gwrc proposed rpmp 2019 2039 submissions · 2018. 10. 3. · 039 little, chris ... while stoats are...

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GWRC Proposed RPMP 2019 – 2039

Submissions

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Contents

Table of Contents 001 Wickens, Jonathan .................................................................................................................................... 6

002 Capital Kiwi ............................................................................................................................................... 7

003 Dowling, Roger ......................................................................................................................................... 8

004 Companion of the Royal Society of NZ ..................................................................................................... 9

005 Project Manager Predator Free Wellington ............................................................................................. 10

006 (Forest & Bird Upper Hutt Chairperson) .................................................................................................. 11

007 Van Berkel, Pat ....................................................................................................................................... 12

008 Brockelsby, William ................................................................................................................................. 13

009 Cowdell, Logan ....................................................................................................................................... 14

010 Leerschool, Peter .................................................................................................................................... 16

011 Markham, Angela .................................................................................................................................... 17

012 Bremner, David ....................................................................................................................................... 18

013 Lane, Jacqui ........................................................................................................................................... 19

014 Basha, Parid ........................................................................................................................................... 21

015 Van Den Hoeven, John ........................................................................................................................... 22

016 Roberston, Andrew ................................................................................................................................. 24

017 Gray, Kerry ............................................................................................................................................. 26

018 Hoffman, Lucy ......................................................................................................................................... 27

019 Beadel, Jack ........................................................................................................................................... 28

020 Wilton, Tony ............................................................................................................................................ 29

021 Grealish, Paul ......................................................................................................................................... 30

022 Johansson, Karin .................................................................................................................................... 32

023 Hurdley, Tom .......................................................................................................................................... 33

024 Boyde, Sue ............................................................................................................................................. 34

025 Fontan, Adriana ...................................................................................................................................... 35

026 Mort, Anthony ......................................................................................................................................... 36

027 Campbell, Maureen ................................................................................................................................. 38

028 Grace, Michael ........................................................................................................................................ 40

029 Clifford, Jack ........................................................................................................................................... 41

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030 Boy, Seth ................................................................................................................................................ 43

031 Sadowska, Paulina ................................................................................................................................. 44

032 Simpson, Andrew .................................................................................................................................... 45

033 Wild Aro .................................................................................................................................................. 46

034 Nash, Chris ............................................................................................................................................. 48

035 Robertson, Caro ...................................................................................................................................... 49

036 Seiler, Oliver ........................................................................................................................................... 50

037 Leachman, Siobhan ................................................................................................................................ 52

038 Fitzjohn, Trevor ....................................................................................................................................... 54

039 Little, Chris .............................................................................................................................................. 55

040 Rooney, Nathan ...................................................................................................................................... 56

041 Valentine Alison ...................................................................................................................................... 57

042 Chair, MIRO ............................................................................................................................................ 59

043 Williams, Anna ........................................................................................................................................ 62

044 Predator Free Miramar ............................................................................................................................ 63

045 Martin, Jane ............................................................................................................................................ 65

046 Peoples, Ramona ................................................................................................................................... 66

047 Perrie, Leon ............................................................................................................................................ 67

048 Rafter, Sonia ........................................................................................................................................... 68

049 Gary, James ........................................................................................................................................... 69

050 McNeill, Florence .................................................................................................................................... 70

051 Rogers, Amanda ..................................................................................................................................... 72

052 Munn, Jordan .......................................................................................................................................... 74

053 Confidential ............................................................................................................................................. 76

054 Wellington Fish & Game ......................................................................................................................... 77

055 Kerridge, Bob .......................................................................................................................................... 79

056 Falkner, Richard ...................................................................................................................................... 82

057 Wilcox, Sarah .......................................................................................................................................... 84

058 Renyard, Ashlyn ...................................................................................................................................... 85

059 Trelissick Park Group .............................................................................................................................. 86

060 Legg, Jesse ............................................................................................................................................ 87

061 Turnbull, Duncan ..................................................................................................................................... 89

062 Tomii, Nobushige .................................................................................................................................... 90

063 Vink, Hetty .............................................................................................................................................. 92

064 Brusen, John ........................................................................................................................................... 94

065 Tocker, Warren ....................................................................................................................................... 96

066 Bell, Ann ................................................................................................................................................. 97

067 Auld, Nicky .............................................................................................................................................. 99

068 Keall, Susan .......................................................................................................................................... 101

069 Thrift, Andrew ....................................................................................................................................... 103

070 Martinson, Paul ..................................................................................................................................... 105

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071 Dawes, Mallory ..................................................................................................................................... 107

072 Petzen, Daniel ...................................................................................................................................... 108

073 Thrasher,Susan .................................................................................................................................... 110

074 NZ Cat Coalition .................................................................................................................................... 113

075 Gazley, Dennis...................................................................................................................................... 118

076 Callister, Paul, Stace Michael, Cave,Shane .......................................................................................... 120

077 Name Confidentiality ............................................................................................................................. 122

078 Department of Conservation ................................................................................................................. 123

079 Shaw, Kerry .......................................................................................................................................... 138

080 Morgan Foundation ............................................................................................................................... 140

081 Predator Free NZ .................................................................................................................................. 142

082 GUARDIANS OF PAUATAHANUI INLET Inc. ....................................................................................... 144

083 Hemingson, Jacqueline,Ann.................................................................................................................. 146

084 Legg, Mary ............................................................................................................................................ 148

085 Legg, Dan ............................................................................................................................................. 150

086 Oliver, Jared ......................................................................................................................................... 152

087 HVNZDA ............................................................................................................................................... 154

088 Bloomfield, Colin ................................................................................................................................... 156

089 Sousa, Luis ........................................................................................................................................... 158

090 Dorifaeff, Josie ...................................................................................................................................... 160

091 Kay, Tom .............................................................................................................................................. 162

092 Federated Farmers of New Zealand ...................................................................................................... 171

093 Porirua Harbour and Catchment Community Trust ................................................................................ 175

094 Sandom, Alan ....................................................................................................................................... 179

095 Raumati South Residents ..................................................................................................................... 181

096 Lower Hutt Forest and Bird, .................................................................................................................. 185

097 Naenae Nature Trust............................................................................................................................. 187

098 Eastboune Hunters and Gathers ........................................................................................................... 189

099 Ministry for Primary Industries ............................................................................................................... 190

100 Masterton District Council ..................................................................................................................... 194

101a Wellington City Council ....................................................................................................................... 196

101b Wellington City Council ....................................................................................................................... 197

102 Feline Rights ......................................................................................................................................... 201

103 Harvey, Annette .................................................................................................................................... 213

104 Le Quesene, Lana ................................................................................................................................ 215

105 Kāpiti Project ......................................................................................................................................... 217

106 Confidential ........................................................................................................................................... 222

107 Hudson, Aaron ...................................................................................................................................... 223

108 Horne, Christopher ................................................................................................................................ 232

109 East Harbour Environmental Association .............................................................................................. 237

110 Churton Park Preditor Free ................................................................................................................... 239

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111 Clifford, Marsh, Wayne .......................................................................................................................... 241

112 Ballance, Alison .................................................................................................................................... 243

113 Wellington Botanical Society ................................................................................................................. 244

114 SPCA .................................................................................................................................................... 258

115 Kapiti Coast District ............................................................................................................................... 267

116 Lower North Island Region, Department of Conservation ...................................................................... 268

117 WELLINGTON NATURAL HERITAGE TRUST ..................................................................................... 269

118 Corie ..................................................................................................................................................... 272

119 Zealandia .............................................................................................................................................. 273

120 Piers ..................................................................................................................................................... 274

121 Sandy Werner ....................................................................................................................................... 274

122 Jacko .................................................................................................................................................... 275

123 EdmundSS ............................................................................................................................................ 275

124 Saisr ..................................................................................................................................................... 275

125 Kakas ................................................................................................................................................... 275

126 Miro ....................................................................................................................................................... 276

127 Jeremy Collyns ..................................................................................................................................... 276

128 Jacqui Lane .......................................................................................................................................... 276

129 John McLachlan .................................................................................................................................... 276

130 Graeme Blanchard ................................................................................................................................ 277

131 Longtime EHRP Park User ................................................................................................................... 278

132 Pando ................................................................................................................................................... 279

133 John Flux .............................................................................................................................................. 280

134 Paul Martinson ...................................................................................................................................... 280

Appendices ................................................................................................................................................. 281

Appendix 1 #99 MPI – supporting documents Appendix 2 #102 Feline Rights – supporting documents

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001 Wickens, Jonathan To Pest Plan Inbox 02-07-18

Hello,

Thanks for the opportunity to comment. I live on the Paekakariki Hill Road and have most of the Tunapo

"area of ecological significance" on my property. I have an extensive trapping network using DOC200s and

Goodnature A24s. I catch several stoats and hedgehogs and 50-100 rats per year. (I only rarely get possums

on my property though.)

I also target magpies, which harass and compete with native birds, especially falcons and harriers. I have

two trip traps that are reasonably good on the younger birds but the traps with call birds your pest animals

team loan out are needed for the older, wiser birds. I requested one about a month ago but they told me that

they're not supplying call birds any more. Having a call bird from outside of the immediate area is important

for these traps to work because the local birds will come in to attack the invader that they don't recognize. I

can catch my own call bird but they're no where near as effective if the other birds recognize it, because it

isn't a potential rival. I used to be able to keep my entire property magpie-free but now I'm really struggling

to do so without a "foreign" call bird.

Another advantage of the call bird traps is less/ zero non-target species by-catch. One problem with the trip

traps is that they occasionally catch harriers. The traps are non-lethal but obviously not great for the harriers.

I have never had any by-catch with your traps though.

I would really encourage you to re-start giving out magpie call birds with your traps as this makes them

significantly more effective. I am determined to do everything I can to keep this special property pest-free,

and spend a lot of time and money doing so. But I really need call birds from outside my area to deal with

the magpies that re-invade. I can't do this bit without help.

Is this something you would consider please?

Thanks in advance

Jonathan Wickens

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002 Capital Kiwi Stanley Ward, Paul

To Pest Plan Inbox 02-07-18

1. Re Capital Kiwi: probably fine at this stage to include it within the wider scope of PFW. Note that while

CK and PFW do have/will have a very close relationship (currently being formalised via an MoU and

management agreement), that CK will be setting up as an independent charitable trust. We will sit under the

wider PFW 'umbrella' but the CK project will have independent governance.

Yell out if it would be helpful to see the draft CK pest eradication plan. This will be finalised over the

coming months in consultation with stakeholders (including GW) and the first traps are planned to be

deployed over the upcoming summer.

2. While stoats are the primary target of CK's pest eradication (to enable kiwi to return), we will also be

looking at other pests that have (lesser) impacts on kiwi viability as landowners' will and opportunities

present themselves. e.g. private landowners (e.g. Terawhiti station, Meridian) have expressed keenness to

get rid of feral cats.

We endorse GW's proposed commitment to acting on controlling feral cats in KNE and TA areas. My only

concern would be that the latter part of the definition of pest animal:

"free-living, unowned and unsocialised, and has limited or no relationship with or dependence on humans."

might allow feral colonies that are being fed by humans to escape being defined as pest animals.

Otherwise: good stuff!

Paul

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003 Dowling, Roger To Pest Plan Inbox 04-07-18

Subject - Feedback

First Name - Roger

Last Name - Dowling

Comments - Saw in the DomPost an article stating hedgehogs were to be included in your Regional Pest

Management Plan because of dangers to shore birds. Happy with this if this is confined to the coastal or

riparian strip as I believe hedgehogs have benefits as well. A more meritorious target is feral cats in urban

and rural areas. Why can’t we trap and kill them in our own backyard? I have found a number of birds on

my lawn killed by cats

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004 Companion of the Royal Society of NZ Brockie, Bob


Subject - Feedback

First Name - Bob

Last Name - Brockie

Comments - Further to my earlier submission -

Hedgehogs are only a minor and declining pest in the Wellington region. I have been counting hedgehog

roadkill on Wellington roads since the 1950s when there were 50 times more hedgehogs. They are

disappearing from the Wellington landscape. Same in Britain where they have become an endangered

species. Better spend the money on eradicating real pests - rats and stoats.

Bob Brockie PhD, Companion of the Royal Society of NZ

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005 Project Manager Predator Free Wellington Willcocks, James


Kia ora

I would like to submit on the RPMP with emphatic support for the inclusion of Predator Free Wellington as

a project in the site led category. This mechanism sets both important context and a strategic framework for

delivering the aspirational goal of creating the world’s first predator free capital city.

Cheers,

James

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006 (Forest & Bird Upper Hutt Chairperson) Bellamy, Graham To Pest Plan Inbox 11-07-18

The Wellington Regional Council

Submission : Regional Pest Management Plan 2018 – 2039

We wish to submit on the Regional Pest Plan as Forest & Bird have been actively involved in maintaining

and improving the environment around Upper Hutt for approx. 25 years. We were instrumental in the saving

and recovery of Barton’s Bush in Trentham Memorial Park and have been working on Hull’s Creek for over

15 years. In the past 2 years we have been instrumental in starting t control and eradicate Old Man’s Beard

along River Road (SH2) from Silverstream to Whakaitki Street in Upper Hutt. This work is ongoing and we

have already done work in other areas of Upper Hutt.

We are currently working with GWRC, UHCC and DOC in starting a PredatorFree project in Upper Hutt

and also continuing to manage the work in Wi Tako Reserve and Trentham Memorial Park KNE sites for

predator control.

We would like to see a closer liaison between GWRC and volunteer groups on work such as pest and weed

control work. We certainly appreciate the support and effort that is being provided but as this work is so

reliant on volunteers we would like to see more staff to support and liaise with the groups working on such

projects. It is really great for volunteers to feel appreciated and recognized for the work that they do. This

could be in the form of an annual letter to them or an annual visit to the group.

The main area of concern to us with the Plan is in the area of Old Man’s Beard (OMB), which we are

actively involved with currently in our area. We note that OMB is listed as a pest weed but the management

of it within GWRC area is under a programme of “Site-led HCC”. This seems to be a programme that only

provides control of the pest weed within HCC TA boundary. We would like to see this extended to cover all

of the GWRC controlled areas. If this is not practical we would like to have a discussion with your staff and

UHCC to get the same control delivery service arrangement set up within UHCC TA boundary.To date we

have been working within the UHCC area to control OMB with the support of UHCC and their contractors

and our own volunteers, but we would like to see a more formal arrangement in conjunction with GWRC

We are in the process of starting a PredatorFree programme in Upper Hutt to control and eradicate rats, and

mustelids in the Upper Hutt area. We look forward to working with your team to support this work and get

community support and volunteers to make this programme a success.

We are also hoping to work closely with Iwi on these programmes.

This submission has been restricted to the above issues due to the time restraint. We do support the work

that GWRC does within its resources and hope that this can be extended to further work on the protection of

the environment from pest weeds and animals.

Graham Bellamy, Chairperson Forest & Bird Upper Hutt Branch.

11/07/18

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007 Van Berkel, Pat To Pest Plan Inbox 12-07-18

Well done Graham.

I concur that we try and get the same control of OMB in UH city as in Hutt City.

It would be great if the F & B branches each attempted the same arrangement with their local council and with

GW. Perhaps Tom can pursue this with the other branches before 27 July submission closing date.

At the very least it would be excellent if the Pest Management Plan included a clause leaving it open to set up a

similar control regime as in HCC, with assistance from the local F & B branches, during the 10-year life of the Plan.

Cheers

Pat

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008 Brockelsby, William To Pest Plan Inbox 18-07-18

Name

William Brockelsby

Email

[email protected]

Street address

19 Norwich Street

Suburb

Wilton

Postcode

6000

Phone Number

0273151435

Pest cats

I support the inclusion of pest cats within the Proposed plan.

Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of native species including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so humans need to control their numbers. Without management cats undermine any predator control work undertaken by council and community groups.

Definition of pest cats

I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat is: “a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on private or public land within the Wellington Region, without the permission of the occupier.”

Possums

I agree with possums being both sustained and site-led pests and support their inclusion in the plan.

Possums significantly impact both primary production and biodiversity and controlling their population is an important regional goal. Urban control is also important to prevent reinvasion into both significant ecological areas and the rural landscape.

Hedgehogs

I agree with European hedgehogs being defined as site-led pests and support their inclusion in the plan. Hedgehogs have serious impacts on lizard and invertebrate populations and eat the eggs of ground nesting birds. More public education is needed around the impacts hedgehogs have on our native biodiversity.

Rule 1 for hedgehogs should also state the people should not release hedgehogs into any Key Native Ecosystem.

Mustelids

I agree with mustelids (stoats, ferrets and weasels) being defined as site-led and for the ambitious goal to eradicate them from areas within the Predator Free Wellington initiative.

An additional rule should be added to make it clear that releasing a mustelid within the Wellington Region is an offence.

Rats

I support the inclusion of rats (Norway and ship) as site-led pests to be controlled at specific sites.

Any other comments you would like to make about the Proposed RPMP?

Keep up the good work team, keep pushing the limits. I trap for Polhill Protectors and see some of the good work you do.

Do you want to attend a hearing? I do not wish to heard in support of my submission

mailto:[email protected]

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009 Cowdell, Logan To Pest Plan Inbox 18-07-18

Name

Logan Cowdell

Email

[email protected]

Street address

336 Oriental Parade

Suburb

Oriental Bay

Postcode

6011

Phone Number

0275784772

Pest cats

I support the inclusion of pest cats within the Proposed plan. All owned cats should be microchipped to differentiate between owned and unowned cats.





Possums



Hedgehogs



Mustelids



Rats



I congratulate you on the inclusion of a definition of a pest cat and look forward to more cat management in parks and reserves.


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Do you want to attend a hearing?

I do not wish to heard in support of my submission

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010 Leerschool, Peter To Pest Plan Inbox 18-07-18

No Information on form just that they support

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011 Markham, Angela To Pest Plan Inbox 18-07-18

Name

Angela Markham

Email

[email protected]

Street address

254 willis street

Suburb

Te Aro

Postcode

6011

Phone Number

021 23 23 348

Pest cats






Possums



Hedgehogs



Mustelids



Rats





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012 Bremner, David To Pest Plan Inbox 18-07-18

Name

David Bremner

Email

[email protected]

Street address

1/254 Willis St

Suburb

Te Aro

Postcode

6011

Phone Number

0212242920

Pest cats






Possums



Hedgehogs



Mustelids



Rats




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013 Lane, Jacqui To Pest Plan Inbox 18-07-18

Name

Jacqui Lane

Email

[email protected]

Street address

40 Happy Valley Road

Suburb

Owhiro Bay

Postcode

6023

Phone Number

0220344667

Pest cats






Possums



Hedgehogs



Mustelids



Rats




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It would be good to provide information about the humanness of trapping. I recently caught a pest cat in a cage in my house. I advertised to find it's owners, turns out it was a pet that had become feral and it's owners came forward to claim it, however they released it immediately, it ran away again and then they requested I rehome it! Sigh. However I was roasted online about the cruelty of caging it. People clearly need to know what is ok as far as trapping and dealing with pest cats is concerned.



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014 Basha, Parid To Pest Plan Inbox 18-07-18

Name

parid basha

Pest cats






Possums



Hedgehogs



Mustelids



Rats



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015 Van Den Hoeven, John To Pest Plan Inbox 18-07-18

Name

john van den hoeven

Email

[email protected]

Street address

7a beryl grove

Suburb

upper hutt

Postcode

5018

Phone Number

0277033207

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Deer need to be controlled too,there are large populations now causing a lot of damage.I know The Deerstalkers are opposed to them being classified as pests but they are.


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016 Roberston, Andrew To Pest Plan Inbox 18-07-18

Name

Andrew Robertson

Email

[email protected]

Street address

58 Waripori Street

Suburb

Berhampore

Postcode

6023

Phone Number

027 948 58 98

Pest cats


They are absolutely out of control in Berhampore.





Possums



Hedgehogs



Mustelids



Rats


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017 Gray, Kerry To Pest Plan Inbox 18-07-18

Name

Kerry Gray

Email

[email protected]

Street address

7 Haunui Road

Suburb

Porirua

Postcode

5026

Phone Number

042399328

Pest cats






Possums



Hedgehogs



Mustelids



Rats





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018 Hoffman, Lucy To Pest Plan Inbox 18-07-18

Name

Lucy Hoffman

Email

[email protected]

Street address

91 Owen St

Suburb

Newtown

Postcode

6021

Phone Number

0272727936

Pest cats






Possums



Hedgehogs



Mustelids



Rats





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019 Beadel, Jack To Pest Plan Inbox 18-07-18

Name

Jack Beadel

Email

[email protected]

Street address

14 pentlow place

Suburb

fendalton

Postcode

8052

Phone Number

03 3516499

Pest cats

I support the inclusion of all cats within the Proposed plan.



I propose the definition of pest cats to be change to clearly include all cats. My suggested definition of a pest cat is: “any cat in new zealand”.

I would like the rule around feeding or sheltering any cats 'pet cats' or 'pest cats' on land to be amended to include any cat. I suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter any cats on private or public land within the Wellington Region”

Possums



Hedgehogs



Mustelids



Rats



Ban all cats



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020 Wilton, Tony To Pest Plan Inbox 18-07-18

Name

Tony Wilton

Email

[email protected]

Street address

53 Waipounamu Drive

Suburb

Kelson, Lower Hutt

Postcode

5010

Phone Number

04 5650778

Pest cats

I support the inclusion of pest cats within the Proposed plan. We live on the edge of the built-up area with bush reserve on two sides. We have been here for more than 40 years. Previously we had a possum problem which was magnificently brought under control by GWRC. What followed was an upsurge in bird life - tui, kereru, bellbirds, grey warblers, waxeyes and many others. But now that birdlife is being attacked by an upsurge of feral cats. Domestic cats have been abandoned and have bred in the bush. We are now at least four generations into this infestation. This infestation is being made worse by some residents who encourage and feed the cute kitties. The role of the SPCA - trap, neuter and return - is infuriating.




Possums



Hedgehogs



Mustelids



Rats



I wish to be heard in support of my submission


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021 Grealish, Paul To Pest Plan Inbox 18-07-18

Name

Paul Grealish

Email

[email protected]

Street address

20 ferry st

Suburb

Seatoun

Postcode

6022

Phone Number

0212222290

Pest cats

I wholeheartedly support the inclusion of pest cats within the Proposed plan.

Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of native species including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so humans need to control their numbers. Without management cats completely vundermine any predator control work undertaken by council and community groups.




Possums



Hedgehogs



Mustelids



Rats

I wholeheartedly support the inclusion of rats (Norway and ship) as site-led pests to be controlled at specific sites.



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Ive been a strong advocate of Predator Free Seatoun and have enjoyed many a tui in our gardens in recent years. I want to endorse cats being included and managed as pests as many roam the area and presumably kill.

Can I also suggest that there are planned efforts made to address pests in expansive hillsides of bush where houses such as

ours border. Do you want to attend a hearing?


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022 Johansson, Karin To Pest Plan Inbox 18-07-18

Name

Karin Johansson

Email

1Street address

110 Wainui rd

Suburb

Raglan

Postcode

2334

Phone Number

07-8257529

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 33

023 Hurdley, Tom To Pest Plan Inbox 18-07-18

I support the application and make further comments: -There should be increased funding and resources to

exterminate feral cats in the Wellington Region. There are significant numbers of the cats in our are, with

the Hutt city council, the pound and SPCA all diverting responsibilty to other party. Therefore a highly

dangerous predator is falling through the cracks.

There should be the opptunity for the community to purchase pest traps at discount prices. This would make

the potentialof Wellington become pest free more of a reality.

There should be a requirement for all cats to be registered (like with dogs)

-There should also be a curfew on all domestic cats to be inside at night time. This approach has been

adopted through the majority of coucil areas in Victoris, Austraila and has been successfulin minimising the

number of native species being killed by domestic cats.

Page | 34

024 Boyde, Sue To Pest Plan Inbox 18-07-18

Name

Sue Boyde

Email

[email protected]

Street address

42 Kaimanawa St

Suburb

Paraparaumu

Postcode

5032

Phone Number

0211198085

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 35

025 Fontan, Adriana To Pest Plan Inbox 18-07-18

Name

Adriana Fontan

Email

[email protected]

Street address

204 Rintoul St

Suburb

Berhampore

Postcode

6023

Phone Number

04 9774553

Pest cats

I strongly oppose the inclusion of cats of any sort within the Proposed plan. It is barbaric, cruel and unfair.

By far, the largest culprit of the loss of habitat and its subsequent loss of diversity are humans. Control sprawling low density cities, control population growth and you will rid the World of environmental problems. Of course, it is easy to distract people from the real causes of our environmental problems by blaming and killing cats.




Possums



Hedgehogs



Mustelids



Rats





Page | 36

026 Mort, Anthony To Pest Plan Inbox 18-07-18

Name

Anthony Mort

Email

[email protected]

Street address

15 banksia grove

Suburb

Maungaraki

Postcode

5010

Phone Number

04 5696777

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 37

No household should be permitted to have more than two cats at any residential area.



Page | 38

027 Campbell, Maureen To Pest Plan Inbox 19-07-18

Name

Maureen Campbellwhite

Email

[email protected]

Street address

10

Suburb

West Harbour

Postcode

0618

Phone Number

4161305

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 39

I would propose that pet cats be properly controlled and confined to the owners property. No other domestic animal is allowed to roam at will. Leaving a pet to roam the neighbourhood is deliberate neglect and should be punishable by law. Our cats should be properly looked after like dogs. Free roaming cats are run over by cars, get into fights, pick up fleas, eat garbage and get sick. They also spread toxoplasmosis by fouling our yards and parks.



Page | 40

028 Grace, Michael To Pest Plan Inbox 19-07-18

Name

Michael Grace

Email

[email protected]

Street address

53 Gatden Rd

Suburb

Northland

Postcode

6012

Phone Number

021722860

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 41

029 Clifford, Jack To Pest Plan Inbox 19-07-18

Name

Jack Clifford

Email

[email protected]

Street address

10 Pitt St

Suburb

Wadestown

Postcode

6012

Phone Number

0277106791

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Long term plan should include phasing out domestic cats. As a cat owner I have experienced first hand my cat bringing in native birds, lizards and insects.


Page | 42



Page | 43

030 Boy, Seth To Pest Plan Inbox 19-07-18

Name

Seth Boy

Email

[email protected]

Street address

68a Raroa Road

Suburb

Kelburn

Postcode

6012

Phone Number

02102418749

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 44

031 Sadowska, Paulina To Pest Plan Inbox 19-07-18

Name

Paulina Sadowska

Email

[email protected]

Street address

200 Waimaori rd

Suburb

Raglan

Postcode

3296

Phone Number

021055809u

Pest cats




I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat is: “a cat without a registered microchip”. They should be desexed and rehomed.

Possums



Hedgehogs

Should be kept out of reserves.

Mustelids



Rats



Stop using poisons such as 1080 and Roundup and all other pesticides which KILL native life like lizards and native snails. The excessive use of poison in NZ is putting animals and humans at risk.




Page | 45

032 Simpson, Andrew To Pest Plan Inbox 19-07-18

Name

Andrew Simpson

Email

[email protected]

Street address

15 Liffey Cres

Suburb

Island bay

Postcode

6023

Phone Number

0274768990

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 46

033 Wild Aro Hawkins, Anthony


Name

Anthony Hawkins

Organisation Name (If submission is on behalf of an organisation)

Wild Aro

Email

[email protected]

Street address

56/46 hiropi St

Suburb

Newtown

Postcode

6023

Phone Number

021 793305

Pest cats

I support the inclusion of pest cats within the Regional Pest Management plan.





Possums



Hedgehogs



Mustelids


Page | 47



Rats




Page | 48

034 Nash, Chris To Pest Plan Inbox 19-07-18

Name

Chris Nash

Email

[email protected]

Street address

7 Norway Street

Suburb

Aro valley

Postcode

6012

Phone Number

0272038299

Pest cats






Possums



Hedgehogs


Mustelids



Rats





Page | 49

035 Robertson, Caro To Pest Plan Inbox 19-07-18

Name

Caro Robertson

Email

[email protected]

Street address

34a ira st

Suburb

Miramar

Postcode

6022

Phone Number

021401412

Pest cats






Possums



Hedgehogs



Mustelids



Rats



I would like to see all NZ native species prioritised over introduced species



Page | 50

036 Seiler, Oliver To Pest Plan Inbox 19-07-18

Name

Oliver Seiler

Email

[email protected]

Street address

17 Marama Terrace

Suburb

Eastbourne

Postcode

5013

Phone Number

0211017314

Pest cats






Possums



Hedgehogs



Mustelids



Rats


Page | 51




Page | 52

037 Leachman, Siobhan To Pest Plan Inbox 19-07-18

Name

Siobhan Leachman

Email

[email protected]

Street address

67 Washington Ave

Suburb

Wellington

Postcode

6021

Phone Number

027 306 3686

Pest cats

I very much support the inclusion of pest cats within the Regional Pest Management plan. Given the plan is to be in place for a maximum of 20 years I believe that the issue of the pest cats should be dealt with in the plan.





Possums



Hedgehogs



Mustelids



Rats


Page | 53




Page | 54

038 Fitzjohn, Trevor To Pest Plan Inbox 19-07-18

Name

Trevor FitzJohn

Email

[email protected]

Street address

24 Bidwill Street

Suburb

Mt Cook

Postcode

6021

Phone Number

021483959

Pest cats






Possums



Hedgehogs



Mustelids



Rats



We need to get serious about pests before more extinctions locally or nationally of birds invertebrates plants and fish. This includes trout as a pest invasive species in some rivers impacting on whitebait species.



Page | 55

039 Little, Chris To Pest Plan Inbox 19-07-18

Name

Chris Little

Email

[email protected]

Street address

85 Madras street

Suburb

Khandallah

Postcode

6035

Phone Number

021747544

Pest cats






Possums



Hedgehogs



Mustelids



Rats



I think all cats should have to be kept in at night and wear a loud bell at all times.




Page | 56

040 Rooney, Nathan To Pest Plan Inbox 20-07-18

Name

Nathan Rooney

Email

[email protected]

Street address

11 Kakariki Grove

Suburb

Waikanae

Postcode

5036

Phone Number

021401350

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 57

041 Valentine Alison To Pest Plan Inbox 20-07-18

Name

Alison Valentine

Email

[email protected]

Street address

29 Highbury Crescent

Suburb

Wellington

Postcode

6012

Phone Number

+6421714322

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Page | 58


I support the close involvement of community groups working on eliminating pest species, plant and animal. We need to continue to eliminate pest plants such as banana passionfruit and old man's beard, which are starting to reappear in areas previously cleared.



Page | 59

042 Chair, MIRO Webb, Terry

To Pest Plan Inbox 20-07-18 MIRO is an entirely volunteer organisation and Incorporated Society whose aim is to protect and restore the native ecosystems within East Harbour Regional Park (EHRP), Wellington, through: the protection and restoration of native flora and fauna; the control and, ultimately, elimination of plant and animal pests; the reintroduction of native flora and fauna; achieving our vision through active involvement in education and advocacy; and doing anything else necessary or helpful to achieve the above. This aim is entirely consistent with the Key Native Ecosystem Plan for East Harbour Northern Forest (2014–17) and the Key Native Ecosystem Plan for the Parangarahu Lakes Area (2014–17). In the past year, over 120 volunteers have contributed to MIRO’s work in EHRP. This submission on the Greater Wellington Proposed Regional Pest Management Plan (RPMP) has been developed and approved by the MIRO Committee.

MIRO is very concerned that feral deer and pigs have been downgraded from being in a Site-led pest category to being classified as ‘harmful organisms’ and that neither of these feral species is a priority for pest control under the proposed plan. We believe that feral deer and pigs, in the context of Wellington’s Key Native Ecosystem (KNE) areas, are pests in that they meet the necessary criteria under the Biosecurity Act 1993 and we cannot understand how they are no longer considered a priority for control (see below). We also note that goats are still included in the Site-led pest category and were thus part of the associated Cost

Benefit Analysis (CBA) for the RPMP. In the CBA document, the preferred option for goat control is:

“Site-led is the preferred option for feral goats in KNE and TA reserves as this provides powers under the Biosecurity Act when

undertaking control. The management approach is essentially the same as under the RPMS 2002 – 2022, which has

continued to work well by controlling feral goats to minimise significant impacts to the environment. A site-led control

programme represents the most pragmatic and affordable management measure for the Wellington Region. In terms of

alternative approaches assessed, under no regional intervention (do-nothing approach) council would not have any mandate

to be involved in feral goat management measures. There would be total reliance on voluntary control by occupiers. Under

‘do-nothing’ there is a high chance that environmental values are increasingly put at risk.”

We would argue that this line of reasoning is equally applicable to deer and pigs, the only difference being that goats

are seen to have lesser value by recreational hunters. Recreational hunting value is not one of the criteria for pest

status under the Biosecurity Act. Furthermore, if it has been argued that recreational hunting will make a significant

contribution to controlling the deer and pig population, we note that ‘means of control’ is not one of the criteria for

pest status either.

One benefit in having deer and pigs in the Site-led control category is that allows for rules to be made. For example,

the current Pest Management Strategy has two rules relating to the release of feral deer. While the unauthorised

release of wild animals is an offence under the Wild Animal Control Act 1977, having specific rules in the RPMP gives

the issue more visibility and, hopefully, provides a greater deterrent (compared to removing these rules). A rule

allowing access to neighbouring land for the control of deer, if the deer being pursued crosses into adjoining land,

would be especially relevant on the western flanks of the Northern Forest of EHRP, where deer are repeatedly

browsing (and destroying) residents’ gardens.

Another benefit of deer and pigs being in the Site-led control category is that it provides the opportunity for Greater

Wellington to spell out what education, advice and support they will provide to landowners, occupiers, and the public

about these pest animals, including the threat they pose to the KNE, and how to control them. Controlling deer on

residential properties is challenging for landowners, so Greater Wellington advice and support is essential.

For these reasons deer and pigs need to be reinstated to the Site-led Pest category in the RPMP.

Page | 60

Deer and pigs need to be a priority for pest control because of the damage they cause in some KNEs

The current GW Pest Management Strategy’s reason for including deer as a pest was:

“Feral deer are of concern to Greater Wellington in actively managed Key Native Ecosystems or reserves where considerable

investment has been previously made by Greater Wellington and/or the landowner/occupier. Deer are highly adaptable

feeders that both browse and graze. Although deer can live entirely on grass, studies show that for red deer living in heavily

forested regions, trees, shrubs and herbs make up to 80% of their diet. This has a high impact on forest regeneration and

biodiversity. Intensive browsing can devastate the forest under-storey and strip bark from trees, severely impacting plant

biodiversity. Stags thrashing and rubbing with their antlers also damage vegetation. Feral deer contribute to soil erosion

through intensive browsing, soil trampling, compaction and wallowing.”

If we take the example of EHRP, GW’s concern is borne out—selective browsing of the understorey by deer has done

significant damage to vulnerable species for a number of years, including wiping out Kirk’s Tree Daisy and Raukawa.

Some of the browsed plants are key for providing food for iconic species, such as bellbirds, in the winter months. The

GW Biodiversity Strategy’s first Goal is that “areas of high biodiversity value [i.e. KNEs] are protected or restored”. This

goal is clearly not being met in EHRP.

Part of the problem here is that some recreational hunters (and others) still believe that we can achieve a balance

point where the level of browsing damage is acceptable and there are sufficient deer for hunting. This clearly is not

the case: current damage is not acceptable and kill returns from the balloted hunting area are near-zero (in 6 weeks),

while the professional hunters working near built-up areas on the western flank average roughly 7–8 kills per year (in

1-2 weeks).

In our view, the only way we will achieve the Biodiversity Strategy’s first Goal is to use professional hunters more

frequently while also looking at alternative control methods close to dwellings. So in certain KNEs, deer control needs

to be a priority under the RPMP. The arguments are similar for pigs, although the types and distribution of damage are

different.

How do these decisions affect conservation volunteers and the local population?

Thanks to great support from GW staff, MIRO is close to having possums, mustelids and feral cats controlled across

most of the Northern Forest of EHRP, with a feral cat network being rolled out over the next few months. For some

MIRO members, controlling these pest animals has been a 20-year effort. For some time, we have been contemplating

what we had seen as the remaining challenge in restoring the forest—controlling the rat population. While this cannot

be done in an affordable or sustainable way at present, technological advances such as self-resetting traps, trap-trigger

signalling, automated visual recognition of pests, and smart trapping approaches using spatial information systems are

likely to make this possible within a decade or so. Once rat control is achieved, the forest would then be ready for the

reintroduction of iconic species such as North Island Robin and Kokako.

If the control of deer and pigs in KNE areas is not to be a priority, the above efforts will be wasted, and the vision of a

fully-restored forest will never be achieved.

Predator Free Wellington

It is encouraging to see Greater Wellington getting involved in the Predator Free Wellington project and supporting

local urban trapping efforts. There is a real opportunity here to use these local volunteers to extend trapping into

nearby reserve areas so that full coverage of the city area is achieved—this should be mentioned in the RPMP.

Page | 61

Given the 20-year timeframe of this plan and the speed with which local trapping groups are being formed, the RPMP

needs to recognise that, in time, the support of local trapping needs to be extended much more widely than just

Wellington City.

Terry Webb, Chair MIRO

20 July 2018

Page | 62

043 Williams, Anna To Pest Plan Inbox 20-07-18

Your Contact details:

NAME:* Anna Williams

Is there a reason that feral pigs, and didymo are not included as pest species to be managed? Greater Wellington

region does seem to be very 'weedy'. I support a greater emphasis on management of the weed-species and

revegetation with appropriate native flora to restore habitat. I also support effective and ongoing pest-animal

control, to allow our indigenous fauna to recover, be reintroduced (where appropriate), and flourish. I am

supportive of the vision of Predator Free Wellington, but believe that we have a real problem also with pest cats,

which we need to deal with.

Page | 63

044 Predator Free Miramar Henry, Dan


Name

Dan Henry


Predator Free Miramar

Email

[email protected]

Street address

170 Darlington Road, Miramar

Suburb

Wellington

Postcode

6022

Phone Number

+6421355848

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Page | 64



Page | 65

045 Martin, Jane To Pest Plan Inbox 20-07-18

Name

Jane Martin

Email

[email protected]

Street address

58 Norway Street

Suburb

Aro Valley

Postcode

6012

Phone Number

0224156694

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 66

046 Peoples, Ramona To Pest Plan Inbox 21-07-18

Name

Ramona Peoples

Email

[email protected]

Street address

35 Banchory Road

Suburb

Blackheath

Postcode

SE3 8SL

Phone Number

07966741297

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 67

047 Perrie, Leon To Pest Plan Inbox 21-07-18

Name

Leon Perrie

Email

[email protected]

Street address

26 Thane Road

Suburb

Wellington

Postcode

6011

Phone Number

0274191378

Pest cats





Possums


Hedgehogs



Mustelids



Rats



Deer and pigs do significant damage to native biodiversity. They are pests and should be listed in Table 4.1. Right now, they should be under site-led control within all Key Native Ecosytems and substantial buffers around these. With time, deer and pigs should become contained within areas specifically designated for hunting them, with eradication and exclusion from elsewhere.

The list of plants on Table 4.1 is small, and shows an embarrassing lack of ambition by GWRC. Many more plant species in the Wellington region should be subject to control/eradication.




Page | 68

048 Rafter, Sonia To Pest Plan Inbox 22-07-18

Name

Sonia Rafter

Email

[email protected]

Street address

12 Upoko Road

Suburb

Hataitai

Postcode

6021

Phone Number

0272123062

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 69

049 Gary, James To Pest Plan Inbox 22-07-18

Gary JAMES

6 Momona Street

Parkway

Wainuiomata

Lower Hutt 5014

Tel: 021-2866282

Email: [email protected]

GWRC Pest Control Submission

I support the plan in principal but would like to following to be taken into consideration:

2.3.2:

Predator Free 2050

I would like to see a greater commitment from the plan towards an overall regional plan towards the 2050

goal as regional wide program of how we will get there.

I think a goal of linking up the areas currently with pest control activities to provide a continuous front of

control to help stop/slow reinvasion should be explored, planned for and led by GWRC.

4.1

Pest plants add the following species to the control list

Japanese honeysuckle (Lonicera japonica) program : eradication region wide

Sweet cherry (Prunus avium) program: eradication region wide

Hawthorn (Crataegus monogyna) program: site led eg Hutt Valley, Wainuiomata.

Climbing asparagus (Asparagus scandens) program: site led eg Te Whitit Park Lower Hutt, Ngaio gorge

Wellington

Pest animals

Red deer (Cervus elaphus) program: sustained control

Possum (Trichosurus vulpecula) program: eradication status

Build upon the Miramar success in eradication and plan for region wide eradication.

Feral goat (Capra hircus) program: progressive containment

Funding: a commitment by the GWRC to increase the pest management budget by 5% each year over the

plans budgeted figures.


Page | 70

050 McNeill, Florence To Pest Plan Inbox 23-07-18

Name

Florence McNeill

Email

[email protected]

Street address

137 Tilley Road

Suburb

Paekakariki

Postcode

5034

Phone Number

021 139 3581

Pest cats






Possums



Rule 1 for possums should also state the people should not release possums into any Key Native Ecosystem.

Hedgehogs



Mustelids



Rats


Page | 71




Page | 72

051 Rogers, Amanda To Pest Plan Inbox 24-07-18

Name

Amanda Rogers

Email

[email protected]

Street address

26A Brighton St

Suburb

Island Bay

Postcode

6023

Phone Number

02102355239

Pest cats




I propose the definition of pest cats to be changed to clearly include all free roaming, i.e. uncontained cats.


Possums



Hedgehogs



Mustelids



Rats



Page | 73



Page | 74

052 Munn, Jordan To Pest Plan Inbox 24-07-18

Name

Jordan Munn

Email

[email protected]

Street address

534 Flux Road

Suburb

Mangaroa

Postcode

5371

Phone Number

027 3376084

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 75

I would like to see flexibility around the use of council owned land for recreational hunting.

The current open hunting areas are hard to reach places and cause a funnel effect with hunters.

When attempting to go for a recreational hunt after work, there is only one local area that we can access in time to actively

hunt before the day ends.

Many areas like, parts of Mt Clyme, tunnel gully, Rimutaka s, amd the East Harbour Park are close or so restricted that we generally don’t access them. If these restrictions are for H&S reasons, I would like to see some examples that have forced the restrictions.

The forestry’s are also a key areas with a high population of large pest species damaging the forests. Large companies like earnslaw one, Reioners or Wenita are large commercial forestry comanies with a successful permitting system.



Page | 76

053 Confidential To Pest Plan Inbox 24-07-18

I fully support the GWRC developing and managing a comprehensive pest management plan and generally

support the proposed plan.

However, I do very much question the listing of rooks and magpies as a pest. There are a lot of urban myths

in NZ about these birds and the damage they are supposed to be doing is often unsubstantiated. Most people

who hold these beliefs and tell these stories have never witnessed any incidences themselves or may just

have read the occasional news article about a problematic individual bird. These birds have an important

role in insect and pest control and there are advantages in having them around.

In my experience, magpies may pose the occasional nuisance when there is open grassland with very few

trees. It's only during breeding season when they may become territorial in this type of landscape - but it's

not a given. However, when there are more trees, they are pretty relaxed and blend in very well with other

birds. They will chase away hawks (but other birds will do this too) but leave other exotic and native birds

alone. The only birds I've seen attacking and killing other birds are tuis, especially during breeding season

and when there is a shortage of food. So is GWRC planning to list tuis as a pest or nuisance as well?

The blanket removal of rooks where ever they appear is outrageous and unnecessary.

I recommend that both rooks and magpies are removed from GWRC's proposed pest management list. The

only reason for controlling individual birds is when there is substantiated and significant evidence that the

disadvantages of their presence outweigh their advantages.

Page | 77

054 Wellington Fish & Game Kavermann, Matt


Please find the submission from the Wellington Fish and Game Council.

Please note that there are some biological inaccuracies within the Impact Assessment and Cost Benefit Analysis 2019-2039, notably:

1. Trapping is not the most effective control method for mustelids. Poisoning operations have far greater impact on mustelid populations (Pg. 167)

2. Mustelids are most readily caught in late spring/early summer when naive juveniles are most active (Pg. 167) 3. Cats are present in many wetlands in New Zealand (as identified in the attribute table on page 173) and their

current and potential land use infested should be considered Low (Pg. 174)

The Wellington Fish and Game Council does not wish to be heard in support of our submission.

Regards,

Dr Matt Kavermann | Senior Fish & Game Officer

Wellington Fish & Game Council 292 Featherston Street, Palmerston North | PO Box 1325 Palmerston North 4440

P +64 6 359 0409 | M +64 21 688 346

Page | 78

24 July 2018

The Proposed Regional Pest Management Plan

Greater Wellington Regional Council

PO Box 11646

Wellington 6142.

l. This is a submission from the Wellington Fish and Game Council on the Greater Wellington

proposed regional pest management plan.

2. The Wellington Fish and Game Council {"Fish and Gam e" ) is the statutory manager of sports

fish and gamebirds within the Greater Wellington Region. It will be a requirement to include Fish

and Game in any planning, decision making or act ion regarding these species.

3. Fish and Game t herefore expect to be consul ted regarding any involving the species under

their management.

4. Fish and Game generally sup por ts the site -lead programs (Table 8) t o cont rol Mustelids

(Mustelafuro, M. erminea and M. nivalis) and pest cats (Fe/is catus) where outcome

monitoring of these programs is undertaken and shown to be achieving the goals of the

con tro l program.

5. However, Fish and Game would suggest that more regular monitoring be undertaken than

that outline on page 80 to assess t h e effectiveness of the site-lead mammalian contro l

programs {5.3 Principal measures to manage pests, 2{d)).

6. Fish and Game also has concerns that outcome monitoring focuses on a measure of relat iv e

density of the pest species (as measured by tracking tunnels, pg. 80) as opposed to the

outcome of sup ressing or er ad icat in g the mammalian pest' s population. Instead Fish and

Game recommends out come monitoring focused on biodiversit y benefits such as fledgling

success or the recovery of a targeted species populat ion to ensure the pest cont rol

operat ion s are spat iall y suff icie nt, and of great enough int ensity, to meet the objectives of

the plan.

7. Fish and Game requests to be listed as a key interested group for any reviews on the

effectiveness of the pl an.

8. Fish an d Gam e are w i lling to w ork with all agenc ies that have a goal of managing predators

or pests that affect the fish and game resource.

Phi l Tea l

Manager

Wellington Fish and Game Council

Statutory managers of freshwater sports fish, game birds and their habitats

Telephone (06) 359 0409 Facs,mllc (06) 356 2780

En,all· [email protected] 111 www f1shandgame org ru


Page | 79

055 Kerridge, Bob To Pest Plan Inbox 24-07-18

TO WHOM IT MAY CONCERN

Attached you will find the submission form confirming my contact details together with my full

submission to the Greater Wellington Regional Pest Management Plan. Please confirm receipt of this.

With regards to being heard in support of this submission please note at this stage that I hope to be

represented in support.

Thank you

BOB KERRIDGE, ONZM., KStJ., JP., FNZIM., BAppAnTech.

Animal welfarist.

Villa 2 Mary Doyle, 3 Karanema Drive, Havelock North 4130, Hawke's Bay

Telephone: (06) 873 8422. Mobile: 0274 959 449

"ANIMALS SHARE WITH US THE PRIVILEGE OF HAVING A SOUL"

(Pythagorous - 570 - 495 BC)

Greetings

Further to my email below I can now advise that Mr Kent Duston, (021 536 873 -

[email protected] ) will be representing me and will make an oral presentation in support of

this submission. Please confirm your understanding and advise me directly when his oral

presentation can be made,

Sincerely


Page | 80

SUBMISSION TO THE GREATER WELLINGTON COUNCIL REFIONAL PEST

MANAGEMENT PLAN – 2019 – 2039

FROM BOB KERRIDGE, ONZM., KSt.J., JP., FNZM., BAppAnTech – ANIMAL WELFARIST

NOTES TO ACCOMPANY SUBMISSION

These appear in the order of the RPMP as printed and circulated with the subject matter being addressed

appearing in bold type and taken directly from the report.

1.0 PEST CAT (Felis catus)

This appears in the Index to the report, and as the heading within the document and is incorrect and therefore

needs to be deleted completely.

This is not a recognised cat descriptor. The Code of Welfare for Cats, (2007), approved by

the Minister for Primary Industries, following a full consultation process through the National

Animal Welfare Advisory Committee, (NAWAC), defines cats in three legally recognised

categories namely:

COMPANION CATS

STRAY CATS

FERAL CATS

The first two categories of cats are fully protected under the Animal Welfare Act, (1999), with only feral

cats being designated as pests under the Biosecurity Act, (1993), and only they can be legally referred to as

‘pests’.

No Territorial Authority has either the legal authority or the power to alter the existing

classification of cats in the Code of Welfare for Cats as approved by statute. To achieve this

it would be necessary for the appropriate Minister to approve such a change by following the

normal procedure as outlined, namely to seek public input and that of his Government

advisers, and to physically alter the Code of Welfare into law. The category suggested of

pest cat is unlawful.

The term ‘pest’ can only be conferred on a ‘notifiable organism’ under the Biosecurity Act by

the Governor General on the recommendation of the appropriate Minister in charge, if he is

satisfied that it is in the public interest to do so. Accordingly no Territorial Authority has the

authority on its own to use the term ‘pest cats’ unless it has been approved by Order of

Council at the highest leve.

If the Greater Wellington Regional Council persists with the use of the words ‘pest cats’ in

this document, it will be subject to a probable legal challenge that has every chance of

succeeding.

To quote the American Bar Association and the law surrounding feral (and pest) status:

“Issues arise when Government agencies attempt to define cats as feral, (pests), for

management and control purposes while disregarding ownership status, anti-cruelty

provisions and public opinion. This approach has led to drastically disparate treatment of

community (companion and stray) cats under the law”.

Page | 81

For the sake of accuracy in determining the action required in the drafting of the Regional

Pest Management Plan, and the reason the Code of Welfare for Cats exists with the three

categories of cats as defined, is that biologically these populations are distinct from each

other requiring different management practices. This is particularly important in the case of

stray v’s feral cats where stray cats are dependent on humans to a greater degree and

therefore seek out human habitation to satisfy their needs. This needs to be recognised in any

management plan.

The attempt to use the terminology of pests when describing cats is an attempt by the

Regional Council to make their task less complicated, as any species of animal that is

branded in this way is not protected under the Animal Welfare Act, and therefore not subject

to the humane treatment for animals as required under that Act. This means that the Council

need not identify what type of cat they are dealing with, and may devise methods of

destruction for these animals that are inhumane and not subject to regulatory scrutiny as

would normally be required. It is abhorrent to any feeling human being to imagine that

council would wish to create laws that would be responsible for the inhumane destruction of

any sentient being the term ‘pest’ would allow.

Reading 7.4 (pg. 173) of the Greater Wellington RPMP, under ‘current situation’ which reads

‘To support the control of feral and stray cats in the Wellington Region, it is proposed to

include ‘pest cats; in the plan’. This reflects the proposed outcome of the NCMSG, that there

will be no feral or stray cats in New Zealand, which it would appear council has, unwisely,

taken completely on board.

Council’s intent is clear, and that is to include stray cats with feral cats, and to re-label them collectively as

pest cats in one new category. This

Page | 82

056 Falkner, Richard To Pest Plan Inbox 24-07-18

Name

Richard Falkner


Richard Falkner

Email

[email protected]

Street address

7 Murphy Place

Suburb

Porirua

Postcode

5022

Phone Number

0212053515

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Page | 83


I think cats should be registered in the same way as dogs. This would help control them as a pest, and help contribute to finding their control.



Page | 84

057 Wilcox, Sarah To Pest Plan Inbox 24-07-18

Name

Sarah Wilcox

Email

[email protected]

Street address

15 st Michaels cres

Suburb

Kelburn

Postcode

6012

Phone Number

0272677586

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 85

058 Renyard, Ashlyn To Pest Plan Inbox 24-07-18

Name

Ashlyn Renyard

Email

[email protected]

Street address

184 Lockington Road, RD 4, Aongatete

Suburb

Katikati

Postcode

3181

Phone Number

+64274949066

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 86

059 Trelissick Park Group Reimann, Peter


Name: Peter Reimann (Chairman)

Organisation: Trelissick Park Group

Address: c/- 51 Heke Street, Ngaio, Wellington 6035.

Phone: 04 938 9602


.

The Trelissick Park Group has been actively supporting pest management in the Wellington City

Trelissick Park (and some adjacent areas) for more than 25 years. This group of volunteers has provided

countless hours during that period to help control pest plants - by their removal and replacement with native

plants. And in the recent ten or more years much volunteer effort has gone into the control of pest animals.

We strongly support the Regional Council in their planning for the next twenty years of pest management –

and hope that volunteer groups like the Trelissick Park Group can be kept involved with collaborative efforts

– with the Wellington Regional Council and the Wellington City Council.

Some comments on the Plan are below:

- Trelissick Park should again become a Key Native Ecosystem because it contains one of the few original

forest remnants within Wellington City.

- There has been an increase in rabbits in Trelissick Park – we need some practical approaches to rabbit

control.

- We have perceived an increase in the rat population in the past year, even with increased residential efforts

to control rats in the surrounding areas. This is possibly a result of making the Park more dog friendly

without dogs being kept under the required control off-track. To avoid dogs eating bait pellets we switched

to block bait in bait stations. However, this has adversely affected rat control because rats can no longer

remove pellets to horde in nests and access for Norway rats is more difficult.

- We need more clarity for City (WCC) roles within GWRC in pest animal control and management.

- Information is sparse on how we should monitor pest animals. We would like to make it more available to

all who are involved in pest management.

- The prevalence of Old Man’s Beard is on the increase in Wellington City. We are disappointed that

GWRC are no longer controlling this.

- We are surprised that control of climbing asparagus in not included - e.g. there are bad infestations in the

forest of the lower eastern Hutt hills. (WCC is tackling it in Trelissick Park on the slopes below Oban

Street).

Some of these comments were amplified in our 2017 submission -

see http://www.trelissickpark.org.nz/Newsletters/Submission%2014Jun2017.pdf.

We do not wish to speak to this submission.

Regards,

Peter Reimann

Trelissick Park Group

https://www.facebook.com/TrelissickParkGroup

http://www.trelissickpark.org.nz/


http://www.trelissickpark.org.nz/Newsletters/Submission%2014Jun2017.pdf

https://www.facebook.com/TrelissickParkGroup

http://www.trelissickpark.org.nz/

Page | 87

060 Legg, Jesse To Pest Plan Inbox 24-07-18

Name

Jesse Legg

Email

[email protected]

Street address

2 stowe hill

Suburb

Thorndon

Postcode

6012

Phone Number

02041362656

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate

populations of native species including birds, bats, lizards and insects. Cats have no natural predators in

New Zealand so humans need to control their numbers. Without management cats undermine any predator

control work undertaken by council and community groups.


I propose the definition of pest cats to be changed to clearly include all unowned cats. My suggested

definition of a pest cat is: “a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I

suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter

to cats on private or public land within the Wellington Region, without the permission of the occupier.”

