No Animal Left Behind: A Thematic Analysis of Public Submissions on the New Zealand Emergency Management Bill

Abstract

This article presents a thematic analysis of submissions made on New Zealand’s Emergency Management Bill. While a key focus is on the importance and frequency of animal welfare concerns raised by submitters, the analysis also examines other critical themes to provide context on the range of issues addressed. The impact of the “No Animal Left Behind” campaign launched by Animal Evac New Zealand in mobilising public engagement on animal welfare provisions is also assessed. Sixty-one percent (n = 191) of public submissions on the Bill raised the importance of including animals in new emergency management legislation and at least 48% (n = 149) of all public submissions were directly attributed to the campaign. Key animal welfare concerns include the need for clear statutory powers and requirements, better coordination and resourcing, and recognition of the human–animal bond. Other prominent non-animal-related themes relate to strengthening community resilience, improving Māori participation in emergency management, and enhancing readiness and response capabilities. Specific recommendations are made for legal changes to better protect animal welfare, including amending key provisions to explicitly address animal rescue and evacuation, mandating animal welfare emergency plans, strengthening animal seizure and disposal processes, and enhancing accountability for animal emergency response charities. With improving animal disaster management law being the most common issue identified, it is logical for a government to apply deliberative democracy to ensure animals are better protected in New Zealand emergency management reforms. The findings underscore the importance of comprehensive, multi-faceted reform to create a world-leading emergency management framework.

1. Introduction

New Zealand’s exposure to diverse natural hazards necessitates a robust and adaptable emergency management framework [1,2]. The Emergency Management Bill aims to replace the existing Civil Defence Emergency Management Act 2002 and modernise the system [3]. This article examines submissions on the Bill, with a dual focus on animal welfare concerns and other key themes, to provide a holistic view of stakeholder perspectives. It evaluates how the impact of advocacy initiatives has influenced elevating animal welfare while situating this within the broader emergency management landscape of issues raised. Specific attention is given to proposed legal changes to address identified gaps and strengthen the framework.

While public submissions were open to the public, the animal disaster management charity Animal Evac New Zealand, launched a nationwide campaign to mobilise citizen input into the Bill. This campaign was known as “No Animal Left Behind” and was publicised through online advertising, electronic billboards throughout the country (n = 19), and interviews with media and podcast producers [4]. The campaign URL www.noanimalleftbehind.nz directed people to a webpage that provided information on the Emergency Management Bill process and provided 26 recommendations for submitters to select and use to address current legal gaps [4]. It was the largest animal disaster management campaign in New Zealand history with an estimated value of over NZD 300,000 and creating 586,996 impressions over a range of digital platforms operated by MediaWorks between 14 and 27 August 2023 [5]. The scale of this campaign provides a useful case study for analysis.

Since the closure of public submissions for the Emergency Management Bill in October 2023, several independent reviews examining emergency management practices in New Zealand have been published. This has led the responsible Minister to announce that a new Bill would be introduced to address the identified shortcomings and failures within the existing system, rather than proceeding with the current Emergency Management Bill [6]. Although this study analyses submissions to a now discontinued Bill, it provides valuable insights that can inform the drafting of future legislation to ensure its effectiveness and comprehensiveness.

This study represents a rare empirical analysis of public submissions on a legislative bill, conducted independently and intended for peer-reviewed publication. Such analyses are uncommon in the academic literature, with most similar efforts typically undertaken by government bodies, potentially subject to political biases and lack of transparency [7]. To our knowledge, only one comparable academic study has been conducted in New Zealand: the 2008 analysis by Park et al. from the University of Auckland, which examined written public submissions on Human Assisted Reproductive Technology [8].

This research addresses a critical gap in the literature, offering a transparent, academically rigorous approach to analysing public input on proposed legislation. By conducting this independent analysis and submitting it for peer review, this study aims to contribute to a more unbiased understanding of public engagement in the legislative process. This approach not only adds to the limited body of academic work in this area but also sets a precedent for future researchers, potentially leading to a more comprehensive understanding of public opinion on legislative issues across various contexts and jurisdictions.

By incorporating the findings and recommendations from the independent reviews, considering the concerns, priorities, and expectations of various stakeholders, and identifying common themes, recurring problems, and potential solutions that may have been overlooked in the original Bill.

2. Literature Review

Recent scientific advances have expanded our understanding of animal cognition and welfare, leading to important developments in how we conceptualise and relate to other species. The concept of animal sentience—the capacity to have feelings and experiences—has gained increasing recognition, with evidence suggesting many animals possess complex cognitive and emotional abilities [9,10]. This growing awareness has contributed to the One Health approach, which recognises the interconnections between human, animal, and environmental health, including in disaster contexts [11].

