• About this site|
• Site index|
• Contact us|
• Jobs

Proposed National Policy Statement on Indigenous Biodiversity: Section 32 Evaluation

Preface

Proposed National Policy Statement on Indigenous Biodiversity

Executive summary

1 Introduction

2 The status quo

3 Situaion under the status quo

4 What are we trying to achieve?

5 Alternatives to the status quo

6 Is the proposed objective appropriate in achieving the purpose of the Act?

7 Will the policies be effective and efficient in achieving the objective?

Conclusions

Appendix 1: Section 32

Appendix 2: Tools and databases

Appendix 3: Location of threatened species

Appendix 4: How to make a submission

3 Situation under the status quo

One of the inherent difficulties in managing native biodiversity is the absence of complete, reliable and relevant information about its current state and trends. Generally speaking, when we monitor and report on native biodiversity, we are forced to use surrogate measures – such as the extent of native vegetation remaining or legally protected – or take a case study approach. While there are many ecological surveys, they relate to highly localised areas, are patchy in their availability and often use differing methodologies. This all makes it difficult to draw generic conclusions.

Despite this, there is general acceptance that New Zealand’s native biodiversity is in serious decline. Considerable work to compile various information sources and expert opinion at the time the NZBS was developed (2000) led to that conclusion and, as noted earlier, this was broadly accepted by ecological professionals and by the Government (which, as a consequence, boosted funding by $187 million). The conclusion echoed a principal finding of the 1997 New Zealand State of the Environment report¹¹ that biodiversity loss was New Zealand’s “most pervasive environmental issue”.

The lack of a measurement tool that could empirically demonstrate the extent of the decline at a national scale led to the development of LENZ¹² as a better (though still limited) assessment tool.

The information that follows draws on LENZ and is the best available, but continues to suffer from the limitations discussed above. As in 1997 and 2000, this assessment needs to draw on multiple sources to assess the status quo and trends in New Zealand’s native biodiversity.

3.1   Overview

At the broad scale, out of the 33 Organisation for Economic Cooperation and Development (OECD) countries, New Zealand has the highest proportion of its land area protected for conservation purposes – 33.4 per cent of our total land area.

As of July 2009, 8,763,300 hectares of New Zealand’s land was legally protected (by public ownership or covenants over private land) for the primary purpose of protecting native biodiversity. Legally protected public land (managed by DoC and regional councils) accounted for 8,525,000 hectares, and private land (protected by the QEII Trust or Ngā Whenua Rāhui) accounted for 238,300 hectares.¹³ These figures do not account for land protected by rules prepared under the RMA.

Of the 8.763 million hectares, 8,401,500 hectares have native land cover. ‘Native land cover’ includes land with native vegetation as well as naturally occurring non-vegetative covers, such as permanent snow and ice, alpine gravel and rock, and waterways.

Recent trends show that protection by public acquisition and covenanting is increasing. Over the three-year period between 2006 and 2009:

• legally protected public land increased from 8,138,500 hectares to 8,525,000 – an increase of 386,500 or 4.7 per cent. About three-quarters of this increase was from land acquired and protected through high country tenure review in the South Island
• legally protected (by covenant) private land increased from 216,200 hectares to 238,300 hectares in 2009 – an increase of 22,100 hectares or 10.2 per cent.¹⁴

3.2   Risks and challenges

These broad-scale figures tell us little about the real state of native biodiversity protection. This requires an understanding of what type of vegetation has been protected, what remains unprotected, how important for biodiversity this unprotected land is, and what the condition (and trends) of vegetation and habitat on that unprotected land might be.¹⁵

When those matters are considered, it is apparent there remain significant challenges for biodiversity protection outside public land. GIS analysis shows New Zealand has done well protecting upland areas – more than 90 per cent of three montane (mountainous) environments within the LENZ classification (permanent snow and ice, Southern Alps and ultramafic soils) are legally protected. However, there has been little progress in protecting biodiversity in lowland areas of the country where many of the principal challenges and threats arise. This is not unexpected, given that lowland areas are generally more commercially valuable and conservation therefore comes at a greater opportunity cost for landowners (and a higher price for public agencies considering land acquisition).