Possums


Possums significantly impact both primary production and biodiversity and controlling their population is

an important regional goal. Urban control is also important to prevent reinvasion into both significant

ecological areas and the rural landscape.

Hedgehogs


Page | 88

I agree with European hedgehogs being defined as site-led pests and support their inclusion in the plan.

Hedgehogs have serious impacts on lizard and invertebrate populations and eat the eggs of ground nesting

birds. More public education is needed around the impacts hedgehogs have on our native biodiversity.

Rule 1 for hedgehogs should also state the people should not release hedgehogs into any Key Native

Ecosystem.

Mustelids

I agree with mustelids (stoats, ferrets and weasels) being defined as site-led and for the ambitious goal to

eradicate them from areas within the Predator Free Wellington initiative.

An additional rule should be added to make it clear that releasing a mustelid within the Wellington Region

is an offence.

Rats




Page | 89

061 Turnbull, Duncan To Pest Plan Inbox 24-07-18

Name

Duncan Tunbull

Email

[email protected]

Street address

1 Estuary St

Suburb

Makara Beach

Postcode

6972

Phone Number

0274762661

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 90

062 Tomii, Nobushige To Pest Plan Inbox 24-07-18

Name

Nobushige Tomii

Email

[email protected]

Street address

4 Riverton Place

Suburb

Hamilton

Postcode

3214

Phone Number

0223198872

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate

populations of native species including birds, bats, lizards and insects. Cats have no natural predators in

New Zealand so humans need to control their numbers. Without management cats undermine any predator

control work undertaken by council and community groups.


I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested

definition of a pest cat is: “a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I

suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter

to cats on private or public land within the Wellington Region, without the permission of the occupier.”

Possums


Possums significantly impact both primary production and biodiversity and controlling their population is

an important regional goal. Urban control is also important to prevent reinvasion into both significant

ecological areas and the rural landscape.

Hedgehogs


Page | 91





Ecosystem.

Mustelids



An additional rule should be added to make it clear that releasing a mustelid within the Wellington Region

is an offense, and set a tough penalty against it.

Rats

I support the inclusion of rats (Norway and ship) as well as mice for site-led pests to be controlled at

specific sites.


I applaud the Greater Wellington Regional Council's proposal to identify cats as pests. This step is

absolutely essential to protect native wildlife in this country.

When it's implemented, it will become a model case for future pest management in other regions as well.

So it is very important to set an example of tough / robust pest management policy.

Please make a bold move and lead the way to achieving a "Predator Free New Zealand"

Best regards.



Page | 92

063 Vink, Hetty To Pest Plan Inbox 24-07-18

Name

Hetty Vink

Email

[email protected]

Street address

134 Tirohanga Rd

Suburb

Tirohanga

Postcode

5010

Phone Number

027 6041335

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Page | 93



Page | 94

064 Brusen, John To Pest Plan Inbox 24-07-18

Name

John Brusen

Email

[email protected]

Street address

63 Branch Rd.

Suburb

New Plymouth

Postcode

4312

Phone Number

069293192

Pest cats




I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat

is: “a cat without a registered microchip”.


Possums



Hedgehogs



Mustelids



Rats


Page | 95



I would like the initiatives above to be implemented in all areas of New Zealand eventually. The Wellington area is a good start, but other wild areas, including private property, should also be included.



Page | 96

065 Tocker, Warren To Pest Plan Inbox 25-07-18

Name

Warren Tocker

Email

[email protected]

Street address

22 Hay Street, Wellington

Suburb

Wellington

Postcode

6011

Phone Number

+6421445983

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 97

066 Bell, Ann To Pest Plan Inbox 25-07-18

Name

Ann Bell

Email

[email protected]

Street address

45, Gurney Road,

Suburb

Kelson,

Postcode

5010

Phone Number

5650924

Pest cats




I propose the definition of pest cats to be change to clearly include all unowned cats., which are clearly and unambiguously owned by a person or persons. I do not agree that all such cats should be microchipped. I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on private or public land within the Wellington Region, without the permission of the occupier.”

Possums



Hedgehogs



Mustelids

I agree with mustelids (stoats, ferrets and weasels) being defined as site-led and for the ambitious goal to eradicate them from

areas within the Predator Free Wellington initiative.


Rats




Page | 98

I think that it is counter productive to insist that cats should be microchipped. I think that by demonising cats (even though they are clearly predators), will be counter productive to the main aim of increasing bird populations. Well fed domestic cats sleep for about 70%+ of the day. Feral or abandoned cats are clearly going to hunt for food, They should be neutered and homed, or humanely killed.



Page | 99

067 Auld, Nicky To Pest Plan Inbox 25-07-18

Name

Nicky Auld

Email

[email protected]

Street address

165 Fitzpatrick road, Brookby

Suburb

Manurewa, South Auckland

Postcode

2576

Phone Number

021972534

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 100

Wellington has a resident endangered Kaka Population which needs extensive areas of pest free vegetation. Where else NZ can you see & hear Kaka flying around an inner city park. (All land ownership types of vegetation need to be covered for pest control) Ie Urban, rural, doc, council parks and private gardens and farms, etc. They also visit outer island depending on food sources available. They live in old native forests often on ridge lines, and live & nest in large holes in old trees. This is were protection from Cats, Rats, Possums and stoats is critical. They are often very noisy in pine plantations in the winter months, feeding on

pine cones, insects etc. They are probably feeding on the ground and are at risks during this time from all pest. Wellington's old pine trees provide habitat for these birds and should not be chopped down and should also be targeted for pest control.



Page | 101

068 Keall, Susan To Pest Plan Inbox

Name

Susan Keall

Email

[email protected]

Street address

67 Volga St

Suburb

Island Bay

Postcode

6023

Phone Number

4635324

Pest cats






Possums



Hedgehogs



Mustelids



Rats



I would like to see a plan to control Tradescantia around Wellington City. It is pervasive in many areas of the green belt and suppresses native seedling germination, and also causes allergic reactions to dogs that come into contact with it.


Page | 102



Page | 103

069 Thrift, Andrew To Pest Plan Inbox 25-07-18

Name

Andrew Thrift

Email

[email protected]

Street address

12a, Coolidge Street

Suburb

Brooklyn

Postcode

6021

Phone Number

0272 730 955

Pest cats



I have seen cats live perfectly happily indoors as "flat cats" when I lived in London and other cities, allowing them to roam at night should be made illegal in NZ.




Possums



I have no problem with the use of 1080 as a method of control.

Hedgehogs



Mustelids



Rats



Page | 104


I would strongly suggest that Tradescantia be added to the list of pest plants to be controlled, this plant is widespread and suppresses native growth and can lead to land slips. It is also noxious and ugly.



Page | 105

070 Martinson, Paul To Pest Plan Inbox 25-07-18

Name

Paul Martinson

Email

[email protected]

Street address

86 Essex Street

Suburb

Masterton

Postcode

5810

Phone Number

0276378890

Pest cats






Possums



Hedgehogs



Mustelids



Rats



Page | 106


Cats are the third most significant causal factor of avian extinction in NZ, but still no law controlling them. Cats need to be micro-chipped and identifiable with an owner. Until that time there is no sure way of distinguishing feral, stray and owned animals from each other. Many 'owned cats are killed as a result. Cat control is essential. Please introduce it.



Page | 107

071 Dawes, Mallory To Pest Plan Inbox 25-07-18

Name

Mallory Dawes

Email

[email protected]

Street address

42 Jacksons Line, RD2

Suburb

Masterton

Postcode

5882

Phone Number

0274180934

Pest cats






Possums



Hedgehogs



Mustelids



Rats





Page | 108

072 Petzen, Daniel To Pest Plan Inbox 25-07-18

Name

Daniel Petzen

Email

[email protected]

Street address

33a Kopara Grove, Stokes Valley

Suburb

LOWER HUTT

Postcode

5019

Phone Number

0221930086

Pest cats







Possums



Hedgehogs



Mustelids



Rats



Page | 109


More effort should be put into controlling all types of rats and mice. I've trapped around 15 mice and 3 rats in the last 8-10 months in my small garden. The best option is most likely to get more people involved in setting traps in their own gardens.



Page | 110

073 Thrasher,Susan To Pest Plan Inbox 25-07-18

Submission, Wellington Regional Council, Regional Pest Management Plan 2019-2039

My Contact Details:

Susan Thrasher

34 Bluegum Road

Paraparaumu Beach 5032

Ph 0274948506


This is my first time making a submission.

I reside in the Kapiti Coast District Council area.

My reasons for making this submission:

Kia ora—

I have been a resident in the Wellington region for 38 years, and have lived in Eastbourne, Lower Hutt,

Wainuiomata, and now up on the Kapiti Coast. I have lived on a lifestyle block (Moores Valley), adjacent to

bush (Lower Hutt Western Hills, Eastbourne), and in coastal areas (Eastbourne, Paraparaumu Beach). I am a

keen walker and nature observer, and I have been for pretty much all of my life.

I believe the pest management plan begins with an assumption that is not necessarily sound: that so-called

“pests” negatively impact and inhibit our native diversity. Yes, they can have an “economic impact” of

course, and of course there may be situations where the particular abundance of a species can influence what

we, as humans, want nature to look like. But that is all human-centric and subjective.

That aside, probably my biggest concern with the pest management plan as proposed is that it talks about the

“control” or “eradication” of a large number of species, both plant and animal, without sharing the detail of

how this is to be done. I am increasingly alarmed at the rampant—and often indiscriminate—use of poisons

in our environment. No poisons are species-specific, and all have an environmental impact and fallout

beyond their target. 1080 and Roundup (glyphosate) get some media attention, probably because they are so

often applied aerially, and there is clear evidence that they are hazardous for human health and can affect the

health of our pets and livestock. Fewer people grapple with, or protest about, difficult-to-pronounce-and-

remember names like brodificoum and Pindone, both anti-coagulant Vitamin-K inhibitors that are often used

as ground bait. And then there are the plant poisons with trade names like Conquest, Kamba 500, and

Terminate, many of these glyphosate-based like Roundup. These are most commonly sprayed with guns

from the ground, a less-visible application and covering smaller areas than aerial sprays, but still affecting

many plants and animals beyond the target species.

None of these poisons are good for the environment, or for us. Our politicians talk about the desire for clean

water, then I see roadside and curbside weed-spraying and know that the residue and run-off goes right into

our streams, rivers, lakes, estuaries, and ocean when it rains. Parks are sprayed, and then our children and

our dogs play there. A few places in the world have gone to using steam to fight unwanted vegetation, which

of course is non-toxic and not residual, or they rely on good, old Weedeaters. Why is that so hard?

If we must pick species to control—and I wish we didn’t do that quite so readily, but I recognize that’s a

minority viewpoint—can we at least control our unwanted wildlife (plants and animals) without zealously


Page | 111

using a bevy of toxic chemicals that contaminate the environment?

Over the years I have noted a general decline in both native and non-native species. When I lived in

Eastbourne thirty years ago, we often had a dozen or more tui in the garden in the spring, sometimes all in

one kowhai tree at once, and kereru were constantly seen soaring over the house. Fantails fluttered about the

clothes line. Flocks of silvereyes and little grey warblers were frequent garden visitors. Ruru called almost

every night, and so did the possums. Hedgehogs regularly ambled through the garden. There were skinks

and weta, deer and wild pig up the hillside in the bush out the back. We had banana passionfruit growing on

the back of the section (the fruit of which we ate, after admiring the gorgeous pink flowers), and a gloriously

beautiful bunch of kahili ginger right in the front of the house perfuming the garden (both plants sadly

destroyed by zealous WRC “pest” exterminators, making us feel both resentful, and like criminals for daring

to like them). The first time I saw a poisoned possum with its still-alive joey at the foot of a tree by our

house, I was distraught. I look back on the time before such rampant poisoning of “pest” plants and animals,

as a sort of environmental “golden age” never to be seen again in New Zealand.

Today I live on the Kapiti coast in a modest house that is no longer close to “native” bush, though I have the

beach nearby. I also have a garden full of sparrows and starlings, which is fine, but even when I go into the

bush, or walking in Queen Elizabeth Park, or through the Waikanae Estuary (which I do often), I am

saddened by many of the “managed” areas (which they all are these days), and I bemoan the constant spray

and cull of vegetation, to be replaced by “native” plants protected by plastic sleeves. I see no beauty in dead,

brown/grey gorse that has been sprayed (as an example, photos below taken at Waikanae Estuary last week),

and I am saddened that these dead areas are rendered no longer safe, useful places for birds and spiders to

nest, nor for bees and insects to gather pollen and nectar, and that the nitrogen fixing (repair) of the soil that

gorse does so well is apparently not wanted. As for the plastic “bags”…

Page | 112

Lastly, I’d like to say I object to eradication plans (no doubt by poison) of the Wellington region’s rooks.

While I do not reside in the Wairarapa region where they are living, I have great respect for corvids; they

are highly intelligent birds. As insect-eaters, they are as likely to be raiding farmers’ fields for grass grubs as

they are damaging grain crops in summer. And if the primary reason for wanting to kill them is simply that

they are not native… Sad in the extreme. I also object to the inclusion of hedge hogs on the pest list.

Personally, I have always felt honoured to be visited by these delightful little animals in my garden, and am

happy to share my [unpoisoned] snails with them. I haven’t seen one in quite a while, though. In the UK,

hedgehogs are in long-term decline with an estimated population now of maybe just a million, down from

an estimated 30 million in the 1950’s, according to a recent Guardian article. Agricultural intensification

and the use of pesticides affecting their food supply are blamed. And I’ll also stick in a plea here for the

poor, over-vilified possums, who are far less a threat than the tonnes of toxins spread across the country in

the name of killing them.

In short: Less killing, please, and fewer toxins.

I appreciate having the opportunity to share my views. Thank you.

Regards,

Susan Thrasher

Page | 113

074 NZ Cat Coalition Duston, Kent


Submission on the Greater Wellington Regional Council Regional

Pest Management Plan (RPMP)

This submission is made by Kent Duston, co-convener of the NZ Cat Coalition, and solely concerns the

classification of cats and their management within the RPMP.

I wish to make an oral submission in support of this document. My contact details are at the end of this

document.

My submission is that:

1. The classification of “pest cat” is not supported in legislation and has no legal authority

2. No evidence is provided to back the assertion that cats are a growing problem in the GWRC area

3. There is no evidential link provided between the problems stated and the interventions proposed

4. The cost-benefit analysis provided is not methodologically sound, is highly unlikely to be accurate,

and cannot be depended upon by decision-makers.

I will address each of these point in turn.

Recommendations

Our recommendations are that:

1. The category of “pest cat” is removed from the RPMP and the technically correct term of “feral cat” is

reinstated, in keeping with the previous version of the RPMP, to ensure GWRC remains within its

delegated legislative authority

2. The RPMP is altered to reflect the evidence-based approach in relation to the assessment and

management of feral cats, as described below.

Pest cat classification

The RPMP contains a classification of “pest cat”. This does not exist in law, nor does GWRC have the legal

authority to introduce such a classification.

In 2007 the Code of Welfare for Cats was approved by the Minister for Primary Industries following a full

consultation process through the National Animal Welfare Advisory Committee (NAWAC). Three

classifications are now the official legally recognised categories by which cats must be described:

• Companion – Common domestic cat (including a kitten) that lives with humans as a companion and

is dependent on humans for its welfare.

• Stray – A companion cat which is lost or abandoned and which is living as an individual or in a

group (colony). Stray cats have many of their needs indirectly supplied by humans, and live around

centres of human habitation. Stray cats are likely to interbreed with the unneutered companion cat

population.

• Feral – A cat which is not a stray cat and which has none of its needs provided by humans. Feral

cats generally do not live around centres of human habitation. Feral cat population size generally

fluctuates largely independent of humans, is self-sustaining and is not dependent on input from the

companion cat population.

Page | 114

Great care was taken in the writing of the Code of Welfare for Cats in defining these three categories, as

biologically these populations are distinct from each other and require different management practices. This

is particularly important in the case of stray cats versus feral, where stray cats are dependent on humans to a

greater degree, and accordingly seeking out human habitation to satisfy their needs.

Under the current laws stray cats are protected under the Animal Welfare Act, 1999. As cats are devoid of

territorial boundaries, they tend to wander and some may stray outside of their own home boundaries. This

straying behaviour does not amount to them being “feral cats” as defined in the Code of Welfare.

Altering the classification of cats

In the proposed RPMP, GWRC attempts to modify the current legal categories of cats by conflating stray

cats with feral cats by using a new “pest cat” definition.

Creating a category of “pest cat” has wide ramifications, in that with this name change both stray and feral

cats are automatically branded as pests, with a new set of controls applying. The use of the term “pest”

makes

the task of GWRC less complicated, as any such animal given this title is not protected under the Animal

Welfare Act 1999, and is therefore not subject to the humane treatment for animals as required under that

Act.

It is apparent that Territorial Authorities have neither the legal authority nor the power to alter the existing

classifications of cats in the Code of Welfare for Cats, as this is approved by statute. To create a new

category of cat, it would be necessary for the responsible Minister to approve such a change by going

through the normal process of agreeing to it after recommendation by officials, seeking public input prior

to approving it, and altering the Code of Welfare in law as appropriate.

Should any Territorial Authority unilaterally seek to alter the existing classifications, they will risk legal

challenge by way of judicial review, on the basis that the decision to reclassify cats amounts to an ultra vires

act.

There are further serious complications involved in using this terminology. Under the Biosecurity Act 1993,

the designation of “pest” can only be conferred on a notifiable organism by the Governor General on the

recommendation of the responsible Minister in charge. Only after this has been done can a declared pest be

administered in an RPMP under the Biosecurity Act. The Minister can only consider this if asked by the

Regional Council concerned, and only if the Minister is satisfied that it is in the public interest to do so.

Without this legal designation by Order in Council, any Territorial Authority who wishes to classify cats as a

“pest” will have neither the legal authority nor the power to do so, unless the Minister has it approved.

For GWRC to unilaterally proceed with reclassification in the absence of legislative authority, Order in

Council or Ministerial support would seem to be a particularly brave step.

Interlinking with the National Cat Management Strategy Group

We note that the arbitrary reclassification may amount to a deliberate attempt to widen the number of cats

that can be justifiably destroyed under the proposed RPMP, in order to satisfy the strategic goals and

outcomes of the National Cat Management Strategy Group (NCMSG).

The National Cat Management Strategy Group is a self-appointed unofficial group that has the aims that

“There are (will be) no stray cats in New Zealand. There are (will be) no feral cats in New Zealand”.

Page | 115

We note that the NCMSG has no official role, does not include prominent cat welfare groups in its

membership, has conducted no public consultation, and contains prominent political lobbyists with the

avowed goal of removing all cats from Aotearoa New Zealand. The NCMSG has neither legal authority nor

democratic legitimacy. Further, the goals, methods and makeup of the NCMSG are not supported by the cat

welfare groups that have been consulted by the NZ Cat Coalition at national hui.

We would therefore caution GWRC from blindly pursuing the goals of political lobbyists in revising the

RPMP.

Evidential base

While the RPMP makes a number of assertions about the impacts that “pest” cats are having in the WGRC

region, these are not backed by any research. For instance, no justification is provided for the assertion in the

Impact Assessment table on p174 that cats are expanding their infestation. In fact, the assertions fail the

immediate common sense sniff-test.

For instance, the document contends that the current land-use infestation rate for “pest” cats on dairy farms

is low, but will rise to high. There is no evidence advanced for why this might be the case, particularly

given the fact that cats are endemic to New Zealand and have been so for more than 200 years. It seems

likely that feral cat populations are limited by the supply of food, so fluctuations will occur as the prey

species increase or decrease – and quite how this dynamic is driven by land use type is unexplained in the

document.

If feral cats are expanding in population – and again, no evidence is provided to support this assertion – then

intuitively it will occur primarily because of either a reduction in predator pressure, or because of an

increase in food supply. Quite what these dynamics are and why they are restricted to specific land types –

dairy farms and coastal land but not forestry land – is unstated in the documents.

Likewise, the same table notes that the impact on dairy farms from feral cats is high – presumably because

of bovine Tb, as noted in subsequent tables – but there is no attempt to attribute the level of bovine Tb

infections in dairy herds to cats. This is important, as there are a number of species that carry bovine Tb,

and targeting the wrong one may end up costing the ratepayer money whilst failing to deliver any

appreciable benefit to farmers.

There are a number of similar limitations in the impact assessment document. For instance, in the Problem

table on p175 the source for the assertions is simply given as “5”. This is clearly a reference to some

external document, but the reference isn’t actually provided – which makes it very difficult for ratepayers

and submitters to assess the veracity of the sources and their applicability to the Greater Wellington

region.

From evidence to intervention

Government policy is meant to be based on the scientific method: we conduct research to ascertain what the

facts are and identify the problems that we’re trying to fix; we assess all the options for interventions to

address the problem(s); and then we select from the range of interventions to identify the ones that will have

the greatest positive impacts whilst minimising the negative impacts.

When it comes to cat management, there is little evidence that this process has been followed in the RPMP.

In fact, it looks suspiciously like the interventions have been identified in advance (the reclassification of “pest

cats” and their removal from the Code of Welfare) and evidence then sought to bolster this position. This is the

antithesis of good policy development.

Page | 116

Within the RPMP documents, it’s also apparent that the interventions assessment process has been cursory

at best. As is acknowledged in the impact assessment table on p174, the level of infestation of feral cats on

most land is low, with the exception of sheep and beef farms and in native bush. This must indicate that –

with the exception of those two land types – current management methods are working adequately, as

infestation rates would be higher otherwise. This is a very strong argument for maintaining the existing

methods on the low infestation land types, given the absence of any evidence that infestation rates are

likely to increase.

Assuming there is evidence that infestation rates are high on certain land types, the next step would be to

fully assess the options for intervention, using the current activity as a baseline. The options analysis

document fails to do this in any meaningful way, and there is no multi-criteria analysis used. Multi-

criteria analysis is a standard technique in the public sector, promulgated by the NZ Treasury, that

assesses the available options against a set of dimensions and critical success factors. It is exceptionally

useful in developing a preferred option that balances factors such as scope, effectiveness, achievability

and affordability, and the fact that this has not been done means that we are forced to conclude that the

interventions have been pre-determined.

Faulty cost-benefit analysis

The cost-benefit analysis used by GWRC to assess the economic value of controlling “pest” cats is

methodologically unsound and reaches conclusions that cannot be sustained. This is an assessment based on

my profession as an investment consultant to local and central government, where I develop and review

business cases using the Better Business Case methodology promulgated by the NZ Treasury.

In my professional role, I have developed business cases and investment strategies for MBIE, NZ Police,

Immigration NZ, LINZ, the Ministry of Social Development, NZTA, Callaghan Innovation, the Electoral

Commission and a range of other central government agencies. In local government I have undertaken work

for Hamilton City Council, Ōpōtiki District Council, Rotorua District Council, Napier City Council,

Gisborne District Council and others.

I also act a business case reviewer for central and local government, and have provided detailed review and

analysis on proposals ranging from infrastructure investments to organisational restructures.

As a result of this work, covering investments from a few million dollars to many hundreds of millions of

dollars, I am thoroughly familiar with cost-benefit analysis. I am a regular user of the CBAx toolkit

developed by NZ Treasury to guide decision making in the public sector, along with the approaches

around social cost/benefit and more short-form assessments.

While the simple cost-benefit used by GWRC in the RPMP looks sufficient on first glance, it is my

professional assessment that it has the following limitations:

1. The allocation of economic costs to cats is not evidentially justified, as the allocation model is

effectively invisible

2. The model makes no attempt to calculate the dis-benefits of “pest” cat control where cats apply

pressure to rodent populations, despite noting this ecosystem service in the text

3. The model makes no allowance for the social benefits of cats, despite widespread support in the

academic literature for the inclusion of this factor.

The sum total of these limitations is that the cost/benefit assessment is unsound, and there is little-to-no

likelihood that the wider economic benefits claimed would materialise. Decision makers should not depend

on the cost/benefit analysis when assessing whether cat control is justified.

While it is understandable that officers have taken a rough stab at assessing costs and benefits in the context

of the wider debate around cat management, the analysis put forward is not fit for this purpose, and should

Page | 117

be ignored.

Recommendations

As noted above, our recommendations are that:

1. The category of “pest cat” is removed from the RPMP and the technically correct term of “feral cat” is

reinstated, in keeping with the previous version of the RPMP, to ensure GWRC remains within its

delegated legislative authority

2. The RPMP is altered to reflect the evidence-based approach in relation to the assessment and

management of feral cats, using a multi-criteria analysis approach.

Officer advice and involvement

In preparation of this submission, we would like to acknowledge the input and advice from Dr Jamie Steer,

whose research on the balance between highly protected and highly modified ecologies in New Zealand has

been invaluable in informing the views of the NZ Cat Coalition. Dr Steer’s insights have been considered,

supported by robust research and shared openly and freely in an effort to educate and inform.

We would also like to thank Dr Davor Bejakovich for spending the time to discuss the more technical

aspects of the RPMP documentation, particularly the underpinning logic of the cost/benefit analysis

and the research. Dr Bejakovich gave very freely of his time and expert knowledge to clarify the

uncertainties and inconsistencies in the RPMP, and he was at all times considered in his views and

plainly interested in ensuring the debates around cat management were fully informed.

Both officers are to be thanked for their time and input in informing the public debate and our submission.

Contact details

My contact details for an oral submission are:

Kent Duston

021 536 873

[email protected]


Page | 118

075 Gazley, Dennis To Pest Plan Inbox 25-07-18

Name

Dennis Gazley

Email

[email protected]

Street address

7 Fillbridge Way

Suburb

Wellington

Postcode

6012

Phone Number

0276752444

Pest cats






Possums



Hedgehogs



Mustelids



Rats




Page | 119

Over the last couple of years the SPCA has held `cat adoption days' in Karori. This is just ridiculous. Surely an organisation such as this must appreciate the great work the Sanctuary and local trapping groups are doing. The SPCA has to be told that their `adoption days' are not welcome in Karori, or even the rest of New Zealand



Page | 120

076 Callister, Paul, Stace Michael, Cave,Shane To Pest Plan Inbox 25-07-18

Submission from:

Michael Stace, 11 Kainui Rd Raumati

Paul Callister, 88 The Parade, Paekakariki

Shane Cave, 7 Miro Road, Raumati

We do not wish to speak to our submission.

Thank you for the opportunity to comment on the draft weed and animal pest strategy. This submission is from three individuals who volunteer for three Kapiti restoration groups. These groups are Nga Uruora, Friends of Queen Elizabeth Park and Guardians of Whareroa farm.

We are grateful for the support GWRC give to conservation efforts in our area of Kapiti. In particular, we are appreciative of the support given via the KNE programme which operates on the Paekakariki Escarpment and within QEP.

There are many issues addressed in the draft. We only focus on two. These are: 1. The responsibilities of road transport agencies and KiwiRail 2. Cats.

The responsibilities of transport agencies and KiwiRail

As you note in your report there are more than 230km of state highways in the Wellington Region. You note that the Transport Agency is the occupier of the Crown land on which the roads lie, together with the road reserves extending to the adjoining land owners/ occupiers’ property boundaries. As you state, land under the Transport Agency’s jurisdiction is subject to the rules for land owners/occupiers as defined in the RPMP, so it has the same obligations as any other land occupier. There are also adjoining Road Reserves.

The Main Trunk line borders all three restoration projects. Nga Uruora also occupies KiwiRail land. You note that land KiwiRail occupies is subject to the rules for land owners/occupiers as defined in the RPMP, and KiwiRail has the same obligations as any other land occupier.

Finally, you note that amendments to the Biosecurity Act arising from the Biosecurity Law Reform Act 2012 now make the Crown bound by those rules identified as Good Neighbour Rules in plans.

While in theory these agencies are good neighbours, in reality they harbour weeds and pests that then migrate onto our conservation projects. Examples are:

1. Along the boundary of the Nga Uruora project there are many weeds on both NZTA and

KiwRail land. These include boxthorn, pampas, English Ivy and Climbing asparagus. Nga

Uruora spends a considerable amount of time trying to control these weeds (sometimes

using grants from GWRC). But there are sites we cannot enter for safety reasons so seed

sources continue to be present. We note that there is a considerable amount of pampas

along the base of the Transmission Gully project which the project seems to be protecting.

This is despite Nga Uruora lobbying the project to get rid of it.

2. Pampas is also rapidly spreading along the highway and the rail line on the boundaries of

QEP and Whareroa farm. Pampas is at a point in southern Kapiti where it could be

Page | 121

eradicated. In a few years’ time it could be impossible to get rid of.

3. We also we catch more animal pests along the boundaries of our projects. These are

untrapped areas, often with good food sources such as dumped food waste.

4. The new Kapiti Expressway creates a new set of pest problems. This is a long corridor

through the middle of Kapiti. Despite it being a requirement of the resource consent to

control animal pests, NZTA has expressed in correspondence with us that it has no

intention to carry out a trapping program. We have recently written to GWRC asking your

organisation to enforce these requirements under the resource consent. While we are

concerned about the range of animal pests already in the southern part of Kapiti, an

additional concern is that ferrets will use the expressway to reach our area.

Cats

Since placing motion triggered cameras on all three sites we have a greater awareness of cat presence. We are also aware of the growing scientific evidence suggesting cats are important predators. We therefore support the inclusion of pest cats within the Regional Pest Management plan.

We agree with the proposal the definition of pest cats to be change to clearly include all unowned cats. We also agree with the suggested definition of a pest cat as: “a cat without a registered microchip”.

We would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. We suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on private or public land within the Wellington Region, without the permission of the occupier.”

Finally, we suggest that there should be on-going education to minimise the risk to native species by those cats people choose to own in urban areas. Ideally, we would like some urban areas near sensitive ecological areas to become ‘cat free’.

Page | 122

077 Name Confidentiality To Pest Plan Inbox 25-07-18

It is important that feral deer be classified as a pest in the same category as hedgehogs and feral goats. The paragraph 7.1 stating that feral deer will not be a priority for pest control under the proposed plan is worrying.

Funding and the ability to control feral deer in KNEs and other areas of high ecological value is required as they are selective browsers and cause damage.

Each deer eats a large amount of food each year (one unverified source said 1.5 tons). In the forested KNEs the food sources are important plants in the ecosystem which should be providing food for birds and other native organisms as well as having their own intrinsic values. The KNEs are rightly protected, with people not allowed to collect plant material without permission, yet some think it is valid to allow deer in the forests so that a very small minority can kill them for their own dinner. Retaining deer in the native forests for individuals to eat is not a valid reason to allow deer. There needs to be a clear goal of eliminating deer from these forests as part of their preservation and restoration.

Feral pigs also need to be classified as a pest, for similar reasons.

Page | 123

078 Department of Conservation

SUBMISSION ON THE PROPOSED REGIONAL PEST MANAGEMENT PLAN FOR THE GREATER WELLINGTON REGION

TO:

SUBMISSION ON: Proposed Regional Pest Management Plan

NAME: Director-General of Conservation

ADDRESS: Address for service:

Department of Conservation

13b Wall Place Kenepuru

Pori rua 5022

Attention Jack Mace

Telephone: 04 470 8412 Email: [email protected]

SUBMISSION BY THE DIRECTOR-GENERAL OF CONSERVATION:

Please refer to Attachment A. I also seek further or alternative relief to like effect to that sought in my submission, and any consequential amendments required as a result of such relief.

ATTENDANCE AND WISH TO BE HEARD AT HEARING(S) I do wish to be heard in support of my submission. SIGNATURE

kiArif

Reg Kem p&

Director, Operations, Lower North Island

Pursuant to delegated authority On behalf of

Lou Sanson

Director-General of Conservation

Note: A copy of the Instrument of Delegation may be inspected at the Director-General's office at Conservation House Whare Kaupapa Atawhai, 18/32 Manners Street, Wellington

6011


Page | 124

Introductory text

I appreciate the opportunity to submit on Greater Wellington Regional Council's proposed Regional Pest Management Plan. We value the partnership we have

with council and assert that our submissions are focussed on strengthening the draft plan and supporting positive outcomes that can be effectively achieved

across various land tenures by all parties. We seek to ensure that the plan is sustainable across the 20 years proposed and that objectives are clearly linked to

outcomes and can be assessed and reported on through the course of the plan.

Submission

Specific section/

objective/ policy/ rule

this submission point

relates to:

Position: My Submission is that: I seek the following relief from Council:

1 Section 1Introduction Support I strongly support the Council's intention to lead

efficient and effective pest management in the Region

that will lead to the minimisation of actual

or potential adverse effects of some pests.

Note.

2 Section 1.1 Purpose Statement about need

for regional

management is not

consistent with

Biosecurity Act.

The plan states that "it is only where an

individual's actions or inactions in managing pests

imposes undue effects on others that regional pest

management is needed". I submit that this

statement mis -represents the intent of the

Regional Pest Plan provisions of the Biosecurity

Act 1993 (paragraphs 70,71 & 72).

Revise wording e.g. "However, it is only

where a subject is capable of causing an

adverse effect in the region, a planned

approach would be more effective than

voluntary management and the benefits

of a regional plan outweigh the costs of

that plan, that regional management is

warranted".

3 Section 1.3 Coverage Crown land should be

identified and

relationship qualified,

The formal requirements of the plan for individual

subjects covered by the plan (as proposed) have

little effect on Crown Land. I submit that the plan

would be improved by highlighting the major areas

of Crown Land and including commentary with

respect to how that land might be i ntegrated into

the planned outcomes for individual pests.

Major areas of Crown Land shown as an

overlay (hatched or shaded) in Figure 1.

Text to include a statement to the effect of

"While Crown Land is generally outside

the coverage of this plan, Council will

seek to work with Crown agencies to

achieve co-ordinated control of targeted

pests. Ref 3.3.2"

Page | 125

4 Sections 2.1.1 — 2.1.1.6

Strategic background.

Support. I support the analysis and documentation of

legislative and policy instruments summarised in

the document.

2 P a g e Specific section/



relates to:


5 2.1.1.1 GW's Biodiversity

Strategy

Figure 2 is not

reflective of the

published strategy

I submit that the GWBS goals identified in Figure 2

are not the goals as stated in the Strategy.

Review and correct representation of the

goals of the Biodiversity Strategy.

6 2.1.1.2 Key Native Clarify relationship of I submit that the KNE programme is an

implementation output from other Policies or

Strategies rather than a stand-alone "driver" for

the pest management plan and should be

identified as such. I further note that;

it is unclear what, if any, authority under

the Biosecurity Act GW requires to operate

in the identified KNE given that it either

owns the sites or has a management

agreement with the owners.

KNEs are not referred to in the proposed

NRP.

Review representation of KNEs in this Ecosystems KNEs to biodiversity section.

strategy, RPS or

proposed NRP

Page | 126

7 2.1.1.5 Marine biosecurity Support I support the Council's identification of marine

biosecurity as a significant and developing area of

concern for the Region. I note that the

Department manages two Marine Reserves within

the Region that are at risk from new organisms,

For GW's consideration, I commend the approach

taken by Hawkes Bay Regional Council and note

that the Department will work with GW to help

ensure protection of marine biodiversity in the

Region.

1. Note

2. Consider amending final paragraph of

this section e.g. "For this reason, as

the national marine biosecurity

surveillance and response capability

increases, throughout the life of this

plan, Greater Wellington will work with

central and local ..."

8 2.1.2 Biosecurity

framework

Clarify I submit that the headings in Figure 3 should be

enlarged on in the subsequent text to clarify what

effect those mechanisms have upon pest

management responsibilities and outcomes in the

Wellington Region.

(I note that some of this detail may be present in

sections 2.2 —2.3 and hence editing may be all that

Review and expand section 2.1.2 to identify the

effect of identified mechanisms on pest

management responsibilities and outcomes in

the Wellington Region.

3 I Pa ge Specific section/



relates to:


is required.)

9 2.2.1 "Council leadership" The Council's leadership

role in this field is

assigned by statute.

I submit that Council should acknowledge that

the leadership role for pest management and

coordination of pest management activities in the

Region is assigned under S.12b of the Biosecurit y

Act

Review and revise paragraph 1 of 5.2.2.1 to

describe assigned role under legislation

10 2.2.1 "Part 6:

Administering an RPMP"

Actions wrongly

ascribed,

I submit that the examples described in this

paragraph are required under Part 5 of the

Biosecurity Act, not Part 6.

Review paragraph and either correctly

ascribe the examples or use other examples

drawn from Part 6.

Page | 127

11 2.2.1 "Changes to the Act

since 1993"

Role of National Policy

Direction should be

identified.

I submit that several "changes" identified in this

section are derived from the fact that a National

Policy Direction has been promulgated not from

legislative changes.

Review section and clarify those

requirements introduced by the National

Policy Direction for Pest Management.

12 2.2.4 "compliance with

other legislation".

Compliance is incorrect

term.

I submit that the Biosecurity Act does not require

compliance with the identified legislation. The Act

(5.7.2) requires that actions taken under the Act

do not "derogate" from various listed legislative

provisions and under S7.5 the Wild Animal Control

Act and the Wildlife Act cannot prevent or inhibit

council's powers with respect to pest management.

Revise and update reference to other

legislation.

13 2.3 Other legislative

provisions not described

Noxious Fish provisions

and Unwanted

Organism status of

many organisms not

mentioned.

I submit that this section should make reference

to legislative provisions with respect to Noxious

Fish particularly as freshwater quality and aquatic

species/ecosystems are key elements of the

proposed Natural Resources Plan. Similarly, the

plan should note that many species have been

classified as unwanted organisms potentially

giving agencies or council access to powers to

survey for and/or control these species.

Review section to include description of

implications with respect to unwanted

organisms and noxious fish. (I note that

description of unwanted organism

provisions in this section provide the

foundation for subsequent coverage in

S.4.3)

14 2.6 Consultation overview Overview of

consultation

undertaken will need to

I submit that Council have chosen to follow S.72.c.

provisions with respect to consultation in the plan and

therefore the outcome of consultation that

Revise paragraph 2.6 at completion of

consultation.

4 1 P a g e Specific section/



relates to:


include the outcome of

the current consultative

phase.

needs to be incorporated into the plan is that

occurring now.

Page | 128

15 3.3 Affected parties Incorporated societies

should be included.

I submit that the incorporated society,

OSPRI/TbFreeNZ, that is a major contributor to

pest management in the GW Region should be

included in this list and its contribution described.

Include incorporated Societies, particularly

OSPRI/TbFreeNZ in 3.3 and subsequent

description.

16 3.3.1.2 Landowners/occupiers

must meet

requirements of good

neighbour rules

I submit that the obligations of landowners extend

to meeting the requirements of any Good

Neighbour Rule that may be included in the plan.

(This responsibility is not confined to Crown

agencies).

Note GNR obligations for Individuals.

17 3.3.2 Crown agencies Crown agencies have

various roles

I submit that several Crown Agencies, particularly

MPI and DOC are significant contributors to pest

management outputs and outcomes within the

Region and that this contribution should be

acknowledged.

18 4.1. Organisms declared

as pests

Strongly support

inclusion as pests

I submit that I strongly support the inclusion of the

listed species as pests

Note


as pests

Include NIPR subjects I submit that pests (Manchurian wild rice, Cape

tulip and Water Hyacinth) currently managed by

GW in collaboration with MPI should be included

as pests in the RPMP. This would give the Chief

Executive of GW authority to appoint inspectors

and authorised persons for the purpose of finding

and removing these plants.

Include Manchurian wild rice, Cape tulip

and Water Hyacinth as eradication pests.


as pests

Include "Pig's ear")

Cotyledon orbiculata as

pest in same zone as

Boneseed.

I submit that the pest plant "Pig's ear" should be

included as a pest in the same context as Boneseed

as it has similar impacts in the same habitats as

Boneseed although perhaps over a greater extent of

the coastal strip. The plant will potentially be a

major problem on the south Wairarapa Coast

Include Pig's ear as a sustained control or

site led pest within coastal habitats

throughout the Region.

5 I Page

Page | 129

Specific section/



relates to:


impacting on Chionochloa beddiei and the type

locality for Sophoiyi molloyi, among many

other high value native plants. Pig's ear was

declared to be an "unwanted organism" by the

Chief Technical Officer of MAF in 2008. I

understand that GW staff are proactively

managing this plant in some high value

habitats.


as pests

Include freshwater

pest fish as exclusion,

eradication or

progressive

containment pests.

I submit that freshwater pest fish pose a significant

risk to natural resources of the Wellington Region.

While DOC is generally the lead agency for

managing these threats GW is engaged in

collaborative actions with DOC in several locations

including Wairarapa Moana. Recognition of these

species as pests in the RPMP would give the Chief

Executive of GW authority to appoint inspectors

and authorised persons for the purpose of finding

and removing these pests.

Include freshwater pest fish including

Noxious fish, freshwater fish that are

unwanted organisms and Brown bull-

headed catfish.

22 4.4 Invasion curve Add relevancy I submit that the invasion phases described in

Figure 6 are not clearly able to be aligned with the

programmes identified for individual pests in table

2.

Either identify invasion phase for each

species in table 2 or list species by phase as a

supplementary table with Figure 6.

23 5.4 Alternative pest

management

arrangements

Clarify status of

alternative

arrangements

I submit that I strongly support the mechanism

described in 5.4 but seek clarity as to whether or

not Council intends that this mechanism will be

used to fulfil the requirements of S.78 of the

Biosecurity Act (exemption from rules).

Reference S.78 of the Biosecurity Act in S.

5.4 of the plan and clarify relationship of

5.4 with 5.9.3 of the plan.

Page | 130

24 Page 31. Rules with

respect to possession of

pests. Research.

Also page 36, 42, 45, 47,

Consider rule impact on

bona fide researchers

and others.

I submit that rule 1. imposes a barrier to the bona

fide possession of pests by researchers for example

the holding of herbarium specimens or research

subjects, including seeds, at Te Papa or Victoria

University.

Modify rule to exclude legitimate

institutional researchers.

W a g e

Specific section/



relates to:


49, 50.

25 Page 31. Rules with

respect to reporting pests.

Also page 36, 39, 42, 45,

49,50.

Consider impact of this

rule

I submit that the rule requiring persons who see or

suspect the presence of any specified pest

anywhere in the Region at any time is impractical

and could create significant costs and risks for

Council.

Modify rule reduce span e.g. "Any person

who sees a pest, included in table 3, on land

they occupy shall report the initial sighting

to GW within 5 working days".

26 6.3.1. Purple loosestrife Map not as described. I submit that I support the intent of the plan to

reduce the impact of Purple Loosestrife,

particularly in the Wairarapa Moana and Lake

Onoke systems and other significant wetlands but

wish to draw Council's attention to the lack of

clarity in the objective. I submit that the objective

is unclear as to whether it applies to all wetlands

with "native wetland biodiversity" or to a set of

wetlands that are in the process of being defined in

the proposed NRP or to the KNEs. I note that

Figure 7 differs from the on -line version of

mapping for the pNRP and the referenced Appendix

3, Map 5 does not exist in the pNRP and shows

KNEs in the RPM P.

Amend section to provide clarity of intent

and, if linking to the pNRP reference the

relevant schedules of that plan.

Page | 131

27 6.3.1 Purple loosestrife.

Written direction to

occupiers

C au ti o n w ith r es p e ct to

u s e o f h e r bi c id e s o ve r

w at e r

I submit that written direction to occupiers to

destroy all purple loosestrife must contain

cautionary advice about the risks associated with

using herbicide over water and in wetland habitat

that may also contain threatened plants.

Note

28 6.4.1 Blue passion flower Support but suggest

inclusion of occupier

requirement to act

I submit that I support the intent of the plan to

reduce the impact of Blue Passionflower but

suggest that rule requiring occupiers to act (even

if just to allow GW access) is required in order to

give those occupiers who wish it, an option to

seek an exemption (as per 9.3) should they wish

to undertake control themselves.

Include occupier rule that could allow occupiers

to access exemption procedures.

7 P a g e

Specific section/



relates to:


29 6.4.2 Boneseed Support but suggest I submit that I support the intent of the plan to Include occupier rule that could allow

inclusion of occupier reduce the impact of Boneseed but suggest that occupiers to access exemption procedures.

requirement to act rule requiring occupiers to act (even if just to

allow GW access) is required in order to give

those occupiers who wish it, an option to seek an

exemption (as per 9.3) should they wish to

undertake control themselves.

30 6.4.2 Boneseed Caution with respect to I submit that service delivery in "non -productive Note.

use of her bicides in habitats" must be undertaken by skilled and

coastal en vironm ent knowledgeable staff because these coastal habitats

are the largest refugia for many threatened and

endangered plants, invertebrates and lizards within

the Region. Herbicides must be used cautiously.

Page | 132

31 6.4.4 Eelgrass Support, with

qualification,

I submit that I support the objective to prevent

the spread of this species but further submit that

the objective would have greater clarity if the

known sites were identified in the plan and

potential risk sites were to be more clearly

identified (refer Purple Loosestrife submission).

Identify known sites and clarify meaning of

"wetland habitats with native wetland

biodiversity".

32 6.4.5 Feral rabbits Support I submit that I support this objective as the effect

of the objective is to limit the spread of rabbits

from one property to another. (Minimisation of

adverse effects on environmental, culture and

production values would likely require a greater

intensity of control.)

Note.

33 6.4.5 Feral rabbits Pr o vide fo r ser vice

deliver y in site - led

pr o gr am m es

I submit that Feral rabbits should also be

incorporated into the site-led programme as

necessary to either protect values directly impacted

by rabbits or to influence population

dynamics of feral cats and/or ferrets.

Include Feral rabbits in site-led programme.

34 6.4.6 Magpie Support, with

qualification,

I submit that I support the intent of this objective but

further submit that the proposed objective and

Change objective to site-led.

81 Page Specific section/



relates to:


actions would be more appropriately classified as "Site-

led" because there is no intent to either reduce the

distribution or spread of magpies but

rather to control them at localised sites.

Page | 133

35 6.4.7 Possum Support, with

qualifications,

I submit that I support the intent of this objective

and note the Department's common goals for

many of the lands it manages in the Region but

further submit that the plan for possums needs

further development. I note the following;

GW does not require a Regional Pest

Management Plan for possums for the

objective they have relating to KNEs.

Council is either doing this work on land

it manages or on land where the

owner/occupier is in agreement.



objective it has relating to actively

managed TA reserves or other sites where

the landowner/occupier is willing to pay

for service delivery.



objective it has relating to the RPPCP if it is

undertaking this work with the agreement

of landowners/occupiers and the work is

funded as a Regional "good" from general

and targeted rates. I note that justification

for this expenditure will need to meet relevant

tests in the Local Government Act, not the

Biosecurity Act.

The plan as proposed contains no rules or

Review proposed objectives, programme

structure and cost benefit analysis for

possums.

9 I P a g e

Page | 134

Specific section/



relates to:


provisions relating to

landowners/occupiers who may impose

barriers to effective control.

The Cost benefit analysis for possums is

poorly developed in that it incorrectly

identifies the objective for the KNE work as

sustained control rather than "Site-based"

and assigns a site-based objective to the

RPPCP work which is clearly "Sustained

control". It also assigns the benefit of

Bovine Tb control to the RPPCP work when

that benefit is already captured by the

National Bovine Tb Control plan for

eradication of the disease.

36 6.4.7 Possum Representation of "Life

time" plan.

I submit that the plan for possums would be

enhanced by over-laying Figures 9, 10 & 11 to

represent the plan's life-time entirety of planned

possum management. I further submit (as per my

point 3 above) that that representation would be

enhanced by including existing and probable DOC

possum/predator control programmes on public

conservation land within the Region.

Provide comprehensive map.

37 6.4.8 Wasps Support Council

involvement

I submit that I support the role and powers the

Council is proposing to assume under this plan.

Note

Page | 135

38 6.5 Site-led plant pests Support with

qualifications

I submit that I support the plan for control of

banana passionfruit, cathedral bells and old man's

beard within the Hutt City Council "site" although I

note;

No cost benefit analysis with respect to

the pests has been presented therefore

the plan may be inconsistant with the

National Policy Direction for Pest

Note and consider enlargement.

1 0 p a g e Specific section/



relates to:


Management.

These "pestiferous" plants are not restricted

to the Hutt City Council area and it may be

appropriate to include, at least, KNEs and

significant wetlands and rivers (particularly

for old man's beard) across

the entire Region.

39 6.5.4. Hedgehog

6.5.5 Feral Goats

Support pest status

with qualification

I submit that I support pest status for these species

while noting that, as with respect to possums, GW

does not require a Regional Pest Management Plan

for these animals for the objective they have

relating to KNEs where council is either doing this

work on land it manages or on land where the


Note

Page | 136

40 6.5.6 Mustelids Support I submit that I support pest status for these

species because to achieve the work required

within the Predator Free Wellington "site" boundary

GW staff and/or contractors may need the status of

authorised persons to be able access l and where

the owner/occupier does not support the work.

Neither stoats or weasels are classified as

unwanted organisms therefore pest status is

required to give access to these powers.

Note

41 6.5.7 Pest cats Support pest status

with qualification

I submit that I support pest status for this species

while noting that, as with respect to possums, GW

does not require a Regional Pest Management Plan

for these animals for the objective they have

relating to KNEs where council is either doing this

work on land it manages or on land where the


Note

42 6.5.7 Pest cats Consider extent of pest I submit that the pest status for Pest cats could be Consider legal status of proposed rule

11 IP age

Specific section/



relates to:


status. construed as being limited to KNEs because this is a

"site-led" plan but the proposed rule extends to the

Region as a whole.

under a "site-led" plan and consider making

the plan "sustained control" across the

Region.

Page | 137

43 6.5.8 Possum (Wellington

Predator Free site)

Support pest status

with qualification

I submit that I support pest status for this species

for this objective because to achieve the work

required within the Predator Free Wellington "site"

boundary, GW staff and/or contractors may need the

status of authorised persons to be able access land

where the owner/occupier does not support the

work. I note that the Predator Free Wellington "site"

boundary could be incorporated into a site - led

programme that included KNEs etc. refer pt. xx

above.

Note and consider revising all possum

planning.

44 6.5.9 Rats (Wellington

Predator Free site)

Support I submit that I support pest status for these

species because to achieve the work required

within the Predator Free Wellington "site" boundary

GW staff and/or contractors may need the status of

authorised persons to be able access land where

the owner/occupier does not support the work.

Neither ship rats nor Norway rats are classified as

unwanted organisms therefore pest status is

required to give access to these powers.

Note

45 8.1 Monitoring Support I submit that I support the planned monitoring

programme.

Note

12IPa ge

Page | 138

079 Shaw, Kerry To Pest Plan Inbox 26.7.18

Name

Kerry Shaw

Email

[email protected]

Street address

156 Ohiro Rd, Brooklyn

Suburb

Wellington

Postcode

6021

Phone Number

04 3844690

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of native species

including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so humans need to control their

numbers. Without management cats undermine any predator control work undertaken by council and community groups.


I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat is:

“a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest Rule 1 (p 74)

is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on private or public land within the

Wellington Region, without the permission of the occupier.”

Possums


Possums significantly impact both primary production and biodiversity and controlling their population is an important regional

goal. Urban control is also important to prevent reinvasion into both significant ecological areas and the rural landscape.

Hedgehogs


Page | 139

I agree with European hedgehogs being defined as site-led pests and support their inclusion in the plan. Hedgehogs have

serious impacts on lizard and invertebrate populations and eat the eggs of ground nesting birds. More public education is

needed around the impacts hedgehogs have on our native biodiversity.

Mustelids

I agree with mustelids (stoats, ferrets and weasels) being defined as site-led and for the ambitious goal to eradicate them

from areas within the Predator Free Wellington initiative.


Rats



I would like to have mice included in site-led pests programme to be controlled at specific sites. I feel that mice need to be

included. I have noticed that once the rat numbers reduce, the mice increase considerably in the areas I monitor traps. They

could become a major pest problem in a few years, ie similar to the Antipodes Island after rats were eradicated. Mice can

have an impact as they eat some NZ native species as well as the foods they eat. They take foods that birds would normally

eat like berries and seeds. Also they keep eating the bait in traps!!

Also I agree with GW supporting, inspecting & monitoring within the boundaries of PF Wellington initiatives but I would like to

see more on how they are going to do this & how often as a lot can happen in 20 years. Also I don't think GW have defined

the areas for weed pest management very clearly. I think that to avoid the spread of pest weeds in the KNE areas, GW need

to show that they will be supporting, inspecting & monitoring within the boundaries of site-led restoration groups' sites in TA

reserves especially WCC.

I think the weed pest management is an enormous activity so GW needs to have a lot of help to do this work from volunteers

so it would be good if they highlight how they will support this volunteer work more clearly.



Page | 140

080 Morgan Foundation Morgan, Jesse

To Pest Plan Inbox 26.7.18

Greater Wellington Regional Council Proposed Pest Management Plan

Submission by

Jessi Morgan on behalf of Morgan Foundation

PO Box 19218. Wellington 6149

Ph (04) 385 1697

Mobile 021 467 122

[email protected]

26 July 2018

This submission is on the proposed Regional Pest Management Plan

Firstly we’d like to commend Greater Wellington on a well thought out and comprehensive plan. The plan highlights

that Greater Wellington highly values native biodiversity within the region, it is a great example of a RPMP.

The inclusion of a pest cat is progressive and innovative. Cats are an apex-predator in New Zealand and if humans

don’t control their numbers nothing else will. Cats are highly skilled hunters that have the ability to devastate

populations of native birds, bats, reptiles and insects. Studies have shown that in populated areas cats kill native

birds faster than they can breed. The damage inflicted on native lizards and invertebrates is unquantified but

probably even greater. This is a huge issue for our native wildlife, and one we need to deal with.

The current definition of a pest cat is unclear and some work is needed to clarify it to make it a useful definition. We

suggest using a similar definition that was in the Auckland Council Proposed RPMP: “A pest cat is a cat without a

registered microchip”. This will clarify the definition and more clearly deal with strays and colony cats.

Cats are one of the biggest threats to the predator control work done by GWRC, landowners and community groups.

Currently cat control near populated area is unfeasible because there is no clear means of determining if a cat is

owned or not. Introducing the proposed definition of a pest cat will enable this.

Cats are also have an affect on primary production and human health. So controlling pest cats is beneficial to all. Cats

are the primary transmission vector for toxoplasmosis, a serious illness in both humans and sheep. Most farmers

immunise their sheep but the immunisation is not 100% effective and storms of toxoplasmosis can still devastate

flocks.


Page | 141

Wellington City Council were the first TLA to introduce compulsory microchipping in their Animal Bylaw and the

definition of a pest cat within the RPMP supports their Bylaw. In fact the inclusion of a pest cat being defined as a cat

without a registered microchip is essential to legally strengthen the WCC Animal Bylaw.

Microchipping and managing cats also brings many side benefits. It is good for cat welfare, which is why is it

promoted by the SPCA and NZVA. Following the Christchurch Earthquake microchipped cats were far more likely to

be returned to their owners.

The rule around people feeding or sheltering pest cats on land without the permission of the occupier could be

further clarified to include any cat. We suggest Rule 1 is re-written to exclude the word “pest” ie. “No person shall

feed or provide shelter to cats on private or public land within the Wellington Region, without the permission of the

occupier.”

Rules around people abandoning cats should be more regularly enforced and more public education around the

impact of cat abandonment is needed.

