Towards sustainable tourism planning in New Zealand : Monitoring local government planning under the Resource Management Act

In the light of the increasing pace and scale of tourism activity in New Zealand, the concept of sustainable tourism has become a key ingredient in the nation’s tourism strategy. This paper explores sustainable tourism planning in New Zealand at the level of local government, and in particular, focuses on the implementation of the Resource Management Act 1991 (RMA) as a mechanism for achieving sustainable tourism. Using the findings of a survey of Regional Councils and Territorial Local Authorities, the paper explores public sector planning responses to tourism impacts and sustainability concerns in New Zealand. The paper extends the earlier work of Page and Thorn (1997. Towards sustainable tourism planning in New Zealand: public sector planning responses. Journal of Sustainable Tourism 5(1): 59-77; 2002. Towards sustainable tourism development and planning in New Zealand: the public sector response revisited. Journal of Sustainable Tourism 10(3): 222-238), which identified major issues of concern at local council level with regard to tourism impacts and argued the need for a national vision for tourism to ensure that the RMA achieved its original goals. Since then, a national tourism strategy has been published and changes in legislation have further empowered local authorities to further progress the sustainability agenda. This paper examines these developments and the ensuing implications, concluding that significant progress has been made in developing tourism policies at the local level, but that a number of constraints and issues limit the development of New Zealand as a sustainable


Introduction
Despite the problems associated with defining and operationalising the term sustainability, the concept continues to mature within tourism research and management (Page & Connell, 2008). A growing acceptance of sustainable development as an approach to tourism planning (Gunn & Var, 2002;Hall, 2007a;Weaver, 2006) has sparked academic interest in the implications for destinations and the way in which the impacts arising from tourism activities and developments are recognised, managed and mitigated. Alongside this, the consequence of international agreements on sustainable development, notably Agenda 21 and the obligations on local governments to embrace sustainable development within activities, policies and plans, is a general recognition that sustainability is now a direct consideration of the planning system. At both theoretical and strategic levels, the concept of sustainable development is now widely accepted as the basis for planning and managing current and future human activity (see Redclift, 2005). However, debates on the application of sustainability have stimulated a concern about the effectiveness of the integration of sustainable principles and practices within planning policies and processes, including tourism (Hall, 2007a). This is coupled with the more well-established issue of the lack of importance given to tourism as a core element in the planning process, despite its economic significance in many areas (Dredge & Moore, 1992). Accordingly, the success of sustainable tourism planning depends on existing planning and management functions that guide appropriate developments and the ability to respond to pressure on infrastructure and environments that increasing tourism demand creates (Bramwell & Lane, 2000;Hall & Page, 2006).
As Inskeep (1991) argues, the special relationship between tourism and the environment, based on a unique dependency on natural and cultural resources, requires a balanced approach to tourism planning and development to maximise the associated benefits and minimise the negative impacts (Dredge & Jenkins, 2007). If ill-planned or excessive development is permitted, tourism can damage the special qualities that are essential for sustainable development. Conversely, it is recognised that tourism can help to promote and support conservation, regeneration and economic development as well as enhance the quality of life of visitors and host communities (Holden, 2008;Wall & Mathieson, 2006). The importance of tourism within a sustainable development context is now acknowledged globally and, while not specifically mentioned in the original Rio Summit in 1992, was addressed as a specific topic in a review of Agenda 21 in 1997. In 2002, the World Summit on Sustainable Development included a submission on sustainable tourism (Chapter IV, paragraph 43) in the Johannesburg Plan of Implementation, which identified that while tourism has positive effects, uncontrolled tourism growth can undermine the basis of tourism. Such a situation is clearly a concern for the industry in New Zealand, where the most recent national tourism strategy (NZTS, 2015) (Ministry of Tourism, 2007) outlines the necessity of taking a prudent approach to future development and developing appropriate management responses to tourism-related pressures on the environment.
One of the overriding concerns about tourism in New Zealand is that the tourism product relies heavily on the natural and physical environment and the focus of marketing rests on the image of a 'clean and green' country (highlighted by Tourism New Zealand's 100% Pure marketing campaign). With the significant growth in tourism demand and the associated pressure of increased volumes of international and domestic tourists, conserving environmental resources has become problematic in some regions. Further, in New Zealand the need to understand the impacts of tourism has become important within a planning context because of the statutory requirements of the Resource Management Act 1991, which takes into account the environmental effects of activities, including tourism developments, within the planning system. While the primary intention of the Resource Management Act (RMA) is to advance sustainable management of natural and physical resources, some criticisms have been lobbied towards the implementation of the Act with suggestions that other mechanisms are required to move towards the goal of sustainable development (Parliamentary Commissioner for the Environment, 1998). In the case of tourism, Page and Thorn (1997) suggested that a national policy or strategy was required in addition to the RMA, if sustainable tourism goals in New Zealand were to be achieved. Since then, a national strategy has been produced, reviewed and subsequently updated, emphasising the sustainable development concept and the desirability of integrating environmental, economic, social and cultural considerations in the long-term management of tourism resources. However, the extent to which sustainable development ideology is translated into policy and practice requires investigation to uncover whether the new tourism strategy has improved this process, particularly given, as Dredge and Jenkins (2007:285-6) argue, that ''governments have become extremely canny in reproducing the sustainable development rhetoric without actually effecting fundamental policy shifts.''.
Accordingly, this paper explores the issues associated with incorporating sustainability in a planning context focusing on the example of tourism in the New Zealand planning framework. The study extends the work of Thorn (1997, 2002) and reexamines the issues that arose from the two previous surveys (conducted in 1995 and2001, respectively, by Page and of local authority planning departments concerning the integration of sustainability in tourism planning. In particular, this paper focuses on the impact of the innovative sustainability legislation embodied in the RMA, which engenders a planning approach that identifies and mitigates the impacts of new developments. As it is more than a decade since Page and Thorn's first study, and several years since the subsequent work was conducted, it seems timely to revisit this subject to chart progress in the development of sustainable tourism planning in New Zealand. A follow-up study is particularly important given the conclusions of the 2001 study, which outlined a number of problems and challenges for sustainable tourism planning within the existing tourism planning framework at the time (Page & Thorn, 2002). In particular, the lack of a central guiding vision for tourism at a national level was seen as problematic given the huge increases in international arrivals since the 1990s and the prevailing political philosophy of growth and development in the absence of a strategy to tackle the impacts of tourism. Since the political restructuring of the 1980s, a promotion-driven, market-led, macro approach to tourism at the national level has created significant repercussions at micro levels where the impacts have been experienced (Memon, Shone, & Simmons, 2005). A lack of central planning advice or a national tourism policy means that responsibility for planning for tourism developments and managing tourism impacts rests with local authorities. One of the biggest challenges identified by Page and Thorn (2002) was the geographical spread of tourists, where overcrowding and overdevelopment in key iconic destinations was a significant feature of tourism activity. Consequently, the benefits of tourism were focused in a few places rather than being spread more widely across a larger number of destinations. As Page and Thorn (2002) argued, a national tourism plan was needed to achieve more balanced, equitable and beneficial patterns of tourism activity and development for destinations and host communities. Accordingly, a third investigation to assess the progress made in tourism planning is opportune given the development of a national tourism strategy by the New Zealand Ministry of Tourism since 2001, changes in planning law and subsequent measures by local government to engage further in tourism. Since Page and Thorn's two earlier studies, growth in international arrivals to New Zealand has been strong, making the need for sustainable tourism planning ever more important and to ensure that sustainable policies are not simply just rhetoric. Coupled with the changing policy background is the growing appreciation of the economic value of New Zealand's environmental image for tourism through 'Brand New Zealand', which is worth billions of dollars a year (Ministry for the Environment, 2001). Business interests, for example Air New Zealand, are becoming increasingly concerned that the environmental resource base, and the image on which it is based, needs to be maintained for the country's competitive advantage (New Zealand Herald, 2008). However, as a PCE report on education for sustainable development (PCE, 2004) highlights, just because people value something does not mean that they will take good care of it. Such issues have major implications for the future of tourism in New Zealand.
The paper commences with a brief examination of tourism in New Zealand and the reasons why tourism has become a consideration of the planning system. Subsequently, the tourism planning context in New Zealand is briefly examined, including developments in legislation and policy that have emerged since Thorn's last study in 2001 (Page &Thorn, 2002). Following this, the methodology and findings of an empirical research study are presented, which aim to provide evidence of the state of sustainable tourism planning in New Zealand in 2007.

