Inadequate Consultation of Māori on 1080 Poison
A presentation to Ngā Kaitiaki Tuku Iho Inc. in Nelson, New Zealand, 20-21 February 2021
FULL TRANSCRIPT:
I’m Jo Pollard, I’ve had a lifelong interest in animals and nature. My qualifications are mainly in ecology and behavior. I’ve had 14 years as a government scientist and published many papers during that time. In 2004, I swapped science for business but I’ve maintained my interest in science, particularly in the aerial use of 1080 poison, to control mammals in New Zealand. In 2007 a major review was published allowing me to dig into this science.
In 2002 the main 1080 poison users were DoC, the Department of Conservation, and the Animal Health Board (AHB), both mainly targeting possums with 1080 poison had to apply to the Environmental Risk Management Authority. ERMA, to continue and increase poisoning as they desire. It was necessary by law for these applicants to consult Māori. It was necessary for DoC and the Animal Health Board if they wanted to carry on poisoning to take into account the relationship of Māori and their culture and traditions with their ancestral lands and taonga.
The Māori consultation on 1080 consisted of 20 hui, held up and down the country by local DoC managers in 2004. A discussion document was prepared and circulated in advance, written submissions were encouraged, Tuputupuwhenua consultants reported on the hui. Landcare scientist, James Ataria, personally attended and assessed 5 hui gaining feedback from participants. Ngā Kaihautū Tikanga Taiao (the Māori Advisory Group) reported to ERMA on the hui. But Ngā Kaihautū reported to ERMA, Ngā Kaihautū, could find little evidence that an appropriate process in sufficient time was used during the consultation hui to discuss outcomes of significance to Māori. Ngā Kaihautu believes that this was a significant lost opportunity to provide this information to the ERMA decision making committee who has a legal duty to incorporate this information into Part Five, decision making.
So what went wrong with the Hui? First of all, there was low attendance. They seem to be held at the wrong time. Māori attendance of the hui was low. If the hui were held in the evenings or the weekends, more people would have attended. They seemed to be poorly advertised. The applicants should have employed forms of media, e.g. local newspapers and radio stations.
There seemed to be an overbearing presence of DoC and the Animal Health Board, preventing open discussion. There was no opportunity to debate the issues because of the overrepresentation of pest control agencies at the hui. The strong presence of applicant representatives during the consultation who was seen as government staff promoting government policy.
For example, in Thames, the hui consisted of 2 Māori, and 8 others, in Christchurch 7 Māori, and 7 others. It seems that the recording of the hui was abysmal. This is feedback from Landcare. There was no evidence of recordings being taken as an accurate record of the participants comments. Copies of the official minutes taken at the 5 consultation hui were requested. However, only minutes from 3 hui were available. Minutes received from 2 hui represent a summary not a written transcript. More on the abysmal recording. Ngā Kaihautū are concern that the information provided in the Tuputupuwhenua report is insufficient for two reasons.
Tuputupuwhenua, I did not attend any of the consultation hui instead relying solely on the minutes, only the minutes of 9 of 20 consultation hui were provided to Tuputupuwhenua. There was pro 1080 bias at the hui. The applicant’s presentation did not always provide an object of review of current information regarding 1080. Some participants felt the presentation was more about advocating the use of 1080.
There was not enough time. Meetings over a longer timeframe would be required to get a representative cross-section of opinions. There was an adequate time allocated in the presentation to explore these issues. The issues that were intended to be explored included impacts of 1080 on Māori culture, health and wellbeing. The Treaty, and environmental outcomes. Some participants remained adamant that further contact and more information are required. That’s all Landcare feedback.
The methods of communication were inappropriate. Many felt that “face to face” transfer of technical and operational information is best, and the applicants were also obliged to fulfill this task. Some consider that the process of written submission is not an appropriate mechanism to capture the views of all Māori. Many consultees found the information difficult to comprehend – The approach was unfair.
Many considered the hui to be about dissemination of information rather than true consultation. Genuine consultation involves the statement of a proposal not yet finally decided upon. Listening to what others have to say, people did not feel supported. Some participants regarded the ERMA process as flawed because the Māori Advisory Board was only able to make recommendations to ERMA and not decisions.
Participants had concerns about adequate Māori representation in the reassessment process. “We were not invited by DoC. DoC has a Treaty obligation to consult Māori landowners.” There was a lack of independence at the hui. The consultation was done by DoC against ERMA’s advice. The applicant did not consider contracting an independent consultant as suggested in the ERMA document, Consultation Guidelines. The reporting wasn’t independent either.
With Landcare scientists, James Ataria, and Sean Ogilvie, providing the Ngā Kaihautū report, and James Ataria providing the Landcare report.
