On 10 December 2009, the third piece of legislation required for the reorganisation of Auckland's governance, the Local Government (Auckland Law Reform) Bill, was introduced. In a statement issued earlier, Minister of Local Government Rodney Hide confirmed that this third bill will provide the detail in relation to Auckland's new governance structure:
The two previous Bills have been about the what - the structure Auckland's new Council will have, and the who - the power and roles of the mayor, councillors and local board members. This Bill is about the how.
Among other things, the third bill:
- Provides for the transfer of staff, assets and liabilities of Auckland's existing councils to the new Auckland Council.
- Sets electoral expense limits based on total constituency population, and other electioneering rules. Mayoral candidates will be able to spend about $580,000.
- Prohibits any new reorganisation proposals for Auckland for 3 years, to ensure the current round of changes have a chance to settle in.
- Provides that Local Boards will be able to propose local targeted rates for local activities and amenities.
- Provides that any disputes between the Mayor and Councillors and a Local Board will be managed through a process of binding resolution by the Local Government Commission.
- States that Auckland Councillors and employees of the Auckland Council may not also be members of Local Boards.
- Provides, from 1 July 2012, for one long-term plan for all Auckland and a single rating system across Auckland. Interim planning, reporting and rating requirements will be undertaken by the ATA, prior to its dissolution.
- Provides that rates will be levied on the basis of capital valuation, but the introduction of the new rating system will be managed so as to protect ratepayers from any sudden and significant increases.
- Creates three Council Controlled Organisations ("CCOs") to deliver Auckland's infrastructure services (Watercare Services Limited, Auckland Transport and Waterfront Development Agency).
- Proposes for the establishment of new CCO's.
- Disqualifies Auckland Councillors from appointment to the Boards of CCOs wholly owned by Auckland Council, except for the Auckland Transport Agency which may have up to two Auckland Councillors appointed as Board members.
- Provides for the establishment of an independent statutory board with representatives of recognised mana whenua groups who wish to participate and representatives of taura here (Maori whose traditional iwi ties are outside of Auckland) appointed by the mana whenua Board representatives.
- Provides that this statutory Board will have a mandate to promote social, economic, environmental and cultural issues of significance for mana whenua and taura here to assist the Auckland Council in its decision-making; and be able to appoint persons to sit on the Auckland Council Committees, in particular those that deal with the management of stewardship of natural and physical resources.
- Provides for the establishment of a Pacific advisory panel and an ethnic advisory panel for the first term of the Auckland Council.
- Finalises arrangements for the delivery of water and wastewater services in Auckland through Watercare Services Limited.
The Minister has said that "[a]fter 50 years of meandering debate, a government has finally acted to meet the needs of Auckland". However, criticism of the third bill has already begun. Two major iwi in Auckland are considering boycotting the proposed statutory mana whenua / taura here board, while Auckland and national Maori leaders have purportedly resolved to support a Treaty of Waitangi case against the lack of representation on the Auckland Council itself. The absence of specified powers for Local Boards has been noted by more than one commentator, as has the proliferation of CCOs to deliver Council services (albeit under the policy direction set by the Council itself). The concern that moving from eight rating systems to one will produce huge rates increases and decreases has also been voiced, and the "rates revolt" caused by the Auckland Regional Council trying to introduce a single rating system in 2003 remembered.
The Minister will be hoping that the actual drafting and content of the Bill will vindicate his efforts and silence his critics. Meanwhile, interested persons will be hoping that, unlike in respect of the recent Emissions Trading Scheme legislation, they will be granted more than two weeks to read, digest and formulate an opinion on the third bill. The Select Committee process will likely prove to be a valuable mechanism for polishing this last piece in the Auckland reorganisation puzzle.
The third bill is due to be passed in May. Public submissions have not yet been called for.
New boundaries for Auckland
The Local Government Commission has presented its proposals on the boundaries and representation arrangements for the new Auckland Council.
Under the Local Government (Auckland Council) Act 2009, the Commission is required to determine boundaries for the new Auckland Council, wards and local boards, ward and board names and the number of members per local board. The determinations must be made by 1 March 2010.
The Commission is proposing:
- 12 wards, and a total of 20 Auckland Councillors, comprised of:
- eight wards with two councillors each; and
- four wards with one councillor each; and
- 19 Local Boards with Local Board membership numbers ranging from five to nine, for a total of 126 Local Board Members
Each Auckland councillor is proposed to represent between 53,590 and 88,000 people.
