ERMA New Zealand Evaluation and Review Report
Application for approval to import a new livestock animal, Camelus dromedarius (dromedary or Arabian camels)
Application Code: NOR08002
Prepared for the Environmental Risk Management Authority, pursuant to section 58(1)(a) of the HSNO Act.
Table of Contents 1 Executive Summary ...... 3 2 Introduction ...... 4 3 Information review ...... 6 4 Risk management context ...... 6 5 Associated approvals ...... 9 6 Organism Description ...... 10 7 Likelihood of forming a self-sustaining population anywhere in New Zealand, taking into ease the chance of eradication ...... 13 8 Identification and assessment of potentially significant adverse effects (risks and costs) ...... 18 9 Previous similar applications ...... 39 10 Associated approvals ...... 39 11 International obligations ...... 39 12 Overall evaluation ...... 39 Appendix 1: Decision path and qualitative descriptors ...... 41 Appendix 2: Biographies of for individuals noted in text and appendices ...... 48 Appendix 3: Organism Description ...... 49 Appendix 4: Probability of a self-sustaining population(s) forming, taking into account the ease of eradication ...... 51 Appendix 5 Australian Vertebrate Risk Assessment ...... 61 Appendix 6: Summary of consultation with District and Regional Councils, Non- Governmental Organisations and Iwi/Māori ...... 78 Appendix 7 MAF and DOC comments on the application and ERMA New Zealand Agency Response ...... 83 Appendix 8 References contained within this Report ...... 90
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1 Executive Summary
Application NOR08002 seeks approval to import for release by rapid assessment a new livestock animal, Camelus dromedarius (dromedary or Arabian camels)
We have assessed potentially significant adverse effects on the environment, human health and safety Māori culture and traditions, society and communities, and the market economy. From this science assessment we have concluded that biophysically camels do not pose significant risks to the environment, human health and safety, society and communities, and the market economy. However, with regard to Māori culture and traditions we have identified two significant effects namely (a) the potential for camels to adversely effect the relationship of Māori and their culture and traditions (including kaitiakitanga) with their waahi tapu and (b) the potential adverse effects of camels on certain Māori cultural practices. The lack of ways to mitigate these two significant effects may be viewed as being inconsistent with the Treaty of Waitangi principle of active protection.
Assessed against the criteria in section 35 the evidence is firmly suggestive that camels fit the criteria; they are not unwanted organisms as defined under the Biosecurity Act and it is highly improbable that the organism, after release camels could: (a) form self-sustaining populations anywhere in New Zealand, taking into account the ease of eradication; (b) displace or reduce a valued species; (c) cause deterioration of natural habitats; (d) will be disease-causing or be a parasite, or be a vector or reservoir for human, plant, or animal disease; or (e) will have any adverse effects on human health and safety or the environment.
We have concluded it is highly improbable that camels will form a self-sustaining population in New Zealand, the climate and habitat is generally unsuitable and camels are unlikely to exceed the minimum viable population size. We see no significant biophysical effects from any release of camels in New Zealand.
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2 Introduction 2.1 The Environmental Risk Management Authority
2.1.1 The Environmental Risk Management Authority, or ERMA New Zealand, comprises the Authority (a quasi-judicial decision-making body), the Agency (the support organisation for the Authority) and Ngā Kaihautū Tikanga Taiao (a Committee to advise the Authority on Māori issues).
2.2 The Evaluation and Review Report
2.2.1 The Evaluation & Review (E&R) report is written by the Agency to assist and support decision-making by the Authority, pursuant to section 58(1)(a) of the Hazardous Substances and New Organisms (HSNO) Act 1996.
2.2.2 This E&R report consolidates the information provided by the applicant and obtained from other sources into a format and sequence that is consistent with the decision making requirements of the HSNO Act and of the HSNO Methodology Order 1998 (the Methodology).
2.2.3 The E&R Report does not make recommendations, nor direct or prejudge the decision that the Authority might make on the application.
2.3 Rapid assessment for release applications
2.3.1 This application for approval to release a new organism under section 34 and has been assessed under section 35 of the Act ‗rapid assessment of risk for importation of new organisms‘. A rapid assessment application seeks approval to release new organisms into the environment without controls.
2.3.2 The purpose of the application is to ―To import for release by rapid assessment a new livestock animal, Camelus dromedaries (dromedary or Arabian camels)‖. Both before and after the formal receipt of the application we have fielded a number of enquiries regarding camels and the desire to use them in New Zealand for purposes such as filming, trekking and general unspecified uses.
2.4 Application receipt and targeted consultation with Councils and NGO’s and iwi/Māori
Table 1 Application Receipt and targeted consultation
Application Receipt and targeted consultation Date
Time first draft application received. 6 June 2008
Initial assessment of whether rapid assessment could be suitable 26 June 2008
Closed 19 Applicant conducted Māori Consultation nationwide with 137 September
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contacts on the draft application. 2008
85 Regional and District Councils and 26 Non-Government 3 September Agencies were provided an opportunity to comment on the - 3 October application. 2008
5 January Formal receipt of application (under section 34 of the Act) 2009
5 January Application placed under a section 58 waiver to allow a second 2009 – round of Maori consultation Expires 20 March 2009
8 January Agency conducted additional Māori Consultation1 with 160 2009 - 27 contacts nationwide on the draft ecological risk assessment. February 2009
Department of Conservation (DOC) and the Ministry of 20 working Agriculture and Forestry Biosecurity New Zealand (MAF BNZ) days for were consulted on the draft ecological risk assessment and final comment application.
20 March Application placed under a second section 58 waiver to allow 2009 - additional time for the completion of the E&R Report. Expires 31 March 2009
2.5 Targeted Consultation
2.5.1 The Authority is not required by Section 53(1)(b) of the Act to publicly notify applications to be determined under section 35 of the Act. However, the Agency conducted targeted consultation with 85 Regional and District Councils and 26 non- government agencies asking for their comments on the application. In addition the applicant was required to consult nationally with between approximately 140 to 160 iwi/Māori during two separate rounds of consultation in accordance with ERMA New Zealand policy and guidelines. Seven councils (8%) and three NGO‘s (12%) and 36 iwi/Māori (12%) provided us with feedback.
1 The agency conducted this further national iwi/Māori consultation as it became apparent that those consulted by the applicant may not have been aware of the full implications of such an application ie that it was not limited to the importation of eight camels for a trekking tourism venture in the Bay of Plenty. Individual names of respondents are not identified throughout this report as there has been insufficient time to confirm whether they agreed with these details being made publicly available.
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2.5.2 Consultation correspondence is summarised in Appendix 6, and any issues addressed in relevant sections of this E&R report under the title ―issues raised during the consultation process‖. 3 Information review
3.1 Information available
3.1.1 The following documents were available for the evaluation and review of this application by the Agency: Application NOR08002 (Form NO1R), including a summary of the local and national Māori consultation (Appendix 1 of the Application). References provided by the applicant in support of the application. This report and any additional information gathered by ERMA New Zealand. Any correspondence received during consultation with iwi/Māori, Regional and District Councils, and non-government organisations (NGO‘s).
3.1.2 We consider that sufficient information has been provided for the application to be considered. 4 Risk management context
4.1 The Act and the Methodology
4.1.1 The Act and the associated Methodology regulation provide the foundation for the evaluation and review of the application NOR08002.
4.1.2 Section 35(1) of the Act allows the Authority to make a rapid assessment of the adverse effects of importing an organism in accordance with section 35(2) and (3) of the Act. The rapid assessment criteria should be seen as the highest threshold for risk with regard to release applications, exceeding section 36 ‗the minimum standards‘.
4.1.3 The identification and assessment of adverse effects is structured such that the consideration of adverse effects includes discussion of risks and costs. The Methodology defines risk as ―the combination of the magnitude of an adverse effect and the probability of its occurrence‖. Costs are defined in clause 2 of the Methodology as the value of particular effects. However, in most cases these ‗values‘ are not certain and have a likelihood attached to them.
4.2 Identification and assessment
4.2.1 The first step is to identify the effects associated with the organism(s) and to undertake a scoping exercise to determine which effects are potentially significant. Identifying adverse effects requires identifying the sources of effect, the pathways for exposure, and the areas of impact as well as the likelihood and magnitude of effect. We have categorised adverse effects in relation to the following areas of impact: the environment, human health and safety, relationship of Māori to the environment, the market economy, and society and community.
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4.2.2 The second step is to assess the effects that have been identified as being potentially significant. Those effects that are deemed to be not potentially significant are described, but are not assessed in detail.
4.2.3 Assessing effects involves combining the magnitude and likelihood resulting in a level of effect. In this instance the process used a qualitative assessment described in Decision making: A Technical Guide to Identifying, Assessing and Evaluating Risks, costs and Benefits. A summary of this qualitative approach is included in Appendix 1: Decision path and qualitative descriptors.
4.3 Application Type
4.3.1 The applicant has submitted this application under section 34 of the Act and requested that it be considered under section 35 of the Act, which provides for an approval to be obtained through the rapid assessment of adverse effects. The relevant decision path for this consideration and associated explanatory notes can be found in Appendix 1: Decision path and qualitative descriptors, of this report.
4.3.2 Even though the applicant has requested the application is assessed under section 35 of the Act, the discretion to undertake a rapid assessment lies with the Authority. If the Authority decides that this application is not suitable for rapid assessment under section 35 then there are alternative options available: Determining the application via a full assessment under section 38 of the Act – this option is provided for in section 35(4), in circumstances where the Authority considers that the application should not be approved under section 35(2). Determining the application via the conditional release route - this option is provided for in section 38B of the Act which specifies that the Authority may, with the agreement of the applicant, treat an application under section 34 as if it were an application for conditional release.
4.3.3 As the section 35 rapid assessment processes only provides for the assessment of adverse effects, a high degree of certainty about the likelihood of those adverse effects occurring is required, and the Act imposes a high threshold by using the term ―highly improbable‖. One of the advantages of determining the application via a full assessment under section 38 is that it would allow for a comprehensive assessment of both the adverse and the positive effects of the organism, and any positive effects could be weighed against the adverse effects.
4.3.4 The advantages of determining the application via the conditional release route would include:
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The flexibility of a conditional release approval – the Authority can impose as many or as few conditions as required to manage risk. For example, conditions that could be imposed could include, among others, limiting the number of organisms to be imported, or requiring that the organisms imported be sterile. That conditionally released organisms remain new organisms i.e. they are still subject to regulation under the HSNO Act. This means that the Authority retains the ability to reassess conditional release approvals and can revoke or widen them as required, for example if new information came to light about the effects of the organism, or alternative uses are envisaged. The benefits that the applicant has identified would be able to be assessed and used to weigh against any adverse effects that result. Consistency with the precautionary approach required by section 7 of the Act. For example, to mitigate any uncertainty about the likelihood of adverse effects occurring conditions could be set requiring that potential adverse effects be monitored by the applicant.
4.3.5 The applicant, while acknowledging that there would be no restrictions if the application is approved by rapid assessment, has described in their application a very specific use for these organisms (namely tourist trekking in the Bay of Plenty). Therefore, inviting the applicant to seek a conditional release approval is an option open to the Authority if the application is not considered under section 35.
4.3.6 As this is an application in which there is likely to be significant public interest2, a further advantage of both a full assessment and conditional release is that the application would need to be fully publicly notified. This consultation could provide information about the effects of the organism not currently available to the Authority
Issues raised during the consultation process regarding application type
4.3.7 Some stakeholders do not consider that a rapid assessment of risk for the importation of a new organism (section 35) is appropriate for camels. For example ―Forest & Bird is very concerned that this application can be considered under the rapid assessment for release provisions of the act, which allows the application not to be publicly notified, and has no requirement to impose controls on the organism‖. Another example is from a respondent who said ―…While the trail [of rapid assessment] is expedient for the applicant it does not allow for robust public participation or rigorous debate through the larger public process…‖. A different respondent stated ―Our role as kaitiaki to the environment means we need to take precaution with the importation of new species in to New Zealand. Given the open ended nature of this application (not purpose limited) we must therefore oppose [this application]‖. Another respondent said ―If the application had been for two camel only, with the door closed after that, maybe we could have looked at the application differently, but as granting approval opens the door, our answer is an irrevocable and resounding NO‖. Yet another respondent felt that every potential new organism introduction to New Zealand should be case by case. While they did not object to the importation of 8 camels that cannot breed in New Zealand, they did ―feel uncomfortable with and
2 The level of interest resulting from consultation undertaken by the applicant and the Agency is discussed in section 2.5 and Appendix 6. This consultation should not be considered to be full public notification.
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object to allowing one application which then grants the full, unconditional release of camels which will allow anyone, anywhere in Aotearoa, to import, breed or use camels, subject to the same restrictions as any other livestock animal currently in New Zealand‖
4.3.8 ERMA New Zealand notes that the applicant has requested this application to be considered under the provisions for a release by rapid assessment. The Authority will need to decide whether these provisions are met. If such provisions are met then the application can be considered under section 35 of the Act. If the provisions are not met then the application will need to be declined or not approved. In addition although full public consultation has not occurred a number of stakeholders have been given a chance to contribute to the process around this application (see 2.5 ‗Targeted Consultation‘).
4.3.9 One stakeholder argues that for a number of reasons, which are addressed under the relevant sections within this report, ―the importation and general release [application] does not meet the requirements of the Act or the Methodology Order and fails to satisfy the tests in Part 2 matters… Māori and the communities do not benefit from this application. That the potential risks outweigh any benefits. The application has failed to meet the tests laid out in sec 35 and sec 36… that the application falls outside the boundaries of the Act for approval and if approved it would set a precedent for open importation of camels with the potential to cause significant adverse effects‖.
