1

WWF-NEW ZEALAND

SUBMISSION ON THE

BIODIVERSITY STRATEGY

WWF New Zealand Level 6, Davis Langdon House 49 Boulcott Street Wellington 6011, New Zealand Amanda Leathers Research and Policy Manager aleathers@wwf.org.nz September 2019

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Contents 1 Introduction ............................................................................................................. 3

2 Summary of key recommendations .......................................................................... 5

3 Comments about Part 1 of the consultation document ............................................. 6

4 Include a strategy for marine biodiversity ................................................................. 7

4.1 Vision and goals for marine biodiversity ....................................................................... 8

4.2 Immediate actions ..................................................................................................... 11 4.2.1 Demonstrate Commitment to marine protection through passing the Kermadec/Rangitāhua Ocean Sanctuary Bill and developing a reformed MPA Policy that is bold and innovative. ....................... 11 4.2.2 100% independent monitoring of fishing activity ......................................................................... 12 4.2.3 Trawl footprint freeze and stop further trawling in areas classified as “vulnerable” .................. 12 4.2.4 Review legislation.......................................................................................................................... 13 4.2.5 EBM case studies – West Coast North Island case study for cumulative impacts and Kapiti Coast corridor of conservation and Mountain to Seas management ................................................................... 13

5 Strategy for empowering kaitiakitanga and Mātauranga Māori ................................15

6 Empowering New Zealanders to connect with, restore, protect and live in harmony with nature ....................................................................................................................18

7 Build a system of support for innovation and a social innovation framework to mobilise and scale up action and innovation ...................................................................19

7.1 We need to actively nurture innovation...................................................................... 19

7.2 We need a social innovation framework for the Biodiversity Hubs .............................. 19

8 Include a strategy for economic transformation for biodiversity restoration and protection ......................................................................................................................20

8.1 Key issues with the current economic system ............................................................. 21 8.1.1 Nature is not valued and accounted for in our current economic system ................................... 21 8.1.2 Current patterns of consumption and production harm biodiversity .......................................... 22

8.2 Vision, goals and actions for economic transformation ............................................... 23

8.3 Priority actions for economic transformation .............................................................. 25 8.3.1 Essential first step: Programme of work to develop robust framework, methods and tools for valuation of biodiversity and environmental services ................................................................................ 25 8.3.2 Engage top influential economic and finance institutions in economic transformation ............. 26 8.3.3 Make accurate and reliable information about biodiversity losses and gains transparent and freely accessible to the public ..................................................................................................................... 26

9 Concluding statement .............................................................................................28

10 References ..........................................................................................................29

Appendix 1: The ever-increasing destruction of the sea floor ...........................................30

Appendix 2: Information about sustainable financing for biodiversity protection ............32

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WWF-NEW ZEALAND SUBMISSION ON

THE BIODIVERSITY STRATEGY WWF-New Zealand is grateful for the opportunity to comment on the proposals for a Biodiversity

Strategy for Aotearoa New Zealand – Te Koiroa o te Koiora. Aotearoa’s Biodiversity Strategy will be

vital for the future wellbeing of Aotearoa’s precious nature and people, and for the world. We are

committed to supporting the Government in this important work.

1 Introduction

Nature is in a state of emergency. The health of our planet is failing at our hands. The WWF Living

Planet Index (see figure 1) tracks a 60 per cent decline in global wildlife populations in the past 40

years (see figure 1).1 New Zealand’s own unique diversity follows this catastrophic trend, with 90%

of coastal and terrestrial wetlands lost, two thirds of our indigenous forest lost, and 90% of our

seabirds, 26% of our marine mammals, and 80% of marine invertebrate threatened or at risk with

extinction.

Figure 1. WWF (2018)

1 There has been a 60% overall decline in vertebrate population sizes (i.e., mammals, mammals, birds, reptiles, amphibians and fish) between 1970 and 2014 (WWF Living Planet Report, 2018)

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The discussion document - Te Koiroa o te Koiora identifies the need for urgent action to stop the

decline of our precious biodiversity. It accurately identifies that biodiversity loss and climate change

are linked. They are two sides of a coin. Climate change drives biodiversity loss (see figure 2), and

this in-turn speeds up global warming because biodiversity is essential for a stable climate. Our

actions on both fronts should be integrated and considered part of one urgent movement of

national and global action.

Figure 2. WWF

Ensuring the health and wellbeing of our planet, people and all living things, will require all people

and all nations working together. It is vital to ensure Aotearoa’s Biodiversity Strategy aligns supports

and strengthens global initiatives under the Convention of Biological Diversity (CBD) and the

Sustainable Development Goals (SDG) and the Paris Agreement.

WWF-New Zealand can help ensure the Biodiversity Strategy is effectively linked to global initiatives

because our network is leading work at a global level. We are currently developing an ambitious,

science-based New Deal for Nature and People by 2020 that will comprehensively underpin the

SDGs and the Paris Agreement. The New Deal for Nature and People will coalesce strong

commitments by Heads of State in 2020 to strengthen global targets and mechanisms that will

reverse the loss of nature by 2030.

The New Deal for Nature has three major goals: 1) Zero loss of natural habitats, 2) Halve footprint of

production and consumption, and 3) Zero extinction of species. Each of these goals have fully

detailed sets of targets and pathways that describe how to achieve them. WWF-New Zealand is

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happy to present and share more information on the New Deal for Nature and People to the

Biodiversity Strategy team.

Figure 3. WWF (2029), The New Deal for Nature goals

2 Summary of key recommendations

Our major comment is that the Biodiversity Strategy needs to provide clearer pathways of action to

achieve long-term outcomes and goals. We support the long-term outcomes 1) Whakahou –

empower; 2) Tiaki – protect and restore; and 3) Wānanga – systems and behaviour, and we see that

theses align with the global New Deal for Nature and People goals, but in an Aotearoa specific way.

However, the long-term outcomes are not well linked-up with goals, and there is no clear pathway

of action to achieve them.

There are also major gaps in the strategy in the areas of marine biodiversity protection, empowering

kaitiakitanga and Mātauranga Māori, empowering people to connect to nature, innovation, and

economic transformation. This submission focuses on these identified gaps. We are confident that

terrestrial biodiversity will get strong attention and focus, so we do not provide detailed analysis or

advice about the terrestrial focused biodiversity goals, except for this one recommendation:

We recommend the Biodiversity Strategy provide stronger direction on protecting indigenous

forests. There should be no clearing or reduction of indigenous/ native forest, and marginal land

should be restored with planting and natural regeneration of native species. Care needs to be taken

to ensure the Emissions Trading Scheme sets strong incentives for protection and expansion of

indigenous forests.

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We recommend that Biodiversity Strategy:

• Include a strategy for marine biodiversity. We have drafted a vision: ‘The mauri (life

force) of our ocean is restored. Healthy productive ecosystems conserve

biodiversity, sustain and enrich our communities and enhance resilience for all

future generations.’ Achieving this will require 100% sustainable Ecosystems Based

Management (EBM); a network of Marine Protected Areas (MPAs) and climate change

resilience – all enabled through the elevation of indigenous leadership and true

Māori/Crown co-Governance.

• Include detailed goals and actions for empowering kaitiakitanga and Mātauranga Māori and

empowering New Zealanders to connect with, restore, and protect and live in harmony with

nature.

• Establish effective support for innovation and a social innovation framework to activate

action, collaboration, support and scaling of success for maximum biodiversity restoration

and protection.

• Including a strategy for economic transformation. We have drafted a vision: ‘Aotearoa’s

green economy restores and protects biodiversity and human wellbeing’, and

set out how this can be achieved through sustainable finance for biodiversity restoration and

protection, fully accounting for the value of biodiversity in our economic system, and

mainstreaming Biodiversity conservation into all economic activity.

This submission provides detailed advice about each of these key recommendations. But first some

small comments about the introductory sections of the consultation documents.

