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 Action for Nature – Implementing New Zealand’s Biodiversity Strategy 2025-2030 Discussion Document, May 2025.

NZCA Submission

In early May 2025 Minister Potaka released the Discussion Document “Action for Nature – Implementing New Zealand’s Biodiversity Strategy 2025-2030” seeking feedback on proposed critical actions for the next implementation plan for the Biodiversity Strategy.

The proposed actions sit within four themes – in each case the Discussion document asks: What do you think of this action? Is there anything you would add or change?

Theme 1: Agreed biodiversity priorities are driving investment and action

• Develop a national picture of our most important biodiversity values and quantify the costs to protect and restore priority species and habitats.

It is not clear (a) how the “most important biodiversity values” and “priority species and habitats” will be identified, (b) whether this will result in a largely terrestrial focus and overlook freshwater and marine species and habitats at risk, and (c) whether the focus will be prioritising species and habitats on public conservation lands, or whether in the process of building this national picture, biodiversity on private and Māori land will also be considered.

NZCA also notes that while targeting species and habitats is very important, in a number of situations integrated ecosystem approaches may result in more effective management outcomes for biodiversity protection.

• Tackle biodiversity loss by agreeing on priority programmes to:

a. protect and restore high-priority degraded habitats (e.g. impacts from browsers, weeds, predators)

b. recover native species

c. develop nature-based solutions for biodiversity and climate change (e.g. wetland restoration), in light of environmental and climate change responsibilities.

In reference to items a & b, while restoration and recovery are important priorities we need to prevent more habitats from becoming degraded. All instruments of government policy need to have the focus on preventing further damage. It is particularly important that there is oversight to make sure that unique habitats are not degraded and biodiversity protection is enshrined in the rapid and significant changes that are being made to a range of legislation and regulatory instruments at present (e.g., resource management, conservation, biosecurity, Fish and Game, Fast Track).

Loss of species, as well as destruction of habitats and ecosystems is happening now, and will probably ramp-up under Fast Track projects. It is important that New Zealand has systems in place to reduce the losses to a minimum.

While later in the Discussion Document there is brief mention of nature-based solutions, there is insufficient detail provided about the approaches planned to develop the nature-based solutions to provide informed comments.

Theme 2: Increased external funding, revenue and support are delivering more work on biodiversity priorities for biodiversity

• Develop a biodiversity investment prospectus to attract and direct external investment into biodiversity priorities.
• Generate new revenue from public conservation lands and waters to invest back into biodiversity.
• Increase private investment in biodiversity by supporting business sector demand and system integrity: including private sector nature-based financial disclosures, reporting and investment.
• Increase the protection of biodiversity on private and Māori land by improving the accessibility and coordination of government support and incentives.

There is insufficient detail provided to fully understand what is intended by these critical actions.

It is very clear that there is insufficient funding for biodiversity protection in New Zealand at present. While attracting investment from sources other than local and central government offers opportunities for biodiversity protection, fundamentally the priorities for biodiversity and the appropriate levels of support need to be driven by government on behalf of all New Zealanders.

Theme 3: An evidence and knowledge-based approach is driving improvements in practice and decisions making for biodiversity

• Agree and implement an achievable set of priority indicators for monitoring progress on national targets, monitoring the effectiveness of interventions, and meeting statutory and international reporting requirements.

It is not clear how the term “achievable” will be applied with respect to the indicators selected – there is concern that this could be reduced to the lowest common denominator based on the current declining budgets available for conservation.

• Support Māori to use knowledge systems, including mātauranga, in decision making and biodiversity management.

While we see this critical action as crucial for future management of biodiversity in New Zealand, it needs to be associated with appropriate funding and support in order for the action to be realised – and requires recognition and adoption in decision making frameworks.

The opportunity to build on and support existing networks, capability and active protection at place among whānau, hapū and iwi is very tangible, and central to longer term goals of achieving enhanced biodiversity outcomes.

• Capture and embed the lessons from existing partnership-based delivery models for biodiversity and biosecurity management to inform decisions on future programmes.
• Encourage optimal investment in nature-based solutions, including the restoration and protection of native ecosystems for carbon and biodiversity benefits, by improving the evidence base, developing case studies and operationalising existing research.

NZCA strongly endorses the need for improved data, and knowledge on which to base biodiversity management – making better use of existing data, applying the results of existing research, supporting and extending monitoring programmes as well as the development of new research to enable more effective management.

NZCA has concerns that the strong economic focus of the newly established Public Research Organisations (PROs) will reduce research on biodiversity and ecosystems services that is key to understanding and protecting biodiversity in a New Zealand context.

Theme 4: Increased capability and support enables New Zealand to address the biodiversity crisis

• Develop a cross-sector plan to address the most important capability gaps in the biodiversity system.
• Increase New Zealanders’ awareness of the value of our biodiversity show how they can make a difference to biodiversity in their communities, and drive urgency and momentum for action.
• Establish cross-agency emerging risks capability for domestic biosecurity to horizon scan, share intelligence and support decision-makers in prioritising emerging risk management.

NZCA welcomes the focus on increasing capability to address the biodiversity crisis. A very significant gap that has been identified for decades, most recently 10 years ago in a report by the Royal Society Te Apārangi concerns the lack of recognition and insufficient support given to biodiversity infrastructure – namely the taxonomic collections and databases and associated taxonomy research.

Support for this infrastructure and the associated scientific workforce is a significant gap. There are many organisms found only in the New Zealand region that are inadequately known, and many others still to be discovered.

The New Zealand Threat Classification System paints a very concerning picture about the gaps in our understanding. The taxonomic and biological collections workforce has the skills required to recognise and document as yet undiscovered species, as well as to be able to recognise biosecurity threats arriving into New Zealand.

While critical to biodiversity protection and biosecurity initiatives, the coordination and effective delivery of this underpinning science and data has been overlooked, and there is no coordinated training and development of new skills and capability resulting in an extremely vulnerable skill base. Cuts to funding being experienced across the New Zealand science environment are threatening both current and future research and training of new capability.

It is also far from clear how this work within what was Manaaki Whenua, NIWA, and SCION will be supported in the future within the PROs. The funding for nationally significant collections in Museums and universities is also threatened in the current funding environment.

The delivery of Te Mana o Te Taiao/Aotearoa New Zealand Biodiversity Strategy was planned to involve cross agency engagement and commitment as well as empowerment of wider New Zealand. It is not clear that the agencies identified to lead particular workstreams will be sufficiently well resourced to be able to deliver the outcomes sought – for example the role of Te Uru Kahika in relation to the protection of biodiversity on private and Māori land.

Other comments

NZCA recommends that in future publications and discussion documents about biodiversity there are more images used, relevant to the associated text, showing examples of a diversity of people highlighting engagement and empowerment.

NZCA would encourage greater consideration of the interactions of the climate crisis with the biodiversity crisis, as understanding the interactions between these are crucial to future planning and management.

Overall, the Authority’s impression is that this document has been assembled to meet international obligations under the CBD – to be seen to be making progress – but it is not clear how the implementation will work given the huge funding gap that exists, and lack of commitment to departmental budgets that will enable the necessary actions.