7 THE PROGRAMME TO RELEASE RCD

7.1 INTRODUCTION

Overview

This chapter examines the submissions in relation to their comments on the nature of a programme to release the RCD virus, covering:

  • the possibility and problems of an accidental or unofficial release of the virus;
  • the goal and objectives of the programme for controlled release;
  • the character of the programme, its statutory and organisational base;
  • the deployment of the virus, its source, entry, multiplication and spread;
  • integration of the release programme with other control measures;
  • programme monitoring; and
  • the economics of the programme and its financial underpinnings.

7.2 THE ISSUES OF ACCIDENTAL OR UNOFFICIAL RELEASE OF RCD

The main themes in this section are:

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

Frequency of comment

Both side have comments on this issue, although clearly their views vary. The overall level of comment is around ten percent.

The risk of an uncontrolled release

Supporters consider that it is inevitable that the virus will arrive in New Zealand, either through natural processes, or by illegal importation. It is suggested that a planned release is more desirable as it will make the best use of the virus in rabbit control. An unplanned release will miss the opportunity of a well managed introduction, and also has the potential to damage our agricultural reputation. They say a controlled release is in everyone’s interest. It is seen as a matter of risk management, where the best approach to reducing the risk is to bring the virus in through a managed programme. It is also noted that the demonstrated robustness of the virus to remain viable in a free form increases the likelihood of its arrival here.

Supporters consider that a likely source of the accidental or deliberate release is footwear or clothing. So an arrival becomes more likely with time. Incentive for an illegal importation is high if the application is denied because of the high costs of control currently faced by farmers under regional pest management strategies. Farmers are commended for their restraint to date. Birds and insects are "windborne" and cited as likely natural trans Tasman vectors, and trade and travel as potential human vectors. Postage is cited as a likely route for illegal importation. Not to introduce the virus would be a crime, they say.

Prevention and management of an uncontrolled release

In an unplanned release it will be more difficult to put the necessary programmes and resources for them in place, and enable the country to capitalise on the full potential of the release. Illegal releases are likely to be piecemeal and of less benefit than a managed release. Inferior strains could assist the immunity of rabbits to increase.

For supporters, if an outbreak does take place, then the responsible course is not to try and contain it, but to carry out protection of domestic rabbits and predator controls where there is risk of prey switching.

Qualified supporters note that there is less likely to be a comprehensive followup control programme with an unauthorised release. There may be no preliminary monitoring. Secondary viruses may piggy back. The wrong strains could build natural immunity.

People in qualified opposition note also that a managed programme is preferable, and that the applicants should be congratulated for using the official channels! They call for punitive measures for anyone who releases the virus without permission, no matter how good their intention might be.

It is also pointed out that scaremongering is not an appropriate way to sway the decision. The virus, it is argued, should not be introduced until all concerns have been dealt with. In the meantime, appropriate border controls should be in place, and every opportunity should be taken to observe, research and learn from the Australian experience.

People in opposition make even stronger statements that a belief that the virus will arrive anyway is no ground for acceptance of the existing proposal for importation. These are seen as irresponsible and fallacious, scare tactics and supposition. They believe that the risk of accidental or illegal introduction is overstated and unsubstantiated. They question whether the agent would in fact be less effective if it arrives illegally. It is essential, to them, that MAF, DOC and the regional councils have a strategy in place to deal with this risk. If others suggest that it is too expensive and time consuming to control the arrival, then, it is suggested, the control of a number of other unwanted pests and diseases can be questioned. They say that it is the responsibility of the government to prevent unwanted introductions and to prepare contingency plans.

An unauthorised release would be open to litigation. There should be harsh penalties.

A plan for vaccinations and a management plan need to be in place.

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

On p xv, line 1, add farming businesses to regional, unitary and district councils as being affected financially by an unplanned release, as they already bear much of the cost of control (e.g. 279).

What border controls are to be established? Make more efforts to warn and educate about illegal inputs, train border control staff about RCD and strengthen quarantine and customs procedures (e.g. 479).

