Boffa Miskell’s submission on the Exposure Draft of Amendments to the National Policy Statement for Freshwater Management 2020

10 July 2022

Our submission focused on the definition of natural wetlands, and sought modifications to improve the clarity and workability of the proposed changes.


Our submission acknowledged the effort that the Ministry for the Environment (MfE) had put into the exposure draft in response to concerns about the ambiguity and unworkability of the National Policy Statement for Freshwater Management 2020 (NPS-FM) regarding the definition of ‘natural wetland’.

Boffa Miskell’s feedback was focused on the clarity and workability of the proposed changes regarding the definition of ‘natural wetland’ as outlined in the exposure draft and was prepared with input from Boffa Miskell practitioners having experience working with the provisions of the NPS-FM.

Dr Ian Boothroyd coordinated the submission document on behalf of the company.

“We work with many guiding documents, scientific literature, planning frameworks, mentors, and our own experiences. As practitioners involved in field assessments of freshwater (including wetlands), and in the interpretation of the application of national, regional, and territorial legislation, policy and regulations, we have first-hand knowledge and experience of the management of freshwater ecosystems throughout New Zealand; as well as the implementation of the effects management hierarchy,” says Ian.

Ecologists and Technical Leads reviewed the Submission document prior to it being sent to the Ministry for the Environment. The submission was signed by Boffa Miskell chief executive Kerry Gupwell, on behalf of the company.

Read the complete submission here.

For further information please contact Dr. Tanya Blakely, Chris Ferguson or Dr. Ian Boothroyd