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Draft National Park Management Plan Submissions – Aoraki Mount Cook and Westland Tai Poutini National Parks

Summary of Club Submissions

Submission templates for individuals

NZAC Club submissions (coming 01/02/2019)

Aoraki Mount Cook Draft Management Plan

Westland Tai Poutini Draft Management Plan

Summary of the Club Submissions on Westland Tai Poutini and Aoraki/Mount Cook National Park Draft Management Plans

A group appointed by the Board and coordinated by Karen Leacock has been diligently preparing the Club’s submissions for both draft Plans. The Club’s full submissions will be made available on the website on Friday, February 1st for members to review and consider before making their own personal submissions. The Club has also made a template submission form in support of the NZAC’s submissions available for both Parks for members to submit directly to the Department of Conservation. You can find those templates and instructions on how to submit them here. The deadline for submissions is 4pm on February 4th.

The proposed changes to these Park Plans have drastic and far-reaching implications for the management of our most iconic landscapes. Please take the time to consider the changes and make a submission.

Themes to emerge from the draft Plans

The Club is concerned by the proposed changes to the management Plans of Westland Tai Poutini (WTP) and Aoraki/Mount Cook (AMC) National Parks. The draft Plans fail to grasp the first principles of National Park protection and preservation embedded in the National Parks Act of 1980. The Club fully supports and advocates for continued recreation access to the premier climbing region in New Zealand and we will continue to do so. At the same time, the Club believes we must not lose sight of the importance of also advocating for the more fundamental park protection and preservation values vital to the sustainability of these iconic landscapes.

It is clear from the draft Plans that the Department has unfortunately started the planning process with a flawed premise that extending visitation to the Parks’ remotest and wildest landscapes should be increased to meet tourism demand rather than acknowledging that some of these landscapes will not be able to absorb such high levels of visitation while retaining their unique character.

The due diligence, consultation and documentation that would be necessary to demonstrate how these areas could support such drastic increases in visitation is missing from the draft Plans. Perhaps the clearest evidence of this planning approach is aircraft access. In addition to the myriad issues that come from increased permitted landings in remote terrain (e.g., noise, visitor conflict and safety concerns), we find the decision to drastically increase aircraft access while New Zealand’s glaciers rapidly thin in response to human-induced climate change to be irreconcilable with the guiding principles of national park management. While the Department explicitly recognises the negative effects of anticipated climate change to the character of the Parks, which we are thankful for, it fails to acknowledge the how these Plans directly exacerbate those effects.

We struggle to find the forward-thinking and distinctive New Zealand conservation ethos, which the Department should be fostering, in these draft Plans.

Considering the depth and reach of the systemic issues we find in both plans, the Club is taking an unprecedented position and submitting that the WTP and AMC plans be withdrawn and reworked.

General concerns with both plans

Here we summarise some of the high-level themes to emerge from both Plans that underpin the Club’s submissions. We have noted the key submission (KS) points in both documents for reference.

  • Greatly increased aircraft activity in enlarged areas throughout the Parks, including in high-value climbing terrain and previously remote, aircraft-free locations. [WTP KS #9; AMC KS #8]
    • The Club accepts the need for pilot discretion of exactly where to land in a dynamic landscape and supports small buffers around designated landing sites. We submit, that, with a few small exceptions, the existing landing sites in the Parks are retained and the maximum number of landings in the parks are kept at or below current levels.
    • The Club submits that in WTP the proposed increases in the areas open to aircraft landings are too large and encompasses remote valleys and wide swathes of high alpine terrain where landings are inappropriate. The club is alarmed by the sheer size of the landing zones.
    • The Club submits that the number of proposed aircraft landings in AMC is far too high and levels should remain as they are in the current Plan. The Club also submits that the proposed landing zones in AMC are also, in general, too large.
    • The Club submits that a distinction between user activities for aircraft access (private and guided recreationists and non-recreationists, such as scenic landings) is important and should be retained. 
  • Obfuscation of the linkages between and utility of management frameworks, in particular the visitor management zones, aircraft access zones and the addition of the desired tranquillity outcomes. [WTP KS #10-11; AMC KS #9-10]
    • The Club finds the various visitor management frameworks hard to use. The addition of a new desired tranquility outcome tool makes visitor management less clear. Changes to the visitor management zones (“settings” in current Plans) are largely inappropriate and often confounding. The Club submits that the tranquility tool be removed and the existing visitor management settings largely be retained.
  • A lack of evidence of adequate formal consultation and engagement with the outdoor recreation community.
    • The Club is worried about the lack of engagement with recreation groups before proposing drastic increases in visitation and aircraft use in remote areas. We submit that the level of engagement must be commensurate with the scale of the proposed changes.
  • Scant mention of the unique and important history of mountaineering in the Parks and the culture and involvement of the climbing community as stewards of these landscapes. [WTP KS #6; AMC KS #6]
    • The Club has actively advocated for the protection and appropriate use of our mountains and crags for generations. The Club submits that this history and culture should be included in the draft Plan to give context to the importance of protecting these mountain landscapes and shed light on the benefits use of these landscapes brings to New Zealanders.
  • The failure to provide a narrative on how the current management Plans have informed the proposed changes in the draft Plans, especially for visitor and aircraft monitoring programmes that exist in the current Plan. [WTP KS #16; AMC KS #14]
    • The Club is concerned that the draft Plans fail to articulate the value of monitoring and—by virtue—public involvement in Park management. The monitoring work essential to the current Plans, especially with aircraft operations, goes unmentioned in the draft Plans. The Club submits that a robust monitoring programme is retained in the Plan and that a discussion of how the current monitoring programme has informed the need for change in Park management is documented more clearly in the Plans. There is also a missing discussion on the coordination of the two Park Plans despite their concurrent revision and shared geography. Finally, the Club submits that more rigorous inclusion of international park management best practices be considered in developing the Plans.

