Future Proof Submission to the Resource Management Review Panel's 'Transforming the resource management system - Opportunities for Change - Issues ...

Future Proof Submission to the Resource Management
Review Panel’s ‘Transforming the resource management
system – Opportunities for Change – Issues and Options
                        Paper’

                   December 2019

To: The Resource Management Review Panel
c/- Ministry for the Environment

PO Box 10362
Wellington 6143
E. rmreview@mfe.govt.nz

Date: 3 February 2020

Name of Submitter:
Future Proof Implementation Committee
c/- Bill Wasley: Independent Chair
P O Box 430
TAURANGA 3144
M. 027 471 3006
E. bill@billwasley.co.nz

Submission:
This is a submission by the Future Proof Implementation Committee on the issues and options paper
entitled ‘Transforming the Resource management System – Opportunities for Change – Issues and
Options Paper – November 2019’, prepared by the Resource Management Review Panel. The
content of the submission follows overleaf. We appreciate the opportunity to provide comments on
the document.

Other Future Proof partners will also be making submissions on the issues and options paper. These
will be more detailed in nature than the Future Proof submission which provides a higher level,
overarching view of the document.

Signed:

Bill Wasley
Independent Chair – Future Proof Implementation Committee

1. Introduction

   This submission is presented on behalf of the Future Proof Implementation Committee
   (Future Proof), the governance group responsible for the implementation of the Future
   Proof Growth Strategy. The Committee is made up of two elected members from each
   partner council (Hamilton City Council, Waikato Regional Council, Waipa District Council,
   Waikato District Council) and three representatives nominated by tāngata whenua - one
   from the Tainui Waka Alliance, one from Waikato-Tainui and one from the tāngata whenua
   reference group Ngā Karu Atua o te Waka. The Committee has additional representation
   from the New Zealand Transport Agency and the Waikato District Health Board. The
   Committee also has an extended membership for the Hamilton to Auckland Corridor Plan
   programme. This membership includes Central Government, Auckland Council and Tāmaki
   Makaurau iwi representation from the Auckland Mana Whenua Kaitiaki Forum.

   This submission is made on behalf of the original membership of the Future Proof
   Implementation Committee and does not necessarily represent the views of the ‘extended
   membership’.

   The Future Proof Growth Strategy is a growth management and implementation plan for the
   Future Proof sub-region. The sub-region refers to the administrative areas of the territorial
   authorities of Hamilton City Council, Waipa District Council and Waikato District Council.
   Future Proof has been in an implementation phase of the Strategy which was originally
   signed off in 2009, and is now undergoing an update. A Phase One update of the Strategy
   has been completed and a second phase is currently underway. The Strategy has been
   successful in providing a strategic, integrated approach to long-term planning and growth
   management in the sub-region.

2. Overall comments
   Over the 10 years since the Future Proof Strategy was adopted, Future Proof has made
   numerous submissions on documents and processes that have been introduced by
   successive governments to examine and amend the resource management system and
   legislation. Future Proof’s view throughout this time has been that there needs to be more
   integration across the various statutes that govern resource management in New Zealand.
   Future Proof supports improved national direction as well as improved integration between
   planning and funding tools and legislation.

   Whilst Future Proof agrees with many of the issues raised in the issues and options paper, it
   does not necessarily agree that all issues can or should be addressed through legislative
   reform. The current planning systems is complex and lacks alignments between various
   planning, funding, regulation and decision-making processes. However, there are elements
   of the current system which are working well. Many of the problems with the system could
   be addressed through better integration of existing provisions, including the integration
   between planning and funding tools, and clearer national direction.

3. Issue One: Legislative architecture
   Question One: Should there be separate legislation dealing with environmental management
   and land use planning for development, or is the current integrated approach preferable?
   The paper discusses how the RMA can address improved outcomes for both the built and
   natural environments. Two broad options are posed – either retaining the Resource
   Management Act (RMA) as an integrated statute with enhanced principles for land use and
   environmental management or splitting the RMA into an environmental management
   statute and a land use planning statute.

   The built environment and the natural environment are not separate from each other but
   are inextricably linked and it is important that the environmental, social, economic and
   cultural focus of Part Two should apply to all developments, whether involving the built
   and/or natural environment. As such, Future Proof is of the view that an integrated statute
   is likely to be preferable. Notwithstanding this, the problem of cumulative environmental
   effects leading to a pervasive trend of environmental decline remains problematic. It
   remains unclear whether this is the result of a lack of clear guidance on environmental
   bottom lines, an artefact of an integrated statute, or the configuration of institutional roles
   and responsibilities. These dynamics should be thoroughly examined before a view is
   formed on whether separate environmental and land use planning legislation or retaining an
   integrated approach is preferable.

