Make a submission – keep our conservation land for all
Aotearoa New Zealand’s parks, forests, and wildlife are taonga.
Enjoying te taiao is a huge part of what it means to be connected to our beautiful whenua. We should be able to rely on government-backed stewardship of our environment to conserve it for generations to come, and for our native species and ecosystems that need it to thrive.
Te Papa Atawhai Department of Conservation (DOC), led by Minister Tama Potaka is seeking feedback on proposed updates to our conservation system. The Department of Conservation (DOC) are conducting two separate, but connected, consultations on the following issues:
- DOC is asking whether charging to access conservation areas is a good idea. Our key recommendation for submitters is to not support access charges for all conservation land, and that any access charges need to be developed with and supported by the local community, especially local hapū.
- DOC’s current proposal is heavily focused on creating pathways to open up public conservation land to greater commercial activity. Our key recommendation for submitters is to not support removing checks and balances, and to ensure that conservation outcomes are the most important consideration.
This consultation is different to consultation on a piece of legislation. Instead, DOC have developed two discussion documents which they are requesting public feedback on. Feedback received by DOC will be used to inform future work, which may include legislation (which would give you another chance to have your say).
Making your voice heard on these changes now will make it clear to the Government that New Zealanders want to prioritise maintaining our precious conservation land for everyone, including future generations.
We have provided some guidance to help you to submit on the two separate consultations. You can submit on both, or just one. Submissions do not need to be long or answer all the questions. What matters is that your position is clear.
Make a submission on charging for access to public conservation land
Why does this matter?
DOC is consulting on whether Aotearoa should introduce charges or fees to access protected natural areas. Taking a user-pays approach to accessing nature risks transforming nature from being open to all, to a privilege for those who can afford it.
We should be working to increase access to public conservation land, not limit it by putting more costs on individuals. We need to tell the Government that it is important that the natural environment remains opento all New Zealanders. This proposal takes us down a troubling path where access to nature and conservation are pulled into this Government’s relentless cycle of commercialisation.
What is the Government consulting on?
Access charges are fees that are required to enter a specific area (for example, a person or vehicle being required to pay a fee to enter a national park). The Government is seeking feedback on whether access charging is a good idea and what the main principles for an access charge should look like, including:
- Who should be charged?
- Where should access charging be used?
- How should the money be used?
Submissions close 5pm, Friday 28 February
DOC have a survey here with questions and prompts which may help you make your submission – you don’t have to fill out every section, just have a say on what matters to you.
You can also write a free-form submission and email it to [email protected].
Fill in the survey |
What could my submission say?
Your submission does not need to be long or complicated. You could share with DOC how and why you and your whānau enjoy free access to Aotearoa’s conservation land. Below are some key points you may want to include in your submission:
- Getting into nature and connecting with te taiao is a huge part of being a New Zealander. It is critical that we have free and equal access to the places that support our mental and physical wellbeing.
- Our national parks are some of the most beautiful and precious places in Aotearoa, and many are home to species that cannot be found anywhere else in the country - or the world! These are places everyone should be able to experience and enjoy without barriers.
- Implementing an access charge will disproportionately affect poorer communities, young people, and those who generally do not have the means to pay to experience nature. Access to nature is a right, not a privilege—introducing access charging will lock some whānau out of experiencing the incredible and unique natural environment of Aotearoa.
- Any access-charging system should include specific consideration for domestic versus international tourists.
- Free access to public conservation land is critical to giving effect to the Crown’s responsibilities under te Tiriti o Waitangi.
- The Government should be focused on enabling sustainable and enduring funding for nature in Aotearoa by prioritising central-government investment in conservation.
- I acknowledge that the Government faces increasing costs to maintain and improve public conservation land. However, these increasing costs should be met by the Government, not by asking households to dig into their own pockets.
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The following information may be useful if you want to fill in DOC’s survey or provide a more detailed submission. You don’t need to fill in every section of the survey, just the parts where you want to have a say.
