2 ISSUES CONCERNING THE OVERALL APPLICATION PROCESS

2.1 INTRODUCTION

The "process"

In discussing issues concerning the process, the concept of "process" is broad rather than narrow. It is not confined simply to the public submissions process, but encompasses the overall process of application and decision making.

Frequency of comment

Almost one in every five submissions makes reference to some aspect of the process. The frequency of comment is far higher from those who oppose the application (one in every four) than from those who support it (one in twenty). There is clearly a high level of concern about the process.

Overview of issues

The framework adopted below for presenting this summary of process issues evolved from the content of the submissions themselves.

There are six linked themes apparent in the body of submission material:

  • the character of the decision-making process;
  • conflicts in the science which informs the application and the decision making;
  • concerns over the roles of various parties in the wider process;
  • the approach to public consultation;
  • aspects of timing; and
  • other aspects of the context for decision making.

For clarity, the issues are discussed under these six themes. However, there is inevitably some overlap between the themes. Furthermore, some of the issues raised in this section will appear again later in the report in more specific circumstances.

2.2 THE CHARACTER OF THE DECISION-MAKING PROCESS

Stance of the submitters

It would appear from the submissions that supporters of the application accept the intended decision-making process. As submission 297 puts it:

"The Applicant Group is going through the due 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.

Submission 454 captures the significance that many submitters attach to issues of decision making process when it states:

"This debate is as much about decision process management as it is of chemo-phobia ..."

Lack of a clear decision-making framework

Several submissions are critical in general terms of the absence of a clear decision-making framework, as distinct from a list of matters to be considered for decision making. For example:

"In considering the application, the issues should be judged in the broad context of the long term impacts on New Zealand’s economic, social and environmental goals. In carrying this out there are four key issues that need to be raised. These include decision-making based on science, comparative risk assessment, extent of knowledge, precedence set by the decision."(478)

One submission (99) suggests that the decision maker needs to know how the introduction of calicivirus will affect sustainability indicators. Another expresses a strong view about certain considerations which, it argues, should NOT be regarded as relevant - any perception that the disease will come into New Zealand anyway either accidentally or deliberately; the fact that the Australian Government has already decided to release the virus in that country; the fact that the New Zealand Government through MAF has already spent considerable sums of money on matters concerning this proposal (673).

Treatment of risk

A number of supporting submissions discuss the proposal for a controlled introduction of RCD in terms of the management of risks. For example:

"..holds the view that the introduction of RCD into New Zealand is largely an issue of risk management. As a result of the rapid spread of RCD in Australia, there must now be an undeniably high risk of virus transmission to this country. than attempting to manage an unplanned epidemic in New Zealand at some time in the future .... believes in an early controlled, coordinated and strategic release into New Zealand." (374)

Numerous opposing submissions highlight the absence of any risk assessment as an important component of the decision-making framework. They relate this, for example, to the need for:

  • a risk/benefit analysis of conservation impacts, with an assessment of costs and the ability to mitigate negative impacts;
  • a comparative risk assessment applied to aspects such as changes in genetic makeup, RCD host specificity, public health concerns and predator/prey switching; and
  • a scientifically defensible method of risk assessment with quantified probabilities and definitions of acceptable levels of risk.
Suitability of legislative decision-making frameworks

Numerous submissions discuss 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 such as this, and that the Hazardous Substances and New Organisms Act 1996, which is progressively coming into effect, provides a more suitable legislative framework and decision-making process.

There is some acceptance on the part of opponents that "the decision making process chosen for RCD is more open than previous and indeed current processes for considering the importation of new organisms"(674). However, the existing legislation is viewed in a number of submissions as being deficient. It is claimed, for example, that the Animals Act was not designed for applications such as this one to import a pathogen as a biological control agent. Furthermore, it is suggested that, in relation to the acknowledged uncertainty, irreversibility, and perceived national significance associated with this decision, there is inadequate provision under the Biosecurity Act for addressing acceptable standards of risk or for public accountability in the decision-making. One submission (99) suggests that it would appropriate to incorporate the RMA principles to ‘avoid, remedy and mitigate’ adverse effects into this application process. Some are suspicious of what they see as a hasty application designed to be processed before the HSNO legislation has come fully into force.

