EXECUTIVE SUMMARY

Prepared by Taylor Baines & Associates for the Chief Veterinary Officer MAF Regulatory Authority

20 December 1996

INTRODUCTION

1. - This report summarises public submissions to the Chief Veterinary Officer on the Application to the Director General of Agriculture to approve the importation of rabbit calicivirus.

2. - The report describes the issues associated with importation of RCD from the perspective of submitters. It is based on a content analysis of 751 submissions, grouped according to the stance they express in relation to the importation proposal.

ISSUES CONCERNING THE OVERALL APPLICATION PROCESS

3. - There is a high level of concern about various aspects of the overall application process.

The character of the decision-making process

4. - It would appear from submissions that supporters of the application accept the intended decision-making process. Opponents of the application point to three main issues:

  • the lack of a clear decision-making framework;
  • the treatment of risk; and
  • the suitability of various legislative decision-making frameworks.

5. - Many opponents highlight the absence of any systematic risk assessment in the IIA, with some focussing on assessment of comparative risks, others on defensible methodology, and others on the application of risk/benefit analysis to conservation impacts.

6. - Many opponents challenge the suitability of the legislative framework. The essence of their argument is that the Animals Act 1967 and the Biosecurity Act 1993 are inadequate for dealing with an importation noted for its uncertainty of effects, irreversibility and national significance. Many suggest that the HSNO legislation, which is progressively coming into effect, provides a more appropriate statutory basis for decision making; one that incorporates an independent decision making authority, an open public process, and the concept of minimum standards of acceptable risk. There is some acceptance on the part of opponents that the decision making process chosen for RCD is more open than previous processes for considering the importation of new organisms.

Conflicts in Science

7. - Many submissions, the vast majority opposing the introduction of RCD, draw attention to the existence of conflicting views within the scientific community, noting particularly criticisms of the Australian research programme on which the Application is based, the treatment of overseas expert opinion which warns of the dangers of RCD, and the restricted input from the wider scientific community in New Zealand.

8. - A few supporters express concern at the possible impact of conflicting scientific viewpoints on public attitudes and consequently on the decision.

9. - Quite a few opposing submissions urge caution in the face of unresolved uncertainties, some noting the evident fallibility of scientific advice in comparable situations in the past.

Concerns over the roles of various parties

10. - Some opposing submissions are critical of what they see as a biased role by MAF in the application process, pointing to the Ministry’s association with publicly-funded background research into the virus in Australia, its management of the peer review and public consultation processes, and public comments from various MAF staff which have been taken to indicate a prejudiced stance by the Ministry towards this Application.

11. - Comments on the role of the peer review panel, although relatively few in number, come from both ends of the spectrum. Supporters express satisfaction over its expertise and capacity to sort through conflicting evidence, while opponents are critical that its Terms of Reference geared it towards ‘fixing up’ the Application, rather than taking a more neutral stance.

The approach to public consultation

12. - Of all the concerns expressed about matters of process, commentary on the approach to public consultation is the most frequent. With a few exceptions, comments are all from people opposed to the Application. Taken together, they embody some very strong criticism of the process, with particular focus on:

  • obstacles to participation in the submissions process;
  • criticisms of the Applicant;
  • criticisms of MAF; and
  • criticisms of the submissions analysis process.

13. - Many submissions are critical of what they see as administrative obstacles to participation in the public submissions process - the timetable, the access to and cost of technical documentation, non-receipt of documentation requested, and the failure to hold public hearings.

14. - The Applicant comes in for criticism on three grounds - failure to consult adequately with iwi groups, perceived bias in their dealings with other parties during the consultation, and perceived bias in the information they presented in the information kit.

15. - A few submissions are explicitly critical of MAF for what they see as withholding information during the public consultation process.

16. - There is some comment critical of the process of submissions analysis, particularly the limited timeframe, the anonymity of those commissioned to do the work, the criteria for analysis, the exclusion of Peer Reviewers’ reports, and denial of an individual submitter’s right to be heard in person.

17. - Several opponents either cite legal precedents for adequate consultation, or indicate grounds for judicial review.

Aspects of timing

18. - The nature of concerns about time and timing show a clear trend from urgency and impatience toward increasing caution, as the stance shifts from unqualified support through to unqualified opposition.

