Submission date:  30 January 2019
Submitted to:  DOC - Predator Free 2050

The Legislative Basis for the New Zealand Conservation Authority submission

1. The New Zealand Conservation Authority (the Authority) was established under the Conservation Act 1987, 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.

2. The Authority has a growing role as an objective advocate on matters of national significance and interest in the conservation arena and to provide high quality independent advice to the Department of Conservation (DOC) on its strategic direction and performance.

3. The Authority has a range of powers and functions, under the Conservation Act 1987, as well as under other conservation related legislation. Under the Conservation Act, Section 6C(2)(c), the NZCA has the power to “advocate the interests of the Authority at any public forum or in any statutory planning process.”

4. One of the NZCA’s statutory functions is to approve conservation management strategies and conservation management plans, and review and amend such strategies and plans. They constitute the key management documents for directing conservation effort and resources in New Zealand. Many of these documents have objectives, policies and outcomes relating to the conservation of native species and predator control.

5. Following the logic of the above powers and functions, the Authority supports DOC’s work to help achieve Predator Free 2050 (PF2050) and appreciates opportunities to provide feedback on how this will be achieved.

Authority feedback

6. DOC have been engaging with the Authority on the development of PF2050 programme since 2017. Already, feedback from the Authority has been incorporated into this Discussion Guide, contributing to the Strategic Framework and Plan.

7. Following the Authority’s review of the Discussion Guide, further feedback has been prepared.

General comments

8. The guiding principles should be reassessed so that they are better coordinated.

9. The science and technical advisory group which will be established should look at all options for the control and eradication of pests, not just those which we are using now.

10. For New Zealand to be innovators in pest control operations, DOC will need to deviate from only using traps and toxins.

11. The flow-on negative consequences from only controlling certain predator species are potentially large, e.g. mouse populations in some areas could expand as other mammals are removed. Data should be collected to investigate such possible impacts.

12. Landscape-scale suppression and eradication of predators, page 11: The fourth 5-year goal specifies 10,000 hectares of rural production land which is a huge undertaking, and potentially unachievable by 2050.

13. The Authority questions how regional councils will come up with their share of the money to fund these operations? Will they be resourced appropriately? Also, how will iwi and hapū be resourced to restore sites?

14. It is also important to ask; how do we balance commercial outcomes with continuing work toward PF2050? This challenge will be raised throughout the process of developing the strategic plan. Within the strategic plan, connection into the National Policy Statement on Indigenous Biodiversity should be specified.

15. PF2050 must be driven at a community level, with regular feedback and monitoring from DOC to continue to encourage and motivate communities.

16. To continue to encourage interest and understanding of this work, visual aspects should be incorporated into progress reporting, providing clear updates against objectives.

Mātauranga Māori specific

17. Imagining a predator free New Zealand, page 1: The fourth paragraph needs to show more meaningful commitment to Māori leading, e.g. co-governance or joint-ownership of conservation programmes, but also the administering of them through post settlement arrangements, as per Treaty of Waitangi/te Tiriti o Waitangi (the Treaty) principles. This means not just saying Māori can exercise kaitiakitanga, but instead providing more meaningful partnership opportunities.

18. A framework for PF2050, page 3: The five broad work streams should be provided in te reo Māori also. For example, the third broad work stream Communications and engagement, iwi, iwi chairs, and hapū leaders can drive this space alongside DOC and others working toward PF2050. This again reiterates the partnership principle of the Treaty.

19. Choosing our guiding principles, page 6: As with the fourth and fifth guiding principle, the other four should also be framed around Māori concepts.\

20. Above all, it is important that this PF2050 strategy gives effect to the principles of the Treaty, as referenced in paragraphs 17 and 18 above. Specifically, this should also be applied to the 5-year outcomes from Mātauranga Māori, page 8 of the Discussion Guide:

• Iwi are genuine partners in PF2050, involved in decision making, scoping and planning; Concerning the partnership principle, not all regions are the same and engagement may occur at the hapū or iwi level.
• Mātauranga values are an integral part of the PF2050 strategic plan; Relates to tino rangatiratanga which refers to the right of Māori to have absolute sovereignty of their land, and so the exercise of that authority based on Māori traditions and values.
• Consultation is done at local, hapū level; The use of the word consult should instead be changed to engage, as it is more proactive and comprehensive. This also relates to tino rangatiratanga, as most Treaty signatories are identified by hapū but the principle of partnership requires more than consultation so outcome (1) and (3) need to be taken together. Combined it could instead read, Engagement is undertaken with iwi/hapū and iwi/hapū are genuine partners in PF2050, involved in decision making, scoping and planning.
• More sizeable, iwi-led eradication projects have begun; Again, this relates to tino rangatiratanga, exercising of authority over lands, forests, fisheries, taonga, etc.
• Examples of best practice in iwi leadership and stewardship are being showcased; Again, this relates to partnership.
• The majority of marae have established trap networks; What constitutes a trap network? Who pays for this network? Who pays for the clearing of traps? Again, this relates to tino rangatiratanga, exercising of authority over lands, forests, fisheries, taonga, etc.
• Rangatahi are an integral part of PF2050 work, and gaining the qualifications required to move through to leadership roles; Again, this relates to tino rangatiratanga.

21. These principles should also be applied to the Long-term milestones, page 13-14:

Summary of feedback

22. It is clear there is great understanding of the need for collaboration within PF2050, which is reassuring as this will be a key enabler for success.

23. A greater effort to expand the ‘tool box’ of predator control methods must be provided for.

24. Resourcing for all level of stakeholders must be considered in greater detail.

25. As a key element of this discussion guide is in developing outcomes, the Authority sees that Treaty principles must be more thoroughly considered. Furthermore, a Māori perspective throughout the document would be preferable to allocated sections.

26. This Discussion Guide signals an opportunity for step-change in predator control and the Authority is encouraged by the direction it provides.