3.2.1   National information showing biodiversity state and decline

Legally unprotected vegetation

The LENZ and 2002 Land Cover Database¹⁶ (LCDB) show that, at the national level, there are 566,348 hectares of native vegetation in national priority 1 environments (ie, in ‘environments’ that have less than 20 per cent of their original land cover remaining).¹⁷ Of this, 98,276 hectares (17.3 per cent) is already legally protected through public ownership or binding conservation covenant, but 82.7 per cent of national priority vegetation remains at risk.¹⁸

The un-representativeness of New Zealand’s protected area network, and the issues this poses for the network’s ability to secure biodiversity goals, are highlighted by some areas and habitats existing only (or almost only) outside of public conservation land or protected areas on private land.
The Ministry for the Environment’s Legally Protected Conservation Land in New Zealand Environmental Snapshot (April, 2010) identifies that, of the 20 LENZ environments analysed, eight had less than 20 per cent of the original cover remaining. At this scale (LENZ level I), the most seriously under-protected are the relatively flat environments of the ‘eastern South Island plains’, ‘central well-drained recent soils’ and ‘western and southern North Island lowlands’, in which less than 1 per cent of native land cover is legally protected. This is shown in figure 1.

Analysis using LENZ and the LCDB not only highlights types of environment that are under-protected, it also identifies significant inter-regional variation in the level of formal legal protection. At LENZ level IV, the level of unprotected priority 1 vegetation ranges from 54 per cent in the West Coast region to 91 per cent in the Otago region. This is shown in figure 2.

Inter-regional variation in the level of formal protection of wetlands shows even greater differences. Although the national average is 38 per cent, this ranges from 87 per cent in Tasman, to just 10 per cent in Gisborne.

Indigenous vegetation loss

The Ministry for the Environment’s Land: Land Use Environmental Snapshot¹⁹ (January 2010) provides further data on land-use change over the period 1990 to 2008. This is based on the Land Use Carbon Analysis System (LUCAS) mapping which was designed to enable New Zealand to meet its Kyoto Protocol reporting obligations.

While the snapshot information is much coarser in its classification of vegetation types than LCDB²⁰ and is less revealing of biodiversity implications, it provides a useful overview of general land-use change. Key findings are that between 1990 and 2008 New Zealand has lost:

• 50,700 hectares of natural forest – a trend attributed to the replacement of natural forest with planted forest
• 311,000 hectares of low-producing grassland (a mixture of exotic and native grassland with lower productivity vegetation)
• 125,100 hectares of scrubland (scattered scrub within or near grassland not protected or managed for regeneration)
• 100 hectares of wetland.

This clearly indicates that, notwithstanding the RMA’s identification of the national importance of protecting significant native vegetation and habitat, its loss has continued.

Manaaki Whenua – Landcare Research

In 2006, Manaaki Whenua – Landcare Research published research on the recent loss of native land cover in New Zealand.²¹ That research remains the most comprehensive work on the state of, and rate of loss of, native vegetation in New Zealand that applies the LENZ categories used in the Statement of National Priorities.²²

Key findings (from the abstract of the paper) are:

• extreme (>70 per cent) historic loss of native cover in 57 per cent of land environments
• poor protection (<20 per cent land area protected) in more than two-thirds of LENZ environments
• loss of native cover has continued, with 49 per cent of environments having lost native cover between 1996/97 and 2001/02, with the highest rates occurring where native cover was already most depleted.

The research showed that net loss of native cover in the five years between 1996/97 and 2001/02 was 17,200 hectares. Conversion to exotic forestry accounted for 65 per cent of the loss, felling for timber 11 per cent, conversion to high-producing pasture 6 per cent, and conversion to low-producing pasture 16 per cent. Further, over the same period, almost 30,000 hectares of low-producing grassland changed to non-native cover. This will also have had biodiversity loss, since much of this was a mix of native and exotic species.

The conclusion to the paper states:

Overall, the data suggest that public awareness and education, voluntary protection, Resource Management Act (1991) provisions, and formal legal protection of remaining indigenous biodiversity have not halted the removal and/or displacement of vulnerable indigenous biodiversity in much reduced and poorly protected ecosystems and habitats. This may arise from a continuing perception that only pristine ecosystems are important or significant for biodiversity (eg, Norton and Roper-Lindsay 2005). This fails to recognise that a high proportion of New Zealand’s most threatened species survive only in depleted and highly modified ecosystems in threatened environments; therefore, protection of highly modified habitats is essential to prevent the extinction of many species.²³

Research on South Island grasslands

The absence of a more recent LCDB has restricted the ability to update the research cited above, but its author (Susan Walker, Maanaki Whenua – Landcare Research) has more recently considered the loss of native grasslands in the South Island as part of evidence for the intensive dairy farming proposals recently considered in the Mackenzie Basin.

