
Environment Canterbury's Chair Rebuffs Government's Directive To Stop Planning
Environment Canterbury (ECan) chairperson Craig Pauling said the work of local government still needs to continue.
''At ECan we've already been impacted by stops to planning and I am personally disappointed some good things in our Regional Policy Statement, which would have made a difference, can't happen.''
The policy statements provide an overview of resource management issues in a region.
Resource Management Act (RMA) Reform Minister Chris Bishop this week announced the government would halt changes to district and regional plans.
It comes ahead of a shake-up of the RMA, which is expected to come into effect in 2027.
Pauling made his comments during a panel discussion at the Local Government NZ conference on Thursday, July 17.
''I would encourage you not to stop the planning. Don't stop thinking. You've got to do the analysis.
''Keep the thinking going, so when things do land you are in the best position.''
ECan voted in November to put its RPS on hold until January 2026, while it awaits more certainty with RMA reform.
It has been unable to adopt a plan change to fix issues in the Canterbury Land and Water Regional Plan, following a Supreme Court decision on a water bottling plant in Christchurch in 2023.
The future makeup of councils
There has been speculation the RMA reform could lead to regional councils being scrapped, but both Bishop and Deputy Prime Minister David Seymour said no decision had been made.
Bishop, who met with regional council chairs during the conference, indicated an announcement was likely by the end of the year.
Pauling said it made sense to consider the shape of local government alongside the RMA reform, as regional councils came into being in 1989, in anticipation of the RMA, which was enacted in 1991.
He admitted there were flaws with the present model, as local and regional councils didn't always work together.
''My personal view is separating land-use between city and regional councils was wrong. We've had so many occasions when land-use has been consented non-notified and then it needs water table allocations (from the regional council).''
LGNZ passed a remit at its annual general meeting calling for a review of local government functions and governance arrangements.
Its chief executive Susan Freeman-Greene said local government needed to be proactive and lead the changes required.
Under existing legislation there are only two alternatives for regional government - regional councils and unitary authorities.
Speaking to Local Democracy Reporting, Pauling said more options were needed, as different regions had different challenges.
Canterbury is much larger than other regions, has more braided rivers and catchments, a centrally located population and sparsely populated districts such as Kaikōura, Hurunui, Mackenzie and Waimate.
''We need to be having the conversation and asking the questions. Would Kaikōura and Waimate survive as unitary authorities?''
Splitting the region into three - North, Mid and South Canterbury has been mooted - but Pauling thinks it would be ''problematic''.
South Canterbury would likely be the largest unitary authority in the country in terms of geography, but with a population of only 60,000.
The Hurunui district alone is the same size as Taranaki and half the size of Auckland, but with a much smaller population.
A Christchurch or Greater Christchurch unitary authority has also been mooted, but questions have been raised about whether the rest of Canterbury would have a sufficient ratepayer base to manage regional council functions.
Pauling said he believed it would be ''unworkable''.
Another option, which ECan councillors considered at a recent workshop, was a Canterbury or South Island Assembly.
This was based on the Greater Manchester model, where the existing local councils could continue and the mayors or council representatives and Mana Whenua representatives could form an assembly to make regional decisions.
Whatever is decided, Pauling said local communities need to be involved in the decision making ''or it wouldn't fly''.
