Public submissions have overwhelmingly opposed the council’s proposed plan change to introduce an inclusionary zoning policy throughout the district.

While several of the 181 submissions supported elements of the proposed policy, only a handful of submissions supported it in its entirety.

There was considerable support for Queenstown Lakes District Council’s (QLDC) strategic direction, i.e. its intention to find a solution to the district’s affordable housing problems, but most said what was proposed missed the mark.

The submissions received by the QLDC came from housing trusts, local businesses, aged concern and retirement organisations, land developers, iwi and individual property owners, among others.

The proposal

The QLDC’s inclusionary zoning (housing) proposal intends to make almost all land developers pay a contribution (either land or cash) to the Queenstown Lakes Community Housing Trust (QLCHT) to support its affordable housing programmes.

Since 2003, major land developers have negotiated deals, via the QLDC, to contribute land to the QLCHT, including Northlake, Longview, Hikuwai, Riverside Park and The Heights.

With this land QLCHT has built and delivered a total of eight housing developments (119 homes) which, together with other houses purchased, has helped 244 local households into homes throughout the district. Further housing developments (totalling over 100 homes) are underway at Northlake, Lake Hāwea and Arrowtown.

The QLDC wants to expand this contribution to all residential land developers (with a few exemptions) and make it mandatory.

The inclusionary zoning policy proposed would make it mandatory for residential landowners building accommodation to contribute land or cash to address the district’s housing needs.

Queenstown Lakes Community Housing Trust’s position

While QLCHT supports the QLDC’s ambition to embed inclusionary housing in policy, it does not support every element of the proposal. 

QLCHT chief executive officer Julie Scott said the trust supported the council’s intention to make the contributions mandatory but only when the value of the land was increased by the action of development.

Increases in land value mostly occur when land is rezoned; from rural to residential or rural to commercial, for instance.

“We believe that when value uplift occurs through development then a set percentage of the development should be required to be provided as affordable housing,” she said.

However, the QLCHT did not support the council’s intention for the mandatory contribution to include all residential land developers, suggesting it would stifle infill development in developed urban areas. 

Instead, it wanted owners of existing serviced lots within the urban boundary, or landowners subdividing a single lot into up to three new lots within an urban boundary, to be exempt from paying a contribution. And it believed the council’s ‘top-up” proposal should be deleted.

Read more: Mixed support for inclusionary zoning

The QLCHT’s position was repeated and supported in a number of submissions, including those from the Ōtautahi Community Housing Trust in Christchurch, the Affordable Housing for Generations organisation and Te Wai Pounamu Housing Network.

Other objections

A variety of other reasons opposing the plan change were also quoted: it was misdirected and would discourage subdivisions and residential development thereby increasing the price of housing; it was unlawful and inequitable; it was inconsistent with the purpose and principles of the Resource Management Act (RMA); it was based on flawed economic analysis; and it hadn’t properly considered other options to resolve the affordability issue.

Two retirement village companies, including Metlifecare which is planning to build a village in Three Parks, said the mandatory contribution would add millions to the cost of constructing much needed accommodation for retirees.

Metlifecare said the supply of retirement village housing aids affordable housing initiatives as it releases existing housing stock back into the market but the council’s proposal will discourage retirement village companies from investing in this district.

Some submitters, including Willowridge Development, LandEscape and Upper Clutha Transport, each with intentions to build worker accommodation to offset the high demand for affordable staff accommodation, said the proposal was unreasonable as it would compromise the viability of such construction, discouraging employers from providing worker accommodation, and would exacerbate rather than help to alleviate the problem.

Several individuals said it would also disproportionately affect first home builders who were also struggling to build an affordable home.

It was an inappropriate redistribution of wealth, one submitter said, as it unfairly advantaged only those on the QLCHT’s waiting list (which currently sits at 800). 

Silverlight Studio’s submission suggested QLCHT’s success to date was largely due to negotiated private development contributions and leveraging those to gain central government funding or grants, and the QLDC’s case made to introduce the mandatory contribution was counter-intuitive and unproven. 

Blaming residential developers alone for a lack of affordable housing was ignoring the fact this was a multi-sector issue involving numerous variables, such as low wages, rental stock being used for short-term visitor accommodation, increased building costs and limited public transport.

Silverlight also said the pursuit of the policy now was an inefficient use of ratepayer money as: the RMA was about to be repealed; and there was a strong possibility this proposed inclusionary housing will be found to be legally invalid under the RMA and costs could be awarded against the QLDC, “resulting in further unnecessary expense to ratepayers”. 

Exemptions sought

A number of submitters said the proposed policy could be improved with further exemptions, including exempting retirement accommodation providers, worker accommodation and land held  by iwi.

Ngai Tahu’s submission supported the council’s principal of inclusionary zoning but wanted the the list of those exempt from paying the tax to include Maori Customary and freehold land, Crown land reserved for Māori, and land transferred to successors under Ngai Tahu Claims Settlement Act 1998 Part 15, such as Sticky Forest.

All formal submissions and a summary of feedback can be viewed on council’s website here.

A number of the submitters advised they would like to speak further to their submissions at the public hearings before independent commissioners and councillors scheduled later this year.

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