There appears to be widespread support amongst opponents of this application that the HSNO legislation 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 under s.36 of the Act.

One submission (673) asserts that the decision-making processes under neither the Biosecurity Act nor the HSNO legislation have been followed:

"This whole procedure is fundamentally legally unsound. Any decision which comes out of it is immediately challengeable in a Court of Law"

Matters which submitters suggest should be addressed or require further information:

develop a clear decision-making framework (e.g. 478).

develop a risk assessment framework, capable of incorporating a complete assessment, of short- and long-term risks and benefits, and identifying acceptable levels of risk (e.g. 99, 585, 674, 690).

resubmit the application under the Hazardous Substances and New Organisms Act 1996, with a decision to be made by the Environmental Risk Management Authority (e.g. 44, 50, 541, 673, 690).

2.3 CONFLICTS IN SCIENCE

Stance of the submitters

Comments under this theme are, with two exceptions, from people who oppose the Application. They address two main sets of issues:

  • issues reflecting conflicting views among scientists; and
  • concern about the need for caution in the face of unresolved uncertainties.
Conflicting views among scientists

Points made in many submissions clearly imply the existence of conflicting views within the scientific community. A few are quite explicit about it, noting what they describe as "widespread international criticism by competent virologists, veterinarians and molecular biologists of the safety of the product" (779), and describing "continuing scientific debate on crucial risk factors such as prey switching, diet switching and any long-term risks to the health of other animals and humans" (489)

There are several particular issues of process that arise as a result of this conflict of scientific views. Several point to criticisms of the research programme that has been carried out in Australia, stating, for example, that "authorities are critical of some of the test methods used on non-target species and of the interpretation of the data obtained from these tests" (779). Indeed, some submissions are scathing in their criticism.

Others are critical of the treatment of overseas expert opinion, giving lists of names and indicating that these experts warn of the dangers of RCD and oppose its introduction. One specifically challenges the NZ CVO’s statement that all appropriate expertise was used, asking "why have reputable scientists who have international standing not been consulted by MAF" (308). Another suggests that the opinions of scientists "who disagree with MAF and CSIRO scientists and the Applicant group must be considered in a scientific manner and in public." (460). More generally, several submitters are explicitly critical of what they see as the restricted input to the scientific debate in New Zealand, saying "it has not been extended to the wider scientific community" (493).

Some of the overseas scientists referred to corroborate these comments in their own submissions on the Application. Some submitters take the view that there is far more expertise overseas in such specialist scientific matters and contend that the views of scientists of international repute cannot be ignored. A few submissions go further and state:

"The weight of expert international scientific opinion goes against introduction of RCD to New Zealand." (605)

A few supporters are also concerned at the possible impact on the decision of conflicting viewpoints. One notes that this has happened before, and expresses the hope that the review panel will be able "to refute incorrect information and avoid the negative political influences which denied us myxomatosis some years ago." (239). Another expresses concerns about the impact of scientific disagreement on public attitudes, urging the decision maker not to be "misled by uninformed and irrational shortsighted public." (348).

The need for caution in the face of unresolved uncertainties

This theme comes through in a range of submissions which oppose the Application. The comments pose a considerable dilemma. Quite a number either expect or request the decision maker to exercise the "precautionary principle" (154) in the face of uncertainties that are acknowledged to remain, advocating that any importation and release should be delayed "until research removing the major uncertainties regarding its properties and effects becomes established." (493).

Opponents point to two particular obstacles that stand in the way of reducing uncertainties. One is the ‘Catch 22’ problem of not being able to conduct some specific aspects of research until the disease is present in New Zealand (478). This applies particularly to aspects of epidemiology and ecological impact, which, it is argued, will continue to lack credibility until research can be carried out that reflects likely New Zealand conditions. (This point will be taken up again in the section discussing the proposed programme of introduction.). The second obstacle concerns the perceived fallibility of scientific advice on matters comparable with the RCD issue. This submission maintains "that scientists in general, and MAF scientists in particular, have been unable to cope with ‘time’ and ‘environment’ (that is, non-controlled situation) factors has been repeatedly demonstrated in the NZ and world contexts." (552).