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NZ Herald
37 minutes ago
- NZ Herald
Tall towers versus volcanic views: The building blocks in Auckland's development
The Minister Responsible for RMA Reform, Chris Bishop, thinks viewshafts 'eviscerate hundreds of millions of dollars of economic value', as he put it in a speech in mid-June. In other speeches in recent months, Bishop has quoted a 2018 study which suggested the toll-booth viewshaft has cost the central city in excess of $1.4 billion. So he's decided to do something about it. Others say, hang on. 'Most cities,' North Shore ward councillor Chris Darby says, 'have few really unique features. But we do. We have the volcanoes. Being able to appreciate them as you move around the city is one of the special things about living here.' Darby's view is probably shared by most of his colleagues. Over the Super City's 15-year history, Auckland Council has shown no interest in making any significant changes to the viewshafts. Bishop points out that in 2016, the council was told quite bluntly by an Independent Hearings Panel (IHP) that it should rethink its approach in order to achieve greater economic efficiency and reduced opportunity costs. That panel had reviewed the viewshaft proposals in the council's draft Auckland Unitary Plan, the big new document that was about to become the city's blueprint for what can be built where. For the most part, it didn't want them eliminated. But it did point out that the council had done 'no sensitivity analysis'. That is, despite having the necessary technology, it had not looked at whether even 'slight changes' might 'significantly reduce [the viewshafts'] impact on development opportunities while retaining views to the maunga [peak]'. Nor did it have a method for deciding if any loss in floor area of new buildings was 'an appropriate trade-off for the values of any particular viewshaft'. 'In the almost-decade since,' Bishop said in a speech in February, 'this work has not been progressed.' The Government has now told the council it must produce a new zoning plan which allows for greater density, and it must be done, with public consultation, by October 10. That's two days before postal voting closes in this year's council elections. The council is expected to consider its position at a meeting on July 31 – and a fight is brewing. There are nearly 80 viewshafts in Auckland. They're mapped like slices of pie: wedges that emanate from a single point where a person can stand, like the top of Newton Rd, or from a stretch of road you can drive along, like the northern approach to the bridge. Building heights are strictly limited inside the boundaries of each wedge, so the view of the natural landscape is preserved, and this creates an overlay on the planning zones. As a rule, buildings inside a viewshaft require a resource consent and if they are to be higher than 9m they may be regarded as 'non-complying'. In this context, it is extremely difficult for such buildings to get a resource consent. Most viewshafts have been in place since 1977, after the Pines apartment block was built on the side of Maungawhau (Mt Eden) in 1969, causing a public outcry and changes to planning rules. The outcry over The Pines, a multi-storey apartment block on Mt Eden, led to the protection of volcanic views. Photo / APN Not that views of Maungawhau have been completely preserved since then: the Department of Corrections was allowed to build a bigger Mt Eden Prison, interrupting the viewshaft from the motorway that runs past it. Much of the attention still focuses on the views of that maunga, which isn't surprising: the nearby central city is where most high-rise development occurs. In fact, Maungawhau is protected by 20 viewshafts, including one from Devonport and one from the Z petrol station on Kepa Rd in Ōrākei. But views of Te Pane o Mataoho (Māngere Mountain), Puketāpapa (Mt Roskill) and the other cones are protected too. And it's not just the cones: views of the Waitākere Ranges and some other ridgelines are also protected, along with views of the Auckland War Memorial Museum. The rules have had a dramatic effect on the city centre. The Sky Tower and the council building on Albert St are just outside the eastern edge of the toll-booth viewshaft, which is known as E10. There's another viewshaft protecting the view of Maungawhau from the bridge itself, called E16. It roughly parallels E10. If you look at the city centre from the north, across the harbour, you can see the effect plainly: east of the Sky Tower, the city is built up. But west of the tower, the level suddenly drops. The Viaduct, Wynyard Quarter, around Victoria Park and up to the new International Convention Centre on Hobson St are all part of the central city. But there are no tall buildings. Constructing high-rise buildings on all this land is prevented by E10 and E16. Bishop thinks the toll-booth viewshaft is especially absurd. Drivers on a motorway are supposed to keep their eyes on the road. But councillor Richard Hills, the chair of the council's policy and planning committee, says: '50% of morning commuters going over the bridge are in a bus, enjoying the view.' Even some of the cars have passengers. 