Boffa Miskell's submission on the Natural and Built Environment Bill

1 March 2023

Our submission focused on the need for improved recognition of the features and characteristics that contribute to the quality of the urban and natural environment.

Our submission acknowledged and generally supported the primary function of the Natural and Built Environment (NBE) Bill, and the accompanying Spatial Planning Bill, including:

The creation of an integrated framework for regulating environmental management and land use planning, and to provide for the development and implementation of long-term, strategic spatial planning across Aotearoa.

The approach of identifying system outcomes to guide national direction, strategies and plans, which will in turn guide consideration of resource consent applications.

The ongoing protection of places of national importance, including outstanding natural landscapes and outstanding natural features.

While we agree with the outcomes identified in the NBE Bill, Boffa Miskell considers that greater recognition of the urban environment and natural environment as a whole — beyond those identified “outstanding” areas that have explicit recognition and protection in the Bill — is needed within the framework of new 'system outcomes'.

"We think it's important to recognise the value in protecting and enhancing the quality of everyday landscapes," says landscape architect Rachel de Lambert, Technical Lead for Urban Design.

"Our submission seeks improved recognition for the features and characteristics that contribute to the quality of the urban and natural environment and, by extension, the well-being of the people who live there."

Boffa Miskell understands and supports the intentional shift away from consideration of amenity values generally, given the focus on preservation of existing amenity in RMA processes by those seeking to maintain the status quo.

We recognise that under an outcomes-based system, change is anticipated; and the purpose of our submission is to bring greater focus to the quality improvements needed to facilitate change.

"The change we suggest is inclusion of a new system outcome, originally recommended by the authors of Randerson Report: to improve the quality of the natural and built environment," says Technical Lead for Planning, Chris Ferguson.

"In an urban context people will be drawn to new development if they provide an improvement over the status quo. Without recognising and providing for that, there's a risk the bill could lead to degraded quality of environments in urban and rural areas."

Boffa Miskell's submission suggested the insertion of a new clause:

5(a) Enhancement of features and characteristics that contribute
to the quality of the natural and built environment to
support the well-being of people and communities.

Rachel de Lambert and Chris Ferguson presented to the Environment Select Committee on Monday 27 February.

Read the full submission here.