

Report To:	Strategy and Policy Committee Workshop
Meeting Date:	21 May 2024
Presenter(s):	Antoine Coffin - Manager, Spatial Planning

Presentation - Spatial Planning Case Studies

Purpose

The purpose of this presentation is to provide some insights from spatial planning studies, work undertaken by Simranjot Kaur, a summer experience student during November 2023 to January 2024.

Background

During the second quarter of 2023-2024, our focus was on exploring the strengths, weaknesses, and innovative aspects of New Zealand, as well as examining international spatial plans and strategies. These understandings would inform our approaches to regional and sub-regional activities we were undertaking, ie, SmartGrowth, Eastern Bay Spatial Plan, Rotorua Future Development Strategy.

We took advantage of the summer experience for students, employing Simranjot Kaur who undertook a comparative analysis of spatial plans across different scales and regions. Sixteen were investigated, these being at the scales of national, regional, subregional, locality, structure and community. These were in our NZ context and the United Kingdom.

Case studies for each spatial plan were developed, with a description, context, key challenges addressed, strengths and weaknesses of the approach and key observations such as innovative ideas.

Figure 1 – Spatial Plan scales

Insights

Eight key insights we gained from this work were:

1. There is diversity in approaches in New Zealand. There was little if any consistency in terminology, methods, topics, unless plans were being developed by one agency in the one jurisdiction. e.g. area and centre plans across Auckland.

2. A clear distinction between the United Kingdom and New Zealand systems is the clear and coherent framework in the UK and the bespoke, disconnected, and diversity of approaches in New Zealand.

3. Most spatial plans involved partnership arrangements that included public agencies, the volunteer sector, and the private sector, however there was no consistent arrangements. In the New Zealand context, the participation of indigenous people at governance, management and implementation is unique.

4. There are advantages in having top-down and bottom-up methodologies (a hybrid approach and one-size does not fit all). This approach fills the gaps, works to the advantages and strengths in each scale, making sure innovative and resilient solutions are at the right level.

5. Some of the best examples of spatial plans and strategies:

· Were very clear about their purpose, scale and what they were addressing.

· Responded to the key challenges of the community regardless of mandate

· a short-term focus on achievable priorities, in collaboration with partners or local communities.

· Had a balanced approach to soft and hard infrastructure.

· Considered a range of inputs complimentary to sciences e.g. indigenous and community knowledge

· Used a range of graphics and maps to communicate significance, constraints and scenarios.

· For locality and community plans, good practise involved a community-centric approach and a living document that is regularly updated to adapt to community needs.

6. Broadly, we observed common weaknesses in:

· A lack of accountability when plans deviate or fail, raising skepticism about their purpose. Accountability is crucial for bridging the gap between theoretical foundations and practical application of plans.

· The theory and methods of spatial plans are generally robust, but the practical implementation of these plans are commonly poor.

· National interventions at local scale, particularly where there is no local buy-in can be detrimental to a spatial plan or strategy success.

· Referring to other strategies and reports in the body of a strategy or spatial plan does not increase credibility.

7. Structure plans in New Zealand context are probably not a ‘spatial plan’ rather rudimentary and bespoke affiliate documents to district plan processes.

8. Our strengths are in regional and sub-regional spatial plans and strategies. We can influence national frameworks and provide information to community, structure and locality plans.

Figure 2 – The diversity of spatial plan and strategy themes

Next steps

Advocate for a national planning framework that includes spatial plans and strategies.

Advocate for a consistent and coherent set of guidance for the preparation of spatial plans and strategies.

Kainga Ora is undertaking a national review of all future development strategies. The learnings from this work can inform future work.

Continue to share learnings especially with the sub-regional strategy and spatial plan development.


Informal Workshop Paper
To:	Strategy and Policy Committee Workshop
	21 May 2024
From:	Antoine Coffin, Manager, Spatial Planning
	Namouta Poutasi, General Manager, Strategy and Science

Regional profiles

1. Purpose

The purpose of this report is to provide an overview of regional profile project and seek feedback on the visualisation of regional profile information.

2. Guidance Sought from Councillors

The Regional Council is a data rich organisation creating and receiving and environmental, economic/financial, social and cultural information from a range of sources. We have completed a data stocktake and literature review in November 2024. The review highlighted among many things that we need to be intentional in who our audiences are and audience-friendly in the way we communicate information to them.

We have been undertaking some work on testing the visualisation of information to internal audiences and will be starting this with partners. As part of this work we are seeking feedback from councillors on the visualisation of regional profile information.

