30 November 2003
The Commissioner of Crown Lands
c/o DTZ New Zealand Limited
P O Box 27
ALEXANDRA
Dear Sir,
Re: Preliminary Proposal for Tenure Review of Mt Burke Pastoral Lease
On behalf of the High Country Landscape Group of the New Zealand Institute of
Landscape Architects, I make this submission on the proposed tenure review for the
Mt Burke pastoral lease.
We wish to have it recorded that we were refused access to look at this property.
We consider the process for this property to be flawed as we are unable to make
a full submission.
We appreciate nevertheless the opportunity to make this submission,
yours sincerely
Anne Steven
High Country Landscape Group NZILA
INTRODUCTION
This submission is made on behalf of the High Country Landscape Group (HCLG) of
the NZ Institute of Landscape Architects.
The HCLG was formed this year in direct response to mounting concerns over the
tenure review outcomes and process. The purpose of the group is to investigate and
report on high country landscape issues, and to advocate and advise on the protection
of landscape values.
We appreciate this opportunity to respond to the preliminary proposal for tenure
review of Mt Burke pastoral lease.
We did not attend an early warning meeting or submit a preliminary report with
respect to this property.
We wish to record that we were not permitted by the lessee to inspect the
property following advertisement of the Preliminary Proposal. Our submission is
therefore limited to what we could see from public places. We consider this
situation unacceptable as our assessment is incomplete and it removes
transparency from the process.
THE PRELIMINARY PROPOSAL
We understand the preliminary proposal to comprise the following:
 7340ha to be designated as unencumbered freehold (this represents over 70%
of the property, most of which is steep hill and rangeland)
 2657ha to be designated as conservation area (the Quartz Creek/Mt Burke
Creek area), with an easement for farm access along the true left of Quartz
Creek)
 a designated 1ha lakeside reserve accessed by dirt track from the end of the
Maungawera Road, on the north side of Quartz Creek mouth
 six small areas designated freehold with a conservation covenant over them, to
protect remnant shrubland and totara forest. These are “paper” covenants in
that the areas will not be fenced and no active management is proposed. They
would continue to be part of the wider area subject to pastoral land
management practices. There are three areas on The Peninsula and three areas
on the south and east side of the Maude range. The covenants only cover the
extent of existing vegetation. They do not include a buffer or context area, or
provide for future expansion.
 a large area of freehold designation (875ha) with a conservation covenant. It
comprises most of the East Wanaka Creek catchment including substantial
areas of Chionochloa macra tussock up to altitude of 1417m. About half of
this area is over 1000m altitude. The mouth of the valley is “cut off” by a new
proposed fence line that runs straight across the lower valley. The special
conditions of the covenant allow for topdressing and oversowing up to the
1000m contour, and grazing of the area. There is no fence proposed along the
1000m contour to prevent grazing of the snow tussock. There is no provision
for public access into this area apart from one easement along the true right
ridge line.
 several easements to provide for public access to proposed conservation areas
The preliminary proposal recognises and enables the protection of significant inherent
landscape values (SIV) over a large part of the lease, which we fully support.
There are significant parts of the reviewable land however which have SIV for which
protection is not being enabled nor provision being made for secure recreational
access to and enjoyment of these areas .
These areas are being proposed for freehold unencumbered or freehold with a
covenant that enables certain pastoral activities to continue.
These lands are described in the Preliminary Proposal as being “capable of sustaining
pastoral farming or other economic uses associated with tourism or rural residential
use.”
Our assessment of the proposal and the reviewable land concludes that there are
substantial parts of the proposed freehold that are not capable of sustaining such use
without significantly and permanently compromising the SIV of these areas.
In our opinion, the objects of the Crown Pastoral Land Act 1998 and the two new
objectives recently adopted by government will not be met under the current
Preliminary Proposal.
CONCERNS WITH THE PRELIMINARY PROPOSAL
The High Country Landscape Group has several concerns about the Preliminary
Proposal:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Inadequate recognition and provision for protection of significant inherent
landscape values of The Peninsula.
