Programme on Housing and Urban Development, and this provides a strong foundation for close cooperation.

4.64     As noted above, the scale and complexity of Auckland means our relationship with central government is different from other local authorities. In addition to effective partnership with government, we also need joined-up planning, investment and decision making that delivers on our joint aspirations and supports capability and capacity building across the system. Council believes there needs to be a stronger commitment to improved partnering and collaborative working from both central and local government, so that we can approach development and resolve issues in different ways.

4.65     Council also notes that clear and consistent direction from central government will be necessary to support alignment and partnership. As noted previously, local government must give effect to national policy statements, many of which conflict with each other and/or do not align with, or are silent on, the aspirations of this GPS-HUD. This will make implementation, stakeholder alignment, and genuine partnership on achieving the vision and outcomes set out in the GPS-HUD extremely challenging.

4.66     Council welcomes the focus on developing meaningful relationships with local voices and communities. However, it is unclear how this will be achieved through the detail provided in the discussion document. Council would welcome more clarity on, for example who will determine affected communities and who will lead engagement with those communities.

4.67     Council would like to see more emphasis in the GPS on partnerships with infrastructure providers, both public and private. Currently, partnerships with infrastructure providers appear to be mixed in with partnerships with local government, but not all are part of local government.

4.68     Council would also welcome more evidence of early and ongoing collaboration with the disability community. Inaccessible housing is one of the top issues for disabled New Zealanders, and their needs and input should be reflected in the GPS.

Sustainable and reliable funding

4.69     Council agrees that investment in housing and urban development has been ad hoc and variable, and that the system needs to work differently to provide sustainable and reliable funding (both public and private).

4.70     We support the need to develop sustainable and reliable funding to enable Kāinga Ora, other agencies, and local government to plan ahead to deliver essential housing and urban development. Auckland’s RLTP and LTP support the Auckland Housing Programme by allocating funding over the next 10 years for infrastructure. However, there are competing demands for other transport-led initiatives such as light rail and Drury that will involve significant additional CAPEX spend if approved by central government and commissioners respectively. Large-scale infrastructure investment for major programmes of work will need to be funded and financed from both local and central government in order to achieve consistent delivery. The current mechanisms available to local government are insufficient and unsustainable.

4.71     Council is of the view that central government needs to focus on a small number of policy initiatives and prioritise development areas in order for all parties to get ‘best bang for buck’. The Auckland Plan sets out development areas where significant growth is anticipated over the next 30 years. This includes consideration of potentially significant sites. Historically government has had a diverse portfolio of sites which it has sought to develop/re-develop at the same time. This means that its efforts and those of partner organisations can become diluted with poor results. An integrated spatial, infrastructure and funding plan would enable everyone to be working towards an agreed outcome.

4.72     Council supports the regular review of finance tools to enable growth. Auckland Council has raised funds through green bonds used for transportation projects including rail electrification, the CRL, public cycling and walking infrastructure as well as energy efficiency projects for LED street lighting and green building upgrades. Government and local government agencies will need to find new and innovative funding and financing tools to enable it to deliver on GPS expectations.

4.73     Council believes this section needs to articulate better the big and bold thinking that is required to solve a broken infrastructure funding and financing system. Council would like to see the language in this section be stronger, and the discussion expanded to include:

·          Bolder thinking - the Infrastructure Funding and Finance Act will be a useful tool in the medium to long term but is unlikely to address the infrastructure funding challenges in the short term.

·          A new way to fund and finance infrastructure – both capex and opex

·          A stronger statement about what a new business-as-usual for infrastructure funding and financing would look like.

Are there any actions that need more emphasis, or which are missing, to deliver the outcomes?

4.74     Council would strongly support a more explicit action around delivering good quality urban design. This needs to be incorporated across all aspects of place where people live, work and play. As we move towards developing a more intensified urban form, we need to ensure the supporting infrastructure, public transport and social and community facilities make this viable. It is also critical that every part of “place” contributes towards achieving quality well-functioning urban environments.

4.75     Council considers that there could be more explicit actions to support the ‘Adaptive and responsive system’ outcome. At present, the line of sight between that outcome and the various focus areas and actions is weak.

4.76     Council would like to see more recognition in the document of the tensions between actions – particularly between growth at pace and quality environmental, resilience and urban development outcomes. For example, infrastructure has an important role to play in delivering both the growth quantum and the quality outcomes sought. However, in order to achieve both, high quality infrastructure decision-making is required, which can take time. This can be supported (and re-work in the infrastructure development process avoided) through early-phase infrastructure decision making that is connected, adaptive and long-term focused. The GPS can support this early decision-making with clear national direction and alignment.

4.77     The GPS sets out a vision and outcomes relevant across Aotearoa New Zealand. However, the actions and delivery mechanisms are weighted heavily towards the developments being delivered by Kāinga Ora. It is important, therefore, to be mindful of the potential for perverse or unequal outcomes if the effect of action under the GPS is to pull both central and local government infrastructure resources towards only a few comprehensive developments, reducing the ability to deliver on the vision in other locations. 

What actions could you, or others in the system, contribute to delivering on, and what type of support would be needed?

4.78     The Auckland Council group, with Māori partners, would like to be involved in ongoing implementation and monitoring of the GPS-HUD as shared infrastructure and growth data will be key to the coordinated action required to deliver on the vision of the GPS.  Council acknowledges it is important to share critical data sets that impact decision making and support the evidence base. Council would like to see clear, agreed definitions of key terms and data standards to promote interoperability, good governance and transparency of decision making. We note particularly that shared infrastructure data is being considered through the development of the New Zealand Infrastructure Commission’s 30-year strategy and if centralised sensibly this would lead to a broad-based improvement in understanding the state of our assets, better planning, and better value for ratepayers and taxpayers. It would also potentially reduce the cost of infrastructure.

What additional, or new, expectations of Kāinga Ora do you think should be included? What about expectations of other agencies?

4.79     The opening statement on what the Government requires of Kāinga Ora (page 70) needs to include recognition that Kāinga Ora needs to work not just with other government agencies, but also with local government. Councils are critical partners for Kāinga Ora, and Kāinga Ora will not succeed unless it works alongside Councils to undertake its functions.

4.80     The GPS needs to clarify how Kāinga Ora (and MHUD) will work with the private sector. In the Auckland context, Kāinga Ora building consent activity constitutes approximately 8-10 per cent of housing activity each month. This suggests that Kāinga Ora cannot produce sufficient housing on its own to deliver on the GPS outcomes unless it forms partnerships with the private sector and other house-builders.

4.81     Council would like to see a number of additional actions for Kāinga Ora:

·          Kāinga Ora should be required to develop shared spatial plans with Council that are supported by funding from other agencies such as MHUD, Waka Kotahi, Ministry of Education, Ministry of Health and so on. Integrated spatial plans should enable communities and the infrastructure required to support them to be planned efficiently and effectively.

·          Kāinga Ora needs to provide homes in the right place at the right time to support well-designed communities built around walking, cycling and that support existing or planned and funded public transport routes and with good access to employment.

·          Kāinga Ora needs to support local employment through its planning and design of communities.

·          Kāinga Ora should lead by example in relation to environmental outcomes – such as demonstrating how natural environments can be restored through urban development rather than simply avoiding, remedying and mitigating effects. This could include specimen tree planting in landscaping, green infrastructure, water sensitive design, stream daylighting / riparian planting and so on. Kāinga Ora should also be designing to minimise waste during site clearance, building, and occupation of the housing they develop.

4.82     The GPS needs to clarify how other Crown agencies are expected to support the urban growth initiatives set out in the GPS-HUD – for example Treasury, Ministry of Education, Ministry of Health, Ministry of Business, Innovation and Employment, Waka Kotahi, NZ Police - as there needs to be a holistic approach taken to address broader issues that go beyond the provision of a physical home. For example:

·          The Ministry of Education working with schools in urban areas where significant growth and density is being unlocked to look at new models for schools being used for shared community purposes (buildings, facilities, playing fields), and working alongside transport agencies to ensure these schools are integrated with the transport network.

·          The Ministry of Business, Innovation and Employment and other agencies on opportunities to unlock/support local economic development and employment opportunities new or within growth locations

4.83     Auckland Council considers that all central and local government agencies involved in the planning and delivery of housing and urban development need to embrace innovative approaches and evolving changes regarding trends and drivers such as the changing nature of work/employment, climate change mitigation & adaptation, technological advancement, move to a circular economy and so on.  Whilst it’s identified for MHUD to play a lead role in this space – this needs to be more widely embraced across all agencies involved in the delivery of urban development.

 

5    Wording Changes

5.1       In addition to the points raised above, we have identified several smaller changes that we would like to see in the final version of the GPS-HUD for clarification and completeness purposes. These changes are outlined below:

Section/Page

Suggested Amendment

Implementation Plans

P11

The direction-setting and implementation diagrams are heavily weighted towards central government strategies and frameworks. It would be useful to amend the diagram to include reference to legislative 30-year spatial plans (Auckland Plan) which set out the aspirations of Aucklanders and provide guidance for Auckland Council.

Roles and responsibilities

P19

Add “significant role in funding and financing” to both the local government and central government boxes. It is in the private sector box so it’s not clear why it’s not included for local or central government.

