Letter to Mr Feng Jing, World Health Centre, UNESCO

Appendix 1. Details regarding Doc’s claim that they have closely monitored results  

• a) In a major review of 1080 poison in 2007, DoC did not provide comprehensive monitoring data for target species:

“Some information on the kill rates achieved in DoC’s operations was included on p 391 of the application (assessment of significant benefits) but was not as comprehensive as the Agency had anticipated. No information was included in this section of the application from the AHB.”

“[Possum] operations excluded were those which are initiated based on a damage threshold (e.g. to vegetation), whereby control occurs without any pre-operational RTCI monitoring and also those which are subject to on-going trend monitoring every 2-3 years. In the latter situation, once the possum numbers reach a trigger level, a control operation is then planned to occur 1-2 years later.”

• Environmental Risk Management Authority Reassessment of 1080 (2007), Agency’s Appendices, p 531.

• b) Regarding non-target monitoring, DoC stated recently that reliable mortality rates from aerial poisoning have only been calculated for six species of birds:

“There have been numerous studies examining the effects on native non-target populations over the last 20 years…The only reliably calculated mortality rates are for kokako, kiwi, kaka, whio and fernbirds…The mean mortality rate for fernbirds is 9.4%”

• DoC, pers. comm., 2016 (letter, see Appendix 1 in Pollard 2017)).

• c) DoC’s monitoring has been of extremely poor quality, and has clearly evident bias:

Two highly qualified scientists wrote a lengthy, detailed critique of DoC’s monitoring of the effects of aerial 1080, in a submission to the NZ Government’s ERMA reassessment of 1080 poison in 2007 (Whiting-O’Keefe & Whiting-O’Keefe 2007). The submission made 7 summary points:

“1. DoC’s aerial 1080 research does not address the bottom-line, fundamental question of net ecosystem effect. 2. DoC’s aerial 1080 research contains numerous methodological, statistical and inferential errors 3. There is substantial evidence that DoC has suppressed critical research that is unfavorable to its bureaucratic agenda. 4. The research is pervaded with bias and misrepresentation. 5. Even if the research were not poorly done and were unbiased, it still does not show what DoC claims it shows, namely that aerial 1080 is benign and beneficial to forest ecosystems 6. The aerial 1080 research is uniformly tainted by the lack of financial and career independence of the researchers.” …

Regarding invertebrates… “The research to establish the truth regarding the effect of aerial 1080 on a broad range of native invertebrates simply has not been done despite the existence of strong evidence that it does enormous harm and almost a decade and a half of ongoing large scale aerial 1080 operations”

• Whiting-O’Keefe & Whiting-O’Keefe 2007.

Pollard (2016) also described flaws in DoC’s methodology. “DoC’s most commonly used method of assessing bird mortality, the five minute bird count, is notoriously unreliable (Westbrooke & Powlesland 2005; ERMA Review 2007; Green & Pryde 2012; Hartley 2012). Nesting success is also used by DoC to assess effects of poisoning and as with bird counts, it is of questionable value. Increased nesting success is claimed to indicate that aerial 1080 has had a beneficial effect (EPA 2013 pp. 13, 114, 28). But it may actually show that populations have been severely culled (Nilsson 1984; Arcese & Smith 1988; Eason et al. 2011)…”

• d) Even less monitoring is required now due to a legal change removing the need to provide an assessment of effects for aerial poisoning operations (Resource Management (Exemption) Regulations 2017).

http://www.legislation.govt.nz/regulation/public/2017/0021/11.0/DLM7104033.html

• e) Many problems in DoC’s management and monitoring of poisoning operations were identified in 2015:

In an overview of its own ship rat, possum and stoat control programmes (Brown et al. 2015), DoC listed many problems internal to their organisation, which included: (1) few staff had completed the Animal Pest Management Framework training; (2) adoption of best practice was patchy; (3) not all DoC control operations were reported; (4) failure to follow best practice; (5) insufficient toxin; (6) budget insufficient; (7) breakdown in communication between technical advisors and operational staff leading to poor design and inconclusive outcomes; (8) did not fully understand the relationship between forest mast events and rodent population responses to these; (9) had too few measures of the long-term benefits of 1080 use to different populations of native species; (10) lack of robust monitoring and follow-through; (11) legal requirements not always met; (12)  how variable operations had been was unknown, as not all control operations were written up; (13) average costs for ground-based trapping and toxin operations were difficult to obtain because they were not consistently recorded.

