Going for Housing Growth: Providing for urban development in the new resource management system

Targeting proposals  

Question: Smaller councils, like Waimakariri and Selwyn, have been included with Christchurch as a tier 1 council and so have been subject to the same National Policy Statement on Urban Development 2020 (NPS-UD) requirements as councils with the population and available resource to implement them. Are there any indications about how the smaller tier 1 councils will be supported? 

Answer: The approach in the NPS-UD of applying certain policies to all councils within an urban environment means smaller councils that are part of the same housing and labour markets are subject to the same policies as large metropolitan councils. 

We are actively considering the current tier system in the NPS-UD and are interested in feedback on key issues for smaller councils within the same urban environment as a large metro council, including what support would be useful and whether it is appropriate for these smaller councils to be subject to the same policy requirements. 

Question: Under the current Resource Management Act 1991 (RMA) provisions, Waipa District Council is categorised as a tier 1 local authority even though our town urban areas are classed as tier 3 urban areas. Could Waipa District Council be better identified under the new system as being a tier 1 authority for only the area of the district that is adjacent to Hamilton City – that develops as part of the city and transitions to Hamilton City's jurisdiction?  

And linked to that the district’s three town urban areas (Cambridge, Te Awamutu and Kihikihi) could be better and more appropriately treated as the tier 3 urban areas they are. 

Answer: See response above.  

Question: Will councils outside of tier 1 and tier 2 urban environments be required to prepare Housing and Business Development Capacity Assessments to inform spatial plans? 

Answer: Currently only tier 1 and 2 councils are required to prepare Housing and Business Development Capacity Assessments. For tier 3 councils, preparing an HBA is currently optional. The discussion document doesn’t propose making it a requirement and we welcome feedback on this and any recommendations for changes. 

Question: Are there separate provisions and growth projections proposed for tier 3 councils? Or will it follow a similar set up to the NPS-UD? 

Answer: The proposal is that tier 1 and 2 councils will need to use high household growth projections for determining demand. The NPS-UD currently requires Housing and Business Development Capacity Assessments to set out a range of projections for demand and identify which is most likely. As noted above, this is currently an optional requirement for tier 3 councils. 

We are still considering the requirements for tier 3 councils the new system. We are interested in feedback on requirements for tier 3 councils to provide for growth, including appropriate growth projections. 

Responsive planning and rural urban boundaries 

Question: What does a system that is responsive to unanticipated development look like?  

Answer: The NPS-UD currently requires councils to be responsive to private plan change requests that would add significantly to development capacity and contribute to well-functioning urban environments, even if the development capacity is unanticipated or out of sequence.  

We’re aware the policy has had different impacts in different parts of the country, likely due to the scope for interpretation provided by the definitions of ‘significant’ development capacity and well-functioning urban environment. The Government is looking to provide more clarity on both these concepts.  

The Government has also signalled it is interested in strengthening provisions around private plan changes to ensure:  

This acknowledges that while spatial and regulatory plans under the new system are expected to plan well for development, the market may recognise opportunities outside of what has been planned for. We’re interested in feedback on this proposal. 

Question: Has the potential adverse effect of ribbon development been considered in the proposal to enable ‘leapfrogging’? 

Answer: The discussion document proposes that councils still only need to be responsive to private plan changes if they would contribute to well-functioning urban environments. 

As noted above, we’re looking to provide more specificity on the definitions of significant development capacity and well-functioning urban environments to ensure there is a clear framework for considering private plan changes. We welcome submissions on the effects of ribbon development implications for achieving well-functioning urban environments.  

The discussion document also seeks feedback on whether the new resource management system should allow provisions in spatial or regulatory plans that would prevent leapfrogging. 

Question: There seems to be a lot of importance and emphasis on long term spatial planning. However, the ‘responsive planning’ directions basically undermine this. Why is there such a contradiction in this approach?  

Answer: We appreciate the challenges councils face in responding to unanticipated development. The Going for Housing Growth proposals are about ensuring plenty of development capacity is provided in regulatory plans, with private plan changes acting as more of a ‘release valve’ if plans are not sufficiently enabling.  

Question: Are the policy settings for out-of-sequence proposals being considered alongside Pillar 2 – infrastructure funding and financing triggers? 

Answer: Yes, the Going for Housing Growth Pillar 1 proposals are closely aligned with the Pillar 2 proposals. This includes looking at options for growth to pay for growth.  

Aspects of Pillar 2 include a new development levy system, changes to the Infrastructure Funding and Financing Act and improving the flexibility of targeted rates for growth infrastructure.