Provide heavier, punitive penalties for a deliberate release under the Biosecurity Act (e.g. 433).

Prepare a contingency management plan, including vaccination programmes and followup control work for an unplanned arrival (e.g. 241, 657).

7.3 THE GOAL, CHARACTER AND ORGANISATIONAL BASE OF A PROGRAMME FOR CONTROLLED IMPORTATION

The main themes in this section are:

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

Frequency of comment

In addition to those with clear stances on both sides, a number of people with qualified stances for and against RCD made comments on the nature of the programme, indicating that this topic is one of their primary concerns or qualifications of their positions.

Goal and objectives of the programme

Comments on the goal of the programme come both from people who support and oppose the introduction of RCD, and also from a number of those with a qualified stance either way.

Discussion of the programme goals requires a distinction between broad programme goals, more detailed objectives and verifiable indicators of change. It is pointed out by several submissions (representing no clear position or qualified opposition) that the goals and objectives of an importation programme are not stated clearly in the IIA document.

Where supporters of RCD comment on the broad goals of the programme, those goals are to provide long-term benefits to tussock grasslands and sustainable land management, with flow on benefits to farm families, the farming community, the rural economy, and national society through improved exports. These aspirations are summed up by one submission:

"The RCD must be introduced into New Zealand. I believe the South Island tussock lands will be transformed into a thriving vibrant asset to which all New Zealand will be proud. This action would truly be a positive contribution to our future generations." (348)

A number of objectives can be identified from the submissions in support. These include:

  • to introduce a new tool or option for farm businesses to control rabbits;
  • to use the new tool along with a number of existing control measures;
  • to control the spread of bovine TB;
  • to allow farmers to concentrate on the positive aspects of farming and profitability;
  • to encourage revegetation and gain soil and water benefits; and
  • to reduce the use of poisons.

A few talk of the ultimate goal of "eradication", others about "getting on top of the rabbit", but the major themes from supporters are improved, more cost effective control, to be used alongside existing techniques and experience, improved productivity and more sustainable land management. They will not, one points out (174), ever forget the threat of what rabbits can do. A farmer group (555) points out that it cannot be assumed that farmers will overgraze after RCD, replacing rabbits with sheep. There will be replacement of uncontrolled grazing (rabbits) with controlled grazing (sheep). High country farmers have a pride in the environment, and an emphasis on quality production. There is also protection through the RMA and the Biosecurities Act.

More detailed comments project a number of beneficial effects. (These are all verifiable indicators that could be the subject of monitoring, see discussion below.)

  • improved soils and plant habitat;
  • less land erosion and degradation;
  • improved water catchments;
  • greater farm expenditure on inputs such as fertiliser;
  • improved productivity and lowered debt;
  • more over-sowing and top-dressing to put better vegetative cover back on the ground;
  • more fencing;
  • better grazing management and more spelling of land;
  • more effort put into eliminating other weeds and pests, and Tb;
  • tree planting for shelter, harvest and aesthetics;
  • smoother income and expenditure patterns;
  • increased demand in rural communities for services and infrastructure;
  • benefits for fertiliser and freezing companies and the rural economy in general;
  • improved farmer confidence and business strength; and
  • ability to engage in better planning and address sustainable land use issues.

Those with qualified support raise similar points, and emphasise that

"RCD should not be seen only as a means of reducing rabbit control costs, but as a means of achieving more effective control". (457)

Another (131) notes the need for changes in land management. Similar points are made, if more strongly, by those categorised as being qualified opposition. RCD will not exterminate the rabbit, they say. It needs to be seen only as one tool that must be supported by other methods. Indeed, they point out it may have only a relatively short "life" and that land management changes will also be essential.

Submitters in opposition are critical that the goal seems to be a "quick fix", one that will bring temporary financial benefit to a small group. They also are concerned that any reduction in rabbit numbers should be effective in the longer term. So pressure has to be kept on the rabbits.

