PCE 1080 Report - Concerning

Yesterday the PCE (Parliamentary Commissioner for the Environment) released her report on the use of 1080 poison in New Zealand.   TV3 news report    TVOne news report    (Overview printed below)

New Zealand distributes over 3 tons of pure 1080 poison across it's forests, every year. That's 85% of the world supply!
The PCE stated in her report that New Zealand drops 300 kilo's of pure 1080, annually - That was an error, it's actually over 3000 kilo's (NZ Herald - 1080 use in NZ) (enough to kill over 2 billion endemic robins, or over 20 million people, annually).

That 3000 kilos of poison is used to make over 2,000,000 kgs of 1080 bait, annually.

The PCE stated that we are dropping less poison into our forests now, compared with years ago - that may be correct, but only by a narrow margin.

We are dropping less bait - about 2 - 3kg's per hectare (2.2 acres/hectare), however, the amount of poison in the bait, now, compared with 20 years ago, is allot higher. We are also dropping across greater areas of virgin rain forest.

When reading through the overview of the report it reads like something straight out of a DoC (Department of Conservation) brochure. 

It's provocative, alarmist, and inaccurate. It seems to indicate a pre-mindset bias (most people in NZ have a bias toward the use of 1080, before even taking on a project like this - us included), or political interference, or perhaps, incompetence - but whatever the cause, the report is of profound concern.

There is ample evidence, on this blog alone, that the use of 1080 poison may be doing irreversible damage. And to add to that, there's still not a competent scientific study that demonstrates a net population benefit to any native species, through the use of 1080 poison in New Zealand. 

New Zealand has been using this poison for over 30 years, and it shows. From our observations - we film and observe wildlife right across New Zealand - there is not a single area that we can name, that has had repeated drops of poison, that shows an obvious benefit to the native wildlife. Not one!
You would think after 30 years of poisoning, the benefits would be obvious, going by what the PCE says about 1080.

However, we can name several areas that have never had 1080 applied, that far exceed the poisoned areas we have visited. Hearsay? Yes. Anecdotal? Yes. Provable? Yes!

We are not against managing pest populations in our national parks. We have personally trapped 1000's of possums, at no cost to the government.

We are not paid for our work to help end aerial 1080 poisoning operations, unlike the majority of people supporting its continued use.

We are vowing to continue to support the campaign to help end the use of 1080 poison in New Zealand, before it's too late - and for some areas, it seems we are too late ...

PCE Overview, conclusions and recommendations

EMBARGOED UNTIL 6AM June 8, 2011

Commissioner's overview

As I write this overview it is business as usual in the bush. This might conjure up
images of tui popping open mistletoe flowers, fantails flitting from tree to tree
behind trampers and the calm of a grove of tree ferns. But in much of our great
forests, the reality is far less halcyon. Sadly business as usual is more likely to
mean stoats patrolling kiwi nests waiting for chicks to hatch, rats hunting down
frogs, geckos and insects, and possums stripping mistletoe, fuchsia and rata.
Last summer while on holiday I mentioned to a friend that I was investigating
the use of the pesticide known in New Zealand as 1080. She responded "That
will be very difficult; there are such good arguments on both sides." What I
have discovered through this investigation is that this is not so. While I respect
the sincerity of those who oppose the use of 1080, without it our ability to
protect many of our native plants and animals would be lost. And without 1080,
keeping bovine tuberculosis at bay to protect dairy herds, and protecting young
trees in plantation forests would be much more difficult and expensive.

In New Zealand, 3,500,000 kilograms of pesticide is used every year, and the
amount of 1080 used is less than one-thousandth of this - about 300 kilograms.
Yet despite this, despite years of research, exhaustive reviews and the setting of
many controls governing its use, 1080 remains controversial, and the call for a
moratorium on 1080 from some Members of Parliament was a major impetus for
this investigation.

Along with a number of other poisons, 1080 is used in bait stations on the
ground, but it is the dropping of it from helicopters that elicits the greatest
concerns. And this is understandable; scattering poison from the skies just feels
like a really bad thing to do. So why is it done?
The great majority of our native plants and animals occur naturally nowhere
else in the world. This makes them especially vulnerable to invaders from other
countries, since there was no need to evolve defences against them. Birds did not
need to fly if there were no ground predators to hunt them down.

