This page created 1 October 2002
Po 379
Harris Mountains
Otago Land District
Tenure review not approved by Commissioner of Crown Lands
26 September 2002
Commissioner of Crown Lands
C/- DTZ New Zealand
P O Box 27
Alexandra
Submission on Glendhu Tenure Review Preliminary Proposal
PANZ wishes to comment on the following aspects of the review
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Area 1 North (Diamond Lake)
We welcome the proposed reservation of this area. Through the development of a walking track network from Diamond Lake to the summit of Rocky Mount, this area has become the primary focus for public recreational activity on the property. A spectacular panorama of the southern Lake Wanaka basin and the glaciated forms of the lower Matukituki valley is available from the summit - in a little over an hour's walk from the Wanaka-Mt Aspiring Road. This has proved to be extremely popular.
The boundaries selected for this conservation area appear appropriate, with the exception of the SW corner. The proposed boundary excludes a triangular area fronting onto the Motatapu River. DOC's original recommendations (Conservation Resources Report, Executive Summary) stated that "a small flat near the Diamond Lake turnoff through to the Motatapu River should also be managed for conservation purposes as it is part of the total landscape of the area and will allow for recreation use to be catered for". This area was mapped for Crown retention at that time. However this recommendation was inexplicably dropped from DOC's revised recommendations and was not pursued through preparation of the Preliminary Proposal. This omission exacerbates a fundamental weakness in the proposal from a recreational perspective. There is minimal provision for water-based recreation along rivers, and a total absence of new usable reserves, despite a pressing need, along the shores of Lake Wanaka.
In this particular reach of the Motatapu, DOC's initial proposal for a walking access easement down the true right bank to the West Wanaka bridge has also been dropped. There are major doubts that much of the existing marginal strip is still aligned with the riverbank and whether this serves any public purpose. There is at times intense recreational pressure on the marginal strip a few hundred metres away, either side of the lower Motatapu bridge. The narrow 20 metre wide strip can hardly cope with the demand for parking, picnicking and other activities, yet there are no plans to increase the area available for recreational use. The triangular area between the river and the Diamond Lake car park provides an opportunity for ample car parking and convenient access to a larger reach of the river than is currently available. Failure to make provision for such an obvious public need is inconsistent with the duty under section 24(c)(i) Crown Pastoral Land Act (CPLA) "to secure public access to and enjoyment of reviewable land".
WE SUBMIT THAT the triangular flat and terrace between the Diamond Lake car park and the Motatapu River be retained in Crown ownership and managed for landscape protection and recreational use.
Area 1 South
The proposed reservation of the heavily bluffed northerly faces of hill 'FF'' is welcome. As the DOC Conservation Resources Report documents, this has become an important rock climbing Mecca but more significantly, this area along with its northern counterpart centred on Diamond Lake, provides a natural gateway to the Matukituki valley and the Mount Aspiring National Park. It is important that this receives permanent protection.
Unfortunately it appears that the potential for recreational use, other than rock climbing, has been overlooked in the design of the boundaries. The proposed upper boundary is on the lip of the crest and does not go to the summit further the south where far more extensive views can be obtained. We note that the initial DOC recommendations were for a conservation area to include the summit of 'FF', however this was dropped from the revised recommendations and therefore did not carry forward into the Preliminary Proposal. Considerably better views of Glendhu Bay can be obtained from 'FF' (Photo 1) than from Rocky Mount, while most of the lower Motatapu valley is also visible.
What has been overlooked in the Preliminary Proposal is the potential for a walking track from the Diamond Lake car park up the leading western ridge to the summit of 'FF'' returning via the eastern ridge and easement E3, or along the base of the hill. However the proposed western and eastern ridge boundaries need review to ensure that practical, convenient access can be constructed within a future conservation area. There are small bluffs that need to be bypassed (Photo 2). Any difficulties in route-finding and construction would be considerably less than that experienced on the Rocky Mount track.
The conservation area should be extended to include the summit of 'FF' as originally proposed (Photo 3). This would provide assured public access, and protection of the summit ridge from inappropriate development. There is also a spectacular bluff along the western lip below the summit, with forest remnants supporting native bird populations. It is unusual to hear bellbirds from open grassland (Photo 4). These features, and the walking experience with panoramic views, qualify as 'significant inherent values'.
It is worthwhile to reflect that Area 1 North would probably not have been identified as being so important for Crown retention if it were not for the vision of a few locals developing a walking track network to the top of Rocky Mount. Prior to their initiative there was no public demand for walking access to this summit. Extension of Area 1 South to the summit of 'FF' would create potential for a complimentary walking track, with the bonus of panoramic views of the Motatapu valley, which are unobtainable from Rocky Mount. Both track networks would be centred on the existing 'Diamond Lake' car park. In combination with additional public reservation, as we suggest along the banks of the Motatapu River, this would make this area a hub of public activity, greatly extending recreational opportunities in the Wanaka district. This would be for the 'price' of very little extra reservation of land additional to what is currently proposed.
WE SUBMIT THAT Area 1 South is extended southwards along the leading ridge to include the summit of 'FF'.
Area 2 (Glendhu Bluff)
The selection of boundaries don't appear to take account of landscape considerations - a natural resource component of 'inherent values' requiring the Crown to protect during tenure review. The upper boundary selected is below the crest of point 465m and visible from Glendhu Bay. Without any other protective mechanisms over the upper part of this hill, there is a risk of incompatible land management or development occurring immediately above the proposed conservation area. This would be visible from the bay and to everyone travelling west along the Mt Aspiring Road. There are already power poles on the skyline. Further structures could be more intrusive.
WE SUBMIT THAT the upper boundary of Area 2 be the ridge crest as viewed from Glendhu and Parkins Bays.
We note that DOC's revised recommendations for reservation included a finger of land pointing towards Paddock Bay. The Drafting Instructions for the Draft Preliminary Proposal included this area, however this has subsequently been dropped from the proposals.
In the official commentary, in the analysis of amendments to the Draft Preliminary Proposal proposed by the holder, it was stated-
"The area proposed to be excluded from proposed reserve has a predominant cover of wilding pines. This portion was originally included on the basis of reserve design. An alternative boundary was arrived at in consultation with the holder which protects the significant inherent values identified, being a hardwood forest/shrubland remnant uncommon and endemic in the ecological district and being an important backdrop to Glendhu Bay".
"It is agreed that fencing this area is unnecessary and undesirable as stock are naturally excluded from this area by nature of the terrain and a fence would create an unnatural line on the landscape" (our emphasis).
Our photograph (Photo 5) of the slopes to be excluded from the Area 2 indicates that, on an area basis, the predominant cover is not wilding pines, but hardwood forest/shrubland. The pines are largely confined to the ridge crest and part of a gully. These could easily be removed and regeneration of native species encouraged. The boundary selected up one gully within this bay "would create an unnatural line on the landscape", which would result if there were clearance of native cover on the freehold side. No practical farming purpose is served by freeholding this area, however the potential detriment to landscape and recreational values from a lack of protection of this slope could be severe. This is a very enclosed bay. Artificial subdivision of its slopes is not supported by objective assessment of its inherent values and is inconsistent with official advice to avoid unnatural lines on the landscape. 'Landscape' is a natural resource component of inherent values requiring protection under section 24(b) CPLA.
An aspect that appears not to have been considered, is the need for practical public access along this shore. There is a sheer rock face blocking any prospect of access along the existing marginal strip. However inclusion of this slope in Area 2 would facilitate alternative access along the ridge and to the legal road along the shoreline of Paddock Bay. Given other failures to facilitate practical access and recreation along the shores of Lake Wanaka, it must be a priority to secure this access whilst protecting the setting for lake recreation.
WE SUBMIT THAT all the visual catchment of this bay be retained in Crown ownership, out to the point at the eastern extremity of the property in this locality.
Lakeshore recreation reserves
"The foreshore of Lake Wanaka is popular over the summer months with boaties and picnickers utalising the area. Glendhu Bay Recreation Reserve is an extremely popular camping ground and is full to capacity over the peak holiday times. On these occasions public day access to the foreshore is difficult because vehicle access is controlled by staff manning the entry/exit gates to the area".
"The Wanaka foreshore between Glendhu and Parkins Bay requires better public access and opportunities for extending the public reserves in this area are required".
Conservation Resources Report, pp. 4-5)
We fully concur with the above and DOC's original recommendations (Executive Summary) which stated-
"Provision for future recreation reserves along the Lake Wanaka foreshore is desirable. Ideally this would result in land north of Glendhu camping ground becoming a reserve for day use only, and another area in Parkins Bay under the Glendhu bluffs near the poplars should also cater for recreational use. Also an extended area near the mouth of the Fern Burn is desirable".
However these recommendation were inexplicably dropped from DOC's revised recommendations. Consequently they were not included in the Drafting Instructions for the Draft Preliminary Proposal. We believe that this is a major failure to provide the CCL with proper advice on inherent values, including recreational values. This must be rectified. We believe that unless there is greater provision for public recreation on the shores of Lake Wanaka, and related access, then this tenure review should not proceed. Provision for public recreational access to lakes and rivers is a matter of national importance. No responsible government can afford to ignore such needs.
The Glendhu camping ground (domain) is effectively privatised and unavailable for non-campers. Other than a very limited roadside area at the eastern end of the bay, there is no other provision for public day access and enjoyment on the shore. There is only one locality with potential to provide for open public access and use of the remaining shore. This is immediately northwest of the camping ground and within the pastoral lease (Photos 6 & 7). It appears to be partly developed for recreational use with amenity plantings, and has dinghies present. It consists of a narrow ribbon about 300m long between the camp ground and a bend in the road below the homestead. Much of this would be marginal strip if the current shoreline is the legal boundary. However there is doubt about this, as overlay of cadastral and topographic information indicates the existing strip to be off-shore.
There is no public access to the strip through the privatised domain or directly from the road. It is essential that all the land between the lake and road in this locality become public reserve and be managed for public day use, as per DOC's original recommendations. The alternative, as currently proposed, is freehold possibly with lakeshore development. Retaining as public open space would not only satisfy a pressing need for further recreational opportunities in this region, but also provide some private benefit by maintaining unrestricted views of the lake from the homestead.
WE SUBMIT THAT all the ribbon of land between the Mt Aspiring Road and Lake Wanaka, immediately north west of the Glendhu Bay camping ground, become recreation reserve and be managed for public recreation other than camping.
Parkins Bay access
DOC's Conservation Resources Report, Revised Recommendations, recommended a public access easement to Parkins Bay and a car parking easement to allow use of proposed marginal strips down the Fern Burn to the lake shore. These recommendations were reflected in the Drafting Instructions for the Draft Preliminary Proposal (Photos 8 & 9).
However during consultation with the holder, the latter objected to the proposed Parkins Bay easement on the grounds that it would change the character of the lakefront and would interfere with farming operations. Both DOC and the CCL's agent objected to removal of this access easement from the proposal for the following reasons-
Report on Consultation, p 7.
The agents further commented that-
"This easement provides convenient practical public access from Wanaka Mount Aspiring Road to scenic Parkins Bay. It has particular importance due to the general limited number of public access points available from public road around Lake Wanaka to the lakeshore. We believe the matter of the provision of such public access in this tenure review will be of considerable public interest. We do not agree with the holder's contention that such an access would change the character of the lakefront. We are of the view that this access is necessary to provide an alternative to lake access via the privately run motor camp at Glendhu Bay. We concur with the DGC delegate's view that the alternative route suggested by the holder is unsuitable for the purpose sought by the Crown".
In the "interests of compromise" DOC and the CCL's agent recommended that, although the holders have not rejected a car parking easement at the Fern Burn, provided the Parkins Bay easement can be secured, it would be acceptable to delete the Fern Burn carpark from the proposal as legal access is provided along the margin of the Fern Burn within the marginal strip.
However BOTH proposals have been deleted from the advertised Preliminary Proposal. There are no provisions for alternative public reserves or access to the Lake. The case for these is well set out above. As far as we are aware no contrary arguments or explanations have been made to the CCL to justify these major omissions. In our view, failure to provide practical public access to Lake Wanaka is also a failure to act consistently with the objects of the CPLA. These deficiencies must be remedied before tenure review proceeds further.
Clearly, none of what we have stated above is "new information".
However, given the divergence between official advice and official
action, the issue of public access and reserves provision around
Lake Wanaka must be revisited. A failure to do so, with open minds
and a willingness to alter the current proposals, would be in
breach of the CCL's legal obligations in regard to consultation,
as summarised in Crown Pastoral Land Standard 8, Appendix D.
See Photo 10 for overview of lakeshore reserves and
access.
