Canterbury Regional Pest Management Plan Review Discussion Document

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1 Canterbury Regional Pest Management Plan Review Discussion Document December 2015 Facilitating sustainable development in the Canterbury region

2 PO Box 345 Christchurch Phone (03) Church Street PO Box 550 Timaru Phone (03) Fax (03) Website: Customer Services Phone Report No. R15/144 ISBN Hard copy ISBN Web Copy Author: Environment Canterbury December 2015

3 Canterbury Regional Pest Management Plan Review Discussion Document HAVE YOUR SAY FEEDBACK PAGE Page 1 of 4 RETURN YOUR FEEDBACK BY 28 FEBRUARY 2016 YOU CAN RESPOND: By mail (no stamp required): Freepost 1201, RPMP Review, Environment Canterbury, PO Box 345, Christchurch 8140 Online: You can have your say online by commenting directly on this document at By pestreview@ecan.govt.nz OFFICE USE ONLY Please fill in your contact details below Your name Address Phone number Signature Postcode Mobile number Date FILE: BIO/STR/RPMS/5 If you would like to be included in future workshops I do not wish my contact details to be made public All feedback forms received are public documents. Copies will be published on the Environment Canterbury website. Have your say - Section (page 11) 1. Do you think there is a need for a change in the focus and resourcing of Environment Canterbury s Biosecurity programme to one that places greater priority on prevention, early intervention and pest risk pathway management? 2. Do you agree that a future Plan should include Good Neighbour rules that bind the Crown in relation to some pests? 3. Do you think all land occupiers and businesses have a responsibility to reduce the potential spread of pests by better managing the vectors and pathways for pests they have control over? 4. Is there another way Environment Canterbury could manage pests outside the Regional Pest Management Plan (the regulatory component of the Biosecurity programme)? 5. Would you support more general rate funding of pest management that has wider regional benefits? 1

4 HAVE YOUR SAY FEEDBACK PAGE Page 2 of 4 Have your say - Section 3.1 (page 12) 1. Do you support the retention of Community Initiative Programmes as a mechanism for enabling proactive communities/ groups of land occupiers to tackle pest management in their area? 2. Are there any specific changes or factors that you consider should be considered in the review of the current establishment procedures and criteria for a Community Initiative Programme? 3. Do you have any suggestions regarding what Community Initiative Programmes might be called under the new Plan? Have your say - Section 3.2 (page 12) 1. Of the approaches outlined in Appendix 1 for each of the pests, what is your preference and why? Are there other approaches or variations on the approaches presented that you think Environment Canterbury should consider? Please outline these, including potential pros and cons. 2. Do you think that declassification of ragwort, nodding thistle and variegated thistle is appropriate? If not, why not? Have your say - Section (page 13) 1. Do you consider that rules to provide some level of protection for pest control investments made by landowners and/or through public funding to protect biodiversity values is an equitable approach? Would it provide useful support for nonregulatory biodiversity programmes and initiatives? 2

5 Canterbury Regional Pest Management Plan Review Discussion Document HAVE YOUR SAY FEEDBACK PAGE Page 3 of 4 2. Are there any particular organisms that impact on biodiversity values not currently declared a pest in the current Plan and not included in section 4 (Potential New Pests) that you consider should be declared a pest and included in the future Plan? If so, please outline why. 3. Do you consider that the spread of wilding conifers is an important pest management issue for the Canterbury region? Do you think there should be a greater level of regulatory support for current wilding conifer control efforts? Have your say - Section 3.4 (page 14) 1. Are there any other pests in the restricted sale programme that you consider should be retained in the future Plan? If so, please outline why and what management approach should be taken. Have your say - Section 3.5 (page 14) 1. Do you think any of the pests proposed to be moved from the Total Control programme to a Progressive Containment programme should instead be retained in an Eradication programme? 2. Do you support Environment Canterbury continuing to focus effort and resources on the eradication of baccharis, entire marshwort, phragmites, egeria and rooks? 3

6 HAVE YOUR SAY FEEDBACK PAGE Page 4 of 4 Have your say - Section 4 (page 16) 1. Are there other harmful organisms that you think should be declared as a pest in the future Plan? If so, please outline why. 2. Are there any organisms listed in Table 4.1 that you do not think should be declared as a pest in the future Plan? If so, please outline why. Have your say - Appendix 1 (page 17) 1. For each of the pests outlined in Appendix 1, what is your preference and why? 2. Are there other approaches or variations on the approaches presented that you think Environment Canterbury should consider? Please outline these, including potential pros and cons. Any other comments: 4