No provision for public recreational access on The Peninsula.
Inadequate recognition and provision for protection of significant inherent
values of the lake faces to the northeast of the isthmus.
The unique values of the isthmus are not recognised. Freehold tenure is not
considered to be the best use of this area.
Inadequate protection of the significant inherent values of East Wanaka
Creek catchment, with associated incoherent boundary line.
Inadequate recognition and provision for protection of significant inherent
values of lake faces on the east side of Stevensons Arm.
Inadequate recognition and provision for protection of significant inherent
values of the southwest side of Mt Maude and Little Mt Maude.
Inadequate recognition and provision for protection of significant inherent
values of Hawea Face (the east side of the Mt Maude ridge). We consider
that the sparing use of covenants is not adequate.
Absence of protection for low altitude kanuka.
Explanation
_____________________________________________________________________
1/2. Inadequate recognition and provision for protection of significant inherent
landscape values of The Peninsula. No provision for public recreational access on
to The Peninsula.
We find it astonishing that neither DOC nor LINZ have recognised and provided for
the protection of the high SIV of this iconic landform, and provided for secure
recreational access to and enjoyment of the area.
The whole of The Peninsula is considered to have highly significant inherent value
and be outstanding natural landscape, for a number of reasons.
It is one of the most significant and dominant landforms contributing to the
unsurpassed natural scenery experienced from on Lake Wanaka and from within
Wanaka township. It is central to the nature and quality of the natural landscape
experience from these places, which is very highly rated at district, regional, national
and international levels.
It is one of the natural icons of the Wanaka area. It is a dominant and distinctive part
of the setting for the township of Wanaka. The protection of the natural setting for the
town is vital for its ongoing status as a prime tourist destination, and for the landscape
amenity and sense of place for its community.
The Peninsula contributes in a major way to the outstanding quality of the natural
landscape of the Wanaka area and the wider central lakes district.
The landscape is highly visible. It is experienced both at close range (from the shore,
which is popular and very accessible for boat-based recreational activity) and as a
whole from a distance, as one moves around on the lake or admires the panoramic
view from the Clutha Outlet Track or Millennium Walkway. Another unique quality
of the area is that one can move right around it, the whole of the landform is visible
from many different perspectives.
The key attributes that underlie its contribution are its high degrees of naturalness,
intactness, coherence and legibility (as stated in the Conservation Resources Report).
There is a predominance of natural elements, patterns and processes. In particular the
absence of obvious cultural modifications or elements over such a large area is a
notable attribute.
The landform is incredibly distinctive and memorable because of its classic icescoured peninsula form, its distinctive skyline, and the juxtaposition of dramatic
bluffs, rock clefts, etc, on a large scale with the lake.
The extensive areas of native shrublands (which are not confined to the proposed
covenanted areas) are of significance both visually and as an expression of the
district’s ecological diversity and natural character. The lush mixed broadleaf
shrublands close to the lake margin add much to the lake experience, especially in
their contrast with the extensive dry-looking kanuka shrublands on the opposite shore
(a key regional ecological transition related to increasing rainfall).1 The groves of
11
the kanuka on the moraine area to the east and south of the lake represent the western-most limit of
climax kanuka forest, a community of limited presence in the Otago region. Where rainfall exceeds
750mm, as on The Peninsula, broadleaf shrubland and forest dominate as climax communities, with
cabbage trees on the eastern slopes are a distinctive natural feature, as are the rusty
patches of kanuka/manuka.
We concur with Bennett’s assessment that The Peninsula is a highly visible landscape
with low suitability for change. It is a landscape that is very vulnerable to adverse
change, due to its high inherent values, its high profile location, and its open, steeply
sloping terrain with predominantly low grass and shrub cover. The Peninsula
landscape is not considered “capable of sustaining pastoral farming or other economic
uses associated with tourism or rural residential use.” It is capable of evolving to a
more natural state.
