This is a guest post by Anna Michels. Anna is an urban designer at HUE in Tāmaki Makaurau.
Auckland Council has published its proposed changes to the Auckland Unit Plan in response to central government directives under the National Policy Statement on Urban Development (NPS-UD) and incorporating the medium density residential standard (MDRS) in the Housing Supply Bill and other matters. which was adopted at the end of 2021.
A major talking point of the proposed changes to the unit plan was the subject of qualifying questions that allow councils to avoid intensifying areas otherwise reserved for zoning under central government mandates. Some of these eligible questions are outlined in the NPS-UD, but councils also have the option of submitting their own.
One of the additional qualifying questions offered by Auckland Council is Special Character Areas (SCA). Any qualifying question must provide strong evidence as to why it should be included. To justify the inclusion of SCAs as eligible material under the NPS-UD, Auckland Council proposed that any SCA should have a high percentage of characteristic individual properties.
Auckland Council assessed existing properties with a special character overlay on six criteria, and each property had to score a 5 or 6 to be considered a feature. For an existing ZCA to be retained, the character properties within these special character areas must represent either 75% of the total properties within a pedestrian watershed or 66% of the total properties outside a pedestrian watershed. (In NPS-UD, broader zoning is required in watersheds within walking distance of rapid transit stops, urban areas, and metropolitan centers.)
These percentage thresholds also appear to have been created by the board. No information has been released on how or why these thresholds were chosen.
Like many other issues under the proposed plan change, Auckland Council’s approach seems to have been to spend a lot of time figuring out how to circumvent the main objectives of the NPS-UD, rather than focusing on the construction of a significant city. Auckland Council’s methodology on the assessment of special character areas is a good example.
Although Auckland Council has not published its methodology, the likely process is easy to understand by looking at the mapped outputs it has created in the official GIS viewer.
What was Auckland Council’s methodology for determining special character areas?
On Thursday (28/04/2022), Auckland Council posted the SCA Residential Results Reports online which show the individual property categories for all dwellings in any current SCA. This information is used to calculate percentage thresholds that determine whether SCAs should be retained or deleted.
The Board’s internal process for reviewing SCAs appears to look like this:
One: accommodations are assessed and classified
Each individual dwelling in existing special character areas is rated and rated from 0 to 6. The basis for the creation of this rating or the property characteristics corresponding to each rating are not yet publicly available. The assessment began as field surveys, but ended as desk studies using aerial photography and Google Streetview. Rankings are recorded in the Residential Outcome Reports and can be found here: https://akhaveyoursay.aucklandcouncil.govt.nz/housing
Two: the concentration of highly ranked properties is calculated
Next, the percentage of individual properties scoring a 5 or 6 within an existing DCA is calculated. SCAs can be as large as 300 houses or as small as 5 houses. The existing boundaries of the SCAs are legacies of the pre-unit plan planning processes. They have materialized in the unitary plan, and it is these limits that are evaluated in this process.
Documents released by Auckland Council indicate that backyard or vacant properties have been excluded from the total number of properties within an SCA, even if they are within the boundaries of the SCA. This affects the data accuracy of percentage calculations.
If the percentage of individual properties scoring 5 or 6 within an SCA is greater than 75% within a passable watershed or 66% outside a passable watershed, the SCA scope of origin is retained.
Three: SCAs are removed or retained
This is really where the story should end. Auckland Council has fulfilled its mandate to assess each character property and determine if it is part of a larger character area. If the methodology were to stop there, there would be far fewer SCAs retained than the preliminary response cards show.
However, Auckland Council appears to have taken another step, which dramatically changes the results.
Four: SCA boundaries are redrawn
If the percentage of individual properties scoring either 5 or 6 turns out to be below either of the 75% or 66% thresholds, ACS limits are adjusted to create a percentage that meets the necessary parameters. This smaller area is now classified as a new SCA sub-area.
This reshuffling of boundaries to achieve a desired outcome can be seen on a small scale with SCAs that lose a handful of houses on the fringe, or on a large scale with SCAs of over 300 houses that are sliced into three SCA sub-zones.
