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5 Issues an NPS should address

Submitters were asked to comment on what issues of national significance an NPS on urban design should address and what relative priority they should be assigned. A small number of submitters attempted to prioritise issues, with most stating they were ‘all important’. Consequently, the following issues are not listed in any particular order and do not represent any form of prioritisation.

There was some confusion between issues of ‘national significance’ and those of ‘national importance’. The RMA states that a national policy statement can be developed for issues of ‘national significance’. This is different from the matters of ‘national importance’ set out in section 6 of the RMA, which all decision makers are required to recognise and provide for.

A small number of submitters simply stated an NPS should deal with ‘sustainable management’ issues (referring to section 5 of the RMA) without elaborating on what these might be in terms of urban design.

Many submitters proposed using the principles in the Urban Design Protocol as the basis for developing issues of priority in an NPS. A few also suggested alternative principles set out in other publications (see section 9.10).

5.1 Global and big picture issues

Some submitters argued that an NPS should address global issues, because these were matters of national importance that might otherwise not be included in a local perspective on urban design:

A issue of national importance is sustainability. A truly sustainable environment provides for social, economic, environmental and cultural elements equitably. Urban design has the ability to help deliver more sustainable environments. (64)

The big picture issues suggested for inclusion in an NPS included:

  • sustainability

  • climate change impacts and adaptation

  • energy use, energy efficiency

  • peak oil and an imperative to reduce the need to travel and depend on motor vehicles

  • urban energy, water and food supply systems.

Of note is the overlap between these issues and the bigger picture reasons other submitters gave for supporting the development of an NPS. This is discussed earlier in section 3.1.

5.2 Mandating urban design under the RMA

Many submitters suggested that an NPS on urban design would be useful because it would mandate urban design under the RMA. In particular, it would elevate the status of urban design and enable councils to combat any criticism for taking into account urban design in preparing district and regional plans. An NPS could “unambiguously assert that the Act’s definition of natural and physical environment includes the urban environment” (submitter 6).

Submitter 48 stated that:

… an excellent outcome would be a revision of the current very narrow assessment of effects criteria in resource consent applications. Effects are assessed in terms of ecological and physical criteria, and on a ‘now’ timeframe … Councils which attempt to forward plan the shape of a particular part of the city are open to attack at any time by applicants under the RMA mechanisms arguing on the basis of effects which are physically based, site specific, and over a short timeframe.

It was suggested that mandating urban design under the RMA would enable councils to achieve urban outcomes beyond the biophysical emphasis of the RMA. An NPS on urban design would also stop debate about whether or not urban design was a legitimate concern under the RMA – a position summed up by submitter 73:

The RMA has been inconsistently interpreted and implemented in regard to urban design matters. The Act has not provided sufficient direction to consent authorities in the formulation and administration of regional and district plans … urban design has not been a matter of priority for consent authorities. The solution to this impasse is a national policy statement.

Submitter 35 reflected the views of many submitters:

An NPS could play a role at this stage by confirming that the delivery of high quality urban design outcomes is a legitimate expectation of sustainable management.

Submitter 89 summarised local government’s position by stating there were mixed views within the sector, and whether or not there was a mandate under the RMA was a cause of debate. Some councils consider they already have a mandate and are addressing urban design issues through their existing planning frameworks, whereas others are concerned about jurisdictional issues:

An NPS would mandate urban design within the RMA framework which would make councils jobs easier in terms of taking into account urban design matters as part of district plan preparation, plan changes and resource consent processing. (89)

An NPS … may be beneficial, helping to avoid any further jurisdictional type arguments that urban design is not a relevant issue under the RMA. (104 and 65)

The prolonged and costly legal processes to resolve RMA policy and consent issues in the absence of sufficient central government guidance results in mediocre (vague, inconsistent, and ineffectual) policy. (17)

5.3 Growth management, urban form, intensification

Many submitters stated that an NPS on urban design needed to address growth management issues. They referred to the urgent need for policies that would deal with:

  • growth and development that was more sustainable

  • encouraging a more compact urban form

  • avoiding low-density urban sprawl

  • increasing densities

  • intensification, especially around transport nodes and along public transport corridors

  • setting urban boundaries or metropolitan urban limits

  • urban containment

  • encouraging a mixture of activities.

