Phil McDermott: Planning to Fail - Wrong Assumptions, Wrong Policies

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?

Given the direction underlying the Auckland Plan – a compact city focused on an intensively developed CBD and relying on a legacy of heavy rail and buses (and now, perhaps, trams) to alleviate congestion – the PAUP will inevitably impact on many people and organisations.  It is surprising, then, that the evaluation of policies did not deal with the distribution of costs and benefits.
  

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.

And what of the quality?

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).[1] 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

The Plan certainly needs to address the future of Auckland’s suburbs: this has been a failing all along in a city which is no longer mono-centric and in which any expansion will be shaped by the simple fact that it is contained on a narrow isthmus.  But this sudden zone change is knee jerk reaction to what has been revealed as an ill-informed plan.  It has no apparent regard for matters of open space, transport and transit, commercial services, schools and other public services, or community and recreational amenities, all critical to the quality of suburban life.
 

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?

The uncritical foisting of a particular set of beliefs – that the way to the future is through less of what we have now -- raises fundamental questions over the practice of resource planning, not just in Auckland, either.  Whatever we call it -- urban design, place making, or resource management –an autocratic and patronising mind-set today permeates urban planning and is increasingly reflected in the diminishing capacity of elected councillors and board members to influence outcomes. [2]

Planning to fail

All this will make life that much harder for many Aucklanders to live here, especially those who do not already own a home.  While much is made of the City's growing diversity there is little evidence that the plan is sensitive to differences in places, communities, and circumstances, or that it is flexible regarding where and how different peoples might live. It looks set to sustain and even exacerbate the division between those who stand to benefit from property ownership and those to whom the Plan offers little hope of home ownership, and the social, health, schooling and employment benefits that brings. 

The proposed unitary plan looks set to accentuate divisions rather than accommodate diversity.

Time to think about connections and consequences

Unless there is a radical change in the way we plan, I see little prospect of sustaining the growth Auckland has recently experienced or of achieving the projections that the Plan is built on. For all its expertise, the Group convened by the Independent Panel failed to agree on what the Plan provides by way of capacity, or to forge the link between housing supply and demand.

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. 

The failure to provide land for sufficient dwellings so graphically illustrated in the Expert Group’s report (and in others [3]) must lead to a decline in demand as prices escalate.  We may have a liveable city on some measures if the PAUP is somehow implemented, but for whom and for how long?

---

[1]        Topic  013 Expert Group (July 2015) Residential Developable Capacity for Auckland Report to Auckland Unitary Plan Independent Hearing Panel

[2]       And unfortunately this is not about to be changed by the Government’s latest tinkering with the Resource Management Act,

[3]       Quite apart from the many submissions to this effect (see Hearings Topic 13 at the Independent Hearings Panel website), the Productivity Commission has published two compelling reports on this issue.