So what were the Māori concerns that came out of the hui?
Most Māori participants felt uncomfortable with the use of poisons in the environment, protecting the forest biodiversity, while the poison was contradictory to fundamental Māori beliefs. Almost all participants opposed or had serious reservations about this method of application, being aerial spreading. The impact and environmental fate of 1080 particularly with respect to mahinga kai and iconic species is still a primary concern.
So how did the ERMA committee respond to the information on the hui and the Māori concerns?
They came to the view that DoC’s policy regarding consultation with Māori sets a high standard. While the policy may set a higher standard but in reality the consultation was an abysmal failure. The concerns raised by Māori relate largely to its aerial application. The committee believes the measures now taken by the Crown, including the continued managed use of 1080 goes some way towards providing active protection of Taonga.
In other words, the committee has taken all of the information given to it and decided that 1080 is good for the environment. Now I looked at that same information and found nothing of the sort, no such reassurance, and I wasn’t the only one that went through this exercise.
Two, highly qualified medical scientists, Pat and Quinn Whiting-O’Keefe, had also scoured through the ERMA review looking at the quality of science and the justification put up by DoC and the Animal Health Board for aerially spreading 1080. They became very irate at the lack of science and the poor quality of the information. They said, “the strongest argument that 1080 is helping, and not harming our forest ecosystems, is the cacophony to that effect persistently emanating from DoC at considerable public expense.”
“In our minds, this is not enough to justify this extraordinary policy unique in the world of indiscriminately poisoning our native forests in defiance of the known principles of ecology and ecosystem management. In medicine, there is a saying …’First, do no harm’. And so it should be here.”
What did Pat and Quinn find wrong with the science?
Scientific research supporting DoC’s claims mostly “reaches only the lowest levels of control. Quality statistics are often poorly done, absent or selectively reported. The studies are short term and narrow in scope. There is not one randomized blind treatment. Results are frequently misrepresented and distorted, often with obvious bias. There are numerous errors of inference, omission and commission. Roughly half of the studies are only published internally. Most of the others are published in a single journal, The New Zealand Journal of Ecology. There is only one study that appeared on a peer reviewed international journal. The entire lot, excepting one or two, was produced by researchers who were financially dependant on DoC’s goodwill.”
So what does 1080 do?
The ERMA review pulled together all the known information on 1080. It is indeed broad spectrum, it kills everything, or harms everything, from microbes, to plants, to birds.
It doesn’t discriminate between native and non-native. It spreads incredibly rapidly in water and up food chains. It contaminates experimental samples. It’s very difficult to control, it causes harm across a very wide range of species, causes birth defects, reproductive defects, harm to organs, and muscles. It’s cruel. With victims suffering hours to days of severe suffering. It persists. It persists in hot places, dry places, it persists in bones.
No one knows how long it persists in invertebrates or cold blooded animals. It’s very poorly researched, both in terms of the amount of research and the quality of research. One thing it has fairly consistently done is cause rat plagues. Ultimately, the benefactors of spreading 1080 in the environment are rats, who do very well after other animal have been poisoned off and left their resources. Rats are generalist feeders. They breed fast, and invade rapidly, and usually within a few months, plagues of rats, or, rats at least at higher numbers than before the poisoning are seen and often DoC uses this as an excuse to poison again.
Another part of the ERMA committee decision was they noted the wealth of relevant research and other information about the impact of 1080 on important species and considers that significant improvement could be made in the communication back to iwi/Māori communities.
In other words, there’s a lot of information and Māori will be more happy when they know about that information. Well, that simply isn’t true …
I think if you look at this slide, which was a table I made up from the ERMA Evaluation and Review Report, some unknown properties of 1080 poison, you’ll see that there’s a frightening lack of information on 1080.
You just go down the list:
- Acute Inhalation Toxicity, represents a data gap;
- Respiratory Sensitization, unable to locate any studies;
- Contact Sensitization, unable to locate any studies;
- Carcinogenicity in mammals, did not find any studies
- Reproductive toxicity to birds (data gap);
- Toxicity to algae (data gap),
- Toxicity to aquatic invertebrates (data gap), and so on ….
… toxicity to terrestrial invertebrates; native reptiles; residues in cow milk; residues in meat, all unknowns. So I don’t believe that more information coming from DoC is going to satisfy any concerns whatsoever.
In Summary
So in summary, DoC failed miserably in its attempt to consult adequately with Māori. This was only one of several major failings in the ERMA review I believe that if Māori had been consulted adequately, we would have learned a lot about pest control and the excuse for 1080 would have gone out the window because there are too many costs and risks and no benefits have yet been discovered.
Thank you.
Dr Jo Pollard