3 Comments about Part 1 of the consultation

document

Nature is essential

In the section titled “Nature is essential” p.13 – We appreciate the visual diagram of ‘The current

state of nature in Aotearoa New Zealand’, and we recommend you expand it so that it includes

different marine biodiversity zones (biogenic costal habitats e.g. sea grass, kelp forests, rocky reefs;

deep sea coral and sea mounts, upwelling and marine mammal hotspots, offshore island sea bird

colonies). You can use the state of the marine environment indicators, and other research which

shows the loss and destruction of different marine habitats i.e. loss of sea grass, kelp beds,

expansion of destruction/damage of sea floor by trawling. The official indicators reporting via Stats

NZ and MfE does not have the data on the annual expansion of seafloor destruction from trawling –

however WWF has collected that from MPI and this is attached as Appendix 1.

The biodiversity system

Pg. 22 figure 5 – “businesses” column needs to include banks, financial institutions, national level

communications. Figure 6 needs a circle around the word “you” as action at the scale of the

individual can be important and powerful too.

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Proposed values and principles – p. 29-30.

The principle of “sustainable use” needs clearer description/ definition. We recommend this means

managing within limits and ecosystem capacity. Limits should be set to enable and build resilient

ecosystems i.e. fisheries management buffers to ensure fisheries are resilient to climate change.

4 Include a strategy for marine biodiversity

The consultation document does not provide a clear plan for stopping the decline of marine

biodiversity or recovering/ restoring and protecting it. While we understand the intention of the

Biodiversity Strategy to cut across domains and take a holistic view of biodiversity, the fact is that

marine biodiversity has, for too long, been sidelined as conservation efforts have focused

predominantly on our terrestrial biodiversity.

Marine biodiversity must be a central focus of this Biodiversity Strategy. Healthy resilient ocean

ecosystems are vital for all life on earth, and how we manage impacts on our oceans will help

determine the wellbeing of future generations. Oceans provide 70% of the oxygen we breath2, they

store one third of the world’s carbon emissions, and 90% of the heat increase from global warming.3

Oceans need to be healthy to be able to continue to provide these essential live-giving ecosystem

services.

We recommend the Biodiversity Strategy has a clear marine biodiversity vision: The mauri (life

force) of our ocean is restored. Healthy productive ecosystems conserve biodiversity, sustain and

enrich our communities and enhance resilience for all future generations. In order to achieve this

long-term vision, we have mapped out a 2030 vision: 100% of our oceans are sustainably managed,

goals for 2030, 2025, and actions we need to be taking now.

We have separated different goals and streams of work for marine protection, fisheries

management, and recovery of threatened protected species in order to identify specific steps of

action. However, it is important to note that these different goals and streams of work are all very

strongly linked. For example, there is a strong link between fisheries management and marine

protection (see Fig. 4). Essential habitats of importance for fisheries management may need spatial

protection; protecting intact ecosystems via MPAs builds climate change resilience and adaptive

capacity of fish stocks and marine ecosystems more widely;4 and recovering threatened marine

species often requires fisheries management issues to be addressed.

2 https://www.nationalgeographic.org/activity/save-the-plankton-breathe-freely/ 3 Intergovernmental Panel on Climate Change, 2013 4 Callum et al. (2017).

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Figure 4, WWF.

You will also see that some recommended actions are steps to achieve multiple goals. For example,

100% independent monitoring of fishing (via observer or camera) is needed to achieve two goals:

effective fisheries management, and protected species recovery. Also, a trawl footprint freeze will

be needed to achieve the goals of: halting the decline of critical and vulnerable ecosystems and

habitats; improving fisheries management (i.e. managing impacts from fisheries) as well as the goal

of ensuring protected species (such as corals) are not further threatened. A trawl footprint freeze –

is not a ban on all trawling, but a ban on trawling in new, virgin (un-trawled) areas.

Achieving these marine biodiversity goals will be facilitated through a strong working relationship

with Iwi, hapu and whanau, and we recommend that this strategy is viewed in line with our

‘empowering kaitiakitanga’ section. Whilst the Biodiversity Strategy recognises the significance of

environmental wellbeing to physical well-being in Te Ao Māori and includes a system shift for

empowering kaitiakitanga and Mātauranga Māori, there needs to be clear pathways to achieve this.

The marine Biodiversity Strategy goals and actions are outlined below, and mapped out Figure 5.

4.1 Vision and goals for marine biodiversity

Overarching vision for the ocean

The mauri (life force) of our ocean is restored. Healthy productive ecosystems conserve biodiversity,

sustain and enrich our communities and enhance resilience for all future generations

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By 2050

• The full extent of marine ecosystems and habitats are intact, functioning, and resilient and

biodiversity is protected.

• Fisheries resources are abundant, resilient and managed within ecosystem limits.

• Protected marine species are thriving and resilient; and bycatch of seabirds, corals, and

marine mammals is reduced to zero.

By 2030

• Aotearoa New Zealand has worked alongside Māori and marine stakeholders to establish an

effective and well connected network of fully or highly protected marine areas, covering at

least 30 percent of all habitats (incl. critical areas, biodiversity hotspots and culturally

significant sites). Effective co-monitoring and co-management plans are in place.

• The decline of critical and vulnerable ecosystems and habitats e.g. biogenic habitats, corals,

seagrass and mangrove areas, has been halted.

• Degraded marine areas have been restored and biodiversity is recovering.

• Knowledge about Taonga species and their life histories has been built and there are

conservation plans in place to enable customary take.

• World leading Ecosystem based fisheries management (EBFM) is effectively managing

fisheries within a wider Ecosystem Based Management (EBM) system. This includes

effective management of direct and indirect fisheries impacts on species and ecosystems

and managing multiple stocks at levels that ensure their resilience and natural adaptive

capacity to environmental fluctuations and climate change. Resilience against climate

change is a key objective imbedded in fisheries related legislation and management.

• Cumulative anthropogenic pressures/impacts on coastal and marine ecosystem are being

managed within sustainable limits everywhere, land-based impacts on the West Coast

North Island marine ecosystem (the habitat of the Māui dolphin) have halved by 2030,

and wetlands on the Kapiti Coast have been restored and expanded by at least 30% by

2030.

• Climate change risks to marine biodiversity, marine ecosystems and species are being

effectively managed and are incorporated into all planning and management activities.

• Protected marine species are no longer threatened by human activities.

By 2025

• All areas of significant marine biodiversity are mapped, and effective participatory

processes are underway to establish a network of MPAs covering 30% of all marine

habitats, according to defined objectives and priorities for protection and management.

• Indigenous communities are leading the identification and establishment of key strategies

to conserve biodiversity (i.e. through spatial management and other legislative

frameworks that are appropriate).

• Aotearoa is recognised for its indigenous leadership and use of Mātauranga Māori as a key

strategy to restore biodiversity.

• Critical and vulnerable marine ecosystems and habitats, particularly biogenic habitats,

corals, seagrass and mangrove areas, have been identified and mapped and are prioritised

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for active threat management, restoration and protection. Mātauranga Māori is used in

this process to identify significant areas for marine biodiversity restoration and

conservation, and tangata whenua are being supported to achieving their priority actions.

o Pass the Kermadec/Rangitāhua Ocean Sanctuary Bill as part of a wider vision to

restore and revitalize the ecosystems of the far north of Aotearoa (Te Haumihi).

o Pass Reformed, fit for purpose, MPA Legislation that is bold and innovative.

o Establish the mechanisms to implement legislation – national level science support

and coordination, clear co-Governance with accountability for driving the MPA

network establishment, effective processes and support for indigenous and local

leadership to drive MPA work at local levels.

o Trawl footprint freeze5 to avoid any new destruction of vulnerable protected species

on the sea floor and removal of threat of trawling from areas identified as

vulnerable marine ecosystems (VMEs).

• The Quota Management System is evolving into effective ecosystem based fisheries

management (EBFM) (multi-stock assessment, more effective management of fisheries

impacts, with resilience against climate change as a key objective).

o Review legislation to enable EBFM.

o Further develop and utilise EBFM science and participatory tools provided by the

Sustainable Seas National Science Challenge and other available resources.

o 100% independent monitoring of fishing activity.

