Appendix ii

Examples of Outrage from the Public

The outrage stemmed from press releases which are typified by the example below. There is no doubt that the announcements by PCE closely followed up by pro 1080 vested interests and green extremists was intended to lead the public into thinking a comprehensive re-evaluation had been undertaken, when in truth the so-called “evaluation” was narrow and in the Commissioners own words;

Given the ongoing controversy regarding 1080, this investigation has been undertaken to provide Members of Parliament, members of the public and other interested groups with an independent assessment of 1080 that is not overly technical and is accessible to the general reader.”

Viz: “not overly technical and is accessible to the general reader.”
In fact, the PCE Evaluation Report is not what the public was led to believe it was.

There follows a series of letters from concerned people to the press and to the PCE. We ask the indulgence of the Ombudsmen to take time to read these letters because there are very relevant complaints and additional important points contained in them.


From: The Eddys []
Sent: 22 February 2011 10:37
To: The Eddys
Subject: Stuff

Morning Graham,

I have just sent a letter to my contact at the PCE office asking him to let me know the status of my Formal Complaint to them (sent just over two years ago) against the The Nelson Marlborough DHB and ERMA.  I also reminded him it was against the handling of my complaints by those authorities over the dumping of 1080 by helicopters.  Seeing this is a topical subject with them at the moment it may get them looking at it.  Hell, two years is a bit on the nose without hearing anything on it.

Did you get any response on your request for the TB Free maps and info?  If you haven’t just let me know and I’ll post these ones to you.

Cheers,  Ron


The Robinson’s biweekly column for this Hamilton weekly…here is a PCE 1080 op piece just published. July 1 2011; Hamilton news.

Playing Politics With Poison Policy


In true Orwellian fashion, the Parliamentary Commissioner for the Environment has manufactured a faith-based pitch for saving New Zealand wildlife by expanded poisoning of our fragile bush ecosystems.

Billed as an “independent investigation”, the report by Jan Wright is an unapologetically political document designed to head off potential legislative controls or a parliamentary moratorium on use of supertoxin 1080.  With a $100m pest control industry under fire, Wright produced a lightweight document that is stunning for its lack of factual substance, its booster tone, and dismissive attitude toward those who disagree.

And it’s easy to see why the current PCE belched up the government line on 1080 policy.  Wright, a career policy analyst and consultant, is the consummate Wellington political insider, with past board positions at Transit NZ, ACC, and Land Transport NZ.   As for her advertised “independence” on the issue of 1080, one of Wright’s former clients was none other than the pro-1080 Environmental Risk Management Authority.

The report lacks any new information but is most notable for what it fails to consider.  Wright refused to consider Maori cultural impacts, views of local communities, accidents and specifics of operations.

The report makes numerous unsubstantiated claims giving the misleading impression her conclusions are fact-based.   After carefully referencing a single study on kiwi populations, for example, she makes a highly emotional warning that six vastly different species of native birds “will almost certainly disappear”.  In actual fact, there is nothing cited in the scientific literature to back up her assertion.

Even worse, Wright’s “Forests Under Attack” scare section features major factual error.  She highlights tui and bellbirds (korimako) as examples of native species certain to “decline further”.  However, a close reading of the 2010 Journal of Ecology predation study Wright uses to buttress her 1080 sales pitch reveals both tui and bellbirds are actually expanding their range across New Zealand and are not classified as threatened to any degree whatsoever.   She warns of “loss or decline” of these seed-dispersing species and “cascading ecological changes in native forests”, but the hard published data shows the exact opposite trend for these species.  It appears Wright has not read her own sources.

Furthermore, much of the so-called “science” and “research” upon which the PCE bases her opinions has been produced by individuals with direct or indirect financial and career relationships to DOC, tainting their findings with the potential for bias.

Readers searching the report for any new evidence to support her wacky conclusions find it’s simply not there.  Despite growing scientific opinion opposed to current 1080 policy, Wright ducks the issue, stating there simply are no good arguments against.   She makes an absurd claim that 1080 “scores surprisingly well” on humaneness. She ignores well-documented, disastrous explosions in rat populations after 1080 drops. She fails to seriously address rural community concerns.

