To: Hon Kate Wilkinson, Associate Minister of Conservation
Date: 21 December 2009
1. One of the statutory functions of the New Zealand Conservation Authority is to advise you on matters of national conservation importance.1 I am writing to inform you of the Authority’s concern over the proposal being advanced by the Game Animal Council Establishment Committee in its options paper released last September. The Authority is particularly concerned about the effects of the proposal on indigenous biodiversity, process, about matters of governance, and public interest. The Authority suggests some other options you may wish to consider that balance recreational hunting with the wider public interest.
2. The Authority recommends that you further clarify the role and status of any proposed Game Animal Council (GAC). The Authority suggests, that if a GAC is considered necessary, the role should be limited to co-ordination, education and advice. Such a body may be more appropriate as a non-governmental organisation rather than a statutory body. Should statutory status be considered necessary, this should be as an advisory committee under section 29 of the WACA.
3. Deer stalking and other recreational hunting on foot is a long standing activity in New Zealand and the NZCA supports efforts to encourage such recreational hunting; especially where there are benefits to native species and ecosystem health. The NZCA recognises that wild animals such as deer, chamois, tahr and pigs have serious adverse impacts on indigenous vegetation. Conservation General Policy2 is explicit that where there are conflicts between indigenous biodiversity values and the hunting of wild animals, biodiversity takes priority.
4. The NZCA considers that hunting should be facilitated in all practicable ways as a means for minimising or mitigating the adverse impacts of wild animals; freely available hunting is one way of managing these animals and should be fostered at little or no cost to hunters, as at present. Splitting the mandate for game animal hunting among interest groups with conflicting (game management and conservation) objectives seems unwise.
5. The NZCA is concerned that a GAC will advocate for wild animal populations to be managed for the benefit of hunters, for sustainable harvest, or the improvement of animal quality, rather than for the benefits of conservation. The NZCA accepts the need for coordinated activity amongst the spectrum of recreational and commercial hunting interests, but is opposed to handing over management of game animals to a GAC as proposed. This is because a special interest group is unlikely to make balanced decisions which could favour other interests over their own. Management of big game animals should remain with the Department of Conservation.
6. Public consultation on the proposal to establish a GAC has been seriously inadequate.
7. A strongly pro-hunting perspective prevails in the discussion document, which seems to be asserting a role beyond that envisaged in your terms of reference. There are alternative points of view and options that need to be considered.
8. Research and past experience show that the level of recreational, and even commercial, hunting of game animals provides inadequate protection for indigenous vegetation.
9. The NZCA notes that the discussion document omits reference to wild pigs although they were included in the 2008 report of the Ministerial Advisory Committee.
10. The Discussion Document anticipates a transfer of funding from the department’s budget, and at a public meeting this was identified as $1 million. The Authority strongly opposes such a transfer.
11. The Authority believes that alternative options available to you as Minister are
- To seek a comprehensive assessment of all options for game animal management in New Zealand following the standards expected by Cabinet in Regulatory Impact Statements for new legislation and regulations;
- To ask the Department of Conservation for a report on recreational hunting areas (RHAs) and options on their purpose and management;
- To instead set up a committee under Wild Animal Control Act3 to work with the Department’s National Hunting Advisor on improvements to the recreational hunting experience generally;
- To assist the taking of these animals legally, meanwhile discouraging the illegal release of them, thereby enhancing the contribution recreational hunting makes to wild animal control.
12. The Authority would appreciate the opportunity to discuss this topic with you in person.
New Zealand Conservation Authority
1 Section 6B(1)(d) Conservation Act 1987
2 Chapter 4
3 Section 29 Wild Animal Control Act National Recreational Hunting Advisory Committee