"Regrettably, like much of what is being provided by central government, there are tight timeframes for responding and this does not enable us to engage with our communities," Kirsty's report to council said.
The draft submission noted indigenous biodiversity in Waipā is largely restricted to limited remnant indigenous forests and remaining wetlands.
There were 73 nationally-threatened species of plants and animals recorded in the district, including the pekapeka-tou-roa (long-tailed bat), matuku (bittern) and kākā. Surviving populations are severely threatened without funded intervention centred around the Waipā and Waikato rivers, central peat lakes and the district's three maunga (mountains) – Kakepuku, Pirongia and Maungatautari.
While the submission broadly supported the intent of the NPS, it said implementation in the district will be constrained by capacity and resourcing issues. It noted a number of concerns, including costs, staff capacity and links to new and proposed laws. The submission also raised financial red flags.
"There is no mention of funding support for ongoing additional costs for tasks undertaken in the later phases. These tasks were not anticipated when the council prepared its 2021–31 Long Term Plan and any increased costs for biodiversity protection would likely result in changes to the levels of service for other council activities," the submission says.
"We will be undertaking an assessment of compliance costs and what this means for our Waipā ratepayers."
The submission pushed back on a suggestion that biodiversity management was already a requirement for local government.
"The reality is that this is currently achieved in Waipā with limited capacity and through collaboration with partners, stakeholders and community groups. There is limited ability to do much more than we are at present. The council will require more skilled staff and resources to implement the National Policy Statement - Indigenous Biodiversity. This is a challenge in the current environment."
Council's submission suggested the NPS should be "crash-tested" for workability by a panel of experts, and that all councils should receive funding for the full implementation, including funding policy and plan changes. The council suggested the Waipā district be considered a pilot project, funded by the central government.
Council said it would discuss its concerns around the process with Local Government New Zealand.
Council's final submission is on the Ministry for the Environment's website.