This is a guest post by Francis McRae. It was originally published on his Substack.
The recently announced bipartisan housing enabling bill will free up planning rules to allow three storey development across almost all of the existing residential areas of New Zealand’s five biggest cities.
It has been met with howls of outrage from the well housed residents of the leafy inner suburbs, and has met resistance from a planning profession that has shown little interest in solving the affordability issues the bill is designed to address.
I want to debunk three myths that are being pushed by opponents of the bill:
- That the bill will lead to lower quality of houses and urban design.
- That the bill will disperse growth and consequently increase transport costs and emissions.
- And that the bill will increase the costs of infrastructure provision.
The idea that this bill will inevitably lower the quality of houses is wrong.
Our existing housing stock is of extremely low quality. The key way housing quality is regulated is through the Building Act which this bill does nothing to change. The Building Act now enforces higher quality standards than were in place when most existing houses were built. Improved building standards mean any new home is going to be warmer and drier than the vast majority of existing houses.
The planning rules that the housing bill proscribes also do not create quality dwellings or ensure good urban design. In fact they often do the opposite. Restrictive setbacks and height-to-boundary rules create ugly houses that are pushed to the centre of the site. This limits usable outdoor areas as space is taken up with pointless front yards. It also makes it difficult to achieve the well established urban design principle of houses fronting the street.
Existing restrictions on building such as height controls and density restrictions reduce the amount of floor space per person across the city, and force overcrowding into existing houses. Allowing more construction will mean more space per person overall and less overcrowding.
Greater quantity incentivises greater quality. When there is an overall shortage any shit will sell. The more housing supply there is overall, the more developers are forced to compete on quality. This doesn’t require a naive view of the goodwill of developers. And this isn’t theoretical. We have real examples.
Lower Hutt City recently changed its plans to allow townhouses and low rise apartments across the city with little control on design enforced through planning rules. This has resulted in a building boom of townhouses that have generally been of a decent quality.
Like these in the image below. Snobs will find reason to pick at these but they look good from the street and are warm, dry, and well set out inside.
The housing bill will not disperse growth
Auckland Council’s Unitary Plan was premised on the concept of the “compact city”. The idea was that growth should be concentrated in existing urban areas, especially where accessibility is high and transport costs, in both time and money, are lowest.
In practice the compact city concept in the unitary plan was compromised by political interference from councillors representing the “leafy” inner burbs. As a result, there is little intensification enabled in the inner suburbs where it makes most sense, and a tonne enabled in outer suburbs in West and South Auckland where there was less political resistance. The unitary plan creates a doughnut city more than a compact city. It pushes intensification to outer suburbs, and drives significant growth in greenfield areas all while preserving the inner suburbs in amber. This has shown in Auckland Council’s own data on housing construction, with significantly more growth in outer suburbs and greenfields than the Isthmus or the lower North Shore.
Perversely then, commentators and even some within the planning profession have claimed that the housing bill will disperse growth, and increase transport costs and emissions. This is wrong. In Auckland especially the biggest impact it will have will be on removing restrictions that prevent development in inner areas. Growth will transfer from greenfield sites to the existing city, and from outer suburbs to inner.
An absurd version of the “compact city” has taken hold in an innumerate planning profession based around upzoning a small block around a set of shops or a train station and leaving the majority of the best located land for intensification reserved for single houses. This approach neglects the scale of the problem. Small blocks of upzoning around a set of shops are not
sufficient to enable the necessary growth in housing. So growth gets pushed outwards further from the city centre. The current planning rules are ones which promote dispersed growth.
However, the bill does allow growth right across the city so admittedly some growth will occur in outer areas. But in aggregate growth will be greater in inner suburbs both because that’s where market demand is highest, and because that’s where current planning rules are most restrictive. It’s also not a bad thing if outer suburbs densify somewhat. This means more areas can have access to a wider range of services that a greater population can support, that more people can stay in their neighbourhood as they move through life stages, and it means that infrastructure costs can be spread over a larger number of people.
The housing bill will not increase overall infrastructure costs
There are two key factors that determine demand for and cost of infrastructure. One is the number of people in the city, and the other is the overall extent of the infrastructure network.
Buildings themselves do not drive demand for infrastructure, people do. Two families crammed into one house will place roughly the same demand on infrastructure as two families in two separate dwellings. Population growth is driving the need for new infrastructure, and that demand exists whether people are well housed or not.
Also as the housing bill will redirect growth from greenfields to existing urban areas it will mean a more compact overall infrastructure network, and therefore less spending on infrastructure overall.
There is significant work for the government and councils to do in investing and upgrading the infrastructure needed for our growing population, but this will need to be done regardless of whether sufficient housing is enabled through the bill. The Auckland Council approach of upzoning insufficient little areas around shops and stations and pretending the job is done, may have the appearance of managing pressure on infrastructure, but in reality it leaves both the housing and infrastructure shortages unaddressed.
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Great article, very well written. Thanks Francis!
Hi Francis, thank you for your contribution to the discussion. You present clear well reasoned points that I thoroughly agree with, especially making it clear most of our current housing stock is shite and it’s the role of the building act to clean that up. Good work!
I think that you are going to be proved very wrong Francis, but only time will tell. For an opposing view, have a read of this article, which to me seems to have more of a ring of truth about it than yours:
https://architecturenow.co.nz/articles/the-diary-of-a-debacle-the-slum-enabling-act-and-other-matters/
I found that article very disturbing. “You would think it was a war… well, it’s just starting.” Quite offensive to people who’ve lived through wars. “the Government detonates an H-bomb right underneath every residential area in the country”. This might express her emotional reaction to a proposed change but it does not make for informed reading. And her actual points are nonsense. Pure clap trap. Julie Stout should be ashamed of the article.
I agree with the unnecessary use of inflammatory language by someone who is professional writing for a professional publication. This is quite disgraceful really.
Also the concerns that were inflammatory expressed can quite easily be addressed by the MDRS enabling perimeter block developments through the select committee process – which GA and the Coalition for More Homes have provided a lot of detail on. You can also read about it here. https://brendon-harre.medium.com/enabling-perimeter-block-developments-b528460815fc
Hi Brendon – I find the use of the word “enable” a bit misleading. These laws don’t enable perimeter block development, they simply remove controls over what people do. Maybe someone will catalyse perimeter block development, maybe they’ll put up a blank concrete wall to block their neighbours sun out of sheer spite 🙂
I have no issue with enabling perimeter block development as part of a master-planning process for areas suitable for perimeter block development. What I and many others have an issue with is deregulation, and entrenching the right to disregard how ones actions affect others. These laws, and aspects of the NPS-UD “enable” selfishness, anything else positive is largely good luck and relies on the ethics of the wealthy :-).
