Submission on Plan Change 78: Intensification

While I do not support the process that parliament undertook to implement the enabling legislation, I do support the enablement of greater intensification.

Enabling more homes will help improve affordability and address some of the causes of the housing crisis, including helping improve the quality of our housing stock. We cannot afford to continue encouraging urban sprawl - it’s unsustainable and covering fertile soil in concrete and asphalt. Greater urban spread creates more infrastructure demands, while a denser urban form will lead to more concentrated investment. Therefore we must focus our efforts on ensuring that the intensification that is delivered is done well.

In my local area of East Auckland, we’ve seen what happens when poor planning enables intensification that lacks the required infrastructure and rules to be successful and sustainable. As a renter, I’m keenly aware of the housing affordability issues and poor quality housing stock. I’ve lived in Auckland my whole life and I know the potential that our city has. I’ve also had the opportunity to travel overseas and see how others have done it (good and bad). We must take this opportunity to ensure that we deliver the best possible outcomes for Auckland, now and into the future.

Chapter D: Overlays - Historic heritage and special character

Figure 1. Newton Special Character Area limiting walkable catchment

I do not support the D18. Special Character Areas Overlay as proposed especially in the walking catchment areas. The process used to determine which areas should be covered is questionable, relying heavily on desktop assessments. I fully support the protection of heritage and would be more comfortable if these overlays were more directly linked to specific heritage buildings. Many of the suburbs that this Overlay covers are some of the best served by transport and other infrastructure, e.g. Newton (figure 1).

Figure 2. Stockade Hill Viewshaft Overlay

I support D20A. Stockade Hill Viewshaft Overlay (figure 2) so that the agreed height controls in the existing overlay remain. However, I note that the limited protection of the harbour views was only part of what the community had asked for (being complete 360 degree protection).









Chapter H: Residential Zones

One of the missed opportunities of our previous intensification has been perimeter block housing. I’ve seen this sort of development delivered extremely well overseas in countries such as Denmark, enabling high quality housing with shared yards and increased privacy. Instead we’ve forced the development of blocks of housing with the minimum amount of yard and windows that face each other. 

I encourage Auckland Council to alter these rules to enable perimeter block housing. I’ve included some proposed rule changes below which I believe will enable the appropriate outcomes.

  • H5.6.5. Height in relation to boundary: change from proposed 4m + 60 degrees to 6m + 60 degrees for four or more dwellings per site within 21.5m of the site frontage. This should encourage development to front the street and discourage outlook to be directed to neighbouring properties increasing privacy and light.

  • H5.6.8.1 Yards: change from proposed Front: 1.5m / Side: 1m / Rear: 1m to Front: 0m / Side: 0m / Rear: 1m. This would enable building out the front of the site and leave more space at the rear.

  • H6.6.6. Height in relation to boundary: change from 4m + 60° for up to 3 dwellings to 16m + 60° within 21.5m of the front boundary of the site. Change from 8m + 60° for 4 or more dwellings to 8m + 60° beyond 21.5m of the front boundary of the site. This should encourage development to front the street and discourage outlook to be directed to neighbouring properties increasing privacy and light.

  • H6.6.9. Yards: change from Front: 1.5m / Side: 1m / Rear: 1m to Front: 0m / Side: 0m / Rear: 1m. This would enable building out the front of the site and leave more space at the rear.

In addition, I encourage Auckland Council to enable low intensity commercial activities (such as dairies and cafes up to 100m2) within the THAB zone to be permitted activities. This should encourage local services to be established within walking distance of higher density living and will make these areas more attractive to live in with services within walking distance.

Chapter G: RUB and Walkable Catchments

Figure 3. Eastern Busway corridor with new bus stations as red dots

I question why the corridor for the Eastern Busway has not been included in the walkable catchment areas for the Rapid Transport Network stops, with only Pakuranga Bus Station included. This is one of the most significant transport projects underway in Auckland that will provide considerable additional transport capacity with new stations at Edgewater, Gossamer and Burswood yet the corridor has not been identified as within the walkable catchment. Given the massive amount of construction and disruption that will occur along this route during disruption, surely now is the time to enable new zoning.

Qualifying Matters: Water and Wastewater Servicing Constraints

Figure 4. Water and Wastewater Servicing Constraints overlay for East Auckland

I support the limited use of the qualifying matter for areas which have been identified as lacking the infrastructure to cope with water, stormwater and wastewater. It was good to see that these areas included a plan to address the gaps, including timeframes. In particular Mellons Bay, Howick and Cockle Bay which have old infrastructure that struggles with existing demands (figure 4).

However, given the large number of properties through Pakuranga and Howick (and surrounding suburbs) that flood during heavy rain yet don’t feature in this overlay I question how well the current capacity is understood and therefore how accurate the controls are for stormwater disposal.

General comments

While I appreciate the complex nature of the legislation and required plan change, I am disappointed in the feedback process. While the interactive map is relatively easy to navigate, the related documents are deeply technical. While some effort has been made to provide simple English explanations in the information sheets, they don’t provide any references to the technical rules that submitters need to quote in their feedback.


Form details

My submission relates to

Rule or rules:
Chapter D: Overlays - Historic heritage and special character
Chapter H: Residential Zones
Chapter G: RUB and Walkable Catchments
Qualifying Matters: Water and Wastewater Servicing Constraints

Do you support or oppose the provisions you have specified? I or we support the specific provisions identified

Do you wish to have the provisions you have identified above amended? Yes

The reason for my or our views are:
While I do not support the process that parliament undertook to implement the enabling legislation, I do support the enablement of greater intensification.

Enabling more homes will help improve affordability and address some of the causes of the housing crisis, including helping improve the quality of our housing stock. We cannot afford to continue encouraging urban sprawl - it’s unsustainable and covering fertile soil in concrete and asphalt. Greater urban spread creates more infrastructure demands, while a denser urban form will lead to more concentrated investment. Therefore we must focus our efforts on ensuring that the intensification that is delivered is done well.

In my local area of East Auckland, we’ve seen what happens when poor planning enables intensification that lacks the required infrastructure and rules to be successful and sustainable. As a renter, I’m keenly aware of the housing affordability issues and poor quality housing stock. I’ve lived in Auckland my whole life and I know the potential that our city has. I’ve also had the opportunity to travel overseas and see how others have done it (good and bad). We must take this opportunity to ensure that we deliver the best possible outcomes for Auckland, now and into the future.

Please refer to the attached submission for more specific comments and feedback.

I or we seek the following decision by council: Approve the plan change with the amendments I requested

Details of amendments: Please refer to the attached submission for specific amendments.

Submission date: 29 September 2022

Supporting documents
2022-09-29 Plan Change 78 Submission - Damian Light.pdf

Attend a hearing: Do you wish to be heard in support of your submission? No

Declaration:

Could you gain an advantage in trade competition through this submission? No

Are you directly affected by an effect of the subject matter of this submission that adversely affects the environment; and does not relate to trade competition or the effects of trade competition. No