draft southland murihiku conservation management strategy: … · 2018-05-25 · definition of...

31-Oct-14Draft Southland Murihiku Conservation Management Strategy: Response to Submissions by Section

Submitter and

submission point

Submission summary Decision Sought Response

Section: General CMS (National Issue)

Congratulations, have viewed the draft CMS and have

no issues with any of its contents.

Safari Club

International NZ

Chapter

24/1

Accept

Thank you.

Support the overall thrust of the draft CMS.Solid Energy NZ Ltd

36/1

Accept

Thank you.

Thought that DOC had finally realised its failings and

was going to genuinely work with people instead of

against them and lose its "we are right", ultra

preservation culture and mentality. Find the situation

has worsened and it is a disgraceful document. It is

narrow focused, impractical, and selective in following

the statutes. Submit on access, land status proposal

changes, pest control, commercial eel fishing and

whitebaiting, and working with existing users.

HR[CMS is contradictory and confusing.

Disagrees with approach taken to manage animals versus

motor vehicles (ref CA provisions).]

Bruce Reay

41/1

Reject

DOC has taken a consistent approach to managing

various issues. This includes working with others to

achieve conservation outcomes.

A very complex document, yet much of it is descriptive

without clear statements of planned conservation

management for particular places. Little confidence in

the ability of some senior Departmental staff to

correctly interpret such important and relevant

legislation and policy statements. This draft CMS is in

such a generalised form as to allow a wide range of

development. Descriptive terms used mostly to facilitate

and encourage recreational access and associated

development and use, rather than ensuring the adequate

protection and sustainable management of the existing

inherent natural values for the benefit and enjoyment of

future generations.

HR[Part one - should provide for aerial 1080 where

appropriate. Try using one with deer repellent. 1080 is a

tool.

Catlin's should be "Catlin's Coastal Rainforest Park" used

to be a sign saying this - now taken down.]

Alan Mark

62/1

Accept in part

The operative parts of the CMS need to be read as a

whole when making decisions.

1080 is one tool that may be used in pest

management, this does not need to be specified in the

CMS.

The name for the Catlins pcl&w is 'Catlins

Conservation Park', under s19 CA87.

We agree with sentiment of collaboration between the

Department and other organisations. However, there is a

stance of being against all fixed-wing aircraft activity.

Reasons for negative attitude relate to vague concepts of

"effects on natural quiet and feelings of remoteness",

"conflicts with other recreational users" and apparent

dislike of people accessing remote areas using

motorised craft. Draft CMS has the same provisions for

both recreational and commercial aircraft takeoffs and

landings. This directly contravenes the Conservation

Act Section 6(e).

HR[DOC allowing commercial but not recreational

landings at some sites. Need better definition of 'natural

quiet' re effects on other users or wildlife.]

Recreational

Backcountry Pilots

Association

64/1

Accept in part

Refer to 'Aircraft' common issues report.

Page 1 of 594Draft Southland Murihiku Conservation Management Strategy: Response to Submissions by Section

Submitter and

submission point


Reporting is not a milestone. The CMS is fundamentally

flawed if there are no concrete milestones. Applies

throughout the CMS.

Reword milestones to have measurable results and clear

goals.

Andrew Penniket

91/2

Accept in part

Many of the milestones have been revised.

General support.Heritage Expeditions

101/1

Accept

Thank you for your suport.

The title 'Campbell Islands' and 'Campbells Island' were

colloquialisms used by the 1895 to 1931 run holders.

Not used in official publications or maps.

Change to 'Campbell Island' where misspelt throughout the

entire document.

Norman Judd

111/3

Reject

The term 'Campbell Islands' refers to the main

Campbell Island/Motu Ihupuku as well as the number

of smaller islands surrounding it.

The use of 'Sub-antarctic' is not recommended by the

Geographic Board.

Change to 'Subantarctic' or 'subantarctic'.Norman Judd

111/4

Accept in part

The term 'sub-antarctic' is only used when referencing

the WHA, as this is how it has been named.

Found the document difficult to follow. Had to go to

many different pages/appendices/maps to find out what

the particular statement was trying to say. In some cases

the relevant document was in a different place, e.g.

FNPMP, and I was unable to find it at all.

David Fortune

114/1

Accept in part

The 'CMS structure' section has been revised to

describe how the CMS is set out and how the

different sections relate to each other. Plus a new

Interpretation section has been added to the

Introduction.

The approved document will be available on-line,

enabling word searches.

Many "Policies" and "Milestones" so vague to be of

almost no use to people administering the policies or to

submitters checking on progress. Agree with the

definition of policies, but many provided failed to give a

specific course of action. Agree with the definition of

milestones, but many gave no measurable steps.

That all policies be checked and many rewritten to give

clear, specific, measurable, achievable courses of action

with a relevant timeframe in which to be done.

That all milestones be checked and many rewritten to give

specific measurable achievable events with a relevant

timeframe in which to be done.

HR [Don't have "Report on ..." milestones.]

David Fortune

114/3

Accept in part

Some policies and many milestones have been

revised. The objectives and outcomes are also

relevant to decision making.

Seems to be reference to economics. Conservation Act

should not and does not require economic prosperity.

Sections of CMS be written to exclude economic aims, and

ensure that CMS be checked to be consistent with the

Conservation Act.

David Fortune

114/4

Accept in part

Economic prosperity is linked to the ability to achieve

conservation outcomes. The CMS is consistent with

the CA87.

Concern for the underwhelming, in some places, regard

for the conservation values. Cannot easily be quantified

in monetary terms, but are of great economic value to

the country overall and can easily be lost by emphasis

on short-term business/economic values.

Document should have as its basis the management,

preservation, advocation, and promotion for conservation

purposes of all areas.

David Fortune

114/63

Accept in part

The management of all conservation values is

addressed in the CMS. Where any conflict arises the

provisions of the CA87 prevail.

Difficult document to use. Lengthy description of

"Places" difficult to fully understand which parts of the

CMS relate to which "sub-places" within the Places.

Some sub-places not adequately covered off in the

Either make the Places smaller, more discrete, or have

subheadings for each sub-place. Ensure that all places are

covered off in the Outcome Statements and Policies.

Fiordland Tramping

and Outdoor

Recreation Club

125/1

Accept in part





Submitter and

submission point


Outcome Statements and Policies. Very hard to know

what activities might or might not be allowed. Greater

clarity needed.


Introduction.

The maps clearly set out which areas of pcl&w are

within each Place. Each Place outcome covers the

whole Place, as do many of the policies. All operative

parts of the CMS need to be considered when making

decisions about activities.

Appears to be being driven by the politics of the day

rather than an apolitical document that guides how our

public conservation land should be managed in the long-

term. Structure and much of the content strongly

influenced by the SOI, a much shorter term document

not subject to public consultation. CMS should inform

the SOI, not the other way round.

Any reference to the SOI should be removed from the CMS.Fiordland Tramping and Outdoor

Recreation Club

125/2

Reject

The SOI has set DOC's priorities for 2013- 2017,

therefore it is appropriate for the CMS to be aligned

with this document. Section 1.5 uses the SOI

outcomes as headings. The content under each

heading meets DOC's statutory responsibility under

the CA87.

Many of the Milestones are very poor. Often no

requirement for DOC to do anything other than report

on things. Writing a report will not result in

conservation gains.

All Milestones need to be re-written and should be specific,

measurable, achievable, relevant and have a clear timescale,

and require DOC to do something that results in

conservation gains.

Fiordland Tramping

and Outdoor

Recreation Club

125/4

Accept in part


All policies should have a "will", "should" or "may"

verb in them to indicate what level of expectation there

is that the objective will be adhered to.