7 Canterbury Regional Pest Management Plan Review Discussion Document FOREWORD Pest management is an important part of the sustainable management of natural resources in Canterbury. Environment Canterbury is responsible for providing regional leadership in pest management. This is done through our Biosecurity Programme, which aims to achieve smart management of pest risks in Canterbury. This Discussion Document is the first step in the review of the current Canterbury Regional Pest Management Plan, as required by the Biosecurity Act Its purpose is to seek the community s views on the best approaches to be taken in a new plan to replace the existing Regional Pest Management Strategy Canterbury has committed significant resources to the management of legacy pests that affect production land, with limited success. Resources are currently committed mainly to compliance inspections, which constrains work to prevent, detect and act on new pests arriving in our region. Environment Canterbury is proposing a change in the way we undertake pest management, focusing more on preventing new pests entering the region. This would help us become more resilient, with pests managed for both production land and biodiversity protection purposes. This new direction would place more responsibility on individual landowners to manage pests on their properties themselves, with compliance inspections focusing more on preventing pest spread to neighbouring properties. This presents an opportunity for more proactive initiatives, such as on-farm biosecurity and the inclusion of pest management in farm environment plans. Environment Canterbury would have more of a leadership role, particularly in the early stages of pest infestation, with more emphasis on advice, education and working with the community. Do you think that there is a need for change in the focus and resourcing of Environment Canterbury s Biosecurity programme? Your contribution to this Discussion Document will provide us with valuable feedback to help position the new plan to meet the community s future needs. We look forward to hearing your views. Tom Lambie Environment Canterbury Commissioner 5

8 REGIONAL PEST MANAGEMENT PLAN REVIEW Environment Canterbury has a responsibility to provide regional leadership in pest management. The Regional Pest Management Plan is an important part of the way we do this. It informs landowners of their responsibilities in terms of what pests to manage and the way to manage them. To try and manage the risk of new pests entering the region, Environment Canterbury is proposing a change to the way we manage pests. This is to make sure our pest management programmes are future focused and address new pest threats. This proposed change means pests will be managed for both production land and biodiversity protection purposes. In order to focus on new pests we need to rethink our priorities, including how legacy pests are managed. Over the last 20 years, pest management in Canterbury has primarily focused on the management of legacy pests that affect production land, such as broom, gorse, rabbits, Bennett s wallaby and nassella tussock. This approach has mainly relied on compliance inspections on rural land. However, reducing or maintaining pest levels across the region has seen limited levels of success. This focus on legacy pests has also meant that most of our resources are spent managing a small number of pest species. There is currently limited surveillance and monitoring work to detect new pests arriving in the region that could impact the economic well-being of the region as well as our indigenous biodiversity. This proposed new approach would continue to set rules for pest management across the region, but more responsibility would be placed on landowners to manage legacy pests on their properties themselves. Compliance inspections would be focused on preventing pest spread to neighbouring properties. Environment Canterbury would have more of a leadership role, particularly in the early stages of pest infestation, and more work would be focused on providing advice and education, and working with the community. Potential changes in approach are: More surveillance and monitoring for pests Management of gorse and broom through boundary rules to prevent impact on neighbours Wallabies managed through a targeted regional rate. The pest management programme would be focused on onthe-ground action. The 2012 changes to the Biosecurity Act and the introduction of the National Policy Direction for Pest Management will mean the new plan looks different from our current plan. The review currently being undertaken will also make sure our plan is aligned with neighbouring regions to help prevent new pests arriving here. The new plan only addresses the compliance part of our Biosecurity work. Pest management work that sits outside the Regional Pest Management Plan will still be included in our Biosecurity work programme, such as addressing wider pest management approaches through on-farm biosecurity and including pest management in farm environment plans. The proposed changes would also better support the environmental protection work we do, increasing the focus on managing pests for biodiversity gains. For example, biodiversity protection projects being undertaken in the Upper Clarence River rely on animal and plant pest control to deliver good biodiversity outcomes. To be successful in this proposed approach, it may be necessary to establish a regional rate for pest management. This would make it possible for Environment Canterbury to respond locally to pest issues that benefit the whole region and would introduce more flexibility to the way we work. For example, Bennett s wallaby management could be funded in a similar way to Chilean needle grass (the current management cost of Chilean needle grass is $1.46 per $100,000 property value rates contribution). We see this as an important potential change for our region and we look forward to hearing your views on the proposed direction. 6

9 Canterbury Regional Pest Management Plan Review Discussion Document TABLE OF CONTENTS HAVE YOUR SAY FEEDBACK FORM 1 FOREWORD 5 REGIONAL PEST MANAGEMENT PLAN REVIEW 6 1. INTRODUCTION Review Process and Timeline Review Timeline Have Your Say 8 2. THE CHANGING FACE OF PEST MANAGEMENT AND BIOSECURITY Increasing Pests and Pathways The Role of the Regional Council Legislative Reform and Central Government Policy Changes Biosecurity Act Reform National Policy Direction for Pest Management New Crown Obligations Good Neighbour rules Environment Canterbury s Focus and Approach Current Approach A More Efficient Approach Shifting the Focus POTENTIAL PEST PROGRAMME CHANGES Community Initiative Programmes Long established, widespread pests Biodiversity Pests Wilding Conifers Restricted Pests Total Control Pests Summary of Potential Future Programmes for Current Plan Pests POTENTIAL NEW PESTS 16 Appendix 1 17 Potential Future Management of Long Established, Widespread Pests 17 Gorse and Broom 18 Nassella Tussock 20 Bennett s Wallaby 22 Feral Rabbits 24 Chilean Needle Grass 26 7

