2017 lgma new zealand exchange final report · 2019-08-19 · 3.5 subdivision consent and the new...

2017 LGMA New Zealand Exchange Final Report

THE SUBDIVISION CONSENT REGIME UNDER THE

NEW ZEALAND RESOURCE MANAGEMENT ACT

Regina Sadilkova | Director of Development Services | Fall 2017

2017 LGMA Exchange Subdivision Consent under the New Zealand RMA

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Acknowledgements My exchange was a unique memorable privilege for which I express gratitude to LGMA for creating this opportunity. I appreciate and acknowledge the guidance and support from LGMA staff which made the exchange a pleasure.

I wish to thank my employer, the TNRD, and my CAO, Sukh Gill. Without his support for my application, I could not have benefitted from the learning experience that I was afforded in New Zealand.

My exchange partner and new friend, Liam Nolan, and Jan his personal assistant, were there for all my needs and persistent questions. Finally a thanks to Liam’s spouse, Julie and their children (pictured opposite with Liam), who invited me into their little corner of the world and made me feel like a part of their family, especially when we ran out of petrol on the wrong side of the Littleton mountains.


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Table of Contents page

1.0 Executive Summary 4

2.0 Introduction & Research Objectives 5

3.0 Subdivision in New Zealand

3.1 Subdivision Consent Legislation & RMA Structure 6

3.2 Planning Framework & Practice of Subdivision Consents 8

3.3 Regional Planning and Subdivision Consents 15

3.4 Agriculture Protection and Subdivision 16

3.5 Subdivision Consent and the New Zealand Environment Court 17

4.0 Broader planning-related matters 19

5.0 Learning from New Zealand

5.1 Lessons & Takeaways 21

5.2 SOLGM Annual Conference, 2017 Rotorua 23

6.0 Appendices

6.1 Research Methods & Interview Form 25

6.2 Resource Management Act Excerpts 27

6.3 Consent Application Process & Guide 46

6.4 Sample Subdivision Consent Letter 48

6.5 Sample Environment Court Hearing Summary 82


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Acronym Guide

BC British Columbia DP District Plan LGA Local Government Act, BC or New Zealand as the case may be LTA BC Land Title Act NZ New Zealand OCP Official Community Plan OIC Order in Council PLA Preliminary Layout Approval PLR Preliminary Layout Review RMA New Zealand Resource Management Act SFD Single family dwelling SOLGM Society of Local Government Managers

Photos and illustrations by author unless noted otherwise.


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1.0 EXECUTIVE SUMMARY At a glance, the New Zealand subdivision consent regime seems not far off that of British Columbia’s: we both have zoning; we establish policy via a statutory plan (District Plan in New Zealand/OCP in BC); we have an application process, review, and response through preliminary layout review/approval or a consent decision letter; then there is engineering, professional studies, development cost charges (called contributions in NZ), works and services, and so forth; and, finally, a survey is electronically deposited at a land title office. But from there, the two regimes diverge. They differ in the manner of the delegation of decision making, especially the reconsideration of any decision. It is local government as opposed to the Province that administers and controls subdivision in rural New Zealand. The basis of how policy or regulations are interpreted and waived or relaxed differs between BC and New Zealand. And New Zealanders have a distinct understanding of government authority versus property owners’ rights.

New Zealand’s lengthy and complex Resource Management Act 1991 governs ‘resource consents’ including subdivision consent. The Act enables a greater measure of discretion by both

1) elected officials who set the objectives, policies, and rules of development through a ‘District Plan,’ a kind of omnibus go-to policy and regulation planning document; and

2) planning staff who administer, negotiate, and approve sub-division via an involved ‘horse-trading’ process.

New Zealand has no independent quasi-judicial subdivision appro-ving officer who can be individually called to answer to a decision or make a call on public interest; instead, planning staff interpret the District Plan as a whole and arbitrate matters, including the notifications and variations that we leave to elected decision makers. There is no Agriculture Land Reserve to slow down the parceling off of farmlands especially in fertile valley bottoms near New Zealand’s urban centres. But New Zealand does share a regional district cooperation and consistently component to their planning, similar to that of our Regional Growth Strategies.

If a subdivision consent decision is appealed in New Zealand, it is typically heard and reconsidered by a qualified educated independent panel, again not an elected assembled body. And finally, New Zealand has a specialized Environment Court which adjudicates everything from resource consents, including subdivision, to statutory plans and appeals from applicants, staff, councils, or the neighbours of a given application. The court supports local government enforcement of regulations by issuing orders and assigning costs.

In summary, the New Zealand legislation and consent process is, in my opinion, far more onerous and comprehensive that that in BC. It is more demanding on staff and developers. As the General Manager of consents for Christchurch put it: “New Zealanders are very much aware of their obligations with respect to citizenship and their individual responsibilities.”

Central Christchurch Botanic Gardens


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2.0 INTRODUCTION & RESEARCH OBJECTIVES My LGMA exchange objective was to build upon my knowledgebase and interest in the regulation of subdivision and to critically examine how subdivision is administered in New Zealand - not only the legislative framework but also in practice and case law. I sought to understand what they see as their future challenges with respect to subdivision of limited agriculture lands near urbanized and desirable vacation areas. And finally, I asked about the interplay of professional decision-making in the political soup of local and regional (and in their case, national) government authority. This is neither a comprehensive survey nor rigorous academic study but I hope it is more than a pondering travelogue.

My paper commences by first setting out some New Zealand basics and context. Then I delve into more detail via the local governments which I researched and whose staff I interviewed. The paper includes asides which focus on issues particularly controversial and challenging in BC, specifically, subdivision of agricultural land, region/municipal relations, residential subdivision and efficient land use (i.e. sprawl control). Part 3 contains the key information and analysis pertaining to subdivision consent.

Part 6 includes five extensive appendices. Please refer to Appendix 6.1 for the research method and the interview form, noting that this form was a starting point and it was the critical discussion that followed my interviews that was often more interesting. I interviewed a total of eight staff across four local governments. A couple of the interviewees were kind enough to allow follow up sessions after the initial interview. For me, it was a two week crash course in consents and the Resource Management Act (RMA) with a conference tagged on at the end. A postscript with the highlights of the 2017 SOLGM annual conference is inserted as Part 5.2.

While some of the appendix content is publicly accessible or available on line, it is attached for ease of reference should these documents be of interest to readers. Researching legislation and ministerial or local government information is obviously necessary, but it is actual subdivision applications and consents that make for more interesting reading. You can find a New Zealand subdivision consent letter in Appendix 6.4 (page 48). They provide a fulsome understanding of how subdivision consents are conducted in practice.

