Credibility on the line: time to get real about Auckland transport and land use options

Councillors are getting nervous about the planned central rail link (CRL).  So they should be.  And while planning is well down the track, it’s not too late to apply the brakes.

This post strings together some of the arguments I have raised against the CRL over the past several years[1], and adds another one –the likelihood that technology gains will further undermine it.

But first some basics. 

Moving more and moving further

Transport is a derived demand: you only get it in response to the demand to move people or goods.  And as information flows more and more freely around the world, so growing demand for travel and trade -- locally, nationally, and internationally -- drives investment in transport. 

As nations, towns, and cities prosper, we travel more and further.  We exercise greater choice in where and how we live.  We consume a greater variety of products and services at lower prices.  And the transport sector responds with ever increasing products, services, and capacity.

Of course, it’s not just a one-way street. Transport innovations facilitate new trading relationships and expand travel demands.  Innovation-driven gains in mobility have enabled the masses and not simply the rich to enjoy the benefits of access to more space, more places, and more lifestyle opportunities. 

For example, the arrival of the wide-bodied jet in the 1960s and the more recent emergence of the single aisle, light weight, twin engine long-distance jet have increased the affordability of long distance travel and supported the emergence of many more international travel destinations for many more travellers. 

Similarly, the globalisation of production has been facilitated by transformation of the freight industry into an integrated transport, storage, and fulfilment logistics sector operating seamlessly to deliver lower priced goods from producer to consumer regardless of the distance and borders between them.

Urban transport – a history of increasing personal mobility

This is not the place to detail the history of urban transport, but it’s worth noting a legacy of occasional step changes resulting from disruptive new technologies interspersed with long periods of refining existing technologies.  These two have offered people the opportunity to enjoy more space, better health, and better lifestyles through progressively improved access to housing, services, work, and recreation. 

 

Hence the displacement of horse and carriage with steam-driven and tracked vehicles in the second half of the 19^th century, the replacement of steam engines with internal combustion engines late in the 19^th century; the introduction of the omnibus at the beginning of the 20^th; the development of mass-production techniques for automobiles in the 1930s; and their proliferation in the 1950s and beyond.

Innovations in engines, propulsion, and materials have led to continuous automobile performance improvements. Even so, concerns about congestion, threats to oil supplies, pollution, and the costs of providing more road capacity raise questions over just how much more car use we can sustain. 

Despite its own gains in distribution, comfort, and speed, mass transit remains an alternative limited by fixed routes especially in today's complex and often fragmented cities.  The problem is less acute for buses than trains, although the economics of providing routes and schedules to suit diverse needs in large cities are entrenched in both modes.

So, where does the next step change lie in urban mobility?

Driving innovation

Perhaps the rate of advance to existing technologies has reached the point that disruptive technologies are less likely.  Ongoing innovation in car operations (built most recently on revolutions in information technology) and advances in engines are likely to deliver major capacity gains from infrastructure and lower the cost and impacts of private motoring[2], lifting personal mobility and reducing the likelihood of step change.  At the same time the propensity to use cars is stabilising, if not diminishing. [3] The threat is that the fixed route options for public transport will become even less attractive.

Of course demand will be  continue to be driven up by population growth, even if individuals drive less.  Herein lies the challenge: we are not talking about the mobility of current Aucklanders, but that of perhaps a million more seeking their share of transport infrastructure. 

How do we cater for this: promote a return to the old technology of fixed route rail capacity?  More roads? Or by managing transport demand through effective land use planning?  I prefer a combination of all three, but it’s a preference based on (1) understanding the particular limits to and costs of continued obsession with rail and particularly (in Auckland) the CRL, and (2) returning to an emphasis on sensible land use as the engine of this particular train, not transport.

