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.