Under unencumbered freehold tenure, there would be no certainty that the landscape
would not change to a more modified landscape and that existing landscape values
would not be compromised. Grazing, burning, oversowing and topdressing,
subdivision fencing, and tracking are all likely future uses. The vegetation cover can
only become more exotic under such a regime, and the presence of cultural elements
would most likely increase. Applications for subdivision into lifestyle lots are also a
future scenario on the east side, where old lake terraces and slumps provide gentler
topography. Classification of The Peninsula as outstanding natural landscape does not
prohibit such development.
We believe Crown ownership for conservation purposes is the best tenure for The
Peninsula.
A further highly significant consideration is the incredible and unique opportunity that
exists to designate The Peninsula as a “mainland island”. The very narrow isthmus of
gentle terrain would be very easy to fence to exclude predators. Less than 500m of
fencing would be required and the lake forms the entire remaining boundary.
This designation would not only secure the significant inherent values of The
Peninsula in perpetuity, it would enable The Peninsula to become an area of
immeasurable value both ecologically and for tourism (since it is so readily enjoyed
from the lake). Other “mainland” islands are not so accessible to the public nor would
they be so very easily created and maintained.
The Conservation Resources Report states that there is a strong tendency for
regeneration (p.4, third paragraph). Freedom from intervention (burning, grazing)
would allow this to happen with greatly increased value as natural landscape.
We are also very surprised to see no provisions have been made for public access to
and along the tops. The views would be spectacular. The whole experience of
landscape in the Wanaka area would step up a big notch if this access was provided.
3. Inadequate recognition and provision for protection of significant inherent
values of the lake faces to the northeast of the isthmus.
We are concerned that this area too is proposed for unencumbered freeholding.
kanuka being more of a successional community (J. Burrell – “Ecology of Leptospermum in Otago”
in NZ Journal of Botany 3:3-16 Mar 1965).
2. E H Bennett and H Russell – Wanaka/Hawea/Makarora – Planning for Landscape Change, Visual
Landscape Assessment, Feb 1993
The landscape of these lake faces is very similar in character and vulnerability to that
of The Peninsula and is assessed to have similar values.
The values of this area are particularly relevant to Mou Waho island. The recreational
facilities on this island are being upgraded both promoting and anticipating increased
future use. The landscape experience from this island is special, because it is an
island, reached by a awesome boat trip, and due to the presence of Lake Arethusa
which offers a very distinctive and memorable experience time and time again. The
lake faces northeast of the isthmus along with the north end of The Peninsula are the
backdrop to this unique, highly natural view. It is critical that the existing degree of
naturalness, coherence and legibility of the background landscape is maintained
through an absence of any further development.
Bracken cover over these slopes is more extensive suggesting a return to native
woody vegetation in the absence of intervention would be vigorous.
Both these areas rise from lake level (at about 280m asl) to over 1000m. Given
freedom from intervention, a full altitudinal sequence of native shrublands and
grasslands could re-establish.
We believe Crown ownership for conservation purposes is the best tenure for this
area.
4. The unique values of the isthmus are not recognised.
The isthmus is a very special, unique and distinctive area. We agree that it is a
intriguing area (p.4 of the Conservation Resources Report, last paragraph).
It has geomorphologic significance, being the place where the Wanaka valley glacier
split in two and overrode the low point, and because it is so narrow - one can see both
parts of the lake at once from it. Its low altitude and small scale is emphasized by the
contrast with the large scale glaciated mountain ranges which it lies between. The
Peninsula is almost an island.
The isthmus is less than 500m across and would easily allow a traverse to enjoy both
parts of the lake from a single landing.
It is considered a key area for the enjoyment of the outstanding natural landscape of
Lake Wanaka.
5. Inadequate protection of the significant inherent values of East Wanaka Creek
catchment, with associated incoherent boundary line.
The Department of Conservation reports clearly acknowledge the high landscape and
ecological values of this catchment and recommended Crown ownership as the
appropriate tenure to protect its values. We strongly agree with this.
East Wanaka Creek is similar in landscape character and has similar significant
inherent value to the Quartz Creek catchment, which is proposed as conservation area.
