- 1.1 THE APPLICATION PROCESS
- 1.2 THE DISEASE RISK ASSESSMENT
- 1.3 THE PROCESS OF CALLING FOR SUBMISSIONS
- 1.4 NUMBER OF SUBMISSIONS RECEIVED
- 1.5 THE OBJECTIVES OF THIS REPORT
- 1.6 CATEGORIES OF RESPONDENT
- 1.7 CATEGORIES OF RESPONSE
- 1.8 THE METHOD OF ANALYSING AND SUMMARISING SUBMISSIONS
- 1.9 THE STRUCTURE OF THIS REPORT
1 INTRODUCTION
1.1 THE APPLICATION PROCESS
Section 21 of the Animals Act 1967, as saved by section 169 of the Biosecurity Act 1993, provides for the Director General of Agriculture to give written permission for the introduction of new organisms into New Zealand. With regard to an application to import rabbit calicivirus disease (RCD) into New Zealand, the Director General has delegated his powers to the Deputy Director General (the "Decision maker").
The RCD Applicant Group was formed to present the case for the introduction of RCD into New Zealand. The RCD Applicant Group comprises the Hawkes Bay, Canterbury, Otago and Southland Regional Councils, Marlborough District Council, Office of the Commissioner of Crown Lands and NZ Federated Farmers (Inc).
The Decision maker has published two papers, setting out a summary of the process the Decision maker intends to follow in considering an application to import RCD into New Zealand and the matters to be considered for decision-making. These papers are entitled:
"Proposal for the importation of the rabbit calicivirus disease virus (RCD virus) as a biocontrol agent"
"Processing an RCD application - Summary"
They are attached as Appendices I and II.
As part of the consultation and assessment process, the RCD Applicant Group was required to prepare an importation impact assessment to accompany its application.
The application and importation impact assessment were lodged with the Director General in June 1996.
1.2 THE DISEASE RISK ASSESSMENT
In anticipation of an RCD application being received, a draft disease risk analysis was prepared by the Ministry of Agriculture’s Regulatory Authority. This was so that it could be subjected to an assessment and consultation process in parallel with the application to import RCD. In the case of RCD, the disease risk analysis addresses the risk of importing other organisms with the rabbit calicivirus.
A disease risk analysis is the basis of an import health standard for the importation of risk goods into New Zealand. An import health standard would be issued only if permission is given to introduce RCD to New Zealand and there is an acceptable level of assurance that no other organisms would be imported with the rabbit calicivirus.
1.3 THE PROCESS OF CALLING FOR SUBMISSIONS
The RCD application, import impact assessment and disease risk analysis were subjected to two rounds of peer review and then, on 5 September 1996, made available for public comment until 4 November. Copies were lodged at Link Centres, notices published in 25 newspapers and Sentinel, the newsletter of the Chief Veterinary Officer, and sent directly to approximately 1400 interested members of the public and organisations.
The letter from MAF Regulatory Authority inviting submissions is attached as Appendix III.
Submissions were received in writing and MAF contracted an independent consultant, Taylor Baines and Associates, to analyse them.
1.4 NUMBER OF SUBMISSIONS RECEIVED
Taylor Baines and Associates took delivery of 799 submissions during the period from 23 October to 8 November. Careful checking identified that:
- 3 were not in fact submissions at all;
- 25 were duplicates [ These involved submissions which were faxed to MAF in the first instance, with the original following by post, leading to the same submission being given two separate submission numbers.] ; and
- 20 were additions to earlier submissions, sent in by the same submitter.
Thus the final tally of submissions analysed by Taylor Baines and Associates stands at 751. The full listing of these, containing submission number and individual or organisational name is attached as Appendix IV.
A number of submissions were received by MAF Regulatory Authority after the closing date, and they have not been included in the analysis and summary presented in this report. A list of these late submissions is attached as Appendix V.
1.5 THE OBJECTIVES OF THIS REPORT
The Terms of Reference
Taylor Baines and Associates was commissioned to analyse and summarise public submissions to the Application to import the Rabbit Calicivirus, the Import Impact Assessment (IIA) and the Disease Risk Assessment (DRA). The Terms of Reference are set out in Appendix VI. In brief, they required the following information from all submissions received by the official closure date:
- total numbers holding each particular stance in relation to the importation proposal;
- a summary of issues raised in the submissions, correlated against the "Matters to be Considered for Decision-making";
- an analysis of the major issues of concern to submitters; and
- an analysis of issues which submitters identify as needing to be addressed, or requiring more information.
It is not the task of the analysts to make judgements on the significance of issues, nor to make any recommendations concerning a decision on importation.