Reasons why an NPS should deal with these issues included:

Growth management issues are inextricable from urban design issues. A basic driver of New Zealand’s dominant urban growth pattern is the practice of designing urban road networks with priority for traffic volume and speed, rather than for public transport, walking, cycling, the quality of the public realm, maintenance and enhancement of local character, mixed use, adaptability and low environmental impact. An effective NPS on urban design will inevitably address issues of urban form, intensification, and location of new development, as these issues are directly relevant to what constitutes good urban design. (49)

Growth of towns and cities is delivering urban sprawl and intensification. Greenfield subdivision is putting pressure on infrastructure, productive agricultural land and requires more reliance on car use rather than a range of transport options. Intensification of the existing built areas is putting pressure on amenity and character of these established areas. (25)

It [an NPS] needs to provide clear policy direction that requires TLAs [territorial local authorities] to avoid further expansion and investment in dysfunctional urban patterns; it must provide policy direction upon the need to adapt current urban form and build resilience for urban communities in the face of an increasingly uncertain global future. (36)

A few submitters thought there was already a high level of support for encouraging more sustainable urban growth but that further direction was required on how to put these principles into practice:

Most large urban centres in NZ now have urban development strategies. All have traversed the same issues, options and challenges and all desire to make urban settlement more sustainable over time. All seek (but perhaps to different degrees) more sustainable urban form (including higher densities and mixed uses integrated with passenger transport and improved walkability, reducing the rate of urban sprawl and ensuring better development and design outcomes). An NPS should provide clear direction on these important elements of urban design and a requirement that they must be pursued in all regional and district plans. This would assist in moving the argument on from ‘what’ to ‘how’ and assist in an enhanced focus on improving implementation. (104)

Submitter 35 cautioned it may not always be appropriate to pursue goals such as intensification and, for this reason, an NPS should focus on the processes involved in giving consideration to such issues:

Any NPS could highlight processes and steps that could be followed when considering urban growth, intensification, greenfield and brownfield development. There could be clear statements that intensification is not appropriate in all circumstances.

5.4 Urban planning

A small number of submitters discussed whether there was, in fact, any difference between ‘urban design’ and ‘urban planning’ and if it would be possible to produce an NPS that confined itself to a narrower definition of urban design. Many thought an NPS could usefully deal with the wider issues which traditionally might be thought of as ‘urban planning’ but were part of an all-encompassing definition of ‘urban design’, such as that used in the Urban Design Protocol. For example, submitter 105 supported an approach like that taken in the United Kingdom’s Planning Policy Statement 1, which states that “good planning is indivisible from good design”.

This statement supports the inter-related nature of urban planning and urban design referred to above. In attempting to agree exactly where urban planning stops and urban design begins, [we] concluded that in the absence of an NPS on urban planning, an NPS on urban design would need to address many issues generally held to be core planning issues. By way of example … transport/land use integration and increasing the use of public transport were fundamental urban design issues, as was the protection of heritage buildings and places. These principles are widely considered to be basic tenets of good urban planning.

Submitter 89 also discussed this issue, stating:

A number of councils also made the point that perhaps an NPS should be more about elevating the status of urban planning and the recognition that planning to create liveable community environments is a matter of national significance. That the underlying patterns of settlement in a district or region and the component structures of these settlements were more important in terms of a possible NPS than specific design matters.

A few simply stated that an NPS should bring back and legitimise strategic planning.

5.5 Integration

Many submitters stated it was the clear purpose of an NPS to address integration – between statutory and non-statutory urban design initiatives and between the RMA and various other pieces of legislation and government policy which deal with aspects of urban design. Most common was a call to integrate the RMA with opportunities to carry out community-based strategic planning under the Local Government Act 2002. (Integration between land use and transport planning was also a significant issue and is discussed separately in section 5.6.) For example, submitters 60, 92 and 107 stated that:

A significant role for a national policy statement is to promote an integrated approach to urban design across the built environment. An integrated approach to urban planning and design at the sub-regional scale and across the relevant legislation will achieve a more sustainable sub-regional urban form when all pieces of legislation operate together, in particular the Local Government Act, Land Transport Management Act and the Resource Management Act.

A small number of submitters stated many urban design outcomes were being addressed under various planning exercises carried out under the Local Government Act 2002. The benefits of this were a collaborative, less regulatory approach which involved the community and included more flexibility. A few submitters expressed frustration these documents did not hold much weight when land use decisions were made under the RMA. For example, submitter 89 stated:

We note the opportunity for growth planning and urban planning exercises under the LGA processes, but also note the limited statutory weight this planning has under the RMA when it comes to the crunch of resource consent decisions. We suggest that it may be useful for the NPS to make the link to urban planning under LGA processes and the link that decisions made on development of the urban environment also have social, economic and cultural consequences.

