Making submissions on the NBA exposure draft is difficult in the abstract, and the right to make further submissions on the full text of the Bill (and related legislation) when introduced into Parliament is reserved. For the reasons given below, the NBA exposure draft does not (as currently drafted) achieve the objectives set out in the terms of reference for the Parliamentary inquiry. Some suggested amendments to the NBA exposure draft are made in this submission. While the terms of reference for the Parliamentary inquiry do not include the counterfactual of amending the Resource Management Act 1991 (RMA) to achieve the stated objectives, an informed and critical appraisal of this approach was covered by Simon Upton in his RMLA Salmon Lecture 2020.1