- 5.1 Target species.
- 5.2 Non-target species / Indigenous flora and fauna and natural communities.
- 5.3 The integrity of indigenous ecosystems.
- 5.4 Valued introduced flora and fauna.
- 5.5 Intrinsic value of ecosystems and ecosystem stability.
- 5.6 The health and social well being of people.
- 5.7 The relationship of Maori and their culture and traditions with ancestral lands, water, sites waahi tapu, valued flora and fauna and other taonga. - A summary of all of the maori issues.
- 5.8 The use and enjoyment of the public of lands and waters to which they have right of access.
- 5.9 Domestic rabbits including laboratory colonies.
- 5.10 People and enterprises based on controlling wild rabbits.
- 5.11 People and enterprises based on harvesting wild rabbits.
- 5.12 International trade.
- 5.13 International standing or mana in relation to clean green image.
- Conclusion
5. The effects, positive and negative, of RCD virus on:
5.1 Target species.
For a discussion on the clinical and pathological effects of RCD virus on the rabbit see section 7.3.
5.2 Non-target species / Indigenous flora and fauna and natural communities.
Submitters confirmed that there is widespread concern and considerable debate about the possible effects that an RCD introduction would have for this country’s flora and fauna.
Ecosystems make the point that people in general, and especially conservationists, are naturally risk averse and many would prefer to not take an active step (such as release of RCD) if there is some chance that it might go wrong. But doing nothing is also an active decision with several attendant risks for wildlife. Failure to objectively weigh the risks of acting, with the risks of not acting, is a common feature of many wildlife management decisions involving the general public, and it is very evident in the submissions on the current RCD debate.
| Submitters expressed a range of views: | |
| - | those opposed to RCD place a lot of emphasis on the uncertainty and inadequacy of the current knowledge base and point to the negative impacts of previous introductions of exotic species. They focus specifically on aspects of the Application itself, and the testing that was carried out in Australia on non-target species; they raise issues of fauna susceptibility and risks to rare and endangered plant species; |
| - | submitters in qualified opposition express the need for more time for testing and to observe Australian experience of ecological effects; |
| - | submitters with qualified support for RCD acknowledge the need to monitor effects on wildlife and emphasise the need for caution when it comes to knowledge of ecological risks; |
| - | supporters of RCD take the view that present research is adequate, and dispute the benefits of further research prior to an introduction. |
| Effects of RCD on non-target species / indigenous flora and fauna and natural communities. | |
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5.2.1 Direct effects of RCD virus
The Application claims that no fauna were directly affected by the RCD virus. For a discussion see section 7.1.
5.2.2 Indirect effects of RCD virus
See section 6. for the mitigation measures.
| The Application introduces the subject with the following: | |
| "Overall, the impact of rabbits on the natural ecosystem is undoubtedly negative. It is nonetheless crucial to ensure that if a new tool is introduced to reduce rabbit numbers, it allows the environment to gain maximum benefit for the altered balance to the ecosystem without also introducing unmanageable risks." | |
| Ecosystems caution with: | |
| "Removal of prolonged grazing pressure from rabbits will trigger profound habitat changes in some places (especially where domestic stock do not graze) which may assist some wildlife species and threaten others. ... | |
| Neither opponents or proponents of RCD can rightfully claim that it will bring net conservation harm or gain for species conservation values. ... | |
| The risk of not releasing RCD to solve current and ongoing conservation problems of species declines and ecosystem degradation in rabbit prone areas has scarcely been acknowledged by opponents to RCD." | |
Impacts on fauna
The rabbit is unique among the herbivores of New Zealand in having a wide range of predators, some of which (the mustelids - ferret, stoat, weasel) were introduced specifically to deal with it. Weasels may now be a minor predator of rabbits, taking mainly other species,including native birds, but cats also prey extensively on rabbits. Rabbit populations therefore are directly associated with several numerous widespread, active, carnivores which have a significant impact on young rabbits. Rodent populations are also preyed on by mustelids and cats. There is then, a suite of predators directly and indirectly associated with rabbits (Fordham). Rabbits are then a classic "keystone species" that have an inordinate variety of far-reaching ecological effects within the ecological community.
