John Pask

Published: November 17, 2023

Submitting To: Ministry for the Environment (MfE)

Issue for Business: The rationale for MfE promoting the proposed NPS-NHD is the growing threat to NZ from natural hazards, increasing the risk to human life and property. MfE also states that the way local authorities identify natural hazards and make decisions on new development varies throughout the country. It should be noted that the proposed NPS-NHD will only apply to new infrastructure.

Action: BusinessNZ has submitted to MfE stating that it is arguable that a NPS-NHD is required for a range of reasons. The propsoed NPS-NHD refers to risk tolerance but there is no clear definition of what 'tolerable' or 'íntolerable' risk is, apart from relatively vague references to loss of property and/or potential loss of life. BusinessNZ considers that given owners and developers of infrastructure generally have strong incentives to build fit purpose, there is little role for regulators to restrict where development can occur, apart from where the potential externalities from a development may impact significantly on third parties and which are not adequately dealt with as part of the development.

Outcome: Awaiting MfE/Government decisions after submissions have been analysed.