Waikato Regional Council: Draft Regional Pest Management Strategy

4th April 2007

Summary: NZDA Concerns with the WRC’s draft RPMS:

1. Deer and feral pigs not pests: NZDA opposes (wild) deer and feral pigs being “upgraded” to animal pests, because of their recreational value, and because no evidence is provided on why the “upgrade” is needed. WRC information re deer and pigs being pests is alarmist propaganda and just plain wrong. It needs correcting. The previous classification of deer and feral pigs should continue.

2. Inadequate information provided for public consultation: There is no adequate information on the reasons for animal pests being included, eg there is no benefit cost analysis, as required by S 72 (1) of the Biosecurity Act. The RPMS should be withdrawn, rectified and re-presented to the public. “Trust us” is not public consultation. As well there was minimal time for public consultation (less than 23 days), and it coincided with the “roar”, making it difficult for deerstalkers to participate.

3. Deer and feral pigs valued recreational and wild food species: These two animal species provide recreational enjoyment and meat for the table for the region’s citizens. They should be recognised as a community and recreation asset in the RPMS, just as farmed deer and pigs are. Ground control and bait stations should be used to protect them in poisoning operations in valued recreational hunting areas. If indiscriminate aerial poisoning is used, animal repellents to protect deer and pigs should be used, to reduce by-kill. When aerial poisons are used, NZDA is concerned at 6-9 month health stand-downs, which disrupt recreational hunting and food harvesting. The recreational hunting value of deer and feral pigs in the Waikato region is significant, and should be recognised in this RPMS.

4. Recreational hunters can help WRC manage deer, feral pigs: There are large numbers of recreational hunters that could assist WRC if any deer or feral pig management was needed. Though NZDA doubts this would be the case, it would save regional ratepayers some rates.

5. NZDA opposes the proposed doubling the cost of pest control: No good reasons why this massive increase in biosecurity expenditure is needed. It looks like staff on an empire building binge. NZDA opposes this misuse of the Council’s rates.

Detailed concerns:

1. Section 6.4: Feral deer (Page 111):

NZDA’s submission is: Deer are not a pest in the Waikato region, but a valued introduced recreational animal and wild meat food source.

Reasons for NZDA’s submission:

1. Primarily DOC’s Job: It is the Department of Conservation’s (DOC) job, under the Wild Animal Control (WAC) Act, to manage deer and wild pigs, especially on public conservation land. Although the Biosecurity Act can override the WAC Act ((S 7 (5)), it cannot do so on public conservation land.

2. No evidence deer are at high densities: No evidence is provided in the draft RPMS that wild deer outside public conservation land exist at high enough densities to threaten environmental values. Deer densities need to be well above 10 deer/sq km to threaten biodiversity values, and much higher than this to threaten water and soil values. No discussion of respective densities is given in the document. This makes us wonder whether WRC understands when deer pose a threat and when they do not.

3. No reasons why deer threat increased: No reasons are given as to why deer have been elevated to a higher threat level in this draft strategy over the previous strategy. Given the high level of susceptibility of deer to aerial 1080, there is a high likelihood that deer populations in the region have declined.

4. No High Value Sites identified: No areas are identified by WRC as being of high ecological value, or as “high value sites”. In any case, most such areas will be on public conservation land, including Coromandel, Pureora, Pirongia, Kaimai-Mamaku, Kaimanawa Forest Parks, or Tongariro National Park in the WRC region, or in scenic reserves or other public conservation land, administered by DOC.

5. No high value sites identified outside Public Conservation Land: No high value sites outside public conservation land are identified. So it is not possible for submitters to comment on the appropriateness of WRC’s pest status designation. Most likely any designation would be on private land, so again permission of the land-occupier would be needed, and nuisance pest would be a better designation.

6. Many valued recreational deerstalking areas: There are many valued areas on public conservation land in the region for recreational deerstalking and pig hunting – see eg NZ Hunting Guide, 2006 by Mark Draper and Mark Airey. Deer and pigs are not considered a pest in the Waikato region, but a valued recreational and wild meat resource.

7. Some of these areas include: Pureora Recreational Hunting Area (RHA), remainder of Poreora-Waihaha Forest Park (including much of the Hauhungaroa Range), Northern Kaimanawa Forest Park, draining into Lake Taupo (including part of the Kaimanawa RHA). This list is not comprehensive, and there are significant other areas not covered. For example, some exotic pine plantations allow recreational hunting of deer and wild pigs eg the Hancocks forests around Tokoroa, parts of Kaingaroa Forest.

