28th September 2006
There are a number of NZDA Branches around this Park, and all can hunt in the Park. Those within 100 Km includes: North Taranaki, Taranaki, Manawatu, Bush, Taihape, South Waikato, Kapiti, Rotorua, Taupo, Te Awamutu, Waikato (Hamilton) and Waimarino. (12 branches)
NZDA asks to be heard in support of this submission.
Summary: NZDA is concerned, as are all recreationalists about the two outdoor recreation essentials:
a) Adequate public access to and across the Park
b) Conditions that do not spoil a rewarding recreational experience in the Park, without unduly compromising important native species survival
NZDA is disappointed that public access to the Park, and the adjacent Waitotara Conservation Area, has been reduced since the last Plan, or is intended to be reduced further. This Park is already one of the most difficult of access in New Zealand. Hunters also prefer motorised access (4WD, boat or helicopter) to take out animals harvested for food. Also taking out tracks and shelters discourages most recreationists from visiting.
Second NZDA seeks more appropriate conditions for encouraging recreational hunting, as encouraged by the new Conservation General Policy. NZDA wishes to work with DOC to encourage greater recreational take of recreational valued wild animals in the Park.
Sixteen Specific issues:
Issue 1: 2.2.2 Impacts of introduced animals - (Page 31)
Recreationally valued big game animals regarded as pests.
NZDA Comment: There is no definition in the National Parks or Conservation Acts of “pests”. Under the Wild Animal Control (WAC) Act, valued recreational wild animals, namely deer and wild pigs, are primarily to be reduced only when their numbers are so high as to cause significant damage to native vegetation. The WAC Act superseded the Noxious Animals Act (1956), in 1977. Prior to that, all animals listed as noxious in the Noxious Animals Act were considered noxious ie excessive pests, regardless of numbers.
“Pest” is a term used in the Biosecurity Act, and determined by a regional pest management strategy. There is no evidence in the draft Plan that the relevant regional councils have declared deer or wild pigs as “pests”.
The reason that introduced mammals are required to be exterminated, has nothing to do with them being pests, but because they are introduced. Section 4 (2) (b) of the National Parks Act requires all introduced animals to be exterminated, unless the Authority “otherwise determines”. It is not because they damage native species that they will “as far as possible be exterminated”, but because they are introduced species.
As well, the recreationally valued introduced species deer and wild pigs have benefits to recreational and commercial harvesters in terms of recreational and food value. These stakeholders do not treat them as pests, as they have significant recreational or food value.
This “value” is reflected in the General Policy for National Parks (GPNP) in sections 4.2 (e) commercial hunting and 4.2 (f) recreational hunting; where commercial and recreational hunting are to be encouraged. These general policies do not talk about “pests” but about “biosecurity and management of threats to indigenous species, habitats and ecosystems” (S 4.2, CGP or S 4.3, GPNP).
There is no requirement under the Wild Animals Control (WAC) Act for the recreationally valued wild animals – deer and wild pigs to be regarded as pests. Under the WAC Act they are only to be reduced if their numbers are so high as to cause ecological damage.
NZDA Requests replacing “Management considerations” page 31: This statement should be updated to current usage, as reflected in the words of the Conservation Act, National Parks Act, WAC Act and the General Policies. For example:
“Introduced animals pose threats to some native species. However the threat level of each introduced species needs to be assessed according to numbers of animals, and any damage.
Recreationally valued wild animals, viz Fallow and Red deer, and wild pigs in this Park, while they may pose a threat at high densities, are also recreationally harvested as food and as trophies, and are consequently highly valued by hunters. While the National Parks Act (Section 4 (2) (b)) requires the extermination of most introduced species, this is unrealistically difficult, and is only pursued in exceptional circumstances. The GPNP is more pragmatic viz:
4.3(j) Recreational hunting of wild animals and animal pests should be encouraged where this does not diminish the effectiveness of operations to control them and is consistent with planned outcomes at places.
4.3(i) Commercial hunting of wild animals and animal pests should be encouraged to maximise the effective control of them, while minimizing any adverse effects of hunting on planned outcomes at places.
Issue 2: 2.2.2 Policies (page 34-35)
NZDA Comment: The Plan should encourage recreational and commercial harvesting of wild animals, as required by Sections 4.3 (j) and 4.3 (i). Yet there is no policy to do this.
