Thank you to Jan Finlayson, FMC president and Dan Clearwater, FMC Development Officer for compiling this resource. If you or your club wants to add to this resource, or assist us building resources about any topic for the Outdoor Community, then drop us a line!
FMC’s raison d’etre is advocacy for mountain recreation and accordingly, for the environments and creatures we recreate amongst.
To advocate effectively requires one to play a long-game, from a position of principle. It demands a clear understanding of the legislative and historical context, which must be applied with sufficient mana and a mandate from many. FMC has long demonstrated these successful qualities, which is why the size and breadth of our support has never been bigger.
For many, the affiliation to FMC is the acknowledgement of your trust in us to do the advocacy as best we can, on your behalf. Whilst the committed volunteers of our executive accept that responsibility, in turn we will also gratefully accept helpful support when it comes to our advocacy objectives.
One area where clubs can, if they wish, make an additional contribution is submissions to notified consultation processes.
In a nutshell, FMC believes it will add to the effectiveness of our submissions, if our member clubs write their own letters supporting the FMC position.
In this resource, we’ll explain:
- FMC’s submission process,
- ways for clubs to contribute to our common submission goals.
- advice on how to write your own submission.
How FMC makes its submissions
Among many other things, FMC keeps an extremely close watch on notified consultations administered by DOC and LINZ, and whenever we believe an issue is worth pursuing, undergo a process to submit on that issue.
An executive member takes responsibility for writing the submission, which is most often the convenor of the regional sub-committee where the issue is located. Simpler issues are dealt with in the sub-committee, and issues which are high-level or contentious enough are debated with the collective wisdom of the full executive.
FMC’s view is that the authors of our conservation legislation got it right. It is clear-sighted, and far-sighted. Our positions, policy and submissions are all founded on the base principles found within those statutes and the policies and plans that come under them.
Our submissions acknowledge the legislative framework, state how we think our positions reflect that, and provide specific recommendations to remove or re-think proposals we disagree with.
We are always open to our member clubs getting in touch to delve further into the thinking behind the final position. Especially when a concept has merit at face value, FMC works hard at identifying and considering all the consequential effects before arriving at a position.
We’ll stand behind our position with clear reasoning, but remain willing to update our thinking in the face of better arguments and evidence.
Where the issue warrants it, FMC executive members will personally attend hearings on the consultation, to press home in-person, the messages within our submission.
How you can add to the effectiveness of FMC submissions.
Each club or individual supporter will do what is appropriate for them, and in no way is FMC placing pressure for you to do more; after all, a significant reason (if not the reason) for being affiliated to FMC is that we are willing to take the burden of advocacy from the shoulders of our member clubs and individual supporters.
However, if there are clubs or individual supporters with the motivation to contribute to the submission process, then FMC believes the most helpful action is to state your support for FMC’s submission in any submissions you or your club makes.
Your submission could be solely in support of FMC’s submission. It doesn’t have to include additional points or recommendations, but a basic comment of why you support our submission adds to its weight, as it shows you’ve given it some thought beyond than just following our lead.
We are XYZ tramping club, based in tramper-town, with a membership of 500.
We wish to submit in support of the submission by the Federated Mountain Clubs of NZ, because our members regularly tramp in this area, and the proposal significantly degrades our opportunities to encounter the outdoors on nature’s own terms.
FMC’s submission addresses our concerns, and that is why we strongly support it.
FMC works hard to keep clubs in the loop.
We strive to keep clubs aware of current issues, and submissions we’re working on. Our aim is to crystalise our position with enough time for clubs to submit in support if they wish to, but with a volunteer executive, some submissions are finalised later than others!
If you are motivated to offer direct support on a particular submission, please get in touch and let us know.
What about copy/paste submissions or online ‘petitions’?
FMC is quite convinced of the general superiority of quality over quantity when it comes to the efficacy of submissions. Among the executive members are those with considerable experience being part of Conservation Boards, Conservation Authority ?? and DOC planning teams. Essentially, the more thoughtful and considered your appeal, the more the decision makers are going to spend assessing your feedback. Anecdotally, large numbers of short, identical ‘submissions’ will be ‘noted’ by the decision makers, but hardly considered.
