Pike River Coal Ltd is suggesting that the question of mining on Department of Conservation land should be addressed only when a commercially attractive mineral deposit is identified.
The privately owned miner has written to its shareholders encouraging them to make submissions in support of the Government's commitment to unlocking mineral wealth.
It suggests a pragmatic solution to what it calls the vexed issue of mining. Only when a commercially attractive mineral deposit is identified would the area be transferred out of schedule 4, or protected, conservation land.
It does advocate better access to schedule 4 land to identify commercial deposits. Currently only an area of four metres by four metres can be disturbed. It wants this increased to 10m by 20m.
The Pike River mine on the West Coast of the South Island is on Department of Conservation administered land and will ultimately be under the Paparoa National Park. The mine, which has disappointed investors, promotes itself as an example of how a coal mine can be developed on conservation land.
The company said the last government transferred 7500 sq km into the schedule 4 conservation land estate in November 2008 without the mineral potential being assessed. That is more than 180 times the total land being mined in New Zealand.
"New Zealand is currently borrowing $250 million per week as we cannot pay our bills. We cannot continue like that if we want to avoid being the Greece of the South Pacific," Pike said in the letter to investors.
"We are leaving a massive debt for our next generation to pay back. That does not seem fair to our kids and grandkids."
It said mining was a high productivity sector and a rich part of New Zealand's history. Mining employees were high income earners. The average income earned by a miner in 2008 was $93,000, which was 3.7 times higher than the average of $25,000 in the tourism industry.
The company said the debate on a government proposal to look at the mineral potential of some of its conservation land has been far from rational or sensible.
The company was hoping to rebalance the debate.