Part 3: Implementing and monitoring climate actions

3.1
We considered whether each council had clearly identified a response to climate change. We were interested in the role of climate strategies in shaping and prioritising climate actions. We were also interested in the performance monitoring frameworks that the councils established for monitoring and reporting on those actions.

3.2
We expected councils to have strategies and implementation plans, and we expected to see them using those strategies to prioritise their climate actions. Where councils did not have specific climate strategies, we expected to see strong alignment of a council's climate actions with its overall strategic priorities and for those actions to be prominent in the council's strategic plans.

3.3
We also expected to see councils using robust performance monitoring and reporting frameworks to show the progress of key actions.

3.4
All four councils had identified climate change as a strategic priority in some way. All had declared a climate emergency. Two councils had climate change or climate resilience strategies, and a third council was preparing one.

3.5
All four councils were actively responding to climate-related impacts and risks and were carrying out specific activities to address them. They were at varying stages of embedding climate change considerations into organisational policies and core functions.

3.6
In our view, all four councils could make better use of performance monitoring and reporting frameworks, particularly given the prominence they have given to responding to climate change in their strategic objectives or priorities.

Councils should clarify how climate change strategies drive prioritisation

3.7
We have previously said – in the context of council infrastructure strategies – that strategies should tell the story about where councils are, where they expect to be, and how they intend to get there.² Having clear strategic objectives helps with understanding challenges, prioritising resources, and maintaining momentum.

3.8
A climate change strategy can be valuable if an organisation is at a relatively early stage of embedding climate change considerations into its policies, decision-making, and activities. Councils might also find them useful for other reasons, such as communicating intentions to the public and other stakeholders.

3.9
Two of the four councils (Whanganui District Council and Christchurch City Council) have a climate strategy document. Nelson City Council was preparing one when we spoke with them in late 2023 and early 2024. Although we did not audit these strategies, we did consider whether they clearly set the direction for the councils' action programmes.

3.10
In our view, the priorities for action in Whanganui District Council's 2021 climate change strategy are not sufficiently defined to guide the Council on a programme of climate actions. It was not clear to us the extent to which the strategy was setting the direction for, or assisting to prioritise, what the Council was doing in practice. Completing its local climate change risk assessment is an opportunity for the Council to clarify and refocus its climate change strategy so that it can more clearly set the direction for climate-related activities.

3.11
Christchurch City Council's 2021 Climate Resilience Strategy has a clear framework with 10 climate action programmes. Those programmes identify some initial actions for the Council to progress.

3.12
A "Phase 1 Implementation Plan" for the strategy focused on embedding climate resilience into the Council's processes, policies, and systems. The Phase 1 Implementation Plan also anticipated that the Council would write detailed action plans for each of the strategy's 10 climate action programmes.

3.13
Council staff told us that their focus has since moved away from implementation plans. They were instead identifying effective "implementation pathways" and influencing and supporting business units across the Council to fully embed climate resilience within their actions and the 2024-34 LTP, activity plans, asset plans, and infrastructure strategy.

3.14
Identifying delivery pathways for implementing the 2021 Climate Resilience Strategy is a new performance measure in Christchurch City Council's 2024-34 LTP. Council staff are making good progress on embedding climate resilience into the Council's processes, policies, and systems. For example, guidance on incorporating climate change into the LTP process was provided to staff during the 2024-34 LTP development, and the repair and rebuild options for Christchurch's South Library included a whole-of-life carbon analysis.

3.15
In June 2024, staff provided the first twice-yearly report to elected members about implementation of the 2021 strategy. This report noted 67 key climate actions under the strategy's 10 action programmes were under way or had been completed and 52 were planned for the remainder of 2024.

3.16
We saw evidence of climate resilience being considered at multiple points during the development of the 2024-34 LTP. However, LTPs tend to be reasonably high-level in terms of describing actions and structured around organisational delivery rather than the council's strategies. Christchurch City Council's LTP does not, therefore, refer to the 10 action programmes of the Climate Resilience Strategy.

3.17
In our view, the Council should clarify how the Climate Resilience Strategy – particularly the 10 action programmes – are reflected in the LTP and related strategic planning documents. The next twice-yearly staff report to councillors on the implementation of the strategy might be an opportunity to do so.

3.18
Nelson City Council's climate change strategy was still being prepared when we carried out our audit. Once the strategy is completed and adopted by the Council, we expect it to set the direction of the Council's response to climate change and provide long-term objectives and improved focus to a revised climate action plan (discussed below). In the meantime, Nelson City Council's climate actions are well aligned with its broader organisational strategic objectives and priorities, which include a clear focus on climate change.

