30 April 2008
New Zealand Deerstalkers’ Association, National Office (NZDA) makes the following submission on the 1080 Database consultation. If hearings are being held on submissions, NZDA wishes to be heard in support 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
NZDA has major concerns about the indiscriminate aerial use of Poison 1080 and about indiscriminate use of poisons generally because they kill a range of non-target species, including native birds and insects, such as weka, kea, and carnivore native birds - falcon and more-pork from primary and secondary poisoning. They also kill the herbivores deer, chamois and tahr, and omnivores wild pigs, in spite of these not usually being target species.
NZDA is also concerned at the very large amount of 1080 per hectare used in aerial 1080 operations, where only 2% of the poison delivered is needed to kill the likely number of target species present per ha. NZDA consequently advocates banning aerial 1080 operations, and in the shorter term for immediate significant reductions in the aerial 1080 used per Ha.
1 The 1080 Watch-list:
NZDA strongly supports ERMA’s creation of the Watch-list. If it remains accurate, and is comprehensive, then it provides an historic record of aerial 1080 operations. This will be useful in assessing the impact of aerial 1080 operations over time. NZDA considers ALL information set out in the “Draft for Discussion” should be required to be supplied.
1.1 Need to collect all the data listed:
NZDA believes the list of data that ERMA has listed is all necessary for a full historic record for analysing future trends. There may also be additional data that is also needed eg see 1.3 below.
It is important too that operators have to fill in all of the info. NZDA is concerned that submitters will not fill in all slots. For example (e), (f), (g), (h) in Additional control 12. Surely, if the data is not available, the operator must state “Data was not collected”. It may be, if operators do not answer these questions that ERMA will
a) miss out on important information for its trend assessment
b) need to require that this important information is collected
It is important that all questions must be answered by submitters, and that supplying the required information is not considered optional.
1.2 Reasons for using aerial 1080 (S 1.3 Situation description) – additional question:
Given the indiscriminate poisoning by aerial 1080, and the high amount of poison that is surplus overkill, NZDA believes ERMA should include a question (suggested as the second question in S 1.3, or as a new second-to-last question in Section 2.1) asking
“Why was aerial 1080 chosen as the method of pest control used?, given its adverse by-kill effects.”
NZDA considers this is a key question ERMA should be asking, given its statements when the ERMA Decision was released that aerial 1080 had significant downsides, and that there needed to be alternatives. Also DOC does not use aerial 1080 when some endangered species are involved eg kiwi, in the St Arnaud Mainland Island, risk to wekas, who scavenge dead carcasses, etc.
1.3 Non-target species by-kill – under-reporting concerns (S 3.1):
NZDA is concerned that it will not accurately record aerial 1080 non-target by-kill. NZDA appreciates that this information is requested in Section 3.1 under Environmental and ecosystem effects Non-target deaths recorded. NZDA considers operators would tend to minimise recorded non-target deaths, as there is a conflict of interest for them in declaring by-kill. Public complaints may be a more accurate indicator.
NZDA asks what checks ERMA intends to include to confirm the accuracy of data entered into the database by operators? Some tend to stretch the truth. Monitoring of data by ERMA is essential.
1.4 Advanced recording of aerial 1080 operations:
NZDA wrote to ERMA on 7 November 2007, asking that ERMA consider recording aerial 1080 operations once they are decided on by DOC or the AHB. Then the public is notified of the agency’s intention. NZDA understands from Greg Kent that this is not possible because of the wording of Additional Control 12. NZDA suggests there is advantage to ERMA in having a prior listing, so that public complaints are allocated to the correct file etc, and that an appropriate code is allocated.
1.5 Operation Unique identifier:
NZDA assumes that ERMA will use a unique identifier code for each operation. This is not addressed in the Document, as it is not chosen by the operator. NZDA suggests a simple code that uniquely identifies the year and location, and is readily understood by all, is desirable.
Thank you for the opportunity to comment.
Yours truly,
Dr Hugh Barr
National Advocate