Submission by Transpower New Zealand Limited on the proposed National Policy Statement on Urban Development Capacity

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1 Submission by Transpower New Zealand Limited on the proposed National Policy Statement on Urban Development Capacity 15 July 2016 Address for service: Transpower New Zealand Ltd PO Box 1021 Wellington 6140 Attention: Jo Mooar, Team Leader, Regulatory Environment, Environment Policy and Planning Group Telephone:

2 Executive Summary 1. Transpower welcomes the opportunity to submit on the proposed National Policy Statement on Urban Development Capacity (the pnps-udc). 2. Transpower understands that there is a critical need to ensure sufficient developable land is available to meet housing demand. 3. Transpower seeks limited but important amendments to the pnps-udc to achieve the following two key outcomes: (a) (b) That the pnps-udc does not cut across or undermine the National Policy Statement on Electricity Transmission 2008 (NPSET); and That the infrastructure provisions, including those relating to consultation, apply to the National Grid. Transpower is the owner and operator of nationally significant infrastructure. Frequently, this infrastructure is located on, and traverses, developable land. It is critical that Transpower can participate in, and be heard on, any assessment of urban development capacity involving land traversed by National Grid assets so that it can protect its vital infrastructure from the adverse effects of urban activity.. The pnps-udc should not undermine the NPSET 4. The NPSET recognises that unrestricted housing development under and near to the National Grid, can constrain the operation, maintenance, upgrade and development of the Grid. 5. Policy 11 of the NPSET protects the National Grid by requiring a buffer corridor within which it can be expected that housing (and other sensitive activities) will generally not be provided for in plans and/or given resource consent. Policy 10 of the NPSET requires decision-makers, to the extent reasonably possible, to manage activities to avoid reverse sensitivity effects on the National Grid and to ensure that operation, maintenance, upgrading, and development of the National Grid is not compromised. 6. The rationale for these policies is housing that is located too close to National Grid support structures, lines and substations creates safety hazards, restricts Transpower s access for maintenance, upgrade and emergency repair work, and creates or contributes to reverse sensitivity impacts (for example where occupants complain about the noise of a line or substation or their visual effects). 7. Local authorities have been giving effect to the NPSET in their regional policy statements and regional and district plans since Some councils have completed this process and many others are underway with implementation. 8. The pnps-udc has the potential to undermine these efforts. It requires councils to identify and provide for development capacity without recognising that development under and adjacent to the National Grid is, or should be, restricted. The pnps-udc does not address the conflict between its provisions and Policies 10 and 11 of the NPSET. 9. In the absence of direction, councils implementing the NPS-UDC will have to be cognisant of, and reconcile for themselves, the provisions of the NPS-UDC with Policies 10 and 11 of the 2

3 NPSET. This could be costly and time-consuming for councils, Transpower, and other submitters and lead to ad-hoc and inconsistent interpretations that constrain the National Grid and undermine the NPSET. 10. It would be more efficient, effective and provide greater certainty if the pnps-udc contains specific direction to councils that when they identify and assess the capacity of land for urban development they must give effect to policies 10 and 11 of the NPSET. The infrastructure provisions in pnps-udc should apply to Transpower 11. Third party development can occur in a way that is compatible with Grid infrastructure through consultation and proactive management. However, unless the constraints of the National Grid are recognised and appropriately managed, new development can significantly compromise the National Grid. In time, this will mean that vital maintenance and upgrade work cannot be carried out, and new replacement infrastructure will be required at significant national cost. This is why New Zealand has, and councils implement, the NPSET. 12. It is important that local authorities consult with Transpower as an infrastructure provider when developing plans and regional policy statements to implement the pnps-udc. This will ensure that potential conflicts between the need for urban land and the extent of development capacity and the operation, maintenance, upgrade and development of the National Grid are identified and appropriately managed at an early stage. It will be highly beneficial for local authorities and Transpower to work together to ensure coordinated land use planning as it relates to the National Grid. 13. Transpower s proposed amendments to achieve the two key outcomes outlined above, are set out in Appendix D to this submission and explained in further detail in Table 1 below. Houses under National Grid lines and adjacent to National Grid substations 14. The National Grid traverses every district in New Zealand except Kaikoura, Gisborne and the Chatham Islands (see map attached as Appendix A). 15. The vast majority of Grid assets (lines and substations) were originally constructed on rural land. Over time, the assets have become surrounded and in places severely underbuilt by residential, industrial and other development (see photos attached as Appendix B). In particular, unrestricted and incremental housing developments have, over recent decades, significantly constrained the National Grid. 16. Transpower has structures (towers and poles) on approximately 10,000 properties through the country and the network traverses some 30,000 properties. 1 93% of Transpower s 12,000km network is over land for which our access rights exist only by virtue of statute (the Electricity Act 1992) Transpower manages and maintains its transmission line fleet to have a perpetual life. It is vital that Transpower is able to access, maintain and upgrade the National Grid in order to deliver a reliable, secure supply of electricity nationally. The Grid is interconnected so maintenance issues on one section of a line can have supply impacts much further away. 1 Transpower, Transmission Tomorrow, May 2016, publications/resources/transpower%20-%20transmission%20tomorrow pdf, 5. 2 Most of the remainder are through registered easements (7%) and property owned outright (0.2%). 3