The character and organisational basis of the programme

There is a strong preference from submissions in support to have a legal introduction of the virus. People want to see it done in a logical and scientific way designed to have maximum impact on rabbit numbers. They call for a coordinated and well managed strategy by the applicant group, to maximise benefits and minimise negative effects. Both supporters and qualified supporters wish to see a programme integrated with other control activities (as discussed below):

"RCD as part of a well-designed integrated rabbit control programme, in order to achieve long term gains from the use of the virus." (477)

On the legal basis of the programme, it was also suggested that while it does not come under the RMA, the principles of that Act should apply.

This programme will need to combine efforts of individual farmers with those of regional councils and other players, and the preference is that this should take place in the context of regional pest management strategies.

For instance, individuals describe the preparations they are making for control efforts after RCD is introduced, such as rabbit proofing of boundary fences. Regional councils in support and qualified support sees themselves taking the role of management agency for RCD in their region, preparing and implementing plans for a managed release in consultation and coordination with each other, the lead agency and other agencies, and monitoring its spread and effects. They argue for a managed release to achieve best control results, and the collection of relevant performance information. Liaison and coordination between organisations is requested, in writing where appropriate. The role of the Ministry of Agriculture is questioned.

There is a call from people in qualified support for a programme that requires farmers to change management practices that modify pasture habitats, decrease stock numbers to allow vegetation to recover, and if necessary actively revegetate areas that are severely degraded. There is a strong call for the release to be part of a long-term strategy of integrated land management for rabbit-prone areas (477). There is also a call for a predator control programme to be organised with DOC (410).

Other suggestions for a controlled introduction programme include:

  • education and extension for landowners on land protection and improvement, and public information and awareness programmes to back up the release programme;
  • a law change to allow compensation; and
  • consideration of the question of compliance with any release programme.
Matters which submitters suggest should be addressed or require further information:

The objectives of the proposed introduction have not been clearly stated (e.g. 478, 489, 258).

The application should be linked to a national pest management plan and regional pest management strategies which set out an overall approach to integrated rabbit control and land management and ensure there is no overstocking and short-term gain (e.g. 343, 541, 628, 640).
All farmers should agree to changes in land management regimes with RCD with an enforceable commitment to sustainable land management plan in place before any release (e.g. 131, 175, 511).

There is no plan to show how the new tool will bring sustainable benefits for pastoralism. There needs to be an ecosystem approach that links changes in the rabbit cycle and land management practices that alter levels of rabbit damage, as well as predator control (e.g. 674).

An education programme will be required (e.g. 101).

The programme should establish liaison and coordination with key agencies and organisations such as DOC and regional and district councils before any release, with key communications in writing (e.g. 410).

The programme should include a vigorous predator trapping programme and a plan to mitigate any adverse effects on flora and fauna, including management of endangered species, to be set up with DOC, before any release (e.g. 379, 411, 433, 790).

7.4 DEPLOYMENT OF THE VIRUS: SOURCE, ENTRY, MULTIPLICATION AND SPREAD

The main issues covered in this section are

  • 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.

Timing of a release

Timing is a concern in many submissions, and comments tend to vary by stance. Most in support want the virus to be introduced as quickly as practicable. Needless stalling is described as poor resource management. Qualified supporters suggest a delay until a programme of research and management has been established. Substantial delays are urged by those in qualified opposition, for up to at least two years, aimed at learning from the Australian experience, including an assessment of effects on all wildlife there and a new application under the HSNO Act (see discussion in Section 2.6). In the meantime border controls should be maintained at the necessary levels. Those in opposition urge decision makers to wait at least until the Australia experience has been fully realised, emphasising the need for a "precautionary approach".

Source, multiplication and containment of the virus

There are only a few comments on the purity of the virus. A submission in support (379) notes that the proposed source of calicivirus is reputed to be a pure strain from Czechoslovakia. It points out, however, that the purity of the strain cannot be guaranteed should it arrive here by other than official means. Another (440) considers that it seems likely that the disease that arrives from Australia will be the desired strain and free of any contaminants that could be in an unauthorised entry. Opponents are concerned that the virus cannot be grown in the laboratory or purified reliably. There is also concern that other diseases may be introduced with the RCD virus. To them the IIA is all very reassuring, but no absolute assurance of non contamination can be given.

