Submission: Conservation Amendment Bill 

July 2026

About 

OraTaiao: Aotearoa New Zealand Climate and Health Council (OraTaiao) is an incorporated society representing over 1,000 health professionals and organisations. We are the largest climate-health advocacy group in Aotearoa New Zealand. We see planetary health as requisite to human wellbeing and have championed equitable and regenerative climate action for 15 years.  

OraTaiao is very concerned about the proposed Conservation Amendment Bill (the Bill) and its implications on the management of public conservation land (PCL) in Aotearoa New Zealand. The Bill proposes a fundamental shift in the function of the Department of Conservation (DOC) from one that focuses primarily on conservation to one that promotes economic use and development of public conservation land “to the greatest extent practicable”. We are concerned about the onward effects of this shift in values on Aotearoa New Zealand’s natural environment and on the health and wellbeing of New Zealanders. The purpose of this submission is to explain our strong opposition to the Bill and its significant implications for planetary health and Te Tiriti o Waitangi (te Tiriti)

Read the full submission here

Submission to Pharmac | Te Pātaka Whaioranga on proposed changes to diabetes medicines’ access criteria

11 June 2026

OraTaiao: Aotearoa New Zealand Climate and Health Council is responding to Pharmac | Te Pātaka Whaioranga’s call for submissions on proposed changes to diabetes medicines’ access criteria that remove ethnicity criteria.

Equity in health and climate policy is essential to improve and protect public health. For this reason, OraTaiao strongly opposes the proposed removal of the ethnicity-based access pathway for Māori and Pacific peoples. Removal of this pathway constitutes the reversal of a clinically-designed equity safeguard in a system with known entrenched inequities.

We are concerned that the proposal risks worsening existing inequities in diabetes outcomes, cardiovascular disease, chronic kidney disease, and premature mortality - as well as increasing health sector costs from treating worsening health with denial of these preventative medicines.

OraTaiao is also concerned that:

• the proposal ignores te Tiriti obligations and ignores the principles of current legislation - in particular, sections 6 and 7 of the Pae Ora Act 2022. OraTaiao notes that the Pae Ora Act 2022 continues in force as legislation ruling Pharmac | Te Pātaka Whaioranga’s work. This Act takes precedence over any Ministerial letters of expectation and other directions, and any other Pharmac | Te Pātaka Whaioranga policy including the recent Access Criteria Policy
• the proposal is founded on a Pharmac | Te Pātaka Whaioranga policy which we find problematic because it ignores current legislation which binds the Board and all Pharmac staff, is not congruent with te Tiriti, is internally inconsistent, lacks public consultation, and contradicts the Cabinet Circular on needs-based services
• Pharmac | Te Pātaka Whaioranga never developed or considered any options to retain the ethnicity criteria – despite these ethnicity criteria meeting the Cabinet Circular’s analytic requirements
• the proposal fails to fully reflect expert advice – which was even initially withheld from this consultation, despite Pharmac’s stated commitment to greater transparency
• details of how key evidence has been interpreted (contributing to Pharmac’s stance) have been withheld – despite Pharmac’s stated transparency commitments.

OraTaiao recommends that Pharmac | Te Pātaka Whaioranga:

• defer the removal of ethnicity criteria, pending further work and more robust public consultation
• amend the proposed special authority criteria by moving the ethnicity criteria’s position and by clarifying cardio-renal risk and early-onset T2DM
• publicly provide economic information for this proposal on QALY health gains, underlying assumptions, and PICOs used – particularly the counterfactuals undertake and publish a comprehensive equity impact assessment of this proposed change
• undertake analysis on whether, under the Cabinet Circular, retaining the ethnicity criteria for diabetes medicines would be allowable
• develop and consider an explicit option to retain the ethnicity criteria for diabetes medicines, if the Cabinet Circular’s requirements are met
• provide the Board with alternative interpretation of the evidence the Diabetes Advisory Committee assessed, that ethnicity criteria have improved, not lessened, access in Māori and Pacific peoples with known CVRD
• urgently revise the Pharmac | Te Pātaka Whaioranga Access Criteria Policy in line with the Cabinet Circular, that ethnicity and age are independent clinical/epidemiologic factors and discriminants, and release the revised Access Criteria for public consultation
• suspend the current Access Criteria Policy and not use it in proposal development until revised and consultation concluded 
• for any consultation on proposals, provide full clinical advice readily, economic information that includes health benefit assumptions, and sufficient time (at least six weeks) to assess all consultation material , for any proposals.

Thank you for the opportunity to provide feedback, and we welcome further contact.

Read our full submission here.

