NZDA wishes to be heard in support of this submission. Time requested: 90 minutes
1 - New Zealand Deerstalkers’ Association Incorporated (NZDA):
NZDA is the national body of recreational deerstalkers and other big game hunters in New Zealand. We have 50 branches and a number of other hunting member clubs throughout New Zealand. We have 7500 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. NZDA’s membership has been growing at 7% a year recently, showing that recreational hunting is an attractive recreation for New Zealanders.
NZDA Branches in, or who hunt in, the Waikato Conservancy are:
In the Conservancy: Waikato Branch (Hamilton), South Waikato Branch (Tokoroa), Thames Valley (Paeroa), Te Awamutu, Te Kauwhata.
Hunt in the Conservancy: Auckland, North Auckland (North Shore), Northland (Whangarei), South Auckland (Waiuku), Bay of Plenty (Tauranga), Rotorua, Taupo, North Taranaki (New Plymouth), Taihape, Taranaki (Stratford), Napier, Hastings.
Based on scientist Graham Nugent’s Survey of 1988, there are probably 25,000 recreational deerstalkers in the northern half of the North Island, who would usually hunt in the Waikato Conservancy if opportunities were available, and the hunting attractive.
2 - Summary:
1 Co-operation on game animal management: NZDA is interested in exploring a partnership with DOC in terms of Public Participation in Conservation (Section 1.2) regarding wild animal management (deer and wild pigs) in the Waikato Conservancy. It would also be part of DOC implementing S 4.2 (f) of the Conservation General Policy (CGP) for DOC to encourage recreational hunting.
2 Pureora Recreational Hunting Area (RHA): NZDA wants this small RHA expanded to the whole Park, to increase opportunities for the 25,000 recreational hunters who live in or near the Waikato Conservancy, and who are poorly catered for at present. DOC is required, under the Wild Animal Control Act (S 28), to consult and amend RHA WAC Plans at least every 5 years. This has not been done for many years, and needs to be committed to in this Conservation Management Strategy (CMS). Tongariro-Taupo is leading the way with a Wild Animal Management Plan Committee for the Kaimanawa Forest Park. Also, DOC has put a bike track through the present RHA, creating conflicts with hunters that would be reduced with a larger RHA.
3 Implementing Conservation General Policies (CGPs): This is a major role of CMSs, and some of them are required to be implemented by CMSs. This has not always been the case in this draft. A number of these are discussed as needing greater detail on implementation.
4 Maps and details of Public land holdings: NZDA thanks DOC for the maps especially supplied as Part 7 of the Draft CMS. NZDA still considers these are hard to understand, and need improvement. Maps etc are a statutory requirement for CMSs.
5 Lack of detail in CMSs: NZDA is disappointed at the lack of detail on DOC assets and future planned provision, and DOC intentions in the CMS. Many sections are so general as to trivialise the process. NZDA realises that this is the evasive policy of DOC Head Office, and that Waikato Conservancy is just following orders. However, Waikato Conservancy can be innovative in this regard, and do a better job than it has done. NZDA urges Waikato Conservancy to do so.
6 Conservation Management Plan for Pureora Forest Park: Because of the lack of clarity of DOC’s intentions in the CMS, regarding Pureora Forest Park, NZDA requests the CMS commit to a CMP for Pureora in this CMS. Though this Park is a “Place”, there is very little detail about how it will be managed to facilitate recreation and enjoyment, the huts, tracks etc that are provided, aerial access points, if any, commercial helicopter recovery, etc.
Forest parks are now recognised as important for outdoor recreation, similar to national parks, which have management plans. Forest/Conservation parks need specific Plans, so the public can comment constructively on them. There was no consultation with NZDA on the bike track DOC has put through the Pureora RHA, for example.
7 Having a Vehicle and Air Access Policy: Required in the CMS by policy 9.5 (b) of the CGP. Not provided. It is not sufficient just to say this will be done. It is required to be in the CMS.
