New Zealand Deerstalkers’ Association Incorporated (NZDA) makes the following submission on GW’s RPMS. NZDA is the national body of recreational deerstalkers and other big game hunters. We have 52 branches and 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.
NZDA maintains the ethical side of hunting by maintaining ethics for hunting, including fair chase, and encouraging harvesting of animals taken for food. We make this submission on behalf of our members, and in the interest of other deerstalkers and pig hunters generally, especially those in the Greater Wellington Regional Council (GW) region.
NZDA requests to be heard in support of this submission.
Remove the Pest status of Deer and Wild Pigs:
NZDA’s concern is that, for the first time, GW has chosen to add the big game species deer and wild pigs as “Site-led pests for Biodiversity”. NZDA asks that they be removed from this category, and placed in the list of “Species identified by KNE management”.
We note that ferrets, Norway rats, ship rats and stoats are not listed as “pests” in the RPMS, though they are far greater threats to native bird species than deer and wild pigs. If these real and major pests are not listed as “Pests” in the Strategy, NZDA sees no reason why the lesser threats from deer and wild pigs need to be classified as “”Site-led pests”.
Facilitate Recreational Hunting on GW lands:
NZDA proposes that GW continue to facilitate recreational hunting of deer, wild pigs and goats in its own regional parks and forests. NZDA also considers GW should co-operate with NZDA Branches in the Region, in control of these game animals on other lands. The Department of Conservation (DOC) has a policy of encouraging recreational hunting on its land because of the increased harvest of big game animals that results from this.
It may also be a way to improve the strained relationship of recreational hunters with GW. This has resulted from the aggressive aerial 1080 drops GW has performed in the past on nationally important recreational hunting areas in the region, eg Aorangi Forest Park, as the manager of AHB programmes.
NZDA specific concerns with GW’s proposed RPMS:
1 Deer and feral pigs are not pests and are not at harmful densities:
NZDA strongly opposes (wild) deer and feral pigs being considered as animal pests, because of their recreational value, and because they have co-existed with regional ecosystems for over 200 years in the case of wild pigs, and for 150 years in the case of Red deer.
Deer numbers in the GW region are generally low (less than 10 deer/sq km), being controlled primarily by recreational and commercial hunters, and by massive dosing with aerial 1080 by GW and DOC. At this low density their browse is usually insignificant. Any damage that deer do to native ecosystems has been significantly reduced since commercial helicopter recovery reduced their numbers in the region significantly in the late 1960s. For the last 40 years deer have been at low densities in the region.
2 By not recognising the resource value of deer/pigs GW is not acting sustainably:
Because GW considers deer and wild pigs solely as pests, and does not acknowledge the significant community benefit in terms of wild food and recreational hunting that these animals provide, it sets up a conflict with those that see them as important recreational and food resources that is quite un-necessary. NZDA wants to see the resource value of deer and wild pigs acknowledged, as they should be if GW wants to make the region truly sustainable.
3 Deer and feral pigs are valued recreational and wild food species: These two animal species provide recreational enjoyment and meat for the table for many of the region’s citizens. They should be recognised as a community and recreation asset in the RPMS, just as farmed deer and pigs are recognised as a commercial asset. Ground control and bait stations should be used to protect them in poisoning operations in valued recreational hunting areas. When aerial poisons are used, NZDA is concerned at 6-9 month health stand-downs that disrupt recreational hunting and food harvesting. The recreational hunting value of deer and feral pigs in the GW region is significant, and should be recognised in this RPMS. Working with recreational hunters can also help reduce the rates cost of the RPMS.
4 Inadequate information provided for public consultation:
There is minimal information provided in this RPMS on which to judge the need or effectiveness of listing deer and wild pigs as Site-led pests. Without adequate information the ratepayers and public have no way of knowing if the GW proposals are justified or not. The fact they are not provided points to the fact the case may be weak.
a) KNEs not listed:
There is no discussion of where the Key Native Ecosystems (KNEs) are, or who manages them, and for what purpose. GW is not responsible for pest management on public conservation land. This makes up the major part of land protected for recreation and conservation, namely the three forest parks, Tararua (119,000 Ha, but part in Horizons region), Rimutaka (20,000 Ha), Aorangi (19,400 Ha). The next largest area is GW’s own holdings for regional forests and regional parks (c 50,000 Ha).
NZDA proposes: GW lists the KNEs in the region, and their areas and managers, so ratepayers know the size of the area GW intends to protect, and who is benefiting at the ratepayer’s expense.
b) No information provided on the threat posed by deer and wild pigs to KNEs:
It is best practice in native ecosystem management to consider the species at risk, what the threats are to them, and how these threats can be measured and reduced cost-effectively. Most regional councils do not appear to use this best practice approach. Judging by this RPMS, and its lack of specific information, GW is one of them. Without this quantitative management approach, pest management often degenerates into empire building, as has happened recently at Environment Waikato. Their RPMS last year was similarly devoid of hard management data.