Sustainability, tourism and the Resource Management Act
Tourism continues to be one of New Zealand's most significant and fastest growing economic sectors with 2.41 million international arrivals in 2006, accounting for 19.2% of total export earnings and providing employment for 9.9% of the workforce (Statistics New Zealand, 2006). Between 1993 and 2007, the volume of international visitor arrivals doubled, with tourism becoming the country's top export earner. Forecasts indicate further growth in international arrivals of 4% per annum, reaching 3.17 million by 2013, with domestic tourism increasing by about 0.8% annually from 52 million to 55 million trips (New Zealand Tourism Forecasts 2007-2013 (Statistics New Zealand, 2006). While New Zealand is by no means a major global tourism destination in terms of volume, the rapid growth in visitor numbers to a small country with sensitive natural and cultural resources and a population of just over 4.2 million (Statistics New Zealand, 2008a) raises significant challenges for the sustainable development of the sector.
By global standards, New Zealand is perceived to be relatively clean and green but the emergence of environmental problems that have the potential to undermine the value of New Zealand's environmental image has been recognised in several government reports over the past decade. Most recently, the Ministry for the Environment's (MfE) State of the Environment Report 2007 identifies the development of serious pressures including population pressures, land and marine use intensification, air pollution, increasing household consumption, transport and traffic, energy use, waste, toxicity and primary production pressures. Some of these issues, including the cumulative impact of developmental pressures, lie outside the remit of the RMA in its current capacity. The OECD (2007) in its review of environmental performance of the country states that New Zealand faces several challenges in integrating environmental concerns into economic activities, while the MfE indicates that New Zealand is reaching a critical tipping point on many aspects of its environment (MfE, 2008). Tourism has been viewed, in some cases, as a way of halting damage by providing an alternative source of income to primary production (e.g. industrialscale forestry and agriculture), although tourism activity and development creates its own set of problems.
Indeed, concerns about the environmental effects of tourism have been widely reported (see Cessford & Dingwall, 1999; Parliamentary Commissioner for the Environment, 1997;Paterson & McDonald, 2004;Ward & Beanland, 1995). The Parliamentary Commissioner for the Environment (PCE) report identified a range of tourism impacts, some of which it felt ''have the potential to seriously damage both the environment and the industry'', including air pollution, water pollution, soil and geological aspects, wildlife disruption, loss of habitat, vegetation damage, crowding, noise, amenity effects, climate change and energy use. Subsequent tourism research has focused on several of these issues as they affect New Zealand, such as tourism effects on wildlife (Constantine, 1999;Lusseau & Higham, 2004;McClung, Seddon, Massaro, & Setiawan, 2004;Richter, Dawson, & Slooten, 2003), mountain areas (Booth & Cullen, 2001;Milne, Bremner, & Delpero, 2006) and other specific environments (Stephenson, 1999;Ward, Hughey, & Urlich, 2002;Wray, Harbrow, & Kazmierow, 2005), tourist energy consumption (Becken & Simmons, 2002), carbon emissions (Becken & Patterson, 2006) and biosecurity (see Hall, 2007b). The (PCE, 1997) identified three principle negative environmental effects resulting from tourism development and activity including: loss of quality of some relatively unspoilt parts of New Zealand's natural environment; loss of amenity values from incremental development, which can also affect communities and lifestyles, especially in places where the proportion of visitors to residents is high; pressure on infrastructure resulting in significant costs to local communities.
While, as Wall and Mathieson (2006) indicate, not all changes can be attributed to tourism, the pace and scale of development in New Zealand suggests that some change in the natural environment is an inevitable result of tourism. The PCE report, while now somewhat dated yet still sadly relevant, recognised strategic issues that detract from progress towards sustainable tourism, notably the fragmentation of the government system for managing tourism and its environmental effects. These concerns were raised some six years after the introduction of the Resource Management Act (1991), the pioneering legislation which seeks to incorporate sustainable principles within planning law in New Zealand.
The sole purpose of the RMA is the ''promotion of the sustainable management of natural and physical resources'' (RMA, 1991 Section 5), and establishes a comprehensive framework for landuse planning and resource management delivered at regional and local levels. The Act defines 'Matters of National Importance', which must be recognised and provided for with regard to managing the use, development, and protection of natural and physical resources (Table 1).
Other issues which are of significance to the Act include: Kaitiakitanga (stewardship); efficient use and development of natural and physical resources; energy efficiency; maintenance and enhancement of environmental quality and amenity values; the intrinsic values of ecosystems; the finite characteristics of natural and physical resources; protection of trout and salmon habitat; the effects of climate change; and the benefits of renewable energy.
As the primary planning law, the RMA sets out responsibilities for central, regional and local government, although application of the legislation is delegated mainly to regional and local government. Regional Councils set out strategic issues that affect natural and physical resources and produce a guiding framework for policies within their respective regions. However, it is Territorial Local Authorities (TLAs) that take the prime responsibility for planning at the local level, and for tourism developers the local council is usually the first point of contact with the planning system. A significant feature of the RMA is that it seeks to address the effects of an activity or development, rather than the management of actual activities. Resource Consents are required for activities not permitted as a right within Local Plans. The consent process enables planners to assess the effects of an activity on the environment, particularly in terms of air, soil, water, land and other natural, physical and cultural resources and to put measures in place that eliminate or mitigate potentially damaging effects of developments. As a requirement of the RMA, councils must prepare a District Plan that identifies development zones in a locale. Such a plan does not encourage development per se but is used as an objective tool to guide developers in submitting appropriate applications in line with local precedents and objectives. Despite Table 1 Matters of National Importance as defined by Section 2 of the Resource Management Act 1991.
Preservation of the natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and their protection from inappropriate subdivision, use, and development Protection of outstanding natural features and landscapes from inappropriate subdivision, use, and development Protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna Maintenance and enhancement of public access to and along the coastal marine area, lakes, and rivers Relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga Protection of historic heritage from inappropriate subdivision, use, and development Protection of recognised customary activities Adapted from Resource Management Act 1991 No 69, Section 2 (as at 09 August 2008), New Zealand Legislation, New Zealand Government. the environmental resource focus of the RMA, Section 1 of the Act defines 'environment' in a broad way to include: ecosystems and their constituent parts, including people and communities; natural and physical resources; amenity values; and the social, economic, aesthetic, and cultural conditions which affect or which are affected by the abovementioned. Therefore, while the Act does not explicitly seek to achieve social or economic outcomes, decisions are to take into account the impact of the use of natural and physical resources on social, cultural and economic matters. In some cases, social, cultural and/or economic benefits can outweigh ecological effects. While the consents process focuses on individual developments, wider effect on destination are considered, for example, tourism values, landscape, historic sites and degradation of water bodies.
It is important to note that, in common with other economic sectors, there is no specific reference to tourism within the RMA legislation primarily because the effects-based system does not recognise specific activities. Of concern is the apparent consequence that some councils have interpreted this as meaning that tourism is not an activity that requires attention in relation to the identification of impacts and delineation of associated policy and management responses. Despite this, as Page and Thorn (1997) argue, there is no doubt that tourism developments, like other forms of development that require consideration under the planning system, remain an intrinsic part of RMA development planning processes, as acknowledged by Local Government New Zealand in the production of a good practice guide for the application of the RMA in tourism planning (LGNZ, 2004).
Accordingly, a range of responsibilities exist in relation to sustainable tourism planning in New Zealand for local government in relation to the execution of the RMA. At this point, it is worth noting that local government plays a significant role in tourism within New Zealand. While Regional Councils can fund and promote tourism at a regional level, TLAs have the most heavy and direct involvement in tourism through funding, operating tourism activities and attractions (e.g. museums and art galleries, parks, gardens, reserves and trails), organising events and organising promotions. In addition, TLAs provide the primary sources of funds for Regional Tourism Organisations, while of course TLAs create and maintain essential local infrastructure from which tourism activity benefits. However, one of the most important functions of councils is the implementation of national planning legislation and policy at the local level. While local authorities are charged under the RMA with developing a plan to set policy and guide development in their area of governance, there is no such statutory requirement to develop tourism plans. While tourism-related developments are considered within the remit of regional and local plans, often there is no guiding policy framework for tourism within a specific area, which is problematic for sustainable tourism development.
Further, while there is an increasing trend for councils and regional tourism organisations to develop tourism strategies, it appears that most of these plans adopt a more traditional marketing perspective with a view to promoting tourism in a region rather than creating clear links to the RMA by recognising tourism impacts and the benefits of planning to control negative effects and maximise positive ones. This is understandable given the economic development remit of local councils, yet a quality environment is at the heart of the New Zealand tourism product. Page and Hall (1999) argued that local authorities might not be well equipped to assess the effects of tourism, primarily because resourcing issues dictate that tourism monitoring is not a major area of focus for a body charged with delivering services to local people, often under severe budgetary constraints. However, because the implementation of sustainable tourism planning is within the hands of local councils, the effective translation of principles into policy and action is essential to progress the sustainability agenda.

Developments in tourism and sustainability in New Zealand since 2001
Since Page and Thorn's (2002) last study, which argued the need for a national tourism strategy in New Zealand, two notable developments have occurred. First, in 2001 the Ministry of Tourism published the New Zealand Tourism Strategy 2010 (NZTS, 2010), which was updated in 2007 to take into consideration the changing global and national trends in tourism issues and travel patterns: New Zealand Tourism Strategy 2015. The NZTS 2015 is underpinned by two key principles kaitiakitanga (guardianship) and manaakitanga (responsibility), creating a uniquely New Zealand approach to sustainable tourism. The strategy recognises that the tourism sector must take a leading role in protecting and enhancing the environment by contributing to a whole-of-New Zealand approach to ensure that New Zealand's environment will continue to be enjoyed by future generations, linking with other strategies and initiatives to develop a coordinated and integrated approach to sustainability. The strategy is a substantive document but in terms of directly relating to local government planning, it is recognised that the tourism sector and communities should work together for maximum and mutual benefit, while local authorities should understand the benefits tourism offers and lead destination management and planning initiatives and processes to maximise these benefits. In addition, the strategy emphasizes that tourism decision-making by local government, communities, iwi and the tourism sector should be informed by high-quality research.
Second, Local Government New Zealand (LGNZ) has increased its tourism work by actively encouraging local government participation in tourism projects. In 2003, LGNZ issued its response to NZTS 2010, entitled 'Postcards from Home' which contained specific actions designed to engage local government with tourism issues. One of the four strategic aims of 'Postcards from Home' was 'to engage communities in planning for tourism which is socially, economically, environmentally and culturally sustainable' (LGNZ, 2003: 6). As part of this aim, it was recognised that there was a need to raise awareness among elected officials and council staff about local government involvement in tourism. It was also recognised that the RMA planning framework required supplementing through research and non-statutory tourism strategies to address tourism growth and impacts, where encouraging the preparation of tourism strategies was stated as a key action.
In addition to strategic policy developments in tourism, at a wider planning level across all sectors the amendments to the Local Government Act 1974 in 2002 increased the flexibility of local government in decision-making and empowering local community in democratic processes, and gave more power to Regional Councils to pursue sustainable development objectives. The purpose of the Act is to: ''. provide for democratic and effective local government that recognises the diversity of New Zealand communities; and to that end, this Act. provides for local authorities to play a broad role in promoting the social, economic, environmental, and cultural wellbeing of their communities, taking a sustainable development approach'' (Local Government Act, 2002 Section 3). The Bill highlighted the need to prepare Long-Term Council Community Plans (LTCCP), in addition to existing District Plans, which outline strategic priorities for the community, and sometimes include tourism promotion and development as part of an economic development scenario. LTCCPs focus on the long-term management and development of specific areas based on council assets, budget forecasts, policies and community consultations on desirable outcomes as a basis for understanding priorities within the area and aligning council services to match these outcomes. LTCCPs are prepared by both TLAs and Regional Councils and cover a ten-year period, with reviews every three years. In the years between reviews, an Annual Plan is devised which sets out budgets and targets for the year ahead.
It is also worth noting that the RMA is subject to ongoing review and amendment. Since 2001, several changes have been embedded into the legislation, including improvements to the Resource Consents Application process (in 2005) and inclusion of matters of international concern such as climate change, renewable energy and energy use (in 2004).
As such, there have been some significant changes at strategic and policy levels in New Zealand, all of which have the potential to influence the sustainable tourism planning agenda. However, the extent to which these changes have infiltrated into local government is an area that requires further investigation. The following section outlines the methodology used to survey local councils to ascertain responses to tourism planning issues at the local level.

Methodology
In November 2007, a self-complete questionnaire survey was mailed to all 85 local authorities in New Zealand. A pre-paid envelope was included for ease of return. The questionnaire was based on the earlier ones utilised by Thorn (1997, 2002) to enable some tracking of changes in findings over time, although some questions required alteration to reflect policy developments and to gauge responses to the launch of the New Zealand Tourism Strategy, which did not exist during the previous survey periods. In addition, questions from the 1995 survey requiring substantive data requests from respondents were omitted where possible to encourage survey completion and to confine the aims of the survey to specific tourism planning objectives (such as identification of tourism impacts and development of tourism strategies) without eroding the aims of the investigation. The survey design incorporated a combination of closed and open questions. Closed questions were utilised to gauge responses to straightforward questions, where a simple tick box suffices to assist in categorisation of respondents. However, recognising the small population involved in this survey, a range of open questions were included to generate a source of more qualitative, explanatory information that can add a richer dimension to understanding responses.
The population comprised 12 Regional Councils (RCs) and 73 Territorial Local Authorities (5 of which are Unitary Authorities with powers at Regional and District levels). Territorial Local Authorities (TLAs) consist of 58 District Councils and 15 City Councils. The survey was distributed to all three types of local authorities to ensure that the responses of all bodies with a regional and local remit and a role in the RMA implementation were represented. Surveys were mailed directly to Planning Officers, who oversee RMA processes and understand how tourism fits into local planning, for completion. Following a reminder, some 43 completed and usable questionnaires were returned, giving a response rate of 51%. The aim of the survey was not to produce large amounts of statistical analysis, rather to generate a picture of current levels of tourism planning at council level which by its very nature can only be descriptive in exploring the issues bearing in mind the small population size. Given that this figure represents half of all local authorities, the information that the survey yielded is considered to be valid in providing a general picture of public sector responses to tourism planning in New Zealand, although non-responses deserve further consideration.
The patterns of response provide a useful geographic spread of data, and represent a good mix of areas in both urban and rural areas, areas with high and low tourism profiles, and North and South Islands. The response rate of Regional Councils was the lowest at 25%, explained primarily by the apparently delegated role of tourism to the local level by some Regional Councils, and whose main concerns relating to tourism are integrated resource management issues, particularly water and waste management. For both District and City Councils, the response rates were over one half of the population (55% and 53%, respectively). The response rate in this survey was lower than that of Page and Thorn (2002) which achieved 57%. Analysis of the response rates indicates that the response from TLAs is very similar, but in this survey the response from Regional Councils is much lower. It is possible that Regional Councils felt that the tourism focus of the survey was not relevant to their functions. If one isolates TLAs, the response rate of 55% is the same as achieved by Page and Thorn (2002), as shown in Table 2.
Methodologically, this study suffers from the same problem as most postal surveys, and while the overall response rate is satisfactory (often a 30% response rate is deemed reasonable for such surveys), it is difficult to assure the representativeness of the responses achieved. In terms of commenting on the non-respondents, the councils were spread throughout the country, some are in significant tourist areas while others are not on primary or secondary tourist routes. City Councils representing the three international gateways responded. The non-respondents included 7 City Councils (out of 15) and 26 District Councils (out of 58); while for Regional Councils the figure was 9 (out of 12). Some 28 responses were received from councils on the North Island (49% response), while 15 responses were received from the South Island (54% response). Overall, the responses received provide a satisfactory sample in relation to tourism areas, population size and geography, all of which will be further elaborated in the findings. Longitudinal comparisons are only possible at the general level, given that although the same population was sampled, not all respondents answered each of the three surveys. Finally, it should be noted that the names of specific councils are not given in the discussion of findings from the survey to respect the confidentiality of the research process which was assured in the research process in order to generate frank and accurate responses.

Analysis of findings
The findings of the survey are reported using a combination of quantitative data where appropriate given the small population, with verbatim responses to open questions to enrich the data and provide further insights. As a first step, it is valuable to recognise the scale and type of communities, areas and tourism profiles represented in these findings, particularly as such variables are useful in cross tabulating findings. The resident population of the survey areas varied from 609 to 404,658 in District Council areas, while Regional Councils contain the largest populations, being made up of a number of District Council areas. Similarly, Regional Councils varied in size from less than 40,000 to over 500,000 residents.
In terms of tourism volumes, it is problematic to represent the volumes of tourism in each area with any accuracy, given availability and reliability of tourism data at District Council level for Table 2 Response rates compared with previous surveys of local authorities.

Responded
Non-response Total % response rate Regional authorities  1995  9  3  12  75  2000  7  5  12  58  2007  3  9  12  25  Territorial local  authorities   1995  40  29  69  58  2000  38  31  69  55  2007  40  33  73  55 comparisons. While a few councils produce reasonably good data on visitor numbers, the overall picture is rather patchy. Data on guest nights and numbers of tourists at Regional Council and Regional Tourism Organisation (RTO) level is available through the International Visitor Survey (IVS), as is data on guest nights and numbers through the Domestic Tourism Survey for each RTO area. Due to inconsistent boundaries, a number of Districts lie within more than one Regional Council area, and similarly RTO areas do not always map consistently with Districts. Therefore, neither of those measures provides an accurate picture of tourism at District levels. However, an indicative picture of tourism activity at District Council level can be ascertained through the Commercial Accommodation Monitor (CAM), which measures tourist nights in commercial accommodation establishments registered for GST and with an income of $30,000 or more. The accuracy of this survey is questionable given that a number of accommodation providers below the $30,000 threshold exist, and certain sectors of accommodation are known to be underestimated, such as backpacking, camping and caravanning, and hosted accommodation (Statistics New Zealand, 2008b). Nevertheless, the CAM assists in giving a broad indication of tourism activity in each area which can be used for cross tabulation purposes.

Tourism policies
Local and regional authorities were asked if they had a tourism policy. While there is no statutory requirement for a tourism policy, the publication of one indicates a strong community interest (given the Local Government Act 1974 amendment) and/or local government commitment to tourism, especially given the encouragement by the 'Postcards from Home' policy. The survey revealed that 26 authorities have tourism policies and a further two are in preparation. This compares favourably with the 2001 survey (Table 3).
Compared with the 65% of councils that have a tourism policy, in the 1995 survey 35% had a policy on tourism while the 2001 survey revealed a much lower figure of only 40%. The trend from 1995 to 2007 shows a small rise in strategies by 2001, but a significant rise by 2007. This would appear to indicate that the effect of the national tourism strategy has been to encourage local government to develop and adopt strategies. Nevertheless, while this increase in strategies illustrates an interest in tourism issues, one third of authorities have not developed any policies. This is not necessarily an issue as not all local councils have or indeed want to develop a tourism profile, although this figure does represent a number of council areas where tourism is a significant activity. Of the five respondents considered to be on the main international tourist route, the 'Blue Ribbon Route' (see Page & Thorn, 1997), four have a tourism policy. This differs somewhat from the 2001 study, where only one respondent had a policy. In the one area where there is no policy, the respondent stated that all tourism matters are delegated to the RTO. Further, there are no substantive differences between areas with large or small numbers of guest nights and whether the council has a tourism policy, although slightly more areas with fewer guest nights had developed a policy. Some 44% of areas with more than a 50,000 resident population did not have a policy, while 32% with a population less than 50,000 were without a tourism policy. Findings suggest that those areas with lower tourism activity and lower population size might be more likely to have developed a tourism policy. It is not generally considered that Regional Councils have a tourism remit, although one RC did have a tourism policy. Indeed, the lack of response from other Regional Councils indicates a lack of interest in tourism at this level, where tourism is delegated to other bodies, including TLAs and RTOs.
Of all the tourism policies that existed, 13 were relatively recent, having been published since 2006, while only 6 pre-dated the 2001 NZTS. This finding reflects the apparent situation for tourism policies to be up-to-date, informed by current practice and understanding of the strategic national tourism context. Most councils had a specified review date for the policy, with many reviewed annually as part of the Annual Plan as required under the RMA.

The influence of the NZTS
The majority of local authority planning officers in councils where tourism plans already existed had seen the NZTS (83%). Respondents who already had a tourism policy and had seen the NZTS were asked to indicate how the NZTS would inform their own policy development. This was seen as particularly important given that 15 of the existing policies were due to be reviewed 2008-2012, and that most of these local authorities thought that there were emerging tourism issues that needed to be included in a revised policy. Five respondents indicated that they had or will incorporate(d) elements of the national plan where appropriate to their particular locality, while a further three stated that they would take the plan into consideration. Two authorities stated that the NZTS was informed by their own existing plans, while a further three stated that their new plan directly aligns with the national strategy. Others commented on more specific elements of the national plan, and appreciated the opportunity to determine the national context and direction of tourism strategy in New Zealand and develop a common approach to core issues. Overall, though, the ways in which the NZTS has already influenced, or will influence, policy at a local level appears to be somewhat vaguely stated in many cases.

Planning for tourism impacts
Some 57% of respondents stated that specific tourism issues need to be addressed in the next review of the policy/plan. The responses are illustrated in Table 4, and in some cases more than one response was given by respondents. The range of emerging tourism-related issues that were identified indicate two approaches to tourism development. These approaches are not quite polar opposites, but do represent different perspectives on tourism activity. On one side are those authorities that have concerns about the impacts of tourism, where key policy issues relate to balancing the needs of residents, visitors and other interests, dealing with impacts arising direct from tourism activity, and managing environmental resources (36% of authorities). A particular concern indicated by three council representatives is that of the cost of developing and managing tourism opportunities, activities and impacts. Two of these indicated impending studies to ascertain the economic cost of infrastructure and attractions, while a third noted the difficulties for councils with small populations to afford infrastructure improvements through the local rates system. Conversely are those authorities who are more concerned about developing tourism assets, promotions and infrastructure in an attempt to generate or meet demand (16%).
A further examination of the councils that identified issues reveals that councils with higher rates of tourism activity were more likely to identify issues, as quite obviously where there are more visitors there are more likely to be impacts that are created and need to be addressed. Similar to previous studies, those areas that did not identify tourism issues were primarily provincial city areas, or rural areas away from main tourist routes. Some 40% of councils did not consider there to be any tourism issues of concern. While this finding may be taken at face value, the response may hide a number of more insidious issues. As Page and Thorn (1997) highlight, some councils may not possess the tourism expertise to identify and deal specifically with tourism impacts, while others may be more focused on championing the marketing orientation of Tourism New Zealand in generating economic benefits. In both cases, there are significant dangers that negative impacts may not be anticipated, mitigated or managed. Worthy of note though is that in the 2001 study, 38% of respondents identified tourism issues that needed to be addressed, compared with 57% in the 2007 study. These findings appear to indicate a growing interest and concern about the effects of tourism and the need for local government to address impacts, both positive and negative, through the planning system. In addition, the range of issues identified in the 2001 survey was not as extensive as in the current study, suggesting either a higher level of tourism awareness within councils or the emergence of a more extensive number of impacts.