My report concludes with Parts 4 & 5, a collection of planning related observations & lessons learned. Readers less interested in technical subdivision, may prefer to skip to pages 19 to 22.

Photos of downtown Christchurch, still visibly and economically impacted by the earthquakes of 2010 & 2011.


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3.0 SUBDIVISION IN NEW ZEALAND

3.1 Subdivision Consent Legislation & Resource Management Act Structure

New Zealand’s Resource Management Act (RMA) 1991,1 sets out over 400 sections across almost 800 pages (and this is in addition to New Zealand’s Local Government Act). RMA sections 108, 220, and 229 to 239 (excerpted in Appendix 6.2) contain some of the core provisions concerned with subdivision consents, a category of ‘resource consents’ however an array of subdivision legislation is scattered throughout the Act. Approval of development or a permission associated with land or the environment in general, is deemed a ‘consent’ rather than a permit, an amendment or simply ‘approval.’ While New Zealanders may occasionally use the term zoning or rezoning, the formal reference is called a land use consent (which may include something we call a ‘variance’). For consistency, once defined, I will generally apply New Zealand terms throughout this paper.

Snapshot of Subdivision Consents

Subdivision authority, rural and municipal, is vested with a local government council rather than an independent officer. Council, in turn, typically delegates the entire process including approvals to staff. Despite that the RMA allows politicians to retain full authority, all the local governments interviewed and those within their regions delegate the entire process to staff. My interviewees offered that small localities with few subdivisions likely do not delegate subdivision consents but knew of no cases where this actually happens. RMA provisions are not dissimilar to that of our legislation in BC in respect of the following:

1. no presumed or a priori right to subdivide land 2. requiring the granting of passive esplanade reserves (i.e. park dedication under BC LGA s. 510) 3. requiring the granting of linear esplanades to access a coast or waterbody (i.e. LTA s. 75) 4. dedication and development of a public road to be vested with local government 5. engineering design and construction of “works and services” directly fronting or in support of the

proposed parcels, including a warrantee period 6. financial/development contributions for offsite infrastructure or amenities (i.e. DCCs) 7. compliance to the ‘District Plan’ (a kind of OCP, Zoning Bylaw, and other land-related catchall,

rolled into one) 8. overall subdivision consent steps thru to registry are similar to that of BC (see Appendix 6.3).

There are differences between BC and New Zealand as well, such as:

1. no discretionary denials on the basis of ‘public interest,’ meaning the reason for denial must be set out in the District Plan or in legislation

2. legislation is significantly more specific, complex, and extensive, for example: application forms are scheduled to the RMA and response/processing times are prescribed in legislation

3. RMA is more empowering and delegates broader authority, enabling a greater scope for District Plan policy thus making for a subdivision process with a good deal of ‘horse trading.’2

1 Fall 2017 during my travels, some amendments to the RMA were being discussed. This paper does not discuss any subsequent RMA changes that may have been passed by the New Zealand National Government. 2 A term used by more than one New Zealand planner.

Local Government Structure The New Zealand context comprises of 16 Regional Councils (of which 5 are Unitary Councils) and 67 Territorial Authorities which include: 12 City Councils 53 District Councils Auckland Council and Chatham Islands Council

See next page for jurisdiction maps and page 15 for more explanation.


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When does the RMA apply?

Land subdivision under the RMA applies to the creation of a freehold ‘allotment’ (i.e. parcel or lot) that has a certificate of title, what we call fee simple. It also applies to lease of land or buildings where the term exceeds 35 years, noting that similar to England, New Zealanders do not consider multi-generational leaseholds to be exotic. This is significantly longer than the 3 year cap for a lease of land (LTA s. 73) in British Columbia. And lastly the RMA also applies to creation of a unit title (i.e. a strata subdivision); a company lease; and finally a cross-lease which is a kind of shared interest under a single title but with distinct exclusive-use portions of land that are surveyed and registered in their Land Title Office. This office is referred to as LINZ or Land Information New Zealand.

When does the RMA not apply?

It does not apply to Māori lands unless the allotment is proposed to be divested to interests outside a hapu, the indigenous local clan or Māori subtribe. It also does not apply to a variety of cases of national and government interests such as for creation of roads, supporting public works or similar such enterprises, protecting heritage; and to create or change a reserve under the Te Ture Whenua Māori Act.

For the purposes on this paper, only subdivision under the RMA is discussed.


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3.2 Planning Framework for & practice of Subdivision Consents

Similar to the Province of BC, questions of land use and the density and attributes of that use or the given development are core considerations in New Zealand planning and subdivision review. In NZ these are set out in a District Plan. All resource consents, including subdivision, must be consistent and conform to that District Plan. The elected officials’ role in resource consents generally starts and stops with District Plan consideration. Once that is in place, staff’s role is to interpret and action that Plan.

What is a District Plan?

A territorial authority (i.e. a New Zealand city or district council) must prepare a district plan, unlike in BC where zoning or an OCP is not mandated. The purpose of a District Plan is to assist territorial authorities in carrying out their functions and to achieve the sustainable management directives of the RMA. For a given local government, it is the omnibus planning document and it sets out the following:

1. Objectives like long range purpose statements in an OCP or Regional Growth Strategy 2. Policies like more detailed specific statements in an OCP or a council policy document 3. Rules like regulations in bylaws such as zoning, tree protection, Development Permit areas,

subdivision servicing, servicing levels, and environmental protection

A District Plan establishes the preceding on a jurisdiction wide basis but it also gets into policy specifics. It may become more onerous by neighbourhood or by condition for certain categories of development or land use or hazard and so forth. According to the NZ Department of Internal Affairs (see RMA s. 75), a District Plan may establish:

significant resource management issues for the district; the methods for implementing district policies; principal reasons for adopting the policies and

methods; the procedures used to monitor the efficiency and effectiveness of the policies, rules, or other

methods contained in the plan; the environmental results anticipated from the implementation of those policies and methods; processes to be used to deal with issues that cross territorial boundaries; information to be included with an application for a resource consent(inc. subdivision); and any other information, policies, or rules for the purposes of the territorial authority’s functions,

powers, and duties under the RMA.

In addition to the preceding, the District Plan must give effect to any national policy statement or any New Zealand coastal policy statement and must not be inconsistent with: a water conservation order; a regional policy statement; and a regional plan for any matter specified in section 30(1) of the RMA (a comprehensive range of

matters related to water, soil, air, hazard, contamination, etc.)