Action is needed today

P22

A useful addition in the “A snapshot of today” box would be a bullet point on the current infrastructure deficit

The housing and urban system

P25

Recommend the addition of reference to funding in the last sentence – “Transforming housing and urban outcomes here requires careful coordination and action across the whole system, and a sustainable and reliable funding mechanism.”

The housing and urban system (image)

P26

For the bottom image on the page, Council recommends the addition of a reference to infrastructure maintenance, not just new infrastructure – i.e. “We build enough infrastructure and housing in the right places at the right cost, and maintain and operate our infrastructure at the right cost and in a way we can afford.”

Thriving Communities

P32

Recommend that “planning for and investing in changing infrastructure needs” may be better expressed as “planning for and investing in an adaptive approach to infrastructure provision in response to changing pressures and needs”.  This would encourage a broader approach to long-term infrastructure planning.

 

Recommend the addition of an additional bullet point under “what we expect to see” heading - “No infrastructure deficit and the ability to pay for the infrastructure we need.”

An adaptive and responsive system – What we expect to see

P37

Recommend the language in the first bullet is strengthened and says “Partnerships, collaboration, joined-up decision making, and funding and financing arrangements across the system that deliver…”

 

Recommend the addition of reference to funding and financing in the fourth bullet point, i.e. “better connection and alignment between central and local government planning and decision-making, and government processes, along with infrastructure funding and financing solutions that will work for the scale of what is needed.”

Ensure that more affordable houses are being built

P40

Recommend that “free up more land” in the section sub-heading is replaced with “enable more development”.

Ensure that more affordable houses are being built

P40 – What we are responding to

Council recommends the third bullet point be articulated differently. We need a fair infrastructure funding and financing regime that works successfully for all parties. 

Ensure that more affordable houses are being built

P41 – What we expect to see

In the second bullet point, suggest the addition of “including aligned infrastructure financing and funding”, i.e. “integrated and aligned strategies for land use, transport, infrastructure investments and upgrades, and social infrastructure, including aligned infrastructure financing and funding

Ensure that more affordable houses are being built

P42 - What needs to change

Recommend that “maintaining a steady supply of land” in the first paragraph is replaced by “maintaining a steady supply of development capacity”, which would capture both brownfield and greenfield development. 

 

Recommend the third bullet point is changed to “partnerships that drive strategic growth planning that meets the focus areas across the GPS-HUD, for example, regional spatial plans with a direct link to infrastructure financing and funding

Ensure that more affordable houses are being built

P43 – Proposed Actions

Suggest replacing bullet point “using new vehicles such as the IFF…” which focuses on current tools with the following:

 

“Incorporate an enduring “BAU” for infrastructure financing & funding solution for both Capex and Opex

·    that takes into account the scale of the problem and provides realistic solutions and tools to solve the problem

·    that provides a system wide solution to provide certainty for all parties (rather than one off ad hoc solutions)

·    Noting that: Where tools that are suggested as solutions are found to not assist, that tools are developed with a full understanding of the problem and the realistic solutions that are possible & achievable”

 

Support resilient, sustainable, inclusive and prosperous communities

P47 – What we are responding to

Recommend the addition of a sentence on the role that housing and urban development plays (and has played historically) in natural environment degradation, greenhouse gas emissions, embodied carbon, and the vulnerability of communities to climate change.

Support resilient, sustainable, inclusive and prosperous communities

P49 - proposed actions

In the action on integrating government investment, it is not clear what is meant by “underutilised transport assets”. We recommend using language that is consistent with:

·    the Climate Change Commission in its report Ināia tonu nei: a low emissions future for Aotearoa which talks about “optimising existing systems, such as reallocating road space and creating low-traffic neighbourhoods or streets” 

·    the Ministry of Transport in its recent discussion document Hīkina te Kohupara – Kia mauri ora ai te iwi - Transport EmissionsPathways to Net Zero by 2050'

Government agency action

P68 – table

The actions need to address who is responsible for developing and implementing a new system for infrastructure funding and financing. Council recommends the addition of an action or owner for “infrastructure financing & funding system & solution”.

 

 


<<appended local board submissions>>


Franklin Local Board

24 August 2021

 

 

363

DRAFT 13 July 2021Submission to the Ministry of Housing and Urban Development
In the matter of the Discussion Document on the Government Policy Statement on Housing and Urban Development
Auckland Council, July 2021

Mihimihi

 

Ka mihi ake ai ki ngā maunga here kōrero,

ki ngā pari whakarongo tai,

ki ngā awa tuku kiri o ōna manawhenua,

ōna mana ā-iwi taketake mai, tauiwi atu.

Tāmaki – makau a te rau, murau a te tini, wenerau a te mano.

Kāhore tō rite i te ao.

 

 

I greet the mountains, repository of all that has been said of this place,

there I greet the cliffs that have heard the ebb and flow of the tides of time,

and the rivers that cleansed the forebears of all who came those born of this land

and the newcomers among us all.

Auckland – beloved of hundreds, famed among the multitude, envy of thousands.

You are unique in the world.

 


 

 

AC new logo_horz_cmyk 

 


Ko te tāpaetanga o te Kaunihera o Tāmaki Makaurau

Auckland Council Submission                                                                             30 July 2021

 

Auckland Council Submission on the Discussion Document: Tuākī Kaupapa Here A Te Kāwanatanga Mō Te Whakawhanake Whare, Tāone Anō Hoki | Government Policy Statement on Housing and Urban Development

 

Submission to the Ministry of Housing and Urban Development

 

1          Introduction

1.1       Auckland Council is pleased to have the opportunity to submit on the discussion document: Tuākī Kaupapa Here A Te Kāwanatanga Mō Te Whakawhanake Whare, Tāone Anō Hoki | Government Policy statement on Housing and Urban Development (“discussion document”).

1.2       This submission represents the views of the Auckland Council group (the council), which includes Auckland Council, Auckland Transport, Eke Panuku Development Auckland (Eke Panuku), Watercare Services Limited (Watercare) and Auckland Unlimited. Input has also been received from the Independent Māori Statutory Board. 

1.3       The Chair and Deputy Chair of the Planning Committee, and a member of the Independent Māori Statutory Board, are designated signatories of this submission. The submission includes input from X Local Board(s), and their input is appended to this submission.

1.4       The council’s submission consists of discussion of the issues it considers most substantive, followed by responses to the questions set out in the discussion document. The substantive issues discussed are:

·      Auckland’s growth and urban form

·      Funding and financing challenges

·      Misalignment between Government policies and strategies

·      Partnering with Mana Whenua and Mātāwaka to deliver better Māori housing outcomes

·      Enduring partnership between local and central government

 

2          Tāmaki Makaurau Auckland Context

2.1       Auckland Council is a unitary authority and the largest local government agency in New Zealand. Its unique governance structure includes: a governing body focusing on region-wide strategic and regulatory directions; 21 local boards making decisions on local issues and representing Auckland’s diverse communities; council-controlled organisations (CCOs) who look after specific council assets, services or infrastructure; and an Independent Māori Statutory Board, which has a statutory responsibility to promote Issues of Significance to Māori (Mana Whenua and Mātāwaka) in Tāmaki Makaurau Auckland and to monitor Auckland Council’s performance in responding effectively to these. Auckland Council also works in partnership with mana whenua entities, who represent the interests, mātauranga and tikanga of mana whenua of Tāmaki Makaurau.

2.2       Auckland is home to one-third of New Zealand’s population, with 1.7 million people. Over the next 30 years, this could increase by another 720,000 people, potentially requiring another 332,000 to 384,000 dwellings and 263,000 jobs. The rate and speed of Auckland's population growth puts pressure on our communities, our environment, and our housing and infrastructure networks. It also means increasing demand for space, infrastructure, and services necessary to support this level of growth.

2.3       About one per cent of the total land area of Tāmaki Makaurau is Māori Land, while some 10 per cent of the Māori population in Tāmaki are Mana Whenua, the rest identifying as Mātāwaka. Nearly a quarter (23.4 %) of the total New Zealand Māori population live in Tāmaki.

2.4       Much of Auckland's appeal is based on the natural environment, but this is vulnerable to degradation from the impacts of human activities. Despite regulation and considerable effort, Auckland's environment continues to be affected by past decisions, Auckland's rapid growth and development, as well as threats such as climate change.

2.5       There are significant levels of socio-economic deprivation in Auckland, often in distinct geographic areas. Key drivers of this include unequal access to education and employment opportunities, along with high – and often unaffordable – housing costs. With the significant increase in the cost of housing in Auckland, the associated decline in home ownership levels is resulting in fewer Aucklanders being able to fully prosper and thrive.

2.6       The Auckland Plan 2050 recognises these pressures in identifying that to achieve the Auckland we want, we must address the three most important challenges of high population growth, ensuring prosperity is shared amongst all Aucklanders, and reversing environmental degradation. The challenge of mitigating the effects of, and adapting to, climate change is also becoming more urgent.

2.7       The Auckland Plan sets out Auckland’s ambition for housing and urban development in Tāmaki Makaurau. The current housing system does not work for many Aucklanders, and Auckland currently has one of the least affordable housing markets in the world. Growing numbers of Aucklanders are unable to afford to buy a home, rents are straining the budgets of many families, and the number of people who find themselves homeless or living in unsuitable accommodation has increased in recent years. Many Aucklanders live far from jobs and other facilities due to limited availability of affordable housing options. This trade-off between the cost of housing and proximity to jobs and facilities is a driver of spatial inequalities and social exclusion in Auckland.