8 Conservancy public investments: Full details of huts, tracks, facilities need to be provided in the Conservancy, so the public can comment meaningfully on DOC’s recreational strategy.
9 Every place ie land holding, in the Conservancy is a special place: Each needs to be briefly noted, together with brief details of its proposed management.
10 Dog Access Policy: Not provided, counter to CGP 9.6 (a).
11 DOC milestones: These are mainly so general as to be meaningless. They need to be more specific. NZDA wants milestones added for deer management.
12 Research and Information: There is nothing in the CMS about this (Section 12, CGP). NZDA would like DOC Waikato to set out its intentions re Research and information (CGPs 12)
3 - Draft CMS, Part 1 – NZDA comments:
These are twenty nine points NZDA makes about specific parts of the CMS and changes NZDA would like to see.
Point 1: Forward (Page 5) Para 2: The purpose of the CMS is stated to be to prescribe a vision
NZDA Concerns: Statutory purpose of the CMS not stated: Section 17D (1) Conservation Act defines the purpose of a CMS to be:
17D Conservation management strategies
(1) The purpose of a conservation management strategy is to implement general policies and establish objectives for the integrated management of natural and historic resources, including any species, managed by the Department under (various Acts) or this Act, or any of them, and for recreation, tourism, and other conservation purposes.
The purpose of CMSs is primarily to implement general policies, the main one being the
Conservation General Policy (CGP) released in May 2005; and “to establish objectives for integrated management of natural and historic resources, under the various acts.”Vision” is not mentioned. This Draft CMS is therefore ultra vires the Conservation Act.
NZDA requests: That the Foreword state the statutory purpose of the CMS, as above, and list the CGPs that are required to be implemented by the CMS ie “will” or “should” policies in the CGP. It is less than 3 years since the CGP was released. This is the first Waikato CMS since their release. So the CMS must concentrate on how the CGPs are to be implemented.
NZDA’s list of these is:
CGPs 4.2 (a), 4.2 (f), 9.1 (b), (c), (d), 9.5 (b), 9.6 (a), 13 (a), (d), (f). Others should be included where relevant eg S 12.
Point 2: Foreword (Page 5) Para 1 Waikato River a dominant feature.
NZDA Concerns: DOC does not control the Waikato River. Much of DOC’s areas are steepland forests – see Land Units, page 6, Part 7. There are also massive limestone underground formations, some of which are on public conservation land (PCL). NZDA does not understand the reason for emphasising the Waikato River, which DOC has little responsibility for eg it is not listed as a “special place”, nor on the maps.
NZDA requests: Emphasise the major natural resources and recreational areas on PCL in the Conservancy.
Point 3 Part 1: Management Objectives and policies (Page 11):
NZDA Concerns: (1) No mention is made of the major job of the CMS, implementing CGPs, and as well the various Acts, which over-ride over CGPs. There are a number of CGPs that are required to be implemented in CMSs.
(2) These management objectives relate to all lands administered by DOC, not just “reserves”.
(3) DOC has a duty (S 6 (e), Cons Act) to foster recreation. This is not mentioned.
NZDA requests: (1) CGPs that are required to be implemented or which should be implemented be quoted in the CMS, with their implementation.
(2) In first bullet, change “reserves” to “lands and waters”. “reserves" means only lands held under the Reserves Act.
(3) add a new bullet “fostering public recreation”.
Point 4: 1.2 Public participation in Conservation (Page 14).This should implement CGP Polices 3 (a)– g).
NZDA Concerns/Interests: (1) Providing for recreation is a major consideration in DOC’s activities. Yet it is not mentioned in this section. In other conservancies DOC welcomes partnerships with recreational groups, not just with ecological groups.
(2) NZDA supports the Management objectives, but considers the Management policies are too general and non-specific.
