Submission 1: Draft Auckland Plan

Introduction The Council is to be commended in planning for the Britomart Rail Loop project, and in clearly stating related implementation and funding strategies. This long term project can be a transformational for the city. However, every long term plan has short term objectives and short term projects which will inevitably come due for delivery before the Britomart Rail Loop. The Council’s plan integrity and prioritisation principles will be tested in these early projects. The Government Foreword to this first Auckland Plan is a surprisingly good read, and demonstrates a fundamentally correct understanding of what spatial plan is. At s.19 we read: “…spatial planning is fundamentally strategic and focusses on the long term development of cities and their communities…”, and at s.21 “…the Government believes that effective spatial planning has the potential to help realise these opportunities to improve Auckland’s economic and productivity performance and the efficiency of its urban form… and connectedness…” Again I reiterate that the proof of the pudding in this plan, will be in what is funded, and what is not funded in the early years. Early projects set the trajectory and the pattern for the future of Auckland Council. Citizens will be able to draw a line through the first initiatives and extrapolate into the future, make predictions, as to the likely future Auckland can anticipate – whatever the fine words are in the Draft Auckland Plan. Urban Expansion in Rural Villages With little justification, the Draft Auckland Plan (DAP) identifies Warkworth and Pukekohe as two of its 8 growth priority areas. This is more than a little concerning for those of us who have participated in the planning of Auckland Region for the past decade. These areas are outside the Metropolitan Urban Limit (MUL). Warkworth is not on a public transport corridor. Helensville is also mentioned as a future area for similar treatment, and , like Warkworth, it is thirty kilometres or so outside the Metropolitan Urban Limit and not on a Rapid Transit quality public transport corridor. The DAP does not appear to distinguish between the type of growth or the different controls that might be appropriate for growth that would be enabled in those rural townships, compared to centres that are within the current MUL. My experience with growth in Albany, and with reaching settlement with Waitakere City Council over the way in which planning for future urban land there should be provided for, gives me cause for concern. I believe Auckland Council must treat these rural development opportunities with a great deal of caution if it intends to avoid the adverse effects that arise from poorly controlled urban expansion. I note that the DAP refers to staging and triggers for development. However, so too, did the plans for Albany, Hobsonville and Westgate. However those controls have had little effect on what happened. Most developers are determined to get quick returns from these new greenfield developments. Residential development goes in first, and the new owners commute into Auckland and further south for work. Once that has happened there is little stomach for the development of local built amenity (shops, cafes, commercial activity, light industrial places of employment….). Vancouver is an interesting exemplar for this matter. It has adopted what it calls “complete communities” approach to the planning of urban expansion. “Thus it has a strategy of “complete communities” and planning and development policies which support that strategy. The objective of “complete communities” is that each community develops so that there is enough local services, employment and basic retail to satisfy the needs of new residents. They don’t have to drive to get those services as soon as they move in. Of course residents can choose to go further afield if they want to, but they don’t need to. That is the essence of that approach to planning the development of new villages. New Zealand’s track record in the field of greenfield development is littered with examples of the market failure to provide for complete community outcomes. Any reliance on RMA planning instruments for these outcomes is destined to fail – simply because the RMA is a free-market development instrument. If the Auckland Council wants “complete community” outcomes – then it must plan appropriately for them. This same criticism and concern applies to land that can be, or is zoned urban within the MUL.

Submission 1: Planning for place-based projects needs to include robust staging criteria and prescriptions for development that will ensure the basic housing, employment, and social service needs of new communities can be met within or close to the newly developed places. This approach to be known as: Complete Communities.