10 1. INTRODUCTION The Biosecurity Programme involves a range of different workstreams and initiatives. The Canterbury Regional Pest Management Strategy (the current plan) is one component of the Programme. Although the Pest Management Strategy is the main regulatory component, the ambit of the Biosecurity Programme is much wider and is not necessarily limited to management of the pests included in the Strategy. Environment Canterbury is undertaking a full review of the Pest Management Strategy, as required by the Biosecurity Act 1. This Discussion Document is a key step in engagement with the community around the review. 1.1 Review Process and Timeline Environment Canterbury has been undertaking background work to inform the review over the past two years. We will continue to engage directly with stakeholders on particular matters, and may initiate targeted events such as focus groups and workshops following feedback on this Discussion Document, as more detail is developed for particular pest and programme options. An indicative timeline for the review process is provided below Review Timeline Review stage Timing Discussion Document released December 2015 Formulation of proposed new plan Late 2015 to mid 2016 Ongoing engagement on particular issues Late 2015 to early 2016 Public notification of proposed new plan Mid 2016 New Plan operative Have Your Say We want to know what you think of the changes we are considering as part of the current Plan review, as well as any particular concerns or issues you have regarding pest management in Canterbury. There are some specific questions asked at points within this document that will help with your thinking. You can have your say online by commenting directly on this document at or you can (pestreview@ecan.govt.nz) or write (Freepost 1201, RPMP Review, Environment Canterbury, PO Box 345, Christchurch 8140) to us, by 28 February This information will be used only to inform the development of a future Plan. 2. THE CHANGING FACE OF PEST MANAGEMENT AND BIOSECURITY 2.1 Increasing Pests and Pathways Pest management and biosecurity deal with living things and systems that are constantly changing. As an island nation, New Zealand faces ever-increasing risks and threats of new pests and diseases arriving here, as well as existing pests moving into new areas. A number of factors are behind this, including: Growing international and inter-regional trade, travel and tourism, meaning much greater movement of people, goods, animals and vehicles Increasingly complex supply chains, both nationally and internationally Widespread land-use change Climatic changes influencing the geographic range that pests can survive in. In Canterbury, these factors are contributing to a changing pest management environment. Some examples: Land use changes following greater irrigation, expansion of Crown conservation land through tenure review, and expansion of urban and semi-urban areas New tourism opportunities, such as increased cruise ship and direct international flight arrivals Changing freshwater habitats and greater water movement with increased irrigation infrastructure such as intakes, canals and storage dams. These changing pest threats mean our biosecurity and pest management systems need to be dynamic, responsive and adaptable. Resources for managing pests are finite, requiring a future focus in pest management that prioritises prevention, early intervention, and pathway management over ongoing management of established, widespread pests. It also highlights the importance of shared responsibility in biosecurity and pest management. It is not something that agencies such as Environment Canterbury can or should be tackling on their own - it is something all of us must take responsibility for. 2.2 The Role of the Regional Council The Biosecurity Act requires regional councils to provide regional leadership in pest management. Pest management encompasses activities that prevent, reduce, or eliminate adverse effects from harmful organisms that are present in New Zealand 2. Many other parties are also involved, including central government, other local government agencies, individual land occupiers, businesses, non-governmental organisations and community volunteers. Recognising that biosecurity and pest 8 1 A full review is required when the Strategy is due to expire within 12 months. 2 Part 2, Section 12B(1) Biosecurity Act 1993.