NZDA requests: (1) State that fostering recreation is an important goal, and that DOC will also work with recreational groups to achieve recreational outcomes under this section. Recreation is of course a part of conservation, as defined in the Conservation Act. Add to Management Obj 3 before conservation, “recreation and”
(2) NZDA and its branches are interested in forming a partnership with DOC in terms of co-operating with DOC in managing deer in the Waikato Conservancy for recreational and conservation purposes. NZDA believes the best way to do this is for there to be a DOC-Hunter Recreational Hunting Committee that meets four times a year and which jointly prepares and monitors a recreational hunting Management Plan for the Waikato Region.
Consequently NZDA proposes adding a Management Policy 3: DOC and recreational hunters ie those who hunt in the region (but may not necessarily live in it) will set up a joint consultative committee of recreational hunters and DOC staff, to address recreational hunting issues, and develop recreational hunting management plans for management of deer numbers, in places where DOC considers deer numbers are too high. As well, the Committee could be a forum for distributing DOC information for hunters and for hunter feedback to DOC.
A precedent for this is the DOC-Recreational Hunter Wild Animal Management Committee recently set up as part of the Kaimanawa Forest Park Conservation Management Plan by Tongariro-Taupo Conservancy.
There are minimal recreational deerstalking areas in the Auckland DOC Conservancy. So Auckland metropolitan area deerstalkers usually have to access other areas in the Waikato, Bay of Plenty, Tongariro-Taupo and Hawke’s Bay Conservancies. Deerstalker numbers in New Zealand are estimated as over 50,000 (Appendix 1).
The populations of the Auckland, Waikato, and Bay of Plenty regions total near to 2 million. On a per capita basis, there would be 25,000 recreational deerstalkers in these areas, who would hunt in the Waikato conservancy if opportunities existed. DOC has an obligation to provide for recreational deerstalkers in the Conservancy.
There are significant benefits to DOC in providing recreational opportunities to hunt deer, and so help protect various browse vulnerable native species. This could also lead to better relationships between DOC and recreational hunters. It would meet all 4 management objectives set out on the bottom of Page 15.
Recreational hunters do not usually see themselves as volunteer pest eradicators. But they are usually prepared to do their bit to keep pests such as rats, cats, stoats, possums at lower levels. They do this while hunting on Stewart Island, for example. They are also interested in hunting deer and pigs, and so can help DOC to achieve its goals, including providing for recreational enjoyment, and meat for the table, as well as protecting biodiversity.
Point 5: Positive relationship between hunters and DOC (page 16):
NZDA Concerns: However, a positive relationship is required based on mutual good faith, co-operation and respect. (CGP 3 (a). In my 4 years’ experience as NZDA’s National Advocate, I have found that many DOC managers are not prepared to act in good faith.
NZDA requests: in Management Policies 1 and 2 (page 16) state DOC will commit to act in good faith, co-operation and respect (CGP 3 (a)) when dealing with recreational hunting groups and in partnerships with them. Add “in good faith” after “work” in Policies 1 and 2.
1.3 Conservation of natural resources (Page 16):
This section implements CGPs 4 of the same name.
Point 6: Indigenous forests and shrublands are rare:
NZDA Concerns: What figures there are in Part 7 Maps strongly contradict that “large almost continuous tracts of indigenous forest are rare in Waikato Conservancy.” For example most of the Conservation land holdings in the Conservancy are of forests and shrublands eg Coromandel FP (72,254 Ha), Pirongia FP (16,500 Ha), Pureora FP (74,023 Ha). Total conservation park area – 3 Parks - claimed to be 163,134 Ha. Then there are all the Conservation areas (63,334 ha) and scenic and scientific reserves.(31,000 Ha). As well, the Kaimai-Mamaku and Whirinaki Forest Parks are on the border of the Waikato region, and readily accessible from it.
NZDA requests: That this statement be removed. Also that there be tables of the numbers of holdings and total areas of the different areas (Indigenous forests and shrublands, wetlands, Islands, dunelands etc that DOC holds in the Waikato Conservancy. This would be useful too, so that staff are more aware of what is out there. It is certainly not obvious from the way Section 7 defining land holdings has been put together.
