23 January 2006
Commissioner of Crown Lands
C/o Tim Broad, Opus International Consultants Ltd
Box 1482
Christchurch
tim.broad@opus.co.nz
This submission is made on behalf of the New Zealand Deerstalkers' Association Incorporated (NZDA).
NZDA is the national body of recreational deerstalkers and other big game hunters. We have 57 branches and a number of hunting clubs throughout New Zealand. We have 7200 members, and have been actively advocating for deerstalking and recreational hunting, and running deerstalker training courses, trips, conferences etc since 1937. NZDA also maintains the ethical side of hunting by maintaining ethics for hunting, including fair chase, and strongly encouraging harvesting of animals taken.
NZDA notes that Redcliffe was separated from Glenrock PL, and public access and boundary issues arise because they are adjacent. The Glenrock PP has been advertised, and submissions close 28 February 2006. Neither Redcliffe or Glenrock PPs provide any CPLA public access mechanisms (easements), in spite of this being a major object of the CPLA (S 24 (c) (i)). It would be best if these two leases were considered together, because, to some extent, they share common boundary and access issues.
1 Summary of NZDA Position - Redcliffe: NZDA supports the surrenders proposed. But we are concerned at the lack of any public access easements to the surrendered lands. The purpose of the PP with regard to public access appears to be to make it very difficult for the public to access the surrendered land.
1.1 Inadequate Public Access; Include a-b-c-d and other access, etc: The Mt Hutt Range, including the wildlands to be surrendered, are an important actual and potential area for hunting and other outdoor foot recreation. NZDA notes that no specific public access provisions are made in this PP (marginal strips are not a mechanism of tenure review under the CPLA, and do not always provide adequate public access). We are very concerned that the PP ignores public access, because the Conservation Resources Report states public access is an important issue viz:
Several important public access routes to both proposed conservation areas and existing retired land require negotiation on Redcliffe Station. These can be protected by access easements and are recommended:
1. From Double Hill Run Road to Hutt Stream catchment reserve This would ensure that the public could gain access to the retired country of Mt Hutt Range
2. From Redcliffe Stream paper road to the Rat Hill reserve
3. From Swift River, up McLennan Stream to the retired country
None of these access ways are provided for in the PP, via CPLA mechanisms. In fact no easements at all are provided for the public in the PP.
NZDA requests that access easements under the CPL Act be provided for these three important public access ways. The farm track Easement a-b-c-d is more direct and easier than the difficult marginal strips up Redcliffe Stream. This DOC only easement must be a public access easement as well, not just DOC's.
Foot access up the farm track east of Terrible Gully, to point V, is also needed - or the nearby farm track identified in the Christchurch Tramping Club submission. This would allow greater ability for round trips, as well. Without better public access, the Tourism concession is being made exclusive to the owner of the freehold, by inadequate provision of public access over that freehold.
NZDA expects that there will be chamois and red deer on parts of the surrendered land. They are there at present, and they will be present in future, given the area is within the wild range of both species.
1.2 Vehicular Access for Recreational Hunters: NZDA's Code of Ethics requires that, normally animals taken should "endeavour to make full use of the game taken." Ability to use a vehicle for taking carcasses out would significantly increase hunting pressure. We ask that this be allowed, as a management purpose when a hunting permit is issued to shoot on this surrendered land, and adjacent public land. This would allow hunters with permits to access a-b, c-d to the high surrendered land.
1.3 Outstanding mountain landscape, and Amenity Value: The eastern side of the lease is visible from the Rakaia Valley and is certainly a nationally outstanding landscape. As well the proposed surrendered land will provide viewpoints from which the land, and the Upper Rakaia Basin can be viewed. It has high amenity value as a result. All the surrendered land has high value for extensive recreation, including big game hunting, tramping, walking etc
1.4 Tourist concession should not include land deemed to have been surrendered in 1986: NZDA is surprised that 4950 Ha of land that should have been surrendered from this lease ie more than half the lease area, was not surrendered in 1986. We note, that as this area has been deemed to have been surrendered, and is therefore deemed to be Conservation land, and not part of this tenure review, it should not be subject to the tourism concession that is part of this tenure review.