• There are effective systems for assessing and managing cumulative impacts on coastal and

marine ecosystems including setting precautionary water quality objectives (as in the NPS on

fresh water management) for waterways, estuaries and marine environment that considers

future climate change implications.

• The West Coast North Island (the habitat of the Māui dolphin) is a test case and model for

cumulative impacts, and mountains-to-sea ecosystem-based-management (EBM).

o Develop effective systems and tools for cumulative impacts assessment and

management (already happening through Sustainable Seas) and enable these

systems with legislative review, capacity building and support.

o Significantly invest (e.g. 15 million dollars over 5 years) in two EBM case studies: 1)

cumulative impacts management of sedimentation, waste, nutrient and pollutants

runoff from urban and farming sources, and for wetland and estuary restoration for

the West Coast North Island, and 2) Mountains-to-Sea EBM, conservation corridor

and connectivity project for the Kapiti Coast.

• No further decline in the number and extent of coastal and freshwater wetlands.

o Map and protect and actively restore all wetlands.

5 A trawl footprint freeze would mean that Trawl fishing could not go into any new (virgin/ un-trawled areas) without an ecological assessment that shows no vulnerable, sensitive habitats or protected species will be impacted.

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• Climate change resilience and adaptation are key objectives built into fisheries

management, marine protection work, protected species management.

o Build science about climate change impacts on marine biodiversity, marine

ecosystems and species and integrate it into the key science tools used to inform

management e.g. risk assessments tools i.e. SEFRA, stock assessments, MPA and

spatial planning.

o Ensure enabling climate change resilience and adaptation is a key objective in

legislative review (of all natural resource management legislation – fisheries, MMPA,

MRA, RMA, Crown Minerals, EEZ etc.).

• In-line with the New Deal for Nature and People goal for zero extinction of species – we

need effective bycatch management system for all protected marine species. This includes:

o 100% independent monitoring of fishing activity.

o Setting bycatch limits that are biologically sustainable (ensuring population

resilience in the context of multiple cumulative threats and climate change) and

align with the value of New Zealanders (including setting the limit at zero for

threatened, endangered and/or declining populations).

o Setting clear policy that drives bycatch towards zero.

o Review of marine/fisheries legislation to enabling effective bycatch management.

o Trawl footprint freeze to avoid any new destruction of vulnerable protected species

on the sea floor and restricting sea floor trawling in areas classified as vulnerable

marine ecosystems (VMEs) – to allow for recovery in these areas.

4.2 Immediate actions

We have identified the top five immediate actions that can drive change in the short-term. These

are essential immediate steps in the pathway to achieving the 2025, 2030, and 2050 goals.

4.2.1 Demonstrate Commitment to marine protection through passing the

Kermadec/Rangitāhua Ocean Sanctuary Bill and developing a reformed

MPA Policy that is bold and innovative.

Enabling marine protection at the scale needed to ensure healthy and thriving oceans should receive

concentrated focus and action in the next few years. New Zealand was one of the first countries to

establish marine reserves, and to prove their benefit for protection and recovery of marine

biodiversity. However, our 44 marine reserves are tiny, on average 13 sq km, and all together they

protect less than 1% of our oceans in marine reserves. Please note that while the Benthic Protected

Areas (BPAs) provide protection from sea floor trawling, they are a fishery management tool and do

not count as MPAs.

This means we are far behind the goals we have set for ourselves for marine protection, as well as

international commitments we have made.

• Our previous NZ Biodiversity Strategy goal was to protect 10% of our marine environment by

2010.

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• We also signed up to the convention of biological diversity Aichi target which is to protect

10% of our ocean by 2020.

Currently, scientists determine that we should protect at last 30% of each marine biogeographic

region to avert large-scale extinction in our seas as they warm and acidify with climate change.6 “In

order to maintain some naturally functioning food webs supported by large predators and associated

ecosystem services in this era of changing climate, a greatly expanded network of effective, fully

protected marine protected areas is needed that encompasses global marine biodiversity.” (Edgar et

al., 2018, p1)

We need to rapidly step up our action and become leaders once again. We can do this almost

immediately by passing the Kermadec/Rangitāhua Ocean Sanctuary Bill. This should be done as part

of a wide framework for 100% sustainable management in the marine area of the Far North (Te

Haumihi) in line with the aspirations of the mana whenua, Ngati Kuri. We also need the long

awaited Marine Protected Areas (MPA) Legislation, and the mechanisms to implement legislation.

4.2.2 100% independent monitoring of fishing activity

Accidental capture of protected marine species such as native dolphins, and seabirds and protected

corals in fishing operation (bycatch) is one of the most urgent threats affecting the health of native

marine species. In some cases, such as Hector’s dolphins, bycatch has likely caused the local

extinction of populations. Bycatch of highly endangered seabirds such a black petrels, yellow eyed

penguin, and Antipodean albatross may be the major threat currently driving populations down.

New Zealand will not be able to tackle the problem of protected species bycatch without vastly

greater monitoring coverage. There are simply not enough fisheries observers to go on the boats,

and the expense and practicality of putting observers on boats means that for some fleets in

particular – such as inshore set net, observer coverage is less than 2% of fishing effort.7

100% independent monitoring of fisheries operations is absolutely essential to achieve several of the

goals in the marine Biodiversity Strategy including those to improve fisheries management, and

management of impacts on protected species. Monitoring via fisheries observers or electronic

camera monitoring will providing essential data for ecosystem bases fisheries management, and to

understand the size and nature of protected species bycatch problems which is essential to enable

effective problem solving.

4.2.3 Trawl footprint freeze and stop further trawling in areas classified as

“vulnerable”

A trawl footprint freeze is needed to achieve the goals of: halting the decline of critical and

vulnerable ecosystems and habitats; improving fisheries management (i.e. managing impacts from

6 Marine Conservation Institute (2016)

7 See the Dragonfly Science website to explore monitoring coverage in different fisheries.

(https://psc.dragonfly.co.nz/)

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fisheries) as well as the goal of ensuring protected species (such as corals) are no longer threatened.

A trawl footprint freeze would stop trawling new (virgin/ un-trawled) areas without an ecological

assessment that shows no vulnerable, sensitive habitats or protected species will be impacted.

4.2.4 Review legislation

Within the first five years of the new Biodiversity Strategy, natural resource management legislation

covering marine and land will need to be reviewed to remove barriers and enable the various goals

of the Biodiversity Strategy. Key objectives of this review must be to enable:

• Tangata whenua to practice their kaitiakitanga role and take a lead in governance systems

from local to the national level.

• Climate change resilience and adaptation to be a key objective in all natural resource

management legislation – fisheries, MMPA, MRA, RMA, Crown Minerals, EEZ etc.

• Ecosystem-based management widely, and in particular for fisheries.

• Effective protected species bycatch management.

4.2.5 EBM case studies – West Coast North Island case study for cumulative

impacts and Kapiti Coast corridor of conservation and Mountain to

Seas management

We recommend significant investment and commitment is provided through the Biodiversity

Strategy to implement EBM in two specific case study areas. The purpose of this would be to

develop and utilise effective systems and tools for cumulative impacts assessment, and mountains-

to-sea management, and enable these systems with legislative review, capacity building and

support.

The West Coast North Island (WCNI) is a perfect case study area to develop effective management of

cumulative impacts from land into the marine environment. There are complex mix of threats

affecting the health of marine, estuary and wetland ecosystems on the WCNI including

sedimentation, pollution from towns and cities, agricultural runoff the parasite toxoplasmosis

coming into the marine environment from cat faeces. There is extreme urgency to reduce these

impacts. The latest science shows that in order to stop the extinction of Māui dolphins, we need to

reduce human caused impacts on Māui dolphin by 50%- 75% in the next ten years.8

We recommend investment, for example, 10 million dollars over 5 years for cumulative impacts

management of sedimentation, waste, nutrient and pollutants runoff from urban and farming

sources, and for wetland and estuary restoration for the West Coast North Island.

