Board Inquiry into New Zealand Coastal Policy Statement
On 14 October I will be presenting Local Government New Zealand's submission on the New Zealand Coastal Policy Statement (NZCPS) to the NZCPS Board of Inquiry in Dunedin. Dunedin will be the sixth destination for the Board, who have been hearing submissions in Wellington, Nelson, Northland, Canterbury and Auckland since August. Hearings are yet to occur in Hamilton, Bay of Plenty and Gisborne.
The Board of Inquiry is made up of four members whose job is to carry out an independent inquiry into the draft NZCPS, provide a report and make recommendations to the Minister of Conservation. The four members of the Board are: Environment Court Commissioner Kathryn Edmonds, iwi authority chief executive Rikirangi Gage, former Nelson MP and Mayor Philip Woollaston and Board Chair, Environment Court Judge Shonagh Kenderdine.
The purpose of the NZCPS is to state objectives and policies to achieve the purpose of the Resource Management Act 1991 in relation to the coastal environment. The Proposed NZCPS contains objectives and policies on subdivision, use and development, natural character, public access, water quality, coastal hazards and historic heritage. In our submission to the Board we raised a number of concerns around the Proposed NZCPS, which generally fell into two camps: scope and appropriateness of some policies and implementation issues.
In our hearing in front of the Board we will cover:
- inappropriateness of some of the policies, in particular the subdivision, use and development and public access policies, along with specific activity policies such as those for maui dolphin, aquaculture and surf breaks of national significance
- the need for a full review of the purpose and thresholds of Restricted Coastal Activities
- the legislative issues surrounding Coastal Occupation Charging
- process issues, in particular deadlines for policy or plan changes, providing for policy or plan changes without going through the first schedule process, and monitoring
- financial costs to councils and the need for an implementation package, particularly around coastal hazard identification.
Scope and appropriateness of some policies
We believe that a National Policy Statement (NPS) should focus on matters of national priority rather than delving into the local level. The Proposed NZCPS goes further than its brief in a number of sections. In particular, subdivision, use and development, and public access sections where there are some policies that are delving into district plan matters, specifically urban planning. We believe that the Proposed NZCPS is not the appropriate mechanism to offer guidance on some of these aspects.
Implementation issues
One of the biggest issues with the Proposed NZCPS is the potential for large financial cost to councils, particularly in relation to policies on coastal hazards. These will require identification of areas in the coastal environment potentially affected by coastal hazards. These are proposed to be assessed over a 100 year time frame and include the effects of climate change.
The data required to make these assessments is expensive and for smaller councils with large areas of coastline almost impossible to afford. We will be raising with the Board the need for an implementation plan that includes assistance and funding for this work.
I look forward to updating you on the outcome of the Board Inquiry at a later date.
Stephen Cairns
Chair of Otago Regional Council and National Council Environment Spokesperson