Nevertheless, it is suggested that in the context of Applications such as this one, that the burden of proof rests with the Applicant:

"It is the Applicant Group which has put forward the Application Document for approval. It is on the case put forward in that Document that the decision must be made. If the case is defective then it must fail. The onus is on the Applicant to prove its case." (673)

Matters which submitters suggest should be addressed or require further information:

rewrite the IIA taking into account the comments of the peer review panel (e.g. 622).

establish an independent scientific group, including calicivirus experts to review the need for further research (e.g. 308, 705, 779).

make research findings more publicly accessible, particularly calicivirus studies (e.g. 120).

2.4 CONCERNS OVER THE ROLES OF VARIOUS PARTIES

Stance of submitters

Comments were made about the following:

  • NZ Ministers of the Crown;
  • the Ministry of Agriculture, and some particular members of its staff; and
  • The Peer Review Panel.

With the exception of several comments from supporters on the role of the review panel, all other issues were raised by opponents of the Application. Most of their attention is focussed on the role of MAF, and its management of the peer review process.

NZ Ministers of the Crown

One submission (755) suggests that the political decision making in New Zealand has been compromised since our own Ministers of Agriculture, Environment and Conservation have already signed the agreement which allowed the official release of the virus continent-wide in Australia.

The Ministry of Agriculture

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

On the topic of the Peer Review process, one submission contrasts what it describes as the limited response in MAF-commissioned reviews with widespread concern of non-MAF reviewers (546). Nevertheless, another claims that while the Review Panel made it clear that the Application "was incomplete, contained misleading information and was not sufficiently robust to enable decision makers to objectively weigh up the risks and benefits of introducing rabbit calicivirus ..... their views are not reflected in the application released for public consultation." (790). Some critics cited Peer Reviewers’ assessments that MAF was irresponsible in releasing the IIA without also releasing the Reviewers Reports. The subsequent decision of the Ombudsman, requiring release of the reports under the Official Information Act confirms in some submitters minds that MAF was not acting with genuine impartiality. One submission (674) notes that MAF:

"...failed to require the Applicant to amend the IIA as requested by the Government Agencies and recommended by the independent consultants. This strongly suggests that the Officers are not sufficiently independent of the Applicant Group to be able to make a decision that takes all interests of the nation into account."

Others are critical of the confusion surrounding the Peer Review process, particularly the perceived secrecy over the identities of peer reviewers, MAF’s apparent unwillingness to release copies of reviewers’ reports to other members of the review panel, and the apparent changes in the composition of the Review Panel between various stages of its work. The Terms of Reference for the Review Panel are discussed below.

There are numerous criticisms of the public consultation process that was established by MAF. These are discussed in the next section below.

These perceptions of MAF’s behaviour lead several submitters to conclude that MAF has already made a decision and "is merely going through the motions" (308), and others to question MAF’s public accountability for any consequences of the decision in years to come.

The roles of the Director-General and the Chief Veterinary Officer are questioned by submitters on two counts; firstly, that the decision is inherently a political rather than a technical matter; secondly, that the involvement of the Ministry with the Applicant Group renders it very difficult for them to make an unbiased decision.

Peer Review/Review Panel

The process of the Peer Review Panel received comments both of support and opposition. Two submissions in support express satisfaction that the Director General of Agriculture has the appropriate expert advice to competently assess technical and scientific evidence and confidence that they "can rely on the review panel to reject spurious and negatively emotional material" (239). Several opposing submissions question the propriety of such a function for the Review Panel, claiming that its Terms of Reference geared it essentially towards ‘fixing up’ the Application, rather than taking a more neutral stance. For example, one submitter suggests that the peer reviewers should have been allowed to make comments about the whole idea, and not just been asked for changes to the document, asserting that the process, as carried out, appeared more designed to assist the Applicant than to help MAF decide whether or not to approve the application (673).

Other opposing submissions questioned the composition of the Review Panel in terms of the necessary range of scientific expertise and criticised the failure to provide evidence of the competency of the Panel.

Matters which submitters suggest should be addressed or require further information:

resume genuine consultation with Government agencies on the original peer review panel (e.g. 673).

include international experts on the peer review panel; also representatives of NZ Science Associations and Environmental Groups (e.g. 308, 406, 796, 460).

