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How NZ could fix property taxation, face down the NIMBY problem, overhaul the RMA and drive sustainable urban development - OECD

How NZ could fix property taxation, face down the NIMBY problem, overhaul the RMA and drive sustainable urban development - OECD

The OECD has run the ruler over New Zealand’s urban planning framework, providing a range of suggestions for overcoming problems regarding NIMBYs, property tax settings, spatial planning, the RMA, infrastructure financing and local road pricing.

The comments were made in the organisation’s 2017 Environmental Performance Review of New Zealand in a section on sustainable urban development. An OECD delegation led by former National Party Environment Minister Simon Upton was in Wellington this week to launch the review.

In general, New Zealand’s urban planning system had responded poorly to the challenges and opportunities arising from urban development, the OECD said. This meant substantial barriers to increasing housing supply and providing network infrastructure in Auckland and other fast-growing cities.

“As such, it has contributed to rising house prices, missed benefits from agglomeration and increased environmental pressures from infrastructure bottlenecks,” the OECD said.

The OECD’s recommendations on sustainable urban development are below. But first is an overview of some of the comments the organisation made in its report:

On property taxation and rates:

  • High reliance on general rates for infrastructure finance may discourage cities to accommodate or promote growth, as it implies that dwellers cross-subsidise infrastructure they do not necessarily benefit from. Councils are therefore reluctant to provide network infrastructure (such as sewerage and public transport) if they think this would push up the rates bill of the local population.
  • Local authorities can address this issue by shifting the burden of financing growth to those who benefit from it (applying the user-pays principle).
  • Targeted rates can also be used to capture windfall gains accruing to landowners from property price increases resulting from the rezoning of land for urban use (land-value capture taxes) or the improvement of local infrastructure (betterment taxes); an example would be increasing them for a defined period.
  • The potential for the tax system to capture such windfall gains is large in New Zealand, particularly in Auckland.
  • Revenue raised through this mechanism could then be used to help fund infrastructure upgrades and expansions needed to service new land (OECD, 2015a), especially where development and financial contributions are not applicable.
  • Property taxes affect land use and urban sustainability by changing the relative cost of the location and types of development. For example, a tax design that is based on buildings and other land improvements (rather than on land value) can incentivise greenfield development to the detriment of infill development, encouraging urban expansion and, at worst, urban sprawl.
  • In New Zealand, most local councils have shifted from setting rates on the basis of land value in favour of capital values, which they perceived would better reflect the ability to pay (NZPC, 2015). However, much of the recent increases in property values reflect rising land values rather than improvements; this suggests that land values may be the more appropriate basis for the tax. There are also indications that land taxes are more progressive in New Zealand.
  • The country may therefore review whether property taxation is aligned with objectives of the urban planning system and, if not, consider shifting towards stronger land taxation.

On encouraging NIMBYs to become QIMBYs:

  • The process of changing land-use rules and regulations tends to be lengthy, with district or regional plans taking more than eight years on average to become operational (since their first notification).
  • These long time periods are in part related to extensive participation and appeal rights under the RMA, which stakeholder groups have used to thwart development of wider public interest (even though these rights have narrowed over time; see Chapter 2).
  • While high levels of public participation are an asset of New Zealand’s public governance, vested interest groups sometimes have disproportionate influence in local council processes, including consultations on budgeting and land-use plans.
  • Resident associations often appeal changes to city land-use plans, fearing that urban development could affect the value of their properties and the character of their neighbourhoods. Indeed, many changes to land-use plans effectively protect the interests of property owners, creating biases towards maintaining the status quo.
  • well-defined national urban design principles or outcomes (see Section 4.2) can provide an objective baseline against which urban plans (and the reasonableness of objections) can be assessed, thereby limiting the risks of appeals to publicly beneficial development.
  • OECD (2012) identified a number of other strategies that city government can use when public opposition against a more compact urban form is high; these include provision of affordable housing, investment in green open space, greening of built-up areas, information and education, and demonstration projects that showcase attractive medium- and higher density development.
  • The city of Vancouver, Canada, for example, turned the acronym NIMBY (not-in-my-backyard) into QIMBY (quality-in-my-backyard) to demonstrate that residential intensification can be based on high-quality urban design and amenities.