Point 7: Management objectives – terrestrial & freshwater (Page 21):
NZDA Concerns: These Management objectives are so general, as to be meaningless. They need to be more specific before any meaningful public consultation can take place, and do not cover all the CGPs in Section 4. NZDA wants to see implementation details in the CMS for Policy 4.2 (f), encouraging recreational hunting, and what DOC’s Objectives, policies and Milestones are for implementing this Policy.
NZDA requests: (1) Consequently NZDA proposes Objective 5A: To work with NZDA Branches and recreational deerstalking and pig hunting clubs in big game animal management, through a memorandum of understanding to facilitate both recreational hunting and reduce areas where deer and wild pig numbers are considered too high.
(2) Add a corresponding additional Management Policy 5A: Will work with NZDA and recreational hunting clubs to encourage recreational hunting, and management of deer and wild pigs in the Conservancy.
These additions are aimed at implementing CGP Policy 4.2 (f) to encourage recreational hunting.
(3) Implementation Milestones (CMS Part 3, Page 100): These are needed to ensure the Objectives, policies and milestones are set and monitored. Add to the Table 1.3.1 a new 4 with Objective 5A above, plus:
Milestone – 3 years: A DOC-Hunter liaison committee established, in its third year of operation, and helping both improve recreational hunter satisfaction, and helping stabilise deer numbers. A deer management plan is in its second year of operation. An enlarged Recreational Hunting Area (RHA) has been established over the whole of Pureora Forest Park. Hunters agree adequate means of reducing deer by-kill have been used by DOC during their possum and rat control operations.
Milestone – 5 years: Recreational hunters have a high level of satisfaction when hunting in the Region. DOC regarded positively by hunters, and deer by-kill continues to reduce.
Milestone - 10 years: relations between recreational hunters and DOC continue to improve.
Point 8: Page 26 1.3.4 Ecosystem services:
NZDA Concerns: Ecosystem services is a vague feel-good term invented by DOC for self-promotion and public relations. Soil and water protection is a benefit. But the presence of vegetation cover is only part of the mix. With global warming, storms have more intense rainfall, and stronger winds. Ecosystem services also includes services on non-conservation land. These eg pastoral agriculture, exotic forestry, are usually significantly greater than those on non-productive public conservation land.
Floods and windstorms still happen, and are increasingly intense eg the major floods at Matata recently in the Bay of Plenty, Manawatu-Wanganui floods of February 2004, tree snow-damage to Southern Urewera forests in a Winter 2006 snow and wind storm and wind damage in the Tararuas in late July 2008. Some of these took weeks for DOC staff to clear major tracks.
The flood protecting capabilities of Public Conservation Land (PCL) are already reflected in the region’s flood modelling and flood plans. But it is unclear what they are worth. DOC appears incapable of quantifying the benefit. A major requirement for flood protection is having ponding areas to deal with slow run-off with heavy rain on flat land. These are better if devoid of vegetation. Certainly native forests and wetlands hold water. But pastoral agriculture requires cleared land, with faster runoffs. Agriculture and forestry is how the nation makes its living. Flood protection is built according to the expected runoffs. Does conservation land vegetation save us much? Probably not.
Carbon Sequestration: Open space has a significant recreational value, as does deerstalking. Removing both is not part of DOC’s role, and will only make conflict with the public. Loading native ecosystems with carbon ie undergrowth and wood residues, also creates wildfire risks in dry hot weather, especially on the east of the main ranges. DOC has not carbon accounted for the many acres of exotic forest it has cleared recently. Native forests and scrub are slow-growing and an inefficient way to store carbon.
NZDA requests: (1) That either the “value” of ecosystem services is quantified, or the space devoted to this self-promotion be cut to half a page, and marked as an advertisement.
(2) That what is meant by “protect the quality” of ecosystem services, and how they cope with increasingly severe winds and floods as global warming increases, be explained quantitatively.
(3) Agree that “Ecosystem Services” is no more than a fancy marketing name for demonising wild animals and other introduced species.
