The Legislative Basis for the New Zealand Conservation Authority’s submission

The New Zealand Conservation Authority / Te Pou Atawhai Taiao o Aotearoa (Authority, NZCA) was established under the Conservation Act 1987 (Act), with members appointed by the Minister of Conservation. It is an independent statutory body with a range of functions, but primarily acts as an independent conservation advisor to the Minister and the Director-General of Conservation.

The Authority has a role as an objective advocate on matters of national significance and interest in the conservation arena and to provide high quality independent advice to the Department of Conservation (Department, DOC) on its strategic direction and performance.

The Authority has a range of powers and functions, under the Act, as well as under other conservation related legislation. Under the Act (section 6C(2)(c) refers) the Authority has the power to “advocate the interests of the Authority at any public forum or in any statutory planning process.”

Following the logic of the above powers and functions, the Authority submits on the Predator Free 2050 Strategy Review discussion document, May 2025.

NZCA Submission

On 5 May 2025 Minister Potaka released the Predator Free 2050 Strategy Review discussion document. The discussion document asked for feedback on two areas:

• A set of goals across four focus areas to achieve by 2030, intended to “act as indicators of our progress and direct our efforts”
• A proposal to retain the current national target species list (possums, ship rats, Norway rats, kiore, weasels, stoats and ferrets).

Set of goals to achieve by 2030

There appears to be little change from the three actions set out for 2020-2025 and three of the proposed focus areas to 2030 in the discussion document:

• 2020-2025: Mobilise: Building support for the predator free goal and providing ways for people to be engaged in community action; compared to: To 2030: Mobilise for action: Inspire New Zealanders and empower communities to take action.
• 2020-2025: Innovate: Developing the new and transformational tools and techniques to eradicate predators; compared to: To 2030: Innovate for eradication: Advance tools and techniques to effectively and efficiently eradicate predators in rural, urban and conservation areas.
• 2020-2025: Accelerate: Rolling out PF2050 across the country as fast as possible; compared to: To 2030: Prepare to accelerate: Develop a clear, evidence-based plan to achieve the PF2050 goal that shows the benefits for New Zealand and attracts the funding required to achieve it.

There is one additional 2030 focus area, namely:

• Maintain the gains: Continue essential predator control to create safe spaces for native species and improve biodiversity outcomes.

The NZCA supports these focus areas although there is some concern that they could be interpreted as downgrading the drive for development of tools that are transformational. The acceleration focus area appears to be targeting investment post-2030.

While the proposal to develop an “investment model” to help enlist the support of public, philanthropic and private funders is an important step to achieve the roll-out of predator eradication required across the country, this also appears to be focused on activities beyond 2030.

There is urgency to address the declines in biodiversity brought about by introduced species – and Predator Free 2050 is absolutely central to achieving critical protection for native species. The focus needs to also be on the next 5 years and not just beyond 2030.

While the stated goals appear to be appropriate for the challenging vision of eliminating the target predators from New Zealand, is not clear how feedback on these goals will influence the refreshment of the Strategy, as these focus areas differ very little from the previous action areas.

In addition, the text under the focus areas and each of the goals provides little detail, so it is not clear if there will be changes in focus or emphasis, and it is not clear how these goals will be interpreted, translated into an action plan and implemented.

For example, it is not clear what “supporting and enabling” will mean in practice with respect to iwi/hapū (Goal under Focus area 1). Is this goal sufficiently broad to include kaitiaki at place carried out by marae and owners of whenua Māori?

In the development of the next stages of the Strategy it is critical that there are measurable goals outlined against which progress can be assessed, and the data baselines are also clear e.g. what is the baseline for increasing community participation by 25%? (Focus area 1)?; measurement of significant trends in populations – (Focus Area 2) from what baselines?; “PF2050 has attracted significant investment…” (Focus Area 4). Does the Department know how much investment is needed? How will significance be assessed when overall budget requirements are not clear?.

Target species

The proposal to continue to focus work on eliminating possums, mustelids and rats is important, but in the view of the NZCA, additional work on feral cats, mice and hedgehogs is also justified – particularly feral cats given the damage they are causing, both in terrestrial ecosystems and in the spread of disease to threatened marine mammals.

We acknowledge the very significant financial and technological challenges of taking on additional elimination targets, but consider work on targeting a broader spectrum of pests may in fact be cost effective in the long run in terms of biodiversity protection as well as tool development.

Context and purpose of the discussion document

In the discussion document it is stated "we will consider your input to refresh the PF2050 Strategy (2025–2030), including the refreshed 5-year goals and a target predator list. We are aiming to update the strategy by the end of the year.”