On the Resource Management, Local Government and Land Transport Acts:

  • The RMA focuses on managing adverse effects of development of the natural environment, but is virtually silent on the urban environment (where natural landscapes are already highly modified). As such, the RMA has limited capacity to recognise and promote the positive economic, social and environmental contributions of high-quality, sustainable urban design and planning (e.g. compared to what is already built or “business-as-usual” development).
  • The RMA, LGA and LTMA create a complex web of separated planning and decision making processes. With land use, transport and infrastructure being subject to separate legal frameworks, plans and decision-making procedures required under the acts are all subject to different legal purposes, processes and criteria, and operate over different timeframes.
  • This has created parallel planning systems with a proliferation of planning documents, overlaps and duplication of efforts, creating significant resource demands on local authorities.
  • Overall, the urban planning system has responded poorly to the challenges and opportunities arising from urban development. The system has been a substantial barrier to increasing housing supply and providing network infrastructure in Auckland and other fast growing cities.
  • As such, it has contributed to rising house prices, missed benefits from agglomeration and increased environmental pressures from infrastructure bottlenecks.

A summary of the OECD's recommendations is below:

The policy and planning framework

  • Examine how to improve procedures, criteria and timeframes for planning and decision making to allow for more integrated and timely management of natural resources and urban environment while preserving the ability for effective local participation.
  • Consider making spatial planning mandatory for all urban areas with population over 100 000, while simplifying infrastructure and transport planning requirements; provide greater recognition and legal weight to spatial planning initiatives in smaller urban areas, and guidance on how spatial planning should be conducted; at the very least, clarify the hierarchical relationships and linkages across planning instruments for land use, infrastructure and transport and, where possible, align planning horizons and review periods.
  • Broaden the scope of the National Policy Statement on Urban Development Capacity, or develop other legally binding measures to ensure that local planning processes and instruments i) recognise and encourage good urban design outcomes and principles for sustainable urban development; ii) identify and appropriately manage important or sensitive environmental systems; and iii) incorporate climate change mitigation goals and resilience against climate change and natural hazards.
  • Facilitate the decision-making process to change existing land-use plans and reduce the scope for vested interests to thwart development of wider public interests (e.g. by front loading public consultations and ensuring an independent expert review of proposed plans and suggestions from the public).
  • Create a common set of urban environmental and economic indicators to increase transparency on cities’ environmental performance, facilitate benchmarking and identification of best practices, inform decision making and allow for better policy evaluation.

Institutional framework and multi-level governance

  • Establish a national co-operative structure comprising national institutions with responsibilities for urban-related matters (e.g. on the model of the Natural Resources Sector), with a view to improving horizontal and vertical policy co-ordination.
  • Consider replicating the Auckland institutional reform in other major urban areas, with the necessary adjustments, and encourage partnerships among smaller municipalities with a view to overcoming institutional and land-use planning fragmentation.

Regulations and economic instruments for sustainable urban development

  • Ensure that regulations in land-use plans pass robust cost-benefit analyses that consider environmental outcomes (including effects on transport, green spaces, etc.), as well as economic and social outcomes (including distributional consequences and intergenerational equity).
  • Make more systematic use of development contributions and rates to guide efficient and sustainable urban land use by: i) differentiating development contributions along the location and type of development to reflect the true cost of development on infrastructure and service provision; ii) considering adjusting development contributions and rates where development yields positive effects on the environment; and considering maintaining financial contributions or develop other instruments to reflect the environmental costs of developments.
  • Remove barriers to road pricing (e.g. road tolls and congestion charging) and encourage councils to introduce volumetric charging for drinking water supply, with a view to foster efficient use of infrastructure and resources, while reducing the burden on local government budgets.
  • Consider the use of betterment levies (e.g. through targeted rates) as an additional cost recovery mechanism for infrastructure and services provision, especially where development and financial contributions do not apply; and explore alternative instruments to finance urban infrastructure, including taxing windfall gains occurring to landowners following rezoning of urban land (value capture).
  • Review whether the current design of property taxation is aligned with land-use objectives and assess the potential benefits of shifting the property tax structure towards a land tax or to split rates.
  • Assess the environmental, social and economic implications of the funding model for roads and public transport; promote innovation encouraging alternative options for public transport (e.g. car-sharing, demand-responsive transport in small or low-density cities), while continuing to expand and improve conventional public transport services.