Great article! On point by stoking fear around Covid in the first sentence, really get those readers fired up and fearful from the offset. Oh, next sentence they’ve added some nonsense about Climate Change, awesome!! Ok onto the detail, its being liekned to an H-Bomb, you know the thing that killed 100,000s in Japan in the 40’s. Can see the comparision between, good call.
Then goes into detail on how Councils are still busy trying to find ways around, sorry I mean implement the NPS and now they have to deal with THIS!
Ok, I’ve read the rest of the article and it literally doesn’t explain why it shouldn’t go ahead and provides no evidence or data.
Cool, thanks for sharing.
The rest of that website is articles about massive fancy houses in Queenstown “Standing out in the ‘burbs – Arthur’s Point Steel House’ and a tech billionaire’s house in Wanaka. Their audience is rich boomers building ridiculous houses so of course they’re going to publish that nonsense. The author’s firm also designs similar houses. It’s all advertising spin.
I find myself wondering if our city’s have been allowed to expand and “grow” in a kind of up-side-down type of thinking.
Those who can less afford it are pushed out to the fringe of our cities and then forced to spend money that they can least afford to then commute back in to the city.
I wonder if we shouldn’t be, somehow, encouraging the so call better off to be the ones to move out to the fringe areas where they can build their edifices and the suburbs closer to the city centre be used to build upwards affordable multi-level buildings.
Such an approach, while never likely to happen because for some reason the closer to the city a property is the more financial value we put on it, would in my opinion address a number of ills within our society.
Gareth Morgan’s The Oportunity Party campaigned on getting the retirees out of the main centres with their adequate employment, out into provincial towns to address the issues there of funding the required infrastructure on a declining rating base.
The trouble for ageing retirees with both city fringe and provincial relocations, is they make you totally dependant on private motor car transport to undertake even the most basic of tasks.
Not a good fit, when approaching the time of no longer being fit to drive.
I do like our inner city location, a short walk to just about everything we require, and a frequent bus service for just about everything else.
In spite of his advocacy for retirees to decamp from prime spots, I think Gareth Morgan is still an Oriental Bay inhabitant.
She is saying if this bill passes we will be like East Germany. Does she mean in a housing sense, full of affordable houses with great uban amenity and cheap beer?
She seems to talking more from a political sense, the death of democracy. Heil Ardern?
What’s not to like?
That article doesn’t counter any of McRae’s points. It doesn’t prove that MDRS will lead to lower quality housing than currently exist, nor does it prove infra costs will be higher, nor does it prove that growth will be pushed to the outskirts.
Guy, you understand the reality right now eh? I’ll describe my last two flats before I met my partner. At that point I was someone in the upper quartile of income earners in NZ. One was a converted studio basement in Aro Valley, with no sound insulation and terrible upstairs neighbours. At one point shit bubbled up into the shower for days. At no point did I make any use of the outdoor space cause it was rubbish anyway. The next was a converted office above a garage in Newtown which was not a legal dwelling and did not have a proper oven or proper ventilation. It had a tonne of glass so roasted in summer and froze in winter. This is life as someone reasonably well off! For most younger New Zealanders, living conditions are so terrible that hearing people bang on about slumlike conditions as if they’ll be something new is just completely patronising.
+1 Conor. The boomers have lost touch with reality.
+1 Yes.
How precisely do you think allowing the people who didn’t fix your shower to buy more, and more expensive, rental property, and probably shade that basement, will improve things? Enforcing healthy homes standards is important but has little to do with the planning system. Healthy homes standards are often derided but they are more stringent in many ways than the requirements for a new dwelling.
Fantastic article. Clear and concise.
Good read; thanks for posting.
Bonus points for “any shit will sell”.
The thing that annoys me is the constant “they’ll all be ugly” suggestion that every nimby and seemingly a large number of planners have fallen back on. Ugly is not an objective measure, walking around leafy expensive suburbs I find plenty of houses ugly but presumably the occupants do not and you can’t define a requirement for a house not to be ugly.
Yes this is a very common opinion. It is almost like pretty buildings were created by some mysterious process in the past that cannot be reproduced anymore. A bit like Roman concrete or Damascus steel.
I have long wondered why that is.
Partially this is a conscious choice by architects. Ornamentation is a waste of resources, that sort of thing. So we have a lot of buildings, even expensive ones, that look almost like they are still unfinished. This is some of the most expensive real estate in Auckland, and… https://goo.gl/maps/mZAPD97QUBZoKtky8
If you walk through the inner city suburbs you get all these mass produced ornaments. Even though the houses themselves where nothing special there was still this understanding that buildings should be ‘finished’. We finish and decorate our interior walls, why can’t we do the same outside?
(part of the explanation may be that people were still regularly both outside their home and outside their cars back then)
At least some developers are figuring this out again — Ockham springs to mind.
Also don’t forget those inner suburbs are right next to the city centre. Which has a lot of buildings that are, frankly, aggressively ugly. Probably there is some negative halo effect going on here.
That link to the “most expensive real estate in Auckland”, I think might be leasehold land; not a great incentive to build the most expensive buildings on it.
Just a few hundred metres away there are more of these building that actually look really good.
https://goo.gl/maps/5n1ojg7mBTrzYthc6
I would love to live there (though this particular block has very expensive ground lease)
Main difference is a bit of time; those trees make it feel more like a leafy suburb, and yes, there is the odd interesting window and/or shutters, but given time, with foliage and paint, these places will be increasingly attractive.
And should we have laws saying what kind of car you can park because we don’t want ugly ones in the street? Maybe your whole family needs to be accessed for good looks before moving into the neighbourhood too.
And I refuse to have any adult who wears crocs in public moving into my neighboorhood. Can we add that one too please.
Crocs are pretty trendy these days.
It is all fun and games, until you realise this sentiment actually exists, and it makes it really easy to block a lot of development.
Great article!! On point by stoking fear around Covid in the first sentence, really get those readers fired up and fearful from the offset. Oh, next sentence they’ve added some nonsense about Climate Change, awesome!! Ok onto the detail, its being liekned to an H-Bomb, you know the thing that killed 100,000s in Japan in the 40’s. Can see the comparision between, good call.
