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8 What Next?

8.1 Making a submission

Anyone can make a submission on the proposed national environmental standard discussion document. Please include the following information:

  • your name and postal address, phone number, fax number and email address (if applicable)

  • the title of the proposed national environmental standard you are making the submission about

  • whether you support or oppose the proposed national environmental standard

  • your submission, with reasons for your views

  • any changes you would like made to the proposed national environmental standard

  • the decision you wish the Minister for the Environment to make.

You must forward your submission to the Ministry for the Environment, PO Box 10362, Wellington, or by email to standards@mfe.govt.nz, in time to be received by 5 pm, 31 July 2008.

Note: your submission is public information and is subject to release under the Official Information Act 1982. Please clearly indicate if any of your comments are commercially sensitive or if, for some other reason, you consider they should not be disclosed.

8.2 Questions

Your submission can address any issue relating to the proposed national environmental standard discussion document. The Ministry for the Environment particularly welcomes specific comment on benefits and costs of the proposal, and on the following questions, which have been highlighted in boxes throughout this discussion document:

Question 1 – Problem statements and issues

Do you agree with the problem statements and the three key problems that were identified as benefiting from national direction?

Question 2 – Assessment and evaluation of alternatives

Do you consider that all available options have been covered? Do you have comments on the assessment and evaluation of alternatives?

Question 3 – The need for interim limits

Do you support the need for, and introduction of, interim limits set through a national environmental standard?

Question 4 – The interim limits

Do you have comments on the numbers for the interim flows and water levels? Are there sufficient divisions of rivers and streams and groundwater systems?

Question 5 – Time bound

The proposal does not set a time limit for how long the interim limits will apply. There is some concern that this will not encourage catchment-specific or regional default flows to be set. Do you think the interim flow and water levels should apply for only a limited period?

Question 6 – Inclusion of existing consents within allocation limits

As currently structured, the interim allocation limits include all existing consents. Implementation of the limits will, therefore, not require claw-back of existing consents to meet the interim allocation limit. Claw-back is an option allowed when an environmental flow is set through a regional plan. How do you think the situation, where the amount of water allocated to existing consents exceeds the numeric interim limit, should be addressed?

Question 7 – The need for an NES on the selection of technical methods

Do you support the aim to provide consistency in the selection of methods for assessing ecological values? Does consistency need to be provided in a national environmental standard or would guidance documents be sufficient?

Question 8 – The approach outlined in the technical document

Do you have any comments on the approach outlined in the technical document Draft guidelines for the selection of methods to determine ecological flows and water levels?

Question 9 – The inclusion of new methods if they become available

How should new and emerging methods be incorporated into the process outlined in the proposed Standard?

Question 10 – NES approach to breaches

How do you think the national environmental standard should address applications for resource consents that breach the interim limits?

Question 11 – Application of the NES to existing and replacement consents

How should the national environmental standard apply to existing and replacement resource consents in each of the situations outlined in Table 2?

Question 12 – Benefits and costs of preferred option?

Have the range of benefits and costs of the proposed national environmental standard been identified? Are the costs and benefits identified in this document accurate? Do you have other information you would like to see included in the cost-benefit analysis that will occur after submissions are received and analysed?

Question 13 – Quantification and analysis

Do you have any comment on the assumptions used in the analysis? Do you have any comment on the partial quantification of costs outlined in this section? Do you have information that would be useful for the full analysis?

8.3 What happens to submissions?

The Ministry will prepare a summary of the submissions, which will be available through the Ministry’s website. Hardcopies of the summary will be sent to all submitters and made available on request. The Ministry will then prepare a report on the submissions. This report, together with the recommendations on the proposal for national environmental standard, will be considered by the Minister for the Environment.

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