FULL TEXT of LETTER to the ATTORNEY GENERAL re UNLAWFULNESS OF AERIAL 1080

  Secretary

Manu Waiata Restoration & Protection Society

Registered office: 2225 Wyuna Bay Road

Coromandel 3581.

10 August 2017

Hon Christopher Finlayson QC

Attorney General

Parliament Buildings

Wellington

cc Hon Te Ururoa Flavell, Hon Ron Mark, Mr Chai Chuah, Ms Michelle Hippolite

Dear Attorney General ,

Please may I have your urgent attention. Department of Conservation plans to spread VTA 1080 over Coromandel's public conservation lands in September and October 2017.

• The operation as planned does not comply with provisions of the Treaty of Waitangi Act 1975, the Hazardous Substances and New Organisms (HSNO) Act 1996, the Health Act 1956, the Health (Drinking water) Amendment Act 2007, and the Communications Guideline for aerial operations (ERMA 2009). The September--October operation will be unlawful.
  

• Aerial poisoning is normally intended for remote and inaccessible terrain where human health does not need to be protected. The Peninsula's Public Conservation Lands are ringed by farms, roads, schools, and coastal settlements and are frequented by local families, hunters, trampers, and tourists.

• Poisoned carcasses do not rot, because fluoroacetate kills the maggots. DOC staff clear carcasses only from designated tracks and the lower reaches of streams. Long after the forests are re-opened to the public, heavy rain rolls poisoned carcasses down gully sides into streams that flow to coastal settlements and coastal roads. Contamination of water and water supplies is a harm that can not be remedied in settled areas.

• Even with waxed baits, dust generated from the helicopter bucket is blown by the wind beyond buffer zones. Two women from Reefton are suffering long term health impairment after being caught in an aerial drop on a roadway in 2014 NOTE 1. Dust is a harm that cannot be managed in settled areas.

• Trap monitoring results suggest possum numbers are not high enough to justify an expensive and non-complying poisoning operation. The very low rtci return for possums at Papakai, with town water supplies sourced from its streams, together with its close settlements and strong public preference for trapping, should invite rethinking the necessity for an aerial operation, NOTE 2.

• Trapping is a viable alternative for the Coromandel Peninsula. The ranges have been logged, mined, burnt and farmed. The forests are largely second growth. A fit person can walk over the range in a day, or up and over Moehau mountain in a day. Moehau is networked with tracks established for trapping in the 2000s when trapping produced the best rate of kiwi chick survival, NOTE 3. Targeted management by trapping has community support. Audits show that trapping is cheaper than aerial poisoning, NOTE 4.

• The purpose of the Treaty of Waitangi Act, to protect the relationship of Maori with their flora and fauna, is discussed under the HASNO Act, the Health Act, and the Communications guideline for aerial 1080 operations (2009). Hauraki Maori place great emphasis on protecting the purity of water and the safety of their food basket. These values are not protected by aerial poisoning. Maori have been vocal in advocating trapping.

• The purpose of the HSNO Act is to manage the adverse effects of hazardous substances. The paragraphs that follow demonstrate that the adverse effects of aerial 1080 cannot be managed on the Coromandel Peninsula. They can be prevented by using hunting and trapping.

• The purpose of s69 of the Health (Drinking water) Amendment Act 2007 is to protect the health and safety of people and communities by promoting adequate supplies of safe and wholesome drinking water from all drinking-water supplies. The paragraphs that follow demonstrate that water supplies cannot be protected during aerial operations on the Coromandel peninsula. They can be protected by using hunting and trapping.

Secretary

Manu Waiata Restoration & Protection Society

Registered office: 2225 Wyuna Bay Ro

Coromandel 3581.

HAZARDOUS SUBSTANCES AND NEW ORGANISMS ACT

1. 1. HSNO s.4. Purpose of Act

• The purpose of this Act is to protect the environment, and the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances and new organisms.

