Proposed National Policy Direction for Pest Management Plans and Programmes - NZCA submission
IntroductionSubmitted 14 June 2013: Read the NZCA's submission on the Proposed National Policy Direction for Pest Management Plans and Programmes.
Submission date: 14 June 2013
Submitted to: Ministry for Primary Industries
The purpose of the Biosecurity Act is the eradication or effective management of harmful organisms in New Zealand and the Authority supports the introduction of national and regional pest and pathway plans, and small-scale management programmes to give effect to that purpose.
The Authority congratulates the Ministry on a clearly presented document and it supports, with some minor amendments, the proposed policy direction.
However, it has reservations arising from reading Part 2 where the intentions behind the policy direction are explained. In the Authority’s view those intentions appear to unreasonably biased in favour of the productive sector. The Authority considers that insufficient regard is expected to be given for both the benefits to be derived from land under natural vegetation, especially where set aside for conservation purposes, whether on private or Crown land and the costs incurred to such land by pest invasion.
Specific comments and recommendations
Recommend “costs and benefits” be defined.
The Biosecurity Act defines costs and benefits as meaning includes costs and benefits of any kind, whether monetary or non-monetary.
As the meaning of costs and benefits is so fundamental to understanding the National Policy Direction, the Authority considers there is value in including it in the Direction rather than relying on users to reference the Act.
6 Directions on setting objectives
(1)(b)(iv), (2)(c)(iv) and (3)(b)(iv) “where the costs imposed on persons are manageable”. The Authority interprets its meaning as the land occupier’s ability to pay. This seems inappropriate as an outcome in this context.
Recommend that in each of the three instances referenced, it be “where the costs and impacts are manageable”.
The inclusion of the word “impacts” reinforces that it is not only monetary costs that are relevant.
7 Directions on analysing benefits and costs
(1)(a) Recommend that benefits and costs be separately identified and valued.
Separating the analysis would require planners to undertake an equal, or at least more deliberate, assessment of benefits and costs which we would expect to include both direct and indirect costs.
Recommend delete “including the direct costs to land occupiers of complying with the rules in the plan” and replace with “including the costs to both the council and land occupiers of complying with the rules”.
The current wording emphasises one aspect which may influence the assessment against a more considered and balanced approach. The Authority acknowledges that its genesis is likely the situation described on page 26 where some councils only considered their own costs and not the costs to land occupiers, but the balance has been tipped too far the other way.
Section 15.3 acknowledges the difficulty of determining true costs and benefits of pest impacts and options available to manage pests. Environmental, social and health-related costs are specifically mentioned. The Authority also notes there could be other costs and impacts such as erosion of ecosystems, damage to cultural and historic heritage and threats to native species. In some cases, e.g. the services derived from ecosystems, costs may be incurred by both individuals such as adjoining landholders and the general public. Similarly, their indirect benefits may far exceed the direct benefits from any individual adjoining landholder’s activity.
(2)(a) The Authority is pleased to see the inclusion of a probability assessment.
10 Directions on good neighbour rules
The explanations given in sections 15.4 and 15.6 appear to identify that narrow interpretation of costs is intended. The boxed example which refers to “economic harm to individual landholders or groups of landholders” reinforces this impression.
The Authority’s recommendations for amendments to the Directions are intended to clarify that costs are to be more broadly considered.
Lastly, the Authority notes that animals may be managed independently of the land occupier and may be managed to a higher level than the land occupier would wish. The Authority has in mind specifically the Game Animal Council Bill currently before Parliament which will provide for the Council to manage designated herds of wild animals on public conservation land in the interests of hunters. That purpose may conflict with the Department’s responsibilities as land occupier. The Authority does not see how this can be solved by the Direction on Good Neighbour Rules but it does see this as a problem.
Dr Kay Booth