We would also like to see GWRC, together with LGNZ, approach central government to develop national legislation

for cat management.

I would like to talk to my submission at the hearings.

Page | 142

081 Predator Free NZ Morgan, Jesse To Pest Plan Inbox 26.7.18

Jessi Morgan on behalf of Predator Free New Zealand Trust

PO Box 25595. Wellington 6146

Mobile 021 467 122

[email protected]

26 July 2018

This submission is on the proposed Regional Pest Management Plan

Firstly we’d like to commend Greater Wellington Regional Council on a well thought out and comprehensive plan.

The list of predators named in the plan is extensive and the plan to control them shows GWRC highly values native

species that live within the Wellington region.

We recognise that Wellington has an important role to play in the Predator Free New Zealand vision and we

commend you on your support for Predator Free Wellington. The increase in the number of predator free

communities throughout the Wellington region is indicative of the high level of public support for this vision. Not

only is it improving biodiversity the impact on connecting communities around a common goal should not be

overlooked. It also important for council to realise the need for them to lead by example on their own land.

Community engagement is a vital part of achieving a predator free New Zealand and encouraging and supporting

community involvement is vital.

The Predator Free New Zealand Trust is very supportive of the proposed plan.

We commend you on the inclusion of pest cats within the Proposed plan. Including a broader term of pest cat is

progressive and innovative. Cats are an apex-predator in New Zealand and if humans don’t control them nothing else

will. Cats are highly skilled predators that kill regardless of hunger and they have the ability to decimate populations

of native species including bird, bat, lizard and insects. Without control measures cats are the biggest threat to

predator control undertaken by council and community groups.

Whilst the term pest cat is greatly improved from feral the definition in the proposed plan does not clearly include

colonies, stray and abandoned cats. We suggest it could be more succinct by following the definition in the Auckland

Council proposed RPMP which is: “any cat which is not micro-chipped; and registered on the New Zealand

Companion Animal Register”. This is a much clearer definition and eliminates confusion around stray and unowned

cats.

Wellington City Council were the first TLA to introduce compulsory microchipping in their Animal Bylaw and the

definition of a pest cat within the RPMP supports their Bylaw. In fact the inclusion of a pest cat being defined as a cat


Page | 143

without a registered microchip is essential to legally strengthen the WCC Animal Bylaw.

It should also be noted that cats are the main vector for Toxoplasmosis which is a production pest, causing

miscarriage and still borns in sheep. Many farmers immunise against Toxoplasmosis but the immunisation is not

100% effective.

The rule around people feeding or sheltering pest cats on land without the permission of the occupier could be

further clarified to include any cat. We suggest Rule 1 is re-written to exclude the word “pest” ie. “No person shall

feed or provide shelter to cats on private or public land within the Wellington Region, without the permission of the

occupier.”

Following the LGNZ remit on national cat legislation being passed, we’d like GWRC to further encourage LGNZ to

lobby central government to create a national cat legislation to ensure all regions are adopting best practice cat

management.

We agree with possums being both sustained and site-led pests. We note that GWRC is aiming for 5% RTC and

suggest you look at lowering this to 4%. Hawke’s Bay Regional Council have 4% RTC in their Proposed RPMP.

We agree with the inclusion of European hedgehogs. Hedgehogs have serious impacts on lizard and invertebrate

populations as well as eating the eggs of ground nesting birds. More public education about the impacts hedgehogs

have will help raise public awareness of the damage that hedgehogs have on our native biodiversity. We would like

GWRC to undertake more public education around the impacts of hedgehogs.

Rule 1 for hedgehogs should also state the people should not release hedgehogs into any KNE.

We agree with mustelids (stoats, ferrets and weasels) being defined as site-led and for the ambitious goal to


An addition rule should be added to make it clear that releasing a mustelid within the Wellington Region is an

offence.

We support the inclusion of rats (Norway and ship) as site-led pests to be controlled at specific

I would like to talk to my submission at the hearings.

Page | 144

082 GUARDIANS OF PAUATAHANUI INLET Inc. Shaw, Tony


Greater Wellington Regional Council Proposed Regional Pest Management

Plan Submission from The Guardians of Pāuatahanui Inlet

We endorse and support the list of proposed pests and the related methods set out in the proposed Strategy.

We submit that there should be two further additions to the Strategy

1: Canada Geese; and

2: Agapanthus

Our reasons for these proposals are:

Canada Geese

Canada Geese have been a pest in the Pāuatahanui Inlet for some time. Their presence recurs every year and the

numbers vary. But it’s not unusual to see 50 to 80 birds in the Inlet. Their diet includes short pasture grasses and

herbaceous saltmarsh, together with sea grass. Their feeding habits strip plants. They are crowding out other, native

birds. They roost in large numbers on the shoreline of the Inlet. They also produce large volumes of waste – up to

half a kilo per bird per day which gets deposited on shoreline and near shore areas, as well as farmland.

In terms of management options, it seems that interfering with eggs and nests is only partially successful. Culling the

birds seems to be a necessary option.

Proposal

We therefore consider that Canada Geese should be listed in the Pest Management Strategy and that the method of

management should be sustained control including egg and nest interference and culling.

Supporting Information

The following 2013 commentary by Robin Chesterfield and Wanda Tate from the Pāuatahanui Reserve Committee

sets out the problems affecting the Wildlife Reserve at the Eastern End of the Pāuatahanui Inlet:

“What exactly is the problem with Canada Geese?

Firstly, the food. The preferred food of Canada geese is short pasture grasses and herbaceous wetland plants. ‘The

geese feed ravenously on the herbaceous saltmarsh plants that fringe the tidal area and just strip them,’ says Mrs

Tate. ‘At times during the year we’ve seen groups of 20 to 30 birds on one of the Reserve tidal basins. We’re

particularly concerned with their impact on a rare native plant called Mimulus repens or Maori musk.’

The voracious feeding habits of the Canada geese also seriously affect the food available for the Inlet’s native birds.

The tidal basins are the feeding spots for waders including pied stilts, and their numbers are actively threatened by

the loss of their food source. Kingfishers and herons are also affected, as they are unable to feed at prime locations

when Canada geese are roosting in large numbers on the shorelines of the Pāuatahanui stream mouth.

The problem gets worse at the start of the breeding seasons when pairs are seeking safe nesting sites.

The key characteristics of a good nesting site are a plentiful food supply for the adult birds and quick easy access to a

reliable waterway, since water is the safest environment for newly hatched goslings to escape to. Such sites are

essential until the goslings fledge and then throughout the summer until the moult is over and the adult birds can fly

again.

Page | 145

Suitable breeding and moulting sites are often quite limited in area and several pairs of geese will nest around the

same site, with an average nest containing anything up to nine eggs. Bird expert and Chairman of Forest and Bird’s

Pāuatahanui Wildlife Reserve Committee Robin Chesterfield notes that when the geese first nested in the Wildlife

Reserve there were seven adult birds and 26 goslings roosting along about 15 metres of grassed track, feeding there

and in the adjacent pond.

For the last few years a particular tidal basin in the Reserve has been the preferred nesting site for up to six Canada

geese breeding pairs. Unfortunately this tidal basin is not only the main feeding ground for the native pied stilt but

also its chief nesting site. The Canada geese are using the shell islands where the stilts normally nest as lookout posts

and pushing the native birds out. ‘Their presence is endangering an important southern North Island pied stilt

breeding colony,’ says Robin Chesterfield.

And finally, that awkward question of poo. Canada geese are large birds that eat a lot and produce a lot of waste –

up to half a kilo per day per bird goes into the Inlet. It doesn’t take many birds concentrated into such a small area

for 4-6 weeks to do a lot of damage. Public access tracks are fouled to the point where they become unusable, but

it’s the muddying and fouling of the habitat used by the native birds that causes the most concern. ‘Herons, pied

stilts, shovellers – they’re all being affected,’ says Wanda Tate.

So much for the problems. What about solutions? Research has been done into how best to control geese numbers,

including into the effectiveness of intervening at the hatching stage. That has already been tried at the Reserve. ‘We

had hoped that population control could be achieved by finding the nests and preventing the eggs from hatching but

that hasn’t worked,’ says Wanda Tate. ‘We were quite optimistic when no goslings were hatched in the Reserve in

2013, but unfortunately late in the breeding season three pairs of geese that had raised clutches further afield

brought their goslings into the Reserve so our efforts at controlling numbers at a specific vulnerable site were largely

ineffective.’

In Canada and USA, where Canada geese are increasingly entering the ‘peri-urban’ (as opposed to wild) environment

in damaging numbers, experience seems to indicate that interfering with breeding by addling or oiling eggs is not

enough to offset the effect of the

20-30 year life expectancy of the geese.

An increase in total numbers of birds in the wider area will put even more pressure on current nesting and moulting

sites. More destruction of the saltmarsh plants, more fouling of the Inlet and its edges and further intrusion into the

habitat of the native birds would be inevitable. ‘Here at Forest and Bird Pāuatahanui we are conservationists, but

conservation of our native bird and plant life requires immediate control of Canada geese numbers. We can’t let

numbers just go on increasing. Future generations would never forgive us,’ says Wanda Tate.”

Agapanthus

Agapanthus is a weed plant that forms dense and expansive mats that are hard to eradicate. It has been bred

because of its looks and flowers, but it tends to overpower and led to the exclusion of other, including native

vegetation, It occupies increasing areas of land around the Porirua Harbour and adjacent to roads, reserves and

walkways. It is also now invading and thriving on seashore areas around the Pāuatahanui Inlet.

Proposal

Agapanthus should be eradicated on all public areas (such as road berms, reserves and walkways), and the harbour

foreshore. Its propagation and sale should be banned from garden centres. Information should be provided to

property owners on the pest status of agapanthus and how to control it.

Page | 146

083 Hemingson, Jacqueline,Ann To Pest Plan Inbox 26.7.18

Name

Jacqueline Jacqueline Ann Hemmingson

Email

[email protected]

Street address

52A Simla Cres

Suburb

Wellington

Postcode

6035

Phone Number

044792541

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of native

species including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so humans need to control

their numbers. Without management cats undermine any predator control work undertaken by council and community

groups.







Possums


Possums significantly impact both primary production and biodiversity and controlling their population is an important

regional goal. Urban control is also important to prevent reinvasion into both significant ecological areas and the rural

landscape.


Page | 147

Hedgehogs





Mustelids




Rats




Page | 148

084 Legg, Mary To Pest Plan Inbox 26.7.18

Name

Mary Legg

Email

[email protected]

Street address

19 Patanga Crescent, Wellington

Suburb

Wellington

Postcode

6011

Phone Number

02102397093

Pest cats






I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat is: “a

cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest Rule 1 (p 74) is

re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on private or public land within the


Possums




Hedgehogs


Page | 149

I agree with European hedgehogs being defined as site-led pests and support their inclusion in the plan. Hedgehogs have serious

impacts on lizard and invertebrate populations and eat the eggs of ground nesting birds. More public education is needed around

the impacts hedgehogs have on our native biodiversity.


Mustelids




Rats




Page | 150

085 Legg, Dan To Pest Plan Inbox 26.7.18

Name

Dan Legg

Email

[email protected]

Street address

19 Patanga Cres

Suburb

Thorndon

Postcode

6011

Phone Number

0226878247

Pest cats






I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of a pest cat is:

“a cat without a registered microchip”.




Possums




Hedgehogs


Page | 151





Mustelids




Rats




Page | 152

086 Oliver, Jared To Pest Plan Inbox 26.7.18

Name

Jared Oliver

Email

[email protected]

Street address

4/521 George Street

Suburb

Dunedin

Postcode

9016

Phone Number

0211604661

Pest cats





groups.







Possums




landscape.


Page | 153

Hedgehogs





Mustelids




Rats




Page | 154

087 HVNZDA Secretary

George, Gordon

To Pest Plan

Inbox 26.7.18

Page | 155

1080.

Whilst we oppose the indiscriminate use of any toxin we pragmatically acknowledge that aerial

1080 may at times be used and where adequate mitigation has been applied to significantly reduce

the bykill of non-target species (e.g. deer) we have a history of working with agencies not opposing

them. An example of this is several rounds of control operations in the Aorangi FP and also in the

Rimutaka (Remutaka) FP. The cooperation with and consideration given by OSPRI should serve as a

model of what is possible working together, we all win with the least stress. That noted we do

require that control operations have the need evidenced and adequate consultation and

notification needs to occur.

The branch strongly endorses the use of deer repellents and has recently contributed to Landcare

research seeking to firm up the growing body of evidence around EDR increasing the attractiveness

of pellets to rats.

Collaboration

The branch and our members seek collaborative ventures with land managers like GW and DoC.

Despite the branch having strongly supported and financed a successful judicial review against DoC

we have a very good relationship with the local conservancy, have donated rats traps to projects, have

maintenance agreements for multiple huts and run a goat control project/contract in the Mukamuka

catchment of the Remutakas. DoC have recently indicated that they wish to try and expand that

project and are contributing equipment to assist. There is strong interest from the branch in these sorts

of practical initiatives which we see as a win for all.

Where GW have evidence of a deer or goat problem we would appreciate the opportunity to be

part of the solution.

Thank you for the opportunity to comment .

G George

Secretary

NZDA HV Branch Inc.

Page | 156

088 Bloomfield, Colin To Pest Plan Inbox 26.7.18

Name

Colin Bloomfield

Email

[email protected]

Street address

70D Majoribanks Street

Suburb

Mount Victoria

Postcode

6011

Phone Number

+021 255 7993

Pest cats











Possums




Hedgehogs


Page | 157



the impacts hedgehogs have on our native biodiversity.


Mustelids




Rats




Page | 158

089 Sousa, Luis To Pest Plan Inbox 26.7.18

Name

Luis Sousa

Email

[email protected]

Street address

70D Majoribanks Street

Suburb

Mt Victoria

Postcode

6011

Phone Number

0291241790

Pest cats











Possums




Hedgehogs


Page | 159



the impacts hedgehogs have on our native biodiversity. Rule 1 for hedgehogs should also state the people should not release hedgehogs into any Key Native Ecosystem.

Mustelids




Rats




Page | 160

090 Dorifaeff, Josie To Pest Plan Inbox 26.7.18

Name

Josie Dorifaeff

Email

[email protected]

Street address

93 Matatiro Street

Suburb

Titahi Bay

Postcode

5022

Phone Number

0210379513

Pest cats





groups.







Possums




landscape.


Page | 161

Hedgehogs





Mustelids




Rats



I have a cat that use to kill birds on a weekly basis but now wears a bird protection collar which I made, getting the idea off

the internet! He he also wears a collar with a bell! He hasn’t caught a bird since! These collars should be made, advertised

and sold locally and cat owners should be encouraged to buy them them to help protect our birds! The money made from

the collars could go to Forest and Bird!



Page | 162

091 Kay, Tom To Pest Plan Inbox 27.7.18

SUBMISSION ON

GREATER WELLINGTON PROPOSED REGIONAL PEST MANAGEMENT PLAN 2019-2039 Royal Forest

& Bird Protection Society of New Zealand Inc

Tom Kay

ef.tefibs

b.:7‘` i514%irks.

LIZA& 04%

.44

Forest & Bird GIVING NATURE A VOICE

Submission sent via email to [email protected] We

wish to be heard in support of our submission.

Introduction

Forest & Bird has been around since 1923 and is New Zealand's largest independent conservation organisation with over 80,000 members and supporters.

The key matters of concern to Forest & Bird relate to the protection of ecological values, particularly tho se associated with native biodiversity, wetlands and the

coastal environment. Forest & Bird's strategic plan is for a predator -free New Zealand in which habitat and species loss has been halted and indigenous

biodiversity is flourishing by 2040. Our Strategic Plan guides our direction and our feedback on what we see to be regional priorities for pest management in the

Wellington area over the next ten years.

This submission will begin with general comments and conclude with specific submission points we would like to see addressed in the Proposed Regional Pest

Management Plan (pRPMP)


Page | 163

General comments

1. We congratulate Greater Wellington Regional Council (GWRC) for developing a plan for pest management in the wider Wellington region. Forest & Bird has

noticed a distinct withdrawal of GWRC resource in some areas of pest management in the Wellington region, particularly possum control. We hope this

proposed Plan allows for more funds to be directed towards important pest management outcomes in the region.

2. While we are happy to see such a comprehensive list of animal pests included in the list of organisms classified as pests (Ta ble 2), we feel the

mammals excluded namely feral deer, pigs and mice, are a serious oversight and must be reinstated to ensure ade quate management is

undertaken.

3. Forest & Bird believes a strong stance is required on invasive herbivores, particularly feral goats and deer and omnivorous f eral pigs. These species,

in conjunction with possums, are a serious barrier to indigenous forest regeneration in the Wellington region. Lower Hutt Branch of Forest & Bird for

example, has received a number of complaints from residents (mainly Wainuiomata) who have had deer in their garden s. We are very concerned about

the damage being done by deer, pigs and goats in local reserves, particularly when they are undermining the hard work of restoration projects in the

region.

4. Forest & Bird supports the inclusion of the mammalian pests listed as site-led pests to be controlled at specific sites, especially the rats (Norway and

ship) and hedgehogs. However, we believe mice must be included. We have noticed that once the rat numbers are reduced, the mice increase considerably.

Mice are an underestimated threat to not only our lizard fauna but also a direct competitor with native species for food such as berries and seed. Also they

keep eating the lure in our traps!!

5. Forest & Bird consider GWRC should add the following species to the animal pest list in Table 2:

Darwin's ant

Feral cattle

Hare

Plague (rainbow) skink

Pig

Deer

Mouse

2 1 J u l y 2 0 1 8

Page | 164

6. While some of these animals are listed in Appendix 2, we consider attention to the damage these animals can cause should be a ddressed in the plan

itself.

7. Forest & Bird supports GWRC supporting, inspecting and monitoring within the boundaries of predator-free Wellington initiatives but would like to see more on how

GWRC plans to undertake this and with what frequency as a lot can happen in 20 years.

8. We would like also like to see the areas for weed pest management defined more clearly. To avoid the spread of pest weeds in the KNE areas, GWRC needs

to show that it will be supporting, inspecting & monitoring within the boundaries of site -led restoration groups sites in TA reserves especially within Wellington

City. Weed management is an enormous activity and GWRC will require a lot of help from volunteers, it would be goo d to more clearly highlight how the Council

will support this work.

9. Introduced plant and animal pests have invaded a significant proportion of New Zealand's freshwater ecosystems and pose a substantial en vironmental and

economic risk to the region. Many of these pest species have a substantial impact on ecosystems and native species, as well as on recreation and tourism

opportunities/benefits. The pRPMP should establish an aquatic pest list. Council could work with DOC to establish which speci es should be included on this list.

10. Council should consider the inclusion of these pest fish species in particular:

• Ameiurus nebulosus, Brown bullhead catfish • Leuciscus idus, Orfe, golden orfe, ide

e Carassius auratus, Goldfish • Perca fluyiatilis, Perch, redfin perch

0 Cyprinus carp 10, Koi carp, common carp • Scardinius erythrophthalmus, Rudd

• Gambusia affinis, Gambusia • Tinca tinca, Tench

* Gobio gobio, Gudgeon

11. Finally, we would like to see some clarification regarding how this plan affects regional parks. Reference to reserves tends to imply this plan only influences actively

managed TA reserves in agreement with the associated TA i.e. district and city council reserves as opposed to regional parks managed by GWRC. We would like

some indication as to how GWRC intends to ensure pests are managed within the regional parks.

3 1 J u l y 2 0 1 8

Page | 165

SUBMISSION POINTS REGARDING THE PROPOSED REGIONAL PEST MANAGEMENT PLAN

Section(s),

page no(s)

Support/support with

amendment/oppose

Explanation:

We seek the following decision from the Regional

Council:

Section 3.3.1

Pg 17

Support

This section is appropriate.

Retain.

Section 3.3.2

Pg 18

Support

We agree with the statement that some "...central

government agencies (including state -owned

enterprises) have been identified as being significant

beneficiaries or exacerbators of pest management in the

Wellington Region."

Retain.

We support the notion that Crown agencies are liable to meet

the obligations or costs associated with a Good Neighbour Rule,

or action under a plan to enforce a Good Neighbour Rule in the

plan. We further support Greater Wellington to continue to

pursue and maintain formal and informal relationships with

Crown agencies to achieve the objectives of this plan.

Section 4.1

Support with

Given the 20 year timeframe for the pRPMP, we suggest

Add words to the effect that GWRC's management

Organisms amendment limiting the organisms declared as pests to such a short programme is guided by, but not limited to, the

declared as list is problematic. Should unwanted pests outside the pests that have not yet established viable or

pests Wellington Region expand their range, or arrive in New persistent populations in the region, at the time of

Zealand, GWRC should be able to undertake a small -scale writing.

eradication programme without the need to review the

4 1 J u l y 2 0 1 8

Page | 166

Pg 21 RPMP. Section 100V of the Biosecurity Act does not make it

compulsory to list all species to target. The key

requirement is that control is not inconsistent with national

policy direction.

Table 2

Support with

We are disappointed to see this table much reduced from

Reinstate feral deer (Cervus elaphus, C. nippon,

Organisms

classified as

amendment the priority species for control list in the current Regional Pest

Management Strategy. However, we are pleased to see

Dama dama) and feral pigs (Sus scrofa).

pests the inclusion of hedgehogs amongst the range of pest

mammals.

Include plague skink (Lampropholis delicata).

Pg 21 Feral deer and pigs need to be reinstated on this table. Feral

deer and pigs are causing enormous damage in the Hutt

Conduct a review of the listed weeds to ensure the

maximum number is included rather than the

minimum which appears to be the case here.

Valley in particular, especially in East Harbour Regional

Park, Wainuiomata Recreation Area and other KNE sites

across the region. Recreational hunting is not an effective

management tool for pigs or deer, site-led management is

absolutely necessary to prevent these species from

conducting further damage across the region.

Delete HCC from the programme of control for old

man's beard (Clematis vitalba). This should be site-led

across the whole region, not just within Hutt City

Council's jurisdiction.

Further to the point made above, plague skink (referred to as

Rainbow skink Lampropholis delicata in Appendix 2) should

be on this table for exclusion. While not present yet in the

Wellington Region, outlier populations of plague skink

occur close by at Whanganui, Palmerston North and Foxton

Beach. Plague skinks would pose a significant threat to the

native skinks of the region and GWRC needs to be ready to front

foot any possible incursion in the future.

The list of weeds is particularly unambitious on this Table.

We acknowledge that at a time of scarce resources then

priorities must be made. However, listing as many weeds as

5 I J u l y 2 0 1 8

Page | 167

possible here will enable advocac y for more resources to ensure

the listed species get resources necessary for management. For

example, at a minimum we would expect the inclusion of

environmental weeds such as climbing asparagus Asparagus

scandens and Cape ivy Senecio angulatus on this table.

Old man's beard Clematis vitalba is widespread outside the

limits of Hutt City Council. Greater Wellington needs to work

with other councils, particularly Upper Hutt City Council, to

ensure site-led control elsewhere in the region. This will not

only reduce infestations elsewhere but will also support the

work already done by HCC.

Section 4.2

Pg 22

Support

We support the inclusion of these organisms on a watch-list for

ongoing surveillance or future control opportunities.

We support the notion that the harmful organisms include, but

are not limited to, those species identified in Appendix 2.

Retain.

Section 5

Pg 25

Support

This section is appropriate.

Retain.

Section 6

Pest

descriptions

and

programmes

Oppose

As stated in Section 5.5, rules play an integral role in

securing many of the pest management outcomes sought by

the proposed plan. Throughout this section, particularly

with regard to animals regarded as pests, the rules are

either not presented or not ad equate to address the key

Craft adequate rules that will actually address the pest

management issues at hand for each specific pest

addressed.

Suggested text, for example:

6 1 J u l y 2 0 1 8

Page | 168

Pg 28 issues. For example, rail corridors are a significant conveyor

of pests such as feral cats, mustelids and environmental

weeds such as old man's beard. Similarly, poorly maintained

road reserves act as a vector of pests. However, more often

than not the sole rule applied simply states:

No landowner shall knowingly act as a source

of any [relevant pest] and, when notified, shall

undertake appropriate pest control.

No person shall possess any living [pest or weed] within the

Wellington Region or a KNE etc.

This rule and others provided are wholly inadequate in

securing the pest management outcomes sought by this

plan.

Section 6.2

Support with

Regarding the rules for those pests to be eradicated, there

Include a section to clarify the outcomes of non-

Pests to be

m an aged

u n der

er adication

pr o gr am m es

Pg 36

amendment needs to be some explanation of GWRC's anticipated

compliance regime after a landowner has been issued a

written direction to undertake the eradication wo rk at their

expense. Forest & Bird has seen many instances where

landowners, in particular Crown agencies, should be

undertaking pest management or letting others undertake

management on their behalf but the landowner has not

been forthcoming. Therefore, s ome explanation as to the

regulatory process on behalf of GWRC is required i.e. what

will GWRC do if landowners do not comply with these rules

even after being presented with written direction.

compliance to the rules outlined in Section 6.2.

Section 6.4.7

Support with

We support the expansion of the Regional Possum Predator

Update Figure 9 to demonstrate which agencies, if

Possum amendment Control Programme to cover the majority of the Welling ton region

but would like this programme to cover the region in

any, in addition to GWRC, are undertaking possum

control in areas not proposed to be covered by the

Pg 56 its entirety by 2030. If other agencies are controlling

possums in the areas currently presented as having no

Regional Possum Predator Control Programme by 2030.

Justification for areas without any form of

7 I J u l y 2 0 1 8

Page | 169

control (Figure 9, Page 58), we would like Figure 9 to reflect

this so it is clear who is doing what, where.

management by any agency would also be useful.

Section 6.5.3

Old man's

beard

Pg 64

Support with

amendment

As previously mentioned, control of old man's beard needs

to extend at a minimum, up the entire length of the Hutt

Valley. Hutt City Council should be only one of a number of

TAs required to control old man's beard around the

Wellington region.

Remove the specific requirement for HCC to

undertake control of old man's beard and instead

require all TAs, particularly Upper Hutt City, and

landowners such as KiwiRail and NZTA to control old

man's beard infestations.

Furthermore, the plan specifically states "Land occupiers will

comply with the rules specified in this section of the plan." But

no rules are actually presented.

Insert a rule that ensures old man's beard is

controlled by all landowners/occupiers across the

region. Suggested text:

A landowner/occupier within the Wellington

Region shall, within ten (10) working days of

receipt of a written direction from an authorised

person, destroy all old man's beard plants on

the property they occupy.

Section 6.5.5

Goats

Pg 69

Support with

amendment

We appreciate the service delivery outcomes outlined for

goats and would like to see a further outcome to ensure

feral goats are able to be controlled by GWRC on land under

active ecological restoration by community groups who are

not necessarily resourced to undertake the work themselves

or able to fund a cost recovery service when goat control is

required.

Include a service delivery that enables GWRC to

undertake direct control of feral goats as and when

required on land under active ecological restoration

by community groups without any cost to those

community groups.

Section 6.5.6

Mustelids

Support

We completely support the control of mustelids in the

Wellington region. We would support a wider vision to control

mustelids beyond the boundaries of Predator Free

Suggest looking into the feasibility of incorporating

traps into the Regional Possum Predator Control

Programme to control mustelids, among other

8 I J u l y 2 0 1 8

Page | 170

Pg 71 Wellington as well. For example, traps could be put out in

conjunction with possum control as part of the Regional

Possum Predator Control Programme across the Wairarapa.

pests, across the wider region rather than just

within the confines of Predator Free Wellington.

Section 6.5.7

Pest cats

Pg 73

Support with

amendment

We completely support a strong approach to cat

management within the Wellington region. We would like to

see an additional service delivery to enable GWRC to assist

community groups who would also like to undertake pest cat

management on their restoration projects. This would

ensure pest cat management across a wider reach than just

KNEs and TA reserves.

Include a service delivery to allow GWRC to

assist community groups who would also like to

undertake pest cat management on their

restoration projects.

Sections

7&8

Support

These sections are appropriate.

Retain.

9 1 J u l y 2 0 1 8

Page | 171

_______

092 Federated Farmers of New Zealand

McGruddy, Liz


SUBMISSION TELEPHONE 0800 327 646 I WEBSITE WWW.FEDFARM.ORG.NZ

To: Chief Executive


PO Box 11646

WELLINGTON 6142

Submission on: Proposed Pest Management Plan 2019-2039

Date: 27 July 2018

Submission from: William Beetham

PROVINCIAL PRESIDENT

Federated Farmers of New Zealand

Address for Service: Elizabeth McGruddy

SENIOR POLICY ADVISOR

Federated Farmers of New Zealand

PO Box 715

WELLINGTON 6140

M: 027 217 6732

E: [email protected]

http://www.fedfarm.org.nz/


Page | 172

Overview

1. Federated Farmers of New Zealand (FFNZ) is a member-based organisation which

represents around half of farming businesses in the region. We welcome the

opportunity to comment on the Proposed Pest Management Plan.

2. FFNZ generally support the proposed plan, including that a purpose is to maximise the

effectiveness of pest management through a regionally coordinated approach.

3. Our principal recommendation is that the time is ripe to move beyond species-specific

and site-based programmes towards a strategic focus on partnerships for multi-

species programmes at larger landscape scale.

Species-specific Programmes

4. We commend the prioritised (risk/cost/efficacy) approach which has informed the

proposals for exclusion/eradication vis-a-vis sustained control or site based

programmes.

5. The proposed plan would be improved by specifically listing those species proposed

to be added or removed from the list, with succint reasons.

6. FFNZ recommend further consideration be given to retaining African Feather Grass

on the list: we are aware of farmer experience de-flowering and spraying and achieving

good results and would welcome an opportunity to talk more with Council regarding

practicalities and costs.

Site-based Programmes

7. We note the proposals to prioritise KNEs, TA reserves and Wellington City for site

based programmes, including for control of feral cats and mustelids. We further note

(figures 10 and 11) that these are principally on the other side of the hill, in and around

the major metropolitan centres.

8. We acknowledge that some provision is made for providing advice and training (eg, for

mustelid control or to a lesser extent, feral cats) in areas around KNEs or in

“defendable or strategic locations such as peninsulas, islands or corridors”; but this is

limited to advocacy and education and does not extend to service delivery.

9. FFNZ is aware that many farmers are keenly interested and/or involved with

mustelid/cat control but currently lack support and resources to design and implement

effective programmes. FFNZ recommend consideration be given to extending service

delivery to include active partnerships with landowners to control mustelids/cats

outside the designated priority sites, including in the Wairarapa, and potentially linked

Page | 173

to the possum programme which we understand was intended to expand into multi-

species control over time.

Possum Control Programme

10. FFNZ commend GWRC for maintaining possum control across the region.

11. We agree (6.4.7) that GWRC should continue to maintain possums at low levels; and

that new programmes be established in collaboration with landowners in areas which

meet Ospri’s criteria to be declared Tb-free, not least to protect the considerable

investment the farming community have made in possum control to date.

12. The practical effect (Figure 9) is a projected very significant expansion of the control

programme through to 2030. In this context, FFNZ is keen to ensure operations are

well planned and prioritised to deliver “value-for-money”.

13. We record specific concern that there may currently be a period of some years between

the withdrawal of Ospri operations before areas are declared Tb-free (eg, Hinakura,

Tararua foothills), ie, possums may not be managed for a prolonged period,

notwithstanding that landowners are paying targetted rates.

14. FFNZ recommend that a higher level of communication between GWRC, Ospri, DOC

and landowners is required to effectively prioritise possum control programmes,

including in areas effectively but not yet formally declared Tb-free.

Landscape-scale Multi-species Programmes

15. The proposed plan describes site based programmes (KNEs, TA reserves) and the

“Predator Free Wellington” project; but is silent on the strategic intent or “fit” with the

discussions currently ongoing for catchment or community scale predator control

programmes (eg, Pukaha to Palliser), ie, linking the current “patchwork” into a

“network”.

16. We suggest the current focus on KNEs be extended to include consideration of QEII

blocks and mapping of the larger river systems and roads which are prime

habitat/corridors for possums/cats/rats etc; aligned to more explicit mapping of

“defendable, strategic areas”.

17. FFNZ recommend the Pest Management Plan add a new section explicitly discussing

the opportunity, strategy and resourcing required for making progress on multi-species

landscape scale control, including the Wairarapa Pukaha to Palliser Project.

Page | 174

Partnerships and Resourcing

18. The growing scope of regional possum programmes and the developing scale of multi-

species programmes compels a more sophisticated approach to council/landowner

partnerships.

19. In this context, FFNZ recommend that landowners be described more explicitly as

partners, rather than just as “beneficiaries or exacerbators”.

20. Across the region, large areas of biodiversity are located on private land: many

landowners want to control pests and should be seen as an asset in pest control. FFNZ

seek a pest management strategy that includes a focus on empowering landowners to

work in partnership with Council for the benefit of the entire region.

21. Currently the plan is structured between direct “service delivery” and indirect “advocacy

and education”: FFNZ recommend a third category for active partnerships with, and

resourcing of, landowners (noting that resourcing may not be direct dollars but could

include advice, infrastructure etc).

22. Another aspect of supporting public/private partnerships is information, but we note

there is no mention of IT in the proposed plan. FFNZ recommend more specific

attention to mapping and monitoring progress, eg, applications such as “TrapNZ” could

be used to provide information from the community back to Council on pests trapped.

23. The budget figures in the proposed plan are currently grouped by species, ie, $60+

million over the 10 years, currently around a third each to terrestrial/aquatic plant pests,

terrestrial animal pests, and possums). In the context of our recommendations above,

we suggest consideration be given to re-structuring information to also show:

Species-based programmes, eg, wallaby, velvetleaf

Site based programmes, eg, KNEs, TA reserves, QEII blocks

Landscape programmes, eg, Predator-free Wellington, Pukaha to Palliser

24. FFNZ recommend budget provision be made for the staff/strategy/coordination

resources required to effectively prioritise, mobilise and empower landowners and the

wider community to contribute to effective pest control across the region.

Conclusion

25. FFNZ appreciate the opportunity to provide feedback on the proposed plan. We

recommend the time is right for a bolder and more strategic approach, working in

partnership with landowners, and would welcome an opportunity to contribute to the

further development of the plan.

26. FFNZ wish to be heard.

Page | 175

093 Porirua Harbour and Catchment Community Trust

Gow, Lindsay


NAME: Lindsay Gow

ORGANISATION: The Porirua Harbour and Catchment Community Trust

PHONE: 021 159 2384

We submit that there should be two further additions to the Strategy:

1: Canada Geese; and

2: Agapanthus

Our reasons for these proposals are:

Canada Geese

Canada Geese have been a pest in the Porirua Harbour and particularly in the

Pauatahanui Inlet for some time. Their presence recurs every year and the

numbers vary. But it’s not unusual to see 50 to 80 birds in the Inlet. Their diet

includes short pasture grasses and herbaceous saltmarsh, together with sea grass.

Their feeding habits strip plants. They are crowding out other, native birds. They

roost in large numbers on the shoreline of the Inlet. They also produce large

volumes of waste – up to half a kilo per bird per day, which goes either into the

harbour or is deposited on the shoreline. They are a pest affecting the rural land

and pasture adjacent to the harbour and especially in the Pauatahanui catchment.

In terms of management options, it seems that interfering with eggs and nests is

only partially successful. Culling the birds seems to be a necessary option.

Proposal

We therefore consider that Canada Geese should be listed in the Pest Management

Strategy and that the method of management should be sustained control including

egg and nest interference and culling.

Supporting Information

The following 2013 commentary by Robin Chesterfield and Wanda Tate from the

Pauatahanui ReserveReserve Committee sets out the problems affecting the Wildlife

Reserve at the Eastern End of the Pauatahanui Inlet:

“What exactly is the problem with Canada Geese?

Firstly, the food. The preferred food of Canada geese is short pasture grasses and

herbaceous wetland plants. ‘The geese feed ravenously on the herbaceous saltmarsh

plants that fringe the tidal area and just strip them,’ says Mrs Tate. ‘At times during the

year we’ve seen groups of 20 to 30 birds on one of the Reserve tidal basins. We’re

Page | 176

particularly concerned with their impact on a rare native plant called Mimulus repens or

Maori musk.’

The voracious feeding habits of the Canada geese also seriously affect the food available

for the Inlet’s native birds. The tidal basins are the feeding spots for waders including

pied stilts,and their numbers are actively threatened by the loss of their food source.

Kingfishers and herons are also affected, as they are unable to feed at prime locations

when Canada geese are roosting in large numbers on the shorelines of the Pauatahanui

stream mouth.

The problem gets worse at the start of the breeding seasons when pairs are seeking safe

nesting sites.

The key characteristics of a good nesting site are a plentiful food supply for the adult

birds and quick easy access to a reliable waterway, since water is the safest environment

for newly hatched goslings to escape to. Such sites are essential until the goslings fledge

and then throughout the summer until the moult is over and the adult birds can fly again.

Suitable breeding and moulting sites are often quite limited in area and several pairs of

geese will nest around the same site, with an average nest containing anything up to

nine eggs. Bird expert and Chairman of Forest and Bird’s Pauatahanui Wildlife Reserve

Committee Robin Chesterfield notes that when the geese first nested in the Wildlife

Reserve there were seven adult birds and 26 goslings roosting along about 15 metres of

grassed track, feeding there and in the adjacent pond.

For the last few years a particular tidal basin in the Reserve has been the preferred

nesting site for up to six Canada geese breeding pairs. Unfortunately this tidal basin is

not only the main feeding ground for the native pied stilt but also its chief nesting site.

The Canada geese are using the shell islands where the stilts normally nest as lookout

posts and pushing the native birds out. ‘Their presence is endangering an important

southern North Island pied stilt breeding colony,’ says Robin Chesterfield.

And finally, that awkward question of poo. Canada geese are large birds that eat a

lot and produce a lot of waste – up to half a kilo per day per bird goes into the Inlet. It

doesn’t take many birds concentrated into such a small area for 4-6 weeks to do a lot of

damage. Public access tracks are fouled to the point where they become unusable, but it’s

the muddying and fouling of the habitat used by the native birds that causes the most

concern. ‘Herons, pied stilts, shovellers – they’re all being affected,’ says Wanda Tate.

So much for the problems. What about solutions? Research has been done into how best

to control geese numbers, including into the effectiveness of intervening at the hatching

stage. That has already been tried at the Reserve. ‘We had hoped that population control

could be achieved by finding the nests and preventing the eggs from hatching but that

hasn’t worked,’ says Wanda Tate. ‘We were quite optimistic when no goslings were

hatched in the Reserve in 2013, but unfortunately late in the breeding season three pairs

of geese that had raised clutches further afield brought their goslings into the Reserve so

our efforts at controlling numbers at a specific vulnerable site were largely ineffective.’

Page | 177

In Canada and USA, where Canada geese are increasingly entering the ‘peri-urban’ (as

opposed to wild) environment in damaging numbers, experience seems to indicate that

interfering with breeding by addling or oiling eggs is not enough to offset the effect of the

20-30 year life expectancy of the geese.

An increase in total numbers of birds in the wider area will put even more pressure on

current nesting and moulting sites. More destruction of the saltmarsh plants, more fouling

of the Inlet and its edges and further intrusion into the habitat of the native birds would be

inevitable. ‘Here at Forest and Bird Pauatahanui we are conservationists, but conservation

of our native bird and plant life requires immediate control of Canada geese numbers. We

can’t let numbers just go on increasing. Future generations would never forgive us, says

Wanda Tate.

Agapanthus

Agapanthus is a weed plant that forms dense and expansive mats that are hard to

eradicate. It has been bred because of its looks and flowers, but it tends to

overpower and led to the exclusion of other, including native, vegetation. It

occupies increasing areas of land around the Porirua Harbour and adjacent to

roads, reserves and walkways. It is also now invading and thriving on seashore

areas around the Pauatahanui Inlet.

Proposal

Agapanthus should be eradicated on all public areas (such as road berms, reserves

and walkways), and the harbour foreshore. Its propagation and sale should be

banned from garden centres. Information should be provided to property owners

on the pest status of agapanthus and how to control it.

Other Matters

Council Eradication Programmes

We wonder why only the Hutt City Council is keen on eradicating the three weeds

(Banana Passionfruit, Cathedral Bells and Old Man’s Beard), but the other

councils are not active. Old Man’s Beard has a strong hold along the rail corridor,

in the Porirua harbour catchment and there is an example of it spreading upstream

along a water course. It invades and eventually decimates trees which then fall

into water courses. Wellington City Council does not, to our knowledge, activelyactively

do anything, despite the fact Old man’s Beard grows up WCC fences in very

prominent places. We consider Old Man’s Beard could and should be eradicated

in the area of the Porirua Harbour catchment and perhaps all other territorial

authority areas.

Wasps

We consider that wasps should be getting more attention/action. We wonder how

GW will encourage others to manage wasps, as indicated in the Proposed Strategy.

The training and certification for vespex bait use is straight forward, and costs

Page | 178

about $100, but then you have to buy the new bait (around $50). So the out of

pocket expenses for individuals can be quite high for what is essentially an action

for the public good. We would like to see more leadership and encouragement,

free training and reduced cost bait sales. The impact by wasps on the food chain is

understated and adversely affects the wider ecosystem

Mobile Community Services

We would like to see GW have mobile community drop in hubs (eg a weekend

morning / weeknight evening) where people can be educated, get traps serviced,

buy bait without retail margins and support community back yard efforts.

Extending Eradication and Control

In relation to possums, rats and mustelids, the Proposed Strategy refers to work in

TA reserves, but our local knowledge from the Porirua Stream catchment suggests

that this applies only to some reserves – for example the Amesbury reserve in

Churton Park and Friends of Tawa bush reserves. The Glenside reserve isn't

getting any GW support and possums, rats and mustelids are rampant. We suggest

that eradication and control measures for these pests should be applied to all

reserve areas.Otherwise the problem remains uncontained.

Page | 179

094 Sandom, Alan To Pest Plan Inbox 27.7.18

Name

Alan Sandom

Email

[email protected]

Street address

176 Cockayne Road

Suburb

Ngaio

Postcode

6035

Phone Number

044793836

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of

native species including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so

humans need to control their numbers. Without management cats undermine any predator control work

undertaken by council and community groups.


I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of

a pest cat is: “a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest

Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on

private or public land within the Wellington Region, without the permission of the occupier.”

Possums


Possums significantly impact both primary production and biodiversity and controlling their population is an

important regional goal. Urban control is also important to prevent reinvasion into both significant ecological

areas and the rural landscape.


Page | 180

Hedgehogs





Ecosystem.

Mustelids



An additional rule should be added to make it clear that releasing a mustelid within the Wellington Region is an

offence.

Rats




Page | 181

095 Raumati South Residents

Association Daniell, Trevor


The Chief Executive


Submission on the Pest Management Plan, 2019-2039.

In the article “Pest Management Plan targets healthy environment “

(gw,govt.nz posted July 3 2018) there is no mention of the

Argentine Ant as a pest animal.

However, both Argentine and Darwin’s are listed in the category

“surveillance” in the article “Pest Animals” (gw,govt.nz posted 20 July 2018.)

We are presuming that the more recent article is the most current position.

We are aware that these ants are extremely difficult to control these ants, and

acknowledge that eradication is no longer feasible. However, given our recent

experience running an ant-baiting trial in Raumati South (attached) we believe

it is possible to manage the infestation.

Page | 182

We believe that management is absolutely necessary for the sake of our

biodiversity and for the sake of the people who live in our region. Ant

infestation is threatening our lifestyles, our well-being, our property values and

our environment. It may not be possible for the GWRC alone to “sustain

control” but it may be possible to reduce infestation by 80% when done in co-

operation with partner councils and community organisations.

We therefore submit that the Argentine Ant, and the Darwin's Ant be included

in Wellington Region's 2019-2039 Pest Management Plan, under the category

of “sustained control” or “suppression”, whichever is the term currently being

adapted in the new management plan.

We recommend that Argentine and Darwin Ants continue to be listed as “site-

led” control but if infestations are found in particularly sensitive areas (for

instance in parts of urban areas) they can be moved into the elimination

category as was done at Rarangi Beach in Marlborough.

RSRA is concerned that GW denies any responsibility in urban areas and

District Councils do not have the where withal or the inclination to provide

relief to the affected communities.

We also note that in the initial Pest Management consultation in 2017, many

public submissions requested far greater “engagement, consultation and

cooperation”, between the GWRC, its Council partners, and community

groups.

We endorse this request. We are aware that the GWRC and the KCDC do co-

operate to identify infestations but we are concerned that statutory

responsibility for control of pest plants and animals lies with the GWRC alone

and district Councils do not act.

Page | 183

RSRA is also concerned that the white ant is not listed and it is if anything more

difficult to eliminate than the Argentine ant, and probably far more expensive

but is not listed.

We therefore request that in the new Pest Management Plan 2019-2039 it be

stated that the GWRC and its partner Councils and DOC clarify responsibilities

and cost sharing, and to coordinate pest management campaigns (along with

the public) on specific issues. DOC would have a much better chance of

success keeping Argentine ants out of Kapiti Island, if there was a public

awareness campaign and on-going community baiting operations in the

surrounding area. Had this been done when argentine ants first arrived we

would have had more chance to eliminate them.

This submission is based on our own experience running an ant-baiting trial

involving 28 households in the Poplar Ave/Dell Rd area. We discovered that

both the Argentine ants and White-footed ants are so well established in this

area, that they are seriously affecting the quality of life of the residents who

live there, as well as the biodiversity of our environment, as already

mentioned. All those who took part are keen to repeat the experience in

spring, and many are continuing the borax baiting during the winter months.

After three months of slow borax baiting, one resident has, for the first time in

three years, got no argentines in her compost. Anecdotal evidence suggests

that ants are a major problem throughout the rest of Raumati Sth also, from

Menin Rd, south to QEP. However, apart from the Poplar Ave/Dell Rd area, we

have no evidence of which ant is established where.

Unless ant numbers are reduced, a pleasant outdoor and sustainable life is

going to be impossible in Raumati South, and probably the whole of the Kapiti

Coast. In the meantime it is a time-consuming, stressful and expensive

problem, which can never be resolved if householders operate alone. They

need help to work together with themselves and with Councils, in a

determined, knowledgeable and co-operative environment.

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Given our specific knowledge of how widespread and numerous the Argentine

Ants are in the south of Raumati South and how difficult they are to control,

The Raumati South Residents Assn recommends;

1) That the Argentine Ant and Darwin's Ant be categorised as “sustained

control” or “suppression”, 2) That a category be allocated for the White-footed Ant recognising that

though it is not a danger to the environment it is a major stress factor in the lives of many urban coastal householders, extremely difficult to eliminate, time-consuming and expensive. If this ant is not included on Regional's list it has no statutory significance.

3) That GWRC and its partner Councils and DOC clarify responsibilities and cost sharing, and coordinate pest management campaigns (along with the public) on specific pest problems.

4) That the Pest Management Control Plan 2019-2039 will require regular publicity about pests including extermination or control measures,

Trevor Daniell

Chair

Raumati South Residents Assn

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096 Lower Hutt Forest and Bird,

Secretary Vinton, Jennifer


Submission on GWRC Proposed Regional Pest Management Plan 2019-2039 July 2018

We totally support and endorse MIRO submission.

Lower Hutt Branch of Forest and Bird is very concerned that feral deer and pigs are proposed to be

downgraded from being a Site-led pest category to being classified as 'harmful organisms' and that

neither of these feral ungulates is a priority for pest control under the proposed plan.

Our branch has recently complained to GWRC about deer problems in Lower Hutt area and received

a ‘not our problem’ response.

We have noticed that there are areas of the eastern hills where nearly all the palatable shrubs and

trees in regenerating bush are dying. These have been killed by ungulate bark stripping and

subsequent fungal infections. Some of this regenerating bush is over 90 years old and calculations

show there is negative or minimal carbon sequestration.

We note that this is a 20 year plan, so it is of huge concern that these pests if left to their own

devices for two decades with population growth unchecked.

GWRC publications show a STAG AT BAY standing (and no doubt later fouling) in a MOUNTAIN

STREAM. Walking track photos show NO UNDER STORY and a large proportion of bare branches and

trunks lying dead on the ground.

GWRC has to decide whether it is looking after native biodiversity or providing a safari park for the

Huntin Fishin brigade. In our opinion it can’t do both. It is a legal obligation to do the former but not

the latter.

One only has to look at TV hunting programs to see how ineffective hunting is in preserving native

flora and fauna - it’s more like farming - kill the odd trophy for its head and leave the rest to breed.

At least with farming nutrients are replaced with fertilizer, this is not the case with GWRC

management.

We understand that GWRC add deer repellent in the way of pig blood to 1080 drops. This should

stop and lines of bait with sufficient 1080 to kill deer and goats should be used.

4.1 Pest Plants

We feel the following species must be added to the control list:

Japanese honey suckle (Lonicera japonica) – program: eradication region= wide

Sweet cherry (Prunus avium) – program: eradication region wide

Hawthorn (Crutaegus monogyna) – program: site led eg Hutt Valley, Wainuiomata

Climbing asparagus (Asparagus scandens) – program: site led eg Te Whiti Park, Lower Hutt,

Ngaio Gorge, Wellington

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Lower Hutt Forest & Bird

Jennifer Vinton

Secretary

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097 Naenae Nature Trust

Mitchell, Andy


Naenae Nature Trust 16 Strand Crescent Naenae Lower Hutt 5011 Naenae Nature Trust submission on the Regional Pest Management Plan 2019 – 2039 27 July 2018 Kia ora, We write to you as Trustees of the newly-formed Naenae Nature Trust, and as individuals who have contributed to the work of many other conservation groups throughout the Wellington region. We have reviewed both the proposed Regional Pest Management Plan 2019 – 2039 and the Current Regional Pest Management Strategy 2002 – 2022, and note the change in status of some pest animal species. It is pleasing to see the elevation of rats and mustelids to the status of ‘Pests to be managed under Site-led programmes’ in line with the national Predator Free 2050 goal, but disappointing to see the reciprocal demotion of recreational hunting species feral deer and pigs to ‘Other harmful organisms’ status, “because, although they may have significant adverse effects, regulatory responses are not considered appropriate or necessary.” Your own website and 2002 – 2022 strategy note that “Deer are highly adaptable feeders that both browse and graze. Intensive browsing can remove much of the forest under-storey and strip bark from trees, impacting plant biodiversity”. There is certainly much evidence of this around the region. Deer numbers seem to be on the increase in bush surrounding suburban areas including ours. We see constant evidence of the presence of deer close to hillside homes, the Rātā Street Loop walking track and the Taita Cemetery, and it was recently reported that a stag was chased down a Naenae street by dogs. Unlike rats and possums, larger pest animals like deer and pigs simply cannot be controlled in any way by local residents or, in our immediate surrounds, even by licensed hunters. Our organisation plans to put great community effort and resources into restoring local forest ecosystems over coming years, yet it seems this may be futile if deer (and pigs, should they also move into our neighbourhood) are allowed to breed unchecked for the next 20 years and browse on or otherwise harm any native flora we plant into local hills. We assume there is some rationale that recreational hunting will keep numbers sufficiently in check, but this has not been the case of late. Recreational hunters have a vested interest in leaving populations to regenerate, and as already noted hunting cannot be undertaken in our local environment anyway. We believe that active control of feral deer and pigs throughout the region is both appropriate and necessary. Furthermore, we note with great envy a significant contribution to the Predator Free

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Wellington initiative, but no mention of even a contingency for leading or supporting consolidated community efforts elsewhere in the region now, or should similar efforts arise any time in the next 20 years. We also note that the Hutt Valley is excluded from the Regional Possum Predator Control Programme both currently and in planned expansions in 2025 and 2030. Again, this is a 20 year plan so the implications are significant – if a similar Predator Free Hutt Valley project came together as early as next year, we cannot see any indication that it would be supported in the same way as Predator Free Wellington until at least 2040, ten years short of the national goal. Thank you for the opportunity to submit on this proposal, and we do hope our concerns can be addressed. Warm regards, Andy Mitchell, Brendan Elks and Katie Elks Trustees, Naenae Nature Trust

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098 Eastboune Hunters and Gathers

Bearman, Wilf


Due to your text boxes on your website not working I have had to hand write this form.

To whom it may concern

I represent the Eastbourne Hunters and Gathers Club with increase at new members we have been

with increase of new members we have been asked to state our case for more access to hunt in the

East Harbour Park. This could be achieved by extending the Ballot system Professional as well as

recreational hunters have to follow the same legal requirements stipulated by the law. Helping Bill

Manson with the wild food Festival each year we can’t supply locally harvested meat because of the

restrictions you have placed on us.

We would like to see less culling and more involvement by recreational hunters to control pig, deer and

goat populations.

GWRC must remember the Park is not only for Groups like MIRO that hold extreme views but are other

users as well.

GWRC must remember deer, pigs are considered GAME animals not pest animals we all realise they

have to be kept at a manageable number

I find this form NOT Professional as one has to hand write it.

The person that designed and uploaded this form needs to be replaced as it was not tested.

I would like to speak to my submission.

Thank You

Wilfred

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099 Ministry for Primary Industries

Hare, Mike


Thank you for the opportunity to submit on the proposed Greater Welling Regional Pest

Management Plan (the Plan). Our comments are largely general, and reflect our role in oversight of

the biosecurity system and the implementation of the National Policy Direction for Pest

Management. However we do have some specific comments regarding wilding conifers and marine

biosecurity.

National Policy Direction for Pest Management (NPD) Consistency.

In general we find the plan is not inconsistent with the NPD. We would recommend that the rules

and supporting information be reviewed to ensure that land occupiers are properly able to

determine whether a rule applies to them. For example, the map of the Key Native Ecosystems used

for the site-led programme in the Plan is too small. We would recommend a clearer map, or to

incorporate a list of the KNEs by reference to make it easier to use.

MPI led programmes

MPI would like to thank the Council for supporting the National Interest Pest Response and National

Pest Plant Accord programmes, and other national programmes such as the Check Clean Dry

freshwater advocacy programme. We would also like to express our appreciation for your

engagement with the Biosecurity 2025 initiative.

Velvetleaf.

MPI support the inclusion of velvetleaf in the Plan. As velvetleaf is a species that MPI consider to be

of particular risk we are glad to see its inclusion within the Plan as an eradication species.

Wilding Conifers

MPI submits that Wilding Conifers are New Zealand’s No. 1 weed and, therefore, should be

included in the schedule of Organisms declared as pests. MPI is concerned that by not including

Wilding Conifers as a pest in the Plan, the Council will not be able to respond efficiently or

effectively to any emerging areas of wilding conifer spread.

We note that the the Plan has no specific provisions for any programmes concerning Wilding

Conifers. The Plan refers to ‘Wilding pines’ as a harmful organism1. The Wellington Region is

fortunate that Wildings have not become established to the extent seen in other regions. However,

there is approximately 800 hectares of Wilding-affected land in the region. Managing this infestation

and keeping the region clear of Wildings will be assisted by including appropriate provisions in the

Wellington Regional Pest Management Plan.