11 Canterbury Regional Pest Management Plan Review Discussion Document management are everyone s responsibility needs to happen at all levels if pest management efforts are to be effective. 2.3 Legislative Reform and Central Government Policy Changes Biosecurity Act Reform Amendment of the Biosecurity Act in 2012 included a number of changes relevant to regional pest management: Clarifying roles and responsibilities of central and regional government A change in terminology, with pest management strategies becoming plans Changes to pest management plan development and review processes to improve consistency and robustness, and enable greater adaptability and responsiveness (for example, the ability to undertake partial reviews of pest management plans at any time to address specific matters or changes) Introduction of new policy instruments including: a National Policy Direction to drive greater consistency, robustness and efficiency in pest management Provision for pathway management plans to specifically address pest and vector pathways in order to reduce the spread of pests Provision for good neighbour rules to which the Crown may be bound National Policy Direction for Pest Management As well as meeting the requirements of the Biosecurity Act, all reviewed pest management plans must now not be inconsistent with the National Policy Direction for Pest Management. This means the future Plan will be subject to the requirements of the National Policy Direction. The purpose of the National Policy Direction is to ensure pest management activities under the Biosecurity Act provide the best use of available resources for New Zealand s best interests and when necessary, align with one another. To achieve this, the National Policy Direction sets out content and process requirements for pest management, pathway management, and small-scale management plans. These aim to ensure greater consistency in terminology, and more transparency and robustness in the rationale for pest management programmes. There are five main Directions in the National Policy Direction on Setting Objectives, Programme Description, Analysing Benefits and Costs, Allocation of Costs, and Good Neighbour Rules. The Directions on Objectives and Programme Description introduce consistent terminology for pest management programmes and associated objectives. There are five prescribed programmes: Exclusion, Eradication, Progressive Containment, Sustained Control or Site-led 3. For each of these programmes, an intermediate outcome is defined. Every pest specified in a Regional Pest Management Plan must be subject to one or more of the five programmes, and the corresponding intermediate outcome will form the basis of the objective for that pest. Regional Pest Management Plans may not include any other type of programme. In response to the requirements of the National Policy Direction, regional councils have initiated a collaborative project that aims to identify areas where a standardised or more consistent approach to Regional Pest Management Plans can be agreed. Environment Canterbury is taking part in the initiative, and anticipates that it will influence components of the future Plan. 2.4 New Crown Obligations Good Neighbour rules Crown land has not traditionally been subject to the requirements of pest management plans. However, the Biosecurity Act amendments and the National Policy Direction now provide for the Crown to be bound under Good Neighbour rules 4. A Good Neighbour rule is defined in the Biosecurity Act 5, and the National Policy Direction prescribes the requirements that must be met in order for the rule to bind the Crown 6. Good Neighbour rules may only address the management of unreasonable costs imposed on land occupiers as a result of the spread of a pest from an adjacent or nearby property. Good Neighbour rules must be specified as such in a pest management plan, and importantly, apply to all land occupiers regardless of tenure; not just the Crown. Environment Canterbury is considering development of Good Neighbour rules for a number of pests to be included in the future Plan (for example, gorse, broom, rabbits and wilding conifers). 2.5 Environment Canterbury s Focus and Approach Current Approach The main focus of the current Plan and Environment Canterbury s pest management resources is on managing established, widespread pests through regulation. This is reflected in Biosecurity Programme spending, with a significantly higher proportion of the annual budget (approximately 60%) spent on regulation relating to established pests than on prevention and early intervention measures. Of the regulation budget, almost 70% is spent on just five pests 7 commonly referred to as legacy pests due to their long-term presence and established nature. 3 These programmes are also applicable for any Pathway Management Plan, and an additional Pathway Programme is specified for Pathway Management Plans should none of the other five programmes be applicable. 4 Section 69(5) of the Biosecurity Act provides that Good Neighbour rules are the only way that the Crown may be bound by a pest management plan. 5 Section 2 Interpretation, Biosecurity Act. 6 Clause 8 of the National Policy Direction. 7 Gorse, broom, nassella tussock, wallaby and rabbits. 9

12 Outside the current Plan, there has been some change in the focus of the Biosecurity Programme in recent years. This has included initiatives to develop surveillance partnerships, coordinated incursion response, developing the advice and advocacy component of officers roles, and raising awareness and understanding of the importance of pest risk pathway management. However, the relative level of resourcing for these initiatives remains very low A More Efficient Approach The pest infestation curve model (Figure 2.1) demonstrates basic pest population dynamics and is widely used by agencies to help determine the most appropriate approach to managing individual pests. Generally, the lower a pest is situated on the curve, the more cost effective it will be to control, and eradication may be feasible. The higher a pest is on the curve, the more difficult and costly it will be to control, although there may be benefit in controlling the pest in specific areas where it is not yet established, or to protect particular values. As a pest moves through the continuum, the management approach should respond accordingly, from concerted initial efforts to prevent the spread, to strategically focused efforts on a site-led basis to protect particular values or sites. Phase 0 Surveillance /Exclusion eg Argentine ants, nutgrass Phase 1 Eradication eg rooks, baccharis Phase 2 Containment/ Progressive containment Eg coltsfoot, Chilean needle grass Phase 3 Sustained control and site led eg Gorse, broom, mustelids, banana passionfruit Infestation Phase 0 Not in Region Vigilance Phase 1 New Arrivals Eradication Phase 2 Expanding Containment Phase 3 Widespread or Entrenched Suppression or Site Led Time Prevent spread Reduce impact Figure 2.1 Pest management continuum and pest infestation stages In addition to the economic benefits, prioritising action in the early phases of the curve (for example, prevention, early intervention and management of pathways), also develops the resilience of Canterbury s communities and economy to ongoing pest threats Shifting the Focus The factors outlined in the previous sections are central to a shift in focus being considered part of the current Plan review process. In practice, a greater focus on prevention and early intervention measures, and on improving community capacity to prevent pest spread might mean: More targeted surveillance and improved incursion response capacity Increased emphasis on pest risk pathway management, potentially including pathway rules and/or a pathway management plan Greater focus on eradication at an early stage More targeted pest programmes focusing on vulnerable areas and those with important values threatened by a range of pest species Greater operational focus on education, advice and whole-property pest management than on inspection and enforcement Reduction in agency intervention in the management of established, widespread pests. There is more of a regional benefit for pest management than is currently recognised in our existing plan. Managing pests in one part of the region has potential benefits for preventing the spread to other parts of the region. Where an approach has wider regional benefits, this may result in a Biosecurity programme funded by a greater proportion of general rates than targeted rates. 10

