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4 Characteristics of an NPS

4.1 What characteristics, qualities or attributes should an NPS have?

The background paper asked submitters to consider any other qualities that would contribute to the effectiveness of an NPS on urban design, aside from the level of detail and nature of the direction it might contain. Most submitters responded by agreeing with views expressed in previous consultation, or providing a list of adjectives describing the kind of characteristics an NPS should reflect. The following list summarises the key qualities submitters mentioned, in descending order of popularity:

  • high level

  • integrated

  • place based, allows local solutions

  • not too directive or prescriptive (although many submitters also mentioned the importance of striking a balance between being too prescriptive and too broad)

  • contains objectives and policies

  • visionary or inspirational

  • proactive

  • based on some, or all, of the Urban Design Protocol principles

  • short

  • describes the roles of central government, local government and regional councils

  • collaborative

  • flexible or responsive

  • long term or future focused

  • directive (but note support above for an NPS that is not too directive)

  • includes indicators or other means of monitoring

  • process based

  • empowering and enabling

  • simple and straightforward

  • sets out the benefits of urban design

  • clear on detail of implementation

  • includes expected outcomes

  • positive

  • useful

  • realistic

  • market oriented

  • promotes a unique New Zealand model, rather than based on an overseas model

  • ‘pushes the envelope’ in terms of design and practice.

4.2 Structure

Overall, submitters would prefer to see an NPS that was high level and visionary. Most thought a useful structure would be for an NPS to set out high-level principles, objectives and policies, but not prescribe how these should be achieved at the local level. A few suggested specific principles; others referred to various overseas models as being a useful structure to follow (for example, the United Kingdom’s Planning Policy Statement 1 – Delivering Sustainable Development).

Some submitters thought an NPS should start by setting out what the value and benefits of urban design were:

Given the relatively low level of urban design awareness and capacity within local government, it may be useful for an NPS on urban design to have a preamble outlining the nature of urban design and its value. This could be based on existing material in the Urban Design Protocol, the Value of Urban Design, and People+Places+Spaces. (49)

The NPS should define the strategic value of urban design and the need for design excellence in development of the urban built environment… (111)

Many submitters agreed that an NPS would need to be visionary and set at a high level. For example, submitter 114 stated:

We believe that an NPS on urban design should provide a common vision … The NPS is an opportunity to agree a new approach to urban design that is guided by a shared vision of our urban areas.

The NPS should be inspirational and enabling… (111)

It should define principles which underlie good urban form and structure and appropriate built responses … It should deal with key design principles and how these result in good design outcomes. (50)

…if an NPS is prepared it could be structured around a series of high level statements rather than detailed information or requirements. These statements could give weight to the Urban Design Protocol and the advice that is contained within this. (35)

Many submitters recommended a cascading structure, starting with high-level principles, then objectives and policies. Often the principles in the Urban Design Protocol (the seven Cs) were referred to as a good starting point:

The structure should start at a high level, then go down to more specific matters… (17)

The content should be structured around the following:

  • Statement of high level urban design principles (these could be based on those already developed as part of the NZ Urban Design Protocol);
  • Statement of how these principles must be applied through the RMA process, including resource consents and plan preparation…;
  • Clear policy statements on a selection of key urban design issues, where these can be simply and succinctly stated and where they are of national significance. (25)

Submitter 24 provided a lot of detail about a possible four-tier approach (abridged here):

At a high level, the NPS says that urban design needs the support of good urban planning. It also needs the close attention to detail at the consent/development stage…

  1. At the macro level, councils should develop [non RMA] spatial strategies to provide a context for specific urban design provisions…
  2. At the micro level, the NPS should go on to state that the quality of the built environment as it relates to the public environment is a matter of national importance…Consent triggers would be incorporated to this end. This is the minimum that councils should address…
  3. the relevant aspects of the spatial strategy under 1 could be drawn upon to further develop local level RMA policy on urban design. The NPS could provide an enabling clause that refers to the need to take into account these strategies when exercising functions/powers under the RMA.
  4. If a council puts in place the spatial strategy under 1, then there would be incentives available in the form of resources and assistance to help implement better urban design under 3…

A few submitters suggested that further detailed information around implementation should be included as part of an NPS but perhaps in a separate document:

It should contain a series of objectives under a short list of key topic areas … A more detailed list of policies or principles should then be set out … it is recommended that the NPS contains a number of references to consistency with a parallel but more prescriptive document or documents (e.g. People+Places+Spaces). The references should be as directive as possible in order to reduce the potential for legal challenges. (105)

…a national policy statement on urban design would be most effective if it provided high level principles that were backed up with supplementary guidance. (102)

A way to achieve this may be to have a two tier document structure where the top level sets out the principles that need to be achieved for a development to succeed, and the second level is a more technical document (or suite of documents) that are called up as matter for consideration, and may be updated over time. (47)

A small number of submitters suggested the structure of an NPS should be based around scale:

…recommends that a national policy statement be structured around the different spatial scales … metropolitan, community and site. This would reflect the different nature and scale of the issues at each of these levels. (92)

Submitter 117 suggested a structure based around priority urban areas:

Given the immediacy of urban design issues in some regions (i.e. Auckland) an NPS must address urban design in both the short and long term … By specifically acknowledging key regions/cities within New Zealand, the NPS can address urban design in a more targeted manner where appropriate … A mixed approach which provides for high level guidance for the whole nation at a principles level, but also focuses down with more targeted, short term goals for key regions and cities may better ensure the desired movement to better urban design is achieved.

Many submitters suggested an NPS would need to contain principles, objectives, policies and guidance which were practical, with some making reference to existing models that could be useful in developing an NPS:

…we envisage that the NPS should contain more detail around how the high level direction can be put into effect. This is likely to be quite directive … The national policy statement on Electricity Transmission adopts this level of direction. (112)

The structure for the NPS on urban design could follow that set out by the New Zealand Coastal Policy Statement – i.e. Interpretation, Objectives, Policies, Schedules, Glossary. (73)

One of the best examples of this…is the English PPS/PPG system – starting with PPS1. The suite of government policy directions are clear, specific and thorough, with urban design … being central to the planning framework … the NPS on urban design must deliver, or be part of, something of this order. (17)

Submitter 68 suggested specific wording for principles contained in an NPS:

Policy content should be at the level of enunciating principles to apply in urban development planning … in the form of ‘should undertake enquiries into …’, ‘should account for …’, ‘should have regard to …’, ‘should avoid …’.

 

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