4 18. While the Electricity Act provides Transpower with legal access for maintenance and upgrade work, it does not ensure or provide for physical access or ensure third party development occurs safely and in a way that does not constrain the ongoing operation, maintenance and upgrade of the Grid. 19. Often, under-build (houses or industrial buildings for example) under or near to lines can restrict or even prevent Transpower workers from accessing assets, therefore delaying or preventing important maintenance work (see Photo 5 in Appendix B). Underbuild can significantly delay emergency response times and create electrical hazard risks and reverse sensitivity impacts. National Policy Statement on Electricity Transmission The NPSET recognises the national significance of the National Grid and requires councils to provide for its effective operation, maintenance, upgrading and development. 21. One of the central aims of the NPSET is to protect the National Grid network from inappropriate development near or beneath Transpower assets. National Grid transmission lines are usually much taller than distribution company lines and therefore can be built under. Electricity Act property rights or Electrical Safety Codes 3 do not prevent underbuild, nor do they manage effects such as restricted access or reverse sensitivity. 22. National Grid lines have unique characteristics. They are not static. The sag and extent of conductor swing depends on a number of factors, including the operating temperature of the line, conductor type and tension and wind speed. Conductors can swing out to 37m either side of the centreline and sometimes further (see photo 6 in Appendix B). 23. Lines constrain development for at least the area where they are physically present during high winds. Any construction plans and building designs need to take this area into account and design accordingly. 24. It was in recognition of effects such as these that the Government approved the NPSET in 2008 following an extensive Board of Inquiry and public consultation process. 25. Policy 11 of the NPSET directs that sensitive activities (such as houses) are generally not to be provided for in plans and/or given resource consent. Policy 10 directs councils to avoid reverse sensitivity effects to the extent reasonably possible and ensure the operation, maintenance, upgrade and development of the Grid is not compromised. 26. Transpower has been working with regional and district councils since 2008 to implement the objectives and policies of the NPSET into council planning documents. Importantly, many councils have recognised that planning provisions that allow houses to locate relatively easily close to lines (through land use or subdivision consent applications) would not give effect to the policy directions in the NPSET. 26 territorial authorities have now included corridor provisions in their plans requiring a 12m setback for sensitive activities from the edge of National Grid support structures and from the centreline of National Grid transmission lines. 22 territorial authorities have plan changes or district plan reviews underway. 16 are yet to start implementing the NPSET. 3 For example the New Zealand Electrical Code of Practice for Electrical Safe Distances (NZECP34:2001). 4