3. Discussion

3.1 Background

In November 2021 the Council discussed a stocktake to identify gaps and opportunities to undertake research and mapping. Council landed on preparing for the Spatial Planning Act through collating information and standardising maps, building Māori capacity to lead spatial planning work.

In February 2023 the Council directed to build an evidence base for spatial planning both a regional and sub-regional level. This was to include technical assessments through the development of a regional profile by 30 June 2024, assessment and visualisation of inter-regional flows of people and freight, and additional research and/or assessments identified through sub-regional forums.

Project Manawa developed a proof of concept for visualising inter and intra regional flows of people and freight. This work was completed in 2023. Staff are undertaking assessments of its continued use and ongoing costs.

Requirements to develop a regional spatial strategy stopped with the repeal of the Spatial Planning Act in December 2023. Sub-regional activities in SmartGrowth, Rotorua Future Development Strategy and Eastern Bay of Plenty Spatial Plan have contributed a range of data rich inputs that can inform and influence decision-making, prioritising and policy making.

In February 2024 the Strategy and Policy committee received an overview of the spatial planning programme for 2024-2026. This included regional profiles that can inform a range of work including sub-regional activities.

The team have been to date working on efficient and effective methods of communicating data and information. This has included:

· Population demographics and projections, including analysis of projected dependency ratios.

· Housing affordability and demand.

· Residential consents, estimated yield and population change using an experimental dataset from Stats NZ, alongside actual building consent data.

· Employment by industry, including occupation projections to support the transition to a clean energy economy.

The Council already has a diversity of data. One of the key parts of our work is checking the source, reliability and use of data. This is one of the key building blocks of our capability to be effective in a range of work environments.

We have been using Power BI to produce a series of simple visually immersive, coherent and interactive insights. Spreadsheets, cloud-based and in-house data can be used. We will show you some example of Power BI data sets. One of the advantages of Power BI is it is off-the-shelf, and can be used across a number of devices.

We are now testing two more applications, story maps and experience builder. These applications visualise data in a spatial environment, the former assisting with telling a story and the latter, an interactive tool for a range of data sets that can be turned off and on at different scales. These have a lot of potential to support sub-regional strategies and spatial plans. They are relatively easy and cost-efficient to construct, operate and update.

3.2 What others are doing

We have looked at what others are doing. We have provided some examples in NZ and international that we think have some synergies with our context in the Bay of Plenty.

Examples in NZ

· See Our City Tomorrow: Spatial Plan for Wellington City (Experience Builder example)

· See the Project Mahitahi Story Map by Nelson City Council and the Nelson Climate Adaptation Story Map (embedded in the Mahitahi Story Map).

Examples of internationally

· See demographic resources produced for local government areas across Australia by .id (informed decisions) for Australia.

· Miami Valley Regional Profiles - The Regional Profiles provide insight on where the Miami Valley Region stands by providing data, information, and maps on a variety of subjects. The Regional Profiles touch on many important aspects of the Region, such as its infrastructure, environment, economy, and social characteristics.

3.3 Overview of regional profiles

The purpose of a regional profile is to gather insights from a multitude of sources to better understand the communities, challenges and opportunities across the region.

A regional profile will endeavour to produce an engaging and informative overview of each rohe within the wider region, bringing numbers to life through data storytelling^{^[1]}.

The regional profile will be dynamic, and enable users to consider topics spatially such as:

· Population growth and decline

· Changing demographic composition, with a focus on our aging population and rising dependency ratios^{^[2]}

· Areas vulnerable to natural hazards and climate change.

3.4 Audiences

We have been giving some thought to some audiences we can test how the regional profiles can meet the needs of specific and broad audiences.

· Spatial Planning and other internal teams such as Transport Planning, Policy and the Climate Change programme team.

· Iwi and hapū of the region (within the three broad rohe of Te Arawa, Mātaatua, and Tauranga Moana).

· Decision makers within local and central government.

· Industry e.g. housing developers, health care providers, education providers, utilities companies and businesses.

· The community – local residents and prospective residents.

3.5 Current options for communicating and sharing regional profiles

We have been using and testing several efficient and effective off-the-shelf tools for communicating our data and information. We have chosen these because they can be accessed on a number of devices, updated quickly, and have a diversity of applications. As mentioned above these are Power BI, story maps and experience builder. We have provided some descriptions of these below and will show you what they look like in presentations.

Power BI - Power BI enables the creation of interactive and dynamic dashboards containing a variety of charts, tables and infographics. Complex data sets can be filtered and customised to meet the needs of the audience. A key benefit is the ability to connect to ‘live’ data so that once built, the dashboards can be easily refreshed with up-to-date data with the click of a button.

