Download SUBMISSION on the

Royal Forest and Bird Protection Society NZ Inc
Contact: Nick Beveridge Ph. 302 3901
[email protected]
15 March, 2013
SUBMISSION
on the
DRAFT AUCKLAND CONSERVATION MANAGEMENT STRATEGY
2014 - 2024
by the Royal Forest and Bird Protection Society of
New Zealand Inc (Forest and Bird).
Table of Contents
INTRODUCTION ................................................................................................................... 3
Structure of this submission ................................................................................................ 3
Structure of the CMSes ....................................................................................................... 3
Formatting ........................................................................................................................... 3
Index and References .......................................................................................................... 4
LEGISLATIVE AND POLICY RESPONSIBILITIES OF THE DEPARTMENT OF CONSERVATION4
Conservation Act ................................................................................................................. 4
Wildlife Act .......................................................................................................................... 4
Integrated Conservation Management ............................................................................... 5
Conservation General Policy 2005 ...................................................................................... 5
Consistency with General Policy ......................................................................................... 5
Use of Words Will, Shall or May .......................................................................................... 6
Purpose................................................................................................................................ 6
Relationship with Other DoC Strategies .............................................................................. 6
Legislative Tools .................................................................................................................. 8
International ObligatIons .................................................................................................... 8
Treaty of Waitangi ............................................................................................................... 8
OBJECTIVES.........................................................................................................................9
Outcomes ............................................................................................................................ 9
Milestones ......................................................................................................................... 10
Forest and Bird Submission – Draft Northland Conservation Management Strategy
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CONSERVATION OF NATURAL RESOURCES……………………………………………………………….…10
Reclassification of Land ..................................................................................................... 13
Freshwater......................................................................................................................... 13
Biodiversity Threats ........................................................................................................... 14
Fire ..................................................................................................................................... 15
Biosecurity ......................................................................................................................... 15
Climate Change.................................................................................................................. 15
MARINE ............................................................................................................................. 17
Marine Reserves ................................................................................................................ 17
Marine Mammals………………………………………………………………………………………………………….18
Marine Farming ................................................................................................................. 19
LANDSCAPES AND SIGNIFICANT GEOLOGICAL FEATURES AND LANDFORMS ................ 19
Ecosystem Services............................................................................................................ 20
STATUTORY ADVOCACY ................................................................................................... 20
PEOPLES BENEFIT AND ENJOYMENT ................................................................................ 22
Vehicles.............................................................................................................................. 25
Aircraft ............................................................................................................................... 26
Hunting .............................................................................................................................. 28
Dogs ................................................................................................................................... 29
Other Animals.................................................................................................................... 29
Sports Fish and Game Birds ............................................................................................... 29
USE OF CONSERVATION LAND - AUTHORISATIONS ........................................................ 29
Private Accommodation .................................................................................................... 30
Sand and Shingle ............................................................................................................... 30
Collection of Materials ...................................................................................................... 30
Filming ............................................................................................................................... 30
APPENDICES ...................................................................................................................... 30
MAPS ................................................................................................................................. 31
SECTION TWO - AUCKLAND SPECIFIC ............................................................................... 32
Forest and Bird Submission – Draft Northland Conservation Management Strategy
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Introduction
The following submission is made on behalf of the Royal Forest & Bird Protection Society
Incorporated (the Society), including Forest and Bird branches within the Auckland
Conservancy Area.
Forest and Bird was founded in 1923 and is New Zealand’s leading volunteer
conservation organisation. Forest and Bird has around 70,000 members and supporters
nationwide. Forest and Bird’s purpose is “To take all reasonable steps…for the
preservation and protection of the indigenous flora and fauna and natural features of
New Zealand, for the benefit of the public including future generations.”
The Society is very pleased that the first of the new CMSes have finally been notified, and
has found it useful, although testing of resources, that three have been released
together, as this has enabled an assessment of slightly different provisions.
Structure of this submission
This submission first addresses generic issues that apply to all Conservation
Management Strategies, with reference to the Auckland CMS, and discusses some of the
key legislative responsibilities of the Department and relates them to broad areas of
subject matter e.g. indigenous biodiversity, visitors and commercial uses. This material
includes the contents of parts 1 and 3.
The submission then discusses the detailed content of the Auckland CMS including the
Places which are addressed at the end of the submission.
Structure of the CMSes
The structure of having broad objectives only in Part 1 and policies in parts 2 and 3
makes it difficult to follow a logic of issue-objective-policy and becomes repetitive of
subject matter e.g. biodiversity, people’s enjoyment and use of conservation resources
are mixed up in Part 3. Topics such as fire, biosecurity generally and climate change
should all be specifically addressed. Under the current structure, they would be placed in
Part 3 but for the purposes of this submission, they are discussed under the headings of
Conservation of Natural Resources, People’s Enjoyment and Use of Conservation
Resources (see below) are also addressed.
Where the structure and policies in different CMSes are identical, they should be
numbered that way e.g. Appendices. Key recreation destinations are Appendix 10
in Auckland and Northland but in Waikato it is Appendix 12. Where a conservancy has
specific appendices e.g. Hauraki Gulf Act, Treaty Settlements, these appendices should
follow the common appendices.
Formatting
All sections of the CMSes should be enumerated e.g the Objectives in Chapter 1 should
be headed 1.4 Objectives, 1.5 Objectives etc. Each Objective should also be numbered to
avoid the laborious counting of bullet points.
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Each section should also be numbered e.g 1.5.1 The diversity of our natural heritage is
maintained and restored.
Decision Sought
Enumerate all sections of the CMS.
Index and References
The Society is surprised that there is no indexing, references or bibliography for any of
the notified CMSes. This is a serious omission which makes these documents less useful,
especially as issues are addressed in numerous Place sections, as well as general ones.
Since their inception, CMSes have been an important reference document in all regions.
The inclusion of national priority approaches without reference to any background
papers is also disturbing.
Decision Sought
Include an Index and References
LEGISLATIVE AND POLICY RESPONSIBILITIES OF THE DEPARTMENT OF CONSERVATION
Conservation Act
“Conservation” is defined as “the preservation and protection of natural and historic
resources for the purpose of maintaining their intrinsic values, providing for their
appreciation and recreational enjoyment by the public, and safeguarding the options of
future generations (section 2, Conservation Act 1987).
Functions of the Department in Section 6 of the Conservation Act 1987 (the Act) are:
(a) To manage for conservation purposes, all land, and all other natural and historic
resources1, for the time being held under this Act, and all other land and natural and
historic resources whose owner agrees with the Minister that they should be managed by
the Department:
(ab) To preserve so far as is practicable all indigenous freshwater fisheries, and protect
recreational freshwater fisheries and freshwater fish habitats:
(b) To advocate the conservation of natural and historic resources generally:
(e) To the extent that the use of any natural or historic resource for recreation or tourism
is not inconsistent with its conservation, to foster the use of natural and historic
resources for recreation, and to allow their use for tourism:
Wildlife Act
Section 3 Wildlife to be protected states:
“Subject to the provisions of this Act, all wildlife is hereby declared to be subject to this
Act and (except in the case of wildlife for the time being specified in Schedule 1, Schedule
2, Schedule 3, Schedule 4, or Schedule 5 hereto) to be absolutely protected throughout
New Zealand and New Zealand fisheries water”.
1
The author has made text on this page bold and underlined for emphasis
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The Society considers that currently parts of the draft CMS do not meet some of these
legislative and policy responsibilities. Some parts of the CMS seem to have overlooked
the primary purpose of the Department to conserve indigenous species and habitats on
public conservation lands and waters. The Department’s functions do not include
promoting economic growth.
Integrated Conservation Management
The purpose of a CMS is to implement General Policies and achieve integrated
management.
Section17 D of the Act states:
“the purpose of a conservation management strategy is to implement general policies
and establish objectives for the integrated management of natural and historic
resources, including any species, managed by the Department under the Wildlife Act
1953, the Marine Reserves Act 1971, the Reserves Act 1977, the Wild Animal Control Act
1977, the Marine Mammals Protection Act 1978, the National Parks Act 1980, the New
Zealand Walkways Act 1990, the Hauraki Gulf Marine Park Act 2000 or this Act, or any of
them, and for recreation, tourism, and other conservation purposes”.
