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Government proposes introducing National Policy Statement to direct local councils to protect highly productive land in the face of urban sprawl; Horticulture NZ happy; Local Government NZ urges 'extreme caution'

Government proposes introducing National Policy Statement to direct local councils to protect highly productive land in the face of urban sprawl; Horticulture NZ happy; Local Government NZ urges 'extreme caution'
Image sourced from Pixabay

The Government wants to introduce a “National Policy Statement” (NPS) that requires councils to better protect the county’s most productive land in the face of urban sprawl.

The Ministry for the Environment (MfE) and Ministry for Primary Industries (MPI) have released a consultation document that proposes an NPS requires councils to put more weight on the value of highly productive land in their land-use planning and decision-making. 

Around 14% of the country’s land (excluding conservation land and existing urban areas) is considered “highly productive”.

The MfE and MPI make the case that the Resource Management Act isn’t clear enough on how this land should be managed.

Consequently, it too often gets broken up into plots that are too small to be used to grow produce, and gets used for housing when there are other less productive sections available or there's scope for densification. 

The ministries recognise New Zealand’s population has burgeoned and people need roofs over their heads, but makes the case that an NPS would redirect development towards areas that don’t compromise a finite resource, if possible, rather than constrain it.

Getting consent for a lifestyle block to be more difficult  

An NPS would require councils to “give effect to” relevant provisions through their regional policy statements and plans, and when they consider resource consent applications. 

In other words, councils would need to do a full analysis of alternatives, costs and benefits when considering whether urban expansion should be located on highly productive land.

MfE and MPI propose the NPS specifically requires councils to:

- Recognise the benefits of highly productive land;

- Maintain the availability of highly productive land; and

- Protect highly productive land from inappropriate subdivision, use and development.

Further to the third bullet point, the MfE and MPI explain: “New urban development may be appropriate on highly productive land when it is the only feasible option and alternative locations and options (eg intensification) have clearly been considered.

“Conversely, uncoordinated urban expansion and sporadic 'rural lifestyle development' on highly productive land would generally be considered inappropriate under the proposed NPS as it is an inefficient use of highly productive land.”

The land-use changes that have accompanied population growth

The MfE and MPI reference research that found that of the 175,000 rural lifestyle developments in New Zealand, 40% have been established since 1998. In Auckland, 35% of the most versatile land is occupied by rural lifestyle properties.

Meanwhile, between 2002 and 2016, the amount of land used for growing vegetables reduced by a third, as the size of New Zealand’s urban areas increased by 10%.

“While not all urban expansion occurs on highly productive land, evidence suggests a high portion does,” the MfE and MPI said.

“From 1990 to 2008, 29% of these new urban areas were on LUC Class 1 and 2 land [highly productive land]… with the greatest urban expansion occurring in Auckland (2,600 hectares) and Canterbury (4,800 hectares).”

An NPS a middle of the road solution among the other options on the table

An NPS would require councils to identify “highly productive land” based on soil quality, climate and the size and cohesiveness of the area.

A key feature of an NPS is that it provides direction from a national level, while giving councils the flexibility to respond to local circumstances.

MfE and MPI considered two other ways to direct councils to better protect productive land; introducing national environmental standards and amending the NPS on Urban Development Capacity.

While the former would have an immediate effect and provide more consistency and certainty, a high level of prescription would limit councils’ flexibility - particularly as they balance other priorities like enabling development.

As for amending the development NPS, this would be cheaper, but would only address the urban expansion part of the problem.

Here is the MfE and MPI’s cost-benefit analysis for introducing an NPS for Highly Productive Land:

The public has until October 10 to make submissions on the consultation document.

Local Government NZ warns of complexities and urges Government to proceed with "extreme caution"

LGNZ will be cautiously assessing the wider implications of the newly proposed National Position Statement on Highly Productive Land (NPS-HPL), noting that that it traverses a number of highly complex policy areas including housing affordability and property rights.

Released by the Government today, the NPS-HPL is intended to protect agricultural land from development, by requiring councils to consider the productive capacity of land in their planning and consenting decisions.

LGNZ supports the policy intent of this NPS, particularly as it relates to future food security, but notes it has the potential to conflict with the Government’s urban growth agenda, which is encouraging fast growing councils to expand house building to tackle New Zealand’s housing affordability crisis. Central Government is expected to release its proposed National Policy Statement on Urban Development next week.

