Our advice on the proposed reforms

22. As the Trustee of the Māori Fisheries and Aquaculture Settlements, our response has largely focussed on matters of principle and the anticipated effect of the provisions within these Bills on the ongoing reciprocal relationship Māori have with Tangaroa and the associated implications on the settlements. We have had an opportunity to review draft responses from the Freshwater Iwi Leaders Group, the Rock Lobster Industry Council, Pāua Industry Council, and Fisheries Inshore through their joint submission, and Aquaculture New Zealand and have referred to parts of these responses and submissions throughout.

23. We note that our response to these Bills has been drafted with incredibly compressed timeframes, and our response focuses on the following key high-level matters within the Bills that fail to align with the approach stated above: i. Inclusion of a ‘use’ outcome in the coastalmarine area (CMA) is required; ii. Upholding Treaty Settlements- including the Māori Fisheries and Commercial Aquaculture settlements in this reform; iii. Managing fishing, and its effects under the new regime; and iv. Successful implementation of resource management reform requires Te Tiriti compliant representation and resourcing to achieve partnership

24. While we have focused on these high-level issues, as the Trustee for the Settlements we have undertaken a clause-by-clause analysis of the fisheries and aquaculture provisions and proposed amendments in Appendix One to ensure alignment with the Settlements.

25. We also lend our support and reinforce key issues identified by several other submitters, whose kaupapa align closely with ours.

outcome in the Coastal Marine Area is required

26. We note that one of the Government’s reform objectives is to “protect and where necessary restore the natural environment, including its capacity to provide for the well-being of present and future generations.”6 It is encouraging to see that these Bills promote a more focused approach in protecting and restoring the environment, working to develop enduring solutions that extend beyond current environmental challenges and consider the full scope of the environment mai i ngā maunga ki te moana (from the mountains to the sea).

27. We recognise that the system outcomes in clause 5 of the NBEB will act as significant drivers of the newresourcemanagementregime,giventhatallplanningunderboththatstatuteandtheSPB must provide for those outcomes so as to assist in achieving the purpose of the NBEB. One of the two foundational purposes of the bill is to recognise and uphold te Oranga o Te Taiao, with each system outcome to provide for this.

28. However, in itscurrent form the bill fails to recognise and uphold te Oranga o Te Taiao throughout the resource management regime, particularly in more operative and technical aspects of the Bill. Aside from the fact that clause 5 includes a number of proposed outcomes that may be in conflict, without any hierarchy or mechanism for weighing or balancing them, there is a critical omission in relationto thesystem outcomes sought for theCMA thatfails to recognise Te Oranga o Te Taiao,particularlyinrecognisingtheintrinsic relationshipbetweeniwi,hapūandtetaiao.

29. The proposed system outcomes do not provide for use of the coastal marine area and its resources in any way. System outcomes that specifically relate to the CMA are: i. the protection or, if degraded, restoration, of the ecological integrity, mana, and mauri of the coastalenvironment (cl.5(a)(i)(B)); and ii. the protection or, if degraded, restoration, of the natural character of the coastal environment (including the coastal marine area)(cl.5(a)(iii).

30. In addition, four other system outcomes will be relevant to the CMA, despite not referring to it explicitly: i. the recognition of, and making provision for, the relationship of iwi and hapū and the exercise of their kawa, tikanga (including kaitiakitanga), and mātauranga in relation to their ancestral lands, water, sites, wāhi tapu, wāhi tūpuna, and other taonga (cl.5(e)). ii. the protection of protected customary rights and recognition of any relevant statutory acknowledgement (cl.5(f)). iii. the conservationof culturalheritage(cl.5(g)); and iv. the ongoing and timely provision of infrastructure services to support the well -being of people and communities (cl.5(i)).

31. Of these, only subclauses (e), (f) and (i) relate to use of the CMA and marine resources in any way and only subclause (e) could be interpreted as providing for some commercial use including fishing and aquaculture.

32. The lack of a ‘use’ outcome in relation to the CMA can be contrasted with the other foundational purpose of the NBE Bill, to ‘enable the use, development and protection of the environnment’ as well as the outcomes related to land -based primary production where use is expressly provided for by the following terrestrial system outcomes: i. well-functioning urban and rural areas that are responsive to the diverse and changing needs of people and communities in a way that promotes the use and development of land for a varietyof activities,including … primaryproduction (cl.5(c)(i)); and ii. the availabilityof highly productive land for land-based primaryproduction (cl.5(d)).