Submission 2: Draft Auckland Plan

New ferry services at Takapuna I note the idea of a ferry service from Browns Bay, Takapuna through an into Auckland City has been included in the transport planning map. This idea has been around for many years and has had some supporters particularly before the Northern Busway and its extensive feeder bus service network was built. As former Chair of North Shore City Council’s Infrastructure Ctte, and of ARC’s Transport Cttes I would like to bring to Council’s attention these points: Before the Harbour Bridge was built, these places needed ferry services, because there were few alternative transport options to get to Auckland CBD. That changed when the bridge was built. Public attitudes to development on beaches has changed since the days of every beach having a wharf. The public want their East Coast Bays beaches kept free from development and activities which detract from the natural environment and peace and quiet. There will always be some who would like economic development opportunities that come with wharves, but I believe these desires are in the minority. Ferry services need to justify their costs. That means that patronage needs to be at a level that justifies the costs of building wharves and landside services - including car parking. The Devonport ferry service is successful in part because about 300 car parks are within a short walk of the ferry. That is not the case at Takapuna where parking space is at a premium, and much of it is valued by recreational boaties. A Takapuna ferry service would not be economic, and car parking would be insufficient. Significant investment has already occurred for Takapuna public transport services, especially to the Auckland CBD. These include the Busway, Takapuna Bus Station and buslanes, and Akoranga bus station. These services provide a 20 minute service between Takapuna and Auckland at nominal cost. Ferry from Takapuna to Auckland CBD would take around 30 minutes minimum (takes 12 minutes from Devonport), and cost more than a bus trip. Takapuna Beach is exposed to North Easterly wind conditions which is one reason it is a popular surfing break on several occasions each year. This suggests that Takapuna would struggle to provide regular “all weather services”. It is not sheltered. While engineers may be able to “build anything” such structures have their own adverse effects on views and recreational water. In my view the economic case for a Takapuna/CBD ferry service has not been made. It is a nice to have, but it is not a need to have. I would also remind Council of the very significant fight that would be fought with Takapuna residents and beach users should necessary consents be sought for an infrastructure required. This is not a high priority project.

Submission 2: Delete the Takapuna Ferry service proposal from the plan of works.

Submission 3: Draft Auckland Plan

Malls and Liveable Cities Probably the most sigificant issue that was debated during the various plan changes that accompanied the Local Government Auckland Amendment Act (2004) was over the planning for Malls. Painted by many as the harbinger of death to local shopping (as witnessed in Takapuna after the construction of its shopping mall, then at Milford after K Mart, then Glenfield’s mall experience, and big box shopping at Link Drive, which was eclipsed by Albany Mega Market….), malls are seen by many as the leading cause of failure of local high streets – with their mix of local shops and local social services, cafes and suchlike. Many point to the vibrant nature of high street shopping in much of downtown Wellington, and note the absence of mall developments. The question is, what is the Auckland Plan for Mall led developments in the growth areas? This is an omission which needs attention.

Submission 3: Provide an urban development policy for Malls in identified growth areas which will encourage the development of an active village or town centre “main street” environment.

Submission 4: Draft Auckland Plan

Parnell Railway Station The City Rail Link Plan map (Pg 166) shows a railway station at Parnell. As readers of this submission will be aware I am concerned that the particular location for this station that is being advocated for within Auckland Council is the location known as “Cheshire Street”. This option ranked bottom of a set of options that were canvassed by Auckland City Council, Auckland Regional Council, and Auckland Regional Transport Authority (ARTA) prior to the current re-organisation of Auckland local government. The main reason for the low ranking of the Cheshire Street option is that the location does not lend itself to the sort of redevelopment and intensification that has occurred around Newmarket and New Lynn Stations. In fact the Cheshire Street location fails a number of the tests for transport funding prioritisation that are set out in Box11.1 Principles (Pg 163) of the DAP. These include that: “transport investment aligns with growth as envisaged in this plan…”, “ ensure that proposed investment is used optimally…” and “take advantage of all opportunities for transport to assist in place shaping…” There may be some advocates who misread the last of these principles. They may interpret that principle as meaning that because Cheshire Street is an opportunity, then it must be taken advantage of. The problem with this logic is that if the Parnell Station is built at Cheshire, then it will mean that no other station will be built in the vicinity, thereby negating the significant opportunities that are known to exist at Carlaw park and at the Parnell Overbridge options.

