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Integrating stormwater requirements: NPS-UDC puts the cat among the environmental pigeons

Integrating stormwater requirements - Featured Image - Local Government September 2017

Interactions between the government’s guidance documents on stormwater are complex. Yet councils are obliged to act on all current and future material in an integrated way. Ian McComb and Debra Bradley say the National Policy Statement on Urban Development Capacity (NPS-UDC) puts the cat among the environmental pigeons and consistency will be key to reconciling tensions around all the various National Policy Statements.

Out of the 3+ bedroom suburban box

The facilitation of rapid expansion in the housing stock, as called for by the National Policy Statement on Urban Development Capacity (NPS-UDC), requires more to change than the alignment of council policies. The wider industry, including councils, Housing NZ and other large players, needs to be involved in new solutions.
So far they are working on providing more traditional housing types. These are still needed but so is some out-of-the-box thinking. Here are some ideas.
100 on 200: Up to 100 square metre housing on 200 square metre sections. Simple, hey? Not so. Numerous planning rules, development standards and development contribution policies disincentivise or block such solutions. Yes, there are good reasons behind these rules, standards and policies. But it’s time to go back to the start and rebuild from the new NPS-UDC paradigm that we must facilitate more housing development.
Developers have told me their “affordable” sections (400 square metres) are often the most sought after, and not just for the sake of saving money. It also represents an opportunity to be in the same suburb as other family members. First home buyers and downsizers are two groups in particular who would often like to live near their family but there is often nothing suitable available.
So, for affordability, social cohesion and housing supply reasons, let’s make 25 percent of new greenfield housing sections 200 square metres, with up to 50 percent building coverage allowed, scattered throughout the development.
Build and move: We also need to avoid prematurely losing the opportunity to live on currently useful land based on future climate change-related hazards. As higher seas and more intense rainfall events occur, many areas that are currently inhabited and developable will become inundated or subject to erosion.
As Kapiti Coast and Christchurch councils have experienced, the current national legal, policy and guidance framework does not make it easy for councils to implement defensive planning based on these future increases in exposure to natural hazards.
Tasman District Council has succeeded in refusing development close to the Ruby Bay coastline. But was this an optimal outcome? Unfortunately, if councils allow development in inappropriate places, the future financial risk lies with them and the insurance industry.
Neither party wants this, so to protect their interests and still supply more housing we need to manage expectations and facilitate flexibility to move houses back from the coast in future, when retreat becomes the best option.
Bring back leasehold: I acknowledge that leasehold development has not been in favour recently. But it’s time to review its usefulness as a solution to some of the upcoming climate change hazards such as sea level rise.
By limiting the life of ownership and linking actual and specific sea level rise to the expiry date of a lease, owners can invest in temporary housing, knowing that it’s not their retirement nest-egg and that neither their council nor the government will be bailing them out when they need to relocate their house.
Piles, overhead power, pressure sewer and other technical solutions can minimise the impact of sea level rise before retreat is necessary.
By Ian McComb, project facilitator at Small Time Developments.

It’s easy to say yes to the outcomes the nation is seeking in the National Policy Statement for Freshwater Management (NPS-FM) and the New Zealand Coastal Policy Statement (NZCPS):

  • we want our rivers and streams to be healthy, and to support environmental, cultural and economic wellbeing;
  • we want the coastal environment to be healthy, and we don’t want contaminated stormwater discharges to impact on marine life.

However, it’s harder to feel excited about how the fish are doing if you have no place to live. That’s the focus of the National Policy Statement on Urban Development Capacity (NPS-UDC), which seeks to secure housing for many more people than is currently available, and to reduce the pressure on housing prices.
The NPS-UDC has put the cat among the environmental pigeons. It requires local authorities to ensure there is sufficient housing and business land development capacity to meet demand.
Even though the preamble states “This national policy statement does not anticipate development occurring with disregard to its effect”, it leaves it up to councils to figure out how to meet demand for growth in their area while also meeting other national objectives.
The NPS-FM and the NZCPS are relatively comfortable bedfellows. Both are primarily focused on improving environmental outcomes, adapting to climate change and recognising the importance of iwi involvement in environmental management.
NPS on Resilience
It’s even possible to imagine the upcoming NPS on Resilience (or natural hazards) rubbing along reasonably well, with a few tricky conversations along the way.
The Ministry for the Environment commissioned a report from Tonkin & Taylor on a ‘Risk based approach to natural hazards under the RMA’. This report recommends an overarching objective of risk reduction and resilience.
The recommended NPS text (policy 2.3 on page 55) includes reference to understanding how natural hazard policy and plan provisions best fit within the context of other planning objectives.
The Tonkin & Taylor report also provides recommendations on the application of the precautionary approach in relation to coastal hazards (as required by the NZCPS) and recommends a consistent approach to application of this principle.
NPS-UDC
It’s fair to say, though, that the NPS-UDC is a different beast. Under the NPS-UDC, councils’ resource management plans must actively enable development, and this must be supported by the provision of the infrastructure the new developments will need. Extra requirements apply for medium- and high-growth areas.
Flood risk and the NPS-UDC
Most of New Zealand’s cities are located near the coast. These include almost all the medium- and high-growth areas listed in the NPS-UDC. Medium growth cities near the coast are: New Plymouth, Nelson / Richmond, Kapiti and Wellington (not Palmerston North). High-growth cities near the coast are: Auckland, Tauranga and Christchurch (not Hamilton or Queenstown).
All these places are potentially affected by the interaction between flood and coastal hazards. This increases the importance of understanding these hazards both individually and cumulatively.
The effects of sea level rise will include stormwater surge (flooding due to seawater inflow into the stormwater network). This is already evident in Nelson, Dunedin, Christchurch and other coastal cities. Sea level rise also has significant potential to result in discharges of contaminated stormwater (due to inundation of wastewater and stormwater networks).
In urban areas, existing and new development is often located within a natural floodplain, creating flooding risks. Increased rates of stormwater run-off also result from the increased surface areas of roofs and paved surfaces associated with urban development.
As the growth of cities intensifies it will become more difficult to carry out upgrades to river and stream channels in a way that provides for environmental and recreational values.
Identifying and protecting corridors for future works is likely to be an important aspect of urban development strategies. However, isolation of large areas of land for future stormwater management could undermine efforts to increase housing.
Water quality and the NPS-UDC
Upgrading urban streams and rivers to protect existing and new development, and to ensure these waterways have the capacity to contain increased flows from development (particularly as climate change increases flood risks) has significant potential to adversely impact on the aquatic values of New Zealand’s urban streams.
Consistency is key
National guidance and national consistency makes sense for a small country. Coming up with lots of different approaches for reconciling the NPS-UDC with the environmentally-focused NPS-FM and NZCPS, as well as the upcoming NPS Resilience, may promote innovation. But it’s also likely to take a lot of time, and result in a lot of permanent buildings and consequent environmental effects in the meantime.
As it currently stands, each council will have to take on all of these national policy statements and figure out how to meet all of their objectives. This may well include trade-offs and political decisions on which NPS objectives are more important.
Here are some things to consider when tackling the integration of the national policy statements at a local level.

  • Alignment within a council will be essential. That means regional policy statements and regional / district plans, infrastructure strategies and asset management plans will need to be consistent.
  • All the planning documents listed above will need to promote innovative and reliable on-site stormwater solutions to limit the additional stormwater flows from new development and enable treatment prior to discharge to waterways.
  • Understanding the interaction between coastal and flood hazards will be essential for the cities which are located near the coast.
  • More investment in wastewater and stormwater networks will be needed to avoid cross contamination as rising sea levels and more intense rainfall events put more pressure on these systems.
  • We all need to get to grips with changing flood event recurrence when assessing what is a 1:50 year and 1:100 year event.

Overall, we need to work together as much as possible to find and share solutions to these NPS tensions, and to create as much consistency as possible across New Zealand.


  • Ian McComb was an infrastructure planner at Tasman District Council. He is now project facilitator at Small Time Developments. smalltimedev@gmail.com. He presented a paper on this topic at the Water New Zealand Stormwater 2017 Conference in Auckland earlier this year.
  • Debra Bradley runs Writing for Councils. debra.bradley@writingforcouncils.co.nz

This article was first published in the September 2017 issue of NZ Local Government Magazine.

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