Hi All,
The Advocates has prepared and made a submission on the proposed Natural Environment and Planning Bills.
Advocates Chair Carl Bergstrom has spearheaded the effort to make sure the environment for trout and salmon are accounted for in this new legislation. It seems probable that the Advocates will be making an oral submissiom as a supplementary effort. If we get the opportunity for this then Carl will again take the lead on this.
Below is a copy of the Advocates submission, a letter to Taupo MP Louise Opston and supplementary letter to all MPs with applicable fisheries within their respective electorates.
We urge any organisation or individual to submit on this important piece of legislation in order to help maintain our healthy freshwater fisheries. A link is directly below, where submissions can be made.
Our Submission.
Submission on the Natural Environment and Planning Bills
The Advocates for the Tongariro River Inc. was established in 2002 in response to
community concern about flooding and erosion in the Tongariro catchment. Since that
time, the organisation’s purpose has broadened to speaking out for the Tongariro River
and its environs, and to promoting management strategies intended to preserve and
enhance the values inherent in the river, its fishery, and associated recreational
activities for the benefit of present and future generations.
While we recognise the need to reform the current resource management legislation,
we are concerned that the Natural Environment Bill and the Planning Bill contain some
important omissions that, if not addressed, risk undermining the protection and
enjoyment of nationally significant freshwater environments.
1. Protection of trout and salmon habitat
New Zealand’s freshwater fishery, primarily trout and salmon, is of great significance to
a large number of New Zealanders for their recreation, health, and wellbeing. The
fishery is also widely regarded internationally as one of the world’s premier freshwater
angling destinations, reflecting the quality of the fishery, the diversity and scenic
character of angling environments, and the broad geographic spread and accessibility
of fishing locations. As a result, the fishery attracts significant numbers of high-value
international visitors. In 2020, the New Zealand Federation of Freshwater Anglers
estimated the value of the freshwater fishery to the New Zealand economy to be well
over $1 billion per annum, based on earlier Department of Conservation and Cawthron
Institute studies. This scale of value is further reflected in the continuing strength of
participation, with approximately 140,000 freshwater fishing licence holders last
season (including over 30,000 for the Taupo District), up 4% from the previous season.
While the Natural Environment Bill contains a general goal to safeguard the life-
supporting capacity of air, water, soil, and ecosystems, and treats ecosystems as
encompassing all living components of the natural environment, it gives specific
operational priority only to indigenous biodiversity through express outcomes and
mandatory limit-setting requirements. There is no equivalent, express protection
framework for non-indigenous species. As a result, the protection of trout and salmon
habitat is left to indirect mechanisms and discretionary planning choices, rather than
being anchored in the core statutory architecture. This represents a retreat from section
7(h) of the Resource Management Act 1991 and from the late-stage amendments to the
Natural and Built Environments Bill, which recognised the need for explicit statutory
recognition of trout and salmon habitat. We therefore submit that Part 2 of the
Natural Environment Bill should be amended to include an express Goal that the
habitat of trout and salmon is protected, so that nationally significant freshwater
fisheries continue to receive clear and consistent statutory recognition.
2. Recreational use and enjoyment of the natural environment
The Planning Bill includes a goal relating to “maintaining public access to and along the
coastal marine area, lakes, and rivers”, but neither the Planning Bill nor the Natural
Environment Bill expressly requires decision-makers to consider the effects of activities
on recreational use or enjoyment of the natural environment. For example, as drafted,
an application that materially alters river flows could preserve physical access while
significantly degrading activities such as rafting, kayaking, or angling, without those
impacts being a mandatory consideration. This represents a retreat from section 7(c) of
the Resource Management Act 1991 (“the maintenance and enhancement of amenity
values” which are defined to include “recreational attributes”), and the late-stage
amendments to the Natural and Built Environments Bill which recognised the need to
provide for recreational use and enjoyment of the natural environment. We therefore
submit that Part 2 of the Natural Environment Bill should be amended to include an
express Goal that public recreational use and enjoyment of the natural
environment, including lakes, rivers, and the coastal environment, be maintained
and enhanced.
Given the more tightly prescribed decision-making framework for natural resource
permits, and the removal of section 104(1)(c) of the RMA which expressly allowed
decision-makers to give weight to any other matter they considered relevant and
reasonably necessary, it is critical that the protection of trout and salmon habitat and
recreational amenity are anchored in the system’s foundation goals. Without that
anchoring, there is no reliable pathway for those matters to influence consent
decisions.
We acknowledge that the Natural Environment Bill retains Water Conservation Orders
as a mechanism to protect outstanding water bodies, including for fisheries and
recreational purposes. However, Water Conservation Orders are, by design, exceptional
instruments. They can apply only to water bodies that are considered to be outstanding,
require a separate application and tribunal process, and exist for only a small number of
rivers and lakes. They do not operate as general system obligations across everyday
planning and consenting decisions, and do not provide a protection mechanism
capable of safeguarding the fresh-water fishery as a whole. Reliance on Water
Conservation Orders therefore does not address the absence of express, system-level
recognition for the protection of trout and salmon habitat or for public recreational use
and enjoyment of the natural environment.