The core components of the material that MPI recommends be incorporated into proposed RPMP

wilding conifer programmes include:

Consistent adoption of the wilding conifer ‘definition’, where Wilding Conifers are

specified as a pest in the RPMP, and

Regulatory ‘protection’ of public investment in wilding conifer control. This means:

o A requirement for occupiers to remove any Wilding Conifers subsequent to

publicly funded wilding conifer control on their land. This requirement would be

triggered by publicly funded control work being undertaken, and, thereafter,

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hands ongoing ‘maintenance’ responsibility to occupiers.

o An externality obligation (essentially a boundary rule) applying to land adjoining

land where publicly funded control has been undertaken. The relevant provisions

in the material are Rules 4, 5 or 6, depending upon the nature and geographic

delineation of the RPMP programme.

o Regulatory support for any objective that includes keeping clear areas clear. Given

the relatively low infestation in the Wellington Region, this would prevent new

areas of wilding conifer infestation and halt the cycle of new ‘legacy’ areas of

Wilding Conifers being created.

Additional components of the material that MPI strongly encourages regional councils to use

include:

Consistent use of the standardised description of the adverse effects of Wilding Conifers,

Consistent use of the standardised objective statements and statements of intent for template rules where these are used,

Specification of the five recommended conifer species as pests where these are present and spread prone in a particular region.

If MPI’s request for the inclusion of Wilding Conifers as a pest in the Plan is accepted, the 2016

guidance document includes a standardised statement of the adverse effects of Wilding Conifers,

which could be included in the Plan.

Further information and MPIs guidance on setting rules for Wilding Conifers in Pest management

Plan are attached to this submission.

1 Marine Biosecurity

MPI requests that the Council:

1. add the following marine pests to an Exclusion Pests Programme in Wellington Harbour:

Sabella spallanzanii (Mediterranean fanworm), Styela clava (clubbed tunicate), Eudistoma

elongatum (Australian Droplet Tunicate), Pyura doppelgangera (Pyura sea squirt) and Charybdis

japonica (Asian Paddle Crab).

2. Add the following marine pests to the Exclusion Pests Programme in Porirua

Harbour/Pauatahanui Inlet: Sabella spallanzanii (Mediterranean fanworm); Eudistoma elogatum

(Australian Droplet Tunicate), Pyura doppelgangera (Pyura sea squirt) and Charybdis japonica

(Asian Paddle Crab).

3. Add the following marine pest already established in Porirua Harbour/Pauatahanui Inlet to

a sustained control programme or other long term management approach: Styela clava

(clubbed tunicate).

Both MPI and regional councils have an important part to play in marine biosecurity.

MPI has a leadership role for biosecurity and manages biosecurity risks offshore, at New Zealand’s

border and within New Zealand. This includes setting border standards for arriving vessels and goods

(e.g. the Craft Risk Management Standard), undertaking national high risk surveillance for high risk

organisms at key New Zealand ports, including in Wellington, leading responses to new to New

Zealand pest incursions, and providing leadership for pest management activities.

Councils have responsibilities for both species–led management and pathway/vector management.

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This is set out in Table 4 on page 16/17 of The Pest Management National Plan of Action (2011). In

our pest management leadership capacity, MPI is working with a number of regional councils to

build marine pest management capability.

Wellington Harbour currently has few marine pest species compared to a number of other regions

with busy shipping and high recreational vessel usage. For example, Sabella spallanzanii

(Mediterranean fanworm) and Styela clava (clubbed tunicate) are serious and significant marine

pests in the Auckland region. Further, both species have been found in small populations in Picton,

Nelson, Tarakohe and Lyttelton, although there are elimination programmes for Sabella in those

South Island locations.

The harbour does already have one notable and well established marine pest species - Undaria

pinnatifida (Undaria, the Asian Kelp or Wakame) is well established. Yet, other significant marine

pests have not become established, in particular, the Mediterranean fanworm, while the clubbed

tunicate has only been detected on two occasions associated with decorator crabs. Wellington

harbour remains vulnerable to incursions of marine pests via infested commercial and recreational

vessels arriving from other locations. There is therefore an opportunity for the Council to take

proactive measures to prevent further pest establishment in the harbour.

Unfortunately, the clubbed tunicate has become established in Porirua Harbour and can be expected

to spread further, including to subtidal areas of the Pauatahanui Inlet, if left unmanaged. This in turn

poses risks of infestation of Wellington Harbour through infected vessels visiting from Porirua

Harbour and Mana Marina.

It is also important that the Council take steps to ensure the marine pests currently in its region are

not spread to new areas.

MPI is of the view that a number of significant marine pest species should be included in the Greater

Wellington Regional Council’s regional pest management plan (RPMP) so that appropriate actions

can be taken, where required. The Council may also wish to consider implementing pathways

management focussed rules, or working with MPI to promote voluntary actions (e.g. regular cleaning

and antifouling of vessels) to prevent marine pest spread.

Key facts: Mediterranean fanworm (Sabella spallanzanii) Grows in very high densities, high growth rate, settles on a wide range of substrates including structures, vessel hulls and the sea bed, potential to outcompete shellfish like scallops and mussels or planktonic food, is an “ecosystem engineer”. Clubbed tunicate/Leathery sea squirt (Styela clava) Grows in high densities, settles on structures, vessel hulls and sea bed, potential to outcompete shellfish like scallops. Australian droplet tunicate (Eudistoma elongatum) Currently found in the Northland and Auckland regions, but likely to extend its geographic range with increasing water temperatures. Grows in unsightly dense colonies during warmer months on structures and mudflats.

Pyura sea squirt (Pyura doppelgangera)

Detected in Northland region and as biofouling on several commercial vessels (Wellington and

Nelson). Grows on hard substrates in sheltered to moderately exposed areas, potential to

outcompete native biodiversity, including mussels, and occupy significant areas in the lower

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intertidal/upper subtidal, known as an “ecosystem engineer”.

Asian paddlecrab (Charybdis japonica) Very aggressive crab, potential to outcompete native crab species and predate on native

biodiversity.

Thank you again for the opportunity to submit on the Regional Pest management Plan. If you have

any questions or wish to discuss any of these points further, please contact Mike Harré on 04

8940533, or [email protected].

Yours sincerely

John Sanson

Manager Recovery and Pest Management


Page | 194

100 Masterton District Council

Hopman, David


From: Masterton District Council

PO Box 444

MASTERTON

Email; [email protected]

Phone; 06 370 6300

SUBMISSION ON PROPOSED REGIONAL PEST MANAGEMENT PLAN 2019-2039

Thank you for the opportunity to make a submission on the proposed Regional Pest Management

Plan 2019-2039 (pRPMP).

In general, MDC supports the pRPMP; however, we ask that Greater Wellington Regional Council

(GWRC) consider the following;

Canadian Geese

• From correspondence with GWRC, MDC understood that Canadian Geese were to be included in

the RPMP as a “Pest” organism, and that a cost benefit analysis regarding this was carried out. This

cost benefit analysis does not appear to have been included with the documentation, and we would

like to receive a copy of this.

• Additionally, the pRPMP includes Canadian Geese as a “Harmful” organism. Council would prefer

to see these categorised as a “Pest” organism with a Regional control programme in place, as this

will provide more effective control.

• If this cannot be justified under the Cost Benefit Analysis, then MDC would be prepared to enter

into an “Alternative” pest management arrangement (e.g. management plan or MOU) with GWRC.

We are happy to discuss the details of this further.

• MDC notes that Canadian Geese are considered a pest species for a number of reasons;

• Canada Geese continue to be problematic at Henley Lake and Homebush WWTP. • Community concerns, particularly at Henley Lake, around the health and

recreation impacts. • The risk that Canadian Geese pose to helicopters, given the close vicinity of the

Wairarapa Hospital helipad to Henley Lake. • Impact on native species through competition for food and space. • Impacts on pasture from grazing and fouling.

• MDC notes that Canadian Geese are no longer protected under the Wildlife Act, and the

Department of Conservation (DoC) are carrying out monitoring and control programmes on

Conservation land.

• We are also aware of control programmes on Lake Wairarapa that are supported by DoC and Fish

& Game as a local control measure. While we support this initiative, we believe that a Regional

approach would be more effective.


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Recommendations

1. That GWRC provide a copy of the Cost Benefit Analysis carried out for Canadian Geese Control.

2. That Canadian Geese be included as a “Pest” species in the Plan.

3. If “Pest” status cannot be justified by the Cost Benefit Analysis, then GWRC and MDC enter into

an alternative arrangement for pest management.

Pest Cats

• MDC recommends that GWRC expand the area for the sustainable control of pest cats to include

the Masterton district. The pRPMP proposes control of pest cats in Key Native Ecosystems (KNE)

areas and TA reserves. Currently, none of those identified areas are located in the Masterton

District. (Note that the pRPMP refers to Appendix 3, Maps 1 and 3. It appears that this should refer

to Appendix 3, Maps 1, 5 and 6.)

• The Masterton district is largely rural and includes many recreational areas, including important

native ecosystems, that boarder rural and urban land. Including the Masterton district in the

controlled area will help to reduce the impacts that pest cat populations are having.

Recommendations

1. That GWRC includes the Masterton district as an area for ongoing inspection, surveillance

and monitoring of the pest cat population; and

2. Carry out pest cat control where appropriate to protect the biodiversity values of the areas.

This would include entering into funding agreements with MDC for management of TA reserves.

Other

• We support the Rook control programme in the pRPMS across the whole Wairarapa. Again, as with

Canadian Geese, we believe that this is best dealt with as part of a regional programme.

The Masterton District Council would like the opportunity to attend any hearing and speak to this

submission.

Ngā mihi, nā

David Hopman

Chief Executive (Acting) Masterton

District Council

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101a Wellington City Council Emeny, Myfanwy


Page | 197

101b Wellington City Council Biaggio, Daniela To Pest Plan Inbox 10.8.2018

FROM WELLINGTON CITY COUNCIL Wellington City Council supports the purpose of the Proposed Regional Pest Management Plan (the Plan) to minimise the actual or potential adverse or unintended effects associated with these organisms. We would be happy to discuss this further at a hearing or otherwise. Our Natural Capital – Wellington’s biodiversity strategy and action plan (2015) sets out a range of goals, objectives and actions that link closely with the Plan. This includes controlling pest species to sufficient levels to protect our indigenous biodiversity, and eradicating them where possible. We appreciate the reference to Our Natural Capital in the Plan. Partnerships provide the capability and capacity to win the war against pest species. We welcome working closely in the development of pest management plans in the future. And we want to work together in the development of the operational plan to achieve the best outcomes.

General points We support the hierarchy of exclusion, eradication, progressive control, sustained control and site led control. We commend that commitment to see eradications through. We would like to work further with GWRC on where individual species sit within that hierarchy. We assume that any exotic pest organism not found in the area should be considered for exclusion (for example didymo). We are interested in the plan further exploring the potential for eradication from parts or the whole of the region. Sustained control can deliver the ecological benefits but often at an increased long term cost. Furthermore, for many species, particularly with some weeds, evaluating the wellbeing of the habitat can be as costly as the control itself, making evaluating the success of the operation is tricky. We consider that some species might be more cost effectively eradicated from the region or parts of the region. We think this plan should not be constricted by operational budget but identify species where eradication would be a cost effective and viable solution. We welcome more investment in protecting the indigenous biodiversity values of the KNEs and we are keen to know what increased investment in KNE control will result from this plan. We recommend the Plan include a summary for accessibility of the document. We would like Greater Wellington Regional Council (GWRC) to have a clear role in accessing private property for the purpose of carrying out key biosecurity work. We would welcome more clarity around how this plan works alongside other plans in the region to deliver effective pest management. In particular how GWRC may work with the Department of Conservation and the Wild Animal Control Act to help tackle some of the challenges we face in Wellington when it comes to pest species such as deer. The Biosecurity 2025 MPI direction statement makes recommendations on how we will achieve success in the pest challenge. This includes free flowing information and sharing of data, and improved analysis to help us make better pest management decisions. We hope the Plan will incorporate this principle and that in particular pest plant information will be more actively shared between our two agencies.

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The Plan only requires GWRC to report annually against a separate Operational Plan. We would like to

understand when and how this Operational plan will be developed and reported on. We propose that

five-yearly reports of performance against the Plan should also be prepared. Public confidence in biosecurity is strongly based on published performance information and effectively communicated

scientific evidence and these reports would help this process.

The cost benefit analysis was often hard to follow or lacking information making it hard to evaluate sustained control against eradication. For example, Purple loosestrife is only in a few areas around lakes (Wairarapa and Kohangapiripiri and Kohangatera). It isn’t clear why it can’t be eradicated given these limited areas of occurrence. Page 87 of the impact assessment and cost benefit analysis seems to indicate it would cost 80K a year to eradicate compared to over 45K for control, but does not specify timeframe for eradication which makes it hard to evaluate that as a whole. Clarity on this issue would be useful.

Pest Animals Council welcomes the Draft Strategy’s support for Predator Free Wellington. We consider it desirable to liaise with Porirua City in the delivery of Predator Free Wellington. The most likely boundary for eradication in the medium term is State Highway One so eradication in the western part of Porirua will be very helpful. The maps, particularly in relation to possums need to show this more clearly. (pages 64, 81 and 104) We encourage the inclusion of the use of best-practice methods in respect of the humaneness of animal pest control in the plan. Deer, Pigs and Goats We oppose the taking feral deer and feral pigs out of the Plan. Feral pigs are a growing pest problem in Wellington. In Te Kopahou Reserve and along the South Coast they are one of the primary threats to the threatened speargrass weevil due to their destruction of Aciphylla. Feral deer are also posing an increasing risk to our indigenous biodiversity values. We propose the Plan should include an aim to manage feral deer and pigs to reduce adverse effects on the environment. There should also be reinforcement of the rule that no person shall move or allow to be moved any feral animal to or within the region. Numbers of feral pigs and deer and goats are growing in Wellington City. Before the problem becomes larger we would like to consider eradication within the South West Peninsula. The Pest Plan should support that objective, including the power to enter properties where landowners are not conducting necessary control. Over the past seven years there has been the South West Peninsula goat project which manages

goats over 4000ha of Wellington City Council reserves and private land to the South West of

Owhiro Bay. More than $500K has been spent on this project to date. This project was initially funded with help of the Biodiversity Condition Fund ($185K and GWRC $50K), and has been

continued by Wellington City Council since 2014. More than 6,700 goats have been controlled,

which has enhanced the natural regeneration and restoration planting in both private and reserve

areas. Since this investment ceased, goat numbers are again starting to rise. This causes significant

damage to ecological recovery including on in coastal areas an across Council’s Outer Green Belt.

We propose that this be included as a site led programme in this plan for the control or possible

eradication of goats in the site.

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These pest animals should be managed in areas where they pose a particular risk to key species. Monitoring and surveillance of key risk areas for these highly mobile species would be required. Rabbits Sustained control is the preferred option for rabbits. We support a sustained control programme to reduce the impacts and spread to other properties. And the continuation cost recovery service to occupiers we welcome the necessary equipment, skills and experience that GRWC provide to this service. We are interested in understanding the feasibility of eradication and the findings from biocontrol agents. Hedgehogs We support the inclusion of hedgehogs in the Plan and welcome further investment and guidance into their surveillance and humane control. They are currently a significant bycatch of pest control work, and are likely to be significantly impacted by the eradication of rats, possums and mustelids as part of Predator Free Wellington. Their control and eradication would significantly benefit insect, lizard, and some bird populations. We encourage GWRC to support further research and trials into the humane control of this species. Pest cats We support the inclusion of pest cats within the Plan, and welcome the opportunity to work with GWRC on effective pest cat management. We would like some clarity around what is meant in the plan with regards to allow for pest cats to be maintained ‘with the permission of the occupier’. Cats roam so will generally go beyond the ‘occupiers’ land. Wellington City Council supports the gradual reduction of stray cats through humane management practices. Wasps Council understands there is experimental work being done on wasp control and eradication. We would support reference to this in the Plan. Other Harmful Organisms Clarification is required on the extent of work that may take place for other harmful organisms. The document is unclear as to how species listed as Other Harmful Organisms will be managed. In some parts of the region eradication may be possible, in others it will be about suppression. We believe the document should cover some level of detail around this issue. We are particularly concerned about mice as these will need increased monitoring and possibly control and we need to have the potential to adapt operations as a result of the changes in species dynamics that might result from Predator Free Wellington. Given recent events where rainbow skinks were found, education and surveillance work is required to protect the region from this threat, and a proactive approach should be a part of the Plan. This is supported by discussions had with the Wellington Regional Lizard Network.

No mentioned is made of other TA’s amongst the organisations that GWRC would partner with to

control Other Harmful Organisms. There is mention of ongoing surveillance but no explanation of how

that would work and what indictors from surveillance operations might lead to a response.

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Pest Plants We are significantly concerned at the reduction in number of pest plants listed under the plan. Now only 15 pest plants out of more than 200 species are included in the Plan. The Regional Pest Management Plan is a guiding document for many other agencies, NGOs and volunteer groups with regards to what threats need to be managed. We believe the reduction in the list of pest plants at this regional level could lead to the reduction in control of those species by other agencies or parties. The Plan fails to mention why several pest species are no longer listed, eg their cost benefit analysis. The changes in the planned boundary control for Old Man’s Beard would result in changes on Council land. Whist we support some investment on boundary control, when the wider issue of the pest plant is not tackled is likely an ineffective strategy. We would welcome the redirection of that effort to help control Old Man’s Beard in properties bordering KNE land and significant natural areas when the Old Man’s Beard is absent in those reserves. We welcome increase oversight for Greater Wellington on the role of key land owners such as KiwiRail and NZTA in terms of their obligations under this plan. We need concerted efforts in control of pest plants such as Old Man’s Beard in order to achieve the environmental outcomes and contribution from those operations which increase pest plant dispersal is crucial. Wellington City as an urban environment is threatened by an abundance of pest plants and more are jumping the fence from gardens on a regular basis. We have heavily invested in pest plant control, and have extensive records of the work and progress which focuses on priority sites. We would like the opportunity to review with GWRC the development of site led programmes, and to allow private property access. We are supportive of the continued site led work on Boneseed control. Finally, the Plan should contain a clear statement of what ‘success looks like’. Wellington City has over the past 25 years been working consistently to restore and enhance the environment including indigenous biodiversity. We want this Plan to support us in that objective and the vision set by Our Natural Capital. Better understanding the outcomes and vision of success the plan is working towards will support for continuous improvement and delivery of operations to achieve it.

Thank you for the opportunity to comment and we look forward to continuing our close relationship

around biosecurity management in Wellington. We welcome and opportunity to discuss these issues

further with GWRC before the approval of the Plan.

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102 Feline Rights To Pest Plan Inbox 27.7.18

Greetings,

Our submission to the GWRC RPMP consultation and associated documentation appended:

* Submission-To-GWRC-RPMP-Consultation-180727.pdf

* linklater-and-steer-predator-free-2050.pdf

* gwrc-submissionto-epa-in-support-of-papp.pdf

* Virbac-NZ-Product-Recall-Notification.pdf

* Modelling The Mesopredator Release Effect.pdf

* The-Vacuum-Effect-Why-Catch-And-Kill-Doesnt-Work.pdf

* Culling-Feral-Cats-Actually-Increases-Their-Numbers.pdf

Pete Rose (Secretary)

Feline Rights New Zealand

http://felinerights.org/

http://felinerights.org/

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26 July 2018

Submission To Greater Wellington Regional Council

Regional Pest Management Plan Proposal Consultation

Antifelinism? We're Not Amused!

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Introducton

New Zealand is presently suffering from a form of mass psychosis, this has occurred due to a deliberate social engineering

process intended to indoctrinate New Zealanders into a thoroughly extremist form of environmentalism. No sane person

can deny that an ideology with killing as one of it's core beliefs is an abberation from the norm. Players in this ongoing

social engineering campaign include both Local and Central Government, Local Government New Zealand, Department of

Conservation along with various private organisations, for example Forest and Bird, the Morgan Foundation, the Next

Foundation, Predator Free New Zealand and others which includes the complicit mainstream media.

Of particular concern to us is the ongoing unjustified demonisation of Cats and those who are guardians of Cats. This in

particular has been ongoing and incessant. We've coined the terms antifelinism and antifelinist to cover those within the

community who harbor a burning hatred of Cats and those of us who keep Cats in the interest of making the connection

between the discrimination directed against Jewish people which occurred in Germany under National Socialist rule. The

Jewish people were valuable contributors to society, yet they were demonised and summarily dealt with. The National

Socialists went so far as to compare persons of Jewish heritage to rats, subjected them to curfews, required compulsory

identification and ultimately consigned millions of individuals to death.

The comparison between what was done in National Socialist Germany and what is now being done in New Zealand is

quite clear for those who have eyes to see and are not in total denial of it. Let's be clear, speciesism is a very similar

abberation to racism, thus we feel the term antifelinism is an accurate representation of what is presently being conducted

in New Zealand.

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The Arbitrary Term "Pest Cats"

Let us begin with the term 'pest Cats' which has been used in the RPMP proposal. This is an arbitrary term fabricated by

antifelinist 'conservation' extremists such as Gareth Morgan of the Morgan Foundation and his daughter Jessi Morgan,

the spokesperson for Predator Free NZ. It has no basis under New Zealand law. New Zealand officially acknowledges three

classifications of Cats: Companion Cats, Stray Cats and Feral Cats. The definitions of the three types of Cats from a legal

perspective is covered in the Ministry of Primary Industries Companion Cats - Animal Welfare (Companion Cats) Code of

Welfare 2007, henceforth referred to as The Code.

Ministry of Primary Industries Companion Cats - Animal Welfare (Companion Cats) Code of Welfare 2007

https://www.mpi.govt.nz/dmsdocument/1413-companion-cats-animal-welfare-code-of-welfare-2007

This is a code of welfare issued under the Animal Welfare Act 1999.

On page 10 of the Code is section 1.8, the glossary, which defines the three types of Cats as follows:

Companion Cat - Common domestic cat (including a kitten unless otherwise stated) that lives with humans as a companion

and is dependent on humans for its welfare. For the purposes of this code, will be referred to as 'cat'.

Stray Cat - For the purposes of this code, means a companion cat which is lost or abandoned and which is living as an

individual or in a group (colony). Stray cats have many of their needs indirectly supplied by humans, and live around

centres of human habitation. Stray cats are likely to interbreed with the unneutered companion cat population.

Feral Cat - For the purposes of this code, means a cat which is not a stray cat and which has none of its needs provided by

humans. Feral cats generally do not live around centres of human habitation. Feral cat population size fluctuates largely

independently of humans, is self-sustaining and is not dependent on input from the companion cat population.

Our view is Greater Wellington Regional Council has chosen to willfully ignore the classification of Cats as defined under

the Code and now attempts to collapse the legal definition of New Zealand's stray Cats so that stray Cats are informally

classified as 'pest Cats', thus providing a fabricated loophole which GWRC erroneously believes will grant them license to

conduct mass executions of Cats in the name of politicised 'conservation'.

The legal opinion we have obtained is quite clear that local government has no power to define a particular species as a

'pest'. This is the role of the Governor General acting on the recommendation of the Minister of Conservation under the

Wildlife Act 1953. By attempting to collapse the legally defined categories of 'stray' and 'feral' into a single informal

category of 'pest Cat' the council acts outside of it's mandate. This approach is totally unacceptable to us and leaves the

council wide open to legal challenge should the RPMP proposal as it stands be approved by council when the matter goes

to vote.

We will next document some of the senior staff involved with 'biodiversity' and 'biosecurity' at Greater Wellington

Regional Council so all citizens are aware of who is who in these departments. On 03 July 2018 two articles appeared in

the media covering the RPMP proposal, the first, a press release from GWRC published at Wellington Scoop, the second a

media report published in the environment section at Stuff.

Smothering, Strangling And Killing - GWRC Press Release - Featuring Wayne O'Donnell

http://wellington.scoop.co.nz/?p=110480

Wellington's Most 'Unwanted': GWRC Releases 'Pest' Hit List - Featuring Davor Bejakovich

https://www.stuff.co.nz/dominion-post/news/wellington/105181268/

http://www.mpi.govt.nz/dmsdocument/1413-companion-cats-animal-welfare-code-of-welfare-2007

http://wellington.scoop.co.nz/?p=110480

http://www.stuff.co.nz/dominion-post/news/wellington/105181268/

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The Good, The Bad and The Ugly

Left: Dr Jamie Steer - GWRC Senior Biodiversity Advisor and Compassionate Conservationist.

Center: Wayne O'Donnell - GWRC General Manager Of Biodiversity and Local Government New

Zealand (LGNZ) representative at National Cat Management Strategy Group (NCMSG).

Right: Davor Bejakovich -GWRC Biosecurity Manager

Let's begin with Jamie Steer, in our view he is one of the good guys. From his thesis entitled 'The Reconciliation of

Introduced Species in New Zealand' through various media articles and interviews on national radio, he has tirelessly

acted as an advocate for introduced species and for a common sense approach to ecology and conservation. He recently

co-wrote a paper questioning the logic behind the idea of Predator Free 2050 with Dr Wayne Linklater, Associate

Professor of Conservation Science and Director of the Centre for Biodiversity and Restoration Ecology at Victoria

University which is an eye opener to say the least. While we are not a great fan of Dr Linklater because of the numerous

antifelinist articles he has published online via his sciblogs site, we raise our hat to Jamie and Wayne for their stance on

Predator Free 2050 which they describe as a flawed conservation policy which displaces higher priorities and better,

evidence-based alternatives.

Wayne Linklater and Jamie Steer - Predator Free 2050 - A Flawed Conservation Policy

http://felinerights.org/linklater-and-steer-predator-free-2050.pdf

GWRC general manager (biodiversity) Wayne O'Donnell was one of the Local Government NZ representatives who

participated in the National Cat Management Strategy Group (NCMSG), along with the likes of Morgan Foundation

general manager Geoff Simmons. NCMSG is a private organisation which advocates the mass execution of Cats via "a blow

to the head with a solid object", "a head shot with a firearm", usage of a "captive bolt tool" and that "all methods should

be followed by a secondary method, a throat cut to ensure that the animal dies from blood loss". Their entire 'strategic

implementation consultation document' may be downloaded here:

NCMSG Strategic Implementation Consultation Document

http://www.nzcac.org.nz/images/downloads/nz-national-cat-management-strategy-discussion-paper.pdf

See page 44 of this document for their recommended methods of executing Cats. See also page 52 where you may read

about the "pervasive, intense and continuing campaign to 'educate' the public about the impacts of cats on wildlife and

human health and the resulting need for culling", something no one can deny has been occurring across the boards on a

weekly basis in the NZ media since at least 2013 when self styled übermensch Gareth Morgan began his accursed 'Cats To

Go' campaign.

In a media article dated 13 May 2016 published in the environment section at Stuff, Wayne O'Donnell said his council

strongly supported limiting cats to three per household, and even fewer in areas that were rich in wildlife. He is quoted as

stating "Making companion Cats identifiable will assist with the control of unwanted Cats in wildlife sensitive areas. But

unfortunately, many of the companion Cats are predators themselves". Whichever way we look at it, Wayne O'Donnell is

no friend of Cats or their guardians and because he was instrumental in planning the Feline holocaust we encourage

Wayne to immediately resign from his position at GWRC.

As to GWRC Biosecurity Manager Davor Bejakovich, his comments in the Stuff article dated 03 July 2018 we have linked

to above speak volumes and are worthy of close attention. The RPMP apparently designates some $85,000 of ratepayer

funds per annum to deal with the alleged problem of 'pest Cats' which the article states are "classified as not microchipped

in an area where microchipping was compulsory; free living, unowned and unsocialised, and with little or no relationship

with, or dependence on, humans.

http://felinerights.org/linklater-and-steer-predator-free-2050.pdf

http://www.nzcac.org.nz/images/downloads/nz-national-cat-management-strategy-discussion-paper.pdf

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Compare that description with the classification of Cats as defined under the Code and it's quite clear GWRC takes the

Wellington regions Feline guardians as fools and attempt to fudge the law.

Davor Bejakovich is quoted in the article as stating: "It's very unlikely we will be trapping cats in the Wellington urban

area but it would give us an ability around areas like Zealandia, to live-trap cats." If we take a look at the following image

of Zealandia sanctuary it's obvious the sanctuary is surrounded on three sides by residential areas. If GWRC, it's private

partners or commercial pest control operatives were permitted to trap Cats around the sanctuary, it is inevitable that

much loved companion Cats will be captured and executed simply for being Cats.

Zealandia Sanctuary - Not the smartest place to put it.

Davor Bejakovich stated "If they're chipped then they would be returned, if they're not owned they would be passed on to

a rescue organisation or killed." Alright, that clarifies things somewhat, he's happy to kill Cats if that's what he thinks is

required.

Even if live captured and the Cats they catch return a positive identification via a microchip scanner, the Cat is still likely

to suffer lasting trauma from being trapped and then mishandled by disrespectful cruel people who do not know how to

handle Cats. Additionally, a trapped Cat will tend to revert to instinctual mode and display all of the characteristics of a

feral Cat making it next to impossible for anyone to get a reading on a microchip scanner. Because of this we believe what

is likely to occur is Cats they capture will be designated as feral and summarily executed in the name of politicised

'conservation'.

To the east of the sanctuary separated by a residential area is the Polhill Reserve. It is an area subject to intensive

ecological 'restoration' and forms part of the arbitrarily designated 'halo' or 'buffer zone' around the sanctuary itself. This

area was embodied into the town belt via the Wellington Town Belt Act 2016 during the watch of the rabid

environmentalist Mayor Celia Wade-Brown.

The term 'halo' is one coined by the antifelinist Gareth Morgan and this 'buffer zone' was imposed on citizens who reside

in the area without reasonable notice or consultation. The Polhill restoration project is funded by GWRC, WCC and the

Morgan Foundation, it is home turf for the Polhill Protectors environmental extremist group lead by one Paul Stanley

Ward, an antifelinist who once wrote an article which described keeping Cats as "a perversely self-destructive act, like

smoking or eating only deep fried Mars bars". Joseph Goebbels himself would buy Polhill Paul a bottle of schnapps for

such a grand effort in the propaganda stakes unequaled since the days of the Der Stürmer tabloid itself.

What happened is the native birds started setting up shop beyond the sanctuary on their own accord and the area was then

defined as a Key Native Ecosystem (KNE). While GWRC has a page on their website which covers KNE areas, we are

quite unclear exactly what administrative and political processes used to designate a KNE and we have yet to view any

documentation which accurately describes scientific research methodology that is used to justify the KNE designation.

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Because of this we are forced to the conclude a KNE in Wellington is similar to the "ecologically significant site"

designation used by Auckland Council in that it's "not a specific technical term, but rather wording developed in

collaboration with council's media team to communicate complex technical information to the public". In other words it's

very likely to be a purely arbitrary term fabricated by the council's propaganda office which may be applied at whim by

council biodiversity staff to any area of reserve land for any reason whatsoever if it suits them to do so including a burning

desire to execute our Cats.

The Wellington City Council planning office describes reserve land as follows: "Our formal definition of reserve land is

public land set aside for recreational, ecological, landscape, cultural and/or historic purposes and generally managed

under a reserve management plan prepared under Section 41 of the Reserves Act 1977. There is approximately 4000

hectares of land managed as reserve. Road frontage is often called "road" reserve but is not reserve as defined above."

So, it's clear enough what GWRC's intentions are, any tiny area of reserve land where a single gecko lizard or fantail is

spotted may be designated as a KNE if it suits them, and they hope that in itself will grant them a license to kill en mass.

We had not heard mention of Davor Bejakovich so we did what we do and and conducted an investigation and you will

never guess what we found. Davor the Devious has been consulting with the Environment Protection Authority advocating

the reduction of notification area for the dedicated Cat poison known as PAPP (Para-Aminopropiophenone) in the form of

a formal submission from GWRC in support of the Cat poison manufacturer Connovation. GWRC would not have their

own biosecurity manager filing a formal submission in support of this heinous poison if they were not intending to use it, so

we'd better take a look at what PAPP is, how it works and what it does.

GWRC Submission To the Environment Protection Agency In Support Of PAPP by Davor Bejakovich

http://felinerights.org/gwrc-submissionto-epa-in-support-of-papp.pdf

PAPP (Para-Aminopropiophenone) - The Zyklon-B Of Predator Free

Spot the difference - Two different poisons, their usage in enforcement of totalitarian political policy is the

same.

Marketed by NZ company Connovation as Predastop, PAPP kills via hypoxia, coma, and death due to the inhibition of

cellular respiration. Connovation's brochure states "The onset of symptoms is rapid and stoats and Cats are usually

unconscious within 45 minutes", however the information we have received suggests it is a terrible inhumane poison:

Quote:

After a cat has ingested a bait containing PAPP there is a lag period before signs of toxicosis such as head nodding,

lethargy, ataxia (uncoordinated movement and difficulty maintaining balance), salivation and sometimes vomiting are

observed. As the toxicoses progresses, cats collapse and cannot move voluntarily. They appear unresponsive, but still show

signs of awareness until they become unconscious for a short period just before death. The duration of the lag phase,

duration and severity of symptoms and time to death can be highly variable.

In a pen study of 31 feral cats that ingested 78mg PAPP baits, the average time from bait consumption until signs of

poisoning was 3 hours 51 minutes (range 43 minutes to 15 hours). The average time from onset of symptoms to collapse was

72 mins (range zero to around 5½ hours) and the average time from collapse to death was 107 minutes (range 30 minutes to

around 8 hours). So this bait can go either relatively well, or terribly for the animal involved. Feeling deathly ill, to actual

death, can range from 43 minutes to 15 hours. The period from collapse to insensibility which is identified as a time where

an animal is conscious and aware, but unable to defend itself or move voluntarily, can be anything from 30 minutes to 8

hours. A poison which leaves an animal immobilised, but conscious and slowly dying for anything up to 8 hours is anything

but 'humane'.



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Suffering: The lag period is likely to be associated with minimal suffering, however after the onset of clinical signs when

cats cannot coordinate body movements it is likely that they will experience some distress, confusion and anxiety as they

cannot perform normal behaviours (e.g. standing, moving, feeding, drinking, defensive and escape behaviours). Lethargy

and weakness are also potential sources of distress. In addition—during the later phase of toxicosis when cats are unable to

move but are still conscious—if they were not able to seek appropriate shelter prior to becoming incapacitated, they are at

increased risk of predation (e.g. from crows, other predators), aggression (e.g. from dogs) and environmental exposure,

which could lead to further distress and suffering.

End Quote:

When sufficient beloved companion Cats have been killed by Connovation's Cat poison that the public become aware of it,

social unrest will be an inevitable consequence. This could conceivably involve outraged citizens interfering with bait

stations and the associated risks of such action if PAPP were to be deployed in urban and residential areas.

We here at Feline Rights strongly discourage such action and would be the first to notify the authorities if we had

intelligence on citizens planning to break the law. However, we cannot monitor the entire nation and there is no telling

what some outraged citizens may do when they feel their family members are under a clear and present threat from

Connovation's Cat poison being deployed in their locality.

Failure Of Microchips

Before we cover the matter of failure of microchips it is important to note that the current Wellington City Council animal

bylaw was created via an illegal process. The bylaw was essentially back engineered and we have a considerable amount of

evidence obtained via LGOIMA request in the form of emails shared between WCC councillors and staff which

demonstrates this is so. Also, WCC first created the animal bylaw, then a year later consulted on animal policy. This is not

the way of good democratic governance. If WCC were truly playing by the standard rules they would have first consulted

on policy then created the bylaw. The fact WCC did the opposite and created the bylaw prior to consulting on policy would

likely be frowned upon by the court and could easily result in the court declaring the bylaw ultra vires.

There is a belief microchips are an infallible method of providing identification. However some veterinarians disagree. Dr

Alan Probert, a senior vet at Miramar Vet Hospital is on record as having noticed some microchips failing to scan. He

expressed concern that "people are living with a false sense of security about the microchip's ability to track and find their

'pet' if it goes missing" and "My concern and I think it's probably every vet's worst nightmare would be that a dog or a

Cat might be inadvertently euthanised, even though it's microchipped". Alan Probert also stated "the problem is

occurring across a range of chip makers".

24 October 2012 - Vet Concerned At Faulty Microchips

http://www.radionz.co.nz/news/national/119027/vet-concerned-at-faulty-microchips

In our second example, Dr Roger Barnard of Kerikeri Veterinary Clinic has provided the following statement about

microchips to our colleagues at Northland Cats In Balance:

"To whom it may concern, microchips placed into animals can be useful for identification but there have been failures that

have occurred. On occasions some expel from the animal soon after insertion, some fail to be read at some later date

because of manufacturing failure and movement of microchip to other parts of the body".

The third example provides total proof that microchips are not an infallible method of identifying companion animals. In

January 2018, Virbac NZ issued a recall of some 15,000 microchips which they determined are prone to failure. We append

the product recall notification from Virbac NZ. We feel this is proof enough microchips can and do fail and thus microchips

should not be used to determine who lives and who dies in the name of profit and environmental mass hysteria.

08 January 2018 - Virbac NZ Product Recall Notification (PDF 235kb)

http://felinerights.org/virbac-nz-product-recall-notification.pdf

http://www.radionz.co.nz/news/national/119027/vet-concerned-at-faulty-microchips

http://felinerights.org/virbac-nz-product-recall-notification.pdf

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Auckland Protest 28 March 2018 - The shape of things to come throughout the nation

While we have already seen protest action in Auckland, thankfully the protests there have so far been peaceful events. Go

down the path of using the microchip ID to determine who lives and who dies and sooner or later companion Cats will be

killed and once citizens become aware of it there is no telling what enraged citizens may do. The media will have a field da

with it, those elected representatives who voted for it will not escape with their political careers unscathed and social unrest

will be an inevitable consequence.

Potential Adverse Ecological Consequenses Of Removing Cats

Which is better for the environment? Pest control the old fashioned way via the good

efforts of our Feline friends? Or the scourge of biological warfare via the RHVD virus?

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The Mesopredator Release Effect

Modelling The Mesopredator Release Effect (PDF 360kb)

http://felinerights.org/Modelling%20The%20Mesopredator%20Release%20Effect.pdf

In truth, Cats as the apex predator are valuable assets who contribute to the control of rodents, rabbits and mustelids.

Remove the apex predator from an ecosystem and this results in what is known as the mesopredator release effect. We

append a paper from the Journal of Animal Ecology entitled 'Cats Protecting Birds: Monitoring the Mesopredator

Release Effect' which covers the scientific perspective in detail. In New Zealand there are documented instances where the

removal of Cats from a locality has resulted in a explosion of the rat population which in turn has had a marked adverse

impact on birdlife. In 2013 in Raglan, persons known to be native bird enthusiasts took it upon themselves to kill all Cats

they could find in Raglan West. One resident had six of her Cats murdered for the cause of 'conservation'. The local vet

clinic documented a total of 16 missing Cats over a period of 12 months in Raglan West.

9 September 2013 - Raglan Cat Lover Wants Out As Killings Continue

http://www.stuff.co.nz/waikato-times/news/9142152/

Within three months, local ecological consultant Adrienne Livingston is on record in the media stating: "I am now

observing the effect the marked absence of Cats is having on this suburban ecosystem". She expressed concern about the

number of half-eaten eggs and dead chicks appearing, all killed by rodents the Cats would have dealt with were they still

around to do their job.

18 December 2013 - Raglan Cat Killings Annihilate Local Birdlife

http://www.stuff.co.nz/environment/9531706/

During winter 2016 DOC put the idea of a predator proof fence for Rakiura/Stewart Island on hold and decided they

would first go after Cats. Media reports at the time suggested the Morgan Foundation and Predator Free Rakiura were

involved in funding the mass execution of Cats on Rakiura/Stewart Island.

12 June 2016 - DOC Puts Stewart Island Predator Fence On Backburner

https://www.stuff.co.nz/environment/80940208/

Multiple Cat killer Phillip Smith claimed "Getting rid of all the wild Cats would change the dynamics of the island".

14 June 2016 - Stewart Island Residents Back DOC's Plan To Get Rid Of 'Feral' Cats

https://www.stuff.co.nz/environment/81014907/

Eight months after 'conservationists' began engaging in the Feline holocaust on Rakiura/Stewart Island, Phillip Smith was

proven correct. The ecological dynamics of the island had indeed changed, but not in the way intended. The following

column written by experienced trampers details their experiences on the Rakiura track and elsewhere on the island. They

stated they "found large rats were everywhere, not only around huts and campsites but on all parts of the tracks". DOC

staff confirmed a much higher rat count than seen for many years. While two successive rimu mast years and inadequate

'pest' control are cited as the causes, we have no doubt the wholesale execution of the islands Cats is a more likely cause of

the sudden increase in the rat population on Rakiura/Stewart Island.

21 February 2017 - Rats A Symptom Of Something Rotten In Protection Of Conservation Estate

http://felinerights.org/Modelling%20The%20Mesopredator%20Release%20Effect.pdf

http://www.stuff.co.nz/waikato-times/news/9142152/




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Documentation provided by the environmentalist movement claims it is "estimated that feral, stray and 'pet' cats kill up to

100 million birds in New Zealand each year". Estimate is the key word here, we have seen zero evidence based scientific

research to support this claim. The bottom line is this figure is likely a huge overestimate provided by private

environmental extremist and antifelinist groups such as Morgan Foundation, Forest and Bird and Predator Free NZ. Well

known animal advocate Bob Kerridge's recent opinion piece published in the NZ Herald covered the matter of 'research'

designed to demonise Cats in the interest of furthering the primary aim of the antifelinists which is the total eradication of

all Cats.

1 March 2018 - Campaign Against Cats Is Using Shonky Evidence

http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=12003469

Many of the misconceptions of the alleged impact of Cats on 'native biodiversity' and the suggestions on what may be done

about it provided by the environmental extremist movement have been thoroughly refuted by competent common sense

ecologists such as wildlife ecologist John Innes of Landcare Research:

15 January 2015 - Cats Not NZs Main Culprit Killers


22 January 2013 - Gareth Morgans Cats To Go Campaign Questioned

http://www.newshub.co.nz/environmentsci/gareth-morgans-cats-to-go-campaign-questioned-2013012300

Consultant ecologist Mark Bellingham, who at one point was North Island Conservation Manager for Forest and Bird

stated: "at night cats are actually really good at getting rid of rats and mice. That's the bulk of what they take."

10 July 2017 - Cat control - Are Councils Too 'Wimpy' To Do It Themselves?


The Vacuum Effect

The Vacuum Effect - Why Catch And Kill Doesn't Work (PDF 550kb)

http://felinerights.org/The-Vacuum-Effect-Why-Catch-And-Kill-Doesnt-Work.pdf

Engage in the removal of Cats from a locality and one is confronted by what is known as the 'vacuum effect'. What this

means is more Cats will move in to where the initial colony once was. We append a document by Alley Cat Allies which

covers the matter of the 'vacuum effect', and an article from Science Alert which demonstrates the vacuum effect in action

in Tasmania.

Culling Feral Cats Actually Increases Their Numbers (PDF 91kb)

http://felinerights.org/Culling-Feral-Cats-Actually-Increases-Their-Numbers.pdf

Recommendations

* Remove all entries of the term 'pest Cats' from the RPMP proposal and abide by the classifications of Cats as defined

under the Code. Failure to do so will inevitably result in legal challenge.

* Biodiversity staff need to purge themselves of the 'kill them all' approach, because by going down that path they may do

more harm to an ecosystem than good. Remove the Cats and a plague of rats who will do more damage to bird life than any

number of Cats is a certain consequence.

* Do not waste ratepayer funds hiring private pest control operatives, to deal with the alleged problem with Cats. These

people are professional killers who delight in dispensing death and are highly unlikely to engage themselves in ethical live

capture activity.

* Totally reject the usage of the inhumane Cat poison PAPP in the Greater Wellington region.

* Responsibility for the attempt to flout the law by including the arbitrary term 'pest Cats' must ultimately be laid at the

feet of GWRC general manager of biodiversity, Wayne O'Donnell. He got that inconceivably wrong and we believe this was

a deliberate act on his part in support of environmental extemism and antifelinism. Therefore he should either do the right

thing and immediately resign from his position or alternatively the council must recognise he has miserably failed in his

duties and thus should be immediately dismissed.

Remember: A vote for the RPMP proposal in it's current form which includes the arbitrary term 'pest Cats' is a vote for







http://felinerights.org/The-Vacuum-Effect-Why-Catch-And-Kill-Doesnt-Work.pdf

http://felinerights.org/Culling-Feral-Cats-Actually-Increases-Their-Numbers.pdf

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the Feline holocaust. Do you really want the blood of these beautiful highly sentient beings on your hands?

A vote in favour of the RPMP proposal is a vote in favour of the Feline holocaust

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103 Harvey, Annette To Pest Plan Inbox 27.7.18

I strongly support the inclusion of pest cats within the Regional Pest Management plan, not just in

KNEs.

I am particularly concerned that pest cat control should be carried out in the WCC Reserves

adjoining Zealandia.

Last season I monitored the breeding success of toutouwai (N.I. Robins) in the these reserves and

found that each season there is ample dispersal of toutouwai (and other endangered endemic

passerines) to support the establishment of new populations, and the birds are able to breed

successfully. However individual survival is too short to enable populations to establish. Monitoring

of tieke showed similar results.

Extensive trapping for mustelids and rats has been undertaken by community groups in Polhill and

parts of Te Kopahou, (which were the only areas where pairs were able to establish), and tracking

tunnel results show that these predators are being kept at very low levels. This strongly suggests

that cats are the major cause of mortality.

Now micro-chipping of companion cats is compulsory it should be possible for live trapping to take

place, and pest cats eliminated.

One of your Service Delivery objectives is "direct control of pest cats within KNEs as part of the

integrated management of those areas, to levels that protect the biodiversity values of the areas.'"

I suggest that the reserves around Zealandia have the potential to be of more significance to the

Wellington community, and possibly also greater value to our endangered taonga, than the KNEs, if

pest cat control is undertaken. Of course companion animal control would also be needed

eventually, and I suggest GWRC should consider legislation that would mean cat owners would have

a 'duty of care' similar to dog owners eg registration, control and containment.

More public education is needed around what approaches exist to limit the impacts cats have on our

native biodiversity, and how companion animals are contained in most other countries, with the

emphasis on the companion animal’s welfare.

There is much publicity about aspirations to make Wellington the Nature Capital, and, in this GWRC

Plan, too effect "Highly significant ecological outcomes – more birds, lizards and invertebrates

contributing to healthy functioning ecosystems." However, this is encouraging unrealistic

expectations unless elimination of pest cats (and the containment of companion animals) is

included. In fact, the encouragement and proliferation of back-yard rat trapping may have the

reverse of the desired effect since with low rodent numbers cats will obviously prey on more birds

and lizards. This will mean not only a reduction in biodiversity but may also lose community

enthusiasm and support as their justifiable expectations of more obvious bird life are not fulfilled.

Therefore I feel that extensive control of pest cats, and gradual education and legislation on the

containment of companion animals, is an essential part of any pest management plan which will

satisfy community expectations. (Obviously, the same limitations apply to the widely publicised

effects of the misleadingly named 'Pest Free 2050' campaigns.)

I also think that the ‘neuter and release’ policy is not in the cat’s best interests and therefor possibly

illegal.

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And I strongly endorse the use of aerial 1080 as an essential tool to save endangered birds until

better methods are found. There is more than sufficient scientific evidence for its efficacy and

importance, eg Jan Wright’s reports.

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104 Le Quesene, Lana To Pest Plan Inbox 27.7.18

I am concerned that deer are not included in the GWRC Pest Management Plan targets list posted by

the GWRC on 3 July 2018. My concern has two main aspects that I hope the GWRC will provide

solutions to, and will incorporate into future pest management plans.

Concern One:

1. I live out the back of Wainuiomata with a view of the hills of the water catchment area. The

view sustains me, and the rainfall over those trees, down those hills, into the lake, provides

more than enough water to keep Wellington baristas busy. You recognise the significance of

that area being free of deer and the deer proof fencing attests to that. Having the vegetation of

that area collapse after heavy grazing by pest animals and particularly deer would play havoc

with the regions water supply.

2. Outside of those fences, goats have destroying the undergrowth of reserves in the Hutt that

I’ve visited, and that other people have told me of. People from other regions have the same

stories. Once the undergrowth has gone, the bush will not sustain itself and will collapse. Loss of

the natural ecology of the area would be a shame.

3. Given that carbon sequestration is important, and the role of forests and bush areas in that

is significant, please move to ensure all parks and reserves in the wider Wellington area are

deer free to avoid collapse of the vegetation.

Concern Two:

4. When I came to live here 14 years ago, I left half of my section to regrow itself, joining the

reserve in ecological character. I seldom saw deer. Perhaps one or two could be heard roaring on

the other side of this gully a year. A few years on, and nibbled young sapling and deer droppings

occurred from time to time. Not often enough, or doing so much damage, as to warrant concern

or to note the frequency.

5. The reserve which my place shares a short border with, was a delight to live next to. Tui,

Kereru, an occasional lone Kotare, Piwakawaka, Riroriro, Tauhou, plus other birds were all

over the place. Once trees were over a few metres, a nesting pair of Korimako started feeding

just outside a bedroom window.

6. Then I noticed stumpy sticks where I’d transplanted koromiko and coprosma, and during

the last three years, the damage has increased significantly and is absolutely disheartening.

Deer have

crossed my place to demolish a neighbour’s citrus trees. A herd of four have frequently been

seen on a security camera, grazing and bouncing about. And a visit into the adjoining reserve

shows massive grazing damage. They’ve run out of food in there, which is why they're grazing

around my house.

7. I checked the GWRC website for who to call. This suggested ringing a gun

club. Three points against that:

a. I did not feel up to being responsible for the safety of neighbours, including those on the

other side of the hill and random bush walkers.

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b. I didn't see how one hunter at my place was an effective strategy to cull deer.

c. I don't have resources to hire or any cover costs incurred.

That was three years ago, since then I've rung the GWRC & HCC, and while staff at each were as

helpful as they could be, there was no solution found.

Others in this street have visits from deer, and gardeners have lost crops and saplings. There are

rumours of culling in other areas, which was promising. People have been up in the reserve doing

out of season roaring and, not knowing who they are or if they’re armed, I avoid the backyard. There

were rumours of a six pointer being shot further along the gully. I saw one at my place a few days

before. This raises concern an accident could happen as no one said they intended hunting here.

The outcome of the review I would like is the GWRC being responsibility for eradication of deer in

urban areas and in all parks and reserves in the GWRC area.

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105 Kāpiti Project Mckay, Andy To Pest Plan Inbox 27.7.18

Introduction

Thank you for the opportunity to comment on the Greater Wellington Proposed Regional Pest

Management Plan 2019-2039. Ngā Uruora is grateful for the support we receive from GWRC to help

with our conservation efforts in Kāpiti. In particular, we are grateful for the support given via the

KNE programme. We are also grateful for the effort GWRC put into culling goats on Perkins farm

thus preventing them spreading into our site.

Predator Free 2050

You state “Engaging with the community will form a large part of the project, and lessons learned by

the Crofton Downs Predator Free Community group and others will inform how we both design and

implement the project design.”

It would be useful to get some more detail into the RPMP around what this actually means in

practice. There are varying levels of support for community conservation groups across the region.

We are grateful for GWRC providing brodifacoum and dried rabbit meat for our pest control

operations, but we are aware that this level of resource is not available to other groups, and for no

discernible reason. GWRC should be an enabling organisation in this space rather than putting up

road blocks for some groups.

We are also concerned that GWRC has over recent years pulled out of some possum control

operations carried out in the South Kāpiti/Pukerua Bay area. We and other landowners we are in

contact with have seen an increase in possum activity since this reduction in effort.

Harmful organisms and pests

You state that “Regional councils are mandated under Part 2 (functions, powers and duties) of the

Act to provide regional leadership in activities that prevent, reduce or eliminate adverse effects from

harmful organisms that are present in their regions.”

It is difficult to follow the reasoning as to why some organisms are classed as pests and others are

not. This appears to be an entirely arbitrary process. It would be helpful to have some clarification

about this process and a set list of criteria that a harmful organism has to meet before it is

considered a pest species.

Spending

The projected yearly spending on pest control hardly changes from 2018/19 through 2027/28. It

does not give an indication of this spending as a percentage of total GWRC spending, which may or

may not to be projected to be growing over time. If this is not inflation adjusted spending this is

likely to represent a real decline in spending over time. It would seem difficult to support an

expanding Predator Free 2050 effort across the region without some increase in spending. The

spending section seems very limited in such an important document.

The responsibilities of transport agencies and KiwiRail

As you note in your report there are more than 230km of state highways in the Wellington Region.

You note that the Transport Agency is the occupier of the Crown land on which the roads lie,

together with the road reserves extending to the adjoining land owners/ occupiers’ property

boundaries. As you state, land under the Transport Agency’s jurisdiction is subject to the rules for

Page | 218

land owners/occupiers as defined in the RPMP, so it has the same obligations as any other land

occupier. There are also adjoining Road Reserves.

The Main Trunk line borders our project and Ngā Uruora also occupies KiwiRail land. You note that

land KiwiRail occupies is subject to the rules for land owners/occupiers as defined in the RPMP, and

KiwiRail has the same obligations as any other land occupier.

Finally, you note that amendments to the Biosecurity Act arising from the Biosecurity Law Reform

Act 2012 now make the Crown bound by those rules identified as Good Neighbour Rules in plans.

While in theory these agencies are good neighbours, in reality they harbour weeds and pests that

then migrate onto our conservation projects.

Examples are:

Along the boundary of the Ngā Uruora project there are many weeds on both NZTA and KiwRail

land. These include boxthorn, pampas, English ivy and climbing asparagus. Ngā Uruora spends a

considerable amount of time trying to control these weeds (sometimes using grants from GWRC).

But there are sites we cannot enter for safety reasons so seed sources continue to be present. We

note that there is a considerable amount of pampas along the base of the Transmission Gully project

which the project seems to be protecting. This is despite Ngā Uruora lobbying the project to get rid

of it.

Pampas is also rapidly spreading along the highway and the rail line on the boundaries of Queen

Elizabeth Park and Whareroa farm. Pampas is at a point in southern Kāpiti where it could be

eradicated. In a few years’ time it could be impossible to get rid of.

We also we catch more animal pests along the boundaries of our projects. These are untrapped

areas, often with good food sources such as dumped food waste.

Cats

Since placing motion triggered cameras in our trapping areas we have a greater awareness of cat

presence. We are also aware of the growing scientific evidence suggesting cats are important

predators. We therefore support the inclusion of pest cats within the RPMP.

We agree with the proposal the definition of pest cats to be change to clearly include all unowned

cats. We also agree with the suggested definition of a pest cat as: “a cat without a registered

microchip”.

We would like the rule around feeding or sheltering pest cats on land to be amended to include any

cat. We suggest Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or

provide shelter to cats on private or public land within the Wellington Region, without the

permission of the occupier.”

We also suggest that the GWRC, along with city and district councils should promote a mandatory

“snip and chip” policy where all domestic cats must be neutered and microchipped by law.

Finally, we suggest that there should be on-going education to minimise the risk to native species by

those cats people choose to own in urban areas. Ideally, we would like some urban areas near

sensitive ecological areas to become ‘cat free’.

Deer

You state that “none of these feral species [pigs and deer] is a priority for pest control under the

plan” and “Therefore the effect of the plan on the regional availability of these hunting resources

Page | 219

will be minimal.”