NZDA requests the following policy be added to implement these two sections: eg
(iiiA) DOC will encourage recreational hunting of wild animals in the Park by a number of specific methods including consultation with recreational hunters.
Issue 3: 4.1.3.3 Mangapurua/ Kaiwhakauka Track (Page 67):
NZDA Comment: We strongly support the outcome of providing recreational access for trampers and hunters along the old Mangapurua Road, including to the extent possible, responsible vehicular access for hunters.
NZDA: Opposes the addition of the Mangapurua legal road to the Park before adequate sympathetic, but permissible responsible access is agreed with recreational stakeholders. In the case of recreational hunters, this needs to include some form of appropriate vehicular access for carrying out harvested valued wild animals. NZDA also asks that its local branches Taihape, Taupo and Waimarino be part of the local consultation on public access along these road lines and that National Office, Wellington be kept informed.
Consequently NZDA opposes Policy ii), page 70, unless a consultation of affected recreational stakeholders is agreed about conditions of vehicle access before any move to closure. This condition should be added to Policy ii).
Issue 4: 4.1.4 Remote experience and wilderness areas: (Page 71)
NZDA is disappointed at Wanganui Conservancy’s withdrawal of tracks and huts from the areas specified as “remote”. The area has significant value for recreational hunting. But withdrawal of huts and tracks makes access difficult for recreational hunters.
NZDA sees this as a cop-out by the Conservancy on its obligations to foster recreation under the Conservation Act. Calling the area “remote experience” and “wilderness” is incorrect. It is really that the Conservancy has decided unilaterally to close down part of its conservancy to users.
NZDA asks how deer, goats, wild pigs are to be managed in these remote areas. We refer DOC to Section 4.3 (j) of the GPNP.
NZDA consequently opposes Objective 1, Page 71, Policy iii) and Policy iv) page 72, because it takes a punitive approach to volunteer contributions, in our experience, rather than encouraging volunteers to contribute, with less onerous conditions. DOC is behaving like any other monopolist in making barriers for other parties to maintain huts and tracks.
Issue 5: 4.2.1 Recreational hunting Page 74:
NZDA Concerns: 1 The “Background” statement does not reference GPNP Statement 4.3 (j):
4.3(j) Recreational hunting of wild animals and animal pests should be encouraged where this does not diminish the effectiveness of operations to control them and is consistent with planned outcomes at places.
Background. At present most of this section is about how terrible hunter dogs are, and gives the impression DOC hates hunters. Section 4.3 (j) is the reason that the Plan’s Policy i) is present (page 75).
Action NZDA Requests: Section 4.3 (j) of the General Policy be stated in the Plan’s 4.2.1
Issue 6: 2A NZDA Concern: Hunter dog kiwi aversion training:
NZDA agrees that “uncontrolled hunting dogs can pose a risk to kiwi and other native fauna –“. However, the current expensive “training” scheme is more a barrier to hunters taking dogs into the Park, and so is a barrier to Section 4.3(j).
Outcome requested: Proof that bird aversion training for dogs actually works, before aversion training is made mandatory. Our understanding is that research to date questions the effectiveness of the training.
Issue 7: 2B:
NZDA Concern: Hunter dog kiwi aversion training: The training penalises the responsible hunter using dogs in terms of time and money. This is why it is a barrier to effective pig hunting. As well, it does nothing for pig hunters that go there without aversion trained dogs. DOC is penalising the honest, but doing nothing about the dishonest – who cause much of the problem.
There is also the matter of which dogs and what parts of the Park dog aversion training is needed for. For example pointer dogs, that deerstalkers can use, are unlikely to attack kiwis. And it is frustrating when hunters have to pay for dog aversion training when there are no kiwis in the areas they go hunting in. Without DOC showing better management of this issue, recreational hunters will simply see it as another unfair hurdle against hunting.
Outcome requested: These problems be addressed and overcome in the third bullet point of Policy i), page 75 and ii) 4th bullet point, page 76. These points be noted in the Plan. A specific policy of DOC trapping, shooting or destroying wild dogs would also seem essential, not least for kiwis.
Issue 8: 3 NZDA Concern: More co-operation and discussion between recreational hunters and DOC:
NZDA strongly supports this, and requests to be kept in the loop as to meetings and information to this end. As mentioned initially there are twelve NZDA branches within 100 km of the Park.