This methodology creates two major issues that have huge impacts on the built form outcome for Auckland, and appear to be a clear attempt to undermine the objectives of the NPS-UD and MDRS guidelines.
The two key problems with the Council’s method
First issue: how do back lots fit into SCAs?
The first problem created by the Auckland Council’s methodology is the obvious discrepancy in statistical data. Excluding rear lots from the percentage calculation creates higher percentages of characteristic single dwellings within a CSD. This is important because it can push SCAs above the percentage threshold needed for retention.
If an area has 20 houses and 10 of them are characteristic, the percentage is 50% of the total. This is too low to reach the 66% threshold. However, if five of the total lots are rear lots and excluded from the calculation, 10 feature properties out of a total of 15 houses suddenly becomes 66% and the original extent of the DCA is retained.
Preliminary response – Example 1:
The property mix in the SCA example is 48 units scoring 5 or 6 out of a total of 98 lots. This is explained by 49% properties with a rating of 5 or 6. These are below the required percentage keep the SCA.
However, because back lots are excluded in Auckland council’s calculationsthe total number of properties within that DSR is reduced by 98 to 61. Reducing the total number leads to the characteristic properties becoming a larger percentage of the total. Therefore, the percentage of properties scoring 5 or 6 as calculated with the AC methodology is 79%.
This now hits the percentage threshold for the SCA to be retained with its original scope.
For statistical accuracy, percentage calculations should include back properties to give a true sense of the abundance of high quality special character housing within DCA boundaries. If the back properties are not statistically taken into account, they should also be excluded from the SCA overlay. Currently, even though backlots are excluded from the calculation, they still receive an SCA overlay, which limits their ability to grow.
Below: some examples of the high quality special character on the street front in the example 1 area – and the newer rear property structures that would be kept in amber under the SCA.
Second problem: who decides where the limits of the SCAs are?
The second issue is the rearrangement of special character area boundaries to create “SCA sub-areas”. Changing the boundaries of DCAs to change the percentage of characteristic individual dwellings in a DCA essentially sacrifices a few houses on the outskirts of the zone to keep as many as possible in the subzone group.
The principle is the same as with the exclusion of back lots. If you reduce the total Number of houses among which are distributed the characteristics, the saturation increased. This is reflected in the percentage, and the result is the retention of otherwise excluded special character fields.
Preliminary response – Example 2:
The image below shows the original boundary of this SAC circled in blue. The mix of properties is 32 units scoring 5 or 6 out of a total of 58. Even applying the AC method of excluding rear lots, the calculation in this area only reaches 64% defining character houses, which does not meet the percentage threshold required to retain the ACS.
Therefore, Auckland Council has reduces the extent of the SCA. New boundaries are shown in yellow. AC referred to these instances as an “SCA subzone”.
The property mix has now been changed to be 26 units scoring a 5 or 6 out of a total of 38. The new SCA sub-area circled in yellow is now considered to have 68% of houses feature and can be kept as SCA.
By readjusting the boundaries and reducing the total number of lots over which the characteristic houses are distributed, an increase in the overall percentage is obtained. This means that a special character box overlay that would otherwise have been removed now meets the set percentage threshold and is retained, but with slightly reduced extents.
Adjusting the SCA limits to get a mix of properties that has the right percentage would be a lengthy process given that Auckland currently has 21,000 homes with a special character overlay.
Below: examples of less characteristic dwellings that will be retained in the adjusted DSR proposed for the sector of example 2.
Emphasis on character at the expense of the city’s future
With a focus on assessing special character areas, there hasn’t been much conversation about what built outcome we want for Auckland in the future, and what building the city would look like based on the best practices.
From this perspective, it appears that the Board process was designed to retain the greatest number of special character areas and the greatest number of properties within them.
The proposed plan change clearly emphasizes the zoning of what exists, rather than the central government’s main focus of a future-oriented planning approach.