Recommendations

33. The result is that thesystem outcomes to be achieved on land areset out in a manner thatrequire a balance between protection and use/development, whereas outcomes for the CMA are almost entirely limited to protection. While we support the inclusion of protection outcomes in the CMA, as we too have serious concerns for the health of the marine environment and the consequential impact on the wider relationship between iwi and Tangaroa, Te Ao Māori does not embrace a view that its relationship with Tangaroa is to create permanent non-use. Rather the opposite, with our kaitiaki responsibilities being to ensure mauri by balancing that use and resting areas on a temporary basis if and where there are concerns.

34. The CMA is, in a Māori worldview, a space in which commercial activities can and should take place, with most of those activities having a long history for iwi. It is important to recognise sustainable utilisation thatcurrently occurs in the CMA that should not be negatedby this reform. Further, the Crown has a Treaty duty to recognise iwi/hapū use and management practices and to enable the exercise of rangatiratanga and kaitiakitanga over their fisheries and other marine taonga (both commercial and non- commercial) including aquaculture. In its current form the Bill does not meet thatstandard.

35. Therefore, we strongly recommend that clause 5 of the NBEB must be amended to provide for appropriate development and use of the CMA and marine resources, in the following terms: i. (x) enable sustainable utilisationof the coastalmarine area and marineresources

36. Without a system outcome in terms such as this, the legitimate and fundamental interests of Iwi in sustainable commercial fishing and aquaculture will not be provided for in the new regime nor will the Bill allow for other legitimate commercial use including ports. That surely cannot be the intent of Parliament.

Upholding Treaty Settlements - including the Māori Fisheries and Commercial Aquaculture Settlements in this reform

37. The Government has stated that these reforms will not affect the integrity of its Treaty Settlements with Māori. While there are several references to Treaty settlements in various clauses of the Bill, we recommend that the proposed system outcomes should explicitly incorporate the Crown’s responsibility to uphold the integrity, intent and effect of all Treaty settlements, and that this can be ensured through the inclusion of a further system outcome in the following terms: i. (x) protecting and uphold the integrity, intent and effect of Treaty settlements

38. As we noted at the beginning of this response, the Māori Fisheries and Aquaculture Settlements are among contemporary mechanisms which aim to reflect the special and reciprocal relationship that Iwi, hapū and whānau have with Tangaroa. The settlements are integral parts of New Zealand’s Treaty settlement framework and, in recognising and providing for Māori rights and entitlements with respect to fishing and commercial aquaculture, are vital aspects of New Zealand’s marine resource management regime. The legislation for both settlements including the mechanisms involved with each, are central to these settlements and must be respected and not over-written by a more generic statute unless and except where this is expressly requested by the relevant iwi and hapū in a particular area.

39. We echo the position taken by the Freshwater Iwi Leaders Group in their submission on the Bills, “that the nature and effect of Treaty settlements should have been foundational to the creation of the system, not viewed and addressed as incidental, consequential or transitional matters” as they are now being treated through this reform process.7

40. In the first reading of the NBEB, it was acknowledged that “Treaty settlements will be fully upheld and carried over.”8 Despite this, the transitional, savings and related provisions for upholding and carrying over Treaty settlements in both Bills focuses on grievance based historic/ landbased Treaty settlements and appear to have failed to appropriately consider the Māori Fisheries and Aquaculture Settlements. This is a significant oversight, particularly given the proposed increased scope through the Bills to regulate fishing (if those proposals in the Bills are accepted and passed).

41. The definition of “Treaty settlement”9 in the Bills includes a “Treaty settlement Deed”10 , and therefore arguably includes the Māori Fisheries Settlement (through the Maori Fisheries Deed). Although MCACSA should come within the Bills’ definition of “Treaty settlement Act” being “any other Act that was enacted before the commencement of this clause and that provides redress for Treaty of Waitangi claims”11, confusion has occurred in the past regarding the status of the Aquaculture Settlement asa ‘Treaty settlement’ given it has no corresponding Deed.

42. Nevertheless, the Māori Fisheries Settlement and Māori Commercial Aquaculture Settlement are unique contemporaryTreatysettlements,and it is crucialthat they are upheld andcarriedthrough into the new resource management regime.