In her evidence, Walker made the point that neither LCDB1 nor LCDB2 identifies most land cover change in grasslands since 1990. The estimates in the 2006 report mainly represent losses to afforestation (which was assessed in the making of LCDB2) and do not include the loss of less-developed grasslands to intensive pasture development.

To get a better understanding of grassland loss since 1990 (and to bring the data as up to date as possible) Walker draws on the work of a doctorate study of the 4.3-million-hectare eastern South Island grassland zone. She reports:

The student’s preliminary, unpublished estimates suggest some 80,000 ha of less-developed grasslands were converted in this zone between 1990 and summer 2007/08. Of this, the student estimates that 66 per cent (about 52,500 ha) was converted for pasture or cropland, and almost half of this conversion (c. 25,000 ha) occurred in six years between the summers of 2001/02 and 2007/08.

These unpublished estimates suggest the average rate of conversion of less-developed grasslands, shrublands and wetlands in the eastern South Island grassland zone for pasture and cropland may have recently increased from about 2,500 ha per annum between 1990 and 2001, to about 4,200 ha per annum between 2002 and 2008. These rates are consistent with accelerating livestock numbers published by MAF and Statistics New Zealand, and support the statement that New Zealand is undergoing ‘record rates of agricultural intensification’ (Murdoch 2009). In my opinion, this development may represent the most significant wave of direct loss and modification of habitats of indigenous species in New Zealand in modern times, and will likely exacerbate the threat status of many of its species.

In the Mackenzie Basin alone, Walker reports 12 per cent (35,000 hectares) of native grasslands have been converted since 1990²⁴ by irrigation or cultivation or over-sowing and topdressing (excluding areas in the process of conversion but not yet fully converted). Her evidence states:

This recent conversion probably represents the most rapid rate of indigenous ecosystem loss and landscape transformation within any single ecological region in New Zealand in modern times. A spatial overlay indicates that parts (>10ha) of at least twenty-nine of the 103 RAPs²⁵ identified in the Mackenzie Ecological Region Protected Natural Areas Programme survey (Espie et al 1984), and nine sites of special wildlife interest (SSWIs) have been converted. Most of this conversion has occurred since 1990.

3.2.2   National information showing biodiversity decline

Further sources of information on the state of New Zealand’s native biodiversity are regional council:

• state of the environment reports (SERs)
• reports on the effectiveness of policy statements and plans.

While these studies are also often limited by a lack of availability of recent LCDB data, conclusions are based on a mix of local (sub-regional) studies and local knowledge, and can be revealing.

The availability of these reports is patchy, and a review of those that are available shows mixed results. Some (such as those listed in Appendix 1) are open about the trend in biodiversity. Others either cannot, or choose not to comment on trends, except at a very general/long-term level. Greater Wellington Regional Council’s SER (2005) sums up the challenge well when it says:

We don’t really know if we are making a difference for biodiversity and we need to develop means of measuring change in ecosystems.

Other regional councils SERs, in particular Auckland and Waikato, also indicate a continuing decline despite efforts to date. Excerpts from the reviews of some SERs are provided below.

• Northland State of the Environment Report 2007

Overall biodiversity conclusion: “Less than 5 per cent of Northland’s wetlands remain as a result of drainage and disturbance. Some wetland types are now close to being lost forever …. Overall the biodiversity of indigenous vegetation is declining with a decrease in the land area covered in indigenous vegetation from 1997 to 2002 and indigenous plant species becoming nationally or regionally threatened, with some species already extinct in Northland. Many once common habitat types, such as riverine floodplain forest and dunefields, are now critically threatened due to land development pressure.”

• Auckland State of the Environment Report 2010

Overall biodiversity conclusion: “At the regional scale, native habitats and threatened species will continue to decline in unprotected or unmanaged areas due to habitat loss, fragmentation and invasive species.”

The Auckland SER highlights that examples of vegetation loss are not restricted to rural New Zealand. For example, it reports a local study of vegetation loss in the highly urbanised North Shore City which shows that between 2001 and 2006, 59 hectares of significant vegetation were cleared, representing 2.63 per cent of the vegetation that had been present in 2001 (with an overall drop in vegetation in the city from 2234 hectares to 2152 hectares).