Story maps - is typically narrative-driven, visually engaging stories that revolve around maps and geographic data. It is more restrictive when it comes to design, but that means it is easy to create an attractive and engaging resource with only minimal training.

Experience builder - has a lot more customization options which allows a GIS professional to create a bespoke resource. It has a library of widgets that allows greater functionality so the user is better able to engage with the maps, charts and resources. It can also host ArcGIS Apps and Power BI workspaces. Using the BOPRC template it presents like a webpage and can be easily incorporated into the organisations website if required for a seamless experience for the user.

4. Next Steps

· We are continuing to update demographics, and Census 2023 information that will be released in late 2024/early 2025. We can make these easily accessible and available to all staff and councillors.

· We are checking meta data source, ownership, reliability and permission for use.

· We will be building packages of reliable data and layers to be used in a range of applications.

· We are liaising with internal staff on centralising data and information.

· We are testing the two applications – story maps and experience builder. We think either of these can be used in SmartGrowth and wider projects.

· We will be leveraging current projects to create/collect data, focussing on the SmartGrowth Strategy implementation and Eastern Bay of Plenty Spatial Plan.


Informal Workshop Paper
To:	Strategy and Policy Committee Workshop
	21 May 2024
From:	Freya Camburn, Senior Policy Analyst and Elsa Weir, Senior Planner
	Namouta Poutasi, General Manager, Strategy and Science

PC11 Geothermal Plan Change - structure and policy direction

1. Purpose

The purpose of this report is to provide an update on the Geothermal Regional Plan Change (PC11) and seek feedback on the high-level policy direction presented.

2. Guidance Sought from Councillors

Staff are seeking:

· Support in principle for the National Planning Standards compliant geothermal chapter structure, including integration of Rotorua Geothermal Regional Plan provisions and integration of freshwater provisions for the Tauranga system.

· Early input on the high-level policy direction presented.

· Feedback on any issues or areas of concern councillors may have at this early stage in the plan change process.

3. Discussion

3.1 Background

The Bay of Plenty Regional Council manages 12 geothermal systems under the Resource Management Act 1991 (RMA). The Regional Policy Statement (RPS) sets the overall management framework, including sustainable and integrated management, and the development of system management plans (SMPs) for certain systems (e.g., Rotorua, Kawerau and Tauranga).

The RPS policies will be given effect to through changes to the geothermal provisions of the Rotorua Geothermal Regional Plan and the Regional Natural Resources Plan (RNRP). This will include combining all geothermal provisions under the RNRP and the cessation of the Rotorua Geothermal Regional Plan as a standalone plan.

3.2 Timeframe

A timeframe for the PC11 geothermal plan change was agreed at the S&P Committee meeting on 20^th February 2024. For several reasons this timeframe needs to be amended. In particular to allow for:

· an additional workshop with Councillors to enable greater input into policy direction.

· integration and inclusion of Tauranga SMP provisions with freshwater provisions.

· internal stakeholder review e.g., consent staff.

· engagement with tangata whenua and key stakeholders to be further progressed.

Working closely with the freshwater team and their plan change timeframes will remain a key consideration.

A revised timeframe is outlined below and will be bought back to the June meeting for approval.

Timeframe	Tasks/Milestones
June 2024	S&P Committee meeting update on progress and approval of revised timeframe
August 2024	S&P Committee workshop on provisions
September	S&P Committee meeting and approval of Draft Plan Change
October - December 2024	Engagement on Draft Plan Change
Jan March 2025	Refinement of draft following engagement
March - April 2025	S&P Committee workshop – workshop final draft
April - May 2025	S&P Committee decision to approve Notification of Proposed Plan

3.3 Engagement

Early engagement is underway, with initial contact made with iwi, hapū, ahu whenua trusts and key stakeholders connected to the geothermal systems. This initial engagement is “pre-draft”, to ensure we are starting the conversations early and getting to know what people think is important and how they want to be involved in the process. This will help to guide our drafting of provisions.

The next phase of public engagement will be on the draft plan change in October to December. Feedback from consultation will inform revisions to the draft prior to notification of a Proposed Plan under Schedule 1 of the RMA for public submissions in 2025.

3.4 Framework and structure of the geothermal plan change

The policy framework established in both RNRP and Regional Policy Statement provides the building blocks for the geothermal plan change. In particular, the system classification approach included in the RNRP and the RPS is the key pillar of council’s sustainable management of geothermal resources in the Bay of Plenty region.

