RMA national direction freshwater and primary sector submissions
Rakatu Wetlands, Southland.
The Commissioner has made a series of submissions on the RMA national direction packages. In this submission he provided feedback on proposed amendments to the primary sector and freshwater packages.
“New Zealand’s problems with water quality and sustainable land use have been a long time in the making. Policy changes like these, that are designed to yield ‘quick wins’, are unlikely to address current or future challenges that require patient attention over much longer timeframes,” he warns.
He also points out the constant reform of national policy statements over the last 15 years has caused confusion and frustration for land users and has been demoralising for local government staff who have struggled to make progress.
He has advised the Government against proceeding with the proposals, noting that they will not, in his view, reduce the likelihood of future change and are therefore unlikely to provide either enduring freshwater or land management systems.
If the Government does go ahead with the proposals, the Commissioner has raised several concerns and suggested amendments. These concerns include that:
- without guidance on how to balance multiple freshwater management objectives, there will be increased uncertainty for regulators and those regulated
- changes to the National Policy Statement for Highly Productive Land are based on the land use capability classification system which is unfit for this purpose
- removing the ‘public benefit test’ from national policy statements would make it easier for mining and quarrying to be allowed on significant natural areas, wetlands and highly productive land by not accounting for the costs of these activities
- removing mapping requirements for wetlands would put these scarce and important resources at further risk.
- changes to the New Zealand Coastal Policy Statement could enable projects with predominantly private benefits, such as resource extraction operations, easier access to the coastal environment without contributing to mitigating the public costs that they create
- changes to the National Environmental Standard for Forestry reduce the ability of local councils to manage poorly documented risks to forestry.