Response 693987640

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Your details

1. What is your name?

Name (Required)
Redacted text

5. If on behalf of an organisation, what is its name?

Name of organisation
Federated Farmers New Zealand

Section 2: How to have your say

1. Do you agree that the current application of the NES-F to the CMA requires amendment?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

2. Do you agree with the proposal to amend the NES-F wetland provisions to no longer apply to the CMA?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

3. Do you think the wording changes proposed in the preferred option make it clear that the NES-F would no longer apply in the CMA?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

5. Is there any additional relevant information that you think the Ministry should consider?

Please explain your answer here
The Discussion Document notes two ‘key issues’ that have emerged:
• The ‘Natural Wetland’ definition can be interpreted as capturing a far greater area of the Coastal Marine Area than was the initial policy intent
• Applying the NES-F rules would constrain or prevent activities “unlikely to cause the loss or degradation of natural wetlands, which goes beyond the original policy intent”
These are the same two key issues Federated Farmers has raised in respect to how the definition will also apply to farmland:
• The ‘Natural Wetland’ definition can be interpreted as capturing a far greater area of farmland than was the initial policy intent,
• Applying the NES-F rules would constrain or prevent farming activities unlikely to cause the loss or degradation of natural wetlands, which goes beyond the original policy intent.
Federated Farmers submits that the key issues identified are relevant for much broader areas than just the CMA.