Access charging – part of the solution?
This section is where you can include general comments on access charging and whether you think it is the appropriate response to DOC’s funding pressures. You could include comments such as:
- Introducing access fees will increase the financial barriers to people enjoying the best and most precious parts of our natural environment.
Who should pay an access charge?
This section asks for views on who should pay access charges, for example, different places might use varied approaches, especially for domestic versus international visitors. You could include comments such as:
- I recommend that any access charging regime applies a flexible approach to setting fees to allow New Zealand residents to continue to access conservation land for free.
Where should access charging be used?
This section asks for views on where access charging should be used. You could include comments such as:
- I agree that any access charges need to be developed with and supported by the local community, especially local hapū.
- I would not support access charges for all conservation land. If compulsory access charges are introduced, I would prefer they were implemented in a few key areas where there is a clear and direct rationale for the charge (such as, the need for ongoing updates to infrastructure in that location).
How should the additional revenue be used?
This section asks for views on how the additional revenue should be used. The three main options being: more of the money should be invested at the place it is collected in; more of the money should be invested in the region it is collected in; or the money should be invested in priority projects across New Zealand, regardless of where it was collected.
Working with iwi and hapū
This section asks how the Government can best meet its Treaty obligations in designing and implementing access charging. You could include comments such as:
- Te Tiriti affirmed that tangata whenua have rangatiratanga over their taonga, including their lands. The Government has a duty to protect these rights and interests.
- Accessing te taiao is a fundamental right of tangata whenua—under no circumstances should the Government further restrict iwi and hapū access.
- Free access to conservation land is critical to ensuring tangata whenua are able to exercise kaitiakitanga over their lands.
Make a submission on modernising the conservation system
Why does this matter?
Making Aotearoa’s conservation system fit-for-purpose is long overdue, but DOC’s proposals clearly do not prioritise the protection and enhancement of our environment.
Our current issues in the conservation system cannot be solved by cutting core funding and then claiming that the only way to pay for conservation is to sell off land, make New Zealanders pay for access, and increase commercial activities on land that is meant to be for conservation.
We need to tell DOC and the Government that its focus should be on improving conservation and protecting biodiversity, not opening up our precious whenua to more commercial activity.
What is DOC consulting on?
DOC is seeking feedback on the conservation management planning and concession system. Any changes need to have improving conservation outcomes at the core. Much of what is proposed by DOC is heavily focused on creating pathways to open up public conservation land to greater commercial activity, without appropriate checks and balances.
Alongside seeking views on their broader approach to conservation, DOC on behalf of the Government is looking at making changes in the following main areas:
- Working with hapū and iwi
- Conservation management
- Unlocking amenities
- Land exchanges
Submissions close 5pm, Friday 28 February
DOC have a survey here with questions and prompts which may help you make your submission – you don’t have to fill out every section, just have a say on what matters to you.
You can also write a free-form submission and email it to [email protected].
Fill in the survey |
What could my submission say?
Your submission does not need to be long or complicated. You could share with DOC why protecting conservation land is important to you. Below are some key points you may want to include in your submission:
- The conservation estate is a taonga to be protected, not exploited for profit.
- Any modernisation of the conservation system should be driven by a need to enhance conservation outcomes in Aotearoa, not prioritise commercial activities.
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The following information may be useful if you want to fill in DOC’s survey or provide a more detailed submission. You do not need to fill in every section of the survey, just the parts where you want to have a say.
Issues—
This section seeks your feedback on DOC’s overall approach to suggesting changes to the conservation system. You could include comments such as:
- Overall, the proposals do not strike the right balance between achieving conservation outcomes and other outcomes such as recreation outcomes or commercial activities.
- The proposals concerningly favour commercial activity and could see the reduction in conservation land and biodiversity.