'Tollbooth' view of Maungawhau/Mt Eden, 1962 Toll booths on the northern approach to the Auckland Harbour Bridge in 1962, showing Maungawhau/Mt Eden in the background. The protected viewshaft applies to the stretch with the toll booths. But if it was moved slightly west, to align with the stretch pointing straight at the maunga, more central city would be freed up for high rises. Photo / Whites Aviation 'Tollbooth' view of Maungawhau/Mt Eden, today The same view today, showing high rises east of the Sky Tower but not to the west, with Maungawhau clearly visible. Photo / Jason Dorday The minister rests his argument against viewshafts on the economic advantages that come with housing and workplace density, especially near major transit stations and along transit corridors. 'In a well-functioning city,' Bishop told his Committee for Auckland audience, 'a floor filled with smart people working next to each other, in a building filled with floors of smart people working next to each other, unsurprisingly, enables greater economic opportunities for productive growth. Proximity encourages collaboration and innovation.' That's on top of the more obvious benefits of having lots of people living and working near train stations and rapid bus stations. More people equals better transit services, because there are more passengers to pay for them. And that takes traffic off the roads. Having lots of people living closer to town also makes their commute shorter, which also takes traffic off the roads. This has become critical in Bishop's thinking about the City Rail Link (CRL), which will open next year, doubling the capacity of Auckland's rail network. 'The City Rail Link is a game-changing investment in the future of Auckland,' he said on June 25. 'It will unlock significant economic opportunity, but only if we have a planning system to allow businesses and residents to take advantage of it.' Chris Bishop: the minister who wants to change Auckland's volcanic viewshafts. Photo / Getty Images Because of this, Bishop used that February speech to call for zoning in Auckland to abandon the six-storey limit around major transit stops, which defines the height of most apartment blocks. That will impact E10, E16, the Newton Rd view (E20) and several other viewshafts. 'We are going to need to go much, much higher than that around the CRL stations if we truly want to feel the benefits of transit-oriented development,' he said. 'My aspiration is that in 10 to 20 years' time, we have 10- to 20-storey apartment blocks dotting the rail line as far west as Swanson and Rānui.' You can see the prototype now, in the form of the 10-storey Westlight Apartments in Glen Eden. The Westlight apartments in Glen Eden tower over the surrounding suburb. Why is there no Westlight in Kingsland, which has a train station and several bus routes? Partly, it's because of the protected views of nearby Maungawhau. It's also partly because of a 'special character' overlay, put there by the council, which preserves older housing areas. Bishop threw down the gauntlet: 'How about if our aim is to make the 'special character' of suburbs be that they are thriving, liveable, affordable communities with access to regular and reliable public transport?' In May, the council adopted new zoning rules for the central city. They allow for more density, but they leave large parts restricted to six-storey heights. The minister's gauntlet was left lying on the ground. He responded quickly. 'The Auckland CBD plan could go a lot further, in my view. It is a real missed opportunity and in due course, the council is going to have to have another look at it, particularly around the viewshafts.' On June 25, Bishop and the Minister for Auckland, Simeon Brown, pulled out their swords. They jointly announced they will legislate to require upzoning for buildings of 'at least 15 storeys' in the 'walkable catchments' around the Maungawhau, Kingsland and Morningside stations and at least 10 storeys near Mt Albert and Baldwin Avenue stations. Fifteen-storey buildings are about 50m tall. Walkable catchments extend in a radius of about 800m, which is taken as the distance of a 10-minute walk. The walkable catchment for the Maungawhau station includes the New North Rd ridge, whose current medium-rise buildings are capped to maintain the viewshaft from Newton Rd, which is known as E20. Bishop's 15-storey ambition would almost certainly spell an end to E20 and could well mean the same for E10, E16 and other Maungawhau viewshafts. The minister says he doesn't want to eliminate viewshafts. But what does he want? The signals are mixed. 