Submission on Managing our wetlands in the coastal marine area discussion document
Chris B, Flickr
In this submission to the Ministry for the Environment, the Commissioner voices his concerns about the preferred option in the Managing our wetlands in the coastal marine area discussion document.
This consultation relates to, but is distinct from, the Ministry's 2021 Managing our wetlands consultation.
The Managing our wetlands in the coastal marine area discussion document proposes amending the Resource Management (National Environmental Standards for Freshwater) Regulations 2020 (NES-F) so that the wetland provisions no longer apply to natural wetlands in the coastal marine area.
While some unforeseen issues with the application of the NES-F rules have arisen since the standards came into force, the preferred option of completely excluding wetlands in the coastal marine area from the scope of the NES-F goes too far.
The Commissioner supports further development of Option 1 mentioned in the discussion document by:
- undertaking further work to carefully assess conflicts, gaps and ambiguities between the different legislative instruments applying to coastal areas
- resolving any conflicts identified by proposing carefully designed amendments to the NES-F to clarify where and how it applies.
The discussion document also mentions definitional issues that surround ‘natural wetlands’. The Commissioner supports commissioning biodiversity and planning experts to come up with a definition of ‘natural inland and coastal wetlands’ that is both ecologically meaningful and policy fit.
The Commissioner undertook an investigation into the management of Aotearoa’s estuaries in 2020. Wetlands in the coastal marine area are diverse; they include saltmarshes, mudflats, rushland, mangrove swamps. All of them are sensitive ecosystems. Given that over 90% of our natural wetlands have been lost since human settlement, we need to tread carefully.
Ministry for the Environment website – Managing our wetlands in the coastal marine area