Boffa Miskell’s submission on the application of the National Environmental Standards for Freshwater to the Coastal Marine Area
27 September 2022
Our submission on the ‘Managing our Wetlands in the Coastal Marine Area’ focused on clarity and workability to the National Environmental Standards for Freshwater.
We acknowledged the effort that the Ministry for the Environment (MfE) had put into the Managing our Coastal Wetlands work programme in response to concerns about the ambiguity of the application of the National Environmental Standards for Freshwater (NES-F) to the coastal marine area.
Our submission further recommends an expansion to MfE’s proposed Option 1. We recommend bespoke regulations in the NES-F for natural coastal wetlands, and also recommend amendments to the New Zealand Coastal Policy Statement to provide consistent policy direction and protection to coastal ecological values from key threats.
Our feedback is focused on clarity and workability and has been prepared with input from the practitioners within Boffa Miskell having experience working with the provisions of the NES-F.
Technical Lead for Sciences, Dr Tanya Blakely reviewed the submission document.
“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 and coastal ecosystems throughout New Zealand; as well as the implementation of the effects management hierarchy,” says Tanya.
“Our practitioners hold registrations in their specific disciplines and represent their specialist expertise in decision-making forums such as hearings and the Environment Court. We work with many guiding documents, scientific literature, planning frameworks, mentors, and our own experiences.”
The submission recommends an expansion on Option 1 to provide bespoke regulations for natural coastal wetlands, amendments to the NZCPS to provide consistent policy direction and seeks modifications to improve the clarity and workability of this definition.
Ecologists and all 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.