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National Parks or Game Parks?

byJames Higham
20 August 2025
11 minute read

New Zealand’s coalition government has recently announced its intention to allow invasive introduced hunting species to be maintained in our National Parks. But behind this plan is an extensive suite of other proposed law changes that have received less attention. These changes do risk our National Parks – so valued for conservation – being reduced to tourist Game Parks.

Transcript

New Zealand’s coalition government has proposed a bill that supports having invasive introduced hunting species, such as deer and North American elk, in national parks. It is called the Animal (Herds of Special Interest) Amendment Bill. The Bill would effectively dispense with fundamental protections in the National Parks Act to allow ‘herds of special interest’ (HOSI) to be established and maintained in our national parks. Large parts of our national parks could then be managed for hunting purposes, including for trophy hunting, in the interests of extractive tourism. 

This bill has, naturally, caused a lot of concern in conservation circles. So what does this bill actually propose? The Amendment allows for the designation of ‘Herds of Special Interest’ to be exempted from the National Parks Act section 4(2)(b). Currently any exemptions to section 4(2)(b) are determined by the New Zealand Conservation Authority.  

This is a very significant change in conservation law. The bill would remove the expert input of the New Zealand Conservation Authority on potentially highly damaging activities in any of New Zealand’s national parks, and place decisions solely in the hands of a Minister. This would remove the key function of the Authority in terms of important checks on decision making in the public interest. Essentially the expertise of the conservation authority on any decisions to introduce an alien species into a national park for hunting purposes would be replaced by the authority of a Minister who might on whatever grounds – personal or political – be persuaded that a herd is of “special interest to hunters”. 

Worryingly, the proposed amendment to the National Park’s Act would also mean that the section 4(2)(b) requirement to preserve the native plants and animals of the national park as far as possible would no long apply to the enormous adverse effects caused by a “herd of special interest”. 

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The Forest and Bird Protection Society, New Zealand’s largest conservation organisation,

has been outspoken in its opposition to the amendment. It encouraged submissions that raise awareness of five key points.

1. The bill violates a fundamental principle of National Parks Act 

New Zealand’s national parks are currently required by the legislation to be maintained as much as possible in their natural state in perpetuity.  This bill means national parks will no longer be maintained in their natural state, because introduced species will be allowed to remain there. This bill could limit public access to national parks, by placing restrictions on access where trophy hunting is prioritised. 

2. The bill undermines New Zealand Conservation Authority (NZCA) decision making 

This bill removes important checks and balances on conservation decision making. This has enormous potential implications for all national parks particularly those where exotic herds already exist, including North American elk and red deer in Fiordland National Park, Himalayan Tahr in Aoraki Mt Cook National Park, Sika deer in Tongariro National Park and White tailed deer in Rakiura National Park. Even at low numbers, invasive species like deer, tahr and North American elk eat tonnes of native vegetation every day, which has adverse effects on New Zealand’s native ecosystems. The bill would remove the opportunity for the NZCA to rigorously scrutinise decisions of national importance in relation to national parks, in the interests of all New Zealanders. 

3. Herds of special interest have serious ecological impacts 

Invasive species, as we have long known, are very hard to control. Ever-expanding populations of exotic pests have in recent decades destroyed extensive native habitats in national parks. Even at low numbers, the grazing of invasive species like deer and tahr have adverse effects on New Zealand’s native ecosystems. In fact even on closely managed farm lands deer have become a major problem despite efforts of farmers and hunters to control populations. Maintaining national parks in their natural state is an ecological and conservation bottom line. But this bill would legitimise invasive species in national parks. 

4. The bill will threatened UNESCO World Heritage status

Forest and Bird also notes that some of New Zealand’s national parks are internationally recognised as UNESCO world heritage areas for ecological and cultural values.  In addition to violating the fundamental principle of National Parks Act 1980, the bill ignores the threat of invasive species on native habitat in our internationally recognised UNESCO World Heritage Areas. Te Wāhipounamu the Southwest New Zealand World Heritage Area includes Aoraki Mount Cook, Tai Poutini Westland, Aspiring, and Fiordland National Parks.  World Heritage inscription identifies invasive species such as deer, elk and tahr as a threat to world heritage values.
 
