18 August 2014
Lower North Island Hunter Liaison Group
Summary of Issues – WARO Review
- The Lower North Island Hunter Liaison Group (LNIHLG) comprises representatives of 11 NZDA branches and four other non NZDA hunting groups located in the Lower North Island. These groups collectively represent over 2000 members. Additionally there are probably as many hunters that are non-club members in the region.
- The Ruahine range is probably the most popular hunting destination for these hunters.
- The group has an MOU with DOC that states the purpose of the group is “To provide a forum for recreational hunters and the DOC to share information, and to raise and discuss issues relating to recreational hunting in the Lower North Island”.
- The MOU has a principal “To operate in a no-surprises manner, bringing any concerns to meetings to work through constructively”
- The group attempted to work with DOC, and following meeting with Peter Dunne where it was agreed to work jointly to prepare a deer management plan. Doc later declined to participate stating the CMS was the place for that issue.
- Information obtained via OIR indicated the conservancy had an undeclared agenda of removing restrictions to WARO in the Ruahines and that the LNIHLG group would be used to facilitate this aim.
- DOC reps voiced views that the relationship was not achieving DOCs desired outcomes and would review their role.
- Ruahine concession changes will have direct impacts on recreational hunting particularly from the WARO targeting of stags during the spring/velvet period.
- Tararua/Rimuataka changes; allowed winter WARO in very high tramper and hunter use areas where WARO has been excluded for 30 years.
- Wairarapa Reserves Closed status removed; these areas are small, forest covered and contain relatively low deer populations. Control has always been maintained by hunters. WARO has a direct impact on ground hunting of these places.
- Only the Ruahines has been included in this review, by DOC. We are seeking DOC to review all changes in the Lower North Island.
- The process of the 2015 WARO concession review should have been through a Notified Consent. The effect on hunters and other recreational users is significant. The changes that have occurred (Ruahine, Tararua, Rimutaka and also other areas within the country) cannot be regarded as of minor effect and in terms of effect upon recreational hunters they are probably the most significant adverse change to WARO that has ever occurred in the history of the WARO concession process.
- Many areas in NZ have restricted WARO on the basis of being of value to local hunters and is a legitimate reason for limiting WARO impacts.
- DOC have stated that “effects” would have the same definition as in the RMA yet DOC have varied significantly from RMA “when to notify criteria” that would be applied within the RMA. To suggest that “the effects of WARO are well known” as a basis for not notifying is a nonsense when those effects are applied when and where they did not exist before. It is akin to putting in casino in a residential neighbourhood noting that the neighbours have no right to object as the effects of casinos are well known.
- DOC do not regard “unhappy hunters” as being an “effect”. This is a ludicrous interpretation. Unhappy hunters are a SYMPTOM of the actual effects of removing opportunities for hunting and deterring hunters from participating in hunting. It is well documented that hunting contribution to conservation increases significantly in the absence of WARO.
- The department guidance to Districts during the concession renewal states the “valued local hunting herd” is not a valid criteria to exclude WARO. The Ruahine range is not the only area that has exclusions to WARO based on hunter interest. The guidance is at variance with the WAC act that requires the department to consider recreational hunters in decision making
- DOC regard there as being no obligation to consult anyone other than themselves and WARO operators. But even the LNI department guidance to staff documentation states that staff should consult where changes that affect users have been decided.
- The department has claimed to “consult” with hunters via the Game Animal Council. In reality no relevant information was provided to the council regarding likely changes that would allow them to submit meaningfully and the GAC submission suggesting a new regime was completely side lined and ignored by DOC.
- Regarding Ruahine changes, the 2009 review documentation recognises that consultation is required with users before existing conditions are changed.
- DOC also acknowledged is the need for any changes to the Ruahine restrictions to be made via the CMS review process. Despite this, DOC have pre-empted the CMS process by applying significant concession changes in total secrecy. The LNIHLG and others have sought to be involved in the WARO review (since last year), all attempts to be involved have been rebuffed.
- The “No surprises” principal of the MOU we have with DOC should have resulted in consultation but this commitment by DOC has been ignored.
- Following the 2009 concession review a report to conservator Alan McKenzie (J Mace) stated that DOCs legal advice was that to amend the Restricted Ruahine WARO status consultation with hunters must be undertaken and there must be evidence that deer were causing unacceptable impacts on vegetation
Ruahine Park Management Plan requirements;
- The changes made are contrary to the policies of the Ruahine Park management plan. The plan policies state there will be “helicopter free areas in the park as long as recreational hunting is achieving an acceptable level of control in these areas”.
