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This submission addresses National Direction Packages 1, 2 and 3.

In summary, the proposed changes to national direction represent a major shift away from managing human activities within environmental limits. As such, they represent a significant threat to the natural environment and its life-supporting capacity, which in turn jeopardises the wellbeing of people and communities.

Overall, the proposals:

  • are inconsistent with New Zealand’s international obligations under climate, biodiversity, fisheries, and natural hazard-related multilateral agreements, and also run contrary to New Zealand’s domestic policy goals and obligations in those areas.
  • do not implement Part 2 of the Resource Management Act 1991 (“RMA”).
  • are internally inconsistent, for example by relying on identification of significant natural areas or mapping of wetlands while also preventing or extending the timeframe for those actions to be implemented.
  • run contrary to the evidence as to the degradation of freshwater quality, reduction in quality and extent of wetlands, biodiversity loss, and carbon emissions.
  • treat protection of the environment as an impediment to be overcome through permissive policy, rather than a critical safeguard to sustain ecosystems, people and communities, and overlook the role of nature-based solutions in providing for our wellbeing.

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