8 ISSUES CONCERNING THE EFFECTS OF THE INTRODUCTION

8.1 INTRODUCTION

As mentioned in Section 4, when discussing the overall framework for analysing and summarising comments on the substance of the Application, there are certain effects of introducing RCD which are intended - reduction in rabbit numbers and associated improvements in farming prospects. These have been discussed earlier in the sections on the Problem and the Programme.

The effects discussed in this section are as follows:

  • ecological effects;
  • people effects;
  • business effects; and
  • effects on rabbits.

8.2 ECOLOGICAL EFFECTS

Introduction

The submissions contained comments about ecological effects and issues at three levels:

  • ecosystem effects;
  • effects on New Zealand flora and fauna; and
  • issues to do with rabbit predators.

Each provides a context for the discussion of more specific issues at the next level.

Frequency of comment

Of all the sets of effects discussed in this section of the report, ecological effects attracted by far the highest level of comment, with substantial commentary generated by both supporters and opponents of the Application. Overall, the frequency of comment was approximately one-in-three submissions, with opponents commenting about twice as frequently as supporters.

8.2.1 ECOSYSTEM EFFECTS

Comments at this general ecosystem level were relatively few. Nevertheless, when analysed by stance, they are indicative of somewhat different perspectives for each stance and therefore provide some useful introductory commentary to the subsequent analysis.

Supporters of RCD view it as a means of helping "this delicate land regenerate" (254). Farming operates in a productive ecosystem and the effectiveness of RCD in reducing rabbit numbers rapidly and permanently will assist the "adjustment problems with the elimination of the rabbit for the natural ecosystem ... in terms of species survival...." (239).

One submission, offering qualified support, notes that the "benefits to productive ecosystems will largely accrue to pastoral farmers" (553), and suggests that the public benefit of "environmental improvement in the degraded lands" will not be assured unless the grazing pressure, including grazing by domestic stock, is removed from the land, at least temporarily.

Submissions expressing qualified opposition note the significance of reduced rabbit numbers on "conservation values" (532) which depends on the nature of the local environment. They also note that it is not simply a matter of reducing the density of rabbits; but "the effect of habitat change" (609) on the whole ecosystem is important.

Opponents of RCD write about the potential impacts on "our fragile eco-system" (756), "a unique environment and bio-diversity which deserves protection" (192). They describe the ecosystems as complex, with effects difficult to predict, and ask whether a new equilibrium after RCD will be any better than the present.

Some of these themes are picked up in more detail in the following sections.

8.2.2 EFFECTS ON NEW ZEALAND FLORA AND FAUNA

There is widespread concern and considerable debate about the possible effects that an RCD introduction would have for this country’s flora and fauna.

Effects are seen as being either direct - susceptibility of fauna to infection by the virus in its present form or some future mutant form - or indirect - impacts on the flora through altered grazing pressures, or impacts on other animal and bird species as a result of prey switching by predators. The latter will be discussed in Section 8.2.3.

Overview of issues

Comments in the submissions can be grouped under four general themes:

  • uncertainty, and the state of knowledge generally about effects on New Zealand flora and fauna;
  • the particular susceptibility of birds;
  • various issues to do with indirect effects on flora; and

summary comments.

Stance of submitters

Views expressed appear to correlate generally with stance:

- those opposed to RCD place a lot of emphasis on the uncertainty and inadequacy of the current knowledge base, and point to the negative impacts of previous introductions of exotic species; they focus specifically on aspects of the IIA itself, and the testing that was carried out in Australia; they raise issues of avifauna susceptibility and risks to rare and endangered plant species;

- submitters with qualified opposition express the need for more time for testing and to observe Australian experience of ecological effects;

- submitters with qualified support for RCD acknowledge the need to monitor effects on wildlife and emphasise the need for caution when it comes to knowledge of ecological risks; and

- supporters of RCD take the view that present research is adequate, and dispute the benefits of further research.

Submissions from all viewpoints give some attention to the likely effects on vegetation and weeds.

Uncertainty and the state of knowledge

Many opponents of RCD express concern about scientific uncertainties and the inadequacy of the current information base:

"Despite the limited testing of the Kiwi, the effect on New Zealand’s animal and flora environment is unknown, and where such uncertainty exists there is no doubt that the risk does not warrant the action." (49)

Some are critical that the risks and benefits to conservation values are inadequately assessed in the IIA, while others focus on the continuing debate about virus host range in relation to New Zealand fauna and its potential to mutate:

"We are dairy farmers ... There is enough overseas warnings of the dangers of doing so and no known protection for other species if this virus should spread to species other than the rabbit. " (154)

There are claims that insufficient time and research effort has been put into these matters, with several commenting on the fact that the original research programme through to 1998, intended prior to the Australian release, has not been completed. In calling for delays to any introduction to allow for more research, several lay emphasis on the irreversibility of extinctions.

There is a range of issues to do with the testing programme - methods and interpretation, coverage, relevance of overseas conditions. One submitter (135) suggests that "At the very least the tests should be repeated by a separate and totally independent analytic laboratory and overseen by a neutral party such as the Ministry for the Environment." Several others challenge the testing programme’s narrow focus on vertebrates, while others challenge the relevance of testing under overseas conditions, for example:

"No overseas study is relevant to New Zealand conditions. The different Flora and Fauna in New Zealand allows a different environment for mutation and migration across animal species ..." (134)

Numerous submissions point to the inadequate coverage of New Zealand species in the testing programme so far, and identify particular species for further research as the focus of their concerns - NZ dotterel, weka, terns; hawks and ground nesting birds; invertebrates and reptiles; waterfowl, pheasants, partridge, quail; marine species; cats; sportfish and gamefish.

One submission (674) is critical of the IIA - over-emphasising the negative impacts of rabbits on conservation values and under-emphasising issues for flora and fauna in areas where rabbit population densities are low.

Many opposing submitters allude to the negative effects of previous introductions of exotic species.

In contrast to the views of opponents, numerous supporters assert that the existing research base is adequate and, furthermore, that the research proves to their satisfaction that the virus is safe for New Zealand fauna.

