11th March 2009
New Zealand Deerstalkers’ Association (NZDA) makes the following submission on this draft CMS and NPMP. NZDA requests to speak to this joint submission. We request a hearing time of one hour. Please contact Dr Hugh Barr, National Advocate, 04 934 2244 hugh@infosmart.co.nz or Dianne Brown, CEO 04 801 7368.
1 New Zealand Deerstalkers’ Association Incorporated (NZDA):
NZDA is the national body of recreational deerstalkers and other big game hunters in New Zealand. We have 50 branches and a number of other hunting member clubs throughout the country. We have 7500 members, and have been actively advocating for recreational deerstalking and hunting, running hunter training courses, trips, conferences etc since 1937. We maintain ethical standards for hunting. NZDA’s membership has been growing at 7% a year recently, showing that recreational hunting is an attractive recreation for New Zealanders.
NZDA Branches who hunt regularly on Stewart Island are: Southland Branch (Invercargill), South
Otago Branch (Balclutha), Southern Lakes Branch (Alexandra, Queenstown, Wanaka), Otago Branch (Dunedin), West Coast, Taranaki, etc.
As well, deerstalkers from all other Branches hunt on Stewart Island for Whitetail deer, as can be seen from information from their DOC hunting permits. Deerstalkers are also attracted from overseas, especially Australia.
Based on scientist Graham Nugent’s Survey of 1988, there are probably 50,000 recreational deerstalkers in New Zealand, who do or could hunt Whitetail on Stewart Island. Recreational deerstalkers find hunting on Stewart Island is an iconic experience, and all New Zealand deerstalkers are interested in doing it. Many who do it return regularly. Even DOC staff who hunt have remarked that they have found Stewart Island hunting inspirational.
The provision of 17 new plus 3 existing deerstalker huts on public and private lands on Stewart Island by the Rakiura Hunter Camps Trust is clear evidence of the importance of recreational deerstalking for Whitetail deer on Stewart Island. It also reflects the scenic and recreational fishing attractiveness of many sites where deerstalkers go on Stewart Island.
NZDA and its branches and members have already made many submissions on Stewart Island, in the preliminary stages of this CMS process, and DOC should also refer to these.
2 Summary:
1 CGPs and GPNPs: CMSs are primarily to implement General Policies especially the Conservation General Policy (CGP) 2005 and the General Policy for National Parks (GPNP) 2005. Where this is done in the CMS, the GPs that are being implemented should be referenced.
2 NZDA supports recreational hunting management of the deer herds on Stewart Island, something that is happening now, with the 2-3,000 recreational deerstalkers/year visiting the Island.
3 NZDA seeks recognition of the recreational and historic importance of the deer herds on Stewart Island, given that the herds’ numbers are controlled by recreational hunting at present, and opposes them being managed by DOC as wild animals to be exterminated.
4 NZDA strongly supports the work of the Rakiura Hunter Camps Trust in providing effective hunter huts to replace often untidy hunter campsites.
5 NZDA opposes WARO concessions because they undermine recreational hunting effort.
6 NZDA seeks de-gazettal of the small residual Pegasus Nature Reserve. The need for it has gone with the transfer of kakapo to Codfish Island and absorption of 80% of the Reserve into the Rakiura National Park.
7 NZDA proposes a conservation park for the eastern public conservation land, because of the increased recreational and tourist use DOC plans for the area.
8 NZDA opposes the remote experience zoning for the residual Pegasus Nature Reserve
9 NZDA supports an additional helicopter landing area at Homestead Hunters Hut, Mason Bay, and at other remote hunters’ huts.
10 NZDA supports a RHCT hunters’ hut being built at Upper Lords campsite.
11 NZDA requests that the ecosystem service provided by the wild deer on Stewart Island be included in the CMS.
3 Draft CMS:
1.2 Public participation in conservation management (p 22):
Public participation in conservation work ie volunteerism, because it is cheaper, and recruits people to DOC’s preservationist agenda, seems to have become DOC’s main reason for being ie making the preservation budget go further and recruiting believers.
NZDA sees self-help by recreational groups as also being important, and applauds DOC for allowing the Rakiura Hunter Camps Trust to replace often rat infested and run-down traditional hunter camps with new vermin-proof huts near the camps on a number of hunter blocks. It has given a major benefit to the recreational hunting community, and to management of the Whitetail deer herd, and control of rats, cats possums near the huts. All this benefit at very little cost to DOC, because of the self-help initiatives of Southland Deerstalkers.
