A Bill Drafted in Haste

A Submission by the Howick Ratepayers & Residents Association, predicts a catastrophic outcome from The Resource Management (Enabling Housing Supply) Amendment Bill 2021. It asks what will be the social cost of what appears to be a plan for creating slums. It also points out that the utmost caution is required due to Auckland’s fragile land and soil types, its topography, its slender heights above sea-level and its existing propensity towards flooding, subsidence, erosion and slippage.

15th November 2021 

Dear Prime Minister 

The Resource Management (Enabling Housing Supply) Amendment Bill 2021, a catastrophic interference into Auckland’s established zoning and in defiance of the Regional Policy Statement, is being pushed through without time for considered public input. 

We have read this Bill and offer the following comments in relation specifically to Auckland City, by far the major “Tier 1” area in the country and unique in its setting: 

1. The Bill looks to have been drafted in haste, as it shows a lack of integrity, offers no wise direction and clearly has no vestige of local Auckland knowledge. 

2. The existing Auckland Unitary Plan (AUP) began to take shape in 2008, was finally “Operative in Part” on 15 November 2016 and is a 30-year document. Why must it be trashed only 5 years into its life? 

3. Auckland is unique amongst our cities. Nothing in the Bill can safely be applied to it. 

4. Auckland’s infrastructure is broken. B-r-o-k-e-n. Weak to the point of serious breakdown, it cannot tolerate the explosion of infill housing intended by the Bill. 

5. Further: its fragile land and soil types, its topography, slender heights above sea-level, existing propensity towards flooding, subsidence, erosion and slippage, and the already noticeable downhill movement of existing properties, all demand UTMOST CAUTION.

 6. Because of this, some areas of the city are already being considered for a complete moratorium of all additional building, the exact opposite of this Bill. 

7. Indeed, back in 2004 parts of East Auckland were placed under a building moratorium, known as Heritage 7, until in 2015 the AUP removed that safeguard but retained this area and others at risk within the stringencies of Single House Zone (SHZ). 

8. Yet this Bill enables indiscriminate and ubiquitous intensification under building rules even broader than the AUP’s aggressive Mixed Housing Urban (MHU) zone. 

a. Think of how liveable this will be, just for starters: 3 x 3-storey boxes 1m from the boundary rising 6m straight up and then 60° from there. Any window only has to have 1 cubic metre (or less) of air-space outside – and that can be shared – along with a small walk-on leisure space for only one downstairs door. And, of course, no compulsory onsite parking – with the distinct possibility now of nothing on-street either. 

b. No guarantee of local transport, shops or facilities: these developments can pop up anywhere, their size governed only by what can fit onto however few m². 

c. Consider Auckland Council’s current habit of permitting whatever comes across its desk, regardless of how much it exceeds site coverage, heights to boundary and sheer bulk, then imagine the outcomes when time is of the essence. 

9. The immediate result of this Bill will be to attract every dodgy builder who can scribble down plans for the cheapest possible structures to cram onto the minimum – or maximum – site(s) he or she can find. And the neighbours don’t even have to be told Submission by The Howick Ratepayers & Residents Association (Incorporated) P.O. Box 38-370, Howick, Auckland, 2145 about it. Starting to look like planning for slums? What will be the social cost of this destruction? 

10. And who do you think will actually buy these ugly, unfriendly properties? Experience is already confirming that even though the AUP officially sets lofty ideals of sensitive, artistic and pleasing designs blending with the environment, in the current MHU it’s mostly not happening, except in large, fully-planned developments. And remember, this Bill is mostly targeting random infill projects. So might potential buyers be:

a. First homers? Probably not. Bulky 3 levels will be way too expensive, although a little row of terraced houses could be cute – but not much profit in those for the developers, who will go for the biggest bang for their buck. 

b. Retirees? 2 double flights of stairs 24/7 and no lift? No parking? Nope. 

c. Returning ex-pats? Who wants to come back home to NZ and live in a row of boxes? They’re looking for the Kiwi dream – remember that? No again. 

d. Renters? Yes – Kainga Ora. How about mum and dad investors? Only if they will accept back-of-an-envelope design, shoddy build, and few workable warranties as fly-by-night building companies reinvent themselves. All bets are off there. 

But apart from all of the above, this Bill totally ignores the staggering fact that Auckland already has not a dearth of properties but a creeping over-supply, with an estimated 20,000 properties above demand, plus an uncertain but large number, many of them apartments, under various stages of construction* 

Not to mention the roughly 40,000 “ghost” houses as counted in the last census, sitting around empty instead of being dealt to.

Thing is, we have no idea who is going to buy these dwellings. Developers are worried. There is no queue. Returning ex-pats, first timers, oldies, are all choosing other things and the competition can be fierce. So we need to build what people want, not what an ideologue government wants them to live in. And the existing AUP is already providing for decades of natural increase.

Are facts and figures being put forward to justify foisting such an ignorant and misguided Bill upon an unsuspecting public? What models examine its effects? Like the cost to social wellbeing, and to the environment? Show us. 

On one level its goal is to herd the population into close-quarter living. That’s not the Kiwi way – you know that – and people will rise up and tell you so. But on quite another level, if a planned result of this Bill is to produce overnight a serious glut of land arbitrarily re-designated for intensification in order to drop the value of land like a stone, then that is political interference on a massive scale, and those who suddenly find themselves in negative equity or worse will have even more to say. 

The Auckland Unitary Plan, with its inbuilt protection for character and heritage, took roughly eight years to design, consult with the public and finalise, and you want to undo it all in a few days, by decree? This is madness. 

So back we come to the huge main point, which alone guarantees that this Bill is dead in the water in regard to Auckland:

INFRASTRUCTURE. Let’s use the time we have in hand and begin to shore up Auckland’s infrastructure, bit by bit, starting with generous incentives to all home owners to invest in tanking and retaining walls, and to partner with Council to install from scratch or to enlarge and renew broken pipework. This needs to be done to a detailed master infrastructure plan, in order to rescue the land, dwellings and treasures that we already have, for example around Howick’s iconic but fragile Stockade Hill, and in the process to enable the AUP’s lavish opportunities to provide additional dwellings, as required.

Let’s also encourage clever, eco-friendly design, planned to a budget and built for the market, such as the Salvation Army’s outstanding success with their Kaitiakitanga Housing Community at 175 Chapel Road, Flat Bush, and their complexes at 691 Mt Albert Rd, Royal Oak and 16 Kapia Road, Westgate. These are managed by Kainga Ora but could just as easily have been sold to the open market. Stunningly inventive and ecologically wise, with space and community in mind, quietly built with no fanfare, they are right on target. Inspirational. 

Any Bill needs to inspire and incentivise people to do things better and to care for community values and the environment, not to set up false premises that bring out the worst of human nature in a dysfunctional end-justifies-the-means mentality. 

Time to wake up, Prime Minister. Listen to the facts, startling as they may be, and ask Auckland Council to work WITH the public in making realistic plans to save and protect this beautiful place, unique in the world. That’s how we will enlarge it and check prices, as well as by extending the city footprint – which you promised to do; but not stampeded by a mindless edict.

We have time. Let the AUP and wise planners do their work. Withdraw Auckland City now from this rushed, destructive and totally unnecessary Bill. 

– Howick Residents and Ratepayers Association Committee