A submission (478) with an unclear stance is uncertain whether the final product would be imported or processing would occur in New Zealand. There is a gap in the knowledge of any proposed processing of RCD in New Zealand. It maintains that information provided on the manufacture of rabbit calicivirus is now out of date. Confirmation of the virus may not be performed on every batch by electron microscopy and antigen ELISA. An opponent (554) is concerned that there appears to be a lack of an appropriate method for conducting cell-culture studies.

There is a lack of information on methods for distributing and activating the virus. Concern is raised about the possibility of infected baits being passed through the food chain.

Opponents of RCD consider that in view of the recent Australia experience there will be no feasible way of controlling the disease once it is released here, that any attempt at containment would be impossible, or the costs would be prohibitive. They ask who will be responsible for the virus once it is introduced, if anything "unforseen" happens. Several call for a contingency plan and vaccination programme to be in place, although doubts are raised about the ability to protect domestic rabbits and other species through vaccination (see Section 8.9 for more detail). A submission in support (367) points out that a decision to decline RCD with no border protection, or plan and resources for containment of the virus, would be a non decision.

Strategy for maximising spread and kill

A numbers of supporters of RCD call for a release strategy that is planned, controlled and monitored. They place emphasis on an approach that is professional and systematic. There is some broad support expressed for the release strategy as outlined, structured to obtain maximum benefits while monitoring effects. There is also support for plenty of consultation and involvement of farmers during the release to use the vast pool of practical knowledge which is available, and a number of issues are identified by supporters at this point. Further issues are raised by opponents.

There is concern from all that there should be a controlled release that will provide a maximum kill effect. The release strategy therefore should aim to minimise the possibility of milder strains emerging under NZ conditions. Patchiness in kill patterns with unaffected "pockets" is seen as likely to increase this risk. In addition to concern about any weakening of the virus strain, there is concern for the possibility of immunity building in rabbit populations.

The season of release is a further issue raised. A supporter (214) has minor reservations regarding the timing of the release as proposed in Section 5.4 of the IIA document. The release should be timed for later in the autumn (March-April) when there are fewer young rabbits to survive the infection. The concern in this submission is that the idea of an "initial" release followed by a "main" release' is driven by research needs rather than the optimal spread of the virus. The suggestion is that research should be undertaken in selected areas at the time of and as part of the "main" release. A later release time may require a faster spread of the virus from the main release sites to ensure full coverage of the rabbit population before mid-winter. It is argued that if this were the case, "farmers will be keen to assist with the spread of the virus if required". (214). Another argues:

"While a 'trial' release would help the subsequent management the probability of uncontrolled spread is very high and therefore a detailed alternative plan for total coverage should be developed for universal and immediate implementation. A haphazard spread must be avoided so that pockets of rabbits which may develop immunity can be minimized." (379)

Another submission (557) requests that the timing of the release should aim for the best possible outcome for native birds, with a further suggestion that release should only take place after predator control has been accomplished. An animal welfare perspective is that release of RCD should be simultaneous throughout NZ when it can be shown that the least number of suckling kits will starve to death in their burrows.

The initial sites for release raise a contentious point. One supporter (398) argues that only the extreme and high rabbit-prone areas of the South Island should be targeted initially. Another concurs, suggesting the virus will spread to the coast, driving predators before it to where they will starve, leaving birdlife thriving in the foothills. Another (99) argues for a catchment by catchment approach. While a further argument is for an approach to selecting sites on ecological criteria. Then it is argued that as the disease is so highly transmissible, it is unlikely to be controlled anyway. And it may not be feasible to limit or control any subsequent re-releases in a locality.

While some concern has been raised that research needs should not interrupt the release plan, another submission argues:

"We believe that it must be made a condition of the release that there be a soundly designed and conducted epidemiological study of the field infection, using valid epidemiological and ecological research methods. Without such a study being incorporated into the release plan and adequately funded, the release should not proceed." (477)

There are opponents who argue that the whole deployment strategy is so uncertain that it is all experimental. Will the speed of transmission even allow for an adaptive management strategy, they ask.

