"In theory they could, but I can't really see people doing that", said Ms Watson.
Holidaymakers were not entitled to use treat the facilities inside the baches as public, she said.
The department initially proposed that all West Coast baches and huts should be removed by 2025, and made the owners responsible for removing them.
However, it softened that stance last year after acknowledging such baches were part of New Zealand culture and said they could stay but owners would "encourage private owners to allow public use of these facilities", unless they were being used as a fulltime residence.
The intention of the plan is to prevent exclusive use of public conversation land where baches - some dating back to the 1960s - have been built.
Public conservation land was for everyone to enjoy, said Ms Watson, although DoC accepted there were some deviations that need to be taken into account.
"DoC's general policy aims, however, to ensure that all visitors have appropriate access to structures built on public conservation land."
As part of the concession, owners would need to "make provision, where appropriate, for public use of the facility", said the policy.
Bach owners would be encouraged to allow public access through the conditions of their concession as they were renewed and several of the 95 baches affected had already been through the process, said Ms Watson.
However, she was unable to confirm how many.
Many owners made submissions on the plan as part of the consultation process - "a number of bach owners submitted at the time that they would be happy to have public access to their bach", said Ms Watson.
The strategy was finalised in 2010 after extensive public consultation.
One new South Westland bach owner, Steve Keen, did not believe the policy when he was informed of it by the Greymouth Star.