   Recent case law, such as the King Salmon case (Environmental Defence Society v NZ King
   Salmon Co Ltd [2014] NZCS 38 (SC)) have provided useful jurisprudence as to the proper way
   in which the RMA should be implemented. The creation of new legislation would likely
   result in costly new litigation as the interpretation of the new act(s) was tested through the
   courts.

   Whilst, as discussed under Question Two below, Part 2 of the RMA provides adequate
   context, the RMA currently provides little in the way of strategic direction or spatial
   consideration of the complexity of urban environments. The current complexity of the
   planning system across numerous acts can create a lack of alignment between the planning
   and delivery components of the system. Spatial planning, if embedded correctly into the
   relevant act(s), could enable better outcomes for the built environment through a strategic
   approach rather than the piecemeal approach provided through a purely ‘effects-based’
   planning regime. For example, one spatial plan for an urban area could be developed which
   addresses the planning, infrastructure and funding elements of planning for the area. This
   might only apply in certain circumstances, such as in high growth areas. See further
   discussion on this under Question Eleven below.

   Future Proof is an example of a high-level spatial plan which has been embedded in the
   Waikato RPS and under which Hamilton City, Waipa and Waikato Districts have developed
   their district plans to be in alignment.

Any new model would need to:
   - Strike the right balance between market flexibility to respond to market conditions, and
      certainty for public and private investment
   - Incentivise collaboration and consistency across municipal boundaries
   - Encourage good urban planning outcomes
   - Consider land use, infrastructure and funding in an integrated way
   - Take account of community views
   - Take account of local context
   - Acknowledge existing spatial and growth plans (e.g. regional or sub-regional plans) so as
      to recognise the significant efforts already undertaken in processes such as Future Proof
      and the Hamilton to Auckland corridor work.

4. Issue Two: Purposes and Principles of the RMA:

   Question Two: What changes should be made to Part 2 of the RMA?
   A criticism raised in the report is that the RMA is primarily a reactive framework concerned
   with managing the adverse impacts of development and has insufficient focus on the
   positive outcomes that can be derived from planning for resource use.

   The purpose of the RMA, including enabling people and communities to provide for their
   social, economic and cultural well-being while protecting the environment they live in, is
   applicable in both urban and non-urban areas. It establishes a resource management
   system which has at its heart a sustainable management purpose. Whilst the application of
   the sustainable management purpose of the Act has not always resulted in the
   environmental outcomes that may have been anticipated, Part Two remains a powerful
   bottom line to ensure that environmental, social, economic and cultural matters are
   addressed in development. These principles should be retained or used as the basis of
   development of any new legislation, should that be the chosen option.

   Question Three: Does s5 require any modification?
   Future Proof is of the view that section 5 correctly reflects the scope of sustainable
   management and is appropriate for both the environmental and urban growth components
   of planning which are currently being considered by the panel.

   Question Four: Should ss. 6 and 7 be amended?
   Future Proof is of the view that section 6 and 7 cover important issues and there is now well-
   established case law with which to assist in the interpretation of these sections. These
   sections should be retained. These sections could provide the framework for a spatial
   planning tool if the panel were minded towards that option.

Question Five: Should the relationship or ‘hierarchy’ of the matters in ss. 6 and 7 be
     changed?
     Future Proof is of the view that an overarching NPS could be put in place which enables
     decision-makers to understand the relative importance of urban matters when balanced
     with other competing Part 2 matters. At present, there is no clear way to balance these
     matters. The numerous national documents currently being drafted will go some way
     towards enabling the matters in ss.6 and 7 to be balanced but an overarching NPS would
     provide the interpretation required to balance multiple complex issues.

     Question Six: Should there be separate statements of principles for environmental values
     and development issues (and in particular housing and urban development) and, if so, how
     are these to be reconciled?

     Future Proof considers that for urban planning there should be an overarching set of
     objectives or outcomes sought at place, which will provide certainty as to the essential
     elements required when planning for urban areas. These should be established locally but
     under a common set of principles, perhaps established through an overarching NPS. These
     should be implemented regionally and locally but under a common set of principles. Spatial
     planning, supported by strong objectives and policies in district and regional plans, could
     then be a tool to ensure that short-term decision-making is aligned with long-term outcomes
     sought for the urban area.

