NZCA Submission

The NZCA reviewed the Draft Herd Management plan for Wapiti (HMP) and provided the following feedback to the Department of Conservation.

Concern regarding the timing of the document

We believe that preparation of a Draft HMP for Fiordland Wapiti is premature. Under the law, as it currently stands, s 4(2)(b) National Parks Act requires that “except where the Authority shall otherwise determine”, the native plants and animals of the parks shall as far as possible be preserved and the introduced plants and animals shall as far as possible be exterminated.

As no determination has been issued by the NZCA in respect of Fiordland Wapiti, then the requirement to exterminate introduced animals as far as possible remains applicable.

While the Draft HMP may anticipate amendments intended to be made by the Game Animal Council (Herds of Special Interest) Amendment Bill, the Bill is not current law, and the Authority has not been asked to issue a determination in respect of Fiordland Wapiti under s 4(2)(b) of the National Parks Act (which remains the law).

An HMP is required to be consistent with relevant overriding considerations, including the General Policy for National Parks 2005, the Southland Murihiku Conservation Management Strategy 2016, and the Fiordland National Park Management Plan 2007.

It is not clear that the draft Fiordland Wapiti HMP is consistent with these overriding documents. The draft HMP should clearly identify how consistency with each of these overriding documents has been assessed and is able to be demonstrated.

This could be included in an appendix to the HMP. Consistency should be assessed against each overriding document as a whole, not simply a few individual ‘cherry picked’ objectives and policies.

S4 considerations

The Treaty Partnerships section is largely devoid of substance. It would be helpful if the views of the four Papatipū Rūnanga and Te Rūnanga o Ngāi Tahu were able to be expressed within the draft HMP.

The draft HMP needs to be prepared in a manner that Page 2 of 2 is consistent with s 4 of the Conservation Act, and in a way that gives effect to the principles of Te Tiriti o Waitangi.

It is not clear, from the draft HMP, that this has occurred. 6. It should also be noted that the takiwa of Te Rūnanga o Otakou stretches across to Piopiotahi, so their views should also be incorporated.

Concluding comments

The Authority are keen to keep working with the Department on the development of the HMP however, it believes it is premature at this stage given the enabling legislation has yet to be passed. 8. There is a need for some clarity / detail within the HMP about the ongoing conservation effort to counter-act the effects of the wapiti herd.