Thematic Analysis
In PC49 and 61, a significant gap is evident in the implementation of comprehensive stormwater management strategies, highlighting the underutilisation of integrated knowledge and solutions. This emphasises the need for a unified approach to stormwater planning and management in greenfield developments.
While the SMPs included in the PC documents received approval from Auckland Council’s technical experts, inconsistencies remain in how these proposed frameworks align with broader stormwater planning objectives. The concerns regarding the planning rule framework in PC61 reveal a fundamental misalignment with integrated stormwater management practices. This misalignment highlights the need for coherent planning provisions to ensure effective, catchment-based stormwater solutions that meet desired outcomes and mitigate the risks associated with fragmented planning approaches.
A significant risk associated with uncoordinated stormwater planning arises when flood assessment and risk management are deferred until the resource consent phase. This often leads to the implementation of multiple, small-scale stormwater management devices that lack coordination and integration, resulting in ineffective stormwater management and heightened flood risks. Such an approach not only restricts development opportunities but also fails to consider the broader implications and cumulative impacts of various projects on the catchment’s receiving environment. The following statements from the applicant and Auckland Council reinforce this perspective.
Applicant’s perspective:
“The integrated stormwater management strategies proposed in PC61, while initially deemed sufficient, have been questioned due to their limited scope and lack of comprehensive integration with broader urban planning objectives.” — PC61
“Recognizes the need for an integrated stormwater management approach through the Drury East Stormwater Management Plan (“SMP”), which aligns with the NDC objectives and employs the Best Practical Option (“BPO”) as demonstrated through the SMP and Stormwater toolbox approach.” — PC49
Auckland Council’s perspective:
“Concerns have been raised regarding the adequacy of the stormwater management provisions in the proposed plans, particularly their ability to effectively address cumulative impacts on the catchment area. This highlights the need for a more integrated approach that transcends individual development assessments.” — PC61.
“Key stormwater issues include the lack of analysis on alternative flood management approaches and uncertainty regarding their delivery, indicating a clear need for integrated planning and execution.” — PC49.
“The NDC and relevant SMP are insufficient on their own to ensure that outcomes are achieved in greenfield development. Precinct provisions are essential to guide development design and apply appropriate controls to development and subdivision to achieve NDC outcomes and effectively manage stormwater impacts.” — PC49
This highlights the applicant’s commitment to aligning proposed stormwater practices with existing regulatory frameworks, such as the Network Discharge Consent. However, it is essential to emphasise the need for a multidisciplinary approach that integrates ecological, planning, and engineering knowledge to achieve cohesive outcomes. Auckland Council underscores the importance of addressing cumulative impacts across the catchment, rather than focussing solely on isolated, site-specific solutions. This approach reflects the necessity of combining expertise to understand system-wide interactions and mitigate risks. The lack of coordination among various disciplines and stakeholders often leads to fragmented stormwater strategies, as seen in the inconsistent implementation of small-scale stormwater devices during resource consent phases. By harnessing expertise from different fields, we can gain a more comprehensive understanding of the hydrological, ecological, and urban development contexts.
Ambiguities in policy language and differing interpretations present considerable challenges in implementing effective stormwater management practices. These issues stem from the absence of clear development guidance within the proposed planning objectives and policies, as well as often ambiguous and contradictory directives from regulatory bodies. For instance, vague terminology in policy language, such as “any approved NDC,” complicate policy interpretation. PC49 highlights the dissatisfaction and disagreements among applicants concerning the policy directives from the Healthy Waters Department at Auckland Council, particularly in relation to the Network Discharge Consent requirements for stormwater management.
Applicant’s perspective:
“We have encountered considerable challenges due to ambiguous policy language, especially regarding interpretations of what qualifies as 'any approved NDC', which varies greatly among different council departments.” — Applicant Submission, PC61
This statement highlights the applicant's difficulties with inconsistent policy interpretations across council units. Ambiguities in terms like "any approved NDC" lead to operational delays and confusion.
“The proposed policy does not sufficiently allow for flexibility in achieving water quality outcomes, which is crucial given the variable nature of stormwater contaminant sources across different sites." — Applicant Technical Evidence, PC49
Auckland Council’s perspective:
“There has been ongoing confusion and inconsistency in the application of policy language, particularly concerning stormwater management requirements under the NDC. This inconsistency limits our ability to provide clear guidance to developers.” — PC61.
“The requirement for water quality treatment of all runoffs from impervious surfaces unless an alternative Best Practicable Option (BPO) is demonstrated in a Stormwater Management Plan and approved by Healthy Waters...” — PC49.
