Submission on the Draft Tourism Environment Action Plan
19 July 2023: Read the NZCA's submission on the Draft Tourism Environment Action Plan 2023.

The legislative basis  for the NZCA’s submission

  1. The New Zealand Conservation Authority / Te Pou Atawhai Taiao o Aotearoa (Authority, NZCA) was established under the Conservation Act 1987 (Act), with members appointed by the Minister of It is an independent statutory body with a range of functions, but primarily acts as an independent conservation advisor to the Minister and the Director-General of Conservation.
  2. The Authority has a role as an objective advocate on matters of national significance and interest in the conservation arena and to provide high quality independent advice to the Department of Conservation (Department, DOC) on its strategic direction and
  3. The Authority has a range of powers and functions, under the Act, as well as under other conservation related Under the Act (section 6C(2)(c) refers) the Authority has the power to “advocate the interests of the Authority at any public forum or in any statutory planning process.”
  4. Following the logic of the above powers and functions, the Authority submits on the Draft Tourism Environment Action Plan (Action Plan).

NZCA submission

  1. The Authority’s submission is based on its analysis of:
    • Draft Tourism Environment Action Plan He Āhurutanga Taiao, June 2023
  2. The Authority has an interest in tourism, and its impacts on Public Conservation Land (PCL) and Waters.
  3. Section 6(e) of the Conservation Act states ‘[…] the use of any natural or historic resource for recreation or tourism is not inconsistent with its conservation, to foster the use of natural and historic resources for recreation, and to allow their use for tourism’. The Authority has used this clause as its guiding principle when analysing the Action.
  1. The Authority acknowledges the importance of the tourism industry to Aotearoa from an economic, social and cultural The Authority is encouraged that the tourism industry is creating an environmental action plan which considers the future wellbeing of te taiao.
  2. Having said that, the Authority is concerned that there is little detail on how the industry intends to meet its stated commitments to te taiao in the short to medium term. The Authority does not subscribe to the view expressed in the plan that ‘it may be beneficial for the volume and economic value of an industry to grow, as it would mean that the environment receives a reciprocal benefit’.
  3. This submission addresses individual sections as set out in the Action

Tīwaiwaka Principles

  1. The plan rightly notes that Aotearoa’s natural environment is a key reason many international visitors travel to The Authority is encouraged that the plan places Principle 1 (‘Caring for the whenua is the first priority’) as the top guiding principle in the plan and that everything should be measured against this.
  2. The Authority notes that many of the natural environment locations that attract visitors are located on PCL.
  3. The Authority is of the view that Principle 1 should reflect not only the whenua but should also include the native flora and fauna that depend on the whenua for their continued
  4. However, it is unclear what Principle 1 really means in practice. The plan acknowledges the importance of te taiao, but there are no clear strategies or action plans to ensure this principle can be achieved either in Aotearoa in total or at specific places. The risk is that the tourism industry will use the ‘caring for the whenua’; to promote its activities, whilst undertaking little real action to ensure its protection.

Regenerative Tourism

  1. The Authority cannot currently see from reading the Action Plan how regenerative tourism will leave the environment better that it was before, and that the net benefit of tourism can be positive to the environment.
  2. Though the plan references the management of visitor numbers, the Authority notes that a key unanswered question is how much tourism PCL, especially national parks, in Aotearoa can sustain.
  3. During the pandemic, with fewer visitors, Papatūānuku was provided time to breathe and With a lack of detail in defining what Regenerative Tourism is, the Authority is concerned that the current action plan may allow for high volume and environmentally impactful activities to return and put Papatūānuku at risk again.

Tirohanga Hou

Tourism Journeys are Decarbonised

  1. The Authority is concerned that this Tirohanga Hou, and the focus areas within it, are highly ambitious with long timeframes. Some of the solutions described to decarbonise tourism journeys (e.g., development of low carbon fuel and decarbonising aviation) are dependent on research and developments outside of New Zealand. A step change is needed globally to achieve real progress on decarbonisation of travel, but in the intervening period negative impacts on the environment and biodiversity need to be carefully managed.
  2. Further, the summary refers to New Zealand’s commitments under the Paris Agreement to limit global warming to 1.5°C by 2050. New research shows that global warming is likely to reach that figure in the first half of the 2030s1. So, while the Authority supports the current 1.5°C limit, we believe the Tourism Environment Plan should be more ambitious than it currently is.
  1. The Authority seeks clarity from the tourism industry on the proposed short to medium- term solutions to address this Tirohanga Hou whilst ambitious, longer-term solutions are developed. Te taiao cannot wait for the industry to de-carbonise.
  2. In reference to focus area C: the Authority notes that many visitors (both domestic and international) visit PCL, which tends to be in rural areas where there are often currently no public transport networks. Further, where private vehicle use is required to access rural areas, the infrastructure to support electric vehicles (i.e. charging stations) and alternative fuel options is not available. There is a need for greater Government and industry investment in travel solutions other than cars, such as electric or alternative fuel powered public and group transport options.
  3. In reference to focus area D: more research is needed to assess the full impact of international visitors on te taiao. In the meantime, the Authority recommends a highly precautionary approach to visitor numbers to prevent the potential for irreversible
  4. The Authority recommends that the Government utilise Qualmark (its existing auditing and quality assurance organisation for the tourism industry) to implement emissions standards as a part of its accreditation criteria.

