NZILA submission on the Proposed National Policy Statement for Renewable Electricity Generation [2023] (NPS-REG); Proposed National Policy Statement on Electricity Transmission [2023] (NPS-ET); Proposed National Environmental Standards for Electricity Transmission Activities (NES-ETA); and Proposed National Environmental Standards for Renewable Electricity Generation (NEW-REG).

The Government opened consultation on proposals to strengthen direction for consenting renewable electricity infrastructure under the Resource Management Act 1991 (RMA). Updates are proposed to national direction for renewable electricity generation and electricity transmission for consistency with Aotearoa New Zealand’s emissions reduction targets and support the pace of development required to decarbonise the economy. The proposals are being developed separately to the wider resource management reforms and aim to support council decision making by providing clearer direction on the need to significantly increase renewable generation to meet New Zealand’s international climate commitments.

NZILA were invited to attend a workshop outlining the proposals on
4 May 2023. The current proposals include:

• Providing for the national significance of renewable electricity generation and electricity transmission
• Creating consent pathways where there are potential adverse effects on significant environmental values, by proposing to provide clear tools for assessing the suitability of renewable electricity infrastructure where there may be impacts on outstanding natural landscapes and features, the natural character of coastal environments, areas or habitats of significant indigenous biodiversity and historic heritage
• Better enabling renewable electricity and transmission where there are potential adverse effects on other areas, including effects on local amenity
• Proposing to enable renewable electricity generation activities where there may be adverse outcomes on areas such as noise, shadow, glare, or effects on the character of the area provided these effects are avoided, remedied or mitigated where practicable
• Recognising and providing for Māori interests
• Upgrading and repowering existing wind and solar generation
• Providing for small and community scale renewable electricity generation

Improving the workability and scope of the national environmental standard for electricity transmission activities.

The NZILA supports the Government’s commitment to achieving net zero carbon emissions by 2050 by achieving: a target that 50% of total energy consumption in Aotearoa New Zealand will come from renewable sources by 2035; and the aspirational target of 100% renewable electricity generation by 2030. This intent aligns and is consistent with the NZILA’s adopted Climate Action Policy, which ratifies the International Federation of Landscape Architects’ Climate Action Commitments.

We want to thank the working group of NZILA members who reviewed the proposals and prepared the attached submission.

Lead Authors:
Emma McRae, Peter Kensington, Alan Titchener.

Key Contributors:
Stephen Quin, Rhys Girvan, Bridget Gilbert, Shannon Bray, Di Lucas, Rachael Annan, Clive Anstey, Sally Peake, Paul Smith.

The submission document suggests that, while we understand the intent behind the Government’s focus on strengthening the national direction on renewable electricity generation and transmission under the Resource Management Act 1991 (RMA), through proposed changes to the current national policy statements for renewable electricity generation and transmission to provide a consenting process that is more efficient, certain and environmentally sustainable; the NZILA should not fully support the currently drafted proposed changes. The working group believe it will be important to ensure that the direction for energy and transmission is compatible with the direction for Outstanding Natural Landscapes and Features (ONFL) protection and enhancement. The current proposals reflect well the direction for protection and enhancement of Significant Natural Areas (SNAs), however direction around ONFLs and landscape values is less clear. Our submission therefore focusses on the recognition of landscape character and values throughout the proposed legislation.

Further information about the proposed changes is available here.