NZAIA's submission on the Natural and Built Environments Bill - 2023
NZAIA supports the broad changes represented by the NBA Bill, in particular the emphasis on strategic level plans, and more directive outcomes and targets. NZAIA particularly commends the emphasis on effects assessment in the Bill, but we have concerns about some of the provisions:
- We are concerned that the Decision-making Principles (s6)(1)(b-d) place so much emphasis on achieving outcomes, that managing effects could become secondary to achieving those outcomes, to the detriment of the environment.
- We recommend the inclusion of a coherent framework for effects assessment, based on international SEA models, set out in the NPF, that would link with the Effects Management Framework, and effects assessment and management requirements in the Spatial Planning Strategies. More specifically we recommend revising Schedule 7, cl 25, to give plan evaluation reports a more explicit strategic assessment role.
- We strongly recommend either the inclusion in Schedule 10 of an indicative (not prescriptive) model of how environmental assessments would normally be carried out, based on internationally recognised good practice principles; or a revision of clauses 6 and 7 of Schedule 10 regarding the content of AEEs to reflect more clearly underlying good practice principles.
- NZAIA supports the recognition of Adaptive management (AM) (s86) as an important management tool, but we are wary about its potential abuse. We recommend that s233(3) be revised.
- We believe that disregarding “any effect on scenic views from private properties” rules out legitimate visual impact concerns of communities that are not simply NIMBYism.