The Environment Committee has examined the Game Animal Council (Herds of Special Interest) Amendment Bill and recommends by majority that it be passed. We recommend all amendments by majority.

The bill would amend the Game Animal Council Act 2013. The purpose of the bill is to make it clear that game animals within a national park can be designated and operate as a herd of special interest (HOSI).¹

At present, the Act allows herds of game animals on public conservation land to be formally designated as HOSIs by the Minister of Conservation.² The designation means the herd would be managed for hunting purposes under a herd management plan. Management of a HOSI for hunting purposes could include managing hunting demand to help maintain a sustainable population of healthy animals. There are currently no designated HOSIs in New Zealand.

Both the decision to designate a HOSI and the herd management plan must be consistent with certain considerations related to conservation. These considerations include, but are not limited to, the general welfare and management of public conservation land, national park management plans, and pest management strategies and plans made under the Biosecurity Act 1993.

The bill would clarify the relationship between the Game Animal Council Act and the National Parks Act 1980. Section 4(2)(b) of the National Parks Act requires that introduced species in national parks must be exterminated as far as possible, unless determined otherwise by the New Zealand Conservation Authority.³ The bill would clarify that, if a HOSI is designated in a national park, this requirement would not apply to that herd. The requirement would still apply to animals that are not designated as HOSIs and to HOSI animals that leave the designated area. The bill would make clear that the Minister can designate a HOSI without requiring a determination from the New Zealand Conservation Authority.

Without the amendment proposed by the bill, maintaining a healthy population in a HOSI for hunting purposes in a national park could be considered inconsistent with the requirement to exterminate introduced species as far as possible. The bill would clarify that there is no requirement to exterminate introduced species in national parks that have been designated as HOSIs.

As part of our consideration of the bill, we have examined its consistency with principles of legislative quality. We have no issues regarding the legislation’s design to bring to the attention of the House.

The bill would make clear that if a HOSI is designated in a national park, the requirement under section 4(2)(b) of the National Parks Act to exterminate introduced species as far as possible does not apply to that herd.

To help make clear the effect of the bill’s proposed amendments on the National Parks Act, we propose a consequential amendment to that Act. We recommend inserting new section 4(3) of the National Parks Act as a cross-reference to direct the reader to section 16(3A) of the Game Animal Council Act. The new section would also note that if a HOSI is designated in a national park, the requirement under section 4(2)(b) does not apply to that herd.

To achieve this change, we recommend splitting the bill into two parts. Part 1 would include clause 4 as introduced, amending the principal Act. Part 2 would include new clauses 5 and 6 to amend the National Parks Act 1980.

The New Zealand Labour Party opposes this bill. This amendment bill overrides the provisions in the National Parks Act 1980 (NP Act) that provide for the control of introduced browsers. The current default position in the NP Act is that introduced species—including valued introduced species such as deer—must be exterminated as far as possible. This bill aims to clarify that this requirement does not apply to herds of special interest since it is not possible to both exterminate a herd of game animals and simultaneously manage it for hunting purposes.

National parks are protected because they are some of our most stunning landscapes and significant ecosystems, and are scientifically important. The primary purpose of the NP Act is to preserve the parks in perpetuity for their intrinsic value and for the enjoyment of the public.

There is substantial evidence that introduced browser populations have increased over time and that they cause significant damage to New Zealand’s indigenous ecosystems. While the Labour Party is not opposed to hunting, we do not agree with legislation that puts hunter outcomes and the management of invasive browsers ahead of the conservation of national parks.

We also oppose this legislation on the grounds that it weakens the role of the New Zealand Conservation Authority (the Authority). The protection of the value of national parks is the primary responsibility of the Authority. Labour Party members share the concern expressed by the Authority at the lack of specific consultation undertaken with it considering this legislation erodes its conservation responsibilities.

Finally, we share the concern expressed by some submitters that this legislation is particularly problematic as it is being considered at a time when the government is cutting funding for conservation and New Zealand is experiencing a biodiversity crisis. While we acknowledge the valuable contribution of hunters to conservation outcomes, this work can continue without the amendment bill and it cannot replace the government’s role in protecting national parks and sufficiently resourcing conservation work more broadly.

The Green Party strongly opposes this bill. This legislation risks fundamental conservation principles and outcomes and lacks any credible evidence-base to justify those risks.

The Department of Conservation’s (DOC) own disclosure statement exposes the fundamentally flawed basis of this legislation:

• "No publicly available inquiries, reviews, or evaluations have informed, or are relevant to, the policy given effect by this Bill."

• "No further impact analysis has become available for any aspects of the policy to be given effect by this Bill."

National Parks are treasured places—our pre-eminent natural areas established to protect indigenous plants, wildlife, and natural landscapes. Along with nature reserves, they provide the strongest legally protected refuges for native species. Functional forest ecosystems that are free from invasive browsers sequester carbon, retain soils, and provide a more resilient landscape to deal with increased frequency and intensity of weather events from climate change. This bill works directly against these key climate benefits.

The bill threatens both our tourism industry and our international reputation by legitimising ecosystem degradation through invasive browsers. National parks provide iconic images for tourism promotion and are a major reason international visitors come to Aotearoa. Visitors come to see our distinctive indigenous plants, wildlife and landscapes—not invasive browsers.

We are particularly concerned about the operational conflicts that could arise as a result of a HOSI designation conflicting with DOC’s conservation role. These include the application of aerial 1080 operations for possum control (due to potential impacts on browsers); increased operational costs where deer repellent must be applied to cereal bait; professional culling or control operations to protect browsed species; or any management perceived as threatening to game animals.

We are equally concerned about the Ministerial delegations and discretion that means the Minister for Hunting and Fishing is able to make resourcing decisions about DOC budget. We do not support the removal of democratic oversight by sidelining the New Zealand Conservation Authority, transferring critical conservation decisions to a single Minister. This represents a dangerous constitutional precedent that undermines scientific decision-making.

Hunter-led management of invasive browsers has been proven not to work because the level, spread, and intensity of recreational hunting effort is uneven and inadequate. We recognise that many hunters care about the natural environment. Despite best intentions, there are no successful examples across New Zealand where hunter-led management has effectively controlled populations.

As a minimum, clear monitoring baselines should be set up to assess effectiveness or otherwise of conservation management regimes before a HOSI is approved and regularly reviewed.

New Zealand’s native ecosystems, evolved in isolation over millions of years without ungulates or mammalian predators, deserve protection based on science and democratic oversight. This bill goes directly against protection and informed decision-making and should be rejected in its entirety.

ACT supports this bill and the intent behind it. Herds of Special Interest will be an important part of New Zealand’s hunting community, and hunters have long called for these reforms. ACT is proud to stand with them in supporting greater recognition and management of these herds.

However, ACT is concerned that unless further amendments are made to the principal Act, the bill will fall short of its goals. In particular, sections 16 and 19 of the Game Animal Council Act 2013. Section 16 requires that the Minister have regard for, and that management of animals is consistent with, the “overriding considerations”. Section 19 also requires that herd management plans are consistent with “overriding considerations”, which may function as a roadblock in progressing any Herds of Special Interest. We believe that this requirement risks undermining the intent of the bill and, as a result, the bill may fail to deliver the clear, lasting outcomes Parliament intends.