The report is astounding in its failure to acknowledge well-established dangers of 1080. Even the 2007 ERMA report concluded that the effect on non-target animals exposed to 1080 is significantly adverse.  A 2007 Landcare Research summary of 1080 possum and rat control warns of “negative long-terms consequences for robins and ground invertebrates.”  Wright’s report flies in the face of recommendations by the Nature Conservation Council and distinguished former PCE Helen Hughes.

As seen from popular destinations like the Coromandel, Wright is a one-woman wrecking crew for the multi-billion dollar tourism industry, as disillusioned tourists increasingly attack New Zealand’s fraudulent green branding.  Export industries from shellfish to timber to fur to meat face potential catastrophic losses as well.  But the PCE report fails to figure that in.

Opposition to 1080 continues to mount.   Regional councils and DOC are under increasing pressure from an informed public. Despite a born-again pitch from PCE Jan Wright, the tide of public opinion can’t be stemmed. Decades of 1080 drops with no net ecosystem benefit have simply poisoned the well.



From: Tony Orman []
Sent: 23 June 2011 13:50
To: Graham Sperry
Subject: Rahui


Hi Graham
I wrote this to MP Rahui Katene (Maori party).
Hi Rahui
You may recall we had communication several months back on 1080?
I urge you not to withdraw your bill as I saw mentioned in the media.
Frankly your bill has been the subject of an orchestrated, concerted action from within the National government, DOC and the AHB to discredit your bill.
The point to realise – which you probably do – is the depot Animal Control Products (ACP) is a State Owned Enterprise, i.e. government. On the board are Minister of Finance and Agriculture (English and Carter)
The two agencies spreading 1080 are government funded. The ERMA review was by a government department’s section. The PCE is a government servant.
The whole beat-up is so incestuous.
The PCE’s report is riddled with errors. Below is a letter I wrote to the NZ Listener on just one of the flaws. Jan Wright seems so lacking in knowledge. Frankly she was a puppet.
yours sincerely
Tony Orman
PS Give me a call if you wish to discuss further.


Browsing Bush

The letter of Ian Henderson raised the matter of plant’s defences to browsing when a reputed 9 million moa and other birds browsed the bush.

Plants developed characteristics or mechanisms such as “divaricating” tangled structures to discourage browsing. As Ian Henderson pointed out, toxins were another.

For example one native orchid has covered its leaves with needle sharp crystals and poisonous chemicals. The needles perforate the soft lining of a browser and then poisons fill the holes causing swelling and pain. The native oxalis have a chemical oxalate that poisons animals causing “milk fever” and consequently staggering and convulsions.

Another is the dracophyllum family which have “anti-grazing chemicals” in their leaves. Similarly alpine willow-herbs have thousands of crystals of insoluble calcium oxalate in their leaf tissues which in conjunction with needles cause swelling and intense pain in a browser’s mouth. Another native alpine St Johnswort produces a pigment hypericin, that can cause sores, ulcers, blindness and convulsions and has been known to kill thousands of sheep in the South Island high country.

For that reason it is extremely surprising that Dr Jan Wright in her controversial report extolling 1080 poison wrote “the leaves of our plants do not contain poisons to deter animals.”

Surely Jan Wright should have known, as a lot of New Zealanders acquainted with the bush know,  kowhia, particularly the seeds, cause diarrhoea and abdominal pains while tutu’s leaves, bark and seeds can cause convulsions, vomiting and even death if eaten in quantity. Cattle are known to have died from eating tutu. Poroporo’s leaves and green fruit can cause abdominal pain, vomiting, diarrhoea and depression. Or that stinging nettle (ongaonga) is poisonous and has caused deaths of hunters?

But then what were Dr Wright’s qualifications relative to the topic of 1080? According to internet search her qualifications are in physics not ecology or biology. Her degree is largely irrelevant to the subject of her report. Certainly most with a degree – like me – are just as qualified to comment on a subject like 1080 and as a regular frequenter of mountains and bush, perhaps more so?
Tony Orman MNZIS

Bridget & Tony Orman
Phone +64 3 577 7875
Fax +64 3 577 7875
P O Box 939, Blenheim 7240, New Zealand



