It has been just over 1,000 days since the Auckland anniversary weekend floods and today marks the day that public submissions open on Plan Change 120: Housing Intensification and Resilience (PC120) – a plan change which seeks to intensify development and increase building heights in certain areas of Auckland near centres and rapid transit hubs, while also introducing stronger rules to protect people and property from flooding and other natural hazards.
PC120 proposes a large number of changes to the regional and district provisions of the Auckland Unitary Plan. If you want to know how this might affect you and whether you need to make a submission, our team of experts is available to quickly assess the effects on your property or business, assist with the submission process and prepare to participate in the hearings process that will kick off in early 2026.
Some context – response to the Auckland flooding disaster:
In early 2023 Auckland experienced catastrophic flooding events as a result of heavy rainfall. This flooding was particularly severe in parts of West Auckland and the North Shore. At the time, Plan Change 78: Intensification (PC78) was already underway in response to the National Policy Statement on Urban Development 2020 (NPS-UD) and was set to increase housing supply by incorporating Medium Density Residential Standards (MDRS) across Auckland, as directed by the previous government. However, the 2023 floods highlighted a pressing need for stronger controls on development in flood prone areas.
In response to changes to the Resource Management Act 1991 (RMA) and the Auckland floods, Auckland Council has been working behind the scenes to prepare PC120 for public notification and it has formally withdrawn PC78. At its core, PC120 seeks to strike a better balance between the need for urban intensification and the need for natural hazard protection.
What are the key dates?
The total process is expected to take 18 months from when the plan is notified. The key dates are:
- 3 November 2025: PC120 was publicly notified and the public have been invited to make submissions on the proposed changes
- 19 December 2025: The public submission period is expected to last seven weeks and the submission period will close at 5pm on 19 December 2025.
Hearings will commence in early 2026 before an Independent Hearings Panel. Those that make a submission will have the option to attend and speak at the hearings.
Some of the key differences between PC78 and PC120 are summarised below.
Key differences between PC78 and PC120:
Housing capacity:
Housing capacity refers to the maximum number of homes that can be built in a given area of land, based on its zoning and other development rules. When PC78 was notified, the maximum plan-enabled housing capacity was increased to two million dwelling units to accommodate Auckland's growing population.
Following direction from the Minister, PC120 maintains the same two million dwelling unit target as PC78, but takes a more targeted approach to where intensification occurs, focusing on areas near rapid transit stops and centres.
Removal of blanket three storey rules in residential areas:
PC78 adopted a blanket approach to the application of the MDRS and would have allowed up to three homes of three storeys in most residential areas across Auckland.
Following a change in government, new legislation gave Auckland Council the option to opt out of the MDRS, provided overall housing capacity remained the same. Two of the key ways this is achieved via PC120 is by:
- Expanding the Mixed Housing Urban Zone (up to three storeys) to cover more areas
- Increasing building heights in the Terrace Housing and Apartment Buildings (THAB) zones up to 10 and 15 storeys in certain areas (subject to qualifying matters).
Intensification around centres and rapid transport hubs:
PC78 required at least six-storey buildings within "walkable catchments" (areas within walking distance) of the city centre, metropolitan centres and rapid transit stops.
PC120 goes further, enabling:
- 15-storey buildings around five specific train stations (Maungawhau, Kingsland and Morningside)
- 10-storey buildings around other stations (Baldwin Avenue and Mt Albert).
Overall, PC120 identifies 44 walkable catchments with heights beyond six storeys (22 at 15 storeys, 22 at 10 storeys).
This aligns with the Council's "compact city" approach, targeting intensification near centres, bus routes and rapid transit stops to provide easy access to jobs, services and public transport, including the $5.5b City Rail Link investment.
Strengthening natural hazard controls:
PC120 includes several measures to build resilient communities and reduce exposure to natural hazards, such as:
- Downzoning high-risk areas: Areas at high flood risk (such as parts of Parnell, Point Chevalier and Glendowie) have been downzoned to Single House Zone with lower maximum building heights
- Stricter consent requirements: Applying more stringent activity statuses to development in areas at risk of natural hazards
- New risk management framework: A three-tiered approach based on risk level:
- significant/intolerable risk: avoid development outside urbanised areas, limit further development and reduce risk within existing urbanised areas
- medium/tolerable risk: limit further exposure and manage risk so that a tolerable level is not exceeded
- low/acceptable risk: enable further development while keeping risk at an acceptable level.
- Updated flood mapping: The Council has updated its flood maps and made it easier to access flood data through the online Flood Viewer tool (available here). These maps are expected to be updated regularly to reflect climate change, development and new land and property information
- Strengthened policies: Updated objectives and policies to reflect the latest information on rising sea levels, climate change and the cultural impacts of natural hazards on tikanga Māori.
What might this mean for you?
For developers, PC120 presents new opportunities for projects in areas near rapid transit stops and metropolitan and city centre zones. PC120 will enable many new residential buildings close to transport hubs to be built at far greater heights than previously enabled (10 to 15 storeys under PC120 compared to six-storeys under PC78). Furthermore, dairies, restaurants, cafes and small-scale office activities are proposed to be permitted activities in the THAB zones, meaning they will not require resource consent.
The targeted intensification under PC120 is intended is to provide Aucklanders with more diverse and affordable housing choices without significantly changing zoning patterns. As PC120 takes effect, the objective is that more Aucklanders will be able to live and buy property near rapid transit hubs, promoting public transport and more efficient travel throughout the city.
PC120 carries over the concept of qualifying matters, which allows the Council to modify the building height or density in a particular area to accommodate a particular feature or value (ie, natural heritage, Mana Whenua, natural resources, coastal environment and special character areas). The qualifying matters incorporated in PC78 are largely carried over to PC120. Three areas where the PC120 proposes to take a different approach to qualifying matters relate to coastal environments, natural hazards and Lake Pupuke. A qualifying matter is also proposed to manage the zone interface where 10 and 15 storey developments are adjacent to boundaries with lower intensity residential zones. This is set to be achieved through a set-back rule requiring high rise buildings that adjoin a lower intensity zone to be set back 18m from the boundary.
We know from experience with PC78 that the approach to qualifying matters is likely to be particular focus of debate at the hearings. In simple terms, if a qualifying matter applies to your property, your development potential may be more limited than the new, generally higher density rules that PC120 would otherwise permit.
Next steps
Landowners who may be directly affected by PC120 have been formally notified by the Council and the submission period is now open to the general public for seven weeks.
If you would like to know how the new rules affect your property you can view the draft plan, proposed zoning maps and make a submission here. Additionally, the Council has prepared some helpful information sheets on the changes, which are also available online.
Those who submit will have the opportunity to appear before an Independent Hearings Panel next year. Amendments may be made by Council before PC120 finally comes into force in around 18 months' time.
If you have any further questions, want to seek advice on making a submission or find out more about what PC120 means for you, please reach out to a member of our team.
This article was co-authored by Lisa Bazalo (senior associate) and Sophie Parker (law clerk).
