Wednesday, January 23, 2019

Submission on the draft management plan for Aoraki/Mount Cook National Park

Thank you for the opportunity to submit the draft Aoraki/Mount Cook National Park Management Plan.
I support, in full, the submission by the New Zealand Alpine Club (NZAC) on the draft Aoraki/Mount Cook National Park Plan and submit that the Plan be withdrawn and reworked.
New Zealand has a long history of protecting significant places in national parks.  Preserving these special places for climbing and related activities is of the utmost importance.  The draft Plan erodes this protection and has other measures that are of concern.
In particular, the huge increases in both the aircraft landing zone areas and the allocated landings (10 fold), while at the same time retaining a separate category for heli-ski landing zones with unlimited landings, will impact enormously.  This, combined with no distinction between tourist landings and those, say, for climber drop-offs on the Grand Plateau, will extend tourism in the park.  Climbers and other recreationalists will be competing with tourists for flights, tranquillity will be diminished and overflights will increase.  I do not support these increases.
While I support the park and ride system as a means of managing vehicle congestion, there is no guidance on protecting access for climbers and other recreationalist who will come and go from the park at all hours.
I support Unwin Lodge being retained.  I do not support the lodge being used by the public at the expense of Club members and their guests in order to maximise occupancy. Unwin Lodge is an NZAC lodge. Mountaineering has a historical connection in Aoraki since the 19th century with a rich folklore and literature. We, the NZAC are part of the cultural/historical heritage of the park. I don’t agree that Unwin Lodge should be available to the general public. This is inappropriate. Unwin is a gathering place of like-minded mountaineers, not tourists who have a different perspective. I recommend the status quo in terms of that.
I do not support the closure of the legal road up the Godley River unless alternative legal vehicle access is secured.
I attach the NZAC submission with my submission and 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 place 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. A key purpose of the new Aoraki National Park Management Plan should be to implement the basic tenets of this General Policy Document.

Inter alia the General Policy 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."

It is these intrinsic qualities of the Aoraki NP that were intended to be preserved under the ‘National Park’ designation at the outset of the creation of the Aoraki National Park. Yet, as visitor numbers grow rapidly across Aoraki National Park, clearly so does overt and covert pressure on DOC to facilitate greater access and 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.

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 Aoraki 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 Aoraki National Park Management Plan is to implement this clearly prescribed, but seemingly overlooked by your drafters, General Policy Document.

These essential and vital provisions are blatantly ignored in the current draft plan.

I request that any proposals in the draft plan that are not compatible with these guiding principles in the General Policy Document and Act, be rescinded from the plan.
I am very concerned about the huge number of overseas visitors that enter the park – more than 800,000 local and international visitors in 2016/17 and predicted to be 1.5m in 10 year’s time. However, this growth assumption may be incorrect. 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. This may well change the dynamics of Mass Tourism. For the present though, I feel overwhelmed by the numbers of tourists when I visit Aoraki. The overcrowding and congestion at White Horse Hill car park are unbelievable. This has to change. Already there is a conflict between Kiwis and the deluge of overseas visitors usurping our special places. The concept of over-flow campgrounds is a short- term fix but will ultimately prove unsuccessful. Limits will need to be put on the number of oversea visitors entering Aoraki NP if DOC is to meet its obligation to safeguard the integrity of the Park’s natural and cultural values. 
There is a lot of discussion in the draft about “Tranquility Zones”. That’s something I firmly believe in. But then it proposes new landing zones at Liebig and Onslow Huts and on Pudding Rock to make it easier for people to assess these areas. I object to this on the grounds of noise pollution, degrading the present Tranquility Zone and altering the spiritual values of Aroarokaehe and Pae Tata. I’ve been to all these places so can testify to their special status.
The greatest challenge for our Iconic places in NZ is undoubtedly Climate Change and nowhere will it be more apparent than in Aoraki. Glacial melt and sea level rise are our barometers of Climate Change and currently undergoing rapid change. NZ glaciers have shrunk by almost 20Km3 in the last 36 years. In 1880, the ice volume on the Southern Alps was 100 km3, in 1978 it was 53.5km3 and now about 37 km3 remaining. In the blink of an eye, we may lose all our glaciers. The associated effect on the geology is likely to be increased erosion leaving a devastated landscape. It’s a perverse situation that the draft plan is promoting greater aircraft access for tourists because of retreating glaciers when they and the aviation industry are contributing and partly responsible for this in the context of huge GHG emissions associated with long-haul flying and local aircraft use.   It is now desperate for this to be addressed at national as well as regional levels and this will include rationing access to the park, eliminating and reducing reliance on activities that use fossil fuels , such as aviation,  and reducing and mitigating  human created pressures on  the natural resources of the park.

Thank you

Dr Stanley Mulvany

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