Outcome requested: NZDA is keen for this co-operation to proceed, and to participate in it.
Issue 9: 4 NZDA Concern: Goats in the Whanganui River corridor:
Some of our members have commented on their inability to shoot goats near the Corridor, and would like the opportunity to do so. Such goats are very visible to those boating the River. They also noticeably damage vegetation.
Outcome requested: That DOC agree to assist recreational hunters control goats in the highest use, high visibility Whanganui River Corridor, and this be noted in the Plan.
Issue 10: 5 NZDA Concern: Better access and shelter for recreational hunters:
Huts and tracks have been taken out of the remoter parts of the Park and adjacent Waitotara Conservation Area, in a misguided attempt, it would seem, to save money or in response to a national DOC policy of cutting back huts and tracks. This reduces recreational hunting pressure on these areas.
Outcome requested: Add to Policy i) (page 75) second bullet point, that improving overnight shelters, vehicle access for recreational hunters, and additional tracks allowing recreational hunters to access areas where wild animals are building up, are issues that need to be addressed.
Issue 11: 4.2.7 Powered vehicles and other forms of transport (Page 80):
Management considerations, 2nd Para “In general, use of vehicles is not considered by DOC to be compatible with maintaining the Park in its natural state, in accordance with the NPA.”
NZDA Concerns: This is a very protectionist interpretation of the NPA. It would mean DOC itself should minimise its use of vehicles in the Park. This is something that never occurs (until petrol runs out) eg Policy i) page 81.
Most other national parks are development and tourism parks, where tourist development is promoted eg Mt Cook, Westland, Tongariro. While NZDA disagrees with DOC’s national parks as development parks policy, we see DOC’s prohibitive statements like the above, as discriminatory against recreational hunters, who need to carry out pig and deer carcasses they have harvested.
This Park is one of the most inaccessible, and sensible decisions to assist with more key roads and tracks are needed. It is a relief that DOC does not control vessels on the River. But it highlights the hypocrisy of this section.
DOC also needs to take account of its obligations under S 4 (2) (e) - the public shall have freedom of entry and access to the parks. The Parks are not DOC’s to lock up and throw away the key.
Outcome requested: Add to policy ii) (Page 81) – and for public use of the Park, including better vehicle access by recreational hunters.
Issue 12: Page 80: Powered vehicles on land:
Refers to Appendix 6, legal roads to be closed.
NZDA Concerns: The legal roads marked for closure in the north-east of the Park viz the Mangapurua/ Kaiwhakauka Valleys, are an area where vehicle access should be improved.
Outcomes requested: 1 NZDA opposes the closure of the Mangapurua/ Kaiwhakauka Valley legal roads until the DOC-Recreational Hunters co-ordination group has assessed these.
Issue 13: 2 That Appendix 6 be deleted.
Our reasons for this that these legal roads are a historic remnant, just as the “Bridge to Nowhere” is. They are a record of the misplaced optimism of past New Zealand governments in their ability to tame wilderness. As well it will save land transfer fees and legal costs.
Issue 14: Page 80 Powered aircraft:
NZDA Concerns: Better hunter access to remote areas. Given DOC’s withdrawal of tracks and shelters from the west and south of the Park/Waitotara State Forest, helicopter access becomes the only option.
Outcome NZDA requests: Additional clearings for helicopter access for recreational hunters (ie more than the current 4 shelters), be allowed in the draft Plan eg add a new iv-A) Additional heli-landing sites will be allowed in Appendix 5 after consultation with the recreational hunting liaison group.
Issue 15: Page 88, Table 2:
Entry: Limitation of recreational opportunities
1 Restriction of free public access to the Park:
NZDA Concerns: See above. The Plan should not be a lock-up plan, with no concern for public use and enjoyment.
Outcome requested: Delete this entry from Table 2.
Issue 16: 2 Loss of Open Space:
NZDA Concerns: This one is a real laugh. NZDA strongly agrees that open space is a valued and rapidly vanishing asset in Whanganui National Park. But it is vanishing because of vegetation regeneration, that under DOC policies is not allowed to be cleared. The only open space is usually open space around huts and for camping areas ie recreational facilities are the only provision for open space in the Park.
Outcome requested: Delete this entry from Table 2.
Thank you for the opportunity to comment. NZDA National Office requests to be heard in support of this submission
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