Concurrently, the biophilia hypothesis proposes that humans have an innate affinity for other living things [12], helping explain the numerous physical and psychological benefits of human–animal bonds. These bonds can be particularly valuable during and after disasters, as companion animals can provide emotional support and help reduce stress for affected individuals [13,14].

The body of knowledge on animal disaster management has grown significantly in recent years, with several key scholarly works contributing to the field. Heath’s 1999 seminal book on animal disaster management marked the start of research and focused publications in the field [15]. Irvine’s book “Filling the ark: Animal welfare in disasters” then provided a comprehensive overview of the challenges and opportunities in protecting animals in emergencies [16]. Irvine highlighted the need for the greater inclusion of animals in disaster planning, the importance of the human–animal bond, and the potential for animal welfare to serve as a gateway to broader community resilience [16].

Potts and Gadenne built on this foundation with their analysis of lessons identified from the Christchurch earthquakes in “Animals in emergencies: Learning from the Christchurch earthquakes” [14]. They underscored the complex interdependencies between human and animal welfare in disasters. Travers et al. conducted a scoping review of scholarly sources on companion animals in natural disasters, identifying key themes around evacuation, sheltering, and the human–animal bond [17].

In the United States, Heath and Linnabary examined the specific legislative and organisational challenges in managing animals in disasters [18]. They identified issues such as weak animal health infrastructure, a lack of measurable standards for animal emergency plans, and funding being diverted from animal emergency management to other purposes.

In the New Zealand context, Glassey and Wilson provided an early assessment of animal welfare impacts following the 2010 Canterbury earthquake [2]. Glassey later analysed the legal complexities around the rescue, seizure, and disposal of disaster-affected companion animals [19]. Glassey et al. conducted a mixed-methods study of companion animal owners’ experiences of the 2017 Edgecumbe flood, revealing issues with evacuation, animal welfare, and disaster preparedness [20].

Conceptual works have also advanced thinking in the field. Glassey situated animal disaster management within the public policy construct of ‘wicked problems’ [21]. Vieira and Anthony proposed an ethical framework for animal caretaking in disaster planning [22]. Thompson et al. [23] and Taylor et al. [24] explored the influence of the human–animal bond on evacuation behaviour and risk perception.

This growing body of research underscores the importance of proactively addressing animal welfare in emergency management. However, gaps remain, particularly in evaluating the effectiveness of legislative and policy frameworks, understanding community experiences, and assessing organisational learning [25,26]. The current study aims to contribute to addressing these gaps in the New Zealand context and provides new insights and perspectives to inform and enhance animal disaster management arrangements.

3. Methodology

3.1. Data Collection

The primary data consisted of 310 written public submissions made to the Governance and Administration Select Committee from July to October 2023, accessed through the New Zealand Parliament website [27] on 2 May 2024.

Initially, 261 submissions were sourced from the New Zealand Parliament website; however, it was later identified that an additional 49 (n = 15%) had not been published on the website due to an unknown reason (Governance and Administration Committee, personal communication, 10 May 2024). The missing submissions were later added to the website and included in the data collection.

3.2. Thematic Analysis

Submissions were analysed using Braun and Clarke’s thematic analysis approach, involving data familiarisation, initial coding, theme development, theme review and refinement, and report production [28]. Particular attention was paid to animal welfare references, the “No Animal Left Behind” campaign, and proposed legal amendments. The author as an advocate for improved animal disaster management law wanted to see whether the “No Animal Left Behind” campaign influenced public submissions on the Emergency Management Bill, and whether there were any other animal-related considerations for disaster management reform that had not been identified in previous works including the 2019 Animal Evac New Zealand report presented at the New Zealand Parliament with the support of Gareth Hughes MP and former FEMA Administrator Craig Fugate [29].

4. Results

4.1. Overview of Submissions

A total of 310 submissions were received, in contrast to the inaugural Civil Defence Emergency Management Bill (Bill 79-1) introduced in 2000, in which only 80 public submissions were received by the Select Committee (Office of the Clerk of the House of Representatives, personal communication, 2 October 2023).

Submissions came primarily from private submitters (73.6%). Submissions were also made by local government (7.1%), businesses (4.6%), non-government organisations (3.5%), non-animal/agricultural industry bodies (4.1%), animal/agricultural industry bodies (1.3%), and other entities (5.8%).

Out of the total 310 submissions received, 191 (61%) specifically addressed the topic of animal welfare in disasters. This represents a significant proportion of submissions.