4.4 Section 35 Criteria
4.4.1 In assessing the effects of the organism(s) the Act requires that the Authority is satisfied that it is highly improbable that the organism, after release: could form self-sustaining populations anywhere in New Zealand, taking into account the ease of eradication (section 35(b)(i)); or could displace or reduce a valued species (section 35(b)(ii)); or could cause deterioration of natural habitats (section 35(b)(iii)); or will be disease-causing or be a parasite, or be a vector or reservoir for human, plant or animal disease (section 35(b)(iv)); or will have any adverse effects on human health and safety or the environment (section 35(b)(v)). 5 Associated approvals
5.1.1 We note that in addition to a rapid assessment approval under the Act, camels will require the development of an Import Health Standard (IHS) under the Biosecurity Act 1993, before any importation could occur. Such an IHS would be designed to prevent any associated organisms (for example diseases and pathogens) from entering the country. Any camels imported would need to meet all of the quarantine requirements stipulated in the IHS before biosecurity clearance will be given by MAF BNZ.
5.1.2 Importers of camels would also be required to ensure that the activity for which they intend to use the camels for meets any other legal requirements. If intended activity is on public land administered by the (DOC) then any activity will require DOC
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concession/approval. Where activities are to seeking to be conducted on private or Māori owned land they will need the consent of the landowner.
5.1.3 The use of any animal, including camels, must be compliant with the Animal Welfare Act. 6 Organism Description
6.1 Organisms applied for
6.1.1 The applicant wishes to import Camelus dromedarius (dromedary or Arabian camels).
6.1.2 The taxonomic classification of C. dromedarius is: Class: Mammal Order: Artiodactyla Family: Camelidae Genus: Camelus Species: dromedarius Common name: dromedary camel, Arabian camel
6.1.3 Camels belong to the family Camelidae, of which there are six extant species, including Bactrian camels (Camelus bactrianus) (two humped), llama (Lama glama), alpaca (Lama pacos) guanaco (Lama guanaco) and vicugna (Vicugna vicugna) (Nowak, 1991). Llama and alpaca have been present in New Zealand for over a hundred years and alpaca are extensively farmed.
6.1.4 A full organism description is provided in Appendix 3.
6.2 Inseparable and associated organisms
6.2.1 The project team notes that as with all animal importation, any pest and diseases will be assessed by MAF BNZ in the development of an IHS under the Biosecurity Act. The IHS will stipulate the quarantine requirements to be met before biosecurity clearance will be given. Until biosecurity clearance is given, release from quarantine cannot be authorised.
6.2.2 Development of a IHS has several phases: work planning and scoping; gathering additional information on risks or risk mitigation techniques; undertaking a import risk analysis; development of the import health standard; and implementation and ongoing management of the standard after it is implemented. The risk analysis is generally the most resource intensive phase of development (Butcher, 2008). Submissions can be made on both the draft import risk analysis and the draft IHS are available for consultation.
6.2.3 Sources of good quality internationally accepted information used in the development of an IHS includes internationally agreed standards such as in the OIE (Organisation International des Epizooties, World Animal Health Organisation), animal health codes and testing manuals, International Standards for Phytosanitary Measures (ISPMs),
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published risk analyses and trading protocols from a country that New Zealand routinely trades with, published reference texts and peer reviewed scientific journals and science conducted by reputable institutions (Butcher, 2008).
Table 2: Import health standard development and management cycle
Information Risk analysis Import health Ongoing management standard
If required . identify . draft import . implement standard hazards health standard . manage and clear . surveys . assess risks . consult imports . research . evaluate nationally and . monitor in case . trials management internationally standard needs . may take option/s . issue import revision more than . issue risk health standard . submit request for one year analysis . implement new import health import health standard work standard
Issues raised during the consultation process regarding the organism and biosecurity
6.2.4 A number of parties have concerns regarding camels being vectors of disease, and a threat to both the agricultural industry (Federated Farmers, Greater Wellington (GW), Environment Waikato (EW)) and the llama and alpaca industry and the risk of importing hitchhiker organism (Federated Farmers).
6.2.5 Concerns or recommendations raised include: ―There needs to be a thorough, expert assessment of the potential disease risk to cattle, sheep, deer, etc., and humans from someone other than the applicant.‖ EW
6.2.6 ―There seems to be a greater potential risk to New Zealand‘s animal husbandry industries [than to biodiversity] from camel-related diseases or parasites. For example, could camels carry any viruses in their blood that could be spread by insect vectors to other animals or humans?‖ EW.
6.2.7 Federated Farmers overall recommendation on the import of camels into New Zealand is that ―a proper assessment is carried out on this proposal to ensure that no ‗unknown‘ or harmful risks are introduced to the New Zealand economy or environment from the imported camels‖.
6.2.8 The Hawke‘s Bay Regional Council (HBRC) believed that while a camel IHS is required before importation, that MAF BNZ should adapt the llama and alpaca IHS currently in place: ―Adapt the import health standard for camels to that of alpaca and llamas that is currently used and possibly include: a pre-export isolation period in Australia and a 6 month isolation period in place in New Zealand before release to the owner...for the purposes of vaccination and testing that these animals are free from all meat export disease and parasites that may impact with this country‘s meat export‖ (HBRC).
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6.2.9 Federated Farmers are of the opposite view, in that ―it is important that camels are treated as a stand alone case and not ‗ticked off‘ as okay due to being from the same family i.e. Camelidae‖.
6.2.10 Greater Wellington regional council raised some concerns in regards to Tuberculosis (Tb) and ensuring camels do not bring any unwanted seeds, organisms or disease into the country with their import. ―Camels are a vector of Bovine Tuberculosis (Bovine Tb), and can contract brucellosis, both known diseases in New Zealand domestic stock. Camels have the potential to threaten the extensive Animal Health Board Bovine Tb vector control programme.‖ ―Will camels be subject to movement restrictions and testing, similar to domestic cattle and deer?‖ ―Are there veterinarians capable of treating camels in New Zealand for illness and disease?‖ ―Will imported camels come from domestic or feral stock?‖ ―What testing and quarantine measures will apply to any imported camels?‖
6.2.11 Greater Wellington also stated: ―Any species imported into New Zealand has the potential to bring pest plants or organism into the country. Seeds, organisms, disease and viruses have the potential to travel on the skin, in the feet or in the gut or bodily fluids of any imported animal‖.
6.2.12 The Marlborough District Council stated that they would have no concerns about the import of camels into New Zealand under this application if there was appropriate quarantine controls in place: ―Staff of this council do not have an issue with this import given the border controls and pre-testing and satisfaction required by all parties that all risks are eliminated or mitigated‖.
6.2.13 Federated Farmers are concerned that ―camels are hairy animals and ‗hitchhiker‘ type organisms could be inadvertently imported without sufficient controls‖. They go on to state that ―It is unclear how this type of risk on the imported camels will be approached‖.
6.2.14 We agree that there are many concerns in regards to importing new organisms into New Zealand. However, such concerns and issues are managed under the Biosecurity Act, and camels will not be imported into New Zealand without the development of an IHS for camels that contains a thorough risk analysis and import regime, as per table two. However, the spread of disease and hitch-hiker organisms (ie seeds) within New Zealand are addressed in this E&R.
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7 Likelihood of forming a self-sustaining population anywhere in New Zealand, taking into ease the chance of eradication
7.1 Background for the ability to form an self-sustaining population and the ease of eradication
7.1.1 In accordance with section 35 and clause 10(e) of the Methodology, we have evaluated the ability of camels to form a self-sustaining population and the ease of eradication of such populations.
7.2 Ability to form an self-sustaining population
7.2.1 We consider that there are several contributing factors relevant to determining whether camels will form a self-sustaining population. For example, the ability of camels to adapt to New Zealand‘s climate; the physical space required for a self-sustaining population to form; initial numbers of camels required to form a self-sustaining population; slow reproductive rate and the ability to find a suitable food source. We consider it highly improbable a self-sustaining population could form.
7.2.2 Our assessment of the ability of camels to form a self-sustaining population is contained in Appendix 4. Our assessment suggests that there are few if any locations in New Zealand suitable for camels and these locations are restricted in size. It is unlikely camels will be able to exceed the minimum viable population size for a self- sustaining population to form. If a self-sustaining population were to occur it would be restricted to very specific areas of New Zealand. Again for the full explanation and analysis of these factors please refer to Appendix 4.
7.2.3 In Appendix 5 a Vertebrate Risk Assessment is made using a slightly modified Australian methodology. Our assessment concluded that camels were ―not dangerous‖ with regard to public safety, and that they had a ―low establishment risk‖. They are scored as having a ―moderate pest risk‖ following establishment (the risk assessment assumes they can establish). For more details see Appendix 5.
Issues raised during the consultation process regarding establishment of camels
7.2.4 Forest and Bird believe that ―New Zealand has large areas of semi arid habitat, particularly on the inland east coast of both main islands....and that camels ―natural preferred habitats are actually low rainfall, semi arid areas‖. In addition, Forest and Bird state that ―In Australia camels started with relatively small numbers in the wild but have now built up to over a million and have an annual population increase of nearly 10%‖.
7.2.5 We have reviewed the literature and note that between 5,000 - 10 000 camels were released into the desert after their use as transport was no longer required in Australia (Edwards et al, 2008). This large number of animals is one of the major contributors to camels success at forming self-sustaining population in Australia, coupled with the climate match from areas in which they evolved.
7.2.6 One rūnanga believes that a precautionary approach should be taken when considering the risk of establishment; ―While the likelihood of the camels establishing a feral
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population is considered low (as per the Camel application Draft Environmental Risk Assessment), we believe that a precautionary approach is necessary. The impacts of introduced species that are now established in New Zealand were not perceived as a threat to the environment upon introduction; however many of these species have since attained pest status and caused significant adverse effects.‖ We note that such an approach is built into the Act requiring decision makers amongst others to take a precautionary approach when ―managing adverse effects where there is scientific and technical uncertainty about those effects‖ (Section 7).
7.2.7 Further to this the rūnanga raised concerns that camels may suffer welfare issues in New Zealand. ―We are not convinced that the camels can transfer to New Zealand without significant animal welfare issues. For example, ground conditions in New Zealand are quite moist compared to a camel‘s natural environment and the animals may experience foot rot. Also, we believe that our environment does not support naturally occurring food sources for the animals which may lead to health problems. Therefore Te Rūnanga questions the suitability of these animals to this land.‖
7.2.8 Another respondent made a similar statement – ―it is clear that the camels will be imported into an environment that is totally out of their normal habit. It is clear that Aotearoa is an unsuitable environment for the importation of camels…Wet or damp areas have the potential to cause ill health effects to the camel‘s feet. Also containing an animal that traditionally roams large areas is akin to bad practice. While there are examples of horse and cows that are domesticated, there is no evidence put forward to demonstrate the camels behaviour in a paddock type containment or the type of suffering that may take place with changes to diet or stress. Sheep or cattle in small farm blocks have a tendency to go lame. The main causes are that animals on small blocks or paddocks do not have the chance to roam larger distances to browse or forage‖.
7.2.9 We agree that without human intervention and management camels are not suitable to the New Zealand environment, hence why it would be difficult for a self-sustaining population to form. We note that camels are like any other livestock animal, (ie horses, cattle and sheep), and that it is not lawful to simply release or walk away from such animals and action can be taken under the Animal Welfare Act, the Biosecurity Act and the Conservation Act. Any human management of camels would need to meet the requirements of the Animal Welfare Act which places emphasis on providing: (a) proper and sufficient food and water; (b) adequate shelter; (c) the opportunity to display normal patterns of behaviour; (d) physical handling in a way which minimises the likelihood of unreasonable or unnecessary pain or distress; and (e) protection from, and rapid diagnosis of, any significant injury or disease.
7.2.10 A number of stakeholders would prefer any imported camels to be sterilised and for numbers to remain at eight (the number that the applicant requested to start their trekking business with), in order reduce the risk of forming self-sustaining populations:
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―Any animals approved for entry to New Zealand should be sterilised prior to shipment. This would eliminate the low possibility of self-sustaining populations being established accidentally‖ (EW). ―Approval should apply only to these eight animals. Their presence in New Zealand should be evaluated for a number of years before further applications will be considered‖ (EW). ―All animals should be sterile and no breeding programme be set in place until all assurances can be met that the activity that these animals are being brought in for is a long term viable venture operation. Given this animal‘s life span (30 years)‖ (HBRC). ―I spoke with the first applicant, and he agreed with me to include in his application, the sterilisation of all imported camels. This simple ‗requirement‘ will address most of my concerns to date‖ (respondent). ―Te Rūnanga acknowledges the applicants entrepreneurial thinking and does not object to the importation of 8 camels that cannot breed into New Zealand. We do however, feel uncomfortable with and object to allowing one application which then grants the full, unconditional release of camels which will allow anyone, anywhere in Aotearoa, to import, breed or use camels, subject to the same restrictions as any other livestock animal currently in New Zealand.‖ (respondent).
7.2.11 As this application is for the rapid assessment and is determined under section 35 of the Act no controls are able to be imposed. If a self-sustaining population is likely to form taking into the ease of eradication then this application must be declined.
7.2.12 ―If the application is approved, it should include a clause about what happens to the animals if the trekking business does not succeed. Are they returned to Australia? Are they destroyed? The objective would be to ensure that they are not just turned loose because someone cannot afford to feed them anymore‖ (EW).
7.2.13 We note that camels are like any other livestock animal, ie horses, cattle and sheep, and that it is not lawful to simply release or walk away from such animals. For example under the Animal Welfare Act it is an offense if ―a person commits an offence who, being the owner of, or person in charge of, an animal, without reasonable excuse, deserts the animal in circumstances in which no provision is made to meet its physical, health, and behavioural needs‖. Further to this it must be acknowledged that while there are legal provisions against the release of animals, people have and do release them and our assessment is based on such events occurring.