     Question Seven: Are changes required to better reflect te ao Māori?
     Please see our comments under issue 3 below.

     Question Eight: What other changes are needed to the purpose and principles in Part 2 of
     the RMA?
     Future Proof is of the view that, on the whole, Part 2 is already fit for purpose. The RMA
     could explicitly require the achievement of positive outcomes when it comes to managing
     development in the urban environment but this would be better achieved as part of other
     tools such as spatial planning or NPSs.

5.   Issue 3: Recognising Te Tiriti o Waitangi/The Treaty of Waitangi and te ao Māori

     Question Nine: Are changes required to s8, including the hierarchy with regard to ss. 6 and
     7?
     Section 8 is clear that the principles of the Te Tiriti o Waitangi/Treaty of Waitangi must be
     taken into account.

     The relationship between the requirements of section 8 of the RMA, and the requirements
     of other acts, including settlement acts, such as those listed below, is important but can
     create complexity. Please see further discussion under question 10 below.

a. Waikato Tainui Raupatu Claims Settlement Act (1995)

b. Waikato Tainui Raupatu Claims River Settlement Act (2010)

c. Ngaati Koroki Kahukura Claims Settlement Act (2014)

d. Ngaati Hauaa Claims Settlement Act (2014)

e. Heritage New Zealand Pouhere Taonga Act (2014)

Question Ten: Are other changes needed to address Māori interests and engagement when
decisions are made under the RMA?
Future Proof would strongly support positive changes that would assist in addressing Māori
issues and engagement when forming policy and making decisions under the RMA. Future
Proof notes that many positive changes could occur without the need for further changes to
the RMA itself. Importantly, for example, in order to effectively implement the RMA it is
essential that iwi and hapu are sufficiently resourced to participate effectively in resource
management processes.

The Te Puni Kokiri document “Te Kotahitanga o te Whakahaere Rawa: Māori and Council
Engagement under the Resource Management Act 1991” (2006) provides a good overview of
Māori participation in the RMA and notes that successful council-Māori relationships are not
based solely on strict adherence to legislative requirements – they are based on good
ongoing informal engagement, trust, transparency, goodwill and supported through strong
structural arrangements. Future Proof’s Nga Karu Atua o te Waka tangata whenua
reference group has been in place for over 10 years and continues to provide advice to every
level of the project from technical through to governance. The reference group is supported
by a secretariat from the Future Proof partnership, members are reimbursed for their time,
and member(s) from the reference group represent the group at the technical, executive
and governance levels of the project. As a result, the reference group has remained strong
and active and continues to enable Future Proof to accurately reflect tangata whenua and
iwi aspirations and concerns. Future Proof would welcome further conversations with the
RMA review panel on how Māori participation in the planning system could be better
enabled.

We acknowledge that treaty settlement outcomes and the case-by-case arrangements that
provide for a stronger role for tangata whenua in our resource management system are
hard-fought and highly valued partial redress for past grievances. They cannot to be set
aside. Notwithstanding this, the increasing complexity on the ground for iwi, councils and
communities who are required to navigate these obligations may reach a point where a
system-wide (rather than case by case) approach will be required to ensuring tangata
whenua representation throughout our resource management and planning systems.
Opportunities to take steps towards this should be explored.

6.   Issue 4: Strategic Integration Across the Resource Management System

     Question Eleven: How could land use planning processes under the RMA be better aligned
     with processes under the LGA and LTMA?
     The current complexity of the planning system across numerous acts can create a lack of
     alignment between the planning and delivery components of the system. The ‘effects-
     based’ nature of the RMA can make it difficult to formulate and implement a strategic
     approach to planning through which to integrate the various components of planning and
     delivery under the RMA, LGA and LTMA. As discussed above, spatial planning, if embedded
     correctly into the relevant Act(s), could enable better outcomes for the built environment
     through a strategic approach rather than the piecemeal approach provided through a purely
     ‘effects-based’ planning regime.

     The Environmental Defence Society in their document “Reform of the Resource
     Management System – the Next Generation” (February 2019) suggested as an option that a
     “Spatial Planning Act” could be introduced which would mandate the creation of spatial
     plans, with the intention of them guiding integrated decision-making under the RMA, Local
     Government Act, Land Transport Management Act, and the spatial components of other
     statutes. This could provide a good mechanism to integrate the various acts. This would
     also then need to be integrated into the other acts e.g. at sections 62, 67 and 75 of the RMA
     (content of regional policy statements, regional plans and district plans).

     Alternatively, a section in the LGA could be added to require spatial plans in a similar way to
     the way that the Auckland Spatial Plan is required through the Local Government (Auckland
     Council) Act 2009.

     Urban Development Authorities could also provide a tool through which strategic urban
     planning is delivered in a way that aligns RMA, LGA and LTMA functions.

     Question Twelve: What role should spatial planning have in achieving better integrated
     planning at a national and regional level?
     Spatial planning is an essential tool for aligning various components of the resource
     management planning system at a regional or sub-regional level. It can set overarching
     strategic direction for an area, indicate the location and timing for the provision of
     infrastructure, priority areas for investment, areas where development will be provided for,
     significant natural areas, and other strategically significant priorities for an area.

     Spatial planning is a very good mechanism for bringing together local authorities, central
     government, tangata whenua and other relevant agencies on an agreed direction through a
     co-governance model. This is already occurring in the Future Proof area as part of the
     Hamilton-Auckland Corridor initiative arising from the Government’s Urban Growth Agenda.

This joint planning arrangement is critical and has great potential to be developed further.
Further guidance should be provided via a National Policy Statement on spatial planning.

In the Waikato, the original Future Proof Strategy was adopted in 2009. Subsequently, the
Regional Policy Statement was reviewed to incorporate the major features of the Future
Proof Strategy, including the settlement pattern showing the location and staging of
residential, industrial and commercial development, along with a set of ‘development
principles’ by which growth should be managed in a way that integrated with the
environmental outcomes sought by the Regional Policy Statement. Subsequent plan
changes and reviews in the Waikato and Waipa Districts and Hamilton City were made to
give effect to the Regional Policy Statement. Significant changes have occurred as a result -
including a significant reduction in the ability to fragment rural land for lifestyle
development, and increases in urban densities which have contributed to a more compact
urban form, including achieving a 50:50 infill:greenfield ratio of development in Hamilton
City. The Waikato Expressway construction and the designation of the Southern Links
transport corridor were also enabled through this strategic approach to growth planning
through the Future Proof Strategy. These examples illustrate the benefits of having an
agreed spatial growth strategy in a sub-region or region.

Any spatial plan needs to have statutory weight and be able to direct land use planning
without a further round of consultation and appeal processes on matters already set out in a
Spatial Plan. A Spatial Plan could form part of a Regional Policy Statement (or have that
effect). However, without a fundamental change in the function of Regional Policy
Statements, it would not be appropriate to replace the RPS mechanism itself with a spatial
plan , given the broad range of issues they are currently required to address.

Consideration should be given to enabling existing spatial plans, or spatial plans already in
development, to fulfil any future statutory requirements for spatial planning, provided they
have been consulted on through a full LGA Special Consultative Procedure or through RMA
Schedule 1. This would avoid unnecessary duplication of processes.

Question Thirteen: What role could spatial planning have in achieving improved
environmental outcomes?
Environmental outcomes must be at the core of what any spatial plan would be seeking to
achieve. If a spatial plan was mandated, it would need to be tied to the sustainable
management purpose of the RMA so that the spatial plan could achieve the integration of
the environmental, social, economic and cultural aspects of the Act.

In particular, a spatial plan would be an appropriate tool to identify priority locations for
environmental protection and restoration for biodiversity, ecosystem service or amenity
values, in a similar same way as other land uses and key infrastructure networks would also
be an expected feature.

Question Fifteen: How should spatial plans be integrated with land use plans under the
     RMA?
     Spatial plans could be incorporated into Regional Policy Statements and should be given
     effect to by regional (as relevant) and district plans. This will ensure consistency across the
     various planning implementation instruments. Beyond the RMA, other policy documents
     under other acts, such as Long Term Plans, Infrastructure Plans and Regional Land Transport
     Plans could be integrated with spatial plans as well. The statutory integration of spatial
     planning will be important to ensure that the necessary integration occurs across the various
     acts.

7.   Issue 5: Addressing Climate Change and Natural Hazards

     Question Sixteen: Should the RMA be used as a tool to address climate change mitigation,
     and if so, how?
     Climate change mitigation is primarily dealt with as a national-level matter and Future Proof
     is of the view that this should remain the case. Individual councils are not able to influence
     the wider systemic changes that need to occur in order to combat climate change, for
     example through the use of economic instruments or incentives for the use of renewable
     energy, or low emissions technologies etc.

