Submission on the 2022 Exposure Draft for the proposed National Policy Statement for Indigenous Biodiversity’ and related documents
Federated Farmers submitted on the Government’s 2022
Exposure Draft National Policy Statement on Indigenous Biodiversity.
This is a draft national policy statement under the Resource Management Act 1991 that would influence new rules aimed at managing protection of indigenous biodiversity in regional and district plans.
Our key messages are:
- Federated Farmers does not support the 2022 National Policy Statement for Indigenous Biodiversity Exposure Draft (“the NPSIB”) as currently drafted.
- We consider the criteria for identifying significant natural areas (SNAs) in Appendix 1 of the Exposure Draft remains flawed. It will capture most if not all indigenous biodiversity as being significant, which is contrary to stated intent.
- While most/all indigenous biodiversity will be treated as an SNA, anything that is remaining will largely be treated the same as an SNA due to application of the effects management hierarchy. The highly mobile species habitat recognition and protection will not work in practice.
- The package of financial incentives and support is wholly inadequate and misses a real opportunity to incentivise the protection of existing biodiversity, an increased planting of indigenous vegetation, and helping meet New Zealand’s wider biodiversity and climate change objectives.
- There is inadequate provision for protecting existing activity. While there is an increasing list of exemptions for other land use types, farmers’ ability to continue pastoral farming is reduced.
- There are a range of practical concerns (including sufficient access to experts, delays and costs) around required consent information requirements.
- Some of the attributes for SNAs within Appendix 1, and Clause 3.10(2)(a) to (e) are unmeasurable.
- There is inadequate information on the impact or extent of the increased definition for Māori land, and what this will mean for remaining landowners when it comes to overall maintenance and targets.
- There is inadequate regard to the real gains that can come through catchment groups, and farm plans in this area.
- The precautionary principle will largely make the NPSIB unworkable in practice.
- Success in the area of biodiversity will largely come as a result of support, partnerships, collaboration and improved information and monitoring. An overly restrictive, or pecuniary, regulatory framework risks disincentivising restoration or enhancement, and deterring of the voluntary involvement of farmers in working with councils, or providing information.
- The ultimate test of workability is whether this policy statement will reduce litigation regarding indigenous biodiversity – why Federated Farmers became involved in the BCG in the first place.
Federated Farmers National Board Spokesperson for Biodiversity is William Beetham.
Our full submission can be reviewed on the right.
For further enquires or queries, please contact:
Peter Matich
Senior Policy Advisor
027 240 9997
[email protected]