"It recognises that a vast amount of highly reputable research information has been accumulated on RCD since 1984 ... This is evidenced in the Application and the accompanying appendices .... is familiar with much of the scientific information ..... we have a high degree of confidence in it." (413)

Several supporting submissions dispute the benefit of conducting further research on wildlife effects prior to introduction, citing Asian and European experience in the field. One challenges the need for further research on endangered species, asking why, if it is deemed to be so important, it was not carried out adequately after previous major knockdowns of rabbit numbers in New Zealand associated with major poisoning operations. One describes specific responses that have been observed:

"Since the Rabbit and Land Management Programme we have seen an increase in bird life ... This has probably come about due to less reliance on 1080 and also to the increase in cover and seed on the land. Most noticeable are increases in the NZ Falcon and Californian Quail." (538)

Several supporting submissions comment on perceptions of risk, for example:

"Those calling for even more research are totally risk averse, yet they have failed to acknowledge the widespread environmental damage that is currently occurring due to rabbit populations." (302)

Several comments from those expressing qualified support for RCD emphasise the caveat "providing it is safe" (637), stating that they "don’t want surprises" (27). There is also support for on-going monitoring of effects on wildlife.

The susceptibility of birds

These comments come entirely from opponents of the Application, and draw attention to what they see as the potentially greater vulnerability of avian species to infection by RCD, for example "Birds have been identified as being more susceptible to viral infections than mammals" (173) Another submission cites previous examples of avian susceptibility:

".. Has witnessed previous unexplained die-offs of game and native species due to ‘viruses’. The Brown Teal duck was one of the countries most common wetland species until a virus impacted on its population in the 1920's. It is now one of the rarest duck species in the world." (135)

and of the New Zealand Weka:

"There is simply no other explanation for why such a ubiquitous and common species should everywhere become extinct all at once. Predators, for instance, were well established in New Zealand long before." (135)

Several submissions suggest that the virus could render eggs infertile, noting particularly the circumstances of carrion birds which are likely to feed on diseased carcases.

Indirect effects on flora

Comments on the recovery of vegetation expected with the reduction in rabbit grazing come from across the spectrum.

Apart from the productive benefits discussed as direct benefits to pastoral farming (refer to Section 7), supporters claim a variety of other benefits from improved vegetative cover - reduced areas of land erosion, enhanced establishment of new pasture species to combat Hieracium, and improved survival rates in tree planting. Many farmers describe how the financial savings on rabbit control will enable more work to be put into controlling other weeds and pests and enhancing habitats for native flora.

There is an expectation, common to all perspectives, that some weed species will prosper with the reduction of rabbits, particularly woody weeds. Opponents of RCD appear more concerned about the ecological impacts of such trends than supporters, although there is agreement that controls on woody weeds will be necessary. One submission (795), with no clear position stated, suggests that certain reptiles could benefit from more woody weed cover.

Opponents raise several other issues about impacts on flora - one in relation to rare and endangered plant species - "Will the influx of weeds also threaten the survival of our fragile unique plants?" (569), and others in relation to burning and overgrazing by stock, suggesting that both practices can be just as damaging to native species as grazing pressure from rabbits.

Summary comments

Some supporters remark that, overall, the introduction of RCD will result in a considerable reduction in the levels of poisons used for rabbit control, which should be beneficial in reducing the non-target impacts of such activities.

Several opponents’ submissions allude to the distribution of risks and benefits between productive and natural ecosystems. One puts it quite explicitly:

".. in the absence of adequate information and research the potential long term risks to New Zealand’s native fauna far outweighs what will be only a short term benefit to a relatively small section of the pastoral farming industry." (469)

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

repeat the tests carried out on kiwis, with an independent laboratory and oversight by a neutral agency (e.g. 135, 149).

extend testing programme for RCD to a broader range of New Zealand species, including avifauna, marine species, cats and gun dogs (e.g. 735, 575, 268, 611, 628, 779, 784).

need for information on expected changes in flora for particular areas, including longer-term successional changes (e.g. 491, 674); also for monitoring (e.g. 585, 121).

need for more detailed information on the status of rare plants and plant communities, and the management initiatives required to mitigate potential negative impacts (e.g. 674).

need for information on the beneficial and detrimental effects of likely habitat changes on New Zealand fauna (e.g. 478).

develop a strategy for control of wildling trees (e.g. 383).

develop a strategy and provide funding for the control of woody weeds (e.g. 416, 478, 505, 532).

8.2.3 PREDATOR ISSUES

Overview of issues

Comments in submissions are grouped under five themes:

  • views on the existence or extent of a prey-switching problem;
  • particular aspects of the prey-switching problem;
  • predator vulnerability to RCD;
  • links with Tb control; and
  • responsibilities for predator control.

Stance of submitters

Predator issues elicited even more comment in the submissions than did concerns about the direct effects on flora and fauna.

There are some areas of agreement amongst supporters and opponents, most notably in acknowledging the prey-switching problem and the need for initiatives to combat it, although there is not consensus amongst all supporters over this. There is however consensus amongst supporters of an important link between control of rabbit populations, rabbit predator populations, and the expected benefits in Tb status, with very little counter argument from opponents.

Views on the existence or extent of a prey-switching problem

Many opponents believe that prey-switching by rabbit predators such as stoats, weasels, ferrets and cats, denied their usual diet, is likely to be a problem for a wide range of species, particularly birds, small vertebrates and invertebrates. Many note particular species - such as albatross, yellow-eyed penguin, pukeko, quail, skinks, geckos, weta, other lizards and invertebrates, domestic pets, poultry and stock. Ground-nesting birds and their eggs, as well as flightless bird species are seen as particularly vulnerable.

Several submissions refer to lists of fourteen species at risk and forty-eight locations identified by the Department of Conservation, and some claim that there are still omissions from the list of vulnerable species.

Quite a lot of supporters acknowledge this risk as well, for example:

"Concerns have been expressed that the introduction of a biocontrol agent could depress rabbit numbers so quickly that predators would be forced to switch to other prey. This could have serious implications for native fauna. I believe the approach which needs to be taken is first to recognise and quantify the risk, then to take whatever steps are required to alleviate the risk. If that requires targeted predator control, then it should be done." (399)

Another supporter observes that the need for such control may be more pressing in the South Island (377), while many point out that the availability of RCD will release funds to support the necessary control efforts.

One submission, with qualified support for RCD, observes that an unauthorised introduction would make effective management of prey-predator problems more difficult (619), and another such submitter expresses concern that effective predator poisons will not be ready by 1997 (247).

Nevertheless, amongst supporters of RCD, opinions are clearly divided between those who assert that there will not be a problem with prey-switching, or that the problem is being overstated by opponents of the virus, and those who acknowledge that there is likely to be a problem which will require control of predator populations.