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

Up to date information is required on the manufacture of rabbit calicivirus and whether this will be done in New Zealand, with confirmation that every batch will be checked by electron microscopy and antigen ELISA (e.g. 478).

Systems are needed to check and guarantee the purity of the virus on entry. Information is needed on whether the stock solution of virus will have been certified free from mycoplasma and that virus was passaged in specific pathogen free rabbits (236, 478).

What are the plan, measures and likely cost if RCD enters New Zealand and an attempt is made to contain it? (e.g. 478, 648, 673).

There is inconclusive information on transmission of the virus (e.g. 612).

Haphazard spread should be avoided, and a detailed alternative plan prepared, c.f. Section 5.4 of the IIA (e.g. 379).

Timing of any initial or main release should be made for maximum benefit, and for minimal adverse impact such as on bird species (e.g. 214, 296, 557).

The applicants should be required to demonstrate that appropriate preparations and planning have taken place to deal with each of a defined range of possible release outcomes (e.g. 477).

Effectiveness of the virus in different habitats should be addressed (e.g. 609).

There should be a detailed plan to keep survivors with immunity from repopulating or
spreading to other areas (e.g. 790).

It is not known who will collect and dispose of infected carcases (e.g. 248).

There is inadequate information on deployment of the virus, such as justification of sites selected, pre release monitoring, details of numbers of pre inoculated rabbits for release, containment of rabbits within initial sites, security to prevent spread from a release site, the time frame to assess transition from initial release to main release (e.g. 711).

There should be commitment and funding for epidemiological and ecological field research as part of the release plan. (e.g. 477).

Greater knowledge is needed of population dynamics and environmental responses. Take full benefit from the opportunity to study the Australian case (e.g. 457).

Delay and resubmit the application after consideration of the Australian experience (e.g. 476).

7.5 INTEGRATION WITH OTHER CONTROL MEASURES

The main issues covered in this section are:

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

Frequency of comment

Comments on this topic were made from both sides of the debate. It was notable that there were a number of people with qualified positions who commented; the need for an integrated approach being part of their qualified position.

Followup control after the release of RCD

Supporters and qualified supporters generally acknowledge the importance of continuing with followup control work after any release of RCD, whether it be official, unofficial or accidental. RCD is not seen by them as likely to be a total control measure. Comments cover the importance of followup work immediately after a release, and also in the medium to longer term. Some primary poisoning may also be required. Their emphasis is on using RCD in conjunction with a range of existing methods, in an integrated approach as described in the IIA in Section 5.6.

This followup work will help first to preserve the effectiveness of the virus, and second to secure complete rabbit control. Because young rabbits are immune, and the rabbit breeds prolifically, it is recognised that other controls will need to be kept in place to achieve the objectives of the programme:

"RCD on its own is not a total solution" (360).

Supporters say that they will be using the window of opportunity to its maximum to kill remaining rabbits, as will all farmers. The effort will be costly but worth it, they say. Some expect considerable ongoing costs of control. Furthermore, it is suggested that the labour intensive secondary control measures will create further rural jobs and downstream benefits.

Farmers consider that as there will be reduced costs of primary control, they will have more resources to carry out expensive secondary control than at present. Some suggest that they will spend considerable amounts on secondary control annually.

There is an acknowledgement that RCD may need to be reintroduced to particular areas or populations, and an integrated approach would aim to lengthen the periodicity of such reintroduction.

But opponents are cynical and question whether there is really commitment to an integrated approach. They are concerned there will be an initial knockdown, followed by a return to "normal years".

"A ten year lull is more likely to engender a decade of complacency and procrastination". (361)

Secondary control is therefore seen by opponents as a vital part of the RCD debate, if the initial effectiveness of the virus is not to be quickly dissipated. They question the way in which the RCD release might be integrated with other control actions, and the monitoring procedures to be followed in relation to measuring the impact of release and adjusting actions appropriately, asking if the required planning has taken place. Or, will RCD be treated with a "poison" mentality. To them, any integrated strategy needs to be planned (with responsibilities and costings) at national and regional levels well in advance of any release. They also recommend farmer education.

