NZ Deerstalkers Association Submission: Bay of Plenty Draft CMS

Greetings.

New Zealand Deerstalkers’ Association Inc (National Office) (NZDA) makes the following submission on this preliminary draft CMS. NZDA Branches may also make submissions independently of this submission.

NZDA is the national body of recreational deerstalkers and other big game hunters. We have 52 branches and as well hunting member clubs throughout New Zealand. We have 7300 members, and have been actively advocating for recreational deerstalking and hunting, running hunter training courses, trips, conferences etc since 1937. We maintain ethical standards for hunting. Further information is available on our website www.deerstalkers.org.nz

There are three NZDA Branches in the Bay of Plenty DOC Conservancy – Rotorua, Bay of Plenty (Tauranga), Eastern Bay of Plenty (Whakatane). As well, there are five adjacent Branches in the Waikato Conservancy who can hunt in the Bay of Plenty viz Te Kauwhata, Thames Valley (Paeroa), Waikato (Hamilton), Te Awamutu, South Waikato (Tokoroa). And other nearby Branches eg Auckland, North Auckland (North Shore), Northland, South Auckland (Waiuku), Taupo, Waimarino, Taihape. Overall there are estimated to be some 50,000 deerstalkers in New Zealand – see Table 1. This would imply some 7,000 deerstalkers either living in the Bay of Plenty Conservancy, or nearby.

NZDA asks to be heard in support of this Submission.

Summary:

1 NZDA is concerned about the lack of information in the CMS about the Conservancy and its proposed management. Without specific names, areas, purpose of holdings etc, the CMS is vague, incomplete and dishonest. It is not a public consultation on DOC’s intentions at all. This information must be provided. A second round of consultation, with DOC BOP’s intentions clearly set out, is called for.

Comments/Proposals on the Draft CMS:

1 Foreword (Page 5): “Thrust from the floor of a primordial ocean - “ The first words in the CMS.

NZDA Comment: This may sound great for the PR man who thought it up. But it is bombastic, and shows that DOC doesn’t know the meaning of “primordial” – there at the beginning Oxford Concise English Dictionary), that DOC doesn’t understand modern science, and that DOC is living in the past, before plate tectonics were understood. The “line of fire” we know from science is a tectonic plate boundary. New Zealand has been moving around via plate tectonics for some 70 million years. This tectonic plate is relatively recent say the last 10 million years, not “primordial”.

NZDA proposes: Better to sack the PR man and get a scientist. Call the predominant feature of Bay of Plenty geology what it is – a tectonic plate boundary. Tongariro-Taupo conservancy also share this tectonic boundary. They make a much better display of its science. See their Visitor Centre at Whakapapa.

2 DOC should acknowledge Recreation (P 5):

NZDA Concerns: The foreword says nothing about outdoor recreation viz 4th para “Successful conservation will come from us all working together, sharing the skills and wisdom we can each contribute as tangata whenua, public servants, communities, businesses or simply citizens of the region”.

1 Public conservation land (PCL) is a national asset for all New Zealanders, not just those in the Bay of Plenty Conservancy/Region. Many recreational users, such as hunters come from outside the region.

2 Recreational enjoyment was as much a reason for the Bay of Plenty PCL being put aside as was preservationism eg Rotorua Lakes as scenic and tourist attractions, similarly the volcanoes and thermal areas. Outdoor recreation is the main reason people use the PCL, not botany.

NZDA proposes: Acknowledge outdoor recreation, and the values and wisdom that recreational users can bring. Otherwise recreationists will draw the conclusion that DOC is an anti-recreation department.

3 Key Conservancy Areas (Ps 6 & 8):

NZDA Concerns: Page 6 briefly summarises the CMS structure, and Page 8 is a map of the region that does not appear to be referenced.

NZDA proposes: That a brief commentary of the area of public land and marine reserves, and the size in Ha, and names of the larger parts of each be listed, either on Page 6, or page 9. This should include the Kaimai-Mamaku and Whirinaki Forest Parks, other significant pieces of PCL eg all the Places to be discussed in Part 2.

4 Details of all the lands/waters etc DOC Bay of Plenty manages:

NZDA Concerns: Also there is no list of all the land in the Conservancy and its status, area or main purpose, as there was in the previous CMS. A brief summary at the front will not substitute for this lack of detail of the areas the CMS is about. It must be provided. Otherwise the lands and waters the Conservancy manages will be unclear to the public.

