The proposals, which are spread across three packages of Infrastructure and Development, Primary Sector and Freshwater, present an overwhelming shift towards prioritising use and development at the expense of the natural environment.

National direction is the ‘engine room’ of the RMA. Regional policy statements and regional and district plans must “give effect” to it and decision-makers on resource consent applications must “have regard” to it. It therefore has significant ramifications for resource management decision-making.

“Taken together, the changes set out pose a significant risk to indigenous biodiversity, freshwater, wetlands, elite soils and the coastal marine environment. They will result in more inappropriate and environmentally damaging activities occurring in New Zealand’s most sensitive places,” says EDS Chief Operating Officer and lawyer, Shay Schlaepfer.

“The environment is not in a healthy state. Monitoring shows ongoing declines in freshwater quality, more threatened and at risk species, a reduction in food producing land, continued loss of remaining wetlands and a marine environment under threat.

“The proposals are wilfully ignorant of that context. They are being pushed through under a ‘growth at all costs’ mentality that will result in more pollution for longer and more destruction of nature. This is not what the RMA provides for."

EDS’s key concerns with the proposals are:

1. Forestry review too narrow: The proposed changes fail to address systemic issues with forestry regulations which are resulting in extensive and damaging slash and sedimentation mobilisation events with corresponding devastating impacts on receiving environments and communities.

2. Infrastructure proposal lacks environmental considerations: The Government's expansive vision for infrastructure and development comes with no corresponding focus on protecting the natural environment.

3. Increased mining and quarrying in sensitive areas: The proposed changes will facilitate more mining and quarrying activities, directly threatening New Zealand’s indigenous biodiversity, vulnerable wetlands and highly productive land.

4. Freshwater management at risk: The proposed changes would unwind decades of freshwater management progress, undermining hard-won legal protections in favour of short-term economic interests.

5. Natural hazards not taken seriously: A gaping hole in the proposals is any regulation to stop building in high hazards areas. If New Zealand is to get real about climate adaptation it needs to prioritise not making the situation worse in the first place.

“The review of national direction is being undertaken before replacement resource management laws are enacted in ‘phase 3’ of the Government’s programme of RMA reform. Progressing substantial national direction review under a regime that is to be replaced, and then implementing those new instruments in a new regime which Ministers describe as being radically different, is a confusing, unstructured and backwards approach.

“This has been exacerbated by Minister Bishop’s recent ‘plan stop’ announcement which has compounded uncertainty about how the package of national direction changes will be implemented. The Government needs to stop rushing and progress resource management reform on a more strategic, coherent footing.

“Most importantly, Government needs to acknowledge that economic growth and good environmental outcomes are both achievable. EDS’s submissions propose changes to the policy settings which would bring the instruments into a more acceptable and lawful outcome,” concluded Ms Schlaepfer.