Submitted 3 August 2020: Read the NZCA's submission on the Department of Conservation's Tahr Operational Control Plan for 2020-21.

Submission date: 3 August 2020
Submitted to: Department of Conservation

The Legislative Basis for the New Zealand Conservation Authority submission

1. The New Zealand Conservation Authority (NZCA) was established under the Conservation Act 1987, with members appointed by the Minister of Conservation. It is an independent statutory body with a range of functions, but primarily acts as an independent conservation advisor to the Minister and the Director-General of Conservation.

2. The NZCA has a growing role as an objective advocate on matters of national significance and interest in the conservation arena and provides high quality independent advice to the Minister of Conservation and to the Department of Conservation (DOC) on its strategic direction and performance.

3. The NZCA has a range of powers and functions, under the Conservation Act 1987, as well as under other conservation related legislation. Under the Conservation Act, section 6C(2)(c), the NZCA has the power to “advocate the interests of the NZCA at any public forum or in any statutory planning process.”

4. The NZCA also has a function under section 18(g) of the National Parks Act 1980 “to give advice to the Minister or the Director-General on any matter relating to any national park”.

5. Among the NZCA’s statutory functions are the approval of conservation management strategies, conservation management plans and national park management plans, and review and amend such strategies and plans. These constitute the key management documents for directing conservation effort and resources in New Zealand. Many of these documents have objectives, policies and outcomes relating to the conservation of native species and predator control.

6. The NZCA has participated in the Tahr Plan Implementation Liaison Group meetings over the last two years.

7. Following the logic of the above powers and functions, the NZCA submits on the Tahr Control Operations Plan 2020/21 and appreciates opportunities to provide feedback on how this will be achieved.

NZCA Submission

8. The NZCA submission is based on their analysis of:

  • Tahr Control Operational Plan 2020-2021
  • Himalayan Tahr Control Plan 1993
  • Conservation Act 1987
  • National Parks Act 1980
  • Wild Animal Control Act 1977
  • Conservation General Policy 2005
  • West Coast Conservation Management Strategy
  • Canterbury (Waitaha) Conservation Management Strategy
  • Aoraki/Mt Cook National Park Management Plan
  • Westland/Tai Poutini National Park Management Plan

9. The NZCA strongly supports the Department of Conservation’s Tahr Control Operational Plan 2020-21.

10. The Department’s Annual Tahr Control Operational Plans seek to achieve the targets set in the Himalayan Tahr Control Plan 1993 (HTCP), prepared under section 5(1)(d) of the Wild Animal Control Act 1977. These annual control plans are devised after advice from Ngāi Tahu, the hunting sector, and the Tahr Plan Implementation Liaison Group, and so reflect the efforts of the HTCP to achieve a balance between human activity and the health of the environment. A balance that can be achieved when the tahr population is at 10,000 across the feral range.

11. The NZCA supports the priorities listed in the Tahr Control Operational Plan (TCOP) 2020-21 and offers comment below.

Priority: Zero density in National Parks

12. The NZCA strongly supports the 2020-21 priority to take the Aoraki/Mount Cook and Westland Tai Poutini National Parks towards zero density.

13. National Parks provide a safe haven for Aotearoa’s native species, and the Department of Conservation has not only a moral, but a legal obligation to ensure that this protection is robust.

14. The extermination of tahr in the National Parks is consistent with the National Parks Act 1980, the General Policy for National Parks, and the Management Plans of both the Aoraki/Mount Cook National Park and the Westland Tai Poutini National Park.

15. Himalayan Tahr were introduced to New Zealand in 1904, and so our native flora are ill equipped to defend against these grazing mammals. The grazing behaviour of tahr damages endemic flora, such as Tall Tussock, Mount Cook buttercup, NZ Veronica, and Godley’s buttercup, which is classed by the NZ Plant Conservation Network as threatened and nationally endangered. This damage has lasting implications for a variety of fauna including insects, moths, birds, and alpine lizards.

