This document is intended as a prototype guideline for people who want to register an objection to pending 1080 operations on or near their property, or in their recreational areas.

It is not intended as a guideline for registering formal complaints AFTER an operation has taken place. (The latter will be the subject of a specific document designed for that purpose.

While a phone call might “get it off your chest”, unless hundreds of people do the same thing, the normal real result is that very little will change. Use the phone call to obtain the contact addresses you need in order to take the actions below. Also, if you do make a phone call, consider repeating it to your local councillor as well.

There are a few extremely critical protocols which must be followed if you are to win any satisfaction whatsoever.

They are as follows.

1. You must make your concerns and complaints in writing and in a formal letter to the relevant authorities.

2. You must insist on a timely written response which fully addresses your concerns.

3. You must keep duplicate copies of everything you send and receive.

5. If you have co-complainants, then you should endeavour to get signed statements from them as well.

6. Make sure your dates and addresses, and locations you refer to are correct.

7. Do not under any circumstances accept a telephone conversation as any assurance whatsoever that what you believe has been said, will have any substantive follow-up or guarantees. Regional Councils, Department of Conservation and other agencies involved in 1080 are notorious for seemingly fobbing off, misleading, ignoring or placing bureaucratic obstacles in the way of people or groups objecting to 1080. By writing yourself, and insisting on and receiving not only written acknowledgement, but also written documents which satisfactorily address your concerns, you will force these agencies and public servants to place on public record both your concerns and their actions. Only in this way can they be held accountable at a later time. In short, your own thoroughness will force them into the open. The public has been bamboozled for decades because they assumed word of mouth communications to and from these agencies would be sufficient.
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Again, the above 7 points are critical.

Sometimes despite all your efforts, you will not get the immediate result you want in the end view, but collectively and over time, multiple instances of properly documented complaints from many diverse sources and locations and responses will have a decided effect in that the 1080 industry and its methods will be completely exposed to formal and wider public scrutiny. Ordinary people will become empowered because of the written record, rather than the reality being hidden, possibly covered up or ignored because there is no written documentation.

There are four Public agencies and / or the Animal Health Board that are usually involved in the application of 1080, no matter where it occurs.

They are:

1. Your Regional Council

2. Your regional Medical Officer of Health. (MOH) (Attached to your local District Health Board.)

3a and 3b: Either or Both, DoC (Minister of Conservation, Parliament) and Animal Health Board (AHB (Wellington))

4. The government agency which creates the laws (HSNO Act) which govern the ways 1080 must be transported, applied and used is ERMA. (Environmental Risk Management Authority, based in Wellington.)

For any planned drop, the public health and safety protocols are defined by the MOH and the Resource Consent for the operation is only permitted with the MOH final authorising signature.

The relevant Resource Consent and MOH conditions are available from your local regional council and they have no right not to provide these on request. Be aware that persons have in the past experienced instances by these public agencies to not readily supply this information, supply incomplete information, or create long delays. If any of these things happen to you, keep a record of it, and make a complaint to the Ombudsmen and cc it to ERMA.
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It is important that you identify which three or four of the agencies are involved in any proposed drop in your area, and when you write your WRITTEN concerns, you need to send a signed copy to every one of them. You should also send a copy to ERMA, who will record your complaint in a register kept for the purpose, and who may or may not allocate and investigative officer to make further enquiries. However, do not rely on ERMA to do your follow-up with the other agencies. You must follow through yourself and expect some aggro; be determined and don’t accept long delays or poor responses. Maintain a dossier of all transcripts. Seek advice from ERMA and/or anti 1080 groups if you run into difficulties.

Be aware that many Regional Councils are operating “business units” within their structures, specialising in poisoning, which you are paying for; in the case of AHB, farmers are being levied to support AHB 1080 operations, and taxpayers are footing the bill to DoC for the same work, so / therefore many bureaucrats whose salaries depend on maintaining the 1080 industry may have little incentive in assisting you, (their paymasters) to have 1080 stopped.

Below are listed examples of a few of the typical concerns of people who don’t want poisons including 1080 on their property or public lands.

They use stream water for their own water needs including stock.

They use tank water. Dying poisoned birds and vermin often end up in water tanks or spouting.

Dying animals wander into the property and create a hazard to dogs, cats, and children. Deer and pigs have wandered over a kilometre before dying.

(Possums can take up to 18 hours to die, and can move a long way in that time; rats also. Rats will collect and store baits, sometimes in huts, and other shelters. Birds can fly distances before dying. Dead and dying rats and birds have been found in water tanks. Dying animals wander or fall downhill; potentially into waterways. Numbers of animals killed by 1080 have been recorded washing miles downstream into populated areas during heavy rain and subsequent high river levels.)
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Poorly managed 1080 drops occur where aircraft such as helicopters over fly residences, villages, property boundaries and pollute / poison stock and private property, which place those people at risk, as well as breaching CAA (civil aviation authority) regulations.

Poison such as TALON, (brodifacoum) have a very long term residency both in soils, pasture, the flesh of animals such as cattle or sheep or any mammal, even in sub-lethal doses, and potentially can have a farming property excluded from producing any meat for human consumption. TALON can also be passed from animal to bird to insect to soil and keep on killing. It can accumulate in body tissues until with repeat small doses over a period of time, finally becomes fatal.

1080 can kill any oxygen breathing animal / bird / bat or insect whether by direct feeding, or by eating a poisoned carcass.

Three cereal pellets or carrot chunks laced with the common concentration of 1080 at 0.15% ww is enough to kill a child.

