RELOCATABLES I submit that the requirement to build relocatable houses is ill conceived. 1. It relies on a premise that the existing landowner has funds to purchase another piece of land on which he can relocate the building. Who has the funds to do that? It has the flow on economic effect of requiring even more investment in real estate when the Government and economists generally keep on insisting that NZ's relatively poor economic performance is due to an over allocation of resources in real estate. 2. Where are the building sites in Kapiti on which these relocatables can be built? 3. There is no provision in the PDP for the hundreds of relocatables to be put. 4 . New subdivisions usually have restrictive covenants preventing older dwellings being built on them, so they will not provide sites for relocatables. 5. No environmental justification can be made out for the environmental costs of relocation. There are the energy costs in moving. There are the trees that need cutting down to make way for the house. There is the cost of removing all existing services to the site from which the house has been removed. There is road damage. 6. There is the extra building costs -up to 15% more to build a relocable. Again this mean that housing becomes less affordable. Is this the objective of KCDC- to make Kapiti an area that few can afford to live in. 7. There is no provision in the PDP for what happens to the vacated land. Will the owner still be paying rates on it? Will KCDC purchase the land off the owner 8. The requirement for relocables is inconsistent with the Building Act requirements for building longevity. Only a buildings structural elements need to last 50 years to be code compliant. Cladding, windows and other elements have only to last 15 years. Ass the unlikely occurrence of a property being washed away is in a 50 or 100 year time frame the relocatable requirement becomes an absurdity. 9. The houses will be unlikely to be relocated in any event. The owners will have to meet the latest Building Code requirements if the building can be relocated. The KCDC will require the owner gets a new building permit, and a Code Compliance Certificate. This I likely to make the whole exercise uneconomic form the point of view of the owner. 10. S 32 (3A) and (40 have not been complied with in imposing the relocatable rule. That section provides (3A) This subsection applies to a rule that imposes a greater prohibition or restriction on an activity to which a national environmental standard applies than any prohibition or restriction in the standard. The evaluation of such a rule must examine whether the prohibition or restriction it imposes is justified in the circumstances of the region or district.
(4) For the purposes of this examination, the evaluation must take into account – (a) the benefits and costs of policies, rules, or other methods; and (b) the risk of acting or not acting if there is uncertain or insufficient information about the subject matter of the policies, rules, or other methods.