Submission on Conservation Management and Processes proposals

FMC has written a submission on the Department of Conservation’s Conservation Management and Processes discussion document.

The discussion document presents three proposals whose stated aims are to make the legislation more workable and help the concessions management systems keep pace with societal and technological changes.

FMC’s detailed submission can be summarised as follows:

Amendment of a significant part of a legislative suite has intrinsic risks. The narrow focus on the immediate task can allow insufficient attention to be paid to the complete statutory picture, and for troubleshooting to be sub-optimal.

Indeed, the commissioning Minister of Conservation at the time of commissioning noted her general opposition to “piecemeal reform”. Despite the positive intent of the resulting Conservation Management and Processes discussion document, and its certain proposals of what FMC sees as real merit, our organisation’s view is that the commissioning Minister’s caution with respect to piecemeal reform was well-founded in this case.

As documented in our submission, it is not only that the work’s problem identification is flawed and that many proposed legislative changes could have sub-optimal outcomes; the overall relevant legislative intent is imperfectly represented, thereby undermining the work and public faith in it.

Federated Mountain Clubs therefore suggests that the Conservation Management and Processes work be reviewed in the light of concerns raised in the submission.

For more info on this submission, please contact FMC executive member Jan Finlayson at jan.finlayson@fmc.org.nz.

Photo at top: Looking down on Hawēa Conservation Park from Mt Gladwish (c) Myrthe Braam