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''We believe the minister [Land Information Minister Eugenie Sage] has jumped the gun,'' Federated Farmers high country chairman Simon Williamson said.
''It would have been more appropriate to determine the fate of the tenure review after all submissions and viewpoints had been received and evaluated.''
Environmental Defence Society chief executive officer Gary Taylor agreed.
''It [the Government] is presenting the public with a 'fait accompli' on the big issue and then consulting on secondary matters. It would have been better to get public feedback before making such a big call.
''Tenure review, if run properly, could be a useful tool.
''The problem has arguably been in its implementation, which has seen the public ripped off and leaseholders given exorbitant profits.''
Mr Williamson said tenure review had been ''a great tool'' for conservationists.
''There's been five conservation parks as a result.
''We've always said we don't think tenure review is the best model in the world and some good grazing land has been lost to tenure review.
''Perhaps a farming management plan would be better. Just closing up land doesn't necessarily improve it; places that have been closed up have deteriorated.''
Mr Williamson said if the proposals locked up land as a quasi-public estate, it would be ''highly unfair''.
''I keep coming back to the adage about Simons Pass Station leasehold, where consents were given under a lease.
''It's like a game of rugby: if a player punches another in the head, you don't take the whole team off, you sort it out individually.''
Pastoral leaseholder Murray Valentine, of Dunedin, plans to run a dairy business with up to 15,000 cows on the Mackenzie Country station, where leases were originally awarded for sheep farming.
The station is being considered under tenure review and a decision is awaited from the Commissioner of Crown Land that could lead to more than 4300ha of the 5500ha property becoming freehold.
Mr Williamson said if leased land was locked up in perpetuity, it would compromise farms' viability in some of New Zealand's harshest country.
''Yet still requiring that farmer to meet all the responsibilities the lease entails, including pest and weed management, without any sort of compensation.''
He said it was timely to review aspects of Crown lease land in the high country but the rights of leaseholders were important.
''We have no problem with a reasoned and balanced discussion on the extent to which the objectives of the Crown Pastoral Land Act (section 24) have been achieved.''
Under the proposals, leaseholders would have to publicly lay out what they wanted to achieve managing the land.
''We already have to jump through hoops now,'' Mr Williamson said.
''This will just add another layer of bureaucracy which shouldn't be the Government's job, it should be local government.
''In the Mackenzie it's impossible to do anything.''
Mr Williamson said Federated Farmers was concerned with major changes proposed to the discretionary process and role of the Commissioner of Crown Lands.
''It's imperative the commissioner is neutral.
''Other governments have tried to have the commissioner accountable to the minister. The key is they have to be neutral.''
Mr Taylor said the Environmental Defence Society also had concerns about the commissioner.
''The report does propose some greater degree of accountability for the commissioner but does not consider alternative approaches.
''The commissioner is the most unaccountable civil servant in the country and past commissioners have made decisions that are questionable in law. Approving massive dairy conversions in the Mackenzie Basin are a case in point.
''It may be that the commissioner's position be axed altogether and a new approach adopted that would achieve improved accountability and better alignment with RMA processes.''
The Government's proposals would mean rent reviews would also be required, unlike the current process, in which there were no rent reviews.
''They will have a fight on their hands, I think, and would have to change the Pastoral Lease Act,'' Mr Williamson said.
Federated Farmers was pleased by assurances from Ms Sage that negotiations with those properties already in tenure review would continue on a case-by-case basis.
Eight leaseholders have accepted a proposal from the Crown and 26 others are still involved in the process.
''Budget provision should be available to ensure farming operations remain viable, with compensation for land and improvements returned to the conservation estate,'' Mr Williamson said.
Consultation on the Government's proposal, ''Enduring stewardship of Crown pastoral land'', closes on April 12.
Mr Williamson said Federated Farmers' high country industry group would be meeting next month to prepare a submission.
-By Chris Tobin