Other aspects of the context for decision making

19. - Other comments, from the diverse range of submitter perspectives, raise issues related to:

  • individual entitlements not to be exposed to virus-related risks;
  • farmers’ expectations for a favourable decision on RCD after the refusal for myxomatosis;
  • conflicting messages over the acceptability of introducing new organisms;
  • matters of precedent - past and future;
  • government responsibility - mandate, credibility and liability;
  • the international context - comparison with what other countries are doing; and
  • the significance of the Australian release and consequent experiences.

SUMMARY OF RESPONSES TO THE PROPOSAL
All responses

20. - Out of 751 submissions, fifty per cent are opposed to the application, forty-three per cent support it, and seven per cent do not state a clear preference either way. The submissions are highly polarised, with the vast majority expressing unqualified positions of support or opposition.

21. - On the basis of total signatures, the balance shifts slightly towards the opposing view. Fifty-seven per cent are opposed to the application, forty per cent support it, and three per cent do not state a clear preference either way. The degree of polarisation remains.

22. - Organisations with statutory responsibilities, and scientific organisations display much lesser degrees of polarisation, with more expressing qualified positions.

23. - Interests in landholding predominantly express unqualified support, those with interests in environmental protection, fishing and hunting, rabbit breeding and rabbit farming, animal farming predominantly express unqualified opposition.

24. - Submissions made in an individual capacity are highly polarised.

25. - Geographically, the only regions not predominantly opposed are Canterbury (polarised), Otago (predominantly in support) and Southland (polarised). These three regions are all represented in the Applicant Group.

THE RABBIT PROBLEM

Nature of the problem

26. - In submissions from the farming community, the problem is sharply focussed on the rabbit as a national pest that has hindered sustainable land management for more than 100 years, and now affects farming, tourism, recreation and conservation values. It is a question, not so much of how to control, but how to afford that control. Without all available tools - including biological controls such as RCD - to make control efforts effective and financially viable, current expenditure cannot be continued, risking the prospect of failure to comply with regional pest management plans and the Biosecurity Act.

27. - For supporters, the problem is seen as having been compounded in recent times by economic factors such as restructuring, withdrawal of central and regional government from rabbit control, loss of subsidies and monetary policy. There is also the technical issue that the dominant method for large-scale control in some parts of the country - the use of 1080 poison - cannot be relied upon to remain effective for ever. It is suggested that, even with past technical innovations in control methods, the hard core problem areas are expanding.

28. - Some opponents suggest that RCD is being considered for purely economic reasons, at the behest of a small lobby group, and that the government needs to address the rabbit problem in several broader contexts:

  • other pests such as possums and gorse and the development of a national pest control strategy; and
  • sustainable land management uses and practices.

29. - Opponents focus on the boom-bust cycles of the rabbit problem and the tendency to seek short-term fixes, as well as the mixed levels of commitment in the farming community to the full range of primary and secondary control methods, already contributing to the problem.

30. - Supporters focus on the links between individual properties and the wider rural economy and community. Falling incomes will be insufficient to continue rabbit control, land will be destroyed and farmers and their families forced off the land, with the impacts flowing on to rural communities and wider economy - less farm labour, less demand for agricultural services or local community services such as schools.

31. - Supporters highlight links between overgrazing by rabbits and Hieracium spread, soil erosion and impacts on water.

32. - Of all areas of discussion, the nature of the rabbit problem drew the most frequent comments. Views are highly polarised in some respects, with supporters and opponents casting the problem in very contrasting ways. There are, nevertheless, some points where the contrasting arguments do merge.

33. - There is general agreement that rabbits contribute to significant environmental damage, and that there are environmental benefits to be gained from more sustainable land management. However, when looking at the immediate causes of this degradation, supporters tend to focus exclusively on rabbits and assert that, without high rabbit numbers, pastoralism will once again flourish. In contrast, opponents point to the dual influences of rabbits and farm animals and ask whether pastoral farming is sustainable as practised.

