Other matters relating to the resource management proposal

Summary of feedback

Overall, 170 submitters responded to this question. Most submitters were homeowners, architect/designers, builders and councils. 

The free-text format of this question, as well as its position towards the end of the survey, saw a wide range of responses, including reiterating matters raised in earlier questions. Submitters used this free-text option to give feedback ranging from process recommendations, resource management system concerns and recommendations, further insight from their professional experience, and further requirements needed in the policy detail - including for the standards and conditions.

Main themes

Some feedback was broad, such as a consistent message that the Resource Management Act is an inefficient and complex process that the submitters find difficult and time-consuming to navigate. There were remarks about overhauling/doing away with the Resource Management Act, and support for amending it. A few submitters also suggested taking councils out of the process and relying on an independent body.

There was consistent messaging, especially from councils that the rules and standards will need to be very clear. A few homeowners expressed concern that councils will find ways to overrule or get around the proposal unless it is very prescriptive.

Submitters asked to include tiny homes and provide flexibility for other temporary living solutions.

Many submissions gave much more specific feedback; there were many recommendations for technical amendments where it is seen that there could be gaps in the drafting. Councils especially gave feedback on issues with the policy and its interaction with the wider resource management system.

Sector views

Homeowners

Many submitters used this question as an opportunity to provide feedback on the Resource Management Act itself, such as:

• Processes under it are expensive (and further comments on costs), it is not enabling, and it is ineffective
• The proposed changes should be enabling, simple and councils should not have an opportunity to veto the ability to build a granny flat.

Several submitters reiterated support for the proposals and asked for a swift introduction of the granny flat changes. Support for homeowners being able to build granny flats was expressed for a variety of reasons, including: the added economic value, expressing private property right/freedom to build (including more control going to homeowner to build versus developers), and support for approaches that reduce the cost burden to homeowners, such as including tiny homes and allowing for flexibility – also for more than one granny flat on a title.

Some submitters encouraged specifically allowing for off-grid options (eg, composting toilets, alternative energy, rain harvesting) as a solution to reduce further pressure on existing infrastructure systems. 

A few submitters asked for consideration for potential impacts on neighbours in the process, including how the height in relation boundary rules can enable granny flats to be built while also mitigating potential impacts on neighbours. There was concern resource management related risks have not been properly identified, and heritage and character need to be protected. There was concern that the proposed process undermined the systematic planning approach in place.

Some submitters expressed concern that more due diligence/detail on risks is required and that granny flats could cost more in the long term than is currently identified; and that the process needs to avoid unintentional consequences. 

Several submitters suggested the policy should support tiny homes and innovative solutions - and asked for specific options that include temporary buildings like Tiny Homes on Wheels, buildings on leased and rented land.

A few submitters identified interactions with other pieces of legislation that should be addressed, such as the Property Law Act 2007. Submitters suggested that covenants should be able to be set aside without taking court action to allow the building of granny flats in the instance where a covenant prevents the development of an additional or a minor dwelling on a site. 

Iwi, Hapū and Māori

The responses to this question from Iwi, Hapū and Māori asked to keep the Resource Management Act intact, and to make the granny flats proposal happen, while enabling self-sufficient and eco-solutions and incorporating national direction for sites of significance. It was also reiterated that the number of granny flats per site should not be restricted. 

Councils

Many councils reiterated earlier or further explained concern with the proposals from the point of view of their role as implementers in the resource management system.

Much of the feedback from councils gave additional detail on the impact of the proposals, describing the burden to council, and importance of development contributions and a robust management, compliance and monitoring approach.

Some councils expressed concern at the level of analysis/review done in creating this proposal. Some councils were sceptical that the proposals would achieve the objective intended. 

Councils provided feedback on specific policy and compliance design, as well as implementation guides.  They suggested that the district plan should be used to regulate granny flats instead of national environmental standards and they expressed a need for proposals to be integrated across the resource management system.

There were also specific policy implementation matters raised, such as:

"Council requests clear wording around the maximum permitted number of MRUs per site in medium density residential zones (MDRS) where three residential units are permitted by default, and current wording could be interpreted that the proposal will permit three more MRUs. Council would oppose this considering the potential unmanageable impacts on services and infrastructure (Selwyn District Council)."

Industry 

Some submitters expressed frustration with the Resource Management Act processes and complexity, sharing their experiences where councils and council officers have not applied it consistently. Submitters suggested ongoing monitoring should be established to manage any long-term impacts.

< Permitted activity standards and alignment with district plans | Part 4: Notification and funding infrastructure >