This established framework will be updated to:

· Incorporate additional RPS policy direction.

· Address RMA section 35 review recommendations and any new technical inputs.

· Integrate Rotorua system objectives policies and rules within the geothermal chapter (previously included in a standalone regional plan).

· Include relevant provisions of the Tauranga SMP when completed.

· Ensure integration with freshwater provisions (where relevant).

The geothermal chapter will be structured to ensure consistency with the National Planning Standards. The proposed structure is shown in attachment 1.

3.5 Policy direction – what are we proposing?

Our work to date has indicated that in most areas fundamental changes to the current management approach are likely not required for geothermal systems outside the Rotorua System, although our engagement process may identify new concerns and management priorities.

A key part of the plan change is updating the existing provisions in line with best planning practice. Many of the changes proposed relate to amending existing provisions as per best practice principles for policy drafting, simplifying and streamlining where possible, and updating the formatting and numbering standards to be consistent with the National Planning Standards. Other changes relate to embedding RPS policy direction not currently included within Regional Plans e.g. requirements for System Management Plans, although these will be “new” policies within the RNRP the policy direction has been in place since 2013 and is well established. Ensuring integration with freshwater provisions for some geothermal systems will also inform changes.

Additionally, our current policy approach may not adequately address Te Ao Māori, Mātauranga Māori or tangata whenua aspirations for geothermal management. This will likely be a focus of discussions with iwi, hapū and ahu whenua trusts through engagement and where additional policy direction may need to be included as part of the plan change.

The integration of the Rotorua Geothermal Regional Plan provisions into the RNRP geothermal chapter is the most substantive change to the geothermal chapter. The extensive work undertaken to develop the Rotorua Geothermal System Management Plan will inform this part of the plan change. Key changes in policy direction for the Rotorua city geothermal system are:

· The inclusion of allocation limits

· Identification of allocation priorities

· Additional provisions to enable customary communal uses

· Establishment of sensitive management areas

For all other parts of the geothermal chapter, most changes being considered do not fundamentally alter the existing policy intent, although updating the style and format of policy drafting will, on the surface, appear quite different. For these parts of the geothermal chapter, changes can be grouped as follows:

· Existing policy – purpose/intent unchanged, wording updated in line with best planning practice.

· Amended policy – additional matters added to policy or wording updated to ensure consistency with RPS direction or to reflect required changes identified through policy review or technical workstreams.

· New policy – additional provisions added to capture RPS requirements, address matters identified through consultation, technical workstreams or RMA S.35 policy review processes.

· Freshwater integration – captured in groups above.

Further detail on each of the above groups will be provided at the committee workshop.

4. Next Steps

Continue early engagement with iwi, hapū, ahu whenua trusts and key stakeholders.

Workshop draft geothermal provisions with the Strategy and Policy Committee in August.

Refinement of draft policy and section 32 analysis to bring to the Strategy and Policy Committee in September for approval to release for consultation.

Attachments

Attachment 1 - Geothermal Chapter Structure ⇩


Informal Workshop Paper
To:	Strategy and Policy Committee Workshop
	21 May 2024
From:	Elsa Weir, Senior Planner
	Namouta Poutasi, General Manager, Strategy and Science

Rotorua Airshed Update and Policy Direction

1. Purpose

The purpose of this report is to provide an update to the Committee on the Rotorua Airshed and seek feedback on a proposed policy direction.

2. Guidance Sought from Councillors

Staff are seeking:

· Support for proposed adoption (in principle) of a PM_2.5 standard; and

· Feedback on associated proposed policy approach in response to PM_2.5standard.

3. Discussion

3.1 Policy Update on Air Quality Management for the Rotorua Airshed

Attached (Attachment 1) is the latest policy update report taken to the Rotorua Air Quality Working Party (RAQWP) in March, which provides an overview of the relevant legislation and policy framework for air quality management as it relates to the Rotorua Airshed. The key points are:

· Air quality in the Rotorua Airshed has improved over time, and it is on track to no longer be classified as a “polluted” airshed under the National Environmental Standards for Air Quality (NESAQ) for PM₁₀.

· However, the move to a PM_2.5 standard is considered to be inevitable, and the Rotorua Airshed will not meet that as it currently stands.

· There is currently no indication or certainty when central government will progress the proposed amendments to the NESAQ (which were consulted on in 2020). The last update we had from MfE was that they were going to be briefing new Ministers in April/May regarding Air Quality.