The thematic analysis revealed several key themes related to animal welfare that emerged consistently across the submissions. These themes provide insight into the public’s priorities, concerns, and expectations for animal-inclusive emergency management legislation. The most prominent animal-related themes included the following: the importance of animal welfare; the need for clear statutory powers and requirements; calls for better coordination and resourcing; and recognition of the human–animal bond. Each of these themes is explored in more detail below, with illustrative quotes from the submissions used as supporting evidence.

4.2. Key Animal Welfare Themes

4.2.1. Importance of Animal Welfare

Forty-eight percent of submissions (n = 149) suggested that animals should be explicitly recognised in legislation as sentient beings deserving of care and protection during emergencies, aligning with growing recognition of animals’ intrinsic value and social significance. One respondent agreed that they supported the recommendation made by Animal Evac New Zealand, including specific changes to recognise animals in legislation.

They also commented that “I never had children, my pets are my children. In a disaster I would never want to have to walk away and leave my pets”. (Submission #201)

Another respondent emphasised that “The principle of ‘No animal left behind’ is crucial not only from ethical perspective. Animals are often true family members, and not securing their rescue and being reunited with the family increases the owners’ distress and may lead to desperate actions by the owners to find and save their animals, including breaking the disaster management rules”. (Submission #36). These quotes illustrate the strong belief among many submitters that animals have intrinsic value and moral status that should be reflected in emergency management law.

There were no submissions that sought to oppose improvements to animal welfare in emergencies; however, one submission placed a caveat on their support for animal-inclusive changes:

“It’s well documented that in a disaster, many people will prioritise their pets over their own safety, and this should be recognised by making legislative provision for the care of animals in an emergency. However, I add the caveats that points 8 and 9 of their submissions (relating to the definition of “life”) may create unintended consequences in their broadness, and point 6 (requiring Controllers to consult a vet before destroying an animal) may not always be practical or possible during an emergency”.

(Civil Defence volunteer, Submission #86)

Several submissions also highlighted the social and cultural significance of animals in New Zealand society. One noted that “pets are considered members of the family by many New Zealanders and their welfare should be a priority in disasters” (Submission #112). Another stated that “animals play vital roles in our economy, ecosystems and social fabric—protecting them in emergencies is protecting who we are as a nation” (Submission #263). These perspectives underscore the multifaceted importance of animals and the need for emergency management legislation to align with contemporary social values.

4.2.2. Need for Clear Statutory Powers and Requirements

Submissions called for clearer statutory powers and requirements relating to animal rescue, evacuation, and care. Gaps in current legislation were highlighted, with calls for unambiguous authority and obligations for agencies and owners. These gaps were referenced by 48% of submissions who referred to the 26 recommendations made in the “No Animal Left Behind” campaign. In respect to statutory powers and requirements, these recommendations included preventing the unilateral destruction of animals by officials, ensuring powers of entry included for the protection and rescue of animals, mandating animals are included in emergency plans, ensuring funding be made available for companion animal disaster welfare response costs, and changing government department responsibilities including the National Emergency Management Agency (NEMA) to coordinate animal disaster management, with the Ministry for Primary Industries (MPI) to focus on animals on farms and in laboratories and zoos, and Fire and Emergency New Zealand (FENZ) to lead integrated animal–human rescue operations.

Submissions also included comments by local authorities in which one recommended that the Governance and Administration Committee:

“Include provisions in the Bill that explicitly deal with animal welfare and resolve the identified ambiguity across different legislation about what actions can be taken and by whom for ensuring the welfare of animals in emergencies”.

(Local council, Submission #240)

Several submissions raised the importance of veterinary services being seen as an essential service within emergency management as it already is under biosecurity and pandemic emergency arrangements.

“…the lack of legislated funding and support for veterinarians working alongside other emergency services during Cyclone Gabrielle, placed a significant mental, physical and financial burden on affected veterinary practices, to the point where there was concern whether they could continue to operate. The contribution the veterinary industry makes as essential workers during times of national crises needs to be formally acknowledged and planned for as part of any emergency response plan”.

(Veterinary practice, Submission #237)

These quotes highlight the current gaps and inconsistencies in the legal framework that create uncertainty around roles, responsibilities, and powers for animal welfare in disasters. Submissions advocated for the new legislation to provide a clear and comprehensive mandate to enable effective animal emergency management.

4.2.3. Coordination and Resourcing

The need for better coordination and resourcing of animal emergency management including disaster veterinary services was emphasised. Submissions advocated for a nationally mandated and funded framework, clear roles and responsibilities, and improved funding mechanisms.

“The separation of human and animal welfare in the Emergency Management Bill is a major concern. Many veterinary professionals argue that a failure to understand interdependency between human and animal welfare creates unintended divisions and results in ineffective emergency responses”.