Add "will", "should" or "may" to all policies.Fiordland Tramping and Outdoor

Recreation Club

125/5

Reject

The words 'will', 'should' and 'may' are only used

where a decision is required. Refer policy 3.1.1 (now

moved to new Interpretation section in the

Introduction).

All tables should be listed in the table of contents for

ease of locating them.

Include list of all tables in table of contents.Fiordland Tramping and Outdoor

Recreation Club

125/9

Reject

This is not part of DOC's publishing standard.

When the CMS is approved and on-line the tables can

be found via a search.

Not entirely consistent with CA87 or CGP. Nowhere is

there a requirement to consider the economic prosperity

of Southland. Not against concessionaire use of public

conservation land, but commercial use should not take

precedent over the provision of recreation opportunities

for ordinary New Zealanders.

Reword the sections that are inconsistent with the CA to

remove reference to economic prosperity.

Make CMS consistent with the current legislation.

Fiordland Tramping

and Outdoor

Recreation Club

125/10

Accept in part

Economic prosperity is linked to the ability to achieve

conservation outcomes.

The CMS is consistent with the CA87.

S6 CA is very clear about the functions of DOC. Many

aspects of the draft are inconsistent with this provision

of the CA and need to be changed.

Ensure the CMS entirely consistent with the Conservation

Act.

Fiordland Tramping

and Outdoor

Recreation Club

125/11

Accept in part

The CMS is consistent with the CA87.

Re: proposed closure of the inland valleys etc of the

South Island high country. Object strongly.

Winston Bevan

Parks

141/1

Reject

Unsure what this is referring to. There is no intention

to close areas to public access other than in

accordance with Policy 3.1.4.


Submitter and

submission point


Support the strong emphasis on freshwater ecosystems.

Wish to see this retained, with some minor amendment.

Waiau Fisheries &

Wildlife Habitat

Enhancement Trust

155/1

Accept

Support conservation efforts, especially those that aim

to reverse biodiversity loss. Don't think this document is

urgent enough, reads like a business status report.

Would like more urgency and speed to the outcomes/aims.

MORE conservation FASTER. Be BOLDER.

Experience

Fiordland

Partnership

157/1

Accept in part

Achieving conservation outcomes is subject to the

resources available. Hence the desire to work with

others to achieve more conservation.

Note support for detailed submission from the NZ Four

Wheel Drivers Association.

Central Otago Four

Wheel Drive Club

161/1

Noted

Fully support.E. A. Loose

169/1

Accept

Thank you for your support.

Supports the CMS document and the Visitor

Management Zone approach. DOC estate in

Southland/Murihiku has a wide range of uses, and this

document recognises that not all parts of this large area

should be managed in exactly the same way.

Te Anau Community

Board

172/1

Accept


Document difficult to read, poor structure, poor quality

supporting maps. Places are very large and generic in

many cases. Will be difficult to use when determining

actions in the future, much of the policies are vague.

Make the document clearer and easy to use.Chris Shaw

175/1

Accept in part





Introduction. The maps will be revised to make them

easier to use. The Places have been retained as is.

Some of the policies have been revised.

Re: Milestones. Vast majority begin with the words

"Report on ...". Should reflect activities that actively

"manage" conservation.

Rewrite to reflect inputs to conservation not simply

reporting.

Chris Shaw

175/6

Accept in part


The timing of the release of three CMS together has

made it very difficult for our volunteer organisations to

find time to read and understand and prepare detailed

submissions.

Suggest that in future the release dates be staggered to

make it easier for volunteer organisations to submit on all

of them.

New Zealand Four

Wheel Drive

Association

177/1

Noted

Thank you for your effort.

Found it difficult to interpret. Suggest clearer wording and reduce in length.Geoff Fischer

185/1

Accept in part





Introduction. Some provisions have been revised to

provide more clarity. The length has remained the


Submitter and

submission point


same.

Oppose the lack of words such as 'will' and 'should' in

the policies. Encourage greater use of these words

where the community sentiment is strong about their

vision for the place. Lack of clarity and affirmative

policy creates ambiguity. Give businesses certainty over

what is or is not allowed.

HR[Not directive/prescriptive, creates ambiguity and

potential disputes, may be more difficult to resolve issues.

May not give effect to public's visions for Places.]

Venture Southland

199/1

Accept in part

The words 'will', 'should' and 'may' are used where a

decision is required e.g. concessions. Refer policy

3.1.1 (which has been moved to a new Interpretation

section in the Introduction). Other policies provide

direction to DOC.

Found it difficult to interpret. Suggest clearer wording and reduce in length.Sylvia Fischer

200/1

Accept in part





Introduction. Some provisions have been revised to

provide more clarity. The length has remained the

same.

Less prescriptive approach fails to provide adequate

guidance. Makes it difficult to oppose an activity.

Milestones-Outputs are very poorly drawn. Many

merely require a "report on progress". Outputs should

specify a measurable tangible outcome.

Otago Tramping &

Mountaineering

Club Inc

206/1

Accept in part

All statutory provisions in the CMS need to be

considered when making decisions.


Fails to comply with CGP policies 9.1 (b) and (c). Does

to some extent with Icon and Gateway Destinations

(terms which are not defined) but fails to do so for the

vast majority of recreational sites in Southland.

Otago Tramping &

Mountaineering

Club Inc

206/2

Reject

Refer to "DM and recreation' common issues report.

Too short and too general to provide much meaningful

direction for conservation land in Southland.

Include a specific and detailed Appendix 11 explaining the

values, importance, and future management regime for

specific huts and tracks across Southland.

Federated Mountain

Clubs of NZ (Inc)

219/1

Reject

Refer to 'DM and recreation' common issues report.

The milestones are generally excellent.Federated Mountain Clubs of NZ (Inc)

219/10

Accept

Many milestones have been revised.

DOC appears to be scaling down and prioritising the

issues it will advocate on.

Federated Mountain

Clubs of NZ (Inc)

219/11

Accept

Correct, there is a need to identify the priorities for

advocacy on a national basis.

Supports the overall CMS and the Visitor Management

Zone approach. CMS caters for a wide range of uses

while maintaining and enhancing the environmental

qualities of the estate.

Southland District

Council Southland

CMS Submission

224/1

Accept


Supports the intention of the draft CMS in its current

form.

Genesis Energy

225/1

Accept



Submitter and

submission point


The NPSREG confirms the importance of renewable

energy and seeks to achieve a consistent policy

formulation and planning approach that recognises the

benefits of renewable energy generation. It is

appropriate that the draft CMS recognises and provides

for renewable electricity generation in a similar capacity

to the NPSREG.

That the draft CMS:

recognises existing renewable electricity infrastructure in

the context of the existing environment;

establishes a policy framework which does not undermine

existing renewable electricity infrastructure or preclude the

establishment of new infrastructure;

provides for the diversification of locations for and access

to renewable electricity generation;

recognises regionally and nationally significant electricity

generation infrastructure within Part 2;

adopts the key definitions for "renewable energy

generation" and "renewable energy generation activities"

from the Renewables NPS.

Genesis Energy

225/2

Accept in part

The NPSREG is given effect to by the RMA91.

Utilities in general are recognised throughout the

CMS, including by way of policy exceptions that

provide for the construction and maintenance of

utilities. A new section for 'Structures and utilities'

and a policy have been added to Part 3.

Generally supports.Westland District Council

226/1

Accept


Support in general.Fiordland Lobster Company

231/1

Accept


Wish to extend protection of night sky values and

natural light to all conservation land, including

limitation of impacts on flora and fauna from artificial

light. Where risks to specific species are identified,

lighting with limited spectra can be used.

Controls for all conservation land should include

management of outdoor artificial light at night. Includes

limits on lighting levels, direction control, timing and

spectrum.

HR [Can save on costs and energy. Need to move away

from using blue lights which affect circadian rhythms.

