Proposed Ōpōtiki District Plan Chapter 8 Rural Zone Hearing Statement on behalf of the New Zealand Deer Farmers Association, Bay of Plenty Branch 27 July 2017 Contact for service: Lindsay Fung Deer Industry New Zealand P O Box 10702 Wellington 6143 Phone: 04 471 6115 Email: Lindsay.Fung@deernz.org
Qualifications and experience 1. My name is Lindsay Fung. 2. I am the Environmental Policy Manager for Deer Industry New Zealand (DINZ), a levy-funded industry-good organisation representing New Zealand deer farmers and venison processors. 3. DINZ represents the interests of all deer farmers and the processing and export sector for venison and velvet antler, and has a specific role in supporting the New Zealand Deer Famers Association and its regional activity and key issues through the Producer Management and Environmental Policy portfolios. 4. Professional advice and support for deer farmers at regional and local levels is a key part of that strategy and is often aligned with Federated Farmers of New Zealand at national and regional level. Scope of statement 5. This statement is prepared on behalf of the New Zealand Deer Farmers Association, Bay of Plenty Branch (NZDFA-BOP) in support of the submissions and hearing statements from Federated Farmers of New Zealand which NZDFA-BOP supports in full. 6. This statement will address the original submission points raised by NZDFA-BOP that have been rejected in the Section 42a Hearing Report: 40.1 provision 8.6.15 (Deer Farming) and subsequently Appendix 8.9.1 40.2 provision 8.3.1.1, condition 3 (Deer Farming) 40.3 provision 11.7.16 (Deer Farming) and subsequently Appendix 8.9.1 40.4 provision 11.3.2.1, condition 3 (Deer Farming) 7. Submission points 40.1 and 40.3 cover the same issue differing only in applying to geographic locations; these will be considered together in this statement. Similarly submission points 40.2 and 40.4 cover the same issue differing only in applying to geographic locations and will also be considered together. 8. NZDFA-BOP requests that this statement be considered for the hearing sessions covering Chapter 8 (Rural Zone) and Chapter 11 (Ōhiwa Harbour Zone). Page 2 of 7
Provisions 8.6.15 and 11.7.16 (Deer Farming as part of the Rural Zone and Ōhiwa Harbour Zone standards) 9. NZDFA-BOP has submitted that these provisions are based on obsolete legislation (the Animal Identification Act 1993) or that the existing legislation is not being applied appropriately (failure to recognise requirements under the Wild Animal Control Act 1977 have been updated as per the Department of Conservation, Deer Farming Notice No. 5, 2008 pursuant to Section 12 A of the Wild Animal Control Act 1977). 10. NZDFA-BOP sought deletion of these provisions as relief and note that this has not been recommended in the Section 42a Hearing Report which provides the following reasoning: Deer and goat farming is controlled through the District Plan to support the District s ecological values. Introduced pest animal species can threaten natural ecosystems and decrease biodiversity and natural character. Supporting other measures to reduce the numbers of pest animals in the district, the plan rules manage goat farming through identified goat management areas and manage deer farming through fencing and management measures. (Proposed Ōpōtiki District Plan Section 42A Report Overview, page 15) Management of deer farming is essential within the District to enable appropriate management. Deletion is not supported. (Proposed Ōpōtiki District Plan Section 42A Report, Chapter 8, Appendix 1, page 13) The rationale for the proposed provisions 11. The rationale appears to be based on the premise phrased as an issue in the Proposed Ōpōtiki District Plan Chapter 8 Rural Zone (page 114): Some animal species, such as deer and goats, must be correctly housed and fenced to avoid adverse effects on areas of significant indigenous vegetation. 12. In respect of the premise that deer must be correctly housed and fenced to avoid adverse effects on... indigenous vegetation, this could be extended to cover all herbivorous livestock. It would be helpful to identify where the areas of significant indigenous vegetation are and why particular livestock species need to be correctly fenced as opposed to other livestock species (that by inference do not need to be correctly fenced). 13. NZDFA-BOP believes that all livestock species need to be correctly fenced to avoid adverse effects on significant vegetation. Therefore the premise is flawed and as we will outline later, inappropriate with respect to the cited legislation. However more importantly correct fencing for deer farming ensures the following: Farmed deer in New Zealand are valuable assets. Commercial breeding hinds range in value between $600-$850, velvet stags between $2,000-$50,000 and young animals raised for venison between $50-$600. As with all livestock that provide income, it is not in the deer farmer s interest to have boundary fences that allow deer to leave the farm (regardless of proximity to significant indigenous vegetation). Page 3 of 7
The majority of deer farmed in New Zealand are red, Wapiti and hybrids. Fallow deer make up the remaining small proportion. Red and Wapiti deer are farmed specifically for meat (venison) or velvet (antler) as such the industry has over the last 47 years invested in genetic lines that have provided significant productivity and animal health gains. While different farmers will adopt a range of approaches to herd genetics (closed breeding systems, buying in of selected genetic lines, open breeding systems with no focus on selection traits) it is increasingly common for farms to have genetic selection criteria to maximise productive capability or reduce costs of production. This adds further need to effectively contain livestock within the farm and equally importantly to exclude feral deer with unknown genetics, temperament and animal health burdens. In line with this need to exclude non-farmed deer, bovine tuberculosis (TB) is classified as an endemic pest and farmed deer and cattle are monitored and tested for presence of Tb. Infected herds are severe economic costs with meat products being unsuitable for export and increased testing and movement controls placed on the herds. Deer farms that have a TB free status would be extremely disappointed to have any risk of feral deer contacting or mixing with farmed deer due to poor boundary fence design (and maintenance). The reality is that over the last 30 years, deer farmers have successfully contained their stock, tested exhaustively for TB at their own expenses under a national TB control programme. There is now also a mandatory lifetime identification and movement traceability national programme (administered through the National Animal Identification and Tracing scheme). Currently there are no TB infected farmed deer herds in the North Island and only two herds infected in the South Island. None of that success could have been achieved if deer farmers had not taken responsibility for their livestock security with appropriate fencing and management. 