- general ideas taken from the readings:

  - EIA often done too late, so only options are mitigation or
    acceptance

  - economic benefits often outweigh environmental damages in
    decision-makers' eyes. This could be avoided with a limits-based
    approach / SEA.

  - councils may simply be too busy or understaffed to properly
    evaluate an application, especially when it is a complex
    application.  <---- KEY IDEA

----------------------------------------

- according to survey (section 2.8)\parencite{ME1069}, number of
  pre-hearing meetings (for notified applications) went down; also the
  number of successful pre-hearing meetings went down.

- councils are not capable of processing consent applications to the
  standards that are detailed in the plans:

  \begin{quote}
    It appears a substantial number of consents are being granted
    without clear or detailed information, due in part to pressures for
    time-compliance as commitment to economic growth [...] prevails over
    environmental protection and enhancement.
  \end{quote} [executive summary, xii / p 13]{confessions}


\parencite{practice}
- criticism from all sides:
  - developers don't like the additional compliance costs incurred
  - professionals:

    \begin{quote}
      Implementation does not appear to be progressing as it was
      envisioned, in an integrated fashion and by employing a range of
      policy mechanisms. Instead, economic decisions are made without
      consideration of environmental impacts and the quality of the
      environment is treated as a second tier policy objective after
      customer service delivery and economic efficiency. Maori values and
      concerns are not successfully incorporated into implementation
      programs and state-of-environment monitoring, a cornerstone of an
      effects-based framework, is still not a management priority.
    \end{quote} [Frieder, as quoted on page 6]

    \begin{quote}
      Planners have thus been subjected to criticism from all
      directions in relation to RMA implementation: they favour the
      developers, they obstruct the developers; they are unduly cautious in
      relation to legislative intent, they are not cautious enough; they are
      administratively cautious; they are administratively cavalier; they
      are environmentally conservative, they are not conservative enough.
    \end{quote} [p 8]