30 November 2009
This submission is made by the New Zealand Deerstalkers’ Association Incorporated (NZDA).
NZDA is the national association of deerstalkers and other big game hunters, with over 50 branches and hunting member clubs throughout New Zealand. NZDA has 7800 members, and has been actively advocating for recreational deerstalking and hunting, running hunter training courses, trips, conferences etc since 1937. NZDA’s membership continues to grow. NZDA sets and maintains ethical standards for hunting.
NZDA requests to be heard in support of this submission.
NZDA has lengthy experience of the Animal Health Board (AHB) and its method of operation. Because there is a high by kill mortality of deer (measured at up to 90% of deer killed) in aerial 1080 operations targeting possums, NZDA makes submissions against most aerial 1080 drops. NZDA usually recommends instead that ground trapping be used instead, as this has zero deer by kill.
NZDA and recreational hunting individuals and groups also made extensive submissions to the Environmental Risk Management Authority (ERMA) re-assessment of 1080 in 2006-07. Some of our experiences gained in these activities with aerial 1080 are raised in this submission.
NZDA concerns about the AHB’s proposed new Strategy for Bovine TB control:
1 AHB Changed Strategy:
The Animal Health Board (AHB) intends to change its strategy drastically from eliminating bovine TB (BTB) from herds of cattle and deer to eliminating BTB from all wildlife. It is not even clear that such a strategy is possible. Human TB for example, has yet to be eliminated from all New Zealanders. Humans are far more readily monitored and treated than back-country wildlife.
2 AHB Progress towards its goal has stalled since June 2007:
The AHB initially made good progress towards its self-imposed target of reducing BTB from 1.4% BTB infected herds in 2001 to 0.2% in 2013. But this decline has levelled off at just below 0.4% since June 2007. [See Figure 1, below from the AHB website]
The main means of infecting herds has been by infected livestock movements. This is because the skin test for infected livestock is only about 90% accurate. Why the AHB progress has stalled in the last two years is not discussed in the AHB’s proposal. The reasons for it should be discussed, and the alternatives to combat it discussed and set out. They are probably much cheaper than the new Strategy the AHB is proposing.
3 Major costs of the AHB Proposal:
The AHB Strategy to reduce infected herds to 0.2% by 2013 has already cost over $1 Billion in 2009 dollars. The AHB now wants to keep on spending at the current rate ($82 Million/year) indefinitely eg another $1.2 Billion by 2025, just to keep the infected herds at the same level (0.4%) for the next 14 years. This would be a failure by the AHB to address and achieve the outcomes it has previously set itself.
4 No AHB phase-out evident in spite of nearly achieving its objectives:
After 12 years of the AHB’s BTB Strategy, the program should be ready to reduce significantly. Significant areas are being declared free of BTB. The AHB and its associated contractors and government agencies appear mainly interested keeping all the funds they are now getting, possibly more. At any time, but especially during a recession, public and farmer funds should not be wasted, if there is no adequate return from investing them.
5 Major issue – livestock transport:
The major reason for much BTB herd infection is inadequate screening of BTB in livestock. The Skin test is only 80% accurate for deer, and only 90% accurate for cattle. So one in ten to one in five animals that have BTB are incorrectly diagnosed as not having it. Improving the accuracy of the Skin test is essential to removing BTB from New Zealand livestock. The inaccuracy of this test may be the reason why infected herds have not reduced in the last two years. A number of recent BTB infections have been traced to infected stock movements.
A Treasury Working Paper "Coughing Up for TB control" in July 2000 questioned the BTB National Pest Management Strategy. On the likelihood of a trade ban - "the risk is probably very small,' and "the true risks are likely to be smaller and shorter in duration than the AHB analysis would suggest."
The paper also addressed how the problem of TB rose in the first place by saying: "the root cause of the problem is not the presence of possums but rather their infection with TB, as is clear from areas like Taranaki, which have possums but are still TB free - suggest that TB was spread by transport of infected animals."