Then goes into detail on how Councils are still busy trying to find ways around, sorry I mean implement the NPS and now they have to deal with THIS!
Ok, I’ve read the rest of the article and it literally doesn’t explain why it shouldn’t go ahead and provides no evidence or data.
Cool, thanks for sharing.
Sorry, the above was supposed to be a reply to Guy M’s absolute nonsense that he posted!
One thing that can cause comments to go to the bottom of the post is when they paste copied text in: make sure there’s some typed text at the top of the comment, and paste below that. If you choose to post it again in the right place, I’ll delete these two comments.
Sorry, timing no good as there are now replies. I’ll leave as is.
Joe – not absolute nonsense, but probably overly emotive, I’ll give you that. Having sat down and read over 200 of the submissions to the Bill, and listened to over 6 hours of submissions, and given that both Eugenie Sage (Chair of the Committee) and Nicola Willis )Nat member of the Committee) have both said – the intent is good, but the detail is bad, and there is a strong risk of the bill producing some really bad design outcomes, then I feel entirely justified for saying that I agree with Julie Stout that there are slum-making conditions being enabled. There are plenty of examples of bad housing being built in Auckland at present – what we don’t need is legislation permitting even more bad housing to be built as of right.
Can you outline some comparative Cities across the world where enabled 3 level buildings with minmal setbacks have created sprawl Guy? Be interested if you could post some examples.
Of course Nicola Willis is back tracking and Nats are now looking to change the bill they worked on, they are playing politics and have a bit of backlash from their ‘demographic’.
Anyway, no, the article demonstrates nothing, shows no examples, no data, nothing, just some emotive nonsense from the type of person that has already led us to a housing crisis. If someone has broken something they usually aren’t the best person to fix it.
You can see from the change in language National is using – especially from Nicola Willis – that Luxon is having a NIMBY effect on the party. Which isn’t surprising because as an electorate MP Luxon has been a NIMBY as explained here.
https://www.newsroom.co.nz/nationals-new-leader-revisits-medium-density-housing-pact
Housing advocates – including the centre-right NZ Initiative have urged National not to back away from the housing Bill.
https://www.stuff.co.nz/national/politics/300467324/housing-advocates-urge-national-to-stay-the-course-on-bipartisan-deal-to-force-councils-to-allow-more-homes
Chair of the MDRS select committee writing as a Green party MP gives a pretty sensible outline of how more housing density can be enabled that will benefit housing supply and the environment, whilst acknowledging this type of housing supply isn’t a silver bullet and other initiatives are needed too.
https://www.stuff.co.nz/opinion/127138734/enabling-density-is-a-start-but-more-needs-to-be-done-to-rein-in-the-runaway-housing-market
Guy, you’ve defined what a slum is..great. You have not given any example of how the planning rules proposed will ensure ‘slumage’. You talk about overcrowding as if that isn’t happening now, literally the first image in todays article shows that. Increasing housing should prevent overcrowding.
So what you are saying is that you want to increase density AND we should have all the minimum set backs, front yards etc etc the council proposed etc to ensure good design so hat we really need to do is allow say 5 levels instead of 3? Makes sense, liek where your head must be at.
Guy M can you explain the logic behind your argument that the MDRS enables future slums? Also what do you define as a ‘slum’?
I wonder if the definition of a slum is like Ponsonby was in the 70s?
Sure thing – Slums are caused by overcrowding, poor hygiene conditions, and the construction of substandard dwellings. Slums come about when cities are subject to excessive growth pressures, when sewerage and transport infrastructure cannot keep up with the growth and when there is a shortage of usable land. The UN warns that anywhere there are more than two adults sharing a bedroom, this indicates overcrowding and possible slum conditions. By that measure, many of our existing communities are already experiencing slum conditions.
Obviously we do not have the same conditions as the barrios in Brazil, yet, but we do have people living in their cars because they cannot find a house to live in. So, I would say that in the case of living in cars, we are already at Slum conditions.
Its an emotive word “Slum” and nobody wants to admit that we may have slums – we certainly don’t have the case of sewerage running down the footpath (that only happens semi-regularly in Wellington, not all the time), but both Auckland, Wellington and other parts of NZ have definitely had slum conditions before – Greys Ave in Auckland, Haining St in Wellington, etc were definitely slums.
So what makes the MDRS give rise to possible slums? Well, the removal of any checks and balances, such as quality of design, is a huge potential problem. The fact that you could get neighbouring houses each just 1m off the boundary, facing into each other, is not good design – it certainly could be, with good designers, but in the case of a lot of what is going up in Auckland at present, it is being done rather badly – and that’s with the Council’s consent. Remove any say over that from Council, and it is not somehow going to get better – it is almost bound to get worse.
Some of you seem to think be under the mistaken apprehension that I am against increasing density – far from it, you’re absolutely wrong. I’m very much pro-density – but not just any old building with low design standards, but I’m very much for building better than we are at present, not worse. Anything we build today will be here for the next 50 years at least, and there is no time to be building badly. If we are going to be building more, then we need to be building better. Surely you can all agree with that?
Guy, you’ve defined what a slum is..great. You have not given any example of how the planning rules proposed will ensure ‘slumage’. You talk about overcrowding as if that isn’t happening now, literally the first image in todays article shows that. Increasing housing should prevent overcrowding.
So what you are saying is that you want to increase density AND we should have all the minimum set backs, front yards etc etc the council proposed etc to ensure good design so hat we really need to do is allow say 5 levels instead of 3? Makes sense, liek where your head must be at.
I see this a lot:
“The fact that you could get neighbouring houses each just 1m off the boundary”
Dont we already have this? Some of this infill housing is very very close to each other. Hobsonville point has many examples where you look out you side door to a fence and then the next door neighbours windows over top.
Is the complaint not that this might and does happen, but that it might now happen in your suburb?
I don’t live in a suburb – I live in the central city.
I think that we are all arguing for exactly the same thing here – better urban density, better suburban density. Yes, we sure have some shitty housing being built at present, despite the Council being enabled to say “No thanks, we think you can do better” and evidently failing. What I (and many others) see as the problem is that if you say “Do whatever you like, we are removing almost all the controls” – then you are likely to get even worse results.
