Making a submission

When someone wants to do something that has an effect on the environment, or directly affects you, there can be an opportunity for you to make a submission on the resource consent application.

This happens when a consent application is publicly notified, or if you are among those served notice of a limited-notified consent application.

Your submission needs to identify what effect the proposed activity will have on you, and what you think the decision on the application should be.

Fill out all the required information including:

  • The parts of the application your submission relates to.
  • Whether you support or oppose specific parts of the application.
  • If there is any specific information you think should be considered when the decision is being made (particularly if you don’t clearly support or oppose the application).
  • Why you are making a submission (eg, you may support or oppose the application, or you may be neutral, but think that additional information needs to be considered).
  • Whether you think the application should be granted or declined.
  • What conditions you would like to see on the resource consent if it is granted.
  • Whether you would want to speak at a public hearing.
  • Whether you would consider presenting a joint case at a hearing with others who have made similar submissions.

Make sure you state in your submission if you want to speak at a hearing. You don’t have to, and while speaking at a hearing can help to highlight what you said in your submission, your submission is just as valid if you don’t speak. But if you don’t want to be heard, and no one else does, a hearing may not be held.

Send a copy of your submission to the applicant.

A well-written submission has two key elements: the relevant content and a readable style.

Remember that the RMA is concerned with managing and protecting the environment Focus on what you see as the positive or negative environmental effects of the activity needing resource consent. You can focus on the application as a whole, or on a particular part of it.

Clearly state your concerns about any environmental effects, and how you want these concerns to be addressed.

In a submission you should also:

  • Remember that if you speak at a hearing, you’ll only be able to talk about issues that you included in your written submission, so make sure you include everything you might want to speak about.
  • Clearly state any conditions you want the council to attach to a resource consent if it is granted.
  • Point out any environmental effects you feel the application doesn’t adequately identify (eg, remember your local knowledge might add to the council’s understanding of the possible effects of the activity)
  • Where appropriate, include maps, diagrams, and professional opinions that support your submission.

Make it clear and easy to read. Planning your submission carefully makes it a lot easier to write and for the council and applicant to understand the points you are making. Unclear and confused writing is often the result of the writer not thinking carefully first.

Create an outline of the points you want to make before you start to write. Decide what point you will make in each paragraph, and the order you will put them in. Write short sentences and short paragraphs. Stick to one point per paragraph. Use lists with bullet points to break up long sentences and make a number of related points. Use simple, everyday words. Type out your submission if possible, and number the paragraphs.

Make sure that your submission does not:

  • Include any personal feelings you have about the applicant.
  • Refer to previous applications made by the applicant, or any other development that is not related to this application.
  • Raise the issue of the commercial success of your business being affected by the establishment of a competitor in your area. This is not a valid environmental concern and your submission may not be accepted. However, you can raise the issue of your ability to operate a business being reduced by a direct environmental effect from the proposed activity (such as exposure to noise, dust or smell), if these issues are relevant and they do not relate to trade competition.