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@@ -11,6 +11,10 @@ devolved approach to environmental assessment brought about.
\subsection{The quality of assessments}
+Applicants of resource consents are required to produce ...
+The RMA requires an Assessment of Environmental Effects (AEE) to be
+prepared for every activity
+
- poor environmental models / baseline => precautionary principle
\textcite{practitioners}
@@ -64,14 +68,11 @@ information; failure to influence the decision-making process; poor
execution of participation methods; and regulatory constraints. As a
review of resource consent processing performance in New Zealand
indicates, especially the latter three are significant obstacles to
-public participation in New Zealand. According to the 2010/11 survey
-of local authorities the New Zealand Ministry for the Environment
-carries out every two years, only about 6 per cent of all resource
-consents were notified in some way, with only 4 per cent being
-publically notified \parencite{rma-survey}. This means that of 36,154
-resource consents that were processed across the country over a period
-of two years, the public was able to provide input on only 1,414
-proposals.
+public participation in New Zealand \parencite{TODO}. According to the
+2010/11 survey of local authorities the New Zealand Ministry for the
+Environment carries out every two years, only about 6 per cent of all
+resource consents in the two-year period were notified in some way,
+with only 4 per cent being publically notified \parencite{rma-survey}.
- opportunities for public involvement?
- limited opportunity for the public to influence decisions
@@ -80,26 +81,41 @@ On the other hand, public participation ... leads to abuse, slow process miller2
-\subsection{Issues associated with devolution}
+\subsection{Cumulative effects}
What sets apart New Zealand's approach to environmental assessment
-from those of other countries is the devolved mandate, meaning that
-most resource consents are processed at the lowest level of
-governance, by district or city councils.
-
-- cannot deal well with cumulative effects, because that's best done
- on a national/regional level \parencite{eia-state-of-the-art}
-
-- \textcite[p 267]{furuseth}: little experience or resources to
- scrutinise EIA on the local level
+from those of other countries is the devolved mandate. The
+distribution of responsibilities to the local levels of government,
+however, brings about difficulties in effective environmental
+management. Project-level EIA usually does not address cumulative
+effects well, i.e. individual minor effects of several projects that
+result in serious impacts when combined, because this would require
+regulation and monitoring at a higher
+level \parencite{eia-state-of-the-art}.
+
+When resource consent applications are processed independently from
+one another at the local level, their aggregate cumulative effects are
+easily overlooked. Although the RMA specifically includes cumulative
+effects in the definition of effects that have to be considered
+(Section 3), it is still up to the council to review an AEE with
+regards to cumulative effects. The quality of this review crucially
+depends on the experience and the resources available at the local
+level to scrutinise an AEE that may not properly address cumulative
+effects \parencite[p 267]{furuseth}. A joint hearing process has been
+used in the past to successfully overcome this limitation for
+individual projects that require multiple resources consent
+applications to be considered \parencite{fookes}.
+
+When the cumulative effects of more than one proposal are to be
+considered, ... need coverage by plan/policies at national/regional
+level + monitoring.
+
+% This is one of the reasons for the birth of Strategic Environmental Assessment.
- very slow publication of NPS and NES at the national level
\textcite{miller2010implementing}
- hence: few constraints on local plans, leading to regional differences
-
-\subsection{Monitoring and follow-up work}
-
- insufficient monitoring (68\%) \parencite{rma-survey}
- one-off projects that don't improve the knowledge basis or affect