34. - Although the language and perspective is quite different in each case, both supporters and opponents appear to agree that the financial prospects for pastoral farming in rabbit-prone areas are not promising, although for supporters this view carries the important caveat - so long as they are denied biological control. On technical aspects of the problem, supporters focus on the inadequacy of the existing suite of control methods, while opponents focus on the view that not all farmers are equally willing to commit themselves to using all the methods available.

Severity and distribution of the problem

35. - Supporters claim that rabbits are much more than a high country problem, certainly one that extends to the drier East Coasts, but also to areas such as Southland. Although the Mackenzie Basin and Central Otago are clearly identified as the main problem areas, other areas such as sand country in both islands are seen as threatened. Drought tends to extend the prone areas. There are some areas where the rabbit is acknowledged not to be a major problem, such as Auckland and Tasman-Nelson. Specific problems are seen outside pastoral farming, such as for young forestry plantings, new vineyards and golf courses.

36. - Opponents argue strongly that the rabbit problem is a localised problem, largely confined to parts of Otago, Canterbury and Marlborough, and that even then rabbits have largely been brought under control in these areas by improved methods and organisational structures, and the activities of the RLMP. Some claim that only a handful of properties are seriously affected.

Rabbit control

37. - Many supporters of RCD question the effectiveness of current methods of control. To them current methods such as aerial poisoning and shooting are only holding their own, at best. They see few if any new tools in recent years. In contrast, many opponents argue that existing methods can achieve control.

38. - Poisoning with 1080 is seen by supporters and some opponents as being limited by increasing concern about its environmental effects. Supporters also view the decreasing length of the primary poisoning cycle as a major concern, with some poisoning failures due to bait shyness or poison aversion. Reinfestation from neighbouring properties can cause problems. There is some agreement among submitters that a variety of methods can be effective as secondary control measures. These include Pindone poisoning, night shooting, and helicopter shooting, with all measures assisted by rabbit fencing. But supporters argue that there are technical and environmental constraints. And some environmental and welfare constraints are noted by opponents of RCD.

39. - Supporters of RCD contend that the biggest problem with existing methods of control is cost. Many submissions contend that farms are finding it difficult to afford rabbit control, either primary or secondary. The new user pays system is seen by many as untenable. To them, RCD will provide an opportunity to "break the cycle" of high control costs and reduced productivity. It also has the potential for "blanket" control across whole farms, and districts. To opponents, existing methods will suffice.

40. - RCD is clearly the preferred alternative method of control for supporters. They see few new opportunities for existing or any other methods. In contrast, numerous opponents consider that existing methods could be used more extensively, and intensively, with more effort by farmers. They often advocate these labour intensive methods for the employment that they could create. To them shooting has the advantage of being a selective method as well. The return of bounties is advocated by many, as well as more commercial harvesting, with markets seen for a range of rabbit products. It is suggested that a reproductive disease be investigated. They also criticise land management practices that encourage rabbits, calling for better integration of rabbit and land management research, land development and the development of unfavourable habitat, and land use changes such as forestry. A return to organisation of control by "pest boards" is advocated by some.

THE VIRUS AND ITS EPIDEMIOLOGY

RCD as a biocontrol agent

41. - A large number of submissions discussed the effectiveness and suitability of the rabbit calicivirus as a biocontrol agent in New Zealand. Both supporters and opponents of the importation of the virus contributed to this debate. The main areas of concern were:

  • the safety or otherwise of the virus;
  • assessments of its effectiveness and suitability as a biocontrol agent;
  • its ability to maintain stated pastoral and environmental goals over time;
  • its use with other methods of rabbit control;
  • the history of importing other organisms into New Zealand; and
  • the irreversible nature of the virus's release in this country.

42. - Discussion about safety, effectiveness and suitability of RCD as a biocontrol agent was very polarised. Supporters emphasised their belief in its safety and referred to a wide range of advantages and benefits for the nation. By contrast, opponents questioned its safety, and identified the disadvantages and costs of its introduction.

43. - Opponents expressed concerns about its temporary nature and the development of immunity by a section of the rabbit population. Supporters recognised that biocontrol is not the complete solution to their problem and advocate its use with other methods of rabbit control. Many opponents refer to the negative experiences of importing other organisms into New Zealand, and others noted the irreversible nature of the virus's introduction.