Management policies: NZDA proposes that Policy 4 be extended by including “recreation” after “community”. Conservation is too narrow a term, usually meaning preservation, and does not include recreation. The Rakiura Hunter Camps Trust is a recreational group, utilising deerstalkers throughout New Zealand to build and maintain its huts.
1.3 Conservation of natural resources (p 23):
“New Zealand’s unique biodiversity is internationally important.” This is true of most recently settled countries. New Zealand is “lucky” in that so much of it is swamp or mountainland, unsuited for production ie one third of the land mass is already protected as public conservation land. No other country can boast such protection. Stewart Island is an outstanding example.
Almost all of its area is useless for production. Timber milling and pastoral farming have both become extinct. Much of the low-lying area is swamp. Tourism and fishing are its last two mainstays. Recreational hunting is a significant money earner for the region. It is surprising DOC believes it can play a role in restoration, when just leaving it to nature seems to be working well. DOC cannot even maintain the tracks on the Island.
It is good to see that gamebirds are acknowledged and Canada geese are certainly present. It is disappointing that the far more interesting Whitetail deer, introduced soon after 1900, and having acclimatised very well, are not mentioned. These also provide a highly regarded recreational hunting resource.
Preservationism seems rife in Southland and Stewart Island DOC offices. There is little talk of anything else. The idea that some unknown past instant of botanic time should be the yardstick for restoration and management on the lands DOC has control of.
Preservation and restoration went out when Charles Darwin postulated evolution 150 years ago. We now know that living systems are in a constant state of change primarily to survive. With climate change now well under way, and humankind determined to do nothing about it, evolutionary forces will be much stronger in future than in the past. They may even start having an effect in the ten years of this CMS.
Evolving ecosystems, rather than preservation should be DOC’s mission. A real problem with preservationism is re-creating the moa population, and Haast’s eagle to go with it, that were a central feature of New Zealand ecosystems only 1,000 years ago. Extermination is forever. Preservationism has been a helpful myth historically. But it is time DOC faced reality.
Useful to have Table 1 setting out the position of endangered native animal species on Stewart Island. It is interesting that no species are listed as stable or increasing. Are all native species doomed under DOC management?
Management Objectives (P 30):
1 “preserve the intrinsic values of - - ecosystems”: “preserve” is not used with regard to ecosystems in DOC’s Conservation General Policy (CGP) Policies 4.1, which this Section of the CMS is primarily to implement. Instead “prevention of loss”, “maintenance of representative examples”, “recovery” are used. “preservation” is an outmoded term and is not defined in the CGP.
2 The CMS should explain what the “intrinsic values of terrestrial and freshwater ecosystems” are, as NZDA, and many other users probably know little about them. There is nothing worse than unclear objectives.
Management Policies (P 30):
1 Add “recreational” after “community”. Recreational groups see themselves as different from “conservation” groups.
2 These management “policies” are not specific enough to be useful in terms of letting either DOC staff or the public have any idea of what they really mean. They are simply obfuscation and puffery, where clarity is specifically needed. More details on the policies are essential. NZDA, and the public in general, cannot comment on such vague and vacuous generalisations.
1.3.2 Biosecurity and management of threats to indigenous ecosystems, habitats and species( P 31):
NZDA agrees that recreational hunting has been the main method of managing the Whitetail and Red deer herds. The size of the Whitetail herd is small, probably around 4-6,000. Recreational hunting control has proved successful and that should continue to be the primary means of control.
Management Objectives (P 35):
Add 6 To recognise the Whitetailed deer herd as a valued, historic and recreational deer herd
The herd is a major recreational asset to the Island. This herd was established in 1905, and has is now managed mostly by recreational hunters. There is an effective partnership between DOC and the deerstalking community, realised in the Rakiura Hunter Camps Trust (RHCT). These huts help attract the significant number of recreational deerstalkers that visit Stewart Island annually to hunt these deer. This also includes rat, possum and cat control around the huts.
Management Policies (P 36):
These polices are far to general to satisfy the requirement of the CMS to implement general policies (S 17D, Conservation Act).
For example, CGP 4.2 ((f) states: “Recreational hunting of wild animals and animal pests will be encouraged –“
This CMS states:
“4 Will encourage recreational hunting on public conservation lands.” This gives no information on how this policy will be implemented. It simply repeats it. This is inadequate. Details of how DOC intends to encourage recreational hunting need to be set out. DOC commits to nothing by this statement.
Eg Include “by 1 Allowing the Rakiura Hunter Camps Trust to maintain, extend and book their huts”
2 DOC recommend to the Conservation Authority that the Whitetail deer herd be recognised under S 4 (2) (b) of the National Parks Act, in Stewart Island/Rakiura National Park, in recognition of their historic, recreational, economic and tourist values.
Note: The herd was established in 1905, almost 100 years before the National Park was set up.
1.3.7 Ecosystem services (P 47):
These were only a minor part of the CGP ie they get only a brief mention as 4.6 (a). Hardly any other CGPs are specifically mentioned. Why this one? They seem primarily invented for DOC propaganda purposes.
For example, carbon sequestration is best done by introduced tree species such as pinus radiata,
Native trees and shrubs sequester far less carbon. As well, the ecosystem value of the Whitetail deer herd is significant in terms of a recreational attraction to Stewart Island, but is not mentioned. NZDA requests it be included. There is also the ecosystem value of possum trapping as a means of control.
Then there is the argument that it would be better to clear native vegetation and plant either fast-absorbing carbon fixing trees, or grow something that is commercially productive.
And there is the minerals development foregone. Vague waffle about the glories of selective ecosystem services is dangerous, and self serving, and may shoot DOC in the foot.
1.5 Recreation, including public benefit and enjoyment (P 53, and CGP Section 9):
Having only 50,000 visitors/year highlights how low the tourist use of the Island is. Many of these will simply visit Oban and the seas, rather than to the public conservation land.
Re recreational hunting on Stewart Island, NZDA agrees that recreational hunting is a unique recreational hunting experience in New Zealand, and one that is highly regarded. Thank you!
Re DOC’s recreational opportunity Spectrum settings, Table 9, they do not differentiate between the types of activity. For example there is no ROS designation for recreational hunting. All ROS does is measure ease of access (Front, Back, remote, wilderness, possibly bushcraft or water-craft skills) and then lumps every recreational type together. Yet access by helicopter and fixed wing aircraft to the beaches makes a mockery of ROS. Though such access is greatly appreciated by recreational users tired of DOC’s illogical restrictions on public access to the public’s land.
This is obviously a spectrum designed to minimise understanding of the activities being undertaken, so is probably solely for administration or DOC management purposes. Usually the most important issue for most recreational users is the activity they are undertaking eg hunting, tramping, canoeing etc. ROS looks more like a zoning that allows DOC to ignore the activities actually being undertaken, no matter that it is useful that DOC does actually talk about a spectrum of recreational activity, even in the very restricted sense DOC has defined it to be.
ROS Map of Stewart Island:
Even so, it is essential that the ROS zoning that DOC is proposing for Stewart Island be shown on a map, so the public is informed as to what it is, and can comment on it. It would be very useful. Why has this not been included? Is it to evade discussion of a controversial issue?
Management objectives (P 58):
1 DOC provides “a range of quality recreational opportunities”: NZDA notes that, apart from huts and tracks, most of the quality opportunities for recreation are provided by nature.
Management policies (P 58): There is no connection between these policies and the objectives stated. The “policies” are so vague that they are in reality objectives again, not policies – which are more specific than objectives. The purpose of CMSs is in any case the implementation of the Conservation General Policies.
There is little sign of any implementations of the CGP Section 9. NZDA is left with the impression that DOC is hoodwinking the public by not stating any implementation details, so the public has nothing to comment on. A number of these S 9 Policies are required to be implemented in the CMS
eg CGP 9.1 (b) “The recreation opportunities and outcomes planned for different places will be identified in CMSs - -“ Not done. Eg No ROS map, or discussion.
CGP 9.1 (c) “Identification of the outcomes planned for different places and the range of recreational opportunities available should include - etc” No real discussion.
CGP 9.1 (d) CMSs should identify (see 9.1 (c)) how public access is enabled, and what type of recreational opportunities, activities etc are suitable for different places and to what extent.” Not discussed.
CGP 9.5 (b) CMSs will identify where the use of specified types of vehicles and other forms of transport may be allowed – establish any conditions of use. Done for helicopters
It is ironic that the lowest quality recreational experience on Stewart Island is using DOC’s awful, muddy tracks. Yet these are not even mentioned, nor whether anything will be done about them, as has happened everywhere else in New Zealand decades ago.
NZDA notes that so called policies 6 (chainsaws) and 7 (freezers, generators etc) are not policies to be implemented at all, but bylaws. NZDA supports the ban on chainsaws, except for appropriate hut maintenance.
NZDA sees the prohibition on the use of freezers as discriminatory against recreational hunters who need to stop their harvested venison from going off, and when away for a ten day hunt, need to be able to store perishable food. NZDA notes that generators are now small and quiet. They are also important for hut maintenance, for running circular saws etc.
1.5.2 Vehicles (including aircraft) (P 59 CGP S 9.5): Again there are no details of how the CGP policies 9.4 are to be implemented, except for the one additional helicopter access to Homestead Hunter’s Hut. NZDA strongly supports this additional landing place. Additional helicopter access to hunter huts may also be appropriate. Most hunter huts are well away from other recreational users.
1.6 Accommodation etc (P 67, CGP Section 10):
NZDA raises the question of hunters camps, which usually exist on each hunting block. NZDA notes that these camps are listed on Maps 3 and 4, which presumably means they are authorised. NZDA proposes that the most untidy of these hunter camps be replaced by the more appropriate hunter huts, if DOC can negotiate this with the Rakiura Hunter Camps Trust.
Part 2: Places (P 75):
Integrated conservation management: This is not defined. How does it differ from conservation management? How can conservation management be “integrated”? eg P 81
Oban-Patterson Place (P 78):
NZDA supports the continued closure of Paterson Inlet to commercial fishing, while allowing recreational fishing (P 82).
NZDA notes that a number of hunting blocks and their huts and campsites are accessed from Paterson Inlet
Eastern/Tai Rawhiti Place (P 94):
NZDA notes that the primary recreational activity in the area is recreational hunting, on public and RMLT lands, probably followed by boating/canoeing and fishing. The RHCT has built a number of hunter huts in the area to replace untidy hunter camps.
There is a hunters’ campsite at Upper Lords River which has been omitted. This site is untidy and cluttered. NZDA supports the RHCT replacing it with a hunters’ hut, should they wish to do so.
Outcome sought (P 100):
NZDA wants the words “and recreation” inserted before “values” in the first line. NZDA agrees that “public access to these lands is further enabled”.
Management Policies (P 100-01):
1 De-gazette the residual Pegasus Nature Reserve:
NZDA questions the need for the residual part of the Pegasus Nature Reserve to remain. The main reason for the designation was to protect kakapo. These have now all been moved to Codfish Island. There is no reason to keep this residual area as nature reserve, as there is nothing more special in it than on adjacent land.
The majority of the Nature Reserve (80%) was absorbed into the National Park, a lower level of protection than Nature Reserve. Permits are required for all nature reserves [S 20 (2) (c) Reserves Act]. However, they are not required in the area now absorbed into the national park, though this was an option – specially protected area. So DOC has agreed by absorbing the majority of the former nature reserve into the National Park, that the requirements of permit access were no longer necessary in by far the largest part of the Nature Reserve.
The remaining small residual nature reserve area should be changed to conservation park, or scenic reserve, so that public access and use is not frustrated by the need to obtain a permit. This is what sensible ‘integrated management” should mean. This is especially the case if DOC is going to allow recreation and tourism in the area, as proposed in this CMS. As well, it is inappropriate for a nature reserve to be simply a buffer zone between the national park and the RMLT land.
2 A Conservation Park for this eastern area:
Given the CMS’s proposed use of this eastern area for recreation and tourism, then designation of the nature and scenic reserve land, and the conservation areas in this Place as a Conservation Park would seem appropriate. NZDA proposes this land designation change, which is in line with the proposed CMS. It could be called the Lords River-Port Adventure Conservation Park for instance.
3 Inappropriateness of a remote experience zoning (Management policy 4):
Given DOC’s intention in the draft CMS to have more recreation and tourism in this eastern area, and in the outcome to further enable public access, it is most inappropriate to zone the buffer section as “remote recreational opportunity”. The Lords River estuary makes boat access to the Upper Lords hunter camp, on the edge of the residual nature reserve, the equivalent of Back Country Drive-in. So a more appropriate ROS zoning would be a mix of front-country and back country, not “remote”. Equally there is access from the coast SW of Lords River, and south across the Scenic Reserve from Big Glory Bay.