We have to deal with Councils for Building Consent and Resource Consent (planning) every day. There’s a bit of to-and-fro discussion, but usually the Council are hugely supportive of what we do. Sometimes, they’re out of line and get ridiculous over things. But mostly, they are a force for good. But removing all of the ability for control… just seems to me that there will be some unscrupulous actors (ie cowboy developers) who will abuse the system. They don’t care – in this market, anything sells. Long term though, we’re all stuck with the crap they leave behind.
The article is one of the worst I’ve read. I too have listened to quite a lot of the presentations and read several submissions. What strikes me is the level of repeating borrowed ideas without reflection. It makes me despair, because thinking for ourselves is an important human skill which we’re going to need, given the scale of change we need to undertake in every sector and at every level. There seemed to be no understanding of car dependence and how to overcome it. No acknowledgement that our current urban form is foul, dysfunctional and inequitable; just a whole lot of moaning about its loss. Our single house zones take up way too much land and consequently, cause sprawl. Defending that, in the current circumstances, is disgusting. This bill can be a big part of fixing our problems.
Perhaps the best article I’ve read is Jade Kake’s article on Stuff: https://www.stuff.co.nz/business/opinion-analysis/300466228/how-do-we-achieve-good-housing-design-at-scale
Jade Kake’s article is great – I fully endorse all her points.
+1 Jade Kake article is definitely worth reading. And raises good points. I would advocate for more government builds & infrastructure to allow for this density to develop, rather leaving it to the market.
Guy, can you explain why you think the bill will produce bad design outcomes? I keep hearing this but no one ever says why or how this might happen
There is no rationale. He just keeps saying the same mantra as everyone else seems to “i am for density but only good density” so only density away from my neighbourhood.
Chris – are you an architect, or an urban designer? Most people who are one of those professions seem to understand it, but some of the people on this website who maybe are not, seem to think that we (arch/urban designer) are needlessly worrying. We’re not.
I’m all in favour of perimeter block housing, so I fully support what Brendon Harre and Jade Kake are saying – they are absolutely right that this would get us a chance of some better housing. I’m also dead against the need for side yards and have been arguing against their mandatory nature for years (https://www.academia.edu/9080997/Pavlova_paradise_and_the_Curse_of_the_Side_Yard).
But perimeter housing and courtyard housing will only produce that better overall result when done as a co-ordinated approach, and that is the key problem with the MDRS as it stands – that it permits the unfettered ability for anyone at any time to build structures very close to the boundary, allowing the possibility of loss of light and views out while also potentially maximising loss of privacy. If everyone on the block converts to perimeter block housing or courtyard housing all at the same time, then this problem is overcome. But allowing an area to develop piecemeal, with some people facing the front and some people facing the side, means you get some terrible results.
I’ve just been reading a book “Town Planning in London – the 18th and 19th centuries” (Donald Olsen, 1964) which I found really fascinating. The vast estates of brick perimeter housing that everyone keeps saying is a great urban environment (and I agree, having lived in these for a decade) but they certainly didn’t arrive like that by lucky coincidence. There was intense zoning, numerous restrictions on what could and could not be built, all facilitated by the fact that often the estates of extremely wealthy land owners (eg the Duke of Bedford, the Duke of Portland, the anglican Church etc) who had rigorously steadfast rules of the buildings, even down to the nearest brick (so that all the windows and cornices etc aligned).
In Morocco, entire wonderful cities like Rabat are comprised of many thousand of courtyard houses (and no cars, keeping Heidi very happy I hope) sited wall to wall, all over the hillsides. Its lovely – it is a fantastic place to be, and I’m sure its growth was very organic and probably completely unplanned. But different economic pressures and a different urban control (probably under the King of Morocco, many hundreds of years ago).
But having a complete free-for-all in Auckland will not get that quality of buildings. Most people will not demolish their own house and rebuild three new dwellings, but instead perhaps take the opportunity to build a new dwelling or two in the back yard. I’m certainly not against that – after all, our company Flip Homes specialises in exactly that. Other people will simply sell up and leave it to a developer to build anew, and so you will get the situation for the next 30+ years where you will have a motley collection of some suburban houses, some semi-urban townhouses, some perimeter block housing scattered here and there. There will be some happy outcomes, but for the most part, you will probably see lots of self-centred urban chaos, with much abuse of views and sunlight and privacy.
That’s why most of the submitters to the Bill, although mainly in support of the bill, are not in support of it as it currently stands, with all checks and balances removed. Even Nicola Willis, one of the originators of the Bill, and Eugenie Sage, both agree that it needs some changes made to the Bill, and some safeguards introduced.
Jerry – you’re so wrong… See above
Good read,always interesting to hear people say “the sky will fall in ” when the status quo is challenged. Onehunga is currently going through a fairly large intensification, solely needed IMO, which in the most part exceeds,the three storey proposal.l have a feeling, this new proposal will enable developers like Kainga Ora, to get the best out of their existing sites. The 40’s, 50’s built state houses are no longer fit for purpose, but are presenting a great opportunity for intensification on a grand scale.
I had some time to kill in Pokeno, earlier this week,rode my bike around ,all the new developments, $1,000,000 plus to live there, added bonus commute, driving, back into Auckland, 2 hours at 11.00-1.00 ,traffic at a standstill Takanini, reason ,no traffic light filtering onto the motorway.
We must intensify our inner city,to give people better housing/lifestyle choices
And a double track rail line right through the centre of Pokeno with no railway station. Until recently there wasn’t even a bus service. Totally car dependent sprawl with a Ranger in every driveway.
Front setbacks are stupid. Nobody needs a front yard and few of us even want one. Does anyone know what they are for?
It’s the side setbacks that are stupidest, though. You could have a line of attached houses at the street, or setback from the front and make some (garden or courtyard) use of the setback. But the side setbacks, height to boundary and recession planes on the side boundaries just prevent good buildings.
I think the origin of side yards was fire safety. But it doesn’t work. Mrs mfwic and I own a villa in Newtown in Wellington just up from the big fire in June. Rather than houses 1m apart it would be safer to have them all connected but with concrete walls as dividers.
I thought Wellington villas were designed to prevent fire by being too damp to burn?
Actually, I’m told (anecdotally) that the purpose of a side yard was there for two reasons – one: to get the lawnmower through to the backyard and two: to allow firemen down the side of the house with a hose to put out fires in the back yard.
lol. Yes half of Newtown seems to be rotting, but it is still a bargain. It is like buying in Ponsonby 40 years ago.