Mammal predators already prey on native vertebrates and invertebrates whether or not rabbits are also available. Whatever the regional stocks of native prey species are now, they are likely to be lower in the future from continuous predation. In other words native prey species will continue to suffer losses (which may be unsustainable for some long-lived slow maturing species e.g. kakapo, kaka, kiwi) from predation whether or not rabbit numbers are reduced by RCD virus.
Predator prey-switching
If RCD was to cause a sudden severe reduction in rabbit numbers in any area of New Zealand it would almost certainly produce in each community a ripple of effects through the guilds of predators and their actual and potential prey. (Changes in predator numbers and their diets may be triggered by relative changes in rabbit availability, not the absolute level of change in rabbit numbers.)
At the individual level, hungry predators would change their diet to available alternative prey. At the population level, predators able to supplement a rabbit-deficient diet with other foods, such as native invertebrates and vertebrates, could be expected to breed normally and eventually recruit young as reproducing adults. Predators short of food and low in condition may not breed successfully, or survival of young may be lowered. Unless alternative prey of an equal biomass were available resident predators would progressively forage more widely to survive. Home ranges would therefore increase in size, or shift. This would affect predator guilds in a complex ripple effect. Another consequence is that dispersal would be stimulated with predators of rabbits moving considerable distances (Fordham).
| Predator dispersal - its significance to native prey species. |
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While predation pressure might increase in conservation-sensitive areas if they attract predators that disperse from areas depleted of rabbits, Norbury and Heyward (1995) found that most ferrets and all cats (most of which were adults) remained on their home ranges after rabbit control in the semi-arid grasslands. Twenty percent of resident ferrets temporarily dispersed an average of 3 km from their home ranges during winter, but only where rabbit control achieved a 99% kill. Most ferrets subsequently returned to their home ranges. The available evidence suggests that dispersal of adult predators following rabbit control is an infrequent event in the semi-arid grasslands. The risk may be even less in wetter areas, where alternative prey are more abundant and predators’ reliance on rabbits is lower (Norbury and Murphy, 1996).
However, it is still possible that dispersal of juvenile predators, which occurs naturally each year, may increase during the first year following RCD outbreaks. Also, predators may shift the focus of their hunting areas within their home ranges after rabbit declines.
Predation pressure over time
| Predation pressure is the percentage of prey mortality due to predation. The potential damage that RCD induced prey switching could inflict on the native fauna would depend very much on the way the disease behaves in New Zealand. |
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| Diet switching due to RCD may have different effects than that of current poisoning methods |
| DoC and Ecosystems believe that RCD-induced decline may have different effects than that of current poisoning methods: |
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| The Application, group in reply, make the following observations: |
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Predator guild changes
It is not known for certain whether predator guild changes would occur in the wake of RCD-induced rabbit declines, and whether they would lead to increased predation pressure on native fauna. However, the limited evidence collected so far suggests that increased predation pressure is a serious possibility.
The main concern would be if declines in rabbit numbers led to increases in stoats and/or rodents.
A study on the Tekapo riverbed in 1986 showed the problems that can be caused when predator proportions change within guilds. Greatly reduced numbers of rabbits led to a decrease in feral cats, ferrets and harriers, but stoats increased in the riverbed area. The stoats (and other predators) exerted more pressure on ground-nesting birds and killed more adults than had ferrets, cats and harriers in the presence of rabbits (DoC).
Ecosystems speculate that a reduction of ferrets and cats (following any prolonged reduction in rabbits by RCD) would probably trigger increased abundance of stoats. Stoats are known to carry Tb but their role in spreading Tb is poorly understood. Therefore, the possibility exists that RCD may merely change the source of the Tb problem from ferrets to stoats in rabbit prone areas and any change in the relative numbers would have an unknown effect on the Tb problem.
The net direction of changes cannot be predicted
In preparing for mitigation the safest assumption is that RCD would spread rapidly, causing a very high mortality in rabbits and cyclic population fluctuations would follow.