Other methods than declaring species as pests can also be considered eg deer and pig-proof fencing around key areas. The KNEs are not listed, nor are the species they are specifically trying to protect. Without this information the Public cannot understand why GW has arbitrarily decided that deer and pigs have suddenly become pests. Is it just for empire building reasons, as with Environment Waikato, in its recent RPMS?
As well, Page 146 of the RPMS lists ferrets, house mice, Norway rat, ship rat and stoat as specific species to be considered as “pests” with regard to KNEs. These pests would all rank as far greater threats to native species than deer or pigs. GW should not have chosen to make deer and pigs as Site led pests, when these other far bigger threats are not included.
NZDA Proposes: Deer and wild pigs be removed from being site-led pests and instead be listed “Species identified by KNE management.
c) No S 72 justification for GW making deer, goats or wild pigs into pests:
Though these three species are “new additions” to the proposed RPMS, there is no discussion of why they have qualified as site-led pests in terms of S 72 of the Biosecurity Act, or what alternative management methods were considered.
One would expect that the KNE areas, primarily maintained by unpaid volunteers, would be much more cost-effective doing control on these three species themselves, than having the large and expensive GW bureaucracy do it for them. As well, there are large numbers of recreational hunter clubs and individuals in the region who may be available to assist KNE managers in reducing the numbers of these animals where the KNE management considers the numbers are too high.
NZDA Proposes: GW list and summarise the reasons why deer and wild pigs met the S 72 pest and CBA requirements. Then ratepayers would have ready access to GW’s arguments as to why they qualify, when ferrets, stoats, and rats don’t. Having 100 page documents purporting to do this is probably evidence of obfuscation, and the weakness of the case.
5 New Section 14.2 Reserves and Forest Health Management including GW’s Regional Parks and Forests:
This addition relates to GW’s own regional parks and forests, some of which are considered as KNEs, and to other local body reserves where GW is asked to assist.
NZDA requests: GW continue to encourage recreational hunting in its regional parks and forests, and not sideline the legitimate and time-honoured recreation of deer and pig hunting. There should be ratepayer dollar savings and social benefits from this.
Recreational pig and deer hunting is allowed on a limited ballot basis in East Harbour Regional Park. Hunters can obtain deerstalking and pig-hunting permits for Regional Forests, though some areas of Reserve in the Wairarapa are not available. There is also a balloted hunt allowed in the Wainuiomata Water Supply area, annually, usually after GW paid professional hunters have shot the place out. NZDA believes that if GW is serious about a sustainable region, then GW would encourage these recreational hunting activities on its own parklands.
There are a large number of recreational deerstalkers who live in the GW region. These include the following NZDA Branches:
Wellington Branch (Wellington City), Hutt Valley Branch (Upper Hutt), Porirua Branch, Wairarapa Branch, Kapiti Branch. The membership of these branches is over 1000 hunters. There are also many independent hunters who live in the region. Manawatu and Bush (Paihiatua) Branch hunters can also hunt in the Region.
A national survey carried out by noted Landcare Research’s deer ecologist Graham Nugent in
1988 showed there were some 60,000 active deerstalkers and pig hunters in New Zealand. These numbers are likely to be similar today. Table 1 below shows the estimated numbers, based on a survey of firearms owners:
GW should be helping provide opportunities for the 6,000 recreational hunters in the GW region, (based pro rata on the national figures). This is especially the case as New Zealand and the world faces up to the need to halt climate change by reducing our carbon footprint. Recreational harvesting opportunities for the population nearby reduces the need for travelling large distances to the central North Island, or the South Island to hunt and harvest big game. Also harvesting the game is far better sustainability-wise than killing or poisoning it to waste.
Table 1 also shows also the significant number of small game, mainly possums and rabbits, harvested in 1988.
Regional council pest destruction activities are ratepayer funded Council monopolies. They are often aimed at taking out the competing recreational and commercial harvesting operators, as all monopolies do. A more competitive market for pest management is desirable. Regional council monopolies should have to be self-funding. In the medium term poisoning strategies for pest control often collapse under their own high costs, and sometimes by ratepayer revolts, as happened in last year’s elections at Environment Waikato.
6 Deer and Wild pigs viewed by the public as a valued resource:
6.1 Research shows Public values wild big game animals highly:
A piece of independent research confirms that the public value deer and pigs as a resource rather than see them as pests. 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)?
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%). Wild pigs (pest 20%, both 45%, resource 32%) are similarly valued. 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. Wild pigs are about 50:50.
The conclusion from Wayne Fraser’s research is that the New Zealand public sees deer especially as valued introduced species.
6.2 Ministerial Game Animal Panel Public Responses:
This Panel has recently reported to the Minister of Conservation, on managing deer, chamois, tahr and wild pigs. There was a very large response from the public, showing the importance of the issue. Some 4,000 submitters answered the questionnaire. This is three times the 1300 who made submissions on the 1080 review in 2007, and the similar number who submitted on the Acland Public Access Review in 2006, two other high-interest issues.
A key question asked whether the submitter saw these animals as primarily a resource or primarily as pests. The submitters favoured these animals being primarily a resource by four to one, 3,200 to less than 800.