DOC is a signatory to the Conventions identified in

submission.

QLDC, Mackenzie DC and Auckland Council have

policies re night light.]

Dark Skies Group,

Royal Astronomical

Society of New

Zealand

238/1

Accept in part

The effects of artificial light on conservation values is

one of many adverse effects that may be considered

when assessing the impact of activities.

Numerous instances of policies with "should not allow

..."

Replace "should" with "will".Backcountry Skiers Alliance

245/1

Reject

'Will' can only be used as per Policy 3.1.1a). 'Should

not' provides the greatest direction possible without

fettering the decision-making powers of the Minister.

(Note: Policy 3.1.1 has been moved to a new

Interpretation section in the Introduction.)

Has a generic format that fails to recognise the New

Zealand is diverse, both from a social and biodiversity

viewpoint, and some issues cannot be generalised for

ignored.

Abandon the generic template approach.Backcountry Skiers Alliance

245/4

Reject

The national template approach has been retained.

However, much of this CMS reflects Southland

Murihiku, particularly section 1.3 and Part Two.


Submitter and

submission point


Too much emphasis on facilitating business. Contains

almost nothing on advocacy for conservation under

statutory provisions. The term "prosperity" is overused.

Rebalance with an emphasis on biodiversity, public

recreation, intrinsic values, historic values rather than how

to encourage business. Change references to "businesses"

to "community groups" or similar.

Backcountry Skiers

Alliance

245/5

Reject

Economic prosperity and working with others

(including businesses) is linked to the ability to

achieve more conservation outcomes. New advocacy

objectives have been added to section 1.5.1.

Very light on detail, and contains very few policies.

Lacks ability to provide certainty as to how

conservation lands will be managed, or sufficient

detail/rules/policies to enable DOC staff to base sound

decisions on.

Have more rules, more zoning, more detail and less generic

comments.

Backcountry Skiers

Alliance

245/6

Reject

The Place outcomes and objectives in Part 1 also

provide guidance to decision-making. All operative

provisions in the CMS need to be considered. The

resolution of any ultimate conflict will be guided by

the CA87.

Support. Retain with specific deletions and rewordings relating to

mountain biking.

Stephen Martin

251/1

Accept in part


Some mountain biking provisions have been revised.

Refer to 'Mountain biking' common issues report.

Concerned by the general tone, could hinder the future

development of people's aspirations for specific places

in Murihiku. Difficult to follow. Appears to be some

inconsistency and vagueness of outcome for some

places and some activities.

HR[Lack of integration with Regional Coastal Plan. Fails

to reflect the characteristics and needs of the tourism

industry in terms of long lead-in times, appropriate scale of

activities and the need for flexibility.]

Op Marine Limited

253/2

Reject

Both commercial and recreational development

within Places will be guided by the Part 2 outcomes

and policies, as well as the objectives in Part 1 and

relevant policies in Part 3. This may mean that some

activities cannot occur in some locations.

The CMS recognises the RCP.

Ensure CMS does not limit the undertaking of

emergency response activities as required under the

Maritime Transport Act 1994.

Ministry of

Transport

257/1

Accept

Any emergency actions undertaken in accordance

with the MTA94 do not require authorisation under

the CMS or conservation legislation.

Support nationally consistent approach of reducing the

overall 'bulk' of CMS, particularly by grouping many

areas of PCL into key places. Nationally consistent

approach to the aircraft access provisions including

aircraft access policies in Part 3, maps for visitor

management zones & aircraft access zones, and

Appendix 13.

Heliworks

Queenstown

Helicopters 2012

Ltd & Southern

Lakes Helicopters

Ltd

265/1

Accept


Support nationally consistent approach of reducing the

overall bulk of CMS. Support using key special places

and the nationally consistent aircraft access provisions

including the aircraft access policies, maps for VMZ

and aircraft access, and Appendix 13.

Totally Tourism

Limited

267/1

Accept


Is well written and well presented. Advice on the

implications of the Conservation Boards would be

Straterra Natural

Resources of New

Zealand

271/1

Accept in part



Submitter and

submission point


appreciated. Observe inconsistencies between the NI

and SI CMSs, e.g.. In the treatment of commercial

activities. Would be better served with two CMSs, one

for NI and one for SI.

271/1 The role of Conservation Boards is set out in s6M

CA87. The milestones in the CMS will be what is

used to report to the Boards, as set out in Part 4.

There are some differences between CMS that reflect

regional values and issues. However, the intent is to

have overall national consistency for the CMS. There

will not be one for the SI & one for the NI.

Supports the format of the CMS. Nationally consistent

approach of reducing the overall 'bulk' of this statutory

document, particularly by grouping many areas into key

special places, is considered beneficial.

Tuatapere Hump

Track Charitable

Trust

276/1

Accept


Considers this CMS is too brief and general to provide

much in the way of meaningful direction over the large

diversity of conservation land in Southland.

Request including a detailed Appendix 11 explaining the

values, importance, and future management regime for

specific huts and tracks.

New Zealand Alpine

Club

284/1

Reject

There has been no change to the overall, nationally

consistent structure of the CMS. Some revisions have

been made to Part 2 Places to provide further

direction. The objectives in Part 1 also provide

guidance to decision-making. All operative

provisions in the CMS need to be considered.

Re: Appendix 11 - refer to 'DM and recreation'

common issues report

The draft CMS does not meet the guidance in the GP

2005 (Policies 9.1(b) & (c). While 'Icons' and Gateways

are identified and a limited number of other

opportunities, the draft fails to identify the various back-

country recreational opportunities in each place.

Request that all references to the Destination Marlborough

Framework of "icon", "gateway", "local treasure",

"backcountry network" be removed for these reasons:

(a) They have no statutory meaning.

(b) They have no practical meaning and do not describe

what makes a place special.

(c) They provide no practical guidance.

(d) The DMF is full of erroneous assumptions.

New Zealand Alpine

Club

284/3

Reject

The backcountry recreational opportunities in each

Place are recognised.

Refer to 'DM and recreation' common issues report.

The milestones in this CMS are generally supported.New Zealand Alpine Club

284/10

Accept

Thank you for your support. Many of the milestones

have been revised.

Agree with the general aim of this draft.Central Otago Recreational Users

Forum (CORUF)

295/1

Accept


Consider that freshwater management is primarily a

function of Regional Councils. Need to recognise that

freshwater ecosystems are used and utilised for many

purposes and in promoting conservation DOC needs to

consider wider social and economic outcomes of the

community. Language adopted is inconsistent and in

Alliance Group

Limited

296/16

Accept in part

DOC has specific functions under s6 CA87 for

freshwater that are in addition to those carried out by

regional councils under the RMA91. This provides

for DOC's advocacy off pcl&w (note new objective

in section 1.5.1). The Freshwater Place recognises


Submitter and

submission point


some instances unreasonable given DOCs intention to

advocate beyond conservation lands/waters.

that freshwater is used for many purposes.

Very clear movement to be more permissive of

commercial activities within DOC lands. Many different

values and qualities of a site or area may be impacted by

increased activities, commercial or otherwise. Increased

recreational access largely beneficial, but only up to a

point.

Increased tourism utilisation and general appreciation of

conservation lands should also be encouraged, but the

basic values of places must not be devalued by over-use

or taking the experience of 'getting there' away.

Potential for impact where independent recreationalists

reach a level where as a whole they degrade everyone's

experience.

New concessions should be non-destructive of

conservation and recreational values. Intent and

integrity of CMS must be maintained, and not

interpreted to suit particular applicants.

HR[Many locals haven't submitted, too hard/threatening.

May not need to 'encourage' more commercial activity.]

