General Policy National Parks Act

Comments:

01   The right and freedom of entry is not guaranteed. It may be stopped by DOC or Tangata Whenua for any reason that these two parties may consider appropriate - last clause p3.

02   The World Conservation Union (IUCN) considers three main purposes of 'National Parks' with the third reason being - "to provide opportunities for spiritual, educational and recreational activities". Do recreational activities include hunting of wild animals? - top of p9.

03   Fig 1: General Policy Statutory Framework diagram refers to "Sports Fish and Game Management Plans" with reference to other acts being Wildlife Act 1953 and Wild Animal Control Act 1977. Does this clause mean that deer and other wild animals are now considered Game and are to be managed and not exterminated? - diagram p11. Probably not, only wild fowl.

04   Fig 2: Relationship of Statutory and Non-statutory Conservation Framework diagram refers under a block heading of Management Plans to "Sports Fish and Game Management Plans". Again under the block heading of CONSERVATION WORK PLANNING, work will be done "Fish and Game Operational Plans". Does this mean that exotic wild life is now considered as game? - diagram p12.

05   1.2 Legislative and Administrative Background states that "Regional and Game Councils (established under Part VA of the Conservation Act) have specific responsibilities to maintain, enhance and manage the sustainable use of sports fish and game species and to promote the maintenance and enhancement of the habitat on which these species depend". Does the game species refer to introduced birdlife (ducks etc) or are other species included? - bottom p13 - probably not.

06   "A management plan must be prepared for each national park and must not conflict with the relevant conservation management strategy". Have any management plans been drafted for each or any of the national parks and have they been sighted? - Top p14.

07   "…………….with the preservation of native plants and animals and the welfare of the parks having primacy over people's enjoyment and use of national parks". Clearly, access can be denied by DOC and presumably the Tangata Whenua at any time for almost any reason that they should so choose. - mid p14.

08   "Except where the New Zealand Conservation Authority otherwise determines, the native plants and animals of the park shall as far as possible be preserved and the introduced plants and animals shall as far as possible be exterminated. [section 4(2)(b)]". Introduced trout are responsible for wiping out the native fresh water fish (galaxiids) in most major rivers and lakes. This is a native species on the verge of extinction yet the introduced trout enjoy a protected "game" status. The native freshwater cray-fish (koura) are similarly predated by introduced trout. Similar comments can be made about salmon, also an introduced "game" specie.

09   Integrated conservation management must consider the economic well-being of local communities or cultural values of local iwi. This clause is followed by non-specific waffle and then a reference of responsibilities relating to the principles of the Treaty of Waitangi - p16. Meaning and clarification?

10   "recognise the roles of the Minister of Conservation and the government of the day and other decision makers;………." Who would be these other decision makers? Are they down to the level of the local ranger or honorary volunteers/rangers? Presumably they could decide to bar access. Is the local iwi included as other decision makers? Decisions may be made outside a statutory decision and can be entirely a "management" matter. - p17

11   Chapter 2 - Treaty of Waitangi Responsibilities" states "Effective partnerships with tangata whenua can achieve enhanced conservation of natural and cultural values in national parks". Is there a partnership with other New Zealanders or is DOC representing the other 85% of the population in decision and/or policy making? - p19. There is no reference in the POLICIES for Maori of this section for "Active involvement and participation in conservation activities should be encouraged. etc" and again "Volunteer work opportunities should include activities that are designed to increase awareness of conservation values, issues and management". Both these clauses and others are included in the POLICIES for the 85% of the population. Does this imply that all Maori are fully aware of total conservation responsibilities? In the north of New Zealand, the native wood pigeon is being "harvested" with rifles to extinction in that area under the claim that they are a traditional food. The brown kiwi is being driven to the brink of extinction in the Ureweras by pig dogs roaming free.