Feral deer must be defined as a pest species under the RPMP.

While outside of our own area, Ngā Uruora is aware of the devastation that feral deer have caused

at the upper end of Stokes Valley and at the back of Eastbourne. It is unacceptable that deer are

allowed to breed in such numbers that they cause this level of impact. Ngā Uruora is not against the

existence of deer in forests managed by GWRC, but populations, especially around urban areas,

must be maintained at levels that allow for forest regeneration. If recreational hunters are not able

to or unwilling to maintain populations at manageable levels then GWRC must be responsible for

culling.

We also note that the area in question in Eastbourne is part of the East Harbour Northern Forest Key

Natural Ecosystem (KNE). We would be interested to hear how allowing large numbers of feral deer

to exist in this area supports Objective 16 of the Regional Policy Statement: “Indigenous ecosystems

and habitats with significant biodiversity values are maintained and restored to a healthy functioning

state.”

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106 Confidential To Pest Plan 27.7.18

I have been using the East Harbour Regional Park for over 50 years and have never seen so much

damage caused by deer! The culling has been seriously ineffective and the balloted hunts have taken

no deer. The herd/s move on to the seaward faces while the hunters are in the valleys.

While crossing over the ridge and living on this side they have destroyed most of the undergrowth

and are causing serious erosion on the steep slopes while at the same time harming the roots of the

beech forest and removing the topsoil and humus essential for beech survival.

This is just not on - it is destroying our public asset and protecting a few deer for hunters runs

completely against the mostly volunteer work done to restore and maintain the Park over decades.

Please consider either removing deer completely or properly controlling them. I have sent in photos

and videos to GWRC several times but absolutely nothing has happened, and the damage just gets

worse.

A comprehensive pest management strategy is needed for these destructive animals, otherwise the

GWRC is being deliberately negligent, ignoring the Park’s KNE status and favouring one type of park

user at the great cost of the parks intrinsic values in favour of another.

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107 Hudson, Aaron To Pest Plan Inbox 27.7.18

Page | 224

Via email: [email protected]

Dear Sir/Madam

SUBMISSION ON THE GREATER WELLINGTON PROPOSED REGIONAL PEST MANAGEMENT PLAN

2019-2039

The NZ Transport Agency (Transport Agency) thanks Council for the opportunity to provide

feedback on the Greater Wellington Proposed Regional Pest Management Strategy 2019-2039

(RPMP).

Our Address for Service is:

NZ Transport Agency

Majestic Centre

Level 5

100 Willis Street

PO Box 5084

WELLINGTON 6011

Attn: Aaron Hudson

Ph: (04) 894 6230

Email [email protected]

This submission provides input from the Transport Agency reflecting its role as the operator of

New Zealand's national state highway network. State highways are linear, travelling through

numerous different human and natural environments. In most cases the road verge that may

harbour pest plants, are reasonably narrow and vulnerable to/influenced by neighbouring

properties, and linear transport networks have significantly more neighbours than most land

occupiers.

The Transport Agency's specific submission points are set out in Table 1 enclosed below. Insertions

we wish to make are marked in bold and underlined, while recommended deletions are shown as

struck out text.

The Transport Agency will support Greater Wellington Regional Council by undertaking pest

plant control. However the Transport Agency notes as a linear network operator commitment,

from other relevant landowners is necessary to ensure beneficial outcomes.



Page | 225

We look forward to working with Council on the further development of the PRMP and more

broadly in the pest management area.

Yours sincerely,

Aaron Hudson

Acting Senior Planner, Consents and Approvals

System Design and Delivery

On behalf of the NZ Transport Agency

DDI 04 894 6230

[email protected]

NZ Transport Agency Submission on Greater Wellington Proposed Regional Pest Management Strategy 2019-2039

Page 2 of 8


Page | 226

Proposed Wellington Regional Pest Management Plan 2019 - 2039

Page | 227

6 18 3.3.2 Crown agencies The grouping of the four agencies in this section may lead to confusion. The New Zealand Transport Agency is a

statutory entity and a Crown agent under Section 7 and Schedule 1 of the Crown Entities Act 2004, and therefore,

a Crown entity. As a Crown entity, the Transport Agency is subject to provisions applicable to, and therefore,

falls within the definition of land occupier for the purposes of obligations for pest control. This is very different

to the Department of Conservation, for example. Our recommended relief is as provided in the column to the

right.

The Transport Agency seeks for

Council to make the following

amends to the RPMP:

It is suggested that, FotH eentral

§Overnment a§eneies (ineltidin§

state owned enter rises) haw'e

been identified as bein§

si§nifieant benefieiaries or

e aeerbators of est mana§ement

in the 'Nellin§ton Re§ion. =fhese

are 88E, the Ni: =frnns ort

A§eney (the =frans ort A§eney),

the New· t:ealand Railw·ays

Eor oration (l iwiRail) and l::and

Information New t:ealand, found

in the first paragraph of 3.3.2

Crown agencies, be amended as

follows: Four central government

agencies (including state-owned

enterprises} have been identified

as being significant beneficiaries

or exacerbators of pest

management in the Wellington

Region. These include:

• DOC

• The New Zealand Railways

•

•

Corporation (KiwiRail}

Land Information New

Zealand

The New Zealand

Tran sport Agency

The New Zealand Transport

Agency is a statutory entity and a

Crown agent under Section 7 and

Schedule 1 of the Crown Entities

Act 2004, and therefore, a Crown

entity. As a Crown entity, the

Transport Agency is subject to

provisions applicable to and

therefore falls within the

definition of land occupier for the

purposes of obligations for pest

control.

Page | 228

7 18 3.3.2 Crown agencies As per comment above, 'The New Zealand Transport Agency is a statutory entity and a Crown agent under Section

7 and Schedule 1 of the Crown Entities Act 2004, and is therefore, a Crown entity," given the Transport Agency

has been identified as being both significant beneficiaries and exacerbators of pest management in the

Wellington region that the Transport Agency be considered/contacted as a key stakeholder in future.

The Transport Agency requests to

be included as a specified key

stakeholder for early consultation/

engagement for biosecurity matters.

8 18 3.3.3 Territorial Authorities We note that Crown agencies are liable to meet the obligations, and costs associated with a Good Neighbour Rule

or action under a plan to enforce a Good Neighbour Rule within the RPMP.

However the RPMP is unclear on the responsibilities and the accountabilities of Territorial Authorities under this

plan.

The Transport Agency seeks for this

section to be amended to outline

and clarify how Territorial

Authorities will be held accountable

to meet their obligations under the

RPMP.

9 19 3.3.4 NZ Transport Agency For consistency with our submission points 7 and 8 above, please replace the current description of the Transport

Agency with the relief provided in the column to the right.

The Transport Agency seeks the

following amendment to section

3.3.4 of the RPMP. We provide the

following text as relief sought:

The New Zealand Trans ort

Agencr is a statutorr entitt and a

Crown agent under Section 7 and

Schedule 1 of the Crown Entities

Act 2004 and therefore a Crown

entitr. As a Crown entitt, the

Trans ort Agencr is subject to

rovisions a licable to and

therefore falls within the

definition of land occu ier for the

ur oses of obligations for est

control.

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11 19 3.3.5 Road reserves The RPMP states that, "where a road reserve boundary is unknown, this will be taken as 10m from the road

centreline." The Transport Agency considers this to be an impractical provision and recommends that a survey be

undertaken as a long term solution where required to defining a pest maintenance boundary.

It is suggested that, Where ii ffJ-flt!

resetMJ htJttfltfflFp' is ttflkfltJWfl, th-15

w#I he tflken as 10m ff()tn themat!

centrelif1e', found in the second

paragraph of 3.3.5 Road reserves,

be amended as follows:

Where a road reserve boundary is

unknown, a survey will indicate

the location of a road or rail

reserve boundary (should this be

necessary}.

12 19 3.3.5 Road reserves It is unclear if there is an obligation on land owners/occupiers adjoining road reserves (where reasonable pest

control is being undertaken) to undertake pest control. To support its pest control methods, the Transport

Agency wishes to be able to rely on provisions of the RPMP in the same manner as other land owners/occupiers.

Further clarification is sought on

the obligations of land

owners/occupiers adjacent to road

reserves. The Transport Agency

recommends that land

owners/occupiers adjoining land

reserves be subject to good

neighbour rule.

13 19 3.3.5 Road reserves It is unclear if there is a pest control obligation for land owners/occupiers adjoining legal road with ready access

to legal road.

The Transport Agency seeks for the

following to be added as a separate

bullet point to the provision, found

in the paragraph stating, "Except

where a rule prevents occupier

control, adjacent landowners are

responsible for controlling pests

on road reserves in the following

situations": the boundary is

unfenced and the adjacent owner

has ready access to the legal

road, in which case res onsibility

for est control shall lie with the

adjacent owner.

14 19 3.3.5 Road reserves It is noted that the Transport Agency is expected to undertake pest management in areas where it is

unreasonable to expect adjoining landowners to do so. For example on steep slopes or cuttings. The state

highway network often has steep banks/ cut faces that can harbour pest plants and be costly and unsafe to

manage by third parties due to the nature of the topography and traffic management requirements. The

Transport Agency would expect that they would be able to work collaboratively with landowners to access and

control as necessary any pest plants of concern and ask that GWC assist in communications between landowners

and the Transport Agency, where necessary.

The Transport Agency recommends

further engagement between

Council, landowners, and the

Transport Agency on pest

management strategies.

15 19 3.3.5 Road reserves The current drafting of "Road reserves where road works have contributed to the establishment of named pests,"

is ambiguous.


statement to be amended so that it

is clear as to what pests road works

may have contributed to the

establishment of.


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16 19 3.3.5 Road reserves The RPMP is unclear how Crown Agencies like the Transport Agency will be informed where programmed pest

management is undertaken.


section to be amended so that it is

clear how information on

landowners undertaking pest

management will be provided to the

Transport Agency.

17 21 4.1 Organisms declared as pests There are pest plants that can cause problems with the day to day operation and maintenance of the state

highway. For example, agapanthus can block stormwater conveyance systems and is readily spread along roads.

Agapanthus is also popular to plant along driveways and gateways and from here can spread onto the state

highway verge. The Transport Agency ask that agapanthus be included with a good neighbour rule applying.


Council to include agapanthus as a

declared pest to be included in the

list of organisms declared as pests

and also made subject to good

neighbour rule.

18 21 4.1 Organisms declared as pests From a national perspective there may be pest plants that are found on the state highway reserve that would be

beneficial for the Transport Agency to focus on. These pest plants may not necessarily be included in section 4.1

of the RPMP. We ask how GWC may support the Transport Agency in its endeavours to manage these pest plants

in relation to neighbours who are harbouring the species of concern.

Further discussion with GWC

regarding how to support the

Transport Agency should there be a

focussed effort to control pest

plants that are not included in the

RPMP.

19 21 4.1 Organisms declared as pests The Transport Agency requests that wattles and prunus be added to the list of pest species that can be managed

through the good neighbour rule.


Council to include wattles and

prunus as declared pests to be

included in the list of organisms

declared as pests and also made

subject to good neighbour rule.

20 22 4.1 Organisms declared as pests The management of feral deer is often a concern for the Transport Agency as part of its operation and

maintenance of the state highway network. The Transport Agency seeks for Council to include feral deer as a pest

that can be managed under the Good Neighbour rule.

The Transport Agency is also interested in aligning with GWC pest control programmes to work with territorial

authorities and other agencies for the best outcome in relation to feral deer.


Council to include feral deer as a

declared pest to be included in the

list of organisms declared as pests

and also made subject to good

neighbour rule.

21 22 4.2 Other harmful organisms The RPMP states that GWC will collaborate and provide support for other agencies where coordinated action

provides the best outcomes. The Transport Agency asks to be considered as one of these agencies and to help

ensure that this approach is kept 'live' through the life of the RPMP.


GWC to advise us of co-ordinated

pest management actions plans.

22 27 5.4 Alternative pest management arrangements The Transport Agency supports the ability for GWC to develop alternative management arrangements with

agencies to establish agreed levels of service with those agencies.

The Transport Agency requests that

alternative management

arrangements be retained as a

mechanism within the RPMP.

23 28 6 Pest descriptions and programmes There is a biosecurity risk of pest species being transported by stock trucks, it is not clear how this risk is being

addressed.

The Transport Agency seeks the

provision be amended to include

reference to how the biosecu rity

risk of pest species being

transported by stock trucks will be

addressed.

24 28 6.1 Pests to be managed under exclusion

programmes

The Transport Agency wish to be a proactive participant and requests to be informed of any known incursions of

the exclusion pest plants, should there be a risk of them establishing within legal road.

The Transport Agency seeks for GW

to grant the relief sought under

point 1 of the submission.

Page | 231

25 32 6.2 Pests to be managed under eradication

programmes

A GIS layer showing known sites of pest plants listed as 'organisms declared as pests' would be very useful. As an

example, Marlborough District Council include this data on their public facing GIS system. Please see below link

to this.

Marlborough District Council GIS Maps

Consider the existing GIS maps be

updated to include information on

pest plants and for the public to be

able to access information

regarding pest plant distribution.

26 34 6.2.1 Moth plant Some pest plants can grow across boundaries which can create confusion over the accountability for managing

the respective pest. It is therefore recommended that moth plant, banana passionfruit, blue passionflower, and

old man's beard have a good neighbour rule attached. Often the main stem of the vine is on one side of the

boundary fence and the bulk of the plant is on the other, causing issues for those wishing to kill the plant

entirely.

The Transport Agency recommends

that the good neighbour rule

applies to the moth plant, and

banana passionfruit, blue

passionflower, and old man's beard.

27 35 6.2, 6.3 Principal measures to achieve objective The Transport Agency supports GWC's 'advocacy and education' action of providing advice and training to

relevant stakeholders for the identification of pests to assist early detection.

The Transport Agency seeks that

advocacy and education be retained

as methods within the RPMP and

that appropriate funding be

provided for these in annual

budgets.

28 62 6.5 Key Natural Environment (KNE) The state highway network adjoins a number of KNE areas. The Transport Agency wishes to discuss these areas

with GWC to understand the particular biosecurity concerns for these areas and likely actions required under the

new RPMP. The current lack of clarity results in uncertainty.

The Transport Agency seeks for the

provision to be amended to provide

clarity on the matters of concern in

the KNE areas as they relate to the

state highway network.


https://marlborough.maps.arcgis.com/apps/MapSeries/index.html?appid=bcf43a62f5944909bfeef264d26c1621

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108 Horne, Christopher To Pest Plan Inbox 27.7.18

John Christopher Horne 28 Kaihuia Street Northland WELLINGTON 6012 Phone 475 7025 [email protected]

27 July 2018

Proposed Regional Pest Management Plan 2019-2039 Greater Wellington Regional Council PO Box 11 646 Manners Street WELLINGTON 6142 [email protected]

SUBMISSION: Proposed Regional Pest Management Plan 2019-2039

To whom it may concern:

Thank you for the opportunity to comment on the document. When hearings are held, I would like to speak in support of my submission. At that time I may wish to make other comments.

Foreword The blank page is a surprise. I assume that this will be remedied in the final RPMP.

Vision Statement and Executive Summary The absence of sections with these titles should be remedied in the final document.

Pest animals - background During the summers of 1957-1958 and 1959-1960, I worked in Ecological Forest Survey teams, run by the Forest Research Institute (now Scion). We recorded species in randomly selected plots in the native forests of Te Urewera, Ahimanawa, Kaimanawa, Kaweka and Ruahine ranges. The objective of the work was the development of



Page | 233

forest-type maps for the North Island. My over-riding memory is of the fearfully degraded state of those forests. The species of native plants palatable to deer, pigs, goats and possums were rare or absent. They were replaced by non-palatable species such as piupiu/crown fern/Blechnum discolor, horopito/pepper tree/Pseudowintera colorata & P. axillaris, and bush rice grass/Microlaena avenacea. The forests were shadows of their former selves, following decades of the rampages of deer, goats, pigs, possums, rodents, mustelds, etc.

Not surprisingly, my over-riding impression of your proposed RPMP is one of shock that the three species of feral deer – red, sika, fallow, plus feral pigs, plus feral stock (cattle, sheep) – are not even mentioned in the Table of Contents.

On the plus side, my experience as a contractor to GWRC from 2001- 2004, filling c. 275 bait stations in WCC reserves including Karori Park, part of the Outer Green Belt, Johnston Hill Reserve, Otari-Wilton’s Bush, Huntleigh Park, Orleans-Mākererua Reserve, and Johnsonville Park, showed me that within about 18 months of starting work, the seedlings of palatable species of native plants became visible. Thus the benefits of reduced possum numbers, and the by-kill of rodents and mustelids, showed the benefits of reducing the numbers of those pest animals.

PART TWO – PEST MANAGEMENT – page 21 Recommendations The final RPMP should:

1. state that while New Zealand has c. 2500 species of native vascular plants, c. 80% of them endemic, it is host to c. 25, 000 introduced vascular plants, many of them already invasive in the wild, and many others going through a ‘lag time’ before they too become invasive;

2. The list of weed species in the Wellington Botanical Society’s submission, be included in the final RPMP.

6.5.9 Rats – page 76 Adverse effects I welcome the inclusion of statement that rats eat ‘… 10% of their body weight per day’.

Recommendations 1. the final RPMP includes estimates of the daily consumption in

kilograms wet-weight, of native vegetation (leaves, fronds, mosses, liverworts, lichens) eaten by cattle/feral, deer/ feral (red,

Page | 234

sika, fallow), goats/feral, pigs/feral, hares, possums, rabbits, hares, sheep/feral;

2. the final RPMP includes estimates of the daily consumption in grams of the weight of invertebrates and lizards eaten by hedgehogs;

3. the final RPMP includes estimates of the biomass of wasps – all species in the region, at the peak of the breeding season, and the estimated impact on nestling and adult native birds.

7. Actual or potential effects of implementation – p 78 7.1 Effects on Māori I agree in principle with the first two paragraphs, with the proviso that GWRC acknowledges that the pest-animal plan as drafted fails to treat feral deer (red, sika, fallow), pigs and goats as pest animals which it should seek to eliminate.

I disagree strongly with the third paragraph. Anyone who can afford to buy a rifle, ammunition, clothing and bush equipment, plus the vehicle and fuel necessary to go hunting, has more than enough money to buy food in the shops, and therefore not resort to going hunting. Some people in the hunting lobby appear to consider that our indigenous terrestrial ecosystems are available for farming feral and other pest animals, so that they can go hunting. In the 21st century, that attitude is not acceptable as the world battles climate change and the loss of indigenous biological diversity.

The entire regional community must realise that: 1. restoring our indigenous ecosystems by freeing them from

browsing by feral and other pest animals is vital to enabling our forests to sequester carbon dioxide to the maximum extent possible, as the world strives to battle the effects of climate change and the loss of species of flora and fauna. NZ’s ratification of the COP21 Paris Accord commits us to do all in our power to slash our greenhouse-gas emissions, and to sequester as much of them as possible in our most effective ‘carbon sink’ – our native plant communities;

2. feral pest animals exert substantial ground pressure on the soils supporting our indigenous plant communities. This compaction can disrupt the germination of seeds and fern spores on the forest floor, and in the worst case, destabilise steep hill-sides, with the potential to cause slips, and flooding of farming areas and communities downstream;

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3. feral pest animals eat the leaves of flowering plants and the fronds of ferns, and mosses, lichens and liverworts. Thus feral pest animals are primary agents of forest collapse.

4. an adult feral red deer can eat an estimated 30 kg– 40 kg wet- weight of native vegetation per day;

5. feral pigs, by rooting on the forest floor, can destabilise trees, shrubs and tree ferns;

6. feral goats are known to eat every leaf within reach in a particular area of native plant.

7.2 Effects on the environment – p 78 I disagree strongly with the first sentence in the first paragraph. It would allow the continuation of the degradation of the environment, because it fails to plan to control feral deer, pigs and goats, with the aim of their eventual elimination from the wild.

I welcome GWRC’s involvement in research and training to minimise the non-target impacts of pest control. I urge GWRC, with researchers, to investigate the preparation and use of lured 1080-licks, for placement in those areas of indigenous plant communities which it, the TLAs and DOC manage, especially those communities visited by the public. Lured 1080-licks could enable firm control on several pest-animal species, while protecting the public and their dogs, from the risks posed by 1080 pellets, or 1080/carrot baits.

The expressed wish in the first sentence in the second paragraph will eventuate only if GWRC, DOC and the TLAs cooperate to drastically reduce the numbers of all pest-animal species, with the aim of eventually eradicating them. Half measures are not acceptable in the natural world, degraded as it is for decades by introduced pest animals and pest plants. In the second sentence in that paragraph, the economic environment will only be able to benefit fully if GWRC, DOC and the TLAs reduce the numbers of all pest-animal species, and eventually eradicate them.

I urge GWRC to use biennial aerial drops of 1080 on the Wainuiomata/Orongorongo catchment, Pakuratahi Forest, Kaitoke Regional Park (away from areas visited by the public), Hutt River catchment and Akatarawa Forest. If lured 1080-licks become available, they should be deployed in QE Park, Whareroa Farm, Belmont Regional Park, East Harbour Regional Park, and in natural areas managed by DOC and the TLAs

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8. Monitoring – p 79-80 Only ten pest animals are to monitored. How can that be justified, while ignoring all the other pest animals in our region?

Appendix 2: Harmful organisms – page 96 Why are the following pest animals are not listed?

carp spp. cat – feral (pictured on p 71) cattle – feral eastern rosella goat – feral (pictured on p 68) hare hedgehog (pictured on p 67) magpie (pictured on p 54) mouse mustelids – stoat, ferret, weasel (pictured on p 70) possum (pictured on p 51 & 75) rabbit (pictured on p 51) rat – ship, Norway (pictured on p 76) rook (pictured on p 37) sulphur-crested cockatoo trout – brown, rainbow wallaby (pictured on p 30)

Appendix 3: Maps – p 97 There are no maps to indicate the distribution of species of pest animals. Obviously most species are widespread, but some, e.g., the three species of feral deer, and feral pigs and goats, are not so widespread, so as a minimum, they each warrant a distribution map in the final RPMP.

Yours sincerely Chris Horne

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109 East Harbour Environmental Association

Rashbrooke, Felicity


EHEA SUBMISSION ON:

GREATER WELLINGTON'S PROPOSED REGIONAL PEST MANAGEMENT PLAN, 2019-2039

Introduction

EHEA is a local environmental group of some 45 years standing. Our mandate is to keep a watching

brief over our local environment, and prevent it from unnecessary harm. Over the years we have

had a particular concern to protect the biodiversity of the Northern Forest area of the East Harbour

Regional Park. We participated in Hutt City's programme to eradicate the pest plant, clematis

vitalba, and for some years now we have been carrying out eradication of other pest plants in the

Park, especially asparagus scandens and more recently blackberry. We have put in many voluntary

hours trying to remove asparagus scandens, and have only achieved very limited success. We note

that clematis vitalba is still listed as being part of Hutt City's site-led programme.

Our submissions below are in line with GW's Key Native Ecosystem strategy on which EHEA has

made submissions.

Pest Plants

EHEA submits that both asparagus scandens and blackberry should come under the site-led

programme strategy, rather than just be considered harmful pests. We believe this is necessary as

both plants are causing very significant damage to the biodiversity of the EHRP – and are spread

large distances by birds, making them very difficult to control. If action is not taken now then

asparagus scandens could become established throughout the EHRP – it is already being found in

more remote parts of the Park – and could lead to the smothering and ring-barking of all the forest

understory.

Some basis for requiring owners of adjoining private property to take appropriate action to remove

such pest plants would also be extremely desirable.

Pest Animals

EHEA strongly opposes the downgrade of feral deer and pigs from site-led pests to harmful

organisms as these animals are uncontrovertibly causing significant damage to our native plants. In

the case of deer they are not only browsing on and killing native plants, especially coprosma species,

but are also invading properties adjoining the Park and destroying people's gardens. In the past pigs

were also found invading private property, and could well do so again unless a site-led approach is

taken to their eradication. We note that although not seen as damaging as possums, deer and pigs

both have been found to carry bovine tuberculosis.

We are aware recreational hunters oppose eradication of deer and pigs. With respect, we fail to see

how a sport for a very small group of people – a sport furthermore with real dangers for other users

of the park, since if hunting is tolerated we can reasonably expect illegal hunting to increase – can be

any ground for consideration in terms of the absolute requirement to protect the high biodiversity

values of the Park.

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Hearing

We would like to be heard in support of our submission.

Felicity Rashbrooke

Chair, East Harbour Environmental Association.

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110 Churton Park Preditor Free Martelletti, Wade


Name

Wade Martelletti


Churton Park Preditor Free

Email

[email protected]

Street address

56 Cambrian street

Suburb

Churton Park

Postcode

6037

Phone Number

0221860714

Pest cats


Cats are highly skilled predators that kill regardless of hunger. Cats have the ability to decimate populations of

native species including birds, bats, lizards and insects. Cats have no natural predators in New Zealand so

humans need to control their numbers. Without management cats undermine any predator control work

undertaken by council and community groups.


I propose the definition of pest cats to be change to clearly include all unowned cats. My suggested definition of

a pest cat is: “a cat without a registered microchip”.

I would like the rule around feeding or sheltering pest cats on land to be amended to include any cat. I suggest

Rule 1 (p 74) is re-written to exclude the word “pest” ie. “No person shall feed or provide shelter to cats on

private or public land within the Wellington Region, without the permission of the occupier.”

Possums


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Possums significantly impact both primary production and biodiversity and controlling their population is an

important regional goal. Urban control is also important to prevent reinvasion into both significant ecological

areas and the rural landscape.

Hedgehogs





Ecosystem.

Mustelids



An additional rule should be added to make it clear that releasing a mustelid within the Wellington Region is an

offence.

Rats



A max of one cat per household and requirement to have smart car doors that keep cars in at night when birds

are easily predated sitting on nets. I have other ideas so please call me on 0221860714. I am hoping to source

these to fund Churton Park Preditor Free along with a few others.



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111 Clifford, Marsh, Wayne To Pest Plan Inbox 28.7.18

PEST PLAN SUBMISSION FROM STOP 1080 IN UPPER HUTT

Stop1080 is a new group in Upper Hutt concerned about the aerial use of 1080.

It is catering to an ever-growing community concern, about the effect aerial drops of 1080 are having on the environment. We are aware of the need for pest eradication processes, but firmly believe that 100% eradication will never be possible using 1080 aerial drops. We believe it will be an ongoing process way beyond the Governments 100% pest free target. Therefore, we further believe that to concentrate on a sustainable program is a high priority going forward. We would like alternatives to be considered for several reasons, with the highest priority being economic, whilst keeping toxins off the ground and out of the waterways. Likely alternatives would look to a positive solution, one that creates jobs, opportunities for local businesses to specialise in game foods, develop an export market for game meat, furs and hides, create a taxidermy market for the growing tourism trade, create a healthy pet food market. Incentives could be developed from the savings, by both Local Council and Regional Council, to form a positive solution, rather than indiscriminately poisoning the environment. We take on board that this would require extra work and planning, but we feel the future of New Zealand and it’s image, is worth seeking an innovative approach. We trust that the Greater Wellington Regional Council would look favourably at being innovative, and supporting the wishes of the local community. In brief..

1. We notice in your Pest Management Strategy that there is an amount set aside for eradicating possums. 2. We understand the need to eradicate the pest possum and also members of the mustelid family and rats, however we would like you to consider alternatives to the aerial use of 1080.

3. Our preference is fully targeted traps and bait stations for these species, so that nontarget species are not killed unnecessarily.

4. Such a programme will also create jobs, build the local economy and support New Zealand’s export industry.

5. The growing International awareness of the current 1080 aerial drops is affecting our clean green image Worldwide, which will ultimately have an affect on future export markets.

6. There are very few areas in the ranges surrounding the Hutt Valley and Wairarapa that are not accessible by hunters and trappers, however they will not be interested in hunting or trapping wildlife that has been exposed to poison which includes the likes

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of feral pigs that will feed off the poisoned carcasses.

7. Hunters are now wary of letting their dogs loose for fear of them contacting a contaminated carcass. Hence the incidence of effective hunting is decreasing. Cost

• The current costs of aerial 1080 projects are between $21 and $40 per hectare, according to the Ministers of Conservation and Primary Industries in the last Parliament. • The costs when using traps and bait stations, such as that carried out by the Hawkes Bay Regional Council, run between $12 and $14 per hectare. • The unseen cost to our clean green image.

Benefit

• Only targeted species are killed • Local hunters & gatherers can continue to live off the land and feed their families by having access to feral pigs and deer, rabbits and the game animal, hare. • Potential wild game meat industry with meat surplus to family needs, available for processing and selling to local and international buyers

• Potential raw pet food industry for wild animal offal and possum meat. • Creates jobs for trappers and bait station surveillance. • Supports local industries such as Woolyarns who are calling out for more possum fur, because they make a luxury fabric from possum fur and merino that overseas buyers can’t get enough of. Conclusion: We would like to discuss this further via an oral submission Regards Wayne Clifford-Marsh

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112 Ballance, Alison To Pest Plan Inbox 29.7.18

Alison Ballance – supporting comments to go with submission on Greater Wellington pest

management plan July 2018

It is great to see Greater Wellington targeting pests and weeds, and I fully support what you're

doing. Between GW's work, WCC and Predator Free neighbourhoods, pests are being increasingly

controlled across Wellington City.

Where I see a gap is with some weed species, such as old man’s beard and acacias which are starting

to spread in Wellington, particularly in my local town belt area on Mount Victoria and on road

reserves. I have lived in Wellington for 10 years, and when I first arrived old man’s beard was very

well controlled. Since then however WCC has stopped doing any work with old man’s beard, and it

has started to spread rapidly in the past couple of years. I am also seeing an alarming spread of

acacias on Mt Victoria.

In the GW pest plan you are only proposing doing old man’s beard control work in the Hutt Valley

where it is a Hutt council priority – I’m very pleased you’re working in the Hutt.

Would it be possible for GW to take more of a lead in Wellington city, and work with WCC to get

more happening in this area, please.

I am aware that land owners need to be responsible for weds such as old man’s beard on their own

land, but I think a public education campaign about what the weeds are, why people need to control

them and the best ways of achieving this would be very helpful. It would also be helpful if WCC took

the lead in controlling it in areas where they are responsible such as the town belt and road reserves

(which are common and very weedy).

Submission ends

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113 Wellington Botanical Society

Abbott, Bev


SUBMISSION ON THE PROPOSED REGIONAL PEST MANAGEMENT PLAN

FROM WELLINGTON BOTANICAL SOCIETY

30 July 2018

INTRODUCTION:

1. The Wellington Botanical Society appreciates the opportunity to comment on the proposed Regional Pest Management Plan 2019-2039 (proposed RPMP). Some details about the Society (BotSoc) are in Appendix 1.

2. There are four parts in our submission:

communication suggestions to make the RPMP easier to understand

weed and pest animal species in and out of the RPMP

opposition to taking feral deer and feral pigs out of the RPMP

some brief comments on some topics beyond our capacity in the four-week consultation period, including strategic governance.

3. We look forward to discussing our ideas with you at the hearings or any workshops.

PART ONE: COMMUNICATION SUGGESTIONS

4. We hope the final RPMP will be more succinct and much clearer. Our concern is not just the words on the 100 pages, but the thinking behind those words.

Submitter: Wellington Botanical Society

Contact details: Bev Abbott

40 Pembroke Rd, Northland, Wellington 6012

Phone 475 8468

[email protected]

We wish to speak in support of our submission.


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The purpose of the RPMP

5. The purpose of the RPMP is not clear. Section 1.2 says “the purpose is to outline a framework for managing or eradicating specified organisms efficiently and effectively”. The framework, however, is not outlined until Chapter 5, and it then takes less than 3 pages, out of the 100 pages in the proposed RPMP.

6. Which other chapters and pages need to be in the RPMP? Could some be transferred to a higher level document, e.g., a wider biosecurity strategy?

7. The purpose statement contains one puzzling comment “… it is only where an individual’s action or inaction in managing pests imposes undue effects on others that regional management is needed”. What about public good? Acting now may save landowners and the public from much higher costs later on.

The Title

8. The title, Regional Pest Management Plan suggests a much wider range of pest management functions and activities than it contains. To use your words, the RPMP is just “one tool in the wider biosecurity programme”. Section 2.1.2 describes it as a “vital cog in a secure biosecurity framework to protect New Zealand’s environmental, economic, social, and cultural values from pest threats”. The word “regional” has always been problematic.

9. Perhaps a sub-title would help, e.g. “Regional Pest Management Plan: one tool in GWRC’s wider biosecurity programme”.

10. The early references to GW’s Biodiversity Strategy 2011-2021 (section 2.1.1.1) and the KNE programme (section 2.1.1.2) suggest a biodiversity focus. We welcome more investment in protecting the indigenous biodiversity values of the KNEs, but are also concerned about the long-term consequences of reducing pest control on other lands and waters.

11. There was no Foreword, but the index shows one is planned. There was no Executive Summary, nor any plan for one, a surprising omission from a 100-page document.

What’s different? How does the RPM “Plan” differ from a RPM “Strategy”?

12. The title of the document has changed from ‘strategy’ to ‘plan’. GW explains the difference as:

“The proposal differs from the current strategy, in that it only provides the rules for

managing identified pests, and does not contain the full Biosecurity approach. This

shifts the plan to become one tool in the wider biosecurity programme.”

13. GW’s Biodiversity Strategy 2011-21 may be the ‘wider biosecurity programme’ referred to, but we think there needs to be something wider again, something that draws together the strategic and operational pest management issues and themes from the many national, regional and local initiatives already underway throughout the region. The fragmentation of the biosecurity sector is a concern.

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Understanding the Rules

14. If the RPMP only provides the rules for managing identified pests, what do the rules allow or prevent? Section 5.5 on p.27 explains that rules create a safety-net to protect land owners and/ or occupiers from the effects of the actions or inactions of others where non-regulatory means are inappropriate or do not succeed. This section doesn’t say what the rules are, or where they can be found, or how they perform their safety-net function. The term is not defined in the Glossary.

15. We found rules for some pests in the 50 pages of Pest Descriptions and Programmes in Chapter 6, but there weren’t many rules, and the inconsistencies were surprising:

Wasps (public health): An occupier within the Wellington Region shall, within ten (10) working days of

receipt of a written direction from an authorised person, destroy all wasp nests on the property they

occupy.

Feral rabbits: An occupier within the Wellington Region shall maintain feral rabbits on land they

occupy below level 5 of the Modified McLean Scale 2012.

Mustelids: No person shall possess any living mustelid within the Wellington Region.

Blue passionflower: No person shall possess any blue passionflower (including any seeds or live

vegetation) within the Wellington Region. A breach of this rule creates an offence under section

154N(19) of the Biosecurity Act. 2. Any person who sees, or suspects the presence of, blue

passionflower within the Wellington Region shall report the sighting or suspected presence to Greater

Wellington within ten (10) working days.

Eradication Plants: An occupier shall, upon receipt of a written direction from an authorised person,

destroy any moth plant, senegal tea, spartina, velvetleaf or woolly nightshade present on the land they

occupy.

The Good Neighbour Rule

16. Most of section 5.5 is about the Good Neighbour Rule. Apparently the National Policy Direction for Pest Management 2015 (NPDPM) requires Good Neighbour Rules to be described. But a note in section 2.4 on p.15 says that GW’s proposed RPMP does not identify any Good Neighbour Rules. No reason is given.

17. Our guess is that GW, DOC, TAs, and the NZ Transport Agency fear that their own neighbours may start applying more pressure on them to be Good Neighbours.

18. The term “neighbours” may be the issue, with its links to boundary controls. It’s not just immediate neighbours who need to collaborate, but neighbourhoods. We see merit in having a Good Neighbour rule that requires both public and private neighbours of KNEs to contribute to the management of pests around each KNE.

Boundary Control

19. The RPMP 2002-2022 established boundary control rules for several species, e.g:

Gorse: Where productive land is affected by the spread of gorse (Ulex europaeus), adjoining

landowners/occupiers shall destroy all gorse within 10m of their boundary following a complaint to

Greater Wellington by adjoining landowners/occupiers whose land is clear, or being cleared of gorse

within the Wellington Region.

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20. GW’s Pest Management Review Discussion Document signalled that the boundary controls would be reviewed, and there are no boundary control rules in the RPMP.

21. We have no immediate concerns about dropping boundary controls. They may never have been very effective in reducing the spread of weeds. Seeds and plant fragments will continue to cross property boundaries, carried by the wind, water, birds, lizards, and mammals etc.

The Target Audience

22. The early sections of the RPMP do not identify the target audience(s). Who should keep reading; who can stop? The technical language and assumptions about prior knowledge suggest the RPMP is for staff with responsibilities for pest management in the nine TAs, DOC, other Crown agencies, GW and MPI. But are land owners/occupiers, iwi, and NGOs seeking help with pest control for restoration also part of the intended audience? They contributed to the earlier consultation.

Language Barriers (specified organisms, harmful organisms, and unwanted organisms)

23. The target audience has implications for the content and language of the RPMP, e.g., what do the intended audiences already know about the topic?

24. We initially overlooked the significance of the word “specified” in the RPMP purpose statement, i.e. “a framework for managing or eradicating specified organisms efficiently and effectively in the Wellington Region”. It wasn’t until we found the table of “specified” weeds on page 21 that we learned that GW is proposing to specify only 15 plant species as pests for the purposes of the Biosecurity Act and the RPMP. That’s 15 out of more than 200.

25. We were also surprised to find that the terms “harmful organisms” and “unwanted organisms” are not synonymous under the Biosecurity Act. Readers need an early alert to this technical difference because it is critical to understanding GW’s approach to weed management.

26. Care is also needed when using words that have different meanings to different audiences. For example, your statement “Relying on voluntary action (the do nothing approach) is unlikely to be efficient or effective in achieving the objective.” Many volunteers are likely to resent their contributions to pest control being dismissed as part of a “do nothing approach”. This phraseology needs to be replaced.

Titles of programmes

27. Section 5.1 defines the five pest management programmes which are key components of the ‘framework’. We prefer the less technical descriptions on page 7 of the Impact Assessment and Cost Benefit Analysis (CBA). These descriptions also explain GW’s roles more clearly.

28. As an example, the two definitions/explanations of ‘sustained control’ are:

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GW: To provide for ongoing control of the subject, or an organism being spread by the subject, to reduce its impacts on values and spread to other properties.

CBA: This involves regular ongoing control by Greater Wellington and/or the occupier in an attempt to prevent further spread and mitigate impacts of the pest. The public good benefits of this programme lie in preventing a species becoming established and imposing much more significant costs on the region in the future.

29. It’s unfortunate that MPI’s drives for national consistency means the CBA definitions can’t be used, but it may be possible to incorporate their wording in other ways.

Glossary

30. The Glossary is important given the number of technical and statutory terms in the proposed RPMP. In some cases, it was only by consulting the glossary that we worked out what was intended. Please do a thorough cross-check of terms in the text with terms in the Glossary.

PART TWO: SPECIFIED WEEDS AND ANIMALS

31. As noted above, we initially missed the significance of the word “specified”.

Specified weeds

32. A table in section 4.1 (p.21) lists the 13 specified weeds by common English names in alphabetical order, and gives their management programme in column 3. We have reformatted the table to give a clearer overview. A similar table for animals is in paragraph 37.

Weed species declared in the RPMP 2018-2038 and their management programmes

Programme Exclusion Eradication Progressive containment

Sustained control

Site-led HCC

Weed species

Alligator weed Moth plant Purple loosestrife Boneseed Banana passionfruit

Chilean needle grass

Senegal tea Climbing spindleberry

Cathedral bells

Nasella tussock

Spartina Eelgrass Old man’s beard

Velvet leaf

Woolly nightshade

33. We were shocked to find that, outside of Hutt City, GW intends to use the RPMP to do three things:

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keep 3 weeds out of the region

eradicate 5 weeds, and

control 4 others.1

34. Some of the explanation for what’s in the table comes later. The Invasion Curve on page 24 models pest population dynamics. The individual management programmes are defined in section 5.1 (p.25). This sequencing makes it hard to get an overview of the weed programmes or the relationship between them. We think the Invasions Curve, and possible the programme definitions should come before the tables.

35. Action: Please include the Invasion Curve followed by our two tables in the Executive Summary. This will give stakeholders an instant overview of how GW has decided to use the powers available to it under the RPMP provisions to deal with weed and animal pests.

Weeds ‘dumped’ from the Regional Pest Management Strategy

36. The authors of the RPMP did not seem to understand that some members of the public would want to know which weeds had, and had not, survived the review process and why. The difficulty we had finding that information has undermined our confidence in the RPMP.

37. We prepared the following analysis which shows that 32 of the weed species in the RPMS 2002-2022 are not in the proposed RPMP 2019-2038. It gives the impression that GW is giving up on more weeds. We would be delighted to hear of any flaws in this analysis.2

1 We eventually learned that some other weeds will be controlled under other programmes, but this consultation is about the

RPMP.

2 Exact comparisons are not possible because the titles of programmes have been changed to improve national consistency.

2007 Review

Programme Number of species

Regional surveillance plants

24

Total control plants 11

Containment plants 4

Suppression plants 0

Site-led pest plants (Boundary control)

8

Total species-led 47

PRPMP June 2018

Programme Number of species

Exclusion 3

Eradication 5

Progressive containment

1

Sustained control 3

Site-led (HCC) 3

Total species-led 15

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Additional weeds that should be included in Appendix 2

38. We are expecting to gain a better understanding of the purpose of Appendix 2 at the forthcoming Regional Biodiversity Workshops. Appendix 2 already contains 200 pest plants, but we have started identifying other species we think should be on this list, for example, karaka, which is not native to the southern North Island, and is spreading as the number of kereru increases. We also want to identify other species where eradication or progressive containment may still possible because they are still present in low numbers or at a limited number of sites.

Specified animal pests

39. Section 4.2 shows that GW proposes to limit the use of the RPMP to preventing the arrival of wallabies, eradicating rooks, and controlling 4 other taxa. Four more taxa will be controlled at some sites. We have reformatted the table from section 4.2 as we did for weeds.

Animal species declared in the RPMP 2018-2038 and their management programmes

Programme Exclusion Eradication Progressive containment

Sustained control

Site led

Animal pest species

Wallaby Rook Feral rabbits Hedgehogs Magpies Feral goats

Possums Mustelids (stoats, ferrets weasels)

Wasps* Pest cats Possums Wasps*

Why have so many species been dumped?

40. Some of the reasons for removing pests from the RPMP were listed in the Pest Management Review Discussion Document, for example:

they have shown no threat of becoming established

they have proven to be more widespread than previously thought

they have not responded to control techniques

they were included to raise public awareness of their impacts - changes in information technology and communication methods make this educational awareness component redundant

they are the responsibility of other agencies, e.g., DOC for freshwater fish pests.

41. Action: We believe including these reasons in the RPMP with named examples will increase confidence in the RPMP.

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Another communication issue: “Other harmful organisms” and “unwanted organisms”

42. We found a list of 200 weeds and 10 animals in Appendix 2 on page 94 under the heading “Other harmful organisms”. The Glossary defines “harmful organisms” as “organisms that have not been declared pests for the purposes of this Plan because, “although they may have significant adverse effects, regulatory responses are not considered appropriate or necessary”.

43. This definition needs further explanation on p.22. Why aren’t regulatory responses considered ‘appropriate or necessary’ for species such as feral deer, feral pigs, and weeds such as Darwin’s Barberry, Pampas Grass, Asiatic Knotweed, and Didymo?

44. Notes on p.22 explain that the “harmful organisms” pose a sufficient future risk to warrant being watch-listed for on-going surveillance or future control opportunities, but we found no related commitments. Is the intention to rely on “passive surveillance”? Have any priorities for official surveillance been identified? Wellington Botanical Society has been playing a role in passive surveillance for decades. On our monthly field trips, we regularly prepare lists of weed species seen, and share that information with GW or DOC, (subject to the land occupier/owner agreement).

45. It was, however, reassuring to learn that some of the “harmful organisms” will be managed under GW’s Key Native Ecosystems (KNE) programme. The KNE map on p. 97, however, shows there are very few KNEs in the Wairarapa.

46. The term “unwanted organisms” is used in several sections of the proposed RPMP but is not defined in the Glossary. DOC’s website says an Unwanted Organism is defined in the Biosecurity Act 1993 as “any organism a chief technical officer believes capable of causing unwanted harm to any natural and physical resources or human health.

47. Action: please expand section 4.2 (p.22) to clarify the meanings of ‘unwanted organisms’ and ‘harmful organisms’; explain the relationship between them in the context of the RPMP; and use coding to identify any “unwanted organisms” in Section

4.2 and Appendix 2.

Funding

48. We also wonder what influence the Long Term Plan budget had on the RPMP.

49. GW’s indicative annual budget for weed pest control over the next 10-years is about $2.2 million per annum (Section 10.5 p.86) but there is no explanation of what it has to cover. The amount seemed very low as we thought about KNEs, salaries, wages, contracts, hire of helicopters for spraying weeds in inaccessible places, purchases of capital equipment such as drones for more efficient compliance, advocacy and education initiatives, and legal costs where GW decides to pursue apparent breaches of the Biosecurity Act.

Budgets ($,000) 2018/19 2027/28

Animals 2,300 2,264

Plants 2,147 2,200

RPPCP (possums) 1,649. 1,769

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50. We are very concerned about how little impact the RPMP is likely to have on the region’s weed populations and densities. Wellington’s weediness is going to get worse. (One year’s seeding, seven year’s weeding.)

51. More than 2,500 introduced plant species have “naturalised” in NZ, i.e., they are now established and reproducing in the wild. New plants jump the fence each year. (We don’t have figures for the region). More than 300 naturalised plants are called ‘environmental weeds’ because they impact detrimentally on the structure, functions or composition of New Zealand's indigenous plant communities, waterways and fauna. Other introduced plants may do little harm (for now), but the Invasion Curve, (p.24) shows a lag effect can be anticipated.

52. Our expectation is that Council will review the LTP pest management budgets every three years.

53. Action: If you decide to put 10-year and annual budgets in the RPMP, please explain what expenditure is included.

The Cost-Benefit Analysis

54. We appreciated the additional information about the competitive and reproductive abilities of some of the weeds in the 200-page Cost-Benefit Analysis (CBA). The time series results for some weeds were also encouraging, e.g. boneseed. We would like to see more ‘stories’ in Chapter 6 about progress towards the control of specific weeds, for example:

Wellington now has 390 active boneseed sites, down from 480 in 2010/11. In

2017/18, 5,635 plants were controlled at a cost of $110,000. As each plant can

produce 50,000 seeds per annum, that investment will have prevented hundreds of

thousands of boneseed seeds from entering the seedbank.

55. There were, however, some disappointing, but not unexpected limitations in the CBA methodology. For example:

“The net monetarised benefit of regional intervention over 20 years is estimated to

be minus $1,931,229. However this does not take into account the non-monetarised

‘values’ of protecting biodiversity values in coastal environments throughout the

region which would be impacted if there was no regional intervention.” (Boneseed

analysis p.104)

56. We hope Councillors had access to cost benefit analyses for some of the species that are not “declared pests” so that they know, for example, how much it may cost to pursue progressive containment for more species. Future generations are not going to appreciate a larger weed debt.

57. We also wondered what role the CBA played in determining which species would be managed, and which could be left to expand and spread? The CBA pointed out the “undoubtedly large amounts of uncertainty around any CBA estimates applied to pest management”.

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“Cost-benefit analysis results can give the illusion of being precise, and providing

robust estimates of future costs and benefits. However, there are significant data

limitations in terms of how much we know about the impacts and spread of pests, and

the costs of their control over future decades.”

PART THREE: FERAL DEER AND FERAL PIGS

58. One of our major concerns is that three species of feral deer (red, fallow and sika), and feral pigs are not specified as pests under the RPMP 2019-2039 (see section 4.2). In the RPMS 2002-2022, they were site-led species with rules. Appendix 2 shows GW’s intention to treat them as Harmful Organisms in the future.

59. This intention was not flagged in GW’s Pest Management Review Discussion Document. Perhaps it was suggested by professional and/or recreational hunting organisations in the preliminary consultation process. Section 2.6, p.16 only describes the process and invitees. It doesn’t report back on key themes.

60. We are strongly opposed to removing feral deer and feral pigs from the RPMP. Please return them to the site-led programme, and enhance the role of rules in controlling them near KNEs.

61. The proposed RPMP presents no explanation or data to show that this proposal is sound. There is:

no description of the damage feral deer can do to forest ecosystems; e.g. the volumes of plant material that deer eat every day and every year, and in their lifetime3

no acknowledgement of the carbon sequestration benefits of leaving all those leaves in situ

no cost benefit analysis, no estimates of feral deer or pig populations or densities; not even any even trend data from GW monitoring reports

no modelling of how their numbers may increase without action under the RPMP

no discussion of the feasibility of keeping deer and pigs out of KNEs and other sites with biodiversity values in the long term

no assessment of the potential behavioural changes that may result from the loss of the rules in the RPMS 2002-2022, e.g. more illegal releases of game animals, more traffic accidents caused by deer

3 Mick Parsons, (pers comm), a dairy-farming member has estimated that a lactating red deer would require 30, possibly 40 kg (wet weight) of ‘bush tucker’ per day given its lower ME (metabolisable energy) than good pasture.

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no recognition of the need for high quality habitats to provide homes for the increased numbers of birds, lizards and arthropods etc., that will result from even partially successful implementation of Predator Free 2050 throughout the region over the next two decades.

62. We suggest you research the effort and expenditure of the New Zealand Forest Service a few decades ago when it became necessary to reduce the deer populations to manageable levels and start repairing the erosion they caused.

63. GW acknowledges in Section 7.1, (Effects on Maori), that it doesn’t see these feral species as a priority for pest control. It also predicts minimal effects of the RPMP on hunting resources will be minimal.

“It is acknowledged that feral animals such as deer, pigs and goats are valued as

replacements for traditional hunting resources. However, none of these feral species is

a priority for pest control under the plan, with the exception of feral goats. Feral goats

will primarily be controlled in KNEs and in areas in the region deemed to have high

ecological values. Therefore the effect of the plan on the regional availability of these

hunting resources will be minimal.”

64. We think sufficient land is already open to hunting, and no more areas need to be opened up. GW’s submission to the Local Government and Environment Committee on the Game Animal Council Bill, reported that “over 150 000 hectares of red deer and feral pig habitat on public lands is open to hunting within the Wellington region” and there are further populations on private forestry and agricultural farmlands with potential for hunting access.

65. The GW statement about the minimum effect on hunting resources also implies that the RPMP will do little to limit the impacts of feral deer and pigs on indigenous biodiversity.

66. Action: This decision is too important to be rushed through after a four-week consultation period with no research-based background information. Feral deer and feral pigs should remain as site-led species until a comprehensive, peer-reviewed research report is prepared to guide decision-making within and beyond GW. We suggest establishing an interagency supervisory panel to commission this report.

PART FOUR: SOME BRIEF COMMENTS ON OTHER SECTIONS

Monitoring and reporting

67. We liked section 8.1 “Measuring what the objectives are achieving”, and suggest combining 8.1 and 8.3. The text in 8.3 about plan reviews is not relevant to monitoring. Reviewing the plan is just one potential response to disappointing monitoring results. It belongs in chapter 2.

68. The RPMP only requires GW to report annually against a separate Operational Plan. We think five-yearly reports of performance against the RPMP should also be

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prepared, even if they only summarise changes in distribution, numbers of sites and densities for each species in the species-led programmes.

Planning and Statutory Background. (Chapter 2)

69. The 11 pages of Chapter 2 are presented under 6 headings and 24 subheadings in Chapter 2. If it all belongs in the RPMP, (and not in a wider biosecurity programme), please review the purpose, structure and placement of the information.

Advocacy and Education

70. Advocacy and Education (A&E) is mentioned in Section 5.3 under the puzzling title “Principal measures to manage pests”. Seven A&E functions are listed, but no objectives or targets.

71. People can’t eradicate weeds if they can’t identify them, and some weeds are easily confused with natives. Natural Capital, Wellington City Council’s Biodiversity Strategy 2015 includes a proposed teaching garden where contractors, volunteers and others can learn to distinguish weeds from similar natives, e.g. pampas from toetoe, old man’s beard from indigenous clematis and from other climbers when no flowers or seeds are on the plant.

Plant diseases

72. Do the specifications for RPMPs exclude diseases like Myrtle Rust?

Climate Change

73. GW’s quick dismissal of climate change is regrettable given the growing literature on the implications of climate change for pest management. (Page 8 says “climate changes in the Wellington region are unlikely to result in measurable changes in species compositions or the pest profiles of listed species in the life of the plan). We read “listed species” as including Appendix 2. We read “the life of the plan” as from now until the first review. We can argue about the nature of “measurable” changes at a later date. As one example, numerous species of terrestrial and freshwater pests may infest new locations downstream very quickly after a major flood event. Those changes may be measurable within a few months. The implications of climate change for current biocontrol programmes may also need to be considered.

Governance and Leadership

74. The biosecurity sector is very fragmented. Our experience with this document has reinforced our view that the Wellington region needs a research-based, post-border biosecurity strategy to bring together into a collaborative approach, the many strategic and operational initiatives already available or underway. Examples include Biosecurity 2025, the Wellington Conservation Management Strategy 2018-2028 (pending), GW’s Natural Resources Plan, the National Policy Statement on Biodiversity (still underway?), Predator Free NZ 2050, the current Government’s plans to plant one billion trees, Treaty settlements, results from research, monitoring and evaluation, and emerging technologies. There may also be national or regional

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strategies to manage the threats of plants, animals and diseases on productive sectors (agriculture, forestry, horticulture, fisheries), and historic heritage.

75. We are not aware of many on-going pest management collaborations at the governance or senior management level, but the Wairarapa Moana model and Predator Free Wellington (Miramar) may influence their development.

Perhaps some one-off meetings could be arranged to test the relevance of each of the five strategy directions in Biosecurity 2025 throughout the Wellington region.

The Wellington Conservation Management Strategy 2018-2028 (pending) will identify place-based heritage objectives and initiatives.

It’s possible that closer links between pest management and biodiversity initiatives are already on GW’s drawing board. (Designing a shared way forward for our biodiversity).

76. The Conservation and Environment Research Road 2017 provides some thoughtful perspectives on what lies ahead. The following come from p.35 and p.32.

Biosecurity risks to New Zealand have been recognised as a high priority for science investment for many years. Despite this, few transformative tools and approaches have emerged in recent times and, of those that have, a significant number have come from outside the science sector (e.g., self-resetting traps and wireless monitoring technology). Significant research and development investment is required in getting tools and approaches application-ready…

Gene-based technologies such as gene editing (eg, CRISPR/Cas9) and the use of transgenerational techniques such as meiotic gene drive manipulation are some of the many evolving biotechnologies that may be key to pest management. However, the pace of change comes with its own challenges, as the ability to deploy these technologies is dependent on the public being comfortable with the implications of their use.

A question that will need to be addressed is whether we have the systems of education, engagement, management and regulation that will assure people of the safeguards, including ethical considerations, necessary to employ these new technologies.

CONCLUSIONS

77. GW will have to finalise the development of its RPMP to meet some of its statutory obligations (e.g. 10 -yearly reviews and compliance with new legislative requirements.