3.2 Current status of the Rotorua Airshed

A clarification to the attached RAQWP policy update report is that the Rotorua Airshed is on track to no longer be classified as “polluted” under the NESAQ on 1 July 2024 – not 2025. While there was an exceedance of the PM₁₀ standard in 2020, a breach of the NESAQ requires more than one exceedance to occur. The last breach of the NESAQ was therefore on 20 June 2019. An airshed is considered to no longer be polluted once it has achieved 5 consecutive years of no breaches.

This will be a great milestone for the Airshed to reach but doesn’t result in a huge change ‘on the ground’. There will be no change to the Airshed itself, or any of the Airshed-specific rules in either the Rotorua Air Quality Bylaw or the Regional Natural Resources Plan, as none of these hinged on the polluted status of the Airshed.

The only regulatory change that occurs is that we will no longer be required under the NESAQ to decline applications for consent to discharge to air for new activities where the discharge would be likely to increase the concentration of PM₁₀ within the Airshed.

As there has always been the option to provide an offset in such situations, or show that the activity would not increase the concentrations above the threshold (2.5 micrograms per cubic metre), there have not been any such consents declined in the Rotorua Airshed.

3.3 What could a PM_2.5standard be?

A more detailed look at the potential PM_2.5standards is included in Attachment 1. Based on the standard proposed in the NESAQ amendments (25µg/m³), and the recently updated WHO guidelines, it seems safe to assume that the most likely scenario is a PM_2.5standard of 25µg/m³ for the 24-hour average.

It is noted that the Canterbury Air Regional Plan already includes a policy that “In Clean Air Zones, reduce overall concentrations of PM_2.5 so that by 2030 those concentrations do not exceed 25µg/m³ (24-hour average) and 10µg/m³ (annual average)”.

It is unlikely, given the strong scientific evidence, that a lesser standard would be adopted. However, in such a case, it is noted that Councils can be more stringent than a national standard.

3.4 Options for Policy Direction

3.4.1 Option One: Status quo/Do nothing

Pros	Cons
No costs involved.	Loss of momentum, and potential to create confusion and impact buy-in from the community.
No risk of being inconsistent with potential future national direction.	Minimal improvement to air quality.
	Puts us on the back foot for when national direction eventuates.
	Ignores WHO Guidelines and HAPINZ 3.0 findings.

3.4.2 Option Two: Adopt PM_2.5 standard in principle, and undertake associated actions (early Bylaw review, Airshed Management Plan etc)

Pros	Cons
Provides clear direction for staff and the community on the future of the Airshed.	No national direction in legislation.
Minimal costs involved – just staff time and engagement materials. Rough estimate of $5000, which fits within the existing budget.	No driver for stronger rule changes (i.e. we are not putting it officially into policy).
Continued momentum of air quality improvements and consistent messaging to community – minimises confusion and maintains buy-in.
Early bylaw review (24/25 instead of 26/27) a quicker, more cost-effective approach to fixing some loopholes and making some small but important gains for reduction of PM_2.5(as opposed to a plan change). The bylaw is due for review in 2027 so is in our expected work programme, and as above, costs would fit within existing budget.
Ensures we are not on the back foot when national direction eventuates, and will not require massive policy change (e.g. plan change) to implement or rectify if direction ends up different than this proposed approach.
Rotorua Airshed Action Plan already reviewed and recommended a new Action Plan (“Management Plan”) be drafted, which was supported by S&P Committee at the 18^th August 2022.

3.4.3 Option Three: Adopt PM_2.5 standard into the Regional Natural Resources Plan and undertaken associated actions (as above plus plan change and new rules in Air Chapter of the RNRP)

Pros	Cons
Provides clear pathway for staff and community on future of Airshed.	No national direction in legislation.
Would provide driver for stronger rules (i.e. it’s adopted into policy).	Lengthy, costly process of a plan change. Rough estimate of at least $40,000 – likely much more on top of staff time. Not currently budgeted or included in LTP.
Ensures we are not on the back foot when national direction eventuates.	If it is prescribed in our plan, would then likely need to implement stronger rules, which would require funding to assist community make changes (e.g. phasing out older burners).
	Should national direction end up being different than included in the Plan, difficult to change.
	Plan change would be overly complex due to on-going s293 process (PC 13) in front of the Court, plus potential for a Mount Maunganui Airshed related plan change (PC 18).

3.4.4 Recommended Option

Option 2 (to adopt PM_2.5standard in principle and undertake associated actions) is the recommended option. As shown by the pros and cons above, this option strikes the right balance of justified action that will enable some progress and better health outcomes for our community, while still being somewhat precautionary, and fitting within existing budgets.

