Have Your Say on Auckland Council’s new housing rules

FEEDBACK TO AUCKLAND COUNCIL ON THE PRELIMINARY RESPONSE TO THE NATIONAL POLICY STATEMENT ON URBAN DEVELOPMENT (NPS-UD) AND THE MEDIUM DENSITY RESIDENTIAL STANDARDS (MDRS)

Auckland Council currently has its new housing rules out for consultation with Aucklanders in a very short timeframe. Feedback is due by Monday 9th May 2022!

You can read about the council’s proposals for housing rules here and what it means for Auckland and Remuera. The proposals remove the Special Character Area Overlay and the Single House zone from most of Remuera. This means that if your property is now zoned THAB you can have a six-storey apartment block built next to you under the Terrace Housing & Apartment Blocks (THAB) zoning to 6 storeys or 3 houses of 3 storeys under Mixed Housing Urban, including up the slopes of Ohinerau Mt Hobson.

Check the council’s draft planning maps here.

Check your and your neighbours’ zoning in the maps.

Use the submission form here to give feedback by Monday 9^th of May 2022. You can support our feedback if you wish.

You can also donate to the efforts of Remuera Heritage and the Character Coalition to fight these new rules here on GiveALittle. Please seriously consider this.

Feedback and Recommendations by Remuera Heritage

1. There was no government directive about Special Character Area Overlays. Councils are able to make their own decisions regarding what is a qualifying matter.

Recommendation: Residential special character overlay areas should therefore ALL be retained as a qualifying matter under the new NPS, at least until the community has had adequate time and resources to analyse this in-depth. A mere 3.6% of the whole city has a character overlay. NO housing supply will be impeded by retaining character areas as a qualifying matter.

2. Further, the housing supply that would replace demolished properties on larger sections or are zoned Residential Mixed Housing Urban will not supply affordable housing, especially in Remuera. Underlying land values are high and will not support the building of affordable housing

3. The bulk of the site-specific analysis was done by desk top surveying.

Recommendation: All areas should have a field survey also done, allowing enough time to carry this out.

4. No findings relating to Remuera were found to be of high quality as the properties did not meet the walkable catchment threshold of 75% for scores 5 and 6 or for the non-walkable catchment threshold of 66%. However, if score 4 is added to 5 and 6, then Bassett Rd, Remuera East, Remuera Isthmus B and Ohinerau Mt Hobson all meet the threshold.

Recommendation: Our recommendation is to include those properties scoring 4.

5. In the council document SCA Residential Survey Guidance, it states

“The following ratings are for guidance purposes only. Terms like “character-defining” and “neutral” are only to be used to help surveyors sense-check their results. This terminology does not come from or relate to the AUP and may change during the life of the project.

• 1. • Sites that score 6 – character defining
     • Sites that score 4 or 5 – character supporting
     • Sites that score 2 or 3 – neutral
     • Sites that score 0 or 1 – detracting
  2. Sites that score 5 or 6 are included in the overall determination of the level of each character area (this is subject to change during the life of this project), which is calculated as part of the Summary of Area Findings report.”

Recommendation: The sites that score 4 should be added to those which score 5 and 6, as they are both deemed to be “character supporting”.

6. Rear properties have been unfairly excluded because they cannot be seen from the street but in some areas like Remuera, there are many larger sections with grand old houses which were not zoned Single House but as Mixed Housing Suburban. Now they are zoned Residential Housing Mixed Housing Urban g. 37 St Vincent, 37 Upland Rd, 78 Orakei Rd, 44 Ventnor Road, 226 Remuera Rd, Market Road have all had large older houses demolished to make way for townhouses selling at $1.3+ – this is unsustainable and not ‘affordable’ housing.

Recommendation: Include houses on rear sections that have heritage values whether they are visible from the road or not.

7. Walkable catchments which have been defined are not always correct. A walkable catchment is a 10 minute walk (800 metres) from a metropolitan centre such as Newmarket. But according to Google Maps –

1. 1. Arney Road which is deemed to be within a walkable catchment, is 1.1km (not 800 metres) to 10 Arney Road and takes 14 minutes, not 10.  160 Arney Road is 1.4 kms from Newmarket and takes 19mins.
   2. Bassett Road is a 12 minute walk (850 metres)
   3. Ohinerau Mt Hobson is 2.1 km from Newmarket, a 27 minute walk.
   4. 1 Warrington Road is 1km, a 12 minute walk from Remuera Station, and 1.4km, a 19 minute walk from Newmarket.
   5. 10 Victoria Avenue is 2.3km, a 29 minute walk from Newmarket Station

Recommendation: In Remuera a walkable catchment from Newmarket would finish along Remuera Road at about the start of Bassett Road. The walkable catchment areas should be reviewed.

8. It may be useful to discontinue the use of the term ‘special character’ as it is rather vague and non-specific. Heritage New Zealand have proposed using the term ‘heritage character’ or ‘historic character’ to better reflect the uniqueness of wooden buildings in older suburbs. Recommendation: We recommend either of these terms be used as they would enable a more targeted approach to heritage values.

9. We would also like to look at what high-value special character properties could be added to a special character overlay, in light of No.10 or where council has determined that a road such as Arney Road does not qualify as ‘high-quality’ special character, even though it has 9 houses listed on the council’s Historic Heritage Schedule or Heritage N Z’s list!

Recommendation: allow time for additions to be added to ‘special character’.

10. Finally, Auckland needs to retain large properties with substantial family homes in order to attract high-wealth individuals, professionals, CEOs and extended families to live in Auckland. This may be seen as elitist but the reality is there are people who want to live in large family houses with heritage values.

11. There has been very little time (3 weeks) to examine the findings by the council on the Have Your Say website. The time period includes2 weeks of school holidays where people have been absent. Full-time workers have had only 2 weekends to examine the findings. Community groups have not had enough time and resources to read and understand the content and implications and then communicate meaningfully it to their local communities. Efforts and resources needed by local communities to give detailed feedback to the council are huge.

SPECIFIC EXAMPLES OF PROPERTIES WITH INAPPROPRIATE ZONING

1. The finding for Ōhinerau Mt Hobson (Isthmus C) has the properties on the side of Ohinerau Mt Hobson zoned Terrace Housing and Apartment Blocks (THAB) because they are in the walkable catchment area of Remuera Station or on Remuera Road. Under the Unitary Plan, these were zoned Single House. It is of great concern that this area has gone from one extreme to the other. The Tupuna Maunga Authority has said that “for more than a century, they (the maunga) were administered by city and borough councils that allowed some to be destroyed and houses to be built on others…few people were aware of their deep cultural, historical, geological and archaeological significance.”[i] The Special Character Area Overlay for the north side of Market Road, Mt Hobson Lane and Pere Street must be retained and zoned Two-Storey Single Dwelling Residential Area, in order to protect this unique sacred maunga.
2. Remuera Road. The area between Glen Esk Place and Portland Road was zoned Single House in the Unitary Plan, covered by the Special Character Area overlay. Of the 20 properties previously zoned Single House and built in the period 1890-1940, all are now zoned THAB or Residential Mixed Housing Urban without the SCA. These well-maintained substantial historic houses should form a sub-area and be zoned Two-Storey Single Dwelling Residential area. They should be considered in conjunction with the properties on the side of Mt Hobson along Remuera Road.
3. Rangitoto Avenue has 19 houses zoned Single House Zone of which 15 (79%) were zoned Single House with the SCA and built between 1910 and 1930. Now all are zoned Mixed Housing Urban without SCA overlay. The 79% of houses should score a 6 or 5. And if Score 6 and 5 and 4 were added together the result would likely be over 66% in a non-walkable catchment area.

Note

You can read about the council’s proposals for housing rules here and use the submission form here to give feedback by the 9^th May 2022.

You can also donate to the efforts of Remuera Heritage and the Character Coalition to fight these new rules here on GiveALittle.

Remuera Heritage

30 April 2022

[i] NZ Herald, Maunga Authority delivers on co-governance, 29 April 2022

Remuera Residents Association

In the last month Auckland Council has opened a consultation window before it makes changes to our Unitary Plan. Changes are directed by an Act of Parliament – the National Policy Statement – Urban Densities (NPS-UD). There are certain qualifying matters that can reduce the impact of the Act on Auckland.

At our well attended public meeting & AGM in the Remuera Library last Thursday the extreme nature of proposed changes and the urgency of citizens response became apparent to all. To aid individuals as they “have their say” we prepared & distributed the following commentary for use when responding to questions raised in the Council’s survey:

KEY MESSAGES FOR PEOPLE PROVIDING FEEDBACK
The Council will pay more attention to our response to their survey if you express them in your own words. Some suggested key points are set out below. Council only has limited scope to moderate the Government’s push for intensification, so your feedback will be most effective if it focuses on Council’s specific questions.

Walkable Catchments and Intensification

• We think the proposed walkable catchments for the CBD, metropolitan, centres (e.g. Albany) and rapid transit stops (1200m, 800 m and 800m respectively) are sensible – they will help focus intensification on areas where it is appropriate.
• We do not support Council’s proposal to apply Terrace Housing and Apartment Buildings Zone in areas up to 400m from town centres, or 200m from local centres. We think these distances should be closer, because those centres are already quite small (with limited public transport links and parking), and would lose their neighbourhood feel if they were surrounded by a large band of high density housing.

Special Character Areas

• We do not support Council’s proposal to include just the “identified” (blue) special character areas as a qualifying matter. All existing special character areas should be a qualifying matter.
• Council’s proposed new rules for identifying “special character areas” are too narrow. The existing special character areas should all be retained, including all in Remuera. They are areas of high character value with an important historical heritage. They should be protected to ensure the area keeps its distinctive character and unique history.
• We do not support Council’s proposed residential special character areas. We think there are more areas that should be identified as a qualifying matter – ie, all special character areas, not just a subset.
• Councils scoring system is too restrictive:
o The proposal requires 66% of individual properties in an area to score 5/6 or 6/6 on a character assessment, before the area would qualify to keep its “special character area” status. The 66% threshold should be lower – (eg. 50% – still a majority of character houses)
o Also, properties scoring 4/6 (which council accepts are still “character supporting”) should be counted towards the percentage test as well, not just 5/6 & 6/6.
• Many other suburbs that are keeping their “special character area status” were surveyed in person by Council representatives doing site visits. Remuera was just assessed using Google Street View, which means Council’s scoring for these areas does not properly show their true character status.

Infrastructure Constraints

• We support Council’s proposal to include areas in Auckland with long term significant infrastructure constraints as a qualify in matter, meaning that infrastructure should be taken into account as a limitation on increased housing density.
• There are areas in Remuera already badly affected by freshwater flooding after heavy rainfall. Increased densification will only make that worse, because more building site coverage means more stormwater runoff. The area does not have the stormwater infrastructure to manage that – there are Sensitive Ecological Areas (SEA’s) in Remuera that would be badly harmed by increased silting and runoff.

AUCKLAND COUNCIL has prepared a preliminary response to the NPS-UD and the Act, that shows how they think they could apply to Auckland. A summary of this preliminary response is explained in the consultation document available on akhaveyoursay.nz/housing, and the planning maps are shown in the draft NPS-UD map viewer (the link to the map viewer is available on akhaveyoursay.nz/housing

Remuera Residents Association
7 May 2022