27 August 2025

OraTaiao supports the intent of this long-term insights briefing (‘the briefing’). However, we believe it can be meaningfully improved and wish to make the following recommendations:

1. Addition of Te Tiriti as a foundation of resilience building.
2. Greater emphasis on the intersection between health and hazards throughout. 
3. Improved articulation of equity and greater emphasis on the necessity of equity in resilience building. 
4. Improved articulation of ‘Climate change and environmental stress’ in Section 2: Forces that shape risk and resilience.
5. Additions to Section 2: Forces that shape risk and resilience.
6. Accuracy on the current status of the Resource Management Act and its relationship to hazards planning.

27 August 2025

OraTaiao is very concerned with the direction this Bill is taking the local government. Local government plays critical roles in human health, and in climate change adaptation, mitigation, and resilience building. This Bill fails to recognise these roles and, with little analysis, restricts local governments’ ability to deliver on communities’ climate and health needs.

We oppose the drastic narrowing of local government functions as it will put human health, climate resilience, and community wellbeing at serious risk. The Bill undermines councils’ ability to act preventatively, instead seeming to relegate them to crisis response once harms have already occurred. It is fiscally short-sighted and will compound inequities in health and wellbeing.

We are deeply concerned about the ad hoc nature of this and other legislative changes. The Government’s piecemeal approach is creating contradictory requirements and responsibilities for local government, with little or no consideration of human health, climate change, or the immense social and economic costs of climate impacts.

We also note the ongoing and deplorable removal of Te Tiriti provisions from public policy by the current Coalition Government. In this Bill, the removal of the requirement for councils to consider tikanga Māori knowledge when appointing council-controlled organisation directors erodes cultural competence and undermines equity. This will weaken the ability of communities to build enduring resilience and health, and reverses progress towards honouring Te Tiriti o Waitangi in local decision-making.

This submission covers:

1. The role of local government in health and climate change, and the need for decisions that recognise these intersections.
2. The failure of the proposed “core functions” and their long-term costs.
3. The value of the four wellbeings, and the wasted resources caused by repeated policy reversals.
4. The importance of Te Tiriti in legislation including for local government.

OraTaiao is opposed to the possible changes to health workforce regulation outlined in the Ministry of Health's Discussion document. Our submission focuses on the ignorance of the role of cultural safety and Te Tiriti o Waitangi in clinical safety, co-option of health language to justify inappropriate overstep into health professional regulation, and clear contradictions in stated goals versus what the actual outcomes would be. We suggest that this review be revoked and reattempted in good faith. Read our submission here.

OraTaiao strongly oppose the proposed Regulatory Standards Bill as a profound threat to climate action, health equity, and Te Tiriti o Waitangi. This Bill ignores the principles of good lawmaking, instead imposing selfish principles that undermine human rights, common good, and intergenerational equity. This Bill will force environmental and social costs onto the public and diminish Māori and collective rights. OraTaiao warns that weakened environmental regulations under the Bill would accelerate resource exploitation and pollution, and worsen environmental and human health. The proposed changes would block the government’s ability to respond to health threats including global overheating. OraTaiao calls for the coalition government to abandon the Regulatory Standards Bill. OraTaiao's full submission to The Ministry of Regulation is available here.

OraTaiao is opposed to the Principles of the Treaty of Waitangi Bill. The Bill threatens to undermine collective well-being, climate action, and health equity by eroding the constitutional and social fabric of Aotearoa New Zealand.

The Bill weakens the health sector, environmental protection, and protections for Māori. 

Unity, cohesion, and respect are essential for well-being. All of which this Bill fundamentally undermines. As health advocates, we stand for Te Tiriti and its promise of equity, justice, and peace for all in Aotearoa New Zealand.

OraTaiao's full submission to the Justice Committee is available here.

The New Zealand Transport Agency released a discussion document in November about increasing the “private share of public transport operating expenditure”. This means that councils would need to take in more revenue to offset the cost of running public transport by charging more money for buses, ferries, and trains. While not set into policy yet, this document shows a clear direction from the government and one that OraTaiao fundamentally opposes.

Our transport working group, led by Steve Grimson, has written a letter to Transport Minister Simeon Brown, calling for the government to reverse this defunding and invest in public transport as a health intervention. Please consider writing a letter to Simeon (feel free to use ours as a template) to show widespread health professional disapproval of such a damaging proposal. 

NZ is the highest per capita historic emitting nation, wealthy, full of natural resources, and among the highest per capita emitters globally. We must be a fair team player to limit global overheating to our humanly adaptable 1.5˚C. There is no excuse for delaying a much more ambitious NDC of over 80% by 2035 for global and international equity. Te Tiriti, fairness, human and planetary health must set NDC2.

OraTaiao's full submission to the Ministry for the Environment, prepared by Liz Springford, is available here.