WE SUBMIT THAT a public foot access easement be created from the Wanaka-Mt Aspiring Road to Parkins Bay, and an area for carparking be reserved at the Fern Burn Bridge (there being insufficient road-side area for parking) so that any future marginal strip can be utalised for access to the lake.
WE SUBMIT THAT an extended area at the Fern Burn be reserved for recreation purposes, as per DOC's original recommendations.
Marginal strips
The fallaciousness of the LINZ's 'nothing-to-do-with-me' stance on marginal strips is yet again demonstrated by this case. Their head-in-the-sand posture will have to change if Government's presumed objectives for public recreation are to be satisfied by tenure review.
We note that there are former Section 58 Land Act, now section 24(3) Conservation Act marginal strips, along the Motatapu and Matukituki Rivers, and the Lake Wanaka shoreline. However these are fixed-position strips that do not move with changes to watercourses. The Designations Plan for the Preliminary Proposal overlays the position of these strips with the topographic database. This reveals substantial lack of coincidence between legal boundaries and riverbanks along the Motatapu, in particular the reach between the upper and lower Motatapu bridges. There is a lesser degree of divergence between strips and the banks of the Matukituki, however the lack of practical linear access necessitated initial proposals for public easements their full lengths. This solution would become unnecessary if, as an integrated part of tenure review, existing fixed strips were exchanged for new movable strips.
As noted earlier, the marginal strip along Lake Wanaka appears to be off-shore. If this is the case, Part IVA Conservation Act will necessitate the creation of new strips along a redefined shoreline at the time of disposition. Also new strips will be required along river banks where these deviate from the existing strip. This will create a very messy legacy that, with further inevitable river realignment, will end up with disconnecting fixed and movable sections of marginal strip. The situation would be better dealt with as follows-
WE SUBMIT THAT all existing marginal strips be exchanged for movable strips utalising the provisions of section 24E Conservation Act.
The above strips were created in 1989 at the time of the issue of this lease. This was a consequence of subdivision from Alphaburn. There are no other marginal strips on this property. We wonder why strips were not also created along the Fern Burn when the legal obligation to do so (at a time of 'disposition') was the same for the above rivers and lake. Casual inspection reveals that the bed of this strip is far in excess of the minimum of "an average of 3 metres". The absence of strips along the Fern Burn creates uncertainties for tenure review.
Whilst the Due Diligence Report, p 2, states that the Fern Burn was "assessed by the Chief Surveyor in 1998 (for tenure review purposes) as being over 3 metres in width its full length of the lease", going by past official performance, there can be no assurance that strips will in fact be created during this current final act of disposition. Yet the tenure review proposals on this property, and the neighbouring Alphaburn, depend on marginal strips being created. Access to and over Alphaburn is necessary for access into the upper Fern Burn and proposed conservation areas, as well as to Lake Wanaka - the latter being the only such provision that may result from tenure review if the Preliminary Proposal is adopted. If marginal strips are not created then alternative public access will be necessary.
If provision of marginal strips really has nothing to do with the CCL's decisions on tenure review, then he should take no account of what DOC may or may not do in regard to creating marginal strips. There is a clear public need for access up and down the Fern Burn. That need must be satisfied under the objects of the CPLA. To be consistent with a 'nothing-to-do-with-me' stance, no unspoken reliance can be placed on other agencies creating public access along this stream. Therefore the sole responsibility for fulfilling the objectives of the CPLA, in regard to securing public access and enjoyment of reviewable land, falls on the CCL and his delegates.
WE SUBMIT that, unless the CCL ensures that marginal strips will be created, public foot access easements be created either side of the Fern Burn, the full length of the property, of sufficient width to secure practical access even when the Burn changes course.
Motatapu and Matukituki River access (including Easement E2)
We welcome the intention of creating public access part way down the true right bank of the Motatapu River between the upper and lower bridges, however we believe that due to the ongoing process of river meandering, fixed position easements fail to "secure public access and enjoyment of reviewable land" as required by section 24(c)(i) CPLA. Only movable marginal strips will achieve this objective.
We note that easement E2 was proposed from the outset of DOC's initial recommendations as part of a more extensive proposal for access the full length of the Motatapu and Matukituki to the West Wanaka bridge. This is what DOC had to say in the Conservation Resources Report, p4 -
"Extended walking access is also desirable from the Motatapu Gorge bridge along the full length of the Motatapu River to its confluence with the Matukituki River. From here the route would go down the Matukituki River to the West Wanaka bridge. While most of this route could be catered for within the [existing] marginal strips, extensions to this strip or easements will be required in some areas".