The limits to rail

At the risk of being repetitive [4] here are some of the reasons to reject major expenditure on the CRL (or a rail-based airport link or harbour crossing for that matter):

(1)  Demand will be limited.  A doubling or tripling of rail patronage will not go far in terms of total commuter demand given the very small base it operates off; 9,000 Aucklanders commuted by train according to the 2013 Census.  That's 2% of commuters.  Currently 10% of Aucklanders commute by public transport, 80% of those bus.
 

Boosting public transport demand though park and ride facilities or integrated ticketing is limited by the relatively small number of destinations served.  Public transport travel time costs are already high and multi-mode travel inevitably lifts them no matter high efficient. 

Boosting public transport demand by providing inner city dwelling capacity is largely irrelevant as inner city commuters already have a high propensity to walk, cycle or take public transport to work (only 55% use a private vehicle).  That market is tiny anyway, and likely to remain so.[5]  

Promoting high density dwelling around stations at key suburban centres to boost train patronage will meet market resistance.  And, if successful, it will lead to conflicts between local activity and park and ride facilities, adding to local congestion. 

Focusing employment on the CBD to boost the use of public transport ignores the needs of the majority of businesses (only 12% of Auckland employment is currently in the CBD).  It also ignores questions over the resilience of the CBD. its ageing, often capacity-constrained infrastructure. and the vulnerability to extreme climatic events of low lying and reclaimed land on which much of it is built[6].

Promoting higher employment densities around stations to lift the viability of rail will generate additional road congestion as much of the interaction around businesses still requires point-to-point vehicle access, the majority of commuters are likely to remain car-bound, and the more people that live in and around the CBD the more of them will need to commute outwards to employment as well as for recreational reasons -- by car.

And there is a real question mark over what those many more white collar workers in the new towers might be doing,[7] especially as high tech employment increasingly favours low rise, green working environments.

(2)  The impact on congestion will be minimal. Creating additional road capacity by diverting some commuter trips to public transport reduces the costs of private transport, encouraging greater car use until such time as unacceptable levels of delay once more set in.  Such evidence as there is for developed cities in North America, Australasia and Europe does not support the proposition that public transport reduces congestion.[8]

(3)  The Capital costs will be high – almost inevitably higher by hundreds of millions of dollars than current estimates;[9].  Even without the usual "large project blowout" the marginal costs will be very high: if the impact was to triple daily commuting patronage to, say, 30,000 people a day a capital cost of $2.4bn (both optimistic assumptions) represents $120,000 for each additional commuter.
 

(4)  Overheads will be high – fixed costs are a large component of rail overheads.  These include operating costs, maintenance, and renewals (for rolling stock in particular), interest on capital, and depreciation.  Any demands on ratepayers or road users to subsidise this are still costs, costs that are likely to reduce the attractiveness of Auckland as a place to live or invest. 

In addition, pricing public transport to recover even a constant share of higher costs from users is likely to lower demand. This, in turn, is likely to reduce income more than costs, potentially leading to a subsidy (public cost) blow out.

(5)  The business case relies on heroic assumptions about the future of work and housing.  Building a case on assumptions about a shift to high density housing on suburban stations and new towers of white collar employees around inner city stations is highly risky, with no evidence that the risks have been factored into decision making. [10]  And there seems to be little consideration given to the risks to rail resulting from technical advances taking place in the automobile industry that should increase the efficiency of roads, lower the costs and boost further the convenience of cars, and improve the performance of buses  [2],

(6)  The economics do not stack up and consequently fiscal risk is high.[11][12]  The legacy of the CRL is likely to be enduring debt and costs that potentially reduce the appeal of Auckland as a place to live without reducing the problem of congestion. And they will be so much higher if the optimistic projections on which the business case is based fail to materialise.  When costs substantially exceed benefits productivity suffer and the Auckland economy is the loser. 

There’s got to be a Better Way

The aim of this post was to contribute to the current debate over the future of the CRL.  Whether or not it goes ahead it is not going to solve Auckland’s transport problems.  Nor will an integrated transport system based on common ticketing and interchange stations with their substantial land demands and impact on local and arterial road congestion help much.