'Even just minor tweaks to existing viewshafts could materially lift development opportunities,' Bishop said in February. 'The 2018 study showed that rotating the E10 viewshaft just 4.5 degrees to the left maintains the view of Mt Eden for a similar amount of time, whilst saving the city 43% of the lost development opportunity cost.' By 'to the left' he means to the west. Views of Maungawhau would be preserved not from the northern approach to the bridge, almost back to Onewa Rd, but from the stretch of highway closer to the bridge, when the maunga is more in front of you. The 4.5 degree adjustment would free up significant parcels of land for high rises. These include some of the Wynyard Quarter and the Viaduct, the Fanshawe/Victoria streets block at the bottom of Nelson St, the TVNZ and Convention Centre block on Hobson St, and the block bordered by Queen St, Karangahape Rd and Symonds St. It also includes the northern half of Wynyard Point, if the council was ever to decide a sentinel waterfront tower should be built there. But that's all within what Bishop calls 'minor tweaks'. His talk of 'economic evisceration', the 'immense' economic and social rewards on offer and new 15-storey and 10-storey buildings near stations all suggest he has more sweeping changes in mind. In August last year, he told the Herald the biggest barrier to building on the Maungawhau station site was viewshafts. And yet, when the Herald asked him directly what he wants – how his hopes for all those tall buildings relate to viewshafts – he replied with a carefully worded written response. 'The bill will provide for a qualifying matters framework which will enable Auckland Council to modify these heights [15 storeys and 10 storeys] to the extent necessary to accommodate a qualifying matter (such as the protection of viewshafts) if this level of development is inappropriate. 'However, any lower heights would need to be justified in accordance with the framework. I intend to use my Direction on the new plan change to reinforce the legislative requirement that heights and densities may only be reduced to the extent necessary to accommodate one or more qualifying matters.' This seems to mean there will be more high rises, but viewshafts could become qualifying matters that limit their extent. To some degree. The debate has ever been thus. Density is easy: almost everyone says it's a good thing, provided it's done in the right places and in the right way. But defining the wrong places and ways, known in the legal language of town planning as 'qualifying matters', is a process that defeats even the most optimistic attempts at consensus. Character Coalition chair Sally Hughes. Photo / Alex Burton Sally Hughes of the Character Coalition, an umbrella group dedicated to preserving the character of the villa suburbs, says changes to viewshafts, special character or other zoning laws are not required because there are 'plenty of under-utilised sites' near the Kingsland and Maungawhau stations 'which are ready for intensification now'. Who doesn't think, when it's their own street, their own view, their own sun at stake: don't do it here, do it somewhere over there? The source of Bishop's thinking on viewshafts is a 2018 paper called City with a Billion Dollar View, written by Geoff Cooper, a former economist with PwC and Auckland Council. It was Cooper who came up with the toll-booth anomaly, the benefits of tweaking E10 by 4.5 degrees and that $1.4b figure for lost economic opportunity. Cooper is now the chief executive of the crown agency Te Waihana: the Infrastructure Commission and, at least informally, has the ear of the minister. Geoff Cooper, author of the report that got the minister thinking. As for Cooper's old employer, Auckland Council, it does not subscribe to his analysis of the economic damage done by viewshafts. The Herald talked to the council's manager of central area planning, John Duguid, about all this in May. Duguid said he doesn't see the need for higher buildings in the E10 viewshaft. 'East of E10,' he said, referring to the parts of the central city already built up, 'there's still a lot of development potential.' Duguid also said the toll-booth story is a myth: E10 has never been just for drivers queueing at the booths. Auckland Council planning boss John Duguid. Photo / Dean Purcell He thinks if it does need to be changed, 'it could be narrowed a bit'. If you squint, that sounds a bit like the minister's 'tweaks'. Even Cooper said something similar in 2018: he called for changes that would 'provide a middle path for city planners that reduce the cost, while preserving views'. But Duguid and the council seem largely intent on preserving the status quo and the minister wants change. The council, Bishop says, has been 'dragging its feet'. Let's back up a little. First, to note that the 14 prominent volcanic maunga of Tāmaki Makaurau are governed by the Tūpuna Maunga Authority, which comprises equal membership from Ngā Mana Whenua o Tāmaki Makaurau and Auckland Council. The Government will need a strong relationship with the authority, Ngāti Whātua Ōrākei and the other relevant iwi, if it wants to change the way we value, see and use the maunga of Tāmaki Makaurau. Second, to note the wider planning context. When the Auckland Unitary Plan (AUP) was adopted in 2016, it preserved the viewshafts while also allowing for the 'character areas' Bishop is annoyed about. This provision has been used to protect the villas of the city fringe: the ring of suburbs that runs from Devonport across the harbour to St Mary's Bay, Ponsonby, Grey Lynn, Mt Eden and Parnell. In 2020, the Labour-led Government's National Policy Statement on Urban Development (NPS-UD) required councils in the larger centres to change their district plans (in Auckland's case, the Unitary Plan), in order to provide for more substantial housing growth than most had been willing to accept. This was followed by new Medium Density Residential Standards (MDRS) in 2021 and a revision to the NPS-UD in 2022. All were aimed at achieving greater density. In Auckland, the council responded by drawing up Plan Change 78 (PC78) and putting it on a slow track to approval. Most councils have now made their plan changes, but Auckland Council has completed PC78 only in respect of the central city, despite closing public submissions nearly three years ago. PC78 (Central City Zone) contains higher limits for development in some areas, but there is no rethink of the viewshafts or the six-storey limit more widely. This was largely supported in submissions from the public. Bishop is clearly frustrated. The minister speaks positively of the NPS-UD and says he will build on it, not abandon it. His Resource Management (Consenting and Other System Changes) Amendment Bill, which will speed up urban density, is back from select committee hearings and due to become law next month. In relation to the bill, Duguid says: 'Our working assumption is that applying 'qualifying matters', including maunga viewshafts, will still be an option, albeit with more onerous requirements to justify them.' On the other hand, Bishop wants those 15-storey buildings near Maungawhau, Kingsland and Morningside stations. The new Maungawhau railway station is the patterned building in the middle distance. Six railway lines run through tunnels under here, and now the enormous empty site is ready for intense developed over the next decade or two. How tall should the buildings be? Maungawhau mountain is away to the left. Photo / Sylvie Whinray And he has told the council: 'The Government is also considering whether further amendments to the bill to fully maximise development opportunities around other CRL stations are necessary, and I will have more to say in due course.' That is, station precincts on the Western Line won't be the only ones to get new height allowances. Ōrākei, Meadowbank and Glen Innes on the Eastern Line and Newmarket, Remuera, Greenlane and Ellerslie on the Southern Line are all no further away from the city centre than the Western Line's Mt Albert. Duguid and his staff have been busy preparing options for a council response to Bishop's pronouncements, for debate by the governing body of council on July 31. Defenders of the viewshafts have taken a persuasive lead role for many decades in the planning and consultation processes of Auckland Council and its predecessors. Prominent among them have been the Auckland Volcanic Cones Society and the Friends of Maungawhau. Roy Turner of the Volcanic Cones Society was the planner charged by the Auckland Regional Council with writing the original 1976 report on viewshafts. In March, he told the Herald that he likes 'most of what Chris Bishop is advocating, but with the cones issue, some of his justification is misguided'. Turner suggests we think about it this way. 'There is a massive area of open space in central Auckland called the Auckland Domain. An economist might calculate how many billions of dollars have been lost by not developing here. The public would respond by saying this is truly an Auckland icon: hands off, no way can we develop here. 