The second case study should be to develop a corridor of conservation and mountains-to-sea

management for the Kapiti Coast. This will involve working with multiple stakeholders, local

community and tangata whenua groups to restore the unique wetland, sand dune, estuary and

marine ecosystems between Paekakariki to Levin.

8 Cooke et al. (2019).

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Figure 5, WWF.

By 2050

By 2030: 100% of our oceans are sustainably managed

The full extent of marine

ecosystems and habitats are

intact, functioning, and

resilient and biodiversity is

protected

Fisheries resources are

abundant, resilient and

managed within ecosystem

limits.

Protected marine species are

thriving and resilient; and

bycatch of seabirds, corals,

and marine mammals is

reduced to zero.

1. Aotearoa New Zealand has

worked alongside Māori and

marine stakeholders to

establish an effective and well

connected network of fully or

highly protected marine areas,

covering at least 30 percent of

all habitats (incl. critical

areas, biodiversity hotspots

and culturally significant

sites). Effective co-

monitoring and co-

management plans are in

place.

2. The decline of critical and vulnerable ecosystems and habitats, (e.g. particularly biogenic

habitats, corals, seagrass

and mangrove) has been halted, and biodiversity

in degraded marine areas

is recovering.

3. World leading

Ecosystem based

fisheries management

(EBFM) is effectively

managing fisheries

within a wider

Ecosystem Based

Management (EBM)

system.

4. Cumulative anthropogenic pressures/impacts on

coastal and marine

ecosystem are being

managed within

sustainable limits

everywhere, and land-

based impacts on the West

Coast North Island marine

ecosystem (the habitat of

the Māui dolphin) have

halved by 2030,and

wetlands have expanded in

Kapiti by 30%.

5. Climate change risks to

marine/indigenous

biodiversity, marine

ecosystems and species

are being effectively

managed, and building

resilience is key objective

imbedded in relevant

legislation and

management.

6. Protected marine species

are no longer threatened

by human activities

By 2025

All areas of significant

marine biodiversity are

mapped (including

taonga species) and

effective participatory

processes are underway

to establish MPAs

according to defined

objectives and priorities

for protection and

management.

Critical and vulnerable marine

ecosystems and habitats,

particularly biogenic habitats,

corals, seagrass and mangrove

areas, have been identified

mapped and prioritised for

active threat management,

restoration and protection.

Mātauranga Māori is used in

this process to identify

significant areas for marine

biodiversity restoration and

conservation, and tangata

whenua are being supported to

achieving their priority

actions.

The Quota Management

System is evolving into

effective ecosystem based

fisheries management

(EBFM) (multi-stock

assessment, more

effective management of

fisheries impacts, with

resilience against climate

change as a key

objective.

There are effective systems for

assessing and managing

cumulative impacts on coastal and

marine ecosystems including limits

on land-based pollution into

waterways, estuaries and marine

environment that take climate

change implications into account.

The West Coast North Island (the

habitat of the Māui dolphin) is a

test case and model for cumulative

impacts management, and Kapiti

Coast is a case study for

Mountains-to- Sea EBM and

wetland restoration.

Actions

Now - 2025

Climate change resilience

and adaptation are key

objectives built into

fisheries management,

marine protection work,

protected species

management and

indigenous biodiversity.

Effective protected

species bycatch

management,

innovation, and

continual

improvement is

driving bycatch

towards zero.

To achieve 2030 goals 1, 2, 3, 5 and 6

• Pass MPA legislation that is fit for the

times and has been developed

alongside tangata whenua.

• Establish the mechanisms to

implement legislation – national level

science support and coordination, clear

co-governance with Māori and

accountability, effective processes and

support for indigenous and local leadership.

• Pass the Kermadec/Rangitāhua Ocean

Sanctuary Bill within a framework for

sustainable management (Te

Haumihi).

To achieve 2030 goal 2 and 3 • Review legislation to

enable EBFM.

• Further develop and utilise

EBM science and

participatory tools

provided by the

Sustainable Seas National

Science Challenge and

from other sources.

• 100% independent

monitoring of fishing

activity.

• Trawl footprint freeze and

halt in areas identified as

VMEs.

To achieve 2030 goal 4 • Develop effective systems and

tools for cumulative impacts

assessment and management

(already happening through

Sustainable Seas) and enable

these systems with legislative

review, capacity building and

support.

• Significantly invest (e.g. 10

million dollars over 5 years)

for cumulative impacts

management of sedimentation,

waste, nutrient and pollutants

runoff from urban and farming

sources, and for wetland and

estuary restoration for the

West Coast North Island, and

the Kapiti Coast.

• Map, protect all wetlands and

support wetland restoration.

To achieve 2030 goal 5 • Science about climate

change impacts on marine

biodiversity, marine

ecosystems and species is

developed and integrated

into the key science tools

used to inform

management e.g. risk

assessments tools i.e.

SEFRA, stock

assessments, MPA and

spatial planning

• Review legislation fisheries,

MMPA, MRA, RMA, Crown

Minerals, EEZ etc.) and

implementation Wai262 to

enabling climate change

resilience and adaptation

To achieve 2030 goal 6 • 100% independent

monitoring of fishing

activity.

• Setting bycatch limits that

are biologically sustainable

(will enable population

resilience in the context of

multiple cumulative threats

and climate change) and align with New

Zealander’s values.

• Setting clear policy that

drives bycatch reduction

over time.

• Trawl footprint freeze and

halt in areas identified as

VMEs.

No further decline in the number

and extent of coastal and

freshwater wetlands.

Marine biodiversity vision: The mauri (life force) of our ocean is restored. Healthy

productive ecosystems conserve biodiversity, sustain and enrich our communities and

enhance resilience for all future generations

15

5 Strategy for empowering kaitiakitanga and

Mātauranga Māori

By 2030

• Enhance the mauri, mana and wellbeing within ecosystems (which includes people).

• Tangata whenua are supported to exercise their role as kaitiaki.

• Effective management and monitoring led by tangata whenua to enable an abundance of

local indigenous species, as well as enhanced mahinga kai and cultural take.

• Encourage Maori-led restoration and research methods that may be supported by science

and innovative technology.

By 2025

• Te Ao Māori perspective is embedded throughout the biodiversity system, and tangata

whenua are empowered as kaitiaki.

o Actions: Traditional knowledge systems are incorporated into planning to increase

biodiversity through active on the ground transformative change of landscapes and

waterscapes by iwi/hapu/whanau and community groups.

o Ensure decision-making includes Te Ao Maori perspective. For example viewing

ecosystems through a Te Ao Maori lense where interrelationships exist between all

living things.

o Holistic approaches to conservation and enhancing indigenous biodiversity.

• Mātauranga Māori is driving biodiversity management and actions from the local to national

levels, tangata whenua are key decision-makers at all levels of governance and

management.

o Actions: Ensure Māori hold key roles in newly established biodiversity system

governance structures.

o Actively encourage tangata whenua to be involved in setting up the local

biodiversity hubs.

o Establish a programme to facilitate graduates to move into roles at DOC and other

organisations.

o Support and fund Māori to tell their biodiversity conservation stories and share

successes in indigenous approaches to conservation at international fora and

conferences, and to be part of New Zealand delegations and teams working on

international agreements (e.g. Intergovernmental Panel on Biodiversity and

Ecosystem Services and the Convention on Biological Diversity).

o Enable opportunities for iwi/hapu to practically contribute to enhancing local

ecosystem wellbeing, cultural survival and knowledge development.

• Tangata whenua are leading local-level management and actively enhancing the

biodiversity and wellbeing of whenua, awa, roto and moana with which they associate.

16

o Actions: Increase employment opportunities for tangata whenua to support

iwi/hapu environmental aspirations.

o Support tangata whenua kaitiaki to work for the iwi and rohe to implement Iwi

Management Plans and ensure local biodiversity related action.