A guideline for how to write a submission
FMC has an obligation to represent in the best interests of its members, which are FMC affiliated clubs rather than individuals within a club or individual supporters.
Clubs can rest assured that FMC will put its best foot forward in advocating for important issues. However, some clubs may feel strongly about a particular issue, enough to want to enquire about FMC’s position, and perhaps even make a submission themselves.
Like FMC seeks feedback and input from our member clubs on various issues, FMC in turn encourages those clubs with strong views to get in touch. Club reps should contact the exec member responsible for the FMC submission, to see if/how the thinking aligns. Hopefully, the club can be reassured that FMC’s words will echo the club’s views.
However, if the thinking differs, the discussion should at least provide mutual understanding of the rationale behind the positions and at best give additional information for use in both parties’ submission.
We do invite you start by examining the relevant FMC policies and legislation first. That research may answer some of your questions before you get in touch with us.
State who you are and explain why you have an interest in the issue: show the decision makers who you represent and what your Kaupapa is.
I am the President of XYZ Tramping Club. Our club does a lot of tramping in this area and we have a strong interest in the ongoing good conservation and recreation management of the park.
The legal landscape
State the relevant laws and planning documents and the particular sections applicable to your following arguments.
This bit may sound a bit scary to some, but is a crucial foundation for your arguments. It demonstrates your understanding of the applicable laws and that what you are about to say will be in accordance with those laws.
There’s little point in a decision maker considering a lengthy submission if it turns out to recommend things which are not legal to do. Showing your understanding up front gives confidence to the decision maker that it’s worth reading.
Also, having to do the research into the law helps you formulate better arguments and develops your overall understanding of the legal constraints for an issue.
Conservation Act 1987
National parks’ management is also governed by the Conservation Act. We note, in particular, distinctions made in the section describing the Department of Conservation’s functions:
Section 6(e) To the extent that the use of any natural or historic resource for recreation or tourism is not inconsistent with its conservation, to foster the use of natural and historic resources for recreation, and to allow their use for tourism.
What laws and documents should we research?
There are plenty! National Parks Act 1980, The General Policy for National Parks, Conservation Act 1987, National Park Management Plans, Conservation Management Strategies, Conservation Management Plans. Or it could be the Resource Management Act and the relevant District Plan. You don’t have to state the whole hierarchy of documents, but instead pick the most relevant ones to your arguments.
Usually, when an agency (such as DOC) calls for submissions, they will state which Act(s) the issue relates to, which gives an excellent starting point for your research, however if it seems too bewildering, then feel free to contact FMC for advice on and we can point you in a good direction.
State your opinion on general issues.
Construct your opinions with reference to principles and/or practical considerations relating to the issue. Such a structure shows a logical basis for your argument; your later recommendations will flow directly from the intent and letter of the law, which makes them compelling and difficult to ignore.
E.g. Within the 2018 submission on the Draft Aoraki/Mt Cook National Park Management Plan, FMC took issue with the way the plan proposed to increase impact from air traffic. These issues were complex, but our submission statement on the general issue of aircraft could be simplified as follows;
This plan needs to express the spirit and intent of the National Parks Act 1980 (principle); this means that aircraft activity should be absolutely minimal across the park (practical consideration).
Follow up with specific recommendations and (if possible) solutions.
The proposed landing zone at the lower end of the Tasman Lake is unnecessary as it is not in accordance with the spirit and intent of the Act. Therefore all reference to this landing zone section should be removed from the plan. (specific recommendation)
Give credit where it’s due.
Show support for parts of the plans which you think are suitable.
Seek peer moderation and review
Especially when the work will be the official position of your club, give yourself time to accept and incorporate feedback.
If you or your club wants to add to this resource, or assist us building resources about any topic for the Outdoor Community, then drop us a line!