Submitter 110 stated that:

It is imperative that the NPS provides an integrated approach to urban design which brings together and rationalises the imperatives embedded in a variety of statutes that go beyond simply the RMA…It is not appropriate that the NPS be constructed only in the context of the RMA. This would be antithetical to the demands of planning for and managing the complexity of urban systems.

Specifically mentioned legislation and government policy that should be integrated with the RMA included:

  • Local Government Act 2002, including the use of Long Term Council Community Plans

  • Land Transport Management Act 2003

  • New Zealand Transport Strategy

  • national and regional land transport programmes

  • regional land transport strategies

  • New Zealand Energy Strategy

  • New Zealand Energy Efficiency and Conservation Strategy

  • Building Act 2004, New Zealand Building Code and Building Regulations

  • Healthy Eating, Healthy Action Strategy

  • Reserves Act 1977

  • Historic Places Act 1993

  • Civil Defence Emergency Management Act 2002

  • conservation management strategies

  • Marine Reserves Act 1971

  • New Zealand Disability Strategy

  • Fire Service Act 1975

  • New Zealand Tourism Strategy.

5.6 Linking land use and transportation

Many submitters thought a key issue that an NPS should address was integrating land use and transportation planning, particularly promoting more sustainable forms of transport. The benefits of such an approach were numerous, including reduced reliance on private motor vehicles, reduced emissions and energy consumption, health benefits, more viable public transport systems and economic benefits. For example, submitter 100 stated:

…transport and urban design must be tackled together. It is important to manage urban design so that people do not become unnecessarily reliant on inefficient travel, with resulting energy consumption and emissions. Ideally, urban areas developed with less reliance on the motor vehicle would mean that residents may not need a car to go grocery shopping, children can walk or cycle to school and adults can walk, cycle or use public transport.

Submitter 21 summed up the importance of good transport and land use planning:

The built environment and transport systems are particularly important in terms of their impact on future energy sustainability and greenhouse gas emissions…wise management and planning can provide communities with ongoing resilience against future threats and uncertainties, such as energy resource depletion and associated price increases and volatility.

Submitters 87 and 112 both identified as very positive the reference to national policy statements in the Land Transport Management Act 2003. The 2008 amendment to the Act requires regional land transport programmes to take into account any relevant national policy statements prepared under the RMA. This was seen as:

A very welcome ‘jumping of the boundary’ from resource management to land transport management legislation, and as such provides an opportunity for integration to be achieved provided the urban design NPS is appropriately focused. (87)

Submitter 17 suggested one way to integrate land use and transport would be “embedding the Local Government Auckland Amendment Act nationwide”.

Other submitters concentrated on the wider benefits of integrating transport and urban design, for example, the ability to contribute to other, related government policies and strategies. Examples given included health and energy:

An NPS on urban design must promote an integrated approach to urban design across relevant legislation. In particular we would like to see the link between urban design, transport and health emphasised and the contributions of the urban environment to health and social goals made clear. For instance, the promotion of active transport such as walking and cycling can significantly contribute to key government health strategies such as in Healthy Eating Healthy Action regarding the uptake of regular physical activity and reducing obesity, as well as government sustainability goals. (114)

The NPS on urban design could play a particularly significant role in giving effect to the New Zealand Energy Strategy’s stated commitments to: develop resilient and low carbon transport; use energy more efficiently; support low emissions power, and foster greater affordability and wellbeing…the New Zealand Energy Efficiency and Conservation Strategy specifically describes how urban form and design are expected to contribute to sustainable energy outcomes. (21)

Two submitters stated the role of streets and roads was the main issue facing urban areas. They stated that the role of streets should be dealt with in an urban design NPS because this:

…would send a strong signal of the importance of effective and appropriate interfaces between urban design, planning and transport to improve urban outcomes. (44)

Submitter 6 stated urban design considerations should be inserted into transportation funding.

5.7 Transportation-related issues

Many submitters supported an NPS which addressed specific transportation-related issues, in addition to linking transport and land use planning as discussed in section 5.6. These included promoting:

  • connectivity

  • public transport

  • walkability

  • walking, cycling and other forms of active transport

  • a balanced approach to parking.

The creation of cities which were easy for people to get around, allowed multi-purpose trips, did not rely unduly on the use of private motor cars and enabled more active forms of transport was seen as having several benefits. These included, for example, reducing carbon emissions and fuel use, improving air quality, improving the population’s physical health, and promoting a sense of community.