If there is long term suppression of rabbits with RCD there are no reliable data to predict whether net predation pressure on native biota would increase or decrease. The effect is likely to vary in strength from place to place and potentially also between indigenous species.
Many more species would potentially be affected than the few listed by DoC and in the Application. Insects and lower vertebrates have been given scant consideration. Species and communities are vulnerable to change throughout the country. There has been a possibly mistaken assumption that effects of RCD on non-target indigenous wildlife would be greatest on or even contained entirely within areas currently experiencing high rabbit abundance. There is no guarantee at all that the ecological effects requiring mitigation, or the species gaining a benefit from RCD, would be restricted to the rabbit prone areas (Ecosystems).
Impacts on Fauna due to Changes in Flora
The possible changes in flora wrought by the proposed RCD introduction are likely to have effects on native birds, reptiles, and invertebrates.
Birds
DoC considers that changes in flora owing to RCD-induced rabbit declines could pose a risk to some native birds - though the magnitude of that risk is highly uncertain. Increases in tall grasses and shrubs could reduce the nesting suitability of herb fields for birds such as banded dotterels.
A decline in rabbit numbers could release river bed weeds such as broom, gorse, willow and lupins. This could be a problem for river bed nesting birds such as the wrybill which will tolerate little or no vegetation on their nesting islands or shingle banks.
Reptiles
Some changes in flora caused by RCD-induced rabbit declines may be beneficial for some native reptiles.
Invertebrates
The great majority of native invertebrates would probably not be further threatened by vegetation changes caused by RCD-induced rabbit declines.
If an RCD release was to be accompanied by measures that keep rabbit populations stable and low then the consequent increase in plant biomass in conservation areas could lead to a long-term increase in invertebrate abundance.
Impacts on Flora
Rare Plants
Only a few rare plants are known to be affected by rabbits. For example:
- The Castle Hill buttercup is browsed by rabbits and has to be given netting protection. It therefore could theoretically benefit from reduced grazing pressure. However, it is unlikely to benefit much as netting protection would still be needed unless virtual eradication of rabbits was achieved.
- Native brooms, many of which are rare or threatened and are eaten by rabbits, would probably benefit from reduced rabbit browsing. Rabbits are currently thought to be severely reducing the recruitment of the rarest native broom in New Zealand, Carmichaelia hollowayi, on Otekaike limestone in the Waitaki valley (DoC).
- Some rare native plants in dune hollows or in sandy soils would probably benefit from relief from the disturbance of rabbit burrowing and scraping activity. These benefits could, however, be outweighed by releasing competitor plants that are normally held in check by rabbits. Rabbit exclusion experiments with the habitat of the tiny gentian Sebaea ovata growing on the Wanganui coast have shown that it can be smothered by introduced grasses as a result of reduced grazing. Any benefits could also be outweighed for some plants (e.g. Sebaea ovata ) that utilise rabbit scrapes for some of their seed germination (DoC).
Uncommon Ecosystems
Rabbits have significant adverse effects on certain types of remnant lowland plant communities. For example, they are believed to intensively crop the palatable native plants and foster the invasion of introduced grasses in dune slacks, a rare coastal ecosystem in New Zealand. They crop silver tussock in the inland low dunes near Cromwell and, following rabbit control on Flat Top Hill Conservation Area, there has been a proliferation of Elymus and Festuca, native grasses believed to have been formerly structurally dominant in these very dry tussock grasslands. Such plant communities would probably benefit from reductions in rabbit numbers.
Tussock Grasslands
Tussock grasslands in the conservation estate may benefit from an RCD introduction. Such benefits would depend on the extent of ongoing conventional rabbit control to minimise fluctuations but, even with minimal control, benefits may accrue.
Rabbits are often a critical factor in the maintenance of mat or scabweed vegetation in degraded tussock grassland. Rabbit reduction might result in structural change, with an eventual return of short tussocks and then tall tussocks. This would lead to an increase in grass biomass which would benefit soil health, soil microbial activity, moisture holding capacity and fertility. There could also be an increase in woody species, which would benefit conservation by allowing expansion of native scrub.