NZDA proposes: That this list be provided in an Appendix, for reference, and to highlight what the CMS is about.

PS: Regional Conservator Henry Weston says there will be a second volume of maps and info about public land holdings in Bay of Plenty, as with the first CMS round in the 1990s. This is great, as details of the land holdings is one of the more useful parts of any CMS. Pity though it wasn’t available with the Draft CMS to assist the public better understand the Conservancy.

5 Page 12: 1.2 Public participation in Conservation Management:

NZDA’s submission is that: On Page 13, Management Objective 1, second bullet point:

NZDA and its Branches wishes a continuing relationship with DOC Bay of Plenty, re recreation gains (and possibly native biodiversity gains too) regarding management of deer, and possibly pigs, with recreational hunters of our Branches, both living in the Conservancy and from outside.

NZDA seeks the following changes: That the CMS state that to the end of better management of deer and wild pigs in the Conservancy, a recreational hunting co-operative relationship between recreational hunting groups who hunt in the conservancy, and the Department be set up.

This “partnership” would share information on recreational hunting opportunities and threats, to the benefit of both DOC and the recreational hunter groups, and their members. This may also be of benefit to tangata whenua hunting groups. NZDA proposes that a recreational hunting forum be committed to in the CMS, with meetings at least 3-monthly.

The CMS should also give an undertaking to develop a DOC-Hunter protocol, and to joint development of a Deer (and possibly wild pigs) Management Plan for the Conservancy. This should be a living document developed with hunting groups from the region. Some other conservancies have already moved in this direction eg Tongariro-Taupo, Canterbury. It is also a means of implementing Conservation General Policy (CGP) 4.2 (f) Encouraging recreational hunting. It should also save DOC some of the costs of controlling deer and wild pigs.

6 Pages 22-24 Biosecurity and management of threats to indigenous ecosystems:

NZDA’s submission is that: The terminology is wrong, showing the staff concerned are unaware of the Wild Animal Control Act, which is the Act DOC operates under re “wild animals”. DOC has responsibility for all species of “wild animals” on lands of all tenures. Wild animals in the BOP region include

• all species of deer – Red and Fallow are present wild in the BOP Conservancy. But presumably Sika and Rusa are only in the Eastern BOP, outside the BOP Conservancy.
• Wild pigs and goats
• Possums
• Wallabies

These are called “harmful species” in the Act.

NZDA seeks the following changes: The role of the Wild Animal Control Act is explained in this part of the CMS. This is DOC’s Act. Usually the Biosecurity Act, which has “pests”, does not generally apply to PCL. This needs stating, especially as the staff who wrote this Draft CMS seem unaware of their statutory responsibilities. The term “pest” is not used in the Conservation Act or the WAC Act.

7 NZDA’s submission is that: A list of species DOC considers pests misses the main issue of the risks these species pose to native endangered species in the Conservancy, and specifically what these risks are. Herbivores such as deer only pose risks to rare native vegetation. Which ones are at risk? This is far more useful in terms of management than vague demonisation and paranoia.

NZDA seeks the following changes: List for each species with the rare native species it is a risk to. Rank the risks of these introduced species – eg carnivores and omnivores (cats, rats, stoats, other mustelids, possums, wasps etc are a far higher threat to native animals than deer. The threats could also be lined up with the vulnerable native species(bottom of Page 23).

8 P 24, Management Policies:

NZDA’s submission is that: NZDA supports Policy 1, to encourage recreational hunting.

NZDA seeks the following changes:This submission makes a number of proposals on how this encouragement can be made to work, including jointly developing a Recreational hunting Management Plan for the Conservancy, and a Hunters’ Committee to work with DOC.

NZDA sets out the following information on recreational hunting and attitudes of the public to introduced species, and whether they see them as valued resources or pests.

A national survey carried out by noted Landcare Research’s deer ecologist Graham Nugent in

1988 showed there were some 60,000 active deerstalkers and pig hunters in New Zealand. These numbers are likely to be similar today. Table 1 below shows the estimated numbers, based on a survey of firearms owners:

DOC should be helping provide opportunities for the 6,000 recreational hunters who can hunt in the BOP Conservancy. This is especially the case as New Zealand and the world faces up to the need to halt climate change by reducing our carbon footprint. Recreational harvesting opportunities for the population nearby reduces the need for travelling large distances to the central North Island, or the South Island to hunt and harvest big game. Also harvesting the game is far better sustainability-wise than killing or poisoning them to waste.