The upper catchment and skyline area of this catchment are a significant part of the
scenic backdrop to Wanaka township, as well as contributing to the setting of Lake
Wanaka.
The intact and healthy Chionochloa macra tussock on the upper slopes not only is of
ecological significance but has special visual qualities as well. Around half of the
proposed covenant area is land over 1000m. It would not be appropriate or practical to
fence off the upper slopes. Continued grazing of the tall tussock is clearly anticipated
under the proposed special covenant conditions.
The proposed boundary for the covenanted area would, if fenced, result in an
incoherent line that would detract significantly from the landscape. It does not follow
the natural topography. It “cuts off” the lower part of the catchment and thus will
disrupt the natural patterns of landform and vegetation and detract from coherence,
legibility and naturalness values.
On-going topdressing and oversowing up to 1000m and grazing of the whole
catchment including the snow tussock up to over 1400m altitude will not enable the
protection of significant inherent values or provide for recreational enjoyment within
the area.
6. Inadequate recognition and provision for protection of significant inherent
values of the lake faces on the east side of Stevensons Arm.
The highly visible sheer steep open faces to the northeast of Stevensons Island are
important to the setting of Lake Wanaka and contribute to the outstanding natural
landscape experience.
They are also part of the distinctive natural landscape backdrop for Wanaka township,
they are an integral part of the fascinating rugged complex of Mt Gold.
It is important that the existing degree of naturalness and intactness of these slopes is
retained and, ideally, allowed to increase and that they remain an integral part of the
Mt Gold complex and continue to be part of the natural setting for the lake and town.
Unencumbered freehold would not guarantee this. It would promote contrast rather
than integrity as management strives to replace native cover with exotic pasture for
grazing.
We believe Crown ownership for conservation purposes is the best tenure for these
slopes, and that they should be part of a Quartz Creek/East Wanaka Creek
conservation area.
7. Inadequate recognition and provision for protection of significant inherent
values of the southwest side of Mt Maude and Little Mt Maude
The landscape of the southwestern part of the range appears to be very similar in
character to the rest of the Quartz Creek catchment, which is proposed for
conservation area. It has a highly natural appearance with extensive native shrubland
remaining over steep dissected slopes with considerable bedrock exposure. Tall
tussock grassland is visible over the upper slopes, which rise to over 1000m. The
landscape over this part is integral with the balance of the range.
The south end of the Maude Range is an important and distinctive part of the skyline
mountain range backdrop to Albert Town and the Maungawera road, as well as parts
of SH6. The extensive native shrubland cover is a notable feature, as is the absence of
obvious cultural elements such as tracks and fence lines.
It is important that the Maude range continues to be appreciated as a whole landform.
Dividing the tenure in the way proposed will promote a contrast and fragment the
landscape, detracting from its overall naturalness and coherence.
A microcosm of this effect will occur with respect to the CC5 area. Only half of the
valley is proposed as covenant area. This will prevent a full range of native
communities evolving according to aspect (which is as important as altitude in respect
of natural landscape diversity, legibility, coherence, etc.).
8. Inadequate recognition and provision for protection of significant inherent
values of the Hawea Faces (the east side of the Mt Maude range).
The Hawea faces are highly visible and have significant natural landscape values.
They form around half of the range land setting for Lake Hawea on its west side (up
to the Neck). The Maude range is the backdrop for the township of Hawea. It is very
important in forming the sense of place and quality of landscape setting for the town.
Spectacular views of the lake and its mountain range backdrop are enjoyed from the
Timaru River Road and associated recreational areas. SH6 skirts around the base of
the range, providing closer views up its steep sides. Further south, the south end of the
range is an important part of the mountainous backdrop to views from the highway
and Albert Town.
The high degree of naturalness, intactness, coherence and legibility of the range
landscape is critical to its contribution to the wider landscape values of the Hawea and
Albert Town areas.
The continuity of a native cover of bracken, kanuka, grey shrublands and grassland
should be maintained and permitted to evolve in a natural way. Like the Wanaka lake
faces, the extent and vigour of the bracken cover suggests return to native woody
vegetation (probably dominated by kanuka but also including totara and celery pine)
would occur given freedom from intervention. A full altitudinal sequence of native
shrubland, woodland and grasslands could re-establish.
