Submission from the NZCA on the Natural Environment Bill
13 February 2026: Read the NZCA’s submission on the Natural Environment Bill.

Submission from the NZCA on the Natural Environment Bill

13 February 2026

Opening statement

The NZCA considers the proposal in relation to the proposed clause 128 of the Natural Environment Bill, has been ill thought out, is unclear and rushed. Consultation has been inadequate and undertaken with incomplete information. We are unable to submit on the final version of the Bill as submissions will close before it has been finalised.

We consider the government is being negligent in its approach to developing the Natural Environment Bill, and this will not be in the best interests of the public or conservation.

Observations
  • The proposal lacks clear direction, and is fragmented in the decisions made.
  • There is a lack of detail around Taonga species (amongst other lack of detail).
  • There has been inadequate consultation, and the process has been extremely rushed. Implications have not been thought through.
  • There is a lack of relevant provision to ensure that Treaty partnerships are upheld.
  • This is not evidence-based policy making.
Concerns
  • This provision is not in the best interests of wildlife and a detriment to conservation values.
  • There is a lack of expertise and resource at a local government level to administer wildlife authorisations within a natural resource permit.
  • Costs will be passed on to local authorities with no apparent additional resource intended to be allocated.
  • The lack of consultation requirements of applicants under the Bill.
  • The much overdue review of the Wildlife Act has been put on hold to concentrate on this mahi.
  • That the lack of thinking around the process will not lead to a streamlined process as imagined.
  • Disparities in resourcing of local councils will lead to disparity in decision making.
  • It is not clear if there will be one authority issuing permits for one location, or multiple. There is potential for applicants to ‘shop around’.
  • Decisions have not been based on evidence which will lead to adverse impacts.
  • Moving the provisions under the Wildlife Act to the Natural Environment Bill will compromise the DOC BioInvest, with the data no longer held by DOC.
Recommendations
  • The NZCA cannot support the provision in its current form.
  • We recommend the wildlife provisions, that are currently contained in the Wildlife Act, are taken out of the Natural Environment Bill, and that resource is redirected into a full review of the Wildlife Act (as originally planned).

The NZ Conservation Authority look forward to engaging further with the process of this Bill & believe we can add value to ensuring a Bill is developed that can balance the needs of the NZ environment & users of our whenua. We remain committed to participating in the process & are available to meet for consultation at any stage.