23 June 2011: Public Press Statement on behalf of NZ Wildlands Biodiversity Management Society Inc’ is:

“The NZ Wildlands Biodiversity Management Society Inc’ (NZWBM) feels that the enquiry into 1080 by The Parliamentary Commissioner for the Environment cannot override the ERMANZ review of 1080 and the resulting HSNO Act regulations and subsequent amendments. We regard the PCE report as being so limited in scope, (refer section 1:3) and by the paucity of public input permitted, to render it less than fully credible. The actual recommendations included actions already being progressed through Parliament including the functions of the Game Animal Panel and the modifications to the Biosecurity Act which will bring the Animal Health Board (an NGO) under the official Information Act. This latter is important because it will force the AHB to fully reveal the true costs of 1080 poison operations into the public arena. We also dispute the 1080 poison operation costs used by the PCE as being far below the actuals and therefore an improper measure with which to compare the alternative ground based options, which the commissioner discounted. Because of the way this enquiry has been conducted we do not consider it as valid. We have engaged with the PCE using the powers of the official Information Act to clarify certain key issues”—
Graham A Sperry

Chairman. NZWBM


From: Tony Orman []
Sent: 15 June 2011 16:10
To: Graham Sperry
Subject: Listener

The Listener has a website showing the editorial (praising PCE report) and giving space to make comments. I have put one in.
Others should do so
cheers Tony

PS Heres what I put in:-

The editorial is naively believing the propaganda pumped out by DOC, Animal Health Board and others. The fact is there never was 70 million possums. Now revised to 30 million it is probably still too high. Travel a highway or country road and observe how few “road kills” there are. This represents a natural progression wildlife populations follow from liberation to peak then drop to low stable level.
Besides even if the 70 million figure was accepted Landcare Research scientist Graham Nugent said the estimated foliage “gobbled” was nowhere near the daily foliage production of NZ’s vegetation.
Some possum facts:-

* Possum numbers are much higher in marginal country and along lower bush edges where possums will “graze” pasture, than in forest. One study near Wellington suggested possum numbers were  400 percent higher (i.e. 4 times) that of numbers in the forest itself.
* Possum numbers in rugged country are usually “controlled” by the rigourous environment especially climate. In inclement weather, natural mortality of possums may be as high as 40 percent.
* The generally unpalatable nature of beech forest does not support high wild animal numbers.
On Tb in October 2001, Dr Frank Griffin of Otago University addressed a Marlborough Deer farmers’ function. The scientist said that New Zealand’s pest management strategy focused narrowly on “killing possums and skin tests”  and  was not the solution to the Tb problem.
“clear” of Tb reading. So the “hidden” Tb infected animal continues to infect fellow cattle.
Why doesn’t AHB use the much more accurate blood test to detect TB? Strange.
Of wildlife vectors for Tb, ferrets are far more likely than possums as Landcare Research
Your editorial has failed to realise the incestuous relationship. Both DOC and AHB – the two biggest users of 1080- are government funded. The PCE is government funded. The 1080 factory is government owned.
Realise too DOC and AHB bureaucrats will perpetuate the possum myth to keep the future of their jobs intact. That’s the nature of the bureaucratic beast.
On native birds, wild cats are in considerable numbers. DOC never mentions them.
I am in the high back country every week. Driving back on farm tracks anywhere from 8 kms to 25 kms and on country shingle roads, I never see possums in the headlights. Hares, rabbits, cats, ferrets, occasionally deer, but never possums. I do see possums (1-2 occasionally) lower down on sealed roads.
Frankly the possum pest is a beat-up.And its costing NZ millions a year.
And on 10980 I have witnessed the demise of native falcons, more porks, tomtits and robbins following 1080. As a Kiwi, I care and get angry.
-Tony Orman


 1080 Report is Scaremongering

Friday, 10 June 2011, 1:48 pm; Press Release: Game Animal Council Establishment Committee

Criticism of the role of new Game Animal Council in the Parliamentary Commissioner for the Environment’s (PCE) Report on evaluating the use of 1080 lacks fact, balance or impartiality said Garry Ottmann, Chairman of the Game Animal Council’s Establishment Committee
The report poses questions about the possible role of the Game Animal Council such as: “what happens if for instance, DOC wanted to carry out an aerial 1080 operation to kill possums, stoats and rats in an area where there would be a risk of killing deer?” And “Because of the risk of by-kill that 1080 poses to deer, it is not clear what would happen if an agency wishes to use 1080 to control possums, rats and stoats in areas managed by the Council.”