2.5 THE APPROACH TO PUBLIC CONSULTATION

Frequency of comment and stance of the submitters

Of all the themes mentioned in the submissions concerning 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.

Overview of issues

Within the overall approach to public consultation, various sets of issues can be identified:

  • obstacles to participation in the submissions process;
  • criticisms of the Applicant;
  • criticisms of MAF;
  • criticisms of the submissions analysis process; and
  • overall comments on the public consultation.
Obstacles to participation in the submissions process

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

Submitters criticise what they see as an unnecessarily "restrictive timetable" (258), claiming that it was too short for adequate consideration of such a major and controversial decision; that there was simply too much detailed and technical information for people to make a considered response within the time allowed; and that this was further exacerbated by the last minute release of the peer review comments.

Several submissions are critical of the cost of technical appendices, saying that this was an unacceptable barrier, particularly when the distribution of public copies of these documents did not go beyond 17 LINK Centres. In similar vein, submission 479 was critical that there was apparently only one set of documents for the whole of Auckland. Another was critical of the limited geographical availability of the peer review comments (722). Two submissions complain that they did not receive documentation after requesting, in one case after repeated requests (235).

Several submissions either criticise the lack of public hearings in the process so far, or request that public hearings be held as part of a revised and extended process.

Criticisms of the Applicant

The Applicant comes in for criticism, in the context of the public consultation process, 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.

Several submissions claim shortcomings in iwi consultation:

"A rigid public submission process, on the basis of application documentation which is available only at prohibitively high cost, cannot be said to constitute the sort of open and genuine consultation which is to be expected of the Treaty partners. ... The fact that no hui was held in Otago, where the greatest effects of an introduction of the virus are likely to be seen, is also a serious flaw in the process." (487)

Indeed, the same submitter notes, referring to p.61 of the IIA, that the Applicant Group accepts that it largely failed to consult with Maori in preparing its application.

One submission, which takes no clear stance on the proposal, observes that there appears to be confusion in the application over who is responsible for consulting Maori and identifying impacts on Maori (478).

Some submissions imply the perception that the Applicant group was generally selective in its consultation. Several are explicit in this criticism:

"All consultation appears to have taken place with those who are already firmly in favour of the virus." (782)

"It would seem that the only people that the applicants and their researchers wish to have anything to do with are those that agree with their point of view. They have publicly sniped at anyone who attempts to challenge their point of view." (531)

One submission (257) asserts that the public information kit on which, it believes, many people have based their opinions contained inaccuracies and false claims.

One submission supporting the proposal also highlighted the need to keep the public informed and to "help avoid the spread of mis-information" (27).

Criticisms of MAF

A few submissions are explicitly critical of MAF for what they see as withholding information during the public consultation process: "to the point of being obstructive in providing timely information" (491).

One cites resistance to enquiries for information on the Terms of Reference of the Peer Reviewers, their names, qualifications, and affiliations (722), while another claims that MAF kept ELISA test results from the public (467).

Criticisms of the submissions analysis process

A few submissions are openly critical of this process of submissions analysis and summary. Their criticisms cover the limited timeframe and concern that the consultants undertaking the task were not publicly named initially, the criteria for analysis set out in the Terms of Reference and the summarising process, claiming that every member of the public making a submission "has a right to be heard by the person charged with making that decision", and their view should not be "filtered out" by an unknown person (673). Several submitters are critical of the exclusion of Peer Reviewers’ reports from the submissions analysis.

Overall comments on the public consultation

Reflecting on the various shortcomings perceived in the public consultation process, several have described it as "a sham" (479), and others are critical that people were put in the situation where there was inadequate information to make an informed judgement. One cites a legal precedent on adequate consultation (673) while another states that the perceived inadequacy in the New Zealand process offers grounds for judicial review (755).

One submission in support of the application expresses concern at the apathy amongst supporters:

"We are concerned that many who support this application may not make a submission, while opponents have made a well organised effort to voice their concerns in numbers that are disproportional to the actual level of national opposition." (456)

Matters which submitters suggest should be addressed or require further information:

full and open consultation process, without undue urgency (e.g. 29, 42, 673).

include public hearings (e.g. 460, 628, 790, 794).

fulfil Treaty obligations to consult iwi groups (e.g. 362, 478).

