New Zealand Deerstalkers' Association

Granting of Heli-Hunting Licences on Public Lands from February 2010

27 January 2010

On 17 December, I wrote to several members of parliament, to draw their attention to the issue highlighted above. Our national executive decided that I should copy that letter to you, out of courtesy, and so you could be made aware of the matter and our strong objection to it.

I wish to follow that letter, with a further representation on behalf of our national executive members, and the 7,700 members of our association. We wish to draw your specific attention to, the alarming process being instituted by the Department of Conservation, in respect of introducing new heli-hunting concessions on lands not covered by general policy, or CMS/CMP provisions, and the National Parks Act.

1. NZDA’s interpretation of the situation

We see the provision of heli-hunting permits by way of a Conservation Act part 3B concession, as being quite different from the provision of wild animal recovery operation (WARO) permits by the same legal instrument. We note that your department’s own determination report on the new WARO framework (File PAC12 08 02, Section 2.2), states that WARO permits may only be used for recovery of animal carcasses, and live deer capture. This section specifically states that:

“… the proposed activity specifically excludes the carriage of either recreational hunters or fare paying passengers.”

Your department’s own definition of heli-hunting is in direct contrast to the terms applied to WARO activities in recent documentation. The definition appears on DOC’s website; I offer some pertinent extracts below.

“Heli-hunting is defined as an activity where an aircraft is used to take a paying client hunting … for trophy animals. The activity generally involves the helicopter being used to search for and find the trophy, to position the hunter on the ground and, if necessary, the helicopter prevents the animal from escaping until it is shot by the hunter. The helicopter then recovers the hunter and the trophy.”

NZDA accepts that the activity of wild animal recovery is a long-standing one in New Zealand’s tradition of commerce in the outdoors. Though we may discourage it and object to its impact, we accept it is legally authorised under the Conservation Act and the Wild Animal Control Act.

However, we refuse to accept that heli-hunting is yet a legitimate activity in any of our back country, and dispute that it can even be considered a legal or legally defensible one, under the raft of statutes which protect, people, animals, and our natural environment.

NZDA wants to point out that our experience of heli-hunting practice differs greatly from your department’s definition as stated above. We would be happy to provide you with substantial documentary evidence of undesirable hunting practice, including the shooting of animals from helicopters by untrained hunters. Please indicate if you wish to learn more of these practices; we will be pleased to assist.

I will ask you respectfully, to consider our interpretation and enquire further of your officials, about the relative status of both activities, and their repute and acceptability as investigated by your department, and its stakeholders. We are certain, from our own discussions with several other NGO’s, that heli-hunting has in no way, the same level of acceptance, that WARO operations do, and is never likely to among recreational hunters.

2. Principal objections to the proposed scheme

The department’s current proposals amount to the imminent designation of huge areas of highly valued conservation lands, for use by heli-hunting operators. Many of these lands are in forest parks or low priority conservation areas, which are excluded from specific management strategy or management plan provisions operated by conservancies. They are also highly valued by hunters who choose to walk into them, and use their own physical effort and mental agility to secure a trophy. Such hunters in our experience are trained to use the New Zealand outdoors safely, skilled in dispatching animals humanely and are likely to disturb flora and fauna only minimally, and only where they have to.

For our executive and our wider membership heli-hunting on a large scale, will threaten the essence of our sport because:

• It will drive hunters away from popular areas traditionally hunted on foot, because foot-hunters will feel unsafe around areas constantly plied by helicopters;
• It will diminish back-country hunting opportunities by preferring heli-hunting operations with large yield potential, who can pay concession fees, over recreational hunters who pay nominal fees for permits;
• It will compromise New Zealand’s high standards of animal welfare observance by introducing a system of “land and shoot” hunting which cannot be policed effectively, and which is likely to have small regard for animal welfare matters, when they are set against trophy returns and client through-put;
• It will compromise animal behaviour patterns, add to animal disturbance and dispersal, and may in fact pose greater risks to indigenous flora by contributing to dispersal and fragmentation of populations.

NZDA is also very concerned that your department has not adequately considered aircraft safety and increased usage of flight-paths, and has not provided any assessment of likely effects of increases in aircraft activity over some popular areas noted in its mapping exercise for heli-hunting.

3. The current process

Finally, we draw your attention to the hurried nature of the process being adopted for lands not subject to specific management instruments. I refer you to section 1 of my letter of 17 December, which paraphrases the process available on DOC’s own website.

NZDA observes that:

• The closing date for initial feedback is 5 February, but DOC will continue to process heli-hunting applications while analysing that feedback. This is irregular and offensive to us, given the potential impact of this activity over so much land.
• The department intends to allow some operators to begin heli-hunting while full public consultation is taking place. We would appreciate your interpretation of this process, and ask that you consider whether a directive should be given to your Canterbury conservancy, to desist from any granting of interim permits, while full and proper public feedback is sought through the standard process for consultation for concessions. This is a new activity, with small favour among many; we strongly believe that consultation on it requires more care for public opinion, and less zeal to eradicate animals.
• Your department wishes to hold a stakeholder meeting on 12 February, to which we have been invited. While we value the opportunity to meet officials, we query the value of this meeting after the closing date for initial feedback, and given the intention stated by your department, to allow concessionaires to begin work, despite any public opposition which already appears to be arising.

I want to emphasise that NZDA will not support heli-hunting at all, whatever its final form; but also that we object as much to the department’s handling of the matter as we do to the activity. That manipulation is, as we understand it, within your jurisdiction and purview, as Associate Minister for Conservation. We would like you to investigate matters raised in this letter and in that of 17 December, and we look forward to a substantive reply.

NZDA will be doing all it can to bring this matter to the attention of other stakeholders in outdoor recreation and conservation. We look forward to more personal contact with you in any endeavours we enter to modify and hopefully, to stop this activity.