National Park or Amusement Park?

I strongly oppose the application from Riverstone Holdings Limited for a concession to build a monorail through the Snowdon Forest Conservation Area on the following grounds:

1.    The application has huge implications for the immediate environment and although the monorail will be built within a Conservation area it will not benefit the majority of New Zealanders who would visit the region but will generally cater for the wealthy elite of the tourist market.

2.    The construction of the monorail may take many years and have a negative impact on all those visiting the area over that time, including the potential restriction of access do due safety concerns.

3.    The current transport infrastructure is adequate for accessing Milford Sound and when compared to similar areas internationally, travel times are not excessive. We should encourage tourists to stay in places outside Queenstown and the existing route to Milford Sound, through rural New Zealand, is widely admired for its own beauty. The need for an alternative transport route is not convincing and the monorail appears to be promoted as an attraction in its own right and is not compatible with Section 17 U( 4) of the Conservation Act 1987 that provides that a concession application to build a structure or facility should not be granted if the activity could reasonably be undertaken in another location that:

a.    Is outside the conservation area to which the application relates; or
b.    Is in another conservation area or in another part of the conservation area to which the application relates, where the potential adverse effects would be significantly less.

4.    This project goes against the philosophy and values of our conservation areas by introducing an unnecessary manmade structure and is incompatible with Section 17 (U) (3) of the Conservation Act 1987 that states ‘The Minister shall not grant any application for a concession if the proposed activity is contrary to the provisions of this Act or the purposes for which the land concerned is held.’ The land is held as Conservation Land and is part of Te Wahipounamu South West World Heritage Area. The World Heritage Committee gave our southern national parks World Heritage status because they were "natural areas of outstanding universal value protected against the threat of damage in a rapidly developing world."
5. Even though it is estimated that the proportion of forest that would be removed is a small percentage of the total conservation area (around .05%) the 22 hectares (22,000 m2) is still considerable as is the 32.3 hectares of total vegetation that will be cleared. This is a large loss of habitat.

6.  If this application is successful it will also open the conservation estate for further development under the 1997 Ngai Tahu Deed of Settlement. Under sections 5.2 and 5.3.1. the Minister for Conservation cannot withhold consent to a similar project from this iwi:

5.2     If the Minister undertakes, or permits any other person to undertake, any development in the conservation area bordering the Land which is in the same visual catchment as the Land when seen by a person standing on the land, the Minister will not withhold consent under clause 5.1 for any proposed development by the Landholder on the Land which is of the same type as, and which has no greater impact on the natural landscape character referred to in clause 5.4 than, the development undertaken or permitted by the Minister

5.3.1   If the Minister permits the undertaking of any development of any form of road or railway between Lake Wakatipu and the Milford road through the Snowdon conservation area (the permitted development), the Minister will not withhold consent under clause 5.1 for any proposed development of the same kind or a similar kind by the Landholder on the Land if the area affected by the permitted development has ecological and recreational values of equal or greater significance to those development, and the Landholder's proposed development has no greater impact on the environment than the permitted development.

The fact that Skyline Enterprises/Ngai Tahu Holdings have a proposal for a gondola in the Caples-Greenstone, accepting the Riverstone Holdings application could force the Minister to accept the other.

7. The use of the monorail construction track as a recreation mountain bike track is nonsensical when the majority of mountain bikers would find riding beside a monorail track diminishes the experience of being in a natural environment. 

While the consents and submission process is bound to looking at each individual project on its own merits and impacts, it has to be recognized that there has been a documented shift in the way our conservation estate is being governed. Money has been cut from the government departments that have conservation responsibilities and the efforts to preserve our natural heritage for future generations have been increasingly constrained.

The fact that commercial interests are being considered above environmental impacts and what would be in the interests of public good, causes me some concern. When there are so few areas of natural wilderness left in the world, that suffer little in the way of human impacts, it is important to preserve the those that remain. The monorail proposal will not support this worthy goal.

I would be grateful if this submission receives due consideration


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