The long-term solution may best be based on a return to basics: identifying the land use pattern that is in accord with both the city’s geography and the ambitions of the council to house another million residents (an ambition that seems to have gone un-debated in the lead up to current plans).  The transport system needs to be organised to serve that. 

Planning land use to serve an outmoded transit model based on an increasingly dated transport mode justified by the view that Auckland can continue to grow as mono-centric city is a recipe for disappointment  - and not just in transport.

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[1] Starting on this blog with Buses or Bust? April 2011 and Rethink the Link: Does Auckland Really Need to Pour Money into a Hole in the Ground, December 2011  To get an alternative point of view, visit transportblog.co.nz/

[2] Cars, Engines, Travel – Fewer, Smaller, Less February 2013,  Driving Blind – Driverless Cars Ramp up the Risk for Rail October 2014

[3] Cities, Cars, People – is Changing Car Use of Function of New Urbanism? March 2012

[4] Here’s an earlier list At least Five More Reasons not to Build the Central City Rail Link December 2012

[5] Living in the CBD or Just Passing Through, October 2014

[6] See Planning for Disaster and The Auckland Plan – A High Risk Recipe, November 2012

[7] See, for example, Whither White Collar Services? December 2011

[8] Do Density and Public Transport Relieve Congestion? December 2013

[9] Tunnel Vision: Thin Edge of the Rail Wedge July 2012

[10] For example Out Might Just be Better than up – the great Housing Debate is not Over April 2013 and on employment More Land, More Jobs, More Income, Addressing the Other Side of the Affordability Question April 2013

[11] This is the sort of contingency that a Business case should address as a matter of course.

[12] A Flawed Case,  Auckland’s City Rail Link and Derailing Auckland – Unravelling the assumptions December 2012

Driving Blind – Driverless Cars Ramp up the Risks for Rail Transit

In a brief radio interview yesterday I was asked about the possible consequences of driverless cars for Auckland’s planned big spend on its rail transit system.  My sound bite wasn’t too coherent, so here are some follow-up thoughts.

Driverless cars are coming

The driverless car is with us today, and its working.  The Minister of Transport’s expectation that it is “moving closer” is in line with international expectations and experience.[1]

In fact, the fully autonomous vehicle is just a further step – admittedly a big one – in the progressive reduction in the driver’s role in vehicle operation.  Automated train systems have operated since the 1960s.  Even aircraft today perform most operations automatically, and we are well on the way to the technology where they even interact to manage air traffic movements.

We can look forward to driverless road vehicles within the foreseeable future.  We are already well on the way.  Consider gains over the past 30 years by way of automatic transmission, power steering, automatic braking systems, electronic stability control, backing sensors, and most recently automated parking.  These innovations, while taking time to diffuse, reduce driver-related accidents and lift the efficiency of vehicle operation. 

Throw in the gains readily available from enhanced traffic management technologies, the use of GPS for better route planning and of GPS-derived Floating Car Data for real time traffic management and we have the promise of ongoing gains in efficiency in on-road vehicles and the prospect of a revolution in personal mobility.  And that’s on top of the promise of further gains in fuel efficiency following the 25% lift recorded by the US EPA between 2004 and 2014 and the impact of alternative fuels.

What are the consequences?

The Rand Corporation recently published a comprehensive study on Autonomous Vehicle Technology that is worth a look.

From this and my take some of the gains we might expect from driverless cars include: 

• The costs of travel will diminish as drivers are frees up to engage in other tasks and as greater travel efficiencies are realised;
• Lower accident costs because there will be fewer of them;
• Vehicle efficiency will improve as a result of: the capacity to use lighter materials; easier uptake of alternative fuels; smoother acceleration and deceleration;
• Development of more efficient parking facilities;
• Network productivity gains from higher vehicle densities and fewer disruptive events. 

This may not mean less congestion.  Numbers on the road may increase as people currently transport disadvantaged find it easier to access and operate motor vehicles.  Cost reductions are likely to boost car use.  And such gains may encourage more long-distance commuting.