2.8       The Auckland Plan recognises that holistic thinking and action is needed to change the system, and there are many factors that will need to be addressed if we are to achieve our vision of enabling Aucklanders to live in secure, healthy and affordable homes and have access to a range of inclusive public places. These factors include, but are not limited to:

·      the way we regulate land supply

·      the cost of new infrastructure for development and who pays for this

·      how and where urban development is initiated, and by whom

·      the use of innovative building approaches

·      productivity of the development and building sectors.

2.9       The need for this holistic thinking and action is becoming more and more urgent. The GPS comes at an important time for Auckland where there is a need to look to the future and ensure we can better provide places to work, live and play for generations of Aucklanders to come, while also addressing the significant environmental decline and challenges we are experiencing.

3    Submission – Substantive Points

3.1       The council supports the overall intent of the GPS-HUD, and a detailed response to the consultation questions is provided in the next section. Council would like to highlight the following five substantive points in particular.

Auckland’s growth and urban form brings challenges and opportunities

3.2       Over 1.7 million people currently live in Auckland, and the population is projected to reach 2.3 million by 2050. This growth rate is higher than the national average. To accommodate this growth, Auckland’s urban form and built environment will change significantly. This could mean 332,000 to 384,000 new homes, 263,000 new jobs, increased community services and facilities, and associated supporting infrastructure.

3.3       Auckland is following a quality compact urban form approach to growth to realise the environmental, social and economic benefits and opportunities this approach brings, such as:

·      It allows opportunities for more housing to be built around areas of activity and close to good public and active transport options

·      It improves the efficiency of the substantial investment required in infrastructure – such as transport, water and wastewater – and other services. This also results in the best asset management and infrastructure provision.

·      It means lower travel costs for people and businesses, increased agglomeration benefits, and localised place benefits.

·      It helps to protect our natural environment, reduce emissions, and maintain Auckland’s rural productivity by limiting urban sprawl.

3.4       Recent monitoring results indicate a significant uptake of intensification within the existing urban area in response to the Auckland Unitary Plan’s up-zoning. In the twelve months to April 2021, 66 per cent of development in Auckland took place through intensification and 13 per cent of new dwellings consented were located within 1000 metres of a rapid transit station. Dwelling consents for more intensive typologies such as apartments and townhouses are increasing at a faster rate than consents for standalone houses.

3.5       In our Development Strategy, we acknowledge that areas must be developed in a cost-effective and sustainable way. They also need to be vibrant places for communities who will live there, with a strong network of centres and neighbourhoods, easily accessible by public transport, walking and cycling. These areas also need to provide opportunities for employment, services, and social infrastructure facilities such as schools and hospitals, parks, sports fields, and community facilities.

3.6       As Auckland moves towards developing a more dense and intensified urban form, good quality urban design needs to be addressed at all scales of development. This includes the quality of the city structure, the urban form and function of places, the amenity of all public realm areas such as public places, spaces, and streets, as well as building and house design. The quality of city design is integral to how it functions, which affects our overall wellbeing. Good quality urban design contributes to making places sustainable, attractive, safe, accessible, equitable, desirable and enduring, thus helping to achieve “thriving communities”.

3.7       Council believes greater clarity and emphasis is needed in the GPS on a number of the issues raised above, including:

·      The importance of compact urban form in (1) enabling emissions reductions in urban areas and progressing towards the Government’s net zero emissions target and (2) maintaining vital areas of biodiversity and highly productive land.

·      The need for housing to be linked to local employment opportunities and good public and active transport options.

·      The importance of good quality urban design for all scales of placemaking, from the regional level to the level of individual sites. 

Funding and financing challenges mean complex choices need to be made

3.8       As Auckland’s population grows, we need to provide more services to more people. We need to ensure that there is enough infrastructure – such as roads, water and wastewater pipes, public transport, parks, community facilities and supporting social infrastructure – to accommodate growth. We also need enough infrastructure to support new business developments, as more people will need more places to work and do business. As Auckland grows, we will also need to spend more to mitigate the impacts of growth on the natural environment and the health of our waterways.

3.9       The council is working to maintain its level of investment in infrastructure to support the city’s and country’s economy, whilst simultaneously providing for future growth. However, our borrowings and revenue are currently highly constrained, and it will be difficult to take on new infrastructure priorities for most of the coming decade.

3.10     Local government has significantly fewer mechanisms available to it to raise funds than central government. For example, we can choose to raise rates, but this may cause financial hardship to our residents, particularly those on fixed incomes. Significant rates increases are likely to attract strong public opposition. We can also choose to increase our debt levels and sell or lease surplus properties. In our Ten-year Budget 2021-2031 we have used a combination of all of these tools to enable us to provide the investment into infrastructure, services and protecting our natural environment that Auckland urgently needs.

3.11     Central government has recognised the criticality of infrastructure funding and financing to achieving the housing and urban development outcomes it is seeking, and has started to address the infrastructure deficit through new tools such as the Infrastructure Funding and Financing Act and Housing Acceleration Fund. While these may be useful tools in certain circumstances, Council believes that infrastructure funding and financing needs a fundamental rethink.

3.12     Council considers it essential that the GPS include a stronger focus on the funding and financing challenges that need to be addressed in order to meet the vision and outcomes set out in the discussion document. The need for integrated spatial, infrastructure and funding plans which have a long-term focus should be recognised. The GPS needs to explain the complex choices that will need to be made when there is not enough money to pay for everything, how this complexity will be managed, and how choices and decisions around which outcomes are prioritised will be made. The GPS also needs to be clearer about whose role it is to coordinate and resolve the infrastructure funding and financing problem facing New Zealand.

Better alignment between Government policies and strategies is needed

3.13     The GPS-HUD is the latest Government initiative that impacts on housing and urban development, and the discussion document notes that it is designed to be a system strategy that aligns government policy and activity that affects housing and urban development. In recent times, Council has responded to a range of initiatives, including the Government Policy Statement on Land Transport, Urban Development Act, National Policy Statements on Urban Development (NPS-UD) and Freshwater Management (NPS-FM), Infrastructure Funding and Financing (IFF) Act, Resource Management system review, Building for Climate Change programme, building system reform, draft National Policy Statements on Highly Productive Land (NPS-HPL) and Indigenous Biodiversity (NPS-IB), as well as consultations by the Climate Change Commission and the New Zealand Infrastructure Commission.

3.14     Council would strongly support the GPS-HUD being used to identify where misaligned policies are currently affecting the housing and urban development system, and to provide stronger direction on how to resolve these misalignments and manage the trade-offs that will inevitably be required between multiple outcomes.

3.15     Misalignments between the GPS-HUD and policies such as the NPS-UD, NPS-FM, NPS-HPL and NPS-IB will contribute to an unresponsive and inconsistent planning system and affect the delivery of aspirations in the GPS. For example:

·      Although climate change is both an objective and policy of the NPS-UD, these aims may conflict with other aspects of the NPS-UD such as requiring councils to allow for development moving ‘out’ as well as ‘up’. The NPS-UD requires local authorities to be ‘responsive’ to private plan changes for development in locations, or at times, not previously anticipated. This impacts the council’s ability to plan for future growth, align land use and infrastructure funding and provision, achieve a quality compact urban form, and mitigate and adapt to climate change.

·      The NPS-UD is silent on natural environment outcomes, but the GPS-HUD anticipates a role for urban development in restoring ecosystem health and improving biodiversity, water quality and air quality outcomes.

·      The GPS-HUD talks about avoiding unnecessary sprawl and protecting highly-productive land, yet the proposed NPS-HPL does not preclude development on highly productive land that has already been zoned future urban. In Auckland, highly productive land within future urban zones accounts for 5 per cent of the region’s productive land.

3.16     To be effective, there needs to be alignment between the GPS-HUD and the existing and anticipated future policies that will be used to deliver the vision and outcomes of the GPS-HUD. There is a risk that the GPS will say the right things at the strategic level, but that the policy and implementation underpinning the GPS will take a different approach that will work against the high-level outcomes.

3.17     Council suggests the integration of concepts such as Te Mana o te Wai and Te Oranga o te Taiao within the GPS. These concepts are central to existing and likely future resource management legislation and policy, and prioritise respectively water and environmental outcomes. Achieving the desired vision for the housing and urban development system will inevitably require trade-offs between multiple outcomes. The incorporation of Te Mana o te Wai and Te Oranga o te Taiao within the GPS-HUD would provide guidance on prioritisation of environmental wellbeing when trade-offs are required.

3.18     Finally, a number of government documents refer to Te Tiriti, partnerships with Māori, and Māori values and terms. It would be desirable of if all parties (in both central and local government) worked to a common Te Tiriti guidance document and practice standards.  For example, one suggestion within the Resource Management system review has been for a national policy statement on giving effect to Te Tiriti principles. It would be desirable if there were one document used across the resource management and urban development system. This document could guide reporting and regular independent review.

Partnering with Mana Whenua and Mātāwaka to deliver better Māori housing outcomes

3.19     Auckland Council is committed to collaborating with Māori to deliver on priority outcomes in Tāmaki Makaurau and to making a positive difference in the lives of whānau Māori. Ensuring that whānau Māori live in warm, healthy and safe homes, and that housing options meet the individual and communal needs of whānau in Tāmaki Makaurau, is a priority for council.

