Thank you for the opportunity to submit on the draft Westland Tai Poutini National Park Management Plan.
I support, in full, the submission by the New Zealand Alpine Club (NZAC) on the draft Plan and I submit that the draft Plan be withdrawn and reworked.
New Zealand has a long history of protecting significant mountain places in national parks for their intrinsic worth. Further, preserving these special places for enjoyment, including climbing and related activities, is of the utmost importance. The draft Plan erodes this protection and has other aspects that are of concern.
In particular, the transformation of many approved aircraft landing sites to two huge zones, such that aircraft could land
(a) anywhere in the névés of the Franz Josef and Fox Glaciers between 1500 and 2500 metres; and
(b) anywhere in the same altitude range in the catchments of the Callery and Cook Rivers including the iconic climbing areas in the Spencer, Balfour and La Perouse, where NO landings are currently permitted, will impact enormously. This, combined with an increase in numbers of permitted landings and no distinction made between tourist scenic landings and those for, say, climber drop-offs at Centennial and Pioneers Huts, will extend tourism in the Park. Climbers and ski tourers will be in more crowded places, tranquillity will be diminished and overflights will increase. I do not support these changes, which fly in the face of experiencing nature on its own terms.
I do not support the creation of an "amenities area" in the Franz Josef Glacier Valley, adjacent to the Glacier and up to an altitude of 1700 metres, either for the proposed gondola or for any other amenities, where national park values will become secondary.
I attach the NZAC submission with my submission on additional matters of concern to me.
In my opinion the draft plan represents a deplorable departure from previous management plans and sets a permissive, development-focused path for the management of this very special places into the future.
Whoever drafted this document is clearly not familiar with the intentions and premises of the National Parks Act 1980 and the general tenor of the General Policy for National Parks (2005) governing document.
It is these intrinsic qualities of the Tai Poutini NP that were intended to be preserved under the ‘National Park’ designation at the outset of the creation of the NP. Yet, as visitor numbers grow across this park, so does overt and covert pressure on DOC to facilitate greater access and create economic opportunities for a swathe of commercial operators. Yielding to that pressure will irrevocably alter or destroy experiences and opportunities available to current and future New Zealanders (who own the park – not you the regulators).
In this context this paragraph from the act is unambiguous.
"It is hereby declared that the provisions of this Act shall have effect for the purpose of preserving in perpetuity as National Parks, for their intrinsic worth and for the benefit, use, and enjoyment of the public, areas of New Zealand that contain scenery of such distinctive quality, ecological systems or natural features so beautiful, unique, or scientifically important that their preservation is in the national interest."
It doesn’t say anything about facilitating commercial exploitation of the intrinsic values of National Parks or creating extensive infrastructure developments in the park.
Under the National Parks Act 1980, DOC is required to administer and manage national parks in accordance with the General Policy for National Parks 2005.
A key purpose of the Tai Poutini National Park Management Plan is to implement this clearly prescribed but seemingly overlooked by your drafters General Policy Document. Inter alia, this General Policy document States: "8.1(c) Planning and management for recreation and other opportunities for the benefit, use and enjoyment of each National Park should:
i) preserve national park values, including natural quiet, as far as possible …
iv) maintain the distinctive character of recreation in New Zealand national parks, including the traditional New Zealand backcountry experience with its ethos of self-reliance."
i) preserve national park values, including natural quiet, as far as possible …
iv) maintain the distinctive character of recreation in New Zealand national parks, including the traditional New Zealand backcountry experience with its ethos of self-reliance."
These essential and vital provisions are blatantly ignored in the current draft plan.
I respectfully submit and request that any proposals in the draft plan that are not compatible with these principles in the General Policy Document and Act be rescinded.
The draft Plan erodes the protection of intrinsic values that I have detailed above and has other aspects that are of concern to me also.
The draft plan gives minimal consideration to the huge carbon footprint created by the dramatic growth of mass tourism envisaged and facilitated by the plan (especially foreign tourists). It is now desperate for this to be addressed and this will include rationing access to the park and reducing and mitigating human created pressures on the natural resources and environment of the park.
An amenities area has been proposed for the Franz Josef Glacier Valley as part of a Gondola development that would run up to near the Almer Hut. This would involve considerable infrastructure, provisions for access and ongoing maintenance. The argument for this is to provide easy access for tourists to enjoy our shrinking glaciers, which is somewhat ironic since they are partially responsible for this with the CO2 emissions of long-haul flying. I think this is a very poorly thought out proposal. For instance, it will have a devastating effect on the integrity of the Westland/Tai Poutini NP and abrogate the intrinsic value of the mana whenua. It will create a visual eyesore and reduce the area to a Disneyland experience for short stay tourists. I think this would be a betrayal of kaitiaktanga, a sellout to developers who have scant regard for the mystical and intrinsic value of our taonga. Not only this, but once the developers get their way, they will inevitably want to ruin other valleys with similar proposals.
Although the draft prioritizes environmental stewardship and protecting mauri, there is a permissive approach to intrusive development to assuage the voracious appetite of Mass Tourism. It is assumed that this deluge of tourists will exponentially increase but this is unlikely. New scientific information on the rapidity of Climate Change over the last few months suggests that New Zealand will have to adopt drastic measures to reduce New Zealand’s fossil fuel industries in the near future, not at some distant date as inferred on page 27 of the draft document This may well change the dynamics of Mass Tourism. The intrusive developments I’m referring to are the Gondola proposal and the increase in aircraft landings over a wide area on the neves.
Protection of our ecosystems and mauri should be our priority. Our endangered fauna and flora need the highest priority along with pest management. We are in the 6th extinction presently and the future looks bleak for all species.
I endorse the various submissions of the NZ Alpine Club on the plan.
Thank you
Dr Stanley Mulvany