The propensity for mutation

44. - Views regarding the propensity of RCD to mutate were widely divergent. The main areas of concern were:

  • the propensity for mutation;
  • changes in host range;
  • the damaging effects of mutation and host switching; and
  • the adequacy or inadequacy of scientific knowledge about the propensity of RCD to mutate and change hosts

45. - Supporters view the risk of mutation as unlikely, although those who took a qualified stance had reservations about its propensity to mutate. Opponents, however, assume RCD is likely to mutate. Opinions regarding the changes in the host range were as deeply divided as those about mutation. Supporters generally dismissed or minimised the risk of RCD jumping or crossing species, while opponents highlighted the risks.

46. - Supporters, who specifically cite the IIA’s discussion of the scientific evidence on RCD's propensity to mutate and change host, accepted its adequacy. Most comments on this issue came from opponents, however, and they were reluctant to accept that this was the case.

Host range

47. - A large number of submissions discussed the issues associated with the host range. The main areas of concern were:

  • the host range;
  • the laboratory studies of the host range;
  • the merits of field studies of the host range compared with laboratory studies; and
  • the validity of conclusions regarding the host range which were derived from a review of the scientific literature.

48. - Comments by supporters varied from apprehension about the safety of other species to assurances that the virus is host specific. Opponents expressed dissatisfaction with the scientific data about host specificity in the IIA.

49. - The laboratory studies of the host range conducted in Australia attracted a lot of criticism from submitters. These criticisms included some rigorous critiques of the tests on kiwis, bats, and other animals. Some submissions noted the merits of field studies, and others challenged the validity of conclusions about the host range derived from a review of the scientific literature.

The virus's ability to survive

50. - Very few submissions commented on the survivability of the virus and nearly all of them were from the opponents of importation. The main areas of concern were:

  • the tolerance of the virus to heat, cold and desiccation; and
  • the survival of RCD in the faeces of grazing and scavenging animals, and dogs.
The virus - classification, history, origins

51. - A large number of submissions discussed this subject with the majority of them being from the opponents of importation. The main areas of concern were:

  • the description and classification of the rabbit calicivirus;
  • the strains of the rabbit calicivirus;
  • the origins and history of the virus;
  • comparisons with other viruses of the same family; and
  • the adequacy or inadequacy of scientific knowledge about the rabbit calicivirus.

52. - Some submissions dispute the description and classification of the rabbit calicivirus as presented in the IIA and suggest other terms (e.g. RVHD, RHD, RHDV) as being more appropriate. The origins and history of RCD generated a lot of discussion by opponents, and many consider its uncertain origins and brief recorded history as reasons for a cautious approach to its introduction.

53. - Only a few submitters discussed the strains of the rabbit calicivirus or compared it with other viruses of the same family. The issue of the adequacy or inadequacy of scientific knowledge about RCD was discussed by a number of submiitters. Although the majority of the comments on this subject were made by opponents who felt the existing scientific knowledge was limited, most supporters considered it was adequate.

Virus effects on the host

54. - Only a small number of submissions commented about the effects of the RCD virus on the target species and the effects in host species. Most of these submissions were from opponents of its importation. The main areas of concern were:

  • the effects on target species - limited because of immunity;
  • the effects in host species - the possibility of switching; and
  • the inadequacy of the information on epidemiology.
Immunogencity

55. - Few submissions addressed matters related to immunogenicity. Most of these were from opponents, whose main concerns were:

  • the effects of immunity on rabbit populations; and
  • the types of antibodies and the role of other components of the immune system.

56. - Most submitters raised the possibility of a younger cohort of the population becoming immune to RCD and a return to high levels of rabbit infestation. One submitter noted that the IIA and other published literature on the rabbit calicivirus did not investigate the types of antibodies or the role of other components of the immune system.

Spread of the disease

57. - Most submissions on this topic were from opponents. The main areas of concern were:

  • the expected behaviour of the disease in New Zealand;
  • the behaviour of the disease in other countries;
  • the lack of parameters or patterns for the spread of the disease under field conditions; and
  • uncertainty about the spread of the disease.

58. - Submitters expressed fears that the effects of the virus would neither be confined geographically nor to rabbits. Some opponents drew upon overseas experience to emphasise its unpredictability and uncontrolled nature, while others note that environmental differences between NZ and other countries prevent any accurate assessment of its possible behaviour here.