Weeds
The spread of such weeds if released from rabbit grazing pressure was a concern expressed by some of the submitters.
The possible increase in woody species due to rabbit decreases may be less likely when one considers that most shrubs require a minimum of 2-3 years to grow above rabbit browse height. Peaks in fluctuating rabbit populations may occur more often than this, preventing such woody species from maturing past their vulnerable stage. As the role of rabbits in containing the spread and density of woody weeds such as broom, gorse, brambles, briar, lupin and boxthorn is largely unknown, the proliferation of such weeds is a possible outcome that would be associated with effective rabbit control no matter what tool is used.
5.3 The integrity of indigenous ecosystems.
| If RCD was to result in prolonged suppression of rabbits there is potential for recovery of land which has been damaged by rabbits. These benefits are all contingent on prolonged suppression of rabbit abundance (an unknown), lack of overgrazing by sheep, little use of fire and some fertiliser input. Benefits may be very slow to emerge (Ecosystems). | |
| "The Otago runanga recognise that the elimination of rabbits from indigenous ecosystems would ultimately be beneficial to those ecosystems, provided that possible negative effects, such as the risk of predator-prey switching and invasion of exotic pest plants, are avoided or mitigated."(487) | |
See also section 1.2.
5.4 Valued introduced flora and fauna.
As RCD virus appears to be species specific it has not been considered to have any direct effect on introduced fauna. See section 7.1.
Valued introduced flora may be affected by a decrease in rabbits if weeds thrive.
5.5 Intrinsic value of ecosystems and ecosystem stability.
As noted in 5.3 the indigenous ecosystem is expected to benefit from the removal of rabbits. The restoration and preservation of ecosystems that have been damaged by rabbits, particularly those in the high country of the South Island, is of concern to many New Zealanders. See also section 1.4.
5.6 The health and social well being of people.
5.6.1 Risks to human health
International evidence indicates that since 1984, when the virus was first identified, it has spread to over 40 countries throughout the world, containing approximately 50% of the world’s population. During this period there have been no reports in the medical, veterinary or microbiological literature linking the virus to disease in humans or subclinical infection in humans.
For a discussion on the host range of the virus, see section 7.1.
| Human exposure levels in many countries is potentially high. For example, in France where the disease is endemic, 25,000 tonnes of rabbit meat is consumed each year. Apart from the close association that people have with the rearing of these rabbits it is likely that a proportion of this meat will be also infected. | |
| "......the numbers of contacts between people and rabbits and hares infected with either the pathogenic or non-pathogenic strains of RCD virus and European Brown Hare Syndrome in Europe and the rest of the world must be many times greater than that likely to occur in New Zealand." (Boag, B) | |
In three laboratories where people have potentially high exposure to RCD virus, serological testing has produced negative results (BRS, 1996).
There has been one challenge study with humans eating cooked rabbits which were infected with RCD virus. They were tested serologically and all tests were negative. One other person who slept in the same location as infected rabbits responded with a low antibody titre which quickly disappeared.
