If you draw a line from Hokitika to Timaru, nearly everything south of it makes up about a third of New Zealand’s land—the same amount that DOC manages on just 0.05% of the national budget. Its network of backcountry tracks is seven times longer than State Highway 1, and our national conservation land provides an estimated $11 billion of tangible and intangible services in value annually.

Despite years of underfunding, DOC is now expected to operate on an even tighter budget while also generating new revenue. Over the past two years, it has increased hut and campsite fees, reintroduced charges for under-18s, and reduced volunteer discounts. Now, it is proposing hut fees for basic huts and bivvies and considering charging for access to some public conservation land as part of a government-mandated 6.5% budget cut.

FMC has prepared a submission with detailed feedback on the access charging proposal.

Main Points of FMC’s Submission

FMC does not support general access charges for public conservation land. Our key reasons include:

    1. A national treasure, not a commercial asset: Conservation land belongs to all New Zealanders and should be protected for future generations, not treated as a revenue source.
    2. Public access is a legal right: New Zealanders have a statutory right to visit conservation land under the National Parks Act, Reserves Act, and Conservation Act. While overseas visitors are welcome, their access should not compromise the rights of New Zealanders.
    3. DOC’s duty to foster recreation: DOC is legally required to encourage outdoor recreation. Access to conservation land improves wellbeing, provides connection with our culture and history, and increases the sense of belonging and identity. Any facility charges must be fair and equitable, ensuring volunteer and lower income groups are not excluded.
    4. Conservation first, tourism last: Legislation prioritises conservation: protecting natural values comes first, recreation second, and tourism third. Access charges should not undermine this hierarchy.
    5. Decisions must be based on accurate data: DOC must collect reliable data rather than relying on rough best-guess estimates before proposing new revenue measures.
    6. Recognizing the role of volunteers: DOC should acknowledge and support the critical role of volunteers in conservation work.
    7. Better revenue sources exist: DOC should increase revenue from concession activities and improve compliance monitoring. The International Visitor Levy (IVL) is a simple, efficient way to fund conservation efforts and should be used to maintain key facilities at popular locations.

Issues with Charging and Congestion

FMC acknowledges growing pressure on conservation land from increasing international visitor numbers. However, access charges alone won’t solve this complex issue.

DOC’s approach — expanding facilities and adding more huts and campgrounds to the booking system — won’t curb demand, it will amplify it. A broader, systemic approach is needed, including a national discussion on sustainable visitor numbers given New Zealand’s limited resources.

A general access charge would create compliance and enforcement challenges, likely costing DOC more than it generates. Without additional measures, fees alone won’t effectively reduce congestion.

We urge DOC and the government to explore alternative congestion management tools, such as parking fees, while ensuring any restrictions (e.g. visitor limits) apply only to key, named destinations which are clearly defined in legislation.

Differential pricing — charging only international visitors — raises practical issues, and charging domestic visitors could backfire in multiple ways.

Finally, DOC must assess whether introducing access fees alters its legal responsibilities under health and safety laws.

We believe a reassessment is needed regarding DOC’s approach to the budget deficit and its proposed solutions. Specifically, we disagree with how the issue has been analysed in the following areas:

  • Expenditure: The connection between DOC’s goals, outcomes, and delivery is weak, partly due to inadequate data.
  • Backcountry network: While the backcountry hut and track network is in its best condition in years thanks to volunteers, we see no need for it to be replaced. However, more planning is required to enhance resilience, particularly in response to increasing severe weather events. 
  • Congestion: Congestion reflects a broader issue—the environmental and social costs of rising international visitor numbers. A national discussion is needed to determine a sustainable visitor volume and tourism model that offers a net economic benefit to New Zealand.

We encourage you to write your own submission. If any parts of the above summary or FMC’s submission resonate with you, you are most welcome to use them. Submissions can be sent to accesschargingconsultation@doc.govt.nz by 5pm Friday 28th February.

You can find our submission here.

Photo: Fox River, David Caruthers