A few simply claim there will be no problem, while others say the opponents overstate the degree of the problem. A number of other lines of argument are put by some supporters which challenge the need for predator control. For example, one disputes that predators will actually switch to birds: "I don’t believe this to be the case. Cats have always preferred birds to rabbit, but without the backup of the rabbit I don’t consider a cat capable of catching enough to sustain life. My experience was when the numbers were very low or nil in a lot of areas, cats and ferrets virtually vanished within two years." (218). Another (??) disputes the role of predators in controlling rabbits in Central Otago, while many advance the argument that current controls produce similar fluctuations: "We maintain if this was a problem why has it not been raised in the last 40 years with knockdown with 1080?" (344). Predators, they claim, simply die off without food.

One supporting submission, while acknowledging that prey switching does occur, believes that "the effect could be expected to be less significant than currently occurs over 1080 poisoning regimes" because, the submitter claims, in general 1080 poison operations kill more than 95% of the target rabbits whereas Australian experience suggests "we may expect RCD to bring kill rates of 60 to 90%." (555).

Aspects of the prey-switching problem

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. All these factors lend uncertainty to predictions about the prey-switching problem.

Several submissions discuss the ramifications of cycles or oscillations in rabbit and predator numbers in any location, preventing the establishment of stable ecological inter-species balances, as well as prey/predator/invasive weed balances. One submission (648) points out that the oscillations in populations could disrupt effective predator control elsewhere in New Zealand. Others note that, since the manner of the spread of the disease throughout New Zealand is difficult to predict, the need for and timing of predator control becomes even more difficult to manage.

A number of submissions are critical of IIA assertions concerning the timing and duration of the prey-switching phenomenon. For example:

"Prey switching will occur immediately after an effective kill, not ‘some months later’. The report suggests that the effect of prey switching will be short term. This assumption is ‘irresponsible nonsense’. Mustelids in particular are ‘rampant killers’ often one small animal kills a dozen or more large adult birds (ducks, fowls, penguins) in one night." (621)

There is some criticism also of the IIA dismissal of the concept of predator guild changes as ‘speculative’. Several submissions discuss this topic, suggesting that stoats and rats, which may take over from ferrets and cats if rabbit numbers remain suppressed for a long time, are more serious conservation pests and are difficult to control. At least one submission supporting RCD, acknowledges the likelihood of predator guild changes - "a reduction in the rabbit predator population ....would almost inevitably result in an unacceptable increase in the rate and stoat population." (360). Others refer more generally to the paucity of knowledge about the population dynamics of prey-predator relationships in various parts of the country, and the likelihood of local extinctions, a matter which, it is claimed, the IIA does not adequately address. The difficulty of controlling all predators simultaneously is also noted.

Predator vulnerability to RCD

Several submissions, from both ends of the spectrum, point to another aspect of uncertainty by asking if rabbit predators will be vulnerable to infection from eating diseased rabbits. They believe this matter is not given adequate attention in the IIA nor in the Australian tests.

Links with Tb control

Many supporters of RCD express enthusiasm about what they see as the potential benefits for their efforts to reduce Tb in livestock. Several state that the role of ferrets in the spread of Tb is now recognised scientifically.

"There is clear evidence that the reduction of rabbits and trapping of predators will see properties move back towards Tb Accreditation." (288)

A few submissions discuss the complementary nature of Tb eradication and predator control programmes. One claims that predator trapping is already occurring in the fight against Tb; that this practice will be reinforced by its added significance for rabbit control and wildlife predation.

This optimism by supporters of RCD is not entirely unchallenged by opponents. For example, one submission (755) claims that hungry predators will tend to travel long distances in search of food, with the consequent risk of carrying Tb long distances as well.

Responsibilities for predator control

While not exactly reflecting agreement on all sides the comments on predator control responsibility indicate a degree of complementarity.

Opponents claim that the IIA lacks clarity about who should have responsibility for predator control, and how funding will be provided. Quite a few express the view that funding should not be the responsibility of the Department of Conservation; this would only have to be traded off against some other under-funded protection programme. Nor should NGO’s like the Royal Forest & Bird Protection Society be loaded with the funding responsibility (There is more discussion of this in Section 9).

Several submissions raise issues of integration in planning predator control strategies. One opponent refers to an absence of previous experience and good examples for predator control strategies that go beyond localised target areas. One supporter notes the potential for interference with existing national disease control strategies (175).

Several supporters make comments that indicate an already emerging partnership with the Department of Conservation, while another (625) urges commitment by all parties to take predator control seriously.

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

collate findings on effects of rabbit population knockdowns on predator species elsewhere in the world (e.g. 542).

more conclusive research on the ‘predator chain’, predator guild changes, and the identity of particularly vulnerable species (e.g. 305, 505, 609, 612).

accelerate the development of effective predator poisons (e.g. 247).

develop improved methods of predator control (e.g. 505).

develop and fund a strategy of predator control prior to RCD release and concurrently with the release programme, including monitoring (e.g. 99, 162, 165, 205, 209, 416, 511, 575, 585).

carry out widespread consultation in developing the predator control strategy (e.g. 554).

make assessment of likely success of predator control efforts to ameliorate prey-switching impacts (e.g. 674, 720).

8.3 PUBLIC HEALTH EFFECTS

Frequency of comment

The frequency of comment on public health related issues is moderately high, at one-in-eight submissions. The frequency of comment is very different between those who support the introduction of RCD (one in thirty supporters) and those who oppose it (one in five opponents). A small number of comments were received regarding the potential food-chain implications from introducing the virus. These came mostly from opponents, with a few from submitters whose position is unclear. Since these comments overlap substantially with other comments on human health risks, they have been combined for the purposes of this analysis.

Overview of issues

There are four general themes underlying submitters’ comments on public health risks:

  • matters to do with the state of knowledge on the possible health risks of the RCD virus;
  • views on the risks and mechanisms of human exposure to the virus;
  • issues concerning human immunity; and
  • the issue of public confidence.

8.3.1 THE STATE OF KNOWLEDGE OF POSSIBLE PUBLIC HEALTH RISKS

The stance of submitters

Both supporters and opponents comment on the amount of research that has been carried out and the standards of evidence available.

Opponents also raise issues to do with scientific precedents and comparisons with other caliciviruses, and the perceived bias in the interpretation of results.

One submitter (420) whose position on the proposal is unclear, raises an issue concerning the inadequacy of certain aspects of testing for human health risks.