(Submission #48)

“We also supported Trifecta in concluding the current Act provisions as not providing adequate arrangements for appropriate animal welfare during emergencies, (declared or undeclared). There are significant gaps in who is responsible for different elements of animal welfare; defining eligible versus non-eligible animals; and resourcing the care for animals”.

(Local council, Submission #240)

“We note the submissions raised to include animal evacuation to be given the same status and requirements as human. While this is part of our current practices (when it is practical), we highlight the need for prioritising human life and where animal evacuation is possible, support is needed to resource this via centrally funded means, including reimbursement of costs and support for appropriate facilities”.

(Local council, Submission #252)

“We are concerned that the Bill does not provide appropriately for animal welfare during emergencies, declared or undeclared. There are significant gaps in who is responsible for different elements of animal welfare; defining eligible versus non-eligible animals; and resourcing the care for animals”.

(Mayoral Forum, Submission #30)

These excerpts demonstrate the fragmented and under-resourced state of current animal emergency management arrangements. Submissions advocated for the legislation to provide an integrated, properly funded framework with clear accountabilities to enable a coordinated and effective animal welfare response.

4.2.4. Human–Animal Bond

Recognition of the powerful human–animal bond and its implications for emergency management was another cross-cutting theme. Many submissions emphasized the strong attachments between people and their pets, and the risks people will take to protect them in disasters. One respondent commented the following: “It’s well documented that in a disaster, many people will prioritise their pets over their own safety, and this should be recognised by making legislative provision for the care of animals in an emergency”. (Submission #86)

“To many peple [sic] their companion animals are their “children” they would do as much to protect those animals as anyone else would to protect their human family. Forcing people to evauate [sic] without these animals besides being morally wrong means that those people often will not leave the site willingly or go back afterwards “illegally” to save them”.

(Submission #215)

These perspectives highlight the critical influence of the human–animal bond on people’s decision-making and behaviour in disasters. Submissions called for the legislation to acknowledge this reality and proactively address it through animal-inclusive planning and provisions. By protecting animals, the legislation would also protect human life and safety.

4.2.5. Impact of the “No Animal Left Behind” Campaign

The “No Animal Left Behind” campaign by Animal Evac New Zealand in 2023 significantly influenced public submissions on animal welfare issues in the Emergency Management Bill. The campaign provided a clear platform for advocacy and public engagement, mobilising participation in the policy process. As a result, 149 out of the 191 submissions (78%) that raised animal welfare issues referenced the “No Animal Left Behind” campaign. A total of 149 submissions (48%) of all submissions, regardless of issues raised, made reference to the “No Animal Left Behind” campaign.

4.3. Other Key Themes

Submissions also raised numerous non-animal specific issues including community resilience, Māori participation, readiness and response capabilities, recovery and risk reduction, accountability and transparency, and underwhelming reform.

4.3.1. Community Resilience

Many submissions stressed the importance of empowering communities to prepare for and respond to emergencies. Building local capacity, strengthening social capital, and harnessing community knowledge were seen as crucial for resilience. For example, one excerpt stated the following:

“We also heard that some disabled people had difficulty accessing support especiallywhen it came to assisting with property clean ups and experienced disruption todisability support services and activities. These factors reinforce the need for a more informed, joined-up disabled people/disabled community-led civil defence response in future climate-related and other emergencies”.

(Submission #56)

4.3.2. Māori Participation

The need to honour Treaty of Waitangi (Te Tiriti o Waitangi) obligations and ensure meaningful Māori participation in emergency management was a recurring theme. Submissions called for greater recognition of Māori perspectives, knowledge, and leadership at all levels.

Specific changes to the Bill were suggested by many submitters, including one example submission that “…strongly recommends that the Emergency Management Bill includes a section in Part 1: Preliminary provisions requiring that all persons exercising powers and performing functions and duties under this legislation must give effect to the principles of Te Tiriti o Waitangi”. (Submission #234).

There was also a minority (n = 7, 2%) that raised concerns over race-based or Māori-specific provisions, with these being labelled as divisive and racist.

4.3.3. Readiness and Response Capabilities

Enhancing the readiness and response capabilities of the emergency management system was a key focus. Submissions called for clearer statutory powers and requirements, improving inter-agency coordination, and concerns over funding.

“It is noted expressly that ‘No new funding powers are proposed to be created in the legislative reforms or funding provided in any supporting package of policies to address any capacity issues in the emergency management system’”.

(Submission 256)

“The lack of consistent application of the Coordinated Incident Management System (CIMS) across agencies and partners has been identified in previous reviews as an issue. In its present form, the Bill does not address this issue”.

(Submission 161)

While many supported the overall intent and direction of the Bill, there were significant concerns raised around the lack of funding to implement the changes, the need for role clarity, and the importance of better integration with other reforms to enable a systems-based approach to improve the emergency management system.