(4) Include harvesting of big game animals as a valued ecosystem service. There is both recreational hunting benefit, and benefit in the value of wild meat harvested for the table, and in the economic value of the expenditure by recreational hunters on public conservation land.
1.3.5 Biosecurity & Management Threats – Page 27-28:
Corresponds to CGP 4.2.
Point 9: Implementation of CGP 4.2 (a)
4.2 (a) Conservation management strategies and plans should identify and, where possible, prioritise the threats posed by pests to indigenous species, habitats and ecosystems.
NZDA Concerns: Policy 4.2 (a) should be implemented in this Section of the Waikato CMS, eg as a table, with discussion. NZDA has found that DOC does not do adequate threat assessment of different species which adversely impact on native species.
A table setting out the size of each threat, and level of damage, and comparing them, would greatly assist DOC cost effectively manage these threats. Implementing Policy 4.2 (a) would go some way to showing DOC was managing the threats it faces in a professional way, rather than just asking for more money.
NZDA requests: That the CMS implement CGP 4.2 (a), by including such threat assessment and prioritisation in this Section of the CMS, as required by the CGP.
A milestone is needed to implement this policy. NZDA provides this in the Milestones – Part 3.
Point 10: Encouraging recreational hunting:
NZDA Concerns: (1) Encouragement of Recreational hunting [CGP 4.2 (f)] is inadequately dealt with in terms of implementation. First deer and wild pigs are not “pests”, a term that is only defined in the Biosecurity Act. In the Conservation Act, the term is “wild animal” defined under the Wild Animal Control (WAC) Act. DOC Deer Manager Keith Briden has assured NZDA that DOC will continue to use the correct term “wild animal”. However, this instruction does not appear to have reached Hamilton yet.
NZDA requests: (1) that, because deerstalking and recreational hunting are valid and popular recreational activities on PCL, that DOC continues to provide opportunities for them throughout the Conservancy, not just in Pureora, or Te Tapui/Te Miro. There are 25,000 recreational deerstalkers in or adjacent to the Waikato Conservancy who can hunt in the Conservancy.
(2)The CMS should commit to develop a Plan in co-operation with deerstalkers, to encourage recreational hunting in the Conservancy, and have it as a milestone.
(3) As the CMS has not implemented CGP 4.2 (a), there is no definition of priority pests by threatened species. Both threatened species and priority pests must be defined in this CMS for these Objectives and Policies to be understandable and meaningful. As it stands they are simply recitals of meaningless jargon.
NZDA requests: DOC adequately defines “priority pests” and “priority indigenous species”. (Objectives 1 and 3).
Point 11: Implementing CGP 4.2 (f)
NZDA Concerns: Minimal details on how DOC intends to implement CGP 4.2 (f) are given in this section. And the statutory Plan for the Pureora RHA needs renewing, with public consultation.
NZDA requests: Incorporate NZDA’s requests, Points 4 (Committee and recreational hunting management plan), 5 (positive relationship between hunters and DOC) and 9 (Implement S 4.2 (a)) above into this section, or refer to the Sections where these points are made in the CMS. A milestone for implementation is needed as well.
Point 12: Policies are too general and undeveloped in detail that the public cannot comment meaningfully on them: (almost all policies)
NZDA Concerns: This CMS consultation is a farce, because DOC has not set out what it will do under its policies. Many are so vague and general that the public has little idea of what DOC will actually do, if anything. It is management by secrecy ie without providing any information about intentions.
NZDA requests: Policies should be much more specific before the Draft CMS was released for public comment. The management objectives and policies for Biosecurity etc (page 28) and Historic and Cultural Heritage (Page 31) are examples of this trivialisation. They are so non-specific they could apply to any region of NZ, or Australia. Without also having prioritised at-risk species and prioritised which introduced species create risks for them, these objectives and policies are meaningless, and a major waste of taxpayer money.
Point 13: 1.5.1 Planning and Management for recreation and enjoyment: Pages 32-34
NZDA Concerns: This section should implement CGPs Policies 9.1(a) - (h).
