Natural and Built Environment Bill: NZILA submission
What precisely does the word environment mean? The NZILA believes it needs to be clearly defined in the proposed Natural and Built Environment Bill if the new legislation is to be successful.
A team of volunteers working on the Institute’s submissions on the bill’s exposure draft focused on key principles including providing definitions for “environment” and “landscape.” Lead author Shannon Bray says “the more you define what you’re talking about the less scope there is for disagreement over methodology”
And in terms of that he says the NZILA is well placed to advise the Government, having already been through the exercise of creating Te Tangi a te Manu: The Aotearoa Landscape Assessment Guidelines.
“When the team worked on Te Tangi a te Manu, they really nutted out our methodology, our approach to how we do things,” Bray says. “And so we wanted to take the same approach with our submission. We said it’s important that the definition outline that environment is a combination of factors, as well as being clear on what those factors are, how they inter-relate, people relate to them, and how they change over time.”
Bray says that the proposed legislation considers environment too simplistically, with an inherent focus on only natural and urban environments. “We recognised that we needed to outline how the environment around us cannot be separated into distinct parts – it is holistic and includes people within it. And it is everywhere, from our mountains to the sea, including rural and coastal environments.”
He says members were also very keen to underline the intrinsic link between environment and landscape, with Dennis Scott defining it as “landscape is the way in which we as people interpret the environment”. The submission therefore includes a definition for landscape that aligns with the concepts and definitions in Te Tangi a te Manu.
Bray says “we felt it important to ensure these concepts were firmly rooted into the legislation, as they would provide greater understanding and clarity about the outcomes sought.” In this way, Bray suggested the definitions would lead to improved efficiencies through the environment planning process.
Another key submission centred on the inclusion of landscape as an outcome. “We’re very aware that the Government wants to remove the term amenity from the new legislation. We understand that – amenity has been criticised as being too subjective and too open to opposition.”
However, the link between the quality of the environment and wellbeing can’t be overlooked, he said. Nor can the inextricable link between quality landscape outcomes and quality of life.
“Landscape is everywhere, all around us. It influences every aspect of our lives, our decisions and choices. It defines who we are and where we are from.
“Mountains, forests, big lakes etc are the bottom line, they’re a must do, you have to protect them. But you have to consider everything else too. We have to positively manage the environment around us for our own wellbeing and survival. We have therefore sought to move Outstanding Natural Landscapes and Outstanding Natural Features into the Environmental Limits section of the Bill, and introduce all landscape as concept into the Outcomes section.”
In addition, Bray says the institute would like a better balance of Te Ao Māori outcomes in the new legislation, noting that landscape architects are leaders in helping other professions to really understand how to explore the Māori world view.
“The way Māori and Pākeha work together in a framework is interesting because the way that New Zealand operates, the very fact that there’s a law, is a very European construct. Māori tend to work through respect and agreement on principles, and so tying the two together can be challenging.”
It’s not just mountains and lakes that need protecting, but all landscapes, the institute says. Photo credit: Ketan Kumawat from Pexels.
“A good example of that is the Whanganui river. If you ask many Pākeha what the Whanganui River was they would likely talk about the water flowing down from the hills to the sea. However, if you asked mana whenua to describe Whanganui River they would likely describe a person who is part of their whanau, their history, and their values.”
However, this had been a challenge for NZILA in writing Te Tangi a te Manu. Bray gives credit to the authors who worked with Te Tau a Nuku to find common ground and common principles, finding a mutually inclusive way to work across cultures. He considers that the proposed legislation could achieve similar outcomes.
“At its core”, Bray says “the RMA was about managing the environment as a resource rather than considering a holistic view. We have an opportunity with the new legislation to change this focus, to find ways to work together with aligned outcomes. Te Tangi a te Manu has shown us that such an approach is possible.”
The institute is also asking the select committee to reconsider the name of the legislation to include Māori, favouring something that encompasses environment more holistically, such as Taiao.
“As landscape architects we don’t think you can separate natural and built, they’re constructs that overlap so much, along with the rural environment. We think a more holistic name, potentially a Māori term, will be more inclusive and reflect that, in our view, it’s legislation for the whole environment.”
Submissions will be considered by a select committee over the next few months, with a revised draft of the legislation released later in the year.
The NZILA members who worked on the submissions were: Clive Anstey, Shannon Bray, Stephen Brown, Brad Coombs, Grant Edge, Bridget Gilbert, Rhys Girvan, Peter Kensington, Di Lucas ONZM, Rebecca Ryder, Dennis Scott, Kara Scott, Kerstie van Zandvoort, Julia Wick.