“If the Commissioner’s Office really wanted answers to those questions it would have been relatively simple to come to the Establishment Committee and ASK” said Garry Ottmann. “This has not happened”

The Report of Recommendations to the Minister of Conservation on the establishment of the Game Animal Council states:
“The Committee recognises that DOC is the manager of public conservation land and retains the overall responsibility for controlling wild animals there. Through public processes such as Conservation Management Strategies and management plans, DOC and the public decide what areas are top conservation priorities, and DOC manages these accordingly.
The Committee is of the view that the Council and DOC should work co-operatively together to identify, by public processes, priority areas where animals need to be actively controlled for conservation purposes. Outside of these areas, however, the Council would be mandated to manage these species for their hunting benefits. This reflects the current and projected future situation whereby DOC carries out only limited wild animal control on some land under its jurisdiction, and has indicated that even if it were better resourced; wild animal control would not be a priority in most areas.”
“The PCE report has selectively taken phrases from our report to support it’s questions and conclusions but has failed to take into account the context of those phrases and the recommendations as a whole” said Garry Ottmann. “The PCE Report makes great stock of good science but fails use good science itself.”

The PCE recommendation on the status of the Game Animal Council also uses words such as; “has the potential to” and “could” in its preamble
“These are words that are used when there is no actual foundation for a statement. Basing a recommendation on innuendo and accusation is again bad science” said Garry Ottmann “The PCE has been badly let down by her office and the quality of the research and work that has gone into this section of the report. We have a number of also unanswered questions but we will take those to the Commissioner directly.”


From: geoffrey robinson <>
Date: Wed, 08 Jun 2011 07:54:03 +1200
To: <>
Cc: Reihana Robinson <>
Subject: 1080 Statement

Dear Ms Wright

Regarding your statement on 1080, you have quite clearly failed to read the extensive scientific evidence relating to health and safety issues.

You are obviously oblivious to the concerns of many scientists and physicians as to the adverse health effects of low-level, sub-acute exposure to 1080, including suspected endocrine disruption.

You appear unconcerned with the fact that 1080 routinely enters waterways and drinking water supplies as a result of aerial application and that citizens…excuse them very much…do not wish to drink minute amounts of this poison.

You have obviously not educated yourself as to the scant testing and reporting requirements for 1080 operations, requirements that were in fact developed by the users themselves (DOC, AHB, regional councils) together with ERMA.

You are also obviously unconcerned with the fact that routine 1080 poisonings are an increasing threat to New Zealand’s tourism sector as well as its export sector, particularly food and timber.

And as to your trumpeting of environmental protection gains, you are obviously unaware of the lack of any scientific evidence as to ecosystem-level gains.  Nor are you seemingly aware of the devastating toll that 1080 aerial application takes on a wide range of vertebrates and invertebrates, including threatened native bird species.

Furthermore, you have demonstrated your lack of concern as to animal cruelty and humane pest control practice.

What you have successfully accomplished is to burnish your credentials as a faith-based advocate of the status quo and a faithful servant of entrenched interests that profit from it.

Rest assured that your recent statement will be taken with a grain of salt as to its content.  It will, however, serve the welcome purpose of stimulating further opposition and direct action in response.

Kind regards

Geoffrey Robinson

Port Charles


 From: Pat Whiting-OKeefe []

Sent: 03 June 2011 11:19
Subject: Some particularly persistent questions answered

Dear Mr. Egan,

We have recently been reminded  by some question from a journalist that certain claims keep coming up the pro-aerial 1080 camp, F&B, the Listener, DoC, AHB and others.  This is true because they keep circulating literature containing them.

We believe that we have definitively answered them in various writings and again at a layman’s level even in Poisoning Paradise, but that does not seem to staunch their progress through the pro-1080 underground.  We would like to draw your attention to these questions and responses since we apparently have not been sufficiently explicit or have failed to delineate fully important distinctions and points.

We are therefore forwarding these responses in the hope that they will assist in your investigation.  They have been edited to eliminate the personal nature of the original and eliminate some of the sarcasm and derision that it contained.

I recognize that we may be too late or even barking up the wrong  tree, but the effort of writing has already been expended, so use them if you can and it is appropriate.

Thank you for your attention to this matter.  I think I can assure there will be no further addenda.

Pat and Quinn Whiting-Okeefe

Attached also is the unchanged Testimony document that I had previously sent.

Please refer to attached files


Macfie Listener Response V2.pdf


10 2 111 .8.50
email to associates.

