At the 11th hour do we want to make a submission by the 28th Feb on the proposed RMA reform bill? The key changes to the Act of interest to members are the changes to section 76 with regard to the protection of significant trees within urban areas and section 32 which relates to the evaluation of alternatives, benefits or costs of regional plans, and national or regional policy statements.
Other organisations such as the Environmental Defence Society have submitted on the importance of trees in their protection of urban stream corridors - this is certainly an issue that NZFSS members may also want to submit on? A summary of the issues, a copy of the proposed bill and EDS’ draft submission can all be found on their website for more info. Sections 32 and 76 can be viewed on http://www.legislation.govt.nz search Resource Management Act 1991.
The changes to the s32 analysis are a more complex issue. This section of the RMA already requires evaluation of the benefits and costs of policies but the proposal is to specifically require consideration of the opportunity costs for economic growth and employment. There is a risk that this may elevate economics over environmental concerns, particularly if upcoming changes to the purpose of the Act also contain an economic emphasis. As most of you know analysing monetary concerns against ecosystem services and intrinsic values is fraught with issues. Balancing the benefits and costs in a purely economic sense is unlikely to result in environmental protection.
NZFSS advocacy and submissions