RMLA submissions on National Direction Packages 1-3

In preparing these submissions, it has not been possible for RMLA to form a single universally accepted view on each of the matters raised and positions taken. It should be noted that individual RMLA members may provide their own individual feedback which may represent quite different approaches to the views expressed in this submission.

Specific Feedback

We provided a Cover Letter with our submissions on NDF Packages 1-3.

We have also filed specific feedback in response to the separate consultation packages respectively:

1. Package #1: Infrastructure & Development

2. Package #2: Primary Sector

3. Package #3: Freshwater

General Comment

• A key concern of the RMLA Executive is the breadth of the change being proposed to both the RMA and current national direction at the same time reform of the legislation is underway. This creates risks in terms of how the changes to the NPF might work alongside the other changes to the RMA and national direction, and RMLA is concerned this may result in many targeted changes that do not fit together coherently or create multiple unintended consequences.

• RMLA questions whether the proposed changes will have the desired effect, particularly where further and significant reform to resource management legislation itself is also proposed in the short term. RMLA has previously expressed concern that the speed with which amendments are being made may well exacerbate rather than ameliorate the perceived issues. This approach is highly unlikely to provide the required certainty to the public and councils. RMLA seeks enduring and cross-party solutions.

• RMLA supports the government’s intent to improve national direction, reduce unnecessary compliance costs, and better enable primary production. However, the proposed changes to national direction present considerable risks to the integrity, clarity, and cohesion of the resource management system.