| A retrospective human health study in Australia conducted on 259 people with and 1013 without occupation exposure to RCD failed to detect any differences in serological reactions and incidence of sickness between the two groups. The Chief Medical Advisor, Department of Health and Family Services, based on information overseas and the Australian health study has stated (BRS, 1996): | |
| "While at this stage, there is no guarantee of human safety with respect to exposure to rabbit calicivirus, I am satisfied that the above findings do not provide evidence that rabbit calicivirus is associated with infection or disease in humans. On this basis, and with the limitations of the study in mind, I have no objections to the controlled release of rabbit calicivirus as a means of rabbit control." | |
| There was criticism of the Australian health study by submitter 1000. The submitter, after reworking the data, claimed that people exposed to RCD had a higher level of illness than the control group, but on investigation it was found that this claim was in error and the original Australian report was correct. The Ministry of Health discusses other issues raised by the submitter and notes that as no positive sera was available the sensitivity of the assay could not be assessed. Dr Michael Catton, Deputy Director, Victorian Infectious Diseases Reference Laboratory, replied: | |
| "There is no doubt that it would have been convenient to have one or more specimens of human sera containing RCV (RCD virus) antibody to prove that the test was adequately sensitive in humans. This becomes a circular argument however, as if we had such sera in our possession there would be a much less pressing need to do a study to see if RCV can infect humans and induce antibodies. We had to be content with the knowledge that the test was a highly sensitive assay for RCD virus in rabbit sera, and that there was no obvious reason why this should not be the case with human sera." | |
| In regard to potential effects on people the Ministry of Health also notes that: | |
| "there is a broad range of human hosts with a whole spectrum of immune competence. This ranges from neonates and children, through patients who are immunosuppressed from HIV and chemotherapies for malignancies. Many of these patients may be much more susceptible to infection than immunologically competent workers exposed to the virus." | |
| "There is no information either in the Application or literature provided to confirm the safety of the virus in these special groups. This is important both regarding the risk of teratogenicity and of foetal or perinatal infection." | |
| "......the best parallel for the introduction of calicivirus would be between a new vaccine or drug and a similar standard of proof of non toxicity for humans ought to be established. This has not been done and the burden of proof should remain on those who wish to release the virus to provide the positive evidence rather than purely negative evidence before approval is determined." | |
Shope finds very little scientific evidence for or against a possible effect on the human fetus and neonate and suggests that such evidence would be difficult to accrue. He does not know how one would identify, for instance, pregnant females with high exposure levels to RCD virus. It would be practical, however, to expose pregnant non-human primates and look for adverse effects. He suggests that such experiments should be considered by New Zealand.
It must also be acknowledged that visitors to New Zealand arrive everyday from countries with endemic RCD and no human health precautions are taken. Similarly New Zealanders travelling overseas are not issued with any health warnings.
The Ministry of Health concludes that:
| "While the introduction of the rabbit calicivirus appears to pose a low risk to human health, it is unable to be quantified at present given the lack of knowledge of the biology of transmission. There is a lack of confidence in the quality of the scientific data." | |
| However, Shope in considering the wider evidence notes: | |
| "Human beings in Asia, Europe, Australia, and North America have been exposed to RCV (RCD virus). Some of these exposures have been of a very high level including farmers and workers who have handled sick and dead rabbits. No convincing evidence of human infection has been presented. Serological tests were done on 259 humans in a survey of potentially exposed people in Australia; an additional 6 workers at CSIRO-AAHL were seronegative. I interpret this evidence and the negative anecdotal evidence from Europe, Asia, and Mexico, to mean that the likelihood that humans have been infected is minimal." | |
5.6.2 Social well-being of people
The effective management of rabbit populations at low and stable levels using RCD is seen by some submitters to provide real benefit to rural communities. The control of rabbits could raise stock carrying capacity and productivity, and help to raise the profitability of high country farming. The main advantage would be that the costs of current rabbit control could be diverted towards farm improvements. See also section 2.5.
Rabbits are a significant problem for some farmers and their communities and there is an expectation that RCD would bring about a significant decrease in the number of rabbits on farms with less cost. As a consequence the profitability of high country farming would be increased and these benefits would flow on into the rural community and the national economy.
There are other people who question the right of one group to expose another to unknown risks, to increased costs and even to the loss of a means of livelihood. Stoats, ferrets, and weasels were introduced in the past for rabbit control and these animals have had a devastating effect on indigenous fauna. Some submitters are concerned that the introduction of an exotic virus could also have harmful consequences.
| One submitter (97) aptly expressed a general concern this way: | |
| "I believe it is against natural justice that my neighbour (metaphorically speaking) may introduce an uncontrollable disease onto his or her farm in order to correct a problem that he/she had but that I do not. I believe my neighbour’s right to have the virus on their farm is no greater than mine to have my farm virus free." | |
5.7 The relationship of Maori and their culture and traditions with ancestral lands, water, sites waahi tapu, valued flora and fauna and other taonga. - A summary of all of the maori issues.