I have had no further response from Rob Egan (PCE) to my email Tuesday 8th Feb , 1725hrs.

I am not inclined to have WBM contribute to PCE in a restrictive format. I agree with your comments below.

Regards, Graham.


Dear Reihana,
‘Rob Egan’; ‘Graham Sperry’; ‘pat whiting okeefe’;; ‘clyde graf’
Wed 09/02/2011 10:45

The CD is out of date and does not contain the latest or strongest analyses.  It would need to be updated to be maximally effective.

However, that is probably not worth our time.  The data (and the truth) were ignored by ERMA and they will probably be ignored here.  The fact is that there is considerable evidence that this is just another attempt by DoC to paper over what is going on and give the appearance of serious investigation, i.e., it looks very much like ERMA revisited, with about the same level of scientific sophistication AND honesty.  We all lined up for that show like good little democrats doing their duty spending countless hours collecting and presenting evidence only to discover it was a wired sham.

If this were otherwise, they would have by now

  • educated themselves more than they obviously have, contacted us and other opposition scientists directly,
  • at least checked out Poisoning Paradise which contains a blue print to the salient scientific information (DoC’s disinformation campaign against it apparently having been very effective at keeping people for even seeing it),
  • have looked at the scientific literature themselves,
  • listened to our Green Plant interview which contains an up to date summary of the arguments, including a discussion of numerous obvious alternatives,
  • used common sense, and thereby realized just how insane by international standards this bizarre practice actually is.

But they obviously have not.

I have CCed Mr Egan, but as I said, we are not impressed that this effort is any less stacked or more genuine than the other efforts by the NZ government regarding this ecological insanity.  The “insanity” of aerial 1080 is not a close call.  It is obvious that absent DoC’s $100M/year motivation, no country in its right mind would be indiscriminately mass dropping food laced with a universal poison into its forest ecosystems.  It does not require another “investigation”.

The DoC may imagine that it can whitewash its behaviour and keep the money coming with sham commissions and “investigations”, and they will probably be successful in NZ, as they have been in the past.  However it won’t work with the outside world.  There is not a single international scientist to whom I have described what is going who has not been absolutely slack jawed in disbelief and wonderment.  We do not believe that New Zealand is capable of fixing itself: too small and too inbred.  Eventually, what is going on will sink in in the outside world and DoC will be forced by external pressure to shove the whole ugly business quietly under the table, and pretend that it never happened.

In the meantime, New Zealand is setting world records for reckless poisoning of ecosystems, hundreds of unique native species are being systematically killed, and we cannot afford to spend more time in pointless attempts to bring them to their senses.  I tell you, the whole thing is so bizarre that 12 years ago when we moved here I would not have believed it.

Quinn and Pat


15th march 2011

Parliamentary Commissioner for the Environment;
Re your re examination of 1080

Dear Commissioner,

I suggest you taker note of this and then open the DVD I sent you 2 years ago about the Turangi Horse Incident, then examine the Hikaka report commissioned by EW; then reopen the correspondence we sent you pre and post the ERMA review via our then group, ESPC.

If you wish, I can also send you details of infractions by AHB and EPRO LTD during the Kaimanawa North drop and the West Taupo Rangitoto ranges drops. I can also provide you with proof that around half a billion dollars of taxpayers money has been spent by the AHB with no regard to transparency to the public over the past 10 years and of fraudulent AHB cover ups. I can also prove neither the Minister of Finance, Minister of Agriculture, Minister of Biosecurity, or MAF itself or government select primary production committees can provide details of how public money is spent in detail by the AHB, the biggest users of 1080. We can also prove the MOH deliberately excluded the NZ public from input into the review of the VTA guidelines 2009 /10.

The fact you choose to ignore our NZWBM society and our close ally FATE, and our evidence is behaviour tantamount to the same predetermined outcome of the ERMANZ review of 1080 where again, the AHB was able to exclude the public and therefore ERMA from full information. PCE looks to become just as irresponsible.

Graham A Sperry

Chairman. NZ Wildlands Biodiversity Management Society Incorporated.

PO Box 1700 Taupo

CC: NZWBM society. Mayor Cooper. TDC. Ombudsmen.
Sarah Bol. Taupo Times fyi.