A concise District Plan . .


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What is a District Plan in practice?

The Plan is divided by the three broad categories with the rules (i.e. density, permitted land uses) confined to certain chapters. All the local governments I researched were at some stage of amending and updating or reconsidering their District Plan. A new plan that is in the works is referred to as the replacement plan vs. the operative plan. Plans can become operative in stages. I found the District Plan for the smaller jurisdictions such as Rotorua or Selwyn’s two volumes within the scope of comprehension and comparable to the kinds planning documents with which I am familiar. The Christchurch City District Plan is another matter.

In practice some District Plans can grow to become beasts. The current Christchurch Operative District Plan can be found on the City’s website. According to the staffers with whom I spoke: no one person holds and administers its full scope; the general public is not aware of Plan contents; and, even elected officials or staff do not know its full content. They are familiar with various chapters. It is thousands of pages long3 and must be read in layers by geographical location, policy, issue, rule, etc. It must be cross referenced with various Plan iterations in time. Internal concordance and subjective interpretation esp. in the case of less tangible policy can be challenging (noting our OCPs suffer likewise). An average member of the public cannot undertake a consent application unassisted. Even professional developers must hire lawyers and other professionals to assist them through a subdivision process.

Preliminaries, application, fees etc. . . .

Application forms are similar to ours but they must follow Form 9 (scheduled to the RMA) which provides a default model form for what can and should be asked as a part of a consent application. Fees vary by jurisdiction but the general approach is user pay. Including a fee per hour for meetings with planners in advance of submitting an application. Some jurisdictions have a “duty planner” and offer the first hour free but then charge by time for any subsequent meeting (e.g. $150/hour for a junior team member and $180/hour for a senior). The model is more like that of a consultant than what I am familiar with in local government. For example, staff time on an application in Selwyn is tracked with the minimum base fee of a $2000 typically covering most of the staff time for a simple non-notified green-field subdivision but once that is used up, the applicant pays an hourly rate.

RMA s. 88 requires that consent applications be reviewed within a legislated 10 day timeframe (business days only) and that incomplete applications must be returned to the applicant immediately and thereupon any resubmission is considered a new application. From the start, the New Zealand subdivision consent process is more specific, professional, and demanding upon all parties involved.

3 Christchurch City senior staff offered it is over 2500 pages but no one was sure of the full extent of the Plan.

Christchurch is in the midst of a Replacement District Plan, initi-ated via a National Government OIC. The process is overseen by a panel of experts. And it is involved. Staff offered that perhaps only an expert on this panel may have a fulsome familiarity and knowledge of the proposed District Plan as a whole.

Christchurch Cathedral, 2017


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What is set out in a subdivision consent?

Consent processing starts with determining its category under a District Plan. Specifically, is it . . .

Permitted allowed outright (e.g. uses listed in a zone) Controlled allowed but you need a permit (e.g. a building consent) Discretionary whereby all relevant policy is considered (e.g. a land use or some subdivisions) Restricted discretionary can be allowed or refused outright (e.g. a typical subdivision consent) Non–compliant similar to Discretionary but has nonconformity in use, density, etc. thus may trigger

a hearing or a denial of the subdivision consent

Subdivision is a “Discretionary” activity whereby planners assess an application against all applicable District Plan policy and then assign it as “compliant” or “non-compliant” against a myriad of objectives, policies, and rules. If and when found to be non-compliant, then its effects are weighed: Are they no more than minor? Like our term “public interest” the term “no more than minor,” cited in almost all of the subdivision consents I read, is used in RMA legislation but not defined. Staff rely on precedent and Environment Court decisions. For example, if a multi lot subdivision includes allotments that do not meet area or frontage criteria, and the staff deem the non-compliance is no more than minor, the application may proceed, even without notification or a hearing (explained below).

As a part of this paper I reviewed just over a dozen subdivision consents and in some cases, the staff report that accompanied them. A simple two lot subdivision consent (i.e. ‘PLA’) is ~10 pages and contains a fulsome analysis and a range of conditions all referring to the District Plan and the RMA. Meanwhile a multi-lot urban subdivision consent, such the sample in Appendix 6.4, contains an analysis that covers all applicable sections of the Christchurch District Plan.

Conditions of subdivision consent

Firstly (and regardless of a District Plan), RMA s. 106 enables a consent authority to outright deny (or set out mitigating conditions) any subdivision that could result in on-site or adjacent land hazard such as erosion, subsidence, slippage, or inundation, and if there is insufficient legal and physical access to each allotment. Then the RMA authorizes the following broad power (emphasis mine):

s. 108 Conditions of resource consents (1) Except as expressly provided in this section and subject to any regulations, a resource consent may be granted on any condition that the consent authority considers appropriate, including any condition of a kind referred to in subsection (2).

Subsection (2) of 108 then refers to s. 220 and provisions in s. 229 - 239 which go on to enable specific conditions pertaining to the following:

1. Financial contributions can be required broadly (not only for infrastructure such as our DCCs) 2. Performance bonds in respect of any of the conditions of a subdivision consent (inc. for ongoing

long term impacts and environmental monitoring even after a consent is approved and filed) 3. Discharge permits (storm & sewage related waste) 4. Conditions for information on precisely how a consent or an action relating to it will be exercised 5. Investigation, measuring, sampling, analysis, reporting, etc deemed advisable at applicant’s expense 6. Vesting of ownership of any waterbody and associated land with the Crown 7. Setting aside and granting esplanade reserves or strips for maintain or enhancing natural functions

of environmental systems, esp. aquatic, and mitigating hazards or enabling public recreation


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8. Setting aside and granting esplanade strips for public water access (RMA s. 230 ) 9. Granting new or revising existing easements, and extinguishing redundant ones 10. Require various amalgamations, land transfers, tenancies in common, etc, justified by access or

subdivision geometry or District Plan policy 11. Conditions that any allotment be subject to building limits as to the bulk, height, location,

foundation, or floor level height of any existing or future improvement

Appendix 6.2 attached to this paper extracts some of the more relevant sections of the RMA, noting that this is by no means near complete; rather, it is intended to give a sampling of the legislation. For interest, please refer to s. 229 which outlines the specific regulations for esplanade reserves and strips (something like our park and public water access dedication but a lot more comprehensive).

