Submission on the Managing our wetlands discussion document

^{Seamoor, Flickr}

In this submission to the Ministry for the Environment, the Commissioner comments on the three broad proposals in the Managing our wetlands discussion document.

The discussion document proposes amendments to the definition of a ‘natural wetland’, and changes to the regulatory framework to enable wetland restoration, as well as several development activities via consent pathways.

Overall, the Commissioner is concerned that the proposals risk further wetland loss, and in particular the capacity of wetlands to protect against adverse climatic events.

Key points from the submission include:

• The proposed changes to the definition of a ‘natural wetland’ will do little to make the definition simpler and interpretation less variable.
• Making restoration, maintenance and biosecurity activities easier, while providing for protection of ‘natural wetlands’ is a sensible proposal that the Commissioner supports.
• The proposals for additional consent pathways for quarrying, landfill, clean fill, mining and urban development are most worrying, as they broaden the reasons to destroy wetlands to almost anything, and would be a U-turn to avoiding any further loss or degradation of wetlands.
• Crucially, wetlands are a natural defence in climate adaptation – they help mitigate flood risks and damage. So we should be much more cautious about believing we can simply engineer our way out of the problem.
• Wetlands are place-specific ecosystems that cannot realistically be relocated or rebuilt. In the context of natural wetlands, offsetting and compensation do not work.