Conservation General Policy 2005
Section 13 (a) of Conservation General Policy 2005 states:
“ Conservation management strategies and plans should include identification of:
i. natural resources, historical and cultural heritage, and recreational opportunities, at
specific places on land and water;
ii. planned outcomes, objectives and policies for specific places2, consistent with the
purposes for which the public conservation lands and waters are held;
iii. potential conflicts between planned outcomes at specific places and explanation of
how these will be resolved;
iv. the adverse effects (including cumulative effects) of different uses and explanation
of how these effects will be minimised; and
v. objectives for departmental advocacy relating to conservation outside public
conservation lands and waters; and should also have regard to:
vi. relevant territorial authority statutory planning documents; and
vii. integrated management of places to achieve national conservation outcomes, and to
coordinate planning between places covered by other conservation management
strategies and plans”.
Consistency with General Policy
There are many areas where the draft CMS does not comply with General Policy which
are detailed in this submission including statutory advocacy, fire, landscapes, ecosystem
services, vehicles and many other areas.
Of particular concern are:
13(a) (iii) potential conflicts between outcomes at specific places and an explanation of
how these will be resolved, especially in relation to disturbance of threatened shorebirds
by people, vehicles and dogs.
2
The author has made text on this page bold and underlined for emphasis
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13(a) (iv) adverse effects (including cumulative effects) of different uses and explanation
of how these effects will be minimised, both of which are specific to Places but also
applies particularly to aircraft.
Use of the words ‘will’, ‘should’ and ‘may’
Inclusion of the following descriptor of the words “will”, “should” and “may”, found on
p14 of the CGP, should be included in the CMS as otherwise the reasoning behind the
choice of verb is likely to confuse. They read as follows:
The words ‘will’, ‘should’ and ‘may’ have the following meanings:
i. Policies where legislation provides no discretion for decision making or a deliberate
decision has been made by the Minister to direct decision-makers, state that a particular
action or actions ‘will’ be undertaken.
ii. Policies that carry with them a strong expectation of outcome without diminishing the
constitutional role of the Minister and other decision-makers, state that a particular
action or actions ‘should’ be undertaken.
iii. Policies intended to allow flexibility in decision-making, state that a particular action
or actions ‘may’ be undertaken.
Decision Sought
Include the aforementioned descriptor in the CMS.
Purpose of the CMS
This section should make explicit:
 the role of the Conservation Board and the New Zealand Conservation Authority in
approving the draft CMS.

the role of the CMS in guiding management actions as well as decision-making.
Decisions Sought
Amend the 4th bullet on p4 to read ‘Policies describe the course of action or guiding
principles to be used for conservation management and decision-making”.
On p4 following the sentence “Each CMS is prepared…” insert a description of the role of
Conservation Boards including monitoring of the CMS and the role of the New Zealand
Conservation Authority as decision-maker in approving the CMS.
Relationship with other Department of Conservation strategic documents and tools
The CMS has been closely shaped around the Statement of Intent 2012-17 (SOI).
There are several problems with this approach:
 The SOI has only a 5 year life span and could very quickly become out of date. A CMS
is supposed to have a life of ten years, but recent history has resulted in documents
being extended for many more years and there is no reason to assume this will not
change in future.
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
The SOI is politically driven. Not all of the SOI is supported in conservation
legislation, specially the Intermediate Outcome:
“More business opportunities delivering increased economic prosperity and
conservation gain” has no mandate in legislation despite its political popularity.
There is some legislative support for business involvement in conservation under the
Outcome “More people engage with conservation and value its benefits.”

There is no mention of the link between the outcomes in Section 1.5 and the SOI.
The draft CMS includes a policy “To increase net revenue flows available for achieving
conservation”. This policy should be deleted. The draft CMS also includes text about the
industries in their regions, some of which is entirely irrelevant and inappropriate.
This section of the CMS should focus on s 6(e) of the Conservation Act “To the extent
that use of any natural or historic resource for recreation or tourism is not inconsistent
with conservation, to foster the use of natural and historic resources for recreation and
to allow their use for tourism”. “More business opportunities delivering increased
economic prosperity and conservation gain” should be deleted and replaced with “Visitor
industry and other commercial uses” or similar and new policies that require
conservation gains to be an outcome of any commercial use.
Decisions Sought
Delete the Intermediate Outcome:
“More business opportunities delivering increased economic prosperity and conservation
gain”.
Delete policies that relate to national departmental processes or revenue gathering such
as Policy 1.5.5.6 “Continue to work with other relevant agencies to streamline and
seeking efficiencies in statutory processes”.
Reconfigure the section based on “More business opportunities delivering increased
economic prosperity and conservation gain” which has no legislative mandate, to be
oriented instead to implications of business activities on public conservation land such as
ensuring positive conservation outcomes and appropriate activities consistent with
General Policy.
Remove excessive and irrelevant text relating to the regional economies e.g.
Auckland is the major economic centre of New Zealand and there is significant potential
to increase the level of engagement and investment by business in conservation in
Auckland. The Department will seek to identify and promote new business opportunities
and partnerships that deliver conservation gains.
The significance of the world class Hauraki Gulf Marine Park is recognised in the Auckland
Visitor Plan13 as one of the key opportunities to increase visitors, including the
sustainable development of Gulf island tourism.
The potential to engage in conservation partnerships increasingly makes sense for
business, as it can significantly improve business worth, value and brand/reputation,
while helping to conserve natural and cultural heritage values.
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Legislative Tools - Closure of Areas
Use of these tools is supported. However for avoidance of doubt, the section on p6
should be cross-referenced to an operative provision which implements it.
Decision Sought
Cross-reference the section on p6 to the Policy 3.1.4
International obligations
There should be an explanation either in this section or the relevant Place (2.15) of any
international commitments including RAMSAR and how they are being met to achieve
Integrated management.
1.4 Treaty of Waitangi
It is acknowledged that this section will be strongly influenced by the nature of Treaty
Settlements, but some generic statements should be consistent e.g. for Auckland it is
stated: “The Department will provide for iwi involvement in kaitiakitanga irrespective of
whether they have settled their grievances or not.” Such intentions should be nationally
consistent.
Objective 1.4 Bullet 8 should be qualified similarly to 1.4 Bullets 4 and 6 i.e. consistent
with legislation, purpose for which the land is held, General Policy and Treaty
Settlements.
Decisions Sought
Standardise nationally the general text in Section 1.4.
Include an overview of the mechanisms that will be operating in the conservancy
Update the text prior to publication to include any settlement made in the intervening
submissions and deliberation process.
Amend 1.4 Bullet 8 to read
“Work with tangata whenua to establish formal protocols to enable the customary use of
traditional materials and indigenous species consistent with kaitiakitanga, the relevant
legislation including Treaty Settlements, regulations, general policies and the purposes
for which the land is held”.
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1.5 OBJECTIVES
The vague ‘Contribute to’ nature of these objectives is opposed. The CMS should say what
the Department is going to do. Whilst it is acknowledged that the Department’s powers to
protect features on private land is limited to advocacy, this should at least be stated in an
objective.
It is also noted that the draft CMS contains additional objectives relating to integrated
management, advocacy, maintaining the pest-free status of islands and to progress
amendments to land classification.
Decisions Sought
Remove the phrase ‘Contribute to’ from all objectives and rephrase to indicate
Departmental action e.g.
1.5.1.1 Manage the priority ecosystems and sites in Appendices 2, 3 and 4 on public
conservation land using an integrated conservation management approach and actively
managing threats, to achieve a healthy functioning state.
1.5.x.x Advocate for, and work with the land owners and community, to protect and restore
the ecosystems listed in Appendix 2 which are not on public conservation land.
1.5.1.2 As a priority, apply resources to the greatest extent possible to ensure the
persistence of the threatened species listed in Appendix 6.
1.5.2.5 Reword Policy 1.5.1.5 “Seek a nationally representative network of marine protected
areas, through the implementation of local or regional marine forums focussed on the
marine ecosystems listed in Appendix 8”. (see discussion below on marine reserves).
Include an objective to re classify any stewardship land where priority habitats or threatened
species are found.
Include objectives for ecosystem services and freshwater, including advocacy.
1.5.3 More people participate in recreation
See People’s Benefit and Enjoyment below p22.
Outcomes
Some of the Outcomes include material that is merely descriptive of values and repetitive of
the introductory text. It is acknowledged that writing Outcomes is easier said than done but
care should be taken to avoid describing threatened species as outcomes when the outcome
is to reduce the level of threat.