5.8 Infrastructure

Several submitters suggested an NPS should address infrastructure issues other than transport. The main concern mentioned was encouraging sustainable water management as a means of easing urban growth pressures. For example, low-impact design or Water Sensitive Urban Design and Management (WSUDM) was promoted by submitter 46:

WSUDM will reduce the environmental impact of urban areas by reducing water consumption and minimising the adverse effects of stormwater on receiving environments.

Other issues suggested for inclusion in an NPS were:

  • infrastructure design

  • “…a balance is required between meeting infrastructure requirements and delivering good urban design…” (submitter 99)

  • managing stormwater

  • electricity and transmission corridors

  • social infrastructure.

5.9 Liveability, quality of place

Many submitters referred to the ‘people’ aspect of urban design – issues of liveability, designing places for people, building communities, amenity, quality of place and other related concepts. For example, submitter 116 stated that:

…the priority for urban areas must be the people within them. Thus the NPS should emphasise safety, pedestrian friendly spaces and connections, built environments that enhance social interaction…

Submitter 63 stated “the significance of urban space in determining the quality of life of all people” was a matter of national significance that should be addressed in an NPS. Submitter 22 thought it was a national priority to address issues such as:

… creating places that are attractive to visitors and investors, creating better places to serve residents from all economic and social communities…

A small number of submitters discussed what quality urban design meant and suggested it could mean different things to different people. Submitter 3 concluded:

…what is not contestable is the qualitative outcomes and the needs and desires of people to live, work and play in a good urban environment.

Many submitters focused on ‘quality of place’ as an essential element which should be included in an NPS. For example, submitter 91 elaborated:

The emphasis on any NPS should be on the quality and design of place so it needs to reinforce that it is the qualitative elements of ‘how’ a place is designed that is most important, not rigid standards or numbers … The quality of place, how an efficient place is created and the experience that people have in those places is paramount in urban design. The NPS needs to set up a robust framework for the measurement of this…

5.10 Quality of public spaces

As a specific issue about creating liveable urban areas (see section 5.9), several submitters highlighted the need for an NPS to focus mainly on the quality of public spaces. For example, submitter 24 supported an NPS that addressed “…the quality of the interaction between the public and private realm”. Submitter 49 summed up the reasons for supporting such an approach:

As noted in The Value of Urban Design, a high quality public realm does not arise by accident, but requires an integrated, all-encompassing approach to its design. The report also characterises as conclusive the evidence that urban design contributing to a high quality public realm attracts people and activity, leading to enhanced economic performance.

5.11 Māori values

A small number of submitters stated that Māori values should be explicitly provided for in an NPS. Submitter 40 suggested that the highest priority for an NPS “should be to provide for cultural values of Maori and Pakeha in an inclusive way”. Submitter 66 felt Māori, as Treaty of Waitangi partners, needed to be involved in developing an NPS for it to be an enduring document:

…introducing a Maori world view … will add value and provide for an integrated, holistic and values based approach to the proposed national policy statement. (66)

Submitter 80 stated all matters in section 6 of the RMA should be reflected in an NPS to the extent that they concern urban design. They specifically referenced section 6(e) – the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu and other taonga. Submitter 79 referred to section 6(e) and requested that its provisions be incorporated in an NPS, as well as the principles of the Treaty of Waitangi and section 8 of the RMA. They further stated an NPS on urban design would be of assistance in achieving both section 6(e) and section 8 by involving a range of strategies, including:

The adoption of Maori values in the planning and design of urban environments. The adoption of Maori concepts and designs within contemporary urban designs for buildings and public space in collaboration with tangata whenua.

Two submitters (57 and 66) specifically mentioned concern over the lack of Māori participation in the development of the Urban Design Protocol:

…the whole Maori dimension has been left out and this missing part is the heart of what should be and could be addressed by a national policy statement. (57)

Submitter 66 also discussed the Te Aranga Maori Cultural Landscapes Strategy:

As the Te Aranga Maori Cultural Landscapes Strategy is a mandated document of national standing it should be accorded equivalent status to the proposed national policy statement.

5.12 Heritage

A small number of submitters considered historic heritage was a matter of national significance that should be addressed by an NPS. Some referred to its status as a matter of national importance in section 6(f) of the RMA and suggested this further validated its importance in an urban design NPS. Submitter 79 stated “historic heritage is a core component of urban design”. They referred to various provisions in the Urban Design Protocol which linked cultural identity, heritage, creativity and urban design.