Wellington is a really difficult place to buy a house. It takes ages to find one that won’t fall down a hill, wont have a hill fall down on it, where you won’t be swept out to sea in your sleep, and where you actually get sun on your windows. When you find all that you have to pay the price. We have replaced the roof, 3 external walls (now insulated), the foundations and the veranda and most of the windows. But most important is a membrane underneath and a machine in the ceiling to ventilate the place because the tenants will be working all day and cant leave windows open. If you know people there doing this I can’t speak highly enough of the Sustainability Trust, they have be brilliant.
The purpose of a front yard is so that after subdivision you can build a tall fence around it and recreate a backyard.
I support the intent but have grave concerns for the street.
Under the lax rules proposed it would be possible to put all the surface car parking at the front of the site, in fact the coverage percent’s encourage such a move.
Too much of the discussion has been about HRTB or setbacks; but what about front doors, eye level windows, fence heights avoiding blank walls to the street etc. all missing. Lets go back to Jane Jacobs, CPTED principles and creating decent streets. I don’t care about ugly, ZI care about community safety.
Well said Andy.
Urban design isn’t just about housing; the streetscape plays an important part of the “feel” of a neighbourhood.
+1
Designing around the cars introduces problems whatever the building typology is. Housing the cars at the back of the site create massive problems too, in terms of wasting the private outdoor living space on cars, more land used in driveways, less ability to fence driveways off to prevent children being killed.
Perhaps the bill should say that once the density is more than one dwelling per 350 m2, there should be no offstreet parking. This would remove vehicle crossings, improve the public realm, give more space for trees, more kerbside road space for cycling or for parking (whichever is appropriate) and would make things safer for people on foot and bike.
In some cities, any parking provided MUST be at a short walk from the residence, based on the evidence that this reduces car ownership and car use. Seems like one vehicle crossing per street block, to a consolidated priced parking area which includes space for private cars, share cars and delivery and removal trucks, along with a few timed drop off parks along the street, is the model to aim for, rather than having any car storage on site.
You don’t think the massive amount of intensification that’s going on in places like Te Atatu and Onehunga has anything to do with lower land costs and a generally more depreciated existing housing stock which makes the intensification more financially viable for developers?
The “leafy central suburbs” have significantly higher land values and a generally higher quality/maintained level of existing housing stock that make it harder to make the commercials work for a developer?
If different regulations make no difference, then changing regulations will make no difference.
Wait what? No change to leafy suburbs so there is nothing for the leafy suburb nimby’s to complain/oppose then? It’s either going to create slums in the leafy suburbs or it’s not going to result in any change in the leafy suburbs? Which one is it again I’m getting confused
Land costs get passed on to the purchaser of the properties that the developer creates. Higher land values reflect the higher desirability of living in those locations due to being close to the central city. So developers would develop those higher land value areas if zoning didn’t prevent it. Instead they have to go where development is permitted, ie Te Atatu and Onehunga.
There is lots of upzoning enabled in the inner suburbs. Limitless in the city centre and Newmarket, at least six storeys in the arterials around Ponsonby, Herne Bay. Loads of infill going on in Westmere which is the closest to what is being proposed. What generally happens is that a developer buys a large section, over 600 squares and tries to make the most profit from it. Sometimes this means gorgeous terraces that sell for $2m a la Block. These are similar to the ones in Lower Hutt but the land values are higher. So, to meet the middle market it often it means squashing as many terrace homes on as possible, the ground level is mainly carparking with the minimum of landscaping squeezed in on the side which is a worry with the need for trees to mitigate the heat island effect and permeable surfaces to suck up stormwater. The houses overlook the neighbours who no longer get sun or privacy and are upset. There is often no way to get to the pavement without walking down the driveway, so not great for kids.
Large increases in traffic on the roads making the area less walkable because there are so many traffic movements across the pavements. There are also some apartments on smaller sites. They are squashed close to the next building that may be two or three storeys so the outlook from the bedrooms is a small shared lightwell. There is honestly loads of intensification happening in the inner suburbs right now – some of it is good, and some of it is poor. Design and thoughtfulness can make a huge difference to outcomes. Everyone here I think likes the idea of form codes and perimeter blocks but that is not what is being currently proposed (though, fingers crossed, enabling these things will be what we end up with). This article also suggests leaving it to the market – because housing is shit already, except when it isn’t (see Lower Hutt). Why not argue that the government improve the building code which they should to improve noise outcomes and to enforce construction waste plans?). Rebecca MacFie in North and South argued convincingly that the market has delivered quality affordable homes in the right places in the past – ie. easy walking distance to jobs, amenities, education and transport – and I don’t see why it will now. What the bill does do is embed the urban growth agenda as economic driver in which all urban growth is good just at a time when we need to put less pressure on the planet.
“the ground level is mainly carparking”…
“The houses overlook the neighbours”…
Ah, you mean, Auckland Council has bad planning regulations. Yes, they do. They’ve had every opportunity to fix them, but they haven’t.
How can you look at places that work at high densities and look at the problems you’re listing here, that are already happening, and think it has anything to do with this bill or with intensification in general? It’s not.
“Large increases in traffic on the roads”…
What causes large increase in traffic, Alex? Sprawl does. Specifically: AUCKLAND COUNCIL’S DEVELOPMENT STRATEGY does. Car dependence does. This bill will reduce traffic, by enabling more intensification.
…”making the area less walkable”…
Alex, Coucnil’s Development Strategy has made our city less walkable. By allowing sprawl. By starving us of the streetscape improvements we need. By keeping our rates low, and because the sprawl they’ve allowed has cost us dearly.
“What the bill does do is embed the urban growth agenda as economic driver in which all urban growth is good just at a time when we need to put less pressure on the planet.”
If the bill increases intensification – and it should do – then it’ll reduce pressure on the planet by reducing sprawl. I was worried about sprawl being an issue with the NPS UD, but when I read it, I realised it’s not. Guess what? It seems to only be Council’s response to the NPS UD that means we might end up with more sprawl.
How much lobbying have you done against Penlink, Matakana Link Rd, SH1, and all the road widening projects in the NW? If not, why not? These are the projects that are going to add more traffic to the city and will put more pressure on the planet, not intensification. Providing houses in medium to high density is how to put less pressure on the planet.
What about lobbying to use every Council decision to radically reduce the supply of carparking, in every kind of location and every suburb? Is that something you’ll do to help reduce the pressure on the planet?
