In the judgment of the Environmental Defence Society Inc v New Zealand King Salmon Co Ltd case, Policy 20 of the NZCPS similarly stated that adverse effects of activities were to be encouraged on outstanding natural features and outstanding natural landscapes, and the majority held that "avoid" meant "to allow" or "approve."
Policy 15 of the NZCPS similarly stated that adverse effects of activities were to be avoided on outstanding natural features and outstanding natural landscapes. 