| The Application notes that for an RPMS: | |
| "Consultation with Iwi by regional authorities setting public policy is mandatory under the Biosecurity Act 1993 and the Resource Management Act 1991." | |
| "All regional authorities have recently prepared, or are well advanced in the preparation of Regional Pest Management Strategies and Regional Policy Statements. All regions, except the West Coast, have Pest Management Strategies incorporating issues concerning the control of feral rabbits. The preparation of these statutory based documents has involved particular consultation with the Iwi of each region. These documents have been reviewed to seek out established Iwi values and concerns regarding rabbits and the impact of rabbit control." | |
| The Application also notes that the Applicant Group have sought to consult with Maori on the proposal to introduce RCD virus. | |
| "The RCD Applicant Group has sought to inform Iwi throughout New Zealand of the issues surrounding RCD as a biocontrol. This information sharing has usually not been at the level of consultation but continues to develop. Meetings with Iwi about RCD have shown there is some concern about the reduced availability of feral rabbits as a (non-traditional) food source. However, tangata whenua are primarily concerned that any introduction of rabbit calicivirus to New Zealand should not cause an increase in predation on native fauna through the loss of rabbits as a primary food source to predators." | |
| "The summary of consultations in appendix O contains further detail on communication between Iwi and the RCD Applicant Group." | |
Between the 2-14 October, 1996 consultation hui were conducted in Whakatane, Whangarei, Hastings, Whanganui, Gisborne, Christchurch, Auckland, Hamilton and Blenheim. Over 70 people attended hui, including 14 people who spoke on behalf of their Iwi/Hapu organisations. Attendance represented Maori farmers and landowners, chairpeople and representatives of land trusts and incorporations, Maori Trust Boards, the Maori Women’s Welfare League, Marae Committees, Conservation Board members and individuals. The RCD Applicant Group and a staff member from Te Puni Kokiri were present at all meetings. DoC was represented at most meetings. The file notes and issues arising from these hui are recorded in the submission made by Te Puni Kokiri.
Modern Maori are deeply concerned about kaitiakitanga (guardianship of the land), safeguarding mauri (the protective spirit) and conserving indigenous species. Rabbits are a direct threat to these values and rabbit predators are a particular concern. Rabbits are recognised as a "real pest" on farm land. They also cause damage to taonga by digging up urupa (burial grounds) and eating cultivated plants such as pingao. Many Maori, particularly children in rural areas, hunt rabbits for sport.
While the measure, severity and distribution of impacts on Maori values are not covered in detail in the Application it is fair to conclude that Maori would prefer New Zealand to be free of rabbits and their predators - if that option existed. It appears that rabbit predators are perceived by Maori to be a more significant threat to their values than rabbits are.
There is concern about the use of poisons and the adverse effect that poisons have on the environment and people. Maori prefer shooting as a control option. This is largely because shooting is perceived as a source of employment and does not interfere with indigenous ecosystems. Biological controls would be more acceptable if they originated in New Zealand.
Concern was expressed that changing predator-prey relationships due to sudden rabbit depopulation could lead to loss of indigenous species regarded as taonga by tangata whenua. From Te Puni Kokiri’s perspective predator-prey issues need to be given high priority and DoC must have the capability and the resources to put protection measures in place should the virus be released.
The possibility that the virus may change and harm people was also raised and it was accepted that these issues would be addressed by the Ministry of Health.
Maori are wary about viruses, as ‘foreign’ diseases like influenza have caused significant suffering and death in the past.
Some Maori were worried that the virus may change and infect animals or that animals that ate RCD infected rabbits would also become infected. It was accepted that advice would be sought on host range and virus stability from independent virologists but it was considered important that the views of virologists such as Professor Alvin Smith were taken into account. There was a request made for a quantification of the risk of the virus changing and losing its host specificity. (See section 7.)
The question was often raised at hui of who would take responsibility for compensation for adverse effects on people, other species, or indigenous flora and fauna. There was also concern about who would pay for the vaccination of domestic rabbits.
In respect to the question about the introduction of RCD virus, most Maori were circumspect and requested a precautionary approach, recommending that either New Zealand should wait and see what happens in Australia, or not permit the introduction.