• f) DoC has not built a science base of publications on ecological management, and does not back up new plans for increased poisoning with any scientific reviews or evidence (e.g. Threatened Species Strategy, July 2017).

http://www.doc.govt.nz/threatened-species-strategy\

• g) DoC has ignored warnings from ecologists about the need for scientific, ecological monitoring of the effects of its pest control:

“Ecological consequences derive both from mammal population reduction or eradication, and from using toxins as the control method. Scientists have not examined the net ecological outcomes of these consequences at the community level due to their daunting complexity, although managers usually manipulate whole communities and key conservation legislation demands that they do so.”…

“Between them, managers and scientists need to communicate more accounts of successful outcomes of toxin use. This will demonstrate to the public that the inevitable ecological risks associated with disciplined use of toxins are much smaller than the equally inevitable risks to natural ecosystems due to the introduced pest mammals which toxins target.”…

“we suggest that priorities are to measure net ecological outcomes at the community level, to reduce toxin use, and to improve pest control strategies and techniques in the maintenance phase of control operations. Finally, we suggest that an annual ecosystem management conference in New Zealand, which explicitly brings together managers, policymakers, landowners, and scientists from the many disciplines now relevant to the complex field of pest mammal control, would enhance progress and co-operation.

• Innes & Barker 1999.

“threatened species usually have a limited ability to recover from additional mortality,  making the consequences of potential losses from poisoning of more concern…During monitoring, one of 40 weka (Gallirallus australis) died, and four of 23 fernbirds (Bowdleria punctata) disappeared.  None of these studies have identified population-level mortality that threatens the viability of a species (Broome et al. 2009).  Recent monitoring of kea (Nestor notabilis) suggests that some populations may be affected by aerial 1080 operations.  Research is ongoing to identify these populations at risk and whether the risks can be mitigated (Broome et al. 2009)….”Considerable care must be taken when using 1080 to ensure that the risks of its use are outweighed by ecological benefits achieved.”

• Eason et al. 2011

“Pest management is complex and ideally integrates knowledge of the species’ biology, our ability to detect and control populations, and their impacts on the ecosystem.  Despite the voluminous amount of ecological research focused on pest species, this research rarely helps managers identify optimal bio-economic pest-management strategies.  A consequence of the disconnect between science and management is that financially-constrained managers are left with a ‘trial-and-error’ approach that may be based on extensive ecological experience but lacks a formal mechanism for assessing management impacts and guiding improvements.”

• Anderson et al. 2014

• h) Recent trials using double- to quadruple dosing of land with aerial 1080 poisoned baits do not consider the effects on non-target species:

https://issuu.com/zipnz/docs/2017-05-05_zip_fact_sheet_jackson_a

References for Appendix 1

Anderson, D., Byrom, A., Baxter, P., Cassey, P., Ramsey, D. & Woolnough, A., 2014. How can science guide best-practice pest management? Kararehe Kino 24: 26.

Brown, K., Elliott, G., Innes, J. & Kemp, J., 2015. Ship rat, stoat and possum control on mainland New Zealand.  An overview of techniques, successes and challenges. Department of Conservation report. 40 pp.

Eason, C., Miller, A., Ogilvie, S. & Fairweather, A., 2011. An updated review of the toxicology and ecotoxicology of sodium fluoroacetate (1080) in relation to its use as a pest control tool in New Zealand. New Zealand Journal of Ecology 35: 1-20.

Environmental Risk Management Authority Reassessment of 1080 (2007), Agency’s Appendix F, p 531).

Innes, J., Barker, G., 1999. Ecological consequences of toxin use for mammalian pest control in New Zealand- an overview. NZJ Ecology 23: 111-127.

Pollard. J.C., 2016. Aerial 1080 poisoning in New Zealand: Reasons for concern.

https://www.researchgate.net/publication/308712508_Aerial_1080_poisoning_in_New_Zealand_Reasons_for_concern 17pp.