• Government recognise the Te Tiriti o Waitangi rights and tikanga of Maori and provide

support for the exercising of these rights in relation to increasing biodiversity. Respect for

and enabling of iwi rights and interests relating to biodiversity conservation, management,

restoration is measurably improving.

o Actions: Agencies to work with iwi to develop ways to better respect and enable

iwi rights and interests relating to biodiversity conservation. For example DOC to

work with iwi/hapu in relation to public conservation land, regional councils

working with iwi environmental trusts to restore sites of significance etc.

o Develop and roll out a simple online survey to assess how well iwi rights and

interests are respected and enabled, and what the key barriers and opportunities

are to better enable practice of kaitiakitanga, with the purpose of establishing

baseline data to monitor progress.

o Review key legislation that relates to biodiversity to ensure it recognises and

provides for kaitiakitanga and mātauranga Māori.

• There are effective streams of support and funding for tangata whenua to manage taonga

species (mahinga kai and others) and use Mātauranga Māori to identify, manage and

monitor the health of these species and related ecosystems upon which their health

depends.

o Actions: Establish funds to effectively ensure iwi/hapu led conservation and

restoration projects result in transformative change of ecosystems.

o Support Whare Wananga, Kura Kaupapa, and Kohanga Reo and other Maori-led

education initiatives to assist with the inclusion of rangatiratanga, kaitiakitanga,

ukaipotanga, pukengatanga and other cultural values. For example, planting native

trees on iwi restoration projects, Kawenata, sites of significance, kaumatua sharing

local historic narratives, cultural health monitoring etc.

17

Figure 6, WWF.

By 2030: Empowering Kaitiakitanga And Mātauranga Māori

Enhance the mauri,

mana and wellbeing

within ecosystems

(which includes

people).

Tangata whenua are

supported to exercise

their role as kaitiaki

Effective management and

monitoring led by tangata

whenua to enable an

abundance of local indigenous

species, as well as enhanced

mahinga kai and cultural take.

By 2025

Actions

Now – 2025

1) Te Ao Māori

perspective is embedded

throughout the

biodiversity system, and

tangata whenua are

empowered as kaitiaki.

2) Mātauranga Māori

is driving biodiversity

management and

actions from the local

to national levels,

tangata whenua are key

decision-makers at all

levels of governance

and management.

• Traditional knowledge

systems are incorporated

into planning to increase

biodiversity through

active on the ground

transformative change of

landscapes and

waterscapes by

iwi/hapu/whanau and

community groups.

• Ensure decision-making

includes Te Ao Maori

perspective. For example

viewing ecosystems

through a Te Ao Maori

lense where

interrelationships exist

between all living things.

• Holistic approaches to

conservation and

enhancing indigenous

biodiversity.

• Ensure Māori hold key roles

in newly established

biodiversity system

governance structures.

• Actively encourage tangata

whenua to be involved in

setting up the local

biodiversity hubs.

• Establish a programme to

facilitate graduates to move

into roles at DOC and other

organisations.

• Support and fund Māori to

attend international fora and

conferences, and to be part of

New Zealand delegations and

teams working on

international agreements (e.g.

Intergovernmental Panel on

Biodiversity and Ecosystem

Services and the Convention

on Biological Diversity).

• Enable opportunities for iwi/hapu to practically

contribute to enhancing local

ecosystem wellbeing, cultural survival and knowledge

development.

3) Tangata whenua are

leading local-level

management and

actively enhancing the

biodiversity and

wellbeing of whenua,

awa, roto and moana

with which they

associate.

• Increase employment

opportunities for

tangata whenua to

support iwi/hapu

environmental

aspirations.

• Support tangata

whenua kaitiaki to

work for the iwi and

rohe to implement Iwi

Management Plans

and ensure local

biodiversity related

action

4) Government recognise the

Te Tiriti o Waitangi rights and

tikanga of Maori and provide

support for the exercising of

these rights in relation to

increasing biodiversity.

Respect for and enabling of

iwi rights and interests relating

to biodiversity conservation,

management, restoration is

measurably improving.

• Agencies work with iwi to

develop ways to better respect

and enable iwi rights and

interests relating to

biodiversity conservation.

• Develop and roll out a simple

online survey to assess how

well iwi rights and interests

are respected and enabled,

and what the key barriers and

opportunities are to better

enable practice of

kaitiakitanga, with the

purpose of establishing

baseline data to monitor

progress.

• Review key legislation that

relates to biodiversity to

ensure it recognises and

provides for kaitiakitanga and

mātauranga Māori.

5) There are effective

streams of support and

funding for tangata whenua

to manage taonga species

(mahinga kai and others) and

use Mātauranga Māori to

identify, manage and monitor

the health of these species

and related ecosystems upon

which their health depends.

• Establish funds to

effectively ensure iwi/hapu

led conservation and

restoration projects result in

transformative change of

ecosystems.

• Support Whare Wananga,

Kura Kaupapa, and

Kohanga Reo and other

Maori-led education

initiatives to assist with the

inclusion of rangatiratanga,

kaitiakitanga, ukaipotanga,

pukengatanga and other

cultural values. For

example, planting native

trees on iwi restoration

projects, Kawenata, sites of

significance, kaumatua

sharing local historic

narratives, cultural health

monitoring etc.

Encourage Maori-led

restoration and research

methods that may be

supported by science

and innovative

technology.

18

6 Empowering New Zealanders to connect

with, restore, protect and live in harmony

with nature

There needs to be more detail about how the Biodiversity Strategy will enable the outcome: “All

New Zealanders to connect with nature, engage in its restoration and protection and understand

its value in supporting intergenerational wellbeing”

We recommend the following additional goals and actions:

• By 2030: Urban biodiversity in every major centre is enhanced by at least 30%; and

Wellington is the “Greenest city in the world”.

o By 2025: Programmes to enhance urban biodiversity e.g. “living cities” to improve

connection with nature and wellbeing of urban communities are being

implemented.

o Focused work to connect and expand biodiversity sanctuaries and hotspots around

Wellington city.

▪ Today: Develop Programmes to enhance urban biodiversity e.g. “living

cities” to improve connection with nature and wellbeing of urban

communities.

• By 2030: Every school is engaged in biodiversity restoration activities and New Zealand

schools collectively will achieve a biodiversity net benefit of at least 30% by 2030.9

o By 2025: Understanding the value of biodiversity and active engagement and

restoration of biodiversity is built into the education system at every level.

▪ Today: Educational review.

• By 2030: Communities are actively engaged and empowered to restore and protect

biodiversity.

o By 2025: A complete network of biodiversity hubs across New Zealand is driving

social innovation for biodiversity protection and innovation, collective action,

connection of people with each-other and nature.

▪ Today: Develop a social innovation framework as the foundation for

biodiversity hubs (see section 6 for more about this).

9 This requires the ability to account and value biodiversity. Please see section … on ‘Biodiversity accounting.’

19

7 Build a system of support for innovation

and a social innovation framework to

mobilise and scale up action and innovation

We fully agree with the statement that for us to be successful in achieving our aspirations for nature,

we must continually innovate. We need to learn from and adapt approaches towards challenges. We

need to look for new ways to solve problems, and experiment without the luxury of complete

knowledge.

As presented, ‘Shift 5 – innovating for the future’ focuses on science, technology, and data as the

key to managing biodiversity. Although this focus has merit for monitoring and measuring

biodiversity-related research activities, as an innovation strategy with the intention of effecting

change and solving environmental problems, in our opinion, this focus alone is insufficient.