Decisions NZDA seeks from WRC:

1. Remove deer as an animal pest (or at the very least, include it only as a nuisance pest, as in the previous Strategy).

2. Deer and pigs are not considered a pest in the Waikato region. They are a valued recreational and wild meat resource. These facts should be noted in the RPMS, if deer/pigs are going to be listed as animal pests.

2. Section 6.4 (p 111) Reason for the Strategy:

NZDA’s submission is: NZDA disputes the environmental threat reasons given that deer are a pest eg

a) No mention that deer have significant hunting and aerial poisoning pressure on them in the region, so their populations are static, or even reducing;

b) “- in forested areas, feral deer will destroy the understorey vegetation, which, when combined with possum damage to the upper canopy, can result in severe deterioration of forested areas. “

c) “Even small numbers of feral deer can cause damage that results in degradation of indigenous flora and fauna, affecting the diversity, rigour and even survival of some rare or endangered species.”

Reasons for NZDA’s submission:

a) Above: No mention of recreational hunter harvest: The Waikato Region contains the following NZDA Branches and associated clubs, and others as well:

Waikato Branch, NZDA, Hamilton; South Waikato Branch, NZDA Tokoroa; Taupo Branch NZDA, Taupo; South Auckland Branch, NZDA, Pukekohe; Te Awamutu Branch, NZDA; Te Kauwhata Branch NZDA; Thames Valley Branch NZDA; Tokoroa Pighunters Club.

There are also many Clubs especially those in the Auckland region (Auckland, North Auckland (North Shore), who have few hunting opportunities in their own region, and who come south to Waikato areas often to hunt.

Other adjacent branches, who hunt in the Waikato region include: Rotorua Branch; Bay of Plenty Branch; Napier Branch; Hastings Branch; Taihape Branch; North Taranaki Branch (New Plymouth); Taranaki Branch, Stratford; Waimarino Branch, Raetihi; Wellington Branch; Hutt Valley Branch.

Consequently there are large numbers of NZDA member deerstalkers and pig hunters that can and do hunt in the Waikato Region. The recreational hunting population is significantly larger than just NZDA membership, probably eight times greater.

So there is no reason to expect that wild deer populations will grow unchecked in the Waikato. As well as this, the extensive and continuing aerial 1080 drops throughout the region have caused significant deer by-kill see eg Eason, C T (2002) “Technical Review of sodiummonofluoroacetate (1080) toxicology” Landcare Research for Animal Health Board, Wellington, Table 5 reproduced below.

Table 5: Red Deer Kills Monitored During Aerial 1080 Poisoning Operations in the 1980s and 1990s
From Eason C T; 2002 "Technical Review of 1080 Toxicology" for AHB

Area and Source	Bait Type	Concentration Percent	Toxic Bait Showing Rate (kg/ha)	Deer Bykill Percent **
North Pureora [85]	Cereal	0.08	10	43
Pureora, 7km Buffer [85]	Carrot	0.15	15*	30
Pureora, 3km Buffer [86]	Carrot	0.15	15*	31
Pureora, no pre-feed [86]	Carrot	0.15	15	42
North Pureora [87]	Carrot	0.09	15*	57
Titiraupenga [88]	Carrot	0.08	15*	93
Titiraupenga [88]	Carrot	0.15	15*	92
Wainuiomata Valley [89]	Cereal	0.15	3^*	5
Orongorongo Valley [89]	Cereal	0.15	3	54

* The area was pre-fed with non-toxic bait prior to the sowing of toxic bait.
^ Sown in concentrated strips at 25 kg/ha with alternating untreated strips.
(Table adapted from Nugent et al., 2001.) [82] References [ ] refer to Eason paper.
** Percent of total deer present killed in the operation

Table 5 shows, in the few cases that deer by-kill of 1080 operations was measured, it was usually significant. The average by-kill of these 9 operations was 50%, and two were above 90%.

Deer were not targeted in these operations. Deer repellent was not used. We know of other operations after 2000 where very high deer by kills also occurred. A deer population growth rate of 20% is high eg assuming say 5% of hinds are too old to conceive, female fawns do not conceive in their first year, and an 85% breeding hind conception and fawn survival rate (cf farmed cattle).

At this rate, and assuming no hunter harvesting, it will take 4 years for a deer population to recover from a 50% by-kill, and 13 years to recover from a 90% by-kill. With by kills like this in the Waikato region, it is highly likely deer numbers are shrinking, and local deerstalkers are being forced to go elsewhere.

b) Above: Deer do not destroy forest understorey: Unless at very high densities eg over 10/sq Km (1/10 Ha) they do minimal browsing damage to forests and scrub. No evidence is supplied that deer numbers are this high anywhere in the Waikato region, except where deer are farmed. Where farmed, they are usually well above this level.