'Quite right, but can't we have our cake and eat it too? Let's just take 10%. A few years down the track, on balance, let's take another 10%, for the same reason, and so on.' Others see it differently. At Greater Auckland, Scott Caldwell has attempted to distinguish between 'the good, the bad, the ugly' and the 'bit ridiculous'. Some viewshafts are blocked by trees, others emanate from places almost no one ever goes. Better to keep the trees and the views that really are valued? Caldwell's not against all viewshafts. Maungawhau as seen from Mt Eden Village, he says, looms above the street magnificently. He'd definitely keep that one. And he has a proposal. He points out that Instagram is full of maunga photos, but they're not of the maunga. Instead, they're nearly all taken by people standing on the mountain and looking at the view from it. These are the views we really value, he says, so they're the ones we should protect. Scott Caldwell suggests the more valuable views are from the maunga. This is a viewing platform on Maungawhau, looking across North Head to Rangitoto. Photo / Alex Burton If the Government changes the viewshaft rules in favour of economic growth, affordable housing, optimal use of transit or some other purpose, how big will the benefits be? We don't know the answer to that, but last month Bishop told the Herald he has instructed officials to find out. They're looking at 'the impact of Auckland's viewshafts on development capacity and economic activity across Auckland'. He added: 'I acknowledge there are also benefits, including to mana whenua, which are difficult to quantify.' Bishop wants the work done this year, although it will probably not meet the October 10 deadline for Auckland's new plan change. But, he said, 'it will help to provide a good evidence base for future plan development as part of the new resource management system'. That all looks like a message for the council: the work you could have done, and should have done, according to the Independent Hearings Panel in 2016, is now being done by the Government. If the council won't address the challenges and opportunities for growth and housing in Auckland, the Government will. If you don't build it, we will come. And we will do it for you. Simon Wilson is an award-winning senior writer covering politics, the climate crisis, transport, housing, urban design and social issues, with a focus on Auckland. He joined the Herald in 2018.


Scoop
17 hours ago
- Scoop
EDS Submissions Highlight Serious Concerns Over Government's Resource Management Changes
The Environmental Defence Society (EDS) has today filed its very extensive submissions on the Government's review of national direction under the Resource Management Act 1991 (RMA). The proposals, which are spread across three packages of Infrastructure and Development, Primary Sector and Freshwater, present an overwhelming shift towards prioritising use and development at the expense of the natural environment. National direction is the 'engine room' of the RMA. Regional policy statements and regional and district plans must 'give effect' to it and decision-makers on resource consent applications must 'have regard' to it. It therefore has significant ramifications for resource management decision-making. 'Taken together, the changes set out pose a significant risk to indigenous biodiversity, freshwater, wetlands, elite soils and the coastal marine environment. They will result in more inappropriate and environmentally damaging activities occurring in New Zealand's most sensitive places,' says EDS Chief Operating Officer and lawyer, Shay Schlaepfer. 'The environment is not in a healthy state. Monitoring shows ongoing declines in freshwater quality, more threatened and at risk species, a reduction in food producing land, continued loss of remaining wetlands and a marine environment under threat. 'The proposals are wilfully ignorant of that context. They are being pushed through under a 'growth at all costs' mentality that will result in more pollution for longer and more destruction of nature. This is not what the RMA provides for. 'EDS's key concerns with the proposals are: 1. Forestry review too narrow: The proposed changes fail to address systemic issues with forestry regulations which are resulting in extensive and damaging slash and sedimentation mobilisation events with corresponding devastating impacts on receiving environments and communities. 2. Infrastructure proposal lacks environmental considerations: The Government's expansive vision for infrastructure and development comes with no corresponding focus on protecting the natural environment. 3. Increased mining and quarrying in sensitive areas: The proposed changes will facilitate more mining and quarrying activities, directly threatening New Zealand's indigenous biodiversity, vulnerable wetlands and highly productive land. 4. Freshwater management at risk: The proposed changes would unwind decades of freshwater management progress, undermining hard-won legal protections in favour of short-term economic interests. 5. Natural hazards not taken seriously: A gaping hole in the proposals is any regulation to stop building in high hazards areas. If New Zealand is to get real about climate adaptation it needs to prioritise not making the situation worse in the first place. 'The review of national direction is being undertaken before replacement resource management laws are enacted in 'phase 3' of the Government's programme of RMA reform. Progressing substantial national direction review under a regime that is to be replaced, and then implementing those new instruments in a new regime which Ministers describe as being radically different, is a confusing, unstructured and backwards approach. 