43. A specific reference to the Māori Fisheries Settlement and Māori Commercial Aquaculture Claims Settlement needs to be included in the definition of Treaty settlements to ensure that these settlements are included in the Schedule 2 transitional processes of both Bills, and that Te Ohu Kaimoana has status to participate in the transitional process alongside the iwi beneficiaries of those settlements.

44. Accordingly, we recommend the following amendment to the definition of Treaty settlement Act in Schedule 2 of each of the Bills as follows: i. Treaty settlement Act means…

“(b) any other Act that was enacted before the commencement of this clause and that provides redress for Treaty of Waitangi Claims, including an Act that provides collective redress or participation arrangements for claimant groups whose claims are, or are to be, settled by another Act (including the Treaty of Waitangi (Fisheries Claims) Settlement Act 1992, the Māori Commercial Aquaculture Claims Settlement Act 2004 and the Maori Fisheries Act 2004.”

45. Alternatively, if the Crown and the Select Committee are of the view that both the Māori Fisheries and Aquaculture Settlements have been comprehensively considered through the development of the Bills, and therefore are explicitly captured within the proposed definitions as they stand, this needs to be communicated to Te Ohu Kaimoana and/or explicitly noted in the Select

7 Freshwater Iwi Leaders Group Submission, page 7

8 Hansard, Minister for the Environment Hon David Parker, Natural and Built Environment Bill First Reading, 22 November 2022.

9 NBE Bill, Schedule 2, clause 2.

10 Ibid.

11 NBE Bill, Schedule 2, clause 2.

CommitteeReport.

46. In any event,we recommendthe following amendmentsto the definitions in Schedule 2:

“Te Ohu Kai Moana Trustee Limited means the company established in accordance with section33 of the Māori Fisheries Act 2004”; and

“Takutai Trust means the Māori Commercial Aquaculture Settlement Trust established by section 34 of the Māori Commercial Aquaculture Claims Settlement Act 2004”

47. Further, we recommend the following amendments to clause 4(5) of Schedule 2 of each Bill by adding the following new text subclauses 5(d) and 5(e):

“Te OhuKai Moana Trusteelimitedfor the Treatyof Waitangi(FisheriesClaims) Settlement Act1992 and the MaoriFisheriesAct (2004); and

TakutaiTrust for the Māori CommercialAquaculture Claims Settlement Act.”

48. Finally, we look forward to engagement with the Crown alongside MIOs and IAOs, through the Schedule 2 process to ensure that not only the settlements but also their original ‘integrity, intent and effect’ is appropriately upheld and carried over into the new resource management regime.

Managing fisheries, and its effects under the new regime

49. Fisheries resources in New Zealand waters (including freshwater habitats and the 200nm exclusive economic zone are primarily managed under the Fisheries Act 1996. The overarching purpose under that Act is “to provide for utilisation of fisheries resources while ensuring sustainability”12. The Fisheries Act provides a comprehensive and integrated fisheries management framework that applies to all aquatic life including marine, estuarine and freshwater habitats.

50. That framework provides tools required to respond appropriately to the effects of fishing while protecting and giving effect to Treaty rights and interests through its recognition of the Fisheries Settlement including the ability to manage customary non-commercial fishing. The Fisheries Act is the regime to manage fishing that iwi and Māori endorsed as part of the Māori Fisheries Settlement. That view was taken noting the other regimes that could affect fishing at the time.

51. The Fisheries Act does not have the ability to manage the effect of other non -fishing activities on fisheries and fisheries habitats – that has largely been the responsibility of regional councils under the RMA in the territorialsea/CMA. Te ao Māori recognises the interconnectedness of all things, not only the whakapapa relationships betweenMāori and their atua,whenua and moana, but the interconnectedness of the environment, ki uta ki tai – from the mountains to the sea.

52. We recognise the direct influence land-based activities such as the level of sediments, nutrients and other contaminants including forestry slash which enter the coastal environment has on the

12 Fisheries Act 1996, Section 8, clause 1 quality of fisheries habitats and coastal waters, and the broader health of Tangaroa. We consider that the management of these types of effects on fisheries habitats has been inadequate under the RMA, and we see little in the Bills that is likely to significantly improve the quality of fisheries’ habitats and coastalwaters.