- The plan also states that these restrictions to helicopter deer recovery will only be removed if monitoring shows “evidence of unacceptable levels of deer control”.
- The land area that was noted as “Restricted” (closed to WARO during summer months) is one of the areas which has been declared “free of helicopters”. Removal of that restriction without justification to allow summer WARO is contrary to the park plan policies.
- The plan also requires DOC to liaise with hunters to get the best contribution to deer control. This has never been effectively implemented.
- The plan restricts the use of helicopters to a limited number of landing sites, to limit the impact on recreational users during periods of high visitor use. Allowing year round WARO access with impact on all recreational users.
Justification used by DOC for the changes:
- The only justification provided in the review documentation has been the perceived “steady increase in the deer population in the Ruahines, and the expected negative impact this population increase is likely to cause to the quality of the forest and grassland ecosystems”.
- Monitoring data that we have been supplied by DOC does not support the conclusion given in this justification. Monitoring reports do not show significant threats to the vegetation from increased deer densities.
- Comparisons between Closed areas (Orua, Makawakawa) and Open areas (Tukituki) have shown that deer densities are similar. Also the restricted WARO area has not shown larger increases in deer. These trends are also similar to that assessed in the Pohogina and Pouragnaki catchments.
- Conclusions presented in the 2007 deer pellet monitoring reports state “Re-measurement of the 1983 pellet lines has shown small, statistically insignificant increases for the six catchments monitored”
- The conclusion could be drawn that in fact recreational hunting is just as effective as WARO. and that recreational hunting has proven to be more sustainable over time
- It is the view of experienced hunters that since the 1960s a vastly modified forest has developed that has ample representation of palatable species. The high forests and alpine scrub zones have become near impenetrable, a totally different place than what existed In the 1960s-70s. DOC surveys state that the most preferred species will not regenerate in the presence of even very low deer densities.
- Post the WARO concession decisions being made we requested the Tier 1 monitoring data that evidenced the increase in deer numbers. Over 2 months post the decision being made DOC have requested more time to provide that data as the analysis had not been completed. Without data how did they arrive at that conclusion?
- The claims made at the meeting with Peter Dunne (19 June 2015), that the Tier 1 monitoring revealed “very high” deer densities was clearly speculation , if the data had never been analysed. Regardless, the analysis suggests that deer densities were overstated.
- In fact, the analysis of the Tier 1 data shows that the Ruahines have similar deer densities as Tararua and Kaweka ranges. There is obviously no immediate significant threat to conservation values
It is of no surprise to hunters that the deer densities in the totally Closed areas are no different to those within the areas open to WARO. It is the heavier stags that are targeted by WARO and removal of these animals has little impact on deer population when removed. If herd reduction was in fact necessary, it is the hinds that need to be culled. The monitoring results clearly show that WARO is not doing delivering the results and the department has been misguided in favouring WARO over recreational hunters wherever it can.
- The criteria for removing WARO restrictions is provided for in the management plan. i.e “evidence of unacceptable levels of control”. This criteria has not been met and therefore the concession changes are a breach of the department’s policies.
- The Wild Animal Control Act requires “the decision maker to have regard to the role of those engaged in recreational hunting as a form of control of wild animals”. There is no evidence in the departmental documentation that any consideration of this legal obligation has been met.
- Currently there are 2300 recreation hunting permits issued for the current 6 month period in the forest park. DOCs own research – Fraser estimates that there is an annual recreational harvest of 54000 from a total estimate of 50,000 hunters. This would equate to a possible harvest of 2500 deer from the Ruahine range by 2300 hunters annually (this is a conservative estimate as more than 2300 individual hunters would be permitted over a full 12 months. Also, it does not take account of the non-permitted hunters, of which there would be a significant number.
- The Tararua removal of Closed status has not been justified in the departments documentation, except that the high use Tararua valleys explanation is “High-visit catchments of Otaki Forks, Holdsworth, Totara Flats, Atiwhakatu and Tutuwai receive lots of campers, trampers and school groups during summer season. High level of use continues through to include Easter” WARO is permitted during the winter months on the assumption that after the Easter period, recreational use is low. The public use and hunting of these valleys is among the highest use areas in the country and they have been the training grounds for generations of hunters.
Conversely the 2009 justification for 12 month Closure is “High year round recreational use areas – concern for public safety and enjoyment of the area re camping, walking tracks, recreational hunters”. The stated Year round high public use has apparently changed to summer months only. This is a total failure to understand use of these valleys by trampers and hunters and is beyond comprehension. Deer densities are low solely due to recreational hunting and there are no threats to vegetation from deer.