7.2.14 One respondent said that the draft ecological risk assessment sent out during iwi/Māori consultation ―has made great play on the issues of the probability of the camels creating self sustaining populations. While [we] may agree with parts of the assessment [we] do not agree with the key focus [on section 35 parameters]…The report has erred in making no assessment of the area or conditions on the use of the camels in the applicants chosen activity which is trekking. There has been no risk assessment of any of the conditions that is likely to be presented in the management of camels in a domestic or commercial state. [We] are aware that electric fencing and deer style fencing is available but contend that as the camels are large, fencing is going to be a consideration. [We] argue that there has not been an assessment undertaken on the domestication of the camel or its likelihood to quickly spread
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throughout Aotearoa with current farm style breeding practices. Nor any research of the damage from camels that pose risks as single or small scale herds‖.
7.2.15 We need to assess this application with regard to section 35 of the Act which is an application for full release. The report has not specifically assessed the proposed camel trekking activity as the effects and impacts of this activity are a subset of our assessment of environmental effects (see 8.2) and as a land-use activity are best assessed under different legislation. We are unsure of the relevance of fencing. This assessment is for a release application and therefore containment is not applicable. We have not assessed the effects of camels as a domestic herd as this would be as a result of human activity not of the characteristics of the organism. However, should any camels escape from such a farm our assessment contained in this report is that it is highly improbable that a self-sustaining population will form.
Summary and conclusion ability to form self-sustaining population
7.2.16 The ability of the organisms to form a self-sustaining population(s) is reliant on camels‘ ability to find suitable space, and remain undetected long enough to form a breeding population. In addition, there are many factors that would make the formation of a self-sustaining population difficult for camels. This includes poor climate matching for the majority of New Zealand (Appendix 4 and Appendix 5), a less than optimum food source, the lack of ability to roam large distances freely and topography (ie, lack of abundant sand dune areas and avoidance of rocky or forested areas). We concluded that it is highly improbable that camels could establish a self- sustaining population in New Zealand.
7.3 Ease of Eradication
7.3.1 Camels are able to be easily located. They are large and distinctive animals (1.8-2.3 m shoulder height), both larger than cattle (up to 1.3 m) and horses (up to 1.85 m). In addition to their size they have a distinctive body shape making their appearance immediately recognizable. They prefer open country and there is no evidence to suggest that they will retreat into the forest like deer. For example Edwards et al (2008) comment that in Australia camels prefer open bush and only calving females enter dense bush for protection. This preference coupled with their distinctive appearance makes them relatively easy to locate, especially in comparison to other large feral animals in New Zealand.
7.3.2 We consider that not only would camels be easy to locate but easily eradicated. There is only a small amount of area potentially suitable for them in New Zealand and this is restricted to a small number of locations. Therefore detection of camels and either their recapture or eradication is not predicted to be difficult.
Issues raised during the consultation process regarding eradication of camels
7.3.3 Both Greater Wellington and Environment Waikato agree that it is unlikely that camels will form self-sustaining populations in New Zealand. Environment Waikato state that ―Any escaped animals would be relatively easy to re-capture or kill. Given that, there does not seem any large scale risk to native plant biodiversity.‖
7.3.4 One council expressed a concern about the mustering of camels in the wild:
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―Is there an established means of capturing or mustering camels?‖ (GW).
7.3.5 The Australian Primary Industries Standing Committee Model Code of Practice for the Welfare of Animals (PISC, 2006), proven mustering techniques of camels include trapping around water sources, by using helicopters, motorbikes or portable yards, by using specifically trained horses or by combination of all the above. Camels do not need to be approached as closely as other animals to get them to move in the desired direction. Camels can also be excluded from areas of high conservation value by strong visible fences (Gallacher and Hill, 2006).
7.3.6 The Department of Conservation has noted that social pressure may have an impact on the ease of eradicating camels from New Zealand. For example they point to Kaimanawa horses as a case where social pressure led to a lower number of animals being eradicated than desirable from an environmental perspective. Camels have a long history of domestication (4000BC)(Long, 2003) and have been a valued by humans for a long time. For example the Afar in Ethiopia may value their camels more than their sons, the Tuaregs of the Sahara use the camel as a symbol of love and many Arabs hold that only the camel knows the hundredth name of God (Köhler- Rollefson, 1993). They are also used widely as pets. Therefore we anticipate that it is likely some New Zealanders will form an affinity with camels. We acknowledge that this public support may lower the ease of eradication. Despite all three examples attracting public support, all attempts at control have been successful to some extent. Kaimanawa horses today are being managed sustainably; attempts at culling the goats from Arapawa Island has begun (DOC, 2008) and the Enderby Island cattle have been eradicated in the wild. These examples involved involve isolated areas that people rarely venture into and hence the damage they do to the environment remains unseen and unrecognised as a problem. In the coastal environment, where camels are most likely to establish, any damage should it happen would be very visible to the public and presumably encourage public support for their removal. In summary we note there is some uncertainty as to the influence of social pressure and that we are unable to accurately predict this and assess the likelihood it could have on ease of eradication.
7.3.7 One respondent has questioned the ability of DOC to eradicate camels ―Mention has been made of the horses in Aupouri area. While there are methods to control the horses it has still become an issue and...[we]...note that only 11 horses were culled by DOC sharpshooters in two years. To date DOC has not achieved eradication of any of the species that they have attempted to do...[we] wish to remind the Authority it is not the size of the animal but the instincts for survival. In addition it is pertinent to mention elephants in the jungle. Elephants are a much larger species and in the jungle or bush are very quiet and very difficult to find if they choose not to be seen or heard.‖
7.3.8 We agree that large animals are not necessarily easy to eradicate if they are capable of hiding in dense, large scale environments such as the jungle. However we note that the (dense) New Zealand bush is not a suitable environment for camels and they will be limited to dry, sandy and open environments. As such their large and distinctive appearance coupled with the limited areas of suitable habitat will make them both extremely conspicuous and relatively simple to eradicate. We also note that the Kaimanawa horses provide a useful example of a large animal located in an open environment from which they have been successfully managed by mustering or shooting and, that if desired, eradication could be achieved.
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Summary and conclusion ease of eradication
7.3.9 We conclude that any eradication attempt will not be difficult and that in the highly improbable event that camels form a self-sustaining population in New Zealand that such populations could be eradicated. 8 Identification and assessment of potentially significant adverse effects (risks and costs)
8.1.1 The adverse effects assessed are those identified as potentially significant, having regard for those matters set out in clauses 9 and 10 of the Methodology.
8.1.2 In accordance with clause 9(c) of the Methodology, the project team, in association with the applicant, has categorised potential adverse effects into those effecting the environment, human health and safety, Māori culture and traditions, society and communities, and the market economy.
8.1.3 These adverse effects have been considered in terms of the requirements of clauses 12, 13, and 14 of the Methodology, including the probability of occurrence and the magnitude of adverse effects, whether or not they are monetary, the distribution of costs over time, space and groups in the community. Risk characteristics are considered in terms of clause 33 of the Methodology. Risks are assessed in terms of the likelihood of the effect occurring and the magnitude of the effect. Appendix 1 of this report lists the qualitative scale used to describe the probability of occurrence and the magnitude of effects for this application. The degree of uncertainty attached to evidence is taken into account, as required under clauses 25, 29 and 30 of the Methodology.
8.1.4 The applicant and the project team have identified and evaluated the following potential adverse effects associated with the import into containment of these organisms.
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ENVIRONMENT
Potentially Agency Cross Effects / Issues significant Assessment reference
Adverse effects Detrimental effect on native vegetation through Highly grazing and trampling Improbable Detrimental effect on erosion of sand dunes Highly Spread weed seeds in New Zealand Improbable Detrimental effect on ground nesting native Highly birds by trampling Improbable 8.2 Hybridise with llama and alpaca in New Highly Zealand Improbable Highly Improbable
HUMAN HEALTH and SAFETY
Potentially Agency Cross Effects / Issues significant Assessment reference
Adverse effects Vectors of disease Highly Harm through a physical interaction Improbable 8.3 Highly Improbable
RELATIONSHIP OF MĀORI TO THE ENVIRONMENT
Potentially Agency Cross Effects / Issues significant Assessment reference Effects of camels on the relationship of Māori and their culture and traditions (including Significant Adverse kaitiakitanga) with their waahi tapu 8.4 effects Significant Potential adverse effects of camels on certain Māori cultural practices
TREATY OF WAITANGI
Potentially Agency Cross Effects / Issues significant Assessment reference
Adverse Inconsistency with the Treaty of Waitangi May be 8.5 effects principle of active protection inconsistent
SOCIETY AND COMMUNITY
Potentially Agency Cross Effects / Issues significant Assessment reference
Adverse None identified - 8.6 effects
THE MARKET ECONOMY
Potentially Agency Cross Effects / Issues significant Assessment reference
Adverse None identified - 8.7 effects
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8.2 The Environment
8.2.1 We assessed the potential for camels to cause adverse effects on the environment and identified the following pathways through which this could happen: grazing and trampling of native vegetation; erosion of sand dunes; dispersal of weed seeds; and trampling of native bird nesting grounds.
Potential for the imported new organisms to have a detrimental effect on native vegetation of New Zealand through grazing and trampling
Grazing
8.2.2 Camels are known to eat a wide variety of food including grasses, herbs, as well as browsing fruits, leaves and stems from shrubs and trees (Edwards et al, 2008). They have a distinct preference for succulent or semi-succulent plant species of high moisture and salt content (Dorges and Heucke, 1995). In addition, they are known to eat very spiny plants and are tolerant of oxalates (a derivative of a poisonous chemical found in some plants such as rhubarb leaves). They also are said to need up to eight times as much salt as other animals, so require halophytic (plants adapted to living in a salty soil or a saline environment) species in their diet (Kohler-Röllefson, 2005; Nowak, 1991).
8.2.3 In contrast to goats, sheep, cattle, deer, and horses, camels tend to browse without stripping the individual plants bare, digging up the roots, or completely clearing grass from the land (Unklesbay, 1992). Camels browse lightly on many different species, rather than browsing enough to kill individual plants. This is because camels are known to browse on the move, rather than feeding intensively in any one area (Dorges and Heucke, 1995, Siebert and Newman, 1989).
8.2.4 In support of this theory, studies in Australia have demonstrated that it is only when camels reach densities of more than two camels per km2, that they have an impact on desert vegetation, (James et al, 1999). This impact is more pronounced in drought conditions when camels congregate around water sources. In Australia, camels at these densities can severely defoliate and suppress the recruitment of some shrub and tree species (Dorges and Heucke, 2003; Edwards et al, 2008). At such densities this may result in the localised extinction of some plant species.
Trampling
8.2.5 Camels cause less damage through trampling than other wild animals in Australia such as horses, donkeys and goats (Dorges and Heucke, 2003). This is due to their large padded and leathery feet, which have a large supporting surface and thus a reduction of weight per cm2 (Dorges and Heucke, 2003).
Table 4: Comparative mass, foot area and static pressure of camels, humans and grazing mammals (from Greenwood and McKenzie, 2001).
Organisms Mass (kg) Total Foot Area (cm2) Static Pressure (kPa)
Camels 450-650 1644 27-40
Humans 46-75 45-163 41-108
Sheep 40-55 63-84 48-83
Horses 400-700 736 54-95
Goats 40 55 60-73
Cattle 306-612 264-460 98-192
8.2.6 In comparison, horses have long been known to cause damage to vegetation through trampling. Overseas studies show that horses have a relatively high potential for doing environmental damage to conservation tracks due to their large weight and small area in contact with the ground (Landsberg et al, 2001). Studies on the impact of horses have been undertaken in mountainous areas, showing that the greatest impacts of trampling by horses generally occur on previously untrodden mountainous areas, with less impact on dry grasslands (Landsberg et al, 2001). Studies have also shown that the wettest parts of tracks are the most vulnerable to trampling by horses (Landsberg et al, 2001). In the Kaimanawa Ranges flush zones and bogs are both highly degraded by horse trampling and grazing regardless of variations of horse density (Rogers, 1991).
8.2.7 We have concluded that damage camels may cause to vegetation through trampling is likely to be less than other wild animals in New Zealand.
Scale
8.2.8 It is important to note that whether or not camels could have a significant detrimental effect on the environment of New Zealand is dependent on scale. One animal in an environmentally sensitive area could have major localised effects. This may be due to small populations of rare plant species being more vulnerable to extinction through impacts such as habitat modification or loss (Rogers, 1991). Studies of wild horse impact in the Kaimanawa range for example, have shown that the damage caused by horses to some plant species found in one or two sites only, may contribute to transferring their status from rare to vulnerable (Rogers, 1991). In contrast a significant effect on a common species in a localised area may be considered insignificant at the national level.
Issues raised during the consultation period regarding effects on native vegetation
8.2.9 Environment Waikato state ―Given that [escaped animals would be relatively easy to re-capture or kill], there does not seem any large scale risk to native plant biodiversity‖.
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8.2.10 One stakeholder stated that ―[Camels] advantage over horses (apart from novelty) is that their leathery feet would not compress tree roots as hooves do, but as such tall animals would be hopeless in the bush anyway this is hardly relevant.‖ (Environmental Futures Incorporated). They also continue ―For open country trekking the point that the animal‘s feet are less damaging than hooves, is probably not such a major mitigating feature since this is New Zealand‘s open country [which] is quite unlike Australia with its fragile desert vegetation‖. We agree that New Zealand‘s open country is very different from Australian open country but believe that camel footprints are much less damaging than horse hooves with regard to trampling of flora. This is particularly the case in fragile areas which do include coastal flora, for example native glassworts and ice plants will be far more heavily damaged by a small sharp hoof than a large leathery foot.