The integration of diverse objectives

Some supporters note that farmers are able to recognise and achieve diverse management objectives, as evidenced by conservation planning, the RLMP, the HCFF Resource Monitoring kit and landcare groups. With RCD, farmers will be able to integrate the objectives of all stakeholders in the programme. The regional councils should facilitate and underwrite this process, and resolve land use conflicts through planning and management. Furthermore, government and local authorities must continue pest management strategies designed to further reduce rabbit numbers beyond those envisaged under a calicivirus regime. Others argue for an integrated land management programme, and to some this should be an enforceable programme.

A specific area of integrated pest control noted by some supporters is the need for predator control in conjunction with the rabbit programme, to ensure that there is a complementary knock down in their numbers, with benefits for reducing the spread of bovine Tb.

A farmer group (279) expects that it will be possible to modify pest management strategies developed under the Biosecurity Act if RCD is available as a control tool. After a successful release of RCD it might be possible to lower the levels of maximum rabbit infestation.

People with qualified positions note that the maximum opportunity should be made to create improvements in both production and conservation. Only significant application of good land management by the occupiers will release the full benefits of RCD for all stakeholders says another. One comments:

"there needs to be an enforceable programme of sustainable land management, including retiring land from agricultural use, follow up with other methods of killing the remaining rabbits, appropriate revegetation and control of rabbit predators" (409).

Matters which submitters suggest should be addressed or require further information

Stringent programmes of rabbit control, with clear responsibilities, should be in place through national and regional pest management strategies, before RCD is released (e.g. 570, 585, 674).

RCD should not be viewed as a `final solution' to the rabbit problem and a programme of follow-up control to keep "surviving" rabbit numbers down should be a condition of any introduction (e.g. 551, 625).

It is not clear how an integrated approach to control will be put in place if the virus distributed itself rapidly (e.g. 477).

The rabbit programme should be integrated with a (enforceable) sustainable land management programme (e.g. 409, 569).

7.6 PROGRAMME MONITORING

This section examines:

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

Level of comment

This was another topic on which there was comment from both supporters and opponents, although the overall level of comment is less than 10 percent of all submissions. But once again there were a high proportion of submissions with qualified stances, suggesting that provision of monitoring is seen as a another area in which there is some common ground among submitters.

Lest we forget

As discussed in the chapter above on the rabbit problem, the farming community are acutely aware of the difficulties that rabbits have posed for over 100 years, in successive "plagues". People from the rural community make a strong point in their submissions that monitoring is needed to ensure people do not forget about rabbits. Opponents considered that farmers and their response to RCD should be monitored to ensure that they are taking full advantage of the reduction in rabbit numbers to restore the land, rather than make a short term gain from rapid increased output.

It is recognised that monitoring will take advantage of a unique opportunity to record and understand the processes of change that take place:

"a managed release gives us the opportunity to monitor the spread of the disease from a zero base and to determine what factors are involved and how they operate" (413).

There is agreement that monitoring strategies need to be put in place before any release of the virus.

Monitoring and research for programme management

Both supporters and opponents of RCD consider that monitoring and research are needed for a thorough understanding of the processes involved as RCD takes effect. Some are not so keen:

"Forget about monitoring and get on with the job of eradication"! (249)

A number of variables are suggested throughout the submission for monitoring, for example:

  • epidemiology;
  • virology;
  • dose responses;
  • incidence of "hot spots" requiring poisoning;
  • followup control work;
  • predator numbers and prey switching;
  • Tb vectors and the incidence of Tb;
  • levels of stock numbers;
  • vegetation;
  • weeds;
  • native fauna before and after rabbit numbers decline; and
  • rabbit densities at vulnerable sites.

