Frank Brenmuhl's comments on the role of the Department of Conservation in the Resource Management Act (RMA) require some clarification. He contends that the activities carried out by DoC on public conservation land are exempt from RMA processes, when in fact DoC is subject to scrutiny and controls as for
any proposed development under the RMA.
If the department's activities are not specifically permitted, then DoC must apply for a resource consent, the same as for any developer. The kinds of DoC activities that are subject to RMA process include piping water in and out of huts, discharging contaminants, such as 1080 poison, or building bridges on tracks.
Any exemptions DoC has from the RMA are laid out in the publicly notified Conservation Management Strategies, which in practice are stricter than the RMA with regard to restrictions on what DoC is allowed to do on public conservation land.
DoC makes submissions on publicly notified resource consent applications, as an affected party, in exactly the same way others get involved, such as adjoining landowners and neighbours, other Government departments (such as the Energy Efficiency and Conservation Authority), statutory bodies (such as Fish and Game NZ), or other relevant organisations such as Federated Farmers.
If a proposed activity is likely to affect natural public resources, e.g. a neighbouring national park, or a protected native species found on that land, then DoC has a statutory responsibility to make sure it advocates the protection of these public resources on behalf of all New Zealanders.
