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6 Issues an NPS should not address

Many submitters specified issues they considered an NPS should not address. These included:

  • global or big-picture issues of national priority

  • growth management

  • urban planning

  • detailed design.

6.1 Global and big picture issues

A small number of submitters stated an NPS on urban design should not address various global or big-picture issues. These included:

  • energy policy

  • economic development

  • climate change

  • vehicle emissions

  • sustainable transport.

The reasons given included that these were not urban design issues and/or would better addressed through other means. Submitter 113 provided further detail as to why climate change and vehicle emissions in particular should not be dealt with:

…we are not convinced that setting up national strategic priorities, such as climate change adaptations or vehicle emissions would be best addressed through this policy statement. With the recommendation that the urban design policy statement be succinct and focused on providing high level principles in mind, and considering the raft of supporting instruments that the government is providing to address the issues of climate change adaptations and vehicle emissions, it might be more appropriate to defer those and remain focused on the principles of good urban design.

6.2 Growth management

A few submitters stated growth management issues should not form part of an NPS. For example, submitter 5 stated:

…the NPS should not focus on growth management. Whilst urban design and growth management can influence each other and can be closely related, growth management is a separate issue that should not cloud an NPS on urban design.

Submitter 119 considered urban growth was driven by many factors, not just urban design:

While urban design plays an important role in growth management there are other significant drivers that determine growth and intensification. These include but not limited to geography and topography, coastal management, transport investment, stormwater/wastewater requirements, population requirements, economic requirements, metropolitan urban limits, regional and district plans … growth and investment is very context sensitive and there is a danger in having an NPS that is too prescriptive implicating other key aspects and considerations which drive growth.

Submitter 22 considered regional growth management, policy planning, large area land use planning, and urban boundaries were most properly addressed by land use planning or high-level policy initiatives.

Submitter 100 stated the appropriate tool to manage urban sprawl was through transport pricing mechanisms.

6.3 Urban planning

Submitter 88 considered urban planning (specifically urban growth, resource management and planning matters) would be better addressed through means other than an NPS. They stated:

It is difficult because of the nature of urban design to exclude such matters but there becomes a very uneasy pattern of how wide the scope should be for urban design. The difficulty lies in identifying what is considered urban design and what is planning. There are of course links, such as between land use and transport, urban form and structure, but the essence of urban design is about spaces, places and how people use them rather than the extent of planning matters. The location of new settlements is considered a planning matter while the form of the settlement might be considered a design matter for example.

6.4 Detailed design

Many submitters stated an NPS should not deal with detailed design issues, particularly those of an architectural nature. Submitter 13 recommended an NPS should exclude:

Details of colour, window widths etc, i.e. the details of building design (but the principles about them being built to be energy efficient, human scale etc should be included).

Similarly, submitter 47:

The NPS should not go to the level of architectural detail – that is, it should not constrain the architecture, but it should make clear that urban design provides a framework within which architecture should work, from built form scale and massing to environmental responses to amenity issues.

Submitter 97 considered:

The NPS should not contain technical design recommendations or requirements. These would be better included in the appropriate design manuals and standards.

Submitter 82 stated an NPS:

…should not be prescriptive as far as the architectural design of building structures are concerned … urban design is highly context specific. It is therefore important for urban design initiatives to be developed at the local level as appropriate.

Others agreed detailed design was best dealt with at the local level. For example, submitter 39 indicated they would be concerned:

…if a national policy statement directed specific ways in which development should be controlled at a regional or local scale to achieve specific urban design outcomes…

Submitter 21 agreed, saying:

…it would not appear wise to usurp local decision making and necessary policy tradeoffs based on local conditions.

6.5 Other

Other issues mentioned specifically as not being suitable for inclusion in an NPS on urban design included:

  • social services

  • green buildings

  • rural environments or non-urban development

  • decision making on competing land uses.

 

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