2.6 ASPECTS OF TIMING

Stance of the submitters

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.

Supporters wish to avoid delay in approval and introduction - claiming it to be bad resource management. For example, one submission claims that time is vital; a controlled release this season is critical to the future of the high country land (372). And elsewhere:

"It is easy for those not directly affected or not understanding the significance of the rabbit problem to stall its introduction. Needless stalling is poor resource management." (297)

From those with qualified support there is one which expresses concern at the haste with which this proposal would see RCD introduced, noting a number of strategic matters that should receive attention before the introduction is given effect, even at the expense of the preferred release date (612).

Those expressing qualified opposition note that there are issues that must be addressed before permission is granted; they also express concern at the short time for consultation (noted elsewhere previously). Several with this stance suggest that it would be prudent to await the results of monitoring in Australia, perhaps even deferring the application for one year in order to allow for the evaluation of the Australian experience. One submission in this group notes that the Applicant Group’s identified need for a well researched Import Application appears to be contradicted by the decision to forgo further research (489).

Those unequivocally opposed to the application are stronger and much more numerous in their calls to learn more from Australian experience before considering a release in this country, including allowing sufficient time for the research necessary to remove major uncertainties, and time for a full inquiry as to how the virus escaped during the field trials on Wardang Island. Several submitters with this stance make explicit comment about the ‘irreversibility’ of the proposed introduction, underlining the perceived gravity of the decision:

"The introduction of RCD is likely to be irreversible so it is not proper to rush the decision" (674) and

"The applicants have the responsibility to prove that there are no serious , long term effects .... the Statutory Authority .. is inadequate to deal with the gravity of this irreversible act, the consequences of which will be with us for ever." (686)

This is also the stance which produced most of the criticism about the restrictive timetable for public consultation, which asks that the Environmental Risk Management Authority be set up before any final decision is taken, and which also urges that the application be resubmitted

under the HSNO legislation.

Matters which submitters suggest should be addressed or require further information:

delay decision to allow time to learn delay decision to allow time to learn from the Australian experience, with particular attention to effects in areas of low rabbit density (e.g. 31, 546, 585, 674).

establish the Environmental Risk Management Authority and resubmit under the HSNO process (e.g. 44, 50, 541, 542, 673, 690, 790).

2.7 OTHER ASPECTS OF THE CONTEXT FOR DECISION MAKING

Other comments in the submissions illustrate, from the diverse range of submitter perspectives, elements of the context in which they see the decision on this application is going to be made. These comments have been grouped into five sets of issues:

  • individual entitlements and expectations,
  • conflicting messages,
  • matters of precedent,
  • government responsibility, and
  • the international context.
Individual entitlements and expectations

The issue of legal entitlements is raised by those who oppose the application, while farmers expectations are declared by supporters.

The New Zealand Bill of Rights is cited, as the basis for asserting that every person has the right not to be subjected to medical or scientific experiment without giving their consent. Also, if people are making a living from feral rabbits, it is claimed that the Bill of Rights protects their right to continue doing this (362), a right which cannot be destroyed without fair compensation (459). Another submission raises an issue in natural justice: "The neighbour’s right to have the virus on their farm is no greater than mine to have my farm remain virus free" (97). Yet another asks what legal rights and responsibilities do people (other than the Applicant Group and the Director General of Agriculture) have in the intended statutory authority under which the decision will be taken (686).

Several submission in support of RCD refer back to the decision on myxo, suggesting that farmers reluctantly accepted the decision not to import myxomatosis, with the very high expectation that RCD would be acceptable to the wider community and become available as a rabbit control tool.

Conflicting messages

Two submissions from opposing stances raise the issue of double standards or conflicting messages. One submission in support notes that biological control is apparently acceptable in the case of controlling plant pests, and asks why it should be different for an animal pest (785). Similarly, one opposing submission notes that travellers receive large fines for importing prohibited plants, and large-scale spraying is carried out to prevent the establishment of a new organism, yet in this application it appears that authorities are advocating the deliberate introduction of a new organism (201).

