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  • Impact Connector
    • Issue #14 Impact assessment for infrastructure development >
      • Impact assessment for infrastructure development - an introduction
      • Place Matters: The importance of geographic assessment of areas of influence in understanding the social effects of large-scale transport investment in Wellington
      • Unplanned Consequences? New Zealand's experiment with urban (un)planning and infrastructure implications
      • Reflections on infrastructure, Town and Country planning and intimations of SIA in the late 1970s and early 1980s
      • SIA guidance for infrastructure and economic development projects
      • Scoping in impact assessments for infrastructure projects: Reflections on South African experiences
      • Impact Assessment for Pacific Island Infrastructure
    • Issue #13 Health impact assessment: practice issues >
      • Introduction to health impact assessment: practice issues
      • International Health Impact Assessment – a personal view
      • Use of Health Impact Assessment to develop climate change adaptation plans for health
      • An integrated approach to assessing health impacts
      • Assessing the health and social impacts of transport policies and projects
      • Whither HIA in New Zealand….or just wither?
    • Issue #12 Risk Assessment: Case Studies and Approaches >
      • Introduction
      • Risk Assessment and Impact Assessment : A perspective from Victoria, Australia
      • The New and Adaptive Paradigm Needed to Manage Rising Coastal Risks
      • Reflections on Using Risk Assessments in Understanding Climate Change Adaptation Needs in Te Taitokerau Northland
      • Values-Based Impact Assessment and Emergency Management
      • Certainty about Communicating Uncertainty: Assessment of Flood Loss and Damage
      • Improving Understanding of Rockfall Geohazard Risk in New Zealand
      • Normalised New Zealand Natural Disaster Insurance Losses: 1968-2019
      • Houston, We Have a Problem - Seamless Integration of Weather and Climate Forecast for Community Resilience
      • Innovating with Online Data to Understand Risk and Impact in a Data Poor Environment
    • Impact Connector #11 Climate Change Mitigation, Adaptation, and Impact Assessment: views from the Pacific >
      • Introduction
      • Climate change adaptation and mitigation, impact assessment, and decision-making: a Pacific perspective
      • Climate adaptation and impact assessment in the Pacific: overview of SPREP-sponsored presentations
      • Land and Sea: Integrated Assessment of the Temaiku Land and Urban Development Project in Kiribati
      • Strategic Environmental Assessment: Rising to the SDG Challenge
      • Coastal Engineering for Climate Change Resilience in Eastern Tongatapu, Tonga
      • Climate-induced Migration in the Pacific: The Role of New Zealand
    • Impact Connector #10 Climate Change Mitigation and Adaptation >
      • Introduction
      • Is a “just transition” possible for Māori?
      • Adapting to Climate Change on Scale: Addressing the Challenge and Understanding the Impacts of Asia Mega-Cities
      • How responding to climate change might affect health, for better or for worse
      • Kanuka, Kereru and carbon capture - Assessing the effects of a programme taking a fresh look at the hill and high country land resource
      • Wairoa: Community perceptions of increased afforestation
      • Te Kākahu Kahukura Ecological Restoration project: A story within a story
    • Issue #9 Impacts of Covid-19 >
      • Introduction to Impact Connector Issue 9 – Impact assessment and Covid 19
      • Covid-19 fast-track consenting: climate change legacy key to success
      • Tourism – the long haul ahead
      • Making sense of the impact of Covid-19: planning, politics, and the public good
    • Issue #8 Social Impact Assessment >
      • Challenges for Social Impact Assessment in New Zealand: looking backwards and looking forwards
      • Insights from the eighties: early Social Impact Assessment reports on rural community dynamics
      • Impact Assessment and the Capitals Framework: A Systems-based Approach to Understanding and Evaluating Wellbeing
      • Building resilience in Rural Communities – a focus on mobile population groups
      • Assessing the Impacts of a New Cycle Trail: A Fieldnote
      • The challenges of a new biodiversity strategy for social impact assessment (SIA)
      • “Say goodbye to traffic”? The role of SIA in establishing whether ‘air taxis’ are the logical next step in the evolution of transportation
    • Issue #7 Ecological Impact Assessment >
      • The future of Ecological Impact Assessment in New Zealand
      • Ecological impact assessment and roading projects
      • EcIA and the Resource Management Act
      • Professional Practice and implementation of EcIA
      • EcIA in the Marine Environment
    • Issue #6 Landscape Assessment >
      • Introduction
      • Lives and landscapes: who cares, what about, and does it matter?
      • Regional Landscape Inconsistency
      • Landscape management in the new world order
      • Landscape assessment and the Environment Court
      • Natural character assessments and provisions in a coastal environment
      • The Assessment and Management of Amenity
      • The rise of the THIMBY
      • Landscape - Is there a common understanding of the Common?
    • Issue #5 Cultural Impact Assessment >
      • Introduction
      • Potential of Cultural Impact Assessment
      • The Mitigation Dilemma
      • CIA and decision-making
      • Insights and observations on CIA
      • Achieving sustainability through CIA
      • CIA - Enhancing or diminishing mauri?
      • Strategic Indigenous Impact Assessment?
    • Issue #4 Marine Environment >
      • Introduction
      • Iwi, Impact Assessment and Marine Environment
      • Sea-Bed Mining Application in Taranaki
      • The wreck of the MV Rena
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The NZAIA submission on 'Better Urban Planning' 
Gillian Stewart

