National Adaptation Plan – clear strategy, detail to follow

But key implementation details are yet to come, including how the cost will be split, the new powers which will be conferred, and how data sets, standards and other guidance will develop.

What is the NAP?

The NAP is required under the Zero Carbon Act and sets out how the Government will achieve its emissions reduction goal. It is the first in a series of National Adaptation Plans to be prepared every six years out to 2050.

The NAP identifies over 120 future actions across a range of delivery agencies. Initial public reaction to the report indicates that, as the evidence of climate risk accumulates, there is a growing acceptance that change, some of it difficult, is necessary.

The stakes are high. One in seven New Zealanders, and over $100b worth of residential buildings, are in areas prone to flooding. And insurance claims for extreme weather events in New Zealand, for example, broke all previous records in each of the last two years.

Four strands to the NAP strategy

The NAP’s strategy has three public-facing strands:

• enabling better risk-informed decisions
• driving climate-resilient development in the right locations, and
• adaptation options, including managed retreat.

These themes will be applied across system-wide issues and five outcome areas or “realms of risk”:

• the natural environment
• buildings
• infrastructure
• communities, and
• the economy and financial system.

NAP’s action points

Actions are identified as critical, supporting and proposed. All critical and supporting actions are defined as “current” – meaning that they have “funding and mandate”. The NAP lists 24 critical actions, which include the following of particular note:

Enabling better risk-informed decisions

• provide access to the latest climate projections data by 2024
• design and develop risk and resilience and climate adaptation information portals by 2028
• deliver a rolling programme of targeted adaptation guidance over the next 6 years
• develop guidance for assessing risk and impact on physical assets and the services they provide by 2024
• support high-quality implementation of climate-related disclosures and explore expansion by 2028
• improve natural hazard information on Land Information Memoranda (LIMs) by 2026

Driving climate-resilient development in the right locations

• reform the institutional arrangements for water services by 2024
• integrate adaptation into Waka Kotahi and Treasury decision-making on infrastructure by 2027

Adaptation options, including managed retreat

• complete a case study to explore co-investment for flood resilience this year
• scope a resilience standard or code for infrastructure by 2024, and
• develop options for home flood insurance by 2023.

Key messages

The NAP is vague on the important question of how the costs and risks of adaptation will be allocated, simply noting that they “will need to be shared between asset or property owners, their insurance companies, their banks, local government and central government”.

Councils will have a huge role to play as they will be responsible for managing forced relocation, and for developing options that will avoid or delay the need to relocate. These could include restricting further development or particular uses of at risk land through planning rules, or setting consent conditions to improve resilience – e.g., minimum floor heights and flood-proofing requirements. They are likely to be contentious in their own right, and may create capacity and capability problems among smaller local authorities.

Particularly important in delivering the NAP’s actions will be the reform to the resource management system. The Climate Adaptation Bill, which is expected to be introduced by the end of next year, will establish a legal framework for managed retreat. The Natural and Built Environment and Spatial Planning Bills, expected to be introduced in October this year, will also be critical in ensuring future growth occurs in the most appropriate locations.

The NAP strongly encourages Councils to use existing powers under the Resource Management Act to drive appropriate location and relocation of activities. However, the Government is aware that a stronger mandate and clearer direction is needed, particularly in light of the current housing intensification push.

In response, the Government has suggested councils ‘stress test’ plans, policies and strategies using interim sea-level rise guidance, the National Climate Change Risk Assessment, and the recommended IPCC Sixth Assessment Report climate change scenarios.

For infrastructure asset owners, the Government has proposed a resilience standard/code to guide risk reduction and resilience planning, and recognised that the asset owners themselves are best placed to manage climate risk.

Access to data will be of particular interest to those undertaking climate risk disclosure (including under the incoming mandatory reporting regime). The proposed information portals could help achieve much-needed data consistency for those grappling with scenario analysis and physical climate risk.

However they will not be fully in place until the end of 2023, and the reporting obligations, commence from next year.

From here

The rest of this year and all of 2023 will be a critical in the implementation of the NAP. In particular:

• the Resource Management Act replacement legislation (the Natural and Built Environment Act and Spatial Planning Act) are due for introduction in October, with a public submissions process through to 2023
• the launch of the initial risk and resilience portal, and
• the Future for Local Government review, which is due to report next year.

The 2023 election may disturb the NAP’s work streams for 2024 (including the publication of the New Zealand climate projection datasets, and the passage of the Climate Adaptation Act).

National has signed up to New Zealand’s climate change targets, and to the Climate Change Commission and Zero Carbon Act architecture. But it has preserved its right to disagree on specific emissions reduction initiatives and these Plans will be political documents.

Contested policies contained within the 2022 to 2028 Plan include the three waters reforms, the Lake Onslow pumped hydro project, and – potentially – the Future for Local Government review.

The prospect of political change heightens the importance of having an independent Climate Change Commission. Every two years, the Climate Change Commission will report to the Government of the day on progress towards the NAP, with the Government required to produce a reply in writing within six months.

This will provide an opportunity to tweak the Plan, and to make political adjustments when there has been a change of government.