Bill Jarvie

305/1

Accept in part

Any application to carry out a commercial activity

needs to be considered against all relevant provisions

in the CMS. The same applies to the development of

new recreation opportunities. This will involve an

assessment of effects and a decision as to whether

those effects can be managed so as not to impact on

conservation values, and whether the activity is

consistent with the CMS.

Use more definite language in policies (such as 'will'

and 'should') where the public and the community have

clearly communicated the vision for the places.

Oppose ambiguity which can lead to subjective

decisions. CMS is one of the main ways the public can

communicate to DOC what is appropriate or not in their

communities. Ambiguous policies lead to more

consultation, which takes further resource, and is

tiresome. Ambiguous policies can lead to inappropriate

development being approved simply because of lack of

opposition. Clear policy leads to more accountability

and better, proactive management.

Diana Zadravec

308/25

Accept in part

The words 'will', 'should' and 'may' are used where a

decision is required e.g. concessions. Refer policy

3.1.1 (which has been moved to a new Interpretation

section in the Introduction). Other policies provide

direction to DOC in line with what the community

has sought.

Do not believe they are at a stage where national

objectives are consistently represented. Current criteria,

assumptions, and the accuracy of values, need to be

clarified and assessed based on science and clearly

established formulas.

There should also be a consistent approach to this

throughout the three draft Strategies.

Film Otago

Southland and the

Regional Film

Offices of NZ

(RFONZ)

312/1

Accept in part

The national objectives and relevant Part 3 policies

(e.g. filming and aircraft) have been revised to be

consistent across the 3 South Island CMS.

The widespread application of Natural Quiet as a value,

including the criteria for determining its value in places

needs to be addressed. Need to be realistic about where

and when natural quiet currently exists and where is

currently does not. The liberal mis-application of natural

quiet throughout the CMS need addressing for it to have

In respect to these questions. Please demonstrate this, if

not, this needs to be consulted on, addressed and applied

with another Draft presented for comment.

HR [WARO activity unlikely to be stopped because natural

quiet is in an Outcome.]

Film Otago

Southland and the

Regional Film

Offices of NZ

(RFONZ)

312/2

Accept in part

Refer to 'Aircraft' common issues report.

There is no further opportunity to notify another draft

CMS for public comment.


Submitter and

submission point


any relevance. One of the key issues is how staff will

interpret these promises of natural quiet. If natural quiet

has been illogically applied as an outcome to a place, it

could become an unnecessarily restrictive obstacle that

will ultimately not deliver on the promise. How is the

importance of natural quiet as a value gauged? How is

this applied or the level of its value or importance in a

place calculated? How has current level of natural quiet

determined? Is there anywhere beyond front country

where natural quiet would not be valued if achievable?

Has the CMS approached this with a scientific and or

consistent set of criteria?

All 3 CMSs are unwieldy and wordy. Frustrating the

lack of consistency in the different CMSs. This made it

difficult to compare especially areas that one would

presume to be similar are not easily comparable, e.g.

Appendix 2 - Cant and Otago include only botanic

values while Southland adds fauna. Also the amount

and quality of botanic info varies from listing species to

referring to the common or Maori name to a general

statement such as "contains many threatened and/or

endemic plants". Also our area of interest is referred to

only as there is a "Marine" in Otago, "Coastal Land and

Marine" in Canterbury and listed under location names

in Southland.

HR[CMS's developed in isolation.]Yellow-eyed Penguin Trust

324/1

Accept in part





Introduction. The 3 CMS will be more consistent.

CMS is to achieve "integrated management of natural &

historic resources", and "natural" is not equivalent to

indigenous. There are wild, self-sustaining, introduced

animal populations highly valued by the community.

Many natural ecosystems supporting indigenous species

include both indigenous and introduced species. There

is inconsistency around the use of terms pest and

predator. Several sections of the CMS refer to

"eradication of trout" where necessary to protect native

fisheries, and refer to CGP 4.2(d).

That the CMS accommodates "valued introduced species",

recognises the validity of them, and provides for the

harvesting of game birds and sports fish in a permissive

manner. Acknowledge the mixed indigenous and

introduced species/ecosystems continuum. If the term

"valued introduced species" cannot be adopted, a better

term would be "wild animal", and to reserve the use of

"pest" for those species legally or regionally defined as

pets. The CMS be revised to be consistent in its wording

with CGP 4.2(d).

Fish and Game New

Zealand (Southland

Branch)

329/2

Accept in part

DOC's functions under s6(ab) CA87 are recognised

in the CMS e.g. the Freshwater Place identifies the

value of healthy freshwater ecosystems to indigenous

and introduced species; and many Places recognise

trout fisheries/habitat.

A new objective has been added to section 1.5.1 re:

working with F&G Councils on freshwater advocacy.

There is no mention whatsoever in the CMS of

eradicating trout and trout/salmon are not referred to

as pests..

SF&G administer the Mandeville Ponds, Redcliff

Reserve and Sinclair Road Wildlife Management

reserves; and has a role in the management of a number

of DOC administered reserves.

Would like these reserves and roles stated, by way of a new

Appendix X- Reserves Administered/Managed by Others,

or mentioned in the Vol 2 land inventory.

Fish and Game New

Zealand (Southland

Branch)

329/3

Reject

A new appendix is not needed. Many objectives and

policies in the CMS refer to working with others,

such as SF&GC.

Vol II can only refer to pcl&w.


Submitter and

submission point


There are many marginal strips which DOC administers

pursuant to s 24C CA for conservation purposes, public

access to and along waterways and lakes and

recreational use of adjacent waterways/water bodies.

The CMS should state:

1. The value of existing marginal strips for:

a. Conservation purposes, including maintenance of

adjacent watercourses/water bodies, water quality and

aquatic life;

b. Public access to any adjacent watercourses or bodies of

water; and

c. Public recreational use of the marginal strips and

adjacent watercourses/water bodies.

2. DOC will advocate for the values associated with

marginal strips and ensure that freshwater values and

public access are protected before any concession for the

use of marginal strip is granted including grazing.

Fish and Game New

Zealand (Southland

Branch)

329/9

Accept in part

The value and use of marginal strips is identified and

addressed in the Freshwater Place, and by way of

Objective 1.5.3.10.

Important that DOC recognises its advocacy function is

not limited to protection of indigenous species.

Otherwise effectively allows for degradation in water

quality and quantity.

References to advocacy for the protection of 'indigenous

species' be replaced with 'freshwater species'.

Fish and Game New

Zealand (Southland

Branch)

329/14

Accept in part

A new objective has been added to section 1.5.1 re:

advocacy for freshwater fisheries, fish habitat and

fish passage. Many of the policies in the Freshwater

Place are not restricted to indigenous species.

Water yield is an essential ecosystem service and in

some cases the primary environmental and economic

justification for the retirement of high country pastoral

land through tenure review.

Add policies:

a) That the Department recognise and further publicise the

water yield and retention benefits of catchments (including

their possible downstream commercial value) containing

native tussock vegetation.

b) That the Department investigate, in partnership with

commercial water users government agencies, and the

community, ways to improve the water yield of appropriate

catchments in Southland in order to sustain conservation

values downstream and existing abstractions.

c) That the Department take into account the water yield

values of public conservation land, including future public

conservation land from the tenure review process, and use

these values as a tool for public awareness and advocacy.

Fish and Game New

Zealand (Southland

Branch)

329/15

Accept in part

Water yield has been recognised in a number of

Places as a result of other submissions.

New common CMS format is a step in the right

direction. Should provide accurate, unambiguous

guidance for decision-makers. Should avoid an overly

prescriptive approach that may prevent new, positive

initiatives that are aligned with conservation outcomes.

More work is required to make the content even more

accessible and user friendly. References to various

activities are spread across all parts.

Would appreciate more clumping of activity-specific

information where possible.

