The Legislative Basis for the New Zealand Conservation Authority’s submission
The New Zealand Conservation Authority / Te Pou Atawhai Taiao o Aotearoa (Authority, NZCA) was established under the Conservation Act 1987 (Act), with members appointed by the Minister of Conservation. It is an independent statutory body with a range of functions, but primarily acts as an independent conservation advisor to the Minister and the Director-General of Conservation.
The Authority has a role as an objective advocate on matters of national significance and interest in the conservation arena, and provides high-quality, independent advice to the Department of Conservation (Department, DOC) on its strategic direction and performance.
The Authority has a range of powers and functions under the Act, as well as under other conservation-related legislation. Under section 6C(2)(c) of the Act, the Authority has the power to “advocate the interests of the Authority at any public forum or in any statutory planning process.”
Following the logic of the above powers and functions, the Authority submits on the Draft Herd Management Plans for Fiordland Wapiti and Sika Herds of Special Interest.
NZCA Submission
The Authority’s submission is based on its analysis of:
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- Fiordland Wapiti Herd of Special Interest Draft Herd Management Plan, and the accompanying Consultation Support Document, and
- Sika Herd of Special Interest Draft Herd Management Plan, and the accompanying Consultation Support Document.
Overarching matters
Noting there are commonalities between the two Herd Management Plans (HMP), the Authority provides the following general observations, insights, and comments.
Overall Objectives
The Authority believes that there should be two clear outcomes that derive from the HMPs – preservation of biodiversity and the benefits to conservation should be highlighted as a priority along with ‘enhancing the hunters experience’. At present the outcomes are more strongly skewed to the hunting aspect, but they should be more purposeful on conservation outcomes and better reflect the hunters’ contribution to conservation efforts (which the Authority recognises).
Funding models
Currently the Wapiti Area is managed by the Fiordland Wapiti Foundation who, since 2005, have established a strong funding model that enables them to undertake widescale conservation efforts – both within the Wapiti Area, and wider across Fiordland National Park.
The Authority is concerned that because DOC is not able to charge for hunting permits on public conservation land, including the area of the Sika Herd of Special Interest (HOSI), widescale ecological management, necessary for both forest regeneration and better conditioned sika deer, will only occur if there is direct funding for the work.
The development of National Parks and why they are important
In 1887 Paramount Chief Horonuku Te Heuheu made an agreement that the Central North Island volcanoes would become a national park, which occurred in 1894. In the early 1900’s red deer were released to control introduced lupins sown on Tongariro for beauty purposes. Around the same time wapiti were released into Fiordland for hunting sport, and goats were present on Taranaki maunga.
Reaction to this promoted the idea National Parks should protect NZ species.
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- Growth in conservation focus
Conservation issues were not a high priority in New Zealand in the first part of the 20th century, with two world wars and depression, most people were concerned with financial security, extraction rather than protection pervaded, the post WWII period saw economic growth and an outdoor recreation boom prompting conservationists to lobby for more National Parks.
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- Separation of decision-making
This generated decades of public and political discourse that resulted in the separation of decision-making structures to address the former dilemma of balancing conservation against development to achieve greater accountability and effectiveness.
This saw a shift from managing forests for timber to preserving trees, the Department of Conservation was formed bringing under one department functions formerly managed by several government departments, e.g. Forestry Department, Lands & Survey and the Wildlife Service.
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- National Park Act 1952
The National Park Act 1952 set up the National Park Authority and National Park Boards to provide guidance and policy, the Act emphasised that native plants & animals would be preserved, introduced species controlled or exterminated. The National Park Authority was strongly aligned to the departments of land, forestry and tourism with NGO representation, i.e. Forest & Bird, Federated Mountain Clubs, and the Royal Society of NZ.
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- National Park Act 1980
The 1960’s debate over raising Lake Manapouri in Fiordland National Park the conservation topic became public for the first time. The National Park Act 1980 addressed some scientific and conservation concerns and added ecological systems to the list of features that merit National Park status.
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- The Conservation Act 1987
The Conservation Act 1987 was created to promote the conservation of NZ’s natural and historic resources and includes the National Parks Act 1980 in its schedules. Section 4 of the Conservation Act states it must be so interpreted and administered as to give effect to the principles of the Treaty of Waitangi (Section 4).
In 1990, the National Park Authority and Park Boards were disestablished and the New Zealand Conservation Authority and Conservation Boards were established. Public right of access to national parks balanced with the need to protect plants, animals and natural features, with restrictions on buildings, roads, signs, vehicles, boat and air traffic.