NZAIA was responsible for one of the 70 submissions to the New Zealand Productivity Commission on its draft report on urban planning processes. Faced by a report comprising 413 pages, ranging across diverse and complex issues, developing a useful submission is a daunting prospect . However, as an organisation we have a clear role with respect to impact assessment, so the main purpose of our submission was to support the continuing role of impact assessment in future urban planning provisions, and where possible bring about significant improvement in practices of impact assessment in urban planning. This would ensure that decisions about, and implementation of, plans for housing and business growth and associated infrastructure will result in more sustainable social, cultural, economic and environmental outcomes.

Our submission focused on a number of broad issues raised in the draft report. First, we noted that the RMA has at its core the “effects-based” approach that mandates the use of impact assessment at all levels of decisions-making under the Act, so we strongly support the retention of this perspective in whatever future form(s) of planning/resource management legislation emerge to deal with urban planning in particular.  

Second, we feel there is a particular gap in the use of impact assessment at the policy and plan levels. Recommendation 12.1 in the draft report states:
A future planning system should place greater emphasis on rigorous analysis of policy options and planning proposals. This will require councils to build their technical capability in areas such as environmental science and economics. It would also require strengthening soft skills – particularly those needed to engage effectively with iwi/Māori.

We supported this and suggested that greater consideration needs to be given to the use of strategic environmental assessment (SEA) as a more robust and internationally recognised approach to carrying out such assessments.SEA methods can be integrated with policy and plan development, in contrast to the s32 analysis conducted after the proposal has been formulated.
 
Related to this, the draft report asks how cumulative effects might be addressed:
Q8.2: Would a greater emphasis on adaptive management assist in managing cumulative environmental effects in urban areas? What are the obstacles to using adaptive management? How could adaptive management work in practice?
 
In our view, cumulative effects are best as part of strategic environmental assessment during policy and/or plan development.  The potential for cumulative impacts can be explored while options are still open, and policies and plans developed that incorporate strategies to avoid or mitigate their occurrence. Adaptive management is one strategy but one that we feel should only be used in the context of a wider understanding of the source of the cumulative effects that comes from an SEA approach.

 The draft report contained the following statement in its finding F7.7 (bullet 3) with respect to urban development and the use of consent processes:
….an overemphasis in the implementation of the RMA on managing or avoiding adverse effects, which does not sit well with the dynamic nature of urban environments.

We did not agree with this finding and our third point was that we feel the emphasis on adverse effects is appropriate, but that the problem is more to do with the poor practice that comes from lack of understanding of the AEE process, especially among developers, but also among other participants in consent processes. This can be addressed by better council guidance on the process, and greater emphasis on early discussions with potentially affected parties.  The recommendations of the then Parliamentary Commissioner for the Environment, in 1995, on how to improve AEE administration by councils are still very relevant as they set out sensible steps to engage interested parties sooner, and to identify and address key issues before they become contentious during the formal consent process.

Fourth, NZAIA did agree with Recommendation 7.6 (bullet 4):
…encourage the use of tools that ensure the full spectrum of interests is understood in council decision-making processes, and that allow the public to understand the trade-offs involved in decisions.

We see impact assessment methods being central to this toolkit, from physical and ecological impact assessment to social, cultural and health impact assessment: all these can be used at policy, plan and project levels, and they feed into an integrated understanding of the implications and especially trade-offs that proposals might imply for local communities.