• Progress toward achieving Environment Waikato’s Regional Policy Statement objectives: Biodiversity and natural heritage (2007)

Overall biodiversity conclusion: “The biodiversity and natural heritage objectives are generally not being achieved due to pests, land-use intensification, water pollution and lack of riparian protection, loss of connectivity, undervalued natural systems such as wetlands, and lack of formal protection for some ecosystem types.”

• Taranaki Regional Council RPS review (2009)

Taranaki’s review of its RPS notes: “Notwithstanding the above [list of regional responses] the Council’s State of the Environment Report concludes that there are continuing threats to our native forests, biodiversity and ecosystems. Many habitat types, such as coastal and lowland forests and wetlands, are poorly represented in Taranaki and are fragmented …. The issue is one of the most important facing the region…”

The Taranaki SER also provides a good example of the use of local studies. It notes, for example, that: “Changes in the extent of indigenous vegetation in Taranaki have been measured for the hill country through the Council’s sustainable land monitoring programme (see chapter 3.1). The total area of indigenous forest decreased in the monitored sites from 3,380 ha in 1994 to 3,295 ha in 2007, a decrease of 3 per cent.”

3.2.3   Native biodiversity on private land

The most recent ecological assessment of the state of native biodiversity outside public land was undertaken in 2002.²⁶ This review found that some native biodiversity is largely or totally dependent on private land for its survival. While the review also found that active conservation management was increasing on private land, it concluded that, despite this, there was ongoing decline and loss of native biodiversity.

Other conclusions from the 2002 review included the following:

• in terrestrial environments, something of the order of 60–70 per cent of threatened vascular plant species appear to be dependent on private land. Some species are entirely reliant on private land
• coastal and lowland forests and scrublands, dune systems, freshwater wetlands, streams and indigenous riparian habitat are largely dependent on private land
• about 50 per cent of Auckland region’s threatened plants occur in shrublands and regenerating forests on private land. In Hawke’s Bay, non-beech mistletoes and other species, including Pittosporum obcordatum and Coprosma pedicellata,occur largely outside conservation lands. In Wellington region, species entirely confined to private land include the regionally threatened orchid Spiranthes novae-zelandiae and all wild populations of the nationally vulnerable Muehlenbeckia asonii. In Marlborough, the Ward Daisy (Brachysone “Ward”) and the chalk cress (Cheesemania “Chalk Range”) are found only on private land. A large array of insects depend solely on Olearia shrubs found principally on private land in central Otago. In Southland, coastal turf communities are nearly all on private land, while the only wild population of Gunnera hamiltonii is on privately owned duneland
• North Island kiwi and kererū are species that move between public and private lands
• for some rare ecosystems, very little is in public conservation lands. For example, in the Waikato region, only 1.6 per cent of flax wetland is protected; and in central Otago, only 0.3 per cent of the original extent of kowhai-kanuka savannah is protected.

Although this review has not been updated, there is no reason to suggest its conclusions are no longer valid, especially in relation to the importance of private land for indigenous biodiversity.

3.2.4   District plans vary in their approach to protecting biodiversity

There have been two national reviews this decade into the adequacy of RMA plans to protect native biodiversity – an in-depth survey in 2004, and a more recent update of that survey in 2010.

The 2004 review of district plans²⁷ concluded that the quality and breadth of native biodiversity provisions varied considerably. It found that about 20 per cent of plans and regional policy statements had comprehensive and detailed provisions for identifying significant sites and habitats, backed up by a range of methods to protect them. About 20 per cent of plans had minimal (or no) means for identifying significant sites and/or a lack of adequate provisions to recognise and provide for their protection. Most plans were found to fall somewhere between these two poles, and 45 per cent did not include any criteria for identifying significant areas or significant habitats. While most district plans (61 out of 77) did have rules covering the clearance and disturbance of significant sites, the identification of these sites was sometimes inadequate and rudimentary. Also, while 41 plans had general clearance rules, these rules were not necessarily backed up with criteria for assessing applications.