“We need to carefully assess and balance the trade-offs between protecting highly productive land and enabling cities to grow, because at first glance these two policy frameworks appear to work against each other,” said LGNZ president Dave Cull.

“In places like Auckland and Hamilton, where New Zealand’s housing affordability crisis is most severe, the only place these cities can meaningfully expand greenfield development is in the areas that the NPS is looking to protect.”

“The Government is effectively pitting potatoes against houses, and at first blush we don’t think the discussion document has considered the implications of this sufficiently.”

LGNZ is also calling for clarity on the Government’s forestry policy, as tree planting also has the potential to lock up highly productive land for many decades.

A further concern is the implications that the NPS-HPL could have for property rights and regulatory takings.

“New Zealand is a democracy built upon property rights, which are one of the key pillars that underpin our open economy,” continued Cull.

“The detail that we’ll want to see is how central government compensates landowners for the loss of their property rights through an instrument such an NPS, or at least lays out a check and balance to ensure natural justice is served.”

“If there is no compensation for these regulatory takings, it could have severe implications for investment confidence around cities.”

“This is a highly complex area and any misstep could have long-lasting implications for ordinary New Zealanders for decades to come, which is why we’re urging the Government to proceed with extreme caution.”

Horticulture NZ says central government involvement is necessary

Horticulture New Zealand has welcomed the Government’s draft National Policy Statement on Highly Productive Land, saying it will help ensure that New Zealand can grow its own vegetables and fruit.

‘The policy statement recognises that New Zealand needs its best soils for domestic food production,’ says HortNZ Natural Resources and Environment Manager, Michelle Sands.

‘Once you build houses on our best soils, you cannot get them back. However, with good planning and buffer zones, houses and horticulture can co-exist, which is important for three main reasons.

‘One, so growers can make best use of available land. Two, so growers can quickly get fresh produce to market and three, so growers have access to workers, given how labour intensive horticulture is.’

Michelle says keeping our best soils for producing food is also important in the transition to a low emissions economy.

‘As the Paris Agreement states, countries need to find ways to adapt to climate change "in a manner that does not threaten food production".

‘New Zealand needs to ensure that it is able to grow all the fresh and healthy food that it needs, in a world where it will be difficult to import fresh food due to climate change.’

Michelle says at the moment, poor rules are preventing new vegetables gardens being established to replace land lost to housing in Auckland.

‘We know the country needs more houses. However, the current situation means that horticulture land lost to houses cannot be replaced.

‘This is why HortNZ is supporting growers in several regional government plan changes, such as Waikato Regional Plan Change 1.

‘This situation is also why we need central government to guide regional and district councils through policy statements like highly productive land, which recognise horticulture’s critical role in domestic food supply.’

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Too may Irish trades in NZ....?

Looks like the Auckland Unitary Plan will need to be reworked.
That will suit the local politicians, now they can blame the government even more for their inability to deliver land to build upon.

Is housing not productive? The market probably values it to be far more productive than potatoes.

We probably export 90% of the food we grow. This is a weird focus.


Housing is not productive. It is consumptive, and entropic.

There are those who use it parasitically, to increase their bidding for real resources - but it is not productive. Period.


This absolutely the right thing for a starter, stupidity is concreting over your food basket.

We agree PA

Stupidity is also selling it to an overseas buyer.

Welcome to the Limits to Growth, folks. Don't say we weren't warned.

Dave Cull had it all put in front of him, years ago. Yet his biggest regret is apparently not landing a 5-star hotel. So help us. My submission to the DCC Long Term Plan, 2015 (searchable still, just...) laid it all out. Since then, he's been guilty of wilful avoidance.

All those folk in those cities, need fed, watered, energised and they consume stuff. That stuff - including food - came from 'somewhere else'. Cities grew, they're now encroaching on those 'somewhere else's'. And it's worse than that, because a lot of that somewhere else, was underground acreage; a one-off event.

This isn't just about houses vs potatoes, any more than climate change is addressable as a stand-alone. We need to address the Limits to Growth, ascertain what 'sustainable' is, and get ourselves within it. And I'll give the Ministers a wee tip (I already gave it to Parker, years ago) - money isn't the mechanism for measuring what needs to be measured. Doing so is what got us into this mess.

