My submission from a template, but personalised. Here
Subs close tonight, July 23rd. Tis a sunny day and welding calls.
This is no wow wow look at me post.
This is a post despite the tug of sunshine and outdoor missions in what has been a saturated wet as time……….this is something I can do in the face of Aotearoa NZ being taken in a direction I do not want, nor want for my kids kids.
The rich and sellout politicians must have no offspring to care for, and the mighty dollar sleeps with them at close quarters it seems.
anyways
here it is.
Thanks for being here.
Namaste
Graham
Submission of Graham Hughes
Overseas Investment (National Interest Test and Other Matters) Amendment Bill
To: Finance and Expenditure Committee
Re: Submission on the Overseas Investment (Forestry and Other Matters) Amendment Bill 2024
From: Graham Roger Hughes
Date: 23rd of July 2025
Tēnā koutou,
I am a 68 year old retired school teacher.
I am concerned deeply about the direction this current government is taking us in.
I do not write out of an partisan emnity, I write out of concern for our country, and my childrens children.
Submission on the Overseas Investment (Forestry and Other Matters) Amendment Bill
I appreciate the opportunity to comment on the proposed amendments to the Overseas Investment Act 2005. While the Bill has been presented as a means to streamline investment approvals and reduce regulatory complexity, I have significant concerns that it substantially erodes existing protections for land that is environmentally, culturally, and historically sensitive. The proposed changes undermine public interest safeguards and the principles of responsible stewardship over Aotearoa New Zealand’s most precious and irreplaceable natural and cultural heritage.
Key Concerns
1. Weakening of the Benefit to New Zealand and Investor Tests
The Bill removes mandatory application of the Benefit to New Zealand test (section 16A) and Investor Test (section 18A) for land that is classified as “sensitive” under Schedule 1—excluding residential and farm land.
This includes:
Conservation land
Offshore islands
Marine and coastal areas
Lakebeds
Wāhi tapu and historic heritage sites
Māori reservations and post-settlement governance entity lands
Te Urewera and Te Awa Tupua (Whanganui River)
These lands would no longer be assessed for the public, environmental, or cultural benefits of overseas acquisition, nor for the character or capability of the foreign investor. Instead, they would be subject only to a discretionary “national interest test” that can be waived or narrowly applied by the Minister, significantly lowering the threshold for approval.
2. Risk of Irreversible Harm to Conservation and Cultural Values
By removing automatic application of the benefit and investor tests, the Bill opens the door for foreign acquisition of ecologically significant or culturally sacred lands without adequate public interest oversight. For example:
A foreign mining company could lease or purchase native forest on a remote island without meeting character requirements or demonstrating public benefit.
A private offshore investor could acquire a wahi tapu or heritage-protected island without any obligation to preserve its values.
This could result in permanent degradation of biodiversity, ecosystems, and places of deep cultural significance, especially those held by Māori under Treaty settlements or customary association.
3. Disproportionate Focus on Economic Expedience Over Long-Term Stewardship
While the government has claimed the Bill will enable quicker investment decisions, it does so by eliminating crucial checks and balances. Economic expediency should not come at the cost of compromising the integrity of our environmental and cultural guardianship responsibilities.
The “benefit test” provides specific criteria – including job creation, environmental enhancement, public access, and protection of heritage values – that are now at risk of being entirely disregarded. These are vital levers for ensuring that overseas investment serves the public good, not just private profit.
4. Disempowerment of Māori and Breach of Te Tiriti Principles
The amendments disregard the relationship of Māori with taonga tuku iho, including whenua, wai, and wāhi tapu. Although the current Act is imperfect and lacks explicit Te Tiriti o Waitangi recognition, recent improvements have enhanced safeguards for Māori interests in land. This Bill reverses that progress and risks undermining mana whenua over places that carry deep ancestral and spiritual significance.
The removal of protections on Māori reservations and co-governed lands such as Te Urewera and Te Awa Tupua is particularly alarming. It fails to uphold Te Tiriti guarantees of tino rangatiratanga and partnership in decision-making over whenua Māori.
5. Lack of Transparency and Public Awareness
The most sweeping and damaging aspects of the Bill have received little or no public attention. The changes to protections on conservation land, coastal areas, and wāhi tapu are not clearly signalled in the explanatory materials and require complex cross-referencing to identify. Such lack of transparency undermines democratic accountability and public trust.
6. Precedent Risks and Treaty-Locking via Free Trade Agreements
I am also concerned that once the Act is amended, the weaker regime may be locked in under free trade and investment protection agreements, particularly in relation to non-farm land and water assets. This could make future governments unable to restore stronger protections without triggering investor-state disputes or trade retaliation.
7. Removal of Protections for Forestry Investments.
For investments in forestry, I oppose the removal of:
the “Benefit to New Zealand test” in section 16A of the Act, where the benefits assessed (section 17) include economic benefits such as jobs and introduction of technology, benefits to the natural environment, enhanced access to the public, and protection of historic heritage; and
the mandatory “Investor test” in section 18A of the Act.
Instead, whether this test is considered will be up to the Overseas Investment Office and the Minister.
Given current and recent events in regions including Tairāwhiti, these proposed amendments can only be described as harmful and inexplicable.
They serve the interests of international forestry investors at the expense of the New Zealand economy and New Zealanders,
and fly in the face of the overwhelming evidence of very high costs incurred by taxpayers and ratepayers that have arisen from poorly assessed and monitored overseas investments in forestry operations in New Zealand.
Recommendations
Retain the Mandatory Application of the Benefit to New Zealand and Investor Tests for all categories of sensitive land as defined in Schedule 1 of the Act.
The “Benefit to New Zealand test” in section 16A of the Act, and the “Investor test” in section 18A of the Act should remain mandatory for overseas forestry investments in New Zealand.
The ‘Investor test’ should be strengthened to ensure that international forestry companies with poor track records are not permitted to invest in New Zealand.
Include Explicit Recognition of Te Tiriti o Waitangi in the purpose and principles of the Overseas Investment Act, and require engagement with mana whenua on any investment involving Māori land or taonga sites.
Strengthen, Rather Than Weaken, Protections for Water Resources, Conservation Land, and Wāhi Tapu, including by ensuring all applications involving these assets are publicly notified and undergo full assessment under the existing tests.
Undertake Further Public Consultation and a Regulatory Impact Assessment on the implications of removing protections from non-farm sensitive land, with particular regard to indigenous rights and environmental outcomes.
Pause the Passage of the Bill until these matters are properly reviewed and any amendments ensure that overseas investment serves the collective interests of current and future generations.
This Bill represents a significant backward step in the protection of Aotearoa’s environmental and cultural heritage.
At a time when the public is demanding stronger kaitiakitanga and protection of water, whenua, and biodiversity, these changes hand more power to foreign investors with fewer obligations to the communities, environments, and tangata whenua affected.
I urge the Committee to reject the Bill in its current form and to ensure that any overseas investment regime upholds the highest standards of environmental stewardship, cultural respect, and public benefit.
And for the benefit of future generations of Kiwi kids...............surely the wealthy have children they wish a better New Zealand for?
Seems not with what is happening with current legislation being pushed through in Aotearoa New Zealand.
Nāku iti noa, nā
Graham Hughes
I appreciate that you took he time and the energy to make the submission! Even if it feels like shouting into the void. Even if it steals your sunshine. Arohanui.
Well said. I find it appalling that they’re banning Te Reo from schools and proposing to sell off 67% of forest reserves. We are as bad here in Australia - though admittedly including (First Nations) Language as part of the curriculum is trickier, given we have about 800 of them .