59. - Other submitters discussed the lack of parameters or patterns for determining the spread of the disease. Opponents voiced concerns about the uncertainties associated with its spread with some calling for a cautious or "precautionary" approach to its introduction.

Methods of transmission

60. - A small number of submitters (mainly opponents) discussed issues about vectors and the methods of transmission. For opponents, and a few supporters of introduction, the main area of concern is the lack of scientific knowledge about the vectors and methods of transmission of the virus.

THE PROGRAMME TO RELEASE RCD

Accidental or unofficial release of RCD

61. - Both supporters and opponents comment on these issues. The main areas of concern were:

  • the risk of an uncontrolled release;
  • planning for and management of an uncontrolled release; and
  • the prevention of an uncontrolled release.

62. - Supporters accept the inevitability of the virus's arrival in NZ and claim that a controlled release is in the interests of everyone. They maintain that, if an outbreak occurs, the responsible course is not to contain it, but to establish protection of domestic rabbits and predator controls where there is a risk of prey switching.

63. - Some opponents state a preference for a managed programme, although many of them also assert that the belief that the virus will arrive any way (after an accidental or unofficial release) is no ground for accepting the present Application. They suggest it is the responsibility of the government to prevent the accidental or unauthorised entry of RCD and to prepare contingency plans.

Goal, Character and Organisational Base

64. - In addition to submitters with clear stances on both sides, a number of people with qualified stances for and against RCD comment about the nature of the programme. The main areas of concerns were:

  • definition of the goals and objectives of a release programme for RCD; and
  • discussion of the likely character and organisational basis of the programme.

65. - Supporters indicate that the broad goals of the programme are to provide long-term benefits to sustainable land management with flow-on benefits to farm families, the rural and national economies through improved exports. They expect the improved and more cost effective control to be used alongside existing techniques and experience to achieve improved productivity and more sustainable land management.

66. - Opponents maintain that the goal appears to be a "quick fix" that will benefit a small group temporarily. They are concerned that any reduction in rabbit numbers should be effective in the long term.

67. - Supporters prefer the virus to be introduced legally by the Applicant Group, with a coordinated and well managed strategy which combines the efforts of individual farmers with those of regional councils and others. Those who give qualified support suggest a programme that requires farmers to change their management practices to allow the degraded land to recover.

Deployment of the virus: source, entry, multiplication and spread

68. - The main areas of concerns were:

  • the timing of any release;
  • the source, multiplication and containment of the virus; and
  • a strategy for deployment and spread of the virus that maximises its effectiveness.

69. - Most supporters want the virus to be introduced as quickly as practicable. Qualified supporters suggest a delay to arrange a management programme, while those who qualify their opposition want a longer delay to learn from the Australian experience. Opponents urge a "precautionary approach" at least until the Australian experience is fully realised.

70. - Only a few submissions comment on the purity of the virus, with opponents being concerned that other diseases may be introduced with RCD. Opponents also consider that in view of what has occurred in Australia there will be no way of containing the disease once it is released, and several call for a contingency plan.

71. - Supporters generally endorse the release strategy as outlined in the IIA, but they want a controlled release which will maximise the kill effect. One supporter has reservations about the timing of the release as proposed in section 5.4, and suggests it be rescheduled for March-April when there are fewer rabbits to survive the infection. There are also a number of suggestions from supporters about the initial sites for release.

Integration with other control measures

72. - Both supporters and opponents contributed to this debate, with submitters having a qualified stance emphasising the need for an integrated approach. The main issues were:

  • the importance of followup control work; and
  • integration of the diverse objectives of the programme.

73. - Supporters recognise the importance of follow up work after the release of RCD. Farmers consider that the reduced costs of primary control will allow them to undertake more secondary control. Opponents, however, question whether farmers have a real commitment to an integrated approach. They also ask if the required planning has taken place to ensure the RCD release will be integrated with other control actions and monitoring procedures.

74. - Submitters with qualified positions propose that following the release of RCD the maximum opportunity should be taken to improve both production and conservation. Others note the need for predator control, an integrated land management programme, and the continued involvement of central and local government with pest management strategies.

