Clown nudibranch. Photo by Luca Davenport-Thomas via iNaturalist (CC-BY)

The govt’s plan to improve biodiversity – Expert Reaction

Making more money off conservation land is one of the ways the government hopes to achieve the country’s Biodiversity Strategy.

Its just-released implementation plan also includes priorities like getting better evidence on where to invest in nature, empowering people to take action themselves, and setting up a domestic biosecurity risk network.

The SMC asked experts to comment. 


Professor Ann Brower, environmental geographer, University of Canterbury, is available for comment:

“The implementation strategy is much more focused on talk than on action, which is surprising for an implementation document. There’s a big emphasis on data gathering, and no mention on wilding pine control, for example.

“Jobs for Nature, an action-oriented programme, is hailed as a success, yet there is no mention of bringing it back to life after its demise a couple of years ago. Jobs for Nature is a great example of an action led programme more focused on physically controlling wilding pines, for example, than on talking about, theorising, or gathering data about wilding pines. Yet Jobs for Nature is gone, and we are back to talking about, theorising, and gathering data on the problems instead of cracking on and solving them.

“I am also surprised to see no role for Regional Councils in the implementation of a biodiversity strategy. Given that a majority of our biodiversity is found on private land, not DOC or LINZ land, I would expect to see a large role for Councils.

“I am more alarmed than surprised to see the focus on ‘nature credits’ in the biodiversity strategy. Research has found biodiversity credits to be better for development than biodiversity. Walker et al found policies like nature credits to sound lofty but accomplish little in part because they the standards they set are “obscure enough to please all parties, vague enough to be unenforcable, and so ill-defined that failures to [protect biodiversity] will be difficult to detect and impossible to litigate.””

Conflict of interest statement: The expert has declared they have no conflict of interest.


Dr Marie Doole, Independent researcher and consultant, Director of Mataki Environmental, comments:

“It is good to see the second plan released to support the 2020 Biodiversity Strategy. As with the first, there are a great many actors and actions identified that need to be progressed – but it is unclear however what funding or support there is for many of them and what buy-in there is outside the Department for the task list.

“The ambition in the goals of the strategy seems unmet by the sometimes pedestrian suite of actions in the plan (a fact also pointed out when the first plan was released). Efforts are of course tireless with what resources there are across DOC, regional councils, iwi and hapū, eco-sanctuaries and other community-led initiatives, and wins at place have been numerous and laudable – but scant funding and limited coordination makes it hard to maintain those gains.

“Further, I have been concerned for some time that community conservation lacks institutional recognition despite the plethora of community and private led conservation efforts across the motu. This plan reflects the same muted recognition we saw in the last one. A very much more collaborative approach is needed for this implementation plan, that compels and supports collective action. An uncoordinated space makes for a tough fight against an overwhelming opponent – an economy that favours extraction over protecting the public interest in a healthy environment.

“Without more transformational solutions that seek to align incentives in favour of nature, we will continue to document incremental improvements at place, cancelled out by reckless resource extraction and consumption overall.”

Conflict of interest statement: “Marie regularly works in research and advisory work on biodiversity conservation including for NGOs and all levels of government and has recently been appointed to Te Rōpū Mahi Nui (one of the advisory groups to support the Predator Free 2050 initiative)”


Manu Caddie, Adjunct Research Fellow, Te Kotahi Research Institute, University of Waikato, comments:

“The “Action for Nature” plan demonstrates commitment to Te Mana o te Taiao through Action F’s focus on removing barriers to Māori leadership. Our concern is that while recognition of mātauranga Māori alongside science, including iwi/hapū-led initiatives, and acknowledgment that “traditional knowledge systems, place-based wisdom, values and practices” are supposedly central, the rhetoric rarely matches reality and resourcing. The funding mechanisms proposed will hopefully accelerate existing restoration work and create meaningful employment pathways, but we’re not optimistic.

“Critical questions remain about implementation gaps. DOC remains the lead agency for many critical actions, leaving Māori decision-making authority unclear, this is a concern for iwi and hapū. More concerning, the plan’s targets appear insufficient to meet New Zealand’s commitments under the UN Convention on Biological Diversity and Kunming-Montreal Global Biodiversity Framework (KMGBF). KMGBF’s 2030 targets are far more ambitious than this plan’s 2050 focus, suggesting New Zealand may be using Māori partnership language to offset global criticism while under-resourcing implementation. This was evident in a response on the targets and indicators that I received from DOC recently. The extension of “market-based approaches” to Māori lands also risks repeating historical extraction patterns.

“Without clear power-sharing arrangements, measurable Māori leadership metrics, protection of mātauranga Māori from appropriation, and timelines aligned with international commitments, the strategy risks becoming another document where Māori partnership language serves state compliance while Māori communities bear conservation labour without commensurate authority or resources.”