Section 1.5 Auckland Conservancy by 2024 is an overall Outcome for the whole conservancy:
‘The key organisational outcomes to be delivered by management of conservation resources
within the Auckland Conservancy over the next 10 years’ (p19).
Contrary to the first paragraph, the maps do not show “how Auckland Conservancy’s key
conservation outcomes fit into the jigsaw of priority ecosystem and recreation outcomes’
(p21). What the maps show are the national priorities in the conservancy.
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There needs to be some clarification as to whether Section 1.5. is about Outcomes, or
Objectives, especially as Outcomes now has a particular statutory meaning in terms of CGP.
Are the Outcomes referred to just the Intermediate Outcomes from the SOI? Or should the
text beneath these, detail each outcome? As the distinctive features etc have already been
set out in Section 1.3, the Society’s view is that Section 1.5. should be written as Outcomes.
Decisions Sought
Amend Heading of 1.5 to Auckland Conservancy Outcomes by 2014
Clarify what is an Outcome for statutory purposes in Section 1.5 and rewrite all sub-sections
in an outcome statement format.
Amend the sentence beginning the maps in Volume II’ to state that it shows the national
priorities in the conservancy.
Milestones
CGP Policy 13 (f) states that CMSes should include major milestones towards planned
outcomes. Milestones should be specific, measureable, realistic and time-bound. Many of
the milestones are vague and limited to merely reporting.
The Introduction to Part 2 – Places states that “Milestones are special events that are
measureable steps towards achieving the outcome statement” (p31). The word “special”
(meaning unusual or better, held in esteem, reserved, reserved for a specific purpose, or not
part of the usual programme/menu, or a reduced price) is not appropriate in this context.
A disturbing number of milestones are “Report on…” such and such. The Society expects to
see milestones that are actions contributing towards meeting the Objectives or Outcomes
e.g. for Objective 1.4.8. an appropriate milestone would be ‘Protocols established with
tangata whenua on customary use of materials’ etc.
Decisions Sought
Review all Milestones to ensure they are action- related.
Delete the words “special events” from the Milestone descriptor in Part Two. Reword as:
“Milestones are actions that are measureable steps towards achieving the outcome
statement”.
Ensure CMS includes milestones for Objectives in Part One.
CONSERVATION OF NATURAL RESOURCES
Lack of detail relating to management of indigenous biodiversity
CGP Policy 4.1 (a) Each conservation management strategy and plan should include
identification of:
i. indigenous species and their habitats and ecosystems;
ii. recreational freshwater fisheries and freshwater fish habitats; and
iii. game birds and, on public conservation lands and waters, their habitats.
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4.1(a) is partially fulfilled by Appendix 6 Flora and fauna present, although the appendix is
restricted to threatened species. However (ii) is limited to 1 sentence on p11, and a broad
summary on p13, neither of which give any reference to native fish populations and their
management requirements. The CMS is also silent on CGP Policy 4.1 (f) and (g) which relate
to whitebait fishing and management.3
CGP Policy 4.1 (b) refers to the establishment of “management objectives for indigenous
species and their habitats and ecosystems and recreational freshwater fisheries and their
habitats, consistent with planned outcomes at places” to prevent loss and maintain
representative examples, recovery of species, restoration of threatened ecosystems and
maintenance of the ecological integrity of ecosystems. Apart from the Appendices of Key
Ecosystems and Habitats and Priority Ecosystems and Sites, there is little or no detail about
what the conservation objectives actually are, or actions to be taken to achieve them.
The threats to the freshwater and terrestrial ecosystems are not identified. This is a crucial
step in identifying and prioritising conservation actions. These threats include change in land
use, poor land management practices (particularly the intensification of farming, quarry
development and logging), sediment derived from accelerated erosion, drainage, water
reticulation and supply, barriers to fish migration, pest plant encroachment (potential
dydimo invasion), pest fish (particularly koi carp, rudd, tench and catfish), grazing,
development, predators and climate change. These threats need to be included.
Objectives are phrased as “Contribute to...” various outcomes without actually specifying
what the department will do. Priority areas are often left to community initiatives and not
DoC-lead. All priority areas (as identified in Appendices) should be DoC-led with local groups
only relied upon to do lower priority projects.
Various Milestones refer to “Conservation actions have been initiated at priority ecosystem
sites at XYZ”. These conservation actions need to be made available (preferably included as
appendices) and open to public scrutiny and submission.
The Society presumes that this detail must exist as part of the NHMS4, but its exclusion from
Conservation General Policy (CGP) the CMS means that the document lacks transparency
and accountability.
Forest and Bird is currently identifying Important Bird Area sites for seabirds in NZ under the
BirdLife International Global IBA programme (Forest and Bird is BirdLife’s NZ partner). The
process is similar to Ramsar sites identification and uses internationally accepted criteria. In
the northern NZ region a number of sites will be identified – in the Kermadecs, Three Kings,
the wider Hauraki Gulf region and on Auckland’s west coast. The CMS should at least
recognise that this process is underway even though the IBA seabirds report will not be
published until later in the year Attached is a list of sites for northern New Zealand. Marine
areas will also be identified under this programme.
3
See submissions below on Freshwater and on Part 3 of the CMS regarding eels and game birds.
Variously referred to as Natural Heritage Management’ and Natural Heritage System’ – see submission below
on Definitions).
4
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The other report that is useful for the CMS will be the Hauraki Gulf Seabird Strategic Plan –
to be published soon by the Hauraki Gulf Forum. This has a number of recommendations
relating to islands/island groups in all three conservancies for which Drafts have been
notified..
Hauraki Gulf Important Bird Area (IBA) Programme
BirdLife International’s Important Bird Area (IBA) programme has for more than 30 years
been successful at setting priorities and focusing conservation action on land and is now
being adapted and extended to the marine environment. It is a global programme with over
11,000 IBA identified worldwide. In New Zealand, BirdLife International, through its New
Zealand partner the Royal Forest and Bird Society of NZ (in association with the
Ornithological Society of NZ), is identifying IBAs for seabirds. This is the first stage of a
programme that will extend to encompass New Zealand’s precious land-, shore- and waterbirds.
IBA for seabirds are those areas recognised for regular high use using a standardised set of
data-driven criteria and thresholds, ensuring the approach can be used consistently
worldwide. Essentially, most of the Hauraki Gulf is to be identified on this basis and given the
complexity of our marine environment and number of species to consider Hauraki Gulf and
other New Zealand IBAs for seabirds will develop from a mosaic of ‘layers’, with each ‘layer’
representing breeding and the high regular use of foraging areas of a particular or distinctive
grouping of species. Thus candidate Marine IBAs are being identified on the basis of their
‘distinctiveness’, a combination of the suite of ‘trigger’ species, whether birds are sedentary
or disperse during non-breeding periods, oceanography, marine habitats, as well as fisheries
interactions (by-catch) and other threat issues. These threats can vary from area to area, e.g.
habitat depletion, shipping volumes and marine/seabed exploration.
As described above seabirds are rebounding in the Wider Hauraki Gulf Region. Considerable
investment in eradications is paying off, and IBA status can reflect significant and sizeable
populations. However, IBAs are also designed to put the spotlight on those sites that are
important to the survival of threatened species. The Hauraki Gulf, like New Zealand with its
suite of threatened species, registers strongly on that count. IBAs are a conservation tool,
and through monitoring and community participation, will provide a measure of how well
we are protecting these important sites, and because they use global criteria, they are a
check on how well we’re doing internationally.
Decisions Sought
Include text identifying biodiversity threats.
Include management objectives and actions consistent with CGP Policy 4.1 (b). This should
be by way of an amendment to the Draft CMS and re-notified to enable informed public
submission.
Re-write the Objectives to clarify the Department’s actions e.g.
1.5.1.1 To protect and restore indigenous ecosystems on public conservation lands and
waters to a healthy functioning state, focusing on the priority ecosystem sites listed in
Appendices 2, 3 and 4.
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1.5.1.2 To give priority to ensuring the persistence of nationally threatened species, as listed
in Appendix 6.
Include an objective To protect the marine species and populations for which the
Department is responsible to achieve the recovery of those that are threatened of that have
been depleted or other adversely affected by human activities and / or invasive species or
pests.