5.8 The use and enjoyment of the public of lands and waters to which they have right of access.
Submitters have raised the issue of the effects of rabbit carcasses generated by mass destruction of rabbits on public health and "nuisance" covered by the Health Act 1956. If such nuisance coincides with human habitation, access or water supply, then the presence of dead rabbits may contravene this Act. While this issue was raised in respect to the possible massive numbers of dead rabbits due to RCD it also applies in principle to the present poison applications. In areas where this is likely to be a problem some effort to dispose of carcasses should be part of the control programme.
5.9 Domestic rabbits including laboratory colonies.
See section 6.2.
5.10 People and enterprises based on controlling wild rabbits.
Impacts on professional rabbit control operators are not addressed in the Application.
Essentially, submitters agree that the advent of RCD could undermine the basis of a range of enterprises that are currently related in a general sense to the control of feral rabbits. Various submitters point to reductions in opportunity for:
- operators involved in large-scale poisoning, usually aerial poisoning (e.g. bait growers and aircraft operators);
- professional game shooters;
- licensors and firms providing equipment to recreational hunters.
One supporting submitter from a firm involved in selling pest control equipment, notes that they have already experienced a significant loss of sales, which they attribute to a downturn in pest control efforts by regional councils, in the expectation of RCD.
The Biosecurity Act provides that when the rabbit has been declared a pest in an RPMS, the issue of compensation for any businesses associated with or dependent upon rabbits shall be dealt with in that RPMS. Existing RPMS’s state that no such compensation shall be paid.
5.11 People and enterprises based on harvesting wild rabbits.
| Harvesting of feral rabbits encompasses the taking of rabbits, dead or alive, for private consumption, pet food manufacture, or processing for domestic consumption or export, which may involve meat, fur or other rabbit products. A submitter’s comment on one harvesting scenario: | |
| "Commercial harvesting provides the opportunity for farmers to contract with a rabbiter and obtain the level of control he requires on his property or to comply with the regional pest plan provisions. The harvester will receive his primary income from the resource recovery but will receive a contract top up fee where he is required to continue working a particular property beyond the time when the catch rate has fallen below a profitable level." (531) | |
The Application considers the release of RCD would eliminate the opportunity for commercial rabbit harvesting of feral rabbits, for either human consumption or pet food manufacture, because reduced rabbit densities may increase the costs of supply to a level that is not economically sustainable. The Australian experience is that the escape of RCD closed most commercial rabbit harvesting enterprises affecting the owners and independent shooters and processors.
Attitudes to the rabbit harvesting industry are highly polarised. Numerous supporters of RCD claim that the potential role of the rabbit-harvesting industry is both exaggerated and mis-represented. Submitters assert that rabbit processing operations do not control rabbit numbers.
| "Since 1993 there has been some commercial harvest. However, properties which are being regularly harvested for commercial gain, are still being issued with enforcement notices by Regional Councils as rabbit numbers are above levels which cause environmental damage. The simple reality is that returns from commercial harvest are not sufficient to encourage hunters to maintain rabbits at acceptable levels. The financial returns from rabbit harvest would have to be significantly higher before acceptable levels of control would be achieved." (555) |
Ten rabbit processing facilities produce meat for pet food. The only licenced feral rabbit processing facility producing meat for human consumption has been in operation as a pilot plant since 1995. In just under 12 months total sales value of processed rabbit has been $1.36 million. They claim that demand for product is increasing. There is also a small industry for harvesting farmed rabbits. The largest plant processes approximately 1,000 farmed rabbits a week for the restaurant and hotel trade, while several smaller plants supply similar products.
| Many submitters opposing RCD assert that its introduction would have severe implications for the fledgling industry based on such a potentially valuable food resource. Citing an export order for one million rabbits per week one particular submitter claims: | |
| "Such an industry cannot establish without a guarantee that RCD will be kept out of New Zealand."(135) | |
A number of submitters point to the loss of jobs that would accompany the introduction of RCD - jobs at existing rabbit meat processors and pet food manufacturers, as well as professional hunters. Looking further into the future, several other submitters anticipate a consequent loss of skills, which would or could have cost implications for both the DoC and for farmers. This assumes that RCD would be effective.