8.2.11 Some stakeholders believed that camels could damage the environment in a manner such as wild horses have done in the past.
8.2.12 One Māori respondent argues ―there has been no research put forward on effects of camels in landscapes that are prevalent in Aotearoa, just assumptions. Certainly no robust scientific study has been put forward on camels in the wetter margins of Australian landscapes or anywhere else‖.
8.2.13 This review report provides evidence of the effects of camels in New Zealand. No information has been reviewed with regard to camels in wetter margins of Australia‘s landscape likely because there are no known or at least significant wild populations of camels established in these areas (see Appendix 4).
8.2.14 ―Potentially then we can have the wild camel scenario that is akin to the wild horse problems we experience/have here in Te Hiku O Te Ika where huge damage by horses on flora and environment for both fauna and flora is devastated or destroyed to a point where extreme management strategies are required to reinstate these back into the environment are called‖ (respondent).
8.2.15 There is also a very strong concern from iwi/Māori that camels could potentially browse on pingao on the sand dunes. ‗This plant serves two important roles as a sand dune stabiliser and natural resource or taonga used for raranga/tukutuku3‘ (respondent).
8.2.16 As camels are generalist feeders that browse lightly on many different species we are unable to conclusively rule in or out whether or not they will browse pingao. Highly localised damage is possible but based on the inability of camels to form a self- sustaining population any damage would not be significant on a national scale.
8.2.17 Another respondent argues that ―we have a lot of bush / natural native forest, flora & fauna in the Northland and we would not want to put that at risk. We have problems with horses roaming these forests and contamination occurs via excrement and hoof trampling. Might camels pose a similar threat of endangering our native plant & animal species already under threat from possums etc.‖
3 Patterned panelling (using woven pingao) found inside Whare Tipuna.
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8.2.18 We have both assessed the potential for the imported new organisms to form a self- sustaining population (similar to a wild camel scenario) and have also assessed the detrimental effect on native vegetation of New Zealand through grazing and trampling. We have concluded that New Zealand and New Zealand forests in particular are not suitable for a self-sustaining population to form and certainly not to the extent that wild horses have done in New Zealand, however we do recognise the potential that highly localised degradation of flora could occur.
8.2.19 One respondent has identified that they believe trampling and browsing will have a large impact on the environment once people start raising domestic camels ―Once in general release it is possible that the novelty factor will kick in and a ready market for camels will take place much like several species such as Scottish Highland cattle which is now littered throughout the country. There is a case to make of domestic camels creating adverse risks in farm landscapes in several matters. Matters such as bush blocks, wetland areas and coastal margins are all at risk from tramping, or browsing. All have the potential to have at risk species within them. It is also clear from the assessment that the normal grazing habits of the camel is not the general conditions found in Aotearoa. All animals are adaptive to change and will change their grazing habits to suit the environment they are in. It is a far stretch of the imagination to think that one single applicant is going to feed the camel its preferred diet. in addition it is also stretching the imagination to think in general release that others are going to obtain the ideal food of the camels. That leaves the animal and owners to allow the camel to adapt to general conditions found in the farm and bush landscape. There is no risk assessment of what food that adapted camel will graze on nor if they will graze on at risk plants or bush‖.
8.2.20 Camels are not suited to bush blocks and wetland areas. Should camels be released in a coastal habitat localised damage could occur. However the evidence suggests that any damage will not be sustained as camels are highly unlikely to form a self- sustaining population taking into account the ease of eradication. We are unaware of any research which suggests camels are capable of massive switches in diet being proposed. An example of this is the camels requirements for salt which could be as high as 6-8 times higher than other livestock (it has been reported some camels will consume up to 120g of salt per day if it is made freely available) (Faird, 1989). Such salt requirements could not be met through the consumption of plants in the New Zealand bush or farmscape and salt deficiency in camels has been associated with the disorder cutaneous necrosis, cramps and serious negative effects on the nervous system (Faird, 1989). This is clearly a food requirement camels are not able to adapt to not having.
In summary
8.2.21 Therefore, taking into account the lack of suitable habitat, the ease of eradication or recapture, and the low propagule pressure for establishment, we consider it is highly improbable that New Zealand would not have a camel density of greater than two camels per km2. As such, it is highly improbable that camels would have a large scale detrimental effect on the environment of New Zealand through trampling or grazing.
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Potential for camels to have a detrimental effect on erosion of sand dunes and coastal areas
8.2.22 We considered the potential effect camels may have on the erosion of sand dunes in New Zealand. Camels are not known to be serious agents of erosion, with their soft pads causing less damage than the sharp hooves of other herbivores (Dorges and Heucke, 1995; Köhler-Rollefson, 2005; Unklesbay, 2005). However, they have been known to cause some erosion, for example by creating erosion channels in desert sand dunes in Australia (Edwards et al, 2008). Although New Zealand is devoid of large and extensive desert sand dunes similar to those of interior Australia, camels may have a potential impact on coastal sand dunes.
8.2.23 Most of New Zealand‘s dune systems have been modified to some degree by human activity or introduced plants (Department of Conservation, 2006). This has included fires destroying native sand-binding communities, and farm animals grazing extensive areas. Introduced plants such as marram grass (Ammophila arenaria), lupins (Lupinus arboreus) and gorse (Ulex europaeus) now replace many of the native sand-binding plants (Department of Conservation, 2006). In addition, four-wheel drive vehicles, motorbikes and heavy pedestrian traffic on dune systems have also caused rapid erosion (Department of Conservation, 2006).
8.2.24 The addition of camels to these already modified systems means it is possible that camels will have a detrimental effect on coastal areas. Any such effect is likely to be localised, small in scale and reversible. However, should camels replace animals that are currently used on beaches such as horses then it is likely that camels would have a beneficial effect as their soft pads are less damaging than hooves.
8.2.25 Human use of coastal areas of importance are protected from potentially damaging land use by either the Department of Conservation, local authorities under the Resource Management Act (RMA) or local government bylaws. Opotiki District Council for example, under section 8.1 of their Beach Bylaws 2008, state that a person shall not ride or lead a horse or other animal on any designated conservation area, coastal vegetation or rehabilitation area, or on sand dunes or let that animal wander onto such areas in an uncontrolled manner (Opotiki District Council, 2008). We have not assessed the effects of camels being used on beaches by people as this would be a result of human activity and not of the characteristics of the organism.
Issues raised during the consultation period regarding erosion
8.2.26 Environment Bay of Plenty (EBOP), raised concerns that camels would effectively be entering an unregulated environment because their Regional Plans had not anticipated camels entering the coastal environment.
8.2.27 We agree that because local authorities have different bylaws and regulations, that not all regions would have bylaws in place restricting the movement of animals, and therefore camels, similar to the Opotiki District Council bylaw. However that does not mean that local authorities could not develop such bylaws if they were needed.
8.2.28 In addition, EPOB raised the issue of a conflict of use of the coastal environment: ―There may be a conflict of use in the Coastal Environment (or other environments which treks are intended to be operated in) and there will be insufficient time to make
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changes to our plans (policies and rules) to manage the activity in accordance with the wishes of the community‖.
8.2.29 A significant period of time will pass between any decision on this application and the first camels to go through the quarantine procedures and gain access to New Zealand. This will give councils time to adjust plans, policies and rules to take account of any change. In addition this does not prevent local authorities managing a conflict of land use in the normal way conflicts are currently managed.
8.2.30 One respondent argues that while they recognise that coastal dune systems have become modified and that four-wheel drive vehicles, motorbikes and heavy pedestrian traffic on dune systems have also caused rapid erosion, they ―completely disagree with the rational that as modified landscapes it is now acceptable to allow more modification by an alien species to this country, albeit with lighter footprints and roaming grazing habits. [We] also challenge the comments that DoC or local government manage the coastal areas effectively. In our area DoC and local government have left the policing and management of the coastal areas and dunes to local people‖. A similar view was expressed by another respondent: ―The result of large numbers of camel in rural and coastal landscapes could produce cumulative risks over a period of time and therefore are unacceptable. Again it is totally inappropriate to state that horses, cows, deer and other animals already impact on those areas and camels will not make a difference‖.
8.2.31 There is no rationale that it is now more acceptable for camels to cause erosion to an already modified habitat. Earlier we noted that camels could have a detrimental effect but that this would be localised, small in scale and reversible. Moreover we noted that should camels replace horses on beaches then the addition of camels would be beneficial. The Agency is in no position to review the performance of DOC or councils but believe the Authority should take into account such factors.
In summary
8.2.32 Taking into account the lack of suitable habitat, the ease of recapturing or eradicating escaped animals, and the low propagule pressure for establishment and current damage occurring on coastal sand dunes we consider it highly improbable that camels will cause any further detrimental effects.
Potential for camels to spread weed seeds in New Zealand
8.2.33 A number of weeds could be spread by camels in their coat and droppings. With regard to dispersal in coats we have used gorse as a case study for weeds present in New Zealand.
8.2.34 Gorse is widespread in New Zealand and considered New Zealand‘s worst weed (Roy et al, 2004). Gorse has an extensive and long lived seed bank (up to 25 years), making it difficult to control (Gouldthorpe, 2006). Gorse seed pods split open explosively, ejecting seed up to 2 m, though most seed falls in or near the canopy of mature bushes (Roy et al, 2004). In New Zealand, there is the potential for animals especially sheep, to transport gorse seed in their coats (Ledgard and Rossiter, 1997). Vehicles, machinery and water are also transporters of gorse seed (Gouldthorpe, 2006).
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8.2.35 Camels may have the potential to disperse gorse and other weed seeds in their coat, if they feed on gorse during seed eruption or eat the seeds. However, camels are less likely to disperse gorse seeds compared to sheep and goats, due to the large height a seed must erupt in order to attach to a camel‘s pelt.
8.2.36 In Australia the grazing of camels on parkinsonia (Parkinsonia aculeata), a large multistemmed woody weed, has seen the reduction of growth and seed production of this weed. Parkinsonia is regarded as one of the worst weeds in Australia because of its invasiveness potential for spread, and economic and environmental impacts (Natural Heritage Trust, 2003). It reproduces by seeds and can produce in excess of 13,000 seeds per year.
8.2.37 Currently approximately 5,000 camels are being used in Queensland to control woody weeds such as prickly acacia (Acacia nilotica), mesquite (Prosopsis spp.) and parkinsonia (Parkinsonia aculeata) on pastoral land. There are no reports to indicate camels spread the seeds of these weeds (Edwards et al, 2008).
8.2.38 Camels also have the potential to spread weed seeds in their dung. In Southern Africa their dung has been found to contain small numbers of grass, legume, forbs (herbaceous flowering plants) and mesembryanthemaceae (brightly coloured succulents) seed but the vast majority of seeds were amaranths and chenopods (Milton and Dean, 2001) both of which have representatives in New Zealand (Webb et al, 1988). Milton and Dean (2001) did test seed germination but no rates for camels are reported.
8.2.39 The weed camelthorn (Alhagi pseudalhagi), a woody leguminous shrub, is thought to have been introduced to the United States from Australia in camel dung used as packaging material around date plants (Parsons and Cuthbertson, 2001). We note that biosecurity requirements will prevent the importation of seed through the camel digestive system from overseas.
8.2.40 Camels could spread weeds present in New Zealand if they consume their seeds or fruit. Given the likely low camel numbers in New Zealand and the analysis with regard to a self-sustaining population we believe any effect will be highly improbable. We also note that any herbivorous action by camels required to spread seed will both be harmful to the plant in terms of browsing damage and beneficial in terms of enabling it to spread further. Such is the case as mentioned above where camels in Australia are used to control the weed parkinsonia (Parkinsonia aculeata) (Natural Heritage Trust, 2003) with no reports of problems of dispersal.
In Summary
8.2.41 Taking into account the low likelihood of a self-sustaining population forming, the restricted areas which suit camels and the ease of eradication we consider that any spread of weeds through camel the coat or dung going on to cause a detrimental effect by spreading weeds in New Zealand is highly improbable. Furthermore should this occur we would expect it to be both a localised and short term effect.
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Potential for camels to have a detrimental effect on ground nesting native birds by trampling
8.2.42 We have considered the effect camels may have on native ground nesting shorebirds through trampling, along the coast line of New Zealand.
8.2.43 Many New Zealand bird species that inhabit the shoreline nest in shallow nests on sand, making them susceptible to crushing by people, vehicles, horses or stock. DOC protects many areas of known nest sites of rare birds.
8.2.44 Fairy terns (Sterna nereis davisae) are an example of a bird at extremely low population numbers (<50) and one that is most at risk through interactions with camels. Full-time wardens are employed to protect New Zealand fairy terns which are now restricted to three populations in Northland (Department of Conservation, no date 1,2). Wardens are employed to maintain fences around nesting sites, help with nest translocations, conduct video surveillance of predators and predator control and law enforcement.
8.2.45 Risk to the ground nesting birds from camels relate directly to the reduction of the bird population due to trampling damage to the nesting sites or the nests themselves. Camels could reach a nesting site in either of two ways; either stray camel(s) could ‗naturally‘ wander onto a site or camels could be used by people on a site as part of a recreation activity. Below we have analysed both those scenarios.
8.2.46 As previously stated we consider that the likelihood of camels forming a self- sustaining population is highly improbable especially given the ease of eradication. Therefore, it is highly improbable that there would be a significant number of camels reaching bird nesting ground in a nationally significant way to cause significant impacts on a vast majority of the ground bird population.