The Local Government Commission's proposals can be viewed at www.lgc.govt.nz.
Helen Liava'a / Allison Arthur-Young
New Zealand's "new and improved" ETS
After months of debate, and two days sitting under urgency, on 25 November 2009 Parliament passed the Climate Change Response (Moderated Emissions Trading) Amendment Act 2009 by a narrow majority of 63-58, with last minute support from the Maori Party.
The Act amends the Climate Change Response Act 2002 by modifying the Emissions Trading Scheme ("ETS").
National's objectives for the Act were to:
- reduce competitive impacts of the ETS and provide greater certainty for economic growth;
- provide a smoother transition for participants into the ETS and protect against price volatility in early years;
- ensure the ETS is affordable within current fiscal constraints;
- maintain flexibility to respond to possible changes in post-2012 international climate change arrangements;
- maximise the degree of harmonisation with the Australian Carbon Pollution Reduction Scheme, in particular to reduce trans-Tasman competitiveness risks; and
- improve the administrative effectiveness of the ETS.
A wide range of concerns have been raised in respect of the likely effectiveness of the revised ETS scheme, with a key criticism being that it fails to adequately bring home the costs of emissions to "polluters", instead leaving those costs to be picked up by the taxpayer.
Main changes to the ETS
The primary points of difference are:
- The commencement of unit-surrender obligations for the liquid fossil fuels, stationary energy, and industrial processes sectors shifts from 1 January 2010 to 1 July 2010.
- Participants in the liquid fossil fuels, stationary energy, and industrial processes sectors are only required to surrender 1 eligible unit for every 2 tonnes of CO2-e (carbon dioxide equivalent) emitted and have an option to pay $25 in lieu of surrendering a unit in satisfaction of unit-surrender obligations from 1 July 2010 to 31 December 2012.
- The export of New Zealand units from the ETS is prohibited (except for forestry-related New Zealand units) from 1 July 2010 to 31 December 2012.
- Participants in the forestry sector are required to surrender 1 eligible unit for every tonne of CO2-e emitted and have the option to pay $25 in lieu of surrendering a unit in satisfaction of unit surrender obligations from 1 January 2008 to 31 December 2012.
- Free allocation of New Zealand units will be provided to emissions-intensive, trade-exposed industries on an intensity basis.
- The commencement of unit-surrender obligations for the agriculture sector will be delayed until 1 January 2015.
- The free allocation of New Zealand units will be provided to the agriculture sector on an intensity basis.
- The point of obligation for the agriculture sector will be set at the processor level initially, with flexibility to move the point of obligation to the farm level in the future.
- The free allocation of New Zealand units to the fishing sector will increase to 90% of 2005 emissions levels for 1 July 2010 to 31 December 2012.
Australia
Australians have also been having a difficult time with their proposed ETS scheme. Prime Minister Kevin Rudd had hoped to take an ETS scheme to Copenhagen, but the proposed ETS was voted down by the Senate.
Australia's position poses a problem for our Government as alignment with the proposed Australian scheme was one of the main reasons given for pushing through some last-minute changes on the ETS (eg placing more of the emissions costs on to taxpayers and delaying the entry of agriculture into the scheme to 2015). The Australian situation also puts plans for a trans-Tasman carbon market in doubt and there is already speculation that this could prompt heavy emitters to consider moving to Australia to avoid being charged in New Zealand.
Copenhagen
After initially dismissing the UN Climate Change conference in Copenhagen as a "photo opportunity", Prime Minister John Key has made a last minute decision to attend.
A key issue for our negotiators is in relation to New Zealand's overall emissions target. Under existing Kyoto Protocol rules, New Zealand's emissions will sharply increase after 2020, when the major 1990s forest plantations will be ready for harvesting. Under the current rules, unless forests are replanted on the same land, the carbon emissions due to the harvesting of those trees must be counted. New Zealand officials are trying to secure recognition that not all the carbon that is sequestered by trees is released at harvest.
The Prime Minister has also made it clear that New Zealand's emissions target is dependent on the rest of the world reaching a new deal on climate change.