The amount of research carried out

One submission (413) in favour of introducing RCD expresses the view that the virus does not pose significant risks to humans on the basis that "a vast amount of highly reputable research information has been accumulated on RCD since 1984 when it first appeared in China", noting particularly the work in Australia and Mexico on laboratory workers.

By contrast, opponents of RCD assert that the public health risks are under-researched; that the Australian laboratory worker studies are essentially anecdotal; that laboratory conditions are unrealistic, given standard laboratory safety precautions; and that no positive testing has been carried out that specifically challenges human health or even surrogates such as apes. Another submission (554) specifically challenges the statement on p.52 of the IIA that "Even if it did switch species, there is no reason to suppose that rabbit calicivirus ... would cause the same pathology in humans or other species" as not being based on sufficient research.

The standards of evidence available

Closely related to the amount of research carried out is the issue of the standard of scientific evidence that is available at the present time. As before this reveals highly contrasting views.

One submission (443) in support of RCD observes that "International research over the last 11 years has not demonstrated that RCD has any negative impact on human health or welfare"

Many opponents express concerns over what they see as inadequacies in the evidence on human health risks at the present time. Submission 29 characterises this sentiment when it states "There is not enough known about viruses etc by scientists and the medical profession to take the chance with humans...". Indeed, a theme running through submissions which oppose RCD is the need for high standards of evidence when dealing with something which has the potential to affect many people and which is irreversible. Several opponents specifically challenge any scientific logic based on the absence of contradictory evidence:

"It is very easy to say there is no evidence when no long-term research has been carried out" (362)

Other submissions note the absence of expert consensus about the effects of RCD on humans; the inadequacy of anecdotal evidence on health effects; the comments reported from the Chief Medical Advisor at the Australian Department of Health and Family Services stating that there is no guarantee of human safety with respect to RCD; and suggestions that Australian authorities show enough concern to insist on protective clothing if working in the field.

Scientific precedents and comparisons with other caliciviruses

It is only opponents of RCD or those with no stance on the proposal who raise the issue of precedents to the proposed RCD importation, or assert the relevance of experience with other caliciviruses or similar viruses. Nevertheless, there are many submissions on these matters.

A considerable number mention the world’s previous experience with "mad cows disease" and CJD, noting the reassurances from politicians and scientists that there was no danger to humans because the disease was specific to cows, and raising in some people’s minds the issue of credibility for scientists and decision makers in these kinds of debates:

"How can we put our trust in the scientific world? The scare with Mad Cow Disease shows just how devious governments, scientists and even the medical profession can be." (40)

Another submission emphasises the long latent period for Mad Cow Disease (52).

A number of submissions which appear to have been compiled after considerable investigation discuss the relationship between various groups of viruses and the susceptibility of humans to infection by them. Submission 376 notes that caliciviruses are divided into five major groups, and asserts that four out of the five groups are known to cause disease in humans, with one already known to cause hepatitis with haemorrhage in humans.

The link between hepatitis E and rabbit calicivirus is made by several submitters. One (448) suggests a possible link between the two viruses, while another draws on the experience with hepatitis E to challenge statements made in the IIA - "Given the world wide failure to identify hepatitis E, it is in our opinion unreasonable to claim no human infection by a very similar virus RHVD/RCD exists" (236).

Yet another submission claims that a health survey in Brazil identified a calicivirus as the cause of gastroenteritis in humans. The submitter believes that recent experience with ‘emerging viruses’ which cause diseases in humans is that "many are unpredictable", citing the example of the hantavirus which in different countries has different hosts and attacks different organs in the human body (768).

Commenting on the potential for human susceptibility to the virus, submission 236 cites the veterinary research literature in attaching significance to a perceived close histocompatibility between rabbit blood and human blood.

Interpretation of results

There are a few opposing submissions which claim bias in the interpretation of results - both in specific instances, and in general presentation. For example, submission 673 is critical of the interpretation of results in the human sera tests carried out in Australia by the Rabbit Calicivirus Human Health Study Group, while submission 240 has a more general criticism:

"The risks are portrayed as remote possibilities and insignificant compared to the benefits."

Shortcomings in the approach to testing for human health risks

Several opponents comment on the absence of a planned positive programme of testing of humans for RCD-related disease, and these were mentioned above (Refer ‘The amount of research carried out’). A more specific aspect of approach was raised in submission 420, which is critical of the IIA analysis of potential risks to humans for assuming that all humans, irrespective of age, are a single species and class of risk. The submitter states from a medical viewpoint:

"Foetus and neonate often behave so differently as to warrant consideration as separate categories of the human species. ......It is my conviction that the risk-benefit analysis of the likely impact of introducing the rabbit calicivirus has not included consideration of these 27 vital months of human life,.."

and claims that until a baby is 18 months old, it has to exist without a fully developed immune system.

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

collate information on the incidence of RCD-related disease in humans in other parts of the world (e.g. 176).

pursue evidence of health risks in Australian field conditions with positive research (e.g. 236, 252, 310).

review research on all caliciviruses and their possible links to human health (e.g. 768).

carry out an independent review of scientific methods used in testing for human health risks in Australia (e.g. 796).

8.3.2 RISKS AND MECHANISMS OF HUMAN EXPOSURE TO THE VIRUS

The stance of submitters

Both supporters and opponents comment on the perceived risks of direct contact with or ingestion of diseased rabbits. Opponents also give attention to indirect mechanisms for exposure to the virus via food chains or water contamination.

Direct exposure to diseased rabbits

A number of submissions comment on the risks to be expected from close exposure to the virus, a situation that would apply, amongst others, to farmers, pest destruction personnel, those engaged in hunting or eating wild rabbit, and owners of pet rabbits. The range of views covers the entire spectrum.

It is clear that farmers who support the introduction of RCD do not anticipate any risk from possible exposure to the virus, although there are a few opponents who do not share their confidence. While supportive of introduction, another submission comments on the situation of pest destruction staff, expressing a somewhat more cautious view "so long as it can be proved to be harmless to humans" (227). A submission (120) expressing qualified opposition asks about the possible risks to hunters eating wild rabbit meat, and several opponents express regret that wild rabbit meat would no longer be a safe source of food.