13 Canterbury Regional Pest Management Plan Review Discussion Document This shift in focus would not be solely reflected in the future Regional Pest Management Plan (which is just the regulatory component of the Biosecurity programme). There are likely to be implications in terms of the number and nature of pest programmes, as well as a greater reliance on the primary principle in pest management that land occupiers are responsible for the control of pests on land they occupy, regardless of whether any rules apply. The impact of these factors on the review of the current Plan is that particular consideration will be given to: Programmes related to established pests with relatively high Council intervention levels and associated costs Pests for which eradication, or even effective containment, are not feasible outcomes either regionally or within particular areas Established pests for which control methods are well developed and widely available to land occupiers. HAVE YOUR SAY 1. Do you think there is a need for a change in the focus and resourcing of Environment Canterbury s Biosecurity programme to one that places greater priority on prevention, early intervention and pest risk pathway management? 2. Do you agree that a future Plan should include Good Neighbour rules that bind the Crown in relation to some pests? 3. Do you think all land occupiers and businesses have a responsibility to reduce the potential spread of pests by better managing the vectors and pathways for pests they have control over? 4. Is there another way Environment Canterbury could manage pests outside the Regional Pest Management Plan (the regulatory component of the Biosecurity programme)? 5. Would you support more general rate funding of pest management that has wider regional benefits? 3. POTENTIAL PEST PROGRAMME CHANGES Potential changes to the current Plan are set out in this section in groupings of pests that reflect current pest programmes - Total Control, Biodiversity Protection, Restricted Sale, Progressive Control and Containment Control. The Progressive and Containment Control Programme pests are addressed together, and referred to as Long established, widespread pests. A table summarising the potential programme changes appears in Section 3.6. This table excludes the six longestablished, widespread pests for which potential future management approaches are set out in Appendix 1 (see Section 3.2). Some of the pests in the current Plan are being considered for removal or declassification as a pest. It is important to note that if this happens, or if there is a shift in management to a reduced and/or more targeted approach, Environment Canterbury will continue to monitor if and how things change in relation to the particular pest(s). It is now possible to undertake partial reviews and changes to a Regional Pest Management Plan at any time, meaning much greater ability to respond to significant changes in the extent or impacts of a particular pest. 3.1 Community Initiative Programmes The current Plan includes provision for Community Initiative Programmes (CIPs). There are currently two CIPs in Canterbury, one for rabbit control and one for possum control, both located on Banks Peninsula. A CIP is a mechanism that enables communities and/or groups of land occupiers to initiate, fund and develop a pest control programme for a particular area. Generally, they aim to achieve a higher standard of control for a particular pest than is prescribed in the current Plan, or at least greater effectiveness and efficiencies through consistent and coordinated pest control. Occupiers within the CIP area agree to a targeted rate collected by Environment Canterbury, which then manages delivery of the agreed pest control programme on the occupiers behalf. The programme may involve occupier responsibilities that apply instead of any relevant Plan requirements. Environment Canterbury currently intends to retain provision for CIPs, but the name will need to be changed so that it is not a programme because the National Policy Direction does not allow programmes other than the five that it prescribes. Environment Canterbury is considering re-naming CIPs as Community Pest Initiatives, but alternative suggestions are welcome. A review of the CIP establishment procedures will be undertaken, although significant changes are not anticipated at this stage. Under the new National Policy Directionprescribed programmes, CIPs are likely to be site-led programmes and at this stage it is anticipated that a CIP could be established for any pest included in the future Plan. 11

14 12 HAVE YOUR SAY 1. Do you support the retention of Community Initiative Programmes as a mechanism for enabling proactive communities/groups of land occupiers to tackle pest management in their area? 2. Are there any specific changes or factors that you consider should be considered in the review of the current establishment procedures and criteria for a Community Initiative Programme? 3. Do you have any suggestions regarding what Community Initiative Programmes might be called under the new Plan? 3.2 Long established, widespread pests The review of the current Plan is a good time to reconsider the balance of regional council and land occupier responsibilities in relation to the management of long established, widespread pests. This section considers the following pests, which are currently managed under Containment Control or Progressive Control programmes: Broom Gorse Nassella tussock Rabbits Bennetts wallaby Nodding thistle Ragwort Variegated thistle Chilean needle grass Sometimes called legacy pests, this term refers to the historical nature of these pests and the long-term regulatory management approach that characterises their current and previous management. For three of the pests ragwort, nodding thistle and variegated thistle the current programmes take a relatively low intervention approach with boundary control rules enforced by complaints received. Due to the widespread nature of these three pests, and the now well established and available bio-control methods, consideration is being given to de-classifying them as pests and removing them from the future Plan. In Section 2.5.2, the high cost and intervention levels for the remaining six legacy pest programmes, relative to prevention and early intervention measures for newer pests was highlighted. Despite the high level of investment, there is not always clear achievement of programme objectives for these pests. In some cases, the programmes appear to function more as a reminder service than the driver of proactive pest management. When considered in light of the pest infestation curve (Figure 2.1), it is evident that a shift in the programmes to a more targeted and/or reduced intervention approach should be considered. This could mean moving away from property-specific compliance inspection regimes to an approach that aims to manage inter-property spread, and to protect clear areas and/or those with particularly high values. In some areas, this could mean an increase in the levels of a particular pest. However, it may not necessarily justify a greater level of Council intervention. In some cases, a less regulated approach may provide occupiers with greater flexibility to manage pests in the most practicable way for their particular property and circumstances, and/or encourage greater coordinated control between adjoining properties. Environment Canterbury has undertaken a detailed evaluation of the current programmes and the range of potential future management approaches for these six pests. A summary of this work is outlined for each of the pests in Appendix 1. Three representative potential approaches are set out for each pest. These do not represent all potential options, but are intended to reflect the spectrum of approaches likely to be able to be justified under Biosecurity Act tests. HAVE YOUR SAY 1. Of the approaches outlined in Appendix 1 for each of the pests, what is your preference and why? Are there other approaches or variations on the approaches presented that you think Environment Canterbury should consider? Please outline these, including potential pros and cons. 2. Do you think that declassification of ragwort, nodding thistle and variegated thistle is appropriate? If not, why not? 3.3 Biodiversity Pests The Biodiversity Protection Programme includes pests that primarily threaten biodiversity values. The programmes are mainly site-led, with a non-regulatory approach focused on facilitating and supporting pest control in High Value Environmental Areas. The Programme includes declared pests as well as a group of organisms that have not been declared as pests but which are included as Other organisms to be controlled. The Biodiversity Protection Programme was introduced before the establishment of Environment Canterbury s wider Biodiversity programme, which now provides an alternative means of managing sites with high environmental values, including pest control. Consequently, Environment Canterbury is considering excluding many of the Other organisms to be controlled from the future Plan, unless there is clear justification for declaring any of these organisms as pests. Currently, only puna grass and Russell lupin are being considered as potential new pests (see Section 4), while hieracium is being considered for declassification and removal from the Plan, given that biocontrol is now well established. The current approach for most of the well-established and widespread biodiversity pests (site-specific and nonregulatory) essentially reflects the nature of the wider Biodiversity programme. Therefore the review is looking to refine the approach to biodiversity pests in the future Plan to better support, rather than mirror, the work of the Biodiversity programme.