Once a consent is issued, its duration is regulated by RMA s. 123. Some types of consents are unlimited (unless specified), others are limited to 35 years. The default subdivision duration - from the day the consent is granted to the day the plan is filed at LINZ - is 5 years, the stated duration in all the subdivision consents I had read. This is significantly longer than the 1 year shelf life of most PLAs in BC.

When is a subdivision consent (or other consent) ‘Notified’ vs. ‘Non-notified’?

Section 95A of the RMA empowers a local authority to decide if any consent application is broadly publicly notified. That said, it must be notified if:

1) the authority believes that adverse environmental impacts will be “more than minor” or some other special circumstances warrant notification;

2) a national rule or standard requires notification; or, curiously 3) if the applicant requests notification.

Subdivision consents are rarely publicly or broadly notified: more often they trigger limited notification.

For the case of limited notification (s. 95B), the local authority is charged to determine if there is an “affected person” such as a neighbor or “customary rights group” such as the Māori, and if so, then they must serve limited notification to the affected person(s). RMA s. 95E reads as follows:

A consent authority must decide that a person is an affected person, in relation to an activity, if the activity’s adverse effects on the person are minor or more than minor (but are not less than minor).

Oi. Comparing the rather explicit and simple notice requirements that we administer in BC, the preceding is complex, subjective, and at risk of being misinterpreted. The staff administering subdivision are charged with assessing and then determining if and what may be an adverse effect? Is that effect less than minor, minor, or more than minor? And who is effected?4 They assured me that this is usually apparent and that applicants most often abide by District Plan rules and recession planes as most prefer to avoid triggering even limited notification. The rules, formats, and deadlines of submissions in response to a notification are all spelled out in detail in the RMA.

In the instance of a subdivision, limited notification may be necessary if the impact to a neighbor’s right to privacy or sunlight will more than minor. Setbacks in New Zealand are called “recession planes” and 4 Limited notification in New Zealand can be compared to our Development Variance Permit or BOV requirements; however, in this case the process is administered and adjudicated by delegated staff.

Christchurch Botanic Gardens


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are considered in three dimensions. Like England, customary rights such as sun, privacy, amenity access, etc. are recognized in New Zealand. So a subdivision consent may limit allotment build out, including the number of bedrooms, the locations of windows, and if those windows can be transparent or translucent.5

If an application is notified, especially if recommended to be denied, then in smaller or rural jurisdictions it may go before council or before qualified commissioners along with a supporting staff report and recommendation. In Christchurch, where the entire process is delegated, this is not the case. Even if an effected neighbor opposes the subdivision consent, unless the proposal is unreasonable or grossly non-compliant, staff adjudicate it against the District Plan, get input, set conditions and then more often, allow it. Finally, it is noteworthy that if an affected person submits their written “approval” or support of the consent, the consent authority then must disregard that impact entirely in considering the subdivision. Reading into this, perhaps the rationale is that it is not the authority’s role to be paternalistic and protect the interests of potential future neighbors or impacted owners.

When does a subdivision consent go to a hearing?

The answer is rarely. Less than 3% of applications in the jurisdictions I interviewed go to a hearing. Again, the determination of whether a hearing is even required is up to the consent authority. Alternatively, it can be triggered by an applicant’s request or that of a person who has made a qualified submission and a written request for a hearing. And if they have made this request, they can ask it be delegated to independent commissioners who are neither staff nor officials of the given government.

The planners I interviewed offered that if a hearing was held, it was typically one or three commissioners (one of whom may be an elected official) but that the panel must be qualified to sit the hearing.6 If a politician wishes to be a commissioner, he or she must take special training to gain the requisite expertise in decision making and pass an examination. This was a complete turnaround to how we adjudicate such matters. In my experience, we only rarely have relevant expertise.

District Plans, discretion, denial, and developers

The RMA spells out the conditions that can be required as a part of granting any resource consent, including that of subdivision (see discussion on page 10). Given imposition of requirements is under a vast sweep of policy, I asked if this was a difficult process for staff. The response was that in the range of resource consents, subdivision is fairly straight forward in respect of conditions related to engineering, density, environmental conditions, and access roads. Other ‘soft’ conditions (relating to granting of esplanades and environmental reserves for example) is in relation to the overall thrust of District Plan policy and thus is a judgement call. My interviewees explained that this is discussed and rationalized amongst staff internally and that there is no (or next to no) contact with either the CEO7 or elected officials. The format and extent of detail in subdivision consent varies significantly by jurisdiction and type of subdivision.

5 This clarified for me why much New Zealand development seems so low to the ground and private. Yes, it is strict earthquake bracing in lateral loads but it is also a shared aesthetic and common law understanding. 6 Similar to our LGA, s. 101 of the RMA sets out hearing notice requirements but in New Zealand the Act also establishes a max. of 35 working days to hold the hearing from date of application and extensive rules on what, when, and how to make a submission for the hearing – even who can make a submission. Legislated processing times, not in place in BC, create a sense of urgency and responsibility in the civic realm. 7 The senior or city manager in New Zealand was referred to as the CEO (not CAO) in all the local governments I visited.


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In respect to application denial, there are very few proposals that are unlikely to succeed as these do not make their way to a full application stage in the first place. If a subdivision consent is denied, the process varies by jurisdiction. Christchurch senior staff make that call. In Rotorua this is put with a recommendation before Council. In Selwyn a report also goes to Council for any denial as well it is expected that it will be before a hearing panel.

Judge Newhook, Principal Judge of the Environment Court of NZ since 2011, offers a critical analysis of the pitfalls of drafting consents under a District Plan and the RMA. The Environment Court is the applet body for denials or reconsideration of requirements that an applicant or developer believes unreasonable or unlawful. Please refer to s.3.5 (pages 17 & 18 of this report) for a summary of his observations.

Monitoring what you said you would monitor?

Some of the consents I read spelled out complex monitoring regimes and prescriptive direction on how a consent is exercised. As previously stated, the RMA provides broad enabling legislation in this regard. On question to my interviewees if this is in fact carried through to practice, staff advised that indeed it was and that their district employed staff in the field to administer, oversee, and monitor all resource consents. They added that after the subdivision (including any applicable warrantee period) was complete and filed in their land title office, LINZ, no further monitoring was typically necessary.

What is an elected officials’ role in consent processing?