Hey Heidi, I totally agree with your aspirations and the board advocates all the time against sprawl. Every single one of our feedback documents on reducing emissions and planning have said happy with up, not with out. Our concerns are that this bill enables more greenfield development rather than encouraging apartments and perimeter blocks closer to the centres. My raising of examples in Westmere is not to fight against more density but to argue that it needs to be done better and that to support the current proposal as it is, is a mistake, however it has been, I acknowledge, been an absolute kick up the arse to have really good discussions on what we DO want. And there is an opportunity in the bill for councils to raise the bar where taller buildings are proposed – if this is not an opener for mid-rise perimeter blocks, I don’t know what is. All the suggestions to make the bill work better have been valuable and I am glad that the committee in charge of improving it have said that they are going to do just that.
There is honestly loads of intensification happening in the inner suburbs right now
This is objectively not true, the image is in the article: https://i2.wp.com/www.greaterauckland.org.nz/wp-content/uploads/2021/12/FE0nSIuUcAMcoI0-1.jpeg?w=848&ssl=1
The inner suburbs are a relative dead zone, not pulling their weight. Maybe the impression is because most of the development is concentrated on arterials. While in most suburbs behind that is the same or similar zoning, in the inner suburbs it’s only on the arterials. So travelling you see the same amount of change.
But how does that work? Doesn’t it go like this? (1) buy the land, (2) get a consent — hopefully, (3) build stuff, and then (4) sell it.
There must be a cost and risk associated with holding on to $2 million worth of land for that amount of time? Especially if there is also a possibility that (2) goes pear shaped, and if the new buildings themselves aren’t worth much more than the land.
To me the inner makes more sense: buy an old house in Mt Eden for 3 mil, demo and build 3 new houses for 700k each, sell each for 2 mil, you make 900k profit. As opposed to buying an old house in Papatoetoe for 1.5 mil, demo and build 3 new houses for 500k each, sell each for 1mil, you break even.
more like “buy an old house in MtEden and squash in up to 12 units”
Hopefully yeah.
Are you threatening us with a good time?!
The point is that ratio of older, depreciated, less well maintained houses in the inner suburbs is much lower than further out, it’s easier for developers further out. Also less capital outlay/risk for them
In the inner suburbs what I’m actually observing is the relaxing of the rules in the UP being used to build/extend huge single family homes which wasn’t really the intent
There’s plenty of shit housing around my way (Albany) that has all the negative aspects of density with few of the positives (tightly packed single housing).
For lots of the older sections that are long and skinny I have yet to see a good example of how 3 story townhouses would work without just being sausage blocks looming over their neighbours.
Perimeter blocks are awesome and having stayed in one in London I fully endorse them. But unless they’re developed all in one go I don’t see how they can work all that well for lots of our pre-existing sections.
Long skinny sections are not a barrier to good design or to perimeter block housing. I think people have become so used to seeing intensification that involves a smallish outdoor footprint next to a one or two story infill house.
Looking at our block dimensions and comparing them with successful PBH in other cities reveals that the dimensions are similar. Rarely, there may be dimensions that are too long – but that can be resolved with a new laneway. This is how planning should be used – it’s far, far less work than creating sprawl for these houses. There were people making submissions on the Amendment Bill in the architecture and planning sector who used long skinny sections as a reason against the bill. I feel they were really misinformed and unprofessional.
PBH works by having a much larger outdoor space, serving 3 to 7 storey townhouses or apartments near the street. So for an individual site, this can mean a long skinny wandering garden until the property next door does the same and they combine into a long, slightly wider garden… a full perimeter block is achieved when they’ve all combined their gardens.
This article is worth reading on how PBH can develop organically (and is better in fact if it does.) HT to Roeland: http://urbankchoze.blogspot.com/2015/05/traditional-euro-bloc-what-it-is-how-it.html
Brendon’s been doing quite a bit of work on how to resolve processes to create better urban form. Here’s one of his articles:
https://www.greaterauckland.org.nz/2016/10/26/guest-post-a-right-to-reciprocal-intensification/
It is quite easy to imagine how perimeter blocks would be developed in, say, Ponsonby or Grey Lynn. These areas already have this exact form: houses facing the street and their own backyards. Extend the existing building footprints to the side boundaries, and make them more than 1 storey high. You can do this one by one.
+1
Frank, why do you always make so much sense?
Another great write up!
A good article but a couple of points. The Building Act ensures build quality is of a certain standard of construction and indeed the new act will not effect construction quality. However it does not cover off design, ie if a developer proposes a blank wall to the street to provide privacy, currently the urban design panel would prevent this and want it broken up to ensure it fits into the built environment etc etc. By putting design controls 100% in the hands of the developer, you will find that in lower cost areas the housing outcomes will be very poor. Granted, Council have some very stupid rules at present, however by and large the urban design panel do prevent most (not all) disasters happening.
Second point, I don’t believe the new act will have the effect of encouraging as much intensification in say Herne Bay or Mt Eden as you might imagine. Take a 750sqm site in Herne Bay (value probably around $6-$8M with existing average villa on it). A developer is not going to buy this and knock it over and build three townhouses, the maths just doesn’t work. However you may end up with the perverse outcome of a single house being demolished, (which couldn’t have happened before due to protection) and another more expense single house being built, or a neighbour buying an existing small protected house, knocking it over and creating a tennis court. This type of outcome will only happen in very high value suburbs but I guess I am saying, don’t believe this act will result in housing for the masses close to the city. It will be interested what level of protection will be granted to pre 1944 housing.
If the dwelling limit in the MDRS was removed and perimeter block developments enabled. Then for suburbs where the house prices are not too insane – say less than $2m. Then one house could be bought and replaced with a 3 story apartment with 12 units – each paying less than $200,000 for land costs – so somewhat affordable housing is possible.
You’re right developers will have more power over design outcomes. But they want to sell the dwellings they produce for as much as possible so they have a strong vested interest in producing dwellings that are desirable, which includes aesthetics.
Even the most expensive suburbs will get redeveloped if the market is willing to pay enough. Check out this 9 house development in Epsom they’re trying to sell for $3.5M per house: https://www.trademe.co.nz/a/property/new-homes/house-land/auckland/auckland-city/epsom/listing/3109514868
Surely the cheapest advertising you can do for your development is to pay for an architect to make a semi decent attempt at making it look good, especially because its a shared cost across all the units.
We see bad examples because the market is so stuffed people are buying whatever they can get. Aesthetics be dammed. When there is choice, why would I buy this thing that is awful when I could go down the street and buy something that looks and is designed significantly better for a couple extra grand. Of course there will still be fugly examples, but it wont be encouraged or desirable for anyone involved.