3.20     Māori in Tāmaki Makaurau have experienced housing stress over many years. Māori have higher than average rates of household crowding, lower than average rates of home ownership, and less stability due to higher than average rates of renting. Māori are more likely to live in damp and mouldy homes and are over-represented among people experiencing homelessness. A thorough investigation is needed to identify the specific systemic and underlying reasons as to why Māori disproportionately face housing issues, and a clear set of actions is needed to address them. 

3.21     The Auckland Plan sets out a number of ways that Māori housing outcomes could be improved, including:

·      Ensuring Māori have access to affordable housing initiatives to promote community health, whānau stability and Māori social wellbeing

·      Leveraging off the work that the community and Māori housing sector is already doing to create increased options and opportunities for housing for Māori

·      Ensuring regulatory and consenting processes are effective and responsive to Māori developers and iwi organisations

·      Tapping into the potential of Māori commercial enterprises, some of which are already playing a key role in delivering housing

·      Aligning housing initiatives in Tāmaki Makaurau with national Māori housing strategies and policies.

3.22     The Independent Māori Statutory Board (the Board) launched the Kāinga Strategic Action Plan in 2019 (developed collaboratively with key players in the sector), with an update and refreshed advocacy priorities approved by the Board in 2020. The Plan identifies several housing actions which have a high degree of alignment with the GPS-HUD, including: a focus on homelessness, emergency housing and transitional housing; supporting the iwi and Māori pathway as part of the Progressive Home Ownership scheme; and removal of Community Housing Regulatory Authority barriers to iwi and Māori housing providers.

3.23     According to the Board’s Kaitiakitanga Report for Tāmaki Makaurau 2019, Auckland Council-assisted papakāinga increased from three in 2012 to seven in 2018. The number of Māori organisations and trustees supported to achieve Māori housing and papakāinga development increased from 12 in 2015/16 to 17 in 2017/18. Information presented to the Wāitangi Tribunal in April[2] showed that of 52 community housing providers (registered by the Community Housing Regulatory Authority) in Aotearoa, 15 identified as Māori, four in Tāmaki Makaurau.

3.24     Nationwide, Māori providers have less than 4 per cent of the public housing held by community housing providers (CHPs) and funded by the Government’s Income Related Rent Subsidy (IRRS). Together, Kāhui Tū Kaha Limited and Whai Maia Charitable Trust hold most of this (330 houses out of the total of 463 held by registered Māori housing providers in New Zealand). There would appear to be significant scope to build on this in Auckland, particularly at a time when the Government has embarked on a major public housing construction programme in Auckland, with CHPs providing a significant share of the new homes. Not having registered CHP status may constrain Māori housing providers from delivering on other parts of the housing spectrum as well, including via partnerships with Kāinga Ora. It is therefore important that central and local government work with Tāmaki Māori on how to address their housing aspirations in implementation plans and identifying appropriate performance indicators.

3.25     We support the GPS’s emphasis on implementation, reporting and a three-yearly review. It is important that there is regular reporting on housing outcomes for Māori, providing up-to-date information on:

·      How Māori are distributed along the housing continuum from home ownership to homelessness

·      Housing quality, security of tenure and related outcomes

·      The number and scale of Māori housing providers, their projects, assets, aspirations and barriers

·      The size of land made available for Māori housing and numbers of houses built.

3.26     The council and the Board strongly support a more active role for government in partnering with Māori to respond to the systemic changes needed to improve Māori housing outcomes and are pleased to see the Te Tiriti response to iwi and Māori housing aspirations that the GPS-HUD has sought to embrace. The integration and application of the Māori and Iwi Housing Innovation framework for action (MAIHI) framework across all sectors will be critical to successful outcomes for Māori. We recommend that MAIHI performance indicators be developed and reported by region and form part of regular integrated reporting of the GPS’s three-yearly review. 

3.27     Council and the Board would welcome greater partnership with government to better deliver on Māori housing and urban development outcomes in Tāmaki Makaurau. Consistent with the GPS, this would include Government taking the lead in enabling Tāmaki Māori housing providers, land leasing options and Kāinga Ora jointly delivering housing programmes with local Māori communities.

An enduring partnership between local and central government to deliver better housing outcomes

3.28     Central and local government both play key roles in the provision of public and social goods for the residents of Auckland and so Council supports the inclusion in the GPS-HUD discussion document of “genuine and enduring partnerships” and the pursuit of “meaningful and real relationships” with local government as one of the four ways of working.

3.29     The real-life context for national strategies and policies is always locally-specific.  The scale and complexity of Auckland means the challenges we face, and our relationship with central government, are different from other local authorities around New Zealand. Within the Auckland region, the social, economic, environmental and cultural wellbeing of communities also varies greatly. Council is very well placed to understand and enable – and often deliver – what is needed to improve the wellbeing of Auckland’s communities.  We understand the connections between urban design, infrastructure investment, economic activity, the environment, housing, and social wellbeing as they play out in our diverse communities. This contextual understanding of our people and places means it is essential for central government work collaboratively with Council to achieve the outcomes set out in the GPS-HUD.

3.30     Council has a history of forming good partnerships with government on critical housing and urban development issues, including through mechanisms such as the Auckland Housing Programme and Joint Work Programme on Housing and Urban Development, and this provides a strong foundation for close cooperation. But we believe this cooperation and collaboration can, and must, be improved if we are to achieve the vision and outcomes set out in the GPS-HUD and in the Auckland Plan.

3.31     There are always opportunities to improve our ways of working – for example ensuring greater communication, sharing of information, use of common data and evidence, and joint engagement with stakeholders where appropriate.

3.32     However, fundamentally, Council believes that to get the best wellbeing outcomes for our communities, there needs to be a change in how infrastructure and services get delivered, including funding mechanisms. The partnership between central and local government needs to be underpinned by integrated spatial, infrastructure and funding plans which have a long-term focus. Agencies such as Kāinga Ora in particular, need to work collaboratively with Council on their spatial priority developments from the early stages of strategic planning, right through to delivery. Decisions also need to involve local communities. Integrated spatial plans should enable communities, and the infrastructure required to support them, to be planned efficiently and effectively, leading to better outcomes.  

3.33     Council also believes that the success of these spatial plans and partnership with government more generally depends on a holistic, systems approach across all government agencies – not just those directly involved in housing and urban development. For the outcomes in the GPS to be achieved, government agencies need to be better at working together and recognising the interconnected nature of the issues set out in the GPS. For example, we cannot prevent and reduce homelessness, without also looking at the welfare system, healthcare, and training and employment.

4    Specific matters: discussion document questions

Do you agree with the proposed vision and outcomes? Is there anything else that should be included?

4.1       The Auckland Plan 2050 recognises the importance of thinking strategically about how the housing system can provide secure, healthy and affordable homes for all Aucklanders. We are pleased to see the Government adopting a multi-decade outlook and setting a clear vision and direction for the housing and urban development system in New Zealand through the GPS-HUD.

 

4.2       Auckland Council supports the overarching vision set out in the GPS-HUD that “everyone in Aotearoa New Zealand lives in a healthy, secure and affordable home that meets their needs, within a thriving, inclusive and sustainable community”. This vision aligns well with the vision set out in the Auckland Plan 2050 Homes and Places outcome that “Aucklanders live in secure, healthy, and affordable homes, and have access to a range of inclusive public places”.

Thriving Communities

4.3       Council supports the focus on thriving communities, and the broad definition of thriving communities set out in the discussion document. Auckland needs thriving communities that are connected, resilient, sustainable and inclusive if we are to achieve the outcomes set out in key strategic documents - the Auckland Plan 2050, Te-Tāruke-ā-Tāwhiri: Auckland’s Climate Plan, Kia Ora Tāmaki Makaurau: Māori Outcomes Performance Measurement Framework, and the Independent Maori Statutory Board’s Schedule of Issues of Significance to Māori. With its wide-ranging sphere of influence and responsibility, the council has an important part to play in achieving the thriving communities outcome.

4.4       Council strongly supports a focus on reducing emissions through sustainable urban form and good quality urban design, public transport services and active transport networks. Urban form is a powerful enabler of emission reductions in urban areas. Achieving a quality compact urban form in Auckland is critical to New Zealand achieving its required emissions reductions. As noted above, however, there appears to be a lack of alignment and consistency in policy documents such as the NPS-UD with this ambition to reduce emissions through good urban form. It is not clear how the GPS will address this.

4.5       We support the statement that communities should grow within environmental limits and urban development should restore ecosystem health. It is not clear from the discussion document, however, what these environmental limits are, how they will relate to the limits that are proposed to be included in the new Natural and Built Environments Bill, or how success will be measured. Auckland Council has developed, and is continuing to develop, clear targets around climate change, waste, urban ngahere, and water efficiency.  We recommend that all Crown-delivered housing should meet or exceed these targets to support the growth of new communities within environmental limits.

4.6       Council recommends that “planning for and investing in changing infrastructure needs” may be better expressed as an adaptive approach to infrastructure provision in response to changing pressures and needs. This would encourage a broader approach to long-term infrastructure planning.

4.7       Council notes that there is no explicit reference in this outcome to addressing inequity. The definition of thriving communities could be interpreted as weighted towards individual needs or a narrowly defined geographic area. We need to ensure that our thriving communities are integrated as part of the broader region to help mitigate the potential for creating inequities.

