Submissions: To the Department of Conservation Hokitika on their Intention to grant concession to; AIRWALKS NZ LTD: to allow the operation of an aerial walkway and associated structural infrastructure in Hokitika Gorge Scenic Reserve

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Our Background and Interests

Federated Mountain Clubs (FMC) is the national alliance of tramping, mountaineering and alpine clubs. FMC also has some skiing, canoeing, sea kayaking and mountain biking clubs in its membership. FMC was formed in 1931 to advocate for outdoor recreation and for the public ownership, protection, management and control of our natural wild lands in perpetuity and subject to that, use for public re-creation and enjoyment. FMC has been a major player in the development of our National Parks, Forest / Conservation Park network. FMC is constitutionally committed to the protection and environmental enhancement of our indigenous wild lands, foreshores and coasts for the enjoyment and re-creation of all New Zealanders. We represent about 12 500 club and individual members throughout New Zealand.

This submission opposes the whole of all of the concession application

Many of our members recreate in the backcountry, front country, coasts, gorges and rivers. The Hokitika Scenic Reserve is protected, we thought under the terms of both the Conservation act and Reserves act, from the type of high impact development proposed in this application. The Federation is concerned at the potential precedent set should this application be granted.

Rationale -

Social Impacts:

The clearance of the vegetation and imposition of buildings and steel structures and jetties will lessen the value of the scenic reserve as a place of quiet enjoyment in an easily accessible area in it's current state of significant inherent value. The intrusion of large crowds resulting from the necessary high volume marketing of the proposed "tourist attraction", in order to satisfy investment returns, some $5 - 6 million in this relatively pristine natural area will impact in a way that is contrary to the reason why the land was gazetted and will effectively convert the area to another use that will not meet the needs of the many New Zealanders in the way that it does now and was intended. A significant change will occur and an ever rarer amenity will be lost to complex infrastructure and development something the Scenic Reserves were gazetted in order that they remain natural, intact and free from this very type intrusion.

Exclusive Possession:

The Company is seeking exclusive possession of parts of the site and the Federation is opposed to this intrusion into public Scenic Reserve Land, it is wrong and inappropriate, in this location to effectively, privatise Reserved Public Scenic Reserve Land.

Public Access:

The Federation opposes any loss of public vehicle access to this site and the Whitcomb valley beyond by vehicle on public road. The ability to freely drive to the end of the road now and enjoy the area at it's current level of development is something that is valued by our members and the wider public. The vehicle access now is adequate for the purposes of the Scenic Reserve, allowing those of all abilities to access it and the Whitcomb Valley beyond.

Alternative sites:

The Federation is aware that this type of activity has been proposed and approved further south on the West Coast at Franz Josef, it would surely be more appropriate and supported at another location closer to the state highway on public or private forested land of a lesser status than the site proposed at the Gorge. Conservation Act Seec. 17 u "The Minister shall not grant any application for a concession to build a structure or facility, or to extend or add to any existing structure or facility, where he or she is satisfied that the activity- (a) Could reasonably be undertaken in another location that- (i) Is outside the conservation area to which the application relates; or (ii) Is in another conservation area or in another part of the conservation area to which the application relates, where the potential adverse effects would be significantly less." The Federation is of the view that a more appropriate site, from the New Zealand public's view point, would be available and that the company needs to move its proposal to another location in order to be consistent with the Conservation act sec 17 (u). Reserves Act 1977 The Federation is of the view that this activity would be contrary to the Reserves act in particular. Sec19.1a " For the purpose of protecting and preserving in perpetuity for their intrinsic worth and for the benefit, enjoyment, and use of the public, suitable areas possessing such qualities of scenic interest, beauty, or natural features or landscape that their protection and preservation are desirable in the public interest". The preservation is in the public interest, in this case the Hokitika Gorge Scenic Reserve, is appreciated and valued by the public all over NZ for its raw natural beauty and uncrowded and very limited developed nature, to be enjoyed on it's own terms, preserved as naturally as intact as possible.

Outcome sought:

FMC believes that this proposal should have been declined at an earlier stage and that this would be consistent with the legislation. The DoC's interpretation of the legislation and the public value of this area has been misjudged and undervalued by the DoC in allowing this application to proceed to this stage. It is unfortunate that considerable time, energy and angst has to go into the advocacy for Wildland Conservation when it is already protected in law. The interpretation of the law on the side of preservation and precaution, in the public interest, needs to be adopted in this case.

FMC requests that the application be declined.

We wish to be heard should a hearing be convened. Yours sincerely Barbara Marshall Secretary