TIA makes tourism-focused submission on Conservation Amendment Bill

The Chief Executive of Tourism Industry Aotearoa (TIA) has made a submission to the Environment Committee on the Conservation Amendment Bill, outlining the body’s concerns around the proposed legislation.

Rebecca Ingram spoke on behalf of TIA, which represents around 1200 tourism businesses across the motu.

In the submission, Ms Ingram outlined that New Zealand’s natural environment is the foundation of many of its visitor experiences, and so tourism operators have a strong interest in seeing conservation protected and enhanced.

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“Retaining the status quo is not our preferred outcome,” she said.

“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.”

The submission outlined three main concerns from TIA, centred around conservation, concessions and the International Visitor Levy.

Conservation must remain the foundation

TIA’s first concern related to 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,” Ms Ingram stated in the submission.

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“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.”

Concessions and investment certainty

TIA strongly supports the intent of modernising concessions, their submission stated.

“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.”

Ms Ingram’s statement also discussed both competitive allocation, which she described as “entirely appropriate in some circumstances,” and pre-approved concessions, but called for the need for clarity and certainty around their processes.

International visitor access levy

TIA conditionally supports the proposed international visitor access levy, subject to three criteria, Ms Ingram said.

“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.”

Getting the statutory framework right

The submission also recognised that “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.”

In summary, Ms Ingram said, “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.

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