4.3.4. Recovery and Risk Reduction

Submissions emphasised the importance of effective recovery processes that address the long-term needs of affected communities. Proactive disaster risk reduction measures, including land-use planning, clarifying risk reduction roles and responsibilities, and strengthening critical infrastructure were also highlighted as essential for building resilience.

“The current EM (emergency management) system is focussed on readiness and response, and this Bill maintains that approach. While these are important, more work needs to be done within the EM framework to better support risk reduction and recovery—in an integrated way. The Cabinet Paper that sought approval to introduce the Bill (LEG-22-SUB-0239) noted that there may be concern the Bill does not sufficiently address climate change, and does not address increased funding for risk reduction or recovery. LGNZ holds these concerns. EM committees’ role in risk reduction is also unclear”.

(Submission 136)

Essential animal welfare and veterinary services were highlighted to be included as part of recovery powers and functions.

4.3.5. Accountability and Transparency

The need for robust accountability mechanisms and transparency in decision-making was stressed. Submissions called for clear performance standards, regular reporting, independent oversight, and opportunities for public participation.

“There appears [to be] insufficient mechanisms for accountability in emergency management. Modern emergency management system such as those in Queensland and Victoria, have an Inspector-General, an independent statutory person who oversees an assurance framework. This would prevent the continued “reviews” of emergencies being undertaken by persons who have no or little qualifications in emergency management”.

(Submission #263)

The submission made by the Office of the Ombudsman (Submission #310) highlighted governance challenges, critical infrastructure issues, and concerns regarding deaf and disabled persons. Of particular interest were comments around the accountability of entities involved in emergency management, specifically:

“It therefore seems appropriate that private entities carrying out public functions during an emergency also should be properly subject to an Ombudsman’s oversight as well as general expectations of transparency under the official information regime. This could be done in a targeted way by referring to the acts/omissions of these entities only so far as they relate to their statutory obligations under the Bill”.

4.3.6. Underwhelming Reform

Despite general agreement on the need for reform, there was a clear theme that the Bill fell short of adequately addressing the issues and inadequacies of the existing emergency management system.

“…the Bill in its current form is also something of a disappointment. It marks a minimalist approach to legislative change in the field and lacks ambition. It is little more that [sic] an updating of the current Act and although it incorporates some of the lessons of the past decades it does not address the overall issues that need to be addressed. It is in effect a missed opportunity and one which I suspect that Aotearoa New Zealand will live to regret”.

(Professor of Law, Submission #132)

Other submissions highlighted specific concerns over the animal welfare emergency management arrangements:

“It is disappointing to see how little progress has been made in this space since 2010”. (Veterinary Association, Submission #167)

“Despite having primacy for animal welfare at national and regional levels, Ministry for Primary Industries are focused on commercial farming livestock and not other animals. This leaves a huge gap for companion animals. DGL 11/1531 implies territorial authorities pick up the animal welfare coordination role with local animal welfare service providers, but this has never been resourced and local animal welfare providers have not been empowered or resourced to deliver on this”.

(Local council, Submission #240)

5. Discussion

The thematic analysis of public submissions on the Emergency Management Bill reveals strong support for strengthening legislative provisions for animals within disaster management arrangements. The recognition of the importance of animals, calls for mandatory animal-inclusive planning, endorsement of advocacy campaigns, and specific amendment proposals all point to a public expectation that disaster legislation should comprehensively address animal welfare.

These findings align with growing international recognition of the need to integrate animals into disaster planning and response. The Sendai Framework for Disaster Risk Reduction 2015–2030, adopted by the United Nations in 2015, calls for an “all-of-society engagement and partnership” in disaster risk reduction, including engagement with “civil society, volunteers, organised voluntary work organisations and community-based organisations” [30] (p. 13). This inclusive approach necessarily encompasses the needs and roles of animals and animal welfare organisations.

The submissions also reflect the evolving societal understanding of animals as sentient beings deserving of moral consideration and legal protection. This shift is evident in recent amendments to animal welfare legislation in New Zealand, such as the Animal Welfare Amendment Act (No 2) 2015, which recognised animals as sentient and introduced new offences for animal cruelty [31]. Extending this recognition to the disaster context is a logical progression.

However, translating these principles into effective legislation is not without challenges. As White [32] and Glassey [19,26,33] note, disaster laws often struggle to accommodate the complex needs and roles of animals, leading to gaps and inconsistencies in protection. The specific proposals put forward by submitters on the Emergency Management Bill attempt to address some of these complexities, but their feasibility and effectiveness would need to be carefully assessed.