The paper also addressed how the problem of TB rose in the first place by saying: "Indeed there are cases of outbreaks of TB known to be due to stock transport,” eg Wairoa, Marlborough's Northbank. The solution by AHB was to aerial drop 1080.
As well, off-season grazing of dairy herds in infected areas can spread BTB eg Marlborough herds being off-season grazed in Kaikoura, an infected area.
6 Hidden regional council costs:
AHB is passing major costs back to regional councils. As it rolls back BTB, the AHB withdraws its possum control funding for that area, and leaves the regional councils (RCs) to “maintain” acceptably low possum numbers for the rest of time from ratepayer funding. These costs alone appear to amount to $20-30 Million annually, borne directly by the RC ratepayers. The AHB meanwhile has the same funding for a decreasing area of land. Instead, AHB funding should reduce as the area with BTB shrinks.
7 Very high opportunity costs compared with alternative investments:
The combined cost of the AHB and RC spend on BTB and subsequent possum control is in the range $82-$100 Million/year. This can be compared with the total Crown funding for AgResearch, the largest agricultural research organisation, which has government research funding of $100M/year (2008). One would expect the incremental benefits from greater pastoral research would be much greater than the risk reduction in BTB from 0.4 to 0.2 of herds. Less funds spent on BTB and possums could mean more funds on pastoral agriculture research and development.
Equally the Varroa Bee Mite eradication program has been run on a total cost all up of $250,000. Having bees to pollinate grasses and horticulture crops is arguably more important to New Zealand than eliminating BTB from wildlife. Alternatively the funding could go to better education or health.
The EU Bureaucrats who initiated the non-tariff-barrier for BTB by requiring BTB infection control would be laughing if they knew it was costing New Zealand $100M/year. The AHB’s massive BTB program is distorting funding for other more important matters.
8 Cheaper alternatives not considered:
Cheaper alternatives to the AHB’s strategies exist, eg vaccination of cattle and deer. This is the usual response to bacteria and viruses in humans and livestock, because usually prevention is a much less costly approach than treatment or eliminating the disease eg small pox, polio, whooping cough etc. Vaccination should be only a fraction of what this AHB Strategy has cost so far.
9 Cost-Benefit analysis biased by self interest and spurious arguments:
Cost-benefit calculations are notorious for being jack-ups. In our experience most are made hard to obtain, and even harder to understand. This is the case here, where the Cost-benefit analysis is not part of the proposal, nor even adequately described in the summary report supplied by the AHB. The AHB’s case seems a prime example of misleading assumptions to get the answer the Agency wants.
The AHB’s so-called “Ad Hoc approach” (See “Technical Assumptions for the 2009 NPMS Review options”, AHB, October 2007) used for comparisons (claimed to be required by the Biosecurity Act), may be appropriate for a start-up situation where there is no strategy. But this strategy has been operating for over ten years. The status quo is to maintain the present strategy at a lower level, not to forget what has been learnt in those ten years, and start from scratch again.
It would be inappropriate to abandon the present strategy and do nothing. Either a “minimal continuation” or a “sensible maintenance” strategy should have been developed. That it was not [See “Bovine Tuberculosis National Pest Management Strategy – Cost Benefit Analysis Summary”, AHB, July 2009] and only the Option chosen by the AHB (eradication, the most expensive scenario) indicates the AHB had already made up its mind what it wanted to do – the most costly alternative it could develop.
The AHB talks about a “containment” strategy. But this is absent from the background cost-benefit calculation paper. Containment is a real option to compare with the AHB’s very expensive proposed eradication strategy. The AHB should be in phase-down mode now that it has almost achieved its objective of 0.2% of herds infected. Much of the country is becoming BTB free. Why the need for continued massive funding?
It should cost significantly less too, especially as the increased cost effectiveness from the research and knowledge developed from the present strategy at a cost of over $1B, should reduce costs significantly. The AHB and DOC boasted about their efficiency gains in their joint submission to ERMA’s 1080 review in 2006. They should be applied now. Why was a “Containment” strategy not analysed? It is likely to be the most cost-effective option.