Qualified supporters note that monitoring needs to be linked to programme management and contingency planning. There are also observations about the need to coordinate monitoring by farmers and the regional councils. A group of farmers (543) comments that all its members would closely monitor rabbit numbers and predator levels following release of RCD, cooperating with agencies such as regional councils and DOC. It is also pointed out that extensive monitoring was undertaken during the RLMP and this could be built on. It is suggested in a range of submissions that a number of other agencies should be involved in monitoring work; for example, DOC, the Ministry of Health, and Landcare.

Both supporters and opponents agree that adequate funding needs to be available for the monitoring work. Although a District Council (548) expresses satisfaction that the strategy for release makes appropriate provision for monitoring, there are a number of suggestions made by others towards improving that strategy, as outlined below. Opponents raise further issues, including the need for technical skills.

The main technical problems and suggestions for a monitoring programme are:

  • inadequate pre-release data on which predictive outcomes can be based;
  • the lack of any longitudinal studies to assist with the assessment of effects;
  • monitoring in Europe and Australia can be used to help interpret effects in New Zealand;
  • no clear information on how rabbit populations will be monitored;
  • there is a need to monitor a much greater area than one square km around each release site (given the rapid spread experienced in Australia);
  • a framework of ecological regions and districts should underline research on ecological consequences;
  • GIS systems can be used to integrate different sources of data and extend current proneness maps with more sophisticated models of rabbit-environment interactions; and
  • laboratory and "contained" experiments of effects on native fauna should take place for five years before any release.
Matters which submitters suggest should be addressed or require further information:

There needs to be adequate funding for ongoing monitoring and research (e.g. 116, 239, 258).

It is not clear what the duration of monitoring will be after the releases (e.g. 258).

There is no long-term plan for monitoring effects. Mechanisms need to be in place to guarantee monitoring will be done and to allocate costs and responsibilities (e.g. 795, 709).

The requisite skills need to be in place pre release, such as virological diagnosis (e.g. 554).

DOC requires adequate resources to monitor predator-prey switching and responses of indigenous flora in particular habitats (e.g. 546).

There should be careful design and peer review of the epidemiological research proposed for the initial release sites (e.g. 309).

It is vital for epidemiological monitoring to develop qualitative immunoassays that distinguish protective immunity from infection (e.g. 711).

There should be monitoring of effects on human populations, with the Ministry of Health involved (e.g. 99).

7.7 PROGRAMME ECONOMICS AND FINANCES

This section examines:

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

Level of comment

There are a number of submission on this topic from both quarters.

Cost benefit analysis

There are many general statements by supporters about the benefits of RCD, that it will save farmers and the economy many millions of dollars, and bring substantial benefits to farm families, the rural community and the environment, and that these have been understated in the IIA. On the other hand, there is concern amongst those in opposition as well that many economic factors have been understated. While some of these reiterate benefits as outlined below, they also add a number of possible costs, also listed below.

It is argued by a number of submissions in opposition that the application has no cost-benefit analysis and that this should be undertaken. They claim that

"no comprehensive, rational and substantiated costing of the problem is provided" (400).

A full cost benefit analysis would need to take account of both quantitative and qualitative information, and also an assessment of risks and direct and indirect effects. It is argued that the analysis should look at the allocation of benefits and costs by sectors of society, and over time (a short term benefit for few for the long term cost of many). It may need to take both a national and various regional perspectives. The lists of costs and benefits given below is drawn from the comments made, and should be seen as illustrative, not exhaustive.

A number of benefits are indicated (mainly by supporters). These are discussed in more detail in other sections of the this report. Benefits that might be included in any analysis include:

  • reduced expenditure on rabbit control;
  • more expenditure on predator control;
  • reduced bovine Tb (through reduced predators);
  • increased stocking rates and farm productivity;
  • increased farm expenditure on productive activities such as pasture development, fertiliser and subdivision, and weed control;
  • increased opportunities for specialist crops;
  • reduced risks to forestry plantings;
  • reduced farm workloads, particularly at night;
  • reduced family stress;
  • reduced risks from firearm use;
  • improved farm finances, debt reduction and easier budgeting;
  • flow-on economic benefits to rural communities;
  • reduced demand for taxpayer input to provide pest control and sustainable soil and water management;
  • increased conservation values; and
  • reduced land, soil and water degradation: more sustainable land management.