Wellbeing through housing

4.8       Council supports a focus on wellbeing through housing in the GPS. The link between housing and wellbeing has been widely documented over the years. The condition of homes, insecure tenure, and wider neighbourhood characteristics all have a considerable effect on Aucklanders’ physical and mental health and wellbeing.

4.9       Council considers that cultural wellbeing needs to be better addressed in the GPS given the growing diversity of our communities.

4.10     Council would strongly support the focus of the “Wellbeing through housing” section being broadened to recognise the importance of places, spaces and ecosystems - and not just housing - to people’s wellbeing.

·      Parks, playgrounds, streets, town centres and other places and spaces have a key role in Aucklanders' mental and physical health as they are places for activity and recreation. Public places can provide respite for those who feel isolated or experience stress or safety issues at home. Public places where people can interact and connect have always been important and will continue to be vital to Aucklanders’ sense of belonging and wellbeing. As we are moving towards more intensive housing development outcomes, the importance of how all public realm areas contribute to community wellbeing is critical.

·      Ecosystems, urban forests and/or planted green public spaces improve community wellbeing when provided within a walkable catchment to housing and places of work. The contribution of well-functioning ecosystems to people’s wellbeing is well recognised in national environmental directions such as Te Mana o te Taiao - the Aotearoa New Zealand Indigenous Biodiversity Strategy.

Partnering for Māori housing and urban solutions

4.11     The council supports the government’s commitment to partner with Māori and to invest in Māori-driven housing and urban solutions. We support a Te Tiriti response to Iwi and Māori housing aspirations, which the GPS-HUD has sought to embrace.

4.12     The government needs to play a more active role in partnering with Māori to respond to the systemic changes needed to improve Māori housing outcomes, which are currently in crisis. The integration of the MAIHI framework across all sectors will be critical to successful outcomes for Māori. 

4.13     It is positive to see the discussion document laying out how Kāinga Ora will engage and partner with others, including Māori. This partnership role will need to be well-resourced, implemented and monitored.

4.14     Collaboration will be critical to the success of this outcome. Partnership approaches need to be tailored to leverage off each other’s strengths. For example, the Auckland Council Māori Housing Unit supports Māori organisations to develop housing on Māori and general land by advising Māori landowners and developers through the development process and acting as a single point of contact within the Council. The Papakura Marae kaumatua housing project and Te Mahurehure Marae Kāinga Atawhai housing project are good examples of Council, Te Puni Kōkiri and MHUD collaborating to contribute to planning, building and development led by Māori communities.

An adaptive and responsive system

4.15     Council supports the desire for an adaptive and responsive system, but this also needs to be a system that delivers a quality urban environment.

4.16     Council notes that the use of adaptive and responsive appears to be heavily weighted towards response to growth pressures. Alignment with the vision of the GPS-HUD would encourage that these adaptive and responsive principles are considered in a more balanced way so that long-term environmental, resilience, equity, and urban outcomes are not lost in the pursuit of short-term growth targets.

Gaps in vision and outcomes

4.17     Council considers that the explanation of the vision set out in the document (page 30) could include more context. In particular, we would like to see it be more explicit and inclusive about the diversity of people in communities. The housing crisis in Auckland is being experienced most acutely by lower income and vulnerable communities, including Māori, Pacific people, and other minority and marginalised groups, such as persons with disabilities, single parents (particularly single mothers), young people and children, and those living in poverty.

4.18     To be effective, there needs to be alignment between the GPS-HUD and the existing and anticipated future policies that will be used to deliver the GPS. From an environmental perspective, Council suggests integration of concepts such as Te Mana o te Wai and Te Oranga o te Taiao across the GPS outcomes. These concepts are central to existing and likely future resource management legislation and policy, and place the health of freshwater and the environment above all other considerations.

4.19     Council notes that there is direction to Kāinga Ora later in the document to avoid development in areas with increasing exposure to hazards.  We recommend that natural hazards are also included in the GPS vision and outcomes, with avoidance of existing as well as increasing hazards as a principle for urban development, in order to apply to all considerations under this GPS.

Do you agree that the proposed focus areas will help us realise the outcomes we want to see? What else should be the focus?

4.20     Council generally agrees that the proposed focus areas provide the appropriate setting for the planned outcomes.

4.21     Council considers that there is scope to include a separate focus area on the natural environment and climate. At the moment, natural environment and climate considerations are part of the ‘supporting resilient, sustainable, inclusive and prosperous communities’ focus area. While we recognise that natural environment, climate and social and economic wellbeing considerations are inherently connected, the role of housing and urban development in the delivery of climate change outcomes (such as adaptation, mitigation or resilience) and natural environment outcomes (such as biodiversity, water quality, waste generation and ecosystem health) is significant. The existing housing and urban development system has played a significant role in observed environmental degradation in Auckland and the GPS-HUD, together with new and anticipated environmental legislation, provide good opportunities to change that. Because of this, Council considers that the natural environment and climate could be afforded its own focus area distinct from other important considerations, such as the inclusivity and prosperity of communities.

4.22     Council would support more explicit consideration of urban land uses other than residential in the focus areas. We would like to see more attention given to the role of business and industry land uses, open space zones, and the wider suite of urban land uses, and their importance in a well-functioning, efficient urban built form.

4.23     Council notes that a critical piece of work will be the development of implementation plans for the actions underpinning the focus areas. These implementation plans need to be developed in partnership, have a long-term view, and have appropriate funding and financing solutions underpinning them. They also need to include agreed measurable targets or indicators to clearly identify whether progress is being made on the outcomes and focus areas set out in the GPS.

Ensure that more affordable houses are being built

4.24     Council strongly supports a focus by government on increasing the supply of housing across the housing spectrum, and particularly on ensuring that more high-quality, affordable houses are built in Tāmaki Makaurau. Auckland’s future economic and social prosperity will be underpinned by its ability to provide secure and healthy housing that people can afford to own or rent. Auckland Council is taking a leadership role to increase the supply of, and access to, affordable housing as part of the Auckland Council and Government Auckland Housing and Urban Growth Joint Programme. To support this, in 2020 Council approved an Affordable Housing Forward Work Programme focused on Council’s key policy and regulatory powers.

4.25     Council believes that additional tools and approaches will be needed to deliver affordable housing in Auckland, and these need to be addressed in the GPS. Enabling the use of inclusionary zoning through legislative change would provide councils with another tool to ensure housing ownership is achievable for more of those who would otherwise struggle to buy. Council supports moves to increase build-to rent-developments and would like to see the Government facilitate greater investment into this sector. We welcome the recent greater provision of social housing in Auckland and would urge further investment in both state housing and community housing providers.

4.26     Building more homes will also require an enduring system for infrastructure funding and financing to be put in place.

·      The extent of the current infrastructure funding and financing issue is alluded to in the discussion document, but Council is of the view that it is not articulated as strongly as it needs to be. Infrastructure also appears to refer to ‘new’ infrastructure, but the ability to pay for maintenance, renewals and operation of existing infrastructure is equally as important.  

·      Council does not agree with the view expressed in the document that “many councils are unable to pay for the infrastructure required to support increased housing supply at the pace needed because they are reaching their debt limits, their ratepayers are unwilling or unable to pay, and they lack all the necessary tools and incentives to shift behaviour.” This needs to be articulated differently. While some shift in behaviour may be required on the part of communities, council and central government, the fundamental issue is rather a lack of system for infrastructure financing and funding in New Zealand to allow growth to occur successfully.

·      A fundamental rethink of infrastructure provision is required if we are to achieve the outcomes set out in the discussion document. Discussion of infrastructure funding and financing in the GPS needs to be expanded to include:

·   Bolder thinking - the Infrastructure Funding and Finance Act may be a useful tool in the medium to long term in some situations, but is unlikely to address the infrastructure funding challenges in the short term.

·   A new way to fund and finance infrastructure is needed – both capex and opex

·   A stronger statement about what a new business-as-usual for infrastructure funding and financing would look like.

·          Council would like to see the GPS recognise more strongly the importance of the joined-up approach that is needed between central and local government, infrastructure providers, and Crown agencies around infrastructure provision. At present this is discussed in terms of conversations and relationships but for the GPS to be successful, the joined-up response needs to be strong, with an effective system and decision-making.

·          A central and long-term view of planned infrastructure will play an important role in coordinated work to achieve the vision of the GPS. However, it is important that a managed infrastructure pipeline accommodates a dynamic-adaptive approach to planning for the infrastructure needs of our current and future communities. This would mean the pipeline would have frequent review and the ability to process new information/projections. This approach would reduce the risk of locking in infrastructure solutions now that may not be optimal in the long-term.

4.27     Council questions the assumption under this outcome that we need to “free up more land”. It is not clear, and no evidence is provided on, what “freeing up more land” refers to, what amount “more” would be, or who would pay to free up that land. Auckland already has a significant amount of zoned land and enabled development capacity. If freeing up more land refers to outward greenfield expansion, this would appear to run contrary to the outcomes the rest of the GPS seeks to achieve and have a significant impact on the ability to deliver infrastructure to achieve the desired outcomes in the GPS. 

4.28     Council strongly believes that increasing the supply of affordable housing should not come at the expense of environmental outcomes such as waste generation or water quality, or creating sustainable urban development and thriving communities. Affordable housing needs to be close to public transport, community facilities and services, and have good access to employment.