Specifically Policies 9.1 (b) and (d) require implementation in each CMS viz
9.1 (b) The recreational opportunities and the outcomes planned for different places will be identified in conservation management strategies and plans and will be consistent with the statutory purposes for which the place is held.
NZDA requests:
CGP 9.1 (b) “will” (must) be complied with in this CMS. This has not been done. Consequently, the Conservancy needs to do this. Because it has not been done, the CMS should be re-issued for public consultation, with these parts added. Without this, the public will be shut out of commenting on an essential part of the CMS. This seems to be DOC’s aim.
9.1 (d) Conservation management strategies should identify (based on the assessment criteria in policy 9.1(c)) how public access is to be enabled, and what types of recreational opportunities, activities, information, accommodation, facilities and services (including those provided by concessionaires) are suitable in different places and to what extent.
CGP 9.1 (d) “should” ie most of the time, identify how public access is to be enabled - are suitable in different places etc. This is not done, and needs to be done before the CMS is acceptable for public consultation.
In the Management Objectives and Policies of 1.5.1 (page 34) DOC is hiding its intentions, assuming it has some, behind this meaningless jargon.
Point 14: 1.5.2 Vehicles including aircraft (Pages 34-35):
NZDA Concerns: CGP 9.5 (b) Conservation management strategies and plans will identify where the use of specified types of vehicles and other forms of transport may be allowed and will establish any conditions for use.
NZDA requests: Apart from identifying 2 roads for 4WD use, but not the conditions, this requirement has not been done in this CMS eg no list of sites or areas where helicopters can land. This is deliberate evasion of the requirements of a CMS. This should be done and the Draft CMS re-issued.
Point 15: 1.5.3 Dogs: This is supposed to implement CGP 9.6 in people’s benefit and enjoyment.
NZDA Concerns: Again there is no actual zoning of lands and why.
NZDA requests: The requirements for dog zoning are set out in Part 5C of the Conservation Act. They require public consultation, something not stated in the CMS.
Point 16: 1.8.2 Land reclassification (page 42): This is CGP 6, including (a), (b), (c), (d).
NZDA Concerns: This section says very little, and does not reflect either the Acts (which set out public consultation processes far broader than Waikato Conservancy is aware of. The CGP on this runs to 2 pages and 4 policies.
NZDA Requests: That what is said in this section is expanded to correctly interpret both the various Acts and the CGP 6. The Milestone for reclassifying public conservation lands (page 105) is laughable, as it says nothing, apart from the method, and is in terms that set no measurable goals. Why it is to take 3 years to investigate areas for reclassification, when surely many of these are known now, and none are listed, seems dereliction of duty. NZDA asks that the prime areas for reclassification be listed.
16A Research and Information (CGP 12) (page 42): There is no mention of any research programme for the region. There should be one, and also information gathering.
NZDA Requests: The DOC Research and info gathering plan for the region, including priorities, be set out.
Part 2: Places
Point 17A: Places– All PlaceMaps
NZDA concerns: - the low standard and lack of detail on the maps provided of the various places is inadequate.
NZDA Requests: Maps that show significantly more detail, including tracks, huts etc are essential for public understanding.
Point 17B: All lands administered by DOC in the Conservancy:
NZDA Concerns: All lands that are administered by DOC in the conservancy are “special places”. By picking only five groups of Places, the Conservancy is devaluing all the other disregarded Places. All public lands administered by DOC have become public protected lands because people cared. Because they hardly rank a mention in the CMS, they are effectively lost lands, stolen from the public.
NZDA Requests: That specific plans for all lands administered by DOC be stated in Volume 2 of the CMS.
2.6 Pureora Place: 85,000 Ha, mainly Pureora Forest Park.
Point 18: NZDA Concerns: Pureora Place is not defined. The Forest Park is 74,023 ha, but the Place itself is 85,000 Ha. The map supplied (page 90) tells a reader very little.
