Call for comments on the Resource Legislation Amendment Bill 2015

The proposed changes aim to provide three main outcomes:

1. consistent and better aligned resource management system,
2. efficient and flexible resource management processes,
3. efficient and durable decision-making.

Public consultation on the Bill is open until the 14th of March 2015. The EEA will be collating a response based on feedback received. We would appreciate your comments to be sent to [email protected] by Monday the 22nd of February 2016, so that a draft industry submission can be prepared and circulated to members before submission to the Select Committee.

During the government consultation conducted in October on national policy statements under the Resource Management Act (RMA), the EEA highlighted the need for more consistency and timeliness in resource consent processes. This consultation is the opportunity for the electricity supply industry to restate some important messages. A summary of the proposed changes and objectives has been prepared by the Ministry for the Environment (MfE; see links listed below). The EEA is particularly interested in receiving members' comments on the following proposals:

Objective 1. Better alignment and integration across the resource management system

• Proposed changes for the development of National Policy Statements (NPSs) and National Environmental Standards (NESs) to introduce: a combined development process for NPSs and NESs, the clarification of NPSs' scope to give more specific direction, and the possibility for NPSs and NESs to be developed in relation to a specific area regarding a local issue that has national significance. In light of the coverage of transmission and renewable electricity generation assets under the NPSREG and NPSET/NESETA and discussions among distribution companies for the inclusion of distribution assets under an NPS/NES framework, do you believe that the proposed changes provide adequate solutions for clearer and more consistent developments of NPSs and NESs?
• Development of a Mandatory National Planning Template (NPT) for national consistency and simplification purposes. Do you agree with the proposal for a mandatory national planning template? Is this an appropriate response to the current lack of consistent resource planning approaches between different councils and local authorities?

Objective 2. Proportional and adaptable resource management processes

• Introduction of two new planning processes in addition to the current system as prescribed in Schedule 1 of the RMA: i. a collaborative approach that seeks greater public engagement, and ii. a streamlined approach, at a council's request, for specific local issues (urgency, unintended consequences of a plan, etc.). What is your view as regards the expected timeliness and efficiency of the above alternative processes? Are there specific cases identified by the electricity supply industry (ESI) in which the collaborative or streamlined planning process would help resource consent decision-making and industry project delivery?
• Option given to councils to limit notification for plans where directly affected parties can be easily identified. Do you believe that this option could negatively affect the ESI's ability to participate in important resource planning processes? If yes, in which instances? Would the ESI prefer an alternative option?

Objective 3. Robust and durable resource management decisions

• Management of natural hazards included in section 6 as a matter of national importance. What comments would you make to ensure that the inclusion of natural hazard risk management under resource planning processes, as prescribed in the proposal, provides an effective coordination framework between different councils, and between decision makers and individual ESI companies' specific risk management plans and emergency procedures?

The EEA is also interested in receiving feedback on any other proposals that may be deemed sensitive or critical for the ESI, or any other details that are considered relevant by our members.