Submission from Central Otago Environmental Society Inc
P O Box 10
Omakau, Central Otago

Ministry of Economic Development
PO Box 1473
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Wellington 6140
 

Dear Sir or Madam:

Key messages

·       Schedule 4 lands - just 13% of New Zealand's total land mass - represent this country’s most significant conservation lands. They warrant protection from mining and exploration with a view to mining. They are simply too precious to mine.

·       Our members are active in conservation and along with the many before us have fought hard to protect these special areas. They underpin our valuable 'clean green' image and our tourism industry's '100 % Pure' brand. It is crazy to put this at risk for short-term profit. Our protected areas must remain protected.

·       All of the areas proposed for mining have outstanding conservation values, which is why they were originally protected – let’s keep them that way.

·       Schedule 4 was put in place by a National Government to protect and safeguard the future of our core public conservation areas – it is grossly irresponsible to attempt to reverse this protection now.

·       We believe that Schedule 4 lands are worth more by remaining intact, providing species habitat, opportunities for recreation, tourism income and ecosystem services.

·       As collective custodians for future generations we ask that you please safeguard these important values by ensuring their future protection.
 

Proposed removals from Schedule 4

We oppose the Government’s proposals to remove areas from Schedule 4 mining protection. Land included in Schedule 4 is, by definition, land of the highest conservation value, protected by national park, reserve, or wildlife sanctuary status. In order to be recognised as a national park, an area must contain “scenery of such distinctive quality, ecological systems, or natural features so beautiful, unique, or scientifically important that their preservation is in the national interest” (National Parks Act 1980, s4). In order to be protected as a nature reserve, an area must be home to “indigenous flora or fauna or natural features that are of such rarity, scientific interest or importance, or so unique that their protection and preservation are in the public interest” (Reserves Act 1977, s20). Every conservation park shall so be managed that its natural and historic resources are protected; and to facilitate public recreation and enjoyment (Conservation Parks, s19).

In all cases, the land must be protected in its present natural state, and its environmental and scenic values, its flora and fauna protected in perpetuity. Any form of mining is clearly inconsistent with this purpose and seen as a personal betrayal in terms of the covenant agreed for our generation and those to come.
 

We therefore oppose the Government’s proposals to remove the following areas from Schedule 4:

·       The Inangahua sector of Paparoa National Park

·       Otahu Ecological Area and Parakawai Geological Area in the Coromandel

·       The other seven areas in the Coromandel Peninsula totalling 2,574 hectares

·       Te Ahumata Plateau on Great Barrier Island
 

In regards to the specific areas:

·       The areas in Paparoa National Park are unique for their water-sculptured limestone and karst systems, a distinctive Jurassic like landscape that contain intact podocarp forest and endangered ferns, and provide vital habitat for threatened birds, including Great Spotted kiwi, Kaka and Keruru. This is an area many hold dear, especially those whose families go back several generations, as well as others who desire to enjoy the special character and distinctive features of this West Coast treasure, and to see that they are retained in perpetuity for many generations to come. Mining for coal is irresponsible as the climate change emissions will be significant. All told the result would be short term monetary gain and long-term intergenerational theft and ruination of a unique landscape and ecological sequence.

·       The Otahu Ecological Area is home to kiwi and the Hochstetter’s frog. This ecological area helps to preserve an intact natural sequence of aquatic habitat from the mountains to the sea. The Parakawai reserve also contributes to this sequence.

·       The areas in the Coromandel are home to kiwi, the Hochstetters and Archey’s frogs, and have significant ecological and recreational value. The area has huge value as a wild and natural region close to major population centres, providing scenic, recreation and wellbeing opportunities.

·       The Te Ahumata plateau on Great Barrier island is part of the Hauraki Marine Park. The area includes critical habitat for the brown teal, an endangered species. There are estimated to be less than one thousand adult brown teal remaining in the wild, making any removal of habitat a real threat to the species’ continued existence. The area is also home to plants found only on the island, for instance the Great Barrier Island tree daisy and the Great Barrier Island kanuka. The islands are invaluable in terms of repositories isolated from mainland threats and man’s ever-increasing, frequently despoiling footprint and presence. Mining would do irreparable harm to the island’s ecosystem and its tourism reputation.
 

