The council's submission was signed by chief of strategy and science Joanna Noble, who began the letter by acknowledging the reform was a once-in-a-generation opportunity to shape how towns, cities, rural and natural environments adapted to challenges.
“Decisions made as part of resource management reform will have enduring impacts for the quality of our natural and built environments and the wellbeing of current and future generations.”
Ms Noble said the council had considered the bills' impact on the council, community and tangata whenua in Tairāwhiti, and was “interested” in avoiding requirements that would have adverse effects.
“The shift to a future-focused, outcomes-based system is not matched by reality,” the letter read.
“The proposed list of outcomes is broad with many competing priorities and expectations. As written, this is unlikely to guarantee environmental protection, let alone enable rehabilitation or restoration of the environment.”
The council acknowledged the Government's intention to contribute to plan-making under the bills, but expressed concern about how it could afford to pay for new requirements on an ongoing basis.
Transformational funding from the central government would be required, it said.
Another concern raised by the council was the “watering down” of the local voice in both bills, which it feared would result in decisions being made that could create further harm to people, property and the environment.
“The bills as worded decrease local voice where we would want to see more. Minimising local voice may result in indirectly minimising the role of mātauranga Māori within the new system.”
As part of its letter, the council provided background on the makeup and unique attributes of the region.
That included over half of the Tairāwhiti population being Māori — or 53 percent compared to a national average of around 17 percent.
The region was home to 70 operational marae with iwi including Ngāti Porou, Ngaāi Tāmanuhiri, Rongowhakaata, Te Aitanga-a-Māhaki, Te Whanau a Kai and Nga Ariki Kaiputahi.
The council was concerned there would be significant pressure on iwi, hapū and tangata whenua to participate in a new system with a lack of acknowledgement for the time required to build capacity and capability.
In order to realise Tairāwhiti's full potential, the development of effective and meaningful collaboration with mana whenua was important, the letter said, to ensure iwi and hapū had a long-term role in the planning and decision-making of the region.
The letter's regional overview referenced population growth, saying Tairāwhiti was now home to more than 50,000 people and had increased at a higher rate than expected in the past three years.
Steady growth was putting pressure on services, housing, infrastructure and the natural environment, it said.
The gross domestic product for the year ended March 2021 was $2.3 billion, with the region experiencing challenges with income and affordability.
The average household income remained one of the lowest in the country, coming in at $82,800 compared with $104,400 for all of New Zealand.
Rates in most of Gisborne's urban area exceeded the 5 percent threshold of affordability, and more than 90 percent of the council's capital expenditure went on critical infrastructure and community facilities.
The region's vulnerable geography was also mentioned.
“Tairāwhiti is exposed and vulnerable to climate risks and multiple natural hazards. Approximately 80 percent of Tairāwhiti is considered erosion-prone.”
The council has asked to be a pilot region for new resource management reforms.
A series of proposed changes to resource management in Aotearoa have come under fire from Gisborne District Council in a robust letter penned to the Government.