On the other hand, the use of driverless vehicles is part of a convergence changing the environmental impact of motoring.  Together with the shift to smart cars for urban travel and to alternative fuels, driverless cars will contribute to a fall in the emission of particulates and CO₂ .

A new mode of public transport?

Driverless cars offer a new take on public transport by providing for shared vehicles that respond to individual demands.  They may be held in private pools; widely accessible vehicles may be in public ownership, or vehicles may held and maintained by a variety of organisations, including specialist operators (equivalent to today’s taxi or rental companies), bodies corporate on behalf of residents of apartments, or businesses on behalf of employees.  

Such arrangements will support the higher densities favoured by urban planners, reduce the costs of car ownership, and maintain efficient point-to-point travel.  In addition, vehicle pooling may encourage more trip sharing, lifting car occupancies.

Supporting fixed route public transport

So what will the consequences be for buses and trains?  Buses should benefit, both in terms of enhanced vehicle flow and, in due course, through adoption of the technology.  This could lead to smaller, more flexible buses with variable routing better meeting demand.  In other words, buses will be part of the revolution in personal mobility resulting from autonomous vehicle development.

Rail is a different matter.  In increasingly fragmented cities, fixed route transit is at a distinct disadvantage, especially when it is based on a limited network.  For rail to penetrate in Auckland it requires either effective feeder road access to park-and-ride facilities or the clustering of high density dwellings and jobs around already busy stations. 

Driverless cars could contribute to both of these.  The intensity of local cross-commuting required to support park-and-ride facilities may be eased by use of driverless cars.  The heightened congestion associated with higher densities in the inner city and on arterial roads targeted by the Auckland plan might be similarly eased by their adoption by residents as well as commuters.

But will driverless cars save rail?

While the adoption of driverless cars might marginally improve the effectiveness of rail transit, this will still be constrained by the intrinsic limits of rail .  Unlike rail, personal vehicles do not run empty for much of the time.  They operate from point to point and largely avoid the high time costs of transfers.  There may be some waiting time in accessing shared cars, but the inconvenience is a lot less than that associated with fixed timetables.  And with technical gains the externalities associated with car use will continue to fall.

Traffic flows should improve, costs fall, and convenience increase for car users.  Car-based transport will be more accessible, reducing the numbers dependent on traditional public transport.  Buses will also be more effective.  None of these positive outcomes bode well for rail with its high capital costs, the lumpy nature of investment, and high operating, maintenance, and depreciation costs.  What they do is increase the fiscal risk associated with Auckland’s plans for an inner city rail loop or extensions to the airport or North Shore as the alternative of road-based transport becomes that much more attractive.

The risk profile of rail investment is already high.  The prospect of driverless cars raises it higher.

Driving a revolution?

In just 25 years we have seen revolutions that have fundamentally changed the ways in which we deal with information, communicate, work, socialise and recreate.  There is every reason to expect the advent of driverless cars to signal a similar revolution in personal mobility. 

Who today would buy a typewriter, a telex machine, or a floppy disk?  So why buy a railway?

 

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[1]              See for example recent articles in The Scotsman and Forbes Magazine.

 

Rebooting New Zealand's Resource Management Act

Do we continue to tinker, or do we act on the Act?

Following many years working in strategy, planning, and development I have some suggestions for reforming the Resource Management Act 1991 (RMA), as many others do!

My first proposal is for more of the same – incremental improvements in the hope of streamlining the Act. This has been the response favoured by Ministerial advisory groups over the years, tinkering with process and increasing complexity without necessarily improving outcomes. If tinkering is the only option my suggestion, below, is for a stronger focus on clarity of purpose, defensibility of policies, and accessible plans. 