'This has been exacerbated by Minister Bishop's recent 'plan stop' announcement which has compounded uncertainty about how the package of national direction changes will be implemented. The Government needs to stop rushing and progress resource management reform on a more strategic, coherent footing. 'Most importantly, Government needs to acknowledge that economic growth and good environmental outcomes are both achievable. EDS's submissions propose changes to the policy settings which would bring the instruments into a more acceptable and lawful outcome,' concluded Ms Schlaepfer. Environmental Defence Society EDS speaks for the environment. It has influence. Since 1971, EDS has been driving environmental protection in Aotearoa New Zealand through law and policy change. That's why it's one of this country's most influential non- profit organisations when it comes to achieving better environmental outcomes. EDS has expertise in key disciplines including law, planning, landscape and science. It operates as a policy think-tank, a litigation advocate, and a collaborator – bringing together the private and public sectors for constructive engagement. EDS runs conferences and seminars on topical issues, including an annual Environmental Summit and the Climate Change and Business Conference. EDS is a registered charity and donations to it are tax-deductible.


Otago Daily Times
a day ago
- Otago Daily Times
‘Enduring' solutions important, councillors say
The Otago Regional Council building on the corner of Broadway and MacLaggan st. PHOTO: ODT FILES Resource management reform should produce "enduring, consistent and stable" solutions, Otago regional councillors say. The Otago Regional Council this week approved wide-ranging submissions on infrastructure and development, the primary sector, and freshwater management ahead of government reforms of the Resource Management Act and the national policy statements and standards that sit under it. Cr Tim Mepham said he was hopeful the council submissions would help to shape the new national directions. "But I definitely have concerns for our environmental management and the future of our freshwater quality. "I'm pretty happy with the comments that have been made in the submission in regards to the need for cross-party agreement because with the political cycles, to-ing and fro-ing, it doesn't create a lot of certainty." Cr Alan Somerville agreed. "Finding some enduring, consistent and stable solution to all this, so there aren't always changes, is very, very important," he said. The submissions demonstrated the value of local government and bringing together a diverse set of views around the council table, chairwoman Cr Gretchen Robertson said. "We listen to each other, just as we have again today and generally, we do come up with solutions that we all agree with — sometimes we don't, though, and that's fine as well." As well as the direct points the submissions made, the submissions made a "broader point" about the value the regional council provided "in partnership with central government and with mana whenua and with our communities", she said. The council submission on infrastructure and development national directions said infrastructure "in particular" needed a stable regulatory environment to drive investment. However, the submission on the primary sector also addressed the "need for enduring solutions". "Without broad political support for the proposals, there is a risk that future governments will reverse this reform, undermining the commitment of communities, industries, agencies and local authorities to plan their future and buy into actions that achieve the desired outcomes." The council supported moves "to better enable quarrying and mining". Its submission on commercial forestry had been drawn up with community concerns in mind, it said. "ORC is aware of the concerns that exist within Otago's communities about the conversion of large tracts of pastoral farmland into commercial forestry and how this may affect Otago's rural communities." The council submission on freshwater management said "three large overhauls" of freshwater policy — in 2014, 2017 and 2020 — "put considerable financial strain on councils and ratepayers and have disrupted planned or ongoing initiatives". The council also said it did not have a consensus view on whether the controversial concept of Te Mana o te Wai should be retained as the fundamental concept underpinning the national direction for freshwater. The council decided to finalise its submission on "going for housing growth" — a reform package designed to free up land for development and remove planning barriers — after staff had spoken to Otago's district and city councils.