78. The timing, however, is unfortunate given the number of other strategic and statutory biodiversity initiatives currently underway, both nationally and within the region. It would have been more efficient to wait until 2022, the expected end-date of the RPMS 2002-22.

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79. We hope the detailed comments about our experience with the proposed RPMP will help you improve the quality of the final version as an educative tool. The public has embraced ambitious targets for “predator control” but is still to develop much understanding of the ecological damage that is being done by weeds and herbivores.

APPENDIX 1: SOME DETAILS OF WELLINGTON BOTANICAL SOCIETY

Our comments reflect our involvement in:

compiling species lists on field trips (indigenous species and weeds), and providing copies to landowners and managers

working for 25 years on pest control in a small ecological restoration project (Te Marua)

publishing a scientific Bulletin every 1-2 years (a total of 56 editions) which includes papers on weeds

providing speaking opportunities for researchers and officials at out monthly meetings

awarding an annual research grant (currently $2,600) and grants to graduate students

participating in public decision-making processes through oral and written submissions.

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114 SPCA Dale, Arnja


Introduction

The following submission is made on behalf of The Royal New Zealand Society for the Prevention of

Cruelty to Animals (trading as SPCA).

SPCA is the preeminent animal welfare and advocacy organisation in New Zealand. The Society have

been in existence for over 140 years with a supporter base representing many tens of thousands of

New Zealanders across the nation.

The organisation includes 40 Animal Welfare Centres across New Zealand and over 80 inspectors

appointed under the Animal Welfare Act 1999.

SPCA appreciates that opportunity to make a submission on the Greater Wellington Regional Council

Proposed Regional Pest Management Plan 2019 – 2039.

Specific feedback on the proposed plan

Rook (Corvus frugilegus)

The proposed plan states that:

Greater Wellington will support appropriate research initiatives, including biological control should it

become available

Provide advice, attend events and undertake publicity campaigns to increase public awareness of

pests

SPCA would like to see research initiatives on humane alternatives supported and prioritised. The

Society would like to see a focus placed on animal welfare and humane methods of animal

population control such as fertility control. There are such alternatives being developed

internationally and we would like to see New Zealand commit to progressive and humane treatment

of all animals, including those labelled as ‘pests’.

The Society also asserts that educating people about and advocating for the humane treatment and

control of ‘pest’ animals is a vital component of providing advice, attending events and undertaking

publicity campaigns; these should not just be undertaken to ‘increase public awareness of pests’.

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Feral rabbit (Oryctolagus cuniculus)


Greater Wellington will:

Release biological control agents for the control of feral rabbits when appropriate

Support research initiatives including biological control

Provide education and advice to land owners/occupiers and the public about feral rabbits, the threat

they pose to the Wellington Region, and how to control them

Help land owners/occupiers and the public to gain the knowledge and skills to help reduce the

impacts and spread of feral rabbits

SPCA would like to see research initiatives on humane alternatives supported and prioritised. SPCA

opposes the use of biological control methods such as the RHDV virus due to the significant suffering

and distress this virus can cause affected animals. The Society would like to see a focus placed on

animal welfare and humane methods of animal population control such as fertility control. There are

such alternatives being developed internationally and we would like to see New Zealand commit to

progressive and humane treatment of all animals, including those labelled as ‘pests’.


control of ‘pest’ animals is a vital component of providing advice, education and undertaking

publicity campaigns, these should not just be undertaken to give information about ‘feral rabbits,

the threat they pose to the Wellington Region, and how to control them’ and ‘helping land

owners/occupiers and the public to gain the knowledge and skills to help reduce the impacts and

spread of feral rabbits’.

Magpie (Gymnorhina species)



Provide advice, education and assistance to occupiers wanting to undertake magpie control

SPCA asserts that educating people about and advocating for the humane treatment and control of

‘pest’ animals is a vital component of providing advice, education and assistance, and that this

should be a focus of advocacy and education activities.

SPCA would like to draw attention to the fact that there are no best practice guidelines for

controlling and monitoring magpies on the National Pest Control Agencies website. In addition, the

Greater Wellington Regional Council magpie brochure suggests using a live call bird to bait traps

which is inhumane and unacceptable. If people are being encouraged to destroy ‘pests’, then those

encouraging this have a responsibility to at least provide information that does not involve the

inhumane treatment of animals.

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Possum (Trichosurus vulpecula)



Support research initiatives including biological control

Provide education and advice to land owners/occupiers and the public about possums, the threat

they pose to the region, and how to control them


opposes the use of inhumane biological control methods that can cause significant suffering and

distress to affected animals. The Society would like to see a focus placed on animal welfare and

humane methods of animal population control such as fertility control. There are such alternatives

being developed internationally and we would like to see New Zealand commit to progressive and

humane treatment of all animals, including those labelled as ‘pests’.


control of ‘pest’ animals is a vital component of providing education and advice; these should not

just be undertaken to give information about ‘possums, the threat they pose to the Wellington

Region, and how to control them’.

European hedgehog (Erinaceus europaeus)



Provide information and advice on pest animal identification, impacts and control

Provide advice to community groups undertaking pest animal control, with priority given to activity

in or around KNEs and in defendable or strategic geographic locations such as peninsulas, islands

and corridors.

The Society asserts that educating people about and advocating for the humane treatment and


just be undertaken to give information about ‘pest animal identification, impacts and control’. In

particular, any advice given to community groups undertaking pest animal control should focus

on animal welfare and humane methods of control. SPCA would like to draw attention to the fact

that there are no best practice guidelines for controlling and monitoring hedgehogs on the

National Pest Control Agencies website. In addition, although the links from the Wellington City

Council, Predator Free Wellington, DOC, and Predator Free NZ do suggest using kill traps that

have passed NAWAC testing, there is no information about how to humanely deal with an animal

that has been injured but not killed, or trapped live. These are serious and concerning oversights

and should be addressed as a priority. If people are being encouraged to destroy ‘pests’, then

those encouraging this have a responsibility to at least provide information that will reduce the

risk of animals being killed inhumanely.

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The proposed plan also states the following rule:

No person shall possess any hedgehog within a KNE identified on Map 1 in Appendix 3.

The prohibition on possession of any hedgehog within a KNE could mean that an already owned

animal would need to be destroyed. SPCA advocates that consideration must be given to those

hedgehogs who may already kept as companion animals by people in a KNE. The Society suggests

that those people who currently keep hedgehogs as companions should be allowed to keep those

animals as long as they remain adequately contained, at least for a period of time to safeguard those

animals currently owned.

Feral goat (Capra hircus)



Provide education and advice to land owners, occupiers and the public about feral goats, the threat

they pose to the region, and how to control them



just be undertaken to give information about ‘feral goats, the threat they pose to the region, and

how to control them’. In particular, any advice given to community groups undertaking pest animal

control should focus on animal welfare and humane methods of control. SPCA would also like to

draw attention to the fact that there are no best practice guidelines for controlling and monitoring

feral goats on the National Pest Control Agencies website.

Mustelids (ferrets, stoats, weasels) (Mustela furo, M. erminea, M. nivalis)


Greater Wellington:

Assist in the release of biocontrol agents for mustelids where appropriate

Provide advice and training to anyone undertaking mustelid control, with priority given to activity in

or around KNEs and in defendable or strategic geographic locations such as peninsulas, islands and

corridors


opposes the use of inhumane biological control methods that can cause significant suffering and

distress to affected animals. The Society would like to see a focus placed on animal welfare and





control of ‘pest’ animals is a vital component of providing education and advice.

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Pest cat (Felis catus)


*Pest cat means any cat within the Wellington Region that is:

(ii) Not microchipped in an area where microchipping is compulsory, and free-living, unowned and

unsocialised, and has limited or no relationship with or dependence on humans, or

(iii) Not microchipped, or registered on the New Zealand Companion Animal Register, and is free-

living, unowned and unsocialised, and has limited or no relationship with or dependence on humans

SPCA has a number of serious concerns about this definition in the proposal. The Society has

concerns about the labelling of cats as pests and a consequent negative impact on their treatment

and potential perceived sanctioning of cruelty towards cats.

There are also a number of important considerations regarding using microchips as an identifier:

• If microchips are going to be used to identify and classify cats, this must be grandfathered in;

this means allowing a grace period for cats that are not currently microchipped to be

microchipped and/or applying the rule only to cats of a certain age and below (so that after a

certain amount of time all cats will be microchipped).

• If using a microchip as a formalised and legal way of making decisions about a cat’s future,

then there needs to be intensive and effective community engagement and notification

about the risks to cats in areas where lethal control will be performed and what people need

to do. There would also need to be assistance offered to help people get their cats

microchipped and registered.

• Also of concern are the recent failures of microchips. Therefore, it is of utmost importance

that other forms of identification are also used to identify cats with a human caretaker.

Determination of whether a cat will be classified as a ‘pest cat’ should include other forms of

identification, such as the presence of a collar. In addition, the new Pet Facial Recognition

Technology 'PiP' technology should be added to the methods used to help identify cats; all people

carrying out cat control should be checking cats that might be euthanased, not only for microchips,

but also for collars and using NZCAR's 'PiP' facial recognition application (i.e. as other indicators that

a cat is a companion cat or managed stray cat with a caretaker).

The definition of a pest cat includes that the cat is “unsocialised, and has limited or no relationship

with or dependence on humans”. How will this be determined? Many cats may behave in a manner

that might make them seem unsocialised if they are trapped and terrified. Will some kind of

standardised assessment be performed? Will cats be given a chance to acclimatise and calm down

before being assessed? Best practice in animal shelters dictates that any behavioural assessments

are performed some time after a cat has entered the shelter and take place over a period of time to

allow the cat’s true behaviour to be assessed (ASPCA Pro, 2018; Weiss et al., 2015). Some additional

clarification and thought about these matters is needed.

The proposed plan also states that:

Greater Wellington will provide information and advice on the impacts of pest cats and best-practice

control methods, particularly to communities near KNEs and TA reserves.

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control of ‘pest’ animals is a vital component of providing education and advice. The

Society would like to see a focus placed on animal welfare and humane methods of animal

population control such as fertility control. There are such alternatives being developed

internationally and we would like to see New Zealand commit to progressive and humane treatment

of all animals, including those labelled as ‘pests’.

The proposed plan also states that:

Under section 14(2) of the Animal Welfare Act 1999: “A person commits an offence who, being the

owner of, or person in charge of, an animal, without reasonable excuse, deserts the animal in

circumstances in which no provision is made to meet its physical, health and behavioural needs”.

Rule 1

No person shall feed or provide shelter to pest cats on private or public land within the Wellington

Region, without the permission of the occupier.

Rule 1 prevents members of the public encouraging or supporting pest cat colonies on private and

public land, to assist with controlling pest and unwanted cat populations.

The definition of a ‘pest cat’ as one with “limited or no relationship with or dependence on humans”

is inconsistent with this rule. Cats that are being fed and cared for by humans are, by this definition,

not ‘pest’ cats and so this prohibition on caring for ‘pest’ cat colonies is contradictory.

In addition, if free-living cats are currently being cared for (i.e. there is a person or people in charge

of them) and those people are prohibited from continuing to feed or provide shelter for the cats,

then this would result in the desertion of the cats and potentially serious negative welfare

outcomes. This is not consistent with adherence to section 14(2) of the Animal Welfare Act 1999.

Careful consideration must be given to any managed cat colonies that currently exist in the Greater

Wellington Region. Good care of cats, including sterilisation, vaccination and health care can provide

good welfare outcomes for colony cats and should eventually result in the colony disappearing if all

incoming cats are rehomed or sterilised (Hughes et al., 2002; Johnson et al., 2014; Levy et al., 2014;

Nutter, 2005; Spehar et al., 2017; Stoskopf et al., 2004). SPCA asks the council to consider

implementing a cat colony register and best practice guidelines to allow exemptions for colonies and

carers, in appropriate areas, if the carers register and adhere to best practice.

Rat (Norway and ship) (Rattus norvegicus, R. rattus)



Assist in the release of biocontrol agents for rats where appropriate

Provide information and advice on pest animal identification, impacts and control

Provide advice and support to community groups undertaking pest animal control, with priority

given to activity in or around KNEs and in defendable or strategic geographic locations such as

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peninsulas, islands and corridors

SPCA would like to see research initiatives on humane alternatives supported and prioritised. The

Society opposes the use of inhumane biological control methods that can cause significant suffering

and distress to affected animals. SPCA would like to see a focus placed on animal welfare and






just be undertaken to give information about ‘pest animal identification, impacts and control’. In

particular, any advice given to community groups undertaking pest animal control should focus on

animal welfare and humane methods of control. SPCA would like to draw attention to the fact that

there are no best practice guidelines for controlling and monitoring rats on the National Pest Control

Agencies website. In addition, although the links from the Wellington City Council, Predator Free

Wellington, DOC, and Predator Free NZ do suggest using kill traps that have passed NAWAC testing,

there is no information about how to humanely deal with an animal that has been injured but not

killed, or trapped live. These are serious and concerning oversights and should be addressed as a

priority. If people are being encouraged to destroy ‘pests’, then those encouraging this have a

responsibility to at least provide information that will reduce the risk of animals being killed

inhumanely.

We are also concerned that the information given in the Greater Wellington Regional Council rats

and mice brochure and Wellington City Council rats and mice brochure states:

Wipe them out

Poison and traps are the best ways of killing rats and mice.

Poison baits

Baits are the most effective form of rat control.

SPCA wants to highlight that poisoning rats and mice is very inhumane. If these animals’ populations

must be controlled then more humane ways should be recommended. The Society encourages

Greater Wellington Regional Council and Wellington City Council to place greater importance on

animal welfare and advocate for humane control. These animals are still sentient creatures

recognised as such under the Animal Welfare Act 1999 (New Zealand Government, 1999), despite

being labelled as ‘pests’.

Conclusion

There needs to be a greater focus placed on ensuring the humane treatment of animals. In the

section on the proposal on actual or potential effects there is no mention at all of animal welfare.

SPCA urges Greater Wellington Regional Council and Wellington City Council to place more

importance on the welfare of animals and give due consideration to the fact that animals labelled as

‘pests’ are sentient creatures deserving of humane treatment. If wild animal populations must be

controlled, the international consensus principles for ethical wildlife control should be followed.

These principles recommend that any efforts to control wildlife ‘should begin wherever possible by

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altering the human practices that cause human–wildlife conflict and by developing a culture of

coexistence; be justified by evidence that significant harms are being caused to people, property,

livelihoods, ecosystems, and/or other animals; have measurable outcome-based objectives that are

clear, achievable, monitored, and adaptive; predictably minimise animal welfare harms to the fewest

number of animals; be informed by community values as well as scientific, technical, and practical

information; be integrated into plans for systematic long-term management; and be based on the

specifics of the situation rather than negative labels (pest, overabundant) applied to the target

species.’ (Dubois et al., 2017).

The issues SPCA has highlighted throughout this submission need to be addressed; there is a moral

obligation on those encouraging the killing of animals to ensure that every effort is made to ensure

the animals’ humane treatment, regardless of the label ‘pest’ that has been applied to the animal.

We appreciate the opportunity to give feedback on this topic and would welcome further

engagement on this issue.

References

ASPCA Pro. (2018). Feline Spectrum Assessment. Retrieved July 27, 2018, from

https://www.aspcapro.org/research/feline-spectrum-assessment

Dubois, S., Fenwick, N., Ryan, E. A., Baker, L., Baker, S. E., Beausoleil, N. J., … Mellor, D. (2017).

International consensus principles for ethical wildlife control. Conservation Biology, 31(4), 753–760.

Hughes, K. L., & Slater, M. R. (2002). Implementation of a feral cat management program on a

university campus. Journal of Applied Animal Welfare Science, 5(April), 15–28.

https://doi.org/10.1207/S15327604JAWS0501

Johnson, K. L., & Cicirelli, J. (2014). Study of the effect on shelter cat intakes and euthanasia from a

shelter neuter return project of 10,080 cats from March 2010 to June 2014. PeerJ, 2(1), e646.

https://doi.org/10.7717/peerj.646

Levy, J. K., Isaza, N. M., & Scott, K. C. (2014). Effect of high-impact targeted trap-neuter-return and

adoption of community cats on cat intake to a shelter. Veterinary Journal, 201(3), 269–274.

https://doi.org/10.1016/j.tvjl.2014.05.001

New Zealand Government. (1999). The Animal Welfare Act 1999. Retrieved May 9, 2018, from

http://www.legislation.govt.nz/act/public/1999/0142/56.0/DLM49664.html

Nutter, F. B. (2005). Evaluation of a Trap-Neuter-Return Management Program for Feral Cat

Colonies: Population Dynamics, Home Ranges, and Potentially Zoonotic Diseases. North Carolina

State University, Raleigh, NC, USA. https://doi.org/10.1007/s13398-014-0173-7.2

Spehar, D. D., & Wolf, P. J. (2017). An examination of an iconic trap-neuter-return program: The

Newburyport, Massachusetts case study. Animals, 7(11). https://doi.org/10.3390/ani7110081

Page 15 of 16

http://www.aspcapro.org/research/feline-spectrum-assessment



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SPCA submission: Greater Wellington Regional Council Proposed Regional Pest Management Plan

2019 – 2039

Stoskopf, M. K., & Nutter, F. B. (2004). Analyzing approaches to feral cat managementone size does

not fit all. Journal of the American Veterinary Medical Association, 225(9), 1361–1964.

https://doi.org/10.2460/javma.2004.225.1361

Weiss, E., Gramann, S., Drain, N., Dolan, E., & Slater, M. (2015). Modification of the Feline-Ality(TM)

Assessment and the Ability to Predict Adopted Cats’ Behaviors in Their New Homes. Animals, 5(1),

71–88.

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115 Kapiti Coast District

Council Cross, Rob


Please append the following to the submission form:

Paraparaumu/Raumati Community Board submission on Greater Wellington Regional Council’s

Proposed Regional Pest Management Strategy 2019-2039

At a meeting on 27 March 2018 the Paraparaumu/Raumati Community Board passed a resolution to

make a submission to Greater Wellington Regional Council requesting that the control of Argentine

ants be added to the Regional Pest Management Strategy.

This resolution was in response to a request from the chair of the Raumati South Residents’

Association, Trevor Daniell, who spoke to the Board regarding problems caused by Argentine ants

for residents of Raumati South.

Argentine ants are categorised in the Proposed Regional Pest Management Strategy 2019-2039 as

‘harmful organisms’ and not ‘ pests’. The Paraparaumu/Raumati Community Board requests that

Argentine ants are categorised as a ‘pest’ in the strategy and that effective control measures are

included.

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116 Lower North Island Region,

Department of Conservation

Fleury, Bill


Hello

In the proposed RPMP the site-led programme for hedgehogs, goats, mustelids, cats & rats

describes the sites as “in KNE area and TA reserves”. These areas are mapped in appendix 3 maps 5

& 6 but in the text it is stated “Appendix 3, Map 1 & 3” which are the Predator Free Wellington

control areas and the Boneseed sustained control programme areas. Rats and mustelids are

targeted for the PF Wellington sites

I also note that the Site-led” plan for possum refers to Predator Free Wellington initiative (Appendix

3, Map 2). Map 2 is the purple loosestrife progressive containment area.

Similarly, I note that the text refers to the “Predator Free Wellington initiative”, in several cases, but

that description does not appear on any of the maps. I assume that you meant the PF Wellington

Control Area shown in Appendix 3 Map 1 but it’s not clear.

Can you clarify please.

Thanks

Bill Fleury

Planner, Lower North Island Region, Department of Conservation,

VPN 6963, (0274)466 923. Private Bag 11010, Palmerston North

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117 WELLINGTON NATURAL HERITAGE TRUST Anstey, Clive


WELLINGTON NATURAL HERITAGE TRUST

The Trust made a submission on your proposed plan earlier during the week.

Subsequently we have had the benefit of reading the Wellington Botanical Society submission. We

would like to endorse this submission.

The Botanical Society raises a number of issues that urgently need addressing. We would like to

suggest that GWRC provide an opportunity for a wider discussion at the proposed workshops.

Perhaps GWRC could provide a summary of submissions to circulate before the workshops?

Clive Anstey

Chair, WNHT

To : Greater Wellington Regional Council

PO Box 11646

Wellington 6142

23.7.2018

Submission : Regional Pest Management Plan 2018 – 2039

Who We Are

Wellington Natural Heritage Trust (WNHT) was incorporated as a Charitable Trust in 1999 following

the purchase of what is now the Long Gully Bush Reserve (LGBR), which runs between Zealandia and

South Karori Road, by a group of prominent Wellington environmentalists.

The Trust’s prime objectives are to:

a) Identify any areas in the Wellington region that merit protection in their natural state;

b) Secure an appropriate level of protection for them;

c) Own, lease and/or administer them;

d) Restore or rehabilitate their ecosystems and natural values;

Page | 270

e) Eradicate or control pests on them;

f) Permit appropriate access to, and public enjoyment of, them.

To date, the Trust has extended the original 50.5 ha area to about 107 ha under its ownership

and/or management. This is the largest block of privately-owned protected land in the city. The

Trust’s land is covenanted with the QEII National Trust. The area was at one time designated a Key

Native Ecosystem.

Goat-proof fencing has been constructed around the property at a total cost of about $130,000.

Significant funding from the Biodiversity Condition Fund and the Wellington City Council enabled the

Trust to contract GWRC to undertake a predator and browser control programme and this has

continued with volunteer participation and by a contractor engaged by the Trust. A major grant

from the Department of Conservation’s Community Fund in 2017 has allowed the Trust to broaden

and intensify its restoration activities, in accordance with a Management Plan published in 2016.

In 2010, the Trust was instrumental in encouraging GWRC and other contributors to purchase Baring

Head as an addition to East Harbour Regional Park. The Trust is also seeking funding for weed

control on a DoC covenant at Makara.

SUBMISSION

WNHT supports GWRC’s proposed Regional Pest Management Plan. It is a concise document that

should bring coherence and consistency to the management of pest plants and animals across the

region.

That said, WNHT would like to see some changes in the specifics of the document, as follows.

1. The Trust would like to see the pest plant species that are being controlled by HCC as site-led

species (i.e. old man’s beard, cathedral bells and banana passionfruit) controlled to similar

levels in Wellington City, and would like to see similar powers conferred on WCC as those

conferred on HCC. To date, WNHT has had to deal with only one of these pest species on land

that it manages, however it recognises that the potential exists for the others to invade at any

time. Because neighbouring landowners (both close by and far away) are under very little

obligation to control these pest plants , the Trust’s Long Gully Bush Reserve, and other areas

of regenerating forest that are not covered by GW’s KNE site-led programme, are at ever-

increasing risk from these plants as populations build up in the wider area.

2. The Trust asks that Long Gully Bush Reserve (LGBR) and adjoining land be included in the

regional possum/predator control programme (RPPCP) by 2025. Figure 4, on page 9 of the

document, highlights what a glaring omission from the programme LGBR has been (LGBR

occupies most of the “uncontrolled” land immediately west of Zealandia, according to this

map). The Trust, a charitable organisation entirely reliant on grants for operational funding, is

currently undertaking the only possum and predator control within LGBR. LGBR provides a

buffer between GW-controlled land to the north and west (Wrights Hill Reserve, the Bargh

property, Makara Peak MTB Park, etc) and private land to the south which is currently subject

to no pest control whatsoever. Inclusion of LGBR in the RPPCP would improve the

effectiveness of pest control efforts in the areas to the north and west by slowing the spread

of pests from the south. It would also improve the survival of numerous native bird species

spilling over from Zealandia. The rest of the Wellington City Rural Area should be included in

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the RPPCP by 2030.

3. The Trust asks that the Predator-Free Wellington project area be extended to include Belmont

Regional Park, so that this can act as a buffer zone for mustelid control for the Wellington

Peninsula.

4. The Trust would like to see the adoption of a strategy to eradicate goats, pigs and deer from

the western Wellington peninsula. This should be explored with the rural and wider

community. The Trust has worked hard, at its own expense, to rid Long Gully Bush Reserve of

these three pests, however all three continue to threaten the work of the Trust because

neighbours do not control them on their own land. Deer were illegally released on land close

to LGBR and are now well- established in the area. Feral goats pose a huge threat to

conservation values in the Wellington City Rural Area. Native regeneration is surging ahead in

LGBR now that goats have been eliminated, however on neighbouring properties where their

numbers remain high, they continue to suppress the reversion of gorse-dominated scrub to

native forest. The Trust would be keen to work with neighbours to move the Wellington rural

community in a more sustainable long-term direction. While the Trust opposes goat farming

in the District, we acknowledge that the District Plan provide for this. The Trust wishes to see

very tight controls imposed on goat farmers, backed up by effective monitoring by the

regulator, to ensure that farmed goats do not pose a risk to protected natural areas.

Thank You for the Opportunity to make this submission.

The Trust greatly values the advice and support GWRC provides.

Chris Cosslett

Board Member on behalf of the Trust

Page | 272

118 Corie [email protected]


Hi there, ive been hunting around wellington for the last 18 years and have feed my self and family

wild venison and no beef for the last 5 years. There are some parts of wellington that have good

numbers of deer but are not open to recreational hunting.( would like to se these spots opened to

recreational hunting. No ballot.) As a hunter i am willing to do my part in keeping the pest numbers

down eg rabbits rats stoats goats and possum by allowing my trained dog to grab and kill most small

pest animals which we do all ready. Please do not use aerial 1080 drops and poison my food

resource and drinking water. I havnt hunted any wrc land since the kaitoke water catchment was

bombed a few years ago. I have seen first hand the jump in rat numbers after a drop. Totara flats 18

years ago i never had an issue with rats. Since the massive poison drops doc did for the kaka project i

dont hunt there either because the rat numbers since the drop have trippled and because of the

amount of dead animals i saw after the drop. Eg fantail robin a couple of morepork black birds deer

pig and a single possom. i dont want me or my family to be poisoned from the misuse of an

extremely toxic substance that dosnt belong any where in nz. Thank you for allowing a little voice to

be heard. Please dont use 1080 its killing every thing not just the pests.


Page | 273

119 Zealandia Hayes, Cameron

Although we are supportive of GWRC and the Pest Management plan in principle, we would prefer that

you source a front-cover image that is not so strongly associated with ZEALANDIA.

While we don’t have exclusive rights to that image, Rob Suisted, the photographer, gifted it to us some

time back. We use it in a lot of our promotional activity, including our website, visitor centre, brochures,

etc.

By using the current image it gives the impression that this plan is related explicitly to ZEALANDIA,

which is not the case.

I’d suggest a GWRC regional park or image of flora/fauna that can equally represent the positive

outcomes of pest management.

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120 Piers Have Your Say 19.12.17

The use of brodifacoum is a concern given it persists in the environment for much longer than 1080

and has more likely longer term effects on invertebrates and birds of prey.

121 Sandy Werner Have Your Say 14.2.18

Although cats are included in the list above, I wonder if it is fair to say "roaming cats". Also,

wondering if the South African praying mantis should be included? And are mice normally in this list?

I would like to stress the urgency of adopting a cat management strategy. There's clearly a need to

control free roaming cats. On the one hand GWRC and city councils are encouraging individuals to

look after our native flora and fauna and on the other hand failing to provide the support we need to

protect the newly arriving birds and lizards to our gardens from being hunted day and night by cats.

The lack of leadership on this front is pitting neighbour against neighbour as the cat vs bird debate

worsens.

There is an urgent need to prevent cats from hunting at night. Lizards and Rurus are both active at

night and therefore at risk from predation by cats at night. Pest Free NZ/Plimmerton has been very

successful so far in significantly reducing rat and mice populations. A ripple effect of these efforts is

and will continue to be the change to the Ruru diet and subsequently the additional stress on lizard

populations. As the Ruru diet changes from eating rats, mice and lizards to rely more on lizards and

larger insects, so too the cats will be hunting lizards more. This not only increases stress on lizard

populations but puts Ruru and cats in closer proximity to each other, both in competition for a

diminished prey.

"Please we need better cat management to protect wildlife, including microchipping, registration,

sterilization, curfews and/or containment. Encourage cat owners to keep pet cats indoors or in an

outside catio.

"Please include the south African praying mantis, since their presence will lead to the loss of our

native praying mantis.

"Please we need better cat management to protect wildlife, including microchipping, registration,

sterilization, curfews and/or containment. Encourage cat owners to keep pet cats indoors or in an

outside catio.

"Please include the south African praying mantis, since their presence will lead to the loss of our

native praying mantis.

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122 Jacko Have Your Say 14.3.18

Isn't the forest ringlet butterfly an endemic?

http://nzbutterfly.info/resident/forest-ringlet/

123 EdmundSS Have Your Say 2.7.18

"Old Man's Beard.

Karo.

Darwin's Barberry.

Wilding pines (if present).

Wilding pohutukawa (because of the hybridising with Northern Rata).

Use 1080 where appropriate. Where it's practical and effective to trap densely, let's do it. Where

it's not practical (e.g. Tararuas) use 1080 until something better comes along.

Eradication, and the creation of pest-free areas (first Miramar/Kairangi peninsula; the entire

Wellington peninsula; the Orongorongo/Rimutaka area & beyond) should be a medium-term aim.

Deer and pigs prey on native birds/eggs. They can be considered a resource, but they're also a pest,

and should be managed accordingly.

124 Saisr Have Your Say 4.7.18

Agapanthus should be added to the pest plant list and eradicated. It is now appearing on the waters

edge of the Pauatahanui Inlet and is displacing the natives which were the only plants there. It has

spread from gardens on the edge of the inlet and along its waterways. Some garden owners remove

the flower heads before they can seed but most leave them and agapanthus is a robust seeder.

125 Kakas

Have Your Say 4.7.18

Privet should be added to pest list. It causes bad asthma and illness and is a noxious weed in a

number of regions.

Why are hedgehogs listed as pests? This doesnt seem justified.



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126 Miro Have Your Say 6.7.18

ivy, eleagnus, asparagus vine, banana passionfruit vine all rampant in Mt Victoria greenbelt city side

of Constable St

127 Jeremy Collyns Have Your Say 8.7.18

Using the new roads (transmission Gully) build a pest exclusion fence along the middle medium strip

one to two meters high to stop the smaller pests moving East to West.The fence would start at

Raumati South Beach and finish at Ngauranga. This would allow clearance of these pests from the

bottom western part of the region and allow the native birds from Karori Sanctuary to populate this

cleared area safely.

This would help the council and community to meet the expectations of Predator Free 2050 and

start the process of clearing the region of pest animals.

128 Jacqui Lane Have Your Say 18.7.18

Convululus and morning glory. And get back onto old man's beard. There wasn't much around for

ages, but it is starting to appear everywhere in the last 2 years, even at parliament.

129 John McLachlan Have Your Say 20.8.18

Towards the aim of a Pest Free 2050, much improvements in pest control has already been

obtained within the area covered by the Kapiti Biodiversity Programme

Protection of those improvements needs to be attempted by intensification of boundary controls

The area should desirably be extended by the utilization of contractors and community groups

working under the control of a project manager.

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130 Graeme Blanchard Have Your Say 20.7.18

Recreational hunters welcome the opportunity to work with you rather despite your plans. Thank

you.

"Really appreciate your direction towards working with recreational hunters, who can play such an

important role in conservation and caring for our environment if allowed.

Thank you.

GRC used to make a point of eradicating Old Man's Beard. It is a really invasive and ugly pest I think

this should be back on your list for eradication.

"Please do something about the deer destroying the most accessible parts of East Harbour Park,

where the understory is damaged beyond recognition and numerous appeals to GWRC have failed to

have any action taken, without explanation.

The ecosystem should be protected for everyone's enjoyment but the current strategy is causing

erosion, widespread damage to trees, roots and regenerating forest.

For a long-time park user it is frustrating that this has not only been allowed to continue, but actively

encouraged through what appears to be neglect. For a KNE it is becoming a laughable management

of public assets. Even my kids now complain about the damage that is clear, obvious and widespread

along all the Western flanks.

But it's not funny, it's an appalling situation that has gone on for years and is getting worse every

year.

Thank you for considering those who do not use the park for hunting yet appreciate the precious

native ecosystem and biodiversity and the value it holds for the wider community and our

descendants.

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131 Longtime EHRP Park User

Please do something about the deer destroying the most accessible parts of East Harbour Park, where the understory is damaged beyond recognition and numerous appeals to GWRC have failed to have any action taken, without explanation. The ecosystem should be protected for everyone's enjoyment but the current strategy is causing erosion, widespread damage to trees, roots and regenerating forest. For a long-time park user it is frustrating that this has not only been allowed to continue, but actively encouraged through what appears to be neglect. For a KNE it is becoming a laughable management of public assets. Even my kids now complain about the damage that is clear, obvious and widespread along all the Western flanks. But it's not funny, it's an appalling situation that has gone on for years and is getting worse every year. Thank you for considering those who do not use the park for hunting yet appreciate the precious native ecosystem and biodiversity and the value it holds for the wider community and our descendants.

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132 Pando Have Your Say 24.7.18

Pine trees should be removed wherever possible and replaced with natives. Especially on Miramar

Peninsular and town belt of Wadestown.

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133 John Flux Have Your Say 24.7.18

"Forest Ringlet is an endangered NZ endemic.

It should be removed from this list of pests."

"Cats should not be on the list until rats, mice, mustelids, and rabbits are removed.

Until then they are helping to catch animals that are trap and poison-shy."

134 Paul Martinson Have Your Say 24.7.18

Cats are the third most significant causal factor of avian extinction in NZ, but still no law controlling

them. Cats need to be micro-chipped and identifiable with an owner. Until that time there is no sure

way of distinguishing feral, stray and owned animals from each other. Many 'owned cats are killed as

a result. Cat control is essential. Please introduce it.

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Appendices

Appendix 1

#99 MPI – supporting documents

Appendix: Wilding Conifers Background and Guidance

Background

Over the last 7 years MPI has led a collaborative national process to improve wilding conifer management in New Zealand. This work led to the development of a status report by Pacific Eco-Logic in 2011 and the New Zealand Wilding Conifer Management Strategy 2015 – 2030, in 2014 (the Strategy). This was followed by a cross-government initiative for a National Wilding Conifer Control Programme (the Programme) that started in 2016 and is ongoing.

The Strategy identified the need to improve regulatory consistency and effectiveness in wilding conifer management. A multi-stakeholder advisory group was involved in developing a suite of provisions and associated guidance that make up a model regulatory framework for use in Regional Pest Management Plan (RPMP), wilding conifer pest programmes.

A considerable investment of public funds has been applied in a collaborative programme involving local government and central government agencies. Phase 1 of the Programme has seen $22 million invested in control of wildings from 2016 – 2019. This work has shown that it’s possible to tackle New Zealand’s No. 1 weed, and retain future opportunities for economic return, conservation, and outdoor recreation.

Current Situation

We are now working with partner agencies on scoping for Phase 2 which will see new areas being tackled as the Programme is extended. Given the significant public and private investment, MPI encourages all councils to adopt a regulatory framework to protect the Phase 1 investment and any new investment that may occur in Phase 2.

This can be achieved by a regulatory framework that:

Prevents establishment of new spread prone-prone conifer plantings;

Requires land occupiers to keep clear areas clear;

Requires land occupiers to keep areas clear following control being undertaken by a

collaborative programme such as the National Wilding Conifer Control Programme; and

Promotes consistency between neighbouring regions.

Wilding Conifer Pest Management Plan Rule Development Project

In April 2016 MPI circulated guidance, and a suite of recommended provisions with narrative commentary for use in wilding conifer RPMP pest management programmes. This is one of a number of initiatives contributing to the implementation of the NZ Wilding Conifer Management Strategy.

Regional variances in the nature and extent of wilding conifer problems and in the resources available to address them is recognised, and guidance in the material emphasises the importance of regional councils determining the most appropriate and effective wilding conifer programme objective(s) and associated principal measures for their region.

However, as regional councils develop their new RPMPs, it is timely to promote this material due to its importance in providing long-term protection of public investment in control.

Under the Biosecurity Act, pests in a Plan are those organisms, or class or description of organism, specified as such. For most organisms this generally requires listing the particular species. However, where it is a class or description of organisms such as Wilding Conifers, the description is the critical factor, rather than the particular species.

The key factor is that the trees are wildings (i.e. naturally established) rather than deliberately planted. Given the legal implications of ss 52 and 53 of the Biosecurity Act when something is classified as a pest, this distinction is particularly important in relation to conifer species that are valuable commercial species when in their planted form, but which can also be pests in their wilding form.

Including a Good Neighbour Rule (GNR) for Wilding Conifers

A key benefit of including a GNR is that it provides a degree of protection of the investment that is made in wilding conifer control by seeking to reduce or prevent the re-infestation of cleared areas due to seed spread from neighbouring properties. MPI regards a GNR to be an important regulatory support to any public investment in control via the National Wilding Conifer Control Programme.

A GNR would apply to all occupiers, including the Crown and complement a ‘maintenance’ type rule for Wilding Conifers.

The Guidance Material is appended.

The regulatory framework for Wilding Conifer management can be complex. The interplay of rules made under the Biosecurity Act and Resource Management Act respectively is summarised in the diagram below:

Wilding Conifer Pest Management Plan Rule Development Guidance

Guidance, and recommended template provisions and narrative for use in wilding conifer pest management programmes within Regional Pest Management Plans throughout New Zealand.

Disclaimer

While every effort has been made to ensure the information in this publication is accurate, the Ministry for Primary Industries does not accept any responsibility or liability for error of fact, omission, interpretation or opinion that may be present, nor for the consequences of any decisions based on this information.


Guidance, and recommended template provisions and narrative for use in wilding conifer pest management programmes within Regional Pest Management Plans throughout New Zealand.

This material has been developed as a component of the New Zealand Wilding Conifer Management Strategy 2015-2030 Implementation Programme.

April 2016

Prepared for Ministry for Primary Industries Pastoral House 25 The Terrace

New Zealand Wilding Conifer Management Strategy Implementation Programme


Contents 1 Introduction ............................................................................................................................... 2

2 Specifying Wilding Conifers as a Pest: Establishing a Consistent Definition for Wilding Conifers . 5

3 Specifying Particular Conifer Species as Pests ............................................................................. 9

4 Determining Wilding Conifer Programmes and Outcomes, and Mapping/Delineating Zones to Which

They Apply ............................................................................................................................... 12

5 Recommended Rules ............................................................................................................... 15

6 Standardised Description of Adverse Effects of Wilding Conifers .............................................. 26

7 Overarching Objective.............................................................................................................. 28

8 Standardised Wilding Conifer Programme Objective Statements.............................................. 29

9 Standardised Statements of Intent for Wilding Conifer Rules ................................................... 32

Appendix 1: Information Sources for Rules 4 – 6 Distances .............................................................. 33


2

1 Introduction

Background

The Wilding Conifer Pest Management Plan Rule Development Project (the project) has been initiated as part of the Implementation Programme for the NZ Wilding Conifer Management Strategy 2015-20302 (the Strategy).

The development of the Strategy was led by the Ministry for Primary Industries (MPI) in collaboration with a multi-stakeholder working group. The Strategy establishes an agreed Vision for wilding conifer management in New Zealand, and identifies that achieving the Vision will require a multi-faceted approach centred round four principles: individual and collective responsibility, cost-effective and timely action, prioritisation and co-ordination. In relation to each principle, a number of objectives and a range of associated actions have been identified.

The Strategy seeks to address some of the critical issues that have at times hindered progress around wilding conifer management and control. These include clarification of the roles and responsibilities of central government, local government, and land occupiers; and development of a cost-share framework that suggests cost shares for scenarios of different origin or source plantings (legacy plantings, post-RMA plantings, future plantings), and land tenure3.

This project aims to contribute to actions and objectives under the ‘Coordination’ principle in the Strategy. Specifically, Objective 4.1 aims to promote a consistent policy approach, and Actions contributing to achievement of this include working collaboratively to develop agreed regional pest management plan rules, and promoting consistent regulation relating to wilding conifer management at the local government level (Actions 4.1a and 4.1c). The project aims to give effect to these Actions.

OBJECTIVE 4.1: Promote consistency in policy across organisations ACTION 4.1a: Work collaboratively to develop agreed best practice regional pest management plan rules, or local strategies, which address wilding conifer spread across boundaries without capturing appropriate plantings, that is, investigating new regulatory options such as development of site-led rules. ACTION 4.1c: Promote consistency across local government including exploring national policy mechanisms to ensure consistent regulation relating to wilding conifer management.

The project was initiated by MPI and undertaken by an independent contractor working with a multi-stakeholder Working Group consisting of representatives from MPI, LINZ, DOC, Regional Councils, Federated Farmers, and forest owners.

The timing of the project aimed to align with finalisation of the National Policy Direction for Pest Management (the NPD) so that consistent provisions for wilding conifers may be incorporated into Regional Pest Management Plans as they are reviewed in response to the NPD.

2 The right tree in the right place: New Zealand Wilding Conifer Management Strategy 2015-2030, December 2014 http://www.wildingconifers.org.nz/images/stories/wilding/Articles/2014_new_zealand_wilding_conifer_management_strategy_2.pdf 3 The cost-share model is set out at p17 of the Strategy, and explained in Appendix II and III of the Strategy.

http://www.wildingconifers.org.nz/images/stories/wilding/Articles/2014_new_zealand_wilding_conifer_management_strategy_2.pdf



3

Project Objective

To develop agreed Regional Pest Management Plan (RPMP) rules for the management of wilding conifers in order to improve regulatory consistency and effectiveness, and to support other components of the Strategy Implementation Programme.

In particular, the project is focused on: - developing an agreed ‘definition’ for wilding conifers for the purposes of specifying wilding conifers

as a pest under RPMPs4; and - developing a core suite of rules that may be used in RPMP wilding conifer pest programmes to

provide a regulatory basis for: o prevention and early intervention to prevent the further spread of wilding conifers; o the management of externalities arising from wilding conifer spread; and o protecting investments made in wilding conifer clearance operations.

The material that has been developed includes: - a definition for wilding conifers, recommended narrative to accompany the definition, and

associated explanatory/guidance material; - recommendations regarding separately specifying several conifer species as pests, and associated

explanatory/guidance material; - recommended factors to be taken into account in determining the nature of RPMP wilding conifer

pest programmes and associated outcomes, and in determining where and how rules do and don’t apply, and associated explanatory/guidance material; and

- a suite of template rules for wilding conifers and/or specified conifer species that may be used as principal measures under RPMP wilding conifer pest programmes, recommended explanatory notes to accompany some rules, and associated explanatory/guidance material.

The above material is set out in the following Sections 2-5, and within each Section the recommended material for inclusion within RPMPs, or for consideration in the development of RPMP provisions, is set out in the grey shaded boxes, followed by explanatory/guidance notes for the material.

Additional Supporting Material

During the development of the above material, an inter-Regional Council project to improve consistency and alignment between RPMPs was initiated. Referred to as the RPMP Collective Project, an output of it was a standardised template for both Proposed RPMPs and subsequent finalised RPMPs.

In order to support a consistent and efficient approach to the development of RPMP wilding conifer programmes, additional material was developed to accompany that set out in Sections 2-5 of this document, and which may be used to populate Section 6 of the RPMP proposal and plan templates developed through the RPMP Collective Project. This additional material is set out in Sections 6-9 and includes:

- Standardised description of adverse effects of wilding conifers

- An overarching objective for the management of wilding conifers

- Standardised objective statements for the 5 potential RPMP wilding conifer programmes

4 Note that this project is an initiative arising from the NZ Wilding Conifer Strategy, which deals exclusively with wilding conifers, not other wilding trees. Consequently, the wilding conifer definition has been developed to be aligned with the Strategy and addresses only introduced conifers.


4

- Standardised statements of intent for all of the template rules set out in Section 5.


5

-

2 Specifying Wilding Conifers as a Pest: Establishing a Consistent

Definition for Wilding Conifers

Recommended Wilding Conifer Definition

Wilding conifers are any introduced conifer tree, including (but not limited to) any of the species listed in Table 1, established by natural means, unless it is located within a forest plantation, and does not create any greater risk of wilding conifer spread to adjacent or nearby land than the forest plantation that it is a part of.

For the purposes of this definition, a forest plantation is an area of 1 hectare or more of predominantly planted trees.

Table 1

Common Name Scientific Name

Douglas fir Pseudotsuga menziesii

Lodgepole or contorta pine Pinus contorta

Scots pine Pinus sylvestris

Dwarf mountain pine and mountain pine

Pinus mugo and P.unicinata

Bishops pine Pinus muricata

Maritime pine Pinus pinaster

Ponderosa pine Pinus ponderosa

Corsican pine Pinus nigra

European larch Larix decidua

Radiata Pine Pinus radiate

Recommended Narrative to Accompany Definition in RPMP Wilding Conifer Programme

Wilding conifers are introduced conifers that have mainly established naturally as a result of natural seed spread. This process has been exacerbated by landowners failing to take action when wilding conifers first occur, and much of the ongoing wilding conifer spread in New Zealand is generated from existing areas of reproducing wilding conifers. Much of the initial wilding conifer spread originated from a range of sources, particularly historic or ‘legacy’ plantings, such as Crown plantings for erosion control and research; long-established shelterbelts and amenity plantings on private and pastoral lease land; and in some locations, from woodlots and forest plantations.

Wilding conifers are produced by many different introduced conifer species. Ten conifer species are recognised as currently contributing most to the wilding conifer problem in New Zealand5. While some of these species now have little or no commercial value and are no longer planted, or much less frequently planted than in the past, several of these species,

5 Froude, V. A. 2011: Wilding conifers in NZ – Beyond the status Unpub. Report MAF


6

particularly Radiata pine (Pinus radiata) and Douglas fir (Pseudostuga menziesii), are highly valuable commercially grown species that contribute significantly to forestry exports.


7

Explanatory / Guidance Notes

In order to establish RPMP rules for wilding conifers, it is necessary to specify them as a pest under the RPMP. To date, this has been done in several, but not all regions, and in each case a different definition or description has been used.

The Biosecurity Act 1993 (the BSA) defines a pest as “an organism specified as a pest in a pest management plan”.

Sections 70-73 of the BSA refer to the ‘subject’ of a RPMP, which may be:

- an organism or organisms; or

- a class or description, or classes or descriptions, of organism or organisms

that are specified as a pest or pests in the RPMP.

Collectively, these provisions indicate that organisms specified as pests under a RPMP may be described under a collective term (such as ‘wilding conifers’). Although it is not clear whether listing the particular species covered by the collective term is required, it is arguable that for certainty, this should be done. Consequently, for the purposes of specifying wilding conifers as a pest in RPMPs, it is recommended that the particular species of concern be included in the definition/description.

One of the key challenges associated with the management of wilding conifers is that while wilding conifers are a pest, planted conifers are a valuable resource. This highlights the importance of recognising the considerable value of planted and responsibly managed conifers, and clearly distinguishing these from naturally regenerated wilding conifers that can pose a threat to a range of environmental, economic, aesthetic, recreational, and other values. The proposed wilding conifer definition incorporates all ten of the most spread-prone conifer species, but specifically applies only to those trees that are naturally regenerated, rather than intentionally planted.

Exclusion for wildings within plantations

The definition excludes naturally established conifers where they occur within an otherwise predominantly planted forest and pose no greater risk of spread than the forest itself. This exclusion aims to take account of the situations where there are wilding conifers within planted forests that do not pose any greater spread risk than the forest itself, and so ‘capturing’ these individual trees will achieve little in terms of any wilding conifer pest programme. Consideration was given to only excluding specified, commercially valuable species in this situation. However, it was ultimately considered more appropriate that the situation should determine the exclusion, rather than the situation and the species. This is also because the principle here is that if a wilding conifer is located within a forest, it is unlikely to pose any more threat of spread than the surrounding planted trees, and therefore little is gained by ‘capturing’ it within the definition. However, it is plausible that the wildings within the forest may be of a significantly more invasive species than the surrounding plantation species (eg contorta within a radiata plantation). If this is the case, and particularly if the wilding is located at or near the edge of the forest, then it may pose a greater risk of spread. This was the basis for the requirement that the wildings do not pose a greater spread risk than the wider forest plantation. This may also address the situation where a forest is harvested, but areas of wilding conifers are left standing. For some species, with the ‘buffer’ of the planted trees removed, the spread risk may increase significantly, in which case the exclusion criteria would no longer be met. This creates an important incentive for spread prone wilding conifers to be removed at the time of harvesting the surrounding plantation.


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Including some species in their wilding and planted state

Consideration was given to developing a wilding conifer definition that covered some species only in their wilding (naturally regenerated) form, and other species (low commercial value, more invasive species) in both their wilding and planted form. However, this added complexity to the definition, and also had the potential to create confusion and ambiguity around whether something was naturally regenerated or not. It is important for a number of reasons, including issues around perceptions and recognising the value and importance of planted forests, that it is kept clear that ‘wilding conifers’ are naturally regenerated trees. Therefore, it was considered more appropriate that some species be specified as pests separately and in addition to, the class of organisms described as wilding conifers. See Section 3 below regarding specifying several conifer species as pests.

Building spread risk, threat to values, and origin of spread into the definition

It has been suggested that the approach to dealing with wilding conifers should be driven more by factors such as the risk of spread and threats to values than simply by the fact that a tree is naturally regenerated, to better reflect the ‘right tree in the right place’ concept reflected in the Strategy Vision. In the context of this project, these factors are considered important and appropriate to inform and guide the determination of RPMP programmes and outcomes for wilding conifers, and where and how rules will apply, but less appropriate to be built into the wilding conifer definition. The definition should be as simple and certain as possible and easily adopted by regions around the country. If the starting point is naturally regenerated conifers, then subsequent determinations about spread risk and threats to values essentially becomes, appropriately, a determination that is made at the regional level based on the regional and local environmental and geographical context, and existing regional values that can be adversely impacted by wilding conifers. Thus these factors are most appropriately applied in relation to determining the most appropriate programme and associated outcome for wilding conifers in a particular region, and then in particular, in determining where particular rules (and/or other principal measures) will/will not apply. Consequently, these factors have been incorporated into recommendations regarding the determination of RPMP programmes and outcomes for wilding conifers and the establishment of zones where rules may/may not apply – see Section 4.

The origin (and associated timing) of wilding conifer spread is also not practicable to use as a refinement tool within the wilding conifer definition. It creates unnecessary complexity when there is not any argument that the trees are wildings, just issues around the equitability of who should meet the costs of control if control is required – making it an issue at the point of determining where/when rules apply, rather than whether the trees are or aren’t wilding conifers. This factor has therefore been incorporated into Section 4 via the application of the Strategy cost-share framework.

NOTE: See Section 6 for a standardised description of the adverse effects of wilding conifers, which may be used in meeting the requirements of the BSA and NPD, and in populating Section 6 of the RPMP Collective Project plan and proposed plan templates.


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3 Specifying Particular Conifer Species as Pests

In order to enable the regulatory control of at least some planted conifers where they pose a wilding conifer spread risk, and at the very least to prevent new plantings of these species, it is recommended that, in addition to specifying wilding conifers as pests using the definition set out in Section 2, RPMPs specify the following introduced conifer species as pests.

Conifer species recommended for inclusion in RPMPs as pests:

- Lodgepole or contorta pine (Pinus contorta) - Scots pine (Pinus sylvestris) - Dwarf mountain pine and mountain pine (Pinus mugo and Pinus unicinata) - European larch (Larix decidua)*

*Excludes sterile hybrids

Explanatory / Guidance Notes Wilding conifers often occur as a result of seed spread from planted conifer trees. It can be difficult to successfully control or manage the spread of wilding conifers over the long term if the seed source is not removed or appropriately managed and contained. There are a range of mechanisms and approaches that may be used, including: regulatory controls under the RMA for new conifer plantings; the potential development of an Accord establishing industry endorsed forest management practices for the management of wilding conifer spread from existing and future forest plantations; education, advice and assisted control programmes aimed at raising landowner awareness about the potential impacts of particular species when used for shelter and other purposes; and assisting landowners to identify, remove, and/or mitigate the impacts of, plantings that cause wilding conifer spread. These are all outside the scope of this project, but are actions likely to be necessary contributors to addressing some of the critical issues in wilding conifer management.

Within the scope of this project, there is the potential to provide for regulatory support through the use of RPMP rules to address those situations where wilding conifer spread from planted conifers is generating unreasonable impacts on neighbouring land, or threatening key areas of value. However, regulating an organism within an RPMP requires that the organism be specified as a pest in the RPMP6. One of the statutory consequences of specifying an organism as a pest is that it triggers ss 52 and 53 of the BSA, which prohibit the propagation, sale, breeding, communication, release etc of the species. Where a species that causes wilding conifer spread also has significant value as a planted and commercially managed resource, as is the case for a number of the conifer species, this creates an untenable outcome7.

6 This differs from specifying an organism as an ‘unwanted organism’ (as is the case currently for Contorta), which is a central government process that triggers the ss 52 and 53 statutory obligations only and does not require removal of any existing trees, whereas specifying an organism as a pest in a RPMP triggers the statutory obligations and enables the development of RPMP rules to manage/control the pest where it is already planted/established. 7 It is relevant to note here that ss 52 and 53 of the BSA are only triggered by the specification of an organism as a pest

or unwanted organism. These sections do not apply if an organism is specified as a ‘pest agent’ for the purposes of a

RPMP rule of the type permitted by s73(5)(h) of the BSA, and this does not equate to specifying the organism as a pest.

During this project, consideration was given to specifying planted conifers as a ‘pest agent’ for the purposes of rules to

manage the spread of wilding conifers onto nearby or adjacent land from planted conifers near property boundaries.


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However, some of the species that cause wilding conifers have very limited commercial value, but can be highly invasive, and therefore it may be appropriate to specify these species as pests in their planted state, in addition to being pests under the wilding conifer definition in their naturally regenerated state. This would effectively prevent new plantings of these species, as well as enable regulatory control requiring removal of these species in situations where they are planted but pose a wilding conifer spread risk.

Contorta in particular, is the most invasive introduced conifer species and represents a significant proportion of all wilding conifers and original sources of wilding conifer spread. Contorta is already an unwanted organism under the BSA, but is specified as a pest and subject to rules in only some current RPMPs.

Other low value but highly invasive conifer species that could also potentially be specified as pests are Scots pine, Dwarf mountain pine, Mountain pine, and European larch. In the case of European Larch, the intent here is to address early plantings that cause ongoing wilding spread, rather than the sterile hybrids that tend to be used in more recent plantings.

Where an RPMP includes a programme for wilding conifers, there may potentially be duplication between that programme and the programme for any of these species, depending on the respective programme outcomes, and geographic areas where these apply. The extent of, or potential for, duplication will vary regionally, and Councils will need to consider whether to:

- retain these species within the ‘wilding conifer’ definition, as well as separately specifying them as a pest

in both their wilding and planted state (recommended);

- exclude these species from the ‘wilding conifer’ definition and separately specify them as a pest in both

their wilding and planted state; or

- retain these species within the ‘wilding conifer’ definition and separately specify them as a pest in only

their planted state.

A key factor in recommending that these species be separately specified as pests is to enable control of them in their planted state where they are causing wilding conifer spread and/or threaten particular values through the spread of wilding conifers, as a means of supporting and contributing to wilding conifer outcomes. Consequently, these species would ideally be managed under the same RPMP programme as wilding conifers, but could potentially also be managed under a different programme in a different part of a region.