If WRC cannot name, with evidence, areas where numbers are at least 10 per sq Km, then there is no need for deer to be listed as pests. If there are such areas, then NZDA Branches and other recreational hunters will be pleased to work with WRC staff to reduce the numbers. There are potentially plenty of recreational hunters who can hunt the Waikato region, who could help.

c) Above: “Even small numbers of feral deer can cause damage –“

No native plant species are given. NZDA does not believe there are any in the Waikato in this category. At a Seminar in 2005, noted Landcare scientist Wayne Fraser said that no known New Zealand plant had become extinct as a result of the high deer populations from 1940 to 1970. The oft quoted example of the Mt Cook lily being vulnerable is a case in point. It is thriving throughout its range, much of the Southern Alps and Fiordland, and associated mountains.

NZ native plants are very hardy and survivable. DOC and Forest and Bird propaganda that they are vulnerable to deer browse is usually just that - lies. WRC staff should read the latest work on historic sources of New Zealand plants, and their survival and extinction over the last 80 million years in “Ghosts of Gondwana- the history of life in New Zealand” by Professor George Gibbs, 2006, Craig Potton Publishing.

This shows, using molecular biology results on DNA the ancestors and time of arrival of species in New Zealand. Many NZ flora have come from overseas, and many have become extinct of natural causes. Many too are recent arrivals.

5.1 Some need for browse of native vegetation:

New Zealanders have forgotten that, until probably 400 years ago, large populations of vegetarian moas roamed New Zealand, eating native vegetation. This may sound outlandish to present day Hamiltonians, who have only seen moas in museums. But Moas’ demise is so recent evolutionarily, that native ecosystems are un-natural without this browsing. We are now aware from recent scientific research, and understanding of tectonic plate movements and better dating procedures, how they have evolved for 80 million years, since New Zealand split from continental Gondwana.

Some botanists’ current ideas that native species are unbrowsed are un-natural. Such a situation has only occurred in the last 400 years or so, since man wiped out the moas. See [Gibbs]

Decisions NZDA seeks from WRC: Remove deer from being a pest, or at the very least correct the incorrect dogma/reasons in this draft RPMS.

4. Feral Deer (Continued) - Means of control (P 112)

NZDA’s submission is: In most cases recreational deerstalkers should be encouraged to assist WRC in deer, wild pig and possibly goat management.

Reasons for NZDA’s submission: Everything is left to WRC’s discretion in Section 11.4. This is not consultation, as no-one can respond to this. NZDA believes given the havoc WRC’s aerial 1080 operations have had on recreational deerstalking and pig hunting in the region, that WRC has a duty to work with recreational hunters to provide alternative hunting opportunities.

Decisions NZDA seeks from WRC: Engage with recreational hunters as the primary means of control of deer and wild pigs, where such control is needed. This will also reduce costs to WRC ratepayers.

5. Significant size of the recreational and commercial hunting community:

In support of NZDA’s above point 4, we set out for WRC the results of the only survey of recreational hunters in New Zealand. This was by noted deer researcher Graham Nugent.

Nugent’s 1989 research [Nugent G (1989) “Hunting in New Zealand in 1988 - Survey Results” Forest Research Institute Report for Deer industry stakeholders (NZDA, Game Industry Board, Mair Foods Ltd, Taimex Trading Co, NZ Acclimatisation Societies)]; was ground breaking.

It is the only research so far to analyse the major contribution of recreational and commercial hunting and their impact on managing wild animal populations. This in itself is an indictment on the one-track perceptions of past and current Crown managers of the wild animal resource – NZ Forest Service, and DOC.

It gives estimates of the number of hunters, total days hunted, and animals taken for 1988, based on a survey of firearms licence holders. It received 4,662 returns. A summary of Table 5 of his Report for hunters active in 1988 is presented as Table 1 below. The Table is divided into big game hunters and small game hunters, two broadly different groups.

Table 1 shows the very significant effort nationally put into deer and wild pig harvesting – 30,000 deerstalkers and 20,000 pig hunters New Zealand-wide. The ARC region has its share of such people. It also shows the significant hunting effort that hunters put in – 390,000 days/year for deerstalkers, and 300,000 days/year for pig hunters. As well, it gives the animals harvested annually – 52,000 deer, and 100,000 wild pigs. To argue that recreational harvesting is ineffective, as this RPMS does, is not supported by this survey.

