Local Government New Zealand urges the Commission to broaden its inquiry into housing affordability from a focus on new home ownership, land supply and the cost of construction, to an assessment of the full cost of housing and the range of factors affecting housing affordability. Policy options for improving housing affordability are likely to be found through contributions from many drivers affecting affordability, such as labour market, transport, population, fiscal and monetary policies, income such as current salary and wage levels, income support, and retirement income policies, and local and regional economic and sustainable development plans and policies.

Housing affordability is not defined by the cost of land alone. The cost of housing has a number of components and the report does not look at the ‘whole cost of housing’. In addition to land cost and construction cost, there is also cost of infrastructure (and who pays), cost of maintaining a house, financing a house, travel, and the opportunity cost of loss of productive land as examples. In addition, the impacts of likely changes to building standards and the cost of insurance following the Christchurch earthquakes has not been considered.