As well, the “Eradication” strategy performs poorly, and only gets by because it claims “biodiversity” gains from killing possums on back-country public land, a benefit that has nothing to do with eradicating BTB. Without the nebulous “Biodiversity” benefit, the AHB’s “Eradication” strategy performs very badly in cost-benefit analysis.
Recommendations:
1) Given the situation described above, what is needed, instead of the AHB’s self serving new Strategy, is an independent Ministerial Review, as to why the AHB is not phasing down its activities as it achieves its BTB targets, and the significant financial and BTB risks it is not adequately managing.
2) That the AHB funding drop to $40 Million/year from 2010, in line with the AHB having reached it’s objective of 0.2% of herds infected and much of the country having been rolled back as BTB free.
10 Massive killing power of present aerial 1080 drops:
Landcare Research (Bruce Warburton) has recently re-estimated possum numbers in New Zealand for the AHB at 30 million. This is based on the equilibrium density for possums in different types of vegetation. The highest density is associated with podocarp forest. Equilibrium densities in beech forest, pine forests and most other types are much less eg 2/ha.
Once the possum population is down to a RTCI of 2%, there are therefore very few possums present, well below 1/ha.
Aerial 1080 bait densities have now moved down to 2kg/ha of 0.15% 1080. This is still an enormous poison overkill to kill probably one possum/ha. 1080 is a broad spectrum poison killing most animals, vertebrate and invertebrate, that breathe oxygen. It disrupts the Krebs cycle, the basic cycle for animals breathing oxygen. It was originally registered in the USA as an insecticide, and is registered in New Zealand as an insecticide for wasps.
The lethal dose to kill 50% of animals, called LD50, is known for most animals. For possums it is 1.2 milligrams per kg of body weight. For the average 3 kg possum, 2 kg of 0.15% 1080 bait is the lethal dose for over 800 possums, when only one or two are expected. Over 99% of the aerial 1080 dropped is available to kill other animals.
Usually native birds eg robins, tom tits, (whose numbers recover quickly) wekas, keas, kakas, moreporks, falcons (which do not raise many offspring) are killed, and are a cost to native biodiversity. This significantly offsets the benefit of killing the possums.
Recommendation: The killing power of aerial 1080 baits should be significantly reduced below 2 kg/ha of 0.15% bait.
Landcare Research – Reduce, refine, replace [See Karerehe Kino, Issue 14, June 2009] show how this can be done.
11 Recreational hunters will be very adversely affected:
Deer and deerstalkers are major losers from the AHB’s “proposed” new “Eradication” strategy. There is no mention of this cost to recreational hunters in the AHB’s Cost-Benefit analysis, nor any mention of mitigation measures the AHB intends to take to reduce the adverse impact on deerstalkers or other big game hunters.
The standard control measure, aerial 1080, has killed 50% of deer on average, in areas where deer by kill has been measured [Eason C T; “Technical Review of 1080 toxicology” 2002, for the AHB, Table 5, copied below].
Table 5 shows that (wild) deer by kill varied from over 90% (18%), down to 5%.
Other aerial 1080 drops in the Blue Mountains in 2001, and the Northern Aorangis in 2003, were both about 70% deer by kill.
(Wild) deer annual population growth-rates, assuming no harvesting or killing to waste, are probably below 20%. So deer populations will barely recover in the four to five years between aerial 1080 drops, let alone provide a recreational hunting resource. With 70% by kill, and no harvesting, the herd would take ten years to recover to its size before the drop. In both cases the herd would be eliminated as a hunting resource.
Aerial 1080 is very effective at killing deer. So the AHB can target deer, even though aerial 1080 is not registered to kill them. AHB should be required to introduce measures to reduce deer by kill from aerial 1080, such as using ground trapping for possums, which is very specifically targeted to possums, with little or no non-target animal by kill, ie zero deer by kill. The AHB proposed Strategy (S 5.2) says: “ - deer may need to be controlled in some locations either to prevent spread or to prevent re-infection of the possum population.” Presumably this implies specific BTB deer control by the AHB is not likely.