Matters of precedent

Most of these comments (all from opposing submissions) look back in time and comment unfavourably on the history of past introductions to this country of exotic species. Descriptors are used such as "disaster" (409), "injudicious" (651) and "deplorable" (17). The general line of argument in these comments is captured by the following:

"The appropriateness of addressing the problems caused by the ill-conceived introduction of one exotic organism by the introduction of another organism (about which comparatively little is known) is highly questionable. ... This country's history of ill-conceived introductions of exotic organisms provides cogent evidence of the importance of not making any irreversible decision except on the basis of comprehensive and over-whelming evidence supporting such a decision." (487)

One other submission (with no clear stance on the proposal) looks forward and asks the question about the precedent-setting nature of this decision for future introductions (478). The submission observes that this will be the first decision to take account of the

requirements of new legislation, including the Biosecurity Act, and notes that New Zealand also has other environmentally important mammalian pests, particularly possums, and damaging plant pests:

"The precedence set by this decision could have far reaching consequences on future decisions for the introduction of biocontrol agents, including the introduction of genetically modified organisms for biological control." (478)

The submission also notes the potential implications of this decision for the type of science commissioned in this country in future, to control unwanted pests.

Government responsibility

Issues raised by opponents cover government mandate, government credibility and government liability.

One submission refers to the lack of any mandate, either public or parliamentary, "to the Applicants or MAF to introduce this disease or any other form of biological control." (236). It is one of several submissions calling for a referendum to be held on the matter.

Another submission challenges government, primarily regional government, to discharge its existing statutory responsibilities (for pest control and land management) effectively. On the basis of experience to date, it questions government’s future commitment:

"If there is no political will to honour currently binding and expensively purchased covenants with landholders, what confidence can there be in any future moves by either Regional Councils or landholders towards more appropriate and sustainable high country farming practices?" (613)

Several submissions raise the issue of government liability. One notes that "the approval process ....lays the Government open to potentially massive open-ended liabilities in the event of major adverse consequences, .." (493), while another states it in terms of possible "duty of care litigation, especially with the threat of human infection from the disease" (236).

The international context

Two issues of international context are raised. Firstly, there is the general comparison with what other countries are supposedly doing; secondly, there are views on the significance of the presence of the virus in Australia.

A few opposing submissions question why New Zealand is proposing to introduce RCD when other (unspecified) countries are said to be trying to eliminate the virus. Several note specifically the position in the US where RCD is said to be classified as a Foreign Animal Disease Agent, purportedly "to be exterminated at all costs" (42).

The presence of the virus in Australia drew a range of comments from across the spectrum of submitters.

Amongst those expressing unequivocal support for RCD there is the belief that with RCD throughout Australia the risk is very real that it will arrive here ‘naturally’ or as the result of deliberate but unofficial action by impatient farmers. These submissions express concern that any unplanned release of RCD would not only severely compromise its effectiveness:

"It would be a disaster to get RCD in a half-baked form." (347)

It would, it is claimed, also create considerable problems for farmers in terms of possible movement controls. The general tenor of these submissions is to cast it as a risk management issue (as noted earlier under ‘Character of Decision-making Process’).

"We also accept that the introduction of any biological agent cannot be regarded as a zero risk act. However, the risk of introducing a laboratory sourced, species specific virus in a controlled manner seems minimal compared to the risks posed by many everyday activities e.g. allowing people to freely enter this country without thorough testing for viruses such as Ebola, HIV strains not found in New Zealand, Handa, drug resistant pathogenic bacteria, new human and/or animal parasites etc." (736)

One submission, expressing qualified opposition to the proposal, acknowledges the possibility that RCD may be introduced accidentally or maliciously into New Zealand, regardless of the success or failure of this application (340).

Amongst those expressing unequivocal opposition there are comments which refute the suggestion that an ‘accidental arrival’ is a foregone conclusion. Several of them take exception to the implied threat, one saying this is tantamount to "blackmail" (342). One submission counters the Applicant’s argument that New Zealand would need very sophisticated border control surveillance and that existing procedures are unlikely to be effective by making the point:

"The risks to the Crown cannot be seen to be any different or more onerous than for the management of any other risk to the country." (531)

Matters which submitters suggest should be addressed or require further information:

the Government should develop a comprehensive management plan and monitoring strategy to anticipate either a planned or unplanned introduction of RCD including enhanced border screening procedures to prevent any unauthorised introduction of RCD into New Zealand (e.g. 258, 340).

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