Oral Submission

Oral Submission - Reassessment of sodium fluoroacetate (1080) and substances containing 1080 (a vertebrate toxin)

NZDA opposes the ongoing indiscriminate use of 1080 in New Zealand because its indiscriminate use kills species not covered by this application including valued introduced fauna, native birds and other native wildlife.
NZDA seeks elimination of all indiscriminate use of 1080 by 2015.

NZDA hunters have repeatedly found the bush silent after the use of 1080-native fauna had been decimated.
First we were told it didn’t happen.
Then “it happens but only slightly”.
Then “it is significant but they will recover”.
Finally it will be “We are terribly sorry for what we have done”.
The bush experience has been significantly damaged by repeated use of aerial toxins destroying native wildlife and game animals.

Future use should, wherever possible be confined to ground-based operations.
Bait must be enclosed in species or target specific containers.
Current use poses unacceptable risks to game animals and hunting dogs.
1080 use on public lands inhibits hunters ability to take safe wild meat for their families.
Any ERMA controls must ensure a measurable mitigation of the effects of 1080 on game animals.
Sufficient uncertainties are expressed by health and science authorities to support an reduction in the exposure levels for New Zealand.
The DOC/AHB appplication fails to acknowlege the value of game animals required to be considered by ERMA’s governing legislation as “Valued Introduced Fauna”.

NZDA estimate 7 million ha of public Conservation estate is of value to hunters.
However only 1.9% is designated as Recreational Hunting Areas.
The only published study (Nugent 1988) indicated.
30, 000 active deerstalkers.

Was an introduced species considered a pest or a resource?
Did the species increase or decrease the enjoyment of a bush trip if encountered.

Deer are most considered as a resource (44%), and as both a pest and resource (51%) and least considered a pest (4%).
Deer increased the enjoyment of 95% of respondents.
Conclusion: deer are a highly valued introduced fauna, with 392,000 days spent hunting and increasing the enjoyment of 95% of respondents when encountered

Other applicants have well traversed the toxicity of 1080.
NZDA deeply shares these concerns but in the limited time available has concentrated on areas which specific relevance to hunters and bush users.

Cost benefit analysis seriously flawed in extrapolating falling cost data for application of carrot and pellet baits.
Questions submitters were to answer were oriented toward supporting 1080-”if you do not support, how could its use by modified to make it more acceptable”.
A broader range of scenarios should be presented than the polarised set presented admitting no middle ground.
Costs such as loss of commercial wild deer recovery industry have been ignored.
Cost of loss of part recreational deerstaking activity has been overlooked.
Recovery of deer numbers may take significantly longer than the 5 years proposed, and 5 year poison returns mean the deer may never recover.
Value of recreational hunting experience is underestimated by a factor of 7

NZDA seeks elimination of all indiscriminate use of 1080 by 2015.
ERMA should explain how public opinion has informed and supported its decision when it is made.
All useful and operable alternatives should be traversed.
The risks of current 1080 use carefully discussed including impacts on the wider community.
The sustainability of current 1080 use must be demonstrated and if not current usage changed.