Wild pig by kill is less, but can still be significant. These adverse effects are not mentioned in the AHB proposal, nor how the AHB intends to mitigate them. Presumably they don’t.
12 Recreational hunting areas to be blitzed by AHB’s proposed “Eradication” Strategy:
The AHB proposal lists five stages for their “Eradication” strategy (page 37).
a) Initial – reduce RTCI to 2% mainly by aerial 1080 drops
b) Maintenance – maintain RTCI at 2% for at least 4 years, again probably by aerial 1080 drops
c) Eradication – two years with vector control, probably aerial 1080, until no vector-related BTB diagnosed livestock or wildlife in the last 5 years and RTCI has been held below 2% for at least 5 years
d) Post eradication – four years with no vector control, and no BTB
e) Surveillance – AHB moves out, but still surveillance of herds for BTB.
North Island deerstalking areas targeted:
The AHB North Island maps (pages 41-44 of their proposal) show that the areas around Lake Taupo and in central and northern Hawke’s Bay are to be blitzed with large aerial 1080 drops. The Taupo area is regarded as the centre of deerstalking in the North Island, because it is surrounded by important deerstalking areas, eg Pureora Forest Park, Tongariro Forest, and Tongariro and Urewera National Parks, Kaimanawa, Whirinaki and Kaweka Forest Parks.
Also to be blitzed is the Wellington-Wairarapa area. Deerstalking areas here include the Tararua, Rimutaka and Aorangi Forest Parks.
South Island deerstalking areas targeted:
In the Upper South Island the AHB maps show (pages 45 - 48), the accessible areas in Nelson, Marlborough, Buller, North Westland and North Canterbury are all to be blitzed eg Mt Richmond, Victoria Range and Lake Sumner Forest Parks, the Kaikouras Conservation Park, and Kahurangi and Nelson Lakes National Parks.
There are also large areas in South Canterbury, and North, Central and South Otago, and in the Hokonuis and Western Southland. These include parts of the tahr range, and recreational hunting areas such as the Catlins, and Oteake, Two Thumb and other tussockland conservation parks.
For a fuller but not comprehensive listing of deerstalking areas see “Spot X Hunting New Zealand” Second Edition, Mark Draper and Mark Airey 2007.
The AHB “Eradication” strategy will wipe out deerstalking in all these areas at least for the duration of the AHB Plan, and probably longer. Though some deer may survive, they will be at such low densities that recreational deerstalking will not be possible. The AHB “Eradication” strategy seems as much about eradicating deerstalking in the areas targeted as it is about eliminating BTB.
Recommendation: Because of the very high by kill of deer with aerial 1080, that the AHB be required to avoid deer by kill in valued deerstalking areas, when using aerial 1080 there, and to consult with NZDA nationally, and as well, with recreational big game hunters and hunting clubs locally, about all aerial 1080 drops.
There is no mention of AHB measures to avoid deer by kill in its “Eradication” or any other scenario. Surveys of recreational hunters have shown that there are 60,000 recreational deerstalkers and pig hunters in New Zealand [Nugent, 1989, summarised in the Table above]. The AHB needs to recognise the importance of recreational hunting as a traditional and valid recreational pursuit that has taken place in New Zealand for over 100 years. This is a requirement of Sections 6 and 7 of the HSNO Act (1996).
Proof of the feasibility of AHB’s “Eradication” strategy needed:
13 Independent proof required that BTB is present in back-country wildlife
Two questions arise about AHB’s proposed Strategy to eliminate BTB from wildlife. What proof is there that BTB is present in wildlife in remote areas? If it is not present, then the AHB is wasting its funds by dropping aerial 1080 there.
A number of cases have arisen where the AHB has authorised aerial 1080 where it was unable to prove that BTB was present eg St Arnaud aerial 1080 drops in 2008.
A well-known case was a deer discovered with BTB in the central Ureweras prior to a 52,000 Ha aerial 1080 drop in the Southern Ureweras and Whirinaki Forests in winter 2006. This is just the large type of drop the AHB intends to use frequently in its proposed Strategy.