Tourism Industry

336/2

Accept in part


Part 3 will be restructured to group the relevant

policies with each section. Place specific policies for

different activities will remain in Part 2.

Grave concern that the CMS appears to foster an

increase under the guise of "recreation" of commercial

HR[Need greater enforcement powers e.g. infringement

notice, instant tickets.]

Environment and

Conservation Accept in part

While the CMS does enable new commercial and


Submitter and

submission point


tourism opportunities on PCL and a parallel increase in

activities broadly involving the use of mechanical

devices to increase visitors numbers to PCL. The focus

on visitor numbers is not matched by any concern that

visitors appreciate the natural/historic resources and that

their recreational enjoyment can be in conflict with

safeguarding those resources for future generations.

Organisations of NZ

Inc

345/1

recreational opportunities, this is balanced against an

assessment of effects and consideration of the

relevant operative provisions in the CMS. The quality

of visitor experiences is one of many matters to

consider. Refer policies 3.1.8 and 3.1.15.

Enforcement actions are taken in accordance with the

relevant conservation legislation and other statutory

provisions e.g. bylaws. A new policy has been added

to Part 3 re: bylaws and regulations.

Think most of the draft CMS is sound, and the text is

clear and concise.

Wellington

Botanical Society

346/1

Accept


CMS is too generic; doesn’t allow for the uniqueness of

this region e.g. winter wilderness zoning in Garvie

Mountains to be addressed.

Make changes to CMS to allow for regional differences to

be celebrated and adequately managed for - more important

than having document that looks the same as the one for

Northland.

Kate Wardle

351/1

Reject

The national template approach has been retained.

However, much of this CMS reflects Southland

Murihiku, particularly section 1.3 and Part Two.

CMS has been prepared with no engagement with

territorial authorities. Makes it difficult to comment. Far

from best practice, and will reduce the quality of our

input.

Given the lack of engagement there may be matters of

interest or concern which are not identified in this

submission.

Meet with each TA in the affected area. Once the CMS is

adopted, meet to address implementation. In future, DOC

should engage with territorial authorities early and in an

ongoing way.

Any such issues should be addressed through ongoing

engagement as requested.

HR [No consultation - in the past we have had a better

working relationship. We should be talking as the CMS is

being developed.]

Clutha District

Council

359/1

Accept

DOC apologises for any lack of consultation with

CDC during the preparation of the draft Southland

CMS. DOC Southland's relationship with CDC

should improve now that the boundary of the

Murihiku office encompasses more of CDC's area,

and there will be more matters of common interest.

DOC accepts your offer to meet, when the Southland

Murihiku CMS is approved, to discuss its

implementation.

DOCs ability to manage pests has an effect on the

implementation of regional pest strategies.

Acknowledgement of DOCs 'good neighbour'

obligations would go some way towards showing the

rest of the regional community that DOC understands

their concerns and is working to address them. DOC

should be subject to the same regional pest management

strategies as all other land occupiers. Appendix 5 details

proposed control mechanisms but is subject to adequate

resources. This is not acceptable.

Amend to acknowledge DOCs responsibility to be a "good

neighbour". CMS goals could be better served by outlining

a region wide strategy which sees DOC identifying

opportunities to work collaboratively with local authorities,

landholders, agencies where alignment between its own

pest control programmes and theirs would better achieve

mutual goals.

HR ["Good neighbour" derived from Biosecurity Act and

implemented through RPMS.]

Federated Farmers

of New Zealand

390/10

Accept in part

A new national objective has been added to section

1.5.1 re: the containment or control of pests and wild

animals (linked to Appendix 5); and a new regional

objective has been added re: the implementation of

the RPMS. Other objectives and policies also support

the management of pests in collaboration with others.

This work will always be subject to a prioritisation

assessment.

Reflection of the Treaty relationship between DOC and

Ngai Tahu: Ngai Tahu has an expectation that the

Crown will honour Te Tiritiri o Waitangi (the Treaty)

and the principles upon which the Treaty is founded.

The Ngai Tahu Claims Settlement Act provided a

practical framework to assist the Treaty partnership

The CMS should promote active participation of NT in

management of the conservation estate by providing for:

- Active and shared decision-making.

- Tino rangatiratanga/kaitiakitanga.

- Customary use of mahinga kai and other resources.

- Processes and protocols to ensure NT treaty rights and

Te Runanga o Ngai

Tahu

391/79

Accept in part

Part 1.4 covers most of this. Decision-making

involvement may occur except in the making of a

statutory decision itself. Customary use is covered by

statute and CGP05 - see also 391/24 response.

Concessions for activities on pcl&w have a standard


Submitter and

submission point


between NT and the Crown. However NT is concerned

that this partnership is not adequately reflected in the

content of the CMS.

kaitiaki role are recognised and provided for when

community and business groups are involved in activities

on public conservation land.

- Development of a co-management approach in regard to

places and species of particular significance to NT.

- Adequate resourcing to allow full participation of NT as

the Treaty partner in DOC's vision to 'grow' conservation.

HR [Raise awareness as to why NT may be involved.

Seeks more than just consultation over issues, shared

decision making, more than just Kaitiaki Roopu meetings.]

clause re NT matters; beyond this (e.g. trusts &

sponsorships) should be covered by 1.4 relationships.

Management involvement with places & species is

covered by 1.4 & ongoing partnership relationship,

but take care with "co-management" terminology

given that term's statutory use in other legislation.

Resourcing is a business planning matter, not CMS.

The primacy and the essence of the Treaty partnership

needs to be clearly reflected throughout the document.

1. In narrative, objectives and policies regarding DOC

working with others, identify NT first and use wording that

reflects the primacy of the Treaty partnership.

2. In each Place section:

(i) include a policy as follows (as the first policy in the

section): In managing public conservation land in this

Place, recognise and protect the rights and values of

Papatipu Runanga in relation to the Place

(ii) make sure all relevant Statutory Acknowledgements

and Topuni are listed.

HR [Sense of marginalisation of Treaty relationship,

appears incorporated into other relationships/subsumed.

Doesn't fully recognise the Treaty/give effect to it as per s4

CA. Use the term 'Treaty partnership' to reflect its

importance and difference to other partnerships.]

Te Runanga o Ngai

Tahu

391/94

Accept in part

1. Yes, CMS wording (e.g. 1.2 Vision intro text x 2)

will make it clear that the NT Treaty partnership

relationship is separate and different from the

community relationship.

2(i) This matter is covered by 1.4 for the whole CMS

and does not need repeating throughout.

2(ii) Deeds of Recognition are the form of statutory

acknowledgements relevant to DOC and referred to

in the CMS; all these Deeds and Topuni, where they

are on pcl&w, will be recorded in CMS text and the

Topuni on the maps.

Reference to NT needs to be consistent across the

document and between DOC regions.

Replace references to "Ngai Tahu whanui' with 'Ngai Tahu'.Te Runanga o Ngai Tahu

391/96

Accept

Text revised. See also 391/95 response.

NT and their forebears were the first people to occupy

the landscape of New Zealand. The document does not

give sufficient emphasis to this presence in either the

general narrative or in the treatment of areas and sites

that are of cultural importance.

General changes requested:

1. Cover - consult with NT to identify imagery reflecting

NT presence to be included on the cover of the approved

CMS.

2. General - provide for use of traditional names, and

include dual names for places and species consistently

throughout the document.

Te Runanga o Ngai

Tahu

391/97

Accept

1. If NT imagery can be used on the cover, NT will

be consulted about this.

2. Yes, subject to DOC publications standards, i.e.

use of NZGB-approved names; non-NZGB names in

a distinguishable way; all species etc names; all

macrons etc.

