Submission date: 26 May 2016
Submitted to: Ministry for the Environment
The Department of Conservation (DOC) and other agencies, such as regional councils and OSPRI, are dependent upon a range of vertebrate toxic agents (VTAs) in their work to control mammal pests, including predators, which threaten our wildlife, and possums, which decimate our forests. The most important of those VTAs are currently 1080 and brodifacoum – but new tools are under development.
The current complexity of the regulatory framework for pest control is an unneccessary barrier to the successful use of VTAs in operations by DOC and other key agencies. With another huge beech mast across many parts of the country, especially the north and west coast of the South Island, DOC are looking to apply 1080 across large areas of public conservation land in order to combat the expected explosion in numbers of mammalian predators. Many of these operations cross local government boundaries, so it is important that conditions are common on the various consents that they require.
The New Zealand Conservation Authority (NZCA) strongly supports the proposal to use a section 360(1)(h) regulation to simplify the regulatory framework for pest control.
We agree that it should include any VTA that has been through a either a full or rapid assessment under the HSNO Act 1996, subject to the requirements set out in the consultation document.
One additional issue that we raise is the need to standardise the conditions/requirements of the Medical Officers of Health, to ensure that, where projects cross the boundaries of different District Health Boards, there is a corresponding similarity of conditions.
The New Zealand Conservation Authority is established by the Conservation Act 1987, with members appointed by the Minister of Conservation. It has a range of functions, but primarily acts as an independent conservation advisor to the Minister and the Director-General. The Authority’s role has, in the past, been seen to be largely as a strategic advisor, but it has a growing role as an objective advocate on matters of national significance and interest in the conservation arena and, more recently, as a “board” to provide high quality independent advice to the Department of Conservation on its strategic direction and performance.
In consultation with the Minister of Maori Affairs:
In consultation with the Minister of Tourism:
In consultation with the Minister of Local Government:
On the nomination of Te Runanga o Ngai Tahu:
On the recommendation of Royal Forest and Bird Protection Society of New Zealand:
On the recommendation of Federated Mountain Clubs of New Zealand:
On the recommendation of the Royal Society of New Zealand:
From public nominations: