1. Following the introduction of the RMA, local government had to progress new planning requirements without central government support in the form of guidance or national direction. The NZ Coastal Policy Statement 1994 was the first piece of national direction to be produced under the RMA. It took a further 10 years before the next piece of national direction was introduced. Likewise, the Quality Planning guidance was not introduced until 10 years after the RMA came intoeffect.
2. This lack of guidance has led to considerable problems with a lack of alignment and integration of policies and plans within the RM system. Each council has developed their plans and policy statements without national direction on how the plan should be structured and formatted. This horizontal and vertical misalignment leads to many issues, includingthat:
· plans are complex, long and often internallyinconsistent;
· local authorities duplicate effort developing provisions that could be made consistent at a nationallevel;
· in many places there is inconsistency between the district plan, the corresponding regional plan, national direction, and between regions which results in costs associated with time spent interpreting plans, litigating, and associated opportunitycosts;
· plans are difficult to monitor andaudit;
· it is difficult to transition to a fully digital format with seamless interaction with other local and central government documents anddatabases;
· national direction is not well reflected in many plans which makes consent applications and decision-making more difficult (ie need to look at multiple documents);and
· it is not always clear where plan provisions are giving effect to national direction (some plans are yet to give effect to some national policy statements (NPS)), so submitters and councils may spend time debating issues which have been resolved at the nationallevel.
3. The proposal is to develop a national planning template to improve the consistency of RMA plans and policy statements. The minimum requirements for the first version of the national planning template wouldbe:
· standardised formatting and structure for plans and policystatements;
· references to existing NPSs and national environmental standards(NESs);
· where possible, standardised definitions;and
· electronic functionality and accessibility of planningdocuments.
4. The template will reduce the complexity involved in creating and using RMA plans and policy statements, and improve the consistency and user-friendliness of plans. The template will speed up decision-making for all resource management decision-makers, who will have less local rule variation to interpret, and will know where to find relevant provisions in each plan. Long-term plan making costs to councils can also be reduced by greater plan standardisation. This will allow councils to devote greater resources to developing unique local content for theirplans.
5. The ability to deliver national direction through template objectives, policies, and rules (or by reference to existing NPSs and NESs) will improve how national direction is reflected in plans. The template will standardise presentation of national direction in planning documents, reduce the number of documents to be referred to for resource management decision- making and ensure national direction is incorporated into all plans through mandatory templateupdates.
6. There will be a short term increase in cost to both central and local government associated with the roll out and implementation of the template and provision of support to councils. This is likely to be concentrated in the seven years following the introduction of the template provisions.
7. Having a standardised national planning template may also discourage innovations in practice by councils, as they will be required to use the set template. This risk can be mitigated by doing careful analysis in deciding what is appropriate for inclusion in the template, especially in regard to how much content (as opposed to structure and format requirements) is prescribed. Councils would have a significant say in plan content which does not relate to nationaldirection.
Provide incentives for quality plans and good environmentaloutcomes
8. This option could include a combination of awards, prizes and public benchmarking reports on plan quality. It would allow indirect pressure to be applied to councils to meet criteria and direct desired outcomes. The effects of this option depend largely on what aspects of plans are encouraged or discouraged. We consider that the ‘bonus’ of awards would encourage councils to innovate in their delivery. The downside to this is that plans are unlikely to become more consistent – although this may be balanced out if some councils adopt the innovative solutions developed by othercouncils.
9. There is a risk that this initiative may result in councils revising their plans more frequently to gain awards or avoid punishments. It would require standard measures of quality to be developed and applied, which can be difficult, and these may also change over time. It may unfairly stigmatise councils with less local capability and capacity. This option would have a high cost to central government in monitoring and would require secure and long term funding to be available. It is likely to encourage innovation rather thanstandardisation.
Councils use one integrated plan perregion
10. This option would allow local flexibility and reduce complexity and duplication of effort as there would be a total of only 16 plans. While this would reduce the costs of making plans there would still be significant costs involved in coordinating the territorial authorities within each region, so the reduction would be minor tomoderate.
11. Reducing the number of RMA plans would make plans more user-friendly. However, regional plans would still differ in their structure and format, so the benefits would be moderate, rather than significant. The proposal in unlikely to lead to increased consistency between regions and a lack of working relationships between councils may hinder the plan makingprocess.
Intervention
12. This option would involve a combination of a national planning framework and power for central government to intervene if plans do not meet objectives. It would improve plan links between policies and objectives, and rules and methods, and ensure that plans implement national direction. This is because we assume these are the major areas the framework would emphasise (and therefore would be the focus of anyintervention).
13. It is also likely that government intervention would improve the comprehensiveness of plans (as some council plans may be incomplete at present) and the user-friendliness of plans (if some plans are deemed by central government to be too hard touse).
14. The downside is that councils that do not meet national standards are likely to incur greater costs revising their plans to meet the criteria, which may also increase duplication of efforts. The increased emphasis on national direction and a national framework may also mean that community values are not as well reflected in plans as they arecurrently.
15. This option is unlikely to result in standardised plans and is likely to increase costs to local government if plans are not right the firsttime.
Non-mandatorytemplate
16. This option would involve developing a national planning template for councils to use on a voluntary basis. This would mean that many councils with less capacity to develop their own provisions could free up some of theirresources.
17. By not making the template mandatory, the benefits of providing national level consistency in structure, format and content of plan provisions are likely to be substantially reduced. Not all councils would take the option of using the template, especially if they felt that their own provisions were adequate. Those that do take advantage of the template would not be bound by compulsory timeframes, meaning that the benefits of standardisation and cost savings would be realised moreslowly.
18. The template is the preferred option. It is a relatively flexible option, which can meet a range of objectives depending on how much (or little) is specified in the template (eg, structure and format only, or a combination of structure, format, andcontent).
19. A common structure and format would significantly improve the consistency and user- friendliness of plans (for users who use plans from multiple regions), and would reduce the duplication of effort required to make plans (as councils won’t have to determine the structure and format themselves). While this may reduce councils’ ability to come up with innovative solutions for plan making, we consider that this risk is outweighed by the considerable benefits of the proposal. The template’s structure and format can also help to reduce the long-term costs of plan making (although there is likely to be an increase in short-term implementation costs), improve plan’s comprehensiveness, improve links strategic and spatial plans, and improve the links between objectives, policies and methods andrules.
20. The resource legislation amendment package is an opportunity to add template provisions into the primary legislation. If they are not included now it could be some time before these can be officially incorporated. The template could still be developed for voluntary use, but this would mean losing many benefits, as outlinedabove.
21. This proposal would have a significant impact on achieving the objective of increased consistency across planning documents, and therefore better alignment and integration across thesystem.