The WRC should be providing for the significant number of recreational hunters in the WRC region. This is especially true as New Zealand and the world faces up to the need to halt climate change by reducing our carbon footprint. Having recreational harvesting opportunities for the population nearby reduces the need for travelling large distances to the central and eastern North Island, or the South Island to harvest wild game.

Table 1: Recreational Hunters, Effort and Take (1988 Survey)
From [Nugent G, 1989], Table 5

Species	Number of Hunters	Percent of Population	Total Days Hunted	Average Days Hunted	Animals Taken	Animals per Day	Annual Bag per Hunter
All Deer	29,739	0.92	391,713	13.2	52,481	0.13	1.8
Wild Pigs	20,506	0.62	303,738	14.8	101,653	0.33	5.0
Wild Goats	10,253	0.31	66,151	6.5	87,677	1.33	8.6
Chamois	2291	0.07	10,839	4.7	1,794	0.17	0.8
Tahr	953	0.03	3,848	4.0	782	0.20	0.8
All Big Game	42,174	1.27	776,288	18.4	240,454	0.31	5.7

Table 1 shows also the number of small game, mainly possums and rabbits, harvested in 1988. The big game recreational harvesting numbers may have not changed much. But aerial 1080 poisoning has destroyed commercial harvesting in many parts of the country.

Regional council pest destruction activities are taxpayer and ratepayer monopolies, which take out the competing recreational and commercial harvesting operators, as all monopolies do. A more competitive market for pest management would be desirable. Regional council monopolies should have to be self-funding. In the medium term poisoning strategies for pest control usually collapse under their own high costs.

6. Deer and feral pigs are valued introduced species:

It can be seen from the significant number of big game hunters (50,000 active in 1988) that big game hunting and deerstalking are important parts of New Zealand life, especially in the rural communities, and also in the cities. The large number of books dating back over 50 years, and the four current regular recreational hunting magazines attest to this.

6.1 Research shows Public values wild big game animals highly:

There is a valuable piece of independent research that confirms this. 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)? And,

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: Perceptions of introduced species as pests or resources (from Fraser 2001)

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%). Chamois, tahr, feral horses and wild pigs, in slowly reducing order, are similarly valued. Horses, tahr and chamois are less well known with a significant “Don’t know”. Rodents, wasps, feral cats, possums rabbits, mustelids and hares, in that decreasing order, are considered primarily as pests.

Figure 9: Likely reaction on seeing introduced wild animals (from Fraser 2001)

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, and with chamois and tahr scoring highly positive too.

The conclusion from Wayne Fraser’s research is that the New Zealand public sees big game animals as valued introduced species.

6.2 Deer recognised as valued recreational animals in DOC’s Legislation:

DOC’s legislation recognises deer and wild pigs as valued recreational hunting resources.

The Conservation Act defines “conservation” (S 2) as “the preservation and protection of natural and historic resources, for the purpose of maintaining their intrinsic values, providing for their appreciation and recreational enjoyment by the public, and safeguarding the options of future generations”.

The functions of the department include “(a) to manage for conservation purposes all land, and all other natural and historic resources, for the time being held under this Act – “

And “(e) To the extent that the use of any natural or historic resource for recreation or tourism is not inconsistent with its conservation, to foster the use of natural and historic resources for recreation and to allow their use for tourism”

Introduced deer and wild pigs are “natural resources” under the Act. So DOC has an obligation to conserve them ie preserve and protect them to maintain their intrinsic value, and provide for their appreciation and recreational enjoyment by the public, and safeguard the options for future generations.

Though DOC talks much about “pests”, the Conservation, National Parks and Reserves Acts do not use the term. “Pests” is a term used only in the Biosecurity Act, a Ministry of Agriculture and Forestry act.

The Wild Animals Control (WAC) Act is a DOC Act that manages many of the animals the Biosecurity Act considers as “pests”. Wild animals include deer, chamois, tahr, wallabies, possums, wild goats, wild pigs.

The WAC Act applies to all land, having regard to the provisions of any Act applying to the land, “and shall be for the purposes of controlling wild animals generally, and of eradicating wild animals locally where necessary and practicable, as dictated by proper land use.” (S 4, (1)).

Section 9 of the WAC Act states “All wild animals shall be the property of the Crown”, provided that when lawfully taken, or killed or held, then they shall be deemed to be the property of the person who has lawfully taken or killed or held them.