CC:Mary. This sequence of photographs and the explanations that follow would be very good to show those kids on the big screen. These exemplify the fact that 1080 keeps on killing creatures other than the targets, including one we hunt and eat like quail, rabbits and pigs. I am also sending to the PCE for their information, since they have denied four times my request that our NZWBM society be allowed to present evidence to their trumped up 1080 enquiry.

AHB carry out no AEE’s of protected or non protected species


From: Graham Sperry []
Sent: 17 June 2010 21:16
To: ‘Mayor – Rick Cooper’; ‘’; brian watts (; Andrea Eng; Matthew McDougall; Meriel Watts; murray hoare Crete;; Office of Te Ururoa Flavell; Peter Dunne; Reihana MacDonald Robinson; Rick Ryder; Roger Dewhurst; (Chairman EW Pest Committee); Todd McClay MP Rotorua
Cc: ‘’; Brent Cannard (;; clyde graf; Dallas and Laurie Hemphill (DALLASHEMPHILL@HOTMAIL.COM); Dave Leslie; David Livingstone; Duncan Farmer; Gary Ingles; ‘Gary Treloar’; Geoff Kenny; Geoffrey Robinson; Harvie Morrow; Helen Murdoch (CPL); Herb Spannagl;; Mike Jeff Stent; Pat Whiteing Okeefe (;;; Tim Shearer; Karen Hohaia

The beginning of the aftermath for the East Taupo AHB aerial 1080 drop

Photos 1 2 3 are a rabbits which has beenpoisoned with 1080, then eaten by a pig.The pig will now be either dead or unfit to eat.
Hawks and falcons also eat the poisoned rabbits and are also killed.
1080 poisoning 1080 poisoning 1080 poisoning
Photo 1 Photo 2 Photo 3
Photos 4 and 5 show the violent death throes of a rabbit which in its agony has worn most of the fur from both sides of its body before dying. 1080 Deaths 1080 Deaths
Photo 4 Photo 5
Photo 6 is a California quail killed. Note how broadly spread the tail feathers are.The birds go rigid in their final death spasms. 1080 Deaths
Photo 6
Photo 7 shows how baits are broken in the bucket spinner and reduced to a size attractive to birds. 1080 Deaths
Photo 7
Picture 8 is one of two dogs killed by biting on poison or poisoned carcasses on Tuesday evening as their masters walked them alongside the main Napier Taupo Highway. There were no poison signs and it is a main highway where any person can walk or stop their vehicle on the side of the main road for a break. i.e. A public area. 1080 Deaths
Photo 8


The Health protection Officer and the Taupo Police were given clear warnings by the Taupo District Council and by the NZ WBMN Society that the Duty of Care requirements were not met in the permit conditions for this drop and that the public and visitors to Taupo and their pets would be placed at risk. Several MP’s were also provided with these concerns with strong pleas made to them to prevent this drop from proceeding.

The drop covered approximately 60,000ha and could have been done using safe alternative ground based methods. The drop of poison started just a few days ago and is now virtually complete.

TDC and NZWBM made every possible lawful submission and plea to Environment Waikato, the Animal Health Board, the Health Protection Officer, the Minister of Health, the Prime Minister, The Minister for Local Government, Minister of Agriculture and others. The only positive political action we are aware of that was taken to address the issue prior to the drop taking place in response to our pleas was by Te Ururoa Flavell and the Maori party, but their efforts were in vain.

All the above photographs were taken today, 17th June 2010.

Graham Sperry.

Chairman. NZ Wildlands Biodiversity Management Society Inc’.


I also wrote a letter to the press which was published on 18th March. I sent a copy of this to PCE via email on 22 March 2011.

The letter is shown below.

 There was no response by the PCE to this article


Press Article


Press Article


Press Article


Then we wrote a further letter to PCE; also with a nil response.

To; Dr Jan Wright

Commissioner for the Environment

NZWBM members and associates.


Wednesday 8 June 2011

These are the specific recommendations made by the PCE commissioners review of 1080.

Recommendations  4, 5 and 6 are positively significant and support what our NZ WBM society has been advocating since our formation; however, with regard to recommendation 6  we have reservations about the transparency of the Department of Conservation based on their reluctance to comply even with the OIA and attempting to force fiscal charges on enquirers.

The main area of disagreement we would have with this PCE report is the assumptions it has made that ground based harvesting is not viable outside farm boundaries and very easy terrain because had we been allowed to make a presentation to the PCE , which was denied us, we could have outlined proposals which would have led to establishment of a far reaching possum harvest and allied pest control industry which would have significant benefits for the NZ economy as well as meeting most possum and rodent and mustelid management requirements.