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- 1952 - 5 national parks (Tongariro, Mt Egmont, Fiordland, Arthurs Pass and Abel Tasman)
- 1965 - 10 national parks
- 2025 - 13 national Parks (3 in NI, 10 in SI). (Urewera delisted 2014)
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Role of the Conservation Authority
The role of the Conservation Authority is to oversee the implementation of the National Parks Act 1980. The Authority oversaw the development of the General Policy for National Parks in 2005 and approves National Park Management Plans as and when the Department produces them.
The only references to the Authority, in either of the HMPs, are regarding the Conservation Boards’ function to advise the Authority on conservation matters and a footnote for the General Policy for National Parks.
Risks and mitigations
Neither of the HMPs contain a section covering risks and mitigations, or measures for the objectives, to enable assessment of their viability or success.
Consideration of alternatives
Alternatives are not presented for addressing the identified issues, managing HOSI, or means of achieving the objectives.
Although the need for herd reduction is explained, and methods of herd reduction and control are described, why establishing HOSI is the preferred approach is not covered. There is no discussion or weighing up of alternatives, such as increasing funding and resources for existing measures with proven effectiveness.
Monitoring and reporting
Herd control assessments are referred to in the documents, but findings are not included to indicate whether the objective of creating a HOSI is achievable or affordable, or by whom, or what impact it would have on current control methods.
Although the HMPs talk to the importance of monitoring, research, and reporting in herd management, there is no suggestion of who would carry out the work, with what budget or oversight, and what actions would follow the reporting. For example, if analysis found the objectives of HOSI (to sustainably restore biodiversity and improve herd quality) were not achieved or achievable, what processes for reviewing or revoking HOSI exist?
Fiordland Wapiti HOSI draft herd management plan
Achievability of HOSI management, based on proposal
It appears the level of herd reduction, aspired to for successful implementation of HOSI, will not be possible through only hunting efforts. The Game Animal Council has been outspoken in its opposition to other methods of control, especially poisons, maybe raising questions about how it would meet the requirements of the HMP, if given a delegation to manage HOSI.
“An objective of the Fiordland National Park Management Plan 2007 (FNPMP) is to reduce, and control introduced animals (including Fiordland wapiti) by all available means to a level that allows for the regeneration of browsed indigenous flora” (p8).
The HMP also notes “While extensive commercial venison recovery significantly reduced deer numbers in the 1970s to 1990s, market conditions have been increasingly unfavourable for commercial operations since then”.
Reflection of conservation objectives
Despite having an objective to restore biodiversity, the HOSI programmes do not amount to intensive management, and the HMPs do not address this issue, as they are not drafted as long-term, adaptive plans (beyond a 5-year review). “Research indicates that regeneration is possible with intensive management, but this is generally slow” (p7).
The plan appears to rely on “hunters adopting a conservation mindset when hunting” when laying out how the HOSI management approach is intended to work:
“Adoption of the Fiordland Wapiti Herd of Special Interest management approach is intended to encourage collective and concerted action for Fiordland wapiti management and the conservation of indigenous flora and fauna in the Wapiti Area. It seeks to do this by recognising and providing for a range of values, conservation outcomes, communities and recreational activities, and by building on recent collaborative efforts between the Fiordland Wapiti Foundation and the Department to improve Fiordland wapiti management. This, in turn, is expected to expand the number of people contributing to conservation efforts more broadly. Working with hunters and other interested parties to increase understanding of the impacts Fiordland wapiti and other introduced species have on indigenous species can contribute to hunters adopting a conservation mindset when hunting.” (p9)
The current key objective is worded so as to "allow for the maintenance" of biodiversity. In the Authority’s view this is providing for the status quo. Rather, the objective should be “provide for enhancement of biodiversity while enabling the hunting experience ... “.
Some simple adjustments of wording would help reflect this. Suggestions below. (additions underlined and deletions in strikethrough)
Wapiti draft HOSI
3 Objectives and strategies
1. Fiordland wapiti are managed in a manner that allows provides for the maintenance improvement of natural biodiversity by restoring ecological processes and communities of browsed indigenous flora and preventing the loss of indigenous species from their current range.
2. The Fiordland wapiti hunting experience is enhanced, and the Fiordland wapiti herd produces high-quality bulls for balloted hunters to take annually during the bugle while contributing to overall management and regeneration of the Wapiti Area.
