RMLA Submission - Resource Management (Freshwater and Other Matters) Amendment Bill

RMLA has submitted on the Resource Management (Freshwater and Other Matters) Amendment Bill.

Overview of submission and approach.

• RMLA welcomes the opportunity to submit on the Resource Management (Freshwater and Other Matters) Amendment Bill (Bill).

• RMLA’s main objective in providing feedback is to ensure that a coherent and workable body of resource management and environmental law and practice is developed in New Zealand. As a result, it is not the RMLA’s practice to comment on matters of policy. Instead, its submissions focus on what (if any) changes should be made to the proposal to ensure that the instrument being considered will:

  (a) Be consistent with the general framework of existing laws and policies and legally sound;

  (b) Be practicable, effective and efficient;

  (c) Assist in promoting best practice; and

  (d) Produce high-quality environmental outcomes.

• As with previous bills seeking to amend the Resource Management Act 1991 (RMA), the timeframes for submitting in respect of this Bill have been very short. As such RMLA has adapted its usual process for seeking member comment. Member feedback has been sought via a brief survey seeking views on RMLA's proposed position on the Bill, with a short window for response.

• We take the opportunity here to reiterate our concerns about the number of ad hoc amendments being proposed to the resource management framework, the impact of numerous changes that require implementation, the volume of requests for input or feedback, and the short timeframes for responses. This is particularly the case with this Bill where changes are proposed to national direction through amendments to the RMA rather than directly to the national direction documents. This approach is inefficient, of questionable effectiveness, and does not promote good resource management practice.

• We also note that there appears to be a lack of evidence to support some of these proposals. RMLA remains concerned that the RMA continues to be "tinkered with" in the absence of evidence of a specific problem, or that the proposed solution will have the desired effect. The speed with which amendments are being made may well exacerbate rather than ameliorate the perceived issues. This approach is highly unlikely to result in enduring, cross-party solutions that will provide the required certainty to the public and councils