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8 Implementation and capacity issues

Many submitters raised concerns about how an NPS would be implemented and if there was the collective capacity to do this successfully. Issues discussed included:

  • the impact of an NPS on councils, particularly small ones

  • the cost of implementation for all those involved in urban design

  • how to develop and maintain appropriate urban design skills in New Zealand

  • the role of professional organisations in implementing an NPS

  • the role of the Ministry for the Environment in supporting councils with implementation

  • monitoring and evaluating the success of a NPS.

8.1 Smaller councils

Many submitters felt an NPS would create significant resourcing issues for small councils. Where submitters were specific, they mentioned costs, time and the people resource involved. First, in making the necessary changes to district and regional plans and, second, in assessing the perceived increase in resource consents that would result.

Submitters felt resourcing issues could have a major impact on the acceptance, uptake and successful implementation of an NPS:

…as many councils are small and have very limited funding, the NPS should not make it more difficult for councils to carry out their functions. If anything the NPS should assist councils in carrying out their functions, by making it easier for them to prepare effective policy documents. (16)

Less well resourced councils may struggle more to achieve quality urban design but these councils may also derive the most benefit from quality urban design. Giving councils an additional burden without support is, I imagine, unlikely to lead to quality urban design outcomes. (23)

Along similar lines, submitter 89 suggested:

…an NPS could end up making very little difference to overall urban development outcomes for larger urban councils that are already making appropriate changes to their district plans and being quite a costly exercise for smaller councils with very small urban centres and very little urban development.

A few submitters made the link between lack of local authority resources in urban design and the need for developing, attracting and retaining urban designers (discussed in section 8.3). For example, submitter 3 stated:

An NPS must avoid placing an obligation (or encouraging) every TA [territorial authority] to gear up with an urban design team. We just do not have the skilled people…

Submitter 108, who did not support the introduction of an NPS, stated any NPS would:

…create an unnecessary burden on smaller councils who may have alternative community based pathways to working towards better urban outcomes.

A small number of submitters also mentioned the costs and benefits of an NPS would need to be carefully evaluated. For example, submitter 39 stated:

The cost of implementing a national policy statement can be significant for both councils and communities. The Ministry for the Environment must ensure that the benefits gained from implementing any proposed policy statement clearly outweigh the costs of developing and implementing it.

Many submitters stated that an NPS would need to be supplemented by a package of resources to assist local authorities in implementing it.

Submitter 79 encapsulated many submissions by saying:

AN NPS on urban design should be accompanied by a support package to assist those local authorities who have limited resources.

Submitter 49 (who is not a local government submitter) suggested:

An indication of the implementation support that might be available for local authorities is likely to influence the local government response to the policy itself.

The NPS should outline funding responsibilities and provide avenues where funding may be received. (23)

Submitter 26 cautioned:

Rather than avoiding approaches that create resourcing issues for smaller councils, an NPS should provide guidance on how resourcing issues may be addressed through regional cooperation and other strategies.

Submitter 24 suggested a “no cost” to councils alternative to an NPS:

…developing a national environmental standard that requires certain types of developments to obtain resource consent, subject to assessment of urban design issues…This type of approach would mean that district plans do not need to be changed…

8.2 Costs of implementation

In addition to the costs of implementation for small councils, several submitters talked about the costs of implementation for other parties involved in urban design.

Submitter 65 cautioned:

Many developers are likely to see a further layer of uncertainty inserted into district plans if only general statements are made within the NPS.

While submitter 96 suggested: “A high level policy … would be an unnecessary burden of cost and time to regulatory authorities and plan applicants”, submitter 32 was concerned about the impact on developers if an NPS resulted in further regulation. In particular, they considered:

…the only legitimate way that urban design objectives and policies can be incorporated into plans with teeth will be through resource consents. This imposes a considerable cost on development.

In a similar vein, submitter 17 was concerned about the inherent conflicts between costs and time on one hand, and quality on the other:

Promoting better design involves giving greater consideration to design matters and a new level of performance from consent applicants, which often involves the application of discretion … This can result … in an increase in costs and time taken for consent processing.

Conversely, submitter 25 believed an NPS would reduce costs to local authorities, developers and communities. Specifically, the submitter referred to:

…lower policy development costs, lower guideline development cost, faster resource consent applications, greater certainty and lower risk for all.

8.3 Developing, attracting and retaining skills

Many submitters mentioned the need for developing and maintaining knowledgeable people in the urban design field, particularly to assist local authorities. At least one local authority noted it was having difficulty in recruiting a qualified and experienced urban designer. Another stated an NPS:

…must be supported by sufficient central government support to develop (and attract and retain) the skill base needed in New Zealand to deliver it. (17)

This was a sentiment also expressed by submitter 63:

An NPS on urban design should establish the importance of developing and maintaining knowledgeable people/groups that are able to advise and assess what is appropriate. It is important that every local planning authority has urban design expertise available to them.

A small number of submitters referred to the 2006 Ministry for the Environment survey of urban design skills within local authorities which highlighted the variable urban design capacity of councils. Submitter 25 warned: “…careful consideration should be given [to this] when drafting the content of the NPS”.

Submitter 111 suggested an NPS could:

…also signal to the tertiary institutions that there is a need to improve professional urban design skills and knowledge through education of future planners, designers and decision-makers.

Submitter 64 was concerned about perceived inadequacies in the tertiary education system because it tended to reinforce the ‘silo’ mentality of the various professions involved in urban design. Instead, they proposed:

…all students involved in designing the urban environment must undertake a year of undergraduate study on ‘urbanism’ or general urban studies that covers a broad aspect of architecture, landscape, planning, engineering and property theory and practice before entering into specialisation … This will ensure future professionals will have more balanced and integrated views of the urban environment.

8.4 Role of professional organisations

Two submitters commented on the role of professional organisations in implementing an NPS. Interestingly, neither submission was from a professional body.

One submitter (68) stated the NPS might broadly signal “the place of organisational, professional and sector actions relevant to good urban design”.

Another considered:

…it is essential that the Government lead a concerted effort to regulate and strengthen the urban design profession in New Zealand. A professional body needs to be established that will be the focus for education, research and professional standards in the industry … Any NPS or other statutory mechanism will only be as strong as the body of professionals that use and police it, so efforts to develop this further are needed alongside the creation of an NPS. (91)

This particular submitter mentioned a professional urban design body in South Africa as a good example of strengthening the capacity of professionals in the urban design field.

8.5 Role of the Ministry for the Environment in implementing an NPS

Submitter 52 considered:

While the Ministry has provided a useful information base on some urban design matters, it would need more effective involvement in key RMA processes, or some early pilots, e.g. through district plan reviews, to support sound urban design outcomes.

This submitter questioned the level of involvement of the Ministry and other government agencies in plan change 6 to the Auckland Regional Policy Statement, which included specific urban design objectives and policies.

8.6 Monitoring

One submitter (49) suggested the NPS should also include measures for monitoring and the benefits of this would go beyond simply monitoring the effectiveness of the policy:

Indicators or other monitoring initiatives would underpin further development of policy in the longer term and could begin to remedy the shortage of urban design research in New Zealand.

 

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