There is no antidote for 1080.

The common excuse for allowing 1080 in waterways is that it is rapidly diluted to levels which will not affect humans; however recent medical research is casting doubts on the safety of this.

The truth is that 1080 breakdown in cold water is very slow (months.)

1080 decimates wild deer herds, which are valued for recreation and food.

On a wider ecological scale, it sets off long-term rat plagues, with dire consequences for birds/insects.

Other poisons such as Zinc Phosphide, Phosphorous, Strychnine and PAPP are extremely cruel, as is 1080.

Almost any terrain that can be walked through by man can be treated by bait stations using cyanide / ferratox, or cholecalciferol, which will effectively and economically kill rats and possums without the multiple risks associated with 1080 and other less pleasant poisons. Combined bait and traps will effectively deal with mustelids such as stoats. The possum trapping, fur and pet food industry will also attest to that fact.
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Be aware that the agencies will try to tell you 1080 is cheaper, but there was ample evidence provided to the ERMA review that this not necessarily so when the bigger picture is looked at.

Another key issue is to obtain proof that possums and ferrets are in high numbers and cannot be controlled by means other than 1080 and Talon. Agencies will attempt to justify the 1080 industry here also. Challenge them in writing and demand all animal survey figures which are available. If you suspect you are not being told the whole truth then inform the Ombudsmen and consider using the Official Information Act to obtain the information you want. The following is a suggested letter format in the event you wish to use the OIA . Have professional possum trappers been given a fair go?

“Under the provisions of the Official Information Act 1982, I request the following information concerning:

In the case of using poison including 1080 on or near your property, or on public lands, you are living in a supposedly free and democratic country and you can demand justification and reasons why safe alternatives such as ferratox cannot be used. You can demand buffer or exclusion zones.

There is a wealth of 1080 information on the Stop 1080 website, Possum Busters website, Graf Boys website and on the ERMA website; but in the latter case understand that ERMA came out and supported AHB and DoC. You may have to look diligently for the submissions which did NOT support 1080 although we have found ERMA staff to be generally co-operative.
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Be aware that recent formal research suggests very low spread rates are just as effective as the nuking that is presently done from the air. Alternatives are available.

The common aerial 1080 application rate these days is 3kg per hectare using carrot or cereal baits at 0.15% ww. 1080, and it is common also for DoC, AHB and Regional Councils to publicly claim in the media that these are very small doses. Putting it simply, this is untrue; these are massive and widespread aerial broadcast doses of a highly lethal and indiscriminate and non selective poison.

Don’t accept their spin, and always remember that it is YOU are paying for this stuff to be dropped on NZ.

Also be aware that it is illegal for aircraft containing 1080 to fly over dwellings.
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Incidents and evidence:

In the event of an incident, you need to inform the police immediately, and again, do it in writing! Most people have been phoning Regional Councils and or DoC, and not contacting Police or the MOH. The MOH and Police are important first contacts in the event of an incident. Some owners of farm stock, poisoned by 1080 have been bought off to ensure their silence. Do not be sucked into this ploy.

Digital camera’s and video cameras provide a simple and valuable means of irrefutable truth of accidents or other non compliance incidents involving application of 1080, including dead animals and birds, over-flying outside designated areas, fine dust from aircraft drifting over large areas and polluting the air, poison entering waterways etc. Get all the photographic evidence you can, and remember to put a date and time and location on it, and retain copies yourself. Let the authorities know you will be doing this as an ongoing procedure.

We trust this preliminary document is of some help. If you require further documentary on 1080 covering many aspects, please enquire via email through the Graf Boys website where an excellent DVD called “A Shadow of Doubt” can be purchased for NZ$25 post free in NZ., or write to ESPC, PO Box 1700 Taupo.

Feel free to contact us with any help advice or information you obtain. We will endeavour to put you in touch with someone from our organisation in your area.
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Additional Information:

In Southland, and possibly other provinces/areas, AHB/DoC or anyone wanting to apply aerial 1080 has to apply for a Resource Consent by way of the RMA. The Regional Council (Environ South) has provided the resource consent, but not before submitters have the opportunity to object and hopefully, have included in the document a number of conditions to make the 1080 drop safer and more acceptable ( if that is at all possible). In the Hokonui’s we insisted on 200 metre buffer zones along our farm boundaries that were supposed to be exempt from 1080 baits.

An Assessment of Environmental Effects or A.E.E. is produced by the applicant/s which outlines the proposed drop and all the effects it is likely to have. The submitters should then go through all the information provided to find any weak points or evidence to use at the resource consent hearing. This is either written or presented in person when the submitter speaks at the hearing. If no-one bothers to make a submission it is assumed there are no objections, with the applicants then able to have their own way. 

With the Hokonui’s consent hearing we all submitted as individuals. In hindsight, some of us should have submitted as a group, because funding can be applied for through a government environmental agency to help with legal costs if there is an appeal by a group. Even though it may seem like a lost cause, it certainly pays to be a submitter, because that is the only way to have any extra conditions imposed on the applicants. It also gives you the right to question any decisions and expect to be kept informed with any monitoring or reports that wouldn’t otherwise be available. If the consent is changed at any stage, the submitters are also involved.

You may discover that you are already subject to a previously granted resource consent, (some of them have been granted for periods of 10 years already), but if this is the case, do not let this prevent you from objecting as recommended above, with vigour and persistence.

Regards,
Graham Sperry , for ESPC.

ESPC. PO Box 1700 Taupo.

sperry@lures.co.nz

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