The staff I interviewed who work in the trenches of consent approval did not deal with elected officials directly. The higher level directors and managers8 offered that elected officials may make suggestions or submit openly on behalf of a community or a group of ratepayers in their ward (New Zealand has a local government ward system) but they do not pressure or lobby the delegated staff who make the final decision. If an application is finally denied (i.e. the applicant negotiates with staff and asks them for reconsideration first), in most jurisdictions the appeal process is not to council anyway but to the Environment Court.

One interviewee who worked for a small rural district and more directly with a hands-on council relayed that if an elected official becomes involved in a given subdivision consent outcome they back away quickly once they see how technical and complex it is to administer the RMA and their District Plan.

8 The General Manger of Consenting & Compliance in Christchurch works regularly with elected officials and oversees over 500 staff via an extensive “Delegation Registry” of who is delegated precisely what authority.

Part of a Christchurch water sculpture by Sam Mahon intended to reflect the ‘messy reality’ of human life


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How do developers fare on subdivision developments?

First, similar to BC, many NZ applicants lift the value of land by securing a subdivision or a land use consent and simply sell before tackling the actual process and the risk of unknown costs. In the urban BC context where land can be expensive and significant engineering and infrastructure is required, developers I have dealt with have frequently argued that they do not actually make money on the subdivision, but rather on the subsequent development of the spec houses or condos or commercial space on the subdivided land. They undertake subdivision so as to control development of the new land. This is not the case in New Zealand.

According to planning staff, New Zealand urban (i.e. serviced) residential subdivisions earn developers a profit of about 20% and most have been selling the new allotments as bare land only. More recently some multi-lot subdivisions are being held by developers for construction. In terms of profit, rural subdivisions, especially 4 ha unserviced so called “life-style lots”, are far more lucrative. According to the interviewees, these semi-rural allotments are in highest demand on the urban fringe.

Based upon some contacts and links I was provided, developers in New Zealand are unsatisfied with the costly and complex planning regimes under which they conduct business. The head of the New Zealand Property Council, Mr. Connal Townsend, was calling for a “national conversation” on their planning regimes, saying:

The planning system is reducing the economic productivity of our cities, escalating social policy issues, is causing poverty and is detrimental to the environment. The system is not delivering the economic, environmental and social outcomes our 21st century cities need.

His organization sets out the following questions that they believe need to be addressed (emphasis mine):

Is there sufficient strategic agreement between central government and councils? Is there collaboration and integrated planning between councils? Given that our systems have inter-connected roles of planning, land-use, and other infrastructure

investment, why is decision-making poor? Are rules and regulations over used? Why do we have overly complicated consultation, funding and investment processes?

I add the preceding simply to illustrate that developers share similar questions, criticisms, and frustrations with planners and the planning processes that in place, regardless of the jurisdiction.


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3.3 Regional Planning and Subdivision Consents

As per the maps on page 7, New Zealand has 16 Regions which are also considered a level of local government not entirely dissimilar to BC’s Regional Districts; however in their case, the Region is responsible for many of the environmental approvals and authorities of the Province. Except for the 5 Unitary Regions where the region and district is one and the same, districts or cities cover the lands within a region. The officials I spoke with all offered that the district/municipal staff to regional staff relationships were open and functional; moreover, the elected officials also had a good working relationship between the levels of local government. A complex resource consent, for land use or environmental matters, may include a shared hearing on behalf of both a district or city and its region.

In terms of subdivision consents, regional policy plays a role. The Region is generally consulted on any major resource consent (inc. subdivision), especially where there is a requirement for overlapping approvals such as allocation of water resources; discharge into the environment (storm or other); soil contamination; flooding and other hazard conditions; coastal sea level risks; and so forth. A given subdivision consent must be consistent with Regional Policy Statement and these in turn, are set out as rules or policy in the District Plan where applicable.9

What is a Regional Policy Statement?

It is a statutory policy document, similar to our Regional Growth Strategy that provides an overview of a region's significant resource management issues. And like an RGS it must be “given effect” by city or district councils when developing their own district plans. It sets out policies and methods for managing major resource management issues, hazards, and other broader geographical priorities. It does not contain ‘rules’ such as those within a District Plan.

Referrals in practice

Christchurch City is within an overlay of the Canterbury Region, a federative structure with a rural focus governed by a combination of rural elected officials and appointees of the national government. According to City consent processing staff, in practice, few urban subdivisions are sent to the Canterbury Region because most are clearly aligned with regional policy - and that policy is usually of a general nature in any event. Rotorua, a significantly smaller jurisdiction, sends more applications for referral and seems to work closer with its Region, the Bay of Plenty.

9 Not unlike our Regional Growth Strategy regional context statements and the OCP consistency rule.


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3.4 Agriculture Protection and Subdivision

New Zealand has neither a parallel to the ALC nor legislated protection for farmland other than any given policy in a District Plan. This means it is up to the local government to protect viable farmland. Those with whom I spoke offered the following comments: • There is no central government pressure to protect farmland. • Protection of farmland is by policy in our District Plan - a

weakness of subdivision consents in prime farm areas as it relies on planners’ discretion.

• The only protection is by density but since we allow subdivision down to 4 ha as a large rural “lifestyle allotment,” it is too small for most economically viable farms.

• Our system makes it hard to assemble holdings to create a large farm, especially near urban areas.

I spoke with the subdivision consent planning staff in Waimakariri and Selwyn, the two main rural Districts surrounding Christchurch in the Canterbury Region (pictured above). Both have seen significant growth in past decade, 35% and 66%10 respectively. There has been a shift from Christchurch City to rural satellite communities, most decidedly since the earthquakes of 2010 and 2011. Over most of the past decade Selwyn has been New Zealand’s fastest growing District (now 2nd to Queenstown). While growth occurred throughout Selwyn, the "commuter belt" close to Christchurch has the greatest number of subdivision consents, including West Melton, Rolleston, Lincoln, Springston, Prebbleton and many rural "lifestyle blocks." While this is addressed by the Greater Christchurch Urban Development Strategy, the traffic increases and relative cost of land are creating a long term question of sustainability. With the exception of greater Auckland, New Zealand generally has few large motorways (i.e. overpasses and free flow thru roads) and their population density does not justify high speed transit economically. All told, from what I could ascertain, the major population shift to rural districts outside of the Christchurch core does not bode well for the future of farming.

In terms of the numbers published by Stats New Zealand,11 8.6% of the country’s 2016 GDP is primary industry, specifically: agriculture, forestry, fishing, and mining in descending order of monetary importance. Agriculture is the main source of national income and accounts for just over half of all exports. Tourism is also a major part of their economy and in good measure, what draws a tourist to New Zealand is the rural and rugged quality of the countryside. Picturesque green paddocks with sheep near oceans and beaches or mountains with hobbits under foot look better than suburban traffic snarls.