Supporting kaitiakitanga: The kaitiaki role of NT is an

expression of rangatiratanga and one of their

responsibilities as mana whenua. The role complements

the statutory responsibilities of DOC for conservation of

natural and historic resources, and NT support DOC's

work in both active protection and advocacy for these

resources. It is important that the CMS maintain a

General changes requested to incorporate the principles are

identified.

HR [Need to expand principles as current 'list' dates from

1989 (ref CGP05).]

Te Runanga o Ngai

Tahu

391/104

Accept in part

See specific issue responses. The CMS does not

specifically list the ToW principles, as in the CGP05,

so there is no need to expand on them.


Submitter and

submission point


primary focus on ensuring New Zealand's natural and

historic taonga are protected for future generations, and

that commercial and recreational use of conservation

land is provided for only where it is consistent with this

objective.

See general reasons. 1. Ensure that the narrative, objectives and policies

throughout the CMS clearly retain priority for conservation

outcomes over commercial opportunities.

2. Ensure that the narrative throughout the CMS recognises

the work being carried out by kaitiaki.

Te Runanga o Ngai

Tahu

391/109

Accept in part

1. The CMS is written in terms of CA87 and its

Schedule 1 legislation, and the primacy of protection

and preservation of natural & historic resources.

"Conservation", by statutory definition, does allow

for public use, commercial or otherwise, and there are

situations where legislation may allow commercial

opportunities to override 'conservation' (e.g. some

Crown Minerals Act activity).

2. Kaitiaki and community work will be recognised

where it involves pcl&w, with specific group mention

where it is a significant and ongoing action.

Enabling exercise of cultural activities: Tangata

whenua, as the name implies, are part of the

land/environment. Mahinga kai is a cornerstone of NT

culture. NT wishes to ensure that the importance of

mahinga kai and cultural materials is recognised in the

CMS. NT also requests that the CMS recognise and

support NT policy on marine reserves.

General changes requested, as identified.

HR [Access and use should be available unless there is a

good reason otherwise.]

Te Runanga o Ngai

Tahu

391/110

Accept in part

See responses to specific changes requested.

Customary use is covered generally within 1.4; see

also 391/24 response - Fiordland Place.

DOC policy on marine reserves is determined by the

MPA Policy, the implementation of which through

such as the current Otago Forum will have to

consider the NT policy, but NT policy is not DOC

policy and does not need stating in the CMS.

Recognising proprietary rights: The Treaty of Waitangi

protects NT proprietary rights in relation to their taonga.

Rights that could be affected by the way in which

conservation land is used include:

- Authenticity in interpretation of NT stories.

- Intellectual property in regard to research on use of

indigenous species.

- Ownership of pounamu and access to this.

- Interests in the vesting of significant NT sites.

General changes and place-specific matters requested to be

addressed.

HR [Need better interpretation of NT values and

knowledge of places/sites/paths.]

Te Runanga o Ngai

Tahu

391/115

Accept in part

- Within DOC publications etc DOC seeks the correct

'authenticity' authority; concessions conditions seek

this elsewhere, but DOC may not always have the

control to ensure authenticity.

- Intellectual property rights are not a matter that

CMS can address under current conservation

legislation.

- Pounamu ownership etc is well-addressed in 1.4.

- Re 'vestings' see 391/51 response.

Re HR, this better interpretation can come about

through DOC operations, but doesn't need in-depth

expression in CMS.

Enabling NT to provide for future development

opportunities: NT considers that rights to taonga that are

protected by the Treaty would reasonably include an

General changes requested to incorporate these principles

are identified.

Te Runanga o Ngai

Tahu

391/123

Accept in part

NT, in seeking commercial opportunities involving

pcl&w, is required by statute to be considered as for


Submitter and

submission point


ability to work with those taonga to develop

opportunities for enhancing visitor experiences on

conservation land or to support themselves and provide

for future generations. The Waitangi Tribunal, in its

report on the WAI 262 claim, found that it would be

appropriate for DOC to accord a degree of preference to

tangata whenua in awarding concessions and contracts,

in order to strengthen kaitiaki relationships through

work and business opportunities.

any other potential concessionaire. While the

aspirations re 'support..and future generations' are

worthy they are not matters that DOC can consider in

its concessions decision-making, and the 'enabling' of

any concession opportunity could be seen as

predetermining the Minister's decision-making role.

Government acceptance of and response to WAI 262

report recommendations has not yet occurred, so

those recommendations cannot currently be

considered. However, as already occurs, DOC does

work with people outside of DOC to develop visitor

experiences and business opportunities with

conservation, as in accord with several current 1.5

section objectives (e.g. 1.5.3.4, 1.5.4.3 & 1.5.5.4).

Re impact on cultural values. Include "Ngai Tahu" in front of the word "cultural" in all

policies.

Te Runanga o Ngai

Tahu

391/144

Accept in part

Where "cultural" refers only to NT culture then this

may be appropriate, otherwise not.

All sections of the CMS should be enumerated. Enumerate all sections of the CMS.

HR [Draft ambiguous and hard to make decisions on.

DOC is not the Department of Tourism.]

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/1

Accept

Numbering will be added to many of the sections at

the publication stage.

Index and References

The Society is surprised that there is no indexing,

references or bibliography for any of the notified CMS's.

Include an Index and References.Royal Forest and Bird Protection

Society of New

Zealand Inc

398/2

Accept in part

References have been identified in the text where

relevant. An Index will be added when the CMS is

approved by the NZCA.

When the approved CMS is on-line word searching

will be possible.

Concerning to read a number of references throughout

the document of an outcome that will see species

continue to face decline within areas that are not

identified as being of priority. DOC cannot function

under the Conservation Act and General Policy. CMS

should better reflect these.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/4

Noted

DOC has to prioritise its efforts and this means that

some species may face decline in some areas, but

overall population numbers should improve. There is

a need to work with others to achieve conservation

gains.

Milestones-Outputs appear for the most part to be

outputs with few milestones.

Seeks that the work the draft CMS states DOC will carry

out also clearly states when this is intended to be achieved.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/6

Accept in part


Protection of biodiversity - words to describe how DOC

will protect biodiversity values both on and off the

public conservation lands are inconsistent between

These need to be standardised.Royal Forest and Bird Protection

Society of New

Accept in part

The national objectives in Part 1 and national policies

in Part 3 will be consistent between CMS. Other


Submitter and

submission point


places, outcomes, policies and milestones and between

CMS's, despite all being driven by legislation and

General Policy Statements.

Zealand Inc

398/7

provisions, including outcomes and policies in Part 2,

reflect local/regional approaches to managing

biodiversity. However, the relevant national

milestones are consistent.

Status of National Park Management Plan versus CMS

Has concerns over the relationship between the CMS

and the NPMPs, and seeks clarification that the NPMPs

have the higher status should there be any conflict. If

this is not the case, then the CMS needs to be amended

to ensure there are no conflicts with the NPMPs, and

that the provisions in Part 3 are subservient to and do

not conflict with the NPMP. In places the provisions for

aircraft landings, visitor zoning and concessions

management do not reflect the current provisions in the

NPMPs. In many cases the new provisions are more

permissive and undermine the NPMPs.

Amend all maps, tables, outcomes and prescriptions etc, for

management relating to national parks to ensure they are

the same as those in the NPMPs, or simply refer to the

relevant Plan provisions.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/8

Accept in part

Two new policies, which clarify that NPMP's and

CMP's continue to have effect and have primacy until

they are reviewed, have been added to a new

Interpretation section in Part 1. Policy 2.2.2 states

that FNP should be managed in accordance with it's

NPMP, and has been revised to include reference to

the visitor management and aircraft provisions. Part 2

policies have precedence over Part 3 policies (refer

introduction to Part 2).

Re Climate Change:

There is limited reference to climate change and no

policy. Climate change is a fundamental threat to be

considered under both policies. CGTP 4.1 (b) & 4.2 (a).

