Submission on the draft National Adaptation Plan


This submission is based on the Deep South Challenge: Changing with our Climate experience of funding and delivering expert climate modelling and adaptation research and science. It has been compiled by the Challenge Leadership Team and Engagement Team.

In general, our submission follows the structure of the NAP itself, with a few key differences. Rather than honing in on a single focus area, we respond to each of the three NAP focus areas, including each outcome area. However, as a matter of priority, we also respond to key documents and issues the NAP does not cover sufficiently. These are: Te Tiriti o Waitangi; the Rauora Framework; and the criticality of consultation and engagement. We also respond to the Research Strategy much earlier in our submission than where it appears in the NAP. We believe the Research Strategy is a vital piece of the adaptation puzzle, and deserves far more visibility. We include, separately, reflections that relate specifically to Vision Mātauranga – reflections gathered through research and engagement. In most parts of our submission, we reference relevant Deep South Challenge research. In summary, the entirety of this submission is based on both our research and our engagement experience of the past eight years.

Climate change is no longer a phase we are entering but one we are firmly within. There is compelling evidence of changing climate conditions. Every day there is news of another deluge or stop bank breach. Subtler indications – like the early Pōhutukawa bloom – demonstrate our transition from a more predictable past to a more uncertain future. The pace of securing a united universal response to climate change has been widely criticised with calls to action now adopting a much more urgent tone. Aotearoa is at a crucial point in time where we as a small island nation must decide how bold, how urgent and how transformative we are going to be to address our changing climate today and how to plan and adapt for a more resilient future.

To this end, The Deep South Challenge amplifies the messages clearly stated in the Rauora Framework, 2021, which we have read alongside the Government’s first draft National Adaptation Plan (NAP). This is a significant step in preparing Aotearoa for ongoing climate change and The Deep South Challenge (DSC) welcomes the opportunity to provide a submission on the draft NAP.

We recognise the significant value in having a national adaptation plan that acknowledges and supports the rich and extensive knowledges held within our communities – including tangata whenua, the research community and industry. To create meaningful, relevant and enduring solutions to the climate crisis, the NAP can take a multi-layered approach, acknowledging the impacts of climate change across our social, cultural, environmental and economic fabric, while balancing the need for efficiency and immediacy in the Government’s response.

This submission canvasses the various chapters of the NAP and responds with key messages in relation to each chapter. Under each outcome area, we have also included a Vision Mātauranga section which specifically highlights the unique submission points regarding Māori. In particular, we were looking for evidence that the NAP has drawn from or is underpinned by The Rauora Framework.

Key Submission Points

Our key submission points, below, are elaborated on in this submission document:

  • Embedding Te Tiriti as an outcome area would strengthen the overarching framework of the NAP. Rangatiratanga and Kāwanatanga spheres are not evident in the NAP, and the proposed Māori foundation is a “supporting action” towards an objective rather than an objective in its own right. This falls well short of genuine partnership. Along with a reworking of the Vision, Purpose and Goals to reflect the Crown’s Te Tiriti obligations and a stronger commitment to equity – this would provide a strong foundation for the NAP and a consistent reference for how partnership opportunities are framed through the various outcome areas.
  • The NAP should show clearly how it has “drawn on” the Rauora Framework. There is a lack of consistency in the language between the two documents. The authority of the Rauora in relation to the NAP must be clarified and strengthened to avoid it being relegated beneath the NAP. As it stands, the relationship between the Rauora and the NAP is vague and lacking substance. The Rauora is a powerful document but under-utilised by the NAP. Failure to genuinely incorporate the recommendations of the Rauora risks the appearance that its commissioning was merely a ‘tick box’ consultation exercise.
  • The Research Strategy should be more foundational in the NAP. The Strategy itself requires more safeguards for research that is outside the boundary of “traditional” biophysical science. In the research strategy section of this submission we have included a number of research actions that we believe should inform the NAP, these actions include development of funding, identification of priorities to close climate adaptation knowledge gaps and investment in research that is Māori-led, with a focus on mātauranga and tikanga, community relevant and engaged research and research that also considers the socio-political and economic impacts and opportunities in climate change.
  • The provision of and access to climate change data for communities must be prioritised. Alongside this, the need for targeted and appropriate engagement to share information with communities is important to create meaningful change.
  • The system-wide actions should be integrated into the front-end of the framework as they respond to the three key focus areas of the NAP. This would give the system-wide actions relevance across all outcome areas.
  • There should be greater alignment of the actions against the objectives (perhaps via visual representation). The current layout makes it difficult to connect the actions with the relevant objective(s). Adding context as to how each action works to achieve the relevant objective would also be helpful.
  • The NAP should make it clear how adaptation will be embedded and integrated across policy areas in practice. In particular, adaptation-relevant policy and legislation must be developed as a suite, rather than in silos.
  • Creating clear adaptation goals that are shared across key areas is important for clarity and shared understanding.
  • The NAP must provide much clearer guidance to He Pou a Rangi – the Climate Change Commission on how to measure Government’s performance against and implementation of the NAP. He Pou a Rangi – the Climate Change Commission must also have the ability to carry out such monitoring.
  • A broader range of primary sector businesses should be supported in the NAP to consider effective adaptation

Read the full submission here: