Submission date: 10 June 2010
Submitted to: Ministry of Agriculture and Forestry Biosecurity
The New Zealand Conservation Authority (Authority) is a statutory body established by section 6A of the Conservation Act 1987. Members are appointed by the Minister of Conservation on the nomination or recommendation of four specified bodies (four members), after consultation with three specified Ministers of the Crown (five members), and after the receipt of public nominations (four members). This process ensures that a wide range of perspectives contribute to the advice provided and decisions made by the Authority. The functions of the Authority are centred on policy and planning which impacts on the administration of conservation areas managed by the Department of Conservation, and the investigation of any conservation matter it considers is of national importance. The Authority has the authority to advocate its interests at any public forum and in any statutory planning process.
The Authority has long considered biosecurity to be of major importance for the conservation of New Zealand’s biodiversity, and marine biosecurity in particular, to be a national priority.
Risk analysis of vessel biofouling
Question 1: Do the ongoing risks posed by vessel biofouling to New Zealand’s economic, environmental, and social and cultural values justify MAFBNZ taking a preventative approach to controlling and managing biofouling on arriving vessels?
The Authority agrees that the risks to New Zealand’s indigenous marine ecosystems from biofouling is high and ongoing. The high degree of endemism, and the incursions to date give weight to a pro-active and precautionary approach to the introduction of exotic species to our marine environment.
Options for New Zealand
Question 2: Three options for managing the biosecurity risk from biofouling on vessels arriving in New Zealand have been considered by MAFBNZ. Are there any other options that could be considered?
The Authority does not have any further options to advance.
Question 3: The option of implementing mandatory requirements for biofouling on vessels arriving in New Zealand, by way of an Import Health Standard made under the Biosecurity Act, is considered by MAFBNZ to deliver the highest overall net benefit for New Zealand. Do you agree or disagree, and why?
The Authority agrees with the option proposed by MAF BNZ for the reasons given in the Consultation paper and as outlined in response to Question 1 and has no further comment regarding the implementation.
Other Comment
The Authority commends MAFBNZ for being proactive in this matter, and suggest you continue to push for international agreement.