Conflict of interest statement: “Manu is a trustee of Ngāti Pūkenga Iwi ki Tauranga Trust. He works in research and commercialisation of products and intellectual property derived from indigenous organisms with iwi, hapū and Māori landowners around Aotearoa. He is also the Indigenous Peoples representative for the Pacific region on the Steering Committee of the Multilateral Mechanism for the fair and equitable sharing of benefits from the use of Digital Sequence Information, including the Cali Fund, established by the UN Convention on Biological Diversity.”


Dr Kiri Joy Wallace, Research Fellow in Science , Te Whare Wānanga o Waikato – University of Waikato

“Action for Nature states “more than 75% of indigenous reptile, bird, bat and freshwater fish species are threatened or at risk of extinction”. This dire statistic highlights a shift from business-as-usual to a new biodiversity care paradigm is urgently needed. Action for Nature compiles excellent ideas, which if enacted well could deliver required change. My key responses:

“The plan could better identify ways to stem systemically-driven biodiversity loss. I agree about joint effort across all society/sectors, but emphasise: it’s critical we embed change in our major economic drivers and societal mechanisms (e.g. business frameworks and government policies). The current shape of these mechanisms causes the majority of biodiversity loss, so is where, logically, we should make changes. The work of community groups is important, however it’s ludicrous to think unabated systemic damage to our most valuable long-term asset/dependency (nature) should be mitigated primarily by volunteers and/or public investment.

“Timeline is appropriate but ambitious. Action for Nature focuses on critical actions to be taken by 2030. The timeframes are short for the monumental amount of relationship building and technical work required. This will only be possible with dynamic leadership and large budgets.

“Monitoring and reporting is critical. Without monitoring, the rest of the Action for Nature plan is impossible to enact. I was relieved to see this emphasis, but know that tracking biodiversity investment through to impact (evidence of change) is a wicked problem. We should leverage new technologies like remote sensing and AI, plus outputs of past public investments regarding indicators and platforms (e.g. BioHeritage National Science Challenge). Our monitoring should align with international standards to aid in honouring our international agreements (glad to see these emphasised).

“Funding, Funding, Funding. I caution against vague methods with likely perverse outcomes like “Generating sustainable revenue from the low-impact use of public conservation lands”. Instead, I applaud the intent to explore nature credit markets and nature-based solutions. I encourage us to reduce the expense side of the ledger (my point #1 above). Restoring biodiversity is expensive and it’s wiser to just stop damaging what already exists.

“Learn from Iwi Māori. As the plan suggests, let’s look to iwi trust and business models, which often avoid initial biodiversity harm and choose sustainable pathways that regenerate nature. Authentic partnership with iwi and traditional knowledge practices is also rightly highlighted.

“Close our biodiversity-related capability gaps. Yes! This requires more investment in specialist roles bridging science research to practical application (e.g. knowledge brokers, science communicators). Without these, any evidence accrued from monitoring efforts is useless.

“As governments, corporations and citizens everywhere currently question their roles in the biodiversity space we have an opportunity to be world leading if this plan is well enacted. Let’s not miss the boat!”

Conflict of interest statement: “Nothing to declare.”


Dr Mike Joy, Senior Research Fellow in Freshwater Ecology and Environmental Science, Te Herenga Waka—Victoria University of Wellington, comments:

“A strategy should by definition have specific, measurable targets, clear identification of who is accountable and budgetary requirements. This implementation plan lacks all these thus is not a strategy; it’s just hand waving.

“If it were a genuine strategy its goals and outcomes would be based on real measurable outcomes and we have this already with the New Zealand Threat Classification System (NZTCS). This is well established and would make an excellent a key indicator of success or failure of a biodiversity strategy.

“The elephant in the room is all this coalition government’s actions to weaken environmental protection and promotion with the likes of The Provincial Growth Fund and the Fast-track legislation enabling all sorts of biodiversity harming projects like irrigation and hydro dams and mining.

“Most of the actions outlined in the plan are based on a business growth ideology that ignores biophysical reality and assumes you can buy anything. The idea that we can buy biodiversity gains while destroying habitats is flawed. Real biodiversity gains are made by not doing something like destroying habitats rather than some commercial activity especially when in the conservation estate.

“Our ecosystems are already so damaged and degraded we need to focus on trophic complexity and system robustness as much as just indigenous trajectories. We need radical shift in the philosophy behind conservation ecology not vague tweaking.

“New Zealand has an appalling record for biodiversity loss, and this implementation plan is based on a flawed strategy will do nothing to halt declines.”

Conflict of interest statement: “None.”