1080 baits contain the poison fluoroacetate. Fluoroacetate does not leave the environment, NOTE 5. It is absorbed by the sap of plants and the fluids of animals. It is eco-toxic that is, it poisons everything that breathes air. In aerial distribution the dust settles on the foliage that insects eat; the baits fall into the clefts of trees where pigeons drink, and onto the ground where insects, frogs, birds eat the baits, and into the streams where koura take the baits and eels and trout eat poisoned carcasses. 

 

1080 poisons introduced predators along with native flora and fauna. Rats increase their population faster than native birds. The adverse effects of 1080 when spread aerially are random and uncontrollable. The effects can not be managed. They can only be prevented by use of a different method.

2. HSNO s.5 Principles relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, recognise and provide for the following principles: (a) the safeguarding of the life-supporting capacity of air, water, soil, and ecosystems:

Mono fluoroacetate spread aerially is absorbed by water, soil, and eco-systems; the dust is carried in the air. It poisons, kills, and debilitates life forms. It weakens the mauri / wellbeing of ecosystems.

3. HSNO s.5 Principles relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, recognise and provide for the following principles: (b) the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social, and cultural well-being and for the reasonably foreseeable needs of future generations.

1080 poisons the food basket of Maori. On the Coromandel Peninsula wild food is significant in Maori diets. Pig hunters report that after the aerial 1080 drops on Moehau and Papakai in 2013, the wild pigs became emaciated and lost weight, It is known from scientific studies that 1080 has entered the food chain. Health warnings have been issued against eating pigs, eels, trout, watercress and puha following 1080 drops. NOTE 6.

4. HSNO s.6. Matters relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, take into account the following matters: (a) the sustainability of all native and valued introduced flora and fauna: (b) the intrinsic value of ecosystems:

Aerial 1080 kills native birds and rats and possums indiscriminately. The rat population numbers recover faster than the native bird populations, NOTE 7. It is foreseeable that repeated applications of aerial poisons will advantage rat populations and disadvantage bird populations.

Pigs and eels are valued fauna of Maori. Pigs and eels scavange the poisoned carcasses of possums, rats and mice and absorb the poison into their flesh.

Native flora and fauna weakened by poisoning are susceptible to disease. Targeted trapping avoids random killing of native biota and avoids secondary poisoning.

5. HSNO s.6. Matters relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, take into account the following matters: (c) public health:

1080 is entering the food chain. Scientific reports that have found 1080 in eels, watercress and puha have issued heath warnings against consuming these foods following aerial poisoning, NOTE 6.

Scientific studies report weight loss in eels NOTE 8, and pig hunters report weight loss in pigs, following scavenging of poisoned carcasses.

The Coromandel ranges are the water tank of the Coromandel peninsula. Helicopter flight paths cross hundreds of hidden streams as they drop poison baits. Poisoned carcasses and baits in the bush and in streams endanger public health. This aspect of aerial poisoning has not been addressed in the operations planned for September and October 2017.

6. HSNO s.8 Treaty of Waitangi

• All persons exercising powers and functions under this Act shall take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi).

7. and HSNO s.6. Matters relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, take into account the following matters: (d) the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga:

DOC Hauraki made the decision to use aerial 1080 for predator control in January 2017 and sent out letters to iwi informing them of this decision. Iwi were notified, not consulted, on the decision to use aerial poisoning. In the Treaty, the Crown agreed to recognise Maori rangatiratanga over the flora and fauna they value. No one was offered options for control in 2013 and 2017. No hui were held to discuss alternative means. DOC's planning proceedures usurped and failed to protect Maori rangatiratanga.

Maori gathered and ate a very wide range of plants found in the forests of the public conservation lands. Scientific studies have found that 1080 is moving through the food chain, through direct and secondary poisoning. NOTE 6. Eels and pigs are poisoned by eating poisoned possums.

Maori did not wastefully and randomly kill their game. The distribution of 1080 is not consistent with traditional kawa and tikanga practices of many hapu; it is not supported by tohunga and generally is not supported by the older kaumatua of Hauraki.

 Letters from hapu and iwi in 2013 and 2017 have advised DOC of Maori opposition to aerial poisoning. A kaumatua wrote, "I would also like to state that we the tangata whenua of Hauraki, see the use of 1080 as an absolute breach of tikanga and a direct violation (takahi) of Māori rituals and practices." Dr Koro Ngapo, Te Paea Marae ki Harataunga, 30 May 2017.

S6(d) provides Maori with statutory protection for their relationship with the flora and fauna they value. However, the relationship of Maori with their food basket is not protected by use of aerial poisoning. Plans to use aerial 1080 in September-October 2017 need to be changed to use of hunting and trapping.

8. HSNO s.6. Matters relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, take into account the following matters:(e) the economic and related benefits and costs of using a particular hazardous substance or new organism:

In 2004 an audit put the cost of aerial 1080 at around $56/ha without including costs for associated works and labour. Hunters and trappers contracted for $16/ha, NOTE 3. Aerial 1080 operations are expensive, hazardous to public health, opposed by the public, and generate adverse effects that cannot be remedied.

9. HSNO s.6. Matters relevant to purpose of Act

• All persons exercising functions, powers, and duties under this Act shall, to achieve the purpose of this Act, take into account the following matters: (f) New Zealand's international obligations.

New Zealand is a contracting party to the Convention on Biological Diversity 1992. The Convention is legally binding. 

Article 10 of the Convention reflects concern that conservation legislation should not prevent indigenous people from harvesting traditional resources. Each Contracting Party shall, as far as possible and as appropriate: (c) Protect and encourage customary use of biological resources in accordance with traditional cultural practices that are compatible with conservation or sustainable use requirements.

Most Coromandel iwi desire to trap for fur and hunt for meat, and need game to be free of poison. Customary treatment of pigs as game animals is recognised by Regional Council. DOC has a working relationship with Coromandel pig hunting clubs for control of wild pigs, but the Clubs were not invited to participate in DOC's planning and consultation for the September -- October operations.

10. HSNO s.7. Precautionary approach.

• All persons exercising functions, powers, and duties under this Act...shall take into account the need for caution in managing adverse effects where there is scientific and technical uncertainty about those effects.

In 1966 a concrete worker died from 0.3 gms of 1080. In 1995 a Maori child ate a bait dropped 130m from a dwelling at Otukou. In 2014, 1080 baits were dropped on two women on a road at Maori Gully, Reefton. A year later both were still ill. One woman had liver and thyroid damage, medically attested (NZ Herald, 29 June 2015). Typically as observed in pigs and eels that have absorbed 1080, she had lost weight. The women will have breathed in the poison dust that falls with 1080 baits.

Following the findings that trout were eating mice poisoned by a 1080 drop in 2014, DOC commissioned independent research into the risk, finding 1080 levels in trout flesh were significantly higher than recognised food safety guidelines.

 "Fish & Game New Zealand chief executive Bryce Johnson said the results were "not a good look" for New Zealand's so-called 100 per cent pure environmental brand ...and called for further research to provide a more accurate picture of the possible risks." The Press, 26 September 2014.

A letter from the Coromandel Pig Hunting Club to DOC Hauraki stated, "The debilitated state of some of the pigs after the 2013 operation and the death of several dogs which were fed on such pigs, suggests that the pigs may be absorbing sub-lethal doses of 1080. This has NOT been researched." F Mock Johnstone, Secretary, 7 June 2017.

The distances that 1080 dust has travelled, where the dust falls, the effects of dust inhaled, the ways in which sub-lethal poisoning is occuring, how 1080 is entering the food chain, have not been adequately researched. Caution has not been exercised in chosing the appropriate method for predator control.

11. HSNO s.13 General Duty. (1) Every person who imports, possesses, or uses a hazardous substance or new organism shall ensure that— (a) any adverse effect caused by an act or omission of that person in relation to that substance or organism on any other person or the environment is avoided, remedied, or mitigated.

Apart from along well trodden paths, DOC staff do not remove baits and poisoned carcasses from the bush before the public conservation lands are re-opened to public use. Carcasses poisoned by 1080 do not break down. Poisoning of water supplies over the long term is an effect that cannot be avoided, remedied, mitigated when an aerial method is used.

Poison dust generated in the distribution of 1080 pellets is causing long term human health problems, medically attested, NOTE 1. Buffer zones in DOC's planning for the September--October operations do not take into account wind blown dust. Some landowners have advised DOC that the buffers are inadequate.

Inhalation of dust is seriously detrimental to human health. Wind blown dust is an effect that cannot be predicted and cannot be avoided when 1080 is spread by helicopter.

In the Mahakirau Forest Estate subdivision, there is no certainty that helicopter flight paths spreading 1080 toxin will avoid pellets falling near dwellings, and no certainty that wind blown dust will not be inhaled by residents. The Mahakirau plan is unrealistic and unlawful under NSNO s13. Inevitably there will be adverse effects on residents that are not avoided, remedied, mitigated. The operation should not be granted permission.

Trapping does not generate harm to other people. The success of predator control by trapping in the Mahakirau subdivision, has been acclaimed in the local press (Hauraki Herald, 26 May 2017).

HEALTH (DRINKING WATER) AMENDMENT ACT 2007

11. s.69A Purpose (1) The purpose of this Part is to protect the health and safety of

people and communities by promoting adequate supplies of safe and wholesome

drinking water from all drinking-water supplies.

s. 69G drinking water—(a) means—(i) water that is potable;

s.69G contamination means,— (a) in relation to raw water that does not normally require treatment to be suitable for use as drinking water, the introduction of a substance or organism into that water or a source of that water, which—(i) makes that water unpalatable or unsuitable for human consumption; or (ii) requires that water to be treated to make it palatable or suitable for human consumption; and (b) in relation to raw water that normally requires treatment to become suitable for use as drinking water, the introduction of a substance or organism into that water or a source of that water, which makes that water unpalatable or unsuitable for human consumption, without intensified, or enhanced, or alternative, drinking-water treatment to make it palatable or suitable for human consumption

s.69ZZO. Contamination of raw water or pollution of water supply

(1) Every person commits an offence who does any act likely to contaminate any raw water or pollute any drinking water, knowing that the act is likely to contaminate or pollute that water, or being reckless as to the consequences of that act.

Helicopters flying along fixed lines above rugged forest while spreading aerial 1080 baits, cannot avoid dropping 1080 poison baits into tributary streams. This is an act of contamination and pollution of the water, regardless of whether the stream is a water supply. Maori place great importance on protecting the purity of water.

HEALTH ACT 1956

2. 12. Health Act 1956. s.29 Nuisances defined for purposes of this Act. a nuisance shall be deemed to be created (k) where any animal, or any carcass or part of a carcass, is so kept or allowed to remain as to be offensive or likely to be injurious to health: s. 30 Penalties for permitting or causing nuisances (1) Every person by whose act, default, or sufferance a nuisance arises or continues, whether that person is or is not the owner or occupier of the premises in respect of which the nuisance exists, commits an offence against this Act.

The plan by the Department of Conservation to leave poisoned carcasses uncollected, is an unlawful activity and abhorrent to Maori. Maori practising tikanga do not allow guts to enter a stream.

COMMUNICATIONS GUIDELINE FOR AERIAL OPERATIONS (2009)

14. The VTA permission forms require Department of Conservation officers to state they have complied with the requirements of the Communications guideline for aerial 1080 operations (2009). The Guideline describes three steps of communication.

STEP 1. Consultation on the options for control and their effects.

In 2013 and 2017 DOC officers made a decision to advertise aerial 1080 operations before beginning consultation with iwi and community groups, demonstrating that DOC did not intend to offer options for control. This is testified in numerous letters sent by hapū members to the Hauraki Director and the Director General of Conservation. There have been no hui or public gatherings where DOC staff have offered options for control.

STEP 2. Consultation on the effects of the operation.

Consultation has consisted largely of notifying people of decisions already made, discussing buffer zones, and identifying water takes. Letters to DOC Hauraki have not been answered and no public meetings or hui have been held.

