Planning barriers to prefab

By - , Build 171

Are planning barriers hindering the uptake of complete prefabricated housing? A Levy-funded project reviewing district plans in 25 high-growth and medium-growth urban areas discovered inconsistencies in requirements.

COMPLETE PREFABRICATED HOUSING, which is fully finished off site and moved onto a site, has been identified as a key enabler to increase housing supply in response to what the Ministry of Housing and Urban Development estimates is a shortfall of 71,766 new houses in New Zealand. It is therefore timely to review the regulatory framework to identify whether planning barriers exist for the uptake of complete prefabricated housing.

Is prefabricated housing treated differently?

A research project by Planalytics tested whether complete prefabricated housing is treated differently to other housing in the residential zones of 25 district plans across the country. It then identified specific differences and actions to overcome them.

No planning barriers in 84% of district plans

It was found the majority of district plans (84%) did not have planning barriers for prefabricated housing (see Table 1). That is, they did not require resource consent for complete prefabricated housing over and above requirements applicable to non-prefabricated housing. How this was achieved differed.

In 40% of those district plans, there was no differentiation between complete prefabricated and non-prefabricated housing.

The other 44% differentiated, but had removed resource consent requirements for prefabricated housing over and above requirements for non-prefabricated housing. This included removing complete prefabricated housing from definitions for relocated buildings.

Planning barriers in 16% of district plans

The remaining 16% of district plans reviewed treated complete prefabricated and non-prefabricated housing differently (see Table 1).


Table 1 District plan treatment of complete prefabricated housing

Whangarei, Auckland, Tauranga, Western Bay of Plenty, Hamilton, Waipa, New Plymouth, Waimakariri, Christchurch, Selwyn, Queenstown Lakes  
Rotorua Lakes, Gisborne, Hastings, Kāpiti Coast, Porirua, Upper Hutt, Hutt City, Wellington, Marlborough, Dunedin  
Napier, Palmerston North, Nelson, Tasman  

Additional resource consent needed

The relocated building rules in these district plans triggered the need for resource consent for complete prefabricated housing in general residential zones, over and above consent requirements for non-prefabricated housing.

Historically, relocated building rules were introduced to control adverse amenity effects on residential neighbourhoods when an older house was moved onto a site and not reinstated in a timely manner. The way that the definitions and rules for relocated buildings are drafted in 16% of the district plans reviewed, however, means that these rules also apply to new complete prefabricated housing, whether this is the intention or not.

Despite resource consent for complete prefabricated housing being required as a controlled activity (so it must be granted), this was seen as creating a planning barrier to complete prefabricated housing uptake due to the additional time and cost incurred obtaining resource consent.

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Case study

Palmerston North City Council, for example, requires resource consent for complete prefabricated houses under relocated housing rules, charging a deposit of $750 for minor non-notified land use consents and a $1,000 refundable bond.

Resource consent is usually approved within 20 working days. Although not a significant expense, the process of obtaining consent may deter some potential owners who would not have to face these cost and time constraints with a non-prefabricated house or if they were building in other parts of the country.

Standardised approach recommended

The findings indicate a range of actions to standardise the approach to prefabricated housing within district plans nationwide:

  • For councils that intentionally require resource consent for complete prefabricated housing, streamline the resource consent process to minimise time and cost requirements for applicants and councils. For example, remove the need for bonds for complete prefabricated housing.
  • For councils that unintentionally require resource consent for complete prefabricated housing, revise district plans to remove relocated building rules as they apply to prefabricated housing in general residential zones. This may not be appropriate in all areas – for example, in character or heritage zones, where specific building typologies are required.
  • For all councils, await the Ministry for the Environment’s National Planning Standards, which seek to improve consistency in the structure, format and content of district plans nationally. If a standard definition for relocated buildings or prefabricated housing is included in the planning standards, all district plans will have to adopt such a definition and a consistent nationwide approach to complete prefabricated housing will be achieved. If not, the status quo will remain, and councils will be able to exercise their own judgement whether or not to require additional resource consent for complete prefabricated housing.

Address local barriers to increase supply

The research established that planning barriers for complete prefabricated housing exist in only 16% of the 25 district plans reviewed. Barriers could be more widespread, however, as the sample size represents just over one-third of all district plans nationwide. It is not known how prefabricated housing is addressed in the remaining 40 district plans across the country.

It is therefore essential that the building sector, particularly prefabricated housing stakeholders, are aware of potential barriers in their local planning system and address these on a case-by-case basis with the council.

This way, the planning system can be optimised to remove unintended barriers, potentially increasing prefabricated housing supply across the country.

Four key findings

  • In most cases, complete prefabricated housing is treated the same as non-prefabricated housing in district plans.
  • In some cases, complete prefabricated housing attracts greater resource consent requirements than non-prefabricated housing.
  • Greater consistency across the country regarding resource consent requirements for complete prefabricated housing is achievable.
  • Communication between the building sector and councils is essential to resolve inconsistencies in how complete prefabricated housing is treated in the planning system.

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