Tourism Champions Biodiversity

  1. The Authority agrees that tourism can, and should, play a role in protecting and enhancing te taiao, but this should go beyond creating environmental awareness. The Authority is concerned that the actions in this Action Plan are not strong enough to result in a net positive gain for PCL.
  2. At a recent meeting of the World Commission on Protected Areas (WCPA) held in Bishkek, Kyrgyzstan, it was recognised that in order to meet the Kunming-Montreal Global Biodiversity Framework of ‘30x30 by 2030’, the world will need to double the number of people working in conservation in the next seven years.2 Therefore, New Zealand has a lot of work to do to meet any commitments it may make in this field.
  3. The Authority is encouraged that the Action Plan acknowledges that New Zealand’s unique biodiversity is at However, when considering a regenerative tourism model, thought needs to be given to how this model could impact biodiversity. For example, building larger carparks or hardening tracks may assist in supporting increased visitors to PCL sites. However, increasing infrastructure is damaging to te taiao and biodiversity and is not sustainable.
  4. This section refers to ‘voluntourism’ and certification schemes so that consumers can identify which operators are acting on climate change and biodiversity. However, it is unclear if any research has been done to demonstrate that international visitors have an appetite to undertake activities which contribute to the environment, or support operators based on their contributions to the environment. For example, do we know that visitors would choose a tourism operator based on a green certification over a cheaper alternative?
  5. The Authority is concerned that the action plan does not address the documented negative environmental impacts of tourism in Aotearoa. 3 4 Whilst the Authority acknowledges that the Department of Conservation is under-resourced, there is concern that a visitor funded model could result in perverse outcomes.
  6. The Authority also does not support the need for the development of tourism biodiversity kāhui. The Authority believes that existing organisations such as DOC, TIA and TNZ utilising Qualmark as the implementation tool is a more effective solution to ensure biodiversity outcomes for the tourism industry.

Visitor Management is Optimised for Te Taiao

  1. The Authority supports a future where te taiao is prioritised when considering visitor carrying capacity, particularly at locations that have high-risk biodiversity.
  2. The Authority supports the principle of booking systems and supports using pricing as a lever to manage visitor volumes. The plan mentions ‘healthy levels of visitation’, but nowhere is this clearly defined, and no specific actions are proposed to determine what ‘healthy’ means in this context.
  3. The Authority is pleased that the Action Plan acknowledges that prioritising growth in visitor numbers or economic returns over te taiao will damage the industry’s ability to connect visitors to the environment. The Authority is also pleased that the plan acknowledges that unsustainable visitor numbers can damage our biodiversity.
  4. However, the Authority is unclear on how this will be measured and monitored in practice. Who will be the responsible party to determine what is sustainable and subsequently have the authority to act when needed?
  5. When considering the management of visitor numbers, the Authority seeks further clarity on plans for the differentiation between international and domestic visitors. New Zealanders should not feel displaced or shut out of their own country, especially PCL.

Accelerated Technology and Innovation Uptake

  1. The use of technology to shift visitors away from popular sites risks widening the negative impacts on te taiao by shifting the problem to other sites. The Authority is concerned that the dispersal of visitors across more sites on PCL could lead to damage, specially to sensitive locations that cannot sustain high levels of visitation. DOC needs to be fully engaged in any technological changes that may contribute to a dispersal of the negative impacts of tourism.

The Tourism System and its Levers are Optimised

  1. The Authority is concerned that the table on page 78 does not see DOC as a key central government organisation with tourism functions, relegating it rather to a lesser group of “Other government agencies [with] key public tourism assets …”. The Department manages 1/3 of New Zealand’s total land area, including 13 national parks, eight Great Walks, thousands of kilometres of tracks and over 1000 huts and campsites – and these are a major drawcard for many international By default, it has become a “tourism organisation”.
  1. Climate Change is Speeding Toward Catastrophe. The Next Decade is Crucial, U.N. Panel Says NY Times (Accessed 18 July 2023)
  2. Lou Sanson (NZ Delegate) pers. comm. 5 July 2023
  3. Parliamentary Commissioner for the Environment (2019) Pristine, popular…imperilled? The environmental consequences of projected tourism growth. 
  4. Parliamentary Commissioner for the Environment (2021) Not 100% - but four steps closer to sustainable tourism