Another issue associated with separately specifying these species as pests in addition to wilding conifers, is that the wilding conifers within forests specifically excluded from the wilding conifer definition, could potentially still be ‘captured’, depending on the species, and on the proposed programme and any associated rules for those species. In addition, legacy plantings of these species that remain within or a part of forests could also be covered. It is unclear how widespread or significant an issue this is, but it is likely to vary regionally. In the event of a low number of sites where this will be an issue, resolution via the granting of exemptions is likely to be the most appropriate approach, however if the issue is expected to be widespread or significant in a region, consideration could be given to building in a similar exclusion for the pest where it occurs within a forest, as is included in the proposed wilding conifer definition.

In terms of potential rules that could apply to these species, this has been considered within the context of managing wilding conifers. Consequently, rather than developing separate rules for these species, reference to these species has been incorporated into the proposed suite of rules (see Section 5, Table 2). This enables the

Section 73(5) of the BSA lists the type of rules a RPMP may include, and s73(5)(h) provides for rules that require an

occupier to take specified actions to eradicate or manage the pest or a specified pest agent (emphasis added).

The BSA defines ‘pest agent’ as: ‘…in relation to any pest, means any organism capable of—

(a) helping the pest replicate, spread, or survive; or

(b) interfering with the management of the pest’

Uncertainty over whether or not a planted conifer tree whose spreading seed becomes a wilding conifer(s) would

fall within the definition of ‘pest agent’ or not, combined with project time constraints, have meant that this issue

has not been thoroughly or legally tested at this stage.


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inclusion or exclusion of these references within wilding conifer rules as is appropriate, depending upon the regional approach taken, and/or enables the same rules to be used without reference to wilding conifers, should any of these species be managed through a separate programme.


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4 Determining Wilding Conifer Programmes and Outcomes, and

Mapping/Delineating Zones to Which They Apply

It is recommended that the factors set out below are taken into account in the determination of wilding conifer programmes and associated outcomes, and in the delineation/mapping of zones where particular rules and other principal measures will and won’t apply.

Factors to take into account in determining RPMP wilding conifer programmes and outcomes, and applicability of associated rules

Current stage of infestation of wilding conifers within a region/area/zone

The nature, location and vulnerability of sites or areas of value that may be threatened by wilding conifer spread within a region/area/zone

The level of wilding conifer spread risk within, from, or into a region/area/zone, based on: o the environmental and geographic characteristics of the region/area/zone; o the nature and vulnerability to wilding conifer spread of predominant land use

(including current grazing pressure) and existing vegetation in the region/area/zone; and

o the extent, species, and location of any known potential wilding conifer seed sources relative to the region/area/zone8

The level of land occupier awareness of the presence of wilding conifers species on their land

Application of the cost-share framework set out in the NZ Wilding Conifer Management Strategy9, which requires consideration of the origins of different areas of wilding conifer infestation within the region/area/zone


The NPD prescribes five potential programmes and associated intermediate outcomes. Any subject of a RPMP must be managed under at least one of these programmes and associated outcome. The possible programmes are: Exclusion, Eradication, Progressive Containment, Sustained Control, and Site-Led. The corresponding intermediate outcomes are: - exclusion: to prevent the establishment of the subject that is present in New Zealand but not yet

established in an area; - eradication: to reduce the infestation level of the subject to zero levels in an area in the short to medium

term; - progressive containment: to contain or reduce the geographic distribution of the subject to an area over

time; - sustained control: to provide for ongoing control of the subject to reduce its impacts and its spread to other

properties; and - protecting values in places: the subject that is capable of causing damage to a place is excluded or

eradicated from that place, or is contained, reduced, or controlled within the place to an extent that protects the values of that place.

8 The wilding conifer spread risk calculator (DSS 1 ad DSS 2) developed by SCION (http://www.wildingconifers.org.nz/images/stories/wilding/Articles/DSSs1&2_NES%20version%2007011.pdf ) may be a useful support tool for assessing spread risk. The calculator has been designed primarily for use at the specific site level, however the factors and scoring within the calculator could be used to inform assessments at the wider scale. 9 The cost-share framework is set out at p17 of the Strategy, and explained in Appendix II and III (http://www.wildingconifers.org.nz/images/stories/wilding/Articles/2014_new_zealand_wilding_conifer_management_strategy_2.pdf ).

http://www.wildingconifers.org.nz/images/stories/wilding/Articles/DSSs1&2_NES%20version%2007011.pdf




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For each subject in a programme, the principal measures proposed to be used to achieve the intermediate outcome must also be specified. Principal measures may or may not include rules, as well as non-regulatory initiatives and/or direct pest control by the management agency.

In order to propose a particular pest programme in a RPMP, there are a number of statutory requirements that must be met. These include provisions in the NPD and in the BSA. In particular, sections 70 and 71 of the BSA prescribe what must be included in relation to each subject addressed in a proposed pest programme, and what the proposer must be satisfied of. The NPD provides additional detail around a number of these factors, such as the analysis of costs and benefits of a particular programme, and factors to be considered in decision making around the allocation of costs under a proposed programme. The factors outlined above will directly inform the evaluations required by the BSA and NPD for any proposed pest programme, and will be central to determining the most appropriate Programme, intermediate outcome and principal measures.

Determining which programme(s) and associated outcome(s) will apply within a particular region or part(s) of a region can only be determined at the regional level. For some regions, it may be appropriate to have more than one programme for wilding conifers, as the outcome sought may be different in different parts of the region. In other regions, it may be more appropriate to have a single, regionally applicable programme, but there may be different zones delineated, in which different short term objectives may apply, although collectively, all will contribute to the regional programme outcome. The most appropriate intermediate outcome(s) for a pest should be determined first, including the area to which the outcome(s) will apply (ie in all or just a part(s) of the region), and then the most efficient and effective principal measure(s) to achieve the outcome(s) would be developed.

In addition to the factors set out in the BSA and the NPD, consideration and assessment of pest-specific factors will also be necessary. One of the central pest-specific factors associated with wilding conifers is that conifers can be both a pest and a valuable resource, depending upon their location, management, and species. Another key factor is the complexity and equitability issues associated with the history and timing of wilding conifer infestation and sources. For example, many original wilding conifer sources are ‘legacy’ Crown plantings or historic shelter and amenity plantings; some wilding conifer sources have been legally established (under the RMA) with no legal obligation to manage wilding conifer spread; some areas of dense wilding conifer infestation is due to the actions/inactions of previous occupiers; and the extent and speed of wilding conifer spread is often strongly linked to land-use, meaning land-use change can have a significant impact (eg destocking and land ‘retirement’ can significantly increase the risk of wilding conifer spread, while intensification of land use may considerably reduce the risk of spread). These factors highlight the importance of ensuring that determinations regarding programmes and outcomes, principal measures, and where and how these will apply, are driven by spread risks, threats to values, and principles of fairness around where costs fall. It also means that in many regions, non-regulatory principal measures and local coordinated operational control plans and strategies will be central to the success of wilding conifer programmes, albeit supported by appropriate rules.

Where regional councils have comprehensive and accurate information about the state of wilding conifers within their regions this will assist in ensuring that programmes and outcomes can be established, and any necessary zones mapped, with a greater level of certainty about the appropriateness and reasonableness of the application of particular rules and/or other principal measures.


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NOTE: See Section 7 for an overarching objective recommended to be used in determining the need and value of a RPMP wilding conifer programme, and Section 8 for standardised wilding conifer programme objective statements, which may be used in meeting the requirements of the BSA and NPD, and in populating Section 6 of the RPMP Collective Project plan and proposed plan templates.


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5 Recommended Rules

Table 2 sets out a suite of recommended rules for use under wilding conifer programmes in RPMPs. The potential RPMP programme(s) considered most appropriate for each rule is indicated, as is any recommended narrative and/or explanatory notes to accompany the rule. Within the rules, parenthesis {} have been used to indicate where relevant regional or RPMP-specific wording should be used.

Table 2: Recommended Rules

Potential Programme Rule Recommended Narrative/Matters to Address in Narrative

Exclusion Programme

Eradication Programme

Exclusion/Eradication component of Progressive Containment Programme

Eradication programme may include Rules 1 & 2.

1 Occupiers within {specified area(s)/zone(s)} must notify the Council of the presence of any {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} on land that they occupy within X working days of the land occupier becoming aware of, or being advised of, the presence of {wilding conifers and/or Contorta pine…etc} on land that they occupy.

Note availability of exemptions under s78 BSA, eg -

A land occupier may make a written application for exemption to the rule or any part thereof, in accordance with section 78 of the Biosecurity Act 1993. An exemption may be granted provided that it will not significantly prejudice the attainment of the RPMP’s objectives, and may be available where –

- the requirement(s) of the rule have already been substantially complied with;

- action has been taken or provision has been made that is as effective or more effective than compliance;

- the requirement(s) of the rule is clearly unreasonable or inappropriate; or

- events have occurred that make the requirement(s) unnecessary or inappropriate.

2 Occupiers within {X region/specified area(s)/zone(s)} must destroy –

a) all {wilding conifers and/or Contorta pine…etc} of cone-bearing age present on land that they occupy {within 2/X years of this Plan becoming operative}; and

b) all {wilding conifers and/or Contorta pine…etc} present on land that they occupy that have not yet reached cone-bearing age before they do so.


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Exemptions may or may not be subject to conditions.

Progressive Containment Programme

Rule may apply:

a) region-wide if objective is to reduce regional geographic distribution;

b) to all areas outside a particular zone(s)/area(s) that seeking to reduce to/contain within; or

c) to a particular zone(s)/area(s) within which seeking to reduce geographic distribution/contain.

Note that where is a reduce objective for a) or c) should include a measure by which will be reduced (eg. By X% of

3A Occupiers within {X region/specified area(s)/zone(s)} must destroy all wilding conifers {and/or Contorta pine…etc} present on land that they occupy prior to cone-bearing, unless –

a) a property-specific Wilding Conifer Control Agreement that specifies a programme for the progressive removal of {wilding conifers and/or Contorta pine…etc} on the land over a prescribed time period has been signed and agreed between the occupier and the Council; or

b) the occupier has agreed in writing to participate in or contribute to, a Council-managed or endorsed Local Wilding Conifer Management Plan, Strategy or Programme that specifies a programme or management approach for the progressive removal and/or management of {wilding conifers and/or Contorta pine…etc} over a prescribed time period and over a defined geographical area that includes the land where the {wilding conifers and/or Contorta pine…etc} are located.

Note availability of exemptions under s78 BSA (see rule 1 narrative), followed by -

In considering an application for an exemption under s78 of the Biosecurity Act, the Council may consider an assessment of wilding conifer spread risk from the land where the {wilding conifers and/or Contorta pine…etc} are located, where the assessment has been undertaken by a suitably qualified or experienced person in accordance with a recognised methodology or calculator that takes account of at least the following factors –

A. the risk of seed dispersal due to species spreading vigour; and

B. the risk of seed dispersal due to the location and topography of the land where the {wilding conifers and/or Contorta pine…etc} are located; and

C. the nature and vulnerability to wilding conifer establishment, of surrounding land use and vegetation cover within 2 km of the land where the {wilding conifers and/or Contorta pine…etc} are located.

Where relevant, refer to the availability of property-specific Wilding Conifer Control Agreements and/or Local Wilding Conifer Management Plans, Strategies or Programmes. These references should include the


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current area/by X hectares etc)

*Potential interdependency with Rule 4, and/or with Rules 1 and/or 2 applying outside any containment and/or reduction zone/area.

following detail regarding what constitutes these instruments in order to ensure sufficient certainty:

For the purposes of clause a), a Wilding Conifer Control Agreement is a written agreement between a land occupier and the Council that includes (but is not limited to) the following information:

- the legal description of, and a map showing the location and extent of, the property to which the Agreement applies;

- the time period over which the Agreement applies; - detail of the location and extent of {wilding conifers

and/or Contorta pine…etc} on the property to which the Agreement applies;

- detail of the programme of {wilding conifer and/or Contorta pine…etc} removal that will be undertaken on the property over a prescribed time period (eg which areas of {wilding conifers and/or Contorta pine…etc} will be removed, when) and the programme of follow-up control of areas once {wilding conifers and/or Contorta pine…etc} are removed;

- the outcome that the Agreement aims to achieve within the period over which it applies.

For the purposes of clause b) a Local Wilding Conifer Management Plan, Strategy or Programme is a document that specifies a programme or strategic approach for the removal and/or management of


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{wilding conifers and/or Contorta pine…etc} over a defined geographical area that includes land under multiple ownership. The document will include (but is not limited to) the following information:

- a description and map showing the geographical area to which it applies;

- the time period over which it applies; - detail of the known location and extent of {wilding

conifers and/or Contorta pine…etc} within the area to which it applies;

- detail of the programme or strategic approach to be undertaken within the area to which it applies for the management of wilding conifers, including the location and timing of {wilding conifer and/or Contorta pine…etc and/or other planted conifer} removal;

- detail of any follow-up control programme, including timing and regularity; and

- the outcome that the Plan, Strategy or Programme aims to achieve.

Progressive Containment Programme

3B Occupiers must destroy all wilding conifers present on land that they occupy prior to cone-bearing, if –

a) the wilding conifers are located on land where control operations to clear {wilding conifers and/or Contorta pine…etc and/or any other planted conifers that were causing the spread of wilding conifers}, have been

Note availability of exemptions under s78 BSA (see rule 1 narrative).


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Sustained Control Programme

undertaken since the date that this Plan became operative; and

b) the control operations were partly or fully publicly funded.

Progressive Containment Programme (rule to apply within delineated containment zone, and potentially, within any reduction objective ‘sub-zone’ outside of containment zone)

Sustained Control Programme

4 Good Neighbour Rule.

Occupiers within {X region/specified area(s)/zone(s)} must, on receipt of a written direction from an Authorised Person, destroy all {wilding conifers and/or Contorta pine…etc} present on land that they occupy within 200 metres of an adjacent or nearby property prior to cone-bearing, if the occupier of the adjacent or nearby land is –

(i) subject to Rule {1, 2, 3A or 3B}; or (ii) taking reasonable measures to control {wilding

conifers and/or Contorta pine…etc} on the adjacent or nearby land.


Clarify that enforcement will be on a complaints basis, eg:

The rule will be administered by the Council and any action pertaining to non-compliance will only be initiated upon the receipt of a written complaint from an adjacent or nearby land occupier.

Note that the Council encourages and will support parties to establish alternative agreements that achieve the intent of the rule in the most practical and cost-effective manner for the parties concerned.

Add reference to the type of things that constitute ‘reasonable measures’ as per NPD Guidance Material, Part 2, especially cl 205 and 206.


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Site Led Programme 5 Good Neighbour Rule.

Occupiers must , on receipt of a written direction from an Authorised Person, destroy all {wilding conifers and/or Contorta pine…etc} present on land that they occupy within 200m of any site {listed in X/described at X/that meets the criteria set out at X} prior to cone-bearing, if the site is on land occupied by a different land occupier, and that land occupier is taking reasonable measures to control {wilding conifers and/or Contorta pine…etc} within and/or adjacent to the site.


Clarify that enforcement will be on a complaints basis (see rule 4 narrative).

Note Council encouragement and support for alternative agreements (see rule 4 narrative).

Add reference to the type of things that constitute ‘reasonable measures’ as per NPD Guidance Material, Part 2, especially cl 205 and 206.

Site Led Programme 6 Occupiers must destroy all {wilding conifers and/or Contorta pine…etc} present on land that they occupy within 200m of any site {listed in X/described at X/that meets the criteria set out at X} prior to cone-bearing, if –

a) control operations to clear {wilding conifers and/or Contorta pine…etc and/or any other planted conifers that were causing the spread of wilding conifers}, from within and/or adjacent to the site, have been undertaken since the date that this Plan became operative; and

b) the control operations were partly or fully publicly funded.


Type Branch here.

Type Directorate here.

Pastoral House, 25 The Terrace

Wellington 6011, New Zealand

PO Box 2526

Wellington 6140, New Zealand

Telephone: 0800 00 83 33, Facsimile: +64-4-894 0300

www.mpi.govt.nz


NOTE: See Section 9 for standardised statements of intent for the template rules set out in Table 2 above, which may be used in meeting the requirements of the BSA, and in populating Section 6 of the RPMP Collective Project plan and proposed plan templates.

Rules 1 and 2

Rules 1 and 2 represent two different options for use in an area subject to an Exclusion or Eradication Programme, or for use in what is effectively an exclusion or eradication ‘zone’ within a wider Progressive Containment Programme.

Either rule could potentially apply as a default rule across a region/part(s) of a region where wilding conifers are not a significant problem, but there may be some scattered trees; or could potentially apply in areas currently clear of wilding conifers. This type of rule will be important for parts of a region that are currently clear, but highly susceptible to wilding conifer spread if a seed source becomes established. Although the majority of wilding conifer spread is predictable, a characteristic of spread (particularly in highly susceptible areas) is also the occurrence of random, irregular long distance spread into areas previously unaffected. These rules provide an early intervention trigger for these vulnerable or susceptible areas.

Rule 2 is only likely to be appropriate in parts of a region where the Council can be reasonably confident that the costs of any required control are reasonably able to be met by occupiers. This highlights the importance of good mapping, spread-risk assessments, and knowledge of the state of wilding conifers within the region/area to which the rule applies. It will also be important to note that exemptions may be granted, given that there may be specific sites or areas of wilding conifers that were not known about, in relation to which the rule may impose unreasonable costs.

Exemptions are available under section 78 of the BSA. The availability of exemptions assists in enabling the development of less complex, regionally-applicable rules that may not address every specific situation. Provided the granting of an exemption will not significantly prejudice achievement of the RPMP’s objectives, they may be available where an alternative approach to the rule requirement that is as or more effective is proposed, or the rule requirement is unreasonable or inappropriate in the particular case.

If either of Rules 1 or 2 are used as part of a stand-alone Eradication or Exclusion Programme, it will be important to assess the feasibility of achieving the outcomes for such programmes. Central to this will be the effective control/management of any predictable seed sources, so that regular re-infestation is unlikely. If this is not feasible, it may be more appropriate to apply these rules as part of a wider Progressive Containment Programme.

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It is estimated that currently 1.7 million hectares of New Zealand land are affected to some extent by wilding conifers, and even with existing control efforts, wilding conifers are spreading in area by around 6% per year10. At this rate it has been predicted that by 2035 the area of land affected by wilding conifers (at various densities) will have increased to 5.4 million hectares11. Successfully preventing this extent of wilding conifer spread will require a range of initiatives, but incorporating rules into RPMPs that aim to keep clear areas clear, such as Rules 1 and 2, will be an important one.

Rule 3A

This rule is designed to apply in parts of a region where eradication is not a feasible outcome, at least in the short-medium term, but where a reduction in the geographic distribution of wilding conifers within a delineated zone down to the most densely infested areas is feasible. This might apply to a zone within a wider Progressive Containment Programme, which is essentially a buffer zone, at the outer edge of the area(s) to which it is intended wilding conifers will, over time, be contained. The rule also seeks to achieve early intervention in areas where wilding conifers are not yet at high densities, in order to reduce the potential long-term costs of control.

Good mapping and/or knowledge of areas where control of wilding conifers is feasible and reasonable will be important, although the exclusion where an alternative property-specific control programme is agreed has been included partly to address situations where the rule would create an unreasonable obligation due to the extent and/or density of wildings on a particular property. In addition, an exemption may be available if an occupier can demonstrate that there is a low risk of spread of wilding conifers from their property.

Given that the areas where this rule is most likely to be relevant are also the areas where the most cost-efficient gains in wilding conifer management are able to be made (controlling outliers and areas of low-density spread), it is important that the flexibility is built in for the Council to work with occupiers on the development of property-specific plans, and/or local wilding conifer management plans and strategies that take a coordinated approach to wilding conifer control across a larger area in multiple ownerships, as these may often offer a more cost-effective approach.

Note that if rule 3A is used, it will be important that rule 4 applies in any adjoining zone/area where wilding conifers are present but neither rules 1, 2 or 3A apply, to ensure that wilding conifer spread from there, does not create an unreasonable cost on occupiers subject to rule 3A.

Rule 3B

The intent of this rule is to provide a level of ‘protection’ for public investment made via partly or fully publicly funded wilding conifer control operations, by transferring responsibility for maintaining the area clear of wilding conifers to the occupier following the control operations. In

10 The right tree in the right place: New Zealand Wilding Conifer Management Strategy 2015-2030, December 2014, pp.9-11 http://www.wildingconifers.org.nz/images/stories/wilding/Articles/2014_new_zealand_wilding_conifer_management_strategy_2.pdf 11 Cost benefit analysis of wilding conifer management in New Zealand Part 1 – Impacts under current management, SCION, March 2015, p20.



23

some regions, this rule may be more appropriate than rule 3A, or, depending upon the specificity of mapping and zoning used, may potentially apply in addition to 3A.

The process of transferring responsibility for ‘maintenance’ wilding conifer control back to occupiers does not always result in effective or cost-efficient ongoing control, particularly where the land in question is steep, extensive, and difficult to access. Therefore, it is recommended that Councils using this rule consider utilising alternative approaches to the implementation and funding of the rule, such as a targeted rate to fund regular maintenance control over a number of properties in an area, coordinated by the Council, rather than each occupier undertaking control in an ad hoc manner.

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Rule 4

The intent of this rule is to manage the impact of wilding conifer spread between properties to avoid the imposition of unreasonable costs on occupiers ‘receiving’ wilding conifer spread. It is intended to be a Good Neighbour Rule (GNR), meaning that the rule applies to all land occupiers, including the Crown.

There are a number of requirements that apply to GNRs in addition to the wider BSA requirements for all RPMP rules. These requirements arise from the BSA definition for GNRs (s2) and Clause 8 of the NPD which sets out specific directions and requirements that regional councils must comply and be satisfied with, before identifying a rule as a GNR. In summary, these requirements include:

- the pest must be present on the obligated occupier’s land

- in the absence of the rule the pest would have spread to adjacent or nearby land AND caused

unreasonable costs to the occupier of that land (Note: costs are not limited to financial costs)

- the obligation imposed must be no greater than that required to manage the spread of the pest,

and the costs of compliance must be ‘reasonable’ relative to the costs the occupier of the adjacent

or nearby land would incur from the pest spreading in the absence of the rule

- the occupier of the adjacent or nearby land must be taking reasonable measures to protect

themselves from the pest or its impacts. ‘Taking reasonable measures’ might include:

o where the pest is not present on the neighbour’s land, regular monitoring adequate for

detecting the pest and the intent and ability to control the pest if detected; or

o where the pest is present, the occupier should be managing its impacts and what is

reasonable will depend on the uses and values of the land.

One of the issues with GNRs that apply at the regional scale, is that there are ‘reasonableness’ factors that have to be built into the rule, but which are best determined on a site specific basis. Consequently, it will be important that this rule is accompanied by clear explanatory notes regarding the proposed operational implementation of the rule. In particular, clarifying that implementation will be on a complaints basis, and that Council encourages, and will support parties to establish alternative agreements that achieve the intent of the rule in the most practical and cost-effective manner for the parties concerned.

The proposed 200m setback is based on consideration of the most common spread characteristics of conifers (wind borne and gravity seed dispersal) and the distance within which the majority of seed dispersal occurs, even though it is possible, under certain conditions, for conifer seed to be dispersed over much greater distances12 (also see Attachment 1 for further information). In addition, when consideration is given to the various conditions that must be satisfied for a GNR (set out above), these become potentially more difficult to satisfy with a greater setback distance.

12 Ledgard, N.J. 2004: Wilding conifers – New Zealand history and research background. In Hill, R.l.; Zydenbos, S.M.; Bezar, C.M.

(Eds) “Managing wilding conifers in New Zealand – present and future”. Proceedings of a workshop held in conjunction with the annual general meeting of the NZ Plant Protection Society in Christchurch on August 11, 2003. ISBN 0-478-10842-7 Published by NZPPS: 1-25

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Rules 5 and 6

These rules have been developed for application under a Site Led Programme. Rule 5 is similar to rule 4, in that it is intended to be a GNR that will bind all land occupiers, including the Crown. Similarly, explanatory notes regarding implementation on a complaints basis and encouragement of alternative agreements where practical, should be included.

Similar to rule 3B, rule 6 is designed to be triggered when a publicly funded control operation is undertaken at a particular site, to provide a degree of ‘protection’ of the investment that has been made.

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Additional Supporting Material

6 Standardised Description of Adverse Effects of Wilding

Conifers

Wilding conifers can have significant impacts on native ecosystems, particularly those with low-stature vegetation13. Wilding conifers grow faster and taller than low-stature native plants and so can shade out many of these species. Where there is dense wilding conifer growth, this can lead to local extinction of native plant communities, the drying of wetlands and riparian areas, and resulting impacts on native fauna through the loss of habitat. Soil and soil fauna are also altered when wilding conifers replace native ecosystems.

Most wilding conifer species do not pose a significant threat to established native forests, however Douglas fir has a higher shade tolerance than other introduced conifer species and consequently wilding Douglas fir is able to spread into shrublands, regenerating native forest and mature forest where there are canopy gaps and a relatively sparse understory.

Wilding conifers can affect amenity and landscape values, particularly where the valued landscapes are characterised by extensive low-stature vegetation {eg. South Island high country tussock grasslands, Central North Island volcanic plateau Insert/replace with locally relevant examples}. In some instances these landscapes are important for tourism and large-scale landscape changes could impact on this. Dense wilding conifer spread can lead to the blocking and/or changing of valued views and vistas, and can impede access to, and enjoyment of, recreational areas.

In areas where there is long-term, seasonal soil moisture deficits, dense wilding conifers can contribute to reductions in surface water flows, potentially impacting on water availability and aquatic ecosystems. Wilding conifers can also increase the risk posed by wild fires.

The impacts outlined above can adversely affect Māori cultural values in some locations through: physical changes to culturally important landscapes, sites and landforms; impacts on mahinga kai; and impacts on the mauri of streams and wetlands.

In areas of extensive pastoral farming, wilding conifer infestations reduce available grazing land and limit future land use options due to the high costs of control.

Sources:

Wilding Conifers in New Zealand: Beyond the status report, December 2011 V A Froude, Pacific Eco-Logic Ltd Wilding Conifers in New Zealand: Status report, December 2011 V A Froude, Pacific Eco-Logic Ltd

13 Indigenous ecosystems at particular risk from wilding conifer invasion include: tussock and other indigenous grasslands, alpine ecosystems, subalpine and dryland scrub and shrublands, frost-flats, wetlands, turf communities, geothermal areas, dunelands, ultramafic/serpentine areas, rockfields and herbfields, riparian areas, coastal margins, bluffs and cliffs.

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The right tree in the right place – New Zealand Wilding Conifer Management Strategy 2015-2030, December 2014 Ministry for Primary Industries

28

7 Overarching Objective

It is important that determining which programme(s) and associate d outcome(s) would most appropriately apply to wilding conifers within a particular region occurs at the regional level. However, following feedback on the draft Wilding Conifer RPMP Rule Development Project (the Project) material, consideration has been given to establishing a common overarching outcome or objective for wilding conifers. This would not only strengthen the consistency being promoted through the Project, but would provide a common basis against which regions could assess the need and value of including wilding conifers in their RPMPs.

Any such objective would be longer-term, and would need to be able to apply at both a regional and a national level. Although it is anticipated that it could be included as a long-term objective in RPMP wilding conifer programmes, it is important to recognise that the overarching objective would not necessarily be RPMP-specific. This recognises that although RPMP wilding conifer programmes will be important contributors, achieving the objective will also be reliant on a range of other regulatory and non-regulatory initiatives led and/or contributed to by local, regional and central government, industry, land owners and occupiers, communities and voluntary organisations.

The NZ Wilding Conifer Management Strategy was recently developed through a collaborative, multi-stakeholder process. The Strategy establishes a Vision for wilding conifer management in New Zealand and within this Vision is a clear Aim, which could apply equally at the national and regional level. Consequently, it is recommended that this Aim provides a relevant and appropriate objective to support the Project material.

The overarching objective for wilding conifers recommended to be used in determining the need and value of a RPMP wilding conifer programme is:

To prevent the spread of wilding conifers, and to contain or eradicate, established areas of wilding conifers by 2030.

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8 Standardised Wilding Conifer Programme Objective

Statements

The NPD requires that for each subject in a pest management plan, the objective must: - State the particular adverse effect(s) on s54(a) matters that the Plan addresses

- State the intermediate outcome (being one of the 5 specified in clause 4(1)(b) of the NPD)

- State the geographic area to which the outcome applies (or, for site led, description of the place or

criteria for defining the place)

- State the extent to which the outcome will be achieved (if applicable)

- State the period within which the outcome is expected to be achieved

Exclusion Programme Objective:

Over the duration of the Plan, prevent the establishment of {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch14} within the {X region/specified area or zone}, in order to {prevent/reduce15} the adverse effects of wilding conifers on pastoral production, indigenous biodiversity, cultural and landscape values in the {X region}.

Eradication Programme Objective:

{By X date/Over prescribed timeframe16}, reduce the infestation level of all {wilding conifer and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} infestations to zero levels within the {X region/specified area or zone}, in order to {eliminate/reduce17} the adverse effects of wilding conifers on pastoral production, indigenous biodiversity, cultural and landscape values in the {X region}.

Progressive Containment Programme Objective:

Over {the duration of the Plan/an alternative prescribed timeframe}, to {contain/reduce} the geographic distribution of {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} {to specified area(s) or zone(s) / to X % of their current area/density (as at X date) / by X% within X region/specified area(s) or zone(s)} in order to reduce the adverse effects of wilding conifers on pastoral production, indigenous biodiversity, cultural and landscape values in the {X region}.

Sustained Control Programme Objective:

Over {the duration of the Plan/an alternative prescribed timeframe}, to provide for ongoing control of {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} within {the X region/specified area(s) or zone(s)} in order to reduce the spread

14 Note: these are the conifer species recommended to be declared as pests in the Wilding Conifer RPMP Rules and Guidelines material. Please refer to that material for further clarification. 15 Prevent if exclusion objective applies region-wide; reduce if exclusion objective only applies to a specified area within the wider region. 16 Must be ‘short to medium term’, as per NPD – could potentially be ‘Over the duration of the Plan if Plan duration is no more than 10 years, provided 10 years is considered ‘medium term’. 17 Eliminate if eradication objective applies region-wide; reduce if only applies to a specified area.

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of wilding conifers to other properties and to reduce the adverse effects of wilding conifers on pastoral production, indigenous biodiversity, cultural and landscape values in the {X region}.

31

Site Led Pest Programme Objective:

Over {the duration of the Plan/an alternative prescribed timeframe}, to {exclude/eradicate} {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} from sites that {are listed in X/are described at X/meet the criteria set out at X}, in order to prevent the adverse effects of wilding conifers on the {pastoral production and/or indigenous biodiversity and/or cultural and/or landscape and/or amenity} values of those sites.

OR

Over {the duration of the Plan/an alternative prescribed timeframe}, to {contain/reduce/control} the extent and/or density of {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} within sites that {are listed in X/are described at X/meet the criteria set out at X} in order to reduce or prevent the adverse effects of wilding conifers on the {pastoral production and/or indigenous biodiversity and/or cultural and/or landscape and/or amenity} values of those sites to the extent that the values of the sites are protected.

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9 Standardised Statements of Intent for Wilding Conifer Rules

Rule 1 Statement of Intent:

Over the duration of the Plan to ensure that any {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} within the {X region/ specified area or zone} are identified and destroyed prior to cone-bearing, using appropriate and timely methods.


To ensure that any existing {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} within the {X region/specified area or zone} are destroyed within two years, and that over the remaining duration of the Plan, any wilding conifer seedlings subsequently appearing are destroyed prior to cone-bearing.

Rule 3A Statement of Intent:

Over the duration of the Plan, to ensure that any {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} {within X region /specified area(s)/zone(s)} are destroyed prior to the next cone-bearing season (for mature trees) or the first cone-bearing season (for immature trees), and to provide for an alternative, localised approach to {wilding conifer and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch} control where appropriate and practicable through formal, specific Wilding Conifer Control Agreements and Local Wilding Conifer Management Plans, Strategies or Programmes.

Rule 3B Statement of Intent:

Over the duration of the Plan, to ensure that new infestations of wilding conifers are prevented at sites where publicly funded operations to remove {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch and/or any other planted conifer species} on private land have occurred.


Over the duration of the Plan, to ensure that the spread of wilding conifers to adjacent or nearby properties, where the occupier is taking reasonable steps to control wilding conifers, does not cause unreasonable costs (either monetary or non-monetary) to that occupier. As a Good Neighbour Rule, this Rule is intended to apply to all land occupiers, including the Crown.


Over the duration of the Plan, to ensure that the spread of wilding conifers to sites that {are listed in X/are described at X/meet the criteria set out at X}, are on land occupied by a different occupier, and where that occupier is taking reasonable steps to control wilding conifers within the site, does not cause unreasonable costs (either monetary or non-monetary) to that occupier. As a Good Neighbour Rule, this Rule is intended to apply to all land occupiers, including the Crown.


Over the duration of the Plan, to ensure that the spread of wilding conifers to sites that {are listed in X/are described at X/meet the criteria set out at X}, and where publicly funded operations to remove {wilding conifers and/or Contorta pine, Scots pine, Dwarf mountain pine, Mountain pine or European larch and/or any other planted conifer species} have occurred, does not lead to new infestations of wilding conifers within the sites.

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Appendix 1: Information Sources for Rules 4 – 6 Distances

1. From: Ledgard, N.J. 2004: Wilding conifers – New Zealand history and research background. In Hill, R.l.;

Zydenbos, S.M.; Bezar, C.M. (Eds) “Managing wilding conifers in New Zealand – present and future”.

Proceedings of a workshop held in conjunction with the annual general meeting of the NZ Plant

Protection Society in Christchurch on August 11, 2003. ISBN 0-478-10842-7 Published by NZPPS: 1-25

The major dissemination agent for conifer seed in New Zealand is wind. Field evidence indicates considerable differences between species in the distances seed can be carried. A pilot trial involving eight conifer species, in which the dispersal distance of winged seed was compared after dropping through a fixed-speed airflow, indicated that seed wing loading, or mass unit per wing area, was more closely related to distance of dispersal than seed weight alone (Ledgard, unpublished data)… contorta pine had the lightest seed and seed wing loading, and was dispersed furthest (along with Douglas fir), while ponderosa pine had the heaviest seed.

2. From: Ledgard, N.J. & Langer, E.R. 1999: Wilding Prevention guidelines. ISBN 0-477-02186-7 Published

by Forest Research.

Most wildings grow close to the parent seed source and are termed ‘fringe spread’. Wildings further afield are termed ‘distant spread’. They grow from seed often sourced from take-off sites and usually occur as scattered outlier trees.

‘Fringe spread’ – from 1m to 200m, usually dense (where most seed falls)

3. Wilding Conifer Spread Risk Calculator requires scoring for downwind land management within 200m

AND within 200-400m OR if 3 or 4 scored in ‘3.Siting’, score out to 2km.

4. DSS1 Calculating Wilding Spread Risk from New Plantings

‘Long distance spread’ – is quite possible if a score of 3 or 4 is scored in ‘3.Siting’, especially if Douglas fir, Larch or Corsican, Contorta, Mountain or Scots pine are involved (all have light seed which is readily dispersed greater distances by wind). In these circumstances the risk of spread relative to ‘4.Grazing’ and ‘5.Vegetation cover’ needs to be scored out to beyond the ‘fringe’ area, to a distance of 2km (‘Fringe’ infers a distance from seed source of 1-200m).

5. DSS2 Calculating Risk of Wilding Tree Spread Into/Within New Sites

‘Long distance spread’ – is likely if a score of 3 or 4 in ‘3.Siting’ is followed by a 2 or greater in ‘5.Grazing’ and ‘6.Vegetation’, especially if Douglas fir, Larch or Corsican, Contorta, Mountain or Scots pine are involved (all have light seed which is readily dispersed greater distances by wind). In these circumstances, the risk of spread may need to be considered out beyond 5km.

Appendix 2

#102 Feline Rights – supporting documents

Journal of AnimalEcology 0888\57\ 171Ð181

Þ 0888 BritishEcological Society

171

Cats protecting birds] modelling the mesopredator

release effect

FRANCK COURCHAMP�\ MICHEL LANGLAIS$ andGEORGE SUGIHARA��Scripps Institution of Oceanography\ University of California San Diego\ 8499 Gilman Drive Ð La Jolla\ CA81982Ð9191\ USA^ and $ERS CNRS 012 {Mathe�matiques Applique�es de Bordeaux|\ Universite� Victor SegalenBordeaux 1\ 035 rue Le�o Saignat\ F!22965 Bordeaux Ce�dex\ France

Summary

0[ Introduced predators account for a large part of the extinction of endemic insularspecies\ which constitutes a major component of the loss of biodiversity amongvertebrates[ Eradication of alien predators from these ecosystems is often consideredthe best solution[1[ In some ecosystems\ however\ it can generate a greater threat for endemic preythrough what is called the {mesopredator release|[ This process predicts that\ oncesuperpredators are suppressed\ a burst of mesopredators may follow which leads theirshared prey to extinction[2[ This process is studied through a mathematical model describing a three speciessystem "preyÐmesopredatorÐsuperpredator#[ Analysis of the model\ with and withoutcontrol of meso! and superpredators\ shows that this process does indeed exist andcan drive shared prey to rapid extinction[3[ This work emphasizes that\ although counter!intuitive\ eradication of introducedsuperpredators\ such as feral domestic cats\ is not always the best solution to protectendemic prey when introduced mesopredators\ such as rats\ are also present[

Key!words] bird conservation\ feral cats\ introduced mammals\ control strategy\ rats[

Journal of Animal Ecology "0888# 57\ 171Ð181

Introduction

Most contemporary worldwide extinctions haveoccurred\ or are currently occurring in island eco!systems[ As an example\ of the 29 species of reptilesand amphibians that have gone extinct since 0599\more than 89) are island forms "Honnegger 0870#^82) of 065 species or subspecies of birds "King 0874#\and 70) of 54 mammal species extinctions "Ceballos+ Brown 0884# that have occurred during this periodhave occurred on islands[

The introduction of vertebrate species is one of themost important threats to many endemic species inmany islands "Moors + Atkinson 0873^ Atkinson0878#[ Numerous rare or endemic vertebrate speciesare currently endangered because of predation byintroduced invertebrates\ reptiles\ birds or mammals\

Correspondence] Franck Courchamp\ Department ofZoology\ University of Cambridge\ Downing Street\ Cam!bridge\ CB1 2EJ\ UK[ E!mail fc108Ýcam[ac[uk[ Tel] 90112!225532[ Fax] 90112!225565[

or by competition from or habitat destruction byintroduced grazers such as rabbits "Oryctolagus cun!iculus\ Lilljeborg# or goats "Capra hircus\ L[# "Moors+ Atkinson 0873^ Atkinson 0878^ Williamson 0885#[According to King "0874#\ predation by introducedanimals has been a major cause of 31) of islandbird extinctions in the past\ and is a major factorendangering 39) of currently threatened island birdspecies[ In particular\ introduced feral cats "Feliscatus\ L[# are known to be a major threat to manyisland bird species[ They are known to have beenintroduced into at least 54 island groups where theyare responsible for the loss of many large land andseabird colonies\ populations or even species "e[g[ Jou!ventin et al[ 0873^ Rodriguez!Estrella et al[ 0880^ Mon!teiro\ Ramos + Furness 0885#^ for example\ a fewcats "around _ve# were introduced to the KerguelenIslands in the mid!century[ They are now responsiblefor the decline or extinction of several bird popu!lations in these islands\ killing more than 2 millionpetrels per year "Chapuis 0884#[ Cats also constitutea major threat to many endemic reptile species or

172

F[ Courchamp\M[ Langlais +G[ Sugihara

Þ 0888 BritishEcological SocietyJournal of AnimalEcology\ 57\ 171Ð181

subspecies "e[g[ Iverson 0867^ Case + Bolger 0880^Arnaud et al[ 0882# and mammals "Spencer 0880^ Mel!link 0881#[ Their impact has also been demonstratedthrough competition towards endemic mammalianpredators such as island foxes "e[g[ Urocyon littoralisdickeyi\ Baird#\ which they replace when uncontrolled"Steve Kovach\ personal communication#[

Eradication of those alien cat populations isrequired in many cases\ has often been tried\ some!times achieved "Rauzon 0874^ Veitch 0874^ Domm+ Messersmith 0889^ Cooper 0884# and several cateradication programmes are currently underway[Paradoxically\ in some particular situations\ the pres!ence of a controlled population of cats might be\ atleast temporarily\ more bene_cial to their endemicprey than its eradication[ Such is the case on manyislands where rodents have also been introduced[

Indeed\ it has been shown that the di}erent speciesof introduced rats "Kiore or Polynesian or Paci_c ratRattus exulans\ F[\ Black or Roof or Ship rat\R[ rattus\ F[ and Brown or Norwegian rat R[ nor!vegicus\ F[# have an extremely deleterious e}ect onnumerous species of amphibians "e[g[ Thurley + Ben0883^ Towns + Daugherty 0883#\ reptiles "e[g[ Mac!Callum 0875^ Newman + McFadden 0889^ Case\Bolger + Richman 0881^ Cree\ Daugherty + Hay0884#\ birds "e[g[ Atkinson 0874^ Konecny 0876^Bertram + Nagorsen 0884# and even mammals "e[g[Brosset 0852^ Bell 0867^ Atkinson 0874#[ This e}ectcan be indirect\ such as through competition for shel!ter\ nest!sites "Seto + Conant 0885# or food\ as thediet of rats comprises mainly berries\ leaves\ seeds andinvertebrates "Clark 0879\ 0870#[ Rats can also havea direct e}ect\ through predation[ Indeed\ these threeintroduced species of rat are known to prey on eggs\chicks\ juveniles and even adults of ground!nestingseabirds and land birds "e[g[ Kepler 0856^ Bertram0884^ Brooke 0884^ Lovegrove 0885# and even tree!nesting birds "e[g[ Campbell 0880^ Seitre + Seitre 0881^Amarasekare 0882#[ In total\ R[ exulans predation isdocumented on at least 04 di}erent bird species\R[ rattus predation on at least 28 bird species\ andR[ norvegicus on at least 42 bird species "for a review\see Atkinson 0874#[ Not only do rats have a potentialimpact on numerous species throughout the world"they are known to have colonized at least 71) of the012 major island groups\ Atkinson 0874#\ but theysometimes cause extremely rapid extinctions on newlycolonized islands[ A well!known example is the estab!lishment around 0853 of black rats on Big South CapeIsland\ New Zealand\ causing the local loss of threeNew Zealand endemic birds\ and the complete extinc!tion of two more\ and of one species of bat\ in lessthan 1 years "Bell 0867#[ Introduced house mice "Musmusculus\ L[# also have a potential negative impact onvertebrate species\ by competition or direct predation"e[g[ Moors + Atkinson 0873^ Johnstone 0874^ New!man 0883#[

The domestic cat is an opportunist predator "Fitz!

gerald 0877#[ When both bird and mammal prey areavailable\ it is believed that the domestic cat diet willinclude mainly mammals "e[g[ Konecny 0876^ Nogaleset al[ 0881^ Nogales + Medina 0885#[ In some islandecosystems\ these cats maintain rodent populationsat low levels[ Although they also often prey uponendangered species\ it is believed that\ in some eco!systems at least\ the bene_cial e}ects of reducing therodent population could outweigh the damage doneto the endemic prey species "Fitzgerald et al[ 0880^Tidemann\ Yorkston + Russack 0883#[ The threatposed by introduced cats to the kakapo "Strigops hab!roptilus\ Gray# on Stewart Island is a striking example[Here\ cats prey lightly on this highly endangered birdspecies "remains were found in 4=0) of 007 collectedscats\ Karl + Best 0871#\ but even low predation pres!sure may be detrimental for fragile species "Rod!riguez!Estrella et al[ 0880#[ However\ rat remains werefound in 82=9) of these 007 scats "Karl + Best 0871#\showing the indirect role cats might play in preservingnative fauna through reduction of rat predation pres!sure on the kakapo[ Moreover\ the elimination of feralcat populations from such ecosystems could lead to amore severe negative impact on the endemic species\as a result of expansion of rodent populations oncetheir predators are removed[ Attempted reduction ofthe cat population of Amsterdam Island is alleged tohave caused a compensating rise in the number of ratsand mice\ and so has been abandoned "Holdgate +Wace 0850#[ This process\ termed {mesopredatorrelease|\ had been described in fragmented insular eco!systems "Soule� et al[ 0877# and applies well to manyinsular foodwebs "e[g[ Schoener + Spiller 0876#[ Con!versely\ the eradication of rodents _rst "which hasnow proven feasible\ even on relatively large islands\Taylor + Thomas 0878\ 0882^ Towns 0885# mightinduce cats to switch prey\ resulting in a brutalincrease in predation pressure on the threatenedendemic species\ as experienced for stoats and rats inNew Zealand "Murphy + Brad_eld 0881#[ Unfor!tunately "from the theoretical point of view#\ there islittle _eld evidence from island management either ofmesopredator release following superpredator eradi!cation\ or of predators switching prey following meso!predator eradication[

As the optimal control strategy is neither simple to_nd nor intuitive\ it is studied through the analysis ofa mathematical model which mimics the dynamics ofthe three species in this system[ In the study reportedhere\ the interactions of a prey species\ such as a birdspecies\ a threatening alien mesopredator\ such as arat\ and an alien superpredator species\ such as theferal domestic cat\ were examined through theircoupled dynamics[ Through this model\ the theor!etical existence of {mesopredator release| and the e}ectof the presence of a superpredator on the prey will beinvestigated[ It is assumed that the superpredatorpreys both upon the prey and the mesopredator[ Forthe sake of simplicity\ reference will sometimes be

173

Mesopredatorrelease in insularecosystems


made to them as bird\ rat and cat\ instead of prey\mesopredator and superpredator\ respectively[

The models

THE PRELIMINARY MODELS

For the sake of simplicity\ models are _rst presentedtaking into account only two species\ and only then isthe third species added and its implied complicationsanalysed[ The construction and analysis of the modelsare based on previous work "Courchamp + Sugihara0888#\ to which the reader can refer for additionaldetails[ The _rst two systems consist of two simplecoupled di}erential equations\ each representing thedynamics of one population[ Each population isdescribed by a simple logistic equation\ modi_ed totake into account its relationship with the other spec!ies[ The other possible prey species populations arenot taken into account^ it is assumed that all the preyspecies form a single {bird| population\ with averagecharacteristics[ The realism of these assumptions hasbeen discussed previously "Courchamp + Sugihara0888#[ The number of individuals at time t in the prey\mesopredator and superpredator populations are B\R and C\ respectively[ The intrinsic growth rates ofthe prey\ mesopredator and superpredator popu!lations are rb\ rr and rc\ respectively[ The predationrate of the superpredator is mb on the prey and mr onthe mesopredator[ The predation rate of the meso!predator is hb on the prey and hs on other food items"seeds\ leaves\ invertebrates#[ The carrying capacity ofthe environment for the prey population is Kb[ Thecarrying capacities of the environment for the meso!predator and the superpredator populations are notconstants\ but depend partially "rats are omnivores# ortotally "cats are carnivores# on the number of availableindividual prey on which their populations can feedat time t[ For the mesopredator\ the carrying capacityof the environment is the number of mesopredatorsthat can live on food other than birds when there isno prey\ to which is added the number of meso!predators that can be fed by the total of available preyat time t[ The carrying capacity is thus the quantity ofnon!avian food S divided by the consumption rate hs\plus the number of prey B divided by the meso!predator predation rate hb] S:hs ¦ B:hb\ that is"hbS ¦ hsB#:hbhs[ For the sake of simplicity\ it isassumed that S is a constant "the carrying capacity inthe absence of prey is kept under the form S:hs insteadof a constant\ say Ks\ to conserve homogeneousnotation#[ Rats are opportunistic predators\ and theirdiet "proportion of avian and non!avian food con!sumed# depends on relative availability of food items"Clark 0879#[ Accordingly\ instead of hbR\ the pre!dation rate of rats on birds is] BhbR:"S¦B#[ In thetwo!species models\ the rat:cat system is notpresented\ because it is the same as the bird:cat system[

The prey:mesopredator "bird:rat# system is givenby]

F

G

j

J

G

f

dBdt

� rbB00 −BKb1−

BS ¦B

hbR eqn 0

dRdt

� rrR00 −hbhsR

hbS ¦ hsB1 eqn 1

There are several equilibrium points[ The _rst twoequilibrium states\ extinction of both populations ð9\9Ł and extinction of the rat only ðKb\ 9Ł are alwaysunstable[ The third state\ extinction of the bird only\"9\ S:hs# is globally asymptotically stable if and onlyif rb ¾ hb:hs[ These three points always exist[ Whenboth populations coexist\ the system reaches "B�\S:hs ¦ B�:hb#[ B� is given in the Appendix with theanalysis of the system[

The prey:superpredator "bird:cat# system is givenby]

F

G

j

J

G

f

dBdt

� rbB00 −BKb1− mbC eqn 2

dCdt

� rcC00 −mbCB 1 eqn 3

It is the same for the mesopredator:superpredator"rat:cat# system "B is replaced by R and b indices arereplaced by r indices#[ They have three stable equi!librium points only\ as the predator cannot survivealone] ð9\ 9Ł\ ðKb\ 9Ł and ðKb"0 − 0:rb#\Kb"0 − 0:rb#:mbŁ[

THE COMPLETE MODEL

To take the three species into account simultaneously\one needs to make further assumptions[ First of all\like the rat\ the domestic cat is an opportunist pred!ator\ which switches prey species according to theiravailability "Fitzgerald 0877#[ Accordingly\ the num!ber of birds and rats preyed upon by cats will dependon their respective numbers[ Instead of mbC and mrC\one will _nd] mbBC:"B¦R# and mrRC:"B¦R# for thebird and the rat populations\ respectively[ Potentialpreferences of the cat for the indigenous prey over theintroduced predator are not taken into account "seeCourchamp\ Langlais + Sugihara\ in press#[ The catcarrying capacity is] B:mb ¦ R:mr[ The compartmentalrepresentation of the model is given in Fig[ 0[

One has the following system]

F

G

G

G

G

G

G

g

G

G

G

G

G

G

f

dBdt


BS ¦B

hbR −B

B ¦ RmbC

eqn 4

dRdt

� rrR00 −hbhsR

hbS ¦ hsB1−R

B ¦ RmrC

eqn 5

dCdt

� rcC00 −mbmrC

mrB ¦ mbR1eqn 6

174



Fig[ 0[ Compartmental representation of the mathematical model with three species "eqns 6\ 7\ 8#[ Each box represents onepopulation\ symbolized by a letter and an animal] superpredator "C\ cats#\ mesopredator "R\ rats# and prey "B\ birds#[ Thearrows represent the ~ux within and are between compartments] curved arrows are intrinsic growth rates^ straight arrows arepredation rates[ The intrinsic growth rates of the superpredator\ the mesopredator and the prey are rc\ rr and rb\ respectively[The predation rates of the superpredator on the mesopredator and on the prey are mr and mb\ respectively^ the predation rateof the mesopredator on the prey is hb[

There are several states with this system] all popu!lations go extinct ð9\ 9\ 9Ł\ only the prey survives ðKb\9\ 9Ł\ only the mesopredator survives ð9\ S:hs\ 9Ł\ onlythe superpredator disappears ðB�\ S:hs ¦ B�:hb\ 9Ł "B�has the same value than in system "0Ð1##\ only the preydisappears ð9\ S:hs"0 − 0:rr#\ S:mrhs"0 − 0:rr#Ł\ only themesopredator disappears ðKb "0 − 0:rb#\ 9\Kb"0−0rb#:mbŁ\ and\ _nally\ no species disappears ðB5�\R5�\ C5�Ł[ There can be between 9 and 4 stationarystates with the equilibrium value of B between 9 andKb\ as solutions of an equation of the _fth degree[ Asits expression is very long and complex for the lastpoint\ it will not be presented here\ but the authorswill provide the Maple _le upon request[ For the samereason\ the comparison between di}erent points istoo complex to be presented here analytically[ Thedeterministic nature of the model allows\ however\ anumerical study[

It can be noted that the fourth\ _fth and sixth equi!librium points are equivalent to some from the models0Ð1 and 2Ð3[ The conditions of existence of thesepoints are described in the Appendix[

SUPERPREDATOR PRESENCE AND

MESOPREDATOR RELEASE

The behaviour of the model is studied analytically "seeAppendix#\ but simulations are presented for heuristicpurposes[ It can be seen from Fig[ 1 that\ under someconditions\ while the rat alone would extirpate thebird "a# and the cat alone would not "b#\ the cat pre!vents extinction of the bird by the rat when both

predators are present by controlling rat "c#\ or evenby extirpating the rat "d#[

One can see that\ in some cases\ the presence of thesuperpredator can indirectly protect a shared preyfrom a mesopredator[ Even in circumstances wherethis is not the case\ the elimination of the super!predator might be more harmful to the prey\ throughthe {mesopredator release|\ which arises when the pres!sure on mesopredators by superpredators issuppressed[ To mimic this process\ the e}ect of thesuppression of the superpredator when the three spec!ies are present in equilibrium is studied[ First one hasto _nd values for which the bird population does notgo extinct when the two other species are introduced[A range of parameters must be de_ned at which allthree populations persist and reach an equilibriumstate[ This range of parameters implies high values ofintrinsic growth rate of the prey "×0=2# if it is tosurvive the presence of the two predators[ From thisequilibrium state "ðB5�\ R5�\ C5�Ł#\ the extinction ofthe superpredator population can be simulated andthe outcome of the two remaining populations moni!tored] new simulations are run with the followinginitial conditions] ðB5�\ R5�\ 9Ł[ This is repeated fordi}erent values of sensible parameters\ to obtain apattern displayed Fig[ 2[ This shows that prey extinc!tion through mesopredator release does occur in thissystem[ Moreover\ it is avoided only for higher valuesof prey intrinsic growth rate "×0=5#[ These correspondto values too high to be biologically realistic\ and willnot often be reached in natura by insular bird species[Indeed\ in the absence of similar predation pressure\

175



Fig[ 1[ Simulations showing the dynamics of the three population sizes plotted against time] "a# the model with only prey andmesopredator "system 0Ð1#^ "b# the model with only prey and superpredator "system 2Ð3#^ "c# and "d# the model with prey andboth mesopredator and superpredator "system 4Ð6#[ The values used for the simulations show that the superpredator canlower the mesopredator population\ to such a point that it prevents the prey elimination ðsimple mesopredator control in "c#\total mesopredator eradication in "d#Ł[ Values used are 0=4\ 3=9 and 9=64 for rb\ rr and rc\ respectively\ 099 999 for Kb and 09999for S\ 43 for mb and 199 for mr\ 5 for hb and 254 for hs[ Initial conditions are in all cases 099 999 birds\ 099 rats and 0 cat "whichcorresponds to the introduction of 099 rats and:or 0 cat into a healthy population of 099 999 birds#[ The scale is di}erent forthe three species[

Fig[ 2[ Phase portrait of the bird vs[ the rat populations\ displaying the e}ect of the eradication of the superpredator on theprey\ for di}erent values of the prey intrinsic growth rate[ Initial conditions are here the equilibrium point of the model whereall three species are present "cat population is set to zero to simulate its eradication#[ This point changes because di}erentvalues are used for the prey intrinsic growth rate leading to di}erent equilibrium values[ Elimination of the superpredatorwithout elimination of the mesopredator results in elimination of the prey population through {mesopredator release|\ whenthe prey intrinsic growth rate is lower than 0=5 "curves in light grey#[

176



these endemic species seldom have developed anti!predator life history traits\ such as a high intrinsicgrowth rate[ These results show that the only endemicspecies with intrinsic growth rates high enough tosurvive the introduction of both a superpredator anda mesopredator will normally be extirpated throughmesopredator release if the control strategy impliesonly the superpredator eradication[ The strategy ofcontrol therefore appears essential in these particularecosystems[

CONTROL STRATEGY

Mesopredator release can occur following eradicationof the superpredator and the presence of the super!predator also has negative e}ects on the prey popu!lation\ therefore a study of control strategies is neces!sary to determine an optimal strategy[ If one appliesa control e}ort of lr on the rat population and of lc

on the cat population\ the model "4Ð6# becomes]

F

G

G

G

G

G

G

g

G

G

G

G

G

G

f

dBdt


BS ¦B

hbR −B

B ¦ RmbC

eqn 7

dRdt

� rrR00 −hbhsR

hbS ¦ hsB1−R

B ¦ RmrC − lrR

eqn 8

dCdt

� rcC00 −mbmrC

mrB ¦ mbR1− lcC

eqn 09

This provides the same number of equibrium pointsas model "4Ð6#\ although with di}erent values[ Valuesof these points are provided in the Appendix\ togetherwith their conditions of existence and stability[

Analysis of this model shows that when super!predator control is high enough "lc × rc#\ the super!predator disappears[ As a result\ the prey also dis!appears when the mesopredator control is not highenough ðlr ³ rr"0 − rbhs:hb# ³ rr#\ because of meso!predator release[ In contrast\ and surprisingly\ theprey does not disappear when the superpredator con!trol is below a certain threshold ði[e[ rc"0 − rb# ³lc ³ rcŁ\ provided the mesopredator control is highenough ðlr × rr − mr"0 − lc:rc#:mbŁ[ This illustrates theimportance of the presence of the superpredator inthe system\ and the need to take it into account incontrol programmes[

Discussion

This study examined\ through a mathematical model\the fate of a prey species in an insular ecosystem intowhich both a mesopredator and a superpredator havebeen introduced[ Although other species could havebeen considered\ such as mongooses and reptiles "Caseet al[ 0881#\ the rat\ feral cat and endemic bird species

were taken as examples[ Indeed\ as Diamond "0878#stated\ {rats and cats are the most notorious killersand island birds the most notorious victims\ in thisregard ðextinctions due to introduced predatorsŁ[| Thiswork shows several interesting features of direct con!cern to conservation biology[ First\ the result of thistheoretical work shows that the presence of one pred!ator only is su.cient to induce the extinction of theendemic prey[ This is not new\ as indicated by toomany examples in natura[ Second\ when both themesopredator and the superpredator are present\seven di}erent situations may arise\ among which isthe case where the three species are present with stabledynamics[ Interestingly\ there is another case whereboth predator species can coexist inde_nitely\ evenafter the eradication of the prey species[ Finally\ andmost interestingly\ is the case where the superpredatorcauses the extinction of the mesopredator\ but not ofthe prey[

It has been shown here that presence of a super!predator may have a global positive e}ect in insularecosystems in which an introduced mesopredatorthreatens an endemic prey[ Indeed\ in the model pre!sented here the presence of the superpredator maypreclude the elimination of the prey by the meso!predator "or allow a larger prey population size#[ Inaddition\ it has been demonstrated that superpredatoreradication should be avoided\ as a means to preventwhat has been termed {mesopredator release| "Soule�et al[ 0877#] a sudden burst of mesopredators\ oncethe superpredator pressure is suppressed[ Rats have alower predation rate on birds than cats\ but they aremuch more numerous and can have a higher impacton the prey "Newman + McFadden 0889#[ Moreover\as they are omnivores\ they can maintain a high popu!lation and a high predation pressure\ even when theprey population size is low\ which the cat cannot[ Thisexplains why rats alone eliminate the prey more easilythan cats alone in the model "Fig[ 1#\ and why the catpresence is sometimes bene_cial to shared prey[ Infact\ over the last 399 years\ rats and cats are said tobe responsible for 43) and 15) of island extinctionscaused by predators\ respectively "King 0874#[ Thestudy of the control strategies clearly shows that thefate of the prey will depend on the superpredatorcontrol level[ Although counterintuitive\ if the super!predator control is too high\ the prey will disappear[This may be a further argument in favour of the useof biological control\ especially with pathogens with asteady long!term impact "see Courchamp + Sugihara0888#\ which are unlikely to be too brutal[

Despite its mathematical complexity\ this modelremains very simple in its representation of the bio!logical reality[ In particular\ spatial and temporalpopulation heterogeneities\ which are important com!ponents of insular ecosystems\ were not taken intoaccount[ Similarly\ the fact that di}erent prey speciesare present in these ecosystems has not been takeninto account[ Instead\ only one species\ which is sup!