See more information about Pillar 2

Question: How will the new Spatial Plans (replacing future development strategies) address out of sequence and fast-track proposals and the removal of rural/urban boundaries, while ensuring infrastructure can be aligned, staged and funded for this reactive growth? 

Answer: See below. 

Question: Are changes to the Fast-track Approvals Act being considered to align with the Spatial Planning for each region? Planning for feasible development for 30 plus years may be difficult for some councils and the infrastructure issue may be exacerbated if fast track applications occur outside of planned growth areas. 

Answers: Decisions are still to be made on the changes that will be required to the Fast-track Approvals Act 2024 as we transition to the new resource management system. 

A key aspect of Going for Housing Growth is shifting to a system where growth pays for growth. Going for Housing Growth, Pillar 2 aims to make it easier to provide infrastructure to support development, including for out-of-sequence and unplanned development. Pillar 3, to be announced later this year, will also look at options to shift incentives towards growth.  

See more information about Pillars 2 and 3

Question: How do you see the proposals on rural-urban boundaries working with other constraints on development such as highly productive land and restricting leapfrogging, whilst providing responsive planning approaches?  

Answer: The Government has been seeking feedback on proposals to amend the National Policy Statement for Highly Productive Land to be more enabling of greenfield development.  

Processes for transitioning current national direction into the new system will look closely at interactions between national direction instruments. We are interested in feedback on options for how policy on highly productive land and urban development should interact. 

There are two areas where agile land release mechanisms or ‘infrastructure triggers’ could be used:

• Planning for Growth – if there is enough certainty about the appropriateness of the area of development, councils may want to put an infrastructure trigger in a place to avoid the need for a future plan change. 
• The Responsiveness Policy – we are considering whether to include new criteria meaning councils would be required to have particular regard to private plan changes, if the private plan change includes infrastructure triggers and/or demonstrates a viable option for funding the infrastructure required for the development (.e.g. via a development agreement). 

Intensification  

Question: The proposed walking catchment sizes are being stated in distance. What is the basis for using distance over time for walking catchment sizes? 

Answer: We're aware that some walkability models are relatively sophisticated and account for factors such as slope and walking speed. This can accommodate more nuance but increases the scope for debate about appropriate catchment sizes. We witnessed significant debate about walkable catchments during the implementation of the NPS-UD.  

The proposed distances are 'as walked' rather than 'as the crow flies'. The proposal deliberately simplifies the concept of walkable catchments to focus on proximity to amenities and services, and to reduce scope for debate. 

We welcome feedback on whether the balance between simplicity and providing for nuance is appropriate.  

Question: Would you anticipate off setting occurring at inter-regional, regional or district scale? 

Answer: We are still developing options for offsetting reductions in development capacity due to non-listed qualifying matters (for example, special character protections). We are also looking at whether mechanisms for offsetting will be needed in the new system given it will regulate a narrower scope of effects.  

We’re exploring two options (primarily in relation to tier 1 urban environments): 

1. offsetting in the same walkable catchment (for example, development capacity lost due to an unlisted qualifying matter will need to be offset by the equivalent amount of capacity in the same walkable catchment)
2. offsetting somewhere with similar land values (but still within the same urban environment). 

Question: If the Government wants to limit debate on walkable catchments, there needs to be clearer direction on exactly where the boundary should be drawn. Measuring 800 metres along a network will end up halfway through a property or along a block. The exact location of the boundary is where the debate is hottest (not the distance or time measurement). Is the Government considering such direction for walkable catchment edges (for example, reduce or extend walkable catchment boundary to nearest road or major road)? 

Answer: We are open to feedback on what level of detail central government should provide on how to measure walkable catchments. 

Regarding defining 'public transport corridors,’ can you explain the reasoning behind focusing on the One Network Framework (ONF) public transport design table (that references 'spine' and 'primary' corridors) rather than the broader 'movement and place' ONF philosophy which would acknowledge other modes on the network? Tagging this to public transport, in isolation, misses how the street context (place) and perhaps some other modes interact in intensification. Might the proposal be enhanced if movement and place came first with the public transport layer as an influencer below the overarching street context? 

We’ve worked closely with Waka Kotahi (NZTA) in designing these proposals. We would welcome a submission elaborating on this point. 

Question: The transport corridors talk about six storeys along the key routes, but will this potentially increase to more (based on the response to the walkable catchment heights question)? Are the two linked? 

We are interested in feedback on what minimum enabled heights should be for different intensification categories. This includes along key transport corridors.