8.2.47 However, in vulnerable bird populations such as the fairy tern one camel could be considered a large threat. As the more vulnerable a population becomes the greater the management from Department of Conservation, local authorities and other private land owners we believe that any stray camels near these highly sensitive management sites would be easily detected and easily removed.
8.2.48 Based on the above discussion we consider that the risk from wandering stay camels to ground nesting native birds is negligible.
8.2.49 Recreation activates such as the use of vehicles and horses are one of the risks faced by fairy terns and other ground nesting birds. These activities are known to have a detrimental impact, through eggs being crushed or the disturbance of birds reducing nesting success. These impacts are worst on the species with low populations limited to a handful of sites. This potential effect must be considered in accordance with the purpose of the act which is to protect the environment and prevent the adverse effects of new organisms i.e. camels.
8.2.50 When considering this effect under the HSNO Act we have to consider whether there is any specific characteristics of camels that would make the use of camel in recreation activity more damaging than if the activity is conducted by horse or vehicles. Our analysis of the biology of camels indicates that given their large soft leathery feet
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which results in low foot pressure on the ground, in comparison to a horse, means that camels would be less damaging to these environments than either horses or vehicles. However we note that any activity near a biological sensitive area such as a fairy turns nesting site could have a non-negligible effect.
8.2.51 When considering this effect under the HSNO act it is worth considering the source of the effect. In this case the adverse does not arise from a biological characteristic of a camel but from the human activity of conducting recreational activity near a biologically sensitive site. Activities such as this are not regulated under HSNO and therefore the outcome of this consideration (whether or not approval is given to import camels) will determine what species is used for an activity but the outcome will not constrain the activity in any other way.
8.2.52 If the Authority is concerned about the effect of camels on such an activity one option would be to inform local authorities and the conservancy offices of DOC that an approval for release has been granted. This would enable them to amend any necessary policies or laws to take into account the ability of people to use camels for recreational purposes.
Issues raised during the consultation period regarding trampling of native birds
8.2.53 One respondent argued that ―DoC are very selective in what areas it assigns wardens to. [We] argue that those areas are limited in number and far and few. It is fanciful thinking to advance that the coasts of Aotearoa are somehow managed by these agencies. In our area the fairy tern is not managed by DoC…It is locals who consistently remind the general public of the fairy tern issue. There are large areas in Aotearoa that DoC and local government do not manage and many communities struggle already with the existing menaces‖.
8.2.54 We note this comment. Though we agree that not all of the coastline of New Zealand are actively managed, we believe that areas of significance around rare native birds are generally managed to the point where a wild camel would be noticed and removed.
In summary
8.2.55 Because most nesting sites of rare New Zealand shorebirds are protected by DOC or local government authority bylaws, the project team therefore consider it highly improbable that camels would cause a detrimental effect by trampling ground nesting native birds of New Zealand. The use of camels recreationally could have significant effects however this is best dealt with under more appropriate legislation.
Potential for imported new organisms to hybridise with llama and alpaca in New Zealand
8.2.56 Camels and llama crosses have produced offspring, but only as the result of artificial insemination to impregnate the female llama. It is unlikely that without artificial insemination any successful crossing will occur, this is due to the large size difference, with camels being six times the weight of llamas. Even with artificial insemination the success rates of such impregnations is low, with one conception from 18 llama - camel crosses, and eight conceptions from 84 camel – guanaco crosses (Skidmore et al, 2001).
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In summary
8.2.57 It is highly improbable that camels will hybridise with llama or alpaca in New Zealand.
Summary of environmental effects
8.2.58 In summary, taking into account the lack of suitable habitat, the ease of eradication or recapture, and the low propagule pressure for establishment, we consider it highly improbable that camels will cause any further detrimental effect on New Zealand‘s environment.
Issues raised during the consultation period regarding unknown and un-assessable risks
8.2.59 One stakeholder mentioned that the importation of any new organism contains potential risks.
8.2.60 ―With the best intentions in the world the introduction of new species to New Zealand does have potential risks, rather than having to police these risks after introduction, we would prefer that they were not introduced in the first place‖ (respondent).
8.2.61 We agree that there are potential risks with the importation of any new organism, we have attempted to assess all likely risks and note that the stakeholder did not point to a risk we have not considered.
8.3 Human Health and safety
8.3.1 We assessed the potential for camels to cause adverse effects on human health and safety and identified the following pathways through which this could happen: vectors of disease; and harm through physical interaction.
Vectors of disease
8.3.2 It has been said that camels in Australia are not overly affected by disease (Dorges and Heucke, 1995). However it has been established that members of the Camelidae family are susceptible to bovine tuberculosis (Tb) and brucellosis (Brown, 2004; DAFWA, 2008; Wernery et al, 2007), although neither disease is present in Australia (Brown, 2004).
8.3.3 Brucellosis is a zoonotic infection caused by the Brucella abortus bacteria which can infect a number of hooved mammals as well as humans (Davis and Elzer, 2002). Brucella abortus is now rare in New Zealand due to successful animal vaccination and surveillance, and no human infections have been recorded since 1989 (Crump et al, 2001).
8.3.4 There has been one known case of a strain of Brucella abortus isolated from a camel infecting humans. This occurred after a centrifuge tube containing live B. abortus was accidentally ruptured (Fiori et al, 2000). Transmission from camels to humans is possible through the consumption of raw untreated milk and laban (buttermilk),
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however transmission from camels to humans was less likely than transmission from goats and sheep to humans (Abbas and Agab, 2002). Given that B. abortus is rare in New Zealand and there is a track record of its effective management we have concluded that it is highly improbable that camels will become a vector of B. abortus.
8.3.5 Bovine tuberculosis (Tb) is an infectious airborne bacterial disease that causes abscesses in various tissues, most commonly in lymphoid tissues and lungs. It can infect humans, and a wide range of domestic and wild animals (Animal Health Board Inc, 2001). Bovine tuberculosis is present in New Zealand.
8.3.6 Camels are expected to be similar to llama and alpaca in terms of Tb, in that they are said to be hosts rather than vectors of Tb, like all warm blooded animals (Paul Livingston, pers comm.). This is because llama and alpaca are capable of passing the disease on to other members of their herd, but that there is no evidence to suggest that they are a source of infection for wild animals (Paul Livingston pers comm.). This is similar to deer, which are only capable of sustaining deer to deer transmission at artificially high densities in farms (Mandy Barron pers comm.). Deer, alpaca and llama do not catch Tb without input from wildlife vectors. Llama and alpaca would probably catch Tb in the same way domestic deer catch it, in that they investigate/attack and mouth sick ferrets or possums that may wander into their paddock (Paul Livingston pers comm.).
8.3.7 Paul Livingston (pers comm.) said that there have been three cases of Tb in New Zealand alpaca and llama, and due to the National Tb Control Programme targeting pest species such as possums and ferrets, this number is likely to decrease.
8.3.8 The project team therefore considers it highly improbable that camels will be vectors for Tb, and would be incapable of passing Tb onto other animal species or humans.
In summary
8.3.9 The project team considers that in view of the Import Health Standard (IHS) that will be required for the import camels, requiring a range of health checks and vaccinations, it is highly improbable that any pathogens of humans or other animals will be associated with the camels to be imported.
Harm through a physical interaction
8.3.10 There is potential for adverse effects to occur through a physical interaction, like all other large herbivores already present in New Zealand. Camels have been domesticated since 4000BC (Long, 2003) and despite their reputation of being bad- tempered beasts that spit often they very rarely spit and bite people (Kohler-Rollefson, 1993).
8.3.11 However with any large animal injuries can occur. In Nigeria there have been records of people sustaining facial injuries by camels kicking, biting, trampling and falling onto people (Ugboko, et al 2002). The same Nigerian study showed that the most common animal to cause facial injury are cattle. There has also been a highly publicised case of one women being killed by her pet camel which knocked her over
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while over-excited (BBC, 2007). Though these incidents can occur they are extremely rare.
8.3.12 To give some comparison for the number of animal related injuries that occur in New Zealand, for 2001-02, 58 regional authorities reported 3,020 dog attacks on people, which extrapolated to 3,435 across New Zealand. In the same period 8,677 accident compensation claims resulting from dog bites were lodged with ACC (DIA, 2003). It is highly unlikely that camel related injuries would ever be more than an occasional incident.
8.3.13 There is potential for adverse effects on human health and safety to occur through car accidents with camels that have wandered onto the road. However the project team consider this is less likely than an accident involving other large animals in New Zealand, of which there is likely to be higher numbers than camels. This is due to the highly improbable chance of camels forming self-sustaining populations in New Zealand and being able to wander freely on New Zealand roads.
Issues raised during the consultation period regarding physical harm from camels
8.3.14 One Māori respondent has suggested that camels, like stampeding horses possibly spooked by dogs, could cause negative health consequences to people on beaches if they become scared or frightened. ―[we] contend that a large camel full of fear and fright has the potential to wreak havoc on coasts and that once viewing what a horse or large animal can do to humans on beaches a precautionary approach should take place‖.
8.3.15 We acknowledge that in the case with any large animal human injuries can and do take place. However we have concluded that human injuries caused by camels will be few and far between and much lower than current levels of attacks society tolerates, for example the 3,435 yearly dog attacks across New Zealand and 8,677 accident compensation claims resulting from dog bites (Appendix 5).
In summary
8.3.16 Like any animal, bad temperament can be attributed to maltreatment and camels have been known to spit or kick as a result of maltreatment. As maltreatment is likely to be an exceptional rather than a normal situation, the project team therefore consider it highly improbable for there to be an adverse effect of humans through physical interaction with a camel.
8.4 Relationship of Māori to the Environment
8.4.1 The potential adverse effects on the relationship of Māori to the environment have been considered in accordance with the HSNO Methodology Order 1998 clauses 9(b)(i) and 9(c)(iv) and sections 5, 6 (especially 6(d)) and 8 of the HSNO Act 1996. In addition, we used the frameworks contained in the following ERMA New Zealand documents as guides for assessing the information in this application and responses to iwi/Māori consultation:
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User guide ―Working with Māori under the HSNO Act 1996‖; Protocol ―Incorporating Māori perspectives in Part V Decision Making‖; and Policy ―Requirements for National Consultation with Māori Under the Hazardous Substances & New Organisms Act 1996‖.
Consultation
8.4.2 Consultation with Māori occurs in order to give effect to section 6(d) of the Act. This section requires the Authority, when exercising functions under the Act, to specifically take into account the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga (referred to here as the relationship of Māori to the environment).
8.4.3 In accordance with ERMA New Zealand policy, the applicant undertook national (Category One) consultation with iwi/Māori using the guidelines contained in the ERMA New Zealand user guide ―Dealing with Māori under the HSNO Act 1996‖.
8.4.4 The applicant sent out information letters and response forms to 137 iwi/Māori contacts supplied by the Agency and 24 responses were received. Of those replies, 12 indicated they had no issues or comments to make, 6 had no issues but wished to be informed on progress and 6 either had issues or requested further information from the applicant.
8.4.5 The main issues raised were: displacement of native species cause deterioration of natural habitats can have adverse effects on human health and safety have effects on New Zealand‘s inherent genetic diversity could cause disease or be a vector for human or animal diseases inadequate information supplied New Zealand has already been impacted by introduction of browsing and grazing animals such as deer and goats that have dramatically changed the landscape and resulted in a loss of ngā taonga tuku iho (valued flora and fauna) the enhancement of which is paramount there needs to be an Assessment of Environmental Effects (AEE) and cultural impact assessment prepared as this is a new animal.
8.4.6 All of the above matters except the last are addressed in other sections of this report.
8.4.7 Despite there being some differences of opinion on the efforts made by the applicants to follow up on the 6 respondents who indicated they had issues and on their general availability to field further questions as they arose (possibly because there were two applicants seemingly working independently of each other), we believe that the applicants fulfilled the requirements of Category One national consultation as currently set out in the user guide. This group of respondents were also afforded
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another chance to present their views during a second round of consultation (as detailed below).
8.4.8 In addition to the applicant-conducted consultation (above), the agency initiated contact with a further 2 iwi groups who were inadvertently left off the original address list supplied to the applicant. Their views are of prime importance as they would be most affected by the current application. The applicant met kanohi ki te kanohi (face to face) with Te Uepu Committee being the tangata whenua advisory group for Papamoa Hills (comprising representatives from Ngā Pōtiki Hapū, Ngāti Pūkenga, Waitaha, and Ngāti Hē) in keeping with ERMA New Zealand‘s consultation policy. The specific concerns raised by Te Uepu are discussed separately below.
8.4.9 From discussions between the agency and some iwi/Māori contacts it became clear that there was some misunderstanding about the full implications of a release application by rapid assessment. It was not well understood that if the application was approved it would mean that anyone, anywhere in Aotearoa could import, breed, and use for any lawful purpose any number of camels as long as their activities comply with other laws. The application would indeed not be limited to the importation of 8 camels for a trekking tourism venture in the Bay of Plenty.
8.4.10 Accordingly, a second round of consultation was conducted, this time by the Agency, using our same contact list (which by this stage had been updated to include approximately 160 iwi/Māori contacts). From this round of consultation a further 12 responses were received.
8.4.11 Of the 12 respondents from the Agency-conducted consultation: 7 opposed the application outright for a variety of reasons 1 required further information 1 suggested a condition of sterilising all imported camels 1 had no opposition4 1 had no issue 1 did not specifically oppose but raised a number of concerns.
8.4.12 Again, many of the issues raised are addressed in other parts of this report. Those that are not are discussed below.