Specific proposed changes of particular interest to the Club

There are changes specific to each Plan that we are also concerned about. We have noted the key submission (KS) points in both documents for reference.

  • The establishment of an amenities area and request for feedback on a proposal for the construction of a Gondola from below the terminus of Franz Josef extending to the névé near Almer Hut in WTP National Park. [WTP KS #15]
    • The club opposes the amenities area, where national park values will become secondary. We believe any positive benefits (potential for increased recreational access) are outweighed by the many negative implications for visitor experience to the valley and glacier, and an underlying transformation of the alpine character of the Park.
  • The establishment of a landing zone at Pudding Rock in the Hooker Valley in AMC National Park. [AMC KS #8]
    • The Club opposes this proposal. The Board has decided that despite an opportunity to increase recreational access to the upper Hooker Valley in summer months, the protection of an iconic valley free of aircraft landings is vital to the character of the Park and should be retained in the Plan. Club members have a wide range of views on aircraft access in the Hooker Valley and the Club appreciates that the Department has considered the need for sustained climbing access in some of the most challenging terrain in New Zealand. The Club believes that aircraft access will erode the special status of the upper Hooker and Aoraki.
  • The continued treatment of heli-skiing as a unique activity with separate access and landing zones. [AMC KS #8]
    • The Club submits that heli-skiing operations be considered in the same way as other aircraft access and recreation for private and commercial visitors. This would improve consistency within the overall management framework while making it easier for the public to understand acceptable use and expected use in AMC. 
  • The pack-out of human waste from the backcountry where there is not toilet. [WTP KS #13, AMC KS #12]
    • The Club supports both plans in the introduction of pack-out methods.  There is a need for an affordable, low carbon solution for waste removal. 

Make your voice heard

There are many other important points in the Club’s submissions on the draft Plans that will be of interest to Club members, including the potential for a park-and-ride system in AMC and changes around the use of Club lodges by non-members.

Please take the time to read the Club’s Key Submission points and to make a personal submission. The Department needs to hear from New Zealand’s climbing community. You can find Club submission templates and instructions on how to submit them here.

The deadline for submissions is 4pm on February 4th.

Download a copy of this summary here.

Submission templates

To use these templates:

  • Download the word documents below. There is one for each of the National Parks. These have to be completed separately and submitted to different addresses.
  • Open and complete the personal details at the top.
  • Amend the content as you wish.
  • Attach the submission, along with the full NZAC submission (if you wish) and submit to DoC as specified at the top of the document before 4 pm Monday 4th February, 2019.

Aoraki Mount Cook submission template (word doc)

Aoraki Mount Cook submission template (pdf)

Westland Tai Poutini submission template (word doc)

Westland Tai Poutini submission template (pdf)

NZAC Club submissions

The Aoraki Mount Cook submission is available below. The Westland Tai Poutini submission will be added when it becomes available.

NZAC submission for Aoraki Mount Cook National Park draft Management Plan

NZAC submission for Westland Tai Poutini National Park draft Management Plan

Posted: 31/01/19

Posted By: Karen Leacock