I don't think this decision will help the government deliver 100'000 affordable homes


There is other land than good growing land, and there is up as well, there are a lot of large sections a stone's throw from central Auckland that could contain many more houses, but growing land must be protected.

True. Reduce over-regulation and free people up to do what they wish with their own land, including to develop it more intensively if that's their thing.

Or go a step further, and insist any residential land within x kms of the Auckland CBD when redeveloped must meet a minimum number of bedrooms per 100sqm of land area.

Oh, it could. You see, beyond this temporary fossil-fuelled arrangement, we will see many more people involved in food-production. And that will be local, by default. So they will be living closer to the tended acres. Which means the homes have to be in rural-village clusters, if not more diffuse. Then all you have to do is remove the ticket-clippers, including the banks, who insist on multiple dunnies and minimum footprints (all a result of attempting to force exponential growth, alle same obesity) and all those who 'make more' from more complex housing.

But this Govt and the previous Minister (I'll work the new one out before I comment) had no idea what their real problem was. Labour are still John A Lee-ing their way into new hospitals - yesterdays answers. So while they still live in the past, you are probably right. Not that anyone else will/can 'fix' the problem anymore.

Cannot happen to soon. LGNZ just gave us some great arguments as to why property rights are not necessarily the best thing in the long run.

Lifestyle Blocks are capable of food self-sufficiency, per household - or close to it. Compact cities are a disaster in waiting - despite some greenies thinking they are somehow the bee's knees.

And hence the split personality of the Green party between those that think salvation is to move everyone into the city and those they think we should all live off the grid on a lifestyle block.

Of course then there is also the huge present waste of underutilised land on lifestyle blocks and suburban front lawns and backyards. And I only mean underutilised in the sense of a better utilized food producing resource. I only have to think back to how my Grandfather (old school gardner), or Google Food growing preppers, or half of rural third world countries grow what they need onsite.

Lawns are the worst, even with a smallish section you can provide quite a bit for yourself, using permaculture preferably

But didn't we just have several commentators telling that pasture (basically lawn) was in fact a good carbon sink? So which is it? is pasture good or bad?

Lawn is not pasture it produces nothing and consumes energy keeping it in trim, and nothing feeds on it.

Too many people for lifestyle blocks, though I agree with you

so to slow down demand for land will they reduce immigration?
you cant have one without the other

Absolutely. And start a discussion about maximum population.

You can tack a few zeroes onto those upticks

Interestingly enough the Vernon Tava’s new SustainableNZ Party ( has no mention of reducing population growth/aiming for a sustainable population etc. Clearly he is too scared to wade politically into such turbulent waters or he really isn’t interested in true long term sustainability. NB. Not to be confused with which is a blog which seems to have been trying to start a discussion on such for years.

Oh yes, Mr Tava. Do you honestly think he will any effect other than to prop up the Nats, they have zero regard for the environment in truth, money trumps everything.

Evidence for this?


If this is the start of a more Malthusian approach to NZ's economic governance, i'm all for it.

House prices may crash, but once that soil is paved over, it's never coming back.

It will have been scraped off before being concreted over

A tiny contrarian comment. The Red Zone in Christchurch - suburbs with extensive (as opposed to intensive) housing, was depopulated after the earthquakes and is currently growing trees, grass, and no doubt some less legal crops. There is fairly much zero sign that it was once wall-to-wall housing. So, 'paved-over' land is perfectly capable of being returned to production.......soil is not a fixed quantity, it actually increases, given half a chance.

Excellent point Waymad, the house I lost in Sumner (and many neighbouring ones) are now green paddocks

What catastrophe are you banking on to return growing land around Pukekohe that, incidentally produces 25% of the country's veges and given that % what land are you proposing in the meantime replace it. Bear in mind it is considered unique so you might need to be fairly creative.

I haven't been to Christchurch in maybe 7 years. I just Googled 'Christchurch Red Zone', and looked at some of the 'before and after' pictures of the red zone. Wow, I had not realised the reality of what its actually looks like. Very interesting.

Yes, it's a tribute to the self-regenerative nature of - er - Nature. Very park-like in overall aspect.

Local councils could have sorted this long ago but as it's easier and more lucrative for them to have contiguous growth, be it into productive land, or draining wetlands, then in step Central Govt.