Local authority perception of tourism
The financial contributions that councils make towards tourism development, promotion and activity can indicate the level of support they make to tourism in their locality. The findings indicate the importance of local authority financial contributions to tourism development, with 34 of the 43 bodies (79%) providing financial support, ranging from NZ $10,000 in a small rural area to NZ $4.2 million in a major urban centre. The majority of funding is directed towards Regional Tourism Organisations (approx 72% of funds), while other major areas of expenditure include event development and promotion, information and visitor centres, marketing and promotion, regional initiatives, attraction development, employment of an events or tourism promotion officer, one-off projects and i-SITEs 2 . Only eight of the 43 authorities (18%) conducted research, two only very occasionally and incurring minor expenditure, while two spent more than NZ$50,000 annually on research. One respondent commented that the RTO carries out research and provides the Council with findings, so a research role at council level was not considered vital. While Tourism New Zealand carries out and commissions a substantial amount of research, much of this pertains to the national level, with some at the RTO level.
While four councils (all of which are in the most heavily visited tourist regions) spend more than $1million on tourism activities, the median average of $185,420 reflects a more modest level of expenditure. About three-quarters of total contributions were less than $400,000, which, even bearing in mind inflation, compares favourably with $200,000 in the 2001 survey. Of the councils that did not contribute financially towards tourism, two were located in areas that receive less than 10,000 guest nights, although, more curiously, a further two are located in tourist regions. It should be noted that it is not the role of Regional Councils to contribute financially to tourism activities.

Importance of tourism in council areas
Respondents were asked to indicate if the perceived importance of tourism had changed within their local council during the preceding five years. Some 28 (50%) respondents stated that the importance of tourism had increased, 7 (17%) of these stating increased significantly. The main reason given for this was the increasing recognition of the realised and potential economic benefits of tourism within the local area. It appears that many councils have become more aware of the beneficial effects that tourism can bring to a locality through expenditure, business development and employment opportunities. In particular, the awareness of the ability of events to draw visitors to an area appears to have strengthened. Other contributing factors included growth in tourism, improved marketing and strategic vision, development of new products and services, and more Council funding.
Only 3 (7%) respondents stated that the importance of tourism had decreased, partly due to the limited tourism appeal of one location but in two others a perceived lack of value, for example: ''**** [RTO] have been unable to demonstrate, articulate and quantify to councillors value for money that has been invested''. Eleven respondents (26%) stated that the importance of tourism remained the same. This was explained by several locations where tourism activity remained fairly static or where growth was limited by infrastructure constraints. One issue identified was the absence of effective tourism organisations and regional co-ordination to take tourism developments forward and to illustrate the benefits of tourism to the council, thereby not propelling tourism forward as a beneficial economic activity. Areas with the lowest number of guest nights were more likely to recognise the economic benefits of tourism, but also the limited tourism appeal of the area and lack of effective leadership.
These findings differ from those in the 2001 study, where 80% of councils identified increased importance of tourism (29% increased significantly), 16% remained same, while only one council stated that it had decreased. This indicates that councils took on board the importance of tourism during the period 1995-2001, and that there is a heightened level of awareness of its importance today. Interestingly, the reasons for change or lack of change differ in the 2001 and 2007 survey. Development of new attractions and recognition of substantial increases in visitors were cited as the main reasons for an increase in importance in 2002, while recognition of economic benefits was more important in 2007 survey. This appears to indicate that councils have a clear understanding of how tourism can benefit their locality, which may have resulted from the key messages in the national tourism plan and associated reports. However, similar issues with regard to lack of financial support given to tourism or lack of importance placed on the activity as mentioned in the 2001 survey are still in evidence and in fact appear to be more marked in the 2007 survey.

Tourism development
Tourism-related developments had taken place in all but three of the local authority areas since 2000. The range and scope of developments indicate a significant rise in tourism infrastructure across the country, from airport enhancements to visitor trails. The most frequently cited form was attraction developments, which had taken place in 33 council areas (78.6%), followed by accommodation development (non-hotel) in 30 areas (71.4%). Areas that reported no new tourism development were those with small populations and received less than 25,000 guest nights. The development of new attractions at all levels suggests vibrancy in tourism development, a point that the 2001 study highlighted where developments had taken place in all areas. In terms of the types of new developments, the list of new attractions, facilities and services on offer is considerable and far to extensive to include, but incorporates a large proportion of new trails, tours, guided walks and outdoor adventure activities, with a smaller amount of development to create or upgrade cafes, wineries, museums and retailing. It is striking that so many of the new developments relate to sporting and adventure type activities in the outdoor environment (see Bentley & Page, 2001), all of which utilise environmental resources and all of which have the potential to create or exacerbate adverse impacts. As such, the role of the RMA in controlling the effects of tourism development is clear in a climate where growth in individual adventure tourism enterprises and outdoor pursuits is occurring.
Some 44.2% of respondents considered their council area to be under pressure from increased tourism and Table 5 identifies the major pressures highlighted by respondents. Three broad categories of responses are distinguishable through examination of a subsequent open question on what pressures existed in localities. First, specific locations were identified as likely to experience increased visitor numbers and associated impacts, e.g. West Coast Beaches, Waitakere Ranges, Whanganui River, Ruapehu, Catlins and Karangahake Gorge. Second, the concerns arising from increased visitor numbers were identified including, demand for infrastructure, construction of tourist-related ventures, dealing with municipal waste, water demand and waste water disposal, increased freedom camping and effects on wildlife and natural areas, housing affordability, second homes and subsequent loss of community when homes are vacant, increase in tourist arrivals (e.g. airport expansion and acceptance of large cruise ships), and environmental costs of tourism have to be carried by small councils with low taxation bases. Third, and somewhat in contrast to the latter responses, a grouping of respondents though smaller than the latter, want to grow tourism and maximise the benefits, through creating infrastructure, building more accommodation and increasing the workforce.
Fairly obviously, the survey identified that respondents in areas with the largest number of guest nights (over 100,000 in peak month 2007) were more likely to report that their area was under pressure from tourism, and correspondingly those with the smallest number of nights (less than 10,000) were the least likely to be under pressure. The areas under pressure tend to include those reliant on the natural environment, cities, areas on main tourist routes and National Parks. Those not under pressure include those wishing to develop tourism currently with low visitor numbers and those off the beaten track. Interestingly, more councils on the South Island perceived their areas to be under pressure (73%) compared with (29%) on the North Island. Explanations for the perceived higher pressure on the South Island include its major attraction based on natural scenic qualities, which are well-developed tourism icons in overseas promotions, alongside often heavy concentrations of packaged tourism and adventure tourism utilising the physical and natural environment.