Sustainable housing

  • Improve the environmental performance of the building stock to reduce health impacts from poor insulation and the emission of air pollutants from inefficient heating by: i) modernising and strengthening national building standards; ii) establishing supplementary incentives to promote investment in insulation and modern heating in rental buildings; and iii) encouraging new housing to meet best practice urban design and sustainable housing principles.
  • Ensure that areas of fast-track residential development (notably those created under the Special Housing Act) are screened against environmental impacts, especially against cumulative and irreversible impacts.

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Thanks for the summary, Alex. Certainly sounds like it demonstrates a good understanding of the issues. Very pleased to see them advocating betterment taxes - and I note the point they make about betterment taxes being a more progressive form of taxation. Not sure what they envisioned, but I'd apply the taxation method city-wide (i.e., as opposed to as a targeted rate - as there are many, many more publicly funded improvements that result in betterment everywhere within a district/city, not just where new residential building is occurring) - the betterment tax would replace what we now know as the General Rate component of rates - leaving all other rates as cost recovery mechanisms (i.e., targeted and/or fixed rates) relating to direct service provision.

And although they recommend greater use of spatial planning as a means to make the RMA more urban development appropriate - in a perfect world we might instead develop a separate piece of legislation to deal with urban planning, incorporating LTMA into it and providing that it must give effect to LGA strategy plans.

The RMA would therefore not cover the built environment - only natural resource management, and perhaps to include minerals (?) with additional amendment to repeal the first-come-first serve water allocation, replacing that with a far more sustainable freshwater resource management framework.

Big legislative overhaul though - one would need a visionary and motivated government.


Nice post Kate- I like the bottom line "one would need a visionary and motivated government."
But not likely while the boomers are in charge.
go boomers


How to fix the boomer NIMBY problem?

If they insist on importing all the youth in Asia to drive up house prices, perhaps an order of reciprocal euthanasia to make room for them?


Or export all the ungrateful millenials in an act of terrible revenge


Too right, those young whippersnappers have no idea how lucky they are to have almost the worst housing affordability in the world while having to pay out social welfare to folks over 65 who have absolutely no need of it! Ungrateful sods!


Why is it the older generations problem to look after the laziness of the younger generation?
Stupid young idiots can't get off thier telephone or ipad long enough to make a go of things.


Poor trolling, 2/10, must try harder.

On the off chance you're serious, I would suggest reading this article that highlights what in incorrect picture you have of young people today, who are on average much less profligate than your generation.

None of your coiffed septuagenarian "alternative facts" here, mind.

But mirroring your point - why is it the young generations' responsibility to pay universal social welfare to old folks who are too lazy to work? I thought you guys were all "My own two feet!" types.

But all these things aside, no one is asking you to "look after" them. They're asking for a bit of balance in law, balance that will rebalance housing to be about homes for New Zealanders, not just investment portfolios for those whose genius was being born at the right time. E.g. foreign purchase Stamp Duty, removing tax advantages for investment property, limiting foreign purchases to new builds, tax to break up land banks. That sort of thing.

On the land bank tax, the actions of governments past to do exactly such breaking up is one of the reasons you own a home today. Appreciate the past and recognise the responsibility implicit in it.


Well you are wrong Mr Strauss.
I started work by pushing a milk trolly full of glass bottles around the the neighbourhood.
I don't need to appreciate the past. Because i lived it.


After 45 years of self denial and hard work and no overseas trips the Boomer dies,alone and unloved, leaving a s...load of highly priced housing infrastructure and cash for the Millenial to give to Apple,Audi, Airlines and dinners for two in Queenstown to fulfil the motto "I spend, therefore I am"


Back in my day, pensioners huddled shivering in cold flats. They weren't off to cafes multiple times a week on the free bus, having overseas cruises and holidays every year etc. These codgers don't know how lucky they are!




You must be near your 100th birthday.
The boomers buried that generation, they were part of that deprived society after the second world war, even the house had to have lower ceilings, that went on for another generation.
It was a low point, even the edwardians probalby enjoyed life more.
The boomers got closer to the flapper generation, fashion concious, loved their booze and ciggies, movies,glitsz and glam.
Gen Z,Y as i know them are much the same, but untested as they have not faced the stress of two world wars.
The Auckland DMZ will be character forming for them.


