The key steps in the public policy cycle are also logical steps in plan development:
- identifying the issue
- setting objectives in relation to the issue
- choosing and evaluating the policy and methods to achieve the objective
- implementing the policy and objectives through the chosen methods
- monitoring and evaluating the effectiveness of the policies, methods, and the environment.
A plan needs only to contain objectives, policies and rules. However, the complete planning process is a logical model to use in plan development and monitoring, and many of the steps are implicit within the duties and requirements of other sections of the RMA (such as ss32 and 35). Provisions, other than objectives, policies and rules can be contained in external documents. The diagram below shows such an arrangement.
Section 79 allows councils to amend any provision of regional or district plans. The section also requires councils to review provisions of regional and district plans at least every 10 years; in so doing councils can choose to amend only the parts of the plan that need to be amended, to be brought up to date. The above planning policy cycle process is equally applicable and relevant to such a rolling process.
- Issues: As an alternative to containing issues in the plan, these could be contained in s32 reports (forming part of the justification for provisions of the plan). It is difficult to evaluate the extent to which objectives are appropriate to achieve the purpose of the RMA without having reference to issues. Therefore issues are usually explicitly covered in s32 reports. Alternatively, issues could form part of the explanatory material in a guide to a plan. Such a guide may not have a statutory function, but would enable plan users to understand why certain provisions existed, and what effects were sought to be avoided, remedied or mitigated. It could also be referred to in making decisions on resource consents as an 'other matter ' under s104(1)(d).
- Objectives in relation to issues: These are mandatory in RMA plans, but each objective is also required to be evaluated (in terms of appropriateness) under s32(3)(a). Refer to the Section 32 guidance note for further information.
- Choosing and evaluating policies and methods to achieve the objectives forms a critical part of the s32 evaluation process to the extent that the policies and methods, and the justification for their existence, and the consideration of them against other potential policies and methods, will be covered. Having chosen the policies and methods to be used, these may then be drafted for inclusion in the plan. It is mandatory for the plan to contain the policies and rules (with rules being a method), but methods other than rules could be transferred to other documentation either as information (for example, in a guide to the plan) or as capital or operational programmes (in which case they may appear in Long Term Council Community Plans, annual plans, or asset management plans for example).
- The way in which plan provisions are implemented are not recorded in the plan itself. However s35 of the RMA requires councils to keep records of decisions made with respect to notification and service of notice decisions made on consents, and complaints about breaches of the RMA and RMA plans (amongst other things). This information forms an important resource for reviewing plan provisions and identifying new issues; a summary of it could appear in background reports to a plan review.
- Monitoring the effectiveness and efficiency of plans is also a mandatory requirement under s35. The results of this monitoring are required to be made available to the public at intervals of no more than five years. Information relevant to this duty, such as environmental results expected, can be placed in documents outside the plan (such as in s35(2)(b) reports). Refer to the Policy and Plan Effectiveness guidance note for further information.
Note: Use of a dashed line indicates items of the public policy or planning cycle that can be contained in plans at the discretion of a local authority, but are not mandatory.