Tourism and the RMA
A key focus of this paper is focusing on the relationship between sustainable tourism planning and the RMA. Under this Act, consents are issued by both the regional and local councils depending on the scope of the consent sought. Consents would be required for all the developments mentioned in the previous section. However, ascertaining accurate data on tourism-related RCAs is highly problematic. While many respondents were able to give precise numbers in relation to RCAs and refusals, a significant number were not able to provide the data (13 respondents). The main reason given for this is that tourism is not always isolated as a key variable in the database recording process for resource consents applications. Some developments are not primarily designed for tourism purposes but may produce a tourism spin-off, e.g. development of a winery. In other cases, databases are not set up to be readily searched, data is not inputted into system as 'tourism', but as 'commercial activity' and in several cases, the detail of activity or data is not even kept. This seems to indicate an inherent problem in the data management of resource consent applications with regard to tourism, and a technical inability to retrieve useful information that can inform tourism planning at local, regional and national strategic levels. Acknowledging the limitations of the data, the following results give a broad indication of the workings of the RMA process in relation to tourism development within local councils.
Twenty-four respondents (56%) had dealt with RCAs since 2000. The highest number of applications dealt with by one authority was 40. Ten authorities had dealt with between 1 and 10 applications, six between 11 and 20 applications, five between 21 and 30 applications, and three had dealt with 31 or more applications. Overall, 395 RCAs were reported in the survey since 2000 relating to tourism projects. While the largest number of applications were dealt with by District Councils, (210 RCAs), 50% of the City Councils accounted for 37% of the RCAs, indicating a substantial number of applications within a small number of urban areas. Some 76% of RCAs submitted were made to councils with a tourism policy, which is an encouraging result suggesting that councils receiving RCAs related to tourism might have a strategic vision of how tourism should develop in their locality. Importantly, most of the councils receiving large numbers of RCAs did have a policy, although 2 receiving more than 25 applications did not. Further, 24% of RCAs were submitted to councils without a tourism policy. There is no particular pattern of number of RCAs received and the visitor numbers in council areas, with the largest numbers of applications (8 councils with over 25 applications) in a variety of rural and urban environments, representing those areas already important tourist hubs (3 of the 8) and those encouraging the development of a tourism economy (5 of the 8). Three districts received no applications, all of which are insignificant tourism areas: two not on tourist routes and one within a provincial city environment.
One might expect a relationship between those councils reporting a large number of RCAs and those reporting that they perceived their area to be under pressure from tourism but this is not always the case. Of the 8 councils reporting 25 or more applications, 5 stated that their area was not under pressure from increasing tourism. In fact of the 19 councils that reported their area to be under pressure, 9 were not able to extract numbers relating to tourism, one had received no RCAs, and a further four councils received fewer than 10 RCAs, suggesting that it is not necessarily new developments that are creating tourism pressures. Indeed, one might say that applications made under the RMA are perhaps less problematic than existing developments that already generate significant demand.
It appears that very few applications are refused, with only eight identified in the survey since 2000. Reasons for refusal include noncompliance with a local plan, impact on environment, objections from neighbours (often about noise), and other cultural and amenity issues. However, as identified by a number of respondents, planning authorities try to work with developers to produce an appropriate application that meets the criteria of the local plan, the RMA and addresses the range of environmental and cultural sensitivities of the locality: ''any difficulties regarding lack of information are overcome by working with applicants''.
Difficulties experienced with tourism development planning appear to be no different to those associated with any other kind of planning application made under the RMA. The two major challenges as identified in the survey are part of the same essential problem, that is, poor understanding of what is required in the application. Eight respondents (24% of those that had experienced difficulties with applications) stated that applications are often presented with incomplete information and a further eight respondents (24%) identified lack of understanding of the RMA process to be a reason why problems are experienced in the application procedure. However, as one respondent commented, early contact with the council is important for the process to run smoothly for the applicant: ''it is not as bad as they initially think''. Similarly, a further difficulty in applications is a lack of consideration of impacts of developments (18%). However, 21% of those that had dealt with RMA applications had not experienced any difficulties. As one respondent commented, ''the RMA is there to protect the environment if a tourist developer follows carefully with a planning/RMA consultant.then things appear to go relatively smoothly. Communication between all parties is key''.
In terms of the relationship between tourism development, sustainability and the RMA, as argued by one respondent: ''at the moment the RMA deals with the sustainability of tourism on a caseby-case basis, however, at a strategic level the sustainability of tourism is not grappled with''. It is also apparent that the RMA does not necessarily assure a sustainable approach to tourism planning outside of the particular development under consideration. For example, one respondent noted that: ''associated with tourism resulting from [the RMA] is pressure for overseas purchase of property -this has contributed to significant increases in land/house prices''.
While it is unclear to what extent planning officers work with developers to ensure resource consents are granted, the general premise that there are few outright refusals begs the question as to whether the RMA process is rigorous in controlling the negative impacts of tourism in areas under pressure from increased visitor numbers. One respondent commented that ''the RMA is not a detractor to tourism development'', which may or may not be a good thing.

