2. Overview of Submissions

2.1 Summary of submitters’ positions

Table 1: Breakdown of submissions, by source

Note: NGO = non-government organisation.

Figure 2: Breakdown of submissions, by source

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This 3-dimensional pie chart illustrates that

For the purpose of this summary, submissions were categorised as:

• standard submissions - broadly defined as brief submissions (less than two pages) and/or single-point submissions, of which there were 52

• complex submissions - submissions touching on multiple parts of the draft standards, of which there were 30.

There is a strong correlation between the submissions of local authorities and complex submissions. Most (but by no means all) individual submissions, on the other hand, are categorised as standard. A similar analysis of correspondence that was sent directly to the Minister for the Environment can be found in section 5.

2.2 Key themes analysis

The key themes analysis was compiled from all submissions and is broken into three parts.

• the position of submitters is outlined in section 2.2.1

• key themes are summarised in section 2.2.2

• detailed points of submissions on sections 3.3 to 3.6 of the discussion document are summarised in section 2.2.3.

2.2.1 Position of submitters

To best reflect the tenor of submissions they are grouped into six categories: opposed, opposed in part, supported, conditionally supported, supported in part and not stated. Due to the nature of many of the submissions, some interpretation was necessary in applying these categories. However, submissions that did not clearly state their position were only attributed a position where this was obvious from the submission’s content and tone.

In particular, it should be noted that conditional support is highly variable, from being conditional on relatively minor matters to relying on very substantive matters (such as a review of NZ2772.1: 1999, or a total rewrite of the standard to have the opposite effect to that proposed). To accurately reflect the level of support for the NES as proposed, submissions that sought changes diametrically opposed to the direction of the proposals have been identified as being in opposition even if the submitter did not themselves refer to either support or opposition.

Identification of a submission as being in ‘support’ does not necessarily mean the submitter did not offer suggestions for improvement, only that the tone of the submission did not suggest that the support was contingent on those suggestions being taken up by the final NES.

Figure 3: Breakdown of submissions, by position

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Where the position of a submission was not obvious (or where the submitter explicitly refrained from stating a view because they believed the case for an NES may not yet be justified), submissions were categorised as ‘not stated’.

Some care needs to be taken in the interpretation of these summary findings. Clearly the difference between ‘supported in part’ and ‘opposed in part’ is open to some debate, but the distinction is intended to reflect the emphasis of the submission. Broadly speaking, submitters were divided roughly evenly between those who opposed the NES and those whose submissions expressed (or implied) support for at least some parts of the NES (with various levels of opposition to selected proposals).

2.2.2 Key themes

The key themes identified during the analysis of submissions are presented in Table 2. For more detail on these themes, see section 3.

Table 2: Key themes: summary

2.2.3 Key themes, sections 3.3–3.6

Key themes derived from specific comments on sections 3.3-3.6 of the proposed NES are summarised in Table 3. For more detail on these themes, see section 4.

Table 3: Summary of key themes, sections 3.3-3.6