5 27. Importantly, Transpower does not want to prevent development from occurring but simply seeks that development is designed in a way that takes the lines into account. There are numerous ways in which development can occur near transmission lines appropriately and safely and without compromising Transpower s requirements. Subdivision offers an opportunity to design a development to provide the buffer corridor required by the NPSET, and also to ensure allotments are big enough to allow a building to be safely constructed. Failing to take the lines into account at appropriate stages can increase development costs, with redesign being necessary. 28. Attached as Appendix C are some examples of how subdivision can be successfully designed around National Grid lines without compromising housing yield. 29. Transpower has been involved in numerous greenfield subdivisions which have appropriately given effect to the NPSET and avoided adverse impacts on the National Grid. Those where early engagement has occurred have been successful in protecting the Grid, and also ensuring efficient plan processes. Costly redesign has been necessary, including demolition of some buildings, where we have not been involved at the right stages. 30. It is important for planning framework tools (such as National Policy Statements (NPS)) to recognise not only the importance of providing for servicing infrastructure in residential developments, but to also recognise the presence of nationally significant infrastructure and the impacts that development may have on that infrastructure. Nationally significant infrastructure generally does not directly service development, but may cross through areas to be developed. Mandatory notification of relevant plan changes and resource consent applications is also critical to ensure infrastructure such as National Grid lines and substations are protected. Competing NPSs 31. NPSs sit at the top of the hierarchy of RMA planning documents and need to be read together. They have to be given effect (implemented) in lower order planning documents. 32. The Supreme Court in NZ King Salmon has held that NPSs, which have gone through a Part 2 balancing process through their development, are not in turn subject to an overall broad judgement of effects. The policies in an approved NPS are deemed to meet the sustainable management purpose of the RMA. 33. Transpower has had experience in the past 18 months with attempting to resolve policy inconsistencies between the New Zealand Coastal Policy Statement 4 and the NPSET. 5 Transpower s view is that it would be more efficient to resolve any policy inconsistencies to the greatest extent possible during the development of the later NPS, rather than leaving conflicting policies to be implemented and reconciled on an ad hoc basis by local authorities. An ad hoc approach could undermine the policy objectives and national direction set by an NPS. 34. Transpower seeks that the pnps-udc recognises the strong directions in the NPSET (in particular Policies 10 and 11). These policies are directly relevant to the pnps-udc. They 4 Policies 11 and 13 which require adverse effects to be avoided in sensitive coastal environments. 5 Policy 8 states that planning and development of the Grid should seek to avoid adverse effects on certain sensitive/high value environments in rural locations. 5

6 protect the National Grid from the adverse effects of incompatible, unmanaged sensitive activities, such as new housing. 35. Transpower seeks that any initiatives around releasing constraints on housing, do not undermine the objectives of the NPSET by allowing (or making it easier for) housing to develop in close proximity to the National Grid (both lines and substations). It seeks that when land is released and development capacity is assessed, constraints on residential activity arising from the existence of the National Grid are properly taken into account. Amendments sought to the pnps-udc 36. Transpower seeks the amendments set out in track change in Appendix D. Table 1 explains the reasons for these amendments and the potential consequences if the amendments are not made. Table 1 Amendment sought by Transpower Reason for amendment Potential consequence if amendment is not made Development capacity means in relation to residential and business land, the capacity of land for urban development to meet demand, taking into account the following factors: the zoning, objectives, policies, rules and overlays that apply to the land and any relevant National Policy Statement or National Environmental Standard; and. Infrastructure means network infrastructure for water supply, wastewater, stormwater, electricity distribution and transmission, transport, and passenger transport The assessment of development capacity needs to take into account relevant NPSs or National Environmental Standards because these planning instruments may restrict the extent to which land is available for urban development. For example, 38 territorial authorities have not yet fully given effect to the NPSET and so buffer corridors are not currently identified in their operative plans. However, buffer corridors are still required which will limit the capacity of some land for urban development. This should be taken into account when Councils assess how much land is required to meet demand for housing. Electricity distribution and transmission are critical infrastructure. Transmission infrastructure does not directly service development but may be constrained by it 6 Councils may mistakenly include land under and adjacent to the National Grid as part of their assessment of development capacity. This will mean they have overestimated the extent of land available to meet demand. It may also raise expectations that such land will be available for housing development. Councils may fail to assess whether or not there is adequate electricity supply existing or likely to exist to support the development of land. Councils may not

7 services. Infrastructure providers means the providers of network infrastructure for water supply, wastewater, stormwater, electricity transmission and distribution, transport, and passenger transport services. PA3: When considering the effects of urban development, decisionmakers must: Provide sufficient development capacity, whilst maximising the positive effects of development, and minimising the adverse effects of development, including reverse sensitivity effects. Give effect to Policies 10 and 11 of the National Policy Statement on Electricity Transmission for the reasons explained above. Electricity infrastructure should be recognised in the definition of infrastructure in the pnps-udc. A number of the provisions of the pnps-udc require consultation with infrastructure providers, and for councils to work with them. Transpower considers councils need to consult with them to ensure coordinated land use planning and infrastructure provision, and to avoid potential conflicts with the National Grid. The direction in the pnps- UDC to minimise the adverse effects of development is inconsistent with the direction in policies 10 and 11 of the NPSET. Councils are legally required to give effect to the NPSET so it would be most effective and efficient to make it clear that this is a requirement when considering the effects of urban development under the pnps-udc. consult with Transpower about development capacity involving land traversed by the National Grid. This could compromise critical Grid infrastructure and undermine the NPSET. This may result in poor planning outcomes that fail to give effect to or undermine the NPSET. Increased cost and delay as Transpower seeks to correct individual plan changes and resource consents. There could be adverse health and safety effects on owners and occupiers of new housing, reverse sensitivity effects, and increased costs to electricity consumers due to limitations and restrictions on access for maintenance and upgrade work. Each council will be required to reconcile the provisions of the pnps-udc with policies 10 and 11 of the NPSET. This is likely to result in: a) Ad-hoc interpretation; b) Increased costs for councils, Transpower, and relevant submitters in debating the issue; and c) Increased litigation, delays and uncertainty for councils, Transpower, and developers. In cases where housing is enabled under or adjacent to the National Grid it will result in adverse effects on the National Grid and owners and occupiers of affected houses as described above. PB3: In carrying out the The assessment of the Councils may mistakenly 7