53. The 2019 decision of the Court of Appeal in Attorney-General v The Trustees of the Mōtītī Rohe Moana Trust (the Mōtītī Decision) confirmed the power of regional councils to make rules under the RMA that restrict or prohibit fishing activities in the CMA, if needed to protect indigenous biodiversity in certain circumstances. This is a seminal judgment as, previously, the Crown and regionalcouncils had operated as if regionalcouncils did not have that power (i.e. that the power rested solely under the Fisheries Act 1996 not the RMA). This is a significant and important change because such decisions could undermine the rights of Iwi and Māori guaranteed under the Māori Fisheries Settlement with the changeddecision-makers having no legislative guidance on the importance of maintaining the integrity of the settlement, or guidance from the Crown as a Treaty partner.

54. Notwithstanding that the Mōtītī decision aimed to provide clarity on the interface between the Fisheries Act and the RMA, subsequent planning processes have demonstrated that the ‘in principle’ determination has resulted in considerable uncertainty and it is proving costly for parties involved. In our response to the NBEB exposure draft we noted that the RMA reform process provided an opportunity to simplify the resource management regime by removing duplication with the Fisheries Act. However, the NBEB in its current form has failed to do this, in fact the levels of duplication across both management regimes has increased in the new bills, with the inclusion of controls to fishing.

Recommendations

55. We remain of the view that the Fisheries Act is the appropriate legislative tool to manage fishing. The use of mechanisms under the Fisheries Act aligns with the agreements made under the Māori Fisheries Settlement and better provides for the ability to ensure protection of biodiversity through appropriate controls on fishing while still enabling levels of customary commercial and non- commercial use consistent with that protection. There are also obligations in the Fisheries Act currently to ensure that adverse effects on the aquatic environment from fishing are avoided, remedied or mitigated (See section 8 of the Fisheries Act).

56. The existing tools in the Fisheries Act should be better utilised so that the perceived gap that the NBE Bill is attempting to fill, can be resolved through the proper use of the existing tools in the Fisheries Act. Coupled with the approach that Te Ohu Kaimoana advocates for in Te Hā o Tangaroa, that would result in better outcomes for the environment, including the right to sustain ourselves through fishing. In that regard,our strong preference is that fisheries and its effects are managed under the Fisheries Act and the duplication removed.

57. However, should the Select Committee determine that both the Fisheries Act and the Bills should regulate fishing, Te Ohu Kaimoana’s expectation is that Māori fishing rights, the Māori Fisheries Settlement and the Treaty of Waitangi (Fisheries Settlement) Act 1992 must be upheld and protected. The final Bills should containanexplicit requirement for decision-makersto assess the effects of their policies, plans and consent decisions on the rights protected by Te Tiriti settlements, including the Māori Fisheries Settlement and the MCASCA when making fisheries management decisions under the RMA.4

58. Further, it is crucial that clear lines and boundaries exist between the management under both Acts, so as to improve certainty and reduce the likelihood of disputes such as that seen in the Northland Proceedings.13 Specifically, the NBE Bill needs to be amended to clarify the scope of overlap between the NBEB and the Fisheries Act, and it is also crucial that if both the NBEB and Fisheries Act are to assist in the management of activities in the CMA, there must be sufficient interface provisions across the statutes.

59. Our recommendations below mirror the ‘alternative solution’ offered by the Rock Lobster Council, the Pāua Industry Council and Fisheries Inshore New Zealand in their joint submission.

60. Specifically, we propose amendments to clause 124(9) restriction which act to provide for ‘an objective,factualjustification for theinclusion of rulesabout fishing in a plan’14 thatarelacking in the bills drafting presently. We propose: i. Controls on fishing should be able to be applied only in discrete areas for which significant biodiversity values have been identified and included in the plan This is consistent with the ‘indicia’ which the Court of Appeal suggested may provide objective guidance when assessing whether a given control would contravene RMA s.30(2) – i.e.: ii. Scope: a control aimed at indigenous biodiversity is likely not to discriminate among forms or species; iii. Scale: the larger the scale of the control the more likely it is to amount to fisheries management; iv. Location: the more specific the location and the more significant its biodiversity values, the less likely it is that a control will contravene RMA s 30(2); v. Rules must relate to the adverse effects of fishing, not to any other type of effects (e.g., trivial effects or positive effects); and vi. The nature of controls that may be placed on fishing should only be prohibition – if a rule were to require a resource consent to be obtained for a fishing activity, that would amount to council involvement in fisheries management.