5. And finally, hunter led management simply hasn’t worked 

The Himalayan tahr control plan, which despite agreed limits, has not managed to keep populations or their range in check. Department of Conservation is well aware that hunter-led management has not been effective in controlling invasive game species. This model closely resembles what has been proposed for the so-called Hunter-Owned Stewardship Initiative (HOSI) under the amendment. The result is likely to be further environmental damage, public access being limited due to areas being balloted for hunting, and growing costs for nature and the wider public.

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So what are the issues that we need to address from a sustainable tourism perspective?

Obviously we need to protect our conservation estate which includes our most outstanding natural areas. National parks exist to protect our indigenous plants and wildlife and spectacular landscapes in their natural state and in perpetuity. They are managed to allow for recreation and tourism as long as it is consistent with conservation of New Zealand’s most precious and spectacular natural areas. Our national parks such as Tongariro, Fiordland and Aoraki Mount Cook are iconic places for all New Zealanders – users and non-users, recreationists, and international tourists. These amendments undermine conservation efforts, and give too much priority to tourism over conservation, which was never the intention of the National Parks Act 1980.

National Parks are the centrepiece of New Zealand’s most awe-inspiring scenic natural beauty, as well as undisrupted ecological and geological processes, where visitors can marvel at the powers of nature. They are also the heart of New Zealand’s biodiversity conservation efforts, where visitors can hope to see or hear rare and unique native species such as kiwi, kea and kākā, tui, takahe and tieke – if they are lucky – the flora and fauna that make Aotearoa New Zealand globally unique. These changes come despite the known ravages of introduced predators such as rats and stoats and possums. It is estimated the 25 million native birds are killed every year by alien predators. The “immigrant killers’ as Zoologist and conservationist Prof. Carolyn King calls them. Not to mention the enormous ecological damage caused by browsing introduced species such as possums. And not to mention introduced hunting species such as elk, tahr and deer which cause enormous damage to alpine, forest and valley habitats in our conservation estate.  

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Modernising conservation lands

The Animal (Herds of Special Interest) Amendment Bill is quite mystifying to me, and deeply troubling, but it is actually just one part of a wider programme of conservation reform that the government refers to as ‘Modernising Conservation Land Management’. It is introducing law changes that will, it claims, unlock greater economic activity on public conservation land while protecting nature and our iconic landscapes.

First among these additional law reforms was an announcement that the Government is introducing a visitor fee for international tourists to access popular sites in our conservation estate. The justification is that everyone can continue to enjoy world-class experiences in nature while contributing to long-term protection through visitor fees. It is proposed that fees will be introduced initially at four popular sites – Piopiotahi Milford Sound, Aoraki Mount Cook, Cathedral Cove and the Tongariro Alpine Crossing. Other sites will be investigated for future charges for international tourists who visit these places for sightseeing, short walks or overnight tramps

This has been a headline conservation law reform and the proposed visitor fees have been generally well received. This is in part due to New Zealand tax payers feeling that they have historically subsidised international visitor use of national parks. But it seems to be supported only if access fees are reinvested in conservation at the locations where the fees are collected.

It is worth noting that charging visitors to use national parks and conservation areas is common practice in countries like Australia, Canada and the USA. And International visitors consistently report that they would be willing to pay for the experiences of national parks that they currently receive at no cost to themselves.

Charging international visitors at just four sites is estimated to raise $62 million a year and the funding will apparently be ringfenced for conservation work. Funding priorities will include maintaining and improving tracks and visitor facilities at locations where charges apply. Whether we can trust the government on this, given recent experiences with the international visitor levy – intended for conservation but used currently for international marketing – is an open question … with many highly sceptical.

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Behind visitor access charges lie a raft of other proposed changes with a strong emphasis on businesses that want shorter processing times for permits and concessions to operate on conservation lands. The proposed changes include:

  • Updated and streamlined rules and processes for granting concessions on conservation land to provide more certainty for business investment;
  • Cutting red tape by allowing more types of activities to occur without needing a concession at all;
  • Enabling more flexibility for the Department of Conservation (DOC) to exchange or dispose of conservation land where it makes sense from a conservation perspective;
  • Changing the management planning system that sets the rules for granted permissions for commercial activities on conservation land. It is argued that these rules are outdated and complicated and delaying the processing concessions.

These changes are ultimately intended to enable a broader range of activities to take place on conservation land. The Government plans to pass these changes into law before the end of the current parliamentary term in mid-2026.