Our fifth point was to note that the Colmar Brunton opinion survey of councils, one of the background reports commissioned by the NZPC, identified economic impact assessment as the main “capability gap” of council staff respondents. We also noted that in the original report of that survey, councils were not asked to nominate particular skill areas but were provided with a pre-determined list, which included “economic impact assessment” but no other forms of impact assessment, and nothing relating to s32 analyses per se. It was not clear to us just what councils are calling for, since “economic impact assessment” is not a mainstream phrase in the impact assessment community that we represent: one  that deals with ex ante analyses (i.e. looking ahead to identify the potential “unintended consequences” that otherwise bedevil policy and plan makers). We assume it meant that the council staff would like more skills in economic evaluation within their s32 analyses (which might suggest s32 evaluations were being viewed quite narrowly, which would be a concern). If the aim was to identify key capability gaps, we felt a proper needs assessment should have been carried out.  

Finally, we were pleased to that cultural impact assessment is given some prominence in the discussion paper.  NZAIA fully supports the use of this method, but also recognises the problems iwi often have in providing resources to support its use. It might be useful to have a national initiative to explore the development and resourcing of cultural impact assessment, and to encourage the growth of a practitioner community that would work with iwi and hapu to produce these assessments. NZAIA would be happy to support such a move.
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  • Home
    • Environmental Impact Assessment
    • Social Impact Assessment
    • Strategic Environmental Assessment
    • Community & Stakeholder Engagement
    • Management, Monitoring and Reporting
  • About Us
    • Core Group >
      • Core Group Meeting Minutes
    • Our Partners and Affiliates
    • AGMs
    • Ethics
  • Membership
    • Sign Up for NZAIA Membership
  • Conferences
    • Proceedings from Past Conferences >
      • 2022 - Wellbeing, Sustainability and Impact Assessment: towards more integrated policy-making
      • 2021 - Social Impact Assessment >
        • Posters
        • 2021 Students
      • 2019 - Climate Change >
        • Posters
        • 2019 Students
        • Conference Photos
        • Contact List
      • 2018 - Regional Development
      • 2016 - Strategic Environmental Assessment
      • 2015 - Where to for Impact Assessment?
      • 2014 - Transport Infrastructure
      • 2013 Fresh Water Management
      • 2012 - Mineral Extraction
  • Impact Connector
    • Issue #14 Impact assessment for infrastructure development >
      • Impact assessment for infrastructure development - an introduction
      • Place Matters: The importance of geographic assessment of areas of influence in understanding the social effects of large-scale transport investment in Wellington
      • Unplanned Consequences? New Zealand's experiment with urban (un)planning and infrastructure implications
      • Reflections on infrastructure, Town and Country planning and intimations of SIA in the late 1970s and early 1980s
      • SIA guidance for infrastructure and economic development projects
      • Scoping in impact assessments for infrastructure projects: Reflections on South African experiences
      • Impact Assessment for Pacific Island Infrastructure
    • Issue #13 Health impact assessment: practice issues >
      • Introduction to health impact assessment: practice issues
      • International Health Impact Assessment – a personal view
      • Use of Health Impact Assessment to develop climate change adaptation plans for health
      • An integrated approach to assessing health impacts
      • Assessing the health and social impacts of transport policies and projects
      • Whither HIA in New Zealand….or just wither?
    • Issue #12 Risk Assessment: Case Studies and Approaches >
      • Introduction
      • Risk Assessment and Impact Assessment : A perspective from Victoria, Australia
      • The New and Adaptive Paradigm Needed to Manage Rising Coastal Risks
      • Reflections on Using Risk Assessments in Understanding Climate Change Adaptation Needs in Te Taitokerau Northland
      • Values-Based Impact Assessment and Emergency Management
      • Certainty about Communicating Uncertainty: Assessment of Flood Loss and Damage
      • Improving Understanding of Rockfall Geohazard Risk in New Zealand
      • Normalised New Zealand Natural Disaster Insurance Losses: 1968-2019
      • Houston, We Have a Problem - Seamless Integration of Weather and Climate Forecast for Community Resilience