Additionally, this option was supported by the Rotorua Air Quality Working Party (RAQWP). At the latest RAQWP meeting in March, Rotorua Lakes Council (RLC) indicated that they would support an early review of the Bylaw in principle, but need to gauge their staff capacity before fully committing. We are working to provide further information to them to help them understand what the review would entail, noting that the Bylaw is fully administered and enforced by BOPRC, and the last review was undertaken completely by BOPRC. It is expected that this would continue.

4. Next Steps

As detailed earlier, there is currently no indication or certainty when central government will progress the proposed amendments to the NESAQ (which were consulted on in 2020). The last update we had from MfE was that they were going to be briefing new Ministers in April/May regarding Air Quality. Staff will advise the Committee of any updates on this matter.

The next steps are to continue with our business-as-usual work programme, including collecting more information to help us better understand exactly what actions would be required to meet any potential new PM_2.5 standards. We are also continuing to engage with RLC to ensure their support for the bylaw review and other actions.

Staff will then bring this matter back to the Committee for approval at the earliest possible opportunity.

Attachments

Attachment 1 - Rotorua Airshed - Policy Update (Rotorua Air Quality Working Party Report 8th March 2024) ⇩


Informal Workshop Paper
To:	Strategy and Policy Committee Workshop
	21 May 2024
From:	Mark Hamilton, Senior Policy Analyst
	Namouta Poutasi, General Manager, Strategy and Science

Mount Maunganui Airshed: Management Plan – scope and process; PC13 (Air Quality) – Unsealed Yards update.

1. Purpose

The purpose of this report is to provide an update on Plan Change 13 (Air Quality) – Unsealed Yards (PC13 – Unsealed Yards) and seek feedback on the direction of a proposed Mount Maunganui Airshed management plan.

2. Guidance Sought from Councillors

Staff are seeking feedback on the scope (PM10, or and odour or and other contaminants), process (brief, broader, or similar to a plan change) and timeframes (1-5 years) of a proposed Mount Maunganui Airshed management plan.

3. Discussion

3.1 Background

Plan Change 13 (Air Quality) (PC13) has been under appeal to the Environment Court since 2019, due to several matters relating to Bulk Solid Material (BSM) handling in the Mount Maunganui Airshed (the Airshed). A frequent side-effect of BSM handling is the discharge of coarse particulate matter (PM10), which is monitored nationwide due to its health implications.

As part of the PC13 appeal, the Court also looked more closely at other sources of PM10 within the Airshed. The Court noted in its first Interim Decision for PC13 that unsealed yards were the largest unmanaged anthropogenic source of PM10 within the Airshed. It consequently directed Council, under s293 of the Resource Management Act 1991, to amend PC13 to control emissions from unsealed yards. This process is variously referred to as PC13 – s293, or PC13 (Air Quality) – Unsealed Yards.

There were two additional outcomes of the PC13 appeal:

1) The Court directed Council to include an additional new policy, Policy 12, in the plan. Policy 12 manages activities which discharge PM10 in the Airshed and requires an iterative approach to improve air quality.

2) The Court ‘strongly recommended’ that Council prepare an airshed management plan (AMP) to ensure the objectives of PC13 are achieved as efficiently and effectively as possible. A discussion about an AMP follows in section 3.1.2, below.

Policy 12 and PC13 - Unsealed Yards have evolved separately from the PC13 appeal, but both processes are being run simultaneously and involve informal consultation, a formal submissions process and an Environment Court hearing. The key dates are noted in the table below:

Date	Process/Action
November – December 2023	Informal consultation with affected parties
15 January 2024	Notify for submissions: · Proposed provisions PC13 - s293 (limited notification) · Policy 12 (public notification)
30 April 2024	Submissions close
May 2024	Proposed provisions sent to Environment Court
June 2024	Environment Court hearing
Late 2024?	Environment Court decision

3.2 PC13 – Unsealed Yards and Policy 12 Update

By the close of the formal submission period, 11 submissions had been received. Four submissions were for Policy 12, three for PC13 - s293 while the remaining submissions addressed both topics. Nine of the 11 submitters indicated that they wished to be heard.

Council staff will now send the Court a summary of submissions and the proposed provisions, incorporating changes made because of submissions. The Court hearing is due to be held in June. Council staff will keep the Committee updated on PC13 – s293 and Policy 12 as they progress through the Court process.

3.3 MMA Airshed Management Plan (AMP)

While the Court has “strongly recommended” (and not “directed”) Council to prepare an AMP, Council staff believe that the Court’s recommendation should be followed, as it will allow key affected parties to assist with the development of this air quality management document.

