Good writing needs good planning. A clear, well-written submission is more effective than an unstructured one.
As a submitter you can:
- support or oppose a proposal
- be neutral (with supporting information)
- request to be heard in support of your submission.
An effective submission will state what effects you think the proposal will have, and why you support or oppose the proposal. If you would like to see changes to the proposal, you can suggest alternatives.
The council will consider different values expressed by submitters, and providing facts supported by evidence will help you build a strong case.
- If you support the proposal in full, or if there are particular aspects you support, say so.
- Clearly state any issues you might have about possible environmental effects, and how you would like these to be addressed.
- If you think that a proposed plan or plan change’s objectives, policies or rules should be changed, specify why and in what way.
- If you think a resource consent or notice of requirement proposal could go ahead with certain conditions to manage specific environmental effects, state what you think the conditions should be and why.
- If you think the effects of a proposal are so serious that it should not go ahead, state what you think these effects are and why.
- Include any maps, diagrams and professional opinions that support your submission.
Make sure that your submission does not:
- include any personal feelings you have about the council or its officers
- refer to issues or effects that are not related to the proposal you are submitting submit on
- raise matters that are not within the council’s control
- raise the issue of your business being affected by a competitor. Trade competition is not a valid issue for consideration under the RMA (see below).
Make sure that your submission does not 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. In a worst case scenario, there may be legal issues and costs (including damages for loss suffered) if it is proven in court that you have lodged a submission purely on commercial grounds. 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.
Submissions that are frivolous, vexatious or offensive can be struck out by the council or hearing panel. If you are quoting independent experts, make sure they really are independent and have the expertise to give evidence, or your submission could be struck out.
To write a clear and effective submission:
- stick to the facts – don’t get distracted by personal issues or past disputes
- focus on the environmental effects
- be specific about your concerns, and give examples
- tell the council what you want them to do – don’t leave them to guess
- write in clear, everyday language.
Sometimes the council or hearing panel may appoint an independent advisor known as a ‘friend of submitter’ to help submitters. The council or friend of submitter can help explain the process, advise you on lodging your submission, how to express your views, and what to do after lodging your submission. However, it is up to you to decide whether or not to make a submission, or what to include in it.
- Complete a submission form from your council offices or council website or the Ministry for the Environment website.
- Make sure you state in your submission if you want to speak at a hearing. You don’t have to and, although it can help to highlight what you write in your submission, your submission is just as valid if you don’t speak.
- Send your submission by email, post, hand delivery, or lodge through the council’s website (if available) before the closing date and time.
- Try to send your submission well before the closing date and time. If you send it by post, do so a few days before the deadline, and check that it has arrived in time.
- Send a copy of your submission to the applicant (if it is about a resource consent application).
- The council’s website should set out deadlines for making submissions.
Tips for writing a submission
© Ministry for the Environment