- In the Wairarapa reserves there has been no justification noted for removing Closed status. All of these small areas are surrounded by farms, have nil or low deer populations and are effectively controlled by recreational hunters. DOC Masterton have a partnership with local NZDA to access some of these reserves for hunting. One reserve of 80 hectares is next to State Highway 2, surrounded by dairy farms and has no deer present. Naively a department manager has stated that “real benefits to conservation values” would result from opening the small Wairarapa reserves.
The 2009 concession review for these reserves stated that “deer absent or very low density of animals not adversely affecting conservation values. Mainly small conservation areas and are surrounded by freehold property and/or neighbouring farms and/or high use recreation areas. Public safety camping walking tracks, school camping activities”.
Yet justification for retaining Closed status of a similar reserve, Hemi matenga reserve is “Low deer numbers adequately managed by rec hunters”. There is total inconstancy in these decisions.
- In Rimutaka there is no justification provided for removal of Rimutaka Closed status for the 2015-18 review. The only areas of where Closed is retained are parts of the forest park including within 200 metres of the Orongorongo valley floor. This fails to recognise the very high public use of the many forest walking tracks in the catchment. The forest park has low populations of deer and control of these animals is effectively done by hunters.
- For the Tararua, Rimutaka and Wairarapa reserves, no submissions were received by DOC for these areas to be made available. It appears that managers have chosen to remove WARO restrictions even though current concessionaires have shown no interest is operating in these places. The removal of restrictions are totally without justification.
Effects of changes
- Impacts of this change will see the experience of hunters significantly adversely affected and its likely more pressure will be placed on the remaining Excluded zones. This will result in a reduced hunting experience and also impact on other park users.
- There will be increased helicopter activity in areas previously helicopter free during the summer impacting on all users, not just hunters.
- WARO are in fact targeting the very same animals that hunters seek during the roar period. Spring/early summer access to WARO will see hunters deterred from hunting these areas.
- It is well known that increased WARO results in less participation by hunters. As by far the major contributor to deer control, the department will stand to lose the only sustained management of deer in the range.
- The Ruahine range has been favoured by hunters throughout the lower North Island, and elsewhere because of the lack of WARO activity over the summer months and the accessibility of the open country. Many hunters use helicopters to access the park. It is well known that the year round WARO in the Tararua range has resulted in many hunters bypassing the range instead preferring the Ruahines to hunt.
- Hunter participation has been shown to increase over the last 10 years. This is in part due to the improved chances of success due to reduced WARO competition. Allowing WARO will result in significant impacts on hunter’s experience.
- It seems ludicrous that a large number of hunters and also trampers that use the Ruahine Forest Park will have their experience affected by one ot two commercial helicopters for which there is no logical justification.
- The Tararua/Rimutaka/reserves will have a negative effect upon a large number of hunters from the Wellington/Wairarapa area and will compel hunters to go to WARO free areas like Aorangi Forest Park, an area of very high hunting activity already.
The concession process was flawed and the Lower North Island changes should be reversed.
- Effects on the recreational hunting experience in the LNI will be significant and simply because the effects are “known” does not mean they can be applied anywhere and at any time without triggering a need to notify.
- Consultation was non-existent despite department documentation that for these changes to occur, consultation must occur.
- The removal of Ruahine WARO closure during the summer months is contrary to the Conservation Act provisions.
- The sole justification was alleged deer densities that pose an unacceptable risk to conservation values. Deer population surveys used by DOC to justify this view have since proved the department claims to be false.
- The department has failed to meet the requirements of Section 2 (f) of the Wild Animal Control Act.
The departments 2015-18 concession process has made these changes throughout the country without any consultation with the most affected group, 50,000 recreational hunters (DOC’s own research estimate – Fraser)
The Liaison group has been repeatedly advised by the DOC Managers participating with the group that deer management issues should be negotiated through the CMS process. Reservation about this were made, considering that the expected 2014 WARO review would occur before the CMS process was complete. This has turned out to be correct, but despite the DOC assurances regarding the CMS process, significant changes have been made regardless, in secrecy. This has been to the detriment of recreational hunting in the Forest Parks and reserves in the Lower North Island.
The surveys of the long term Closed areas of the park demonstrate that recreational hunters do control deer populations adequately. Clearly recreational hunters, if able to hunt without the disturbance from WARO are more than capable of managing deer densities.