The 1080 poison operational costs written in this PCE report are generally vastly low, being about 1/3rd of actuals that we know of. This means that other information assumed by the PCE to be correct with regard to comparison with harvesting options is also heavily biased against alternatives.

The reporting of 1080 operations to ERMANZ is significantly weak as is the enforcement of the relevant MOH and HSNO regulations by the issuers of resource consents. Every proposed 1080 poison operation should be subject to individual and independent public objections prior to any issue of a resource consent. Long term non notifiable regional consents are inappropriate.

Because the AHB has not been subject to the OIA it has been able to obfuscate costs and other data.

Our NZWBM society and associates will have significant disagreement with the conduct, findings and adequacy of this PCE report.

Below are the recommendations made by PCE.


I recommend that:
1. Parliament does not support a moratorium on 1080.

I recommend that:
2. The Minister for the Environment investigate ways to simplify and standardise the way 1080 and other poisons for pest mammal control are managed under the Resource Management Act and other relevant legislation.

I recommend that:
3. The Minister of Conservation establishes the Game Animal Council as an advisory body that works collaboratively with the Department of Conservation, but ensures that responsibility for all pest control remains with the department.

I recommend that:
4. The Minister of Justice introduces an amendment to the Ombudsmen Act 1975 to add the Animal Health Board to Part 2 of Schedule 1 of the Act, and thereby make the Animal Health Board also subject to the Official Information Act 1982.

I recommend that:
5. The Minister of Conservation asks the Department of Conservation to prioritise the development of national policy and operational procedures on possum fur harvesting.

I recommend that:
6. The Minister of Conservation improve information about pest control on the conservation estate by providing consistent and accessible information on the Department of Conservation website, including the purposes and results of different pest control operations.


Graham A Sperry
NZ Wildlands Biodiversity Management Society Inc’

1483 River road, RD1, Reporoa 3081.


I received no response from the PCE relating to the email above.


From: Steve []
Sent: Tuesday, 8 February 2011 8:56 a.m.
To: ‘’

Subject: PCE report ON 1080 AND ALTERNATIVES

Good morning Rob
My name is Steve Boot, and I am the Chair of the NZFC (New Zealand Fur Council). Our organisation represents all those industries that use possum as a core resource for their business.
I am not sure if you are aware of the scope of the industry in NZ.
There are approx 1.75 Million possums harvested every year. In the main this harvest is for the fur as a fibre to blend with wool for the knitwear industry. There is a small but growing use of the meat for pet food, and a resurgence of the pelt industry.
The industry combined generates $125,000,000 at the retail end ,and, and sustains 1,500 full time jobs and several thousand part time, it has the potential to double  if it could get better access to the resource.
It is our belief that the harvest could exceed 3 million if there was recognition and support from central and regional govt.
All these animals are recovered with out the use of controversial toxins like 1080; in fact the use of such toxins is seriously damaging our industry in a lot of ways.
It is the belief of NZFC, that a greater willingness of central and regional government to support what this industry offers would significantly reduce the perception that toxins like 1080 are the only option. NZFC strongly advocates that commercial harvest would provide a more sustainable, and less divisive funding solution to future possum management.
The NZFC would like to opportunity to have some dialogue with the commissioner in this regard

Kind Regards
Steve Boot
New Zealand Fur Council


From: Rob Egan []
Sent: Tuesday, 8 February 2011 3:48 p.m.
To: Steve

Hi Steve,

Thanks for the information about the fur industry. We’re keen to get a bit more of an idea of how it operates. Is there any chance you can give us an idea of:

  • How many possums are shot and how many are trapped
  • Roughly how many possums are harvested per hectare of land
  • Where are possums currently harvested and in what numbers
  • Whether possums are harvested from the DoC estate and if so where and in what volume

I’d also appreciate it if you could outline how toxins are harming the fur industry. Is it simply due to reduction of possum numbers or is there more to it than that?

I’m sure that we’ll have other questions about this to and your help is greatly appreciated.


