20 January 2010
The national executive of the New Zealand Deerstalkers’ Association Incorporated wishes to make the following points, in respect of facts and relevance of issues, treated in the discussion paper entitled: Heli-hunting in Aoraki/Mount Cook National Park.
The executive makes the following points on behalf of the wider membership, and will fully support submissions made by interested branches, whose submissions will be complemented by this one.
1. Matters of fact
1.1. We find the paper grossly in error in several matters of fact, and economical with the full reality of current contexts, in other cases. Specific concerns we have are:
A. The definition and description of heli-hunting. The department’s description of this activity in this paper, (footnote 1 and Para 12), is a highly sanitised version of actual practice. We find it unacceptable that DOC staff should include a definition which fails to include reference to real situations where animals are harried and chased to the point of exhaustion by helicopters, and where shooting from helicopters by untrained unskilled hunters does occur. The true situation is well-known to many of our members, and the DOC definition will not adequately reflect the wide range of barbaric practices, which conservation board members need to be aware of, in assessing the suitability of this activity. NZDA will seek to make board members aware of the less palatable aspects of heli-hunting independently of departmental staff, if necessary, to alert them to the shameful conduct towards animals, of some operators already working illegally in the park.
B. The history of the activity of heli-hunting. DOC is conveniently ignoring in its paper, the prior history of this activity, which in every case we know of, has been illegal. We know of no single instance in any conservancy in the South Island, where a request to undertake heli-hunting as if it were a concessionary activity, has been granted to this date. This is relevant to the varieties of advice the board must consider, because the board must have regard to the principles of management of national parks, and also to DOC’s historic view and management of, all activities in them. We find it unacceptable that a very brief, and edited version of the history of heli-hunting, failing to acknowledge refusals by DOC to grant historic permit applications for this activity, is part of this paper; a more substantial and truthful treatment may serve as better advice to the board.
C. The use of foot-access by hunters. Members familiar with the park have informed the executive, that DOC’s passing references to foot-access within the park are incorrect, and that greater summer and winter use of tracks and remote areas by hunters on foot, is attested by hunter data available to NZDA. NZDA expects more detail to be included in any advisory papers to the board, and will provide it ourselves, through local submissions and through our own representation, to members of the board at any public engagements we have with its members.
1.2. A major flaw in the paper is the absence of a treatment of potential effects on visitors, or projection of environmental effects and visitor impacts, of this new activity. DOC requires concessionaires to provide as part of their applications, full EIA documentation which is especially appropriate for new activities. Yet, it cannot even provide an adequate risk assessment, based on visitor data, tahr ecology and impacts on tahr behaviour, or from standard planning tools used for conventional assessments of environmental affects. Such a gap in the paper is in our view, enough to undermine the integrity of this proposal, and is well below the standard DOC sets for those whose activities on Crown lands, it oversees.
1.3. This paper makes a conveniently brief reference (Para 26), in a pointless rhetorical manner, to the question of whether heli-hunting is the best use of aircraft, which may justify an increase in aircraft activity, given the purposes of a national park. NZDA notes that the question is left open-ended and no reference to the “purposes” of national parks, referenced from their governing legislation, is provided.
For the record, the pertinent sections of The National Parks Act 1980, are:
S4(1) which refers to national parks as being preserved for their “intrinsic worth” and “for the benefit, use and enjoyment of the public …”; and,
S4(2)(e) which states in part that: “…the public shall have freedom of entry and access to the parks, so that they may receive in full measure the inspiration, enjoyment, recreation, and other benefits that may be derived from mountains, forests, … and other natural features.”
NZDA finds no congruence between these provisions and DOC’s over-zealous desire to increase noise pollution, disturbance of natural quiet, and diminution of visitors’ freedom to self-interpret and take up the wild state of the park, through its novel devotion to encouraging heli-hunting. We are amused but also alarmed by the flagrant economy with truth and omission of references to binding legislation, in this paper; omissions which conceal the serious matter of ensuring the park is protected thoroughly and with the intent of the law.
1.4. We are also concerned about inadequate reference to animal welfare matters, which DOC is careful to circumvent in this paper. Of course we are all aware that such are the province of MAF and its committees, NAWAC and NAEAC. This however does not avoid the reality that DOC will have to honour obligations it has as the legal owner of tahr, under the Animal Welfare Act, an ownership conferred by S9(1) of the Wild Animal Control Act 1977. Such ownership makes it mandatory via Section 8 of the Animal Welfare Act 1999, and also through SS10-12 of the same, that the Crown ensures animals are treated humanely and do not suffer while they are owned by the Crown.
The reader is referred to S12 and also to S28 of this act especially, the latter of which details offences against animals by any person, irrespective of their relationship to animals. DOC has failed miserably in this paper to provide sound advice, or seek input from MAF, which could add value to the advice available to the board. NZDA may consider making its own corporate approach to the minister responsible for animal welfare, if DOC fails to improve the treatment of this issue, in papers to the conservation board.
1.5. NZDA finds the paper is clumsy in its reference to the Godley Valley, failing to distinguish as the park’s management plan does, between the Upper Godley and the Godley in general. It is not clear whether the Upper Godley is intended for heli-hunting in this paper, or whether DOC has taken note specifically of Para 3, of method 4.1.1(b) of its own park management plan which states:
“3. The Godley Valley “remote” visitor management setting area and the whole of the Hooker and Mueller Valleys up-valley from the White Horse Hill, will be particularly managed to protect “natural quiet”,…”
We note the contrast between the statement above, and Para 24 of this paper which reads:
“The Upper Godley Valley, like the Mueller and Hooker Valleys, is within the plan as a no aircraft-landings area, with the Godley being recognised as a more-remote, high natural-quiet area.”
The only consistent notion of fact here, is that the Godley, in part or in total, is managed to preserve natural quiet, which would be directly contravened by DOC’s current proposal to the conservation board. We highlight the textual problem because it makes the document confusing and shows poor drafting. NZDA also draws attention to the matter because DOC appears to be exercising an intention which is outside a widely-stated premise of its own park management plan.
2. Positions on matters raised in the paper
2.1. NZDA believes DOC has failed to provide the public and the board with adequate information about potential impacts on the environment and visitor experience of the park. It should produce data from visitor surveys, or social research, which provides insights into perceptions of current and future aircraft-based activity, before presenting any advice on a plan-change to the conservation board. We see heli-hunting as being counter-intuitive to the sport of recreational hunting, and we strongly assert it will act to deter foot-hunters from using the park. This is likely to have an adverse affect on tahr management where recreational hunters on foot, already contribute to tahr control.
2.2. NZDA believes the DOC paper is very short on assurances of DOC’s competence to manage new heli-hunting concessions, and we note that virtually no concession management recommendations or tools are mentioned in this paper. We are certain that as things stand, DOC’s compliance monitoring record to date will only encourage poor operators and poor hunting practice within any new heli-hunting operations.
2.3. NZDA does not support any amendment of policies 4.3.3C and 4.3.3D nor any changes to 4.3.3J of the park management plan. We do not believe any relaxation of aircraft noise restrictions, or access permissions is required, and we actively discourage any further exploitation of the park’s natural assets by operations using only mechanical transportation as a means of access.
NZDA looks forward to speaking to this submission during any opportunity for engagement with the conservation board or conservancy staff.
NZDA encloses with this letter, its interim policy statement on heli-hunting, which has been well received by other interested groups.
© 2011 New Zealand Deerstalkers' Association