Moreover, as the submissions highlight, legislative change is only one piece of the puzzle. Effective animal-inclusive disaster management also requires operational planning, resource allocation, capacity building, risk management, and coordination between agencies [16,17,26]. The Bill can provide a legislative foundation for this work, but its success will depend on the commitment and collaboration of all stakeholders.

The submissions also emphasise the importance of considering the welfare of all animals in disasters, not just companion animals. While much of the focus was on pets, some submitters also highlighted the need to protect livestock, wildlife, and service animals. This aligns with the growing recognition of the interconnectedness of human, animal, and environmental health under One Health [11,22,34]. A truly holistic approach to disaster management must consider the impacts on all animals and their habitats.

Another key theme emerging from the submissions was the importance of collaboration and coordination between government agencies, animal welfare organisations, and other stakeholders. Many submitters highlighted the vital role played by animal charities, rescue groups, and volunteers in disaster response, and called for this to be formally recognised and supported in the legislation. This echoes the findings of researchers such as Travers et al. [17], Glassey [26,35], and Sawyer and Huertas [36], who argue that effective animal-inclusive disaster management requires a collaborative, multi-stakeholder approach that leverages the expertise and resources of all sectors. Glassey goes further to present the concept of One Rescue, which espouses an integrated approach to human and animal rescue and wider emergency management, citing numerous benefits such as reducing evacuation failure, improving search efficiency, reducing duplication of effort, and improving trust in public authorities [21,26,37].

The Emergency Management Bill presents an opportunity to incorporate this principle in legislation and provide a platform for ongoing cooperation.

However, some submitters also cautioned against over-reliance on volunteer organisations, noting that they are often stretched thin and under-resourced. This highlights the need for a balanced approach that recognises the complementary roles and responsibilities of government, civil society, and individuals in protecting animal welfare in disasters.

A cluster of submissions (n = 10) advocated for the explicit inclusion of animals in Clause 102 of the Emergency Management Bill, which pertains to entry onto “premises” for rescue purposes. It appears the submissions are based on defining premises as limited to buildings. However, the Bill contains no definition of “premises” but caselaw has defined the term more broadly such that it would already encompass farms. While “premises” is an ordinary word not defined in the Bill, its meaning must be taken from the context in which it is used and prior precedent. In this instance, it is established in New Zealand law that land can be considered “premises”, does not require buildings, and can include farmland (In re Alloway. New Zealand Law Reports. 1916, pp. 433–434). Contrary to the cluster’s recommendation, “premises” is the most appropriate means to ensure farmland and the structures within are included and no change is required. Paradoxically, many submissions within this cluster also seek to categorise animals as “property” within the context of emergency management law. This stance is at odds with research conducted by Best [38] who argued that “the status of animals as ‘property’ under law increases their exposure to hazards and affects their priority in disaster planning and response”. Therefore, their proposed changes may inadvertently increase the vulnerability of animals by perpetuating a diminished legal status of animals within the emergency planning framework. Furthermore, the cluster of submissions called for the seizure of animals for their safety. This provision already exists in the current law and is proposed to be carried forward in the new Bill. The use of the power to “seize” is also more appropriate than rescue as by common definition, “rescue” may be conditional to the situation presenting imminent danger, which may not always be the case in a disaster. In previous New Zealand disasters, the stock was isolated from safe pasture or food such as in the 2010 Darfield earthquake [2] and the 2017 Edgecumbe flood [20]. This involved stock unable to access water due to fault scarps and stock left stranded in flood water, respectively. In both situations, there was no imminent threat to the animals’ lives, but interventions (such as relocation) were needed to protect their welfare and the livelihoods of farmers. The impacts of flooding on dairy cattle farms should not be underestimated given surviving animals are often at risk from mastitis, lameness, bacterial and parasitic diseases, injuries, stress, and malnutrition [39]. However, a significant oversight in the cluster of submissions is not addressing the lack of provisions in the Bill for the disposal of seized items, including animals. This omission leaves seized (i.e., rescued) animals in legal limbo, with no clear pathway for their care, disposal, or rehoming [19,26]. Though, many of this cluster attributed these recommendations to the New Zealand Veterinary Association, it is not clear from the submissions where these positions were sourced.