AHB contractors were used to search for BTB in wildlife in the area, even though their reward for finding it would have been the opportunity for million dollar contracts for aerial 1080-ing the forests. The AHB now says the one infected deer that was found had been recently introduced to the area, and so did not prove that there was BTB in the Urewera herd.
AHB was told this at the time by a Wild Animal Control helicopter recovery (WARO) operator, who had never found BTB in deer taken from the Ureweras in his twenty years of WARO-ing there. AHB chose to ignore his knowledge. Incidents like this show the AHB process lacks integrity. Will this irresponsible behaviour continue in future? And continue to waste taxpayers’ and farmers’ money, and disadvantage recreational hunters, WARO operators and possum trappers?
14 Can BTB be eliminated from wildlife?
The second issue is whether it is possible to eliminate BTB from wildlife, if it is present. The AHB believes this is still to be proven, and that it will have evidence that may determine this by 2025. Fifteen years and $1.2 Billion is a lot of someone else’s money and time to bet on the truth of this outcome.
There is also the adverse cost to recreational hunters, WARO operators, possum trappers etc from this “suck-it-and-see” approach. It is lazy thinking, and an unscientific approach. The AHB has not assessed the evidence adequately, or considered alternate strategies that better address the issue. This needs to happen before the Strategy is agreed to.
Another question that needs answering is whether BTB in remote areas of the back country pose a threat to livestock many hundreds of kilometres away, eg South Westland, and livestock in Otago, or Southland? The likelihood of infection would seem very low. If the AHB has adequate tools for monitoring BTB in the back country, it could track whether the BTB was moving dangerously nearer to uninfected livestock. Only then, when it was identified as a hazard, would action be needed. This is a much lower cost strategy than the AHB proposes.
Recommendations:
(1) That AHB be required to produce independent evidence of BTB in back-country areas before it undertakes aerial 1080 operations there. Such operations are very detrimental to both recreational hunters and to WARO operators, so need substantial independently collected evidence.
(2) That AHB be required to prove any remote BTB provides a direct threat to livestock, before it is allowed to spend money trying to eliminate it.
15 AHB blocks analysis of evidence of the presence of BTB in backcountry deer:
WARO harvest of deer in the back country is one way of assessing where and how much BTB is present. NZDA’s National Advocate Dr Hugh Barr asked for past data from the NZ Food Safety Authority (NZFSA), to see what this data indicated. However, this request was forwarded to the AHB, and no data was provided. The AHB seemed to have a relationship with NZFSA that allows it to stop the release of data that could undermine the AHB’s proposed new Strategy.
NZFSA comes under the Ministry of Agriculture and Forestry (MAF), giving the impression that a number of government agencies that stand to gain from the AHB proposed new Strategy, are actively engaged in getting it approved, independent of its merit.
Recommendation: WARO data is analysed independently, to test the AHB hypothesis, and their Strategy re-assessed accordingly.
Conclusion:
Because there are so many unanswered questions about the AHB Strategy, it’s excessive expense, whether an un-researched experiment like this will work, NZDA requests an independent ministerial enquiry on these matters.
NZDA strongly opposes the AHB proposed new “Eradication” Strategy for the reasons set out above, based on our experience from dealing with the AHB. The concept has still to be proved, it is excessively expensive, the cost-benefit analysis is biased and inadequate, and in any case does not show a positive benefit compared with the high cost. By 2025 the infected herds level will not have achieved the 0.2% target for 2013.
The AHB’s proposed “Eradication” Strategy needs to be compared with a sensible “Containment” strategy, based on improved efficiencies and an initial budget of say $40M per year.
As well, given the major damage that will be done to the deerstalking resource over large areas of New Zealand, the Strategy needs to provide for reduced by kill of deer from aerial 1080 eg by ground trapping of possums (zero by kill) in place of aerial 1080, where deer herds are valued recreationally.
NZDA wishes to be heard in support of this submission.
Yours truly,
Alec McIver
President
Dr Hugh Barr
National Advocate
© 2011 New Zealand Deerstalkers' Association