15 Canterbury Regional Pest Management Plan Review Discussion Document Declaring an organism a pest in a Regional Pest Management Plan triggers a statutory and regulatory framework and associated tools that are not otherwise available in the management of biodiversity sites and values; for example, a statutory restriction on the sale, propagation or distribution of the pest, and ability to impose rules in relation to its management. This is central to the way the future Plan might better support the Biodiversity programme, as well as landowners taking action to protect biodiversity on their properties. Environment Canterbury is considering the introduction of rules in relation to Biodiversity pests in the future Plan. These might include boundary and/or Good Neighbour rules triggered when an adjacent landowner is proactively managing the pest and/or where publicly funded pest control is being undertaken to protect biodiversity values. Rules that require occupiers to undertake ongoing maintenance pest control at a site following publicly funded control at the site are also being considered as a way of providing a level of protection for the public investment. The Biodiversity Protection Programme will be discontinued under the future Plan due to the new National Policy Direction requirements for pest programme names. Most of the pests currently in the Biodiversity Protection Programme are likely to be included in Site Led and/or Sustained Control programmes in the future Plan. Where a pest is managed through a Site Led programme, the site(s) to which the programme applies must be identified. This may be done by specifying the geographic area(s), a description of the place/type of place, or criteria for defining the place to which the programme applies. If a description or criteria are used, this must give sufficient certainty to occupiers for them to determine whether the programme applies to their land. If the specific sites or areas where a Site Led programme will apply are already known (for example, a specific part of a catchment, within specific riverbeds, at particular reserves or covenanted areas) these will be able to be mapped and/ or listed in a schedule to the future Plan. However, for programmes aimed at managing pests at sites with high biodiversity values but not predetermined locations, it will be necessary to specify particular, and relatively easily determinable, criteria. The current Biodiversity Protection Programme applies at High Value Environmental Areas and the current Plan includes the framework for determining whether a particular site or area would qualify. However, this does not contain sufficient detail for an occupier to determine whether the programme applies to them or not, and mapping and identifying all potential High Value Environmental Areas where the Biodiversity Protection Programme may apply is currently impractical Wilding Conifers Wilding conifers are currently included in the Biodiversity Protection Programme. A general rule requiring occupiers to take all steps reasonably necessary to prevent the spread of wilding conifers is included, although the focus of the operational wilding conifer programme is on targeted high-value areas where Environment Canterbury works in partnership with occupiers and other agencies. As one of the highest priority pest management issues facing the Canterbury region, wilding conifers will be retained in the future Plan. Wilding conifers could be managed via Site Led and Sustained Control programmes, and could include Good Neighbour rules. However, management programme specifics will be informed by work currently being led by the Ministry for Primary Industries. This work involves a collaborative project to develop agreed Regional Pest Management Plan provisions (including rules) for the management of wilding conifers. The project aims to improve consistency and effectiveness in the management of wilding conifers, and forms part of the implementation programme for the New Zealand Wilding Conifer Management Strategy released in December Environment Canterbury anticipates that any future wilding conifer programme will continue to involve a prioritised strategic approach delivered through partnerships. However this is likely to be supported by clearer regulatory obligations, and potentially a more geographically targeted regime. HAVE YOUR SAY 1. Do you consider that rules to provide some level of protection for pest control investments made by landowners and/or through public funding to protect biodiversity values is an equitable approach? Would it provide useful support for non-regulatory biodiversity programmes and initiatives? 2. Are there any particular organisms that impact on biodiversity values not currently declared a pest in the current Plan and not included in section 4 (Potential New Pests) that you consider should be declared a pest and included in the future Plan? If so, please outline why. 3. Do you consider that the spread of wilding conifers is an important pest management issue for the Canterbury region? Do you think there should be a greater level of regulatory support for current wilding conifer control efforts? Consequently, Environment Canterbury is considering what the criteria for biodiversity-related Site Led programmes might include. It is intended that these programmes would only apply at sites where there is agreement and some level of partnership with the landowner(s). Therefore, although the criteria may include physical, ecological and/or geographical factors, it is likely that one of the criteria would be a prescribed type of agreement between the landowner(s) and Environment Canterbury. 13