From the interviews and a limited literature review, there is surprisingly little to no alarm over subdivision and fragmenting of productive farmland - despite the critical role that agriculture plays in the New Zealand economy. Perhaps the great extent of good and passable farmland across New Zealand, could mean that there is little incentive to protect it near urban centres. Selwyn planning staff acknowledged that while there are outer plain areas with 20 ha and high country lands with 120 ha minimum lot size, farmers have been pushed out of the best soils in the valley bottoms. The light on the horizon is that they are looking at District Plan changes to better protect the best soils in Selwyn.

10 NZ Census data - Waimakariri 2006 pop of 42,834 increased to 57,800 by 2016; and, Selwyn: 2006 pop of 33,642 increasing to 56,415 by 2016 ten years later. 11 Source: http://www.stats.govt.nz/datavisualisation/ date viewed Nov. 2, 2017

Canterbury farmlands Source: GNS Science l d

http://www.stats.govt.nz/datavisualisation/


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3.5 Subdivision Consent & the Environment Court

Under New Zealand’s Ministry of Environment, Part 11, s. 247 of the 1991 RMA established the authority of the “Environment Court,” one of three specialized courts in the country. The Environment Court is the authority that decides arguments and appeals (including via mediation) in respect of any resource consent denial, approval, or condition. The Court provides leadership for managing natural resources and human impacts on the natural environment. It can hear appeals by a development applicant who is unhappy with the requirements of their subdivision or any party who believes a decision is wrong, say a neighbor of an approved land use consent. It can hear appeals to heritage, zoning interpretation, District Plans, water conservation, and regional policy (like our RGS). Enforcement orders pertaining to nuisance and District Plan compliance (e.g. zoning) can be issued by the Court. It also hears matters related to 9 other acts, including New Zealand’s LGA and regulations relating to transit, mining, forestry, and utilities. Finally, they also increasingly administer mediations.

See www.environmentcourt.govt.nz/ for more information. We have no parallel body in BC.

Who makes up the Environment Court and how do they conduct business?12

Hearings are more informal than our court process. The Court comprises of 9 specialist principal judges (the Act caps the number at 10) and 14 environmental commissioners and their deputies who are conferred power by appointed judges to hear and decide proceedings. They typically serve as a mobile panel (a judge and two commissioners qualifying the occasional case may only have one sitting judge) whereby parties do not necessarily need lawyers and decisions are relatively expedient.13 Hearing conduct is flexible whereby a judge or a panel can adjust the process to suit the case at hand. Panel appointees have specialized knowledge such as hazard lands/slopes, water rights, groundwater protection, flooding and rising ocean levels, or District Plan interpretation. An applicant who does not agree with a condition (or a denial) of a subdivision consent can appeal or a neighbour who feels their interest is compromised by an infill subdivision that is contrary to a District Plan can appeal.

Hearings are open to the public (unless sensitive evidence is presented) while mediation is private. Importantly, an appeal must be lodged within 15 working days of notice receipt of a consent application decision or 30 days of a plan or policy statement. The fee to submit an appeal is $511 (~$460 Can). Thereupon the Court’s timeline for processing is about 6 months. Mediation is faster and free. The Court can make orders; overturn council (or delegated staff) decisions; and impose any number or range of conditions including the assignment of costs. In some cases they may require a security deposit with an application to ensure that costs can be paid if an applicant is unsuccessful. All in all, it seems more efficient and intelligent than our system.

The Court considers legal arguments (not under oath); evidence including that of experts under oath; and exhibits, including all the documents considered by a council or staff in making their decision. All evidence must be exchanged with the other party no less than 5 working days before a hearing. The Court’s decisions are drafted in plain English and published online. Some make for interesting reading,

12 For more info go to the following link: www.mfe.govt.nz/publications/rma/everyday/court-guide/index.html 13 Some advise that a decision is made on the same day however the Court’s website states that most decisions are reserved.

Snapshot: All the interviewees I had spoken with had experience with the Environment Court; however, they qualify that only one or two subdivision consents make their way to the court annually.

http://www.environmentcourt.govt.nz/


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particularly cases where a council disagrees with their planning staff or where a region opposes a consent granted by a member municipality. For quick reference, attached as Appendix 6.5 please find a case pertaining to rising ocean level and climate change in respect of a subdivision. Finally, appeals of an Environment Court decision are to the New Zealand High Court and can only be on point of law.

Problems/concerns the Environment Court has with subdivision consents

In perusing a few District Plans and reading subdivision consent letters, I found the complexity and length intimidating. I had asked my interviewees about their opinion and confidence level of working under the regime of the RMA and their District Plan – just how subjective and defensible is a subdivision consent? There was no consistent response. Some offered that there were ‘good’ subdivisions they wished they could approve but clearly noncompliant with their District Plan and conversely others that should be denied but given no basis, had to be approved.

Not having the expertise, to comment critically I refer to the Principal Environment Court Judge Laurie Newhook’s summary list of chronic problems that the Court has found with consent drafting and imposition of conditions:14

Uncertainty of purpose and of expression Conditions imposed beyond the legal powers of the local authority Invalid delegation of the duties of the local authority Conditions unenforceable in that they rely on compliance by third parties Imposition of a financial contribution beyond the terms of the RMA (inc. expropriation of land

for a public purpose (e.g. for a reserve/esplanade) beyond the authority granted in legislation Conditions that effectively nullify the grant of consent (rather than deny the consent outright) Vague or ambiguous wording Failure to specify objectives where details of compliance have been left to implementation

through the development of management plans Delegation of further detailed decision-making over the subject matter of the consent (as

opposed to requiring certification of compliance by suitably identified and qualified persons) Conditions enlarging consent beyond the scope of the activities applied for Conditions purporting to prevent application for future consents, particularly for subdivision Inappropriate choice of security for performance of conditions

While some PLAs (or PLRs) issued by BC approving officers may be criticized on the preceding points, our subdivision process is not near as complex thus, arguably, it is less likely to be subject to the preceding problems. PLAs in BC electoral areas are even less so, because in our Regional District the MoTI approving officers typically neither consider nor apply any ‘soft’ planning policy or objectives such as that of an Official Community Plan or Regional Growth Strategy policy in their subdivision review and response.