Programme monitoring

75. - Comment on this topic came from both supporters and opponents, and a high proportion of submitters with qualified stances indicating that there is some common ground. The major concerns were:

  • monitoring to maintain an overview and detailed information on the rabbit problem; and
  • monitoring and research for programme management.

76. - Both points of view recognise the value of monitoring and agree that adequate funding needs to be available for monitoring work. Supporters making the point that it is necessary to ensure people don't forget about rabbits, and opponents concerned that farmers take full advantage of a reduction in rabbit numbers to restore the land.

Programme economics and finances

77. - here are a number of submissions from both sides of the debate. The main concerns were:

  • the need for a full cost benefit analysis of the proposed programme;
  • the financial underpinnings of the programme and who should pay; and
  • the financial basis for mitigation measures.

78. - Many supporters note the benefits of RCD to farm families, the rural economy and the environment, and maintain that they have been understated in the IIA. While opponents acknowledge some of those benefits, they also identify a number of possible costs. A number of them point out that the application has no cost-benefit analysis and maintain that this should be undertaken.

79. - Opinions on the source of the funding of the release programme differ. Some view the rabbit as a national problem requiring government funding. Other likely sources identified by submitters are the applicant group, MAF, and the regional councils. For some submitters it is a farmer problem, and they maintain that the agriculture sector should pay. Another suggestion is that the costs should be apportioned between the major stakeholders.

80. - Many opponents focus on the need for DOC to have extra funding for the work needed to protect areas where native species are at risk from prey switching by predators. There are also concerns that additional funding is made available for monitoring, mitigation and field and laboratory research. Opponents argue that the costs of mitigation strategies should be borne by farmers, and not by DOC which already has a limited budget.

ISSUES CONCERNING THE EFFECTS OF THE INTRODUCTION

81. - Of all the sets of effects discussed in this section of the report, ecological effects attracted by far the highest level of comment.

Effects on New Zealand Flora and Fauna

82. - The themes that elicited most attention are the scientific uncertainty and state of knowledge, the particular susceptibility of bird species, and various issues to do with the indirect effects on flora. In most cases views are polarised, but not invariably so.

83. - Views on scientific uncertainty and the state of knowledge are very polarised. Opponents emphasise the inadequacy of the present knowledge base and the negative impacts of previous introductions of exotic species, while supporters hold the view that present research is adequate and dispute the benefits of further research. Those in between the extremes argue for time to observe the Australian experience.

84. - It is only opponents who suggest that some bird species are potentially more vulnerable to RCD infection.

85. - There is an expectation, common to all perspectives, that some weed species will prosper with the reduction of rabbits, particularly woody weeds. Opponents appear more concerned about the ecological impacts of such trends while supporters emphasise the productive benefits and reductions in erosion and Hieracium. Nevertheless, there is some agreement across stances that control of woody weeds will be necessary.

Predator issues

86. - Predator issues elicited even more comment than did concerns about the direct effects on flora and fauna. Furthermore, there is far more consensus on some of these issues than elsewhere in the wider debate about ecological matters.

87. - There is some agreement between supporters and opponents over the existence of potential prey-switching problems and the need to do something to combat it. There are very many farmers who put considerable emphasis on the potential synergy between controlling rabbit predators and reducing Tb in their herds, and very little contradiction of this by opponents. Also, some of the comments about responsibilities for predator control suggest a degree of common ground between supporters and opponents.

88. - As part of the extensive commentary on prey switching, particular attention is given, mostly by opponents, to various characteristics of the problem - oscillatory patterns preventing stable ecological balances; unpredictability, timing and duration; predator guild changes - and to various outcomes of the problem - difficulties in controlling predator populations and possible species extinctions.

Public health effects

89. - Views are very polarised and most comments come from opponents.

90. - A theme running through submissions which oppose RCD is the need for high standards of evidence when dealing with something which is irreversible and has the potential to affect many people.

91. - Other cautions include a strong challenge to scientific logic based on the absence of contradictory evidence, the absence of expert consensus about the effects of RCD on humans, and the inadequacy of anecdotal evidence when considering public health effects.

