This article was first published on Phil's Cities Matter blog on Friday, November 27, 2015
A Complex and Contested Plan
Deficiencies in the vision for a compact city promoted in the Auckland Plan are apparent in the contested nature of the statutory document intended to implement it. The Proposed Auckland Unitary Plan (PAUP) has attracted 13,000 submissions and is subject to extensive hearings by an independent panel.
The proposed Plan is complex and detailed. It aims to manage the public domain and private behaviour mainly by regulating land use, defining in detail what can be done, how, and where. And because there will be winners and losers from applying its many rules, it is not surprising that many people are concerned at the content.
Where is the evaluation?
But then, the analysis, such as it is, is not very strong on costs and benefits at all. Anyway, despite the long list of papers and reports assembled in support of the PAUP (the “Section 32 Report”), few appear relevant to or reflected in the land use policies adopted.
The evaluation is focused, the S32 Report claims, on “the objectives and provisions within the proposed Auckland Unitary Plan that represent significant changes in approach from those within the current operative Auckland RMA policies and plans”.
The comparison of policy options required for evaluation appears to have relied on a bunch of like-minded people comparing four somewhat arbitrary scenarios of the future. Curiously, all four scenarios are based on a single population projection as if how we plan has no impact on the outcomes! That hardly matters, I guess. I could see no recourse to any formal analysis of policies anyway, and no obvious attempt to distinguish the marginal differences among them that an evaluation of changes from “current operative policies and plans” would call for.
My concern about the quality of evaluation is heightened because the proposed Plan’s spatial policies are based on misleading analysis. The fundamental assumption that the proposed plan needs to provide sufficient capacity for an additional 400,000 households over the next thirty or so years is demonstrably wrong.
Having heard the level of disagreement among experts about the credibility of this number, the Hearings Panel back in April asked them to jointly produce an estimate that they could agree on.
They couldn’t. Over several months of collaboration and analysis the best the group could come up with was an estimate of 83,420 “developable feasible” dwellings – or 26% of the Auckland Council’s Plan estimate (013 Expert Group, p5). And despite acknowledging that this was much more realistic , the Group failed to reach a consensus on a final number.
Which to my mind was just as well: to believe that we can predict both dwelling demand and supply without even seriously referencing the impact of price on demand (among other shortcomings) over 25 to 30 years is a conceit too far. The more we refine such projections, seek consensus, and treat the results as reality, the less we are prepared for the uncertainty that inevitably attends our plans, and the greater the risk that, in our ignorance, we adopt inappropriate policies.
So what happens when the policy makers get it wrong? They keep going regardless
What is even more disturbing, though, is that the Council gives the appearance of cynically changing the Plan rules to offset its miscalculation. This has been done in haste, apparently, without reconsideration of the policies they support, without obvious analysis of the effects of these changes, and certainly no consultation with those affected. Hence, the New Zealand Herald reported in September that by relaxing rules within the plan, council planners were able to get their capacity numbers over 150,000 (still a long way short of what the plan is supposed to deliver).
To help achieve this, the heritage provisions of the Plan, always problematic, were effectively dumped in October. And in November, the Council’s Unitary Plan Committee accepted changes to the Single House Zone in central and western suburbs to Mixed Use to enable townhouses, studios and apartments to achieve the new number.
Now where did that come from? I have searched the Council website for an analysis of the effects of these new policies and cannot find it. At least the media is prepared to air the changes and their potential effects.
Dumping on the suburbs
Simply creating new rules that can fundamentally change the character of suburbs because the planners got it wrong first time round without any obvious attempt to appraise or moderate adverse effects undermines the credibility of the proposed Plan, the process, the planners, and the politicians. And it’s cynical to the extent that it potentially circumvents the independent hearing process and suggests that the Plan is no more than an ad hoc means to an arbitrary end.
A step too far?
Planning to fail
The proposed unitary plan looks set to accentuate divisions rather than accommodate diversity.
Time to think about connections and consequences
A new approach is called for. Let’s treat housing as a right, land for housing as a necessity, and prepare a plan that enables us to provide it in a cost effective and timely manner.
 Topic 013 Expert Group (July 2015) Residential Developable Capacity for Auckland Report to Auckland Unitary Plan Independent Hearing Panel