In closing and despite the pitfalls listed above, I believe that the broad legislated authority, expertise, and efficiency in both time and cost of New Zealand’s Environment Court make it a remarkable solution to the arguments and enforcement proceedings in respect of consents, subdivision or otherwise, in the realm of local government.

14 Judge L. Newhook (RMA Roadshow, July and August, 2014) has sat on the Court since 2006 and held the title of Principal Judge since 2011. Retrieved from http://www.rmla.org.nz/wp-content/uploads/2016/09/conditions_of_consent_judge_lj_newhook_final.pdf

http://www.rmla.org.nz/wp-content/uploads/2016/09/conditions_of_consent_judge_lj_newhook_final.pdf


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4.0 BROADER PLANNING-RELATED OBSERVATIONS

This Part indulges my wish to share five observations (in no particular order), some obvious, some subtle, that had made an impression and stuck with me since my return. Items 4.4 and 4.5 below, have me questioning my basic assumptions about what makes a well-planned residential subdivision.

4.1 Tracking, charging, and supporting (a healthy) bureaucracy

The staff with whom I met were all professional and forthright. They have adopted a user-pay approach to development and processing. For example, some jurisdictions have a base fee and then they track staff time and charge an hourly rate for the entire subdivision consent. Others charge for meetings whereby a landowner or developer may get one hour gratis but then must pay based on the clock for further pre-application support or processing. Meetings, even prelim informal sessions, are tagged, numbered, and recorded in writing, more like our legal ‘discovery’ system. To some this may seem bureaucratic and onerous, but I believe this is a sound practice that could be readily implemented in our offices and perhaps other rural and small town local governments. Our customers may be encouraged to be more organized and efficient (and in some cases professional) when participating in the development process.

4.2 Who is ‘council’ in New Zealand?

When BC local government staff say ‘council’ or ‘board’ they usually mean elected officials (hopefully acting in properly assembled meeting). If we mean staff, we say ‘staff.’ If we refer to elected officials and staff collectively, we will use the given municipality name. We distinguish between the office of staff vs politician.15 Meanwhile New Zealand legislation, brochures, consents, and other documents say that “Council will . .” (e.g. a subdivision consent will read that “Council has determined that the owner must . . . .”). But in fact the matter is entirely delegated to staff. Please see process diagram on Appendix 6.3 for an example (page 46/47). During my interviews I was caught up several times when they said that “Council reviews/approves a consent.” When asked to clarify, they confirmed that the matter never did go before Council but was handled by staff. My point is that it is a shift, albeit subtle, in the fundamental understanding of government structure and authority. It is more cohesive.

As an aside, all the offices I visited had open area workspaces which did not speak to organizational hierarchy. As per the adjacent photo, an administration assistant and a department director (who manages >500 staff) shared the same cubicle size and geography across all six levels of the civic building.

4.3 Techno-literacy

New Zealand has systems in place that assume and require a technologically savvy general public. For example, all Christchurch Building Consent drawings and supporting info must be submitted digitally and are reviewed electronically (i.e. not redlined). Also, complex District Plans can be queried by inputting the property in question into GIS whereby applicable specific rules, relevant maps, inc. some policy for given land(s) are downloaded electronically. Finally, the SOLGM conference proceedings were on line and all the voting and other input/questions were streamed in real time at the conference via internet. Granted parts of BC may be similarly advanced (e.g. Lower Mainland), but the jurisdictions which with I am familiar are nowhere near this tech-savvy.

15 The general public, in my experience, distinguish between elected officials and staff less.


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4.4 Building-out backwards, is it better?

The Christchurch District Plan sets out a density cap but it typically does not the limit the number of dwellings per allotment.16 Thus if a lot is 700 sqm and the District Plan allows one SFD per 350 sqm, an owner can construct two detached dwellings under a building consent. They may own both or may lease one (possibly via a surveyed long term cross-lease whereby each has a title and can be mortgaged). Or they may create a unit title, similar to our strata subdivisions. The key is that they can build to density first and then subdivide – which is the preference of subdivision consent planning staff. They explained that this can make a subsequent subdivision go more smoothly and quickly. This is backwards to how we zone and control most urban development.

4.5 Learning to love panhandles – everywhere!

The accepted suburban residential survey template in New Zealand differs from that in North America. The layout, even in many new subdivisions is double depth, meaning there is a narrower allotment fronting the public road flanked by a long narrow easement, pan-handle, or common lot, as the case may be, to access anywhere from one to four (or more!) private SFD lots in the back. Our policy and bylaws typically strictly regulate panhandle lots, for example allowing them on the ends of cul de sacs.

In fact this is efficient and practical as there is less road and utility length to maintain and can make for private quiet infill residences. On question regarding emergency or other access, the planners I interviewed advised this was workable and they have never heard of a problem.

The zoning template for yards also differs. A home is not assumed to be addressing or presenting itself to a fronting street: it is more cloistered. As per the photos below, fence height is not required to be reduced at the front yard. A 6ft high masonry wall contains the street and provides privacy to residents. The purpose is not security – according to the 2017 Global Peace Index, New Zealand is rated 2nd (after Iceland) as the safest country in the world.17 Finally, similar to England, build-out and discretion relating to new construction includes consideration of sunlight and privacy rights. Thus a building or subdivision consent may limit where windows are allowed and may stipulate setbacks, called ‘recession planes,’ that are three dimensional.

16 While this was also the case in a few other jurisdictions I visited, I cannot say if this is common across NZ. 17 Noting Canada is 8th on this index which crunches 23 relevant statistics ranking 163 countries around the world. Retrieved Dec 23, 2017 Source: https://en.wikipedia.org/wiki/Global_Peace_Index


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5.0 LEARNING FROM NEW ZEALAND

5.1 Lessons & Takeaways

1. Reconsidering our suburban survey templates and land ownership models

The entire New Zealand approach where privacy is respected and delineated between private space and the public street; access by driveway or panhandle; rights to sun and privacy; and alternative models for land ownership (besides fee simple or strata) would serve us well. Our template for suburbia follows an American model and less the British, meaning we favour a house as a positive object in the middle of a parcel with a front yard on display across full road frontage, especially in our sprawling ‘suburbias.’ We do not perceive the negative space around a building as ‘positive’ – except if it is say a courtyard within a building. I found the New Zealand model makes better use of land, supports more density, and has more efficient road patterns than our system.