8 assessments required under policy PB1, local authorities must estimate the sufficiency of development capacity provided by its plans and proposed and operative regional policy statements, having particular regard to: The cumulative effect of all zoning, objectives, policies, rules and overlays in plans, and provisions required, or likely to be required, to give effect to other National Policy Statements or National Environmental Standards, and the effect this will have on opportunities for development being taken up. sufficiency of development capacity needs to take into account relevant NPS or National Environmental Standards because these planning instruments may restrict the extent to which land is available for urban development. For example, 38 territorial authorities have not yet given effect to the NPSET and so buffer corridors are not currently identified in their operative plans. However, buffer corridors are still required which will limit the capacity of some land for urban development. include land under and adjacent to the National Grid as part of their assessment of sufficiency of development capacity. This will mean they have overestimated the extent of sufficient land available to meet demand. PC1: When developing plans and regional policy statements to implement this National Policy Statement, local authorities must consult with other local authorities, local infrastructure providers and central government infrastructure providers that share jurisdiction over, operate within, have assets located on, or that traverse a Medium Growth Urban Area or a High Growth Urban Area. The term jurisdiction does not capture the interests of all infrastructure providers in relevant assets in a Medium Growth Urban Area or a High Growth Urban Area. It will be highly beneficial for local authorities and Transpower to work together to ensure coordinated land use planning as it relates to the National Grid. Some key infrastructure providers may not be consulted with on the basis they do not have jurisdiction over a Medium Growth Urban Area or a High Growth Urban Area. This may result in avoidable issues for plans and regional policy statements. Attachments Appendix A: Map of National Grid Appendix B: Photos of incompatible development around and under National Grid lines and conductor swing Appendix C: Examples of subdivision design that is compatible with National Grid lines Appendix D: Track changes version of pnps-udc showing changes sought by Transpower 8

9 Appendix A: Map of National Grid 9

10 10

11 Appendix B: Photos of incompatible development around and under National Grid lines and conductor swing Photo 1: Subdivision development in South Auckland around National Grid tower Photo 2: Work on a line in Auckland 11

12 Photo 3: Residential underbuild in Auckland Photo 4: Tower maintenance (abrasive blasting and painting) in residential area 12

13 Photo 5: New house being built in Auckland. The location of the house restricts Transpower s access to the tower. Photo 6: Conductor blowing out in high wind 13

14 Appendix C: Examples of subdivision design that is compatible with National Grid lines 14

15 Appendix D: Track changes version of pnps-udc showing changes sought by Transpower Proposed National Policy Statement on Urban Development Capacity 2016 Preamble New Zealand is one of the most urbanised countries in the world, with 73 percent of us living in cities of at least 30,000 people 6. Cities are characterised by their intensity, the access they provide to things that people value, their scale, and often by high rates of population and economic growth. These have both positive and negative impacts: successful cities maximise the positives and minimise the negatives. Successful cities provide people with access to a choice of homes and opportunities to earn income, and attractive built and natural environments. They have good quality physical and social infrastructure and open space. They use resources efficiently, and they minimise their environmental footprint. They make the most of their ability to connect to other parts of the world. Such cities attract people and investment, and are therefore constantly changing, dynamic places that make a significant contribution to national economic performance. Local authorities play an important role in shaping the success of our cities by planning for growth and change, and providing some critical infrastructure. Ideally, urban planning should enable people and communities to provide for their social, economic and cultural wellbeing through development, while managing its effects. This is a challenging role, because cities are complex places; they develop as a result of numerous individual decisions, and this often involves conflict between diverse preferences. This National Policy Statement provides direction to decision-makers under the RMA on urban planning. It has a particular focus on ensuring that planning enables development through providing sufficient development capacity for housing and businesses. The National Policy Statement aims to help reduce regulatory barriers to the supply of housing, and reduce the cost of housing relative to income. High house prices drive wealth inequality, increase the fiscal burden of housing-related welfare, and pose a risk to the national economy. It is also important that planning provides good accessibility between housing and businesses, and the social infrastructure necessary in a successful city. 6 According to Statistics New Zealand s most recent estimates. 15