4 Hunter hut replacing Upper Lords hunter camp (Policy 11):
This should be “will” rather than “may”. This hunting block is popular, and having a hunter hut there would greatly reduce the present clutter, and reduce rubbish. Instead of Policy 11, NZDA proposes instead a Policy of DOC working constructively with the RHCT to provide better for recreational hunting in this Place.
5 Guided walking, guided hunting questioned(Policy 13):
NZDA questions where any guided walking will take place, given there are no tracks in the area or planned for it. NZDA is also sceptical of guided hunting in the area, given the area is popular for recreational hunters already.
Part Three: Implementation, monitoring, reporting, review and milestones (P 103):
3.3 Milestones (P 103):
Milestone – 5 years: NZDA opposes gazettal of any wilderness in the southern part of Stewart Island. Such a wilderness area is inappropriate when the area is so readily accessible by boat and helicopter. Rather than DOC locking up this area to save DOC money for tracks and possibly huts, more public use of this area should be encouraged. Much of Stewart Island is already made inaccessible by DOC policies of closing tracks, and letting the tracks it has fall into disrepair and become bogs.
End of NZDA CMS Submission.
Section 2: Draft Rakiura National Park Management Plan (P 121 on)
NZDA Summary:
1 Deer numbers in the National Park are stable and managed almost solely by recreational hunting. 2,000-2,500 recreational hunters visit the Park annually, showing such hunter management is likely to be effective in future.
2 Recreational hunters visiting Stewart Island is a New Zealand tradition dating back 30 or more years. Deer were introduced to Stewart Island in 1901, over 100 years before it became a national park.
3 NZDA seeks a hunter partnership with DOC Southland in managing deer in Rakiura National Park.
4 NZDA seeks recognition of the Whitetail deer as a valued historic, traditional, recreational, managed herd, not subject to extermination because it is in the national park.
5 NZDA does not support a southern Stewart Island wilderness area, and is concerned at DOC’s lock-up mentality regarding the park’s back-country.
6 NZDA supports giving recreational hunters priority in booking hunters huts
7 NZDA supports an additional helicopter landing site at Homestead Hunter hut
8 NZDA opposes WARO concessions in the Park
3.2.2 Introduced animals - deer (P 152):
From the top paragraph, P 152, it is clear deer control is not a DOC priority because of cost and re-invasion. No data is given about deer numbers, and whether numbers are growing or declining. Presumably they are not growing because otherwise they would be a DOC priority.
The reality is that there is minimal commercial recovery. The market is only attractive for Red deer, and these are scarce. A few Whitetail may be being captured live for game estates. So the 2-3,000 recreational hunters who visit Stewart Island each year are holding deer numbers constant, or reducing them. Though the RNPMP does not acknowledge it, this is a very valuable partnership between recreational hunters and DOC, saving DOC significant control costs. DOC should be more forthcoming in acknowledging it and its benefits.
Deer were introduced over 100 years before Stewart Island became a national park in 2002. They are an historic resource, and a significant part of New Zealand’s biodiversity. Yet DOC has not acknowledged deer and especially the Whitetail as an historic resource, or as a major attractor of people to the Park and the Island. Neither have DOC been prepared to acknowledge the successful adaption of deer in living wild on Stewart Island.
Objectives (P 152):
Objective 1 is “to eradicate, control and manage introduced animals in Rakiura National Park in accordance with national plans, RPMSs and Southland Conservancy priorities.”
NZDA strongly opposes eradication of deer on Stewart Island, in objectives 1 or 2, as part of Objective 6. Control and management should be the aim.
The Biosecurity Act and its associated RPMSs do not generally “affect or derogate in any way” from the provisions of the National Parks Act or Conservation Act, by S 7 (2) of the Biosecurity Act. SO RPMSs should play only a peripheral role eg on non-public lands and waters.
The 1980 National Parks Act with its paranoia for exterminating introduced species is more and more out-of-date with the reality of managing public lands in the 21st Century, the true meaning of biodiversity, the difficulty of exterminating most introduced animals, and for deer, that they are highly regarded as a food source, and for their recreational hunting value.
The RNPMP has a major omission in not setting out what the national plans, RPMSs and Southland Conservancy priorities are in Objective 1, or give references to them. The public has no inkling for what the Objective really means without more details. DOC is evading telling the public what it intends to do. Yet the purpose of management plans is to set out what DOC intends to do over the next ten years. By not doing that DOC has turned this consultation into a farce, as the public have nothing to respond to.