And assuming they are calling for submissions to get an idea of what they need to do, rather than having already made up their mind and the call for submissions is only for PR and legal tick off, I'll leave my effort for making a submission.

Auckland does not allow contiguous growth. Pukekohe is being concreted over is because it is non-contiguous with Auckland. Auckland Council works with the principle of least accessible development and spreading people apart, as this increases the costs and inflates council budgets. Empires are built and the city becomes sprawled.

The mayor and councilors happily do absolutely nothing to rein in costs.

Paving over good soil like volcanic is shortsighted and incredibly stupid. So fully support this NPS.

Sounds like business as usual to me... more vague rhetoric.

Agree with government. Anything and everything should not be turned into a house section.

Please remember that supply is not the only reason for the current housing situation.

In country where Government felt that housing crisis is a Good crisis reflects the mindset. Real shame.

Yes, land supply has nothing to do with why a $800K house at Hobsonville Pt is $600K land and $200K house.

That’s about 40,000 square kilometres of hort land
Mutter,mutter, maybe 50sq meters required per person for fruit and veg
10 million people, we need 500 sq kilometers for gardens legislated for Allotments by councils as per the English system
We can do it

I going to give you the benefit of the doubt and laugh

The allotments are very clever socially and not to be scorned.

On food for the cities can I say only 10% off our food production is domestic , In other words our farmers don’t give a damn about our society.
That is quite different to most countries that consume what they produce internally.
So a strong city food self sufficiency would be a good strategy.
Ask any doomer

I smell a rat. Infact I smell rotten cabbages, tonnes of them abandoned on the slopes of prime developable land in pukekohe because its been raining all winter. Open air cultivation is not productive use of high value land, it is inefficient and wasteful. Horticulture NZ is simply safeguarding the future capital gains of its membership with this ploy. Go down to Wairaka near Taupo and marvel at all the tomatoes they manage to grow in that most inhospitible central plateau climate...all year round, snow rain or hail. Its called growing in controlled conditions and its a hell of a lot more productive than your clay gardens everyone is so concerned about. Oh and then theres an interesting technology called hydroponics and another called vertical gardening...gosh suddenly growing in dirt is looking rather victorian....

Food-production is an energy equation - as are cities.

Yes, you can un tunnel-houses and insulate the growing beds. But vertical gardening lacks the area-per-occupant required, and hydroponics runs into the nutrient-replacement problem. As does all ag/hort, of course. Sooner rather than later, you have to close the loop - linear systems like phosphate extraction, simple run out.

Thats not necessarily tru pdk. With the greatest respect you and your fellow neo environmentslists can be just as blinkered to reality and the options within it as neo liberalists. Israel is a barnstorming success in applying agricultural concepts well outside the norm with which to feed their population. Vertical gardening is exploding internationally and I would have thought that due to its ability to redeploy old buildings and be energy self sufficient that you'd be right in behind the concept.

exploding? Beware stats - particularly exponential claims coming off a low base. I repeat - the sunlit area available per tenant, is not adequate to feed those inside high-format accommodation. Augment yes, feed no.

I'm a fan of garden-per-house, or allotments per village. In food terms, lifestyle blocks have it all over both density and tract-housing. The 1/4 acre section does OK, too.

Very interesting. I myself am quite taken by the urban garden movement and have had many heated discussions with my parents in my younger years about placing a rooftop garden on their large monopitch roofed house. There was hundreds of sq mtrs going begging. How about you extrapolate that across a urb setting, no need for market gardens then?

I guess that is fine if you don't want your food to taste of anything.

I'm sort of in agreeance.
Almost on the daily we see everyone here becrying the incompetence that is local government. Yet people seem to be fine with them arbitrarily dictating how land must be utilised.
The fertility of the Puke soils is not in question. But why not let the market decide whether those soils are best for urban development or local food production. New Zealand doesn't really want for two things; land and zero marginal cost energy production which doesn't at all mean this area has an absolute advantage in food production. Yet, for some unbeknownst reason, the urbanisation of Pukekohe is made out to be the most abhorrent idea known to man by PA.

Sorry, the reason is only unbeknownst to the unbeknowing. For a start, energy is not 'produced'.

Sans fossil energy, we would actually have trouble feeding ourselves, at current population numbers. The draw-down can also be traced to Nauru (now empty) and rain-forest clearance for palm kernel. The problem with 'the market' is that it flies blind, has no capability to see long-term, indeed it closely resembles economics in that regard.
The land problem has been clearly identified upthread - when something is paved over, it is gone. That isn't a market choice, it's a linear progression in one direction.