61. Further, we consider there must be a clearer interface and requirement that decision-makers consider measures applied or able to be applied under the other statute to provide for integrated decision making. Currently the drafting does not adequately mirror the Fisheries Act requirements - while decision-makers under the Fisheries Act must have regard to planning documents under the Bills (including the NPF), decision-makers under the Bills have no equivalent provision requiring them to have regard to fisheries planning documents or regulations. An equivalent provision ensures that management of fisheries effects under the Fisheries Act can be complemented by mechanisms under the Bills and not undermined. It would also ensure that the fisheries and aquaculture settlements continue to be upheld through this regime.

62. Further, the final Bill should contain an explicit requirement for decision-makers to assess the effects of their policies, plans and consent decisions on the rights protected by Te Tiriti settlements, including the Fisheries Settlement and the MCASCA when making fisheries management decisions under the RMA ensuring these rights are upheld across the regime.

63. We recommend that the drafting of Clause 107 - Considerations relevant to preparing and changing plans – be amended by adding two new matters to subclause (2) which a Regional Planning Committee (RPC)must have particular regard when preparing an NBE plan, as follows:

I. Management plans and strategies prepared under other Acts

II. instruments made under the Fisheries Act 1996 relating to ensuring sustainability, or the conservation, management, or sustainability of fisheries resources (including instruments relating to taiāpure, mahinga mātaitai, or other non-commercial Māori customary fishing).

Successful implementation of resource management reform requires Te Tiriti compliant representation and resourcing to achieve partnership

64. Te Ohu Kaimoana are supportive of the intent of the reforms in providing new pathways for partnership for iwi and hapū in the development of the new resource management regime

65. We do, however, have concerns around the quality of this engagement and its ability to meet the threshold for enabling a Te Tiriti partnership.

66. The current provisions for participation at the National and Regional levels (including the National Planning Framework (NPF) and representation on Regional Planning Committees (RPC)) are inadequate to ensure that the reforms are consistent with the principles of Te Tiriti. We support the position that Māori should be represented through iwi and hapū and should have 50/50 representation in appointments at all levels. Anything less than this does not represent a partnership and therefore is not consistent with Te Tiriti

67. Even if membership and representation is 50/50, it is essential that the participation of the NPF and RPC does not usurp the mana of iwi and hapū to exercise their rangatiratanga

68. Te Ohu Kaimoana is seeking a commitment from the Crown to the deliberate development of capability building at the iwi and hapū level to coincide throughoutthe 10-year transitionprocess. This must be accounted for, both through specific Bill provisions, and in successive budgets, to ensure that the reform succeeds and the requirements under Schedule 8 of the NBE are met.

69. Further, adequate resource must also specifically be provided for iwi and hapū to engage in the transitional process provided under Schedule 2 of the NBE Bill. This includes capacity to engage with the Crown, and capacity and expertise to renegotiate the respective settlements. This includes for iwi, hapū, and settlement entities like Te Ohu Kaimoana

Te Tiriti representation in the Development of the National Planning Framework

70. The National Planning Framework will play a significant role in the new resource management system, and it is not an overstatement to say that the success (or otherwise) of the new resource management system largely depends on the quality of the NPF.

71. Presently, the Bills are lacking crucial details on the operation of the reformed system, with the NPF to provide this subsequent to the enactment of the Bills. Given this context, it is increasingly crucial that the NPF is co-designed with iwi and hapū, in accordance with Te Tiriti.

72. The centrality of the National Planning Framework to the system means iwi and hapū as Te Tiriti partners must have direct input into its development. This cannot be left in the current state where a privileged position is provided in legislation over iwi and hapū for a National Māori Entity that does not have a process for accountability to iwi and hapū.

A role for Te Ohu Kaimoana

73. Further to this, we recommend there is a support role by Te Ohu Kaimoana to iwi and hapū as part of this process. The intent of this is not to usurp the mana of iwi and hapū being engaged as Treaty partners in the national and regional planning process. However, we consider there is a role for us in this space alongside iwi and hapū to ensure the Māori Fisheries and Aquaculture settlements are enhanced or maintained through the development of the NPF.