16 An overarching theme running through this National Policy Statement is that planning decisions must actively enable growth and development in urban areas, and accommodate that in such a way as to maximise wellbeing now and in the future. The National Policy Statement requires plans to provide sufficient development capacity to meet long term demand. This includes both the total number of dwellings and the amount of business space needed, and the range of demands for different sizes, types and locations. Another key theme running through the National Policy Statement is for planning to better understand the property market and enable it to provide for the community s needs. While taking account of all factors that affect well-being, planning should respond to demand, enable what is commercially feasible, and promote competitive land and development markets. The National Policy Statement requires planning to place a greater emphasis on monitoring what is happening on the ground, and responding to that. This National Policy Statement requires development capacity provided in plans to be serviced or likely to be serviced with infrastructure. This will necessitate better integration and coordination between land use and infrastructure planning and will require local authorities, infrastructure providers and central government to work co-operatively. This National Policy Statement also places a strong emphasis on planning coherently across urban housing and labour markets, which will require coordinated planning between local authorities that share jurisdiction over Main Urban Areas. The National Policy Statement targets different policies to different local authorities, as per the table below. All local authorities Local authorities that have a Medium Growth Urban Area within their jurisdiction Local authorities that have a High Growth Urban Area within their jurisdiction Objectives that apply All All All Policies that apply PA1 PA3 PA1 PA3 PA1 PA3 PB1 PB5 PC1 PC3 PD1 PD4 PB1 PB5 PC1 PC3 PD1 PD4 PD5 PD9 16

17 1 Title This national policy statement is the National Policy Statement on Urban Development Capacity Commencement This national policy statement comes into force on the 28th day after the date on which it is notified in the New Zealand Gazette. 3 Interpretation In this national policy statement, unless the context otherwise requires, Act means the Resource Management Act Business land means land that is zoned for productive economic activities in urban areas, including but not limited to the following: industrial commercial retail business and business parks mixed use and centres, to the extent that it is available for productive economic activities. but does not include residential dwellings that are also used for a productive economic activity such as home occupations. Decision-maker means all persons exercising functions and powers under the Act. Demand means: In relation to residential development, the demand for residential dwellings within an urban area in the short, medium and long-terms, having particular regard to: a) the total number of dwellings required to meet projected household growth; b) demand for different types of dwellings; c) the demand for different locations within the urban area; and 17

18 d) the demand for different price points. recognising that people will trade off (b), (c) and (d) to meet their own needs and preferences. In relation to business land, the demand for floor area in the short, medium and long-terms, having particular regard to: a) the quantum of floor area to meet forecast growth in different sectors; b) the demands of both land extensive and intensive activities; and c) the demand for different locations within the urban area. Development capacity means in relation to residential and business land, the capacity of land for urban development to meet demand, taking into account the following factors: the zoning, objectives, policies, rules and overlays that apply to the land and any relevant National Policy Statement or National Environmental Standard; and the provision of adequate infrastructure, existing or likely to exist, to support the development of the land, having regard to the relevant proposed and operative regional policy statements, regional plans and district plans; and any relevant management plans and strategies prepared under other Acts. Feasible means the commercial viability of development, taking into account the current likely costs, revenue and yield of developing. High-Growth Urban Area means: Any Main Urban Area that, according to the most recent Statistics New Zealand growth projections set out in Appendix A2, is projected to experience population growth of more than 10% over the medium-term; or Any Secondary Urban Area that at any point in the year has a combined resident and visitor population of over 30,000, and according to the most recent Statistics New Zealand growth projections set out in Appendix A2, is projected to experience population growth of more than 10% over the medium-term. Infrastructure means network infrastructure for water supply, wastewater, stormwater, electricity distribution and transmission, transport, and passenger transport services. Infrastructure providers means the providers of network infrastructure for water supply, wastewater, stormwater, electricity transmission and distribution, transport, and passenger transport services. Local authority has the same meaning as in section 2 of the Resource Management Act Long-term means within the next thirty years. 18