In July 2010, MfE commissioned a study to update the 2004 review, with particular emphasis on establishing the extent and strength of biodiversity provisions in district plans.²⁸ Summaries of the key findings from this review are:

• A number of councils now have biodiversity strategies in place and appear to be making good progress towards achieving statutory requirements. Selwyn, Thames-Coromandel, Christchurch, Hurunui and Nelson councils all provided good examples, although others are also making progress.
• Some councils appear to be significantly more advanced than others. At one end of the spectrum, councils such as Thames-Coromandel, Waimakiriri and Marlborough, have rigorous protection mechanisms and strategies in place. On the other hand, some councils have no or only limited provision for protection. Examples include, but are not limited to, councils on the east coast of the North Island – eg, Hastings, Gisborne, Napier, Wairora and Whakatane councils.
• There is a significant range in plan development for biodiversity protection. While many plans have been updated since the 2004 review, there is little change in the number of plans that have rules governing the clearance and/or disturbance of significant sites of native plants and animals (ie, 61 in 2004; 63 in 2010). However, there does appear to be an increase (from 41 to 59) in the number of plans with general clearance/disturbance rules, which may (in part) be accounted for by the inclusion of riparian clearance rules in the 2004 study.
• There has been an increase in the number of district plans with stated criteria for the purpose of identifying significant natural areas (60 out of 75 plans, or 80 per cent). However, there appears to have been little change or no change in the types of criteria used – 13 plans identify significant natural areas but do not specify criteria; while two plans (Auckland City and Napier District) do not include criteria or identify sites.
• Only minor change was evident in the specificity of monitoring provisions across plans in relation to biodiversity (38 to 41).
• A wide range of techniques are used to identify significant native plants and animals, with different criteria applied. The most commonly used criteria are those relating to DoC’s Protected Natural Areas Programme or a variant on these. Other plans use criteria such as those identified by Norton and Roper (1999)²⁹, while yet others continue to use rudimentary criteria.
• 84 per cent of plans (63 out of 75) have rules targeted at protecting significant areas (including wetland and special ecological zones), and most plans (59 out of 75) contain provisions targeting the protection of biodiversity outside section 6(c) requirements. These include measures such as general clearance controls, controls on pest species, controls on certain activities (eg, deer and goat farming), controls on earthworks and controls on riparian activities.
• Non-regulatory biodiversity protection measures cited in plans include education, advocacy, financial incentives/assistance and land acquisition or swaps. Some councils are very specific about such measures – eg, Selwyn District Council has set up an annual contestable fund of $30,000, while Banks Peninsula District Council will consider offsetting by establishing new areas of equal environmental value.

Local Government New Zealand has also recently undertaken a survey of regional councils to determine the extent to which the national priorities³⁰ influenced regional councils’ biodiversity programmes. The results indicated little influence. Similarly, a MfE review of RPSs found that the priorities had little influence on policy statements and plans. It should be noted, however, that most plans/RPSs pre-dated the release of the national priorities. There was some evidence of at least one recently notified RPS reflecting the national priorities, and some others that demonstrated a degree of coincidence between regional criteria and the national priorities. Overall though, it cannot be concluded that the national priorities have been a significant influence.

3.2.5   Community attitudes towards protecting biodiversity

Having established that there is evidence of loss of biodiversity and that the approaches used by councils to protect biodiversity vary in their effectiveness, it is important to ask whether this loss is something that really matters to New Zealanders.

In signing the international Convention on Biological Diversity in 1992 and preparing the New Zealand Biodiversity Strategy in 2000, successive Governments have resolved that native biodiversity does matter. The high level of native biodiversity that is only found in this country (endemic biodiversity) makes an important contribution to global biodiversity and places an international obligation on us to ensure its continued existence.

Maintaining a landscape with a recognisable New Zealand character requires an approach directed at maintaining the survival of native species in their natural communities and habitats, and preventing the loss of any class of natural ecosystems. Studies over the last decade have attempted to obtain an estimate of how we, as a nation, value our native biodiversity. Of particular relevance were the results of a study conducted by Massey University (2001) of 2000 over-18-year-olds,³¹ which demonstrated:

• 49.6 per cent of people considered the loss of species was “very serious”, while another 37.7 per cent thought it was “serious”. It was unclear from the survey, however, whether that reflects people’s views about the importance of species or people’s understanding of the risk
• New Zealand’s unique plants and animals were valued “very much” by 77.3 per cent of those surveyed, “moderately” by a further 20.9 per cent, “a little” by 4.8 per cent and “not at all” by just 0.6 per cent.