Although the centre of Detroit gives us a clue as to the future of urban cores........

All I hear is an old man yelling at a wall.
Fine, PDK. You know best. You always have. You're the oracle that we ignore at our peril.
The only known non finite resource is your wisdom.

And I see a zealot.

The problem is a Systems one. We spent all our effort growing our population, and sprawling a car-centric infrastructure web out from initially-mall hubs. Unfortunately, the housed hordes need fed. We did that using a one-off store of energy. But the regime won't continue.

Nothng to do with your magic market.

You of all people should be careful calling anyone a zealot.

The market does not always turn out the best results. What part of unique, frost free soils do you not understand. 25% of the country's vegetables are grown around Pukekohe, and it is able to be produced over a much greater length of time than in other places. Yes, Nymad, concreting over that land is extraordinarily dumb!

Yes. And Auckland Council has a stellar record of producing the best results when relied upon to do so.

I'm not commenting on whether or not it's a good idea, I'm just saying that leaving the decision of land allocation in the hands of Auckland Council can only result in perverse outcomes. This is especially the case when we have no cohesion between policy at Local and Central government levels.
You worry about natural endowment but ignore the fact that so long as the land supply is restricted around Auckland, the productive output of that contiguous land can only fall as the cost of labor (and land value) increases. I don't know what the marginal productive value vs market price of a hectare of horticultural land is, but I dare say it is going the same way as dairy land - low - for this very reason.

So, no, it's not straight forward what the optimal allocation of horticultural and residential land is and furthermore (essentially) arbitrary decisions about it's use don't maximise production.

The protected land could be rated accordingly. And we could always stop importing people

Population - Agree. But that goes back to my policy cohesion comment.
Controlling land prices by rating schemes is absurd. It's not addressing the issue and simply increases costs of production here. High costs = lower quantity - Queue my productivity comment.

Too much what iffery, the fact is that Pukekohe soils due to long growing season, can just about double the amount of produce that can be grown anywhere else. Thus even more stupidity in concreting it over.

Stop being so dismissive.
These are exactly the considerations that need to be made. It is not just a case of saying that because of the soil quality it should be preserved because, like I say, high yield potential means nothing if the costs of production are too high so as to achieve it.

Again, that is where rating and preventing subdivision comes in, if you can't use it for higher return then the value stays more in line with its usage. I see absolutely nothing wrong with doing that to preserve your ability to provide food. Honestly, I cannot work out how anyone can say any different. I will stick with that.

There are no oranges grown in Orange County and LA hasn't run out of oranges.

However, to make policy now without an eye on the future and consideration of food security would be incredibly short-sighted.

What is he on about?

“The detail that we’ll want to see is how central government compensates landowners for the loss of their property rights through an instrument such an NPS, or at least lays out a check and balance to ensure natural justice is served.”

“If there is no compensation for these regulatory takings, it could have severe implications for investment confidence around cities.”

The RMA provides for a number of activity classes from permitted to prohibited;

There are no provisions for regulatory takings in the event a particular activity is prohibited.

as it should be. Hard to justify insuring a bet.

They have just admitted that profits are private but losses public.

What about the loss of anyone's property right where councils impose a restriction by zoning on what the owner can do with his land.

Natural Justice would involve all of them losing their jobs for them trying the rort the NPS before the ink has dried.

Big Yellow Taxi

They paved paradise
And put up a parking lot
With a pink hotel, a boutique
And a swinging hot spot
Don't it always seem to go
That you don't know what you've got til its gone
They paved paradise
And put up a parking lot......

And for the red zone apparently
This used to be real estate, now it's only fields and trees
Where? Where is the town?
Now, it's nothing but flowers

Soil quality varies immensely. We have very limited amounts of highly productive soil. The Christchurch stories do not tell about how productive the land would be for growing food when the houses are removed. Most of that land was too low in quality to productively grow food on to begin with. The reality is it takes tens of thousands of years to get high grade topsoil like Pukekohe. A soil expert told me 100 years per 1 cm of topsoil. Building over high grade soil it is the equivalent to logging old growth forest to build houses on it. If the houses are removed for some reason it would take thousands of years to restore to what was destroyed.