Oral Submission To The Environment Committee: Conservation Amendment Bill

Rebecca Ingram, Chief Executive, Tourism Industry
Aotearoa

Chair and members of the Committee, thank
you for the opportunity to speak today. 
My name is
Rebecca Ingram, Chief Executive of TIA.
TIA is tourism’s
peak body, representing approximately 1,200 tourism
businesses throughout New Zealand.
So tourism and
conservation are deeply connected. New Zealand’s natural
environment is the foundation of many of our visitor
experiences, and tourism operators have a strong interest in
seeing conservation protected and enhanced.
Retaining the
status quo is not our preferred outcome. We strongly support
the direction of reform. Our submission is about getting the
settings right so that the system is more enabling and
efficient, while maintaining conservation at its
centre.

There are three areas want to focus on
today.

1. Conservation must remain the
foundation

Our first concern is the proposed function
requiring the Department to ‘…enable use and development
to the greatest extent.’

We support DOC having a
stronger and more active role in enabling appropriate
tourism activity. But, we think the wording in the Bill goes
too far. It potentially creates uncertainty about whether
economic development is being elevated above conservation
objectives.

Our preferred wording is simple: DOC
should enable use and development ‘…to the extent
consistent with conservation.’

Making this change
will give DOC a clear and positive mandate to recognise and
enable appropriate economic and tourism opportunities, while
establishing a clear conservation boundary. This is the
balance the legislation must strike.

2. Concessions
and investment certainty

TIA strongly supports the
intent of modernising concessions. Our comments relate to
concession system, both in terms of how concessions are
granted and how competitive allocation will work.

For
a tourism operator, a concession is the cornerstone of their
operation, which allows them to invest in all the
facilities, people and systems. Many concessionaires have
spent decades developing operations around particular places
and are genuine partners in conservation. They invest in
predator control, restoration projects, visitor education,
yet the current framework can feel more transactional than
collaborative.
Tourism operators are seeking a system
that recognises responsible operators as partners in
achieving conservation outcomes.

Here is an example of
how the current system can play out for a tourism
business:
We have a TIA member that has been operating
responsibly on PCL for around 40 years, including making a
tangible contribution to conservation outcomes. Following
the process outlined by DOC, they applied to renew their
concession that was due to expire in 2023.

DOC
initially offered a concession that in some cases reduced
their allocation by over 90%, completely devaluing their
business. It then took the next 2.5 years to prove their
case which highlighted inconsistencies in interpretation of
planning documents and the allocation of concessions for
other operators. They were finally granted a satisfactory
concession in June this year.
While individuals within
the Department were sympathetic and helpful, they were all
at the mercy of a broken system that was disempowering
businesses and frustrating the Department.

For this
reason gains around efficiency, statutory timeframes and
improvements to concessions granting processes are very much
supported. 
With regard to competitive allocation:
We acknowledge that competition may be entirely appropriate
in some circumstances. But operators need clarity about when
competitive allocation might occur, how decisions will be
made, and how existing investment and conservation
contributions will be recognised.
That certainty is
critical to continued investment in visitor experiences on
conservation land. We therefore ask the Committee to
recommend greater clarity in the Bill around competitive
allocation.

We have similar feedback about
pre-approved concessions. We support the principle. Removing
unnecessary bureaucracy for straightforward, low-impact
activities makes sense.
But the design needs appropriate
safeguards. 
In particular, a 12-month approval may
be too short to justify meaningful investment in staff,
equipment, safety systems and product quality. There is a
risk that a mechanism designed to make the system easier
could inadvertently favour short-term, low-investment
operators over businesses committed to a place for the long
term.

There are also questions around cumulative
effects, carrying capacity and how pre-approved activities
interact with existing concessionaires at busy
locations.

3. International visitor access
levy

My third area of focus today is the proposed
international visitor access levy. TIA supports the
principle, but our support comes with some important
conditions.

• First, the revenue should be
  additional to existing DOC funding. It should not simply
  substitute for Crown funding.
• Second, we believe
  there should be a strong connection between the money raised
  and the place where it is collected. If a visitor is being
  charged to access a place, they should be able to see that
  their contribution is improving conservation or the visitor
  experience at that place.
• And third, implementation
  needs to recognise how international tourism is sold.
  Tourism products are often priced, contracted and sold
  internationally well before the visitor arrives in New
  Zealand, sometimes years in advance.

Our
submission therefore recommends at least 18 months’ notice
before a new access charge takes effect so operators can
incorporate it into pricing and international contracts if
needed.

We also need to consider the cumulative cost
to the visitor, rather than looking at each charge in
isolation. An international visitor already pays the IVL at
$100 per person and may also face parking charges and costs
passed through from various concessionaires. An additional
access charge needs to be considered as part of that overall
visitor value proposition.

Getting the statutory
framework right

Finally, many of the practical
effects of this legislation will be determined through the
National Conservation Policy Statement, Area Plans, Visitor
Amenity Areas and future regulations.

We support
tourism and recreation being explicitly recognised within
the new planning framework. Not every operational detail
belongs in primary legislation, but Parliament does need to
establish the important principles and guardrails now. We
also think appropriate scrutiny and recommendation roles
remain important, particularly given the greater
concentration of decision-making authority proposed by the
Bill.

TIA strongly supports modernisation of the
conservation system.

We want a system that is easier
to navigate, provides greater certainty, encourages
responsible investment and enables tourism to contribute
more to conservation.

This Bill should proceed with
changes. Three things are fundamental:

1. Conservation
must remain the overriding purpose, while enabling economic
development

2. The concession system must provide
sufficient certainty to encourage long-term
investment.

3. And the new powers, planning processes
and visitor charging mechanisms need clear statutory
guardrails.

With those settings right, we believe this
Bill can deliver better outcomes for conservation, visitors,
tourism businesses and New Zealand.

For more
information, please contact TIA Communications Manager James
Craw – james.craw@tia.org.nz or 021 224 8056.

KEY
FACTS

• Tourism Industry Aotearoa (TIA) is
  Aotearoa New Zealand tourism’s peak industry body. We are
  the only independent association that represents all sectors
  of the country’s large and diverse tourism
  industry.
• TIA has about 1,200 member businesses from
  across the industry, ranging from small owner/operators to
  large publicly listed tourism corporates and international
  hotel chains.
• TIA leads implementation of the
  industry’s Tourism Sustainability Commitment, which aims to
  see every tourism business in Aotearoa New Zealand
  contributing positively to our people and cultures, our
  environment and our economy.
• TIA delivers a
  comprehensive range of industry events including TRENZ, New
  Zealand Tourism Awards, Discussing Tourism regional events
  and Tourism Summit Aotearoa.
• Visit www.tia.org.nz
  for more
  information.

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