NIMBYs come in all age groups - and betterment tax would go quite some way toward eliminating the problem given by far the most betterment actually occurs on the isthmus in the old Auckland City area. Every multistory complex that is built (be it commercial or residential) betters (i.e., provides a land value gain) to the near vicinity neighbourhood. It's the reason that isthmus residents like population growth, as more and more people arrive - greater job/business opportunities present and more money is spent on inner city/CBD amenities. All these being within their wider neighbourhood - but not actually in their backyard. Start reflecting that privilege fairly via progressive taxation and the city can afford to fund growth out, whilst also seeing an improvement in growth up nearer the centre.

It's what the OECD refer to as turning NIMBYs in QIMBYs.


More sage advice from the OECD, God help us all.


Yeah, it's a surprise for sure - I get the distinct impression that the organisations' culture has changed in that they see the folly of the status quo/neoliberal reform approach - understanding now that inequality (inequality it baked in) actually matters.


The OECD has next to no credibility and it would be better off focusing on that social and economic train wreck called France, where it is headquartered. However, "do as we say, not as we do.."
A lot of the recommendations revolve around more bureaucracy and controls, a la the French socialist, big government model. Result: exorbitant taxes, bigger government and a dying economy. While they concoct their amazing plans to deal with all their policies that helped create these problems in the first place, the market will resolve these problems in a far more efficient follows:
- Rising interest rates going forward, will "tax" mortgage holders dramatically and help to significantly reduce house prices. No government intervention will be required.
- To pay for Auckland's infrastructure needs in the next 10yrs, rates will need to at least double from the current base to pay the bigger pile of debt, and this assumes that interest rates will stay low, which is highly unlikely. Again, no new taxes will be required and house prices will fall as pending retirees sell up while they still have some equity.
- The ability of central and local government to introduce new taxes will be limited, and as their credit ratings go down the toilet and more global funds realise that government debt is unpayable in the future, defaults will inevitably arise and (hopefully) a return to balanced budgets and basics will take place...


Just to clarify - are you suggesting the creative destructive forces of capitalism are the "fix" for all our woes, or the "punishment" for all our sins?


A collection of the current memes du jour. But is there any substance? Not sure after one quick read.

It's not clear to me whether the OECD (or possibly Alex) know the difference between 'funding' and 'financing'. The difference is absolutely crucial in local government infrastructure.

Councils do not fund infrastructure from rates. End of.

They find funds to build new infrastructure from other sources. If we are talking growth related infrastructure that source is mainly development contributions and assets vested by developers. If there is enough in the kitty then this expenditure has zero impact on general rates.

What is true is that if, for any reason, some infrastructure has to be loan-funded then the finance charges (just the interest) may be paid through rates charged for that activity.

I would also love to see some evidence for the assertion that properties are being charged rates for services they do not receive. I imagine by now it is universal practice for councils to divide up their rates into components (Roading, Water, Sewer etc). I know it is standard practice in the councils I have worked in that households only pay rates for services they receive.

This reads like the NZ that Upton used know 30 years ago in his wunderkind days. Times have changed.

PS the problems in Auckland are largely caused by the sudden change in the rate of growth not the growth itself. And these problems were compounded by attention being diverted by the unnecessary amalgamation and the Len Brown-led councils being absurdly focused on constraining expansion.


Of course rules regarding DCs changed recently;…

And indeed many councils (in order to be "competitive") never set their DCs at a level that fully recovered the cost of growth - hence borrowing to fund the shortfall, and recovering the interest on those borrowings via the General Rate and/or UAGCs.

UAGCs are indirectly an example of "properties being charged rates for services they do not receive." as their make up (what actual costs they relate to) is never disclosed (at least not in my experience). Here's ACC's explanation:

The UAGC is a fixed rate that is used to fund general council activities.…

Also in my experience, some council's used to explicitly explain the breakdown of "funding source" for each major activity undertaken. For example, RMA and BA consent processing - and (in my experience) it was never fully cost recovered from the users of those consent services - the balance not recovered was normally recovered from the General Rate.

I've found more recently that this type of detailed reporting is no longer a standard practice.

And then there is the curious treatment of asset revaluation and depreciation. A totally mysterious accounting practice to my mind - seems unique to local government - where this money goes... well perhaps you know.


Hate to tell you, Kate, but 2012 was 5 years ago not "recently". It was a good change though as it focused DC's more on where they were indisputably needed. So just to be clear: DC's are charged to fund projects identified in a Ten Year Plan that will ameliorate the effects of growth. Those projects can be roads, 3 waters, public toilets and cemeteries. The separate provisions for funding or handing over land in kind to form reserves is also still in force.