Table 1 also shows also the significant number of small game, mainly possums and rabbits, harvested in 1988.

Deer and Wild pigs viewed by the public as a valued resource

9 Research shows Public values wild big game animals highly:

A piece of independent research confirms that the public value deer and pigs as a resource rather than see them as pests. Wayne Fraser [2001 “Introduced Wildlife in New Zealand: A Survey of General Public Views” Landcare Research Science Series 23], used FRST Public Good research funds to survey a sample of 859 responses on their attitudes to introduced wildlife – primarily mammals. The survey was carried out in 1994.

Figure 8: Perceptions of introduced species as pests or resources (from Fraser 2001)

Fraser asked two key questions:

1) Did the respondent consider an introduced species as a pest or a resource (or both)?

2) If encountered on a trip into the bush or high country, would it increase or decrease their enjoyment?

Effectively the public were asked whether they thought the species were valued introduced species or not. The responses to these questions are summarised in Figures 8 and 9 in the Report, reproduced below.

Figure 8 clearly shows that deer are considered the least pest (4%), and the most as both a pest and resource 51% and as a resource (44%). Wild pigs (pest 20%, both 45%, resource 32%) are similarly valued. Rodents, wasps, feral cats, possums rabbits, mustelids and hares, in that decreasing order, are considered primarily as pests.

Figure 9: Likely reaction on seeing introduced wild animals (from Fraser 2001)

Figure 9 shows a similar response to meeting deer, feral horses, chamois or tahr on a visit to the back country. Deer are the most positively regarded, with 95% of respondents being positive. Wild pigs are about 50:50.

The conclusion from Wayne Fraser’s research is that the New Zealand public sees deer especially as valued introduced species.

10 Page 30, Untitled photo of Weka:

NZDA’s submission is that: Weka are extinct in the BOP Conservancy, except for the introduced Mokoia Island group. This photo seems out-of-place, unless weka are to be re-introduced to the Conservancy. The CMS makes no mention of this. Does this photo date from a previous age whe the BOP Conservancy included East BOP, where there are still a few weka in the wild.

NZDA seeks the following changes: Unless weka are being re-introduced, which NZDA would support, delete the photo.

11 Page 30-31, 1.3.6 Ecosystem Services:

NZDA’s submission is that: There are ecosystem services associated with all lands, waters, seas, atmospheres on Earth. The ones on PCL usually contribute far less to the community than developed farmland, arable land and managed forests, or managed fisheries. The most significant ecosystem services on public land provide is recreational and tourist opportunities. Yet these are not mentioned.

NZDA notes that flood control for very large eg 50 year return time or greater, floods require ponding areas, as the runoff from an extreme rainfall storm cannot be cleared to sea fast enough by the river system. Ponding in the Rangataiki would occur, or be planned to occur, regardless of the tenure of wetlands or drained wetlands in its valley. There is little ‘benefit” that can be ascribed to them being PCL. NZDA notes that flood protection schemes in the Wairarapa use Lake Wairarapa for flood ponding, which just happens to be PCL. But in the Manawatu there is no big lake. Ponding is done via the Motua Floodway, on farmland, to rush the flood waters to the sea. NZDA notes the scientific research papers quoted later, (point 33) show other factors than vegetation cover have the most adverse effect, namely extreme weather events. Native forest has little impact.

NZDA seeks the following changes: Delete this vague special pleading, with no specific evidence, as to why some magical undefined elixir called “Ecosystem services” somehow pertains to PCL. Instead the value of recreation and tourism, which at least is hard information, should be set out. Why isn’t it?

Re carbon storage on PCL, such modification of the native ecosystem for commercial purposes is ultra vires the Conservation Act. Either an ecosystem is un-modified, or modified. Storing large amounts of carbon is as modifying as planting up pine plantations. Planting pine plantations is probably the most efficient way to store carbon. NZDA strongly opposes DOC becoming another taxpayer subsidised Forest Service.

12 Page 31; Management Objectives and Policy – Ecosystem Services:

NZDA’s submission is that: Terms such as ecosystem services are not defined. Until they are these objectives and policies are vacuous special pleadings, and simply bring DOC into disrepute.

NZDA seeks the following changes: Delete.