Respondents to the Massey University survey were also asked their attitudes towards environmental regulation. The study found that nearly 60 per cent of New Zealanders believe the Government should pass laws to protect the environment, even if it interferes with people’s rights to make their own decisions, and more than 80 per cent believe the Government should pass laws to make businesses protect the environment.

Submissions (response cards) to the Rio +10 community programme, conducted by MfE,³² back up the results of the Massey University survey – 82 per cent of respondents believed biodiversity protection should have high or medium priority.

3.2.6   Likely future issues

All available evidence suggests that the biodiversity has continued to decline since the introduction of national priorities in 2007.

While it is also possible to identify many anecdotes of individual and community group projects that have successfully protected or restored particular sites (and regional reports do a great deal of this), such efforts need to be seen against a backdrop of broad-scale national decline in native vegetation on private land.

Even if this was not the case and existing planning efforts were ‘holding the tide’, it is important to look forward and determine whether they are likely continue to do so in the face of foreseeable change in economic and social pressures. The following issues are emerging as potentially significant threats to biodiversity that current plans are unlikely to be well placed to address.

• The 2008 introduction of forests into the Emissions Trading Scheme (ETS) has some potential to create incentives for land clearance in order to establish exotic forests. There could, for example, be a risk to biodiversity if deforested land is worth more in an alternative use (eg, exotic forestry) than if left under native vegetation.
• There has been long-standing and ongoing concern about whether the process of South Island high country tenure review is producing net biodiversity benefits. Recent decisions by Cabinet (CAB Min (09)26/7C) to modify the tenure review process (and in particular remove the ‘lakeside policy’) explicitly rely on addressing gaps in district plans as the alternative means of preventing unsustainable or inappropriate development. One way identified in the Cabinet paper is for the Crown to submit on the 8 to 10 district plans as they are reviewed. A complementary way would be to have a NPS that ensures the key impacts of biodiversity are appropriately identified and managed.
• It is likely that current patterns of land-use intensification will continue to place pressure on native grassland and shrubland conversion; for example to provide for further urban development and meet the needs of a growing dairy industry.
• Regional and district councils are likely to face increasing pressure with competing priorities for financial and administrative resources. For example, the recent emphasis on water management at the regional level has led to many regions shifting their focus and resources to address complex water issues. While this is important, it is likely to divert attention from issues such as biodiversity, which many communities may perceive as of lower priority.

Spatial match between risk and biodiversity vulnerability

There is an apparent correlation between likely future pressures and the presence of biodiversity values and vulnerability.

Walker (2007)³³ ranked territorial authorities according to the extent of native cover not legally protected in the five threatened LENZ environment categories. The top 10 councils (those with the greatest unprotected threatened environments) are as follows:

The four councils with the greatest extent of threatened native cover are all high country districts potentially affected by tenure reform. Waitaki and Mackenzie are also subject to the dairy expansion. The next two highest ranked councils (Far North and Gisborne) are probably those councils at some of the greatest risk from the ETS and forestry sector expansion. Southland, Marlborough and Hurunui will also have extensive areas potentially subject to tenure review. Southland is a focal point of dairy expansion.

This suggests that, at least at the broad scale, those parts of the country with the greatest extent of threatened native cover are also the parts facing, or likely to face, the greatest pressure for land-use change.

3.2.7   Status quo: Conclusions

• There is a lack of full, comprehensive data of vegetation loss (a surrogate measure for biodiversity loss). The most recent data is either broad-scale vegetative cover change or particular case studies.
• All the information we have indicates there was a decline in native biodiversity on private land until the early 2000s. Since then, we have no reason to think that decline has been arrested, and some evidence to suggest it has accelerated.
• This decline in biodiversity is occurring despite almost all district plans having RMA provisions in place designed to protect significant vegetation. This suggests that, overall, those RMA plans are not effective and need revisiting.
• There is a significant range in plan development for biodiversity protection, together with a wide range of protection measures, techniques and criteria. Consequently, some councils are well advanced in providing for biodiversity protection, while others provide little or no protection.
• Emerging land-use trends are likely to place increasing pressure on native biodiversity, which will in turn put increasing pressure on regional and district councils to provide for biodiversity protection at a time when they already face competing priorities for financial and administrative resources.
• RMA plans need to be improved to more fully address the current and future risks of biodiversity loss. This is amplified by the correlation between the biodiversity importance of places and the risk faced in those places.