All of these areas have significant ecological, recreational, tourism and cultural values which would be fatally compromised by mining. These values far outweigh their potential exploitive mineral values. They should not be despoiled in this fashion. Nor should we be saddled with the reparation, and the environmental risk associated with the mining waste and associated access infrastructure. Schedule four protection must be permanent and never removed.


Proposed additions to Schedule 4

We support the addition of core protected areas to Schedule 4, as was intended by Parliament.
We recommend that all places that match the types listed in Schedule 4 should be automatically added to Schedule 4 when gazetted to ensure protection from mining. This includes all new marine reserves, national parks, nature reserves, scientific reserves, wilderness areas, wildlife sanctuaries, internationally significant wetlands and any additions to these areas.
We also recommend that the following high-value conservation area types are added to Schedule 4: national reserves such as Lewis Pass; all of our World Heritage areas (Te Wahipounamu, Tongariro and the Sub-Antarctic islands), and all ecological areas.

 
Areas for further mineral investigation

We oppose the Government’s proposal to subsidise the minerals industry by spending $4 million to investigate the mineral potential in any of our public conservation areas. Public conservation land, especially Schedule 4 areas such as Rakiura National Park, belongs to the people of Aotearoa/New Zealand for recreation and tourism, not mining. Rakiura must remain protected now and for future generations. It would be a travesty to disturb the bird song of Rakiura with mining machinery. Those who have served as nest minders to the Kakapo, the world’s rarest most endangered bird, and experienced the Whenu hoe Island dawn chorus, will attest that there is no choice but conservation.

Conservation land is for protection, not mining exploitation.
 

Joint Ministerial approval for mining permits

We oppose the proposal for joint Ministerial approval for access to public conservation land. We agree with the Parliamentary Commissioner for the Environment that public conservation land is held in trust by the Minister of Conservation on behalf of the New Zealand public. It is for the Minister of Conservation to decide who should or should not have access to it. It is inappropriate to hand decision making power over activities on conservation land to Ministers engaged in promoting ecologically destructive industrial activities.

Schedule 4 land is managed by the Department of Conservation for conservation purposes. Joint approval would create a significant risk of those purposes being supplanted by other purposes contrary to those of the Conservation Act. Outside of conservation areas we all too often see environmental considerations overridden by pressures for economic growth of the kind that is not sustainable long-term. New Zealand society has a contradictory, irrational approach to our environment. On the one hand we value, set aside and protect areas of high conservation value – implicitly recognising their highly productive and priceless life-sustaining natural capital – while on the other we systematically degrade and unsustainably erode that natural capital, as shown by the key indicators of this nation’s true environmental health. Sadly, misguidedly, all of this is carried out in the name of ‘growth’ and increased productivity.

The Department of Conservation as represented by its Minister is the effective custodian of conservation land held in trust for the people of New Zealand. It’s entirely appropriate that the Minister should act in accordance with the expert advice of his, or her, department, and assess whether mining is compatible with the purpose for which the land is held.

Joint or dual Ministerial approval would muddy Parliamentary accountability for decisions to grant access to, or alter the classification of high-value conservation land. Ministers could point the finger at one another, and accountability left muddied, in disarray. We argue this would be a marriage certain to founder and fail.

 
Conservation fund from mining royalties

We support the proper funding of the Department of Conservation to carry out its central role in protecting and maintaining our public conservation land and its precious plants and animals. The  $53 million cut from the department’s budget should be restored. Conservation should not rely on mining royalties. Providing a conservation fund from mining royalties falls well short of protecting our precious natural heritage. We do support a genuine community conservation fund, but not as a reason to allow mining. Existing conservation land must continue to be protected.

Conservation is a community wide responsibility working in conjunction and along side the Department of Conservation. We ask that you abandon the contestable conservation fund, restore the $4million per annum Community Conservation Fund as negotiated by the Green Party, and reinstate DoC’s 2009 budget cut of $53 million.

 

Areas proposed for addition to Schedule 4

It’s hard not to see this as a bribe when these additions were due to come about anyway. They are overdue and the Crown Minerals Act should be amended to make such additions automatic.


Additional recommendations

·       We ask for the opportunity to be notified of applications to mine any public conservation land. Mining is the only activity that is exempt from public processes and this privileged status should be revoked.

·       We ask for a law change to prohibit all open-cast mining and tailing dams on public conservation land.

 

signed on behalf of the Central Otago Environmental Society Inc.

         Dr. Richard Kohler, President COES