One of the submissions which expresses no clear position on the Application cites the French experience as indicative of many other countries:

"..since 1984, when the virus was first identified, the virus has spread to over 40 countries throughout the world containing approximately 50% of the world’s population. During this period there have been no reports in the medical, veterinary or microbiological literature linking the virus to unexplained disease in humans or subclinical infection in humans. ...human exposure levels in many countries is potentially high. For example, in France where the disease is endemic, 25,000 tonnes of rabbit meat is consumed each year." (478)

Then there is the case, which several other submissions refer to as ‘the Bailey Case’. Their own submission (38), which takes no position on the Application itself, notes their personal experience of unexplained skin complaints when looking after rabbits that were subsequently diagnosed as having died of RHVD. Their submission explains that while the condition persists they have been unable to access either adequate diagnosis or treatment for it.

Indirect mechanisms for exposure

A few opposing submissions ask about the risks to those who eat wild game that may have devoured diseased rabbits, infected with RCD. A few also raise the issue of the potential for diseased rabbit carcases, (particularly in large numbers that would follow an initial outbreak of the disease) to contaminate water systems in those catchments.

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

assess possible water quality impacts for catchments where high numbers of rabbits are expected to be killed over a short period (e.g. 236, 673).

determine programme for the disposal of diseased carcasses (e.g. 236).

address issue of isolating babies from possible infection (420).

carry out research specifically on potential "food chain" risks from RCD (e.g 611, 784).

8.3.3 HUMAN IMMUNITY

Stance of submitters

The few comments received on this topic represent the full range of stances - from support to opposition, including one with no clear position stated.

Several opponents express concern at the lack of fail-safe or preventative vaccines, with one also noting the difficulties of achieving this "with mutation going on" (479). One opposing submission (135) makes the point that "The lack of obvious symptoms would mean that if humans were affected we would probably not even realise we had anything worse than a cold before death occurred.". Several other submissions state the view that "our immune systems have enough to deal with .." (474) without the extra stress of another virus or vaccine.

The special circumstances of the reduced immune system capacity in babies has been noted above (Refer ‘Shortcomings in approach to testing’).

One supporting submission puts the contrary view in relation to the challenge that the introduction of RCD would pose for humans’ immune systems. It suggests that "the dangers of RCD introduction are overstated", adding that:

"The disease is already part of the global ecology. It is thriving in some of the densest human populations on earth, with access to 1000 times the population of NZ. If it were to mutate to a harmful virus in this sense, it would arrive in this country like any other viral disease. It could be argued that our best defence against such an improbable scenario, would be to expose our population to the benign form as soon as possible!" (271)

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

address special risks of foetuses and neonates (420).

collate information specific to teratogenicity of RCD (420).

8.3.4 PUBLIC CONFIDENCE IN THE PROPOSED INTRODUCTION

Stance of the submitters

All stances express views that indicate their perceptions of the state of public confidence at the present time. In addition, opponents brought up the question of the long-term nature of the risk.

Public confidence

Of the submissions in support, many reflect their confidence in the health implications of introducing RCD in simple statements such as "no threat to human health" (379) and "believes RCD is proven safe for humans" (417). Despite expressing confidence in the findings of the IIA, one supporting submitter acknowledges that the risk of human infection had been one of the more important risks to consider (157). Another supporting submission put the argument as follows:

"...believes that balance of scientific evidence indicates the risks of potential negative effects on humans and other species are not significant compared to the benefits." (413)

There are many opponents who express their doubts over the risks to human health. Several acknowledge that anecdotal information concerning reports of incidents for individual cases overseas has triggered or reinforced their doubts, while other submitters acknowledge the influence of other medical scares in recent memory, such as the BSE-CJD scare and the worries over blood contamination associated with hepatitis or HIV/AIDS. Several say that the failure of the IIA to address human health issues adequately could lead some to conclude that health issues have not been considered and do not matter.

A common theme in submissions from opponents is that"Its just not worth it." (141)

A few submissions, all opposing the Application, make the point that the risk to human health posed by the deliberate introduction of RCD into New Zealand is not just a new risk factor; it becomes a long-term, indeed permanent risk factor, and one that may change over time.

8.4 EFFECTS ON MAORI

Frequency of comment

The possible effects of the RCD virus on the relationship of Maori and their culture and tradition with ancestral lands and other taonga is among the topics that drew the least comment. Comments can be grouped under two themes:

  • the adequacy of identifying effects; and
  • the effects in the context of Treaty responsibilities.

Issues to do with the process of iwi consultation were discussed in Section 2.

Adequacy of identifying effects

One South Island Council involved with the Applicant Group submits that during consultation some concerns were expressed about possible unforeseen effects of the disease. However, the submitter takes the view that such unforeseen effects are dealt with adequately in the Application (413).

In contrast, one opposing submission (referring to p.22 of the IIA) notes the apparent bias in relation to potential Maori concerns, where concerns about the current use of toxins in areas considered to be waahi tapu or waahi taoka are discussed without mentioning the equally strong concerns relating to any introduction of an exotic virus (487).

Another submission, not expressing a clear position on the proposal, is nevertheless critical of the poor depth and coverage accorded Maori issues, stating that the Application does not sufficiently identify the impacts of rabbits as pests on Maori values, nor does it substantiate the points that are included (478).

In the context of the Treaty

Several opposing submissions claim that the Application does not uphold the principles of the Treaty: "it would be in breach of ‘Te Tirit O Waitangi’." (649). Another observes that introduced pests such as rabbits have affected kaitiakitanga, and so will RCD as its short and long-term effects are unknown (436).

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

incorporate and substantiate views of Maori on possible effects of RCD (e.g. 478).

8.5 EFFECTS ON ENTERPRISES BASED ON CONTROLLING WILD RABBITS

This section deals with comments on pest control, pest management or related businesses. Harvesting of feral rabbits as a resource is discussed in Section 8.6.

Frequency of comment

The frequency of comment related to impacts on rabbit-controlling activities was low, with little difference between the frequency of supporting and opposing submissions. Nor does there appear to be much disagreement over the likely consequences of introducing RCD. Essentially, submitters agree that the advent of RCD would undermine the basis of a range of enterprises that are currently related in a general sense to the control of feral rabbits.

Various submitters point to reductions in opportunity for:

- operators involved in large-scale poisoning, usually aerial poisoning (e.g. bait growers and aircraft operators);

- professional game shooters;

- the growing petfood industry, currently based on rabbit meat; and

- licensors and firms providing equipment to recreational hunters.

One supporting submission from a firm involved in selling pest control equipment, notes that they have already experienced a significant loss of sales, which they attribute to a downturn in pest control efforts by regional councils, in the expectation of RCD (247). A submission opposing RCD expresses concern that the impacts on licence sales will occur all around the country, even though, in its view, 95% of the country does not have a rabbit problem (135).

