6bii How would you define type’? (eg, would it be based on types of industry such ‘proposal as power generation, or housing development?) It could be industry type, but also it could be effects based, and pay attention to the receiving environment and the affected community and its concerns and the nature of impacts on environmental systems and capital. 7. Who do you think gains from the single threshold approach? Who misses out? The single threshold is likely to be simply the investment input dollar value, and thus the applicant will benefit and others will have to wear the costs of the direct referral and the distinct freezing off of community engagement. 8. Who do you think gains from the different threshold amount approach? Who misses out? The answer to this depends on what the nature of the threshold tests are. Setting the threshold amount 9. For your preferred measure, at what level would you set a single investment threshold amount so that it selects for proposals with significant economic scale at a regional level? This is such a bad test, given the RMA’s purpose that we object to this being the focus. It is not really possible to answer this unless we know whether the discussion is net investment from a broader societal viewpoint, gross private investment or what. 10. How would you adjust the threshold amount to take different location into account? Yes, probably we would, and in particular, we would have a test of irreversibility and severity of divestement or degradation of natural capital, and impacts on the community. 11. How would you adjust the threshold amount to take different proposal types into account? As in 10 Exceptional circumstances 12. Which of the above matters do you agree should be prescribed? If there are additional reasons why those matters should be prescribed, please provide them. We do not understand why the Ministry paper equates with “exceptional” “unforeseen”. There are many things that are exceptional but not unforeseen. The exceptional circumstances are those that are rare and unusual, or which have compelling ethical or cultural or social implications, not unforeseen.
6bii How would you define ‘proposal type’? (eg, would it be based on types of industry such as power generation, or housing development?) It could be industry type, but also it could be effects based, and pay attention to the receiving environment and the affected community and its concerns and the nature of impacts on environmental systems and capital. 7. Who do you think gains from the single threshold approach? Who misses out? The single threshold is likely to be simply the investment input dollar value, and thus the applicant will benefit and others will have to wear the costs of the direct referral and the distinct freezing off of community engagement. 8. Who do you think gains from the different threshold amount approach? Who misses out? The answer to this depends on what the nature of the threshold tests are. Setting the threshold amount 9. For your preferred measure, at what level would you set a single investment threshold amount so that it selects for proposals with significant economic scale at a regional level? This is such a bad test, given the RMA’s purpose that we object to this being the focus. It is not really possible to answer this unless we know whether the discussion is net investment from a broader societal viewpoint, gross private investment or what. 10. How would you adjust the threshold amount to take different location into account? Yes, probably we would, and in particular, we would have a test of irreversibility and severity of divestement or degradation of natural capital, and impacts on the community. 11. How would you adjust the threshold amount to take different proposal types into account? As in 10 Exceptional circumstances 12. Which of the above matters do you agree should be prescribed? If there are additional reasons why those matters should be prescribed, please provide them. We do not understand why the Ministry paper equates “exceptional” with “unforeseen”. There are many things that are exceptional but not unforeseen. The exceptional circumstances are those that are rare and unusual, or which have compelling ethical or cultural or social implications, not unforeseen.
Consultation%20on%20proposed%20changes%20to%20the%20direct%20referral%20consenting%20pathway%20-ECO%20submission-1.docx