What councils can't do is collect DC's to fund enlarging a library or swimming pool.

In my experience (and every council will do it differently) our local UAGC is explicitly charged for community and recreation purposes (all of the activities are listed in the TYP). Any service that a household is able to receive is charged whether they use it or not. Locally we also have a rural/urban differential for road rates. I admit I know what I am looking for but our rates are transparent and are not applied to a household that cannot receive the requisite services.

To the best of my knowledge the LGA still requires councils to identify funding sources for each activity so we can know how much is coming from rates, charges, subsidies etc.

I bore for Britain on depreciation and asset revaluation. Honestly it's Accounting 101 stuff but it has the magical outcome that households effectively pay a daily charge to use council services. Someone who has being paying rates for 50 years has no more claim on council finances than the person who moved in yesterday.I think it's pretty neat.


No need to get uppity/defensive, Donald. The link above and my reference to recently relates to LG Act Reform Bill (no 3) 2014;…

But we are splitting hairs here.

When referring to "our local UAGC" - are you okay letting me know what LA you refer to. I'd be keen to look up their document to see how explicit they are with respect to the UAGC being charged only against community and recreation purposes. Always happy to refer to examples of best practice in terms of transparency.

Your comment that "I admit I know what I am looking for" is instructive. You and your knowledge is not the norm in the community - but that is no reason/excuse for such documents needing to be so complicated the average ratepayer can't find and/or interpret the information they deserve.

Nice answer to asset revaluation and depreciation - again, I guess what you are really saying is: "you are so so stupid that you don't understand Accounting 101" - so why don't you just say that?

You must work/have worked for a council.


Really not setting out to be offensive so many apologies if I have been.

The "Accounting 101" reference is shorthand for the fact that councils like the whole public sector comply with Generally Accepted Accounting Practices and/or International Financial Reporting Standards. That is, all their accounting practices are orthodox and practiced by all private businesses as well.

However you are right to say that it looks arcane from the outside. Because councils don't pay company/income tax and because they are confident they will be owning very similar assets in 100 years time they use depreciation slightly differently from what you learn in Accounting 101. Each council can use its own depreciation policy but my experience was with straight line depreciation over the lifetime of the asset based on replacement value. The replacement value gets updated every three years via the revaluation exercise. This broadly (but not exactly) has the effect of adjusting depreciation up in line with inflation.

The revaluation also affects asset management plans in the sense that it creates new numbers for the cost of replacing assets in the future.


No offence taken and appreciate the apology.

The thing is, what I believe has been found with time is that when assets need to be replaced there is no money in the kitty per se and more borrowing occurs and subsequently, rates rise beyond the rate of inflation. I know it shouldn't happen, but it seems to. I think that is why when 10 year plans were first introduced, so much deferred maintenance was discovered - and hence the very high initial projections with respect to future rates rises.


Yes and no.

There may be a looming problem of lack of funds for replacing assets. I don't think so but if there is it is already known about.

When the first full LTCCP round happened in 2006 Audit NZ made it a requirement for councils to have a robust asset management plan sitting behind the budgets for the infrastructure services in all councils. It isn't widely known but LTCCP/TYP's have to be audited before the draft goes out for consultation. That back-room requirement has since been formalised as the (30 Year) Infrastructure Strategy that now forms part of every TYP.

The process of compiling a long-term plan for infrastructure presents asset managers with some choices. The big one is whether to allow an asset to crumble or to carry out life-extending upgrades/maintenance. In the past they may have been informal, set of the pants decisions. Now they are carefully thought through. I suspect that many asset managers discovered back in 2004/5 that it was better economics to give some assets makeovers rather than replace them outright. Whether that counts as deferred maintenance or just better planning I'm not sure.

The A-G had a look at local government asset management a few years ago. If there was ever an occasion to raise a red flag over a looming funding crisis it was then. But she didn't.

I read this comment about deferred maintenance all the time. It doesn't ring true with me and I am still waiting for anyone to put up some hard evidence that relates to the whole sector.

If I get a moment tomorrow I will share my theory on where the need for debt comes from.