Another key issue for New Zealand at Copenhagen is in relation to land use and agriculture issues, as agriculture makes up a significant portion of our emissions. Negotiators will want to secure new rules around agriculture (especially dairy cattle) emissions so that those emissions can be treated differently until technical developments can be made to reduce emissions in this area.
Liz Hardacre / Allison Arthur-Young
Review of Land and Subdivision Development Standard
Standards New Zealand is reviewing the Land Development and Subdivision Standard (NZS 4404:2004) ("Standard") and has recently released a proposed draft standard for public comment.
The Standard provides for comprehensive design standards in relation to earthworks, roads, drainage, water supply, services and landscaping, and it is widely used by territorial authorities and designers to test technical compliance for the subdivision and development of land. Some territorial authorities have adopted the existing standard in its entirety, others with amendments, and others have produced their own documents for the same purpose.
The impetus for the review arose from requests for changes from Government entities, including the Ministry for the Environment ("MfE"), New Zealand Transport Authority ("NZTA"), Local Government New Zealand ("LGNZ"), and individuals. Concerns had arisen that the existing standard was reviewed at a time when new thinking in urban design was emerging, but had not yet been sufficiently developed in the New Zealand context to be able to be incorporated at that time.
A review committee, comprising representatives of a number of organisations, including MfE, NZTA, LGNZ, Urban Design Forum and Road Controlling Authorities Forum New Zealand, was tasked with undertaking the review and providing a draft standard. The broad objective of the review is to obtain design outcomes for communities that emphasise liveability and quality of environments. In preparing the draft standard, the review committee sought to develop a revised document that:
- encourages sustainable and modern design;
- provides some certainty for designers and territorial authorities; and
- prevents the poor outcomes that can arise when the sole focus is cost minimisation and compliance with minimum standards.
The review was initially limited to editorial corrections, updating terminology for consistency with the National Road Classification and developing an informative appendix for general urban design and future-proofing of subdivision. However, the review committee quickly determined that in order to develop an informative appendix for general urban design and future proofing, significant changes were required to design standards in relation to roading and stormwater.
Roading
The current road designs standards table has been relied upon to produce good road design, although it has largely been used as a minimum standard to be achieved, encouraging highly uniform outcomes without much consideration for the place or context in which a road is located.
The review committee has determined that road design should be focused on achieving safe operating speeds and addressing the use of adjacent land.
Stormwater
The draft paper introduces a conceptual shift in the emphasis of the management and treatment of stormwater. Whereas the Standard had previously been focused on the management and treatment of stormwater once the water entered the stormwater drainage system, the focus is now on creating opportunities to utilise or replicate the natural drainage system through, for example, grassed swales, natural or artificial waterways, ponds and wetlands. The aim is to produce low impact design by providing for and / or replicating these natural drainage systems, particularly if low impact on receiving waters downstream is critical. Although this is the preferred approach, piped stormwater drainage networks may be required to support the preferred primary stormwater drainage system.
Climate Change
Developers will be required to consider climate change and potential sea level rise. As climate change is considered to be likely to increase the magnitude of some hazards, the review committee considered it important to incorporate risk management in the design of infrastructure supporting new developments to maintain the same level of service throughout the design lifetime.
Submissions on the draft standard close 5 February 2010. To view a copy of the draft standard, including the proposed specific details of the design standards in relation to roading and stormwater, click here.
Upper Clutha Environmental Society v Queenstown Lakes District Council
The Environment Court recently dismissed an appeal by the Upper Clutha Environmental Society ("Society") against a decision of the Queenstown Lakes District Council ("QLDC") to grant resource consent to the trustees of Matukituki Trust ("Applicant") to establish, occupy and maintain a residence on the eastern tip of Roys Peninsula, Wanaka.
Roys Peninsula is an elevated 440 hectare landform that stretches out into the middle of Lake Wanaka. The Environment Court described the Peninsula as clearly being the "visual and physical centrepiece within the Lake". It is accorded the strongest protection under the Queenstown Lakes District Plan ("District Plan") as being an Outstanding Natural Feature in an Outstanding Natural Landscape, and therefore consent for residential development (a discretionary activity) could only be granted in "exceptional cases".
In a planning process stretching over five years, the Applicant was initially declined consent by QLDC for a dwelling on a different site on the property, that application being opposed by the Council, a neighbour and the Society. The Applicant successfully appealed the decline of consent in the High Court, but subsequently lodged a fresh application for a dwelling on an alternative, less elevated, site on the property. The fresh application was granted consent in 2008 by independent commissioners and appealed to the Environment Court by the Society.