However, despite there being a clear recreational need for this access, DOC's revised recommendations inexplicably dropped access the full length of the Motatapu and Matukituki.
Fish & Game also recommended that access should be provided along the Motatapu to the Matukituki, however, "they also advised that in their view the marginal strip which will deem to exist along the Motatapu River on disposition of this land will satisfy their requirements" (our emphasis), Submission Draft Preliminary Proposal, p 12. However the above conclusion was based on an erroneous assumption that there are no existing fixed strips and consequently new, movable marginal strips are yet to be created. If the latter were the case, this would be adequate and additional easements unnecessary. However as discussed earlier, the existing marginal strip is fixed in position and does not coincide with current river banks its full length. Its existence, along current sections of river bank, precludes the creation of new movable strips, unless the CCL and DOC make a policy change to deal with marginal strips as part of tenure review, involving the use of section 24E Conservation Act. Either the existing fixed strip needs to be exchanged for a movable strip so as to accommodate the reasonable anticipation of further changes to the river course, or other access arrangements made over those sections where the marginal strip is impractical for access.
The case for practical public access the full length of the Motatapu and Matukituki River banks has already been made. This is stated to be in accord with the objects of the CPLA. The Preliminary Proposal of only partial riverbank access is therefore not in accord with the Act's requirements.
The proposed fixed-position easement, as depicted on Schedule G to the Drafting Instructions, shows the alignment crossing two river flats that are subject to periodic meandering by the river. The easement alignment is apparently based on two erroneous assumptions. The first is that the easement is secure from further attack and interruption by the river. Both topographic record and evidence on the ground (old channels), demonstrate that this is far from being the case. It is almost certain that the chosen alignment will be interrupted in the future (Photo 11).
The duty under section 24(c)(i) CPLA to secure public access, along the banks of actively meandering waterways, cannot be satisfied by an immovable easement. 'Secure' is defined as-
'Secure': Safe against attack, impregnable, reliable, certain not to fail or give way, having sure prospect from interruption. Concise Oxford, Seventh Edition.
An alternative mechanism is required. The only alternative mechanism available under relevant law are moveable marginal strips. Section 24E Conservation Act provides a means of creating such when existing fixed strips are already in place. The creation of movable strips along these riverbanks provides the only obvious means of compliance with the CCL's duties under section 24(c)(i) CPLA.
The second erroneous assumption behind this easement is that the duty to secure public access and enjoyment is confined to providing a means of travel just between start and finish points. The proposed alignment appears to be outside of the probable location of the existing 20 m wide marginal strip for much of its distance. The easement will therefore not provide legal rights of access to the riverbank and riverbed - which is the primary recreational attraction. The Conservation Resources Report records the river as being the focus of existing recreational activity, yet the current proposal makes only incidental provision for river access, in possibly only a few places where easement and marginal strip boundaries coincide. It also takes no account of river users, whom commence their downstream journey either by foot or floatation at the upper Motatapu bridge, from exiting via the easement wherever river conditions may force them to do so. In effect, the provision of a public access way parallel to but distant from the river and the marginal strip will create a necessity to trespass across intervening freehold land. Creating such an avoidable violation of private property rights is not an action of responsible Government.
Currently there is minimal public foot-orientated use of most of the lower Motatapu and Matukituki riverbeds and banks because there is no provision for access, except near road bridges. With the provision of a marked, and where necessary formed, route this situation would change dramatically. There are very limited opportunities for riverside walks in the Wanaka region. In combination with other opportunities at Diamond Lake, a walking route allowing through access between the West Wanaka and Motatapu bridges, with ease of access to and from these rivers, would become extremely popular (Photo 12). We believe that the Crown has a major obligation to ensure that this opportunity is secured, now. It is most unlikely that any official moves will be made to do so subsequent to tenure review, as there will be no incentives for future freehold owners to agree to such, and probably plenty of contrary reasons. Action to create movable marginal strips as part of tenure review, would provide secure, long-term access without the additional time and expense of creating a flawed and inadequate easement.
WE SUBMIT THAT, using the provisions of section 24E Conservation
Act, existing marginal strips along the banks of the Motatapu
and Matukituki Rivers be replaced their full length with movable
strips of sufficient width to ensure uninterrupted practical foot
access now and in the future.