This investigation is focused on three pests that do immense damage to our great
native forests, as well as to other ecosystems and to the economy more generally
- possums, rats and stoats. Most of us still think of possums as the major
enemy, but over the last 15 years or so, scientists have developed a much deeper
understanding of the destruction caused by rats and stoats. Increasingly, stoats,
not possums, are spoken of by conservationists as 'enemy number one'.
The interaction between rats and stoats is particularly important. When there
is plenty of food, rodent populations boom, providing meat for the carnivorous
stoats. So-called 'mast events' are particularly tragic. In the very years when
certain tree species flower profusely, when millions of seeds drop to the ground
to enable birds to lay more eggs than usual, the rat and stoat populations irrupt
and the chicks are doomed.

It was a surprise in this investigation to discover that possums, rats and stoats
are only controlled on one eighth of Department of Conservation land. We may
well be looking at a future where many of our special plants and animals can be
found only on offshore islands with extremely limited access to the public and in
sanctuaries behind big fences. Without active pest management, kiwi chicks have
a one-in-twenty chance of making it to adulthood.

1080 is a substance that occurs naturally in many plants in Western Australia
and other countries. That it exists naturally is no argument in its favour - so does
hemlock. Plants that contain 1080 evolved it as a defence against browsing
animals. Consequently, possums and other native animals in Western Australia
have become immune over eons of evolutionary time. This has made it possible
for 1080 to be aerially dropped over millions of hectares in Western Australia to
kill foxes, feral cats and wild dogs.

An ideal method for controlling possums, rats and stoats would kill them
effectively and enable native trees and animals to flourish, it could be used
tactically to rapidly knock down irrupting populations of rats and stoats during
mast events, and it could be used cost-effectively over large remote rugged areas
as well as on small accessible reserves.

Such an ideal method would also have no unwanted effects. It would not kill
or harm native birds, fish, lizards and insects, and it would not kill introduced
animals that are not pests. It would not leave long-lasting residues in water
and soil or endanger public safety. And it would kill possums, rats and stoats
humanely as well as effectively.

In this investigation, 1080 and its alternatives (to the extent possible) are
compared with this imaginary ideal, and 1080 scored surprisingly well. It is
not perfect, but given how controversial it remains, I for one expected that it
would not be as effective and safe as it is. In large part this is due to the many
improvements in practice and controls that have been put on its use over the
years.

In order to fully understand the concerns about 1080, my staff and I have had
lengthy discussions with a variety of people at the forefront of the opposition to
its use. We have striven to understand the nature of their concerns and studied
the written material they have produced. Certainly some operations have not
been well done; there is always room for improvement and there is always the
possibility of human error, intentional or otherwise.

It must be extremely upsetting to lose a cherished dog to 1080, but only eight
dogs have died this way in the last four years. The sad reality is that many many
more will die on roads each year and no one is proposing a moratorium on
traffic. It is important to keep risks in perspective.

The Department of Conservation often refers to 1080 as "one of the tools in
the toolbox". This may give the impression there are alternatives that can do the
same job, but this is not the case.

Indisputably trapping has a role to play, particularly in bush margins and reserves,
along with a number of other poisons besides 1080. But ground operations
can never be as effective or as cost-effective as aerial operations in large rugged
remote areas.

One commonly used poison is cyanide. It has the advantages of killing humanely
and breaking down quickly in the environment, including in the carcasses of
poisoned animals. But because of this it cannot kill stoats; because stoats are
carnivores, the only way to kill them in large numbers is secondary poisoning,
that is, feeding on poisoned possums and rodents.

Another commonly used poison is brodificoum, but brodificoum has a higher risk
of by-kill than 1080 because it persists in the environment for a long time, and it
is particularly inhumane.

There are other alternative poisons to 1080 under development, but while they
have some advantages over 1080, they cannot replace it. Biological control
options held promise for a time, but research funding has stopped due to lack
of progress, and probably also because most of the options involved genetic
engineering.

The Prime Minister's Chief Science Adviser Sir Peter Gluckman frequently calls for
policy decisions to be based on evidence. A solid body of evidence supporting
the continued use of 1080 has been built up over the years; the large number of
notes and references at the back of this report are testament to this.

It is my view based on careful analysis of the evidence that not only should the
use of 1080 continue (including in aerial operations) to protect our forests,
but that we should use more of it. And it is not as if much is being used now.
Currently there is more Crown funding given to the Animal Health Board to kill
carriers of bovine TB than the Department of Conservation spends on controlling
possums, rats and stoats over the entire conservation estate.

It is seldom that I come to such a strong conclusion at the end of an
investigation. But the possums, rats and stoats that have invaded our country will
not leave of their own accord. Much of our identity as New Zealanders, along
with the clean green brand with which we market our country to the world, is
based on the ecosystems these pests are bent on destroying. We cannot allow
our forests to die.

Dr Jan Wright
Parliamentary Commissioner for the Environment




Recommendations:

8.1 No moratorium on 1080

The native plants and animals in New Zealand are unique because they have
evolved in almost total isolation from the rest of the world. This makes them
particularly vulnerable to predators because they have not developed defences
against them. In particular, because there were virtually no native land mammals,
the invasion of small mammals that followed the arrival of Europeans requires
constant vigilance and effort. Possums, rats and stoats are increasingly damaging
our national parks and other conservation land, and possums, rabbits and hares
lower the productivity of our agriculture and forestry.

Traps and bait stations play a crucial role. But it is a limited role. In our great forests
on the conservation estate, possums, rats and stoats breed virtually unhindered,
and ground control methods, no matter how sophisticated, simply cannot cover
large areas of rugged terrain or prevent the devastation of mast years. The only
option for controlling possums, rats and stoats on almost all of the conservation
estate is to drop poison from aircraft. And 1080 is the only poison currently
available for aerial pest control on the mainland that can do this job.

Dropping a poison from the sky will always be contentious and understandably
so, even if a poison were to be developed that was perfectly effective, safe and
humane. In this report, 1080 has been systematically assessed for its effectiveness,
safety and humaneness. While it is not perfect, it scores surprisingly well, due in
large part to the increase in scientific understanding, the establishment of a strong
body of evidence, and the addition of many controls over the years.

Research to develop better poisons (and possibly biocontrol options) should
absolutely continue. Alternatives, whether currently available or on the horizon, can
complement the use of 1080, but cannot replace it. The huge effort, expenditure
and achievements to date in bringing back many species and ecosystems from the
brink would be wasted if the ability to carry out aerial applications of 1080 was
lost.

I recommend that:
1. Parliament does not support a moratorium on 1080.

8.2 Simplify regulations

The labyrinth of laws, rules and regulations that govern 1080 and the other poisons
used to control introduced pests creates unnecessary complexity and confusion.
Under the RMA, the use of poisons for controlling pest mammals is treated
differently by different councils. Some councils treat the use of poisons as a
permitted activity with only a few conditions, while other councils treat exactly
the same use as a discretionary activity requiring a resource consent. In one case
the number of aerial 1080 operations that can take place under the consent is
specified, making it very difficult to respond to mast events. Many of the rules also
replicate controls already in place under other legislation.

There is considerable scope to simplify and standardise the management of
these poisons. There is a strong case for the use of 1080 and other poisons to be
permitted activities under the RMA, with local control reserved to those activities
that are not covered by already existing controls under other legislation. One
way to achieve this standardisation and simplification could be with a National
Environmental Standard.

There may also be other opportunities for simplifying various practices associated
with the use of 1080, some required under regulations and some not. For instance,
over 2,500 water samples have been taken for more than 20 years from drinking
water supplies, streams and lakes after aerial 1080 operations. In all this time 1080
residues have never been detected in drinking water supplies, and only found in
vanishingly small and harmless levels in 3 percent of the remaining samples. We do
not need more water samples to tell us that the way 1080 is used poses no real risk
to water.

I recommend that:

2. The Minister for the Environment investigate ways to simplify and
standardise the way 1080 and other poisons for pest mammal control
are managed under the Resource Management Act and other relevant
legislation.

8.3 The Game Animal Council

The Government has committed to establishing a Game Animal Council to advise
on and manage hunting interests on the conservation estate. The Council will
report to the Minister of Conservation and work with her department.

While greater collaboration between different interest groups on the conservation
estate should be encouraged, the proposal has the potential to conflict with the
Department of Conservation's ability to carry out pest control.

The discussion paper on the Game Animal Council suggested that DOC and the
Council work together to identify priority areas 'where animals need to be actively
controlled for conservation purposes'. Outside these areas the paper suggests the
Council should have responsibility managing game animals.

While the Council would not be tasked with responsibility for managing possums,
rats and stoats, it could under the suggested management structure effectively
halt 1080 operations for these pests if it thought game animals may be at risk. This
would place an unacceptable constraint on DOC's ability to carry out pest control
effectively and efficiently.

I recommend that:

3. The Minister of Conservation establishes the Game Animal Council as
an advisory body that works collaboratively with the Department of
Conservation, but ensures that responsibility for all pest control remains
with the department.