14. There are therefore sufficient commercial imperatives for farmed deer to be contained within the farm boundary and for non-farmed deer to be excluded from the farm property as is the case for all farmed livestock species. 15. NZDFA-BOP notes that a similar rationale was used to justify deer fencing standards in the proposed Hastings District Plan (currently under appeal) where the desired outcome was that Animals that pose a threat to the District s Indigenous vegetation and fauna will be prevented from escaping from farms into the wild (see Proposed District Plan as Amended by Decisions, Section 5.2, 5.2.6H, page 19 - http://www.hastingsdc.govt.nz/proposed-district-plan-decisions). A screenshot of the proposed standards is provided: Page 4 of 7
16. The standards were opposed by Deer Industry New Zealand and were subsequently removed in the decisions version with the following reason provided in the Proposed Hastings District Plan Decisions Report Section 5.2 Rural Zone: 10) The latest regulations result in the standard for deer fencing no longer being relevant. The submission from Deer Industry New Zealand referred to the Deer Farming Notice No. 5, 2008. 17. NZDFA-BOP understands that similar proposals were also removed in the Waipa District Plan (operative in November 2016) following submissions from Deer Industry New Zealand and Federated Farmers of New Zealand. The section 42A report discussion on the proposed provisions 18. Paragraph 8 above lists the Council s reasons for the retention of the provisions. NZDFA-BOP considers that these are fully addressed through industry current practice for deer fencing for the reasons outlined in paragraphs 11 and 12 and the original submission which stated that: The clause 1. Deer shall be kept in accordance with the Wild Animal Control Act 1977 is in effect redundant, as the Department of Conservation, Deer Farming Notice No. 5, 2008 pursuant to Section 12 A of the Wild Animal Control Act 1977 defines the areas for regulating or prohibiting deer farming and areas where it is permitted (with no limitations). A review of the rest of Section 12 A (Deer farms) of the Wild Animal Control Act 1977 does not indicate that there are any more requirements for farmed deer. Page 5 of 7
Deer Farming Notice No. 5, 2008 only prescribes fencing standards for deer farms within the regulated zone. The Ōpōtiki district is not part of the regulated zone. The clause 2. Deer shall be identified in accordance with the Animal Identification Act 1993 is redundant as the Animal Identification Act 1993 was repealed with the passing of the National Animal Identification and Tracing Act 2012 which requires farmed deer to be tagged and registered in the NAIT system as well as recording and confirming animal movements. Merely repeating national legal requirements for deer farmers provides no additional benefit to the council s intended outcome. The clause 4. Written advice of the location of the deer farming activity shall be provided to Council at the time of the establishment of the deer farming operation appears to be a copied approach for deer farming in regulated areas where written notification is supplied to the Director-General of the Department of Conservation. NZDFA-BOP notes that this is not a requirement in other District Plans where deer farming falls outside the regulated zones defined in Deer Farming Notice No. 5, 2008. This then appears to be an administrative exercise that will add time and cost for both the council and the farmer with no clear benefit. Page 6 of 7
Appendix 8.9.1 deer fencing standards 19. NZDFA-BOP note that these are also a direct copy of the requirements in Deer Farming Notice No. 5, 2008 which are only applied to deer farms in the regulated zone. While NZDFA-BOP considers these requirements to be fit for purpose there are also alternative fencing designs that achieve the purpose of containing (valuable) stock within the farm boundary. Further advice on fencing design and specifications can be found at the Deer Industry New Zealand website: https://goo.gl/d9yfo9 Provisions 8.3.1.1, condition 3 and 11.3.2.1, condition 3 (Deer Farming as a specific permitted activity as part of the Rural Zone and Ōhiwa Harbour Zone) 20. The first licence for deer farming was granted in 1970. Over the last 47 years deer farming has evolved from the management of essentially wild animals to an industry that focusses management on genetic improvement, animal health and nutrition and environmental sustainability. Deer farming is generally not an isolated activity; an industry survey (in 2012 involving 600 farmers) revealed that over 80% of deer farmers are mixed livestock farmers (i.e. the farm has deer, sheep and/or beef cattle and/or other livestock). In essence deer farming is another component of modern New Zealand mixed livestock farming (albeit a small component). 21. NZDFA-BOP notes that Bay of Plenty Regional Council has opposed the relief sought by BZDFA- BOP that condition 3 is deleted citing the reason as deer are subject to the Wild Animal Control Act 1977. The scope for farmed deer requirements under this Act has already been outlined in paragraph 16. The removal for deer farming as a specified permitted activity does not diminish the requirements under the Act. 22. The Section 42a Hearing Report provided the following recommendation: Management of deer farming is essential within the District to enable appropriate management. Deletion is not supported. (Proposed Ōpōtiki District Plan Section 42A Report, Chapter 8, Appendix 1, page 13) 23. As the proposed plan seeks to have management of deer farming via provisions 8.6.15 and 11.7.16 and these are redundant, no further purpose is served or benefit gained by distinguishing deer farming from general (livestock) farming. The original submission NZDFA- BOP in its entirety therefore remains valid. Page 7 of 7