Possible costs are also indicated (mainly by opponents) and these include:

  • costs of preparing the application;
  • an increase in woody weed control and of consequent burn offs and chemical spraying;
  • loss of the feral meat processing industry;
  • reduced carrot production for aerial poisoning;
  • ongoing costs of secondary control;
  • effects on endangered and other species through prey switching;
  • predator control;
  • research and monitoring; and
  • vaccination programmes.

The financial basis of the release programme

There needs to be a comprehensive and well financed plan to make use of the brief opportunity offered, including adequate followup control work as discussed above. Views on the source of funding differ, among all submissions. Some see the rabbit as a national problem requiring government funding. Comments tend to identify "the applicant group" or MAF as the main likely sources. Regional councils are another funding source identified, given their responsibilities and the development of regional pest management strategies. Others argue vehemently that it is a farmer problem and they, or more broadly the "agriculture sector", should pay. Another argument put forward is that an equitable framework should be used to apportion costs between various stakeholders.

Some opponents would prefer that

"The resources being devoted to the application to import the virus would be better utilised to fund further research into the potential effects of RCD in NZ, and to ensure that measures are in place to safeguard human health, native ecosystems and wanted rabbits" (657).

Supporters also see the need for increased expenditure for predator control, and possum control, primarily to reduce the threat of bovine Tb. They often explain that this funding will be released to farmers from their reduced expenditure on rabbit control.

Numerous opponents focus on the need for DOC to have sufficient extra funding to cover costs of the specific work needed to protect the areas where native species have been recognised as being at risk from predator switch (refer to page 14 table 1.2). They consider that this funding must be immediate and not found from the existing DOC budget.

Another set of costs are likely to be faced by regional councils, who will be required to undertake additional work such as monitoring.

There will also be a need for research, and the question is raised, Who will fund research? It is suggested that it is not sufficient to rely on Public Good Science Funding to carry out the necessary field and laboratory research and it is not clear if these funds are in fact available. Some oppose the proposed programme because of the lack of funding identified so far for ecological research and monitoring.

Funding for mitigation measures

Opponents contend that funding and personnel must be available for any necessary mitigation measures. The RMA is evoked, and the requirement "to avoid, remedy or mitigate any adverse effects on the environment" (682). It is not clear what agencies will have long-term responsibilities for monitoring and mitigation, and if they have in fact agreed.

It is argued by opponents that costs of mitigation strategies should be borne by farmers, not taxpayers.

The greatest concern of opponents is that the financial costs of mitigation measures for predator control will fall on DOC, who already have a limited budget. They see this work as potentially being labour intensive and costly.

Another area of concern is funding for mitigation of effects on domestic rabbits. Opponents want vaccine to be available free to all pet, show, breeding, laboratory and commercial domestic rabbits for five or more years. It is suggested (590) that any cost of upgrading cages and facilities should be borne by government, MAF or the applicant.

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

Costs and benefits should be considered more comprehensively including mitigation measures, and where possible quantified, with a full report of the analysis in the IIA (e.g. 279, 489, 674, 717).

A CBA analysis needs to account for social costs and benefits (e.g. 279).

There should be adequate funding for research and monitoring, not drawing on DOC (e.g. 409, 433, 674).

It is not clear if the groups identified in the IIA have agreed to undertake monitoring, or if public science good funds are available as required (e.g. 258).

There should be a well funded predator control programme outside vote conservation. Costs and resource needs should be identified (e.g. 409, 476, 546, 588, 628, 640).

Funding should be available for vaccination programmes and any other protection needed for domestic rabbits (e.g. 119, 590).

There should be funding identified for any weed control costs resulting from the programme (e.g. 741).

Clarify which part of the total programme cost will be met by the runholders and what part will be met by the public of NZ (e.g. 133).

Landcare groups should be resourced to contribute to the programme, including the necessary education, expertise and finance, in recognition of the stake of farmers in sustainable land use (e.g. 99).

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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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