Another submission also notes that the cooperation between town and country over rabbit shooting that was generated by the move to ‘user pays’ in pest control, will probably be lost (235).

8.6 EFFECTS ON THE HARVESTING OF FERAL RABBITS

Harvesting of feral rabbits encompasses the taking of rabbits, dead or alive, for private consumption, pet food manufacture, or processing for domestic consumption or export, which may involve meat, fur or other rabbit products. The effects of an RCD introduction on overseas markets are discussed in Section 8.7 - International Trade.

Frequency of comment

The frequency of comment on rabbit harvesting issues is moderately high, at one-in-ten, with a greater frequency amongst opponents of RCD (at one-in-seven) than amongst supporters (at one-in-twenty five). More significantly, the submissions on this topic represent quite polarised viewpoints.

Overview of issues

The discussion in this section focuses on the potential of the industry in New Zealand, and issues to do with feral rabbits as an informal food source. Issues raised in the submissions can be grouped into three themes:

  • the industry environment - attitudes, opposition, incentives;
  • resources of the industry - the potential raw material, employment, skills and markets; and
  • informal food gathering.

The industry environment

Attitudes to the rabbit harvesting industry are highly polarised. Numerous supporters of RCD claim that the potential role of the rabbit-harvesting industry is both exaggerated and mis-represented. For example:

"Since 1993 there has been some commercial harvest. However, properties which are being regularly harvested for commercial gain, are still being issued with enforcement notices by Regional Councils as rabbit numbers are above levels which cause environmental damage. The simple reality is that returns from commercial harvest are not sufficient to encourage hunters to maintain rabbits at acceptable levels. The financial returns from rabbit harvest would have to be significantly higher before acceptable levels of control would be achieved." (555)

Other submissions assert that rabbit processing operations do not control rabbit numbers and have struggled to survive even in heavily infested areas, leading to continued land degradation and negative effects on neighbours. Supporters of RCD maintain that it is not farmers or the market uncertainties that will stop commercial rabbit harvesting:

"An enterprise based on unconfined feral rabbits would be very difficult if not impossible to manage within the constraints of the Resource Management and Biosecurities Act." (271)

The opposing view (advanced by opponents of RCD) states 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, a matter over which they are critical of the IIA. In this regard, several submissions note the paradigm shift that has occurred over deer:

"Thirty years ago our Government paid for deer kills - now the deer industry is earning us millions. This is primarily due to a paradigm shift regarding deer. Rabbits, as a source of protein, is not addressed at all (in the IIA) ... and no disqualifiers are offered why rabbits could not be similarly exploited as a resource." (400)

Various submissions claim knowledge or experience of bureaucratic obstacles to the establishment of rabbit harvesting ventures, while several say they would rather see incentives introduced to provide better returns to farmers and shooters and thereby foster commercial harvesting, than have the virus introduced.

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: "A thorough investigation into the viability of this operation in New Zealand is necessary bearing in mind the existence in this country of a $300 million pet food industry and the alleged popularity of ‘white’ meat." (175)

Arguments about equity are equally polarised. For example, supporters of RCD say:

"The only people who are likely to suffer any loss of income are the people who process rabbits either for meat or pelt. To my mind their loss is completely insignificant in relation to the loss of income suffered by farmers who have a heavy infestation of rabbits." (157)

and:

"The elimination of these activities is surely a minor price to pay for the huge benefit that would accrue to our productive and eco systems." (239)

while opponents of RCD say, for example:

"By removing the options for commercial harvesters to further develop this industry, one is disadvantaging this group in order to satisfy the demands of, in reality a very small number of other business opportunists in NZ, i.e. those who do not take their responsibilities and address their risk management policies seriously. The principle is quite simple - if you cannot stand the heat, get out of the fire!" (366)

Resources of the industry

Many submissions opposing RCD assert that its introduction will have severe implications for the fledgling industry based on such a potentially valuable food resource. Citing an export order for one million rabbits per week one particular submission claims "Such an industry cannot establish without a guarantee that RHD will be kept out of New Zealand." (135). Submitters are critical that the IIA has failed to assess the commercial opportunities for rabbit products from a virus-free country, and that there is no consideration of compensation for this loss of opportunity.

A number of submissions point to the loss of jobs that will accompany the introduction of RCD - jobs at existing rabbit meat processors and pet food manufacturers, as well as professional hunters. Looking further into the future, several other submissions anticipate a consequent loss of skills, which will have cost implications for both the Department of Conservation and for farmers:

"... an adverse effect on our next crop of ‘smallgame hunters’ who harvest rabbits on a sustainable no cost basis all farms they have access to." (193)

"Over 80% of new firearms licence holders give rabbit hunting as their reason for obtaining the licence. Many will over time graduate to big game hunting and make a major contribution to conservation and cost savings to the Department of Conservation." (201)

Countering the view, expressed by numerous opponents of RCD, that rabbit shooting would make gainful employment for the unemployed, a supporting submission (297) observes that such allusions to what used to happen fifty years ago are no longer valid, since people’s expectations for a basic standard of living have changed so much.

One submission, stating no clear position on the Application, cites that the Australian experience of RCD has closed most commercial rabbit harvesting enterprises, affecting owners, independent shooters and processors (478).

Comments on the threat to markets overseas are discussed in the section on International Trade.

Informal food gathering

Three issues are raised by people engaged in hunting wild rabbits for the table - all opponents. Firstly, they express regret that such wild meat will no longer be available, either because of scarcity or the risk of contamination with disease. Secondly, they ask what safeguards are intended against the possibility that infected rabbit might be consumed. Thirdly, they ask whether the introduction of RCD would be a precedent for introducing other biological controls for other pests which currently provide wild meat.

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

more in-depth analysis of commercial harvesting options (e.g. 547).

information on whether infected meat can be processed safely for consumption (e.g. 784).

8.7 EFFECTS ON INTERNATIONAL TRADE

Frequency of comment

The frequency of comment on trade-related issues is moderately high, at one-in-ten, with a greater frequency amongst opponents of RCD (at one-in-seven) than amongst supporters (at one-in-twenty five). More significantly, the submissions represent quite polarised viewpoints.

Much of the comment on image and trade is of a very general nature, although particular industry sectors come in for some specific attention. Thus, in addressing international trade implications, most submissions imply a focus on traditional agricultural exports. Some focus their attention on the international market opportunities for feral rabbit products, while a few highlight the inbound tourism industry, and another (673) draws links with this country’s international conservation status.