4.29     Council would like to see greater consideration in the GPS of transport costs as part of housing affordability. Household transport costs are inextricably linked with housing location. The cost of living in a particular house includes not just the cost of purchasing or renting that house but also the on-going cost of travelling to and from that house. Achieving more affordable housing in locations with poor or expensive transport choices would offset some, if not all, of the affordability savings and undermine the ability to achieve the vision and outcomes of the GPS.

4.30     Council supports better alignment between local and central government in decisions on land use, transport and other infrastructure. Council’s in-depth knowledge of our communities, infrastructure and local context are a critical element in the delivery of the outcomes and vision set out in the GPS.  Decisions in these areas should be aligned with investment decisions.

4.31     Finally, Council considers that this focus area needs to better address the competitiveness of the building supplies sector. While the cost of building materials themselves is not the main problem when it comes to the cost of construction (land and associated infrastructure are the largest cost components of residential housing development), it is a contributor. If competition issues in the sector are tackled, this may have some impact on housing affordability in the medium to long term.

Provide homes that meet people’s needs

4.32     As noted above, Auckland will likely require another 332,000 to 384,000 dwellings over the next 30 years. Not only do we need more good quality housing to be built, but we must also ensure that a range of housing types and sizes are built across the region. We need to build more apartments, including for individuals and large families, and townhouses, of different sizes and price points. Other examples could include intergenerational, papakāinga-style, and communal, or co-housing. This will reflect the fact that Aucklanders’ lifestyles and housing preferences are changing. For example, there has been positive take-up of terraced housing and apartments that are close to transport corridors and nodes in recent years.

4.33     Council is pleased to see language such as “accessible” in relation to housing. Auckland Council has long been an advocate for the improvement of accessibility in New Zealand homes. However, we consider that there is a lack of clarity and consistency in the use of the term “accessible” throughout the discussion document. Accessible appears in relation to housing at times, and at other times is completely absent. In some circumstances, accessible is referring to access to jobs or transport, but not necessarily that the transport itself is accessible to disabled people. Council would like to see better definitions of the term and more consistency in how it is used throughout the GPS. Council would also like to see more evidence of the need for accessible housing presented in the GPS. This need is most pronounced amongst disabled people, Māori, Pacific people, older adults, and those with lower incomes. If adequate evidence around this need is not clearly stated, there is a risk that the issue will not be adequately addressed. 

4.34     Council supports the focus on increasing the supply of homes that meets people’s needs as our demographics change.

·      Auckland’s population is ageing. The ability to find suitable and affordable housing in Auckland is not always straightforward for older people. The available housing stock often does not meet their needs – 59 per cent of adults over the age of 65 have at least one impairment, which greatly increases the need for accessible housing. The percentage of people reaching retirement with no mortgage has been dropping in recent years, and the costs of owner-occupied and private and social rental housing are increasing. Also, the overall quality of the housing stock is poor, particularly the quality of rental stock, which has both health and safety implications.

·      Auckland's Māori and Pacific populations will continue to have relatively younger age structures due to their higher birth rates. Māori and Pacific peoples have seen no increase in home ownership over the past 30 years, something that has traditionally provided households with both a secure home and greater intergenerational wealth. If Māori and Pacific peoples are to enjoy the security of tenure, social mobility and levels of wellbeing in line with other groups, their poor housing outcomes cannot continue. In addition to the partnership approach with Māori to improve Māori housing outcomes, Council welcomes the action around implementation of the Pacific Housing Strategy to improve the housing outcomes of Pacific People.  

·      Multi-generational households are increasing across all ethnic groups, driven by various demographic, social and financial reasons such as people marrying later, cultural traditions, childcare arrangements, caring for elderly and so on. Many Māori and Pacific aspire to have inter-generational living. There is a real need to build larger houses, look at new models of ownership and design, and cater for the social wellbeing needs of multi-generational households.

4.35     Council supports the focus on improving housing quality. Cold and damp housing, including in our state housing stock, is a serious issue, affecting the health and wellbeing of many Aucklanders. Council is pleased to see a focus not just on the quality of existing dwellings, but also on sustainable design and construction of new dwellings which will be important not just for health and wellbeing outcomes, but also to support the move to a low-carbon, climate resilient future.

4.36     Council would welcome greater recognition in this focus area on peoples’ needs more broadly, particularly within the scope of access to urban ngahere, public and private green spaces or public open spaces.

4.37     We would also like to see more emphasis in the actions on the role of the Building Act and Building Code in improving wellbeing through housing.  For example, the Building Act is where accessible housing needs to be addressed, and where improvements can be made to minimum building standards to help improve the quality of housing.

Support resilient, sustainable, inclusive and prosperous communities

4.38     Council supports the aspirational outcomes that are identified in this focus area, such as climate change resilience, improved biodiversity, better public transport and active transport links and local economic development. These outcomes are generally well aligned to the Auckland Plan and Council objectives.

4.39     Council would like to see this focus area given stronger policy direction, allowing it to be given sufficient weight when balanced with the other focus areas.

·      Rather than “support”, this focus area could be reworded as “ensure resilient, sustainable, inclusive and prosperous communities”, which would signal the importance of this focus area, and encourage it to be considered alongside the provision of new, affordable, fit-for-purpose housing, and taking care that the communities created are fit-for-purpose too. Currently, Council considers that the wording is not robust enough to adequately achieve the GPS-HUD vision, particularly the second half of that vision around “a thriving, inclusive, and sustainable community.”

·      Council anticipates that when faced with pressures of developers wanting to provide residential development in unsustainable locations, this focus area would lose out to others with stronger, more directive language. Council regularly faces challenges with private plan change requests and resource consent applications proposing residential and urban land-uses on highly productive land and in poorly connected rural locations, residential development in areas strategically planned for business uses, and urban development in areas of significant environmental value, where resulting environmental degradation would be significant. To allow these to continue, and not provide rigorous policy support to push back on such proposals, would critically undermine the vision set out in the GPS-HUD.

4.40     Council notes that the proposed outcomes in this focus area do not align with existing delivery vehicles, such as the NPS-UD, which is silent on natural environment outcomes. Actions supporting this focus area must consider how implementation mechanisms can be aligned to effectively deliver on the desired aspirations. Actions also need to better link to the desired outcomes – for example Council would support a more explicit action around restoring water quality and biodiversity.

4.41     Council strongly supports the recognition that addressing climate change requires urgent investment in better transport options (including more walking, cycling, and public transport) and better urban land use to accelerate development in the places that increase access and reduce travel times. We agree that homes need to be constructed in well-designed communities built around public transport and active transport networks, allowing reduced private vehicle use and promoting mode shift, with good access to employment. Staging and sequencing is key here to ensure development happens in the right place at the right time that ensures alignment with planned and funded infrastructure.

4.42     Council supports this focus area recognising the importance of developing strong, thriving and resilient local economies. To support the focus on ensuring communities are connected to jobs, council recommends the inclusion of a specific action around supporting local employment and better access to employment.  Auckland Council’s Economic Development Action Plan 2021-2024 includes an action around developing a consistent economic development planning approach to Auckland’s identified urban growth locations and new economic areas. 

4.43     Council would also like to see more of a focus in this section on building affordable, low-carbon homes. Although de-carbonisation is mentioned, there are no clear directions on reducing embedded carbon within infrastructure and housing or the materials used. Truly sustainable, zero-carbon communities need to think about the life cycle of materials utilised and the embedded carbon values of the construction, combined with zero or low emission targets.

4.44     There is minimal acknowledgement in the discussion document of the significant amount of waste generated from housing construction and demolition activities, and associated environmental, cultural, social and economic costs. In terms of construction, Council’s own research indicates that practices such as over-ordering are commonplace – for example each new house built is estimated to generate, on average, around four tonnes of waste with discarded materials valued at $31,000. These are materials the homeowner pays for but neither sees nor gets any benefit from. Actions that promote the avoidance and reduction of waste during housing construction and demolition should be explicitly incorporated within this focus area, as well as through Kāinga Ora’s role to “manage its functions and operations to mitigate and adapt to the effects of climate change”.

4.45     Council would like to see additional actions in this focus area:

·          an action highlighting the importance of, and giving weight to, sound strategic land use planning in the form of spatial plans, structure plans and land supply strategies. To prevent an “intensification at all costs” approach, weight needs to be given to prioritising and implementing robust strategic planning.

·          a more explicit action around restoring water quality and biodiversity.

·          an action that focuses on supporting places as they evolve and change in response to climate change, demographic shifts, technological advances and changes to Auckland’s urban form. Any investment in new or existing community services infrastructure needs to ensure assets are adaptative and flexible to respond to changing customer preferences and the dynamic nature of communities.

Invest in Māori-driven housing and urban solutions

4.46     Council welcomes the partnership approach being taken with Māori and we support a Te Tiriti response to Iwi and Māori housing aspirations that the GPS has sought to embrace. A critical piece of work will be the development of implementation plans for the programmes that will underpin this approach. For all sectors, this will require the building of capacity and capability, a willingness to see systemic change, and integration across all organisations involved. 

4.47     Council would like to see greater recognition in the GPS-HUD of the need for systemic change across not just government housing and urban development agencies and local government, but also across social sector agencies (such as the Ministry of Education, Ministry of Corrections and District Health Boards) to address many of the structural and systemic issues/barriers that have culminated in Māori being disproportionately positioned at the lower end of the housing spectrum.

