We've identified key issues across both Bills and developed specific solutions. You can use our detailed breakdown below to craft your own submission addressing particular topics that matter to you.
Issue: No definition of wetlands. No clear mechanism for identification, protection, or restoration. Risk of incremental loss, especially for small or modified wetlands. Lack of information on making it easier for wetlands to be created and improved.
Solution sought: Insert a clear definition of "wetland" and require national instruments and plans to identify and protect wetlands. Require national instruments and plans to enable wetland restoration and creation.
Example wording: "Wetland includes permanently or intermittently wet areas, shallow water, and land water margins that support a natural ecosystem of plants and animals that are adapted to wet conditions"
“Amend clause 32 to clarify that permitted activities can be for the purpose of enhancing and restoring the natural environment (not just its use and development).
Issue: Absence of recognition marginalises Fish and Game's statutory management framework and decades of investment in monitoring and planning.
Solution sought: Insert explicit requirement to have regard to SFGMPs in plan-making and consenting.
Issue: Goals are narrowly framed and omit recreation, enhanced public access and habitat protection for trout, salmon and game birds. Ecosystem values are framed almost exclusively around indigenous biodiversity, and do not provide for valued introduced species.
Solution sought: Insert explicit goals that provide for:
Issue: As drafted, ecosystem health is defined by referring to 'life supporting capacity' which only includes indigenous species and does not include trout and salmon.
Solution sought: Amend the definition of life supporting capacity to include valued introduced species or use the phrase ‘ecosystem health’ and define that in a way that includes the ecosystem needs of valued introduced species like trout and salmon. Either way include valued introduced species.
Issue: As drafted, there is no requirement for the Minister to set methodologies for ecosystem health limits. This means there could be a scenario where every council sets their own methodology, creating national inconsistency.
Solution sought: Require the Minister to set methodologies and national bottom lines that provide for valued introduced species including the habitat of trout and salmon.
Issue: There is currently no requirement to consult with Fish & Game in the preparation of national instruments, despite its statutory role.
Solution sought: Add a requirement to consult with Fish & Game on matters that impact the habitat of trout and salmon and game birds.
Example wording: "The Minister must consult the New Zealand Fish and Game Council on any proposal that may impact the habitat of trout and salmon and game birds."
Issue: No requirement to have regard to Sports Fish and Game Management Plans.
Solution sought: Add to have regard to SFGMP in relation to habitat of trout and salmon and game birds.
Example wording: "have regard to—
Issue:
Solution sought:
Issue:
Several definitions need amendment to provide clarity and better protection:
Bed (Part 1 Interpretation)
Water body (Part 1 Interpretation)
Issue: Limits framework excludes trout and salmon by defining ecosystem health solely by reference to indigenous species. This prevents limits being set to protect sports fish habitat.
Solution sought: Broaden the definition of ecosystem health / life-supporting capacity to include valued introduced species where they are integral to ecosystem function and recreation.
Issue: Regional councils cannot lawfully set limits to protect trout and salmon habitat, even where degradation would destroy wild fisheries.
Solution sought: Enable ecosystem health limits to be set for water quality, quantity, and habitat attributes necessary to sustain trout and salmon populations.
Issue: National instruments are highly directive but have minimal consultation requirements. No obligation to consult Fish and Game despite statutory responsibilities.
Solution sought: Require mandatory consultation with Fish and Game where national instruments affect freshwater, wetlands, public access, recreation, or habitat of sports fish and game birds.
Issue: Enforcement relies heavily on councils, which may lack capacity. Fish and Game's existing enforcement capability is not utilised.
Solution sought: Explicitly recognise Fish & Game as a complementary enforcement body with powers to investigate, fine, and prosecute relevant breaches.
This is for those who make a detailed submission recommending changes to specific clauses and propose solutions.
We've identified key issues across both Bills and developed specific solutions. You can use our detailed breakdown below to craft your own submission addressing particular topics that matter to you.
Step 1. Write your submission
We've outlined key issues and the solutions we're seeking. You can use these to inform your own submission.
Step 2. Visit the Parliament website.
Go to the Parliament website to make your submission here.
Step 3. Submit your response
Click "I am ready to make my submission".
You can either:
Step 4. Share your submission with us
Also please share a copy of your submission with us to media@fishandgame.org.nz, so we can share your views and encourage others to help.
Our submission will be seeking to provide pragmatic solutions to these and other areas in the proposed bills to positively represent our angling and game bird hunting licence holders.
Submissions close on 13 February 2026.
The following topics are also addressed in detail in our submission: