To: Director-General of Conservation
Date: 17 October 2011
Thank you for your letter of 19 September 2011 concerning heli-hunting or aerially-assisted trophy hunting.
You attached one of the applications for a long-term aerially-assisted trophy hunting concession, the provisional report on the 2011 season to 8 August 2011, and notes of a meeting held on 13 September 2011 with a range of interests for the Authority’s consideration.
You requested any feedback by 17 October 2011.
The Authority has since sought the final report on the 2011 season to inform its consideration and advice to you but this has not been available.
The Authority has consistently
- upheld the provisions of the statutory planning documents as the ‘handshake’ with the community which needs to be honoured when considering commercial use of public conservation resources; including aircraft or other motorised-assisted recreational use;
- sought to satisfy itself that the statutory planning documents it approves give effect to relevant legislation (with legal advice obtained as necessary);
- requested evidence that aerially-assisted trophy hunting contributes to the control of harmful species of introduced wild animals and the means of regulating the operations of recreational and commercial hunters, including wild animal recovery hunting using aircraft, so as to achieve concerted action and effective wild animal control (WAC Act);
- objected to this recreational activity being given rights of aircraft access not provided to other recreational users;
- upheld the range of recreational settings1 concept under which public conservation land has been managed for since 1990 and which is embedded in the statements of general policy, meaning that a few areas are kept free of aircraft access for recreation-related purposes, others have a low level of such access, and yet others have higher levels of aircraft access;
- objected to long-term concessions being granted in ignorance of the effects of the activity, an absence of policy and planning for the activity, and without public consultation.
The Authority has seen nothing in the papers sent to it now which changes its views.
This is because –
- There continues to be a lack of robust information upon which to give informed advice and make an informed decision on effects of aerially-assisted trophy hunting and its effectiveness as a wild animal control mechanism;
- Formal policy development and planning for the activity through the reviews of conservation management strategies and national park management plans should be undertaken before long-term concessions are granted;
- Proposals for long-term concessions should be publicly notified to ensure that any identified effects or the extent of those effects can be tested through a public consultation process.
If the decision-maker decides to issue multi-year permits, not withstanding the Authority’s advice, the Authority considers they should be no longer than three years during which time further information should be gathered on effects to be considered in long-term decision-making.
In addition, the Authority expects that –
- the specific provisions relating to aerially-assisted trophy hunting in the Fiordland and Mt Aspiring National Park Management Plans will be given due weight by the decision-maker;
- specific provisions will be imposed to ensure that aerially-assisted trophy hunting concessionaires genuinely contribute to concerted action and effective wild animal control at priority sites for the Department;
- non-performance of such specific requirements will lead to forfeiture of the permit;
- the restriction on the Department from culling bull tahr when it is doing its end of season cull will be lifted;
- aerially-assisted trophy hunting concessionaires will required to report the size and location of mobs of tahr seen to facilitate DOC culls;
- consideration will be given to requiring a specific control activity in association with all aerially-assisted trophy hunting on public conservation land; not only national parks and wilderness areas2.
With regard to specific places, the Authority has decided not to provide comments.
The Authority agrees with the Department that, with regard to any authorised activity under the Wild Animal Control Act, “the bottom line is the achievement of a satisfactory level of control to protect natural values”3.
1 Based on the Recreational Opportunities Spectrum; reflected in the DOC Visitor Strategy and the two statements of general policy. In essence front country, back country, remote, and wilderness; each with different standards and managed for different interests and capabilities.
2 Such control activities might include sponsorship of Judas tahr in areas of low tahr density and on the margins of the tahr feral range to prevent the spread of tahr beyond the current feral range.
3 Page 20 2011 report to the decision-maker.