19 Main Urban Area means as defined by Statistics New Zealand set out in Appendix A1. Medium-Growth Urban Area means: Any Main Urban Area that, according to the most recent Statistics New Zealand growth projections set out in Appendix A2, is projected to experience population growth of between 5% and 10% over the medium-term; or Any Secondary Urban Area that at any point in the year has a combined resident and visitor population of over 30,000, and according to the most recent Statistics New Zealand growth projections set out in Appendix A2, is projected to experience population growth of between 5% and 10% over the medium-term. Medium-term means within the next ten years. Plan means an operative or proposed regional plan or a district plan. Planning decisions means any decision on a regional policy statement, regional or district plan, or plan change. Secondary Urban Area means as defined by Statistics New Zealand set out in Appendix A1. Short-term means within the next three years. Sufficient means the provision of enough development capacity to meet residential and business demand, plus, to take account of the likelihood that not all capacity will be developed, an additional margin of at least: 20% over and above projected short and medium-term residential and business demand; and 15% over and above projected long-term residential and business demand. The total capacity should reflect the demands for different types and locations. Urban area means an area with urban characteristics and a moderate to high concentration of population, irrespective of local authority boundaries. Urban form means the overall pattern of development within an urban area, and the relationship of its constituent parts to each other. 4 National significance This National Policy Statement is about the national significance of the contribution that urban areas make to the social, economic and cultural wellbeing of people and communities, and the need to enable urban development and change in order to provide for this. 19

20 5 Objectives The following objectives apply to all local authorities. Objective Group A Outcomes for decision-making OA1: OA2: OA3: To support effective and efficient urban areas that enable people and communities to provide for their social, economic and cultural wellbeing. To provide sufficient residential and business development capacity to enable urban areas to meet residential and business demand. To enable ongoing development and change in urban areas. Objective Group B Evidence and monitoring to support decision-making OB1: To ensure plans and regional policy statements are based on a robust, accurate and frequently-updated evidence base. Objective Group C Coordinated evidence and decision-making OC1: To promote coordination within and between local authorities and infrastructure providers in urban areas, consistent planning decisions, integrated land use and infrastructure planning, and responsive planning processes. Objective Group D Responsive planning OD1: OD2: To ensure that planning decisions enable urban development in the short, medium and long-terms. To ensure that in the short and medium terms local authorities adapt and respond to market activity. 20

21 6 Policies Outcomes for decision-making Policies PA1 to PA3 apply to all local authorities. PA1: By decision-makers: Providing for an urban form that maximises the potential for social and economic exchange within the urban area. Providing for the efficient use of resources, having particular regard to scarce urban land and infrastructure. Enabling the competitive operation of land and development markets. PA2: PA3: By local authorities providing at all times sufficient residential and business development capacity for the short, medium and long terms. When considering the effects of urban development, decision-makers must: Recognise and provide for the contribution that urban development will make to the ability for people and communities and future generations to provide for their social, economic and cultural wellbeing. Provide sufficient development capacity, whilst maximising the positive effects of development, and minimising the adverse effects of development, including reverse sensitivity effects. Give effect to Policies 10 and 11 of the National Policy Statement on Electricity Transmission Have particular regard to the positive effects of urban development at a national, regional and district scale, as well as its local effects. Evidence and monitoring to support decision-making Policies PB1 to PB5 and PC1 to PC3 apply to all local authorities that have part, or all, of either a Medium Growth Urban Area or High Growth Urban Area within their jurisdiction. PB1: Local authorities must, by the end of 2018, or within 12 months of becoming a Medium or High Growth Urban Area, and thereafter on at least a three-yearly basis, carry out: A Housing Assessment that estimates the demand for dwellings, including the demand of different groups in the population for different types of dwellings, locations and price points, and the supply of development capacity to meet that demand, in the short, medium and long-terms; and 21

