FMC’s Submission on Modernising Conservation Land Management

In November 2024, the Government released a discussion document seeking public feedback on proposed changes to conservation planning and management. The focus is on streamlining the concession process, improving the conservation planning system, and clarifying how DOC will give effect to its Treaty obligations.

Federated Mountain Clubs (FMC) has summited feedback on the proposed framework, emphasizing the core values and principles that should guide conservation land management. FMC firmly believes that:

• Public conservation land belongs to all New Zealanders – it is a taonga and a national asset that must be protected for future generations, not treated as a commercial resource. Public should have a say in how it is managed.
• A clear hierarchy of responsibilities is essential – protecting conservation values must come first, followed by recreation, with tourism as the lowest priority, as set out in several Acts.
• Land should be protected in perpetuity – conservation decisions must take into account a long-term, multigenerational view, with independent oversight from the NZ Conservation Authority (NZCA) and Conservation Boards. 
• Concessions are a privilege, not a right – use of public land for commercial purposes must be carefully managed.

FMC broadly supports a simplified planning framework but highlights key areas of concern:

• Public consultation must remain central – NZCA and Conservation Boards must continue to play a key role in oversight, ensuring public input is upheld. Sufficient consultation time must be allowed and public notifications maintained.
• Fairer concession processes – we expect a fair and transparent concession process, especially when concessions are competitively allocated e.g. tendering, auctioning etc.
• Clarity is needed – many of  proposed changes lack clarity and more details are needed to assess their practicality  
• No land swaps or disposals – FMC strongly opposes these, as the criteria are subjective, open to misuse, and they impose an economic lens on conservation land value.
• Commitment to Treaty principles – how these are applied should be determined by iwi and hapū in line with the principles of kaitiakitanga and tino rangatiratanga. DOC must uphold Crown’s commitment of active protection and strengthening partnership.

In addition, FMC reminded DOC of other critical issues that should be addressed in this reform process.

We encourage you to write your own submission and welcome you to use any parts of our submission or key point above, if you wish. Submissions close 5pm on Friday, 28th February and can be sent to: landlegislation@doc.govt.nz

Our submission can be found here.

Photo: Ben Platt