3.19
Environment Canterbury does not have a climate strategy document. However, climate resilience features prominently in its overall strategic framework and had, until recently, been reflected in its operational portfolio structure.³ This meant that climate resilience had been prioritised and resourced, and portfolio-level reporting had helped to provide accountability and maintain momentum. The documents we saw on climate-related activity consistently demonstrated how actions aligned to Environment Canterbury's strategic objectives and what the actions were intended to achieve.

3.20
Because Environment Canterbury's 2024-34 LTP organises its work around three core services, climate change is no longer explicitly identified like it was under the previous portfolio structure.⁴ We encourage Environment Canterbury to consider whether it, too, now needs a dedicated climate change strategy to maintain focus on what remains one of its four strategic priorities.

All four councils are actively responding to climate-related impacts and risks

3.21
Environment Canterbury has had a project under way to prepare a region-wide climate action plan that involves all Canterbury councils. It has also prepared its own climate action plan. It has already firmly embedded climate change considerations into its river resilience programme, and it provides technical support to other councils in the region with their work on coastal adaptation.

3.22
As noted above, Christchurch City Council has reported many climate actions that are completed or ongoing. These span a broad range of the Council's operational activities. They also include embedding climate change considerations into organisational processes.

3.23
Nelson City Council has similarly documented multiple actions in a 2021 climate action plan. These actions encompass risk identification, emission reduction, and adaptation and include council processes and operations as well as community-focused activities. We understand the 2021 climate action plan has been updated concurrently with work on the Council's upcoming climate change strategy.

3.24
Whanganui District Council has a more discrete programme of climate change activity, with staff reporting against 21 initiatives. The programme covers both emission-reduction and adaptation initiatives.

3.25
All four councils were carrying out some similar activities. For example, all four councils were engaged in some way in coastal hazard adaptation planning – possibly one of New Zealand's most challenging climate-related adaptation issues. How each council is involved in coastal hazard adaptation planning differs according to each council's role, local environmental challenges, resources, and preferences.

3.26
Christchurch City Council, for example, has engaged a community-based coastal panel to provide informed recommendations to the Council on adaptation options in the Lyttelton/Port Levy areas. Nelson City Council is leading its community engagement. Whanganui District Council is supporting a community and hapū collective – Ngā Ringaringa Waewae – in the first round of coastal action planning. Environment Canterbury supports other Canterbury councils' coastal adaptation work (including Christchurch City Council's coastal panel) with technical and specialist expertise.

3.27
Councils told us that the lack of a national legislative and financial framework governing major climate adaptation was a challenge. We heard that certain adaptation options currently lacked sufficient legislative basis to manage legal risks,⁵ or that the public might lack confidence that plans made now would be followed through by future councils. Although a legislative and financial framework might ultimately be necessary for carrying out some adaptation options, in the meantime councils are getting on with having important conversations with at-risk communities and exploring what matters to them and what adaptation options look like.

3.28
These conversations are an important prerequisite to decisions that will need to be made about adapting to the impacts of a changing climate. Although central government has a role in providing appropriate legislative frameworks, in our view councils need not see the current absence of a legislative and financial framework for adaptation as a reason not to begin adaptation planning.

3.29
Some of the four councils' climate-related activities were well advanced. As noted above, climate change considerations are well embedded in Environment Canterbury's river resilience programme. Similarly, both Christchurch City Council and Nelson City Council have made good progress in working through the Dynamic Adaptive Pathways Planning process in their climate adaptation planning.⁶

3.30
On the other hand, each council also had actions at an early stage of development. For example, the Canterbury Climate Partnership Plan – a regional climate response to identify joint action plans in which both Environment Canterbury and Christchurch City Council are involved – was in its early stages during our audit.⁷

Use of performance monitoring and reporting frameworks was mixed and could be improved

3.31
Councils need good performance information on their activities so they can monitor progress and provide a high level of accountability to their communities. A performance reporting framework should provide clarity about what the council plans to achieve in the short term and provide an indication of its plans and performance in the longer term.⁸

3.32
Because all four councils had identified climate change as a strategic priority, we expected them to have frameworks in place to monitor and report on their progress in implementing key climate actions. We looked at service-level performance measures⁹ in LTPs as well as any available governance and management-level performance reporting.

3.33
We saw examples of both service-level measures and internal performance monitoring, but there is scope for most councils to improve how they formally report on their progress with key climate actions.