It (the issue of deferred maintenance) was I believe widely raised and subsequently investigated by this inquiry;…

If I recall off the top of my head - their investigation was inconclusive (data not readily available) but they erred on the side of it (deferred maintenance) not being one of the major drivers of the increased cost/expenditure forecasts from that first LTP round - they more pointed to (the then) method of depreciation as being more of a main driver of those increased costs. But that is all 10 years ago now.


Day 1:

Central Government: "Hey, Councils, we have passed a whole lot of legislation to make you do wonderful things for the country and you have to find the money".
Local Government: "???"

Day 2:

Central Government: "Hey, Councils, you sure are wasting a lot of money!"
Local Government: "WTF?"

Slightly oversimplified but the essence of what 2006 was.


LOL, yes, but I think HC called for the inquiry in response to the AKL ratepayers threatened rates revolt. It was an extremely good, thorough review process. The TYP was a needed discipline - and I really liked the introduction of the community outcomes process as well. So, all in all, I felt the LGA 2002 was good legislative reform for local government. Main problem now to my mind is the central government pull-back from local decision-making - both with respect to the RMA and the LGA. And in a general sense, we need a better calibre of politicians in LG - which we won't get if they are seen to be mere rubber-stampers.


Here I will mostly part company with you:

- HC initially refused to conduct any inquiry but caved under relentless pressure from Rodney Hide. The Inquiry TOR precluded any consideration of the impact of government policy changes on council finances (much to the chagrin of our Mayor). So sort-of thorough but not comprehensive.

- Community Outcomes were an unmitigated disaster that delivered absolutely nothing for all the rates poured into them

- With my magic wand I would repeal LGA 2002, get rid of TYP and start again. Councils already had to publish ten year projections but with way fewer strings attached. They are so constrained now in their financial planning and that is one of the root causes of the housing disaster in Auckland.

Absolutely agree with your final sentence 100%.


Really from me


Yes, I look at it from the outside - and I tend toward favouring any legislation that promotes collaboration between those on the inside with those on the outside :-). Outcomes processes were of course just another costly bit of public participation, but in a sector which has such low voter turnout - and such poor understanding of the requirements and complexity of local governance - anything that draws more people in to become involved and to get a better understanding of what the inside does, has to be a good thing. In many communities they did build trust - the AP/TYP process just doesn't achieve the same enthusiasm from the public in my experience. But then my experience is not wide - as I only lived in one community at the time :-). Thanks for the exchange - really enjoy your views and always learn so much.


Frankly, whilst this report raises some valid - if very far from novel - points, it is a very muddled policy wonk piece indeed.
For example, on one hand it advocates for more nimble and efficient planning processes, then on the other it talks up all those amorphous planning buzzwords like 'spatial planning' and 'integrated planning' - which in my experience, are usually very time consuming things and which often offer limited value. And it talks up a whole lot of other things which would just involve more bureaucracy and meddling.
It also recommends some things which are already done. For example, Section 32 of the RMA already requires cost / benefit analysis of rules to weigh up social, economic, cultural AND environmental costs and benefits.
Pretty ordinary stuff.


Agree on the amorphous buzzwords - I've seen instances where spatial plans are determined and implemented as LGA strategies ... which then end up having to be translated into District Plan rules eventually. So yeah, cumbersome - and duplicating and creating more work for planners.

Hence why I personally am in favour of a separate act for urban planning - not an "effects-based" piece of legislation (as the RMA is) but rather a property rights based piece of legislation.

Section 32 analyses are not cost/benefit analyses as per the economics discipline's definition of CBA - quite different and the difference is explicit in this regard;

Section 32 requires that the appropriateness of policies and methods be assessed having regard to their efficiency, rather than a more formal and prescribed Cost and Benefit Analysis (CBA)... One way to measure a cost or benefit in non-monetary terms is to apply value in accordance with a simple rating scale such as, for example, -5 to +5. Consultation with resource users and the community may aid in determining the 'score ' given to different costs and benefits. Alternatively, the highly subjective nature of many of the costs and benefits can be acknowledged by simply rating them on a narrative 'low, medium, high and very high ' spectrum.…

In my experience, few s.32 evaluations quantify/monetise costs and benefits for all options considered in line with a CBA approach - normally they use the matrix type example (high, medium, low) and/or subjective statements (as explained above) to legitimise/defend the appropriateness (i.e., the efficiency and effectiveness) of the choice made.

Not a criticism of the s.32 analyses I've read - it's that the legislation never intended them to be based on CBA techniques as per the principles taught within the economics discipline.