1.5.1.5 To seek a nationally representative network of terrestrial and marine protected
areas, including marine reserves, taking into account the ecosystems listed in Appendix 2, 4
and 8, through implementation of regional marine forums.
Include an objective ‘To advocate, through statutory processes, for the legal protection of
terrestrial and freshwater ecosystems, habitats and species both within and outside
conservation land’ either here, or in a new Statutory Advocacy section.
To advocate the conservation of natural and historic resources generally
Amend the CMS so that conservation actions for all priority sites are DoC-led.
Include text and policies on Important Bird Areas, either in Section 1.5.1 or in a Hauraki Gulf
Place. Include an Outcome that seabirds have better protection and become much more
conspicuous because their breeding and feeding areas are better managed.
Re-write the Milestones to be more action-specific.
Reclassification of Land
FRESHWATER
s 6 (ab) of the Conservation Act is “To preserve so far as is practicable all indigenous
freshwater fisheries, and protect recreational freshwater fisheries and freshwater fish
habitats” and the department is also responsible for implementing the fish passage and
other responsibilities under the Freshwater Fisheries Regulations 1983, yet the CMS lacks
comprehensive provisions to achieve these functions.
Auckland doesn’t seem to place much priority on Freshwater conservation although some
priority sites include wetlands and Appendix 2 p157 includes wetlands as a Key ecosystem
and habitat. Management response at these sites includes:
“Plant and animal pest control, biosecurity surveillance and management, and advocacy and
consultation.”
Auckland has no general objectives or policies for freshwater except for 3.131 “Work with
the Northland and Auckland/Waikato Fish and Game Council on the management of sports
fisheries and game birds”.
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Decisions Sought
Add to text:
Threats to freshwater / wetland ecosystems include poor water quality, change in land use,
poor land management practises (particularly the intensification of farming), drainage, water
reticulation and supply, pest plant encroachment, pest fish, grazing, development and
predators”.
Provide more comprehensive provisions for freshwater conservation to implement s6 (ab) of
the Conservation Act and the fish passage and other responsibilities under the Freshwater
Fisheries Regulations 1983, including more information and policy direction for the
management of whitebait species e.g. Will work with other organisations and landowners to
protect the pathways of indigenous migratory freshwater fish (primarily whitebait and eels)
species and ensure sports fishing doesn’t adversely impact these species.
Include an Action Plan as a milestone by Year 3 to implement these provisions.
Include Waikato Policy 2.2.2 (d) in the Auckland CMS.
Biodiversity Threats
CGP Policy 4.2 requires the identification and prioritisation of threats posed by pests. This
seems to take the form of Appendix 5.
Auckland does not seem to have an equivalent Objective to Northland (1.5.1.7 Collaborate
with agencies and communities to prevent the establishment and spread of the plant,
animal and invertebrate pests listed in Appendix 5) and even Little Barrier Place has no
reference to weeds or pests in its policies. Waikato has a more comprehensive and
acceptable approach:
1.5.1.11 Control pest plants and animals (identified in Appendix 6) to improve the quality
and functioning of the ecosystems identified in Part Two—Places of this CMS, and the
ecosystems and habitats outside those Places identified in Appendices 3–5, and to protect
significant populations of indigenous species at the highest risk of loss within Waikato
Conservancy.
However there is little detail of what the Department will do.
Decisions Sought
Ensure the Appendix of Pests is linked to an effective provision using Objective 1.5.1.11 in
the Draft Waikato CMS as a model.
Provide more detail in the Place section on Pest actions.
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Fire
There is no general mention of fire management. Fire is an issue that should be generally
addressed in the CMS, preferably in Part 3.
Decision Sought
Either include a policy similar to 2.2.10 in the Ahipara Place in Northland, "2.2.10 Continue
to actively engage with the community to reduce local fire risk and implement reduction
measures wherever necessary, particularly a... " or otherwise include as a general policy in
Part 3.
Biosecurity
Northland CMS includes the following Policy (and in all other similar Place policies:
2.1.13 Promote biosecurity measures to minimise the threat of PTA (kauri dieback disease)
to the forests.
However “Promote” is not enough. The Department should have a plan and implement it. All
forests on public conservation land where kauri is present, especially close to tracks, should
have signs and footwear cleanser at track entrances. Some tracks may need to be closed,
subject to monitoring.
Decision Sought
Add a policy:
Implement and update as required a biosecurity plan to minimise the threat of PTA (kauri
dieback disease) to forests where kauri is present with priority given to areas with public
tracks. Measure to include provision of sanitiser and track closure where necessary.
Climate Change
There is limited reference to climate change and no policy.
CGP 4.1 (b) (see under Biodiversity above) requires objectives for the prevention of loss and
maintenance of representative examples of the full range of species, habitats and
ecosystems. 4.2 (a) requires identification and prioritisation of threats by pests. Climate
change is a fundamental threat to be considered under both policies.
The following statement should be included in the CMS:
“Likely climate change impacts as pertaining to Public Conservation Land
Climate change represents the single biggest threat to the survival of New Zealand’s
indigenous flora and fauna.
There are six key aspects to this.
1. Changing conditions in habitats that host flora and fauna that are unique to those
areas, making them inhospitable to their endemic dependents.
2. Increased populations of existing introduced predator and pest species.
3. New species of introduced pest species being able to establish because of
changed climatic conditions
4. The direct effects of extreme weather.
5. Sea level rise.
6. The role the conservation estate can play in carbon sequestration
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As New Zealand’s temperatures rise and climatic patterns around the country change, the
nature of our plant and animal habitats is changing. Alpine areas are becoming more akin to
lower altitude environments; conditions in southern areas are starting to become more like
those in the north; and many lowland areas are becoming drier than they have ever been
before.
For those native plants and animals that exist only in small, specific parts of the country
(whether that be because they have evolved according to the unique conditions found there,
or because much of their preferred habitat has been lost to development), these changes
are likely to result in extinction, particularly if those habitats are cut off from any similar
areas by human activity.
Warmer temperatures are likely to upset the breeding cycles of other endangered animals,
such as tuatara - the gender of tuatara hatchlings is determined by the average soil
temperature that the eggs experience while they develop. The higher that average
temperature the less females that hatch.
Changing weather patterns can be expected to further disrupt the already heavily-modified
ecosystems that exist in the public conservation estate. For example, increased
summer/autumn temperatures are causing beech forests to seed more and more often. This
allows the populations of seed-eating predators to more regularly burgeon, which then in
turn will have major consequences for native trees, birds and insects.
Greater use of effective, integrated pest control over large parts of the conservation estate
not only protects vulnerable species against introduced predator plagues, but also allows the
vegetation in the conservation estate to sequester greater quantities of carbon. DOC should
considerably increase the resources it puts into the Predator-Free New Zealand concept.
Animals such as possums, deer and goats eat their way though huge amounts of carbon sinkforest every year; reducing this toll would also make an important contribution towards this
country’s part in fighting climate change.
The extreme weather events that are becoming increasingly common in New Zealand are
likely to threaten the survival of many of our indigenous plants and animals. This threat is
only likely to grow, as the extreme weather events continue to become more common. For
example prolonged dry spells and associated low freshwater levels can deprive endangered
species of food, and habitat. Prolonged dry conditions are known to make it impossible for
kiwi to drive their beaks into the soil as they hunt. Unseasonal high rainfall and resulting
floods can destroy the river bed habitat used by species such as wrybill to nest on.
The continued acidification of oceans will alter the characteristics of the food chain,
particularly for those organisms that produce calcium based shells or skeletons with
unknown consequences for the many animals that rely on those organisms, for food. The
rapid (in geological terms) rise of sea levels will likely see the reduction, modification or
elimination of many intertidal habitats. “
These threats should be identified, monitored for, and addressed where necessary.
Provisions for migration of ecosystems (especially coastal and marine – marine mammals)
should be considered in reserve design and acquisition and advocacy for a precautionary
approach and mitigation.
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Decision Sought
Include a more fulsome discussion of climate change and its effects on indigenous
biodiversity such as the statement above.
Identify the threats for the conservancy and monitoring that is required.
Advocate for a precautionary approach and mitigation where relevant.
Marine
The Marine provisions in the CMS need strengthening.
Marine Reserves
Conservation General Policy states:
4.4 (c) The establishment of marine reserves adjacent to public conservation lands and
waters will be considered where it is beneficial for conservation management.
