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Analysis of Regional/District/City policies and plans

5.3 Data analysis 1 Plan Quality

5.3.5 Design planning approach

This approach consists of using design measures such as protecting and enhancing sand dunes as a buffer to erosion, building stop banks along rivers, setting minimum floor levels for flood risk and minimum earthquake strength. All structural works have their limits though and reliance on design can actually increase risk. The proposed RPS (in contrast with the operative RPS), BOPRC AP, ODC LTP, and TCC AP do not mention any design codes.

5.3.5.1 BOPCDEM Group plan

As this plan does not determine requirements for design it is not surprising that there is only one ‘physical works’ code referring to the fact that “flood protection is usually provided to a higher degree of safety in urban areas than rural areas” (BOPCDEMG, 2012, p10).

5.3.5.2 BOPRC RPS

The protection of ecological infrastructure to maintain “the integrity of natural ecosystems that are natural defences against flooding, inundation or erosion” (BOPRC RPS, 2010, p143) is one of the objectives of the RPS. ‘Physical works’ is coded more than any other design code in the document due to the flood management role of BOPRC. However, there are six codes that warn against the dangers of relying on these kind of physical works such as:

Natural hazard mitigation works can sometimes have the following adverse effects on people and communities… (b) Expectations of protection are not met because it is

physically impossible to build effective protection works for some types of natural hazards; and (c) Protection works may encourage further development and consequent increasing vulnerability when design levels are exceeded” (p143).

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Design approach in RPS & District/City Plans

5.3.5.3 ODC DP

Ecological infrastructure is encouraged in the plan such as dune planting programmes (under methods) and the benefits of planting forests (in the

introduction). Protection works will be considered when activities are threatened by a hazard but “should only be permitted where they are the best practicable option for the future” (alluding to limits) (ODC DP, 2005, p83). ‘Regulations’ codes include requiring “detailed site investigations prior to subdivision, use, or development of land subject to or likely to be subject to natural hazards” (p82).

5.3.5.4 TCC operative DP

There is strong mention of protecting ecological infrastructure (15 codes) and in particular the coastal environment as a defence against erosion and inundation. Dune protection and road policies both require enhancing the capacity of dune to act as a buffer to natural forces whenever possible. The plan makes mention of physical works five times, all in relation to storm water management but does not acknowledge the limits of such works. Design regulations also focus on coastal hazards as well as flooding. Minimum ground or floor levels of 2.7m- 2.9m (+/- 200mm) for new development are a requirement (TCC DP, 2006, p7) but if this is unable to be achieved “alternative mitigation methods, as

determined at the time of subdivision or land use consent” (p7) will need to be employed.

5.3.5.5 TCC proposed CP

This proposed plan includes 21 ecological codes (six more than the operative DP) and again focuses on maintaining or enhancing the strength of natural coastal defences. Regarding activities in the CHEPA:

All activities shall ensure that the site is reinstated so the natural buffering ability of the foredune is not compromised. All excavated materials from the site and other sites which comprise sand material shall be respread within the CHEPA and be re-vegetated with native dune plants. Revegetation

planting shall be established within 6 months of the respreading of the sand material (TCC CP, 2012, p9).

There is provision for physical works to protect infrastructure and lifeline utilities; however, such works should enhance natural protection where

possible. As with the operative DP there is no acknowledgement of the

limitations of physical works. Regulations within the CHEPA include: “buildings and structures must be able to be relocated and removed with minimal

disturbance to the land or adjacent land” (p10) and “increasing the gross floor area of a structure by more than 20m2 or projecting a building further seaward [is] prohibited” (p11).

Figure 14 Design approach in BOP LTPs and APs

5.3.5.6 BOPRC LTP

Regarding ecological infrastructure the BOPRC plans to “enhance the resilience of ecosystems by protecting significant natural habitats and ecosystems” (BOPRC LTP, 2012, p78). This plan has more design codes than any other with 41 physical works codes alone; the major focus being on the maintenance and construction of works to control flooding. There appears to be continued enthusiasm for more physical works in the future in response to climate change “We have planned to incrementally build the capacity of the assets across time

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Ecological Physical works Limits Regulations

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Design approach in BOP LTPs and APs

to meet the anticipated climate change predictions” (p192). However there is some acknowledgement of the limits of physical works in four codes including: “we cannot avoid all risk of damage from flooding, particularly if there is an intense flooding event above a scheme's design protection level” (p41).

5.3.5.7 ODC AP

There is only one ecological code in the small two-page section on emergency management.

5.3.5.8 TCC LTP

The LTP states in its only code, ‘regulations’ that “there are a large number of hazards controlled by [plans and regulations] which include determining minimum floor levels to prevent flooding and ensuring buildings are to the desired earthquake standard” (TCC LTP, 2012, p243). This author would argue that plans and regulations do not control hazards but when implemented the effects of hazards can be mitigated.

5.3.5.9 Findings

Within the operative RPS and the BOPRC LTP there is a major focus on the maintenance and construction of physical works in an attempt to control flooding. Whilst this may be a result of inherited catchment and drainage responsibilities, the creeping threat of climate change and the threat of creating a “safe development paradox” (Burby, 2006) raises the issue of how practical it is to continue upgrading existing works in the long term. In comparison, the proposed RPS does not have any physical works codes, but neither does it contain any ecological nor regulations codes unlike the operative RPS. Both the TCC operative DP and proposed CP have a strong emphasis on protecting ecological infrastructure in relation to the coastal environment.

The TCC LTP needs to reconceptualise its terminology on natural hazards after suggesting that plans and regulations can control hazards. It would be more correct to say that exposure can be regulated by these means.

The region has a plethora of policies and plans that can be used to reduce vulnerability. To make sure these documents are effective they need to have outcomes that are measurable so they can be improved. For vulnerability reduction, the financial, gender, health, political and social ties determinants of vulnerability need to be acknowledged and addressed better as a starter. Genuine public participation and engagement is needed in the formation of policies and plans and the ‘existing use’ rights conundrum presented by the RMA requires serious thought if we are going to make meaningful locational decisions to reduce exposure. Future design measures may need to be

reconsidered in the light of future climate change and the risk of creating a ‘safe development paradox.’ In the next chapter we will review how to more

effectively reduce vulnerability according to information and opinions gleaned from informants from around the Bay of Plenty.

Chapter Six