Within the cluster, a few (n = 3), all from farming industry bodies made an additional recommendation along the following lines:

“… Clause 102 is expanded to ensure anyone who enters a farm for animal welfare reasons during a declared emergency must only do so if authorised by the response governance function”. (Submission #52)

The sub-cluster submissions (n = 3) provided no rationale for the addition. However, one possible reason could be to deter or prevent animal rights organisations from entering their premises as has occurred in disasters such as the Buck Eye farm disaster in 2000, in which several tornados struck leaving over one million hens trapped in their damaged shed [16]. As Irvine [16] (p. 49) suggests, “allowing rescuers in would allow outsiders to see appalling conditions”. This disaster ended in significant negative media attention for the company that operated the farm [16]. During a state of emergency, controllers and constables may exercise additional powers including exclusion of persons from places (cl. 101) and giving directions (cl. 106). It is an offence to fail to comply with these exclusions or directives (cl. 126 and cl. 129, respectively). Should there be occurrences of animal interest groups purporting to have approval from emergency management to carry out “rescues” to advance their own agenda to expose pre-existing conditions, it is likely that an offence under cl. 132(1) is committed:

“A person commits an offence if the person by words, conduct, or demeanour pretends to be the Director, a Controller, a Recovery Manager, a member of an Emergency Management Committee, or a person acting under the authority of any of those persons, or any person authorised or employed for carrying out any provision of this Act or any emergency management plan”.

The recommendation made by the Office of the Ombudsman is that private entities be subject to oversight by an Ombudsman.

“It therefore seems appropriate that private entities carrying out public functions during an emergency also should be properly subject to an Ombudsman’s oversight as well as general expectations of transparency under the official information regime. This could be done in a targeted way by referring to the acts/omissions of these entities only so far as they relate to their statutory obligations under the Bill”.

(Submission #312)

The Office of the Ombudsman has recommended that private entities carrying out public functions during an emergency should be subject to oversight by an Ombudsman, as well as general expectations of transparency under the official information regime. This recommendation has potential ramifications for charities that formally support emergency management arrangements where they are exercising powers or functions under law, such as the power to enter premises, seize animals, or enter restricted areas during a state of emergency.

This would include a wide range of charities such as Surf Lifesaving, the non-council-operated New Zealand Response Teams, Land Search and Rescue, the Red Cross, the Coastguard, and numerous animal charities that undertake field response activities. The Ombudsman’s recommendation may also address calls to ensure there are greater protections to prevent unauthorised persons from entering farms (Submission #52), as organisations that elect to carry out such public functions would be subject to oversight.

Leaving government entities responsible for public functions, such as Fire and Emergency New Zealand (FENZ) leading animal rescue and decontamination operations, and local councils operating temporary animal shelters, means these activities are by default under accountability and transparency mechanisms. FENZ is subject to Ombudsman oversight and the Official Information Act 1982, while local government is subject to the Ombudsman’s purview and the Local Government Official Information and Meetings Act 1987.

The financial auditing and reporting requirements for charities in New Zealand are prescribed based on operating expenditure thresholds. However, regardless of size, all charities deploying into a disaster are undertaking a public function, and the Ombudsman’s recommendation is clear that such private entities should come under their purview and be subject to the Official Information Act.

Animal welfare organisations play a crucial role in disaster response, providing rescue, care, and support for animals affected by emergencies. However, the lack of transparency surrounding funds raised by these organisations during disasters raises concerns about accountability and the potential misuse of donations. It is essential for animal charities to maintain public trust by ensuring that the funds they receive are used effectively and efficiently to help animals in need. Following major disasters, animal welfare organisations often experience a surge in donations from the public. For example, after Hurricanes Katrina and Rita in 2005, animal charities received a record-breaking USD 50 million in donations [40]. Similarly, during the 2019–2020 Australian bushfires, the Wildlife Information Rescue and Education Service Incorporated (WIRES) raised AUD 91 million [41]. While these donations are intended to support the organisations’ disaster response efforts, the lack of transparency makes it difficult to assess how the funds are being used.

One concern is that animal charities may benefit from unsolicited donations that exceed their operating costs, which may be reimbursed by the government. This could lead to a situation where the organisations are “double dipping” or have surplus funds that are used to finance non-disaster-related functions. Such practices may incentivise charities to respond only when there is significant media and public attention, as this drives donations [35].

The dependency on disaster revenue may also discourage animal welfare organisations from actively engaging in mitigation and preparedness activities, as they may prioritise responding to disasters that generate income based on animal suffering. This moral complexity highlights the need for greater transparency and accountability in the use of animal disaster funding [35].

To ensure that animals are not being exploited for financial gain, it is crucial for animal charities to provide clear and detailed reports on how disaster-related donations are being used. This transparency will help maintain public trust and ensure that the funds are being used effectively to help animals affected by disasters [35]. Furthermore, it is important for these organisations to invest in mitigation and preparedness efforts to reduce the impact of future disasters on animals, rather than solely relying on disaster response as a source of revenue [35]. In summary, while animal welfare organisations play a vital role in disaster response, the lack of transparency surrounding their use of disaster-related donations raises concerns about accountability and the potential misuse of funds. Greater transparency and a focus on mitigation and preparedness efforts are necessary to ensure that animals are not being exploited for financial gain and that the public’s trust in these organisations is maintained.