      • Innovating with Online Data to Understand Risk and Impact in a Data Poor Environment
    • Impact Connector #11 Climate Change Mitigation, Adaptation, and Impact Assessment: views from the Pacific >
      • Introduction
      • Climate change adaptation and mitigation, impact assessment, and decision-making: a Pacific perspective
      • Climate adaptation and impact assessment in the Pacific: overview of SPREP-sponsored presentations
      • Land and Sea: Integrated Assessment of the Temaiku Land and Urban Development Project in Kiribati
      • Strategic Environmental Assessment: Rising to the SDG Challenge
      • Coastal Engineering for Climate Change Resilience in Eastern Tongatapu, Tonga
      • Climate-induced Migration in the Pacific: The Role of New Zealand
    • Impact Connector #10 Climate Change Mitigation and Adaptation >
      • Introduction
      • Is a “just transition” possible for Māori?
      • Adapting to Climate Change on Scale: Addressing the Challenge and Understanding the Impacts of Asia Mega-Cities
      • How responding to climate change might affect health, for better or for worse
      • Kanuka, Kereru and carbon capture - Assessing the effects of a programme taking a fresh look at the hill and high country land resource
      • Wairoa: Community perceptions of increased afforestation
      • Te Kākahu Kahukura Ecological Restoration project: A story within a story
    • Issue #9 Impacts of Covid-19 >
      • Introduction to Impact Connector Issue 9 – Impact assessment and Covid 19
      • Covid-19 fast-track consenting: climate change legacy key to success
      • Tourism – the long haul ahead
      • Making sense of the impact of Covid-19: planning, politics, and the public good
    • Issue #8 Social Impact Assessment >
      • Challenges for Social Impact Assessment in New Zealand: looking backwards and looking forwards
      • Insights from the eighties: early Social Impact Assessment reports on rural community dynamics
      • Impact Assessment and the Capitals Framework: A Systems-based Approach to Understanding and Evaluating Wellbeing
      • Building resilience in Rural Communities – a focus on mobile population groups
      • Assessing the Impacts of a New Cycle Trail: A Fieldnote
      • The challenges of a new biodiversity strategy for social impact assessment (SIA)
      • “Say goodbye to traffic”? The role of SIA in establishing whether ‘air taxis’ are the logical next step in the evolution of transportation
    • Issue #7 Ecological Impact Assessment >
      • The future of Ecological Impact Assessment in New Zealand
      • Ecological impact assessment and roading projects
      • EcIA and the Resource Management Act
      • Professional Practice and implementation of EcIA
      • EcIA in the Marine Environment
    • Issue #6 Landscape Assessment >
      • Introduction
      • Lives and landscapes: who cares, what about, and does it matter?
      • Regional Landscape Inconsistency
      • Landscape management in the new world order
      • Landscape assessment and the Environment Court
      • Natural character assessments and provisions in a coastal environment
      • The Assessment and Management of Amenity
      • The rise of the THIMBY
      • Landscape - Is there a common understanding of the Common?
    • Issue #5 Cultural Impact Assessment >
      • Introduction
      • Potential of Cultural Impact Assessment
      • The Mitigation Dilemma
      • CIA and decision-making
      • Insights and observations on CIA
      • Achieving sustainability through CIA
      • CIA - Enhancing or diminishing mauri?
      • Strategic Indigenous Impact Assessment?
    • Issue #4 Marine Environment >
      • Introduction
      • Iwi, Impact Assessment and Marine Environment
      • Sea-Bed Mining Application in Taranaki
      • The wreck of the MV Rena
      • High Court RMA Controls on Fishing
      • Initiatives in the Pacific Islands
      • SEA in an NZ context
    • Issue #3 Strategic Environmental Assessment
    • Issue #2
    • Issue #1
  • Resources
    • Webinars
    • IAIA Resources
    • United Nations Guidance
    • Donors Guidelines and Principles
    • Oceania and the Pacific
    • Natural Systems >
      • Biodiversity & Ecosystem Services
      • Agriculture & Food Systems
      • Water Management
    • Social Impact Assessment
    • Health Impact Assessment >
      • Climate Change & Health
      • Air Quality Impact Assessment
    • Cumulative Impact Assessment
    • Community and Stakeholder Engagement
    • Indigenous Peoples
    • Climate Change and Disaster Risk Resilience >
      • Adaptation Planning
      • Nature-based Solutions
    • Urban Development
    • Sustainable Development Goals
    • Strategic Environmental Assessment
  • Community
    • Membership Directory
    • News
    • Policy Submissions >
      • Past Submissions
    • Courses