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All of this reminds me of a research project with Norwegian colleagues that I completed about ten years ago. At the time, the Norwegian government had committed to economic succession due to its historical dependence on the oil industry, volatility of oil prices at the time, and the commitment of the Norwegian government to achieve carbon neutrality in all sectors of its economy by the target year of 2030. The response was to actively encourage alternative industries such renewable marine energy production, aquaculture and regional economic diversification through tourism to address the decline of rural economies.

Norway is renowned for areas of outstanding natural beauty with an extensive system of protected natural areas that could be capitalised upon to stimulate growth in tourism through branding, marketing and visitor management strategies. My Norwegians colleague saw much to learn from New Zealand’s extensive system of national parks, which had been developed over the course of a century in accordance with a dual mandate of protection of nature in perpetuity, and use for recreation and tourism, as long as it is consistent with protection in perpetuity) as stated in New Zealand’s Conservation Act, 1987.

We essentially undertook an international comparative analysis of the Norwegian and New Zealand conservation management policy settings as they relate to tourism. New Zealand served as a useful comparative case because of its dual mandate – the long tradition of nature conservation and economic development through recreation and tourism management in national parks.

On this project I also learned a lot about the history of conservation management in Norway.

Recreational use of national parks in Norway is embedded in a longstanding tradition of simple outdoor recreation among its citizens. This tradition is known as friluftsliv – a uniquely Scandinavian term thatdefies simple translation into English. Most broadly speaking, Friluftsliv essentially means “outdoor living”. It describes a tradition of unrestricted access to engage in simple and self-organised outdoor recreation activities in nature.

Itexpresses a way of engaging with nature that is understood in various ways by Norwegians but is generally taken to denote experiences of nature that are independent and self-reliant. The tradition of friluftsliv is evident in the philosophy of deep ecology, which highlights the intrinsic value of nature, which should be respected and protected.

Friluftsliv is embedded in Norwegian national identity and is clearly outlined in Norway’s Outdoor Recreation Act (1957), as are individual public access rights that allow anyone to access by foot or on skis, uncultivated land in public ownership. Little or no conservation management priority has historically been given to visitor services, facility development or tourism marketing in association with National Parks, all of which fall outside the provisions of the Outdoor Recreation Act (1957).

The philosophy of friluftsliv stands in obvious contrast to the provision of recreation and tourist facilities, and commodification of nature experiences through tourism development.

My Norwegian collaborators were very interested in New Zealand’s dual mandate approach and saw some scope for Norwegian policy makers to learn from the New Zealand example. But it was interesting that at the end of the project, some of my Norwegian colleagues were wary of the dual mandate. In part because of the importance of the tradition of friluftsliv in Norwegian society – which, like our national parks in New Zealand, is an important part of national identity. But they also cautioned against the possibility that future governments might abuse the intended balance between conservation and tourism in the interests of short-term economic goals. They saw weakening the primacy of conservation in our National Parks in the interest of tourism as an ever-present future threat.

And here we are today. Very prophetic indeed.

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These are critical issues for tourism and conservation. Getting the balance right is critically important

The conservation estate is our base tourism asset. Our national parks provide the natural beauty that underpins the 100% Pure New Zealand brand. Of course public access to national parks is not in question. But these policy changes are already raising eyebrows internationally.

The Guardian used strong language last week when reporting on the plans of the New Zealand government to make it easier for businesses to operate on conservation land as part of a “… controversial proposal to “unleash” growth on ecologically and culturally protected areas”. The Guardian wrote that the government’s announcements “…form part of a wider shake-up of conservation law that will also make selling or exchanging conservation land easier and allow more activities to go ahead on conservation without needing a permit”.  The prime minister, Christopher Luxon, was quoted in the Guardian saying “…In the spirit of saying yes to more jobs, more growth and higher wages”, the government would “unleash a fresh wave of concessions” including in tourism, agriculture and infrastructure at some locations.

According to the Guardian they reflect the government’s fast-track legislation that was passed in 2024 that could see contentious mining and infrastructure projects fast-tracked for approval.

The last word goes to Nicola Toki, the chief executive of Forest & Bird. She said that the latest reforms “represent the most significant weakening of conservation law in a generation” and would increase pressure on vulnerable species. “They shift the focus from protection to exploitation, dismantling the very purpose of our national parks and conservation lands.”

There are great concerns that under the current government the pendulum is swinging away from the protection and conservation of National Parks and towards the touristification of Game Parks – and rightly so. 

References

Author
James Higham
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