However, we see that it has been wrongly included (Tourism concession Schedule 1, Item 1 Land = 7,724 Ha). Only (7,724 - 4950) = 2,774 Ha should be in the Tourism concession. Also, nowhere in the PP is the area deemed to have been surrendered actually shown. If this area was truly not part of the TR, then it should have been completely excluded, and shown as a separate public Conservation Area. The lessee is getting a second bite at the cherry.
2.1 Surrendered to scenic reserve - SR1 (109 Ha); SR2 (4 Ha)
2.2 Surrendered to Conservation Area - 7,724 Ha, (2,774 Ha if take off the 4,940 Ha that should have been surrendered), subject to a 10 year recreation concession for guided hunting & tramping. Rises to Mt Hutt (2,185 m) and north end of the Mt Hutt Range, Mt Bruce (1,829 m), Mt Hecla (1,734 m), Steepface Hill (1,876 m). Includes 4,950 Ha of land notionally surrendered in 1986, which was not legally surrendered. Also noted - a covenant at Cookies Flat, that was never set aside.
2.3 Freeholded - 1,355 Ha of the 9,192 Ha minus the 4950 Ha that was not surrendered in 1986, when it should have been ie 4,242 Ha. Easement for DOC (a-b, c-d), none for the public, who have to use a marginal strips up either Redcliffe Stream (North west) or Hutt Stream (east). New fencing required along the eastern side of the freehold.
No public access provided via the CPLA.
Deerstalking and hunting of deer, tahr, chamois etc is likely.
NZDA branches in this area that would/could hunt on the surrendered land include: Ashburton Branch, Malvern, North Canterbury, North Otago, Otago, Palmerston, Rakaia, South Canterbury, Southern Lakes (Queenstown/Wanaka/Cromwell). Ashburton Branch has a hut at Lake Clearwater (Chamois Lodge), built because of the big game animals available in the Mt Hutt area.
Other branches further away, or from the North Island also visit the area.
Tahr and deer hunting in this area would attract regional interest. Returning the proposed areas to full Crown ownership and management will provide hunters with the ability to hunt these areas, because they will become public park land.
NZDA is disappointed the CRR has almost nothing about actual or potential recreational use. The area is within 80 minutes drive of Christchurch, and provides some of the highest peaks so close to the City.
4.1 Inadequate Public Access: It is essential better public access be provided, for example, as set out above. Adequate public foot and vehicle access is needed to the proposed surrenderted land from the east., north, west, and south.
The present lack of reasonable public access is counter to the requirements of the Crown Pastoral Lands Act (CPLA). It includes in its objectives
"The securing of public access to and enjoyment of reviewable land"
In many tenure reviews, only limited access is provided which does not meet these objectives. The mechanisms provided for in the Act for public access are limited to (S 2 "protective mechanisms" - (a) Easements under S 12 of the Reserves Act; S 7 (2) of the Conservation Act; or S 8 of the Walkways Act. All of these three mechanisms are for ordinary people, not super fit or super experienced outdoors experts.
Consequently the CPLA is clear that access provided should be suitable for optimum public use bearing in mind that the land in question is often rugged. The Department of Conservation (DOC) is responsible for reporting to Land Information New Zealand (LINZ), which administers pastoral leases, about public values including recreation and access. DOC's own manual for tenure review states:
"All areas to be restored to Crown ownership as conservation area or reserve should have legal, practical and reasonably convenient public access secured where it does not exist at present".
This is manifestly not occurring in this PP. Access is inconveniently located along flood prone and steep/rugged marginal strips, or unreachable legal roads. There is better access available via farm tracks on easier ground. On Redcliffe no CPLA access is provided where a minimum of two routes are needed for "recreational enjoyment" (such as round trips) and mountain safety reasons. The public access proposals in this PP are unacceptable, and must be revised to meet adequate standards, eg as proposed above.
4.2 Surrendered Land Unsuitable for sustainable use: NZDA strongly agrees that the land proposed for surrender is unsuitable for sustained production, and should be surrendered. It also has high actual and potential value for hunting and other outdoor recreation activities.
Thanking you
Yours truly
Dr Hugh Barr
National Advocate
© 2011 New Zealand Deerstalkers' Association