The release of the discussion document in early May was followed by a Budget announcement less than three weeks later on 22 May 2025 that Predator Free 2050 Ltd was being disestablished with its functions to be handed to the Department of Conservation by August.

Predator Free 2050 Ltd (PF2050 Ltd), a Crown-owned, charitable company, was established in 2016 to help deliver the New Zealand government’s ambitious goal of eradicating possums, stoats and rats by the year 2050 - to invest in large landscape scale projects and breakthrough research. For the past decade it has co-funded a range of large-scale predator elimination projects, in addition to working alongside companies in the development of innovative technical solutions for predator control.

Releasing a discussion document ahead of a major change in the way support for Predator Free 2050 is being facilitated, supported, and funded is unusual timing, if the intention is to elicit future-focused submissions. There are many individuals through to organisations engaged in work on PF2050 Ltd projects, businesses and researchers involved in innovation and product development and application, and research teams working on components of PF 2050 Ltd programmes.

Clarity about the Government’s intentions and the release of a discussion document after this significant change was announced would have enabled more informed and appropriate submissions in the context of the new landscape in which this work will be conducted. Inevitably there are questions about the Department’s capacity to deliver and continue the streams of work previously held by PF2050 Ltd that have been key to the mobilisation, innovation, and acceleration action areas.

The NZCA is also concerned that the discussion document is focused on only part of the strategy The original strategy indicated a 5-yearly public process for a Strategy reset. It seems unlikely that this discussion document will achieve the type of engagement needed across the elements of an effective new Strategy. Wide engagement is critical for the relationships that this ambitious programme is absolutely reliant on – across the biosecurity and predator free communities – iwi, community groups, the private sector, and the philanthropic community.

In the transition of PF2050 Ltd to the Department, the NZCA has identified some pressure points and potential risks to the achievement of the Predator Free goals and also to reputation and relationships.

Staff and capacity: The skills and staff required to manage the commercial contracts and the co-funding arrangements with multiple providers and companies in addition to research contracts will require significant staff time. It is not clear to the NZCA that the skills required to administer and manage these contractual arrangements will be able to be conducted more efficiently inside DOC than under PF2050 Ltd.

Relationships across New Zealand: PF2050 Ltd has played a critical role in the development of relationships and communication across a wide network – iwi, community groups, business and philanthropic sectors, linking communities working on predator free projects, sharing knowledge and lessons learnt. These relationships have been built over time – and maintenance and development of relationships will be critical to the success of the transition and will require significant staff time.

Research

The breakthrough science and tools that PF2050 Ltd was charged with developing have made major impacts – ranging from AI-driven detection systems and remote monitoring networks, to smarter traps and more targeted toxin use.

The development of data standards and the best practice guides that PF2050 Ltd has developed are also significant contributions to the predator free landscape.

Tools developed in New Zealand are being picked up internationally – and New Zealand is being recognised as a global leader in innovation for this area of conservation work. However, the funding environment in which this work has been operating has changed significantly with the end of the National Science Challenges, as well as the very significant structural changes to Crown-funded science, and the postponement of MBIE funding through the Endeavour programme.

These changes mean that funding is particularly precarious for the biosecurity sector and especially for work on eradication of possums, rats and mustelids.

The innovation cycle that has developed with PF2050 Ltd and its programme of co-investment has been very productive. The NZCA urges the Department to ensure this is able to be continued and developed further.

Departmental budgets

The NZCA acknowledges the very significant constraints that the Department is facing in terms of budgets and staff. It has been reported that the Department will "absorb the cost of managing the company's projects and contracts within its baseline", and that the remaining Crown funds ($2.3 million) that had been allocated to PF2050 Ltd would be “transferred to DOC and continue to be invested in predator free projects and contracts to avoid disruption”.

It has also been reported that the intention of closing the company “would remove any duplication of work, make the programme more efficient and provide better value for money”.

The Predator Free 2050 vision requires long-term thinking and planning – and the capacity to work on time frames beyond annual budget cycles. The NZCA looks forward to seeing how these savings will be applied to the work required to meet the vision.

Further comments

The Authority recognises the need for there to be better integration between regional pest management strategies and Predator Free 2050, so that regional pest management strategies amplify the work of Predator Free 2050.

The Authority also notes that it is important that recreational hunter-centred management of ungulate pests does not hinder the ability of the Department to deliver landscape scale control of predators. Policy and operational work to manage ungulate pests should safeguard landscape scale control of predators.

Managing predators is crucial to meet national and international biodiversity targets and NZCA supports the Department in its work to meet the vision of Predator Free 2050 and will be following with interest the transition to the new arrangements within the Department.