92. - Many submissions convey a sense of skepticism about public assurances on the risks of exotic viruses, referring to recent experience with ‘Mad Cow Disease’, and other similar events. Comparisons with other caliciviruses, the Hepatitis E virus and ‘emerging viruses’ in general reinforce this skepticism amongst those who have made enquiries.

93. - The approach to testing for human health risks is criticised on several grounds: firstly the absence of a planned, positive programme of testing, and secondly the failure to distinguish between adult humans and foetus/neonates as distinct classes of risk.

94. - Farmers who support the introduction of RCD do not anticipate any risk from possible direct exposure to the virus, although there are a few opponents who do not share their confidence. Other submissions, of no particular stance are also divided on this risk. In terms of public confidence over the perceived risks to human health generally, opinion is highly polarised.

Effects on Maori

95. - This topic did not attract much comment overall, although the comments generally reinforce the view that potential effects have been inadequately addressed in the IIA. (Lack of iwi consultation was noted earlier).

Effects on enterprises based on controlling wild rabbits

96. - There was a low level of comment on this topic, but a high degree of consensus - that the advent of RCD would undermine the basis of a range of enterprises that are currently related to the control of feral rabbits.

Effects on the harvesting of feral rabbits

97. - There was a moderately high level of comment on rabbit harvesting, with very polarised attitudes evident.

98. - Supporters of RCD claim that the potential role of rabbit harvesting is both exaggerated and mis-represented; that on the basis of experiences to date, rabbit processing operations do not help with the control of rabbit numbers, and have struggled to survive even in heavily infested areas. They suggest that it is neither farmers nor market uncertainties that are the biggest obstacles to commercial rabbit harvesting, but the fact that they would find it difficult to comply with the requirements of the Resource Management Act and the Biosecurities Act over standards of pest control.

99. - Opponents of RCD have the view that farmers and some public agencies are locked into a mind-set about rabbits as pests and seem unwilling to view them as a possible source of protein and other products, thus creating obstacles to the proper establishment of the industry.

100. - In between these extremes, a couple of submissions which express qualified support for RCD also show sympathy for the white meat industry and commercial rabbit farmers likely to be affected.

101. - Many submissions opposing RCD assert that its introduction will have severe implications for the fledgling industry based on such a potentially valuable food resource and are critical that the IIA has failed to assess the commercial opportunities for rabbit products from a virus-free country.

Effects on international trade

102. - Frequency of comment is moderately high, representing polarised views. The issues cover four main themes:

  • the likely perceptions regarding New Zealand’s image overseas;
  • the direct trading impacts for established exports;
  • market opportunities for feral rabbit products; and
  • the circumstances regarding RCD that prevail in other countries.

103. - Supporting submissions adopt a perspective of comparing perceptions of RCD with existing control technologies, focusing their attention on the potential downside of continuing to use existing control methods that put a lot of 1080 poison and lead shot into the environment. They also suggest that failure to control rabbit plagues will not enhance our international reputation for caring for the environment, and that New Zealand stands to be seen as ecologically responsible if it introduces a biological control to kill an introduced pest which is causing environmental, social and economic destruction.

104. - Opponents point to several aspects of the image they see as being vulnerable: the importance of maintaining this country’s relative disease-free status; the view that this country’s meat exports are already vulnerable to interruption by disease risks without introducing any more disease, and that any action in New Zealand that led to extinctions of further species would badly affect the country’s standing in world conservation.

105. - In terms of direct trading impacts, supporters of RCD describe aspects of marketing and competitive advantage for the traditional agriculture sector, including the expected benefits for meat producers of reducing the incidence of Tb in New Zealand, and the potential benefits from changes in stock condition enabling New Zealand to get an edge on its competitors.

106. - Opponents of the application are critical of what they see as the narrow and short-sighted nature of the assessment of trade impacts, particularly its failure to assess impacts on the biotechnology industry (the products of which are in demand overseas because they come from a disease-free environment), tourism in general, and rural tourism in particular. Some submissions raise 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.

107. - Many submissions 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, claiming that rabbit meat is amongst the lowest cholesterol white meats available, and pointing out that some countries have already banned rabbit products from countries where RCD is established.

Animal welfare concerns

108. - The frequency of comment on animal welfare is moderate; the comments are again very polarised.