Submitters were critical that the Application failed to assess the commercial opportunities for rabbit products from a virus-free country, and that there was no consideration of compensation for this loss of opportunity. The commercial viability and sustainability of rabbit harvesting is questionable in the absence of a full analysis. It would be likely to require effort and financial input to establish large enough overseas markets for rabbit products (Macaulay).
It is possible that commercial rabbit harvesting enterprises could be severely affected and that rabbit owners and rabbit farmers could incur additional costs in protecting rabbits from the disease.
5.12 International trade.
Opponents of the Application are critical of what they see as the narrow and short-sighted nature of the assessment of trade impacts. Several submitters raised explicitly, the potential longer-term implications for the meat, dairy and poultry industries should the virus ultimately mutate into a form that can infect livestock. (See section 7. for a discussion on the probability of host change.)
In the shorter term however, despite the perceived risk that non-tariff trade barriers could result from the introduction of RCD, with the exception of a feral rabbit meat processing plant, all meat producers contacted by the Ministry of Commerce expressed no concerns about market impacts.
It is likely that this small pilot plant exporting feral rabbit meat for human consumption would expand if RCD was not introduced into New Zealand.
Many submitters opposing RCD draw attention to what they see as the large potential for New Zealand to export rabbit products such as meat, skins and fur. They point to the high prices in Europe for organic feral rabbit meat, the perceived huge demand in China, that is well beyond the present capacity of NZ exporters, and the demand for skins in India and skins and meat in other Asian countries.
The biotechnology industry is involved with the sale of high value products which are in demand overseas because they come from a disease-free environment. The industry urges caution, since this sector of trade would be jeopardised to some extent by the arrival in New Zealand of another virus infection such as RCD.
Supporters of RCD take the view that much of the world’s population lives with RCD already. Since the virus has been in many European countries for over a decade, its introduction into New Zealand is hardly likely to have an impact in the minds of Europeans.
The Office International Des Epizooties (OIE) classes the disease as belonging to "List B" which means that it is a transmissible disease considered to be of socio-economic and/or public health importance and significant in the international trade of animals and animal products. This reflects on the economic importance of rabbit farming. RCD is identified as a foreign animal disease in North America.
It is anticipated that the only direct trade consequences from the release of RCD in New Zealand would be a reduction in the production of rabbit products, especially rabbit meat for human consumption.
5.13 International standing or mana in relation to clean green image.
Submitters are polarised on this issue. In general, submitters in support of RCD believe that its introduction should help New Zealand’s image and trade prospects because it is considering the introduction of a biological control to kill an introduced pest which is causing environmental, social and economic destruction. Some saw the introduction of virus as an opportunity to reduce the use of poisons such as 1080 and pindone.
Opponents comment generally on the threat to the "clean and green" image. Some focus particularly on the importance of maintaining this country’s relative disease-free status, while submitter 673 asserts that any action in New Zealand that led to extinctions of further species would badly affect the country’s standing in world conservation. However, New Zealand is losing the battle of retaining its unique species and it is unknown whether the introduction of RCD would help the preservation of these species or hinder it. See section 6.1.
Conclusion
It is not possible to predict the indirect effects of the virus on indigenous flora and fauna because it is not known how the virus would behave in New Zealand.
The Ministry of Health consider that the virus poses a low risk to human health but have some reservations because there is little known about the behaviour of the virus. However, the virus is widespread in more than 40 countries and no convincing evidence of human infection has been presented.
Rabbits are a direct threat to certain Maori values and are recognised as a pest. However, the potential loss of indigenous species through predator prey switching is of greater concern and because of this Maori want protection measures to be given high priority.
It is likely that commercial rabbit harvesting enterprises would be possibly severely affected by an introduction of RCD virus.
The potential to export products from the biotechnology industry could be affected to some extent by the arrival in New Zealand of another virus infection such as RCD.
Contact for Enquiries
Manager, Strategic Science Team
MAF Biosecurity New Zealand
PO Box 2526
Wellington
NEW ZEALAND
Phone: +64 4 894 0115
Fax: +64 4 894 0731
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