- Include a more comprehensive discussion of climate

change and its effects on indigenous biodiversity such as

the statement provided.

- Identify the threats for the conservancy and monitoring

that is required.

- Advocate for a precautionary approach and mitigation

where relevant.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/169

Accept in part

A new paragraph has been added to the descriptive

text in section 1.2 to acknowledge that the ecological

and social environment of New Zealand will change

(including climate change), and that future revisions

of the CMS will reflect these changes.The 3rd para of

the long-term Vision has been revised so that

conservation outcomes are 'responsive to change'.

'Managing the effects of climate change' has been

added to section 1.3, Safeguarding valuable flora and

fauna. Objective 1.5.1.12 covers climate change.

Marine aquaculture has the potential to have effects on

seabirds, marine mammals and the benthic communities.

Associated structures may also be vectors for the

introduction of invasive marine species. There is no

subsection on marine threats such as climate change,

sedimentation from adjacent land, invasive marine

species or pollution/debris.

- Include a policy to advocate for sustainable use of the

coastal marine area focussed on threats such as climate

change, sedimentation, invasive marine species or

pollution/debris.

- Advocate for and work collaboratively with the Ministry

of Primary Industries and industry to achieve protection of

the wetland and bird and marine life from adverse impacts

associated with marine-based activities (such as fishing and

aquaculture).

- Include a policy to raise awareness about the values of the

marine environment through education programmes and the

media.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/170

Accept in part

Many of these issues are addressed in the Foveaux

Place in Part 2. Aquaculture has been added to the

description and is covered by the Outcome. A new

objective has been added to section 1.5.1 re working

with others to manage or avoid threats to marine

mammals.

Re Mitigation/Biodiversity Offsets

A new section is needed to guide DOC in making

decisions regarding proposals that may require

Include the following or words to similar effect:

"Mitigation of adverse effects/biodiversity

offsets/compensation should only be considered provided

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/174

Reject

A specific policy/objective for this matter is not

required, as it is one of many tools that may be used.


Submitter and

submission point


mitigation/biodiversity offsets/compensation, or the use

of pcl for mitigation/biodiversity offsets/compensation

from developments off pcl. This could either be in Part

3 or Part 1 of the CMS.

there is a net conservation benefit, there is no risk of

extinction or extirpation of species and the activity is close

to and ecologically similar to the affected site and follows

the best practice principles as set out by BPOP."

398/174 The objectives in section 1.5.1 and the outcomes and

policies in Part 2 provide sufficient guidance as to

what the goals for managing biodiversity are.

Generally supports, subject to specific submission

points.

Trojan Holdings

Limited

399/1

Accept


Outcomes, policies do not provide sufficient rigour or

direction. Contribute to, encourage and foster do not

give adequate direction, nor provide robust enough

basis for reporting milestones and are inadequate for

measuring meaningful results.

AmendCatherine & Ad Sintenie

403/6

Accept in part

While DOC may well lead some actions, it is not the

only agency with responsibilities in the areas covered

by the objectives/policies, some of which direct

advocacy. Three objectives in Part 1.5.1 have been

revised and combined into a single objective that no

longer uses the term "contribute". See NHMS

common issues paper section 2.

Section: General Introduction (National Issue)

Unnecessarily long-winded. The amount of background

material should be cut down considerably. Should be

provided on the DOC website for in a separate

document.

Riverstone Holdings

Limited

335/5

Accept in part

This is information that is needed to explain the key

points about what a CMS is, how it works and how it

relates to other planning and legislative tools. The

section on Tenure review has been deleted.

Obligations in regard to the Treaty of Waitangi should

be recognised in the same way, and placed in the same

context as international and other legislative obligations.

1. Include a new subsection headed "Treaty of Waitangi

obligations" before the subsection headed "International

obligations" and move the following content from Section

1.4 into the new subsection:

(i) First paragraph referring to responsibilities under

Conservation Act S4 and under Ngai Tahu Claims

Settlement Act.

(ii) The paragraph headed "Responsibilities under specific

legislation relating to Ngai Tahu".

(iii) The paragraphs headed "Ngai Tahu (Pounamu

Vesting) Act 1997 and pounamu management".

2. List applicable Ngai Tahu management plans in the

section headed "Relationships with other planning

processes".

Te Runanga o Ngai

Tahu

391/80

Accept in part

1.The CMS format is specified in a nationally-

developed template that DOC wishes to maintain for

national consistency, and 1.4 was the section agreed

on with NT early in the CMS review stages.

Legislation under which the Minister/DOC has

responsibilities, including ToW ones, are set out

under the "Purpose of CMS".

2. NT management plans are already listed at the end

of the 1.4 text, but the heading font needs changing

so they are not listed as a sub-section of

"Responsibilities under specific legislation...", and

intro sentence revised to read: "...have prepared the

following non-statutory documents...".

Section: General Part One (National Issue)

Generally supportive. May be appropriate to make

explicit commentary around the importance of allowing

for commercial activity, particularly in front country

areas. In deciding whether to allow commercial activity,

a useful test could be whether access is likely to result

Add the following clause: "To enable limited commercial

activity in the DOC estate in Murihiku where this can occur

in a manner, and at a scale, which will not have significant

adverse environmental effects or significant impact on

recreational users."

Southland District

Council Southland

CMS Submission

224/5

Accept in part

Commercial activity is more specifically addressed by

the outcomes and policies in Parts 2 and the policies

in Part 3.


Submitter and

submission point


in the promotion of a conservation ethic amongst those

who get to experience the DOC estate.

Disappointed about the low profile given to Southland's

flora. Few references in the text to seaweeds or non-

vascular terrestrial plants such as mosses, liverworts and

lichens. These plants have important roles in healthy

ecosystems but are often overlooked.

Insert more references to Southland's plants. Should also

include information that would help readers to put

Southland's flora in a national context. See extract from the

draft Northland CMS.

Wellington

Botanical Society

346/2

Accept in part

Southland's flora is addressed in Section 1.3, with

more detail provided in Part 2. As the CMS is not

meant to be a resource document is can only focus on

the significant species. This does not negate the

contribution that non-vascular plants make to healthy

ecosystems, and they are recognised at an ecosystem

level.

Pleased to find milestones in part one but concerned

about the wording of some of them. Recognise the

pressures for measurable milestones, and for nationally

consistent milestones. Craft milestones that would

deliver more informative reports.

Modify the milestones for year 10 and possibly year 5 so

that they generate more detailed information about the

progress made during the term of the CMS.

Wellington

Botanical Society

346/15

Accept in part


Objectives set out to "contribute' to various

conservation work. Although it is understood that it is

important for the department to work collaboratively on

conservation work, particularly other statutory bodies,

the use of the word does not clearly express the

department's statutory functions under the Conservation

Act. 'Contribute' could potentially mean the department

will do very little or a great deal.

The objectives need to clearly state the role of the

department.

Royal Forest and

Bird Protection

Society of New

Zealand Inc

398/5

Accept in part

While DOC may well lead some actions, it is not the

only agency with responsibilities in the areas covered

by the objectives/policies, some of which direct

advocacy. Three objectives in Part 1.5.1 have been

revised and combined into a single objective that no

longer uses the term "contribute". See NHMS

common issues paper section 2.

Section: General Part Two (National Issue)

Description and outcome part of each place not

referenced by way of a numbering system, and bullet

points have been used for listing the Milestones-

Outputs. When making a submission on those sections

there is the potential for error and misunderstanding.

Would be beneficial to incorporate a paragraph

numbering system. Also enable effective cross

referencing when providing explanations.

Amend the description and outcomes by incorporating a

paragraph numbering system.

Amend the Milestones-Outputs by replacing the bullet

points with a numbering system.