7.1 We need to actively nurture innovation Lack of support for innovation is a major barrier. There is very little support out there for new

products, systems, and solutions that are very new, unproven, with no backing or assurance of

success. Innovations that have potential to change the game in biodiversity restoration and

protection often do not meet the criteria of current funding streams. By their very nature,

innovative ideas do not fit well in existing boxes. Innovators and inventors may not be skilled at

writing funding proposals, marketing or selling their innovations. The Biodiversity Strategy should

enable careful and focused nurturing of innovation. A good example is WWF-New Zealand’s 9-Wire

programme which provides tailored and targeted and wrap around support for innovation.10

7.2 We need a social innovation framework for the

Biodiversity Hubs In analysing all aspects of the consultation proposals we see the need for social innovation

frameworks to create the shifts and changes required to achieve the Biodiversity Strategy vision and

goals. Social innovation frameworks resolve problems through involving and empowering people,

catalysing more effective or new capabilities, interactions, and relationships. Social innovation

harnesses the problem solving power of many small groups actively engaged in trialling and

experimentation. Once proven successful, the innovation is transplanted to other areas for

implementation or scaled as applicable. There are many examples of social innovation in the EU as

well as social innovation frameworks, which can be lifted and used for the Biodiversity Strategy.

We see particular potential for a social innovation framework to be the basis of the proposed

network of Biodiversity Hubs. We think the Biodiversity Hubs are a great idea, however these must

10 Please be in contact if you would like us to present our 9-Wire programme to you, or for some more

information please see: https://www.wwf.org.nz/take_action/9wire/

20

not be an extension of Government departments, like regions DOC offices. They should be bottom-

up, engaging, adaptive, nimble, linked, sharing ideas and producing innovative solutions. The

network of hubs can be a mechanism to find the innovative solutions that can be scaled for

maximum biodiversity restoration and protection impact.

WWF-New Zealand has developed a social innovation framework for our own 9-Wire programme,

and are keen to talk with the Biodiversity Strategy more about how such a framework could be used

nationally.

8 Include a strategy for economic

transformation for biodiversity restoration

and protection

Achieving the Biodiversity Strategy vision and the 2070 goals will require unprecedented economic

transformation. We need to move away from a system that values profit from increasing

consumption of natural resources, and passes the price of biodiversity loss and costs of

environmental destruction to the poor and marginalised and to future generations. We need to

move to a system where the full value of nature is accounted for, where biodiversity restoration and

protection is a central function of a new innovative green economy, imbedded and mainstreamed at

the highest levels of our economic and financial institutions and part of status quo practice for all

businesses.

Imagine a future where every business reports transparently for the public, not only the monetary

profits and losses, but also the environmental costs and benefits they generate. Imagine companies

competing to have the best environmental profiles, investors targeting the best biodiversity net

positive portfolios, and consumers being fully empowered (i.e. with full, honest and easily accessible

information) to drive an increasingly clean, green economy.

The consultation document provides no clear goals, steps or pathways to achieve this kind of vision.

There is significant work going on through the Aotearoa Circle’s financial sustainability arm which

can inform the development of a more comprehensive strategy for economic transformation in the

Biodiversity Strategy. However, in this section we give it a go. We identify some key issues with the

current economic systems and we provide some ideas about what might go into a strategy for

economic transformation for biodiversity.

21

8.1 Key issues with the current economic system

8.1.1 Nature is not valued and accounted for in our current economic system

Each year, around US$125 trillion worth of ecosystem services are provided to the global economy.11

See figure … for examples of ecosystem services. The central problem is that our current decision-

making and economic systems globally and in New Zealand, don’t account for these ecosystem

services. This is essentially a market failure – economic activities benefit individuals, companies,

corporations – but the cost of biodiversity loss is unquantified and spread across society and into the

future. The result of this market failure is clearing of native forest, draining wetlands, agricultural

runoff, sea floor trawling and other destructive modes of extraction and industry.

Figure 7, WWF (2018).

11 WWF (2018)

22

Legislation and decision-making processes perpetuate the market failure – where the value of

nature is not accounted for. For example, the Fisheries Act 1996, requires enabling “utilisation” and

“sustainability”, but utilisation more often than not trumps sustainability, and decisions that restrict

utilisation for sustainability purposes often result in legal action from the fishing industry. Since

2002, the fishing industry has defeated measures to restrain fishing for the conservation of

protected species in four court cases.12

The problems of not accounting for the value of nature are also pervasive throughout the financial

system. The major obstacles with our Finance system include:

• Directors, managers, trustees and financial advisors do not explicitly require environmental,

social and governance (ESG) factors to be considered.

• Financial decision-making is primarily made in favour of short-term financial returns, often

at the social and environmental expense.

• The financial system does not reflect long-term values and costs.

• Accurate and comparable environmental and social data is the basic building block for

making financial decisions, but is not readily available.

• Businesses have no obligation to disclosures non-financial reporting. eg. Task Force on

Climate-related Financial Disclosures (TCFD).

• Low levels of awareness and capability regarding sustainability, responsible investment and

sustainable finance exists.

8.1.2 Current patterns of consumption and production harm biodiversity

Patterns of consumption and production globally and in New Zealand are underlying drivers of

biodiversity loss, and it is vital that we transition away from the most destructive patterns of natural

resource consumption and production. Global initiatives including the new CBD targets, will require

clear goals. New Deal for Nature and People is setting a goal that by 2030, there is a 50% reduction

in the negative impact of production and consumption, with the remaining 50% on a path to

achieving sustainability by 2050.

12 Section 10 of the Fisheries Act 1996 is supposed to enable Ministers to make precautionary decisions, however it is arranged in a way that has resulted in precautionary decisions being denied, delayed or diminished by the court (Modeste, 2011; Wheen, 2012).

23

Figure 8, WWF (2018).

The discussion document does not provide adequate analysis of the patterns of consumption and

production in New Zealand (e.g. carbon consumption/ emissions, expansion or intensification of

agriculture) or their associated costs to the environment. We recommend that clear goals for

reducing the environmental impact of production and consumption by 50% by 2030 be included in

the Biodiversity Strategy.

8.2 Vision, goals and actions for economic transformation

Economic transformation vision:

Aotearoa’s green economy restores and protects biodiversity and human wellbeing.

2030 goal: “Economic growth is a net restorer, not a net subtractor, of our natural environment.”

(Section 2.2 “Vision”, p28). This is about fully accounting for the value of biodiversity in our

economic system.

2025 goal 3: National economic reporting takes full account of value of biodiversity

(economic, intrinsic, and for social cultural wellbeing) i.e. the net benefit and costs to

biodiversity from economic activity is a key objective of national accounting and reporting.

Actions for now – 2025:

▪ Programme of work to develop robust framework, methods and tools for

valuation of biodiversity and environmental services.

▪ Biodiversity metrics are imbedded into government performance measures

– including the living standards framework and wellbeing budget.

2025 goal 4: The value of biodiversity is central to national, regional and local economic

development strategies, poverty reduction strategies, planning processes, and accounted

for in natural resource-use decision-making.

24

Actions for now – 2025:

▪ Ensure RMA, land-use, coastal and marine resource use decisions take full

account of environmental services and biodiversity values. Performance

measures include: effective systems and processes for

biodiversity/ecosystem services valuation are being used in decision-

making; accurate and reliable information about ecosystem services,

biodiversity losses/ costs and gains is transparent and publicly accessible.

2030 goal: Aotearoa’s economy is set up to sustainably fund the restoration and protection of

indigenous biodiversity.

2025 goal 1: Top banking and financial institutions are committed to and driving economic

transformation to a green economy and sustainable financing of biodiversity restoration and

protection.

Actions for now – 2025:

▪ Engage top influential economic and finance institutions in developing

principles and a plan of action that will drive economic transformation to a

green economy and sustainable financing of biodiversity restoration and

protection. A lot of work is already happening through the Aotearoa

Circle.13

2025 goal 2: Effective biodiversity restoration and protection activities are supported/

linked with sustainable funding from private and corporate sources.

Actions for now – 2025:

▪ Biodiversity hubs provide expert support/ networking and linking to finance

restoration and protection actions.

▪ FMA (Financial Markets Authority) to provide guidance that incorporating

environmental and social factors in investment decisions.

▪ Require investment stakeholders over a certain size to have formal training

including sustainability.