Pollard, J.C., 2017. Response to the Department of Conservation’s reply to “Aerial 1080 poisoning in New Zealand: reasons for concern”

https://www.researchgate.net/publication/313881837_Response_to_the_Department_of_Conservation%27s_reply_to_Aerial_1080_poisoning_in_New_Zealand_reasons_for_concern

Whiting-O’Keefe, Q.E., Whiting-O’Keefe, P.M., 2007. Aerial Monofluoroacetate

in New Zealand’s Forests. An appraisal of the scientific evidence. http://1080science.co.nz/wp-content/uploads/2016/06/Whiting-Okeefe-2.pdf 88pp.

Appendix 2. Details regarding DoC’s claim of more benefits than adverse impacts from aerial 1080  

• a) Investigations have revealed no scientific evidence supporting this claim:

Whiting-O’Keefe & Whiting-O’Keefe (2007), in a detailed scientific appraisal of DoC’s science, wrote that “despite years of massive aerial 1080 “operations”, not one Control Level 1 or better study has been done at the ecosystem level. Thus, the question of net harm or good of aerial 1080 is unanswered in a scientifically credible way.”

Regarding bird studies, the Whiting-O’Keefe appraisal stated “1.The research is of poor quality and almost always inconclusive. 2. Native birds of some species are killed in substantial numbers by aerial 1080 poisoning of the forests. 3. There is no credible published evidence of population benefit for any native species of bird.”

Pollard (2011) reviewed the report by the NZ Parliamentary Commissioner for the Environment (Wright, 2011), which claimed there was evidence of benefit of aerial 1080 possum control to tree species. But of the four tree species claimed to benefit from aerial 1080, kamahi, mahoe and tawa showed highly variable results and where positive effects occurred, these were only minor. Fuchsia appeared to benefit but the study was flawed by a lack of replication and inconsistent recording. Negative effects on red mistletoe and fruitfall of pigeonwood were found.

Pollard (2017) reviewed Doc’s claim that aerial 1080 operations provide a “net benefit” to native species (DoC 2016, pers. comm.) “Net benefit” as used by DoC is the recorded mortality of marked birds due to poisoning, compared to a recorded increase in nesting success immediately following the poisoning (Kemp, 2014b, unpublished, p. 5). But increased nesting success of survivors is an expected response to a high death rate in a population, and is not a measure of population gain as implied.

Pollard (2017) also investigated DoC’s claim that two long-term studies “have shown native forest birds benefit from aerial 1080 operations” with the citations “O’Donnell and Hoare 2012” and “G. Elliott, DOC, unpubl.” (DoC, pers. comm., 2016 (letter, see Appendix 1 in Pollard 2017). DoC’s claim proved to be untrue. O’Donnell & Hoare (2012) had studied native birds in the Landsborough Valley subjected to continuous ground trapping for stoats plus trapping and ground-based poisoning of possums and four aerial 1080 operations over 11 years. The unreliable technique of five-minute bird counts was used to monitor numbers.  There were no pre-treatment monitoring and no control. Reported results were decreases in four species, no change in two, and increases in nine. The other citation “G. Elliott, DOC, unpubl.” turned out to be made in error and should have been cited as “pers. comm.” (Ann Thompson, DoC, personal communication, 2/10/16).

• b) This claim has been used erroneously to defend high mortality rates of rare species from aerial poisoning.

DoC is still aerially spreading 1080 in kea habitat (NZ’s rare mountain parrot (Nestor notabilis) even though it is killed in large numbers by 1080 poison (12 % of marked birds, on average, per operation in kea habitat) and there is poor knowledge of the number of kea remaining (possibly 1000 or less). Claims regarding benefits of 1080 to kea (Kemp et al., 2014 unpublished; 2016 unpublished) are not based on scientific evidence (Pollard 2017).

• 1080 has been aerially applied despite evidence of a lack of need:

An example of this is the Makarora poisoning by DoC, February 2017, when rat numbers were very low and stable. Possums were also to be controlled but no monitoring was carried out on possum numbers (data obtained from DoC, under the Official Information Act 1982, available upon request).

