- 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.

- upward trend: number of objections against consent decisions (see
  section 2.10)\parencite{ME1069}

- side agreements: applicants can buy consent by paying directly
  affected people, incurring poor environmental outcomes for the
  community or future generations. \parencite{PCE1998}


  \begin{quote}
    The environmental risks associated with side agreements depend on
    the council’s knowledge and treatment of any contractual
    arrangements by consent applicants. Good practice by the consent
    authority can help to minimise these risks. For example, where a
    private agreement does not necessarily result in effects on the
    environment being mitigated, consent authorities should impose
    appropriate conditions to mitigate these effects.
  \end{quote} \parencite[][p 9]{PCE1998}


- wider example may be the golden link mine where the applicant
  promised to do unrelated work for the community to secure approval

- 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]
 



% TODO: split assignment into Theory / Legislation and Implementation