Submitted 6 November 2007: View the NZCA's submission to the Game Animal panel, on deer, chamois, thar and pigs.

Submission date: 6 November 2007
Submitted to: Deer, chamois, thar and pig panel of inquiry

Identification of the New Zealand Conservation Authority

The New Zealand Conservation Authority (NZCA) is established by section 6A of the Conservation Act 1987. It has 13 members appointed by the Minister “having regard to the interests of conservation, natural earth and marine sciences, and recreation”. The NZCA has a range of statutory functions, primarily set out in the Conservation Act and the National Parks Act 1980.

Role of the NZCA

The NZCA, as a statutory body with decision-making powers, has issued General Policy for National Parks (which applies solely to national parks) and contributed to Conservation General Policy under s 6B(a) of the Conservation Act (which applies to all other public conservation areas), to provide guidance for the interpretation of conservation legislation. The NZCA also has other decision-making functions, and is at pains to ensure that it has a firm basis in law to defend its decisions.

The NZCA’s other functions include giving advice to the Director General and the Minister on any matters of nature conservation it considers of national importance, and to consider and make proposals for the change of status or classification of areas of national and international importance.

General Policy

Issues relating to the management of introduced species on public conservation lands, including recreational and commercial hunting, were thoroughly examined by the Authority in the exhaustive General Policy process 2003 - 2005. Consequently, NZCA confirms that the policy position as set out in the GPNP and CAGP is its preferred approach. i.e. wild introduced animals to be controlled as threats to indigenous species, habitats and ecosystems.

CGP 4.2(e) Commercial hunting of wild animals and animals pests should be encouraged to maximise the effective control of them, while minimising adverse effects of hunting on planned outcomes at places.

CGP 4.2(f) Recreational hunting of wild animals and animal pests should be encouraged where this does not diminish the effectiveness of operations to control them and is consistent with planned outcomes at places.

Public conservation land does not all hold the same land classification - historic, nature, scenic and scientific reserves, national parks, and others.   Legislative expectations as to how the land will be managed differ with the land classification which sets out the purpose for which it is held. To give an example – in general terms national parks are places where the native plants and animals of the parks are preserved and introduced plants and animals are to be exterminated. Whereas in recreation reserves, the fauna, flora and wildlife are managed and protected to the extent compatible with the principal or primary purpose of the reserve (although fauna protected by the Wildlife Act and archaeological features retain high levels of protection).

As stated in General Policy for National Parks 2005,

Many introduced plants and animals pose serious threats to the survival of indigenous species and the functioning of indigenous ecosystems in national parks. Plant and animal pests are increasing in both number and distribution and have become a pervasive obstacle to the preservation of indigenous plants and animals and ecosystem functions in national parks.

The Authority affirms that the immediate objective is to reduce by all available means introduced species to a level where they do not impede the preservation of the indigenous species within a national park. To the extent identified elsewhere in this General Policy, this objective does not apply to the extermination of salmonids and introduced game birds. The extermination of other introduced animals in national parks, and in particular areas within national parks, should be undertaken if this is possible.

There should be a strong emphasis on comprehensive biosecurity and pest management planning and on timely and, where appropriate, rapid intervention to prevent the introduction or spread of introduced plant and animal pests that pose serious risks to national park values.

The NZCA approach

1. Notwithstanding the legislative framework, the NZCA supports giving primacy to indigenous fauna and flora over introduced species as an over-riding principle of conservation management in New Zealand, particularly on public conservation lands. In the case of national parks, the NZCA is of the firm belief that there should be no change to the National Parks Act to remove the extermination goal referred to above (see section 4(2)(b) of the National Parks Act).

New Zealand’s national identity is grounded in our national parks and other public conservation lands, which were set aside for protection of their intrinsic values and indigenous species. Browsing animals have, and are, modifying our indigenous ecosystems to the extent that the public may be seeing a highly modified species composition when they visit public conservation lands. The loss of palatable fruiting plant species from the under-stories of our forests has a cumulative impact on the food chain for other native species, especially birds. Despite the legal protection ascribed to them, many of our indigenous species, habitats and ecosystems are under severe threat.

A management regime which facilitates degradation of indigenous biodiversity, which is New Zealand’s unique natural heritage, in favour of recreational or economic benefit based on introduced animals is considered unethical; the more so in areas specifically set aside for the protection and enjoyment of qualities unique to New Zealand.

The fact that the exact density of feral animals to achieve restoration of biodiversity to a former more natural state is not precisely known, is not a reason to allow for these animals to be managed by recreational and commercial users. Indeed, the generally accepted principle in such instances is to take a precautionary approach which in the current instance would be for the Crown to retain its role and decline to liberalise the existing legislative regime.

NZCA does not accept the hypothesis advanced in the discussion paper that ungulate browsing is no different to that of extinct moa species. There is, conversely, plenty of evidence to suggest otherwise.