22 A Business Land Assessment that estimates the demand for the different types and locations of floor area for the local business sectors, and the supply of development capacity to meet that demand, in the short, medium and long-terms. Local authorities must have regard to the benefits of publishing the assessments under policy PB1. PB2: In carrying out the assessments required under policy PB1, local authorities must have particular regard to: Demographic change, including population growth and household size projections, using the most recent Statistics New Zealand growth projections set out in Appendix A2. Future changes in the sectoral composition of the local economy and the impacts that this might have on residential and business demand. Information on the market s response to planning obtained through monitoring under PB5. PB3: In carrying out the assessments required under policy PB1, local authorities must estimate the sufficiency of development capacity provided by its plans and proposed and operative regional policy statements, having particular regard to: The cumulative effect of all zoning, objectives, policies, rules and overlays in plans, and provisions required, or likely to be required, to give effect to other National Policy Statements or National Environmental Standards, and the effect this will have on opportunities for development being taken up. The actual and likely availability of infrastructure. The current physical and commercial feasibility of development capacity. The likelihood of opportunities for development being taken up. and must estimate the additional development capacity needed if any of these factors indicate that the supply of development capacity is not likely to meet demand in the short, medium or long-term. PB4: PB5: In carrying out the assessments required under policy PB1, local authorities must consult with infrastructure providers, community and social housing providers, the property development sector and any other stakeholders as they see fit. To ensure that local authorities are well-informed about the market s response to planning, local authorities must monitor a range of indicators on a quarterly basis, or as frequently as possible, including: The relative affordability of housing, including the ratio of house price to income and the relative cost to rent; The increase in house prices and rents; 22

23 The number of resource and building consents granted relative to the growth in population; Vacancy rates for business land; The ratio of the value of land between rural and urban zoned land; and The ratio of the value of improvements to the value of land within the urban area. Local authorities must have regard to the benefits of publishing the results of its monitoring under policy PB5. Co-ordinated evidence and decision-making PC1: PC2: PC3: When developing plans and regional policy statements to implement this National Policy Statement, local authorities must consult with other local authorities, local infrastructure providers and central government infrastructure providers that share jurisdiction over, operate within, have assets located on, or that traverse a Medium Growth Urban Area or a High Growth Urban Area. The relevant local authorities and infrastructure providers will work together to agree on data and projections used in the development of the assessments required under policy PB1. The relevant local authorities and infrastructure providers will work together to, as far as possible, ensure coordinated land use planning and infrastructure provision, including expected levels of service for infrastructure. Responsive planning Policies PD1 to PD4 apply to all local authorities that have part, or all, of either a Medium Growth Urban Area or High Growth Urban Area within their jurisdiction. PD1: PD2: When the evidence base or monitoring obtained in accordance with policies PB1 to PB5 indicates that development capacity is not sufficient in any of the short, medium or long terms, local authorities must respond by providing further development capacity in accordance with policies PD2 and PD3 as soon as possible. A local authority must consider all options available to it under the Act to enable sufficient development capacity to meet residential and business demand, including but not limited to: Changes to plans and regional policy statements, including changes to: o o o Objectives, policies and rules, zoning and the application of those in both existing urban and undeveloped areas; Activity status; Provisions about the notification of applications for resource consent; 23

24 o o Existing overlays, or the introduction of overlays which enable development; and Make them simpler to interpret. Consenting processes that are customer-focused and coordinated within the local authority; and In granting consent, the conditions of consent imposed. PD3: Local authorities must consider the following responses: In the short term, further enable development through customer-focused consenting processes and, where appropriate, amending the relevant plans. In the medium term, amending the relevant plans and policy statements to provide more development capacity. In the long term, providing a broad indication of the location, timing and sequencing of development capacity in order to demonstrate that it will be sufficient. PD4: In giving effect to policy PD1 with respect to residential development capacity local authorities should have particular regard to enabling capacity: In the locations that the Housing Assessment, required under policy PB1, indicates are of highest demand; and That is feasible. such that it maximises the contribution to meeting demand for residential development. Local authorities that have a Medium Growth or High Growth Urban Area within their jurisdiction should not restrict their responses to meeting demand to only the area that lies within the Medium Growth Urban Area or High Growth Urban Area. Policies PD5 to PD9 apply to all local authorities that have part, or all, of a High Growth Urban Area within their jurisdiction. Regional councils must have amended their proposed and operative regional policy statement to give effect to policies PD5 to PD6 by: The end of 2018; or Earlier if the Housing Assessment required under policy PB1 shows development capacity is insufficient to meet demand; or Within 12 months of becoming a High Growth Urban Area. Regional councils must amend their proposed and operative regional policy statements to give effect to policies PD5 to PD6 in accordance with section 55(2A) of the Act without using the process in Schedule 1 of the Act. 24