None of the established community groups has been consulted. We have been kaitiaki of this environment for many decades. There has been no account taken of the effects of using aerial 1080 from the perspective of our missions: Forest&Bird (forests, wetlands, trapping), Manu Waiata (streams, fish passage, trapping advocacy), Kuaotunu Environmental Action (food forestry, trapping without poisons), the Pig Hunting Clubs (culling pigs, trapping), and the Coromandel Colville Community Board (community resolutions opposing aerial 1080 and supporting trapping).

STEP 3. Notification.

Communication has been primarily by advertisements and letters of notification.

15. The Guideline states, "The operations manager needs to establish the communication processes that are appropriate for the proposed operation".

No hui have been held. In DOC's 2013 permission application the individuals listed as being consulted on behalf of Maori did not hold hui with their hapu, and many hapu members did not know they had been spoken for.

DOC's lack of consultation with Maori was a subject of National News in 2013, NOTE 9.

16. The Guideline states, "When consulting with Māori, you need to take into account Section 6(d) of the HSNO Act: 'The relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taunga'.".

The public conservation lands intended for aerial poisoning operations in 2013 and 2017, are domains where Māori hunt game and gather materials. Kaumātua and iwi and hapū trusts have made known their strong opposition to the poisoning of the food basket. Scientific studies have reported traces of 1080 in foods eaten by Māori. Health warnings have been issued for pigs, eels, trout, watercress and puha following aerial poisoning operations.

Māori tikanga for reaching decisions was not observed in 2013 and 2017.

17. The Guideline states, "Notification on its own is not sufficient communication if an operation is taking place on public land. On public land, Māori, neighbours and hunting groups should be consulted either at a programme level or at minimum, at an operational level."

In 2013 and 2017 there have been no hui initiated by DOC to discuss options for predator control that could ensure safe use of public conservation lands by Māori, hunters, and local families (neighbours).

There is widespread support for trapping. Consultation at a program level would have identified concerns, and then options for control should have been offered.

On 16 June 2017 Māori and Pākehā published an Open Letter in the Hauraki Herald stating that Department of Conservation does not have a social licence for aerial 1080. People repeatedly said, We have not been consulted. DOC has trodden on our democratic right to decide on predator control in our own landscape. DOC has trodden on our rangatiratanga.

CONSULTATION WITH LOCAL GOVERNMENT

18. Moehau and Papakai public conservation lands are in the Coromandel Colville ward. Coromandel Colville Community Board has resolutions passed in 2007, 2009, 2011, 2017 opposing use of 1080 and supporting alternative methods such as hunting and trapping with cyanide only. Thames Coromandel District Council has resolutions passed in 2009 supporting the Community Board and advocating possum trapping for fur.

DOC officers did not offer to local government options for control in 2013 and 2017. Democratic process invites respect for local government. However, DOC has not consulted the Community Board. On 16 June 2017 Māori and Pākehā published an Open Letter in the Hauraki Herald stating that Department of Conservation does not have a social licence to use aerial 1080 on Coromandel's Public conservation Lands.

On 29 July 2017 Māori and Pākehā marched at Whitianga to protest against aerial poisoning. Speakers from tangata whenua, political parties and local government addressed the marchers. This was the only public meeting on the 1080 drops. Department of Conservation did not send a speaker.

NOTES

NOTE 1. 1080 baits were dropped on two women on Maori Gully Road near Reefton in June 2014. Ten months later both were still ill, it is assumed from inhaling the dust. One woman had liver and thyroid damage, ongoing nausea and digestive problems, and typically, as has been observed in pigs and eels that have absorbed 1080, she had lost weight. (Greymouth Star, 22 September 2014. NZ Herald, 29 June 2015)

NOTE 2. DOC's objective is to reduce possums to 5% rtci. 

 

MOEHAU. Monitoring of possums at Moehau in October 2016 recorded an rtci of 6.27% (Department of Conservation, Trend report for Moehau 2016, p.44). For the sake of reducing possums by 1.27% the Department has planned an expensive and risky aerial operation that may cause greater losses to native biota. 

