Submissions

ELI is concerned to see many stocks in the current consultation round are showing significant signs of decline or collapse, yet options proposed are not always sufficient to enable recovery. In particular, some of the consultation papers present status quo options even where the material indicates that existing catch settings are causing decline.

Fisheries New Zealand (FNZ) has not provided a detailed analysis of why status quo options continue to be presented even where sustainability issues have been flagged. Where the evidence indicates that current settings are not achieving the sustainability outcomes required under the Act, maintaining those settings is not a lawful or acceptable management response.

SNA 2 is a major New Zealand inshore fisheries management area for snapper (Pagrus auratus), stretching along the east coast of the North Island from Gisborne down to Wellington/Makarā.

In ELI’s view, two of the three Options as currently developed present significant risks of kina barren proliferation, as has occurred within SNA 1. Emerging science on Snapper predation on kina provides strong support for the need to avoid kelp loss to prevent ecosystem collapse.

ELI submits that the NZ ETS settings should be designed to ensure genuine emissions reductions, including by limiting new unit supply as much as practicable to help address the NZU stockpile. We also submit that decision-makers continue to consider New Zealand’s climate international obligations, and that annual ETS settings decisions should be retained to allow timely and responsive adjustments.

ELI has submitted on the Conservation Amendment Bill 2026.

This Bill is of pre-eminent significance. It appears that the amendments would enable, and possibly encourage, activities and decisions inconsistent with conservation. ELI does not support this outcome and opposes the legislation proposed in full. The Bill should be withdrawn.

The Bill is an extraordinary and unjustified intervention in live proceedings, and lacks any substantive rationale beyond shielding specific defendants to a civil claim. It undermines access to justice and public confidence in the rule of law.

ELI submits that the Bill should not proceed.

In June 2026 we lodged a formal submission on the Hazardous Substances and New Organisms Amendment Bill.

We submit

The proposed changes substantially expand ministerial and executive discretion, weaken precautionary and ecosystem‑based protections, and reduce opportunities for public scrutiny and legal challenge.

We submit that DOC should consider the possibility of moving safe zones for marine mammals and spell out how it will achieve improved enforcement within Te Pēwhairangi Marine Mammal Sanctuary.

Abolishing the Ministry poses significant risks for the protection of the environment.

The Bills remove established environmental limits, enable more pollution by opening new rights not previously legally available to polluters, limit public standing to participate, as well as judicial review rights, hollow out existing accountability mechanisms, and establish potential conflicts with the Wildlife Act 1953.

Submission on the establishment of Puketeraki mātaitai reserve in East Otago.

Our submission to the DOC and Fisheries NZ consultation on the future of marine management in Kaikōura.

In ELI’s view, there are significant issues with the proposals and their underpinning analysis.

The most significant issue is the lack of a proper justification for the proposal that the Crown bear the proposed $3.76 million in annual costs associated with the on-board camera programme.

The legal and policy analysis underpinning this proposal is seriously deficient.

Our submission on the MPI Proposals to Amend the New Zealand FoodNotice: Maximum Residue Levels for Agricultural Compounds.

ELI’s submission to the Water Services Authority (Taumata Arowai) on a set of proposed wastewater environmental performance standards (wastewater standards) under section 138 of the Water Services Act 2021.

ELI’s submission on Westland Mineral Sands Co. Ltd’s resource consent applications for its Heavy Mineral Sands Mining Operation, Mananui Mineral Sand Mining.

ELI’s submission to the Department of Conservation on the Modernising Conservation Land Management proposals.

ELI’s submission on the Resource Management Act (Consenting and Other Systems changes) Amendment Bill.

ELI’s submission to the Environmental Protection Authority’s proposal to ban chlorpyrifos. Chlorpyrifos is an insecticide used to control a broad range of insect pests on plants. ELI supports the EPA’s proposal to revoke all approvals for chlorpyrifos-containing substances.

ELI’s submission to Fisheries NZ’s review of sustainability measures for spiny rock lobster (crayfish) for the area known as CRA 2, which covers the Hauraki Gulf.

ELI has submitted on the Government’s consultation on Setting Aotearoa New Zealand’s Second Nationally Determined Contribution under the Paris Agreement.

The Government’s choices outlined in its proposed Emissions Reduction Plan would needlessly delay our transition towards a cleaner, healthier environment, society and economy.  

With growing awareness of the potential risks associated with specific chemicals found in everyday products, evidence-based regulation of these substances is imperative to safeguarding the health, safety, and well-being of the environment, its people, and our communities. In light of this, ELI recently submitted their recommendations to the Environmental Protection Authority (EPA) regarding the proposed revisions to the Cosmetic Products Group Standard. Read our full submission here.