Overview of issues

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.

Perceptions of likely impacts on New Zealand’s image overseas

Most of the supporting submissions adopt a perspective of comparing perceptions of RCD with existing control technologies. They focus 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:

"Continued high use of 1080 poison may, in time, prove unacceptable to some of our major trading partners, through non-tariff barriers..... Although the introduction of RCD may not preclude the use of 1080 poison, it will significantly reduce the need for its use to a level where hopefully it would be unimportant to our major trading partners." (583)

"How Clean and Green is the present indiscriminate use of poisonous chemicals?" (444)

One submission (271) in support suggests that failure to control rabbit plagues will not enhance our international reputation for caring for the environment, while another (296) argues 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.

In general, submissions from supporters of RCD believe that its introduction should help New Zealand’s image and trade prospects.

Opponents point to several aspects of image they see as being vulnerable. Many comment generally on the threat to the "clean and green" image. Some focus particularly on the importance of maintaining this country’s relative disease-free status and suggest that it "is unreasonable for the small percentage of people affected by rabbits to put at risk New Zealand’s clean green image by the importation of a virus that most of our trading partners want to have nothing to do with." (246).

Submission 791 suggests that this country’s meat exports are already vulnerable to interruption by disease risks without introducing any more disease, while submission 673 asserts that any action in New Zealand that led to extinctions of further species would badly affect the country’s standing in world conservation. Another claims there is no evidence to suggest that RCD will enhance our clean, green market image, since so many pesticides and herbicides are widely used. (436)

Direct trading impacts

Arguments from supporters of RCD describe aspects of marketing and competitive advantage for the traditional agriculture sector. Submission 189 claims that RCD is necessary for rabbit control in New Zealand if this country is to be competitive with Australia, which already has the biological agent. Another submission states:

"We believe the controlled introduction of RCD would have no effect whatsoever on the marketing strategy or the acceptance of this high quality product within the international marketplace." (583)

while several point to the expected benefits for meat producers of reducing the incidence of Tb in New Zealand.

One submitter, offering qualified support for the introduction of RCD, sees the potential benefits from changes in stock condition enabling New Zealand to get an edge on its competitors (457).

Opponents of the Application are critical of what they see as the narrow and short-sighted nature of the assessment of trade impacts. The biotechnology perspective is described as being involved in the sale of high value products which are in demand overseas because they come from a disease-free environment. The submitter (153) urges caution, since this sector of trade would be jeopardised to some extent by the arrival of RCD. Tourism in general, and rural tourism, including farmstays, is viewed as vulnerable because of the risks that tourists might unwittingly act as carriers of the virus on their shoes and clothing (755).

Submission 768 asks whether a wider economic assessment of potential trade impacts has been considered; one covering a wider range of export sectors.

Quite a few 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. In the shorter term however, despite the perceived risk that non-tariff trade barriers could result from the introduction of RCD, with the exception of a feral rabbit meat processing plant, all meat producers contacted by the Ministry of Commerce expressed no concerns about market impacts (489).

One submission, with no clear position on the proposal, suggests that the Australian experience to date indicates that the only trade consequences from the release of RCD have been on rabbit products (478).

Market opportunities for feral rabbit products

In this section, views on the implications for the international trade in rabbit products are discussed. Other aspects of the potential impact of RCD on rabbit harvesters were discussed in Section 8.6 above.

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. They point to the high prices in Europe for organic feral rabbit meat, the perceived huge demand in China, that is well beyond the present capacity of NZ exporters, and the demand for skins in India and skins and meat in other Asian countries. One submission draws attention to the claim that rabbit meat is amongst the lowest cholesterol white meats available (135) while others point to the possible employment opportunities.

Several submissions suggest that the potential for a rabbit meat industry is excellent. Its main opposition, it is claimed, comes from those farmers who are unwilling to see rabbits change from an agricultural pest to an agricultural commodity. Some countries, it is claimed, have already banned rabbit products from countries where RCD is established (554).

Circumstances regarding RCD that prevail in other countries

Competing viewpoints are expressed by supporters and opponents of RCD on the significance of RCD being present in other countries. Supporters of RCD take the view that much of the world’s population lives with RCD already. Since the virus has been in many European countries for over a decade, its introduction into New Zealand is hardly likely to have an impact in the minds of Europeans. Even a submission which expressed qualified opposition to the proposal, contains the view that because the virus has been long established "it is not seen as novel nor significantly threatening." (489).

However, opponents of the RCD proposal say that it is precisely this difference - the fact that New Zealand is one of the relatively few parts of the world that could reasonably expect to escape RCD, unless deliberately introduced, that is the basis for this country’s advantage.

Opposing submissions go further and claim that some trading partners classify RCD as a Foreign Animal Disease (FAD) agent or notifiable disease; that releases of such biological control agents are not legally possible in a number of countries; that indeed some countries are trying to eradicate the disease.

It is suggested that the FAD status of the virus in the US could pose a significant threat to the levels of US-sourced tourists.

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

a more comprehensive assessment of the potential impacts on overseas trade, with some particular attention to tourism (e.g. 458, 478, 576, 577, 722).

8.8 ANIMAL WELFARE CONCERNS

Frequency of comment

The frequency of comment on animal welfare issues is moderate, at one-in-fifteen submissions. The frequency of comment is very different between those who support the introduction of RCD (one in thirty supporters) and those who oppose it (one in ten opponents).

Overview of issues

Comments in the submissions address:

  • personal judgements about the humaneness of RCD, and balancing concerns about pests and land;
  • comparisons of RCD with other methods of rabbit control;
  • perceived evidence for rabbit suffering; and
  • criteria for establishing rabbit suffering.

Personal judgements and balancing concerns

Many of the submissions make personal judgements about the humaneness or inhumaneness of RCD as a method of killing rabbits. These judgements invariably reflect the submitters stance on the proposal.

One submission in support of the proposal asserts that the public outcry about the suffering of rabbits is based on ignorance (279) - ignorance of the trade-offs that have to be made, or ignorance of the merits or otherwise of alternative methods for killing rabbits. Various farmer submissions assert that farmers are not gratuitous in wishing to inflict pain on rabbits:

"We acknowledge the concern for the associated suffering to the rabbit population. Farming communities have a close affiliation with their animals, and farmers generally have a very responsible attitude to inflicting pain on any animal." (456)

However, they argue, the image of ‘cuddly’ rabbits has to be offset by the need to deal with an urgent farm problem. Another submission in support of RCD notes that people also experience anguish over "good land being destroyed by rabbits" (279) and this needs to be remembered as well when weighing up the welfare arguments.