While opening the range to summer WARO may achieve short term reductions in deer (mainly stags), the department fails to comprehend that this will simply push deer into the forested areas resulting in reduced deer recovered but also little recreational hunter interest and therefore inadequate sustainable deer control.
If a reduction in deer population was required, the department should be aware that the WARO practice of targeting heavier stags is not going to achieve this, when in fact it is a reduction in hinds that is needed. While recreational hunters target stags during the popular Roar period, hunting for meat is popular during other periods, as well as during the roar.
Going by the published monitoring results, the recreational hunter has arguably been more effective than WARO, when WARO is excluded totally.
The department claims that exclusion of WARO during the summer months is reducing the effectiveness of deer control by WARO. This not consistent with the Tararua range where year round WARO is permitted. The Tier 1 monitoring results indicate the Ruahine deer densities are similar to Tararua. If DOC claims that Ruahine deer are increasing significantly then higher deer densities would be expected in the Ruahines than occur in the Tararuas. But this is not the case, according to the Tier 1 results.
Section 4.2 (f) of the WAC act states “Recreational hunting of wild animals and animal pests should be encouraged where this does not diminish the effectiveness of operations to control them and is consistent with the planned outcomes at places”. Considering that recreational hunters are the major contributor to Ruahine deer control and have achieved control of areas excluded to WARO over a very long term, it would be expected that greater encouragement of hunting be given by the department, rather than attempting to undermine the deer management effort of hunters.
The Director General himself stated at a meeting in May 2015 with the GAC that most recent research indicated that if deer control ceased it would be 200 years before there was irrecoverable harm to the forests.
At a time when the WARO industry is struggling to exist throughout the country due to the economics of deer recovery, it would have been logical for the department to work closer with hunters to obtain the best result from recreational hunting in the control of deer in the forest park. Throughout the history of the helicopter deer recovery industry, there have been constant fluctuations in effectiveness and only recreational hunting has been a consistent contributor to deer control.
There appears to be a continuation of the anti-deer dogma that WARO should be given access to every piece of Public Conservation Land (PCL) regardless of the lack of threats from deer or the interests of recreational users. This is no better illustrated than in the Tararua range where Closed areas have been opened regardless of very low deer densities and very high recreational use. Naively a department manager has stated that “real benefits to conservation values” would result from opening the small Wairarapa reserves.
The previous period of restricted WARO operation that included the month of November has been detrimental to the efforts of recreational hunters experience and contribution to deer control. This period of WARO sees a high harvest of stags that are the same animals that hunters seek later in the year. The taking of stags does little to reducing deer populations and the permitting of WARO during this period returns little on deer control to the department.
The short sighted preoccupation with WARO as the saviours of our forests fails to recognize the changes that have occurred in the industry. Hinds have not been targeted by WARO and this has resulted in less reduction of deer densities than has occurred in the past.
The LNIHLG was established to work with DOC to enhance recreational hunting and management of deer in the Lower North Island. A refusal to recognise the impact on hunters and honour the obligations of the MOU of No Surprises is seen as a betrayal of that agreement.
The whole process undertaken has been shoddy and the refusal to meet obligations to consult with recreational users leaves the department open to a legal challenge from hunters that could see the entire national review overturned. The department has shown complete disregard for recreational hunters who are major users of the Ruahine Forest Park, and also the Tararua and Rimutaka ranges.
The aim of the LNIHLG is to achieve Herd of Special Interest (HOSI) status for the Ruahine Forest Park. There is the willingness by hunters to pursue this objective which will provide improved recreational hunting for the many hunters that frequent the forest park. We intend to promote this goal through the CMS process for the region. HOSI would enhance the Ruahines as a destination for hunters and with targeted WARO the deer population would be managed to the levels needed to meet the department’s conservation goals.
DOC proffered Justifications based on deer impacts have been exaggerated and the policies of the Ruahine Management plan have been contravened. The changes currently benefit a single concessionaire but affect the experience of thousands of park users in Ruahine, Tararua and Rimutaka FP’s. Concessionaires had no interest in seeking access into Closed areas in Tararua, Rimutaka or Wairarapa reserves.
The LNIHLG to request
- Remove the Ruahine Open status and return to the winter month’s only condition that existed prior to the 2014/15 review.
- Additionally exclude November from the period of operation in the concession
- Remove the Open and Restricted status recently designated to the Tararua, Rimuataka Forest Parks and also Wairarapa reserves that existed prior to the 2014/15 review
- Direct the departments LNI staff to work with the Liaison Group to develop a regime that achieves the agreed best outcome for conservation and recreation in the Lower North Island forest parks and reserves.