The Court has specifically identified Ngāi Te Rangi, Toi Te Ora, and “affected industries and other affected parties” as necessary participants in the preparation of an AMP. However, staff need the Committee’s guidance to direct the development of the AMP.

Staff believe that the following key matters need to be decided at the very beginning of the AMP process:

3.2.1 Scope

The Court’s focus throughout the PC13 appeal has been on PM10, but PC13 objectives have a wider scope than just PM10 (AIR-O1 and Air-O3 refer more broadly to contaminants discharged to air). Furthermore, the community has other concerns such as odour, which is reflected in Pollution Hotline statistics, as well as other contaminants. In addition, the 2022 Health and Air Pollution in New Zealand report focuses on Nitrogen Oxides (NOx) and PM2.5. Should the AMP’s scope extend beyond odour to include any other contaminants?

3.2.1.1 Option One: PM10 only

Pros	Cons
Lowest cost.	Precludes contaminants other than PM10.
Quickest option to introduce.	Disregards concerns of community, especially in relation to odour.
MMAQWP involvement may allay community and submitter fatigue in light of other recent and current air quality projects in/around the MMA.	Disregards full breadth of PC13 objectives.

3.2.1.2 Option Two: PM10 and odour only

Pros	Cons
Minimal costs involved.	Excludes contaminants other than PM10 and odour.
Second quickest option to introduce.	Disregards concerns of community in relation to contaminants other than PM10 and Odour.
Greatest source of community complaint is addressed.	Disregards full breadth of PC13 objectives.
MMAQWP involvement may allay community and submitter fatigue in light of other recent and current air quality projects in/around the MMA.
Includes contaminants able to be controlled by Council.

3.2.1.3 Option Three: PM10, odour and other contaminants

Pros	Cons
Includes contaminants other than just PM10 and odour.	This option has the greatest cost.
Acknowledges concerns of community in relation to contaminants other than PM10 and Odour.	Slowest option to introduce.
Considers full breadth of PC13 objectives.	An extended process runs risk of submitter or community fatigue in light of other recent and current air quality projects in/ around the MMA.
	May refer to contaminants from sources that Council is unable to control (i.e. vehicle and shipping emissions of NOx and SO2).

The costs to Council of formulating any of the above three options for an AMP are likely to be largely restricted to the staff time to carry out the background work to develop the plan. As such, all options can be considered in scope of current budgets.

3.2.2 Process

Should the AMP undertake a quasi-plan change type process with consultation, notification, feedback, a hearing, deliberation then a decision? Or should the process be shorter and have the Mount Maunganui Air Quality Working Party (MMAQWP) recommend the acceptance of the AMP to Council (which is what happened with the Rotorua Air Quality Working Party and the Rotorua Air Quality Action Plan).

Staff note that, in addition to Plan Change 13, there are a number of other recent projects that have been undertaken, or which are underway, with public involvement and at least some kind of reference to industrial processes or industrial discharges in the Mount Maunganui industrial area. Tauranga City Council’s Mount to Arataki Spatial Plan (incorporating the Mount Industrial Planning Study), and Priority One’s Mount Maunganui Industrial Blueprint may intersect in places with a Regional Council-prepared AMP.

As such, when these projects are considered in addition to recent notified air discharge resource consent hearings, there is some staff concern that there may be submitter fatigue in relation to being asked to contribute time and expertise to a further air quality initiative. Conversations staff have had with some affected parties speak of a frustration that there is a lot of talk about requiring industry to improve air quality but not a lot of success in achieving it, and that their submissions have been in vain.

Possible options for the process are:

i) Brief consultation and MMAQWP interim approval only

ii) Broader consultation process and MMAQWP interim approval only

iii) Quasi-plan change: broad consultation, Council hearing and deliberation

As the breadth of the AMP process increases, consequently there are greater requirements and costs, such as for staff input for matters such as undertaking consultation and hearing preparation. All such inputs result in a longer, more costly AMP process.

3.2.3 Timeframes

The time required to prepare an AMP depends on the matters above. The broader the scope of the AMP, the more time and resources it will require. This demand for time and resources is mirrored for processes which are more collaborative, or which have a full hearings process.

Possible timeframes for an AMP:

i) Narrow scope with PM10, brief consultation: 1 - 2 years

ii) Broader scope with PM10 and odour, broader consultation: 2 – 3 years

iii) Broadest scope and consultation, Council hearing: 3 – 5 years

Given the indicative timeframes for each of the options, and the fact that the preparation of the AMP would need to work in with the ongoing PC13 - s 293 process, the AMP could take several years to prepare, depending on which options Councillors prefer.