NZDA Requests: That the make-up of the “Place be set out in a table, stating the various land areas making it up, and their areas. These land names and numbers should also be shown on the “Place” map. The RHA should also be shown. The A4 map is inadequate for purpose.
Point 19: Management of Pureora Recreational Hunting Area (RHA):
NZDA Concerns: DOC is not fulfilling its statutory obligation under the WAC Act, to renew the WAC Plan for each RHA, at least every 5 years (WAC Act S 28 (1) and (2). The present Plan has not been revised for a considerable time.
NZDA requests: The CMS acknowledges the Pureora CMS, and the need for at least 5-yearly consultation on the Pureora RHA Wild Animal Management Plan, via an advisory committee of recreational hunters and DOC. An additional reason for this is that DOC appears to lack staff with knowledge of recreational hunting management.
Also add to Management Outcomes – Pureora (page 93): 3A Maintain or expand the RHA, to better cater for the large number of recreational deerstalkers in the Hamilton and Auckland urban areas.
Point 20: Expansion of Pureora RHA:
NZDA Concerns: The Pureora RHA is the nearest one to Hamilton and Auckland. Both have significant recreational hunting communities, probably 20,000 deerstalkers. The Pureora RHA, at 18,750 Ha, is only a quarter of the size of the Pureora Forest Park. The RHA has already had a significant bike trail put through it with no consultation with recreational hunters.
In spite of RHAs being the only areas where deer repellent can be used on public land, only about one third of the RHA had repellent used on it in last winter’s aerial 1080 drop, significantly lowering the number of deer present. One reason for this was DOC’s concern that deer repellent may adversely affect kokako.
It is DOC’s job to foster recreation, including recreational hunting. This is especially the case, as the next nearest RHA to Pureora is the Kaimanawas, significantly further than Pureora from Auckland and Hamilton. Making Pureora Forest Park more attractive would reduce travel and carbon emissions.
A major goal of forest (called conservation) parks is to facilitate recreation and enjoyment (Cons Act, S 19 (1)). Making a greater area of the Park a RHA would help achieve this goal.
NZDA Requests: That this CMS agrees to have consultation on extending the RHA to the whole of the Park. This should be a milestone in Part 3, with consultation achieved and the decision analysed within 2 years.
Point 21: Improved public access to Pureora Forest Park:
NZDA Concerns: Public vehicle access to Pureora FP is poor in a number of places. Examples are: Waituhi Saddle in the South-east. Here a logging road has been allowed across conservation land. As far as NZDA is aware, there is still no agreement in writing to allow public vehicle use of this road. Public vehicle access could be improved in South Pureora and Ongarue. There may be others. Improving vehicle access will assist to put greater recreational hunting pressure on areas of the forest.
NZDA Requests: A new milestone be added to Milestone 1.5.1 Planning and management for people’s benefit and enjoyment
4 Objective: Increase vehicular and walking access points to lands administered by DOC.
2 year goal: Gain formal agreement for public vehicular access to Pureora FP at Watuhi Saddle Road.
Point 22: Management Policy 1, page 93:
NZDA Concerns: NZDA does not support this policy (Will manage priority pest plants and animals to low levels). No priority pest plants and animals are listed. Many animals DOC should call wild animals appear to be called “pests” in Waikato Conservancy.
Point 23: Management Objectives (page 93):
NZDA Concerns: Facilitating recreation is a primary purpose of conservation parks. Pureora is a conservation park. DOC has a statutory duty to foster recreation, and to facilitate recreation in Pureora Forest Park.
NZDA Requests: Add new Objective 1A: To facilitate recreation throughout the Park.
Point 24: Management policy 7, page 94:
NZDA Concerns: A recreational hunting area is already zoned in the Park. Recreational hunting is a legitimate activity in conservation parks. Conservation parks are only required to protect natural resources, not “enhance” them. DOC has a responsibility to the recreational public to manage public conservation parks to facilitate recreation. DOC appears to lack the capability to do this, as required by the Conservation Act.