4.4 (d) Marine reserves will be managed to be maintained or restored to a natural state as
far as possible.
4.4 (e) The Department should work with other agencies and interests to promote and
develop a marine protected areas network, including marine reserves, wildlife reserves,
sanctuaries and other protective mechanisms.
CMS Policy 1.5.1.5 “Contribute to building a nationally representative network of marine
protected areas, taking into account the marine ecosystems listed in Appendix 8”, is very
broad, and as mentioned above, doesn’t say what the Department will do.
The Society understands that the stock-take and gap analysis of the North-eastern Marine
Biogeographic region has been completed. Therefore the objective should incorporate
initiating regional marine forums. It is not acceptable that such an important conservation
function not be planned for in the next 10 years. All of the coastal Places should have marine
forums established with associated milestones.
The Outcomes for existing marine reserves should include the words from CGP “maintained
or restored to a natural state as far as possible”
Decisions Sought
Reword Policy 1.5.1.5 “Seek a nationally representative network of marine protected areas,
through the implementation of local or regional marine forums focussed on the marine
ecosystems listed in Appendix 8”.
Include Milestones relating to the marine forums (by Year 3) and the achievement of marine
protected areas (by Year 5).
Include the words from CGP “maintained or restored to a natural state as far as possible in
all Outcomes for existing marine reserves.
Amend aircraft policies to the effects that there should generally be no aircraft landings in or
adjacent to marine reserves except for management or research purposes.
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Marine mammals
There are 4 generic policies in the CMS:
3.12.1 Support research into and monitoring of the impacts of human interactions with
marine mammals.
Monitoring should be required, not just supported.
3.12.2 Take a precautionary approach to the number of commercial operators involved in
marine mammal operations, including seeking a moratorium on the issuing of new
permits if research and monitoring indicates that such a step is required.
3.12.3 Require commercial operators viewing marine mammals to provide a high
standard of education and interpretation.
3.12.4 Review at regular intervals, and implement, a marine mammal tourism site plan
for Auckland Conservancy, which sets out desired objectives for management of the
marine mammal tourism industry.
DOC Auckland should consider establishing a cost recovery system associated with the
management and protection of marine mammals within the Auckland Conservancy.
A cost recovery system such as this is “best practice” in terms of contemporary ecotourism.
Maui’s Dolphin Marine Mammal Sanctuary
A CMS should “establish objectives for the integrated management of natural and
historic resources, including any species, managed by the Department under the …
Marine Mammals Protection Act 1978…” (CA Section 17D).
Section 3A of the Marine Mammals Protection Act states:
“Department of Conservation to administer marine mammals and sanctuaries
The Department of Conservation shall administer and manage marine mammals and
marine mammal sanctuaries in accordance with—
Any statements of general policy approved under section 3B of this Act; and
Any conservation management strategy5 and any conservation management plan for
the time being in force for the area concerned”.
CGP Policy 4.4 (f) Marine protected species should be managed for their long-term
viability and recovery throughout their natural range.
This policy has not been implemented in relation to Maui’s dolphin.
Maui's dolphin is facing a very real threat of extinction unless there is immediate action to
remove ALL threats from their natural range. They simply won't survive otherwise.
Regardless of political considerations, to achieve CGP 4 (f) the Minister should be:
 addressing both fishing and non-fishing threats. There should be a total ban on the
key threats - all gill nets, trawling, seismic surveys and all forms of marine mining.
5
The author has made text on this page bold and underlined for emphasis
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
extending the existing sanctuary to include all dolphin habitat, i.e. 'natural range',
which science tells us is waters out to the 100m depth, or at a minimum to the 12nm
boundary, and including harbours.
Decisions Sought
Amend Policy 3.13.1 “Support research into and monitoring of the impacts of human
interactions with marine mammals” so that monitoring is required, not just supported.
DOC Auckland should consider establishing a cost recovery system associated with the
management and protection of marine mammals within the Auckland Conservancy with a
Year 3 milestone.
Include more factual information about threats facing Maui’s dolphin and the existing
Marine Mammal Sanctuary.
Include a policy to review the Threat Management Plan to
- address both fishing and non-fishing threats. There should be a total ban on the key threats
(all gill nets, trawling, seismic surveys and all forms of marine mining.)
- extend the existing sanctuary to include all dolphin habitat, i.e. 'natural range', which
science tells us is waters out to the 100m depth, or at a minimum to the 12nm boundary,
and including harbours.
These actions to be completed as soon as possible.
Marine Farming
The CMS is silent on marine farming. There is extensive marine aquaculture within the
Auckland Conservancy which has the potential to have effects on both seabirds and marine
mammals. Associated structures may also be vectors for the introduction of invasive marine
species.
There is also no subsection on marine threats such as climate change, sedimentation from
adjacent land, invasive marine species or pollution.
Decisions sought
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.
Include a policy to raise awareness about the values of the marine environment through
education programmes and the media.
LANDSCAPES AND SIGNIFICANT GEOLOGICAL FEATURES AND LANDFORMS
Because Part 1 is structured around the SOI and Part 3 is minimalist, some generic issues
have been overlooked including protection of landscapes on conservation land.
There is an Appendix 9, Significant Geological features and landscapes with the
Geopreservation sites but there is no policy linked to it. More context is required e.g.
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‘Auckland has many significant geological features and landscapes. Refer to Appendix 9 for
details’. To fully implement CGP, include Policy 4.5 (b):
“Activities which reduce the intrinsic values of landscape, landform and geological features
on public conservation lands and waters should be located and managed so that their
adverse effects are avoided or otherwise minimised.”
Waikato CMS has a policy in the Pureora Place that structures should be erected on the
skyline. This sort of policy could be generic.
Decisions Sought
Tie Appendix 9 to a policy in Part 3 to protect landscapes and geopreservation sites on pcl
and advocate for their protection elsewhere e.g. “Will advocate for the preservation of the
outstanding natural character and landscapes of the coastal environment to central
government agencies, local authorities, tängata whenua and the community”.
Include CGP Policy 4.5(b) in the CMS.
Include a policy to avoid structures on skylines or prominent features on pcl.
Ecosystem Services
Policy 1.5.5.2 is the only provision where ecosystem services are alluded to: “raise public
awareness that intact functioning ecosystems underpin New Zealand’s economy both
directly and indirectly.”
Considering the significant role of ecosystem services provided by public conservation
land, it is surprising that there is little or no explanatory text or more effective policies
promoting it, including consideration of both management activity and authorisations.
This should really be located in the section1.5.1 or Part 3.
Decisions Sought
Include a more fulsome discussion of ecosystem services.
Include policy 4.6 (a) of CGP :
Activities on public conservation lands and waters should be planned and managed in
ways which avoid or otherwise minimise adverse effects on the quality of ecosystem
services.
Statutory Advocacy
Section 7 of the CGP 2005 - Conservation Beyond Public Conservation Lands and Waters
states: “The Department should undertake statutory advocacy to protect natural
resources and historical and cultural heritage outside public conservation lands and
waters and for the benefit and enjoyment of the public”.
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Section 1 states that it will guide the department in advocacy. The only advocacy action
in Part 1 is:
Work with tangata whenua to advocate for the protection of mahinga kai, wāhi tapu and
other cultural resources located outside public conservation lands in accordance with
Treaty settlement outcomes (p21).
Appendix 2 includes advocacy and consultation for most ecosystem types “including
supporting legal protection of highest priority sites on private land”.
There are references to specific advocacy in several Places in Auckland CMS:
1.5.1.7 Advocate for a representative range of priority ecosystems sites off public
conservation lands and waters within the Auckland Conservancy”.
This should also say “to be protected”.
1.5.1.13 Advocate for integrated management between those agencies that have a
statutory role in the management of Kaipara and Manukau harbours and their
catchments (p21).
2.15.1 Advocate for a reduction in catchment-wide impacts on the Wetland [Firth of
Thames/Tikapa Moana Place] particularly with respect to:
(a) minimising sediment and nutrient inputs and
(b) protecting wildlife habitat, botanical values and hydrological processes.
2.15.2 Advocate for the prevention of aircraft activity…
2.15.3 Advocate for … the Muddy Feet Project… (p110)
Whilst these actions are all worthy, they do not implement Policies 7 (c) and (d) of CGP:
CGP 7 (c) The Department should undertake statutory advocacy to protect the values of
public conservation lands and waters where necessary.