 

PAPAKAI. The rtci for possums and rats was not known when the decision to use aerial 1080 on Papakai was made in January 2017. Subsequently, monitoring of possums at Papakai in February 2017 returned an rtci of 5.15% (Department of Conservation, Trend report for Papakai, 2017, p.21). An expensive aerial operation is to be undertaken for the sake of reducing possums by 0.15%.

90% of the public support trapping for predator control and 34% support aerial poisoning (IPSOS, Survey of New Zealanders, report for Department of Conservation, 2016).

NOTE 3. Trapping is cost effective.

Audits demonstrate that employing trappers is cheaper than conducting an aerial operation. For example, Hudson calculated the cost of the Hokonui aerial 1080 drop on 23 and 24 July 2004 at $56.40/ha, compared with a quote from hunters and trappers of $16/ha for ground-based predator control. The cost at $56.40/ha did not include the costs of helicopter hours, stand-by helicopter, digger and 2 graders to upgrade road, freight on baits, 24 hour security patrol, Insurance, resource consents hearing, administration by three bodies, consultation meetings and hui with locals (Animal Health Board, Project No: R-10573 (LC0203/107)).

In 2010 an audit of Animal Health Board for Cabinet, costed aerial 1080 at around $57/ha (Bovine Tb Strategy Review of Costs, July 2010, Table 3.4, p.21) of which $35/ha was control + survey (p.22).

NOTE 4. Trapping succeeds.

Possums were hunted and trapped on Moehau successfully, in the 1990s. From 1996-2007 Project Kiwi ran a successful trapping project on the Kuaotunu Peninsula. The project enhanced kiwi chick survival rate by around 50% per annum. Following Project Kiwi's template, Department of Conservation ran a successful stoat trappping programme on Moehau in the 2000s. “A simple recipe of predator trapping backed by kiwi chick survival monitoring, and hard work on the hill has produced this exceptional result, along with valuable knowledge of kiwi.” (Hauraki Conservator, John Gaukrodger quoted in Hauraki Herald, June 2007, and in Coromandel Town Chronicle, August 2013, p.28.).

NOTE 5. How the chemistry of 1080 works.

What is 1080? 1080 is Sodium monofluoroacetate CH2FCOONa.

 

Does 1080 occur naturally? No.

 What makes 1080 so toxic? It is the monofluoracetate ion (CH2FCOO-) which is toxic, the sodium ion (Na+) is irrelevant. Monofluoroacetate is toxic because it is the same shape and almost the same size as the acetate ion. When monofluoroacetate gets into a cell it is converted into monofluorocitrate and enters the citric acid cycle (how aerobic cells get energy). Unfortunately for the cell, fluorocitrate interferes with the enzymes that do the next step in the cycle. The cycle stops, the cell dies.

Does monofluoroacetate occur naturally? Yes. It is, however, potassium monofluoroacetate (CH2FCOOK) which is found naturally occurring. As with 1080 (CH2FCOONa) the potassium ion (K+) is irrelevant, it is the monofluoroacetate- ion which is toxic. There are three possible fluoroacetate ions with 1, 2 and 3 fluorine atoms (monofluoroacetate CH2FCOO-, difluoroacetate CHF2COO-, and trifluoroacetate CF3COO-). All three forms of fluoroacetate are equally toxic and it makes no difference to toxicity whether the source is natural or manufactured.

Forest & Bird Society, DoC, et.al., insist on claiming a natural source for fluoroacetate. This is to IMPLY a greater safety because fluoroacetate is “naturally occurring” that trades on the persistent, unsubstantiated belief held by the public at large that natural is “good” synthetic is “bad”. This is spin.

Is 1080 biodegradeable? Yes. Almost everything is, it is simply a question of how fast and by what process. IUPAC definition: “Degradation caused by enzymic process resulting from the action of cells”.