2. District Plans vs. OCP and other BC land use bylaws, plans, and policies

The idea of an omnibus go-to planning document that contains virtually everything from zoning, policy, long range planning, heritage protection, environment protection, to regional statements and strategies, and so forth was impressive. It is rigorously provided for in legislation and promoted in New Zealand info materials. In practice though, I believe it would be unwieldly for most of the local government staff and officials with whom I have worked. Moreover, I believe that our public would not have the requisite patience and planning literacy to accept such an approach. I would not have comfort asking them to navigate this kind of a document. Our public and politicians, especially in BC rural areas, are less tolerant of jargon laden lengthy planning documents. That said, we always benefit from learning other approaches to planning and how planning documents are undertaken.

New low density residential development on Christchurch City streams and creeks.

4 unit title allotments (strata) accessed via common private lane

4 fee simple allotments with 2 at rear accessed via private easement or a panhandle.

1 fee simple allotment w/ 6 exclusive occupancy leaseholds accessed via a cross-lease private lane


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3. Local government discretion & detailed legislation – is this the direction to go?

Tackling the RMA, District Plans, and subdivision consents was humbling and overwhelming.18 We may be frustrated that the Local Government Act parts pertaining to planning and subdivision in BC are not being amended, updated and improved, but the concept, responsibility, and office of a subdivision approving officer in BC is more simple and ascertainable than the process in New Zealand. Parts of the RMA are excessively complex and for all that effort, they may not result in better outcomes. I believe that some subdivisions should be denied because they are not in the public interest despite that they may meet all bylaw requirements. If subdivision in New Zealand is a forensic process, by comparison we sometimes operate like the Wild West. As a last word, the idea of legislated processing times would cause me and many planners I know a good deal of anxiety.

4. Should hearings and decisions be left to qualified ears?

Re-assigning discretionary decisions for matters such as zoning or appeals of delegated decisions from an elected council to a panel of commissioners who have qualifications in the matters being considered (or at least have the required training in good planning and decision making) is the best take-home idea that I offer in this paper. Unfortunately this is not an idea I have heard discussed in BC. Yes, we may delegate our public hearings but shifting final decision making from politicians is not likely in our future.

Most agree that educated and interested decision makers make better decisions; however, our system inclines to direct democracy (think new services in regional districts) or to decision making by those that are democratically elected. Granted, an argument can be made on both sides. Our elected officials often believe they should retain decision rights as that is why they were elected. If they are not serving the public will, well then there is a vote for that every 4 years. On the other hand, elected officials may not by choice or circumstance be educated in, interested in, or invested in many of their discretionary decisions. They decide simply on the basis of a duty to vote as a part of a council or board.

5. An evolved civil society

The General Manager of consents in Christchurch put it succinctly, telling me: “New Zealanders are very much aware of their obligations with respect to citizenship and their individual responsibilities.” New Zealand may be characterized by some as an expensive ‘boutique’ country and by others as socialist, but I found New Zealand to be a mature, literate, egalitarian society. In a lot of respects, they have figured it out. They are an extraordinarily safe civilized country.19 They plan and legislate for the future – even for higher ocean levels hundred years from now.

18 While a comprehensive academic study is beyond my time and purpose, my research and literature review went well beyond interviews and my limited time in New Zealand. I learned enough to know that there is a whole lot more to learn. I did however get a sense of the demand and challenge that being a professional planner in New Zealand entails. 19 Note that they do not enable civil liability: so if you trip on a sidewalk, you should have watched where you were walking. Instead, they have implemented universal insurance coverage if you are sick or injured.

Christchurch City Hall


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5.2 SOLGM Annual Conference – 2017 Rotorua

The 2017 New Zealand Society of Local Government Managers (SOLGM) annual conference titled “Today: Tomorrow” was held in the central North Island town of Rotorua (pop. 57,800) and focused on visioning and future-proofing local government. While this theme is not unusual for many similar organizations, this conference cast its eye well beyond the shores of New Zealand.

We arrived in Rotorua during a storm midday on the 27th to prepare for a VIP dinner. Our small group was welcomed at the door of Te Puia hot springs by a traditional and intimate M𝑎𝑎ori ceremony, called a ‘powhiri.’ We were delivered by caterpillar-carts to a heated tent in the heart of the main geyser area for an amazing catered dinner.

The conference opening keynote was by futurist, Mark McCrindle of Australia who spoke on global mega trends and generational transitions – focusing on the workplace. He dished out levity, gravity, and comedy in equal measure. Aside from the break-out sessions and workshops (provided by locals and New Zealanders), most of the conference sessions turned their gaze internationally or on national New Zealand challenges. Granted, New Zealand lacks of a mid-level government (i.e. province or state) and their local governments play a broader role than ours but the difference was more profound. They seem to have a great agility and ability to accept change.

The most memorable session was “Towards localism: Lessons from Switzerland,” an intense well researched comparative study of New Zealand and Switzerland local government. The presenters, Dr. Oliver Hartwich and Craig Stobo, set out a challenge to think boldly about changing near everything about New Zealand local government. They were unapologetic about thinking big and applying a capitalist competitive model in a country known for a socialist model.

Satellite image of Rotorua. Source: Google Earth


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Various other SOLGM conference sessions included the following:

• Tomorrow’s Communities: being age friendly (re. the mess of generations in the workplace) • International Case Studies (CAOs from around the world sharing how they successfully and

fundamentally changed their respective organizations) • Pushing the Boundaries of Local Government: Singapore, Switzerland or Both? (a political

commentator’s take on the New Zealand national election and its impact on local government) • Tomorrow’s economic world: constrained by yesterday or shaped by today or inspired by tomorrow’s

today? (a collection of anecdotes and observations by a national economist) • Big, Bold, Brave – Borrow. Build. Brag. (designing cities and transportation in the future city based

on the experiences in New York City)

By way of aside, SOLGM participates in numerous international exchanges. As one of five international exchange attendees, I spent two evenings comparing experiences with others from USA, Britain and Australia. Again, discussions and conference content were more international and fulsome than conferences in British Columbia.

As compared to our LGMA or PIBC conference, SOLGM was broader in scope and attendance and better funded. This is in no small part due to a significant corporate presence and sponsorship of every aspect of the conference, noting there were very few lawyers in attendance.

I will close by saying that, in my experience, New Zealanders are irrelevant, observant, cosmopolitan, and kind and do not seem to be from a small island. They know how to hold a party and can stay awake a lot later than me.

Te Puia hot springs, Rotorua, at dusk

2017 lgma new zealand exchange final report · 2019-08-19 · 3.5 subdivision consent and the new...

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