It is difficult to see these animals as a high threat to native bird species, compared with rats, cats ferrets, stoats, and wasps, all of which predate specifically on, and compete with, native birds and insects.
7 Comments on deer as pests (pages 130-31):
The RPMS text makes no reference to the population density of the deer making a significant effect on the adverse effects of deer browse. If deer density is low, and if they have access to pasture, which they prefer, then browsing pressure on native species will be low, and there is little adverse impact on regeneration of native species. See for example “A hydrologist’s contribution to the debate on wild animal management” Patrick J Grant, NZ J of Ecology, V 12, p 165-9 which shows erosion and flooding are due to significant shifts in climate eg heavy rainfalls, or droughts, not deer browse.
Though it may be possible that “Feral deer contribute to soil erosion through intensive browsing”, The quoted paper makes the point that weather effects such as major floods, such as those in February 2004 in the Wairarapa and Manawatu-Wanganui, or droughts, have a much larger effect.
Also, re damage to native forests by deer, the paper “Episodic forest mortality in the Kaimai Ranges, North Island New Zealand” by G T Jane and T G A Green, P 21-31, NZ J of Botany 1983 V 21, shows that ”Investigations of the upland vegetation of the Kaimai Ranges showed widespread tree mortality. However this was not caused by browsing by introduced mammals, but is linked to two severe droughts that occurred in 1914 and 1946.” Similar results have been obtained for the Ruahine Ranges, and probably also in other forest areas.
It is now widely recognised that deer are not major contributors to soil erosion and flooding.
NZDA agrees with the conclusion that owners should be much better at controlling deer and pigs on their KNE areas, than GW.
Nowhere in the RPMS is any evidence provided to show that deer numbers in any part of the region are high enough to justify them being a “pest”. Statements such as “Intensive browsing can devastate the forest under-storey and strip bark from trees, severely impacting in plant diversity” is irrelevant scare-mongering, if there is no likelihood of it happening.
8 Wild pigs as pests (pages 134-35):
It is hard to believe that wild pigs, having been in the region probably since the 18th century (for over 200 years), and given that pig numbers peaked in the late nineteenth century, that pig damage “pose a serious threat to biodiversity by eating seedlings and root systems, native insects and ground-nesting birds, and their young” etc. I
f so then such species would have been wiped out. They have not been. There is no evidence supplied in the RPMS to show that wild pig numbers in the Region are high or increasing. Much of the text is GW staff scaremongering, without data. NZDA’s understanding is that recreational pig hunters in the region control pig numbers.
9 GW Cost Benefit Analysis (CBA) for Deer, Goats, feral pigs:
Comments on GW’s Dost-Benefit Analysis for Deer, Goats, feral pigs:
No calculations are shown for the Cost-Benefit Analysis, unlike with pest plants. Why are similar calculations not supplied for these three animals? NZDA notes on Page 85 of the CBA ”It is GW’s opinion that the benefits of a KNE RPMS outweigh the costs –“
This is not the result of a CBA, but simply the opinion of staff. The Biosecurity Act S 72, requires a calculation, not an opinion by an agency with a significant conflict of interest.
Errors in the Statements:
1 The Wild Animal Control (WAC) Act does not make these animals “pests”. They are defined by the Act as “Wild animals”. The word “pest” is not used in the WAC Act. Deer, goats, pigs are not listed as pests under the Wild Animal Control Act as pests, as stated.
2 ”Reproduction is low with most female deer (hinds) producing one fawn a season.” Not true. Even with farmed hinds of fawn-bearing age (2-10 years) such hinds only wean 80% of fawns. In a much harsher mountain forest environment, the weaning rate is probably nearer 50%.
3 There is no mention that recreational hunters can keep deer, goats, wild pig numbers down in the region. There are significant numbers of them, as discussed. Nowhere is the option of GW working with NZDA Branches or other recreational hunters to control numbers. This is an option that is cost-effective, and should be considered.
4 Goats are not “widespread in most suitable habitats.” As claimed. They are primarily around where they were farmed in the 1980s.
5 At least with plants figures and a benefit are given, even if they are grossly inflated. With these animals the CBA is all scaremongering, errors and opinion by an agency with a major conflict of interest.
1 Deer and wild pigs be removed from the Site-led pest category (Biodiversity), and placed in the list of “Species identified by KNE management”.
2 GW continue to facilitate recreational hunting of deer, wild pigs and goats in its own regional parks and forests, and involve NZDA Branches where possible, where they are interested, in recreational hunting to harvest deer, wild pigs and goats.
3 GW acknowledge in the RPMS that deer and wild pigs are a valued wild food and recreational resources for many of the region’s citizens. Using this resource is a way to make the region more sustainable.
4 GW provide more quantitative information in the RPMS, eg on KNEs, areas of threat, etc, to better inform the Region’s public as to the size of various threats, and how it intends to deal with them cost-effectively
5 Comment on the Cost-Benefit Analysis (CBA) and definition of deer/pigs as pests – to come, extension of time granted.
NZDA wishes to be heard in support of this submission.
Dr Hugh Barr