3. Importance of early community consultation and getting plans right
The new planning framework is expressly designed to shift public participation
upstream into plan development, rather than at the consenting stage. The explanatory
notes for both Bills state that “community engagement is intended to primarily occur
during … plan development rather than at the consenting / permitting level” meaning
that there will be fewer opportunities for communities to influence outcomes through
project-level resource consents, and that the content of plans will largely determine
future decisions. This makes it all the more important that overarching spatial, land use,
and natural environment plans are developed through robust, accessible, and effective
community consultation processes. For small community organisations, participation
in independent panel hearings on complex, region-wide plans is often beyond practical
reach. If meaningful opportunities to engage are not secured at the earlier consultation
and drafting stages, local community values risk being excluded from the system
altogether. Currently, the bills only require that the evaluation report for a proposed
natural environment or land use plan must state “how, if at all, the draft has been
influenced by (i) pre-notification consultation, and (ii) any other engagement with local
communities”. The inclusion of the words “if at all” makes clear that such consultation
is not mandatory. We therefore submit that the Bills should include clear,
mandatory requirements for early community consultation and engagement in
plan development, to ensure that community perspectives are genuinely
incorporated before draft plans are finalised.
Our letter to Taupo MP Louise Upston:
Carl Bergstrom
Chair, Advocates For The Tongariro River Inc.
Taupahi Road
Turangi 3334
[email protected]
29 January 2026
Hon Louise Upston
Member of Parliament for Taupō
3 Anzac Street
Cambridge
Waikato 3434
Tēnā koe Ms Upston,
Re: Support for Strengthening the Natural Environment and Planning Bills
I am writing on behalf of the Advocates For The Tongariro River Inc., a volunteer group
committed to the health of the Tongariro River and the Taupō trout fishery. As Parliament
considers the Natural Environment and Planning Bills, we seek your support to ensure
these reforms continue to protect what is both an environmental taonga and a
foundation of the Taupō regional economy.
We welcome the Government’s intention to create a clearer and more efficient system
to replace the RMA. To fully realise these benefits, we believe the Bills would be
strengthened by explicitly recognising trout and salmon habitat and the recreational use
of our rivers and lakes. At present, the draft Natural Environment Bill provides strong
protection for indigenous biodiversity but leaves the nationally significant trout fishery
reliant on indirect or discretionary mechanisms. Similarly, neither Bill requires
decision‐makers to consider the effects of activities on recreation, despite its
importance to local businesses and employment.
To maintain the value of the Taupō fishery for future generations, we respectfully request
amendments that:
• require particular regard to the protection of trout and salmon habitat;
• maintain and enhance public recreational use and enjoyment of freshwater and
coastal environments, for example, to ensure any future changes to river flows are
assessed for their impact on angling, rafting, and kayaking.
These additions would align the Bills with the region’s economic realities and help
safeguard a resource that supports guiding services, accommodation providers,
hospitality businesses, and the wider tourism sector.
We have provided the Select Committee, considering these bills with our submission
regarding this issue. I attach the submission for your information.
Thank you for your consideration. I would welcome the opportunity to discuss these
matters further as the Bills progress.
Ngā mihi,
Carl Bergstrom
Chair, Tongariro Advocates
Attachment – Advocates for the Tongariro – Submission to Select Committee on Draft Natural
Environment and Planning Bills
Our Letter to additional MPs- whom electorates have an interest in this proposed legislation:
Carl Bergstrom
Chair, Advocates For The Tongariro River Inc.
Taupahi Road
Turangi 3334
[email protected]
29 January 2026
Member of Parliament for:
Waitaki – Miles Anderson
Wairarapa – Mike Butterick
Waimakariri – Matt Doocey
Taranaki/ King Country – Barbara Kuriger
Taieri – Ingrid Leary
Rotorua – Hon Todd McLay
Rangitata – Hon James Meager
Southland – Joseph Mooney
Rangitikei – Suze Redmayne
Tukituki – Catherine Wedd
Waikato – Tim Van der Molen
Tēnā koe,
Re: Natural Environment and Planning Bills – Implications for the Trout and Salmon Fishery
and Regional Economy
I represent a group of volunteers based in Turangi that advocate for the local Trout fishery
although our interest and concern for the freshwater fisheries extend across the country. As
Parliament considers the Natural Environment and Planning Bills, we seek your support to
ensure these reforms continue to protect our trout and salmon fisheries and safeguard an
environmental taonga and an important part of regional economies.
We welcome the Government’s intention to create a clearer and more efficient system
to replace the RMA. To fully realise these benefits, we believe the Bills would be
strengthened by explicitly recognising trout and salmon habitat and the recreational use
of our rivers and lakes. At present, the draft Natural Environment Bill provides strong
protection for indigenous biodiversity but leaves the nationally significant trout fishery
reliant on indirect or discretionary mechanisms. Similarly, neither Bill requires
decision‐makers to consider the effects of activities on recreation, despite its
importance to local businesses and employment.
To maintain the value of our trout and salmon fishery for future generations, we respectfully
request amendments that:
• require regard for the protection of trout and salmon habitat; and,
• maintain and enhance public recreational use and enjoyment of freshwater and
coastal environments
These additions would align the Bills with the region’s economic realities and help safeguard a
resource that supports guiding services, accommodation providers, hospitality businesses, and
the wider tourism sector.
We have provided the Select Committee considering these bills, with our submission
regarding this issue. I attach the submission for your information.
Ngā mihi,
Carl Bergstrom
Chair, Tongariro Advocates
Attachment – Advocates for the Tongariro – Submission to Select Committee on Draft Natural
Environment and Planning Bills