4.48     Council is concerned at the risk of a disconnection between what central and local government ‘place-based’ spatial priorities are, and what Māori consider to be priority areas. For example, less than 1 per cent of land in Auckland is Māori land. The majority of this is located on the regional periphery or is island-based with limited infrastructure. These areas will potentially be viewed as low priority due to location and development scale, yet are critical to Māori. This disconnect may limit access to development opportunities and resources. This issue will need to be explored in the implementation plans falling out of the GPS-HUD and MAIHI approach.

4.49     Māori-driven housing needs to also embrace and include remote rural communities. There is an assumption that Māori Freehold Land (MFL) is for new kāinga developments, for those returning to the whenua, and ignores the fact that many do reside on Māori Freehold Land in substandard housing in New Zealand’s rural communities. In the Auckland region and across rural New Zealand, there are housing quality and equality issues for Tangata Whenua – Haukinga and Ahi kaa residing on Māori Freehold Land, living in traditional communities. Access to housing upgrades is needed. There are major barriers to access the appropriate funding, raising capital, and consent to reside on their lands.

4.50     As noted in our commentary on substantive issues, Council would like to see more discussion in the GPS-HUD on the role of Māori housing providers and how government will support building capability in the sector. In Auckland, Kāinga Ora building consent activity constitutes approximately 8-10 per cent of housing activity each month. This suggests that Kāinga Ora cannot produce sufficient housing on its own to deliver on the GPS-HUD outcomes proposed unless it forms partnerships with the private sector and others, including Māori housing providers.

Prevent and reduce homelessness

4.51     Data from 2018 shows that there were over 18,000 people homeless (living without shelter, in temporary accommodation or sharing temporarily, or living in uninhabitable dwellings such as garages and sheds) in Tāmaki Makaurau.

4.52     In 2017, Auckland Council agreed that homelessness should be “rare, brief, and non-recurring” and has placed homelessness high on its agenda. We therefore support the focus on preventing and reducing homelessness in the GPS-HUD.

4.53     Council is supportive of the National Homelessness Action Plan. The objectives of the plan closely align to the objectives agreed by Council in 2017. Council is supporting the plan by coordinating regional collaboration, participating in government projects, and changing and improving Council operations to achieve better outcomes for people who are homeless.

4.54     The first COVID-19 lockdown occurred after the release of the National Homelessness Action Plan. During the lockdown, extensive support was offered to people who were homeless, including provision of motel accommodation and wraparound support. Ensuring a path from emergency accommodation to stable, secure long-term housing with wraparound services to deal with causes of homelessness such as mental health and addiction is critical. Council is pleased to see recognition of the importance of these services in the discussion document.

Re-establish housing’s primary role as a home rather than a financial asset

4.55     Council welcomes a focus on ensuring that the housing market responds to housing need rather than investment priorities. The Auckland Plan recognises that the right to adequate housing is a basic human right for all Aucklanders.

Do the proposed ways of working reflect the approach that is required from government?

4.56     Council agrees that the proposed ways of working generally reflect the approach that is required from government.

Place-based approaches

4.57     Council supports the recognition that place-based approaches are appropriate, as a one-size-fits-all solution will not work. The scale and complexity of Auckland means the challenges we face, and our relationship with central government, are different from other local authorities.

4.58     Council strongly believes that place-based approaches need to be innovative and move us away from business-as-usual activity to new models and ways of working. Doing what we have always done, or making small changes around the edges, will not solve Auckland’s housing crisis or deliver the social, environmental, economic or cultural outcomes council and government are seeking.

4.59     Innovative place-based approaches will be particularly important if we are to address existing inequity issues in Auckland. Communities need tailored solutions that work for them in each place, and solutions will need to be targeted and developed collaboratively to meet their needs. One way of doing this is to look for opportunities to retain and enhance place-based planning through District/Unitary Plans as part of achieving a well-functioning urban environment.

4.60     It will be important to consider the scale at which ‘place-based’ approaches are used. This is particularly important when it comes to the planning and provision of infrastructure. For example, Tāmaki in Auckland is a ‘place’, but the infrastructure network that serves it extends Auckland-wide.

4.61     Government agencies – particularly Kāinga Ora – need to work collaboratively with Council on their spatial priority developments from strategic planning through to delivery, as councils often have the legacy and contextual understanding of the places where change is going to happen. This is not about duplicating work, but rather utilising the resources and expertise of both organisations and working better together to achieve agreed outcomes. Working with the private development community will also be key as they must be a viable contributor to providing affordable housing in Auckland.

4.62     Council supports the naming of the housing and urban development focus areas in Auckland that have been agreed through the Auckland Urban Growth Partnership and are reflected within the Auckland Transport Alignment Project and Regional Land Transport Plan. We support the continuation of this Partnership as a collaborative approach to integrating infrastructure and land use planning. These focus areas must, however, be considered in the broader context of the region to avoid creating inequities and undermining broader outcomes.

Genuine and enduring partnerships

4.63     Council supports the recognition in the GPS-HUD that implementation requires government to collaborate and partner with others with key roles, including local government as one of the four ‘ways of working’. Effective partnership with government is essential to Auckland’s future. Council and government have a history of forming good partnerships on critical issues, including through mechanisms such as the Auckland Housing Programme and Joint Work Programme on Housing and Urban Development, and this provides a strong foundation for close cooperation.

4.64     As noted above, the scale and complexity of Auckland means our relationship with central government is different from other local authorities. In addition to effective partnership with government, we also need joined-up planning, investment and decision making that delivers on our joint aspirations and supports capability and capacity building across the system. Council believes there needs to be a stronger commitment to improved partnering and collaborative working from both central and local government, so that we can approach development and resolve issues in different ways.

4.65     Council also notes that clear and consistent direction from central government will be necessary to support alignment and partnership. As noted previously, local government must give effect to national policy statements, many of which conflict with each other and/or do not align with, or are silent on, the aspirations of this GPS-HUD. This will make implementation, stakeholder alignment, and genuine partnership on achieving the vision and outcomes set out in the GPS-HUD extremely challenging.

4.66     Council welcomes the focus on developing meaningful relationships with local voices and communities. However, it is unclear how this will be achieved through the detail provided in the discussion document. Council would welcome more clarity on, for example who will determine affected communities and who will lead engagement with those communities.

4.67     Council would like to see more emphasis in the GPS on partnerships with infrastructure providers, both public and private. Currently, partnerships with infrastructure providers appear to be mixed in with partnerships with local government, but not all are part of local government.

4.68     Council would also welcome more evidence of early and ongoing collaboration with the disability community. Inaccessible housing is one of the top issues for disabled New Zealanders, and their needs and input should be reflected in the GPS.

Sustainable and reliable funding

4.69     Council agrees that investment in housing and urban development has been ad hoc and variable, and that the system needs to work differently to provide sustainable and reliable funding (both public and private).

4.70     We support the need to develop sustainable and reliable funding to enable Kāinga Ora, other agencies, and local government to plan ahead to deliver essential housing and urban development. Auckland’s RLTP and LTP support the Auckland Housing Programme by allocating funding over the next 10 years for infrastructure. However, there are competing demands for other transport-led initiatives such as light rail and Drury that will involve significant additional CAPEX spend if approved by central government and commissioners respectively. Large-scale infrastructure investment for major programmes of work will need to be funded and financed from both local and central government in order to achieve consistent delivery. The current mechanisms available to local government are insufficient and unsustainable.

4.71     Council is of the view that central government needs to focus on a small number of policy initiatives and prioritise development areas in order for all parties to get ‘best bang for buck’. The Auckland Plan sets out development areas where significant growth is anticipated over the next 30 years. This includes consideration of potentially significant sites. Historically government has had a diverse portfolio of sites which it has sought to develop/re-develop at the same time. This means that its efforts and those of partner organisations can become diluted with poor results. An integrated spatial, infrastructure and funding plan would enable everyone to be working towards an agreed outcome.

4.72     Council supports the regular review of finance tools to enable growth. Auckland Council has raised funds through green bonds used for transportation projects including rail electrification, the CRL, public cycling and walking infrastructure as well as energy efficiency projects for LED street lighting and green building upgrades. Government and local government agencies will need to find new and innovative funding and financing tools to enable it to deliver on GPS expectations.

4.73     Council believes this section needs to articulate better the big and bold thinking that is required to solve a broken infrastructure funding and financing system. Council would like to see the language in this section be stronger, and the discussion expanded to include:

·          Bolder thinking - the Infrastructure Funding and Finance Act will be a useful tool in the medium to long term but is unlikely to address the infrastructure funding challenges in the short term.

·          A new way to fund and finance infrastructure – both capex and opex

·          A stronger statement about what a new business-as-usual for infrastructure funding and financing would look like.

Are there any actions that need more emphasis, or which are missing, to deliver the outcomes?

4.74     Council would strongly support a more explicit action around delivering good quality urban design. This needs to be incorporated across all aspects of place where people live, work and play. As we move towards developing a more intensified urban form, we need to ensure the supporting infrastructure, public transport and social and community facilities make this viable. It is also critical that every part of “place” contributes towards achieving quality well-functioning urban environments.

4.75     Council considers that there could be more explicit actions to support the ‘Adaptive and responsive system’ outcome. At present, the line of sight between that outcome and the various focus areas and actions is weak.

4.76     Council would like to see more recognition in the document of the tensions between actions – particularly between growth at pace and quality environmental, resilience and urban development outcomes. For example, infrastructure has an important role to play in delivering both the growth quantum and the quality outcomes sought. However, in order to achieve both, high quality infrastructure decision-making is required, which can take time. This can be supported (and re-work in the infrastructure development process avoided) through early-phase infrastructure decision making that is connected, adaptive and long-term focused. The GPS can support this early decision-making with clear national direction and alignment.

4.77     The GPS sets out a vision and outcomes relevant across Aotearoa New Zealand. However, the actions and delivery mechanisms are weighted heavily towards the developments being delivered by Kāinga Ora. It is important, therefore, to be mindful of the potential for perverse or unequal outcomes if the effect of action under the GPS is to pull both central and local government infrastructure resources towards only a few comprehensive developments, reducing the ability to deliver on the vision in other locations. 

What actions could you, or others in the system, contribute to delivering on, and what type of support would be needed?

4.78     The Auckland Council group, with Māori partners, would like to be involved in ongoing implementation and monitoring of the GPS-HUD as shared infrastructure and growth data will be key to the coordinated action required to deliver on the vision of the GPS.  Council acknowledges it is important to share critical data sets that impact decision making and support the evidence base. Council would like to see clear, agreed definitions of key terms and data standards to promote interoperability, good governance and transparency of decision making. We note particularly that shared infrastructure data is being considered through the development of the New Zealand Infrastructure Commission’s 30-year strategy and if centralised sensibly this would lead to a broad-based improvement in understanding the state of our assets, better planning, and better value for ratepayers and taxpayers. It would also potentially reduce the cost of infrastructure.

What additional, or new, expectations of Kāinga Ora do you think should be included? What about expectations of other agencies?

4.79     The opening statement on what the Government requires of Kāinga Ora (page 70) needs to include recognition that Kāinga Ora needs to work not just with other government agencies, but also with local government. Councils are critical partners for Kāinga Ora, and Kāinga Ora will not succeed unless it works alongside Councils to undertake its functions.

4.80     The GPS needs to clarify how Kāinga Ora (and MHUD) will work with the private sector. In the Auckland context, Kāinga Ora building consent activity constitutes approximately 8-10 per cent of housing activity each month. This suggests that Kāinga Ora cannot produce sufficient housing on its own to deliver on the GPS outcomes unless it forms partnerships with the private sector and other house-builders.

4.81     Council would like to see a number of additional actions for Kāinga Ora:

·          Kāinga Ora should be required to develop shared spatial plans with Council that are supported by funding from other agencies such as MHUD, Waka Kotahi, Ministry of Education, Ministry of Health and so on. Integrated spatial plans should enable communities and the infrastructure required to support them to be planned efficiently and effectively.

·          Kāinga Ora needs to provide homes in the right place at the right time to support well-designed communities built around walking, cycling and that support existing or planned and funded public transport routes and with good access to employment.

·          Kāinga Ora needs to support local employment through its planning and design of communities.

·          Kāinga Ora should lead by example in relation to environmental outcomes – such as demonstrating how natural environments can be restored through urban development rather than simply avoiding, remedying and mitigating effects. This could include specimen tree planting in landscaping, green infrastructure, water sensitive design, stream daylighting / riparian planting and so on. Kāinga Ora should also be designing to minimise waste during site clearance, building, and occupation of the housing they develop.

4.82     The GPS needs to clarify how other Crown agencies are expected to support the urban growth initiatives set out in the GPS-HUD – for example Treasury, Ministry of Education, Ministry of Health, Ministry of Business, Innovation and Employment, Waka Kotahi, NZ Police - as there needs to be a holistic approach taken to address broader issues that go beyond the provision of a physical home. For example:

·          The Ministry of Education working with schools in urban areas where significant growth and density is being unlocked to look at new models for schools being used for shared community purposes (buildings, facilities, playing fields), and working alongside transport agencies to ensure these schools are integrated with the transport network.

·          The Ministry of Business, Innovation and Employment and other agencies on opportunities to unlock/support local economic development and employment opportunities new or within growth locations

4.83     Auckland Council considers that all central and local government agencies involved in the planning and delivery of housing and urban development need to embrace innovative approaches and evolving changes regarding trends and drivers such as the changing nature of work/employment, climate change mitigation & adaptation, technological advancement, move to a circular economy and so on.  Whilst it’s identified for MHUD to play a lead role in this space – this needs to be more widely embraced across all agencies involved in the delivery of urban development.

 

5    Wording Changes

5.1       In addition to the points raised above, we have identified several smaller changes that we would like to see in the final version of the GPS-HUD for clarification and completeness purposes. These changes are outlined below:

Section/Page

Suggested Amendment

Implementation Plans

P11

The direction-setting and implementation diagrams are heavily weighted towards central government strategies and frameworks. It would be useful to amend the diagram to include reference to legislative 30-year spatial plans (Auckland Plan) which set out the aspirations of Aucklanders and provide guidance for Auckland Council.

Roles and responsibilities

P19

Add “significant role in funding and financing” to both the local government and central government boxes. It is in the private sector box so it’s not clear why it’s not included for local or central government.

Action is needed today

P22

A useful addition in the “A snapshot of today” box would be a bullet point on the current infrastructure deficit

The housing and urban system

P25

Recommend the addition of reference to funding in the last sentence – “Transforming housing and urban outcomes here requires careful coordination and action across the whole system, and a sustainable and reliable funding mechanism.”

The housing and urban system (image)

P26

For the bottom image on the page, Council recommends the addition of a reference to infrastructure maintenance, not just new infrastructure – i.e. “We build enough infrastructure and housing in the right places at the right cost, and maintain and operate our infrastructure at the right cost and in a way we can afford.”

Thriving Communities

P32

Recommend that “planning for and investing in changing infrastructure needs” may be better expressed as “planning for and investing in an adaptive approach to infrastructure provision in response to changing pressures and needs”.  This would encourage a broader approach to long-term infrastructure planning.

 

Recommend the addition of an additional bullet point under “what we expect to see” heading - “No infrastructure deficit and the ability to pay for the infrastructure we need.”

An adaptive and responsive system – What we expect to see

P37

Recommend the language in the first bullet is strengthened and says “Partnerships, collaboration, joined-up decision making, and funding and financing arrangements across the system that deliver…”

 

Recommend the addition of reference to funding and financing in the fourth bullet point, i.e. “better connection and alignment between central and local government planning and decision-making, and government processes, along with infrastructure funding and financing solutions that will work for the scale of what is needed.”

Ensure that more affordable houses are being built

P40

Recommend that “free up more land” in the section sub-heading is replaced with “enable more development”.

Ensure that more affordable houses are being built

P40 – What we are responding to

Council recommends the third bullet point be articulated differently. We need a fair infrastructure funding and financing regime that works successfully for all parties. 

Ensure that more affordable houses are being built

P41 – What we expect to see

In the second bullet point, suggest the addition of “including aligned infrastructure financing and funding”, i.e. “integrated and aligned strategies for land use, transport, infrastructure investments and upgrades, and social infrastructure, including aligned infrastructure financing and funding

Ensure that more affordable houses are being built

P42 - What needs to change

Recommend that “maintaining a steady supply of land” in the first paragraph is replaced by “maintaining a steady supply of development capacity”, which would capture both brownfield and greenfield development. 

 

Recommend the third bullet point is changed to “partnerships that drive strategic growth planning that meets the focus areas across the GPS-HUD, for example, regional spatial plans with a direct link to infrastructure financing and funding

Ensure that more affordable houses are being built

P43 – Proposed Actions

Suggest replacing bullet point “using new vehicles such as the IFF…” which focuses on current tools with the following:

 

“Incorporate an enduring “BAU” for infrastructure financing & funding solution for both Capex and Opex

·    that takes into account the scale of the problem and provides realistic solutions and tools to solve the problem

·    that provides a system wide solution to provide certainty for all parties (rather than one off ad hoc solutions)

·    Noting that: Where tools that are suggested as solutions are found to not assist, that tools are developed with a full understanding of the problem and the realistic solutions that are possible & achievable”

 

Support resilient, sustainable, inclusive and prosperous communities

P47 – What we are responding to

Recommend the addition of a sentence on the role that housing and urban development plays (and has played historically) in natural environment degradation, greenhouse gas emissions, embodied carbon, and the vulnerability of communities to climate change.

Support resilient, sustainable, inclusive and prosperous communities

P49 - proposed actions

In the action on integrating government investment, it is not clear what is meant by “underutilised transport assets”. We recommend using language that is consistent with:

·    the Climate Change Commission in its report Ināia tonu nei: a low emissions future for Aotearoa which talks about “optimising existing systems, such as reallocating road space and creating low-traffic neighbourhoods or streets” 

·    the Ministry of Transport in its recent discussion document Hīkina te Kohupara – Kia mauri ora ai te iwi - Transport EmissionsPathways to Net Zero by 2050'

Government agency action

P68 – table

The actions need to address who is responsible for developing and implementing a new system for infrastructure funding and financing. Council recommends the addition of an action or owner for “infrastructure financing & funding system & solution”.

 

 


<<appended local board submissions>>


Franklin Local Board

24 August 2021

 

 

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[1] Ministry of Housing and Urban Development (2020), Public Housing Report: Snapshot for whānau māori. Prepared for Wai 2750.

[2] Ministry of Housing and Urban Development (2020), Public Housing Report: Snapshot for whānau māori. Prepared for Wai 2750.