16. With the impending escalation of climate change effects, we must do all we can now to ensure that these endemic and native species are provided the protection assured to them under the status of National Park.

17. Previously, the Department have compromised the intrinsic value of our National Parks for the appeasement of the hunting sector; so the NZCA is pleased to see that the proposals within this plan realign the Department’s legal and moral obligations to the Aoraki/Mount Cook and Westland Tai Poutini National Parks.

18. The National Parks comprise 21% of the tahr feral range, and so there is significant alternate opportunity for tahr hunting in New Zealand to continue across 558,000 hectares of public conservation land.

19. In addition to this, and prior to Covid-19, location data from Aerial Assisted Trophy Hunting concessionaires reveals that an average of only 67 bull tahr were declared shot per year in these two National Parks over the last five years. The hunting tourism industry that takes place within National Parks, is a niche one, for which the ecological sacrifice cannot be justified.

Priority: Recreational hunting, guided hunting, and commercial recovery

20. The NZCA supports the priority to maximise efficacy of population reduction through recreational hunting, guided hunting, and commercial recovery.

21. It will be important for the Department to work with the hunting sector on public conservation land, private land, and pastoral lease land in order to fully realise the current population levels and to reach those specified in the HTCP. There may be opportunity to offer employment opportunities to those hunters affected negatively by Covid-19.

The NZCA submits that: the Department explore potential employment opportunity through the Jobs for Nature initiative in order to utilise professional and commercial hunters who have been negatively affected by the Covid-19 pandemic, to achieve tahr population levels as specified in the HTCP.

Priority: Bring populations towards levels in the HTCP  

22. The NZCA supports the priority to bring populations towards levels in the HTCP by focusing on localised areas of high density of tahr and on areas where tahr have mobbed up, thus protecting natural values at place.

23. There are contemporary factors to consider when assessing the control needs for tahr in 2020-21. The impacts of Covid-19 have already had significant effects on control and monitoring operations planned between March and May 2020. Covid-19 will continue to require severe border restrictions, and so will continue to impact the international market and hunting tourism industry for an undetermined amount of time. This is an unprecedented situation and warrants the intervention of the Department to undertake control operations.

24. Controlling tahr numbers in National Parks to the lowest practical densities, as far as possible, and to a maximum of 10,000 across the feral range, as stipulated in the HTCP, will provide opportunity for Aotearoa’s biodiversity to thrive, ensuring the enjoyment of the National Parks, and the Southern Alps for generations to come.

Priority: Establish the size of populations off PCL

25. The NZCA supports the priority to establish the status of tahr populations off public conservation land.

26. The populations of tahr on private and pastoral lease land is currently unknown. It will be critical to the ongoing control of tahr, for the Department to understand these population densities and trends.

Research and monitoring

27. The NZCA strongly supports the work proposed to develop an integrated research and monitoring programme.

28. The HTCP recognises the need to continue to monitor and undertake further research. This will enable the Department to accurately assess the impacts of tahr control environmentally, culturally, and economically.

The NZCA submits that: the development of an integrated research and monitoring programme should appear as a priority in the Tahr Operational Plan 2020-21.

Concluding Comments

29. The NZCA have delivered consistent advice to the Minister of Conservation on this matter, as can be seen in the attached public correspondence dated July 2018, April 2019, and July 2020. The NZCA has consistently highlighted the rising numbers of tahr and the expanding feral range as major concerns, and have advocated for many of the actions now stated in the TCOP 2020-21 to come into effect in previous Control Operational Plans.

30. The TCOP 2020-21 displays a tangible intent to fully understand the extent and impacts of tahr populations in New Zealand. There is a focus on striking the balance between ecological health, and achieving sustainable hunting practices.

31. The NZCA give their full support to the policy of total control of all tahr within the National Parks, and continued efforts to achieve a tahr population level and feral distribution in accordance with the HTCP.

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