My preferred proposal is to return the Act to a focus on environmental matters by locating the onus for setting and applying standards in a scientifically strong central agency operating through regional offices.  Through this an environmental envelope can be established within which local communities – including resource users – can pursue development, moderated, perhaps, under the provisions of the Local Government Act 2002 (LGA).  This Act, too, would needs refinement though, to avoid it becoming as litigious and onerous as today's RMA.  Under the proposed arrangement a clear line can be maintained between protecting environmental assets and advancing local development.

Before outlining these proposals, a quick bit of background on costs and why they are so high. 

 

The costs of environmental regulation

These proposals\have been developed following analysis of the costs of the RMA. These include:

·        Substantial overheads associated with preparing and reviewing plans within councils;

·        The costs incurred by resource users, interest groups, and the public in responding to proposed plans and plan changes by way of submission and appeal;

·        The costs of applying for and responding to resource consents, including council costs (which are usually charged back to the applicant so that there is little incentive for containing them);

·        The costs of making submissions on or objecting to notified applications  for consents;

·        The cost of complying with any conditions imposed by the plan or as a condition of consent, and

·        The opportunity costs of development foregone or delayed by ambiguous or specious environmental claims and conditions.

Costs can be justified by the need to maintain environmental standards . They are the price society pays to manage natural resources wisely. But how much is too much?  And what if the societal costs are high and the environmental benefits no more than modest?

The costs and benefits of environmental regulation are hard to measure. But not attempting to do so means that it is too easy for costs to be excessive and benefits limited.  Given this prospect, procedural issues, attitudinal differences, and an adversarial approach all-to-often prevail in the dealings between resource users and councils.  Particularly problematic is the failure at the objective setting and policy development stages of planning to appreciate the difficulties of applying and enforcing rules if we are to pursue other societal objective.  

Consequently, a fractured and fraught process, often based on cursory or partial evaluation, may impede the opportunities for society to provide for its economic and social needs while failing to deliver the desired environmental outcomes.

Mission creep

High costs result when matters not obviously to do with the impact of activities on the natural environment are written into plans and weighed into decisions on applications for resource consents.  It is timely to ask how this situation arose, and how we might put it behind us.

While the original intent of the Act was to protect the physical attributes of the natural environment, its scope today has been extended to include the built environment.  From the Act:

environment includes—

(a)        ecosystems and their constituent parts, including people and communities; and

            (b)        all natural and physical resources; and
            (c)        amenity values; and
            (d)        the social, economic, aesthetic, and cultural conditions which affect the matters
                        stated in paragraphs (a) to (c) or which are affected by those matters

The definition of amenity values is also all-encompassing:

amenity values means those natural or physical qualities and characteristics of an area that contribute to people’s appreciation of its pleasantness, aesthetic coherence, and cultural and recreational attributes,

... as is the definition of natural and physical resources through to "all structures":

natural and physical resources includes land, water, air, soil, minerals, and energy, all forms of plants and animals (whether native to New Zealand or introduced), and all structures.

The result? A statute designed to manage the effects of development on the natural environment is now being used in attempts to manage social and economic matters.

Complexity

Mission creep explains the size and complexity of today’s plans.  Yet the Minister’s Technical Advisory Group in 2012 suggested accepting this by further reducing emphasis on the natural environment and adopting a perspective informed simply by “general principles”.  The statute was not designed for this expansion and practitioners are poorly equipped to apply it. 

This raises the question of how far tinkering with an act that was arguably never implemented as intended simply continues to move it away from its purpose.  Has the departure from the original environmental principles reached the point that the Act is today counter-productive?

Uncertainty

Complexity of process arising from a history of tinkering is a source of uncertainty.  Uncertainty consumes time and drives up costs. 

Complexity means that resource users must rely on a host of professionals to progress development even when the scope of a proposal is modest or consistent with the objectives of a plan. They include the planning professionals who specialise in writing and interpreting plans.  Lawyers are needed to advise on how best to navigate the process, represent protagonists views, and search ever-expanding case law for precedents and principles.  Physical scientists assess and propose responses to effects on the natural environment, and social scientists are called on increasingly to deal with possible economic, community, and cultural effects.  