Implications
It is clear from the survey findings that the dual role of many councils in performing a regulatory planning function and promoting tourism raises issues about potential conflicts of interest in applying the RMA while considering the economic development of a locale. This debate is an old one -environment vs economicsbut in a sustainable development context the need to conserve environmental resources to ensure future economic stability is mandatory. This is particularly so given the Tourism Strategy's recognition of sustainability and the need to protect the environment to retain New Zealand's 'green and clean' image: ''the best kind of tourism for New Zealand is sustainable tourism, that is, tourism that delivers maximum value -economic, social, cultural, and environmental -with as few unwanted effects as possible'' (NZTS 2015:14). Since 2001, it is clear from observations of local government that local councils have engaged more actively with the tourism sector through development of tourism plans and policies. The turn in policy developments at a national level reflects Thorn's (1997, 2002) arguments that destination marketing and management practices should be much more clearly integrated, and that a move away from the traditional growth perspective without thought about the impacts within the country is a necessary prerequisite to achieving a more joined up approach with the RMA. The drive towards sustainable development as a national policy direction is reflected in the National Tourism Strategies, through increasing awareness of tourism within councils and to address impacts through strategy preparation.
Yet for local authorities with limited resources, especially those with a small population base and limited ability to raise revenue through rates, providing infrastructure, promoting tourism growth and managing impacts is a financial burden on tight budgets: this emerges as a clear theme in the survey. New legislation currently under consideration to minimise waste provides a refund to councils based on permanent population but would not cover the transient but often substantial visiting population. This is one example of where finding ways to compensate councils and ratepayers for the use of local services is clearly a challenge and for many councils in New Zealand and, indeed, world-wide, juggling the economic costs and benefits of tourism and justifying the outcomes to ratepayers remains problematic. Resources from central government to develop and improve water and sewerage infrastructure are perceived as inadequate, even though some funding has been available through the Ministry of Tourism's Tourism Demand Subsidy Scheme.
This study shows that local authorities clearly understand the role of the RMA with regard to tourism, focusing on the effects of tourism activity within their area. However, looking at the bigger picture, one of the criticisms of the RMA is that because of the caseby-case nature of the process, it is difficult for planning authorities to consider cumulative effects of tourism development or to consider tourism impacts in an integrated way, an inherent problem in impact research (Wall & Mathieson, 2006). As such, while the intentions of the RMA in preventing undesirable developments are laudable, the cumulative effects of a number of seemingly innocent, less damaging developments might be equally detrimental. Only one respondent specifically drew attention to this issue, but that does not detract from the importance of the point -indeed it might be questioned whether planning officers are sufficiently aware of the dangers posed by this breach within the RMA framework. Similarly, the focus of the RMA on effects of activities, while well intentioned, could result in significant economic sectors, like tourism, not being adequately and proactively planned for. Somewhat worryingly, this might be reflected in the lack of response from Regional Councils, who do not appear to take tourism as a specific concern under their remit, although are clearly concerned by the effects of tourism such as waste.
The inherent difficulties of extracting tourism-related projects from RMA databases held by local authorities appears to be an issue in understanding the implications of the RMA for tourism and the extent to which projects are acceptable in the local planning decision-making process. Quite clearly this reflects inadequacies within data management and retrieval, but also indicates a systemic challenge for the core workings of the RMA, which by its nature is not concerned with specific industry sectors but with the effects of activities. While the key focus on natural resources provides a valuable framework for the development of appropriate policy and decision-making frameworks, the ability to understand the scope and scale of tourism-related developments is essential particularly given the ambitions of the national tourism strategy. Worthy of note is that of the 13 councils that were unable to retrieve tourism-related data due to technical problems of searching were: four of the eight districts on the North Island stating that their areas were under pressure from increasing tourism; further, two of New Zealand's very significant tourist locations; and, further again, three other well-known tourist areas. These omissions from knowledge at a planning level indicate the potential to not fully understand the rate of tourism growth from a supply perspective and the cumulative effects of tourism development linked with local aspirations within the confines of LTCCPs.

Conclusions
The main aim of this study was to explore the continuing involvement of local and regional government in tourism planning and the development of sustainable tourism approaches given the framework of sustainability in New Zealand government strategy. Further to the investigations of Thorn (1997, 2002), this study recognises a more firm course being steered for New Zealand tourism through a national tourism strategy, which clearly distinguishes sustainability as the main thrust. In addition, reform to the Local Government Act 1974 has given an impetus to communityderived planning outcomes through LTCCPs, with the role of tourism in economic development established and recognised in statutory plans. Sustainability now underpins the policy framework for tourism in New Zealand, and the landmark steps taken to develop and review national aspirations for tourism development represent a step forward in establishing a clear remit for local government in planning for tourism. The extent to which this is rhetoric rather than reality is questionable, given the somewhat mixed results in the survey of local government reported in this paper. Quite clearly, a range of pressures continue to affect local areas, and the challenges that face many local councils in trying to manage the effects of tourism on environmental resources are as pressing as ever. The LTCCP enables councils to evolve futures that befit environmental resource opportunities and constraints, community aspirations and local budgets. While tourism is mainly a private sector industry in New Zealand, the public sector adopts a dual role as the gatekeeper of tourism developments through planning control, while promoting economic development opportunities through tourism. As such, while councils have become the arbiters of sustainable tourism through their role in implementing the RMA, the appeal of developing the local economy places them in a dichotomous position.
While much of this discussion sounds positive, there is still a major gap between strategy and implementation in the evolution towards New Zealand as a sustainable destination. While sustainability is now one of the cornerstones of New Zealand tourism strategy, much of this lies at a national, strategic level and remains as a philosophical stance. Yet, the perception of New Zealand as at the forefront of sustainable policy developments is not matched in reality, with an absence of any truly national sustainable business accreditation scheme (at the time of writing) to highlight its national commitment to sustainable tourism and a way to manage the continuity of the effects of tourism operations once past the initial development control stage. Internationally, the image of New Zealand relies heavily on its natural environment as a tourist attraction, and is used consistently in the marketing of the country, inherent in the 100% Pure campaign. However, evidence suggests that problems created by tourism pressures do exist and some of these are difficult to deal with given the limited budgets of local government. Pressure at key tourist hotspots and with certain tourism-related activities is recognised, and with the continuing growth in tourist numbers forecasted, the effects of tourism have the potential to change the nature of the tourist experience and the very foundations on which New Zealand tourism is built. The existing problems of geographic concentration of tourism activity will only worsen, exacerbating the pressures on local authorities.
At this juncture, a policy at a national level that assists local areas in dealing with visitor volumes and the distribution of visitors in a more systematic manner would enable a more proactive public sector approach to tourism planning. Steps towards understanding the dynamics of tourism in New Zealand have been made by the Ministry of Tourism in establishing a Tourism Flows Model although the data used to generate this model remains at the level of RTOs. A national tourism plan could set out a rationale for the way in which tourism should develop, setting targets for environmental protection and enhancement through tourism activity (Page & Thorn, 2002). Further steps would help destinations to ensure the RMA achieves the goals and principles enshrined in the original legislation. Without a more concerted attempt to challenge pro-development policy, New Zealand is likely to lose pace in terms of competitive advantage as a clean, green and sustainable tourism destination. As Edgell, Allen, Smith, and Swanson (2008: 335) argue, ''those destinations, localities and nations that prepare good policies and implement detailed strategic plans will reap the benefits for sustaining their tourism products in the future'', which is a cornerstone of New Zealand tourism strategy.