8.4.13 A geographical spread and summary of all the responses from both rounds of consultation is given in Appendix 6. However the individual respondents have not been identified as there has been insufficient time to confirm with each respondent whether they wish these details to be made publicly available or not.
Potential for camels to adversely affect the relationship of Māori and their culture and traditions (including kaitiakitanga) with their waahi tapu
8.4.14 The role of Māori as kaitiaki has been formally recognised including in the Resource Management Act 1991 as guardians and/or stewards of New Zealand‘s natural
4 The exact comment from this respondent was ―After discussing at a monthly Runanga meeting, it was decided to approve the application ‗To Allow Importation of Dromedary (or Arabian Camels) into New Zealand.‘ There was no opposition.‖
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resources. Kaitiakitanga is the undertaking of duties and obligations inherited from the Atua (gods) over the realms of those Atua in accordance with tikanga Māori. It is the responsibility of people as kaitiaki to ensure the protection of cultural and spiritual health and wellbeing of themselves and the resources for which it is their duty to protect. This is achieved by performing kawa (ceremonial rituals) according to the tikanga (laws/rules of those rituals) (see ―Incorporating Māori Perspectives in Part V Decision Making‖).
8.4.15 There are three key spiritual elements (taha wairua) of kaitiakitanga – mauri, mana and tapu. As tapu is regarded as the sacred link to the mauri and mana of the spiritual guardians, the protocols of tapu become the mechanism that controls human behaviour in regard to their use of resources (see ―Incorporating Māori Perspectives in Part V Decision Making‖). Of particular relevance in this section is the use of tapu to protect the sanctity of waahi tapu.
8.4.16 Once the applicant met with the tangata whenua of Tauranga on 10th December 2008, it become apparent that the proposed trekking trail was going to take place in a waahi tapu (sacred area).
8.4.17 In their written response of unequivocal opposition to this application Te Uepu5 (tangata whenua advisory group for the Papamoa Hills) comprising representatives from Ngāti Hē, Ngā Pōtiki, Ngāti Pūkenga and Waitaha, had this to say – ―The area is considered waahi tapu6 after the many battles that occurred there…[these are] associated with the occupation of Ngā Potiki in relation to the musket wars in the area.‖ They provided confidential documents to support their claim as well as two references with further commentary on this musket war history.Te Uepu also had this to say about the Tumu Kaituna 14 Trust who are the owners of the land on which the camels intend to be housed ―In communication also with the applicant who stated that the Maoriland Trust of the subject site are supportive, however this maori view differs as it is built on commercial interests as not consistent tikanga and kawa with regard to the waahi tapu nature of the area‖.
8.4.18 The project team has assessed Te Uepu‘s opposition to this application as being relevant particularly in terms of section 6(d) of the HSNO Act and 9(c)(iv) of the Methodology. More specifically, the introduction of camels into a known waahi tapu would significantly adversely affect the relationship of Māori and their culture and traditions with their waahi tapu in a number of ways. The following statements are intended to demonstrate some of those ways which were articulated during further discussions between the Agency and Te Uepu as well as other Māori given that the application is for a release potentially into other parts of Aotearoa:
8.4.19 The mere presence of a camel in a waahi tapu would break the sanctity of such an area.
8.4.20 A waahi tapu is a place that has had a restriction put on it. If someone goes ahead and knowingly breaks that restriction (by introducing a camel to the area for instance) then the mana of that iwi who has placed the restriction on has been desecrated.
5 Owner of the proposed land for containing the camels on their trekking operation. 6 The waahi tapu include both urupā (burial sites) and parekura (battlegrounds).
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8.4.21 An activity like camel trekking has the potential for unintentional or intentional disturbance of kōiwi (human remains). If kōiwi are uncovered they could be taken away or left exposed which contravenes tikanga Māori (which is to bury or place kōiwi out of sight).
8.4.22 It is current practice for some iwi to destroy animals that have entered (by intentional or unintentional means) an urupā (which is a waahi tapu). Animals used for recreation purposes such as horses and dogs (and this would include camels if introduced) are destroyed as a means of cultural safety as such animals may become unpredictable due to cultural contamination via violation of waahi tapu. To demonstrate this point further, animals such as cows and deer are also destroyed by some iwi if they are found in an urupā as they are a source of food that has been culturally contaminated and are not wanted entering the food chain.
8.4.23 Finally, from reviewing written correspondence between the applicants and Te Uepu and from further verbal communication between the Agency and these parties it appears that the possibility of applying conditions had been discussed on more than one occasion (despite this application being for a release).
8.4.24 It also appears from the same written and verbal communications that there may be some tikanga Māori mitigation measures in relation to waahi tapu that may be able to be put in place at least in the case of the tangata whenua of the proposed application site. However, it is uncertain as to whether this would be the case for all iwi.
8.4.25 The very nature of the application as it currently stands (unconditional release) would appear to preclude discussions of either conditions or mitigation measures in any case however the project team wishes to illustrate the possibilities should an alternative option to a release by rapid assessment be deemed appropriate.
Potential adverse effects of camels on certain Māori cultural practices
8.4.26 Iwi/Māori consultation brought out the potentially significant issue of camels adversely impacting on certain Māori cultural practices. ―Many of the Maori coastal communities plant out spinifex and pingao and are struggling against a tide of ignorance by the general public as they either create or allow the destruction of the dune areas. [We] view the added large alien species [camel] as a further risk to our cultural identity and cultural practices [of planting out spinifex and pingao]‖. As mentioned earlier in this report small scale, localised and reversible damage could occur to vegetation through camel browsing. While not significant at a national level any damage to a culturally sensitive and taonga species used for raranga/tukutuku can be considered significant.
8.4.27 Earlier on in this report the project team assessed that it would be highly improbable that camels would have a large scale detrimental effect on the environment of New Zealand through trampling or grazing and highly improbable that camels will cause any further detrimental effects to damage already occurring on coastal sand dunes. However there are additional Māori cultural dimensions being advanced here in relation to these biophysical effects that have not been addressed and therefore fully assessed earlier. Taking into account all available information the project team therefore assesses the potential impact of camels on certain Māori cultural practices (such as planting pingao) as significant.
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8.5 Potential adverse effects on the Treaty of Waitangi
Potential Inconsistency with the Treaty of Waitangi principle of active protection
8.5.1 Section 8 of the HSNO Act 1996 requires that when considering applications the Authority shall take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi). The project team notes the potential for adverse effect to the following Treaty of Waitangi principles as identified by the Court of Appeal decision in New Zealand Māori Council v Attorney General 1987: the obligation to act reasonably, in the utmost good faith and in a manner that is consistent with partnership the requirement to make informed decisions the obligation to actively protect Māori interests the obligation on the Crown to not unduly impede or diminish its capacity to provide redress where a valid Treaty grievance is established.
8.5.2 The principle of active protection was defined as ―not merely passive but extends to active protection of Māori people in the use of their lands and waters to the fullest extent practicable‖ (Cooke, 1987). This principle is applicable both in terms of: Mātauranga and tikanga Māori as it relates to the knowledge developed and established about the relationship of Māori to the environment; and Kaitiakitanga as a tangible expression of the rights of Māori over their traditional lands, waters and other natural resources.
8.5.3 The project team considers that approval of an application to release camels in to Aotearoa with no means of being able to place conditions on it or no opportunity to discuss mitigation measures with respect to the two potentially significant effects just mentioned (waahi tapu and Māori cultural practices) may be viewed as being inconsistent with the Treaty of Waitangi principle of active protection.
8.6 Society and communities
8.6.1 The project team considered the potential for camels to have adverse effects on New Zealand‘s society and communities. Based on the information available, the project team did not identify any potentially significant adverse effects on society and communities in New Zealand.
8.7 Market economy
8.7.1 The project team considered the potential for camels to have adverse effects on New Zealand‘s society and communities. Based on the information available, the project team did not identify any potentially significant adverse effects on society and communities in New Zealand.
8.8 Requirement to meet Section 35 Criteria
8.8.1 As noted above the applicant has submitted this application under section 34 of the Act and requested that it be considered under section 35 of the Act, which provides for
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an approval to be obtained through the rapid assessment of adverse effects. Early on the Project Team decided to undertake a much fuller assessment of adverse effects than required under the Act and to relate these back to section 35. We are therefore confident that there are no other potentially significant adverse effects that we have not identified.
Is the organism an unwanted organism as defined in the Biosecurity Act 1993?
8.8.2 Camels are not unwanted organisms as defined by the Biosecurity Act.
After release could the organism form self-sustaining populations in New Zealand, taking into account the ease of eradication; (section 35(b)(i))
8.8.3 As per the assessment in 7.3.9 we conclude that in the highly improbable event that camels form a self-sustaining population in New Zealand that such populations could be eradicated. Therefore we believe it is at the minimum highly improbable that camels will form a self-sustaining population in New Zealand taking into account the ease of eradication.
After release could the organism displace or reduce a valued species; (section 35(b)(ii))
8.8.4 We have assessed the detrimental effects camels could have on valued species by investigating the effect camels may have on ground nesting native birds and native vegetation. We concluded that it was highly improbable that camels would have a negative effect on nesting native birds and highly improbable that camels would have a negative effect on valued native vegetation.
After release could the organism cause deterioration of natural habitats; (section 35(b)(iii))
8.8.5 We have assessed the detrimental effects camels could have on the coastal environment. As per the assessment in 8.2.32 we concluded that it is highly improbable that camels would have a negative effect on the on the natural coastal environment.
After release will the organism be disease-causing or be a parasite, or be a vector or reservoir for human, plant or animal disease; (section 35(b)(iv))
8.8.6 We have assessed the risk of camels vectoring or spreading bovine tuberculosis (Tb) and brucellosis. As per the assessment in 8.3.4 and 8.3.8 we have concluded it is highly improbable that camels will vector or spread any human or animal disease.
After release could the organisms have any adverse effects on human health and safety or the environment (section 35(b)(v)).
8.8.7 We have assessed the risk camels will have to human safety through the vectoring of disease and harm caused through physical interactions. We have assessed the risk of camels to the New Zealand environment by assessing the risk of camels grazing and trampling of native vegetation; causing the erosion of sand dunes; dispersing weed seeds; and trampling of native bird nesting grounds. As per the assessments in 8.2 and
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8.3 we have concluded it is highly improbable that camels will have any adverse effects on human health and the environment. 9 Previous similar applications
9.1.1 This is the first application for a vertebrate release considered by the Authority and hence there are no similar applications. 10 Associated approvals
10.1.1 As noted by the applicant, importation of these organisms will require a Permit to Import and an IHS from MAF. 11 International obligations
11.1.1 The project team is not aware of any international obligations relevant to this application in accordance with clause 9(c)(vi) of the Methodology and section 6(f) of the HSNO Act, apart from those meet by the legislation outlined in section 10 above. 12 Overall evaluation
12.1.1 The application is to import camels for unconditional release into New Zealand.
12.1.2 If the Authority found that the application did not meet the criteria specified in section 35 or fit with the principles of part two of the Act then the Authority could decide to not approve the application and suggest to the applicant that it is best considered under section 38 of the Act.
12.1.3 We have evaluated the potential of camels likely to be imported under this application to form a self-sustaining population in New Zealand in accordance with section 35(2) of the Act. The science assessment clearly concludes that based on the New Zealand‘s environment, which is very different from environments in which camels occupy as both feral and domestic animals that it is highly improbable that camels will form a self-sustaining population in New Zealand. In addition we believe that if a self-sustaining population were to form that it could be eradicated.
12.1.4 We have also assessed the likelihood that camels: Could displace or reduce a valued species; or Could cause deterioration of natural habitats; or Will be disease-causing or be a parasite, or be a vector or reservoir for human, plant, or animal disease; or Will have any adverse effects on human health and safety or the environment,—
12.1.5 We have concluded that the likelihood of all these adverse effects is highly improbable. In our assessment we did not identify any other significant biophysical effects that are outside of these criteria. Our overall evaluation from a biophysical perspective is that it is almost certain that camels would not have any negative effect on the New Zealand environment or human health and safety.
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12.1.6 Our assessment also concluded that there was a significant adverse effect on (a) the potential for camels to adversely effect the relationship of Māori and their culture and traditions (including kaitiakitanga) with their waahi tapu and (b) the potential adverse effects of camels on certain Māori cultural practices. The lack of ways to mitigate these two significant effects may be viewed as being inconsistent with the Treaty of Waitangi principle of active protection.
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Appendix 1: Decision path and qualitative descriptors
Decision Path
Context This decision path describes the decision-making process for applications to import for release, or release from containment, a new organism (non GMO) under the option of rapid assessment These applications are made under section 34 of the HSNO Act, and determined under section 35 of the Act.
Introduction The purpose of the decision path is to provide the Authority with guidance so that all relevant matters in the HSNO Act and the Methodology have been addressed. It does not attempt to direct the weighting that the Authority may decide to make on individual aspects of an application.
In this document ‗section‘ refers to sections of the HSNO Act, and ‗clause‘ refers to clauses of the ERMA New Zealand Methodology.
The decision path has two parts – Flowchart (a logic diagram showing the process prescribed in the Methodology and the HSNO Act to be followed in making a decision), and Explanatory notes (discussion of each step of the process).
Of necessity the words in the boxes in the flowchart are brief, and key words are used to summarise the activity required. The explanatory notes provide a comprehensive description of each of the numbered items in the flowchart, and describe the processes that should be followed to achieve the described outcome.
For proper interpretation of the decision path it is important to work through the flowchart in conjunction with the explanatory notes.
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Decision path Decision path for applications to import for release from containment, a new organism (non GMO) under the option of rapid assessment (application made under section 34 of the Act and determined under section 35 of the Act). For proper interpretation of the decision path it is important to work through the flowchart in conjunction with the explanatory notes
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Explanatory Notes
Items Information that should be reviewed includes that in the application, the E&R 1, 2 & Report, and from experts (where relevant). Review should occur in terms of 3: section 40(2) of the Act and clauses 8, 15, 16, 20 and 22 of the Methodology. Additional information may need to be sought under s58 of the Act. If the applicant is not able to provide sufficient information for consideration then the application is not approved. In these circumstances the Authority may choose to decline the application, or the application may lapse.
Item 4: Consider whether the organism is an unwanted organism as defined in the Biosecurity Act 1993.
Item 5: The range of risks (and costs) to be identified should be that covered by section 35(2)(b) and section 36 of the Act. There are two steps within this part of the process:
Step 1: The identification of all risks and associated costs.
Step 2: The elimination of those risks and associated costs that can be readily concluded to be negligible or irrelevant, having regard to the characteristics of the organism and the circumstances of the application.
Item 6: All potentially non-negligible risks identified in Item 5 should be assessed in order that the criteria in items 7 & 8 below can be determined.
Item 7: Consider whether the application meets the criteria specified in Section 36 of the Act (Minimum standards).
Item 8: Consider whether the application meets the criteria specified in Section 35(2)(b) of the Act.
Item 9: If the application fails the rapid assessment criteria as specified in Section 35(2)(b), the Authority may decide to ―not approve‖ the application. This is not the same as declining the application as it may be further considered under Section 38 of the Act. The applicant has the discretion to decide whether or not to proceed to full assessment should their application fail the rapid assessment criteria.
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Qualitative descriptors for risk/benefit assessment This section describes how the Agency staff and the Authority address the qualitative assessment of risks, costs and benefits. Risks and benefits are assessed by estimating the magnitude and nature of the possible effects and the likelihood of their occurrence. For each effect, the combination of these two components determines the level of the risk associated with that effect, which is a two dimensional concept. Because of lack of data, risks are often presented as singular results. In reality, they are better represented by ‗families‘ of data which link probability with different levels of outcome (magnitude). The magnitude of effect is described in terms of the element that might be affected. The qualitative descriptors for magnitude of effect are surrogate measures that should be used to gauge the end effect or the ‗what if‘ element. Tables 1 and 2 contain generic descriptors for magnitude of adverse and beneficial effect. These descriptors are examples only, and their generic nature means that it may be difficult to use them in some particular circumstances. They are included here to illustrate how qualitative tables may be used to represent levels of adverse and beneficial effect.
Table 1 Magnitude of adverse effect (risks and costs)
Descriptor Examples of descriptions - ADVERSE Minimal Mild reversible short term adverse health effects to individuals in highly localised area Highly localised and contained environmental impact, affecting a few (less than ten) individuals members of communities of flora or fauna, no discernible ecosystem impact Local/regional short-term adverse economic effects on small organisations (businesses, individuals), temporary job losses No social disruption Minor Mild reversible short term adverse health effects to identified and isolated groups Localised and contained reversible environmental impact, some local plant or animal communities temporarily damaged, no discernible ecosystem impact or species damage Regional adverse economic effects on small organisations (businesses, individuals) lasting less than six months, temporary job losses Potential social disruption (community placed on alert) Moderate Minor irreversible health effects to individuals and/or reversible medium term adverse health effects to larger (but surrounding) community (requiring hospitalisation) Measurable long term damage to local plant and animal communities, but no obvious spread beyond defined boundaries, medium term individual ecosystem damage, no species damage Medium term (one to five years) regional adverse economic effects with some national implications, medium term job losses Some social disruption (e.g. people delayed) Major Significant irreversible adverse health effects affecting individuals and requiring hospitalisation and/or reversible adverse health effects reaching beyond the immediate community Long term/irreversible damage to localised ecosystem but no species loss Measurable adverse effect on GDP, some long term (more than five years) job losses Social disruption to surrounding community, including some evacuations Massive Significant irreversible adverse health effects reaching beyond the immediate community and/or deaths Extensive irreversible ecosystem damage, including species loss Significant on-going adverse effect on GDP, long term job losses on a national basis Major social disruption with entire surrounding area evacuated and impacts on wider community
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Table 2 Magnitude of beneficial effect (benefits)
Descriptor Examples of descriptions -BENEFICIAL
Minimal Mild short term positive health effects to individuals in highly localised area Highly localised and contained environmental impact, affecting a few (less than ten) individuals members of communities of flora or fauna, no discernible ecosystem impact Local/regional short-term beneficial economic effects on small organisations (businesses, individuals), temporary job creation No social effect
Minor Mild short term beneficial health effects to identified and isolated groups Localised and contained beneficial environmental impact, no discernible ecosystem impact Regional beneficial economic effects on small organisations (businesses, individuals) lasting less than six months, temporary job creation Minor localised community benefit
Moderate Minor health benefits to individuals and/or medium term health impacts on larger (but surrounding) community and health status groups Measurable benefit to localised plant and animal communities expected to pertain to medium term. Medium term (one to five years) regional beneficial economic effects with some national implications, medium term job creation Local community and some individuals beyond immediate community receive social benefit.
Major Significant beneficial health effects to localised community and specific groups in wider community Long term benefit to localised ecosystem(s) Measurable beneficial effect on GDP, some long term (more than five years) job creation Substantial social benefit to surrounding community, and individuals in wider community.
Massive Significant long term beneficial health effects to the wider community Long term, wide spread benefits to species and/or ecosystems Significant on-going effect beneficial on GDP, long term job creation on a national basis Major social benefit affecting wider community
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Likelihood in this context applies to the composite likelihood of the end effect, and not either to the initiating event, or any one of the intermediary events. It includes: the concept of an initiating event (triggering the hazard), and the exposure pathway that links the source (hazard) and the area of impact (public health, environment, economy, or community).
Thus, the likelihood is not the likelihood of an organism escaping, or the frequency of accidents for trucks containing hazardous substances, but the likelihood of the specified adverse effect7 resulting from that initiating event. It will be a combination of the likelihood of the initiating event and several intermediary likelihoods8. The best way to determine the likelihood is to specify and analyse the complete pathway from source to impact.
Likelihood may be expressed as a frequency or a probability. While frequency is often expressed as a number of events within a given time period, it may also be expressed as the number of events per head of (exposed) population. As a probability, the likelihood is dimensionless and refers to the number of events of interest divided by the total number of events (range 0-1).
Table 3 Likelihood
Descriptor Description
1 Highly improbable Almost certainly not occurring but cannot be totally ruled out
2 Improbable (remote) Only occurring in very exceptional circumstances.
3 Very unlikely Considered only to occur in very unusual circumstances
4 Unlikely (occasional) Could occur, but is not expected to occur under normal operating conditions.
5 Likely A good chance that it may occur under normal operating conditions.
6 Very likely Expected to occur if all conditions met
7 Extremely likely Almost certain
Using the magnitude and likelihood tables a matrix representing a level of risk can be constructed.
7 The specified effect refers to scenarios established in order to establish the representative risk, and may be as specific as x people suffering adverse health effects, or y% of a bird population being adversely affected. The risks included in the analysis may be those related to a single scenario, or may be defined as a combination of several scenarios. 8 Qualitative event tree analysis may be a useful way of ensuring that all aspects are included.
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In the example shown in Table 4, six levels of risk are allocated: A, B, C, D, E and F. These terms have been used to avoid confusion with the descriptions used for likelihood and magnitude, and to emphasise that the matrix is a tool to help decide which risks (benefits) require further analysis to determine their significance in the decision making process.
The lowest level (A) is, in most circumstances, equivalent to ‗negligible‘. In this table ‗A‘ is given to three combinations; minimal impact and an occurrence of improbable or highly improbable, and minor impact with a highly improbable occurrence.
For negative effects, the levels are used to show how risks can be reduced by the application of additional controls. Where the table is used for positive effects it may also be possible for controls to be applied to ensure that a particular level of benefit is achieved, but this is not a common approach. The purpose of developing the tables for both risk and benefit is so that the risks and benefits can be compared.
Table 4 Level of risk
Magnitude of effect
Likelihood Minimal Minor Moderate Major Massive
Highly improbable A A B C D
Improbable A B C D E
Very unlikely B C D E E
Unlikely C D E E F
Likely D E E F F
Very likely E E F F F
Extremely likely E F F F F
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Appendix 2: Biographies of for individuals noted in text and appendices
Dr Mandy Barron
Mandy Barron is part of the Scientist Wildlife Ecology and Epidemiology Team, Landcare Research, Lincoln. Her research has involved modelling infectious diseases in wildlife vectors such as bovine tuberculosis in brushtail possums, canine distemper in stoats, and rabbit haemorrhagic disease. She has a PhD in Ecology, MApplSc (First Class Hons), and BSc in Ecology.
Paul Livingston
Paul Livingston is the Technical Manager of the Animal Health Board. He has been involved in the Tb Control Programme in New Zealand since 1973. Paul has a BVetSci, and a Master of Preventative Veterinary Medicine.
Dr Carolyn King
Carolyn King is a Senior Lecturer in the Centre for Biodiversity & Ecology Research. Her area of research is on the ecology of small rodents and mustelids, especially stoats and weasels. Other research interests include the philosophy and management of national parks, and the traditional and contemporary relationships between science and theology. Carolyn is the scientific editor of the New Zealand Journal of Zoology.
Dr Richard Duncan
Richard Duncan is a Professor of Ecology in the Bio-Protection and Ecology Division at Lincoln University. His area of research focus is on the understanding of processes by which some species are introduced, establish and become widespread invaders in new locations. This involves theoretical work on the processes of transport, establishment and spread, compilation and analysis of historical introduction data, and field surveys and experiments to understand the invasion process in a variety of taxa. Richard is also part of the Landcare Research Ecosystems Process team investigating the processes that maintain New Zealand‘s ecosystems. This includes the investigation of the impacts of disruption of ecosystems; and biosecurity risks from foreign weeds, pests and micro-organisms.
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Appendix 3: Organism Description
Distribution and population size
Camels may have originally inhabited desert regions from North Africa to India, but no wild populations exist there now (Long, 2003). It is believed that camels were domesticated in central or southern Arabia about 4000 years ago (Long, 2003). Domesticated populations now live in dry desert and flat regions of Sudan, Kenya, Ethiopia and Somalia, as well as the Middle East, parts of China and the Russian Federation (Long, 2003). The only wild population of camels occur in the central and desert regions of Australia, covering 40-50% of the mainland, some 3.3 million km2. In Australia the population is estimated at 960,000 giving a density of 0.29 camel/ km2 (Edwards et al, 2008; Naturebase, 2008).
Biological characteristics
Camels are large and very distinctive animals with a shoulder height of 180-230 cm and weight of 300-690 kg. They are well adapted to desert environments having broad feet with soft leathery pads that flatten upon contact with the sand to prevent sinking (Nowak, 1991). Their coat is relatively short and thick, providing some insulation during the cold desert nights and some daytime insulation against the heat (Macdonald, 1995; Nowak, 1991). In addition, their eyes have long thick eyelashes and translucent eyelids, allowing them to gain a sense of direction in sand storms. Their ears are small and hairy, and their slit-like nostrils can be closed to keep out dust and sand (Dorges and Heucke, 1995; Nowak, 1991).
Diet
Camels eat a wide variety of plants over expansive home ranges. In Australia, camels can wander up to 70 km per day, grazing on most plant material including fresh grasses and shrubs. In Australia they have a strong preference for plant species of high moisture and salt content such as prostrate succulents, shrubs and leaves rather than native or introduced grasses (Dorges and Heucke, 1995; DAFWA, 2008; Shiebert and Newman, 1989). In some places that camels are kept as domestic stock they may require their diet to be supplemented with salt as the local vegetation cannot supply the amount needed (Wilson, 1989). The browsing habits of camels in relation to their choice of foods and the height at which they browse mean that they generally do not compete with other livestock for food (Wilson, 1989). Camels usually spend little time in one place and browse on the move (Dorges and Heucke, 1995; Shiebert and Newman, 1989).
Growth and reproductive characteristics
Camels can live up to 50 years, and may actively breed for 30 years (DAFWA, 2008). They reach sexual maturity at age three in females, with mating beginning from ages four or five. Males begin to rut by age three, but do not reach full sexual maturity until age six (Naumann, 1999).
Females come on heat several times a year and with pregnancy lasting around 13 months. Normally one calf is born, which is usually weaned when it is one and a half
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years old (Nowak, 1991). Females, on average, give birth every two years (DAFWA, 2008; Nowak, 1991).
Camels are social animals and live in three types of non-territorial groups. Bull groups occur throughout the year and consist of all ages of males although elder bulls may often be solitary. Cow groups consist of females and their calves but only form outside of the breeding season (summer). In summer breeding groups form consisting of one adult bull and several cows and their calves (Dorges and Heucke, 1995). During the summer droughts in Australia, groups may congregate and form large herds of hundreds of individuals around water sources (Dorges and Heucke, 1995).
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Appendix 4: Probability of a self-sustaining population(s) forming, taking into account the ease of eradication
Introduction to self-sustaining populations
There are many views on what entails a self-sustaining population. A common theory is that a minimum viable population level exists, below which populations are not going to be sustainable (ie, deaths outnumber births) (Shaffer, 1981). This is because small populations are more prone to extinction (Shaffer, 1981).
In theory, for a population of camels to become sustainable in the wild, they need to have a minimum number of animals that are able to breed and produce enough offspring to increase in numbers and counter the stochastic events that small populations are prone.