• d) The “Battle for the Birds” aerial poisoning strategy contains a large number of flaws:

Pollard (2016) pointed out many flaws: DoC’s “Battle for the Birds” programme uses widespread aerial 1080 poisoning to attempt to control expected rises in pest animals (rats, mice and stoats) associated with episodic masting (seeding) of beech trees (Elliot 2016). This idea overlooks many important ecological facts: many different plant species (not just beech trees) mast at different times with variable responses by pest animals (Innes 2005; Ruscoe & Murphy 2005; Canham et al., 2014; Griffiths & Barron 2016); mice rather than rats are expected to increase in beech forests following masting (Murphy & Pickard 1990; Ruscoe & Murphy 2005; Efford et al. 2006); 1080 is usually very ineffective at killing mice (Fisher & Airey 2009) and poor at controlling stoats (King & Murphy 2005; Dilks et al. 2011); NZ birds and other animals have weathered massive rises in rat numbers since the time of the kiore (King 1984); responses to masting naturally decline on their own within a few months (King 1984; 1990); in poisoning deaths, priceless genetic material (along with the potential to adapt, e.g. to predation pressure (Urlich 2015)) is lost from populations; NZ’s endemic species such as kea are long-lived, slow reproducers to whom an occasional poor nesting year is likely of little consequence provided the adults survive (King 1984); there are well-documented, scientifically acknowledged increased pest impacts following poisoning due to prey-switching by predators (King & Murphy (2005) and mouse and rat numbers increasing markedly (Caut 2007; Sweetapple & Nugent (2007); Ruscoe et al. 2011; Shapira 2013; Innes et al. 2015; Urlich et al. 2015; Griffiths & Barron 2016).

References for Appendix 2 

Kemp, J., Orr-Walker, T., Elliott, G., Adams, N., Fraser, J., Roberts, L., Mosen, C., Amey, J., Barrett, B., Makan, T., 2014, unpublished. Benefits to kea (Nestor notabilis) populations from invasive mammal control via aerial 1080 baiting. Department of Conservation. 29 pp.

Kemp, J., Hunter, C., Mosen, C., Elliott, G., 2016, unpublished. Draft: Kea population responses to aerial 1080 treatment in South Island landscapes. Department of Conservation, 14 pp.

Otago Regional Council Recommending Report, 2016. Discharge Permit Application RM16.174.01 by Department of Conservation to discharge pesticides onto Regionally Significant Wetlands within the Matukituki and Makarora River catchments.

Pollard, 2011. A Scientific Evaluation of the Parliamentary Commissioner for the Environment’s view on 1080 (http://1080science.co.nz/a-scientific-evaluation-of-the-parliamentary-commissioner-for-the-environments-view-on-1080/).

Pollard. J.C., 2016. Aerial 1080 poisoning in New Zealand: Reasons for concern.

https://www.researchgate.net/publication/308712508_Aerial_1080_poisoning_in_New_Zealand_Reasons_for_concern 17pp.

Pollard, J.C., 2017. Response to the Department of Conservation’s reply to “Aerial 1080 poisoning in New Zealand: reasons for concern”

https://www.researchgate.net/publication/313881837_Response_to_the_Department_of_Conservation%27s_reply_to_Aerial_1080_poisoning_in_New_Zealand_reasons_for_concern

Whiting-O’Keefe, Q.E., Whiting-O’Keefe, P.M., 2007. Aerial Monofluoroacetate

in New Zealand’s Forests. An appraisal of the scientific evidence. http://1080science.co.nz/wp-content/uploads/2016/06/Whiting-Okeefe-2.pdf 88pp.

Appendix 3. New Zealand’s management of 1080 poisons is poor 

• a) There have been repeated, untruthful statements regarding 1080 poison by New Zealand’s Parliamentary Commissioner for the Environment.

The New Zealand Parliamentary Commissioner for the Environment has repeatedly stated that 1080 was rated as “moderately humane”(Wright 2011, 2013) when the research cited actually rated it as having an “intermediate welfare impact”[1] consisting of severe effects, lasting for hours (Beausoliel et al. 2010).

Another example of mistruth was the PCE’s claim “that we do not need more water samples” (Wright, 2011) ignoring the facts that the ERMA (2007) reassessment had identified a serious problem regarding the validity of results from water sampling, and that more research had been recommended (ERMA Reassessment Committee Decision, p 119) but it was not underway (Pollard 2011; 2017).

The PCE’s report stated under “What this report does not cover …the Animal Health Board’s action in controlling bovine tuberculosis (TB) in any detail.” (Wright 2011 p. 12). Misleadingly, Wright (2013 p.6) later quoted the Animal Health Board as stating, regarding the 2011 report, “Hopefully such a comprehensive report will reassure the New Zealand public that the carefully-regulated use of biodegradable 1080 to control predatory pests, such as possums, is not only safe, but necessary.”

• b) Independence of official scrutineers of reviews on 1080 has been wrongly claimed.

ERMA’s 2007 Evaluation and Review Report was not independently assessed, as implied in a statement from DoC that it was “externally peer reviewed” (DoC, pers. comm., 2016 (letter, see Appendix 1 in Pollard, 2017)).

The reviewer Dr Abdul Moeed was not historically external to ERMA. He had been a government ecologist, then worked for ERMA for many years as Senior Science Adviser, New Organisms.

(A truly independent assessment by Drs Pat and Quinn Whiting-O’Keefe concluded that “the government’s reassessment of the use of 1080 in 2007 was flawed because of committee composition, biased ex-DoC employees, prejudgement, and failure to acknowledge or hear countervailing evidence” (Whiting-O’Keefe & Whiting-O’Keefe 2013).)

In 2015, “independent” reviews of the science underpinning bovine Tb control in NZ (supporting aerial 1080 poisoning) were written by scientists Drs Peter Caley and John Hellström who had been involved in Tb research in NZ over many years (see Pollard 2016).

1. c) A lack of information on the effects of 1080 was highlighted at least 300 times in the 2007 ERMA Reassessment of 1080 (see http://1080science.co.nz/1080-data-quality.) Research recommended by ERMA (2007) has not yet been carried out to fill important data gaps, including the validity of results from stored samples, and degradation rates in water (Pollard 2017).

Unknown properties of 1080 poison as noted in the Environmental Risk Management Authority’s Reassessment (2007, Evaluation and Review Report)*

Effect	Page	Wording
Acute inhalation toxicity	300	“…represents a data gap…”
Respiratory sensitisation	304	“…unable to locate any studies…”
Contact sensitisation	304	“…unable to locate any studies…”
Carcinogenicity in any mammalian species	306	“…did not find any studies…”
Adsorption/desorption in a range of soils	349	“Data Gap” (no definitive studies)
Reproductive toxicity to birds	349	“Data Gap” (no definitive studies)
Toxicity to algae	349	“Data Gap” (no definitive studies)
Toxicity to aquatic invertebrates	349	“Data Gap” (no definitive studies)
Chronic aquatic toxicity	349	“Data Gap” (no definitive studies)
Biodegradation in aquatic systems and soils at varying pH, soil type and temperature	349	“Data Gap” (no definitive studies)
Toxicity to terrestrial invertebrates (p. 350)	350	“Data Gap” (no definitive studies)
Toxicity of the breakdown product fluorocitrate in water or soil (p. 360)	360	“The applicants did not provide, and the Agency was not able to locate, any data…”
Toxicity to native NZ reptiles (p. 416)	416	“No data are available…”
Presence of residues in cow milk (p. 561)	561	“No information was available…”
Presence of residues in the main human meat sources, such as cattle, pigs, and deer (p. 562)	562	“The Agency did not find data…”

*This list is not exhaustive

• d) Ecological science in New Zealand depends on government funding therefore scientists are not independent of the government’s pro-poisoning policy, especially those working for DoC:

“Unfortunately, virtually all scientific information concerning monofluoroacetate is controlled and generated (directly or indirectly) by DoC, the bureaucracy that benefits from the growth of what may very well be called New Zealand’s “possum control industrial complex” ”…Add this to the ardour of DoC’s advocacy which includes the numerous examples of misrepresentation and distortion that we have documented in this paper, and it becomes clear that DoC simply cannot be assumed to be a neutral broker of conservation strategy.”

• Whiting-O’Keefe & Whiting-O’Keefe 2007.

• e) Regulations requiring consultation with affected parties and assessment of effects for aerial 1080 and brodifacoum operations have been removed:

http://www.legislation.govt.nz/regulation/public/2017/0021/11.0/DLM7104033.html

• f) Publicly released information from DoC contains untruths:

For instance the Makarora 2017 poisoning was not preceded by possum monitoring, but public signs stated that possum populations had reached a threshold requiring action (data requested through the Official Information Act 1982, and photographs of signs, are available upon request).