12   Chapter 3 - Public Participation in National Parks states "Those with a particular interest in national park management include Maori as the Crown's Treaty partner, neighbouring landowners and managers, etc………..". It appears that any individual or any group (including scientists) from the 85% of the population will have to negotiate with the partnership of DOC and Maori being joint partners on the other side. - p21

13   Protection of marine ecosystems. These comments may be premature in light of the recent controversy over title/ownership/traditional use of sea beds and sea shores. - bottom p23

14   Chapter 4: Nature Conservation states in POLICIES 4.1(b) diminishing of landform features within national parks should be prevented as far as possible. Yet mining "exploration" licenses have been issued and logging ("selective"?) is being carried out in New Zealand Forest Parks. These activities should not be allowed in National Parks yet 4.1(b) seems to allow this to happen and 4.2(a) states "should be avoided or otherwise minimised".

15   4.3.2 Biosecurity and pest management: many introduced pests are not being risk assessed or even researched while heavy expenditure is going into overkill in other areas. As examples, introduced heather on the volcanic plateau is choking out native species, hyriciam (?) is a considerable problem in the south island high country, varoa mite is wiping out the native bee with unknown consequences to native birds and forest regeneration, german wasps are also competitors with native birds to honey dew and buddleia is spreading in the bush in the lower north island. What action has been taken regarding the illegal liberating of catfish into Lake Taupo? It is a reasonable presumption that these fish will eventually spread down the Waikato River with a serious effect on the downstream river fauna. Various water weeds are causing problems in the Waikato (particularly in the hydro lakes) and elsewhere.

16   4.3.2(e) "Subject to controls to ensure public safety, hunting to reduce wild animal numbers should be permitted, especially where this compliments other forms of pest control". Few persons hunt wild pigs in areas where there has been extensive poisoning with broadifacoum. A result of this is that there is an increase in the number of wild pigs now spreading bovine Tb. Also deer are not hunted immediately after where there has been recent use of 1080.

17   4.3.2(f) states that the impact of control methods on indigenous non-target species should be evaluated. How much research has gone into the resulting effects of depressing the population of one species relating to population levels of other species?

18   Chapter 5: Cultural and Historic Heritage. Half way down the page it states that the Tangata Whenua have a particular interest in some sites of significance known only to them and the sites are not identified publicly in order to protect them. This is reasonable but in reality they must convince the Authority of the validity of their claims otherwise the door is left open for vexatious and frivolous claims resulting in wasting of time and money and perhaps denying access to the majority of the public.

19   Chapter 6: The creation of new national parks. The minister correctly must seek the views of the Tangata Whenua when creating new national parks regarding areas of cultural and sacred significance. Will such areas be excluded from the national park or included when compensation is made as indicated in POLICIES 6(h) i)?

20   Chapter 7: Natural Hazards. POLICIES 7(c) states that risks arising from natural hazards should be minimized where practical consistent with cultural values. For example, there is a predicted risk of a serious lahar from the crater lake of Mt Ruapehu in the near future. Yet nothing is done because the local iwi state that the mountain is sacred and it would be culturally insensitive to cut an overflow channel from the lake to reduce pressure. Instead, an eyesore channel and stopbank has been bulldozed on the Rangipo plain. Does this mean that cultural sensitivity take precedence over predicted loss of life as it has been estimated that a large lahar could spill onto desert road traffic and also cause considerable damage down the Whangaehu River?

21   Chapter 8 states that salmoniod fish and game birds were introduced into national parks and established to provide a recognised recreational resource for visitors. In most overseas countries, our introduced feral animals classified as "pests" are highly sort after as game for hunting. - bottom p42.

22   Chapter 9: Non-Recreational Uses provides for granting of grazing concessions in national parks. The POLICIES state that grazing animals shall be kept out of waterways and effectively controlled by fencing if necessary clauses 9.1(a) v) and vi). Clause 9.1(b) describes grazing as a management tool. These conditions are rarely if ever met with stock polluting streams and with free access into the bush. Fencing is usually non-existent or derelict. Cattle grazing does far more damage than deer browsing as they trample the bush and graze in one place while deer are browsing animals. Leases in national parks and forest parks should not be renewed if there is genuine concern for the indigenous flora and fauna.