5 key points from the UDF Submission on NBA Exposure Draft

UDF Resource Management Reform working group is currently finalising UDF’s submission on the exposure draft for the proposed Natural and Built Environments Act (NBA).

We wish to share the following key points of our submission. Our intention is to:

  • Update our members
    Many of our members have contributed to the thinking behind the submission through the well-functioning environment activities through the year.
  • Provide any other potential submitters with a starting point where our concerns align
    The RM reform working group has had contact with NZIA and NZILA as well as some local government teams and have identified shared concerns. We encourage individuals to put in submissions too as this will help demonstrate the extent of agreement among urban environment professionals, to the Parliamentary Committee considering submissions.

Submission Key Points

Overall, UDF Aotearoa supports the Resource Management Reform objectives, in particular welcomes the shift from an effects-based to an outcomes based system.

  1. Natural vs Built

    The Act does not make reference to the integration of and the interaction between the natural and built environments.

    UDF considers that the integration of Natural and Built environments in context of urban environments is not only possible but necessary for the well-being of individuals and communities as well as for more effective responses to climate change. Their integrated consideration must be more explicit in the Act.

  2. Quality built environment

    While the Act is titled “Natural and Built Environments”, built environment is conspicuously absent from the purpose of the Act.

    Quality, including aspects of urban form and design is required to support the well-being of current and future generations (Over 80% of whom currently live in urban areas) and should be promoted by the legislation.

    UDF considers the Act must include the objective of providing a quality built environment for current and future generations in its purpose.

  3. Built form definitions

    The Exposure Draft includes many definitions relating to the natural environment, including “natural environment” itself. In contrast, key definitions for the built environment are largely missing. Notably there is no definition for “built environment”.

    UDF considers it is essential for these to be included in the Act, rather than leaving this to potentially many years of case by case court or ‘planning committee’ (as are introduced in Part4) processes.

    Key definitions for built environment, urban environment, well-functioning urban environment and urban area are required to be included in the Act. UDF makes draft suggestions for these terms, suggesting these would be best defined through a cross-disciplinary integrated process. UDF offers to contribute to a collaborative cross-industry process.

  1. Well-functioning urban environments/ areas and urban design

    The environmental outcomes listed in the Exposure Draft makes reference to ‘well-functioning urban areas”.

    UDF generally supports the use of well-functioning urban environments terminology subject to the above definitions discussion and proposes a draft well-functioning urban environment definition.

    UDF considers “*provisions for urban design, including urban tree cover” should be included at this level of legislation as these are critical to a well-functioning urban environment and will avoid unnecessary confusion and debate at a later stage.

    *The parliamentary paper accompanying the Exposure Draft states the intentional exclusion of urban design and urban tree cover from the NBA.

  1. Environmental outcomes

    According to the Part 4 S.24 (d), the resolution of conflicts between the environmental outcomes are left to planning committees whether by regional plans or on a case-by-case basis.

    UDF advocates for a hierarchy, grouping, weighting and/or prioritisation for the 15 environmental outcomes that are listed in section 8 (a) to (p).

    The non-prioritisation at the NBA level is in conflict with the reform objective for “improving the efficiency and effectiveness of the system, and reducing complexity, while retaining appropriate local democratic input”. This approach overlooks some of the inherent tensions between these outcomes which will be costly and inefficient to resolve if not directed at NBA level.

Posted by Ekin Sakin on behalf of the UDF Resource Management Reform Working Party

Considering making a submission? Submissions close on Wednesday 4 August.
https://www.parliament.nz/en/pb/sc/make-a-submission/document/53SCEN_SCF_INQ_111944/inquiry-on-the-natural-and-built-environments-bill-parliamentary#RelatedAnchor

Source: Ministry for the Environment
Source: Ministry for the Environment

Earlier posts on the RM Reform

Te Oranga o te Taiao in the Natural and Built environments

Natural and Built Environment Bill does not expose enough!

Exposure draft for the NBA (part replaces RMA) is announced

From RMA (Resource Management Act) to NBA (Natural and Built Environments Act)

 

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