“This includes a privately built network seeking to connect. If no SMP is adopted, or Healthy Waters does not accept developer-built stormwater devices for vesting in Council, then a private discharge consent is required...” — PC49.
These excerpts highlight a rigid and prescriptive approach that may not adequately address site-specific needs, or the innovative solutions proposed by developers.
This situation points to a broader issue within the existing policy framework; its rigidity often leads to varying interpretations and conflicting viewpoints among technical experts, planners, and decision-makers. Such discrepancies can impede the effective implementation of catchment-based solutions. To address these complexities, it is crucial to develop essential to create policy frameworks that are both clear and adaptable, ensuring a consistent understanding among all stakeholders while accommodating the diverse needs of development projects and allowing for flexibility in successful catchment-based stormwater management. Policy ambiguities and rigid interpretations can intensify conflicts between developers and regulatory authorities, obstructing the adoption of adaptive stormwater practices. This highlights the importance of establishing clear, flexible policies to foster alignment among stakeholders.
The tension between regulatory compliance and the adoption of innovative stormwater solutions is evident in PCs 49 and 61. Developers are seeking flexibility in using alternative stormwater management devices, while council authorities emphasise the importance of adhering to established guidelines to mitigate environmental risks. Effectively navigating the complex regulatory landscape and addressing the technical specifics of stormwater management is essential for planning sustainable systems. This situation highlights the challenges of implementing precise stormwater management practices, selecting appropriate management devices, and planning necessary infrastructure upgrades. PC61 underscores the need to carefully consider technical constraints and cumulative impacts. Conversely, PC49 reveals ongoing discussions about compliance with existing stormwater guidelines set by regulatory authorities, alongside developers' preferences for what they consider the best practicable alternative devices.
Applicant’s perspective:
“The technical guidelines provided by the council often do not align with the innovative approaches we consider best for practical stormwater management, leading to frequent discrepancies in project execution.” — Applicant, PC61
This statement from the applicant highlights a recurring challenge: the gap between regulatory standards and the evolving technologies in stormwater management.
“The proposed policy does not adequately allow for flexibility in achieving water quality outcomes, which is essential given the variable nature of stormwater contaminant sources across different sites.” — Applicant, PC49
Auckland Council’s perspective:
“It is crucial that all stormwater management devices and practices comply strictly with our established guidelines to prevent potential long-term environmental impacts, which some proposed alternatives by developers may not adequately address.” — PC61.
“This includes a privately built network that wants to connect. If no SMP is adopted, or Healthy Waters does not accept developer-built stormwater devices for vesting in Council, then a private discharge consent is required…” — PC49
Auckland Council reaffirms its commitment to established technical guidelines, highlighting the challenges of integrating innovative or site-specific solutions within existing regulatory frameworks.
The gap between council standards and developer innovations underscores the importance of early collaboration to ensure technical compatibility. Without this alignment, developers may have to seek private consents, which can complicate the planning and implementation process. The review of these plan changes emphasises that clarity and consistency in regulatory guidance from the beginning are vital for achieving sustainable stormwater management outcomes. Any ambiguities or inconsistencies in this guidance or policies could raise concerns about the long-term validity of proposed stormwater management solutions. Therefore, it is crucial to establish clear and consistent directives from regulatory authorities early in the development process to effectively guide the planning and implementation of desired stormwater management outcomes.
A significant challenge identified in PCs 61 and 49 is the lack of consensus and effective collaboration among stakeholders, which is crucial for driving innovation and achieving integrated stormwater management outcomes. PC61 highlights both the benefits of stakeholder participation and the challenges that can emerge from these collaborations. These obstacles often hinder the implementation of comprehensive, catchment-based stormwater management strategies, despite considerable efforts to include diverse stakeholder perspectives.
In PC49, the differing views among stormwater management and planning experts are apparent. Some experts emphasise the importance of strict compliance with existing planning and stormwater regulations, while others advocate for exploring alternative stormwater management approaches. This division not only creates considerable barriers to innovation but also complicates the pursuit of integrated outcomes. Therefore, promoting consensus and flexibility among stakeholders is essential to support innovative practices in stormwater management.
Applicant party’s perspective:
“We understand the importance of engaging all stakeholders in the planning process to leverage diverse perspectives and expertise, which is crucial for innovative stormwater management. However, aligning these varied interests remains a significant challenge.” — Applicant Submission, PC61.
“We have actively engaged with stakeholders, including local iwi and community groups, to ensure our stormwater management plans are inclusive and reflect broader community interests. Nevertheless, differing stakeholder expectations regarding environmental outcomes and development pressures continue to create challenges in uniting everyone towards a common goal.” — Applicant Rebuttal, PC49.
