In 1990 and 1991, Salmon was a member of Simon Upton's review group that finalised the definition of sustainable management included in the Resource Management Act 1991.
Upton was educated at Southwell School, St Paul's Collegiate School and the University of Auckland, where he gained degrees in English literature, music and law, and Wolfson College, Oxford, as a Rhodes Scholar.
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The new Minister, Simon Upton, noted the divergent views of submitters on the proposed purpose and principles of the Bill.
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However, the new National Minister for the Environment, Simon Upton, continued the law reform process leading to the enactment of the RMA.