74. Te Ohu Kaimoana has a specific function and purpose as the trustee of the Māori Fisheries and Aquaculture Settlements, and on behalf of our iwi beneficiaries to analyse and advocate on coastal and marine issues. Our involvement alongside iwi and hapū in this process will ensure appropriate safeguards across the NPF exist that protect the Māori Fisheries and Aquaculture settlements, iwi and hapū interests in the coastal marine area and their relationship with Tangaroa. This supports the requirement to give effect to the principles of Te Tiriti and commitments by Ministers’ to protecting and upholding TreatySettlements.

75. While we have largely focused on aspects of the Bills that relate directly to the responsibilities of Te Ohu Kaimoana under the Māori Fisheries and Aquaculture Settlements, we have also been working closely with other parties, and there are several aspects of their submission that we would like to support and reinforce.

76. The Freshwater Iwi Leaders Group submission provides a comprehensive analysis of the Bills, and we support, in particular its analysis and recommendations in relation to: i. Support for the inclusion of the concept of Te Oranga o te Taiao and elevation of consideration for the principles of Te Tiriti. We also hold their concerns that while the intent is clear in the Bills that the principles of Te Tiriti are to be given effect and Te Oranga o te Taiao is to be recognised and upheld throughout the regime, those standards are not reflected in the more operative and technical aspects of the Bills. We agree that additional work is required to ensure that the Bills operationalise their stated intent with respect to Te Tiriti and Te Oranga o Te Taiao across the entire resource management system. ii. We also share their concern regarding the National Māori Entity and agree it should be removed from the Bills If it is not removed from the Bills, we agree that the appropriate role for this entity is to provide an auditing function and the remit of this entity as described currently in the Bills extends beyond its stated purpose.

77. We note our position varies from the FILG submission in relation to clause 71, which provides that a regionalplanning committee must amend a plan if a plan rule duplicatesor conflicts with a frameworkrule. A plan rule is determined to conflict with a framework rule if: a) The plan rule is more stringent than the framework rule and the framework rule does not expressly say that a plan rule may be more stringent;or b) The plan rule is more lenient than the framework rule and the framework rule does not expressly say that a plan rule may be more lenient.

78. The FILG submission opposes the first limb of this test, instead stating that local communities should be able to make more stringent rules when local circumstances demand that. We generally support this position, however, there are specific circumstances in relation to the management of marine aquaculture that requires us to differentiate our position. The National Environmental Standards for Marine Aquaculture (NES-MA), in effect, set a ‘ceiling’ or upper limit on the kind of rules that can apply rather than a ‘floor, except where existing aquaculture is in an “inappropriate” area. If it were possible to set more stringent or restrictive rules in each region, then the purpose of the NES-MA would be defeated. While this is a limited circumstance, it is important to differentiate our position on this point.

79. The NZ Rock Lobster Council, the Pāua Industry Council and Fisheries Inshore New Zealand have also shared their joint submissions with us. We agree with their analysis that there is a lack of clarity in theNBE billat present regarding the marine biodiversityprovisions, in particular the lack of clarity in both the intent and effect of these provisions. We further support their recommendation that appropriate marine knowledge, experience and expertise is required when decisions are being made in relation to the CMA, including in the development of the NPF, NBE plans and Regional Spatial Strategies.15

Discrete amendments required to provide for the Māori Fisheries and Aquaculture Settlements

80. While ensuring the proper provision for upholding the intent of the Māori Fisheries and Aquaculture Settlements through the process set out in Schedule 2 of the NBEB is dealt with earlier in our response, there are several specific amendments to the Bills that are required to ensure that: i. The provision for some forms of aquaculture being a permitted activity does not compromise Crown obligationsto iwi under MCACSA, the Marine and Coastal Area Act 2011, andNgā Rohe Moana o Ngā Hapū o Ngāti Porou Act 2019; ii. Protections be provided for the rights and entitlements provided through the Māori Fisheriesand Aquaculture Settlements - these could be expressedin a similar manner to the drafting provided to recognise customary marine title and protected customary rights under the Marine and Coastal Area (Takutai Moana) Act 2011; and iii. The current mechanicsproviding for the MāoriAquaculture Settlement under the RMA are maintained or improved.

81. We have populated the table below (Appendix 1) with a clause by clause analysis on discrete amendments that are required to provide for the Māori Fisheries and Aquaculture Settlements. While we have touched on some of these in the body of this response, the table contains a number of important technical amendments for the Bill to ensure alignments with the settlements. We are happy to discuss these recommendations should further clarification on the technical detail be required.