7 (d) The Department should undertake statutory advocacy to protect natural resources
and historical and cultural heritage outside public conservation lands and waters and for
the benefit and enjoyment of the public, including public access, in particular where:
i. the resource or heritage is of international, national or regional significance; or
ii. indigenous terrestrial or aquatic species or recreational freshwater fisheries are
threatened with loss or decline; or
iii. significant marine or freshwater habitats and ecosystems are threatened with loss or
decline; or
iv. significant geological or geothermal features or landforms are at risk of permanent
degradation; or
v. activities taking place or proposed in places linked to public conservation lands and
waters could have adverse effects on them; or
vi. proposed activities are likely to cause further loss, degradation, or fragmentation of
significant places; or
vii. important linkages between significant places can be maintained or improved; or
viii. representativeness of the full range of indigenous habitats and ecosystems can be
maintained or improved; or
ix. natural character of the coastal environment and the margins of lakes and rivers
would be compromised; or
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x. recreational freshwater fisheries are threatened with loss or decline; or
xi. public walking access to rivers, lakes or the coast and to public conservation lands and
waters is inadequate.
In view of the statement in Section 1 mentioned above the CMS should make it clear that
these are specific additional areas of advocacy to those in CGP.
Decisions Sought
A more comprehensive and consistent approach to advocacy is required and should be
set out in Part 3 of the CMS.
The CMS should make it clear that the advocacy actions specified in the Places are
additional areas of advocacy to those in CGP.
PEOPLE’S BENEFIT AND ENJOYMENT
Priority to preserve and protect natural and historical resources
Section 6 (e) of the Conservation Act states:
The functions of the Department are…
(e) To the extent that the use of any natural or historic resource for recreation or tourism is
not inconsistent with its conservation, to foster the use of natural and historic resources for
recreation, and to allow their use for tourism:
This provides a clear hierarchy to the Department’s functions and responsibilities with
regard to the relationship between use of natural resources and their use for recreation and
tourism.
The protection and preservation of natural and historical resources has priority over
recreational enjoyment to the extent that recreation must not be ‘inconsistent’ with
protection and preservation of natural and historical resources, and similarly, recreation has
priority over the provision of tourism.
The Department’s hierarchy of responsibility is, therefore, to preserve and protect natural
and historical resources, followed by fostering recreational enjoyment followed by allowing
tourism, as long as the prime responsibility is not compromised in each case.
Within the text and the management objectives and policies of the draft CMS this
responsibility has been compromised. Nowhere in the text is there any mention of the fact
that not all recreation and tourism activities are appropriate on public conservation land.
Many of the management objectives and policies in the draft CMS reflect an approach which
is generally inconsistent with the intent of the Act. Many policies focus on recreation while
policies associated with actions required to preserve and protect of natural and historical
resources have been written that they could be interpreted to be of less importance. This is
particularly the case with Objectives 1.5.3.1:
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Understand and respond to demand for particular types of recreation and other forms of
participation when providing facilities and services.
and 1.5.3.5:
Provide visitors with the opportunity for a positive social, physical and learning experience
on public conservation lands.
The problem with a demand-driven approach is that this does not necessarily equate with
what is appropriate on protected lands.
The Auckland (1.5.3.6) CMS has an objective relating to conflicting uses. Such a provision is
necessary to begin to meet CGP 13(a) (iii) potential conflicts between outcomes at specific
places and an explanation of how these will be resolved, although this is not followed
through in other sections.
As discussed elsewhere the expectations that visitors will “accept” aircraft noise is not
acceptable and visitors to public conservation lands, part from tourist spots, should be able
to enjoy natural quiet.
Decisions Sought
Add after the last sentence of the introductory text in 1.5.3 the words “However not all
recreation and tourism activities are appropriate on public conservation land.”
Amend objective 1.5.3.1 to read
Understand and consider the demand for particular types of recreation and other forms of
participation when providing facilities and services where consistent with the status of the
land.
Amend Objective 1.5.3.2 to read “Prioritise the sites listed in Appendix 10 for provision and
management of visitor services.”
Delete 1.5.3.3 This is vague and meaningless.
Amend objective 1.5.3.5 to read
To provide and manage a range of recreation opportunities on public conservation lands and
waters in a way that facilitates public use, education and enjoyment and is not inconsistent
with the conservation and protection of natural, historical, cultural or recreational values,
including natural quiet and remoteness.
Include additional Objectives:
The Department will monitor the quality of the visitor experience and effects of visitor
activity for consistency with the conservation and protection of natural, historical, cultural or
recreational values, including natural quiet and remoteness.
Avoid, minimise and otherwise manage conflicts between different users, including people
undertaking different types of activities in the same location, in particular by:
a) providing guidance on appropriate shared-use etiquette;
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b) using one-way direction of travel or specified single-use tracks; and
c) placing seasonal restrictions on some activities.
The Visitor Management Zone Maps are very small scale and difficult to interpret,
precluding the ability to make a coherent submission on detail, especially the boundary
between front and back country and how the Destination Management Framework is
integrated with ROS. (There is a similar problem with the Aircraft Access Zones). Inadequate
maps mean that zone boundaries cannot be identified for purposes of submission or
decision-making (legally the published maps are the basis for decisions). These should be renotified to allow for informed submissions.
Appendix 11 Prescriptions for Visitor Management Zones sets out the ROS classes much as
we know it. There are two problems with the Back Country descriptions:
(i) The way the Accessibility by vehicle, boat or aircraft is expressed is somewhat confusing
In the third bullet point the word “generally” should be deleted to read “motorised ground
access restricted to designated tracks”.
(ii) The Desired Visitor Experience states that the Back Country visitor is “generally accepting
of occasional intrusion of noise”. This is not accepted. Note that even the SOI states “People
seeking to hunt, tramp and wander on public conservation lands even where there are few
or no facilities. People seeking challenge and adventure in the backcountry—‘nature on
nature’s terms’.”
The Prescription for management of effects of concessions in Front Country excludes the
requirement to “remedy” as in avoid, remedy or mitigate”. This is inappropriate in a
conservation setting and the full range of management options should be available.
Local Treasures (Appendix 10)
Many of these places are on main roads and are destinations for visitors or of national
significance e.g.Miranda wildlife viewpoint, Tititiri. One is just a carpark (Mt Auckland).
‘Conforming’ activities
DoC has schedules of ‘conforming’ recreational concessions i.e. lists of tracks and party size.
Applications for concessions for these activities are fast-tracked. There is no reference to
these in the CMS and there should be.
Decisions Sought
In Appendix 11, Amend the Back Country descriptions:
Accessibility
Clarify in the second bullet that ‘Back Country Accessible’ applies to areas reached by
existing authorised gravel or 4WD roads, by boat or via designated aircraft landing sites.
In the third bullet point delete the word “generally” to read “motorised ground access
restricted to designated tracks”.
Amend (ii) The Desired Visitor Experience to read ‘Absence of built environment and
commercial enterprises (e.g. shops, cafes etc) apart from basic facilities (toilets, shelters).
Sounds of nature predominate.’
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Amend the Front Country Prescription for management to include “avoid, remedy or
mitigate”…
Include reference to ‘Conforming’ activities and include as schedules.
VEHICLES
Vehicles and transport systems can affect natural quiet, enjoyment of other users; have
direct impacts on ecosystems and wildlife, and can be a vector to spread weeds or pests e.g.
Didymo. There is no obligation to allow vehicle use but it may be provided to foster
recreation subject to protecting conservation values (and the costs of maintenance being
achievable). The CMS should include policies for advocacy for protection of areas outside
pcl.
CGP6 requires vehicles and transport use to be compatible with the statutory purposes for
which the place is held, or be necessary to enable the Department to perform its functions.
CMSes have to identify where the use of specified types of vehicles and other forms of
transport may be allowed and establish any conditions for use.
A table or map listing roads, tracks or routes open to use should be included and any
restrictions specified e.g. 4WD only, time of year etc.
The use of the word “generally” in the first sentence, paragraph 2 on p113, is misleading.
Paper roads
There is no discussion as to whether there are any unformed legal roads that should be
closed. Possible policy:
Identify any legal roads running through conservation land that should be stopped and
added to pcl.