Point 25: Conservation Management Plan for Pureora Place:
NZDA Concerns: Pureora Place, including the Forest Park, is probably the most important and significant public land holding in the Waikato Conservancy. It is the largest land holding. The proposed CMS gives no details of the proposed DOC management for this area. All that is provided are trivialised statements that mean nothing, and that do not even implement the CGPs.
Given this lack of integrity in DOC’s proposed consultation, it is important that actual Plans for Pureora Place actually be developed.
NZDA Requests: That the CMS state that a CMP for Pureora Place be developed within the next 3 years. This would be best as a 3-year milestone for section 2.6 Pureora (page 111) 3 year milestone.
Part 3 Implementation, monitoring, - milestones (page 97)
Point 26: Milestones
NZDA Concerns: Most of these Milestones are non-specific, and many are ridiculously so. For example in 1.2.1 why does it take 3 years to develop community action plans for each area office? Presumably a significant number of community partnerships already exist. These need to be listed, or else one will get the impression no new ones will eventuate.
NZDA Requests: 1 Make these milestones more specific.
2 Include NZDA’s three milestones from Point 7 above, in 1.2 Public participation Milestones. And other ones noted for other headings.
Part 7 Maps (page 135):
Point 27: Map presentation
NZDA Concerns: The maps are essential to show where the land parcels are. They are all special
places for some people, and for some reasons. However, the maps lack detail as to the names of the parcels, though, if one can read small print, they all have a number.
NZDA Requests: 1 Land reserve names please: The maps would be more user-friendly and informative if they had the names of significant parcels of land on them. The “Places” are diagonally lined, which is a help. But they should also be named as they are in the text. Also, Islands, and other major or important areas, eg greater than 500 Ha of land should be named as well.
2 Note the areas for which management is likely to change, and how.
3 List all conservation parks together ie split up conservation areas and reserves into their basic land statuses; don’t amalgamate different types, as has been done in the Draft.
Conclusion:
The Draft CMS does not adequately detail DOC’s plans and strategy for the Waikato Region.
There is inadequate supporting data and information on the present situation, and almost no information on how the CGPs are to be implemented. Most statements in the CMS simply replicate the CGP, usually in more general terms. NZDA is disappointed at both the lack of information, and the lack of statements of intent on what DOC intends to do.
This lack of information provided in the CMS trivialises the consultation process.
In spite of this, NZDA is interested in working with DOC on improving the recreational deerstalking and pig hunting experiences for recreational hunters in the region, and encouraging recreational hunting.
I trust these comments will be helpful to you.
NZDA asks to be heard in support of this submission.
Yours truly
Dr Hugh Barr
National Advocate
1 Recreational Hunter numbers (1988 Survey):
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, as information to be taken account of in this CMS Review.
A national survey carried out by Landcare Research’s noted 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, and may have grown. Membership of NZDA branches is growing at about 7% a year, showing deerstalking is becoming more popular, as is providing wild meat for the table.
Table 1 below shows Nugent’s estimated numbers who hunted in 1988, based on a survey of firearms owners. Some 20% of the sample said they did not hunt in that year, but intended to hunt in the future, showing the additional potential continuing hunters.
DOC should be interested in helping provide opportunities for the say 30,000 recreational hunters who can hunt in the Waikato Conservancy, based on the populations of Auckland, Waikato and Bay of Plenty, and pro-rate the 60,000 deer and wild pig hunters in 1988. 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. This helps reduce carbon emissions from transport, something DOC claims an interest in reducing. Also harvesting the game is far better in terms of sustainability than shooting or poisoning them to waste.
Table 1 also shows also the significant number of small game, mainly possums and rabbits, and Game-birds harvested in 1988.
Altogether some 140,000 New Zealanders are hunters, and the lands administered by DOC provide by far the largest area where they can readily recreate, and is a significant actual and potential recreational use of these public lands.
2 Deer and wild pigs viewed by the public as a valued resource:
Research shows the 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.
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 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, and are positive about other larger introduced species.