2. As a guiding principle, management of public conservation lands should take an overall integrated view in the wider public interest, and not be driven by any single group or use. There is an extensive history of legislative and policy developments, science and operational experience to support this view.

3. The NZCA considers that recreational hunting is well provided for on public conservation land, with the vast majority of these lands being open to hunting, including several areas designated Recreational Hunting Areas (RHAs)) under the Wild Animal Control Act.

The NZCA considers that there is ample scope within the current management regime for the Department of Conservation and hunters to work together to maximise the effectiveness of recreational hunting as a mechanism for the control wild animals. There may be conflict within the hunting interests as to goals for the management of wild animals depending on the nature of their interest; for example, sport, trophy gathering, food, exercise, camaraderie, conservation. No one set of hunter interests will represent all interests, even within the hunting fraternity, and a broader view needs to be taken when managing wild animals.

A UMR survey of September 2007 established that only 3.9% of visitors to public conservation lands go hunting or fishing; this small percentage which includes fishermen reinforces the importance of taking a broad view in the general public interest and not allowing the interests of a few, albeit a vocal and politically astute few, dictate public policy.

4. The NZCA especially does not support the use of public conservation lands for the protection of wild animals or their management in the interests of those who put the personal or economic benefits they derive from them ahead of a wider range of values, the purposes for which the land was set aside, and the interests of others in that land, including safeguarding the options for future generations.

Another likely outcome of such an approach would be what is known as the ‘tragedy of the commons’ , where the cumulative actions of individuals seeking to maximise their own benefit results in disbenefits for the public as a whole.

5. The Authority does not support hunter control of wild animal management in a formal sense. It may or may not be effective in the promotion and protection of hunter interests, but under such a mandate it inevitably follows that the interests of others are secondary. Examples include the management of sambar deer and Canada geese, where the objectives of other parties, including directly affected commercial parties, have not been delivered.

Such approaches also create difficulties for future decision-making, as they inevitably result in a resistance to any removal of mandate or diminution of rights which have been created.

The assertion that hunters can control Himalayan tahr (thar) numbers is not backed up by the figures in the annual reports.  Hunters reported only 911 kills in 2006 and 522 kills in 2005, necessitating culls by the Department of 2120 and 2498 animals respectively to keep numbers close to the maximum set in the Himalayan Thar Control Plan.

The Panel’s discussion document

The NZCA is disappointed that a broad context is not provided by the Panel in its discussion paper. One view only is given and limited options only for people to select from.  This approach inevitably results in pre-determination of outcome. A broad context would have provided goals for the preservation and protection of indigenous biodiversity and more open questions would have enabled a broader range of perspectives and interests to have been expressed.

It is disappointing, too, that the Panel’s terms of reference precluded it from taking a wider review which could have better addressed the biosecurity aspects of the management of wild animals.

None of the options proposed by the Panel are supported by the NZCA.

The NZCA considers that any management regime of wild animals:

  • Should be based on priority being given to the maintenance of indigenous values, including species, habitats and ecosystems, in naturally occurring assemblages and across their natural range; especially in national parks and reserves.
  • Should avoid entrenching economic exploitation of any introduced species of any kind that have negative impacts on the aforementioned including the full range of benefits (including commercial) that can be derived from them
  • Be a rational, integrated and sustained approach, avoiding the historical “see-saw” approach to pest management that has led to the current situation where pest numbers fluctuate according to social and economic, as well as biological and climatic, factors.

In the 21st Century, consideration of the adverse effects of introduced browsers on “ecosystem services” provided by public conservation lands, should be given much more serious consideration, including adverse effects on soil, water and forest conservation, and the production of greenhouse gases and as potential disease carriers, and should be part of a fully integrated conservation management approach.

For clarification, NZCA does not see “integrated management” as meaning “multiple use”, which is implied in the options promoted by some hunting interests. The history of New Zealand’s conservation management leading up to the formation of the Department of Conservation illustrates the weaknesses of the multiple use model. A conscious decision was made by Parliament to depart from that model, and the NZCA sees no evidence to justify returning to it.

The experience of multi-use management in other jurisdictions e.g. the northern hemisphere, is irrelevant because New Zealand’s native ecosystems are fundamentally different from such ecosystems as are its species and their ability to withstand the impacts of introduced wild animals.

Another option to the status quo is to set targets for a programme of restoration of larger areas of public conservation lands (including national parks) to be largely pest free, building on the current mainland island programmes.

To conclude, the Authority does not support any of the options laid out on p15 of the discussion document, as even the option to manage these wild animals as pests makes assumptions that there are only some places where control is needed, and does not address the intrinsic values of our public conservation lands. Nor are the options consistent with the National Parks Act, Conservation Act, and their statutory policies which is about protection, not mitigation. The Authority is disappointed that none of the proposals are seriously aimed at reducing the damaging effects of these animals on our natural (and in some cases, historical) heritage.

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