In upholding the grant of consent, the Environment Court acknowledged that the application package was "exceptional", with the combination of the unique physical features of the site, the innovative house design and the mitigation package resulting in adverse effects being no more than minor. These features included a recessive and partially underground dwelling integrated into the topography of the site, an extensive ecological restoration programme including control of animal pest and exotic weeds, revegetation of 98 ha of the 108 ha site in indigenous vegetation, restrictive covenants to prevent further development, the removal of existing telecommunication towers and the surrender of an existing unimplemented resource consent for the construction of a farm building.
In perhaps one of the most detailed cases ever presented to the Environment Court for a single dwelling, the Applicants provided expert evidence covering visual simulations, architecture, landscape architecture, opthamology, lighting, reflectivity, geomorphology, engineering, horticulture, ecology and planning. The Society challenged all these aspects of the Applicants case, albeit that they only provided "expert" planning, landscape and horticulture evidence.
The key issues in the case resolved around the application of the very detailed District Plan assessment criteria for dwellings on Outstanding Natural Features in Outstanding Natural Landscapes including effects on openness of landscape, visibility of the development, the visual coherence and integrity of landscape, nature conservation values and positive effects of the development.
The central issue was whether it was appropriate to have a dwelling located near the top of such a prominent landscape, even if the house met the District Plan criteria of being reasonably difficult to see. An associate professor of opthamology gave evidence for the Applicant that while the house would theoretically be visible from some distant locations, the likelihood of it being "spotted" in its proposed location was negligible. Landscape experts for the Society considered that knowledge of the mere presence of the house, even if not visible or if reasonably difficult to see, would be an adverse effect on the perception or "integrity" of the landscape.
The Applicant conceded that knowledge of what could not be seen could be relevant to some assessment criteria, such as integrity of the landscape or nature conservation values, however, assessment criteria on visibility, openness of the landscape and visual coherence all addressed what was able to be seen. In addition, if mere knowledge of an (unseen) dwelling could affect perception of the landscape, this should be balanced against knowledge of the proposed ecological restoration, the covenants protecting native vegetation and the prevention of further development.
A particularly unusual feature of the decision was the strong criticism of the evidential case presented by the Society. The Court found that little weight could be given to the planning evidence presented by the lay planner for the Society, who, although very experienced, was the current secretary of the Society and past long serving president. Equally the visual simulation expert who gave evidence for the Society was a former member (and trustee of the secretary's family trust), and his degrees were found to be in "general three-dimensional design with a specialisation in furniture and related product design". The Court considered that this explained the difficulty this witness had in comprehending aspects of the methodology of the Applicant's visual simulation experts. One of the landscape experts for the Society was found to have "cut and pasted" large sections, including conclusions, from the evidence of a colleague given in relation to the Applicant's previous house application on a different site. The other landscape expert's consideration of positive effects was limited to one sentence in a 47 page brief and "hardly suggested a balanced and impartial view to the case".
While ultimately the Applicant was successful in what was a very difficult and lengthy planning process, which might be seen as encouraging for development in sensitive areas, the Court noted that there was minimal scope for precedent value because of the highly detailed and prescriptive assessment criteria in the plan. In addition, the unusual combination of the natural physical features of the site and the design and mitigation package ensured that the application would enhance rather than degrade the site - the overall environmental effects would be positive. The bar for development on Outstanding Natural Features in Outstanding Natural Landscapes in the Queenstown district has been set very high.
Christian Brown / Nick Ravaji
National Environmental Standards for Telecommunication Facilities - Users' Guide
The MfE has released a users' guide to implementing the Resource Management (National Environmental Standards for Telecommunication Facilities) Regulations 2008 ("NES") for practitioners in local government, the telecommunications industry and the public generally.
By way of background, in October 2008 the NES came into force. Prior to the implementation of the NES there was considerable variation between territorial authority district plans in terms of how they addressed and controlled the installation of telecommunication antennas (or masts) and equipment cabinets in road reserves. For instance, the infrastructure could be a permitted activity in one district but a discretionary activity in an immediately adjacent district, making the process to gain planning approval to build such infrastructure a time consuming and expensive process. The NES sought to provide more certainty and improve telecommunication infrastructure by providing that the following activities by network operators were permitted activities:
- The planning and operation of a telecommunication facility, provided it complies with the New Zealand Standard regarding maximum exposure levels to radiofrequency fields.
- The installation of telecommunication equipment cabinets in a road reserve, subject to specified limitations on their size and location.
- Noise emitting from telecommunication equipment cabinets in a road reserve, subject to specified noise limits.
- The installation or replacement of masts and antennas on existing structures in a road reserve, subject to specified limitations on height and size.
The controversy surrounding the NES concerns the lack of consultation or community consent required with respect to the location of new telecommunications infrastructure, and the fear that the proliferation of such infrastructure may increase the risk of people being exposed to what some people argue to be potentially dangerous electromagnetic radiation. The NES removed the requirement for telecommunications companies to obtain resource consent for some low impact structures by the roadside, and although telecommunications operators are required to comply with the requirements of the district plan (in terms of the specific areas or values the community wishes to protect or manage), community input regarding the location of new telecommunications infrastructure is limited.
Recently, Prime Minister John Key stated that he would recommend Cabinet undertake a review of the lack of consultation requirements in the NES process generally.
Please click on the following link to be taken to the User's Guide - http://www.mfe.govt.nz/publications/rma/nes-telecommunication-facilities-user-guide/nes-telecommunications-facilities.pdf.
Updating the HSNO Regulations
The Environmental Risk Management Authority ("ERMA"), in conjunction with the MfE, is calling for public submissions on proposals to amend the hazardous substances classification framework under the Hazardous Substances and New Organisms Act 1996 ("HSNO"), to reflect the current United Nations Globally Harmonised System of Classification and Labelling of Chemicals ("GHS").
The Hazardous Substances (Minimum Degrees of Hazard) Regulations 2001 and the Hazardous Substances (Classification) Regulations 2001 were developed from draft proposals for the GHS that were available in 2000. Since that time, the finalised GHS has been published by the United Nations and a third revised edition was released in July 2009. Consequently, there are now several areas of difference between the classification framework of the HSNO regulations and that of the GHS.
ERMA has produced a discussion paper which identifies the differences between the HSNO regulations and GHS, and which discusses the processes other countries have employed to adopt the GHS classification system.
The paper suggests proposals and options for updating the HSNO regulations to align with some of New Zealand's major trading partners. If the HSNO regulations are not updated to correspond with the internationally adopted form of the GHS this may have significant cost implications for industry, particularly in relation to the labelling of imported chemicals. As Australia is proposing to adopt the 2009 version of the GHS it is essential to the trans-Tasman trading relationship that the HSNO regulations are updated to avoid inconsistencies between the two systems.
Potential benefits of revising the regulations include:
- facilitation of trade with other countries that have adopted the GHS;
- harmonisation of labelling requirements with overseas requirements;
- greater transparency in classification;
- increased efficiency in chemicals management and increased effectiveness of the HSNO Act; and
- decrease in compliance costs, both for regulators and industry.
The consultation being undertaken relates only to the classification framework contained within the HSNO regulations and does not concern other parts of the regulatory framework, such as labelling requirements, or the classifications assigned to particular substances.
Submissions on the proposed amendments to the regulations close 19 February 2010.
Click here for a link to the ERMA website and discussion paper, including a table of the amendments sought to the regulations.
No bridge over troubled water for ECan
The Government has recently announced a review of Environment Canterbury ("ECan") due to poor performance.
ECan is to be reviewed under section 24A of the Resource Management Act 1991 ("RMA"), which is the first time the provision has been used. Section 24A empowers the Minister for the Environment to investigate the performance of a local authority and it can potentially lead to an exercise of the Minister's residual powers under section 25 of the RMA which empowers the Minister to appoint one or more persons to perform the functions of the local authority. A second component of the investigation is a non-statutory review of ECan's governance and policy functions under the Local Government Act 2002.
The Minister for the Environment, Hon Nick Smith, had been openly critical of ECan, labelling its performance as "hopeless" in Parliament in June. In defence of ECan, its poor performance is in part explained by it having a large and complex consent workload, particularly in the flashpoint area of freshwater management, where central government leadership has been lacking.