13 Pages 31-33; Historic and cultural resources including Management Policies:

NZDA’s submission is that: The management policies are so general that they give no information specific to BOP.

NZDA seeks the following changes: Add specific policies that this CMS is to implement. Vague policy statements such as here, show DOC is either refusing to set out its policies, or has none. This is not public consultation.

14 Page 33-38; 1.5 People’s Benefit and enjoyment:

NZDA’s submission is that: In 1.5.1 recreational hunting has been left out. It is a valid and permitted recreational activity, in fact probably the largest by numbers in Whirinaki, and significant in other forested areas.

NZDA seeks the following changes: Add “recreational hunting” to the list of recreational activities in the Conservancy especially given its importance.

15 P 33; 6 million domestic visitors/year to BOP:

NZDA’s submission is that: This figure is irrelevant. What is important is how many visit the PCL etc in BOP Conservancy. Presumably DOC doesn’t know.

NZDA seeks the following changes: DOC set out the major attractions on PCL in the Conservancy. Most of the stand-out attractions eg the Lakes, Mt Tarawera, geothermal fields etc are not on PCL, or as with Waimaungu, are outstanding attractions DOC has seen fit to divest itself of. Reads like a lurid travel brochure.- maximum hype, minimum information.

16 Page 35; Management Objectives:

NZDA’s submission is that: There is nothing in these five Objectives which are specific to the BOP region. Public consultation when DOC puts no specific information in the CMS is an insult to the Public and a farce. These five objectives are equally applicable to Southland, Auckland or any other conservancy.

NZDA seeks the following changes: State some of the recreational facilities that BOP DOC expects to provide, or take out, in the next ten years, together with their expected costs.

17 Page 35; Facilities, Huts & Tracks in the Conservancy:

NZDA’s submission is that: It is now almost four years since the DOC announced the results of its lengthy consultation on its 10 year Plan for hut replacements, tracks and bridges to be maintained, etc. This CMS should include which ones are being kept, rebuilt and maintained by DOC, and which ones were to be maintained partly by volunteer recreational groups, or to be abandoned at the end of their useful lives. Providing tracks and bivs in areas with game animals will encourage recreational hunting.

NZDA seeks the following changes: All facilities information is listed in the Draft CMS, and especially for all the areas listed as important “Places”. The CMS is a very appropriate receptacle for updating this consultation and set of DOC decisions, listing what progress has been made, and whether DOC’s Plan has been kept to. Such lists were part of the initial CMSs. Without them, DOC is not setting out its Plans for recreational facilities. This would have allowed public discussion of placement of facilities.

Unfortunately, because no such list is in the Draft, DOC BOP has not consulted the public about it. NZDA proposes that the CMS acknowledge that this consultation will be done as a separate exercise.

18 Page 36; Management Objectives and Policies – Vehicles:

NZDA’s submission is that: This again says almost nothing specific to the BOP Conservancy. No designated or possible sites are listed. This is not consultation. It is obfuscation. It also reads as if DOC’s primary aim is to lock all vehicles out of PCL except its own. NZDA seeks 4WD vehicle access for recreational hunters to encourage more recreational hunting in the BOP Conservancy, as the main purpose of recreational hunting is to harvest wild meat for the table, and good vehicular access makes this easier.

Many people see mountain bikes as more dangerous to other users than 4WD use.

NZDA seeks the following changes: These policies need to be BOP specific. Without that they are largely meaningless. Add that a Recreation strategy, including vehicle access, will be consulted on with the community, within the first 3 years of this CMS.

19 Page 36; 1.5.3 Dogs:

NZDA’s submission is that: Again Deer and pigs are referred to as Pests”. They are wild animals, not pests. NZDA is interested how “These pests (deer) damage PCL and waters by modifying habitats, preying on ground-dwelling fauna, and threatening forest stability.” NZDA enquires where in the BOP conservancy is this happening. This stuff read s like something straight out of a Forest & Bird propaganda sheet, with nothing to do with reality on the ground. It highl;ights why a split of DCO to allow some other agency to manage Deer and other big game animals is essential. DOC has no capability or desire to manage big game.

NZDA seeks the following changes: Leave this bit of Forest & Bird propaganda and lies out.

20 Page 37; Dogs, Management Policies:

NZDA’s submission is that: Development of these dog policies requires public consultation on what areas are to allow dogs and which aren’t.