We consider that the sparing use of covenants as proposed would not adequately
protect the inherent values of even the woody remnants they are supposed to protect,
because there is no protection of their landscape context. They will lose their meaning
and become little more than botanical specimens. There is no opportunity for
expansion of the communities.
Isolated covenanting is not an appropriate mechanism to protect the significant
inherent values of the Hawea faces, which have value as a whole range landscape.
It also does not provide for secure public access and enjoyment of this landscape.
It would be undesirable to introduce 7km of new fence line along the ridge because it
would detract from the naturalness and sense of remoteness.
9. Absence of protection for low altitude kanuka.
There is considerable mature kanuka on the lower basin floor areas. It contributes
significantly to the landscape character and aesthetics of the basin floor. It is a
substantial remnant of the former predominant indigenous community of the area.
No mechanisms are being proposed to protect the kanuka in perpetuity. Basin floor
kanuka is under threat through clearance from development (cultivation, vineyards,
life style units).
Protection of the kanuka down lower Quartz Stream would maintain an ecological and
visual link from the proposed Quartz Creek conservation area to the lake with its
marginal kanuka shrublands.
To address our concerns, we would like to see the proposal amended as follows:
1. The whole of The Peninsula be retained as Crown land with a short term
grazing licence. We cannot stress highly enough the significant inherent
values of this unique and distinctive landform. There should be only light
grazing with maintenance top dressing. There should be no further burning or
oversowing. It is expected that the native woody vegetation would gradually
be able to return and grazing would be phased out. The potential for a future
mainland island would be safeguarded. Public access route (not a track) up to
the top should be defined.
2. The Isthmus area reserved for public recreational use and enjoyment of the
lake landscapes. Exotic woody weeds (sweet briar for example) would be
eradicated and native species replanted for amenity, shade, bird habitat, etc.
Two or three paths between both shores would be defined to enable easy
traversing of the land.
3. The lake side faces northeast of the isthmus and the faces overlooking
Stevensons Arm designated as conservation land. Continued burning and
oversowing and topdressing would be required to maintain pastoral value. On
these highly visible faces with a strong propensity to revert to bracken (and
eventually native woody species) conservation uses are considered to be the
best use.
4. East Wanaka Creek be retained as conservation area, as proposed by DOC in
the Proposed Designations Report. This would provide catchment wide
protection and retain and enhance the existing significant inherent landscape
values. Continued grazing of high altitude tall tussock is understood to be
unsustainable. A contour fence around the 1000m mark (the upper limit of
topdressing and oversowing) is not considered desirable.
5. The entire Maude range become conservation area. On going pastoral use will
require regular burning and topdressing and oversowing to continually replace
bracken and kanuka with exotic pasture. Because of the size of the area
concerned, the high visibility of the range and its high significant inherent
value, this would have a huge effect on the long term natural character of the
landscape and seriously detract from wider landscape values.
The best use in our opinion is to allow the existing shrublands and forest
remnants (which include totara and beech species) to continue to exist with no
further interference, which will then allow the area to evolve to a more natural
wooded state. This is the appropriate outcome for the backdrop to Hawea town
and the natural setting for Lake Hawea.
6. A covenant over the freehold around Quartz Creek to protect in perpetuity all
existing kanuka and manuka. No clearance would be permitted.
These amendments are shown on the attached plan.
CONCLUSION
_____________________________________________________________________
The HCLG supports the designation of conservation area for Quartz Creek.
We do not support the other proposals. We submit that the protection of SIV of
large areas of Mt Burke pastoral lease is not being enabled as required under the
Crown Pastoral Land Act 1998, Part II nor is public access to and enjoyment of
these areas being secured.
We have suggested appropriate amendments to the proposal which would ensure
it meets the requirements of the Act. These amendments would also ensure
consistency with the two new Tenure Review Objectives recently adopted by
Government