And in the name of a better built environment, urban designers now participate in a process under a statue never intended to achieve urban design outcomes and not obviously equipped to deliver them. Codifying rules to enforce standards on the creativity, visions, and collectivity that underpin the urban landscape is not something the RMA was intended to do, if indeed it can be done at all. And as with the other specialists there is not often consensus among the experts on what constitutes a good outcome.

Uncertainty is not measured just by the length of time plan change and consent processes take, the number of experts involved, or by the lottery-like nature of the decision process.  It is compounded by the discretion consenting officers may exercise in approving, rejecting, or modifying applications for resource consent.  Such discretion often appears arbitrary, ad hoc, and inconsistent, although it seems generally to start from the conservative position of preserving the status quo. 

And how, in all this complexity, can communities hope to have a consistent or coherent say on the development outcomes they might favour?

 

Option 1: Further Amendments to the RMA

The first option is to continue to amend the RMA but in a fundamental way.  My proposal calls for a focus on the quality of plans and plan-making on the grounds that simplicity and clarity will eliminate the need for discretionary rules, increase certainty for resource users (including those contemplating activities best prohibited), and reduce consent processing demands.  This might be achieved by:

1.     Enforcing the simplification and reduction in size and scope of district plans by requiring that they include objectives only when a causal link can be established between them, the policies identified to implement them, the efficacy of rules under those policies, and their likely outcomes:

2.     Requiring a risk assessment likely costs against the probability of successful implementation and the magnitude of likely benefits (defined with reference to the relevant objectives);

3.     A commitment to monitoring outcomes and to modifying or eliminating objectives and policies if rules are not delivering against objectives;

4.     Eliminating non-complying activity status as far as possible in plans, with activities permitted, subject to explicit conditions, or prohibited, and the basis for any remaining discretion fully prescribed in the plan;

5.     A commitment to pre-application meetings for resource consents between policy officers, applicants, and their advisers.  All too often this meeting of minds (or at least clarification of differences among experts) only occurs at the behest of the Environmental Court following a council decision and subsequent appeals!

6.     Requiring notification to be used sparingly, restricted to matters which have potentially significant environmental effects that were not anticipated at the time of plan preparation and therefore fall outside plan parameters;

7.     Ensuring that plan preparation gives all parties the opportunity to influence objectives, policies, and rules, requiring quality consultation at each stage based on a “no surprises” principle;

8.     Allowing disciplines only indirectly associated with the effects of development on the environment to participate in plan preparation rather than implementation;

9.     Maintaining clear separation of responsibilities for objective setting (by elected representatives advised by their executive),  policy and plan development (the ambit of specialist policy analysts and planners), and implementation.  Provided that plans have clarity and practical rules implementation, which covers confirming permitted activity status, processing consents, and enforcing them, is largely a procedural matter that can be undertaken by people with appropriate technical training.  This is an area in which the current initiative to introduce competition in the planning process may have something to offer.

10.  Training for policy analysts, planners, and consent officers should ensure that their skills and experience meet community expectations for and understanding of development.  I would expect the educational and institutional paths for development of the planning profession to be reviewed to support any further reform of the RMA.

Time to Move on

The preceding suggestions constitute just another in a string of propositions for improving the RMA.  Most of these have simply complicated matters. It is instructive that the Government sees it as appropriate to truncate RMA processes for the preparation of Auckland's unitary plan and circumvent the Act altogether to advance residential development there and elsewhere. 

If nothing else, this tells us the Act is not working, and it is time to move beyond incremental statutory adjustment.

Option 2: Starting over – centrally-driven regional environmental plans

More fundamental reform would confine the RMA to managing the natural environment, to measures that manage, preserve, and enhance biodiversity, soils, and air and water quality in the face of the pressures of development, production, habitation and consumption. The principles of avoiding, remedying or mitigating effects can be maintained and, indeed, strengthened.  However, the grounds for intervention would be based on a combination of international protocols and nationally agreed standards mediated by local physical conditions, all subject to rigorous evaluation.