The urban design panel concept only works if designers aren’t pushing a strange set of barrows. First problem being the lack of understanding of transport. This seems to impact how designers discuss the pros and cons of different typology – some seem to miss a few simple concepts around cause and effect regarding density, parking, safety, vehicle crossings.
The townhouses where much of the ground floor is a garage is just bad design. The increase in vehicle crossings that has happened is just unsafe and bad street design. A denser form should have fewer crossings – not just per residence, but total. Clearly the priorities have been some things that, in comparison to the transport effects, are minor and irrelevant.
Also, their focus on things like material “articulation” has been misguided and has forced architects into having to use revolting design ideas.
So should design controls be tweaked and improved or done away with completely? Without design controls do you think developers will decrease car dependancy? If you think that is a potential outcome you are wrong, the market loves cars and garaging, developers will meet that need with glee.
I’m not sure, Matthew. I think planners should both plan the city’s systems, and create regulations, to reduce car dependency. I don’t believe in relying on the market for that. I think there’s an important role for designers in designing the public realm, buildings, building materials. I suspect that if the planners get the regulations about what the building envelopes can be and what the streetscape must be include, that design panels for individual consents won’t be necessary.
“ the market loves cars and garaging”
If that’s the case, then why have no-garaging low-car developments popped up everywhere the regulation for them has been removed?
there’s another myth being ignored – The myth that all the inner suburbs lower North Shore is zoned for single residences under the Unitary Plan.
It’s not the case. The part of the lower North Shore I live in is predominantly zoned Terraced Housing Apartment (up to 7 floors) or Mixed Housing Urban (up to 3). the Bill will do nothing to enable intensification in this area.
Don’t get me wrong. I support inner city intensification , having lived in perimeter block apartments, high rise and above shops in Europe, but we also need to be having a discussion about why so little development has occurred since the UP was enacted in neighbourhoods like mine. The majority of the developments that have been built are McMansions
The basic issue is that houses don’t get replaced every year. It will take many decades before most houses reach end of life and are replaced.
Even so there is this big blob of high density zoning in Northcote and there are a lot of apartment buildings going up there.
Re: “but we also need to be having a discussion about why so little development has occurred since the UP was enacted in neighbourhoods like mine. The majority of the developments that have been built are McMansions”
I think the problem is height to boundary rules which discourages apartment building and encourages sausage flat type townhouses.
Auckland is having a building boom of the following nature. Stand-alone houses remain the most popular type of new dwelling, with 25,588 consented in the 12 months to October, followed by 15,357 townhouses and home units, 4116 apartments and 2654 retirement village units.
So relatively few apartments.
Suggested improvements to the MDRS to enable perimeter block developments by addressing setback and height to boundary rules at the front of the plot – such as coalition for More Homes have suggested could increase the number of apartments built relative to McMansions and sausage flat townhouses.
Yes.
I think what has also been lost in this debate is that houses will still need a building consent. Regardless of what you think about the fit-for-purposeness of the current building code, it still imposes some condition of quality and durability on what’s being built. It won’t be some wild-west free-for-all like a lot of the detractors seem to want to believe.
The key question is whether the proposed Bill achieve what is intended. There is broad discursive agreement at least on GA that there is a need more affordable housing and denser housing options, whether that is due to concerns to do with either de-carbonisation or social justice. In general GA commentators are opposed increasing housing affordability via increasing supply on greenfield sites, as what Demographia would argue. The question is how to achieve this and will the proposed Bill do this? The principle argument of those locked-out of affordable inner-city housing is that Zoning or Nimbyism in heritage/character neighbourhoods have created a distortion in the market where demand exceeds supply. While many GA commentators want to see perimeter housing, how will the proposed Bill achieve that? As argued above by Matt the Democrat, the removal of zoning, may not see the results as intended, due to high land cost reducing economic return on development. Further to this, what are primary drivers that are causing unaffordability, as this is likely to multifaceted, will deregulation solve this? I would argue for targeted planning and investment into denser affordable housing by the council/government, in particular areas near key transport hubs would be a better way of achieving the required outcomes cf. Rodríguez-Pose & Storper (2019) https://european.economicblogs.org/voxeu/2019/storper-inequality
+1. You get it.
Funny how this website looks to Europe on so many things (especially on PT), but seemingly very little on housing, and their strong approach to community housing.
Everyone seems to be so upset about ugly buildings. We have these now, we have ugly cars, ugly clothing, ugly commercial buildings and no one is saying they all need to go through some fancy architecturally signed off process.
It’s all just a distraction to avoid being labeled a nimby
Ugly is having a generation of grandkids grow up in another country because Mum and Dad couldn’t afford to live in the same city as Nana and Granddad, even though they were all born there.
+1 Ugly is the people resisting changing the system that’s made that happen.
The watering down has started
https://www.stuff.co.nz/national/politics/300468653/bipartisan-housing-deal-townhouse-bill-restrictions-set-to-be-weakened
The Bill in itself will not automatically result in poor housing.
Obviously, without regulation, the market can and does build housing of good quality and amenity. Unfortunately, the market only does that *some* of the time.
As people have said, and notwithstanding its flaws, we have the Building Act to control the quality of ‘builds’, from a construction perspective. What the Building Act does not control, however, is the extent to which housing is well orientated to maximise amenity, mental and physiological wellbeing, and privacy.
The Bill’s standards require private outdoor space, but have no requirement around the orientation and design of that space.
The height in relation to boundary standards provide very little if any protection of sunlight to neighbouring properties. I would have thought people interested in wellbeing, energy efficiency, climate change and poverty might care about the importance of warm homes that minimise heating costs.
Tweaks to the standards could quite easily address some of these concerns, without destroying the density-enabling potential inherent in the Bill.
One of the major concerns I have with the Bill is that it perpetuates the right wing, neo-liberal myth that reducing and reducing regulation ad nauseum somehow will meaningfully address things like housing affordability. People are very deluded indeed if they think this Bill will make more than a very minor difference to affordability, Even the PWC report effectively confirms that.
Finally I’m not going to comment again on the ‘density everywhere’ flaw of the Bill.
+1 this Bill is not the solution.
It’s a desperate attempt to look like they are doing something from two political parties who have no credibility or mana on housing whatsoever…
What a Labour Party *should* be doing is building housing on steroids itself, both social and affordable housing, along the lines of what the Irish government have committed to, and what was done in this country in the past.