177



posed to represent the {average| of all prey species\ wasconsidered[ As the rats and the cats are opportunisticpredators\ which switch prey species according to theirrelative availability "Clark 0879^ Fitzgerald 0877#\ itwould be interesting to study the e}ect of the presenceof several prey species[ This model is robust enoughto be extended to other ecosystems that can be welldescribed by the preyÐmesopredatorÐsuperpredatortrophic web[ It therefore holds for systems where sev!eral prey species are present "e[g[ landbirds\ seabirdsand lizards# provided that they are prey of both themesopredator and the superpredator[ Some changesmay occur in the solutions of the model according tothe characterics of the species "e[g[ if they have di}er!ent antipredation response#\ but the general con!clusions should remain the same[ Similarly\ the resultswill be the same if another superpredator\ say a birdof prey\ is present[ Di}erent e.ciencies in huntingdi}erent preys would here again add more complexity[In contrast\ the model results will undoubtedly bedi}erent if another species is present which does notfully _t into one of these three trophic levels\ becauseit would describe a totally di}erent system[ It is thecase\ for example\ if a prey species "e[g[ the rabbit# ispresent which is not preyed upon by both the super!predator and the mesopredator] islands where cats\rats and rabbits have been introduced should there!fore be described by a di}erent model[ Despite thesepossible improvements\ this theoretical work showsthat it is crucial to take into account the presence ofother alien species when designing control pro!grammes for one introduced species "see also Cour!champ et al[\ in press for another example#[ Emphasisis placed on the following important distinction thatshould be understood from this work] in some eco!systems where rats are present\ introduced cats mightplay a positive role "implying that their removal couldhave negative aspects on local fauna#^ however\ theirintroduction cannot be recommended\ whatever thecircumstances[

Several points allow optimism about this particulararea of conservation biology[ First\ the recoveryand:or preservation of the ecosystems involved is notin con~ict with local economic or politic interests\even if the governments of many concerned islandscan hardly a}ord costly programmes such as mammaleradications[ Second\ eradication of introduced mam!mals such as domestic cats "Bloomer + Bester 0881#\rabbits "Flux 0882#\ rats "Taylor + Thomas 0882#\possums "Cowan 0881#\ foxes "Bailey 0881#\ goats"Parkes 0889# or others\ once thought impossible\ isnow known to be feasible^ for example\ 019 successful{pest| eradications have already been conducted onNew Zealand islands "Veitch et al[ 0881#[ Third\ manystudies show that\ when the introduced species hasbeen successfully removed from the whole ecosystem\the threatened species "plant or animal# generallyrecovers\ sometimes rapidly\ from the e}ects of thesealien species "e[g[ Cruz + Cruz 0876^ Brothers + Cop!

son 0877^ Towns 0880\ 0883^ Newman 0883^ Cooperet al[ 0884#[ Fourth\ in the cases where alien speciesinduced the complete extinction of the population\local populations were often concerned^ species orsubspecies extinctions are less frequent "Moors +Atkinson 0873#[ Moreover\ seabird populations arenot dependent on the land for food\ and breedingcan continue on isolated islets and stacks free frompredators "Atkinson 0874#[ In most cases of colony orpopulation extinctions as a result of alien predators\there are\ in nearby islets\ populations able to re!colonize the ecosystem once the predator eradicationis achieved "Moors + Atkinson 0873^ Case et al[ 0881^Jouventin + Micol 0884#[ Last\ in some cases "as inthe well known case of the kakapo\ Clout + Craig0884^ Powlesland et al[ 0884# it is suspected that onlya small number of individuals "cats as well as rats#have learned to kill the prey or eat the eggs "Grant\Pettit + Whittow 0870^ Moors + Atkinson 0873#[ Inthese cases\ when heavy programmes\ such as com!plete eradication or long!term control\ are not poss!ible\ selective control to eliminate these particularindividuals may be su.cient in the short term\ andshould thus be implemented[

However\ the situation is critical in many cases\ andthe media and scienti_c coverage of the situation onmost islands does not seem to be proportionate tothe problems faced by these often unique ecosystems"Crystal 0878#[ Despite numerous indications of cata!strophic e}ects of introduced mammals on most oce!anic islands\ politically organized policies to resolve\or even prevent these e}ects remain comparativelyfew[ Recent examples\ and other older ones\ showthat solutions do exist[ It is often the high _nancialconstraints on eradication programmes that precludethem "Powlesland et al[ 0884#\ or that impose unde!sired priorities in the order of their attainment "Bro!thers + Copson 0877#[ In these cases\ a predictivestudy on the feasibility of the eradication and itspotential e}ects on the ecosystem is needed\ especiallywhen there is more than one introduced species\ inorder to maximize the e.ciency of eradication pro!grammes[ Theoretical studies\ such as mathematicalmodelling could ful_l this task[ This study shows thatthe intuitively evident need for feral cat eradicationmay not be the best solution in some speci_c cases\such as when introduced rodents are present[ This iswell illustrated by the case of Raoul Island\ where ithas been said that eradication of feral cats might bringlittle bene_t to bird populations\ because Norway ratsare present on this island and constitute a major partof the diet of the cats "Fitzgerald et al[ 0880#[ Empiricalexamples remain\ however\ scarce regarding the e}ectsof eradication of predators "top predators or meso!predators# on population dynamics of coexistingspecies[

The idea that top predators may be important spec!ies for conservation biology is not new[ It has beensuggested that they have a disproportionate importance

178



in food webs because their extinction can gen!erate a cascade of unexpected secondary extinctions"Paine 0855^ Pimm 0879#[ For example\ the extinctionof several prey species has been attributed to theincrease of generalist and:or medium!sized predatorymammals because of the lack of top predators indi}erent ecosystems "Terborgh + Winter 0879^ Dia!mond + Case 0875^ Wilcove\ McLellan + Dobson0875^ Diamond 0878^ Bo�hning!Gaese\ Taper +Brown 0882^ Goodrich + Buskirk 0884#[ With theexample of lynx\ mongooses and rabbits\ it has beenshown\ both theoretically and empirically\ that toppredators actually bene_t their prey through intra!guild predation on other smaller predators whichshare the prey "Palomares et al[ 0884#[ What is newhere is rather the application of this idea to an alreadyperturbed ecosystem\ a rather counter!intuitive idea]in some cases the removal of one of the causes ofperturbation may lead to increased damage[ This isthe case with the mesopredator release "Soule� et al[0877#[ In some systems\ only the direct negative e}ectsof the top predator on endemic threatened prey havebeen examined\ while in some cases greater positivee}ects may be present on the same species[ Obviously\outcomes of changes of these already perturbed tro!phic webs are not intuitive\ and intervention as dra!matic as species eradication should always be pre!ceded by careful empirical and theoretical studies ofthe whole ecosystem[ Indeed\ in the present case\ era!dicating the rats before the cats "at _rst a seeminglysound strategy# might in fact lead to another case ofmesopredator release\ as shown by the recent exampleof Bird Island in the Seychelles[ Here\ a recent eradi!cation of the introduced black rat population led to anexplosion of the exotic crazy ant Anoplolepis longipes\Jerdon\ which has been shown to be threatening thebird colonies which rat eradication was intended toprotect "Feare 0887#[ As complete removal of thosealien predators is most of the time "and often rightly#the only envisaged solution "Veitch 0874^ Ashmole\Ashmole + Simmons 0883^ Rainbolt + Coblentz0886#\ this idea of possible positive e}ects of top pred!ators should be kept in mind in conservation biology[

Acknowledgements

This work was supported by a Lavoisier fellowshipfrom the French Foreign O.ce\ by Biological Ocean!ography Grant ONR] N99903!84!0!9923\ and endow!ment funds from the John Dove Isaacs Chair in Natu!ral Philosophy\ and was part of the IFRTP ProgramNo[ 168[ We thank Professor T[ Clutton!Brock\ Doc!tors M[ de L[ Brooke\ S[ Lingle and P[ Rohani fortheir helpful comments on the manuscript[

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180



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Received 07 February 0887^ revision received 05 June 0887

Appendix

SYSTEM "0Ð1#

There are several stationary states for the _rst system"eqns 0\1#[ The _rst two equilibrium states ð9\ 9Ł andðKb\ 9Ł are always unstable[ The third state ð9\ S:hsŁ isglobally asymptotically stable if and only if rb ¾ hb:hs[These three points always exist[ When no populationsgo extinct\ the system reaches ðB�\ S:hs ¦ B�:hbŁ\where B�\ the bird population size at equilibrium\ isthe solution of a quadratic equation and therefore onecan have 9\ one or two equilibria with both popu!lations present between 9 and Kb] B� � ð−t ¦z"t1 − 3hsrbu#Ł:1hsrb\ with t � hsKb − hsrb "Kb − S#\and u � "hb − hsrb#"SKb#[ Numerically\ when there aretwo points with admissible coexistence\ one only\ atmost\ is stable[ If 9 ³ hb ¾ hs\ then there are two cases]if hb:hs ¾ rb\ the point is stable\ otherwise it does notexist[ If 9 ³ hs ¾ hb\ then there are two cases] ifhb:hs ³ rb\ it is stable\ if rb ¾ 0 ³ hb:hs it does not exist[If 0 ³ rb ³ hb:hs\ then if hb × hb�\ it does not exist\ ifhb � hb�\ it is stable\ if hb ³ hb� there are two valuesfor this point[ hb� � "hsBmax

1 ¦ rbhbSKb#:KbS\ withBmax � ð"rb − 0#Kb − rbSŁ:1rb × 9[

SYSTEM "2Ð3#

The second system "eqns 2\ 3# has 2 stationary states[P023] ð9\ 9Ł\ P123] ðKp\ 9Ł\ and P223] ðKp"0 − 0:rp#\"0:mp#Kp"0 − 0:rp#Ł[ The dynamic behaviour of thissystem is given by four cases[

181



0 Case 0] rc × 0] if rp ¾ 0 the system reaches P023\otherwise it reaches P223[1 Case 1] 9 ³ rp ¾ rc ³ 0] the system reaches P023[2 Case 2] 9 ³ rc ³ 0\ rc ¾ rp] in this case\ the dynamicsdepend on the initial proportion of prey and predator[If C"9#:P"9#× mp"rp − rc#:"0 − rc#\ then the systemreaches P023[ If 9³ rc ¾ rp ³ 0\ then the systemreaches P023[ If 0 ³ rp\ then] "i# if rc ¦ rp × 1\ thenthe system reaches P223^ "ii# if rc ¦ rp � 1\ then thisstationary state becomes a centre\ all nearby trajectorybeing periodical^ "iii# if rc ¦ rp ³ 1\ then this point isunstable[3 Case 3] rc � 0] if 9³ rp ¾ 0\ the system reaches P023\otherwise it reaches P223[

SYSTEM "4Ð6#

There are several equilibrium points for this system[The two equilibrium points ðKb\ 9\ 9Ł and ð9\ S:hs\ 9Łalways exist but are never stable[ There are 9\ one ortwo equilibrium points where only the cat populationdisappears\ since it is the solution of an equation ofthe second degree ðB�\ S:hs ¦ B�:hb\ 9Ł[ These pointsare never stable when they exist[ The point where onlythe prey disappears ð9\ S"0 − 0:rr#:hs\ "0:mr# "S:hs#"0 − 0:rr#Ł is admissible if rr × 0 and is stable ifrb ³ ðmb:mr ¦ hb"0 − 0:rr#:hsŁ and rc ¦ rr × 1[ Thepoint where only the mesopredator disappearsðKb"0 − 0:rb#\ 9\ "0:mb#Kb"0 − 0:rb#Ł is admissible ifrb × 0 and is stable if rr ³ mr:mb and rc ¦ rb × 1[ Innumerical simulations\ at least one equilibrium pointwith persistence of the three species ðB5�\ R5�\ C5�Ł isfound if the above conditions are not ful_lled[

SYSTEM "7Ð09#

Several equilibirum points arise[ Only the prey sur!vive] ðKb\ 9\ 9Ł[ This point is stable if lr × rr and lc × rc[Only the mesopredator survives] ð9\ "0 − lr:rr#S:hs\ 9Ł[This point is stable if lr ³ rr\ lc × rc and lr ³ rr"0 −rbhs:hb#[ Only the mesopredator disappears] ðKb"0 −0:rb ¦ lc:rbrc#\ 9\ Kb"0 − 0:rb ¦ lc:rbrc#"0−lc:rc#:mbŁ[This point is admissible if] rc × lc × rc"0 − rb#[ It isstable if rc × lc × rc"0 − rb#\ lr × rr − mr:mb"0 − lc:rc#and lc × "1 − rc − rb#:"1 − rc#[ The last conditionimplies rc ³ 1\ which is ful_lled by studied cat popu!lations in natura "e[g[ rc � 9=32Ð9=44] Derenne 0865^or 9=122Ð0=060] van Aarde 0867\ 0872#[ If not\ onewould have to replace it by] "1 − rc#lc × "1 − rc − rb#[Only the prey disappears] ð9\ "0−0:rr ¦lc:rrrc −lr:rc#S:hs\ "0 − 0:rr ¦ lc:rrrc − lr:rc#"0 − lc:rc#S:mrhsŁ[This point is admissible if] rc × lc × rc"0 − lrrr:rc − rr#[ It is stable if rc ×lc × rc"0−lrrr:rc − rr#\rb ³ mb"0 − lc:rc#:mc ¦ hb"0 − 0:rr ¦ lc:rrrc − lr:rc#:hs

and lc × rc"lr¦1 − rc − rr#:"1 − rc#[ The same com!ment holds for the last condition "rc × 1#[ Only thesuperpredator disappears] as in the case withoutcontrol\ there are 9\ 0 or 1 points\ given by the solu!tions of an equation of the second degree[ð−t 2 z"t1 − 3rrhshbu#:1rrhshb\ S:hs ¦ B�:hb\ 9Ł\ withhere t � lrhsKb ¦ rr ðhsKb − hsrb "Kb − S#Ł\ andu � lrhbSKb ¦ rr "hb − hsrb#"SKb#[ The point wherethe superpredator disappears is unstable if lc ³ rc

"new introductions lead to other states#[ Numerically\this point can be stabilized by increasing the value oflc "increasing the control of the superpredator#[ Innumerical simulations\ at least one equilibrium pointwith persistence of the three species ðB5�\ R5�\ C5�Ł isfound if the above conditions are not ful_lled[

Received: 19 February 2018 Revised: 19 June 2018 Accepted: 21 June 2018

DOI: 10.1111/conl.12593

P O L I C Y P E R S P E C T I V E

Predator Free 2050: A flawed conservation policy displaces higherpriorities and better, evidence-based alternatives

Wayne Linklater1 Jamie Steer2

1Centre for Biodiversity & Restoration Ecol-

ogy, Victoria University of Wellington,

Wellington, New Zealand

2Biodiversity Department, Greater Wellington

Regional Council, Wellington, New Zealand

CorrespondenceWayne Linklater, School of Biological Sci-

ences, Victoria University of Wellington,

Wellington 6140, New Zealand.


AbstractNew Zealand's policy to exterminate five introduced predators by 2050 is well-meant

but warrants critique and comparison against alternatives. The goal is unachievable

with current or near-future technologies and resources. Its effects on ecosystems and

26 other mammalian predators and herbivores will be complex. Some negative out-

comes are likely. Predators are not always and everywhere the largest impact on bio-

diversity. Lower intensity predator suppression, habitat protection and restoration,

and prey refugia will sometimes better support threatened biodiversity. The policy

draws attention to where predators are easily killed, not where biodiversity values

are greatest. Pest control operations are already contested and imposing the policy is

likely to escalate those conflicts. While “high-profile,” a focus on predator eradica-

tion obscures the fact that indigenous habitat cover and quality continues to decline.

Thus, the policy is flawed and risks diverting effort and resources from higher envi-

ronmental priorities and better alternatives. Biodiversity conservation policies should

be guided by cost-benefit analyses, prioritization schemes, and conservation planning

in an adaptive management framework to deliver nuanced outcomes appropriate to

scale- and site-specific variation in biodiversity values and threats. The success of

biodiversity sanctuary-“spillover” landscapes, habitat restoration, and metapopula-

tion management provide the foundation to build a better policy.

K E Y W O R D Sbiodiversity conservation, brushtail possum Trichosurus vulpecula, eradication, exotic species, introduced

predator, invasive species, islands, mammals, rats Rattus rattus, Rattus exulans, Rattus norvegicus, stoats

Mustela erminea

1 INTRODUCTION

New Zealand's (NZ's) government has launched the world's

largest mammal eradication––to exterminate stoats (Mustelaerminea), brushtail possums (Trichosurus vulpecula), and

rats (Rattus rattus, Rattus norvegicus, Rattus exulans) from

the entire country by 2050 (Owens, 2017). The species

targeted by the Predator Free 2050 policy (Bell, 2016,

This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original

work is properly cited.

© 2018 The Authors. Conservation Letters published by Wiley Periodicals, Inc.

p. 110) impact biodiversity on the world's islands, especially

NZ's (Jones et al., 2016). The policy identifies potential

social and economic benefits too (e.g., public engagement in

conservation, sustaining natural capital). Island eradications

have occurred globally (Jones et al., 2016) and NZ is a world

leader in the practice (Russell & Broome, 2016). The attempt

will therefore be keenly watched and potentially emulated by

other countries.

Conservation Letters. 2018;e12593. wileyonlinelibrary.com/journal/conl 1 of 6https://doi.org/10.1111/conl.12593

http://orcid.org/0000-0003-2627-693X

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2 of 6 LINKLATER AND STEER

Regarded as audacious and aspirational, the policy

attracted widespread attention in international media (Anony-

mous, 2016; Owens, 2017). Critique, however, especially

of its scientific support, has been limited. This is surprising

because the policy appears to be flawed on multiple levels:

technical, financial, social, ecological, and ethical. Although

well-meant, the high-profile policy may direct attention and

effort away from higher biodiversity priorities and alternative

policies better supported by science, lower-risk and more

suited to the biodiversity conservation capacity and needs

of NZ.

2 TECHNOLOGY, FINANCE, ANDSCALE

Predator Free 2050 has been positioned as a rational pro-

gression from mammal eradications on NZ's small, offshore

islands (Parkes, Byrom, & Edge, 2017). It is, however, more

accurately described as a “project born in a leap of faith”

(Sir Rob Fenwick: Chair of the Predator Free NZ Trust and

a Director of Predator Free 2050 Ltd., Fenwick, 2017). Scien-

tists commenting on the policy acknowledge it to be unachiev-

able with current or even near-future technologies (Parkes,

Nugent et al., 2017).

Island eradications amount to only 0.2% of NZ's land area

(Parkes, Byrom et al., 2017) and its main islands are over

4,000 times larger than the world's biggest islands cleared

of rats. The challenges sometimes overcome on small islands

(e.g., pest refugia, compensatory immigration, and reproduc-

tion: Doherty & Ritchie, 2017) cannot yet be addressed on

much larger ones. The policy's success is, therefore, reliant

on yet to be invented and tested “silver-bullet” technolo-

gies (Goal 3.4: Bell, 2016, p. 110) affordably killing, or

making infertile, every individual, everywhere. Gene drive

or “Trojan” females (Esvelt & Gemmell, 2017) are being

considered, but evidence for immunity to gene-edited infer-

tility suggests that they are unlikely to be the required

panacea (Hammond et al., 2017). Such technologies are

also a very long time from being operational in situ or

“socially licensed.”

If a “silver-bullet” technology does not manifest, it is con-

servatively estimated that the attempt will cost $32 billion or

almost $1 billion every year until 2050 (Parkes, Nugent et al.,

2017). That equates to the NZ government spending around

1.5% of its international revenues ($62 billion) or 0.54% of

GDP annually-–a large investment compared to government

expenditure on other environmental protections (0.33% of

GDP), universities (0.9%), and defense (1%; The NZ Trea-

sury, 2015). The $97 million so far allocated is not enough to

sustain the project.

Nonetheless, if scale, unproven technologies, and uncer-

tain finance were the only challenges, eradicating the five

mammals might, eventually, be possible. But there are con-

siderably more complex challenges too. In particular, small-

mammal eradication successes worldwide have occurred

only on islands with simpler predator–prey communities

and without human populations and economies to also

navigate.

3 SOCIO-ECOLOGICALCOMPLEXITY

As well as the five species targeted, NZ's largest islands have

six other introduced mammalian predators or omnivores (fer-

rets Mustela putorius furo, weasels Mustela nivalis, hedge-

hogs Erinaceus europaeus, mice Mus musculus, cats Felissilvestris, and pigs Sus scrofa) with substantial ecological

impacts (King, 2005). The 11 predatory species depredate

and scavenge another 20 species of introduced mammalian

herbivores (lagomorphs, macropods, and ungulates). These

31 introduced species interact in complex ways with each

other and indigenous species. Eradicating just five predator

species from such a complex community will likely have

adverse effects for some indigenous species and the environ-

ment (Bodey, Bearhop, & McDonald, 2011; Norbury, 2017;

Rayner, Hauber, Imber, Stamp, & Clout, 2007; Ritchie &

Johnson, 2009; Zavaleta, Hobbs, & Mooney, 2001). Unin-

tended consequences may include the eruption of unwanted

herbivores and competing predators (e.g., mice and rabbits,

and cats and other mustelids: Caut et al., 2007; Courchamp,

Langlais, & Sugihara, 2000; Goldwater, Perry, & Clout, 2012)

and invertebrate biodiversity declines (Watts, Thornburrow,

Cave, & Innes, 2014). Some effects will be unexpected and

may be unrecoverable (Doherty & Ritchie, 2017; Ritchie &

Johnson, 2009).

Consider also that, while introduced predators threaten

indigenous biodiversity they are not the largest impact on

biodiversity in all places. The biodiversity values of some NZ

ecosystems are impacted more by other introduced animals,

particularly grazers and browsers, than the predators being

targeted (e.g., Cruz, Thomson, Parkes, Gruner, & Forsyth,

2017; Forsyth et al., 2015). Also, in other environments

and at some scales, lower intensity predator suppression,

habitat protection and restoration, and enhanced refugia from

predators may be more efficient at protecting and recovering

biodiversity (Doherty, Dickman, Nimmo, & Ritchie, 2015;

Doherty & Ritchie, 2017; Ruffell & Didham, 2017). Predator

eradication, therefore, is not always and everywhere the

strategy most likely to protect biodiversity (e.g., Bodey,

McDonald, Sheldon, & Bearhop, 2011; Hoare, Adams, Bull,

& Towns, 2007; Ruffell & Didham, 2017).

When the goal of biodiversity policy is predator eradica-

tion, rather than biodiversity protection, resources may be

diverted from more substantial threats and better, multifaceted

LINKLATER AND STEER 3 of 6

biodiversity recovery strategies (Doherty & Ritchie, 2017;

Helmstedt et al., 2016). For example, the policy was cham-

pioned by a government that oversaw continued declines in

the quality and quantity of indigenous habitat (Ministry for

the Environment [MfE], 2018; OECD, 2017). The policy's

implementation has also focused on areas with the most obvi-

ous, accessible predators, like those in urban landscapes (e.g.,

https://predatorfreenz.org/about-us/), rather than in areas with

greater, or more vulnerable, biodiversity.

Last, impediments to small mammal eradication from

islands with permanent human populations and their

economies are significant (Glen, Atkinson et al., 2013;

Oppel, Beaven, Bolton, Vickery, & Bodey, 2011). NZ is a

democracy with 4.7 million socially and culturally diverse

people living in urban and rural landscapes over two-thirds

of the country. Its economy is dependent on foreign revenue

from tourism, the export of agricultural and horticultural

products, and the import of goods and services. Preventing

the reinvasion, or vindictive introduction, of eradicated

species to such a globalized economy is improbable, par-

ticularly for commensal rodents. How biosecurity and

invasive species control is achieved is already contested,

especially with respect to the humaneness of the methods

used, property rights, the autonomy of local and indigenous

peoples’ governance, and the safety of broadcast poisons that

are the mainstay of landscape-scale predator control for the

foreseeable future (Goldson et al., 2015; Oppel et al., 2011).

A significant and growing proportion of New Zealanders

(NZers; 40%) oppose the use of poison for controlling invasive

animals (Russell, 2014). Those concerns will also be shared

by some customers of NZ's tourism, agriculture, and horticul-

ture, with a growing sensitivity to the inhumane treatment of

animals and environmental toxins. An increase in poison use

to meet Predator Free 2050 goals will probably run counter

to these trends both in local communities and international

markets.

Genetic modifications of wildlife to spread infertility (see

Section 2) are proposed as alternatives to poison use but

are the subject of international controversy among scientists

and others because of the potential for unintended, uncon-

trollable consequences (Esvelt & Gemmell, 2017). Discus-

sions to develop and test these technologies in NZ have

already been criticized for their lack of openness (Fisher,

2017). The release of genetically modified mammals in NZ

will also raise concerns in other nations (Esvelt & Gem-

mell, 2017). NZ's current government is opposed to the

release of genetically edited organisms, underlining how

fraught any reliance on genetically engineered solutions

may be.

Added to this complexity are the views of NZ's “first-

nation” peoples, the Maori, some of whom also oppose

poison use and genetic manipulations of wildlife. The eradi-

cation of some introduced species is also contentious because

some Maori regard them as culturally important. The Pacific

rat, for example, while targeted by Predator Free 2050, is

protected on some Maori lands. The policy does not consider

the cultural barriers to its success, instead opting to engage

with Maori after the fact.

An ethical case for nationwide predator eradication is being

developed a posteriori (Morton, 2017). The rationale is that a

net ethical benefit will be achieved because no further killing

would be required. But a positive ethical “balance-sheet”

depends on the humanness of control techniques and eradi-

cation success, about which there are substantial uncertain-

ties (Cowan & Warburton, 2011; Doherty & Ritchie, 2017).

The improbability of success and the perception by some that

current tools are cruel are substantial barriers to ethically

robust outcomes. More compassionate approaches to man-

aging predators (Wallach, Bekoff, Batavia, Nelson, & Ramp,

2018) are not being considered.

Ultimately, the Predator Free 2050 policy's implementa-

tion has enormous consequences, negative as well as positive,

for people and their environments. To be successful, such

consequential conservation policies should encourage debate

and not fuel the escalation of existing conflicts (van Eeden,

Dickman, Ritchie, & Newsome, 2017). They should also be

designed to reinforce public trust in the institutions that imple-

ment them (Crowley, Hinchliffe, & McDonald, 2017) so that

wider support for environmental governance is not put at risk

(Oppel et al., 2011). Didactic policy that only tells the public

what must be done should be avoided (Crowley et al., 2017;

van Eeden et al., 2017). Unfortunately, Predator Free 2050 is

just such a policy, having been designed without formal con-

sultation or participatory research and development with the

wider public. The social science it has supported, while well

intentioned, was instigated after the policy was announced and

implemented (MacDonald, Edwards, Greenaway, Tompkins

et al. 2017). And that research has been directed at obtaining

a “social license” for new pest control technologies (e.g.,

gene editing), not toward developing and implementing a bio-

diversity policy informed by NZers (MacDonald et al., 2017).

The risks of policy implementation, and then failure, eroding

wider support for conservation have not been adequately

considered.

4 BETTER POLICY AND PRACTICE

It would have been better had mammalian predators not been

introduced to NZ. However, now that they are here, and with-

out a realistic chance of removing most of them, we need to

find ways of managing the ecosystems they have invaded and

the biodiversity they threaten.

Many of NZ's native species persist, and some even thrive,

alongside introduced predators (e.g., Hoare, Shirley, Nelson,

& Daugherty, 2007). For the most vulnerable species that

https://predatorfreenz.org/about-us/


cannot, NZers have proven that they can be protected in sanc-

tuaries where predators are intensively managed (e.g., http://

www.sanctuariesnz.org; e.g., Armstrong, 2017; Armstrong

et al., 2014). Importantly, they have also proven that the

“spillover” from those sanctuaries is substantial and facili-

tated by lower-cost, larger-scale predator suppression in the

landscapes surrounding them (Miskelly, Empson, & Wright,

2005). NZers are also beginning to investigate how habitats

might be better managed to increase refugia from predators

and to adapt prey to their presence (Hoare, Shirley et al.,

2007; Norbury, Heyward, & Parkes, 2009; Urlich, 2015).

Some experts suggest that a national network of sanctuar-

ies, with predator suppression in adjacent landscapes could

achieve NZ's biodiversity goals without the extreme costs

and risks of attempting complete eradication (Parkes, Nugent

et al., 2017). Predator eradication at small scales, alongside

species reintroductions and restocking, and habitat restora-

tion and predator suppression at larger scales, would sup-

port the development of national metapopulations of threat-

ened species. The sanctuary-spillover sites would be selected

because they are national biodiversity “hotspots” with the

potential to be connected by dispersal or species transloca-

tion with other hotspots. Only pests with the largest or partic-

ularly critical impact need to be targeted in each sanctuary-

spillover site to achieve biodiversity outcomes. Sometimes

predators but, at other times and places herbivores or weeds,

for example, will be prioritized and targeted. The pests man-

aged are likely to be very different between sites depending

on the different biodiversity values prioritized at each (Parkes

& Nugent, 1995). This is a strategy that is possible with cur-

rent tools and finance in an adaptive management framework

(Glen, Pech, & Byrom, 2013; Parkes & Nugent, 1995; Parkes,

Nugent et al., 2017) that already receives widespread public

support.

Predation from introduced mammals is one of the threats

to NZ's biodiversity (Goldson et al., 2015) but it should

not be overstated when considering biodiversity conserva-

tion at the national scale (Doherty & Ritchie, 2017; Parkes

& Nugent, 1995). Its prominence resulted from the traditional

focus of ecological investigations on large, iconic native ver-

tebrates in biodiversity reserves (e.g., birds) with less atten-

tion on other native taxa (e.g., invertebrates and flora) and

communities in the modified environments that dominate NZ

(MacLeod, Blackwell, Moller, Innes, & Powlesland, 2008;

Trimble & Van Aarde, 2010). But biodiversity conserva-

tion requires policy that enables site and species prioritiza-

tion for nuanced conservation management across space and

time (Doherty & Ritchie, 2017). Habitat loss, pollution (espe-

cially of aquatic habitats), and urban and rural development

have been the major causes of biodiversity loss in NZ (MfE,

2018; OECD, 2017). For example, around two-thirds of the

country's indigenous forests, and almost all of the indige-

nous grasslands and lowland forests, have been removed or

fragmented and all but ∼10% of its wetlands drained (Norton

et al., 2016). A focus on predator eradication does not address

these other more fundamental causes of biodiversity decline

or opportunities to recover it.

5 CONCLUSIONS

The world will be watching NZ with interest as its PredatorFree 2050 policy is implemented. It will likely prove a

useful case study in the interaction between science, gov-

ernment, and communities for other nations to consider

when deciding how to design and implement biodiversity

policy. Unfortunately, it is already clear that the policy has

not been well informed by scientific knowledge or conser-

vation best practice. It also misdirects attention from more

fundamental and direct threats to biodiversity protection and

recovery.

While predator control and exclusion remains a necessary

part of biodiversity conservation in NZ, the nationwide

eradication of predators is not. And if biodiversity recovery

is our ultimate goal then predator eradication is secondary

to the need for somewhere for biodiversity to live. Sup-

ported by modern socio-ecological theory and practice,

NZ's biodiversity goals (Norton et al., 2016) could be

better achieved with a less extreme (i.e., less costly and

lower risk), and more nuanced and multifaceted policy.

That policy would use existing, proven technologies and

strategies, and be guided by scale- and context-dependent

cost-benefit analyses and prioritization schemes (Helmstedt

et al., 2016; Parkes & Nugent, 1995), and incorporate

decision theory (Driscoll et al., 2010), conservation planning

(Margules & Pressey, 2000; McIntosh, Pressey, Lloyd, Smith,

& Grenyer, 2017), and adaptive management (Doherty &

Ritchie, 2017; Parkes, Robley, Forsyth, & Choquenot,

2006).

Biodiversity recovery requires different strategies in differ-

ent places, at different scales, in different communities of peo-

ple, and at different times. Protecting some species from intro-

duced predators will likely remain a focus of conservation in

NZ's biodiversity sanctuaries. That focus, however, must not

detract from other biodiversity conservation priorities at the

national scale, including the pressing need to protect and grow

habitat. While Predator Free 2050 is well intentioned, NZ's

future conservation policies need to be less bombastic, and

better informed by the environmental, ecological, and social

sciences.

ACKNOWLEDGMENTSThe authors would like to thank John Parkes, Doug

Armstrong, and three anonymous reviewers for suggestions

that improved the manuscript.

http://www.sanctuariesnz.org

http://www.sanctuariesnz.org

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Predator Free 2050: A flawed conservation pol-

icy displaces higher priorities and better, evidence-

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Fact Sheet

www.alleycat.org • 7920 Norfolk Avenue, Suite 600 • Bethesda, MD 20814-2525 • ©2011

THE VACUUM EFFECT: WHY CATCH AND KILL DOESN’T WORK

Removing cats from an area by killing or relocating them is not only cruel—it’s pointless.

Animal control agencies and city governments have blindly perpetuated this futile approach

for decades. But years of failed attempts, scientific research, and evidence from animal control

personnel prove that catch and kill doesn’t permanently clear an area of cats.

Scientific evidence indicates that removing feral cat populations only opens up the habitat to an influx of new cats, either from neighboring territories or born from survivors. Each time cats are removed, the population will rebound through a natural phenomenon known as the “vacuum effect,” drawing the community into a costly, endless cycle of trapping and killing.

The vacuum effect is a phenomenon scientifically recognized worldwide, across all types of animal species.

Well-documented among biologists, the vacuum effect describes what happens when even a portion of an animal population is permanently removed from its home range. Sooner or later, the empty habitat attracts other members of the species from neighboring areas, who move in to take advantage of the same resources that attracted the first group (like shelter and food). Killing or removing the original population does nothing to eliminate these resources; it only creates a “vacuum” that will inevitably draw in other animals living nearby.

Scientific research has observed the vacuum effect across many species—herbivores, carnivores, and omnivores. When studying mountain lions, for example, one researcher noted, “When you remove resident lions that have established home ranges you

create a void.” He continues, “Other resident lions that have home ranges that may overlap the individual you removed now find that territory empty. This allows them to expand their range, as well as create openings for transient lions to establish a new home range.”1

Simply put, when mountain lions are removed from their habitat, other mountain lions move in. This behavior has also been documented in possums,2 badgers,3 and raccoons.4

A habitat will support a population of a certain size. No matter how many animals are removed, if the resources remain, the population will eventually recover. Any cats remaining after a catch and kill effort will produce more kittens and at a higher survival rate, filling the habitat to capacity. As one study found, “populations greatly reduced by culling are likely to rebound quickly.”5 Over time, the number of cats in an area where a feral cat colony has been killed or relocated will simply recover and return to its original size.

Removing cats from an area is a futile effort—one that cannot succeed.

The only documented “successful” effort to remove a population of cats occurred in a cruel program on uninhabited,

Research

Fact Sheet:


sub-Antarctic Marion Island. It took two decades and ruthless methods—methods that are impossible to replicate in areas inhabited by people including poisoning, hunting with guns, and introducing disease—to clear the island of cats. As scientists tried each method, they noted “the recolonization of preferred habitats, cleared of cats, from neighboring suboptimal areas…”6 In other words, like the mountain lions, whenever they killed cats in the best habitats, the cats next door simply moved in. (See sidebar on page 3 for more information: ‘Marion Island proves that removing cats from an area is a futile effort that leads to decades of cruelty.’)

The Marion Island example proves the vacuum effect while it also proves the impossibility of permanently clearing an area of an entire target population. Municipalities engaged in any type of catch and kill efforts are fighting a cruel, endless, losing battle against nature that is a gross waste of taxpayer dollars and ends hundreds of lives.

Years of failed catch and kill policies prove this method’s ineffectiveness.

Animal control officers all over the country have observed the ineffectiveness of lethal methods firsthand through years of misguided policy.

Joan Brown, President and CEO of the Humane League of Lancaster County (PA), says that her organization made the switch to Trap-Neuter-Return when they started to realize that they were never making any headway with catch and kill.

“I finally went to the board and said, ‘Where in our mission statement does it say euthanize? Because all we’re doing is taking [feral cats] in to euthanize them…we’re not only doing an inhumane thing, we’re actually contributing to the problem, creating a vacuum effect that will just be filled again—and probably at a faster rate than when we started,’” says Brown.

Brown says that they noticed it was a never-ending and growing problem, draining their resources and their morale: “At the very least, we were standing still. That was clear, and it seemed as if we were running forward, but actually moving backward.”

Other animal control and shelter organizations nationwide have also taken a stand after acknowledging the failed results of their catch and kill efforts. Maricopa County, Arizona’s animal control website says, “We have over 20 years of documented proof that traditional ways of dealing with feral cats don’t work. The catch and kill method of population control (trap a cat, bring it to a shelter, ask that the cat be euthanized), has not reduced the number of feral cats. The cat may be gone, but now there is room for another cat to move in…So, catch and kill actually makes the problem worse.”7 And the Humane Society of Ochocos (Oregon) agrees: “…[W]e know now, that more than 30 years of trapping and killing cats has done nothing to reduce the feral cat population.”8

The National Animal Control Association amended its feral cat policy in 2008 to be more supportive of Trap-Neuter-Return, in part because, as then president Mark Kumpf put it, “[i]t’s recognizing that in some cases, certain jurisdictions and communities are more interested in maintaining a stable cat population than they are in simply bailing the ocean with a thimble.”

He continues: “What we’re saying is the old standard isn’t good enough anymore. As we’ve seen before, there’s no department that I’m aware of that has enough money in their budget to

THE VACUUM EFFECT: WHY CATCH AND KILL DOESN’T WORK, page 2 of 4

Catch and kill is a costly, endless, inhumane cycle.

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Fact Sheet:


simply practice the old capture and euthanize policy; nature just keeps having more kittens.”9

If catch and kill had any long-term effect on cat populations, animal control officers nationwide—and their leadership organizations—would have observed it by now. Instead, they are reading the writing on the wall and switching to the method that works.

Trap-Neuter-Return is the responsible, humane method of care for feral cats.

Trap-Neuter-Return stabilizes feral cat populations. The cats are humanely trapped, vaccinated, and neutered, so no more kittens will be born. They are then returned to their original location to live out their lives in their outdoor home. Not only is Trap-Neuter-Return the humane option for feral cats, it also improves cats’ lives by relieving them of the stresses of mating and pregnancy. In the end, unlike catch and kill, TNR works.

It’s time to stop the killing.

Cities and shelters across America have experienced great success with Trap-Neuter-Return—it is now official policy for feral cats in Washington, DC, Baltimore, and Chicago. It’s time to learn from past mistakes and move forward instead of going around in circles—it’s time to stop fighting the endless battle of catch and kill and protect cats’ lives.


CASE STUDY: Marion Island proves that removing cats from an area is a futile effort that leads to decades of cruelty.

The only documented instance of a population of cats being permanently, “successfully” removed from their habitat occurred in an abhorrently cruel program that proves just how impossible, impractical, and inhumane it is to attempt to kill off a target population of cats.

In 1975, scientists set out to kill all of the 2,500 feral cats living on Marion Island—a tiny, uninhabited sub-Antarctic island measuring just 115 square miles, where there was no chance that new cats could move in. In their first attempt, researchers aerially sprayed feline distemper virus over the island. Sixty-five percent of the cats suffered and died painfully, but the other 35% developed immunity and the population quickly rebounded. Compounding this failed effort with further cruelty, they next brought in dogs to flush out the remaining cats. Between 1986 and 1991, the last cats were hunted with guns and, when that also failed, trapped and poisoned.10

It took 19 years and ruthless methods to clear Marion Island of cats. That’s nearly two decades to kill all of the cats in an environment where no new cats could enter. Even in this extremely isolated environment, scientists noted “[T]he recolonization of preferred habitats, cleared of cats, from neighboring suboptimal areas…”11 In other words, they still observed the vacuum effect.

The outrageously inhumane methods used to kill the cats of Marion Island were unacceptable 20 years ago and they remain unacceptable today—not only because of their horrific cruelty, but also because they are impossible to replicate in populated areas like cities and towns. Although often held up by opponents of TNR as an example of successful feral cat control, all the Marion Island example proves is the existence of the vacuum effect and the futility of attempting to permanently clear an area of cats by killing them.

Trap-Neuter-Return stabilizes feral cat populations.

Fact Sheet:


1 McKinney, Billy Pat. “Mountain Lions, Deer and Predator Control.” The Role Of Predator Control as a Tool in Game Management - Symposium Proceedings. Kerrville, TX: Texas Agricultural Research and Extension Center, 2001. 70-73.

2 Ji, W., S. D. Sarre, N. Aitken, R. K. S. Hankin, and M. N. Clout. “Sex-Biased Dispersal and a Density-Independent Mating System in the Australian Brushtail Possum, as Revealed by Minisatelite DNA Profiling.” Molecular Ecology 10 (2001): 1527-1537.

3 Killian, Gary, Kathleen Fagerstone, Terry Kreeger, Lowell Miller, and Jack Rhyan. Management Strategies for Addressing Wildlife Disease Transmission: The Case for Fertility Control. Staff Publication, Lincoln, NE: U.S.D.A National Wildlife Research Center, 2007.

4 Rosatte, Rick, et al. “Racoon Density and Movements after Population Reduction to Control Rabies.” Journal of Wildlife Management 71, no. 7 (2007): 2372-2378.

5 Killian, Gary, Kathleen Fagerstone, Terry Kreeger, Lowell Miller, and Jack Rhyan. Management Strategies for Addressing Wildlife Disease Transmission: The Case for Fertility Control. Staff Publication, Lincoln, NE: U.S.D.A National Wildlife Research Center, 2007.

6 Bester, M. N., et al. “A Review of the Successful Eradication of Feral Cats from Sub-Antarctic Marion Island, Southern Indian Ocean.” South African Journal of Wildlife 32, no. 1 (April 2002): 65-73.

7 Maricopa County Animal Care & Control. “Feral Cats.” 2011. http://www.maricopa.gov/pets/pdf/livingwithferalcats.pdf (accessed February 10, 2011).

8 Humane Society of the Ochocos. “Feral Cat Problem.” 2011. http://www.humanesocietyochocos.com/Feral.html (accessed February 10, 2011).

9 “Taking a Broader View of Cats in the Community,” Animal Sheltering, September/October 2008. http://www.animalsheltering.org/resources/magazine/sep_oct_2008/broader_view_of_cats.pdf (accessed February 10, 2011).

10 Bester, M. N., et al. “A Review of the Successful Eradication of Feral Cats from Sub-Antarctic Marion Island, Southern Indian Ocean.” South African Journal of Wildlife 32, no. 1 (April 2002): 65-73.

11 Ibid.

Graphic illustrations by June Matics.


APP202879-PredaStopforferalcatsSubmissionReferenceno:73DavorBejakovich,GreaterWellingotnRegionalCouncil(DavorBejakovich)1056FergussonDrive,UpperHuttWellingotnNewZealandPh:[email protected]: NotspecifiedSource: Email

OverallNotes:

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ClauseAllsubmissionsaretakenintoaccountbythedecisionmakers.Inaddition,pleaseindicatewhetherornotyoualsowishtospeakatahearingifoneisheld.PositionNoIdonotwishtospeakaboutmysubmissionatthehearingNotes

SUBMISSION 127083 REFERENCE 73

LETTER

Greater Wellington Regional Council (GWRC) strongly supports the reduction of the notification area for

PredaStop from 3km to 500m.

Under the Resource Management Act 1991, and the Biosecurity Act 1993, the Greater Wellington Regional

Council (GWRC) has statutory obligations for the management of pest animals within the 813,000 hectares of

the Wellington Region. These obligations include the maintenance of regional indigenous biodiversity and

the implementation of the Regional Pest Management Strategy 2002-2022.

GWRC undertakes predator control operations across the Wellington Region for Biodiversity purposes.

Mustelids and feral cats are some of the worst predators of our native flightless and ground nesting birds, and

the vulnerable lizard and invertebrate populations. Ferrets are a known vector for Bovine Tb, and are actively

monitored and controlled by TBfree NZ and their contractors. The current management of these species is

restricted by the limited range of control products available on the New Zealand market.

For mustelid control, trapping remains the key control method with only one toxin, Diphacinone

Ferret paste, available. The situation is similar for feral cats, with the only toxin available - 0.1%

1080 feral cat bait, being limited to use solely by the Department of Conservation, and PAPP with

the limitations of the 3km notification area. It is vital to Greater Wellington, and the pest control

industry as a whole, that a wider range of control methods are available to ensure economic and

efficient predator control operations.

Reducing the notification area for PredaStop from 3km to 500m would allow GWRC to integrate the

use of PredaStop with our existing possum and rodent control programmes and enable better

management of these predators in our Key Native Ecosystem sites.

GWRC recognises the importance of taking actions to reduce feral cat numbers and reduce the subsequent

risk of toxoplasmosis. Toxoplasmosis in sheep flocks only occurs due to feral cats being in the environment.

The protozoal disease toxoplasmosis (Toxoplasma gondii) is widespread throughout New Zealand and cats

are the only definitive hosts of the protozoa and may shed millions of infectious oocysts in their faeces into

the environment. Since the 1950s, toxoplasmosis has been recognised as a significant cause of abortion in

sheep, goats and pigs (Tompkins 2014) and it results in substantial economic and welfare impact.

Having a range of control methods available allows safe and effective control in different land-use

area. Varying between trapping and poisoning helps to catch target animals that are adverse to either

method. Trapping is costly and inefficient in many situations, and an effective, affordable predator

toxin would have wide benefits for the biodiversity of the Wellington region, and New Zealand as a

whole. With growing opposition and restrictions on poisons such as aerial 1080, it is important that

the pest control industry continues to investigate, develop and trial new toxins. The use of specific

toxins with less risk of secondary poisoning, and an effective and affordable antidote, are of

increasing importance. In the event of accidental poisoning, PAPP has an antidote, methylene blue,

which has been used for over 100 years for the treatment of nitrate poisoning in ruminants. The

availability of this antidote makes PAPP a valuable tool in areas of public use, and helps mitigate

any potential negative impact on the community.


LETTER PAGE 2 OF 2

GWRC also recognises PAPP as a very valuable tool as part of the national goal of a predator free

New Zealand and in the management of toxoplasmosis in a rural landscape. Even though PAPP is

very effective, it is considerably more humane than other forms of VTA control, and has minimal

risk to non-target species, the current 3km notification requirement, which we believe is

unwarranted, significantly restricts its use. As a result, feral cat management is not conducted over

larger areas than otherwise would be, therefore having negative impacts on both the environment

and primary production.


BEC CREW 8 APR 2015

Culling Feral Cats Actually Increases TheirNumbers, New Study FindsKilling them only makes them stronger.

A new study has found that trapping and culling might not be the best solution toAustralia’s feral cat problem - the practice can actually cause an increase in theirnumbers.

TECH HEALTH ENVIRONMENT SPACE HUMANS PHYSICS NATURE VIDEO POLITICS & POLICY

Culling feral cats actually increases their numbers, new study finds https://www.sciencealert.com/culling-feral-cats-may-actually-increase-their-numbers-study-suggests

1 of 4 4/16/2018 3:22 AM

Of all the feral animals currently eating, stomping, and hunting their way throughAustralia’s suburbs, cities, rural areas, and desert plains, none have been quite sodisastrous as the cat. According to the ABC, cats are estimated to eat 75 millionnative animals every night in Australia, which is a rate we can’t possibly sustain.Right now, we have the worst mammal extinction rate in the world, with 29 nativemammals having become extinct since European settlement, and on a global scale,one in three mammal extinctions in the last 400 years have occurred in Australia.

Culling cats seemed like a pretty straightforward solution, and has become fairlycommonplace in the country's most problematic areas. For example, between 2012and 2013, almost 6,000 of them were culled at a national park in far south-westQueensland in an effort to protect a small population of wild bilbies.

But an accidental finding by researchers in Tasmania suggests that this isn’t thesmartest way to handle Australia’s feral cat problem at all. "You may be inadvertentlydoing more damage than good," wildlife biologist Billie Lazenby, from the TasmanianDepartment of Primary Industries, told Anna Salleh at the ABC.

Lazenby said that the reason culling has been so widely used in Australia is thatstudies have shown how effective it can be. But the problem is these studies havereally only been done on islands, rather than mainland areas such as Australia,where as soon as one cat is removed, another will readily take its place from aneternally self-replenishing population.

This realisation came from a recent study published in the journal Wildlife Research,and conducted by Lazenby and her colleagues in the forests of southern Tasmania.The team looked at populations of small native mammals in areas where feral catshave been left to their own devices, and compared these to populations were cats


2 of 4 4/16/2018 3:22 AM

have been reduced via culling.

And although the culling did what it was supposed to - initially lowered the feral catpopulation - the researchers found that soon after, the population not only replenisheditself within 12 months, but actually ended up increasing.

"In the areas that I had tried to reduce cat numbers, I recorded an increase in catnumbers. I actually had more cats running around on those sites than beforehand,"Lazenby told Salleh at the ABC. "We recorded a 75 to 211 percent increase in theminimum number of feral cats known to be alive in the culled areas."

While they’re still analysing the results of this study, the team suspects that cullingthe cats upsets the power balance, and when you remove the dominant individuals,more and more ‘subordinates’ move in to explore the area.

So what’s the solution? Sustained culling could work, because it does effectivelyreduce feral cat numbers, but the government has to be prepared to keep it up sopopulations aren’t allowed to be replenished. Otherwise, we need to figure out how tolive with the number of feral cats we have, and somehow reduce their impact on ourwildlife using strategies such as fences, or giving small mammals better places tohide and shelter themselves.

"What we really should be focusing on when we talk about managing introducedspecies like feral cats is reducing their impact," says Lazenby. "But it's reallyimportant that we keep in mind that you don't always reduce impact by reducingnumbers, as one individual might cause 90 percent of the damage."

Source: ABC News


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gwrc proposed rpmp 2019 2039 submissions · 2018. 10. 3. · 039 little, chris ... while stoats are...

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