We need productive land for the health and well-being of people but we also need to provide affordable high-quality housing and living environments. Photo / Nick Reed
OPINION
A potential roadblock to future urban housing development is currently being considered by the Government.
The proposed National Policy Statement (NPS) is intended to protect highly productive land (HPL) and the Cabinet Committee will consider the NPS this week with a decision to be made by full Cabinet onMonday, August 29. If approved, it will be gazetted and take effect soon after.
New Zealand has one of the highest rates of food production per capita. We need to protect productive land now and into the future for the health and wellbeing of people, and for our economic well-being. However, we also need to provide affordable high-quality housing and living environments for our urban populations.
The Ministry for the Environment and Ministry for Primary Industries are working on the NPS-HPL to address issues raised in public submissions, and to ensure the proposed NPS-HPL is effective and promotes the sustainable management of New Zealand's productive land.
The flip side is that there must be a pragmatic and reasonable opportunity for development as affordable housing and quality urban environments are important for the health and well-being of people and communities.
The proposed NPS-HPL considers Class 1, 2 and 3 soils using the Land-Use Capability system to be highly productive land and, while the intentions are sound, the wording will be extremely important in ensuring that there are reasonable pathways to achieving other equally valid national aspirations such as those set out in the NPS Urban Development ("NPS-UD").
The summary of submissions document states that, "The proposed NPS-HPL does not seek to provide absolute protection for highly productive land and recognises that non-productive uses are appropriate on HPL, in certain circumstances."
The proposed NPS-HPL discussion document included a transitional definition of highly productive land based on the Land Use Capability system (LUC) 1-3 with a minimum threshold within a site or 50 per cent of 4ha, whichever is lesser. The definition was intended to apply to general rural and rural production zones, not to rural lifestyle zones, throughout New Zealand. The definition was to apply from the start date until such time as regional councils have mapped HPL in their regions.
The issue is that there are many urban areas surrounded by land likely to be defined as highly productive.
These areas may not have been considered in detail in relation to demand for urban expansion or growth. Some areas are currently zoned future urban and therefore potentially exempt from the NPS-HPL, or provided a potential pathway for urban development. This zone is used in Auckland, Whangārei and Waikato.
In Auckland the extent of the zone is applied to land needed for urban growth for the 30-year period from 2010 to 2040.
Since these areas were identified in Auckland, there have been other legislative changes such as the NPS Freshwater and the National Environmental Standards Freshwater Management 2020. Additional land may very well be required for urban development beyond that anticipated in 2010.
This should not come at the overall cost of protecting our highly productive land; but nor should the protection of highly productive land come at the cost of closing the door to efficient high-quality urban outcomes to enable the provision of affordable housing.
Growth patterns change. We have not currently identified all land required for all urban growth from now into the foreseeable future.
It is imperative that the NPS-HPL provides clear pathways to ensure that land required for urban expansion, now and into the future, is able to be zoned for that purpose, if the benefits of using the land for urban development exceed the costs.
This is an analysis that should already be undertaken through the existing analysis required under the Resource Management Act. Without these pathways, the NPS will obstruct other NPS such as the NPS-UD.
When the Cabinet Committee votes on the NPS-HPL on Monday, the success will be in ensuring there are clear tests and clear pathways to enable land to be used for the best purpose.
These tests should require the robust assessment of all resource management issues with an appropriate balancing that elevates finite resource protection and use against non-finite resources; while ensuring all decisions promote broad health and well-being outcomes for all New Zealanders.
• Burnette O'Connor is director of consultancy The Planning Collective.