This submission is made on behalf of the Taranaki Whanganui Conservation Board (the Board). One of the roles of the Board is to advocate for communities of interest and conservation in general in our rohe/area.

It is disappointing that at none of the more recent Taranaki Whanganui Conservation Board meetings was there an agenda item which provided an opportunity for us to discuss and give feedback on the proposals in a formal manner.

A media release hyperlink was distributed via email to the Board on June 17th 2019 'for our information'. This is not an ideal way to draw busy Board members' attention to a very important subject. Four of our Board members did however attend the Public Consultation on July 26 2019 in New Plymouth. We noted a lack of Iwi representation at that meeting along with a large representation from the local disgruntled fishing industry, with very few pro conservationists.

A significant part of our coastline will be impacted by implementation of the proposed Threat Management Plan. As advocates for conservation, we agree and support in principle that more needs to be done to achieve the vision: 'New Zealand's Hector's and Maui dolphin populations are resilient and thriving throughout their natural range.

To what extent we provide our support for their protection is where we have some concerns; as the impacts to and on our wider communities are unknown.

There are also some questions over the methodology for the population figures and modelling etc, given that the only way to distinguish hectors from Mãui is through DNA testing.

It really does feel like imposing regulations are 'putting the cart before the horse' and the four medium term goals, listed below, reflect this.

1. Ensure known human-caused threats are managed within levels that allow subpopulations to thrive and recover.
2. Engage all New Zealanders in Hectors and Mãui dolphin conservation.
3. Understand how tangata whenua wish to exercise kaitiakitanga of hectors and Mãui dolphin.
4. Improve knowledge of poorly understood threats.

Imposing restrictions before fully understanding, engaging communities and exploring the above goals seems hasty and ill-conceived and one could argue that all of the threats are poorly understood, as per medium term goal four.

We understand that iwi across the region are also preparing submissions on the Threat Management Plan and it is unlikely, given the short timeframes, that iwi will be in a position to share submission points with the Board prior to finalising for filing. We will defer to the relevant iwi to submit on those matters.

Specific points on behalf of the Taranaki Whanganui Conservation Board are set out below. The consultation document sets out that Mãtauranga Mãori will be embedded in any Threat Management Plan, but we note that there has been no engagement with the Crown's Treaty partners in the preparation of the Threat Management Plan (is it all consultation after the fact?);

The Updated Threat Management Plan should be a complete and comprehensive threat management plan which sets out strategies for addressing ALL threats to the Hector and Maui species. The current plan focuses heavily on set net fishing rather than a heavy focus on toxoplasmosis which is the highest cause of death for these species; a plan that states we are going to develop a plan for toxoplasmosis is, quite frankly, not good enough; and investment needs to be made in further research to ensure that we have better information upon which to make decisions.

We are not seeing any significant additional information in these proposals than what was provided five or more years ago when the first plan was developed.