Comparisons of RCD with other methods of rabbit control

Numerous submissions from both sides of the spectrum make comparisons, in animal welfare terms, of the various methods of rabbit control.

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 acceptable humane.

Two points are made by submitters who state no clear position on the RCD proposal. One recommends that any control method be as humane as possible (262) while the other points out that the IIA contains no comparison with the humaneness of other methods (478).

Based on their first-hand experience of rabbit killing, some supporters of RCD present a very different picture of the comparisons with other methods. Several suggest 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. Another observes:

"Death and injury from shooting, poisoning and trapping can be very traumatic and cannot be considered humane" (413).

Perceived evidence for rabbit suffering

That rabbits do suffer is a topic addressed explicitly by a few opposing submissions.

Submission 554 asserts that the suggestion that RCD is humane is not borne out by the available information, and claims that a passive reaction does not necessarily mean there is no suffering. Another expresses the view that similar conditions in humans - blood clots and heart and respiratory failure - cause excruciating pain (448). Several cite reports received from Australia describing rabbits "screaming in pain before death, blinded and convulsing" (449) and describing how harsh the vaccine is to rabbits.

Criteria for the acceptability of suffering

A few submissions make observations on this theme.

Several opposing RCD assert that just because the suffering is out of sight - internal to the rabbit, or in burrows below ground - does not make it acceptable. One opponent draws the analogy with bacteriological warfare as cruel and historically deemed to be totally unacceptable (591). Another expresses cynicism over the renaming of the virus, suggesting that the change from Rabbit Haemorrhagic Disease (RHD) to Rabbit Calicivirus Disease (RCD) is an attempt "to make it sound more humane" (695).

The concept of ‘aggregate pain’ employed by the IIA to describe the pain experienced by populations of rabbits draws support from one submission favourably disposed to RCD (279) and is criticised by one submission of the opposing view (554).

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

more research into humane forms of rabbit control (e.g. 554).

systematic comparison with humaneness of other control methods (e.g. 478).

8.9 CONCERNS FOR DOMESTIC RABBITS

Overview of issues

This section covers comments in the submissions which address the potential impacts on pet owners, breeders, rabbit farmers and laboratory/research operators.

Topics covered include the perceived likely impacts on all these categories of rabbit owner, as well as a range of issues concerning an RCD vaccine.

Frequency of comment

The frequency of comment overall is moderate, at one-in-fifteen submissions, most of which come from people opposing RCD.

The few submissions from those who support RCD declare their belief that a vaccine is available to protect domesticated and farmed rabbits:

"I am satisfied that the risk to domestic rabbits, recreational and commercial users is adequately explained and justified." (553)

Impacts on pet owners

Many submissions state their objection to the threat that RCD creates for those who own pet rabbits, and allude to the distress that pet owners will experience if their pet dies from the disease. Several point out that, since rabbits are relatively inexpensive to buy and keep, they provide a lifelong hobby for many people, a hobby, it is claimed, which it is their right to enjoy. Some submissions highlight that rabbits are often owned by the young and the elderly, and one describes experience of their importance as pets for disabled children.

The risks of cross-infection, it is argued, will lead to a situation where showing rabbits will become virtually impossible. Moreover, the concern of pet owners for their rabbit’s health and welfare after any introduction is viewed not just as a remote possibility but rather as a daily concern.

Impacts on breeders and rabbit farmers

The impacts on breeders and rabbit farmers are described as being both financial and logistical.

Measures seen as necessary to protect rabbit breeders include erection of rabbit proof fencing, sterilisation of feed and bedding materials, control of airflow and insects in the sheds, vaccination of breeding stock, and footbaths for managers. Similar measures for boundary protection, sanitation, insect control, sterilisation and vaccination are expected for rabbit farmers. A rabbit farming operation expresses concern about the difficulties and expense of inoculating their rabbits because of the quick turnover of stock (319). The inability to guarantee safe feed supplies is also mentioned.

All these come at considerable financial cost, as well as the responsibility on employees.

One submission raises the possibility that infection by RCD could decimate the limited gene pool for rabbit breeders (448).

Another submission in opposition from a rabbit farming enterprise notes that Japan has already banned a consignment of rabbit by-product from Australia because of the risk of contamination after RCD escaped from Wardang Island (458).

One submission which states no clear position on the proposal suggests 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 (478).

Impacts on laboratory/research establishments

One opposing submitter, who is involved in a long-term genetics case study on rabbits, objects to the threat to the bloodlines that have been developed in the experiment (45). The submission indicates that the research involves large numbers of animals over a long time period in order to obtain significant results, and claims that the vaccination costs for all stock each year would be prohibitive.

Vaccine availability

A range of issues are raised concerning the availability of vaccines for protecting domestic and farmed rabbits from RCD. These issues include the uncertainty surrounding its availability, the cost factor and who should pay. Quite a few assert the viewpoint that any vaccination should be free to domestic rabbit owners, while several submitters express the view that the Applicant Group should bear the costs of vaccination, since they would be the principal beneficiaries of the virus. Another submission notes that vaccination is not likely to be a one-shot exercise (45). It will be a recurring burden.

Several other related issues are mentioned. Submission 49 expresses concern that there is no reassurance in the Application that domestic rabbit owners will be advised of the need to vaccinate, and notes also that there are 35 species of domestic rabbit in New Zealand to provide for, while submission 502 indicates that, in the event it was needed, the vaccine should be made available before RCD is introduced.

Vaccine effectiveness

In addition to the question of vaccine availability, quite a few submissions express doubts about the efficacy of a vaccine. Several note that the IIA (on p.63) acknowledges some problems with vaccinations.

Spanish and Australian experience is cited in several cases. Submission 362 notes that RHD vaccinated rabbit farms in Spain have had outbreaks of RHD, which have been attributed not to low immunity but to new strains of the virus with altered properties. Several submissions cite reports from Western Australia suggesting that vaccines "appear to be failing to save animals as new strains of the virus are emerging and killing inoculated rabbits" (695), and that some domestic rabbits have wasted away and died after vaccination, while others developed hair loss and ulcers. Australian experience is also reported as casting doubt on the effectiveness of the vaccine on young rabbits, and raising some doubts that vaccinated rabbits can reproduce.

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

more attention to matters of vaccine efficacy (e.g. 477).

 

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