Rob Egan


From: Steve []
Sent: Wednesday, 9 February 2011 10:49 a.m.
To: ‘Rob Egan’

Hi Rob
I will answer the questions in the order you sent them

  • The majority of possums harvested are with traps and Cyanide poison. Only around 5% would be shot. There are three ways that fibre is presented for sale, Hot plucked (fibre removed by hand plucking at time of death, trapping ,and shooting) Machine plucked(fibre removed from animal by machine ,this is used when possums are recovered using cyanide products) Slipe, (fur removed by chemical means from pelts recovered from the field)
  • This is a hard on to quantify, for example in areas of continuous habitat at medium to high densities it could be as high as 15/ 30 to the ha. For example on conservation land or exotic forest. On rateable land i.e. farms where habitat is scattered it could be as low as 3/5 per ha. It is a very subjective question.
  • Possums are being harvested throughout NZ wherever they can be found and access assured. Our stats over the last 5 yrs or so show that approx 70% comes from the North Island ,and 30% from the south. There has always been higher densities in the north due to better habitat; this split has been exacerbated by control programmes in the SI over the last 10 yrs. Logic dictates that where densities are on average higher, and those agencies responsible for administrating official policy are sympathetic and lateral, higher numbers are harvested. Northland would be a good example here. One company alone takes the fur off between 20/40,000 possums per month. One of the reasons for this is that both Regional Council, and DOC are very proactive in encouraging fur harvest as an integral part of management. Most private forest owners in Northland rely on fur harvest as there primary tool in possum management. Taranaki would be another example area of high harvest, with a sympathetic RC, DOC however not so
  • There are large numbers of possums harvested on conservation land; a ball park figure would be 500/600,000 per year.

There are however some limiting factors in this regard. DOC as an organisation interprets SOPs at regional and area office level. This means that there is no consistent policy with regard to fur harvest. Some conservancies/ area offices are very sympathetic and proactive with regard to looking at ways that commercial imperatives could be utilized to meet their own aims and goals. Some actively seek to make it hard, and are very inflexible when it comes to access and operational guidelines. It is the opinion of NZFC ,and the industry in general that this combined with a reticence at head office (Wellington) level to actively engage in a meaningful way with the industry has a significant impact on  the potential that harvesting could provide on public lands. The industry is of the opinion that up to two million possums a year could be harvested from public land if DOC used fur harvest as a management tool to its full potential

Rob you asked me to elaborate on how 1080 impacts our industry.
Yes the continued used of 1080 where possums could be harvested is of concern. There are large areas of NZ where ground control that utilizes harvesting as a management component, could be undertaken at a greatly reduced cost than aerial application of 1080. A good example of this would be East Taupo Forests.
It is a concern that where new 1080 operations are being planned there is no provision for allowing the industry access prior.
The other major concern for us is public and international perceptions. Those companies at the manufacturing and retail level have made very large investments in state of the art technology, and actively used the ‘100% Pure NZ’ brand as a successful marketing tool. More and more they are fielding concerns from domestic and international customers about the way toxins are used in this country. 1080 is not well regarded overseas, and is socially divisive domestically, and will continue to have a high profile. This industry is very concerned that this investment is being put a risk by those continuing to advocate that 1080 is the only solution

1080 has been used for 50 yrs in this country, and we still have possums. Yet we are continually being told that it is a panacea and we will all go to hell in a hand basket if we restrict or lose its use. The reality is that it is just a tool and a very blunt and clumsy one at that. It is the opinion of NZFC that the continued use of 1080 as it stands has more to do with an ideological agenda. 1080 is only registered for possums and rats (there is plenty of evidence that its effectiveness on rats is very short) yet thousands of deer pigs and other mammals and birds are killed as by-kill every year.
It is worth noting here that only around 20% of all pest control undertaken in NZ uses 1080; this includes hand laid. The very impressive gains that have been made in reducing possum densities in NZ over the last 15 years have been on the back of very efficient and cost effective ground control that has used methods other than 1080
NZFC is very concerned that the continued use of 1080 as it stands at present is putting at risk an industry that generates $125,000,000 per year and removes 1.75 million possums from the NZ environment at little or no cost to public and private funders

Sorry to be so long winded but this issue and this industry I am very passionate about. I have been involved as a private hunter, trainer, contractor business owner for 30 yrs.
I believe that the Commissioner has a chance to send a message that we must be looking for a more holistic solution to what is being presented at this time. This industry firmly believes that there are better solutions than those being presented at this time.

Kind Regards
Steve Boot