Loop Track at 650m north from Rocky Mount
DOC original recommendations included a circuit easement north from Rocky Mount, however this was reduced to a short return track to a proposed reserve, now to be a covenant. This track has now been dropped completely from the Preliminary Proposal. DOC stated that "the (circuit) route is likely to be very popular", Drafting Instructions for Draft Preliminary Proposal.
However after consultation with the holder it was recommended that this easement be deleted from the proposals. The official justification was-
"It is accepted that this easement traverses a wide area of proposed freehold land which will be subject to grazing by domestic animals which may conflict with public access. Also the route is likely to receive only moderate public demand. In light of these factors we support this easement being deleted from the proposal" (our emphasis).
The above instance is an example of all too prevalent tailoring of advice to advance current proposals, rather than reliable professional guidance to the CCL.
A full circuit easement would provide outstanding views of the mountains surrounding the lower Matukituki valley and of the river itself. Such views are partly obscured from Rocky Mount. The initial advice that this route "is likely to be very popular" is the more reliable, given that an estimated 150,000 people have enjoyed the Diamond Lake-Rocky Mount walking track over the last 10 years (Otago Daily Times, 16/9/02), and that the proposed northern circuit would directly link on to this. How such heavy use can be officially downplayed to "only moderate" should be cause for inquiry by the CCL, given his reliance on such advice for his decision making.
Terms of easements E2 & E3
Dispute resolution
We note mechanisms for resolving disputes between the Transferor and the Transferee, but there is no provision for public involvement. Given that "any member of the public" is included within the definition of 'Transferee', but excluded from any settlement of disputes, we think it only proper that there be an express requirement for s49 Conservation Act procedures whenever any change, or extinguishment, to the terms of public easements is proposed, or if protracted obstruction or closure of public access occurs. WE SO SUBMIT.
Exclusion of schedules
We note an express exclusion of the rights and powers contained in the Ninth Schedule of the Property Law Act, but not of those in section 126G which enable modification or extinguishment of easements through the Courts, without public process. Such a provision undermines the legislative intent of section 24(c)(i) CPLA to secure access. WE SUBMIT THAT section 126G of the Property Law Act be expressly excluded from the terms of the public access easement.
Temporary closures/suspension
We are concerned about the 'temporary suspension' provisions of the draft easement -
"The Transferee may close all or part of the Easement Area and suspend public access to it if reasons of public safety or emergency require closure, or otherwise in accordance with the provisions of section 13 of the Conservation Act 1987".
Section 13 Conservation Act only applies to conservation areas. The easement areas will be private freehold. Therefore including the above provision in the terms of the easement cannot be in accord with the Conservation Act and must be deleted.
There is no statutory authority cited for closure for public safety or emergency. Emergency powers should be exercised either by the Police or Rural Fire controlling authority for genuine emergencies only. In view of DOC's partiality towards private sector interests at the expense of public recreation, we do not trust the department with powers of considerable discretion and vagueness such as "public safety". Such powers could easily be subject to misuse.
These provisions fail to properly comply with "the securing of public access to and enjoyment of reviewable land" as required by section 24 (c)(i) CPLA.
WE SUBMIT THAT the temporary closure provisions be deleted.
OSH and ACC
We note that in official papers supplied to us in regard to the Longslip tenure review, the holder raised concerns about Occupational Safety and Health, and Accident Compensation Commission liabilities arising from public easements over freehold. As far as we are aware, this is a generic issue that has not been dealt with in this or any other tenure review. The CCL's failure to deal with these issues potentially undermines all easement provisions arising from tenure review. There is no assurance, despite the express terms of these easements, that the public right to pass and repass at all times will prevail over land holders taking action to remove liabilities that may arise from having members of the public on their freehold. The holders' solution may be to bar public passage, notwithstanding the terms of this or other easements.
The dedication of public paths/roads, rather than the creation of easements, would avoid such difficulties. Paths would be public rather than private property, and unable to be deemed places of work or employment for the purposes of OSH or ACC.
WE SUBMIT THAT, to provide security of public access, as required by section 24(c)(i) CPLA, the proposed public easements instead be dedicated as a public roads-paths for pedestrian passage.
Yours faithfully
Bruce Mason
Researcher & Co-Spokesman