     However, an explicit requirement to consider the impacts on climate change when making
     decisions on urban form (including through spatial planning) would reflect the powerful role
     that councils have in influencing urban form and development outcomes for example by
     planning for places where people can live, work and play and are able to limit their need to
     travel, or by making it easy to walk, cycle or take public transport to destinations. Well
     planned urban form can both ensure our urban areas adapt and are resilient to the effects of
     climate change, and can contribute to climate change mitigation through working towards a
     low carbon future.

8.   Issue 6: National Direction
     Question Nineteen: What role should more mandatory national direction have in setting
     environmental standards, protection of the environment more generally, and in managing
     urban development?
     The notion of a single combined instrument such as a national policy statement, under
     which local/regional spatial plans could be prepared, has merit. This would enable a clear
     set of policies which could integrate a suite of legislative outcomes where there is a spatial
     element. At present, there is a plethora of national policy direction, not all of which aligns
     well, particularly across statutes. Regional or sub-regional spatial planning would be a useful
     tool to implement national direction at a more local scale.

9.   Issue 8: Consents/Approvals

Question Twenty Six: Are changes required for other matters such as the process for
      designations?
      The provision of bulk and network infrastructure is crucial for areas to grow and develop
      successfully. Often this requires long lead times. It is often more effective and efficient to
      plan for infrastructure well in advance of it needing to be in the ground.

      We recognise that designation timeframes can sometimes be too short, particularly where
      works for designated areas are scheduled to commence within specific Long Term Plan or
      Infrastructure Strategy timeframes and subject to funding availability. In such cases,
      provision could be made for longer designation timeframes provided that there is a clear
      commitment to funding so that there is certainty that the proposal will proceed.

      Future Proof would also support proposals to streamline processing of large-scale
      infrastructure projects.

11.   Issue 9: Economic Instruments:
      Question Twenty Nine: What role should economic instruments and other incentives have in
      achieving the identified outcomes of the resource management system?
      Future Proof supports the ability to make increased use of economic instruments to
      facilitate the achievement of resource management outcomes – in particular when seeking
      to manage within environmental limits and as ‘no-net-loss’ or ‘betterment’ tests are
      becoming increasingly common. In the case of various forms of environmental credit
      markets and transferable development rights, we suspect that their success (or otherwise) is
      connected to having:
          •   enabling policy;
          •   clear standards; and
          •   robust systems and process to verify, track and audit the transactions.
      While the ability to make increased use of such economic instruments would be welcomed,
      their use should be contingent on the ability to provide the standards and systems necessary
      for them to be effective in achieving the desired resource management outcome. This is
      likely to require additional investment.
      Question Thirty: Is the RMA the appropriate legislative vehicle for economic instruments?
      Yes.
12.   Issue 10: Allocation
      Future Proof understands that the focus of the panel’s thinking is on the allocation of water
      takes, discharges, and coastal marine space. The Waitangi Tribunal case Wai 2358
      considering Maori rights and interests in freshwater allocation is out of scope of the current
      review. Future Proof also understands that other ‘allocations’ under the RMA, such as the
      assimilative capacity of the environment more generally, navigations rights on the surface of
      rivers, lakes and in the sea, and river and coastal marine area materials (e.g. gravel and sand)

are included in the panel’s review scope although are not identified as significant areas of
focus. The following questions are answered on that basis.

Question Thirty One: Should the RMA provide principles to guide local decision-making
about allocation of resources?
Under the current first-in-first-served system there is currently limited ability to weigh the
relative benefits of different proposals in the context of a wider strategy. The
environmental, social, economic and cultural values of resources are subject to often
competing demands. There is currently limited scope to consider how we might best, as a
country, allocate resources to the highest environmental, social, cultural and economic
values. National-level guidance would assist in weighing these complex demands.
Future Proof is of the view that the RMA, or a national policy statement, should provide
principles to guide local decision-making about allocation of resources. These principles
would then be reflected in regional policy statements to provide the context within which
decision-making would occur.
In the case of water take allocations, Future Proof is of the view that a common expiry date
for resource consents for water takes would allow resource consents to be considered
together on a comparative basis. This would also allow the merits of competing applications
to be considered before consent was granted or declined.
A number of Future Proof partners have raised an issue with the Resource Management
(Discount on Administrative Charges) Regulations 2010. These regulations are seen as a
barrier to regional councils processing applications with a common expiry date. This is
because the regional council would take on financial risks and penalties if unable to process
all consents within the timeframes required by the RMA. A practical solution may be to
exclude water take consent applications from the discount regulations under the RMA.