Submission 4: Properly consider all options for a railway station at Parnell, taking into account the transport development principles of the Draft Auckland Plan, and taking account of previous work by Auckland City Council, Auckland Regional Council and Auckland Regional Transport Authority, before committing to any construction work on a Parnell Railway station.

Auckland Governance - Hardening the Silos

Lots of people and organisations are putting the finishing touches now to their submissions to the Local Government (Auckland Law Reform) Bill. We dealt with ARC's submissions earlier this week. And of course we - and probably you reading this - are tigers for punishment and know the in's and out's of what's happening.

But consider this: it's my reckoning that 90% of Auckland ratepayers don't know what's happening. Yet. I've lost count of the conversations I had in January - you know - by the BBQ, over a beer, catching a fish - with professional Aucklanders - that go like this:

"You know the supercity thing...?"
"Yes..."
"Is it happening...?"
"Yep. This year."
"But you'll be all right. Won't affect the ARC will it...?"
"Too right. Everything's abolished. They're starting with a clean slate."
"Shit. I thought the whole thing had sort of died away. The Herald doesn't tell me a thing..."

Since going back to work at ARC I've had conversations with a lot of other local body politicans who echo this experience. I think the public have no real idea. But a lot of concerned people do, and there are going to be a lot of personal submissions. I think the Select Committee hearing submittors is going to get a painful wake-up call. National MPs will be surprised to get so many angry and concerned submissions from people and groups they would normally rank as supporters.

The thrust of a lot of informed submissions could go a bit like this:

....The changed governance arrangements set out in the Bill “aim to create one Auckland, which has strong regional governance, integrated decision making, greater community engagement and improved value for money.” (You can find these exact words in page 2 of the General policy statement that is embedded in the Bill's explanatory note).

. These laudable aims are presumably the desired outcome of the Bill’s provisions however there seems no chance they will be achieved given the contents of the Bill:

· There is no detail on five of the seven council-controlled entities (CCOs) that government’s high-level governance decisions provide for in Auckland’s new governance framework;

· The Bill fails to provide clear authority, control and accountability linkages between the Auckland Council, its role to develop a spatial plan and associated strategies, implementation of these plans, and the delegation and control of proposed CCOs to deliver the policies and strategies set by Council;

· There is no detail around how the Council will achieve alignment and integration among and between, and maintain control and accountability of the CCOs that Government has agreed be established to operate at ‘arms length’ from Council, even though suggestions for how this be achieved are set out in Cabinet papers and this is stated to be one of the Bill’s major aims;

· Also missing is important detail on the functions, powers and duties of the tier of local boards that will (presumably) deliver the ‘greater community engagement’ and community based decision making that the Bill claims is a major aim;

· It is difficult to see how integrated decision-making will be possible - either horizontally or vertically - given the strong structural separation that has been designed into the overall structure....

People have begun talking about the hardening of silos...

Councils are often criticised for "silo thinking". Council divisions and departments become laws unto themselves and challenge attempts at integrated decision-making. And this is the thing with the reforms - stronger regional governance was a key objective. And this has always required integrated decision-making. Across departments - ie across land use planning, transport, water, economic development, parks - the lot. Joined up decisions.

Place-making or place-shaping, usually done at local level, demands joined up decisions too. Integrated decisions.

Instead of silo removal in Auckland, we are getting hardened silos.

I remember talk of hardened silos when I was involved in the anti-nuclear movement in Europe. Nuclear missiles went into hardened silos. The silos were so hard and strong they could withstand a nearby nuclear strike. Seriously tough.

Perhaps that's the objective for Auckland governance: build service functions into hardened silos, tough enough to withstand attack. From ratepayers. From the little old lady down the street. And tough enough to withstand challenge and questions from councillors.

Now that's a recipe for successful local government.

In Albania.

But not Auckland, New Zealand.

Should Auckland Council have a Spatial Plan?

My preliminary planner's answer to this question is an overwhelming yes.
But there is a debate here, in Auckland, across Auckland, within the existing councils, the ARC, and within the Auckland Transition Authority. I will be writing much more about this as the discussion unfolds.

