Unsustainable costs across the racing industry has led to New Zealand Thoroughbred Racing proposing to close 21 venues by 2030.
NZTR has released a Venue Plan document suggesting a reduction to 27 venues in total across the country over the next eleven years.
In a statement the NZTR said plan is not as a result of any Government processes underway.
Last year the government released the Messara review which suggested outsourcing the TAB's commercial activities, reducing the number of thoroughbred racetracks from 48 to 28 and building three new new all-weather tracks at Cambridge, Awapuni and Riccarton.
In December racing Minister Winston Peters appointed a five-member Ministerial Advisory Committee to advise on what actions to take from the Massara review.
An interim report from the committee is due by the end of February.
"While NZTR agrees with the Messara report that a reduction of venues is required, having already undertaken substantial work in this area over some years we have a view of how this could look," NZTR chief executive Bernard Saundry said.
"Despite the best intentions of committed and passionate volunteers, many of New Zealand's racing venues are in urgent need of major development," he said.
"Spending is required to bring infrastructure up to standard and to meet Health & Safety obligations. An upgrading of venues will also improve the punter experience by providing better and more consistent track surfaces."
The consultation document initially proposes that 10 venues are not allocated licences in the 2019/20 racing season.
This includes Dargaville, Thames and Wyndham who are racing at other venues in the current racing season.
The other affected venues are Wairoa, Stratford, Blenheim, Reefton, Hokitika, Waimate and Winton.
NZTR anticipates that those clubs which lose their traditional venues will continue to race at an alternative track.
"A key commitment of the proposed NZTR Venue Plan is that all clubs in New Zealand will have an approved and appropriate venue at which to race. We see a future for every club," Saundry said.
Craig McNeill, who was the past-president of the Feilding Jockey Club in 1999 when it sold its property and relocated racing to Awapuni, believes clubs should embrace the opportunity for change.
"What a lot of people do not realise is that moving made us stronger not weaker," McNeill said.
"We are focused on the community and sponsors like never before and that sees increased investment and attendance at our meetings."
NZTR will conduct meetings with stakeholders over the coming weeks with 19 March the deadline for feedback.