Federated Farmers of Gisborne Submission for Resource Management Amendment Bill
We take an interest in the Bill because we are concerned the proposed changes will undermine the important collaborative working relationship that exists between Gisborne District Council and stakeholder groups such as ourselves. This important work includes five years worth of investment in the development and implementation of the Tairawhiti Freshwater Plan.
We have serious concerns the Bill will hinder rather then enable public participation opportunities. As representatives of those who rely on land-based resources public participation is particularly important as we work to ensure those interests are adequately considered.
The Gisborne/Wairoa province acknowledges and supports the comprehensive Federated Farmers of New Zealand national submission.
Specific Comments
Gisborne/Wairoa Federated Farmers opposes the Bill, and submits that it should not be progressed any further.
The Bill adds nothing except to further confuse and complicate a piece of legislation that is already overly confusing and overly complicated. It creates more bureaucracy and adds to the time delays already problematically inherent in the legislation.
The Bill also pre-empts the consultation process that is currently taking place around freshwater, as part of the government’s “Essential Freshwater Package” proposals. An outcome of that consultation process may well be a better way forward than the “new specialised planning process for freshwater” that is currently proposed in the Bill. It is entirely unacceptable for the government to be seeking feedback on whether streamlined freshwater planning processes are supported as part of Freshwater Proposal consultations, while concurrently including fully drafted changes as part of the Bill. This is an example of ‘Clayton’s consultation’, with decisions being made prior to the results of purported consultation being received.
Overarching objectives
We support the purported overarching objective intention, but strongly oppose any suggestion that the contents of the Bill are consistent with it.
The planning proposals for freshwater in particular are rushed, pre-emptive (given the separate Essential Freshwater Proposals are mid-process) and will add significant uncertainty, confusion, costs and delays to freshwater planning processes.
Rather than “restore public participation opportunities”, the freshwater planning proposals will end up creating an outcome of ‘survival of those with the deepest pockets’. We’ve seen this in previous fast-tracked planning processes, where they are effectively managed as if they were Environment Court proceedings, with costly and time-consuming requirements for expert evidence, caucusing, cross-examination and rebuttal of evidence, a along with extensive mediation and pre-hearing meetings. The outcome is typically for well-resourced organisations to continue involvement, while members of the public simply cannot resource, or fund, the intensive on-going requirements. It simply becomes overwhelming.
We also dispute the alleged “urgent need to improve freshwater management and outcomes”. This is overstating the realities of current freshwater state and trend (as discussed within the separate Federated Farmers submission on the Essential Freshwater Proposals).
Importantly, there is not an urgent need for the Bill to improve freshwater management and outcomes. This is being concurrently and separately addressed through a number of significant regulatory proposals before government – including the draft National Policy Statement for Freshwater Management, the proposed National Environmental Standard for Freshwater and draft Section 360 Stock Exclusion Regulations. These matters are already complicating and confusing existing planning proposals under the current National Policy Statement for Freshwater, and there is no further need to complicate matters at this time.