6.3 Recreationally Valued wild animals - Conclusion:

Consequently the Wayne Fraser research shows deer and pigs are not normally viewed as pests, but as valued species. There are many more animals that rank more highly as pests than deer and pigs. NZDA proposes WRC put more effort into the species New Zealanders really worry about, eg wasps, rats mustelids, rabbits etc.

It seems to NZDA that this WRC “crusade” against valued big game animals is against both the desires of the majority of Waikato citizens, and against the interests of Waikato Region ratepayers.

7 Section 6.6 Feral Pigs (page 115):

NZDA’s submission is: Similar to NZDA’s concerns for wild deer. NZDA notes the Nugent survey showing the harvest of wild pigs at 100,000/year, a major contribution to the community’s wild food harvest, and a significant benefit to the community. Wild pigs are not a pest.

Reasons for NZDA’s submission: As well NZDA notes that in the previous 2002-2007 RPMS that wild pigs were not a pest. No reasons for this change are provided in the draft RPMS. If there is no evidence of increased wild pig numbers, or of increased pig damage, then NZDA strongly opposes this change, because of the very large wild food harvest that wild pigs provide, and proposes that wild pigs be dropped as a pest.

Decisions NZDA seeks from WRC: Remove wild pigs from the “pest animal” category.

8 Lack of a Benefit Cost Assessment, as required by S 72 Biosecurity Act:

NZDA’s submission is: This lack makes it impossible for the public to assess the options and alternatives for control. This is an important component for NZDA, as we wish to see recreational hunters playing a major role in any required control of wild deer and pigs, as discussed above. It is the responsibility of WRC to provide an assessment of its preferred alternative, and compare it with other alternatives.

WRC staff, David Stephens and John Simmons made separate trips to Wellington to talk to NZDA about this draft RPMS. Both assured us that the Benefit-Cost assessment would be made for deer and pigs. It has not been. NZDA considers such an approach by WRC staff as unacceptable.

Under S 72 (1) (a) and (b) of the Biosecurity Act such a CBA should be in the document, or at least publicly available. Otherwise there is no proof the regional council has acted correctly. No CBA has not been made available to us, or the public for any species we are aware of.

Decisions NZDA seeks from WRC: NZDA considers this a breach of the requirements of S 72, and asks that the RPMS be rectified, and the public consultation be undertaken again.

9 RPMS Budget doubling in 5 years is opposed: NZDA’s submission is: because there is no substantiation of any major pest threats in the RPMS, including, the unnecessary and inappropriate addition of deer and wild pigs to the animal pest category, NZDA opposes any increase. The threat has dropped because bovine Tb is under control, and expenditure is expected to decrease. NZDA sees this as a cynical attempt by WRC staff to empire build.

Decision NZDA seeks from WRC: Reduce WRC’s Biosecurity budget.

10 Adverse effects of pest management on harvesting deer and feral pig meat:

Deer and feral pigs provide recreational enjoyment and meat for the table for many of the region’s citizens. These species should be recognised as a community and recreation asset in the RPMS, just as farmed deer and pigs are.

Decision NZDA seeks from WRC: Ground control and bait stations should be used to protect deer and feral pigs in poisoning operations in valued recreational hunting areas. If indiscriminate aerial poisoning is used, animal repellents to protect deer and pigs should be used, to reduce by-kill. However, when aerial poisons are used, NZDA is concerned at the required 6-9 month health stand-downs, that disrupt recreational hunting and food harvesting. The recreational hunting value of deer and feral pigs in the Waikato region is significant, and should be recognised in this RPMS, by employing pest control measures that do not interfere with recreational harvesting of wild meat.

NZDA is also very concerned at build-up of anti-coagulants in feral pigs. This poisons the pig meat, and means that pig hunters will not hunt such pigs, so making the region poorer, and increasing the number of feral pigs. The NZ Food Safety Authority has expressed concern about this very adverse effect. It makes a mockery of New Zealand’s claim to be “100% Pure”.

Decision NZDA seeks from WRC: Avoid using anti-coagulant poisons in areas where feral pigs are harvested.

11 Non-response to NZDA’s request for extension of time for RPMS submissions:

NZDA wrote to the Chair of WRC about the short time for submissions – 23 days, including 2 days for draft in mail transit. I personally followed up this letter with phone calls, none of which were replied to. The submission period also coincided with the deer “Roar”, when most active deerstalkers are away in the hills. I am still waiting for a reply. I attach a copy of NZDA’s letter to this submission.

This arrogant behaviour by WRC is unacceptable.

NZDA requests to be heard in support of our submission.

Hugh Barr, National Advocate