The perspectives of submitters
The primary objective has been to represent as honestly as possible the issues and comments expressed in the submissions, albeit in summary form. As will become clear from what follows, the range of issues raised by submitters encompasses:
- the background scientific investigations;
- the Application itself and associated Import Impact Assessment;
- the Disease Risk Assessment;
- the public submissions process including this analysis; and
- the decision-making context.
1.6 CATEGORIES OF RESPONDENT
In this analysis of the submissions, two bases have been used for categorisation - the interests represented by the respondent (based on explicit information contained in the submissions), and the geographical location of the respondent.
Interests represented
The interests represented by the respondents are categorised as follows:
- organisations with statutory responsibilities (central, regional and local government agencies);
- scientific organisations;
- potentially directly affected parties:
- interests in landholding/land management (farmers, farmer organisations, farm consultants, pest advisory/destruction organisations, etc.)
- interests in environmental protection
- interests in animal welfare
- interests servicing livestock farming (veterinary services, stock and station agents, fertiliser manufacturers, etc.)- interests related to rabbits (breeders, harvesters, associations, etc.
- interests in fishing/hunting
- interests in other land-based recreation (hiking, tourism, etc)
- community groups, not included elsewhere;
- other groups, including national organisations, not included elsewhere;
- individuals [ Submitters with organisational links who wrote submissions in a personal capacity are categorised as "individual".] .
Geographical Location
Geographical location has been assigned to each submission in terms of the regional council/unitary authority area. Government departments, national organisations and scientific organisations have been classified as having national coverage.
1.7 CATEGORIES OF RESPONSE
The Terms of Reference ask for six categories of response to be differentiated. Five of these categories describe the spectrum of responses, as follows:
- unequivocal SUPPORT, where a submission identifies no issues of concern and expresses clear support for the Application;
- QUALIFIED SUPPORT, where a submission expresses support for the Application whilst still acknowledging the existence of significant areas of concern;
- clearly stated INDIFFERENCE, where a submission makes a positive statement of no view for or against the Application;
- QUALIFIED OPPOSITION, where a submission expresses opposition to the Application, but notes certain conditions that, if addressed, would render the Application acceptable; and
- unequivocal OPPOSITION, where a submission states unqualified opposition and may also provide additional elaboration of the issues of concern.
The sixth category allows for submissions where the position of the submitter is unclear, or where the submission does not state either support or opposition but raises issues or makes observations about the Application.
In each case, the classification of response - in other words, what is judged to be the stance of the submitter in relation to the Application - has been made on the basis of explicit statements contained in the submission.
1.8 THE METHOD OF ANALYSING AND SUMMARISING SUBMISSIONS
Method of Analysis
The method of analysis involved four main steps:
- identifying each submitter’s stance in relation to the Application;
- coding issues in each submission;
- sorting all coded issues by stance; and
- content analysis of all the coded material, separately for each stance.
Submitter stance was identified according to the categories described above.
Issues were coded using a set of topics which reflect the range of elements contained in "Matters to be considered for decision-making" (refer to Appendix I). The topic framework allowed for any issues to be acknowledged by including the additional topics - "process’, "report", and "other issues". Each submission was read and key issues coded and summarised in preparation for later content analysis. This material was entered into a text database.
Using the text database, the issue material was collated by key issue and sorted by stance.
Finally, a content analysis was carried out on the issue material with the aim of identifying major issues for each stance of submitters, noting particularly areas of strongly polarised views, or conversely areas of agreement.
The Terms of Reference required that, in writing the report, indications of the numbers of submitters holding a particular view about an issue should be indicated in a general way. This involved using phraseology such as "one submitter", "a few", "many" and so on. It should be noted that the use of the singular - "one" - may denote either that only one person made the point or raised a particular issue, or that one person’s way of expressing an argument is being used to indicate a particular angle on an issue that is raised by others as well.
1.9 THE STRUCTURE OF THIS REPORT
The rest of the report is structured in the following manner:
- a discussion of issues concerning the application process (Section 2);
- a quantitative summary of responses to the Application (Section 3);
- a discussion of issues associated with the Application (Sections 4-9);
- a summary of comments on the IIA document itself (Section 10);
- a summary of comments received on the Disease Risk Assessment (Section 11);
- some observations on the submissions from the team of analysts (Section 12);
The Terms of Reference require the identification of issues of concern "that submitters identify as needing to be addressed or requiring more information". In Sections 2 to 9 of the report, such points have been collated and presented in text boxes. Section 10 contains further similar lists based on comments on the IIA document itself. These lists have been compiled directly from the body of submissions. Therefore, they reflect submitters views.
They should not be taken to imply that any decision has been made by the decision maker which confirms a need to address the matters listed or to gather more information.
Submission numbers contained in these text boxes are indicative, rather than exhaustive.
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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