References for Appendix 3 

Beausoleil, N., Fisher, P., Warburton, B, Mellor, D. 2010. How humane are our pest control tools? MAF Biosecurity New Zealand Technical Paper no: 2011/01. 

DoC, pers. comm., 2016 (letter, see Appendix 1 in Pollard, 2017). 

Pollard, 2011. A Scientific Evaluation of the Parliamentary Commissioner for the Environment’s view on 1080 (http://1080science.co.nz/a-scientific-evaluation-of-the-parliamentary-commissioner-for-the-environments-view-on-1080/). 

Pollard, J.C., 2016. Aerial 1080 poisoning in New Zealand: Reasons for concern.

https://www.researchgate.net/publication/308712508_Aerial_1080_poisoning_in_New_Zealand_Reasons_for_concern 17pp.

Pollard, J.C., 2017. Response to the Department of Conservation’s reply to “Aerial 1080 poisoning in New Zealand: reasons for concern”

https://www.researchgate.net/publication/313881837_Response_to_the_Department_of_Conservation%27s_reply_to_Aerial_1080_poisoning_in_New_Zealand_reasons_for_concern 

Whiting-O’Keefe, Q.E., Whiting-O’Keefe, P.M., 2007. Aerial Monofluoroacetate

in New Zealand’s Forests. An appraisal of the scientific evidence. http://1080science.co.nz/wp-content/uploads/2016/06/Whiting-Okeefe-2.pdf 88pp. 

Whiting-O’Keefe, Q.E., Whiting-O’Keefe, P.M, 2013. Overview of scientific and other implications of the New Zealand government’s aerial distribution of food laced with the poison 1080 for pest control. http://1080science.co.nz/overview-of-scientific-and-other-implications-of-the-new-zealand-governments-aerial-distribution-of-food-laced-with-the-poison-1080-for-pest-control/

Wright, J., 2011. Evaluating the use of 1080: Predators, poisons and silent forests. Parliamentary Commissioner for the Environment, Wellington. 85 pp.

Wright, J., 2013. Update Report.  Evaluating the use of 1080:  Predators, poisons and silent forests. Parliamentary Commissioner for the Environment, Wellington. 15 pp.

Appendix 4. Some ecologists have recommended preservation of habitats and acceptance of our mammalian fauna, rather than widespread poisoning with the aim of killing it. 

King 1984:

“I think we should accept predators as permanent members of the New Zealand fauna; attempt to limit the damage they can do in the most sensitive remaining areas, but not waste money on impossible, general control of their populations; recognize that large-scale predator control on the mainland is not now necessary, even if it were possible, since the processes of nature are repopulating New Zealand with birds that are able to live with predators, while the rest are either adapting or have already gone; vigorously defend what isolated remnants of the ancient fauna are actually defensible in the long term; and temper our regret at the passing of the old endemics with positive appreciation of the new colonists.”

“Some few species, such as the South Island saddleback, the black robin and the stitchbird, have been brought back a step or two from the brink of extinction over the last few years.  But while attention has been focussed on them and not on the greater importance of habitat conservation, the destruction of mainland forests and swamps has continued unchecked; so it is probable that in the course of the same few years many smaller, less appealing species have been pushed over the brink, some even before they were known to science. Conservation is the prime task, and arguments for establishing reserves should be based primarily on the need to conserve whole ecosystems.”

Steer 2016:

“Change is continuous and countless recent studies investigating rates of evolution show that it happens a lot faster than we used to think. Both native and introduced species don’t care about our historical baselines and are actively breeding and (de)selecting themselves away from them. Much like technological innovation in times of crisis, evolution seems to be speeding up in response to the environmental changes we have wrought. I’m going to go out on a limb and say that this is a good thing and that trying to stop it might actually be damaging to the vitality of future ecosystems.”

References

King, C. 1984. Immigrant Killers.  Introduced Predators and the conservation of birds in New Zealand Oxford University Press. 224 pp.

Steer, J. 2016. http://biodiversityprofessionals.org/5-reasons-why-you-should-love-introduced-species/

[1] The ‘intermediate’ rating fell between cyanide which causes suffering for minutes, and brodifacoum which causes severe to extreme suffering lasting days to weeks (Beausoliel et al. 2010).