Several major points:
- The present wholesale restructuring of Auckland local government was originally (at any rate) driven by a perceived need to improve and empower regional planning (ie not to weaken it).
- Auckland's current planning environment - largely driven by RMA - is an effects based planning environment. We plan for what we don't want (want to avoid, remedy, mitigate). We don't plan for what we do want - and we need to. Now.
- It took several years for Auckland to adopt the Auckland Region Growth Strategy, and a decade later, Auckland is still finding it a challenge to implement it. Regional planning frameworks and priorities take a while to develop, gain acceptance, and get implemented.
- Government decisions to incorporate major infrastructure services (water, wastewater, transport, waterfront development, stadia, property development etc) into arms length entities requires Auckland Council to plan for Auckland's future, in a way that sets the priorities and directions for those entities

Bill 3 contains a suite of provisions for a Spatial Plan which range from the sublime ("...to state policies, priorities, programmes, and land allocations that will implement the strategic direction and to specify resources that will be provided to implement the strategic direction....") to the even more sublime ("...to visually illustrate how Auckland may develop in the future, including how growth may be sequenced and how infrastructure may be provided...").

But the Bill does not require Auckland Council's substantive entities (Watercare and Auckland Transport), to "give effect" to this Spatial Plan. Nor does the Bill say when the Spatial Plan should be built. Nor does it indicate how frequently it should be updated.

To say that these Spatial Plan provisions is "disconnected" would be an understatement. Clearly they are disconnected from what Auckland Council should be expected to control (eg transport and water services). But they are also disconnected from other regional plans.

Auckland Council will inherit various plans, some works in progress, some complete. These include 7 District Plans, 1 Regional Policy Statement (halfway through a major review), 8 Long Term Council Community Plans (LTCCPs), a partially reviewed Regional Transport Strategy, plus other plans like the half-baked "One Plan", a Business Land Strategy, a Regional Parks Management Strategy .... and I can imagine a whole heap of Economic Development Strategies.

These plans will all be based on, or supported by, a cluster of data sets, maps, and council specific GIS systems. Different systems. Different software. All needing to be integrated. So there is a common information base upon which to build a technically competent and reliable Spatial Plan. Though something a little higher level could preceed this....

The ARC has been advised that, in preparing Bill 3, Cabinet considered various options for Regional Planning that included the idea of a Spatial Plan, and these included:

1) Status Quo (we all need to await the Second Round of RMA reforms - which are likely to include - horror of horrors - abolition of controls like Metropolitan Urban Limits);
2) Changes to the LGA 2002 so that the LTCCP would contain the Spatial Plan;
3) A statutory Spatial Plan that replaces other existing strategic plans;
4) A statutory Spatial Plan with strengthened legislative linkages. so that the Spatial Plan influences planning under other legislation (LGA 2002, RMA and LTMA planning frameworks);
5) A statutory Spatial Plan with no additional or strengthened legislative linkages, with changes to be considered later through the RMA reform process....

It appears that option 5 has been chosen.
But there is little justification for that choice.

The ARC's draft submission re Spatial Plan provisions, suggests that either:

1. The Government proceeds with (4) - ie sorts out the linkages (connexions) with other planning frameworks and legislations - and then brings in legislation requiring a Spatial Plan; or
2. Deletes the (half-baked) Spatial Plan provisions in the Bill, until work on the RMA is complete, when the Government could make a change then to LGA 2002, or to the Auckland Council Act, to require a statutory Spatial Plan.

So. Very hairy.

My take on this, whichever of the ARC options are recommended (and there may well be other positions taken by other parties), it is essential that Auckland Council is in the position to adopt strategies and priorities and directions very soon after being formed that have the effect of directing the activities of the plethora of CCOs that will exist in Auckland.

This would be an interim set of strategies and priorities. Maybe covering the first 24 months or 36 months. Terse and to the point. A controlling document for the region.

You only have to look at the very brief and punchy directions that Government adopts in respect of the SOE's that it controls, to get some idea of what Auckland Council should be in a position to quickly develop and adopt and require giving effect to, when it takes office.

More on this later. Actually sooner than later....