A detailed analysis of the Emergency Management Bill reveals a substantial number of specific amendments and additions necessary to adequately address the needs of animals in disaster situations. The majority of submissions (61%) advocated for improved animal disaster management arrangements within the Bill, while nearly half (48%) echoed the specific recommendations outlined in the “No Animal Left Behind” campaign. These findings suggest that the policymakers of any subsequent version of the Bill must consider and act on the growing calls for new animal-inclusive disaster legislation.

The high proportion of submissions supporting enhanced animal welfare provisions in the Bill highlights the increasing recognition of the importance of animal well-being in disaster management. This aligns with the growing body of research emphasising the need for a more comprehensive, multi-species approach to emergency planning and response. The “No Animal Left Behind” campaign, which provided a framework for integrating animal welfare into disaster management, has evidently resonated with a significant number of submitters, underscoring the necessity for legislative reform in this area. By providing accessible information and a unified message, the campaign empowered citizens and animal advocates to engage effectively with the legislative process, emphasising the need for animal welfare in emergency management law. The campaign’s success is evident from the significant volume of public submissions it inspired, highlighting its impact on shaping policy priorities and public discourse around protecting animals during emergencies. This influence is further demonstrated by the historic levels of public submissions on emergency management law changes in New Zealand.

Given the evidence presented in the submissions, it is incumbent upon policymakers to address the identified gaps and shortcomings in the current Bill. Not doing so risks perpetuating a disaster management framework that is ill-equipped to protect the welfare of animals and, by extension, the well-being of the communities that depend on them.

Many submissions framed the issue of animal welfare in disasters as a matter of ethical obligation and social justice. Submitters argued that as sentient beings, animals have an inherent right to protection from suffering and that society has a moral duty to uphold this right. This framing resonates with the growing body of literature on animal ethics and disaster justice [16,26,32,42,43]. It suggests that the issue of animal welfare in disasters is not just a matter of pragmatic planning, but a fundamental question of values and moral progress.

Given the number of non-animal themes identified, including community resilience, Māori participation, readiness and response capabilities, recovery and risk reduction, accountability and transparency, and underwhelming reform, further research is needed and would benefit input into future iterations of the Bill.

6. Conclusions

The public submissions on New Zealand’s Emergency Management Bill demonstrate strong support for comprehensive legislative provisions to protect animal welfare in disasters. Recognising the importance of animals, mandating animal-inclusive planning, endorsing advocacy campaigns, and proposing specific amendments, the submissions make a compelling case for change.

While the current Emergency Management Bill has been discontinued, the insights gained from analysing the public submissions remain highly relevant and valuable. By carefully considering these insights in conjunction with the findings of the independent reviews, policymakers have a unique opportunity to develop a new Bill that addresses the identified failures, incorporates the priorities and concerns of stakeholders, and ultimately strengthens New Zealand’s emergency management capabilities.

However, legislation is only the starting point. Realising the vision of a truly animal-inclusive approach to disaster management will require ongoing commitment, collaboration, and resources from all stakeholders. By working together to give animals a voice in disasters, we can create a more compassionate, resilient future for all.

The submissions also highlight the need for a holistic, One Health approach that considers the impacts of disasters on all animals, from companions to livestock to wildlife. This requires a shift from a narrow focus on pets to a broader understanding of the complex interdependencies between human, animal, and environmental well-being. The concept of One Rescue may also be more pragmatic for first responders to understand the benefits of integrated human–animal emergency management.

Collaboration and coordination emerge as key themes, with submitters calling for formal recognition and support for the vital role of animal welfare organisations in disaster response. At the same time, there is a clear message that government must provide leadership, resources, and a legislative framework to enable effective cooperation.

The submissions also identified a significant number of non-animal related issues that are critical for consideration in future iterations of the Bill, such as lack of funding to implement legislative reform, improving accountability and transparency, clarifying roles and responsibilities of mandated agencies and organisations, and ensuring disaster risk reduction responsibilities are defined to name just a few. It is clear, that though there is support for a new Emergency Management Act, the Bill fails to meet the issues raised by the public in its present form.

As New Zealand navigates the path towards a new Emergency Management Act, these submissions serve as a powerful reminder of the public’s expectations and aspirations for animal welfare. They offer a roadmap for reform that is grounded in science, ethics, and the lived experiences of those on the frontlines of animal rescue and care.

By heeding these voices and crafting legislation that truly protects animals in disasters, New Zealand has an opportunity to set a global standard for compassionate, effective emergency management. In doing so, we can honour the profound bond between humans and animals and build a more resilient future for all.