16 3.4 Restricted Pests The current Plan includes a restricted sale programme, the objectives of which are to: Prevent the establishment of pests not known to be present in Canterbury Ensure those pests known to be present are not spread by sale, propagation or distribution. The primary focus of the programme is on plant nursery inspections, general surveillance, and raising public awareness about the potential impacts of the plant pests included in the programme. The restricted sale programme will be discontinued under the future Plan due to the new National Policy Direction requirements for pest programme names. At this stage, the restricted pests not currently known to be present in Canterbury could be managed under an exclusion programme aimed at preventing them from establishing in the region, while the remaining restricted pests are likely to be declassified and not included in the future Plan. See Table 3.1 for the specific pests proposed to be included in the exclusion programme, and those being considered for removal from the Plan. HAVE YOUR SAY 1. Are there any other pests in the restricted sale programme that you consider should be retained in the future Plan? If so, please outline why and what management approach should be taken. 3.5 Total Control Pests Pests currently managed under the Total Control programme are a significant threat to the region s economy and/or environment. These pests are of low incidence or density throughout Canterbury. The objective for most of these pests is eradication over the lifetime of the current Plan. Attempting to eradicate pests while they are at low incidence is a cost-effective and efficient approach, as shown by the pest infestation curve (Figure 2.1). The National Policy Direction equivalent programme is Eradication, and the prescribed intermediate outcome is to reduce the infestation level of [named pest] to zero levels in an area in the short to medium term. This differs from the way the objective for most Total Control pests is currently expressed over the duration of the strategy, destroy all [named pest] plants prior to viable seed set in the Canterbury region. reduction objective, and potentially a longer-term eradication objective. There is unlikely to be a significant change in the operational management of these pests. Achieving zero infestation levels within the short to medium term is only considered feasible for three of the current Total Control pests baccharis, entire marshwort and rooks. It is anticipated that these pests will be managed under an Eradication programme. Outside the Total Control programme, there are two other pests in the current Plan with eradication objectives - phragmites and wild thyme both currently in the Biodiversity Protection programme. Eradication is considered feasible for phragmites but not for wild thyme which is likely to be managed under a Sustained Control programme in future. Egeria, also currently in the Biodiversity Protection programme and known to be present at one site only, is likely to be shifted to the Eradication programme. HAVE YOUR SAY 1. Do you think any of the pests proposed to be moved from the Total Control programme to a Progressive Containment programme should instead be retained in an Eradication programme? 2. Do you support Environment Canterbury continuing to focus effort and resources on the eradication of baccharis, entire marshwort, phragmites, egeria and rooks? 3.6 Summary of Potential Future Programmes for Current Plan Pests Table 3.1 summarises the programmes that pests in the current Plan may be managed under in future. Although the National Policy Direction limits programmes to the five set out in the table, a pest may be managed under more than one programme. For many of the plant pests that impact primarily on biodiversity values, management may be most appropriate via both a Site Led and a Sustained Control programme. Where it is anticipated that this approach may be taken, the pest is marked with an *. The bottom row of the table includes the prescribed intermediate outcome for the programme, which will form the basis of the objective for each of the pests in it. The table does not include the following pests, for which representative potential future management approaches are outlined at Appendix 1 gorse, broom, nassella tussock, Bennett s wallaby, feral rabbits and Chilean needle grass. The nature of the National Policy Direction-prescribed outcome for Eradication programmes, particularly the short to medium term timeframe for achieving zero infestation levels, means not all Total Control pests will shift to an Eradication programme in the future Plan. An efficiency and effectiveness review of the Total Control programmes has also signalled that eradication in the short to medium term may no longer be practicable for many of the Total Control pests. For most, future management is likely to be via a Progressive Containment programme, with a 14

17 Canterbury Regional Pest Management Plan Review Discussion Document Table 3.1 Potential Future Management Programmes for Pests in the Current Plan 8 Exclusion Eradication Progressive Containment Sustained Control Site Led Australian sedge Rooks African feather grass Boneseed* Banana passionfruit* Broomsedge Baccharis African love grass Darwin s barberry* Feral cats Noogoora bur Egeria Bell heather Wilding conifers* Feral goats Nutgrass Entire marshwort Bur daisy Wild thyme Lagarosiphon Oxylobium Phragmites Coltsfoot Mustelids Palm grass Saffron thistle Old man s beard* Spiny broom White edge nightshade Possum Woolly nightshade To prevent the establishment of [pest]in [the Canterbury region/a prescribed area] To reduce the infestation level of [pest] to zero levels in [the Canterbury region/a prescribed area] in the short to medium term To contain or reduce the geographic distribution of [pest] to [a prescribed area] over [time/a prescribed period] Hieracium, nodding thistle, Ragwort, variegated thistle To provide for ongoing control of [pest] to reduce its impacts and its spread to other properties Wasps Wild cotoneaster [Pest] is excluded or eradicated from [mapped/ defined place/ place that meets prescribed criteria], or is contained, reduced, or controlled within [mapped/ defined place/ place that meets prescribed criteria] to an extent that protects the values of that place Proposed declassification barberry, bathurst bur, blackberry, boxthorn, buddleia, burdock, cape honeyflower, cape ivy, goats rue, hawthorn, German ivy, hemlock, Himalayan honeysuckle, nardoo, perennial nettle, plectranthus, plumeless thistle, privet (Chinese), sheeps bur, Spanish heath, spartina, St Johns wort, sweet briar, velvet groundsel, wild elaeagnus 8 Table 3.1 does not include the following pests, for which representative potential future management approaches are outlined in Appendix 1 gorse, broom, nassella tussock, Bennett s wallaby, feral rabbits and Chilean needle grass. 15