This reflects the applicant's commitment to incorporating diverse viewpoints, especially those of mana whenua, into stormwater management planning.
Auckland Council’s perspective:
“While we advocate for strict compliance to ensure stormwater management meets environmental standards, we are also open to innovative approaches proposed by developers, as long as they align with our overarching water management objectives.” — PC61.
“The collaboration between various departments within the Council and external stakeholders, including the community, underscores the complexity of achieving consensus in the stormwater management process. Despite ongoing efforts, reaching a unified approach remains challenging due to differing priorities and interpretations of policies.” — PC49.
Auckland Council recognises the challenges in reaching consensus among diverse parties with differing priorities, especially in greenfield developments. While engaging stakeholder engagement is vital for effective stormwater planning, achieving agreement is often difficult due to conflicting priorities and varying interpretations of policy objectives. Developing better collaboration frameworks could help address these gaps and promote shared ownership of stormwater solutions. To tackle these challenges effectively, it is important to encourage a more inclusive dialogue that explores alternative strategies and approaches, thereby increasing the likelihood of comprehensive and integrated stormwater management solutions that receive broad support from all stakeholders.
This theme highlights the considerable challenges associated with a fragmented approach to stormwater management, which often leads to inconsistent and ineffective results. This approach tends to neglect the interconnectedness of stormwater systems, resulting in insufficient management practices and planning. Often, stormwater management issues are only addressed through individual resource consent applications after the proposed changes have already been implemented. This disconnected method does not account for the cumulative impacts of development on stormwater systems within a wider context, leading to suboptimal management outcomes.
Applicant party’s perspective:
“The current segmented approach to stormwater issues in resource consents does not adequately address the broader environmental impacts, often leading to unexpected challenges after implementation.” — Applicant, PC61.
“The proposed water quality treatment expands the requirements of Chapter E9 of the Auckland Unitary Plan, which targets High Contaminant Generating Areas, to include all roads and public car parks, ensuring they are treated in accordance with GD01, along with treatment of other impervious surfaces using a risk-based approach. While this represents an effort to comprehensively address stormwater effects, certain areas still experience a piecemeal application due to the phased nature of regulatory approvals.” — Applicant, PC49.
While this demonstrates an effort to implement consistent standards, it also reveals the fragmented nature of regulatory applications, which may fail to account for cumulative effects.
Auckland Council’s perspective:
“We must adopt a more integrated approach to stormwater management, transitioning from individual consents to a catchment-wide strategy that recognizes the cumulative impacts of all developments within the area.” — PC61. “Relying solely on assessments during the resource consent stage will lead to a fragmented approach to stormwater management across the plan change area, promoting disconnection rather than the integrated approach required in Chapter E1 of the Auckland Unitary Plan.” — PC49.
Auckland Council expresses concern over the tendency to address stormwater issues solely during the resource consent phase, as this approach hampers comprehensive catchment management.
“Assessing stormwater only at the resource consent stage increases the risk of disrupting the natural hydrology of streams and wetlands to facilitate development.” — PC49.
The current fragmented approach to stormwater management significantly impedes sustainable outcomes. By implementing catchment-wide strategies that emphasise long-term planning and cumulative impact assessments, councils and developers can better manage the interconnected nature of stormwater systems. Experts have been raised concerns about this piecemeal approach, as it can disrupt natural hydrological systems, increase risks to freshwater environments, and adversely affect receiving ecosystems. Furthermore, this method may result in hasty and poorly informed decisions that overlook broader catchment implications, ultimately compromising the long-term effectiveness of stormwater management solutions. To tackle these challenges, it is essential to move towards holistic, integrated, catchment-based strategies, particularly in greenfield developments. Focussing on long-term sustainability and effectiveness will lead to improved outcomes and ensure comprehensive consideration of stormwater management issues.
The findings and insights from this research, while specific to Auckland, New Zealand, are highly relevant on global scale. The challenges identified in implementing catchment-based stormwater management—including ambiguous regulations, fragmented policy frameworks, and the necessity for comprehensive stakeholder engagement—reflect urban planning issues encountered by rapidly urbanising cities around the world. A nuanced understanding of how socio-political, technical, and governance factors intersect to influence sustainable water management in greenfield developments provides a robust framework that can be adapted to various urban contexts. By applying the principles and strategies outlined in this research, urban planners, policymakers, and environmental managers in other cities can enhance their stormwater management practices, ensuring effective integration of catchment-based solutions into urban development. Thus, this study not only contributes to local discussions but also offers valuable insights that can inform the development of resilient, sustainable urban water management systems globally.