Form follows function

Changing the way things are done requires breaking down institutional inertia.  A reorientation of statutes and practices cannot easily be imposed on existing organisations, as we learned in the difficult and protracted transition from the Town and Country Planning Act to the RMA.

It is proposed that a national environmental agency should absorb the functions of the Ministry for the Environment and the current Environmental Protection Authority.  It would also take over consenting responsibilities for the Department of Conservation which would consequently become more clearly the manager of and advocate for conservation values and the conservation estate.

Given that regional councils are generally effective in environmental management, it makes sense to transform them into the regional offices of the environmental agency with responsibility for delivering nationally mandated environmental outcomes locally. They could develop regional environmental plans to do this and have delegated authority for issuing consents and enforcing plan rules.

The knowledge and skills base of regional offices would ensure that the rules to implement policy are sensitive to local conditions.  Rules should also reflect extensive consultation in the course of plan preparation, including territorial councils.  Proposed regional environmental plans could be challenged, perhaps before panels comprising independent commissioners and local council members.  The Environment Court would continue as the final arbiter on matters of substance. 

The Office of the Parliamentary Commissioner of the Environment could assume an Ombudsman role. Its independence would counter the potential for any partisan political agenda to over-ride the primary focus of a national agency on the quality of the natural environment.

Managing development

The impact of decisions on land use, infrastructure, and urban form suggests that many matters that councils are trying to deal with through the RMA may be better dealt with under the Local Government Act.

The LGA requires councils to provide for the social, economic, cultural, and environmental well-being of communities when they prioritise, plan, and budget their expenditure. The change to the RMA proposed here would exclude councils from controlling matters to do with the natural environment though.  Instead they would be required to comply with regional environmental plans.

Local regulation of development may be through spatial plans which map a council’s commitments as defined in its long-term community plan.  They would include provision for future land use, expectations for built form, and the infrastructure and public investment required to achieve desired development.

Strengthening the local in local government
Separating environmental regulation from planning for the built environment could pave the way for significant institutional changes in local government.  Territorial boundaries may be modified to reflect communities of interest and not simply physical boundaries.  The shape and composition of local boards could be aligned more clearly with the different circumstances, values, and needs associated with sub-urban areas, smaller settlements, and rural areas. 

Changes would be required in Council Controlled Organisations.  CCO business plans often influence development outside plans prepared under the RMA.  Consequently, CCOs may act as de facto consent authorities when their corporate plans do not provide support for the land uses a council requires. 

To promote integrated planning a greater onus might be placed on CCOs to implement agreed spatial plans. Among other things, this would mean that the fiscal consequences of spatial plans would need to be established at the outset. 

 

In summary

The proposed changes to function and institutional form suggest a different way forward. 

1.     They consolidate responsibility for environmental regulation in a national agency operating through regional offices;

2.     The agency would respond to international environmental commitments, central policy direction, and the state of the natural environment in the regions;

3.     National policies and standards would be founded on robust scientific evidence and implemented through regional environmental plans subject to rigorous evaluation and prepared in consultation with local communities;

4.     Territorial councils would be bound by these plans but responsible for community well-being within the development envelope established by them.  Their role would focus on ensuring adequate land is available for development, programming infrastructure, providing public services and amenities, and maintaining the quality of the built environment (particularly with reference to efficiency and safety);

5.     Boards would have the capacity to influence the built environment in the interests of local communities;

6.     CCOs would be accountable for the delivery of the infrastructure required to support spatial plans (but need not have a monopoly in this role).

While reducing local autonomy over environmental matters, the capacity of spatial plans to respond to social, cultural, and economic matters should be enhanced, albeit in a light-handed manner, especially as a major cost to councils – that of environmental regulation – is shifted to the taxpayer. 

At the same time, the transparency of council plans and council accountability will be raised as their mandate is clarified and conflicts around the RMA are reduced.