Responsibility
The HMP suggests DOC is not the Monitor and the Authority is not needing to be consulted. The party responsible for management must be “Exploring the use of new monitoring methods, tools and technologies, and seeking the views of Papatipu Rūnanga, the Southland Conservation Board and the Department prior to their use in the Wapiti Area” (p12).
Although no delegation decision has been made, the document also suggests DOC is not the HOSI manager, by stating research findings must be presented in an Annual Report and the party must “Work with the Department when preparing the annual report prior to its finalisation and public release” and “Present the annual report to Papatipu Rūnanga and the Southland Conservation Board, if requested”.
Current role of the Authority as it relates to stakeholders and the region
The Wapiti HMP includes, as its 5th objective (p11): “The Treaty partner relationship with Papatipu Rūnanga and Te Rūnanga o Ngāi Tahu is strengthened, and opportunities for Papatipu Rūnanga to be involved and participate in the management of Fiordland wapiti are increased”.
There have been issues raised by Ngāi Tahu whanau around the ballot system for Wapiti, and opportunities for whanau to undertake contemporary mahinga kai opportunities.
Potential impact of the proposed plan on the Authority’s role
A ‘Stewardship’ requirement is listed (p13, 3.10) which goes beyond the parameters of HOSI management: “Seek to provide a range of opportunities for the hunting community and other interested parties to contribute to wider conservation initiatives within the Wapiti Area, such as predator trapping and control programmes and the maintenance of historic huts and public recreation infrastructure”. This may cross into existing responsibilities of other parties.
Position of the Authority
NZCA recognises and is deeply concerned by the fact that the control of deer in Fiordland National Park is not adequate, and this situation is having serious impacts on the biodiversity of the area. The activities of the Fiordland Wapiti Foundation have been providing a level of control that DOC has not delivered. The establishment of a HOSI in a National Park has raised a number of issues that are not fully addressed in the current proposal as noted in the points articulated above. A critical element is the Treaty relationship - and whether there is agreement by mana whenua for the establishment of a HOSI in Fiordland.
Sika HOSI draft herd management plan
Achievability of HOSI management, based on proposal
HMP details do not appear to support the goal. Although targeting hinds is reported to be the most effective control approach through hunting, the HMP notes “stags are hunters’ preferred target”. It is not made clear how this behaviour would be modified to meet the objective of reducing herd size (p10). Further, it is noted that stags have a wider grazing area – this suggests the intended predominantly male herd will be harder to control as it is more likely to move into private land, out of controlled areas (p11).
It is possible recreational hunting opportunities may be reduced by the introduction of limited permits (ballot system) for hunting HOSI, noting the number of hunters is attributed as a leading means of controlling herd size. Open hunting areas are proposed, but conditional on not negatively impacting hunters’ safety or experience (p13). Any impact open areas would have on generating revenue, to recoup costs, is not discussed
Reflection of conservation objectives
The HMP contains very little detail to support its claim to promote conservation goals. For example:
“Adoption of the Sika Herd of Special Interest management approach is intended to encourage collective and concerted action for sika management and the conservation of indigenous flora and fauna in Kaimanawa Forest Park, Kaweka Forest Park and Kaweka Forest Conservation Area generally. It seeks to do this by recognising and providing for a range of values, conservation outcomes, communities and recreational activities, and by building on recent collaborative efforts between the Sika Foundation, the Department and others to improve sika management. This, in turn, is expected to expand the number of people contributing to conservation efforts more broadly” (p11).
The current key objective is worded so as to "allow for the maintenance" of biodiversity. In the Authority’s view this is providing for the status quo. Rather, the objective should be “provide for enhancement of biodiversity while enabling the hunting experience ... “.
Some simple adjustments of wording would help reflect this. Suggestions below. (additions underlined and deletions in strikethrough)
Sika draft HOSI
3 Objectives and strategies
1. Sika are managed in a manner that allows provides for the maintenance improvement of forest ecosystem processes, including canopy regeneration, and protects threatened species and their habitats.
2. The sika hunting experience is enhanced while contributing to overall management and regeneration of the Sika Area.
Position of the Authority
The Authority acknowledges that while there need to be new approaches to dealing with the destruction to forest health and biodiversity caused by deer, and that while the HOSI proposal presents a path forward, there are significant unanswered questions as noted in the points articulated above.
Overall comment
The intended conservation outcomes are not prioritised in the text of the management plans, and some of the unanswered questions about goals, objectives and responsibilities that NZCA has raised here (and in previous conversations with DOC staff and in submissions) need to be addressed before the HOSI are established and agencies move to the development of implementation plans.