3.34
Some of Environment Canterbury's climate-related activities were identifiable in performance measures in its 2021-31 LTP. Staff also included other climate-related "key initiatives" alongside internal governance reporting on the LTP measures as if those key initiatives were part of the LTP performance reporting framework.

3.35
However, although climate change continues to feature prominently in Environment Canterbury's strategic priorities, fewer climate-related LTP performance measures were included when Environment Canterbury shifted from its portfolio organisational structure to its three core services structure for its 2024-34 LTP. We encourage Environment Canterbury to consider how it might give prominence to measuring and reporting key climate-related activities under its new core services structure.¹⁰

3.36
We saw good internal performance monitoring of some climate-related activities at Christchurch City Council. A Capital Programme Performance Report that staff prepare for the Council's Finance and Performance Committee provides useful performance updates about the major cycleway route construction as part of the capital projects portfolio. Major cycleway routes are a component of the Council's climate strategy. The updates allow councillors to see, at a glance, overall progress, performance against project budget, risks and issues, and how risks and issues are being managed.

3.37
Christchurch City Council's CHAP programme also had good management-level performance monitoring and reporting, showing the status of the programme's finances, schedule, scope, and resources. Key risks are identified along with mitigations or updates from previous reports. However, we did not see this information feed into governance-level reporting.¹¹

3.38
As noted earlier, Christchurch City Council has introduced a new performance measure in its 2024-34 LTP to identify implementation pathways for its Climate Resilience Strategy, replacing a previous measure about preparing the strategy. It also has several performance measures related to its goal of reducing vehicle emissions by encouraging non-car modes of transport.

3.39
We also note that, in its 2024-34 LTP, Christchurch City Council has introduced a new service level and performance measure for its CHAP programme. The measure is to "work with communities and rūnanga in low-lying coastal and inland communities to develop adaptation plans that respond to the current and future impacts of coastal hazards caused by climate change."¹² We consider that this new measure reflects an important and expanding climate response activity and is a useful addition to the Council's performance reporting framework.

3.40
Nelson City Council and Whanganui District Council have also introduced their first climate-related performance measures in their 2024-34 LTPs. Both measures relate to reducing emissions. We support these new additions. However, other than these new performance measures, we saw little other performance measurement related to Nelson City Council's and Whanganui District Council's other key climate actions.

3.41
In our view, greater use of performance measures is needed by all four councils for key climate-related initiatives, given the prominence that climate change has in their strategic frameworks and priorities and the impact it has on their communities.

2: Controller and Auditor-General (2022), Matters arising from our audits of the 2021-31 long-term plans, paragraph 3.13, at oag.parliament.nz.

3: Under its 2021-31 LTP, the work of Environment Canterbury was structured into five portfolios: water and land; biodiversity and biosecurity; climate change and community resilience; air quality, transport, and urban development; and regional and strategic leadership. Each portfolio had its own set of service levels and performance measures. The 2018-28 LTP was similarly structured.

4: For the 2024-34 LTP, Environment Canterbury has moved away from grouping its work in portfolios and instead focuses on three core services: environmental regulation and protection, community preparedness and response to hazards, and public transport.

5: For example, protection of existing use rights under the Resource Management Act 1991 has been seen as presenting potential challenges to local authorities in implementing managed retreat.

6: Dynamic Adaptive Pathways Planning is an iterative process described in Ministry for the Environment guidance on managing coastal hazards and climate change (Ministry for the Environment (2024), Coastal hazards and climate change guidance, at environment.govt.nz). The process is intended to help communities understand what is happening with climate change, what communities value, options to address change, and how to implement a strategy and review its effectiveness. See Appendix 1 for more information on this action area.

7: The Canterbury Climate Partnership Plan has since been finalised.

8: Controller and Auditor-General (2024), Local government planning and reporting on performance, page 14, at oag.parliament.nz.

9: Service levels are the attributes of services that a council commits in its LTP to formally report against in its annual reports. Each service level has a performance measure, which is how the service attribute will be assessed. For each performance measure, there is a target, which is the level of performance that the council aims to achieve.

10: Environment Canterbury has since told us that work has begun on a monitoring, evaluation, and reporting plan for the newly adopted Environment Canterbury Climate Action Plan. This includes identifying performance measures and determining how to integrate them into organisational reporting, including LTPs, annual plans, and annual reports.

11: A Council Coastal Hazards Working Group operated during the previous council term and may have received relevant performance updates. It has recently reconvened and had not received any reports at the time of our audit.

12: Christchurch City Council (2024), Our Long Term Plan 2024-2034, Volume 1, page 150, at ccc.govt.nz.