By this definition, 1080 is biodegradable. 1080 is stable below 200˚C except when it is ingested by a living cell -- any aerobic cell will do, like the cells you and I are made up of, or the cells of a morepork or rat or frog or dolphin, insect, bird, tree etc.

There are a few an-aerobic species which are able to degrade 1080 without visible harm. However, most of the 1080 dropped will eventually encounter a susceptible living cell which will ingest it, and attempt to metabolise it. Most of these cells will themselves be damaged or killed. Killing and damaging cells is not good for the environment.

Once a cell is dead, all enzymatic processes stop and any remaining fluoroacetate or its metabolite fluorocitrate will stop being degraded, leaving poisoned carcasses uncollected, each one capable of poisoning and/or killing the next scavenger.

Again, DoC et.al., insisting on describing 1080 as "biodegradable 1080” is spin, because it trades upon the commonly held belief that “biodegradable” is “good”. Biodegradable ONLY by damaging or killing cells is NOT “good”.

Fluoroacetate does occur in nature in a few species of plant probably as a defence against browsing. These plants are native to land masses which originally made up part of Gondwanaland, Australia, Africa and Latin America. None of these plants are native to NZ.

Animals can develop a tolerance for specific toxins when they evolve in the presence of those toxins particularly if they are folivores like the Australian Brushtail Possum. Thomas Look

NOTE 6. Health warnings.

"A withholding period of 30 - 38 days should be observed after any aerial 1080 operation in an area where puha may be in close vicinity to bait." (Miller et al, 2009)

"A withholding period of 10 days should be observed before collecting watercress after an aerial 1080 operation in the area." (Ogilvie et al, 2009)

"We detected 1080 residues in eel tissue that were on average 12 times higher than the PMAV, 1 day after eels consumed contaminated tissue. This suggests a withholding period for eel harvest after an aerial 1080 operation should be implemented." (Lyver et al, 2005)

"Research by DOC, the Federation of Freshwater Anglers, and Fish and Game New Zealand showed trout take up small amounts of 1080 into their flesh after eating mice infected with the poison." Southland Times, 2 October 2014.

Cawthron Research Institute commissioned by Department of Conservation advised, "a trout eating a small number of mice with 1080 will have traces of 1080 that potentially exceed New Zealand Food Safety Authority limits for 1080 in food."

Elaine C. Murphy , B. Kay Clapperton , Philip M. F. Bradfield & Hazel J. Speed (1998) Effects of rat poisoning operations on abundance and diet of mustelids in New Zealand podocarp forests, New Zealand Journal of Zoology, 25:4, 315-328. 

 

Sweetapple, P.; Nugent, G. 2007: Ship rat demography and diet following possum control in a mixed podocarp-hardwood forest. New Zealand Journal of Ecology 31: 186–201. “Mean ship rat abundance indices increased nearly fivefold after possum control and remained high for up to 6 years…the typical outcome for most pulsed possum control is an uncontrolled ship rat population in the presence of a low-density possum population for most of the 3-7 year cycle.” 

 

Innes, J., Kelly, D., Overton, J.M. & Gillies, C. (2010) Predation and other factors currently limiting New Zealand forest birds – a review. New Zealand Journal of Ecology, 34 , 86–114. “Intermittent control of possums and ship rats may have the nett effect of increasing ship rats for most of the time.”

NOTE 8. 1080 residues in eels.

P.O'B. Lyver, J. Ataraia, K. Trought, P. Fisher, 2005, Sodium fluoroacetate (1080) residues in longfin eels, Anguilla dieffenbachii, following exposure to contaminated water and food. New Zealand Journal of Marine and Freshwater Research, Vol. 39: 1243-1252

NOTE 9. Lack of consultation with Maori.

"Kaumatua says iwi not consulted over 1080", Radio NZ News, 8.13pm, 3 May 2013. "A Ngati Pukenga kaumatua says the Department of Conservation has not adequately consulted iwi over an upcoming 1080 drop....The chairman of Te Moana a Toi Leaders Forum, Awanui Black...says his Coromandel whanau opposes the drop, but DOC does not seem to be listening."