The Government recently released the National Adaptation Framework^[1], New Zealand’s first national strategy to guide how the country prepares for and responds to the impacts of climate change. It forms part of the Government’s response to the recent Inquiry into Climate Adaptation, which we discussed in earlier updates^[2], and is focussed on achieving greater resilience to climate change, and how and when adaptation needs to occur.

While commendable, in particular for its focus on the mapping of high-risk areas and pre-emptive planning for adaptation, for it to succeed, the Framework will require additional implementation tools and solutions to the ever present challenging of funding.

The Framework

The Framework is built around four pillars, with a total of 16 discrete actions, with the new highlighted below. 

Risk and Response information sharing	Roles and responsibilities	Investment in risk reduction	Cost-sharing pre- and post-event
A National Flood Map. NEW	New national direction under the RMA for managing risks from natural hazards.	Require Councils to weigh up the cost and benefits of adaptation options	Introduce a new development levy system to ensure Councils charge developers a proportionate amount of necessary capital expenditure.
New hazard datasets and risk standards.	Use the reformed resource management system to identify high-risk and areas for future growth.	Use the Funding and Financing Framework to guide investments in Crown assets or realise broader national benefits.	Deliver new tools to support government recovery decisions following severe weather events.
Update the Natural Hazards Portal.	Require local government to adopt adaptation plans in priority areas. NEW	Invest in resilience through the $1.2 billion Regional Infrastructure Fund.
Invest in high-quality risk information.	Invest in emergency management via the Emergency Management Investment and Implementation Roadmap.	Proactively manage risk to Crown assets over time.
Deliver science, innovation and technology reforms.	Focus local authorities on core services including managing natural hazard risk.

A number of the actions repeat existing policy announcements, or tie into other legislative reform. The two most significant NEW actions are the announcement of a new National Flood Map, which is to be developed by 2027, and the new requirement for district councils to prepare adaptation plans for priority areas.

A new National Flood Map

The intention for the National Flood Map is that it is a frequently updated tool that clearly identifies flood hazards for individual properties. The finer details of how this tool will be developed and managed remain unknown, with the cabinet paper indicating that options remain under investigation.

In our view, the consolidation of flood hazard data into a single accessible map could have significant advantages - by providing better information to property owners and prospective purchasers, infrastructure providers, insurers, and local government. However, there is a degree of overlap with the existing hazard maps managed by territorial authorities (through their district plans), regional councils (through their generally available hazard portals), the information sharing requirements under LGOIMA, the Natural Hazards Portal managed by the Natural Hazards Commission, and the Earth Sciences New Zealand (formerly NIWA) new national model for flood risk.^[3]

What would be of clear benefit is a set of clear and consistent standards to guide what degree of flood risk should be mapped as high-risk, to remove the differentiation that we see across regions and districts at present. Overall, having a source of information that provides a uniform understanding of ‘high risk’, can only be a sensible initiative for our country.  

There will be some key challenges that will need to be addressed as part of developing this new tool, including:

• Integration with existing data, and district plans:  Where a single National Flood Map is produced there will need to be clarity around how it interacts with regulatory (district and regional plan) maps, overlays, policies, standards and rules. Poor integration may lead to a National Flood Map that only adds uncertainty and confusion for landowners and regulators.
• Regulatory implications: Related to the above point, it will need to be resolved whether the tool will be used to guide other regulatory assessments under the Building Act 2004 and other frameworks, or the functions of local authorities more generally (including the issue of LIMs). Having clarity on who is responsible for the tool, and how it is to be used or challenged, will be critical to resolve - particularly given the history of challenge to the publication of hazard information that can impact capital value.

Local Government has a specific role adaptation planning

The Framework proposes to amend the Climate Change Response Act 2002 to require district councils to prepare adaptation plans for high priority areas for coastal and flooding risks. The purpose of adaptation plans will be to provide clarity in high-risk areas regarding the nature of those risks, management of them and future investment. 

It is expected that these amendments will be introduced in early 2026, and followed by further legislation that will set out process requirements for preparing adaptation plans. We understand that the delay in introducing these amendments is intended to ensure alignment with the new resource management system legislation, including the proposal for new regional spatial plans.  

However, the amendments to the CCRA will likely be significant, as while its purpose refers to developing national policies that will “allow New Zealand to prepare for, and adapt to, the effects of climate change”, the CCRA does not prescribe any particular roles to councils, or provide for sub-regional adaptation planning. The question should perhaps be asked whether this is the right place for this new planning requirement, or whether it should be wrapped up with the new spatial planning processes (particularly as there will presumably be equivalent consultation requirements).
 
There are some positives to take from the announcements in terms of their alignment with existing work and other proposed reforms, including:

• High priority areas will also be identified within new regional spatial plans prepared under the new resource management system. 
• There is an intention for adaptation plans to open up access to accelerated regulatory and/or investment pathways, although the details of these pathways remain unknown.
• There will be pathways for existing adaption plans that meet basic requirements to become adaptation plans under the new system. This is crucial for those councils that have already made progress in this space.

Overall, the proposed introduction of a new statutory framework for adaptation planning will be helpful. It will provide clear mandate and direction for adaptation planning that currently lacks ‘teeth’ in a statutory sense, but important questions remain. This includes whether additional powers will be provided to local government to implement any adaptation measures, including taking land, and also whether there will be any additional funding for adaptation. 

We suspect that some may see this as either a duplicate requirement, or one which lacks funding for an already overloaded sector. What is encouraging however is that the framework refers to managing natural hazard risk as a “core service” of local government, which suggests that the focus on “civil defence emergency management” in the Local Government (System Improvements) Bill may be amended. See our previous discussion of climate adaptation, in which we commented on several other regulatory barriers to managed retreat.^[4]

Special thanks to Jack Apperley for his help in preparing this article.