109. - Opponents assert variously that shooting is a more humane method, that fertility control would be more humane, and that just because RCD might be viewed as less inhumane than myxomatosis, this does not mean that it is acceptably humane.

110. - Based on their first-hand experience of rabbit killing, some supporters of RCD present a very different picture, suggesting that RCD is more humane than shooting, and that rabbits appear to die quietly from RCD compared with what they describe as a quick but painful death from 1080 poisoning.

Concerns for domestic rabbits

111. - The frequency of comment is moderate with most comments from opponents of RCD.

112. - Many submissions state their objection to the the distress that pet owners will experience if their pet dies from the disease. The risks of cross-infection, it is argued, will lead to a situation where showing rabbits will become virtually impossible.

113. - The impacts on breeders and rabbit farmers are described as being both financial and logistical. There is always the risk that RCD could decimate the limited gene pool for rabbit breeders in this country. It is also claimed that because of the high infectivity of RCD, any infection of domesticated rabbit colonies may require implementation of a "slaughter-out and disinfection policy" where vaccination is not possible.

114. - A range of issues is raised concerning the availability of vaccines for protecting domestic and farmed rabbits from RCD, including the uncertainty surrounding its availability, the cost factor and who should pay, and the fact that it will be a recurring burden each year.

115. - Submissions express doubts about the efficacy of a vaccine, attributed not to low immunity but to new strains of the virus with altered properties. Experience of significant side effects is also noted, including hair loss, ulcers, inability to reproduce, and wasting away after vaccination.

ISSUES CONCERNING THE MITIGATION OF EFFECTS

116. - Many matters raised throughout the summary as needing to be addressed should be considered as improvements or pre-conditions which might reduce some of the uncertainties.

117. - The focus on mitigation is two-fold: (i) mitigation for specific known or well-defined effects that discusses, for example, vaccination in relation to domestic rabbits, predator control in relation to prey switching, woody weed control in relation to reduction in grazing pressure; and (ii) mitigation for less easily resolved risks and uncertainties (e.g. mutation, host switching and human infection) where many submitters agree that the ‘probability’ is not easily defined, but the ‘possibility’ is frequently predicted.

118. - In the latter cases, the issues focus on the need to clarify the liability and compensation arrangements, if any, and the particular question of Crown liability in the overall decision.

COMMENTS ON THE IIA DOCUMENT

119. - The following features were evident from the group of submissions that commented about the documents:

  • the polarisation of views regarding the documents;
  • the preponderance of comments that are critical rather than supportive; and
  • the contrasting views of the scientific information in the documents.

120. - There was a considerable volume of comments in the submissions which raised specific issues about the documents themselves and these have been noted for further consideration.

THE DISEASE RISK ANALYSIS

121. - Only four submissions, three of which were opposed to the introduction of the virus and one whose stance was unclear, commented on the DRA.

122. - Two submissions made general comments about the DRA. One notes that it does not assess any potential risks of the calicivirus itself, while the other points out that there is no indication that it has been certified free from mycoplasma and that the virus was passaged in specific pathogen free rabbits. These and other submissions also make specific comments about several paragraphs of the DRA.

ANALYSTS’ COMMENTS ON THE SUBMISSIONS

123. - he submissions indicate a great deal of investigation by a large number of individuals. There has obviously been a great deal of networking amongst submitters - both supporters and opponents of the Application. One particular aspect of networking evident in these submissions, particularly those of opponents, is the use of the Internet to access and correspond with organisations and individuals overseas and in other parts of New Zealand.

124. - Although the numbers of submissions for and against the Application is reasonably balanced, the volume of material embodied in the submissions of opponents is considerably larger than is the case for supporters. Thus, in trying to represent and summarise the richness of the commentary contained in the submissions, there is inevitably more to include from opponents' submissions.

125. - There is another consequence, that 'Matters needing to be addressed will mostly come from opponents.

126. - Overall, there is a high degree of public polarisation over the Application. However, this is not invariably so for particular issues. It has been noted that there are some issues where perceptions are shared across the stances, even if the same conclusions are not drawn from those perceptions.

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Manager, Strategic Science Team
MAF Biosecurity New Zealand
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