Formal Opposition to
Game Animal Council (Herds of Special Interest) Amendment Bill

(Government Bill 151–1, James Meager)

From: Ukes Baha | 22 July 2025

Submitted in response to the call for public submissions on the Game Animal Council (Herds of Special Interest) Amendment Bill

Summary of Position

I oppose the Game Animal Council (Herds of Special Interest) Amendment Bill in full.

This bill is a reckless and unjustified interference with New Zealand’s most sacred conservation legislation — the National Parks Act 1980. It strips away long-standing ecological protections, ignores biodiversity science, sidelines Māori environmental leadership, and hands discretionary power to a first-term Minister lacking conservation credentials.

Presented under the guise of “flexibility” or “hunter-led conservation,” this bill is in fact a Trojan horse for political favouritism, lobbyist appeasement, and ecological deregulation. It is a legislative shortcut to weaken the public estate for private gain.

1. Undermines the Purpose of National Parks

Section 4(2)(b) of the National Parks Act mandates the extermination of introduced species “as far as possible.” This bill overrides that core duty — allowing harmful species to remain simply because they are declared a “herd of special interest.”

Problem: This subverts the Act’s foundational purpose. National parks were not created as hunting reserves — they are sanctuaries for native species under permanent ecological protection. The bill reverses that purpose, making eradication optional and invasive species negotiable.

2. Creates a Legal Loophole for Invasive Species

Through a simple ministerial designation, this bill legalises the permanent presence of destructive introduced species — deer, tahr, wapiti, chamois — inside our most ecologically fragile and legally protected areas.

Problem: No ecological review, environmental impact report, or biodiversity risk assessment is required. A single Minister can declare a herd “special” for cultural or recreational reasons, with no external accountability.

3. Politicises Wildlife Management

This bill removes the requirement for advice from the New Zealand Conservation Authority and concentrates power in the hands of the Minister for Hunting and Fishing. It also fails to define:

Problem: Wildlife classification becomes politicised — driven by pressure from hunting groups or commercial outfitters, rather than science, tikanga, or public interest. It is an invitation to arbitrary decision-making.

4. Harms Biodiversity and Threatens Ecosystems

Every major ecological review — including DOC’s own reports — confirms that hoofed browsers devastate native bush, degrade alpine ecosystems, erode soil, and disrupt waterways.

Problem: This bill incentivises the spread and protection of invasive animals in our most vulnerable areas, undermining predator control, reforestation, and native regeneration. It actively works against every major biodiversity strategy and climate adaptation plan New Zealand has endorsed.

5. Breaches Te Tiriti o Waitangi Obligations

Nowhere in the bill is there mention of:

Problem: The bill erases indigenous authority over land, ecosystems, and taonga species. It mirrors colonial policy patterns — allowing non-native species to occupy land without Māori agreement, governance, or benefit.

6. Grants Power Without Definition, Limit, or Process

This bill includes:

Problem: “Herds of special interest” can be declared indefinitely, based on popularity or politics. No ecological, legal, or democratic guardrails exist. This is legislation without boundaries.

7. Sets a Dangerous Precedent Across Conservation Law

Allowing a Minister to override a core provision of the National Parks Act by designation creates a constitutional precedent:

Problem: The bill opens the gate to future deregulation of conservation lands and undermines the legislative consistency on which public trust and environmental stability depend.

8. Reckless for a First-Term Minister

James Meager has no professional background in ecology, conservation science, or indigenous environmental governance. His tenure in Cabinet is recent and his legislative record minimal.

Problem: It is inappropriate for a new Minister — with limited policy depth and no conservation credentials — to lead such a foundational shift in environmental law. New Zealand’s biodiversity future must not be shaped by ministerial overreach, inexperience, or ideological loyalty.

Conclusion and Recommendations

This bill is not a refinement — it is a retreat. A retreat from biodiversity protection, from scientific consensus, from Te Tiriti obligations, and from the long-standing principle that national parks exist to defend nature — not market it.

I recommend that the Environment Committee:

  1. Reject the bill in full to uphold the ecological integrity of the National Parks Act.
  2. Reinforce Section 4(2)(b) and prevent exceptions for introduced species.
  3. Prohibit ministerial overrides without science-based, public, and iwi-supported processes.
  4. Define “special interest” based on ecological thresholds, not popularity or tradition.
  5. Require environmental and cultural impact assessments before any species can be retained in protected areas.
  6. Ensure mandatory partnership with tangata whenua in biodiversity governance and legislative reform.
  7. Reaffirm New Zealand’s global commitments to biodiversity, climate resilience, and indigenous partnership.

Conservation law is not a playground for hobbyists or lobbyists. Once compromised, native ecosystems may never recover.

Respectfully submitted,
Ukes Baha
Public Health Advocate | Counsellor | Policy Analyst
ukesbaha.com