Introduction
- The Royal Forest & Bird Protection Society of New Zealand Inc. (Forest & Bird) welcomes the opportunity to make a submission on the Environment (Disestablishment of Ministry for the Environment) Amendment Bill (the Bill).
- Forest & Bird is Aotearoa New Zealand’s independent voice for nature, with over a century of experience advocating for the protection and restoration of indigenous biodiversity, freshwater, and the natural environment. We engage extensively in national and local government policy, planning, and legislative processes where environmental outcomes are at stake.
- Forest & Bird recognises the importance of improved coordination across portfolios such as housing, transport, local government and the environment. However, we are concerned that the approach proposed in this Bill risks weakening environmental governance, accountability, and resourcing at a time when stronger, not weaker, environmental institutions are required.
Overall Position
- Forest & Bird does not support the Bill as currently drafted.
- While integration across government portfolios is desirable in principle, Forest & Bird considers that disestablishing the Ministry for the Environment and embedding its statutory functions within a large, development-oriented super-ministry creates significant risks. These risks outweigh the potential benefits of administrative improvements and integration.
- Forest & Bird’s opposition is grounded in consistent themes which are also included in our recent submissions on resource management reform, local government reform and rate capping:
- environmental functions are already under-resourced and vulnerable to de-prioritisation
- governance structures matter for ensuring environmental outcomes are visible, contestable, and accountable
- consolidation and simplification exercises frequently result in environmental responsibilities being diluted rather than strengthened
Risk of Dilution of Environmental Functions
- The Bill transfers the statutory functions of the Ministry for the Environment to a Secretary located within a consolidated Ministry responsible for cities, transport, housing, local government and the environment.
- Forest & Bird is concerned that, in practice, this will dilute the time, focus, and institutional weight given to environmental leadership. Environmental stewardship is not simply one interest among many; it is a core public good that requires sustained, specialist focus.
- At a time when New Zealand is having to contend with increasingly clear impacts of twin climate and biodiversity crisis it makes no sense to weaken the leadership attention and focus that is able to be given to environmental matters.
- Forest & Bird has repeatedly observed — including in the local government context — that when environmental responsibilities compete directly with development and infrastructure imperatives within the same governance structure, environmental outcomes tend to lose out unless strong statutory safeguards are in place.
Risk of Conflicting Mandates and Weakened Advice
- Forest & Bird is concerned that the Bill introduces structural conflicts of interest by embedding environmental statutory functions alongside mandates to promote development, transport efficiency, and urban growth.
- This concern is reinforced by the Bill’s amendments requiring the Secretary to have regard to environmental matters “as far as practicable”. Forest & Bird considers that this language risks downgrading environmental considerations when they conflict with other departmental or ministerial priorities.
- We note similar concerns in our submissions on local government reform, where Forest & Bird opposed governance models that obscure trade-offs and reduce the visibility of environmental advice to decision-makers.
Risk of Reduced Transparency and Contestability
- Forest & Bird places high value on transparent, contestable environmental advice to Ministers and decision-makers.
- Consolidating environmental advice streams within a large Ministry risks:
- internalising trade-offs behind closed doors
- reducing the clarity of environmental impacts in regulatory impact assessments
- limiting the ability of Ministers, Parliament, and the public to see where environmental considerations have been overridden
- Forest & Bird has consistently argued that clear institutional separation helps ensure environmental advice is visible and not silently subordinated to short-term development objectives.
Risk of Defunding Environmental Functions
- Forest & Bird is particularly concerned about the implications for funding transparency and security.
- Our submissions on rate capping and local government reform highlighted how environmental functions are often the first to be cut when funding is constrained or bundled within larger appropriations.
- Embedding environmental functions within a broader Ministry risks making environmental funding:
- harder to identify in appropriations
- easier to erode without public scrutiny
- less stable over time
- Forest & Bird submits that, at a minimum, dedicated, transparent funding lines for environmental functions must be retained.
Institutional Stability and Reform Fatigue
- Forest & Bird is concerned about the timing of this reform. The environmental system is already undergoing substantial change through resource management reform and implementation of new national direction.
- Further changes in the structure and operation of local government are also being considered. Collectively, the wider environmental management and regulatory framework is undergoing extensive change.
- Institutional disruption — including potential loss of specialist staff and institutional knowledge — poses real risks to effective implementation of these reforms.
- Fragmented, disjointed change of this scale and importance increases the risk of system failures.
If the Bill Proceeds: Minimum Safeguards
- If the Committee recommends that the Bill proceed, Forest & Bird submits that the following safeguards are essential:
- a clear statutory establishment of the role of the Secretary for the Environment
- transparent, ring-fenced funding for environmental functions
- mechanisms to ensure environmental advice remains visible, independent, and contestable
Drafting
- If the Bill does proceed, we would endorse the drafting recommendations raised in the submission by the Environmental Defence Society (EDS). These are listed under 13 (a) (b) (c) and (d) of their written submission. We would also seek deletion of “as far as practicable” from clause 12.
Conclusion
- Forest & Bird urges the Committee to recommend against the Bill in its current form.
- Integration across government can and should be achieved through mechanisms that strengthen environmental leadership rather than subsume it.
- Forest & Bird remains open to alternative models — such as inter-departmental boards or strengthened coordination mechanisms — that preserve the independence, visibility, and resourcing of environmental governance.