Question 7
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What was asked
Question 7: Are there any other benefits, costs or risks of this policy that we haven’t identified?
Summary of feedback
Overall, 490 submitters answered this question, views varied amongst different submitter groups. Feedback has been structured in order of benefits, costs and risks identified.
Benefits
Homeowners
Social benefits were the key benefits identified by homeowners. Emphasis was placed on enabling intergenerational living, both in terms of supporting elderly family members and grown-up children. Submitters also noted the financial savings enabled by intergenerational living.
Most homeowners approached the proposal from the perspective of housing family members; however, some also noted the potential to make use of granny flats as a rental property, and the associated economic benefits.
Iwi, hapū and Māori
Iwi, hapū and Māori submitters identified social benefits as the most significant. Submitters stated that the benefits lay in reducing homelessness by making access to housing easier, and in doing so, increasing mental wellbeing. The potential to increased independent living afforded by the proposal was also cited as promoting positive wellbeing.
Industry
Some industry stakeholders elaborated on the social benefits of the proposal, including the positive effects of intergenerational living on mental wellbeing. Submitters also cited the reduction in ‘red tape’ may decrease stress. Additional comments included the incentivisation of innovative thinking within the market.
Councils (including Building Consent Authorities)
Councils showed support for benefits such as greater diversity for living arrangements, increased housing stock, and a more efficient and cheaper process for achieving these goals.
Costs
Submitters across demographics stressed that consenting costs comprise only a very small proportion of total building costs, arguing that the primary drivers of costs were building materials, land, and labour.
Homeowners
Homeowners and individuals raised concerns about possible financial costs imposed by councils because of the construction of one of the proposed buildings. For example, increased rates and contribution fees. Community costs such as negative impacts on a neighbourhood’s aesthetic were also noted among submitters.
Industry
Industry submitters contended that the long-term costs of non-compliance were high, affecting public health and safety, insurability (both for homeowners and Licensed Building Practitioners), and liability. Submitters pointed to the reduction in council oversight and shifting of liability for non-compliance onto the industry and homeowners, with financial consequences for remedial work.
Councils (including Building Consent Authorities)
Councils identified costs in relation to possible rates increase, notification to council, and liability. Councils were concerned that the notification to council of an intent to build via a Project Information Memorandum (PIM) may put monitoring obligations on councils with potential financial ramifications that could negate the assessed cost-savings.
Feedback from councils maintained that the indirect costs to councils to respond to and investigate complaints of non-compliant building work, including issuing notices-to-fix, would be high, and require a larger compliance team.
Risks
Homeowners
Of the risks identified by homeowners, the impact on neighbours, liability issues, and infrastructure and water servicing concerns feature most prominently.
Iwi, hapū and Māori
Iwi, hapū and Māori submitters noted the potential risks associated with stormwater and flooding, as well as suggesting the influx of un-planned higher density housing may lead to increased pollution and crime.
Industry
A consistent theme across submitters from different groups within the industry is concern around the compliance, monitoring, and enforcement of the Building Code. Submitters argued that without the oversight of councils, the risks of ‘cowboys’ constructing granny flats that are not code-compliant would be much higher. Submitters noted that although the proposal lists specific conditions, the proposal did not provide for a means of checking that these conditions were in fact adhered to.
Industry submitters raised risks regarding stormwater, parking, noise pollution, and the risk to neighbouring properties if councils did not have accurate documentation of the final build. Submitters questioned what checks would be in place to ensure the correct building and engineering techniques were used for difficult sites, such as land that may be subject to a natural hazard.
Councils (including Building Consent Authorities)
Councils strongly disagreed with the assessment of the risks and long-term costs associated with the proposal as presented in the discussion document. Submitters stressed that the mitigating conditions proposed were not enough to prevent sub-standard, non-compliant building work from occurring. An additional risk raised was the possible reputational harm to industry due to increased levels of non-compliance.
Aside from the risk of non-compliant building work itself, councils raised concerns regarding the lack of a formal record of work and the implications for homeowners. Relatedly, these submitters stated the importance of infrastructure providers requiring visibility on where and when new developments are built. Linked to this was the risk of an increase in the number of dwellings located in a floodplain or overland flow path, or the alteration of the overland flow path owing to the construction of an unconsented dwelling under the proposed exemption.