25 PD5: Regional councils must set minimum targets for the supply of sufficient residential development capacity that must be achieved, in accordance with its Housing Assessment, and incorporate these into the relevant regional policy statement. These minimum targets must specify: The total number of dwellings; and Different types of dwellings. To take account of the likelihood that not all capacity will be developed, it must require an additional margin of at least: 20% over and above projected short and medium-term demand; and 15% over and above projected long-term demand. PD6: A regional council s minimum targets set under policy PD5 must be set for the medium and long terms, and must be reviewed every three years. When a regional council s Housing Assessment required under policy PB1 shows that the minimum targets set in the regional policy statement are insufficient to meet demand, regional councils must revise those minimum targets in accordance with policy PD5 and incorporate those targets into its regional policy statement in accordance with section 55(2A) of the Act without using the process in Schedule 1 of the Act. Local authorities shall give effect to policies PD7 to PD9 within the following timeframes: By the end of 2018; or Within 12 months of becoming a High Growth Urban Area. PD7: PD8: Local authorities must provide a future land release and intensification strategy alongside the relevant plans and regional policy statements to demonstrate that there will be sufficient development capacity in the medium and long terms, and that minimum targets will be met. The future land release and intensification strategy must: Identify the location, timing and sequencing of future development capacity over the long term; and Provide a process for flexible implementation. PD9: In developing this strategy, local authorities must: Be informed by the Housing Assessment and Business Land Assessment required under policy PB1; Take into account the views of infrastructure providers, land owners, the property development sector and any other stakeholders as they see fit; and 25

26 Have particular regard to policy PA1. 26

27 Appendix Statistical Information A1: Statistics New Zealand: Classification of Urban Areas Main Urban Areas Whangarei Northern Auckland Zone Western Auckland Zone Central Auckland Zone Southern Auckland Zone Hamilton Zone Cambridge Zone Te Awamutu Zone Tauranga Rotorua Gisborne Napier Zone Hastings Zone New Plymouth Whanganui Palmerston North Upper Hutt Zone Lower Hutt Zone Porirua Zone Wellington Zone Nelson Christchurch Dunedin Invercargill Kapiti Blenheim Secondary Urban Areas Pukekohe Tokoroa Taupo Whakatane Hawera Feilding Levin Masterton Greymouth Ashburton Timaru Oamaru Rangiora Queenstown Source: Statistics New Zealand (sourced May 2016) Classification of Urban Areas 27

28 A2: Statistics New Zealand: Projected Total Population by Urban Area Year at 30 June Urban Area Whangarei 53,600 55,000 56,000 56,800 57,400 57,600 57,600 Northern Auckland Zone 288, , , , , , ,900 Western Auckland Zone 217, , , , , , ,000 Central Auckland Zone 450, , , , , , ,100 Southern Auckland Zone 425, , , , , , ,200 Hamilton Zone 180, , , , , , ,800 Cambridge Zone 18,400 19,850 20,600 21,200 21,800 22,300 22,700 Te Awamutu Zone 15,850 16,600 17,250 17,800 18,300 18,700 18,950 Tauranga 125, , , , , , ,800 Rotorua 55,800 56,100 56,200 56,000 55,400 54,400 53,000 Gisborne 35,200 36,100 36,700 37,100 37,400 37,400 37,200 Napier Zone 60,600 62,500 63,400 64,100 64,300 64,200 63,700 Hastings Zone 67,000 69,300 70,500 71,400 71,900 71,800 71,400 New Plymouth 54,800 57,900 59,900 61,600 63,100 64,300 65,400 Whanganui 39,300 39,000 38,700 38,300 37,600 36,600 35,500 Palmerston North 81,500 84,500 87,000 89,400 91,600 93,400 95,000 Upper Hutt Zone 39,000 40,500 41,400 42,200 42,600 42,800 42,800 Lower Hutt Zone 100, , , , , ,300 98,500 Porirua Zone 53,500 55,600 56,700 57,500 57,900 57,800 57,400 Wellington Zone 196, , , , , , ,800 Nelson 63,300 66,600 68,700 70,400 71,600 72,400 72,800 Christchurch 369, , , , , , ,800 Dunedin 115, , , , , , ,100 Invercargill 49,300 50,600 51,100 51,400 51,400 51,100 50,500 Kapiti 40,700 42,100 43,500 44,800 46,100 47,100 47,900 Blenheim 30,100 30,900 31,500 31,900 32,100 32,100 32,100 Source: Statistics New Zealand (sourced May 2016) Projected Total Population at 30 June (2013-base) Clerk of the Executive Council 28

29 Explanatory note This note is not part of this national policy statement, but is intended to indicate its general effect. This national policy statement comes into force 28 days after the date of its notification in the New Zealand Gazette. It provides that ensuring sufficient development capacity is a matter of national significance under the Resource Management Act 1991 and prescribes objectives and policies to guide the making of resource management decisions. 29

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