Mountain biking
The Mountain Bike Definition p139 is “A non-motorised bicycle that can be used off formed
roads”. This should be amended to also exclude power-assisted bikes, as the potential speed
of these vehicles will be a safety issue for other users. Note that the definition of Power
Assisted Cycle (up to 300 watts) is not used in the document. The capability of powerassisted bikes is expected to increase significantly in the next decade. It is not clear whether
a battery powered bike is considered to be “motorised”.
Amend to read “A non-power assisted bicycle...”
The text at the beginning of Part 3 says “Improved track designs, management techniques,
user education and signage have reduced concerns about potential user conflict and impacts
on site values.
Amend the text relating to mountain biking on pg 113 to read:
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CGP 9.5 The use of vehicles and other forms of transport
9.5 (a) The use of vehicles and any other forms of transport should.
9.5 (b) Conservation management strategies and plans will identify where the use of specified types of vehicles and other
forms of transport may be allowed and will establish any conditions for use.
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Mountain biking has become an established recreational activity on public conservation
lands. Improved track designs, management techniques, user education and signage have
reduced some of the early concerns.]
Decisions sought
Include a table or map listing roads, tracks or routes open to use and any restrictions
specified e.g. 4WD only, time of year etc.
Delete the word “generally” used in the Introductory text.
Identify any legal roads running through conservation land that should be stopped and
added to pcl.
Amend the definition of mountain bike to exclude any power-assisted bikes.
AIRCRAFT
Inadequate maps mean that zone boundaries cannot be identified for purposes of
submission or decision-making (legally the published maps are the basis for decisions). If
zones are to be used, maps should be re-notified for informed submission.
Aircraft comes under CGP 9.5 (b) which says that the CMS will identify where the use of
specified types of vehicles and other forms of transport may be allowed and will establish
any conditions for their use. Technically the maps show the frequency of where aircraft are
allowed but there are few other conditions specified.
The approach used is far too permissive, specifically the yellow and green zones, and
encourages an increase in aircraft use on pcl, facilitating both positioning of recreationalists
and for purely social uses. The approach of little or no control unless problems arise is short
sighted as history shows that efforts to wind back use once established is very difficult if not
impossible. It also reflects a naivety about future growth and the exploitation of loopholes.
The issue is what recreational use of aircraft is justified, and if so where and how often
(limited or regular use). Even 5% encounter rate is high on pcl in a remote or back country
zone.
The use of standard zones in each conservancy is flawed, as there is no consistency in how
the zones are applied in the first place. About half of pcl in Northland is Green zone, whereas
Waikato and Auckland have more specific provisions in several Places.
The Yellow Zone is flawed because the argument that there is a low aircraft use, is not a
reason to increase it! The presumption for approval is mistaken. In addition, the national
conditions of two landings per operator per day at any one site (defined as within a 1-km
radius) and a maximum of 20 landings per site per operator per year does not take into
account the total number of operators. Motutapu Island appears to be largely zoned yellow.
It should have its own specific aircraft limits.
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The Green Zone is flawed because it assumes there are places where values are not affected.
The Society is hard-pressed to think of any places on pcl where this would be the case. It is
also considered that the “natural limits” and “unlikely demand” scenarios are not plausible.
There are always those who seek to push the limits, whatever they are. Again, the
presumption to approve is contrary to the traditional kiwi back country experience.
The Prescriptions for Management of Aircraft Zones (Appendix 13) includes an average
percentage of time that aircraft are likely to be encountered: Remote 1% or less, Back
Country Occasional 5% or Regular 25% and Front Country Frequent 50% or more. The
combined effect of this and the zoning prescriptions is that there is likely to be a
considerable increase in aircraft use in response to pressure for access to picnic spots, for
weddings in the back country, heli-walking, biking and hunting etc.
Problems with this approach:
 Aligning aircraft use with natural quiet (noise) parameters of the Visitor Settings
might appear logical but busy Front Country areas could be most inappropriate
places to have aircraft operating. People noise does not equate to motorised noise,
especially aircraft noise.
 There would be very few places where visitor values are not affected by landings.
 Back country visitors should not have to accept noise for 25% of their visit and 50%
for front country – only Milford and the glaciers would probably have this level of
use.
 Basing policy on the assumption there is no demand is short sighted – canny
operators are likely to take advantage of this.
 Limits on landings per operator do not include limits on the number of operators.
 There is an assumption that aircraft use is normal on pcl and entrenches it across pcl
except for remote and wilderness areas indicated by the use of the word “should”
rather than “may” for the Green zone. This is contrary to the notion of people
seeking experiences on conservation land to get away from developed environments
of the rest of New Zealand. The more encounters people have both with aircraft (by
way of noise) and more encounters with other people, remote and back country
areas will become less remote the more people are present and the easier it is to
access a place. Essentially the aircraft policies allow a re-zoning by concession.
 There is always going to be some aircraft use everywhere for management purposes.
In practice, there appears to be a conflict between this approach and some of the Place
policies, Map 4 and Appendix 11.
The permissive approach continues with concessions where aircraft use is generally
permitted for concessions. Policy 3.4.10 states that DoC “should permit aircraft landings and
take-offs on public conservation lands for the construction and/or maintenance of utilities
authorised by concession”. This means that a concession can effectively change a recreation
or aircraft zoning, when the converse should apply – concession use of aircraft should reflect
the zoning for the area.
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Decisions Sought
Re-notify any aircraft zone maps for informed public submission.
Add new objective: avoid or otherwise minimise adverse effects on the qualities of peace
and natural quiet, solitude, remoteness and wilderness.
Re-visit the entire approach to aircraft zoning and use and base the management approach
on a presumption against an increase in aircraft use (by using the words ‘may’ or ‘should
not’) to reflect the natural, and in many cases, remote character of public conservation
lands, and this should be included in all the Outcomes. The Yellow and Green Zones should
be deleted and CMSes should include strict limits outside existing use, including landing
sites, flight paths and frequency, duration, time of year. At the very minimum delete the
words “should be” from the Green Zone in Appendix 13 and replace with ‘may’ and change
the words “should allow” in policy 3.4.1 to “consider”.
Amend Policy 3.4.10 “Aircraft landings and take-offs on public conservation lands for the
construction and/or maintenance of utilities authorised by concession should be consistent
with the recreational zoning and included in overall limits for aircraft use”.
HUNTING
There are no general hunting policies for Auckland. However pig hunting is widespread and
should be addressed, and the CMS should explain the Wild Animal Control Act and the deerfree areas to achieve the integrated management required under s 17D.
Although there are hunting policies for some Places, there should be a general hunting
section in Part 3 that includes a policy to require avian aversion training for all permits for
dogs wherever there are ground nesting birds.
Feral pigs are a pest in Auckland forests – their foraging habit destroys ground cover and
prevents regrowth of forest canopy and understorey, and is a threat to kiwi nests. The CMS
should provide for departmental control where recreational hunting is not effective in
keeping damage to biodiversity to minimal levels. This may include use of traps and
organised club events focussed on a particular area. Management of feral pigs by hunting
organisations should not be allowed.
Decisions Sought
Dog use for hunting should require avian aversion training in all areas with ground nesting
birds.
Include a policy for departmental intervention where feral pigs are impacting on biodiversity
values.
Include a policy to not allow management of feral pigs by hunters.
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Dogs
For a comprehensive, educational and user-friendly approach, the lists of Open and Closed
Dog areas should be included as an appendix in the CMS.
Decision Sought
Include the Gazette notice for Controlled and Open Dog Areas, or a schedule as appropriate,
in an Appendix.
Other animals
There is no conservation reason for allowing other animals on pcl.
Policy 3.6.3 is worded in a way that may preclude some options.
Decision Sought
Amend the title to read “Other animals (including pets)”
Amend Policy 3.7.2 to read “Will not permit any other types of animals...etc”
Policy 3.6.3 should read “will consider reviewing horse riding”
Sports Fish and Game Birds
Policy 3.13.1 is minimalist in the extreme and does not satisfy CGP 9.4. (Note referencing
error in the notified draft). The introductory text includes policy in the last paragraph which
should be included.
Decision sought
Amend policy 3.13.1 to read:
Will work with the Northland and Auckland/Waikato Fish and Game Councils to provide for
sports fishing and gamebird hunting, while ensuring there are no adverse impacts on the
indigenous species and their habitats, and is consistent with the purposes for which the land
is held.