Streamlining the conservation management system—
This section seeks your feedback on simplifying the conservation management system, including the structure of planning documents, allowing planning documents to make decisions on categories of concessions, and changing the process for preparing and reviewing planning documents. You could include comments such as:
- I agree that the statutory planning documents need to be streamlined with the aim of benefiting conservation outcomes.
- It will be important to build strong checks and balances into any new planning process.
- Engagement with Treaty partners on ‘classes’ of activities rather than individual activities should remain limited to when and where those iwi have chosen to take that approach.
- I agree that Government should set clear engagement requirements when developing planning documents, especially with iwi and hapū. It is important that processes include iwi and hapū, and are not limited to post-settlement governance entities.
Speeding up concession processing and driving better performance and outcomes from concessions—
Concessions are permissions granted by DOC to use public conservation land for certain activities, such as guided walks or installation of campgrounds. We know the concessions system is not currently working most effectively. You could include comments such as:
- I welcome proposals to create a more equitable charging system for the use of conservation land. Given the value that access to the conservation estate provides to concessionaries, the system must ensure they are appropriately charged.
- Any measures to speed up the concessions process must ensure that the appropriate checks and balances are maintained to not threaten conservation outcomes.
- Any criteria used to decide how to competitively allocate concessions must include: the applicants’ environmental compliance record; contribution to conservation, scientific, and mātauranga research; benefits to the local area; and uphold Tiriti rights, including building authentic relationships with tangata whenua.
- Engagement processes with iwi and hapū must remain flexible to the needs and capacity of individual rōpu and should not be altered without engagement with those affected. Setting timeframes for Treaty partners to provide their views on concessions could lock many iwi and hapū out of engagement. It is not clear how this proposal would enable DOC to meet its Treaty obligations under section 4 of the Conservation Act.
Unlocking amenities areas to protect nature and enhance tourism—
This section seeks your views on making changes to ‘amenities areas’. Amenities areas are small areas in national parks or conservation parks that are suitable for the development and operation of recreation and related amenities and services appropriate for public use and enjoyment of the park, e.g., a visitor centre or car park area. You could include comments such as:
- Better-supported development in our conservation areas should not be focused on supporting the tourism industry at the expense of conservation values. Any changes to the way amenities areas are established or managed must be for the benefit of conservation.
- I do not agree that the Minister of Conservation should be allowed to establish an amenities area in a national park without requiring the recommendation of the New Zealand Conservation Authority. This proposal removes a key check from independent conservation experts.
Land exchanges —
Conservation land exchanges are the process of swapping land managed by DOC for other land. In this section DOC suggests a range of concerning changes to the land exchanges process, including changes to further align the Conservation Act with the controversial Fast Track Approvals Act. You could include comments such as:
- The goal of land exchanges is to improve conservation outcomes. The whole concept of conservation is predicated upon permanent protection of areas that meet the statutory requirement—these proposals are in direct contradiction with this notion.
- DOC should not provide for further flexibility for land exchanges and disposals in line with or beyond the provisions in the Fast Track Approvals Act, especially considering the widespread opposition to the Act.
- These proposals could see land with conservation values that is received by DOC protected, but land that is sold and privatised could be developed and conservation values lost. I am therefore concerned that the net result to Aotearoa will be a loss of conservation values.
- The test for land exchanges should not be changed. I support the existing approach of the Conservation General Policy, where even stewardship land may not be disposed of (including by exchange) unless the land has “no, or very low, conservation values” and agree that conservation land should only be disposed of in very limited circumstances.
- I do not support allowing for land exchanges with net-conservation benefits. This could allow, for example, that a loss of biodiversity value could be exchanged for a gain in historic values, resulting in a net loss for biodiversity. At a time when DOC and the environment sector generally are being required to make cuts, encouraging the sale of parts of the conservation estate is deeply alarming.
- Changes to the land exchanges regime must continue to give effect to iwi rights of first refusal and take into account potential future settlements.