NZDA seeks the following changes: Stae that public consultation on dog access matters in Policy 1.

21 Page 38-39; 1.6 Private accommodation; Management Policies:

NZDA’s submission is that: Under S 17X, the Minister has the ability to waive concession fees if the hut or lodge has a public benefit viz

S 17X Power of Minister to impose and enforce conditions (on a concession)

(f) The waiver or reduction of any rent, compensation or bond where -

(i) The concessionaire makes any contribution to the management of the lands or the public interest in those lands; or

(ii) There is any other non-commercial public benefit from the activity; or

(iii) Any circumstances of the concession justify such waiver or reduction; or

(iv) The costs of setting and collecting the rent exceed any rent which may be collected:

It appears that the CGP does not acknowledge this possibility.

NZDA seeks the following changes: NZDA proposes that where S 17X (f) applies, this elimination of “private” accommodation should not apply. School lodges and recreational deerstalker huts would come under S 17X (f). Change the management policies to allow subject to the S 17X (f) test. The legislation in any case overrules the inadequate CGP policy. NZDA draws DOC’s attention to CGP 10 (a) – “Accommodation - may be allowed –“

Part 2: Places

22 Page 43: NZDA’s submission is that: Whirinaki is not listed as a forest/conservation park. Yet it was made a Forest park in 1984, as stated in the CMS text.

NZDA seeks the following changes: List Whirinaki as a Forest Park here and at the top of page 45 etc.

23 Page 45: NZDA’s submission is that: The ecological values of Whirinaki forest are over-stated – 3^rd para “Whirinaki is one of the country’s most important indigenous forests.” etc. Around Arahaki lagoon the podocarp forest is impressive. But upstream, the forest is infertile steepland forest similar to much of the Urewera forest tract. It is similar to much of the steepland forests in other parts of the North Island eg Raukumara, Hutt water supply, Pureora-Waihaha. Much of the impressive native forest around Minginui has been clear-felled, and is regenerating scrub and slash.

NZDA seeks the following changes: Be realistic. Downgrade the hype around mid and upper Whirinaki forest to be primarily infertile steepland forest, similar to other forests in the Urewera Forest tract.

24 Page 47 para 4“ red deer, possums, pigs, rats, cats, stoats and mice are present, “.

NZDA’s submission is that: Red deer and wild pigs have lived in the Park area for the last hundred years, and are now at low densities. Deer have not caused any know native species extinctions in New Zealand, let alone in Whirinaki Forest Park. Deer and pigs are not the major threats to endangered native species in Whirinaki.

NZDA seeks the following changes: Specifically identify the major threats to endangered native species eg in a table, and set out the measures DOC intends to take to control each of them. Aerial 1080, the only tool DOC appears to use, is not effective against rats, cats or stoats for instance, as populations can bounce back very fast. NZDA is intrigued as to what native species mice put at risk.

25 P 47-48 Recreation, Whirinaki Forest Park:

NZDA’s submission is that: Though recreational hunting is mentioned, and is a major recreational activity in the Park, there is no mention of this recreation being encouraged. Forest parks (S 19, Conservation Act) are the only DOC land designation that mentions facilitating recreation. So DOC should be facilitating appropriate and traditional recreation such as recreational hunting (deer, pigs). Most huts in the Park were put in by NZFS to foster recreational hunting, and the area is noted for deerstalking (See Spot X NZ Hunting Guide, Pages 36-41).

NZDA seeks the following changes: That this “Place” section of the CMS acknowledge the historic and traditional value of the Whirinaki Forest Park for recreational hunting, and state that DOC will continue to facilitate deerstalking and pig-hunting in the Park, and work with recreational hunters to that end.

DOC has a requirement (CGP 4.2 (f)) to encourage recreational hunting. It also has a requirement to foster recreation (S 6 (e) Conservation Act), and facilitate recreation in conservation parks.

Instead, DOC seems to be a department dedicated to removing recreational hunting as an important and traditional activity on PCL.

26 Page 48, Last para: “Mountain biking, horse riding, four wheel driving, quad-bike riding and trail-bike riding will be investigated, and established where appropriate.”

NZDA’s submission is that: These activities often conflict with othr recreational users, and with preservation. NZDA agrees that these activities need recognition by DOC, and to be provided for, just as recreational hunting does. NZDA also agrees that, because of the emphasis on recreational activity in conservation parks, it is appropriate to have these activities provided for in Whirinaki Conservation Park.