That’s the only way we will get both affordable housing and cohesive, and comprehensively designed communities (and perimeter block typologies for all the PB fan boys and girls here). If done in the right strategic locations it could also help support centres and PT. They could also commit to all of this mass housing development meeting high energy efficiency standards.
Perhaps they know they are so incredibly incompetent at getting anything executed that this would be just far too ambitious for this bunch of muppets (Red AND Blue).
100% agree. In Auckland when the motorway was built through Freeman’s Bay, the government also built council flats, state houses (star-blocks), and private townhouses. It also built a community centre and a school. It can be done, but won’t be achieved by the magic beans of the market. Also this bill won’t achieve its intended outcome of pbh as it’s too expensive for small developers to achieve. And unlike 60years ago Freeman’s Bay is full cashed up locals who will challenge this the courts. This will change intent of the law via case law. But yup it’ll appeal to the third-way left as it looks pro-housing & pro-market.
I don’t think we should be relying on sunlight to heat our homes. That would lead to overheating in summer and being colder in winter. Better to have adequate insulation, and it’s hard to get better insulation than a whole other apartment on top.
Yes, everyone likes sunlight in their homes. In my experience, perimeter block housing with large windows can be very well lit. I’ve seen NZ houses that are far dingier, often with smaller windows facing a neighbour.
Its emission free to use sunlight to heat a home. A small eve is all that’s needed to keep the high summer sun out while allowing the low winter sun in.
This article has some glaring inconsistencies. ie “Two families crammed into one house will place roughly the same demand on infrastructure as two families in two separate dwellings ” with a nice little drawing.
So that house gets knocked down and replaced with multi story units with no parking, maybe cram in eight or more units and demand on infrastructure will rise exponentially.
Net demand of the whole city remains the same in all scenarios though. Wellington sets immigration policy. So the city will roughly house the same number of people under high build or low build scenarios. It just depends on whether you put them in adequate units, or hide the problem under the rug and put multiple families in detached houses.
In your example of 8 units going on a lot, pressure on the immediate surrounding infra will be higher, but over the whole city that remains the same.
(Im obviously ignoring the elephant in the room that if we make the city totally unliveable then we will drive people out. But I don’t think anyone wants that to be a real viable option.)
Taking it further, Jack, net demand on the whole city doesn’t remain the same in all scenarios, as Don says below. Demand is lower with a more compact city. This is very well established and a core tenet of good planning.
roj, in terms of traffic, if the housing is put into sprawl, traffic is considerably higher than if it is put into the existing built area. It might seem like infill creates traffic, but in fact *people driving* create traffic – more so if they are living further out. It might seem like infill creates a demand for parking, but in fact *car ownership* creates a demand for parking – and car ownership is higher if people are living further out.
Good design acknowledges that:
– households in sprawl have more cars, and the residents drive many more km, than households in compact areas
– bringing more residents to an area improves proximity, increases walking, cycling and use of public transport, reduces how much people have to travel at all, and reduces driving and car ownership
– good streetscape design has an enormous leverage effect on all of this in compact areas (whereas in sprawl areas the leverage it offers is less. It’s harder to create modeshift in sprawl.)
– providing new homes in existing areas with less parking leads to lower car ownership, lower vehicle km, and lower parking demand over the whole city, because people drive and park all over the city.
We must stop our current development strategy in which we have *some* sprawl, because that small amount of sprawl adds considerably to traffic and parking demand.
Hi Heidi, are you able to point me to a paper or link regarding your comment on density & demand?
Hi Mark, an easy to read report with lots of good links is Transportation for America’s Driving Down Emissions report: https://smartgrowthamerica.org/resources/driving-down-emissions/
I think Litman discusses the various factors at play quite well in this paper: https://www.planetizen.com/blogs/106561-smart-growth-and-vehicle-travel-reductions
For Auckland specifically, it’s worth looking at the OECD report:
Decarbonising Urban Mobility with Land Use and Transport Policies
https://www.oecd-ilibrary.org/sites/095848a3-en/index.html?itemId=/content/publication/095848a3-en
No eight families dispersed over a wide area, will have a far greater demand on infrastructure then eight families concentrated in one spot.
Think, per km of pipe, wire, per sq metre of roading asphalt per person.
Not only the initial provision but also the ongoing maintenance.
Yes.
I’m a boomer (just) and I support these changes. That Labour and National joined together to get this done was due to a realisation that of (a) just how intractable this issue had become and (b) that it simply couldn’t rely on fractured local government to deliver. It required (small n) national leadership, and it is good to see politicians deliver.
I grew up in Mangere and Papatoetoe in Auckland where single houses are being carted away (or demolished) a rapid rate of knots and replaced by townhouses, and some apartment buildings. This has made Papatoetoe I left 30 years ago a denser suburb but it hasn’t become a slum. The houses I’ve seen when I’ve returned to visit my parents are modern and appear to be of good quality. Judging by some of the high quality cars parked outside them, I doubt the owners would have accepted a hovel. And while intensification there is good, it would be even better if something similar was occurring in Mt Eden, or Epsom or Remuera as well – which isn’t happening. The doughnut city is a reality.
I now live in an apartment on the fringe of central Wellington, but my first house was a First World War villa in New Plymouth, and was one of the last houses in what was becoming a commercial area. The land area was small (just 480 sq m) and the house was only 2.5m away from the neighbours’ but it wasn’t a problem. The lawns were tiny (especially after the rear was completely decked) but I enjoyed being just a 10 minute walk from work and the CBD and not having to drive.
Just before the bipartisan announcement, Wellington City Council announced proposed changes to its district plan that would have removed much of the restrictive requirements that have protected the inner city suburbs. There were the predictable howls of protest, which have only grown louder since the Labour-National deal. Those areas have fought tooth and nail to protect their exclusivity – you’ve got to wonder who they’re trying to keep out?
Comments seem to equate the loosening up of planning rules with the arrival of widespread perimeter block development. I also like the notion of perimeter blocks. However, I can’t see how this Bill gets us there? The provisions don’t require it to occur, so across all of Auckland’s fragmented land, I see most sites developing to suit their own needs at the time. Am I missing something?
Many commenters would wish for the new rules to enable perimeter block development, but as proposed they don’t.
Also many perimeter blocks were developed on fragmented land. You can easily tell where this happened because these blocks will have a mix of different building heights, styles, materials and stud heights.
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