Question Thirty Two: Should there be a distinction in the approach taken to allocation of the
right to take resources, the right to discharge to resources, and the right to occupy public
space?
Future Proof is of the view that the right to take resources, the right to discharge resources
and the right to occupy public space are very different issues and as such there should be
distinctions in the approach to each of these matters.

Question Thirty Three: Should allocation of resources use such as water and coastal marine
space be dealt with under the RMA or elsewhere as is the case with minerals and fisheries,
leaving the RMA to address regulatory issues?
Future Proof is of the view that the RMA should continue to allocate resource use for water
and coastal marine space.

Regional council boundaries are largely consistent with the boundaries of major water body
      catchments. This is the scale at which planning for water takes and water discharges should
      occur, rather than at a national scale. Water take and discharge issues are also tied closely
      to specific attributes of catchments – resource consents will address the need to avoid,
      remedy or mitigate adverse environmental effects. The methods which various councils use
      to allocate these resources will differ depending on the nature and attributes of the
      catchments. This doesn’t lend itself to a national approach as with minerals or fisheries.

      In relation to the allocation of coastal marine space, such as for marine farming, again this is
      best dealt with at the regional scale. The issue of allocation of space in the context of the
      coastal and marine area in inextricably tied to other issues such as the specific
      environmental conditions and the, the cultural and social (e.g. recreational) uses and values
      in the area. This doesn’t lend itself to a one-size-fits-all approach to management.

      Ultimately, any recommendations made by this panel, should be integrated with the
      freshwater reform package of work currently underway.

14.   Issue 13: Institutional Roles and Responsibilities:
      Question Thirty Nine: Although significant change to institutions is outside the terms of
      reference for this review, are changes needed to the functions and roles or responsibilities
      of institutions and bodies exercising authority under the system and, if so, what changes?
      Future Proof is of the view that plan making and land use regulation needs to remain with
      councils, albeit with guidance from central government, as this will ensure that different
      local circumstances and needs are addressed and that local communities get to have their
      say in key policy outcomes that affect their amenity.
      There is room for further responsibilities for central government and infrastructure
      providers in terms of nationally significant projects, better alignment of land use and
      infrastructure, and new and innovative infrastructure funding options. This would help to
      support better urban planning.
      National interests in planning outcomes may include:

      -   Transport, particularly where the inter-regional and international movement of people
          and goods are affected;
      -   Social infrastructure (eg education and health);
      -   Affordable housing initiatives.

16.   Issue 14: Reducing Complexity across the system:
      Question Forty Two: What other changes should be made to the RMA to reduce undue
      complexity, improve accessibility and increase efficiency and effectiveness?

Any revised planning system should consider providing a standardised process which can
enable plan changes/variations to be prepared quickly and cost-effectively.

Any revision to the planning system could also consider a streamlined process whereby third
party rights of appeal could be limited for some plan change/variations that address areas of
national policy significance (such as affordable housing). Future Proof would also be very
supportive of initiatives which fast track planning approvals (plan changes or consents) for
developments which are part of an agreed settlement pattern contained within a growth
strategy or spatial plan, such as the Future Proof strategy. Public consultation would have
already occurred as part of spatial plan development and in the case of settlement patterns
contained within a Regional Policy Statement, would have already been through a first
schedule RMA 1991 process.
More broadly, a feature of the current system is a considerable time lag between national or
regional policy direction being agreed and regional or district plans giving effect to these
directions – regularly in excess of 10 years. This is too long.

While National Environmental Standards and the use of the National Planning Standards,
both present options to shortcut this process they also limit or remove the ability to develop
a tailored response reflecting local conditions.

Future Proof suggests that in tandem with more streamlined plan making processes, it be
made easier for Regional and District Councils to run joint Regional Policy Statement /
Regional Plan / District Plan change processes that simultaneously amend multiple resource
management plans without necessarily joining the plans themselves. We accept that current
legislation makes such processes possible in theory but the lack a fixed formula for matters
such as the appointment of members to hearings panels and decision-making processes
makes this a daunting prospect. Specific legislative provision and clear guidance for such
joint processes may assist.