▪ Incorporate reporting of non-financial data (such as energy consumption,

water use, carbon emissions).

Please see Appendix 2 for good examples of sustainable finance practices and initiatives.

2030 goal: “Biodiversity conservation is mainstreamed into all economic activity and every business

is helping to restore nature (this goal aligns with Aichi target 2 and 414)

13 For information about the Aotearoa Circle, see: https://www.theaotearoacircle.nz/

14 Aichi target 2: By 2020, at the latest, biodiversity values have been integrated into national and local

development and poverty reduction strategies and planning processes and are being incorporated into

national accounting, as appropriate, and reporting systems.

Target 4: By 2020, at the latest, Governments, business and stakeholders at all levels have taken steps to

achieve or have implemented plans for sustainable production and consumption and have kept the impacts

of use of natural resources well within safe ecological limits.

25

2025 goal 5: Major businesses and financial institutions are taking actions to achieve net

positive biodiversity conservation and restoration. Measures: the top 50 most

profitable/powerful businesses or institutions in New Zealand have a biodiversity pledge

and action plan to ensure net positive impact from their business on biodiversity.

Considering ESG factors is a normal and explicit part of the fiduciary duties for directors,

managers, trustees and financial advisors.

Actions for now – 2025:

▪ Workshop on mainstreaming biodiversity conservation into business -

involving experts who are already doing it, thought leaders on how to

achieve economic shifts and build incentives, and experts on legal and

regulatory mechanisms to create economic behavioural change.

▪ Support businesses to develop biodiversity pledges and action plans.

2025 goal 6: Effective incentives and market mechanisms are driving decisions that protect

and restore biodiversity.

Actions for now – 2025:

▪ Make accurate and reliable information about biodiversity losses and gains

associated with public and private business activities transparent and freely

accessible to the public. This should include information about GHG

emissions, water, waste to landfill, H&S incidents, diversity, pay gaps,

community engagement and human rights).

▪ Collect, accumulate and present environmental and social data for the big

institution (banks, insurance companies, Kiwisaver providers etc.).

▪ Require climate risk reporting aligned to the TCFD by large entities.

2030 goal: The environmental impact of production and consumption is reduced by 50% by 2030.

(We have not worked out what intermediary goals are yet, but please let us know if it would be

helpful for us to provide more on this)

8.3 Priority actions for economic transformation

We identify three top priority actions that will spur economic transformation from the top down as

well as the bottom up:

8.3.1 Essential first step: Programme of work to develop robust framework,

methods and tools for valuation of biodiversity and environmental

services

If we don’t first develop robust ways to value and account for biodiversity and ecosystem services,

we will not be able to achieve economic transformation. We need to be able to account for the

value of biodiversity in order for it to be a driver in national economic accounting and reporting –

including the Living Standards Framework and Wellbeing Budget. We also need methods to account

for the value biodiversity to ensure it is central to national, regional and local economic

development strategies, poverty reduction strategies, planning processes, and accounted for in

natural resource-use decision-making.

26

8.3.2 Engage top influential economic and finance institutions in economic

transformation

New Zealand should develop principles for banking and financial practices and commitments by

leading institutions that will drive required economic transformation to a green economy and

sustainable financing of biodiversity restoration and protection. The importance of top financial

institutions on-board was recently recognised at the UN. On the 22nd September 2019, at the 74th

session of The United Nations General Assembly (UNGA) the UN Environment Programme Finance

initiative (UNEP FI) Principles for Responsible Banking launched with 131 founding signatories from

49 countries and representing 30% of global banking transactions. The UN Secretary General said To

the bankers,: “Place your bets on the green economy, because the grey has no future”.

8.3.3 Make accurate and reliable information about biodiversity losses and

gains transparent and freely accessible to the public

If the public has accurate and easily accessible information about the biodiversity losses and gains

associated with public and private business activities, and the net losses and gains associated with

companies and brands, they are able to make informed choices that favour biodiversity restoration

and protection. We recommend:

• GHG emissions, water, waste to landfill, H&S incidents, diversity, pay gaps, community

engagement and human rights) in are presented in Annual Reports.

• Collect, accumulate and present environmental and social data for the big institution (banks,

insurance companies, Kiwisaver providers etc.)

• Require climate risk reporting aligned to the TCFD by large entities

This transparency can fix market failure (associated with imperfect information), and activate

consumer choice to drive change. This will in-turn create strong incentives for businesses to gain

social licence by producing net gains for biodiversity. We will know we are achieving this goal of

creating effective incentives and market mechanisms through these performance measures:

• transparent accounting shows that losses or cost to biodiversity are paid for by those who

benefit.

• the number and scope of activities that result in losses or cost to biodiversity are reducing in

number and scope;

• the number and scope of activities that result in benefits to biodiversity system are

increasing in number and scope.

27

By 2030

Aotearoa’s economic

activity sustainably

funds the restoration

and protection of

indigenous biodiversity.

Economic growth is

a net restorer, not a

net subtractor, of our

natural environment.

Biodiversity conservation

is mainstreamed into all

economic activity and

every business is helping

to restore nature

By 2025

Actions

Now - 2025

Economic transformation vision: Aotearoa’s green economy restores and protects biodiversity

and human wellbeing

1) Top banking and

financial institutions

are committed to and

driving economic

transformation to a

green economy and

sustainable financing of

biodiversity restoration

and protection

2) Effective

biodiversity

restoration and

protection activities

are supported/ linked

with sustainable

funding from private

and corporate

sources.

Engage top economic

and finance

institutions in

developing principles

and a plan of action

that will drive

economic

transformation to a

green economy and

sustainable financing

of biodiversity

restoration and

protection

Biodiversity hubs

provide expert

support/ networking

and linking to

finance restoration

and protection

actions

3) National economic

reporting takes full

account of value of

biodiversity (economic,

intrinsic, and for social

cultural wellbeing) i.e.

the net benefit and costs

to biodiversity from

economic activity is a

key objective of national

accounting and

reporting.

Programme of work to

develop robust

framework, methods

and tools for valuation

of biodiversity and

environmental services.

Biodiversity metrics are

imbedded into

government

performance measures

– including the living

standards framework

and wellbeing budget

4) The value of

biodiversity is central

to national, regional

and local economic

development

strategies, poverty

reduction strategies,

planning processes,

and accounted for in

natural resource-use

decision-making.

Ensure RMA, land-

use, coastal and

marine resource-use

decisions take full

account of

environmental

services and

biodiversity values.

5) Major businesses

and financial

institutions are taking

actions to achieve net

positive biodiversity

conservation and

restoration.

6) Effective

incentives and

market

mechanisms are

driving decisions

that protect and

restore

biodiversity

Workshop on

mainstreaming biodiversity

conservation into business

- involving experts who are

already doing it, thought

leaders on how to achieve

economic shifts and build

incentives, and experts on

legal and regulatory

mechanisms to create

economic behavioural

change.

Support businesses to

develop biodiversity

pledges and action plans.

Make accurate and

reliable information

about biodiversity

losses and gains

associated with public

and private business

activities transparent

and freely accessible to

the public including: GHG emissions, water,

waste to landfill, H&S

incidents, diversity, pay

gaps, community

engagement and human

rights); climate risk

reporting aligned to the

Task Force on Climate-

related Financial

Disclosures (TCFD)

Biodiversity The

environmental

impact of production

and consumption is

reduced by 50% by

2030

28

9 Concluding statement

WWF-New Zealand considers the Biodiversity Strategy to be extremely important for the future

wellbeing of Aotearoa’s precious nature and people, and for the world. New Zealand has a rich

history of innovating, and the world often looks to us to try and test new things. We are uniquely

capable of quickly developing effective models for biodiversity restoration and conservation, and we

have strong potential to enable indigenous leadership and effective models of co-governance. By

doing this work, and sharing our knowledge with the world, we can truly scale up biodiversity

conservation globally.