Objective 5: To consider joint working programmes with those who have an interest in - management of introduced animals.”
Objective 6: Recognise the value that recreational hunters place on Whitetail deer within RNP.
NZDA strongly supports these two objectives, and proposes discussing joint management programmes with DOC. This Objective, for deer, is implemented by Policy 4 - DOC will work with the hunting community on deer management, and control of other introduced species eg cats rats. Such a de facto unwritten programme for deer management exists at present. NZDA would like to see the DOC-NZDA/Southland Branch relationship develop further.
Re Policies 2 and 3, NZDA supports continuation of the Stewart Island/Rakiura Pest Liaison Group, and its meetings. The group has been helpful in providing community feedback.
Policy 7 – Conditions for eradication programmes: NZDA notes the references quoted in the Rakiura Hunter Camps Trust submission (p 4) stating the difficulty of eradicating Whitetail deer, and their ability to bounce back rapidly from low numbers, as a reason why they do not meet the conditions for eradication, should that ever be proposed.
Policy 9: Undertake community consultation for new toxins – NZDA supports.
Policy 10: Monitor introduced animal densities and vegetation to ensure trends are known; Re deer, this information should be made available in a timely fashion to recreational hunters eg on the DOC website. This would help implement Policy 18.
NZDA notes Policy 11 where eradication is not possible, and sees the Whitetail herd as being controlled at present as not having an unsustainable effect on native species and vegetation.
Re Policies 12-14, NZDA supports the eradication of rats, cats, possums from Stewart Island.
Regarding Policy 15, NZDA supports, except for strongly opposing (b) for eradication of deer from Stewart Island. NZDA supports eradication of deer from smaller offshore islands. NZDA supports Policy 16, eradication of illegal or accidental introductions.
Re Policy 17, WARO operations, NZDA opposes any WARO operations on Stewart Island, unless DOC can show clearly that recreational hunters are not controlling deer numbers, and restricts operations only to where the numbers are too high. WARO operations usually interfere with recreational hunting, so decreasing its effectiveness, and so discouraging recreational hunting.
Re Policy 18, Continue to encourage recreational hunting within RNP as a key method towards controlling of the deer population to reduce deer impacts on vegetation, NZDA strongly supports, but proposes “a key method” be “the key method”. This is the present status quo. DOC should recognise it.
NZDA also supports Policy 19 of encouraging hunting kill and sighting returns.
Section 4 (2) (b) Determination for the Whitetail deer herd in Rakiura National Park
NZDA wishes to see greater recognition than Objective 6 for the Whitetail deer herd, because of its important historic, wild food and recreational hunting value. One way for this would be by a dispensation under Section 4 (2) (b) of the National Parks Act, as is allowed for in Section 4.2 of the GPNP. It is clear from S 4.2 (a) of the GPNP that any such determination should be sought as part of this CMS/NPMP Process ie
“4.2 (a) Any determination - - should form part of the process of adopting or amending GPNP, or approving a CMS or NPMP”
As S 4.2 (d) of GPNP states, the main exception to extermination in national parks at present are trout and salmon and introduced gamebirds ie recreationally valued animals. Whitetail deer also fit this recreationally valued situation.
NZDA seeks DOC Southland’s support for this determination for the Whitetail deer in Rakiura National Park, and in helping determine appropriate management conditions for the herd, that would be acceptable to DOC eg the present status quo, which still allows for the present number of recreational hunters in the National Park. NZDA sees the herd as primarily for recreational hunting, provided that other means of control would be used should recreational hunting not be capable of managing animal numbers.
There may be similarities to the Wapiti management area in Fiordland National Park.
Part 4: Historic and cultural heritage (P 163):
4.1.3 Recent history (P 164):
The RNPMP should mention the Whitetail (introduced in 1905) and Red deer herds (introduced in 1901).
These are a significant part of the historic and cultural heritage of Stewart Island, and an attractor of recreational hunters, as still evidenced by hunter campsites, and the legacy of the RHCT’s recent huts.
Part 5: Recreation (Public benefit, use and enjoyment) of the Park (P 175):
NZDA supports Objectives 1, 2, 4. Re Obj 3, NZDA questions why removal of facilities is proposed. Many tracks have already been closed by DOC eg the northern start of the Tin Range track, tracks from Freshwater Landing north-west etc.