NZDA seeks the following changes: Maps are needed setting out where these activities are intended to go. This CMS is totally inadequate public consultation on this issue, and the CMS needs to commit to specific public consultation on this matter. NZDA is not aware that this consultation took place over the 16 Km MTB track.

27 Page 48-9: Minginui commercial helicopter recovery exclusion zone:

NZDA’s submission is that: NZDA supports a commercial helicopter exclusion zone around Minginui. It identifies the extreme adverse effect on recreational hunting of helicopter recovery.

Commercial helicopter recovery is equally detrimental to recreational hunting throughout the Park.

NZDA seeks the following changes: Also declare the whole of the forested part of Whirinaki Forest Park as a No-go area for commercial helicopter recovery, as for Minginui. But for the benefit of the large number of recreational hunters that use the Park. As conservation parks are primarily for recreation, this would be legislatively appropriate, provided recreational hunters could keep deer and pig numbers below levels damaging rare and endangered species. NZDA also requests that a Recreational hunting committee be set up to work with DOC to achieve a better recreational hunting environment in Whirinaki Forest Park.

28 (Page 49) Whirinaki Recreational Hunting Management Plan:

NZDA’s submission is that: DOC Tongariro-Taupo Conservancy are developing a Recreational Hunting Management Plan for the Kaimanawa Forest Park, as part of their management plan for the Park. It is being developed via a working group representing the hunting community, via a formal Memorandum of Understanding. See page 87, Section 7.7, Recreational Hunting, Objective 3 Kaimanawa Forest Park Management Plan, 2007. There is every reason for DOC Bay of Plenty to do the same for Whirinaki Forest Park.

NZDA seeks the following changes to the CMS: That DOC Bay of Plenty commit in the CMS to developing a Recreational Hunting Management Plan for Whirinaki Forest Park, in consultation with recreational deerstalkers who hunt in the Conservancy, through a formally established Working Group, in a similar way to what is being done for the Kaimanawa Forest Park. NZDA regards the KFP example as best practice. Such a Plan would also formalise implementation of CGP 4.2 (f) in the Pureora Forest Park. It would cover both deer and pigs.

29 Page 49, Outcomes – Whirinaki:

NZDA’s submission is that: Objective 2 should include not only locals, but also the recreational user community, some of whom are not locals. Objective 3 should recognise the cultural and historic activity of recreational hunting.

NZDA seeks the following changes: Objective 2: add ‘and recreational user” after “local”. Objective 3: Add “including recreational hunting” after “Whirinaki”.

30 Page 49, Management objectives:

NZDA’s submission is that: DOC’s goal in this CMS is to ignore recreational hunting in spite of this being counter to its statutory duties. DOC is increasingly becoming a Department of Recreational Confrontation, rather than an agency that sees itself managing our public lands for the benefit of recreational users.

NZDA seeks the following changes: Recognise the value of recreational hunting in the park, and include in Obj 2:

• Work with recreational hunting interests to develop a management plan for deer and wild pigs in the Park, and with minimal use of commercial recovery

Include in Obj 5: Add “recreational deer and pig hunting” after “walking tracks”

31 Page 50, Management Policies: Policy 4: 4-day tramping circuit for families.

NZDA’s submission is that: Whirinaki is such an out-of-the-way location, on a secondary road, NZDA asks why family tramping is being encouraged, when the forest is unexciting with few extensive views, or other tramping highlights.

NZDA seeks the following changes: Delete. Leave the family walking opportunities in more accessible parts of the North Island.

Add: “4Adeveloping a Recreational Hunting Management Plan for Whirinaki Forest Park, in consultation with recreational deerstalkers who hunt in the Conservancy, through a formally established consultative hunter Working Group.”

2.2 Kaimai – Mamaku Forest Park (page 53):

32 Page 55, Biodiversity:

NZDA’s submission is that: This park area has been cut over from 100 years of milling. It has consequently been badly degraded as a mature forest.

NZDA seeks the following changes: Specifically state this in the Biodiversity section. Mammalian browsers have done little damage in comparison.

33 Pages 57-58: Outcomes, Management Objectives, Management Policies:

NZDA seeks similar changes to those sought for Whirinaki: Recognise the value of recreational hunting in the park, and include in Objective 6:

• Work with recreational hunting interests to develop a management plan for deer and wild pigs in the Park, and with minimal use of commercial recovery

Policies: Add: “4ADevelop a Recreational Hunting Management Plan for Kaimai-Mamaku Forest Park, in consultation with recreational deerstalkers who hunt in the Conservancy, through a formally established consultative hunter Working Group.”