USE OF CONSERVATION LAND – AUTHORISATIONS
The 3rd sentence of the text says “The Department aims to allow for a range of
authorisations that are consistent with relevant legislation and policy, the protection of
natural resources and historic and cultural heritage, and the recreational settings and
planned outcomes for specific places.” This statement contains an element of
predetermination.
Decision Sought
Redraft to use the word “may” instead of “aim”.
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Private Accommodation
Policy 3.9.2 is not consistent with CGP 10 (h).
Decision Sought
Replace “should” with “will” in policies 2 and 3
Sand and Shingle extraction
CGP 11.4 (c) states that CMSes will identify where material can be removed.
Decision Sought
Amend policy 3.10.1 to read:
Will only authorise sand and/or shingle extraction from public conservation lands and waters
where adverse effects can be avoided, remedied or mitigated and the resource cannot be
practically be accessed elsewhere.
Collection of Materials
For completeness the text in the Waikato draft is recommended:
Decision Sought
Include the Waikato CMS text:
“Applications for the collection of material for research and information needs are
addressed in, and must be consistent with, the Conservation General Policy 2005 (section
12: Research and information needs).
The collection of material from public conservation lands and water also includes customary
activities of significance to tangata whenua (refer section 1.4: Treaty of Waitangi
responsibilities). Treaty settlement legislation also recognises the significance of customary
activities to tangata whenua and in many instances specifies processes for customary use of
materials managed under conservation legalisation, e.g. the Reserves Act 1977. “
Filming
The CMSs should consider effects of “film tourism” where relevant i.e. where use of a
conservation area as a location for films is likely to generate visitors to see that site.
Decision sought
Add ‘effects of any subsequent increased visitor use of area as a result of filming activity’ to
3.14.1.
APPENDICES
Appendix 1 Activity Scope
Point 3 refers to “as agreed in consultation with the community” but there is no indication of
what this consultation might be. It should be clarified and cross-referenced to a policy.
Appendix 2
Significant Values
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This is over-summarised. It implies the named areas are the only places with significant
values, which is not the case. The ones named are the outstanding areas.
Similarly the Administrative status is too general – it does not indicate scientific or scenic
reserve etc.
Lakes and Rivers
Dune lakes have been omitted and there is no data at all about rivers.
Appendix 3 Islands
The heading of the 3rd column “Desired Island Classification’ needs further explanation and a
policy to link it to.
The Issues should be addressed in the Places but are not.
Appendix 5
Pages 171 & 172 need to be swapped around.
Hedgehog – Priority place for action should include sites where integrated pest control is
being undertaken.
Rainbow skink- action should be taken to prevent further expansion.
Appendix 10 and 11 and 13
See submissions above in Visitor and Aircraft sections.
Decisions Sought
Amend the Appendices as outline above.
MAPS
Legend
Visitor Management Zones on non-public conservation land should be deleted.
The difference between High and Second Priority ecosystems is difficult, if not impossible, to
distinguish on the printed maps.
The Visitor Management Zone legend should be shown on Map 3.
Legibility
Maps 3 and 4 are of too small a scale to understand the application of the Policies. Visitor
management zones and aircraft zones (if any – see submission above), should be provided
for each Place.
Decision Sought
Amend Maps as outlined above and re-notify them to allow for informed submissions.
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SECTION TWO
Section 2 of this submission discusses the detail of the draft Auckland CMS, and identifies
recommended changes and additions. This are written in the same order as found in the
draft CMS.
PART 2: PLACES
2.1 Marine Reserves Place
Motu Manawa-Pollen Island Marine Reserve
Paragraph 1 should include the fact that the reserve land is a breeding area for three
threatened/at risk bird taxa: northern NZ dotterel (nationally vulnerable), fernbird
(declining) and banded rail (naturally uncommon) and that it is habitat for the Bactra sp.
moth.
Decisions Sought
Outcome
Amend the outcome so that it includes the breeding area for northern NZ dotterel, fernbird
and banded rail and includes the habitat for the Bactra sp. moth.
Policies
Add a policy addressing the need for predator control, especially during the bird breeding
season.
Milestone
Predator numbers less than 5% within 3 years
Insert a new place:
Te Arai canal and estuary to Pakiri Coast Place (extension of the Northland CMS
Whangaruru-Mangawhai Coast Place)
The status of the NZ fairy tern is critical and with the current decline in already low numbers
every effort needs to be made to prevent its extinction. The major causes are predation and
disturbance but there is also a shortage of suitable nesting sites and territories.
Decisions Sought
Outcome/Policies
Include and outcome and policies to upgrade the status of land to give the highest
protection to fairy tern breeding, foraging and roosting areas including extending protection
to mean low water, and to maintain intensive and comprehensive pest control for these
habitats, year-round if necessary.
Include complimentary policies to those in section 2.9 (Whangaruru-Mangawhai Coast Place)
of the Draft Northland CMS. This is a continuous habitat area for NZ fairy tern aqnd NZ
dotterel, with birds moving between all of these places.
2.3 Hauturu/Little Barrier Island Place
The New Zealand storm petrel was thought to be extinct until its rediscovery in 2003.
However its breeding site was unknown until it was recently discovered on Hauturu.
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Decision Sought
Outcome
Amend the outcome so that it includes mention of the recent rediscovery of the breeding
site for NZ storm petrel.
2.7 Kaipara Harbour Place
The Kaipara Harbour is the winter feeding ground for fairy tern and they nest at South
Head/Papakanui. A new nesting area is proposed at Bird Island, Taporapora, and if successful
the adjacent Manukapua Id may also be suitable. These will require protection from people,
vehicle and dog disturbance and predators, as part of an on-going programme to increase
the nesting sites for this taxon.
The land status of these sites should be addressed so that they are made into Wildlife
Management Reserves to Mean Low Water to enable control of people, dogs and vehicles.
The status of the Okahukura Conservation Area should also be changed.
Decisions Sought
Outcome
Amend the outcome to include new fairy tern breeding sites established at Bird Island and
Manukapua and numbers have reached 100 birds.
Policies
Add a policy addressing the establishment of new fairy tern breeding sites at Bird Island and
Manukapua including appropriate land classification to minimise disturbance from people,
dogs and vehicles.
Add a policy addressing the need for comprehensive predator control, especially during the
fairy tern breeding season.
Milestones
NZ fairy tern population stabilised by 2017 (3 years out); breeding pairs doubled in 5 years
and population of over 100 individuals in 10 years.
Include Policy 2.7.17 a) and b) to be implemented by the end of year 3 after CMS approval
(2017)
Change aircraft outcomes and prescriptions to Red Zone.
2.8 Kawau Island Place
Paragraph 7 mentions issues with introduced pests. These should also include pests such as
wallabies, possums and lillypilly and other plant pests.
Decisions Sought
Outcome
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Amend the outcome to include the eradication of wallabies and pest trees.
Policies
Add a policy requiring a pest eradication plan for wallabies and pest trees, including lillypilly
(Syzygium australe, S. smithii)
Milestone
Implementation to be completed by 2017
PART 3 - Specific policy requirements for Auckland Conservancy
Amend to include climate change, biosecurity and indigenous biodiversity.
Milestones
Amend this section to include some Year 3 and 5 milestones e.g. marine mammal tourism
site plans.
Decisions Sought
Policies
Add a policy addressing the threat of climate change in terms of the impact of both rising
temperatures and sea levels.
Add a policy addressing the threat posed by introduced weeds and animal pests, including
PTA (kauri dieback disease).Add a policy addressing the protection of indigenous
biodiversity, particularly NZ fairy tern, Maui’s dolphin (including the West Coast Marine
Mammal Sanctuary), black petrel, brown teal, chevron skink, Great Barrier Island kanuka and
other threatened flora and fauna.
Milestone
Amend review of mountain biking to after 5 years
APPENDIX 7: Icons in Auckland Conservancy
Decisions Sought
Add the following:
Flora: kakabeak (Kaipara), Waitakere rock koromiko, Great Barrier Island kanuka, West Coast
kowhai
Fauna: Maui’s dolphin, NZ fairy tern, kokako, black petrel (LBI & GBI), NZ storm petrel,
chevron skink (GBI), hihi
VOLUME II MAPS
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Map7.7 Kaipara Harbour Place
Decision Sought
Identify Bird Island as such
Conclusion
Forest and Bird would like to conclude by congratulating the Department and Conservancy
on the good work it has done and continues to do.
The Society would like to appear in support of this submission.
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