However, the Minister has criticised ECan's performance across all consenting categories. The Environment Court made the following comment in relation to the ECan's struggle to promulgate its weighty regional plan:
It is one of the disappointments of resource management in Canterbury that after seven years the Regional Council has not yet finished its hearings on the proposed NRRP, and consequently has not released any decisions, let alone put a full regional plan into operation.
There must be something in the Canterbury water this year. Following a reported rift between urban and rural interests, in September a motion of no-confidence was passed in respect of chairman Sir Kerry Burke, with Alec Neill voted in as the new chairman. The Auditor-General's office is currently investigating whether four councillors had potential conflicts over water interests and ought to have voted on proposed water charges. Prior to the ECan review being announced, Canterbury region mayors had written a letter to Local Government Minister Hon Rodney Hide complaining about ECan's performance. Meanwhile a radical shake-up of water governance has been formulated in the Canterbury Regional Water Management Strategy.
Former Deputy Prime Minister Wyatt Creech will oversee the investigation of ECan's resource management functions. Chairman Alec Neill has welcomed the review, and says the ECan will work cooperatively with the review team.
Some further thoughts on Project Hayes decision: The Court going too far or a lack of policy direction?
The recent decision by the Environment Court regarding Meridian Energy's Project Hayes raises questions about the future of new renewable generation, especially wind-farms. In particular, is the Court the right body to be setting national policy for wind-farms and is insufficient regard being had to climate change goals in the RMA context, or is there simply insufficient guidance from central government on the issue?
Project Hayes involved the construction and operation of 176 turbines on the high plateau of the Lammermoor Range in Central Otago. It would have provided "clean, green" power for 278,000 homes while contributing very little carbon to the atmosphere. One of the primary reasons the Environment Court declined to grant consent was the adverse visual impact on the outstanding natural landscapes in the vicinity of the site.
It is not unusual for large projects to be refused consent on the grounds of one or two unacceptable adverse environmental effects. Indeed, only the Court has the opportunity to hear and weigh all the expert evidence regarding a proposal. On balance, the Court in the Project Hayes decision seemed to find the national and regional benefits were outweighed by the impact on the local environment. This balancing act is common for many large-scale infrastructure projects.
But the question must be asked whether the Court has failed to have due regard to the national benefits of the project. The reduction of carbon emissions (or more accurately the use of carbon-free power generation in place of carbon-emitting sources) is already an important national goal and is included in the RMA through s7(i) - the effects of climate change is a matter that decision makers shall have particular regard to. If the latest international round of negotiations in Copenhagen result in a binding framework for significant reductions, then New Zealand will need to consider and adopt significant measures to reduce carbon emissions.
In the context of a pressing need to first halt, then reduce, the number of carbon emitting sources, the Court may need to give significant weight to the benefits (political, economic and environmental) of carbon-free renewable energy. But is it the Court's job to elevate carbon issues above other environmental concerns? If the Government is serious about renewable energy and carbon reduction, then perhaps this should be reflected in legislation.
Equally interesting are the Court's comments that wind-farms should be sited in locations other than outstanding landscapes. Even though the comment was obiter and did not directly affect the decision, it was a comment to send "shivers down the spines" of power generators. One of the principles of the consenting process is that the Court should only consider the proposal at hand. Statements from the Court that wind-farms should only be located in non-outstanding landscapes are arguably too prescriptive and could amount to wind-farm licensing. Each proposal need to be considered on its merits. Whilst a consideration of alternatives can be relevant, the RMA is not a "best use planning" statute, and the proper question is whether any particular development proposed promotes sustainable management.
Some form of broader national policy on wind-farm locations could be useful for, and no doubt welcomed by, the industry. The UK Government is introducing a national policy on this very issue to provide guidance on the balance between national benefits of wind-farms with local concerns. This is an appropriate course of action, as it should be the Government rather than the Courts determining such policy.
The Court's decision in respect of the Project Hayes was cognisant of this lack of national policy direction in addressing the balance between national benefits and local costs and the lack of an overall wind-strategy. It specifically noted that the New Zealand Energy Strategy to 2050 highlights the need to balance the two concerns but provides no guidance to local authorities (or the Courts) on how to achieve this. Perhaps it is therefore not surprising that the Court acted as it did and also choose to comment on the wider alternatives. The Government already has a lot on its plate with the Phase 2 RMA reforms, but it may need to add two more helpings: wind-farms and climate change.
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