NZDA notes that water and soil values are affected much more by climate and, potentially earthquake and landslide action than they are by the existence of forest cover. Recent examples of catastrophic storm effects on areas include:

East Coast Cyclones such as Bernie (Easter 1982), Bola (1987), Manawatu, Wairarapa-Wanganui (February 2004) etc. Bernie bowled hundreds of ha of native beech forest in the Kaimanawas, and similar extensive areas of exotic pine forest in Kaingaroa. Massive slips and floods resulted from the 2004 Manawatu storm, and its extreme rainfall (more than a 100 year flood event.

This result is well researched eg

Jane, G T and Green, T G A; “Episodic forest mortality in the Kaimai Ranges, North Island New Zealand”, NZ J Botany, V 21, p 21-31, 1983

Grant, Patrick J; “A hydrologist’s contribution to the debate on wild animal management” NZJ Ecol 12, p 165-9, 1988

Grant, Patrick J; “Drought effects on high-altitude forests, Ruahine Range, North Island New Zealand,” NZ J Botany, P 15-27, V 22, 1984.

Papers 1 and 2 attached to this submission

34 Pages 83-87; 2.6 Volcanic and Geothermal environments:

NZDA’s submission is that: Most of the outstanding geothermal and volcanic features of the BOP Conservancy are not PCL eg Lake Tarwera, Lake Rotomahana etc. Neither is Mt Tarawera. White Island or Mayor Island. Nor is access to Waimangu Geothermal area. (The concessionaire owns the tracks.) What areas does DOC BOP manage?

NZDA seeks the following changes: A list of the volcanic and geothermal areas that the public have access to that DOC BOP is essential, so one knows what DOC is talking about. Or is DOC simply proposing to pump taxpayer funds into private hands?

35 Pages 88-89; Te Arawa/Rotorua Lakes Indigenous Forests:

NZDA’s submission is that: Again, no list of PCL holdings is given.There are no maps. Who owns these forests? DOC or private landowners?

NZDA seeks the following changes: State which significant areas of PCL are involved. Add a map of the DOC land holdings, Show the proposed route of the Trail Network. Also show those such as Lake Okataina Scenic Reserve which are privately owned. Where the land is not PCL, explain why DOC is involved in management, and the expected cost.

NZDA opposes the Te Arawa/Rotorua Lakes Trail network. There is minimal information, and it appears to have all the problems o taxpayer money supporting private profit.

36 Page 89; Management Policies, deer and pigs:

NZDA’s submission is that: No details are provided on management of deer and pigs.

NZDA seeks the following changes: That a new policy be provided that DOC will work with recreational hunting groups to develop plans for control and management of deer and pigs on PCL in these areas, as discussed under Whirinaki.

37 Pages 92-96; 3.3 Milestones:

NZDA’s submission is that: These milestones should be referenced in the sections they relate to. NZDA notes that only two of the 24 objectives relate to recreational matters, viz Objective 9, re Whirinaki, which appears to be a commercialisation Plan, to massively change present hunting and tramping use, rather than to do with recreation at all. And 11 Kaimai Heritage Trail, likewise a presumably commercial venture. To shove lots of tourists through the Park. Two of the Objectives, 5, and 6, are to control recreational activities that DOC BOP doesn’t like, namely 4WD clubs, and dogs.

NZDA seeks the following changes: Devolve the recreational part of DOC to a new agency prepared to manage PCL for recreational use and users.

Conclusion:

NZDA is very disappointed with the inadequate information and policies set out in this Draft CMS, and especially its Forest and Bird propaganda inserts, and lack of desire to positively address recreational hunting, one of the major outdoor recreation activities in the BOP Conservancy.

Without objectives and policies specific to the Bay of Plenty Conservancy, the CMS is vague, incomplete and dishonest. Almost no information is provided on DOC BOP plans. It is not a public consultation on DOC’s intentions at all. This information must be provided. A second round of consultation, with DOC BOP’s intentions clearly set out, is called for.

NZDA wishes to be heard in support of this submission.

Yours truly

Dr Hugh Barr Encl: Jane & Green and Grant papers attached

National Advocate