18 4. POTENTIAL NEW PESTS As part of the current Plan review, Environment Canterbury is considering the inclusion of a number of new pests in the future Plan. There are a several tests under the Biosecurity Act that must be met for a pest to be included in a Regional Pest Management Plan, and ultimately the net benefits of regional intervention must outweigh the costs. Table 4.1 sets out organisms currently being considered for inclusion in the future Plan, sorted according to the pest management programme it is anticipated they are most likely to be managed under. Most of these organisms can significantly impact on biodiversity values, so those that are well established and potentially widespread (listed under Site Led in the table), are likely to be managed under a Site Led programme but may also be considered for management under a Sustained Control programme. Table 4.1 Potential New Pests for Inclusion in the Future Plan Exclusion Eradication Progressive Containment Sustained Control Site Led Hornwort Moth plant Puna grass Beggars tick Ants (various species) Yellow water lily Bermuda buttercup Kangaroo grass Yellow bristle grass Canary reed grass Cathedral bells Chilean flame creeper Himalayan balsam Horsetail (rough) Knotweeds (various) Purple loosestrife Rum cherry Russell lupin Spurge laurel Sagittaria platyphylla HAVE YOUR SAY 1. Are there other harmful organisms that you think should be declared as a pest in the future Plan? If so, please outline why. 2. Are there any organisms listed in Table 4.1 that you do not think should be declared as a pest in the future Plan? If so, please outline why. 16

19 Canterbury Regional Pest Management Plan Review Discussion Document APPENDIX 1 Potential Future Management of Long Established, Widespread Pests This section focusses on broom and gorse, nassella tussock, feral rabbits, Bennetts wallaby and Chilean needle grass. With the exception of Chilean needle grass, these pests are often called legacy pests, due to the historical nature of these pests and the long-term regulatory management approach that characterises their current and previous management. Environment Canterbury has undertaken a detailed evaluation of the current programmes and the range of potential future management approaches for these six pests. These pest programmes currently carry high cost and intervention levels. However, despite the high level of investment, there is not always clear achievement of programme objectives for these pests. In some cases, the programmes appear to function more as a reminder service than the driver of pro-active pest management. To help achieve the programme objectives for the management of these pests, a move away from property-specific compliance inspection regimes to an approach that aims to manage interproperty spread, and to protect clear areas and/or those with particularly high values may be required. A summary of this work is outlined for each of the pests in Appendix 1. Three representative potential approaches are set out for each pest. These do not represent all potential options, but are intended to reflect the spectrum of approaches likely to be able to be justified under the Biosecurity Act. HAVE YOUR SAY 1. For each of the pests outlined in Appendix 1, what is your preference and why? 2. Are there other approaches or variations on the approaches presented that you think Environment Canterbury should consider? Please outline these, including potential pros and cons. 17

20 GORSE AND BROOM Current programme Containment control programme 9 Objective: To prevent gorse/broom from infesting land currently free from them Rules: Occupiers required to control scattered plants and plants along property boundaries Where are we at with gorse and broom? Gorse is well established, with almost inexhaustible seed-banks, in most available habitats across Canterbury Broom is also well established, although in some areas infestation levels are lower than for gorse and a number of headwater areas remain relatively of it Effective control tools are widely available and well understood Occupier control decisions are often more influenced by prevailing economic capacity and land use and intensity choices than regulatory requirements (for example, in 2012/13, of the 1031 properties inspected, 911 were not compliant) Improved understanding of the role played by animals in seed spread, indicates that once gorse or broom are established they are likely to remain present on land under sheep grazing In some situations, gorse and broom can function as a nursery crop for regeneration of native vegetation, provided the site has the necessary additional characteristics (such as nearby seed source). Alignment with the rest of New Zealand in most other regions the objective for gorse and broom is primarily to manage impacts on neighbours, with just boundary control requirements, enforced on a complaints basis. Higher standards may apply in specific targeted subzones with low/minimal infestation levels, or sites with high environmental values Implementation of the current regulatory regime is expensive and whether or not it is achieving the objective is unclear and difficult to determine due to the wide number of other factors that influence control decisions and spread, as well as the impact of lateral creep from infestations above the threshold for required control. 9 Would be Progressive Containment (with a contain rather than reduce objective) under National Policy Direction terminology. 18

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