8.4 The Animal Health Board & the Official Information Act

The goal of the Animal Health Board (AHB) is to eliminate bovine TB from New
Zealand. Most of its effort goes into killing possums and other carriers of the
disease. The AHB is a major user of 1080, mostly in ground control operations
along with trapping and other poisons such as cyanide.

The Department of Conservation and regional councils are subject to the Official
Information Act and the Ombudsmen Act, but the AHB is not. Moreover, New
Zealand's principal manufacturer of 1080 baits, Animal Control Products Ltd, is
subject to both Acts.

The AHB receives about $30 million of central government funding and about
$6 million of regional council funding every year. As a recipient of government
funding, it would be consistent with sound public policy to increase the
transparency and accountability of the AHB by making it subject to the Official
Information Act and the Ombudsmen Act.

Currently the Biosecurity Law Reform Bill 256-1 (2010) before Parliament would
see this occur at least in part. The relevant proposed amendment (clause 79) is
not specific to the AHB, but rather is directed to any agency "if they are corporate
bodies, in their role under pest management plans or pathway management
plans".

However the question arises as to whether the coverage proposed in the
amendment is as comprehensive as is desirable. If the intent is to ensure the AHB
is fully transparent in a manner consistent with other public agencies, then AHB
should be specifically named in the Ombudsmen Act.

Including the AHB in the Ombudsmen Act would also automatically subject the
AHB to the Official Information Act. The Official Information Act provides for
requests to be made for information and sets time limits for responses. If the AHB
were made subject to the Official Information Act, then an individual or group
would have much greater access to information. For instance, someone concerned
about whether buffer zones were actually adhered to in an aerial 1080 drop might
request a copy of a map of the actual flight tracks recorded on the GPS system in
the helicopter.

I recommend that:

4. The Minister of Justice introduces an amendment to the Ombudsmen
Act 1975 to add the Animal Health Board to Part 2 of Schedule 1 of
the Act, and thereby make the Animal Health Board also subject to the
Official Information Act 1982.

Chapter 8 - Conclusions and recommendations

8.5 Economic value from pests without undermining
conservation

During this investigation the economic potential of the possum fur industry has
been raised. Some have argued that large scale possum fur harvesting would be
an effective pest control method. Others have suggested that reducing possum
numbers could actually make things worse, by leading to higher populations of
rodents because there would be more food for them, and then stoats would
multiply because there would be more rodents for them to eat.

While "a good possum is a dead possum", commercial fur harvesting is unlikely to
benefit the conservation estate. Unless possum fur becomes much more valuable
than it is now, commercial harvesters would probably stop catching possums long
before their numbers have been reduced to levels that are low enough to benefit
native animals and plants. Nevertheless there is every reason to encourage possum
fur harvesting on the conservation estate, provided it does no damage.

Currently agreements between pest control agencies and fur harvesters appear
to be ad hoc. Where possums are being controlled entirely by ground methods
commercial trappers are sometimes allowed in to have "first crack". But there
could be considerable potential in large areas of back country where there is no
pest control at all taking place.

It is not cost-effective to control pests using ground operations in large areas of
back country. However, well-organised large scale fur harvesting, like the wild
venison hunting of the seventies, may be economically viable.

A working group involving the Department of Conservation, the Animal Health
Board, regional councils, and industry representatives has been established to
consider developing policies and procedures for testing the economic potential of
fur harvesting, but it is not at all clear that it is a priority.

I recommend that:

5. The Minister of Conservation asks the Department of Conservation
to prioritise the development of national policy and operational
procedures on possum fur harvesting.

8.6 Department of Conservation: improve transparency

In the course of this investigation it has become clear that the quality of
communication about 1080 operations and the relationships between pest control
agencies and communities varies across agencies and regions.

A key communication tool is the Department of Conservation website. Currently
it contains four-monthly updates on pest control operations and conservancy
plans for pest control, including maps. The provision of such information makes
an extremely valuable contribution and should be encouraged. However, the
information given in conservancy plans is not consistent; for example, only some
conservancies state the size of the area that is to be treated. And no conservancies
provide information on why a particular operation is being carried out, such as the
need to knock down rodents to protect kokako nestlings.

Providing relevant information on 1080 operations on the website in a consistent,
readily accessible format is essential.

Reports on completed operations should also contain the results to demonstrate
what worked, what did not work and why. Open communication of success and
failures is critical for building good relationships between pest control agencies and
the public.

I recommend that:

6. The Minister of Conservation improve information about pest control
on the conservation estate by providing consistent and accessible
information on the Department of Conservation website, including the
purposes and results of different pest control operations.

ENDS