Now that Rakiura is a national park, greater development may be expected, rather than a continuing tendency by DOC to close off additional parts of the Park and lock the public out. Proposals for wilderness areas and remote experience areas are thinly disguised moves by DOC to discourage use, and save on providing facilities.
DOC has done very little to adequately maintain many of its tracks, which are notoriously muddy as a result. DOC seems to wallow in the state of these tracks as being “character building”. That sort of response went out in the 1970s in other parts of New Zealand. Admittedly Stewart Island peat swamp has its problems. But much is run down by not cutting or re-aligning tracks. Even basic maintenance is not being done.
Policy 1: The recreational opportunities at the five places need summarising in this section.
Policy 2: NZDA opposes removal of facilities, and asks that they be replaced.
Policy 4: Open bookings for hunters huts: These huts have been specifically put in for hunters hunting on a specific block. Given DOC’s desire to see recreational hunters managing deer, and given the RHCT, a hunter supported trust, built and maintains the huts, then hunters should have priority. As well they usually stay for 5-10 days, so will be disrupted if non-hunters can book the huts for only a day or two. On the NW Circuit track, huts are specifically provided for trampers, who should preferably use these.
So NZDA supports instead a preference for recreational hunters in huts built by the RHCT. This could be done for instance, by allowing huts to be booked by trampers only within a week of the start of their trip ie when the booking is unlikely to displace a hunter group.
Policy 6: Provision of recreational facilities: NZDA supports, but considers DOC is failing in its maintenance of most tracks.
5.8 Aircraft landings (P M183-4):
NZDA supports limited helicopter access to remote hunters huts. NZDA strongly supports helicopter access at the Homestead Hunters Hut, Mason Bay.(Policy 4)
6.2 WARO Concessions (P 190):
NZDA opposes all WARO operations in RNP, unless good reason, in terms of deer numbers being too high, are clearly occurring. If such concessions are issued, then the three policies listed should apply.
6.7 Accommodation and related facilities (P 195):
This has already been partly covered under Part 5 Recreation re hunter and DOC public huts. Generally NZDA opposes private lodges in Rakiura National Park.
Objective 3: To remove unauthorised private accommodation facilities including encampments -.
NZDA proposes the hunter camps remaining on hunting blocks in the National Park should be specified as exempt from this Objective, and asks that this be made clear in the MP. Map 8 shows six hunter campsites on the NW Circuit. These should be exempt from this Objective, as should at least one such campsite in each recreational hunting block that does not have a hut. These should be specified in this NPMP.
Policies: 2: New accommodation should be able to be built by the RHCT, which is a Trust, rather than a “recreation club”. Please add the Trust to this Policy.
Part 8 Places (P 199):
NZDA supports the five places proposed, but with the following differences:
8.2 Northern Place: The southern shoreline of Paterson Inlet is similar to the coastal areas in the rest of the Northern Place, and has hunters’ huts near the shore.
Taking the strip above the line from Rakeahua Hut to the southern point of Big Glory Bay in the park, from the Southern Place to the Northern Place would be appropriate. NZDA proposes this swap. This is very similar land/water to the rest of the Northern Place, and already has tracks from Paterson Inlet to Pryse Peak and to the SW Arm. Alternatively the block taken out could be that area east of a line from Doughboy Bay to the southern end of Big Glory Bay.
8.4 Southern Place (P 219-223):
This area is supposed to be a wilderness. However, the Hunter huts on Southern Paterson Inlet need to be removed, as proposed as an addition to the Northern Place. However, the necessary exclusion of the Pegasus Place, because of its popularity, and shelter for boats and as an area for huts, cuts out the 30 year old original concept of a “Pegasus Wilderness”, as the Pegasus area must be excluded. The Tin Range too is an historic industrial site, so hardly a wilderness.
With the increasing popularity of the Pegasus area, the need for a track along the Tin Range from near Rakeahua Hut becomes more pressing as an alternative means of accessing the Pegasus area. NZDA thinks the concept of a “Southern Wilderness” on Stewart Island is inappropriate. The “wilderness” should be replaced by a central track, and a remote experience zoning. Wilderness, in this day of aircraft overflying is looking more and more a romantic armchair dream.
8.5 Port Pegasus (P 224):
This is the southernmost point of “mainland” New Zealand. It would seem valuable to provide a helicopter landing area in this zone.
NZDA asks to be heard in support of this submission. Thank you.
Yours truly
Dr Hugh Barr
National Advocate
© 2011 New Zealand Deerstalkers' Association