WWF-New Zealand looks forward to supporting the development of a Biodiversity Strategy that will

bend the curve of devastating loss of nature, and help to secure a safe planet where people live in

harmony with nature.

29

10 References

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Boris Worm, and Juan Carlos Castilla (2017). Marine reserves can mitigate and promote adaptation

to climate change. PNAS June 13, 2017. 114 (24) 6167-6175.

Cooke, J.; Constantine, R.; Hamner, R.M.; Steele, D.; Baker, C.S. (2019). Population dynamics

modelling of the Māui dolphin based on genotype capture-recapture with projections involving

bycatch and disease risk. Fisheries New Zealand Aquatic Environment and Biodiversity Report No.

216. doi:10.1111/j.1748-76

Edgar, G.J.; Ward, T.J.; Stuart-Smith, R.D. (2018). Rapid declines across Australian fishery stocks

indicate global sustainability targets will not be achieved without an expanded network of ‘no‐

fishing’ reserves. Aquatic Conservation.

Intergovernmental Panel on Climate Change (2013) Climate change 2013: The physical science basis.

Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on

Climate Change eds Stoker TF, et al., (Cambridge Univ Press, Cambridge, UK

Levin, S.A. and Lubchenco, J. (2008). Resilience, Robustness, and Marine Ecosystem-based

Management, BioScience , Volume 58, Issue 1.

Marine Conservation Institute (2016) ‘IUCN World Conservation Congress Passes Motion to Protect

30% of Ocean by 2030 by Large Margin.’ https://blog.marine-conservation.org/2016/09/iucn-world-

conservation-congress-passes-motion-to-protect-30-of-ocean-by-2030-by-large-margin.html

Modeste, D. (2011). ‘The Precautionary Principle and the Fisheries Act’ (2011) NZLJ 179.

Wheen, N.R. (2012). How the Law Lets Down the ‘Down-Under Dolphin’ – Fishing-Related Mortality

of Marine Animals and the Law in New Zealand. Journal of Environmental Law (2012).

Perry, R.I., Cury, P., Brander, K.M., Jennings, S., Möllmann, C. and Planque, B. (2010). Sensitivity of

marine systems to climate and fishing: concepts, issues and management responses. Journal of

Marine Systems 79: 427-435.

WWF. 2018. Living Planet Report - 2018: Aiming Higher. Grooten, M. and Almond, R.E.A.(Eds). WWF,

Gland, Switzerland

file:///Users/amanda/Downloads/lpr2018_full_report_spreads.pdf

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Appendix 1: The ever-increasing destruction

of the sea floor

In environmental reporting the Fisheries New Zealand tends to report that the annual area trawled

has declined over time.15 However annual area trawled is not the same as the overall impact. This

is because the recovery of benthic habitats and species can take centuries after fishing has ceased,

so the overall impact is the cumulative trawl footprint - which increases every year.

While the newly trawled areas are small in the vast scale of our oceans, if you were to draw a

comparison on land - the growing impacted area is significant. Over the five years from 2012/13 and

2016/17 is 386.3 km2 of virgin sea floor was trawled for the first time (this is not just filling in the

gaps - but new exploration). This is equivalent to 38,630 rugby fields (around 1 hectare big), or three

times the size of wellington (119.8km2).

Management of impacts on our deep sea environment is decades behind management on the land.

On land you would need a permit or impact assessment before you could go in and knock things

down from a native forest.

The data below represent the following, for data from 2012-13:

• new seafloor trawled each year – most of which is within cells that are already well

contacted by trawl gear and the “new area” could well be an effect of the jittering.

• summary of the new area trawled based on the new cells analysis, and this indicates new

areas being exploited or explored.

Area trawled (km2) for the first time for Deepwater Tier 1 and 2 fishstock targets (based on 1989/90–2015/16

analyses by Baird & Wood 2018, provided by Rich Ford to A.L. 12/06/2018 and information provided in OIA

request sent by MPI to WWF-NZ 12/02/2019).

Fishing Area trawled for the first time Main target/area

year Total New cell area

2012/13 2946.1 km2 45.5 km2 Most new cell area was from the southern

Chatham Rise in Statistical Areas 409 and

410 for HOK; off the southern west coast

South Island in Statistical Areas 032–034

for BAR; off northwest South Island

(Statistical Area 036) and off North-

eastern North Island in Statistical Area 004

for SCI; and to the north of Campbell Rise

in Statistical Areas 607 and 618 for SBW

15 https://www.mpi.govt.nz/news-and-resources/science-and-research/fisheries-research/

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2013/14 3091.7 km2 52.8 km2 Most new cell area was from the southern

Chatham Rise in Statistical Areas 408 and

409 for HOK; off the northwest South

Island in Statistical Area 036 for JMA; off

south-western South Island in Statistical

Area 031 for LIN; and on features off the

east coast North Island in Statistical Areas

045-047 for ORH

2014/15 2968.5 km2 129.0 km2 Most new cell area was from the

Challenger Plateau for ORH off the west

coast South Island in Statistical Areas 702

and 703

2015/16 2564.5 km2 76.6 km2 Most of this new cell area was trawled for

orange roughy across the north-eastern

Challenger Plateau in Statistical Area 701

2016/17 3021.8 km2

82.4km2 Most of this new cell area was trawled for

orange roughy across the West Coast

South Island in the Challenger Plateau,

Statistical Area 702 - 704

• Total area newly trawled areas – being exploited or explored for the first time between

2012/13 and 2016/17 is 386.3 km2.

• This is equivalent to 38,630 rugby fields (around 1 hectare big), or three times the size of

wellington (119.8km2).

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Appendix 2: Information about sustainable

financing for biodiversity protection

Some useful information about sustainable financing for biodiversity can be found through the links

below.

• Our Planet: Our Business

• The Central Banks and Supervisors’ Network for Greening the Financial System (NGFS) is a

group of 42 members and 8 observers (as of 16 July 2019) who have acknowledged that

“climate-related risks are a source of financial risks” and have published a set

of recommendations for its members to address those risks. WWF provided input to the

first comprehensive report of the NGFS. As a result of our engagement, in addition to its call

for action on climate, the report includes a call for environment-related work beyond

climate to “…achieve robust and internationally consistent climate and environment-related

disclosure.” In the forward to the report, the NGFS Chair noted that “going forward, the

NGFS also expects to dedicate more resources to the analysis of environmental risks.

• Net-Zero Asset Owner Alliance (more info attached) Link

“The members of the Alliance commit to transitioning their investment portfolios to net-zero

GHG emissions by 2050 consistent with a maximum temperature rise of 1.5C degrees above

pre-industrial temperatures, taking into account the best available scientific knowledge

including the findings of the IPCC, and regularly reporting on progress, including establishing

intermediate targets every five years in line with Paris Agreement Article 4.9. This

Commitment must be embedded in a holistic ESG approach, incorporating but not limited to,

climate change, and must emphasize GHG emissions reduction outcomes in the real

economy. Members will seek to reach this Commitment, especially through advocating for,

and engaging on, corporate and industry action, as well as public policies, for a low carbon

transition of economic sectors in line with science and under consideration of associated

social impacts. This Commitment is made in the expectation that governments will follow

through on their own commitments to ensure the objectives of the Paris Agreement are

met.

• SUSBA - Sustainable banking assessment. https://susba.org/ Report attached. An

interactive tool for banks to assess and benchmark their Environmental, Social, and

Governance (ESG) integration performance, and identify key improvement areas to stay

competitive, resilient and relevant in a resource-constrained, low-carbon future.

• Incorporation of environmental, fintech data analytics into Index and rating agencies MSCI

Inc. acquire Zurich-based environmental fintech and data analytics firm, Carbon Delta AG

(“Carbon Delta”) Link

• London Stock Exchange acquired Paris-based Beyond Ratings. Link

• MSCI Inc. acquire Zurich-based environmental fintech and data analytics firm, Carbon Delta

AG (“Carbon Delta”) Link

• London Stock Exchange acquired Paris-based Beyond Ratings. Link