TrustPower Limited

138/11

Accept in part

Numbering will be added to the headings and the

milestones at the publication stage.

Section: Foreword

Re: 3rd para. CMS draft did not go before a panel of

experts prior to public notification, obvious in the

inconsistencies of its cultural heritage content for

Campbell Island.

Norman Judd

111/1

Noted

While every attempt was made to consult with a wide

cross-section of people and groups during the

drafting of the CMS, it is not always possible to elicit

everyone's views. Hence the public notification of the

draft CMS so that any person can make their views

know through a submission.


Submitter and

submission point


No information about the size of the area covered by the

CMS or any comparison with the total area of land

managed by DOC.

Add your best estimate of the total area covered by this

CMS.

Wellington

Botanical Society

346/3

Reject

This CMS covers the whole of Southland Murihiku

(excluding Rakiura/Stewart Island). The amount of

pcl&w within this area is visually represented on the

maps in Volume II. It is not necessary to state these

figures in the CMS.

Section: Purpose of conservation management strategies (National Issue)

The statutory framework shows a relationship with the

National Parks Act 1980. Is there not also a relationship

with the Reserves Act 1977, particularly in S20 with

regards the management of the Subantarctic Nature

Reserves?

Norman Judd

111/5

Noted

CGP05 was prepared under the CA87 but also

applies to the RA77 and a number of other Acts, as

listed on the following page in the CMS.

Re: public participation (last para, pg 7). DOC has not

adequately consulted with FMC in the preparation of

this document. This shows with the almost non-existent

strategy for backcountry huts and tracks. FMC did

provide unrequested advice on the pre-draft Southland

CMS, none of this advice appears to have been

incorporated.

Federated Mountain

Clubs of NZ (Inc)

219/5

Noted

DOC consulted with the public and a wide range of

stakeholders when drafting the CMS. This means that

everyone's views cannot be incorporated as wished.

Decisions were made not to list backcountry facilities

in the CMS. Refer to the 'DM and recreation'

common issues report.

Has been active in assisting and advising councils and

DOC on the development of bylaws and gazette notices

for freedom camping. Provide strong guidance for our

members on acceptable freedom camping practices with

an emphasis on self-containment. DOC should be

setting an example and giving leadership to local

authorities in properly applying the principles of the

FCA in their respective policies and bylaws.

Make explicit provision to provide guidance and leadership

to local authorities in the development of their freedom

camping bylaws to ensure they are consistent with the FCA

and contribute to the integrated range of opportunities for

freedom campers.

New Zealand Motor

Caravan Association

232/1

Reject

The Minister's role in the FCA11 is recognised. There

is no need to repeat the provisions of this Act.

Providing for a range of camping opportunities is

addressed in section 1.5.3.

Pg 7, 2nd para. The Crown Minerals Act 1991 should

be included.

Include within the Minister of Conservation's

responsibilities, the Minister's role as land owner under the

CMA 1991.

Straterra Natural

Resources of New

Zealand

271/6

Accept

CMA91 added to list.

Pg 7, 2nd para - includes the Electricity Act 1992. No

other reference made in CMS to this Act, which confers

on works owners such as Transpower, right of entry

onto land to inspect, maintain and operate electricity

works. Transpower owns and operates approximately

104 km of transmission line and 269 transmission

structures on DOC land in Southland.

Explicitly recognise the presence of Transpower assets on

DOC land in Southland and the importance of ensuring

access to these critical assets is not compromised or

restricted.

Transpower NZ Ltd

301/1

Accept in part

The first sentence of Part Three Authorisations

(General) has been revised by adding a reference to

exceptions provided by other legislation.

Pg 7, last para, re: public participation. Tourism

operators favoured TIA/DOC workshops.

The value of joint TIA/DOC workshops is communicated

at a national level and becomes a SOP for any strategy or

plan development process.

Tourism Industry

336/1

Noted


Submitter and

submission point


Unclear of the relationship between the CMS and other

planning documents; especially NPMPs. What trumps

what?

Members concerned that a CMS may impact on the

NPMP and ultimately their concession.

Risk of change to concession activity without warning

appears low.

More work is required to make the content even more

accessible and user friendly. References to various

activities are spread across all parts.

Greater efforts are needed to clarify the relationship

between the CA, GP, NPA, NPMP and CMP.

Review periods for CMSs and NPMPs. Alternatively

CMS's could exclude national parks. Or make it clear that

the park is managed using the NPMP; future management

decisions would occur when the NPMP is reviewed, not via

the CMS process.

Would appreciate more clumping of activity-specific

information where possible.

Tourism Industry

336/3

Accept

New text has been added explaining the 'order' of

planning documents. Two new policies, which clarify

that NPMP's and CMP's continue to have effect and

have primacy until they are reviewed (with the review

being undertaken within the framework established

by the CMS), have been added to a new

Interpretation section in Part 1.

In most cases, this CMS refers to the FNPMP for the

management of FNP.

Part Three will be re-organised to group the relevant

policies with each sub-section for different activities.

Section: Relationship with other DOC strategic documents and tools (National Issue)

SOI is a short-term political, internal document for use

within DOC, not subject to public consultation, not a

genuine long-term vision for conservation within New

Zealand. CMS operates over a much longer time-frame.

To frame the CMS in terms of the current SOI will

hamper the actions of DOC in the future when a very

different SOI will be in place.

Modify the CMS such that it focuses on being a strategy

for conservation as defined in the Conservation Act.

Remove references to the SOI.

HR [SOI is written to satisfy the Public Finance Act,

changes the CA requirements. CA doesn't refer to enabling

tourism.]

Chris Shaw

175/2

Reject

The SOI has set DOC's priorities for 2013- 2017,

therefore it is appropriate for the CMS to be aligned

with this document. Section 1.5 uses the SOI

outcomes as headings. The content under each

heading meets DOC's statutory responsibility under

the CA87.

Supports the direction towards integrated management

for the case-by-case consideration of proposals for

minerals exploration and mining.

Supports reference to the SoI, in particular, Intermediate

Outcome 5. This is not reflected in the objectives listed

on page 37.

Include an Objective on page 37 to reflect Intermediate

Outcome 5.

Straterra Natural

Resources of New

Zealand

271/3

Accept in part

Section 1.5.5 addresses Intermediate Outcome 5.

Specific policies relating to minerals exploration and

mining are set out in Part Three and some Part Two

Places.

As a place-based document, to say that a site will be

managed as, say, an "Icon Destination", provides no

'reason' for why this site has been chosen.

The CMS should describe the site and its special qualities

and then, at some later stage, DOC could decide to manage

it as an Icon Destination in its own planning toolkit.

New Zealand Alpine

Club

284/4

Accept in part

The text has been revised to clarify this. Refer to the

DM common issues report.

Supports the continued use of the recreational

opportunity spectrum.

References to the "visitor management spectrum" should be

removed, in favour of the existing term.

New Zealand Alpine

Club

284/7

Reject

The text has been revised to clarify the relationship

between ROS and VMZ. Refer to the DM common

issues report.

SIEIA has been led to believe that the Threat

Classification System is not a management tool. It is

merely a prioritisation system for DOC internal resource

allocation.

It should not appear in planning documents of this nature.

HR [TCS not a planning tool, not science-based. Should

rely on ecosystem enhancement rather than species.]

South Island Eel

Industry Association

Inc

286/10

Reject

The Threat Classification System relies on scientific

papers and analysis to determine species' threat

rankings.

Refer to the NHMS common issues report.

Last para, 2nd sentence. Oppose the use of the word

'guide'. Needs to more clearly reflect the 'direction'

provided by CGP Section 13 re purpose of CMS "to

Reword "CMSs integrate the Dep

draft southland murihiku conservation management strategy: … · 2018-05-25 · definition of...

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