Submitter 85 stated a matter of national significance was:

Architectural legacy, social and cultural heritage and the historic role of identified spaces and buildings should be preserved all over the country that will serve as character building for each city…

Submitter 79 referred to several principles for practical implementation of urban design and historic heritage. These are contained in the New Zealand Historic Places Trust publication Sustainable Management of Historic Heritage Guidance Series Discussion Paper No. 4 Urban Design and Historic Heritage.

5.13 Landscape

A small number of submitters stated the relationship between urban design, urban form and landscape should be included in an NPS. Reasons given included those set out in submission 49:

The design of urban development and redevelopment frequently ignores natural topography and drainage, resulting in excessive earthworks and adverse effects on freshwater catchments and the coastal environment. Urban sprawl … has also significantly degraded natural and cultural landscapes and natural character in urban areas.

Submitter 25 stated landscape qualities were integral to New Zealand’s national identity, however:

…there are numerous examples of poor built insertions into this landscape, both at a settlement level and at an individual building level … Often these significant landscapes are in areas where small local authorities are under resourced and struggle to provide robust guidance as to the qualities of new development and how they should better integrate with the natural landscape.

5.14 Biodiversity

A number of submitters suggested protecting indigenous biodiversity should be given priority in an NPS on urban design. For example, submitter 8 referred to “bringing nature back into the city”. The reasons given for including biodiversity protection in an NPS were the significant negative impact of past developments, and the resulting loss of indigenous biodiversity. Submitter 7 stated:

An objective of urban design should be that all development initiatives have positive biodiversity outcomes … Existing areas of biodiversity value need to be maintained and enhanced by urban design.

Submitter 49 explained how urban design could contribute to biodiversity protection:

Urban design can contribute to the protection or enhancement of indigenous habitat fragments in urban cores, larger fragments in peri-urban areas, and connecting corridors of green space.

5.15 Housing

A small number of submitters stated the provision of quality, affordable housing was a matter of national significance which should be dealt with by an NPS. For example, submitter 116 stated:

Housing is a core part of the urban landscape. This should be reflected in the NPS. Developing affordable, sustainable, healthy dwellings that provide a secure form of tenure…is a core part of the creation and maintenance of social capital.

Similarly, submitter 63 referred to housing:

The significance of supplying affordable, sustainable, good quality housing appropriate to individual needs in order to promote the well-being of a community.

This submitter elaborated on the links between urban design and housing:

Together, housing and urban design are fundamental to the establishment and maintenance of safe communities. Together, housing and urban design must look towards the future, understanding the future needs of a community as well as its present needs.

5.16 Retail location, role of town centres

Several submitters stated an NPS should deal specifically with retail location and the important role of town centres. Reasons given related to the importance of town centres in terms of being economic drivers for a community and providing an essential focus for community life. For example, submitter 25 stated:

Town and city centres are important as they have the potential to bring together a range of activities and people. They are the nucleus of communities. These centres are under threat through rationalisation, big-box retail, and a range of large scale out-of-centre development. This puts the viability of centres under threat and greater challenges to the sustainability of communities.

Submitters 52 and 44 both stated the role of town centres was one of only two significant issues for urban areas an NPS should deal with. Submitter 52 stated:

Significant long term investment in physical and natural resources in New Zealand’s town centres has been undermined by a narrow approach to the evaluation of adverse effects under the RMA, and an accompanying narrow focus on retail analysis and hierarchies, rather than the benefits and costs of development in town centres… There has been limited understanding of the key role of strong walkable town centres served by public transport, with public facilities and amenities being the base for economically and socially strong communities.

Submitter 82 was concerned large format retail had been identified as a potential threat to good urban design. They stated there was a need to:

…distinguish between stand alone large format retail which has urban design challenges and [certain] shopping centres which incorporate a significant degree of urban planning and design.

In a similar vein, submitter 27 could see nothing wrong with large format retail from an economic perspective:

Large format retail increases retail productivity and leads to higher employment growth, lower prices and higher wages in the retail sector.

5.17 Mixed use

A small number of submitters agreed an NPS should include provisions which encouraged mixed-use developments. Reasons given for promoting a mix of land use activities were that residents had less distance to travel to conduct their daily activities, with resulting benefits in terms of energy and transport efficiencies. Submitter 33 supported an NPS which would:

…encourage high-quality, compact mixed use neighbourhoods and town centres where uses are located closer together and a range of services, activities and transportation options are available and are accessible to all people.