3.2.4 Financial implications

The highest cost to Council of any of the above options for an AMP is likely to be the staff time to carry out the background work to develop the plan. However, as the breadth of the AMP process increases, consequently there are greater requirements and costs, such as for staff input for matters such as undertaking consultation and hearing preparation. In addition, a wider scope would likely incur costs related to scientific input, particularly for contaminants other than PM10 and odour. All such inputs result in a longer, more costly AMP process.

4. Staff Recommendation

To take the Committee’s feedback on the Scope, Process and Timeframes for an AMP, compile a draft AMP project outline and bring it back to Council for approval at the earliest opportunity.

5. Next Steps

S293 – Unsealed Yards and Policy 12: Staff will report back with developments from s293 Court hearing at the August Committee meeting.

AMP: Following the discussion in this workshop, staff will record the Committee’s preferences (and note any additional analysis they may require) and bring back a draft project outline for approval at the earliest opportunity.


Informal Workshop Paper
To:	Strategy and Policy Committee Workshop
	21 May 2024
From:	Nassah Rolleston-Steed, Policy and Planning Manager
	Namouta Poutasi, General Manager, Strategy and Science

Update on Proposed Change 8 (NPS-HPL)

1. Purpose

Provide a progress report on Proposed Change 8 (NPS-HPL) to the Bay of Plenty Regional Policy Statement (RPS) to implement the National Policy Statement for Highly Productive Land (NPS-HPL) and seek advice on whether to pause this project.

Key updates include:

· Draft RPS highly productive land maps have been developed and are on Council’s website (link);

· Targeted consultation with iwi, territorial authorities and industry groups commenced in August 2023;

· Specific issues for iwi and Māori owned land have been identified; and

· MfE have informally indicated the NPS-HPL is currently being reviewed as a result of new government work programmes.

Due to uncertainty about changes to the NPS-HPL, particularly the likelihood of removing LUC class 3 land from the definition of highly productive land, staff seek advice about whether to put on hold any further work on developing Proposed Change 8 (NPS-HPL).

This project is arguably not as high a priority as the Essential Freshwater Policy Programme, and the RPS already contains rural growth management provisions highly aligned with policy direction in the NPS-HPL. In the interim, staff are continuing to:

· respond to stakeholder, iwi/hapū/Māori landowner and community requests to meet; and

· contribute to regional sector discussions aimed at ensuring a nationally consistent approach to implement the NPS-HPL.

2. Prior Strategy and Policy Committee Reporting

The NPS-HPL implications were workshopped with this Committee on Tuesday 28 March 2023. In particular, the requirement to change the RPS to include maps of highly productive land (HPL) in the region.

At its meeting on 16 May 2023, this committee approved the formal commencement of Proposed Change 8 (NPS-HPL). That approval included the process and timeframes set out in the project plan and communication and engagement plan. That involved commencing region wide consultation with tangata whenua, territorial authorities (TAs), and key stakeholders.

Attachment 1 to this report provides detail on:

1. NPS-HPL requirements and associated implementation timeframes;

2. Consultation to date on Proposed Change 8 (NPS-HPL);

3. Komiti Māori submission on changes being considered to NPS-HPL;

4. Draft RPS highly productive land maps;

5. Implementation challenges;

6. Notification timeline for Proposed Change 8 (NPS-HPL); and

7. NPS-HPL Review by MfE and MPI.

3. Next Steps

Wait for confirmation of changes to the NPS-HPL before considering next steps. Staff will report to the Strategy and Policy Committee once the NPS-HPL changes are confirmed. That report will provide amended project process and timeframes to give effect to the amended NPS-HPL. In the interim staff will continue to respond to requests for information and hui from persons who wish to discuss Proposed Change 8 (NPS-HPL) and continue to contribute to regional sector discussions. Deferring NPS-HPL implementation will result in efficiency savings under the Policy and Planning 6113 Regional Policy Statement budget.

Attachments

Attachment 1 - Body of report ⇩

Attachment 2 - Komiti Maori submission on NPS-HPL 26 October 2023 ⇩

[1] Data storytelling communicates a data-derived message. This may or may not, be visual. Data visualisation presents data visually. This may or may not, tell a story (Kat Greenbrook, Rogue Penguin).

[2] The dependency ratio gives the number dependents (children aged 0-14 and adults aged 65+ years) per 100 working age adults (15-64 years). A high dependency ratio indicates that the working population faces a greater burden support the dependent population.