Submitter 94 considered mixed-use development should be dealt with in an NPS, but from the perspective of protecting residents from the adverse impacts of non-residential activities. This submitter also advocated for a mixed environment, with a wide range of community and cultural facilities – not just bars and restaurants.

On a related issue, submitter 22 suggested matters of national significance which should be dealt with by an NPS included “redevelopment of waterfront areas experiencing land use transition from industrial uses”.

5.18 Natural hazards

A few submitters stated natural hazard management should be part of an NPS on urban design. For example, submitter 7 stated:

Urban design should seek to minimise natural hazards by avoiding development in hazard prone areas such as flood plains, coastal edges and steep land.

Submitter 113 considered it was “essential for good urban planning to take into consideration risks from natural and technological hazards to our cities”. This submitter also considered the concepts of risk and resilience should be built into an NPS.

Submitter 36 stated new, pressing issues for New Zealand included “the need to adapt urban form to the direct and indirect consequences of climate change”. Included in the direct effects were extreme natural events such as storms, flooding and landslips.

5.19 Access to open space

A small number of submitters considered access to open spaces within an urban environment was a critical urban design issue that should be dealt with in an NPS. Submitter 36 summed up the reasons:

There is increasing evidence of the positive correlation between access to green space and improved physical and mental health of communities.

5.20 Protection of soils

Some submitters considered an NPS should include a specific provision protecting versatile soils for food production. For example, submitter 59 stated:

A responsible national policy statement regarding urban design must consider the living standards of future generations. To this end, it would be prudent to re-introduce the protection of versatile soils, establish urban boundaries, with a view to not just protect our ability to produce food, but produce it relatively cheaply so that people can afford it.

5.21 Rural–residential development

A small number of submitters stated an NPS should address rural–residential or other developments on the urban periphery. Submitter 7 stated:

In terms of many regionally important matters, rural residential development is having more significant effects than urban development.

5.22 Safe environments

A few submitters stated that a priority area should be the creation of safe urban environments. Submitter 94 encapsulated a definition of a safe environment:

Safe from accidental injury ... safe from environmental harm … safe from physical threat, intimidation and violence, and damage to or theft of property, safe for our vulnerable populations such as women, children and elderly.

Specific reference was also made to inclusion of the Crime Prevention Through Environmental Design (CPTED) principles in an NPS. Submitter 11 stated reasons for this:

An integrated approach to urban design and crime prevention will enhance the physical amenity of our urban areas, as well as their sustainability as vibrant communities.

5.23 Accessible neighbourhoods

A small number of submitters stated an NPS on urban design should address the creation of accessible neighbourhoods as a matter of national significance. An accessible environment was seen as one that took into account the needs of all people, including those with disabilities. Submitter 98 stated:

Urban areas that work well for older people and people with disabilities will work well for all. We therefore recommend that any national policy statement on urban design give national strategic importance to the needs of these groups.

Submitter 33 stated many New Zealanders considered themselves to have a disability, and the population was increasingly ageing:

Given the large portion of the New Zealand population affected by this issue, it is important to recognise that access and mobility in our built environment is a matter of national significance. As such it should be provided for in any NPS on urban design.

Submitter 26 stated New Zealand would soon ratify the United Nations Convention on the Rights of Persons with Disabilities. This convention includes a requirement that appropriate action is taken to ensure increased accessibility for disabled persons:

An NPS on urban design should reflect this by acknowledging that accessibility, mobility and usability are issues of national significance.

5.24 Link to physical health

A few submitters stated an NPS should make a strong connection between urban design and physical health:

We believe it [an NPS] should clearly show the significant impact of urban environments on people’s health and wellbeing…There is now a large body of evidence that shows that the settings in which people live, work and play, have a huge influence on health and wellbeing throughout the life span. (114)

5.25 Environmental issues

A small number of submitters stated an NPS on urban design should deal with environmental issues such as:

  • discharges to air

  • discharges to water

  • surface water quality

  • water use

  • waste management and recycling.

5.26 Solar access

Some submitters agreed an NPS should encourage solar access for buildings, or other ‘green building’ attributes.

5.27 Protection of the night-time environment

A small group of submitters stated that protecting the night-time environment should be in an NPS. For example, submitter 45 stated:

…protection of the values of the night environment be an essential part of a national policy statement on urban design. Specifically guidelines should be included that encourage efficient and effective outdoor lighting techniques that prevent unwanted effects from that lighting.

 

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