The New Zealand experience
For a self-sustaining population of camels to form in New Zealand, enough camels of breeding age would need to become wild and remain undetected long enough to find a suitable food source, and then successfully breed, in the first steps to forming a self-sustaining population. Using the definition of Standards Australia/ New Zealand (2006) an organism would only become invasive, if a self-sustaining population persisted, and then began to spread. It would only become a pest should it have a negative economic, environmental, social effect (Figure 1).
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Figure 1: Invasion event tree depicting the discrete stages an invasive species passes through, and alternative outcomes at each stage.
Invasion Stages Transport Transport
Death or Introduction captivity Establishment Establish/ Fail Self-sustaining population Spread
Remain local Spread Impact
Impact Human Low High Perception
There have been extensive studies conducted into what makes animal species successful at establishing self-sustaining wild populations once introduced to new environments (especially oceanic islands) (for example Cassey et al, 2004; Cassey et al, 2005; Duncan et al, 2003; Forsyth and Duncan, 2001; Hayes and Barry, 2008; Lockwood et al, 2005, Veltman et al, 1996). New Zealand provides an excellent model for such studies as there is good historical data on which exotic animals were introduced and their manner of introduction. This includes 54 introductions of exotic mammals of which 14 (26%) are now widespread and 19 (35%) failed to establish (King, 2005).
The consensus of these studies is that the more individuals released and the more separate release events, the higher the chance of a species forming a self-sustaining population and establishing. A feature of introduced species is that they are typically released in low numbers, and therefore start with small populations. Smaller populations are at greater risk of extinction from unpredictable fluctuations owing to demographic, environmental, or genetic events (Shaffer, 1981; Pimm, 1991). Small populations may also suffer from an inability to find suitable mates at low population densities, and are more prone to natural catastrophes (Shaffer, 1981; Duncan et al, 2003).
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Biologist Dr Carolyn King (2008, pers. comm.) agrees with previous studies on introduction and establishment success, that species introduced in larger groups, and introduced more often, are more likely to establish in New Zealand. The most successful exotic species introduced into New Zealand were repeatedly liberated in large groups. For example, one thousand red deer (Cervus elaphus scoticus), were released between 1851 and 1923 in New Zealand in over 50 sites, with most being multiple releases of mixed stags and hinds. Red deer are now considered the most widespread introduced mammal in New Zealand. King (2008, pers. comm.) however states that some of those groups of ungulates may not have survived, had they not been protected during their early years.
Forsyth and Duncan (2001) investigated the impact of the number of individuals released on the probability of establishment of hoofed animals in New Zealand. Their results indicate that in cases where six or more individuals had been introduced, it is likely they would be successful at establishing, if they were introduced into suitable habitat. King (2008, pers. comm.) however notes that some of those groups of hoofed animals may not have survived, had they not been given protection during their early years.
In conclusion the primary determinants of establishment success appear to be the size and number of releases of a species (King, 2005). For camels to form a self- sustaining population in New Zealand there is a threshold level of breeding individuals which would need to escape and become wild for a self-sustaining population to form. These individuals would need to escape detection (see below in reference to eradication) to go on and find suitable food sources, successfully breed and finally successfully raise their young.
New Zealand case studies of other similar species
Other members of the Camelidae in New Zealand
Two species of the family Camelidae have already been released in New Zealand and these have not formed self-sustaining populations. Alpaca were first introduced into New Zealand in 1878, while llamas were introduced in 1865 (King, 2005). Alpacas and llamas were originally released into the wild, and neither established and formed self-sustaining populations (King, 2005). Subsequently, alpaca and llama were reintroduced into New Zealand as farm stock in more recent times (King, 2005). There are currently 14,000 registered alpaca in New Zealand (Aplaca Association of New Zealand, pers. comm.). Guanacos are also present in New Zealand (Warmington et al, 1989). There is no evidence to suggest these species have ever formed a self- sustaining population.
Alpacas and llamas, which have evolved in the Andes of South America, are more suited to the New Zealand climate and landscape than camels. Alpacas‘ native range includes the central and southern Andes from Peru to Argentina and up to elevations of 4800 m, with annual precipitation of 400-700 mm and maximum temperatures of 16°C (Castillo-Ruiz and Lundrigan, 2007). The alpaca grazes on grasses and small woody shrubs (Castillo-Ruiz and Lundrigan, 2007).
Llamas also originated in environments similar to New Zealand. Their native range occurs along the Andes mountain range, although all llama are now domesticated and
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no longer found in the wild (Portman and Myers, 2004). The Andean highlands are covered with low growth, including various shrubs and stunted trees. Llamas are known to inhabit elevations no greater than 4000 m above sea level. Llamas browse on native grasses, low shrubs, lichens and mountain vegetation (Portman and Myers, 2004).
It can be speculated that of the Camelidae llama and alpaca, particularly alpaca with their large captive population, are more likely candidates to establish self-sustaining populations in New Zealand than are camels.
Feral Horses in New Zealand
Horses are an example of an herbivorous animal introduced into New Zealand that has become feral and is cited as a model that camels would follow. Two distinct populations of feral horses exist in New Zealand, one in the Kaimanawa ranges, and one in Aupouri, Northland. The Kaimanawa population is currently managed by DOC and as part of the management plan have capped the population at 500 individuals. In contrast there is no management of the Aupouri population (Fraser and Parkes, 2005).
Kaimanawa horses
Horses in the Kaimanawa area were first introduced in 1876. They include a mixture of cavalry horses turned out from Waiouru army base in 1941, farm escapees and stock horse liberations from surrounding farms (DOC, 2008). The herd was estimated to total 174 in 1979, but following protection after concerns that public shooting and capturing of horses might lead to their extermination, horse numbers escalated to over 1500 (DOC, 2008).
Concerns over horses impact on the environment, led to a DOC management plan to reduce the herd by shooting from helicopters. Public submissions however revealed little support for such an operation, and instead, the removal of horses by mustering was conducted from 1993-1995 (Fleury, 2006). Since then, a number of Kaimanawa horse advocacy groups have formed, leading to a steady demand for adoption of Kaimanawa horses for private ownership. In addition, a new management plan was developed with representatives from all interested parties working towards common goals and objectives for their management. These goals include: to ensure that the welfare of the horses is dealt with appropriately; to promote the sustainability of the natural features and ecosystems of the Moawhango Ecological District, with respect to Kaimanawa wild horse impacts on these; and to manage the Kaimanawa wild horse herd at a sustainable level.
The Kaimanawa horses are interesting for the following reasons:
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Despite many introductions the population was not self-sustaining until they were protected from human hunting and capture. Until this protection they were in decline. Their biology and population size is such that they could be easily eradicated at any time. For social reasons society is prepared to tolerate a pest species and the environmental damage it causes. Camels are unlikely to follow a similar model.
Aupouri Horses
Horses were first introduced into the Aupouri area in 1820 and left to roam on unoccupied Crown land. Local people have regularly mustered horses for their own use and for sale, while occasionally intentional introductions have also occurred (Fraser and Parkes, 2005).
Aupouri Forest is the largest sand dune plantation forest (planted in Pinus radiata) in New Zealand and is privately owned. Concerns regarding the damage to forest plantings were first noted in 1980s; however no control measures were taken. Horse numbers have since been assessed, and a measure of their impact undertaken. Total horse numbers were estimated at 400-600, with an overall density of 6.4horses/km2, and an approximate rate of increase of 21% per annum. Damage to seedlings increased to 16.5% 30 months after planting (Fraser and Parkes, 2005).
While there have been no complaints from locals or the forest owner, DOC has attempted management of horses in the past by shooting 11 horses over two years. Past DOC management was conducted because the horses were damaging an electric fence surrounding conservation land. Since then, no eradication attempts of this population have been made, due to tangata whenua and public outcry over the shootings (Gardiner, 2001).
Again, as for the Kaimanawa horses, the Aupouri horses have a special status as do all horses and therefore cannot be used to predict or understand what might eventuate with camels.
The Australian camel experience
In Australia, camels have been released often, in large numbers, and over a 50 year period. Up to 20,000 camels were imported into Australia between 1840 and 1907 to assist in exploration, carting goods and as draught animals (Edwards et al, 2008). When camels were replaced by motor and rail transport, some camels were killed, but most were simply released into the bush. Based on camel registration records it is estimated that 5,000 to 10,000 camels were released between 1920 and 1941 (Edwards et al, 2008). With such a large founder population it would have been remarkable if camels had not established. The population is now estimated to be between 950,000 and 960,000 (Edwards et al, 2008).
Both Carolyn King and Richard Duncan (2008, pers. comm.) also state that after number of individual animals released and introduction effort, a secondary but persistent factor affecting the establishment success is an environmental match between a species native range and its location of introduction.
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This appears to also have been an additional factor in the successful establishment of a self-sustaining camel population in Australia. The dry remote areas of central Australia are similar to countries in which camels once occupied and now thrive in large domestic herds. The Australian populations have no natural predators, an adequate food supply, and low disease incidence, all of which contribute few limiting factors for growth of camel populations in Australia (Dorges and Heucke, 2003).
Suitability of the New Zealand Environment to Camels
Climate matching
Camels evolved in and still inhabit arid lands, for example, 63 % of all camels are in North Africa. The largest populations occur in Sudan (2.8 million), Somalia (2 million), India (1.2 million) and Ethiopia (0.9 million). Sudan also has the highest density of camels, with 3.15 per km2 (Macdonald, 1995). These countries are predominantly arid equatorial or Saharan with vast areas of flat open desert or dunes, with limited rain and vegetation, and with hot day and cold night temperatures.
Camels in Australia are restricted largely to desert with some spill-over into the surrounding arid grassland (Bureau of Meteorology, 2008; Edwards et al, 2008)
Figure 2: Map of climate classification of Australia. (Bureau of Meteorology, 2008)
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Figure 3: Map of Australian camel distribution (from Edwards et al, 2008)
Countries where camels have failed to establish both, domestically and in the wild include Germany, Italy, Portugal, Spain, Russia, Namibia, Poland, Macedonia, Bulgaria, Canada, USA, Peru and Brazil (Long, 2003, Nowack, 1999). A temporary wild population did form in California in the 1860s after camels were released after their use by the army during the US civil war, but this population subsequently died out by the 1940s. This makes Australia the only country in which a wild population of camels has become established and persists to the present day (Long, 2003). Failure of camels in these other countries is likely to be due to unsuitable climate and too small a founder population.
In New Zealand parts of Northland, such as Ninety Mile Beach, are possible regions where climate (warm and dry) and topography (open sand dunes) could favour the formation of a self-sustaining population. A population of wild horses has established in this area at Aupouri. Currently there is no culling of these horses, however it could easily be eradicated if desired (Gardiner, 2001).
Habitat match
Having originally inhabited arid, desert regions of North Africa and the Middle East, camels have many adaptations that allow them to survive life in the desert. For example, they prefer dry, sandy, open environments, and as such, they are not adapted to life in wet, forested, and mountainous landscapes that are typical of New Zealand. With their soft, padded feet, they avoid the more rugged Kimberly area in Western Australia.
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In Australia camels have formed wild populations which are in the some of the driest and remotest parts of the continent and not found in human-modified landscapes. Although they can live in a range of arid habitat their preference, in Australia, is for open bush land. This preference is attributed to rich and varied diet regardless of season, open vegetation that provides easy observation of threats and the presence of shade trees in summer. Dense bush land is generally avoided except for calving females (Edwards et al, 2008).
In New Zealand there is little if any habit similar to that in which camels are now found. There is a lack of open range land in which camels can form a self-sustaining population in New Zealand. Wild camels in Australia are reported to travel up to 1463 km a year looking for suitable food and water sources (Grigg et al, 1995). There movements are punctuated but they do not remain in one location for long, preferring to roam over large areas (Dorges and Heucke, 1995).
New Zealand being a much smaller country does not have the open spaces that interior Australia does. Over the past 200 years, much of New Zealand‘s most accessible and productive land has been cleared or modified for a range of different land uses. These include agriculture, horticulture, road infrastructure and human settlement (Anon, 2007). The agricultural and horticultural areas have been extensively fenced, reducing the area of open land in which a population of camels could roam.
Of New Zealand‘s total landmass, 31% is forested (both native and exotic), while 39% is primarily pasture grasses (high-producing exotic grassland and low-producing grassland), which is fenced and in use for farming practices. Other major areas include metropolitan and mountainous areas, and those used for horticulture. This leaves 2.5% of the land ungrazed (Anon, 2007), which is often inaccessible and unsuitable for farming. This ungrazed land, ie Volcanic Plateau, Central Otago, and Canterbury back country, are high altitude, cold and wet in winter making them unsuitable for camels.
In Australia, camels only wander onto agricultural land when searching for a more permanent water source in severe drought. Camels return to undisturbed desert once conditions are favourable (Naturebase, 2008).
Climate change
It is now widely substantiated that the Earth‘s climate is changing, with causes due to not only natural variation, but to the effect of rising greenhouse gases from human activity (NIWA, 2008). Climate changes around the world have been predicted over the next 100 years. The National Institute of Water and Atmospheric Research (NIWA) have projected changes in New Zealand‘s climate.
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While uncertainty exists regarding the magnitude of regional climate changes, certainty is growing as to the direction of expected changes over the coming century. These significant directions include: increasing temperatures over the whole country (2.1°C by 2090) increasing annual average rainfall in the west of the country and decreasing annual average rainfall in Northland and many eastern areas reductions in frosts increasing risk of dry periods or droughts in some eastern areas increasing frequency of heavy rainfall events rising sea levels.
The increase in temperature and drought could create arid grassland conditions suitable for camels to form a self-sustaining population. However it is highly likely that such lands will be highly managed to meet New Zealand‘s future agricultural needs in a more difficult situation rather than the abandonment of these lands to pests and weeds.
Summary of the suitability of the New Zealand Environment to Camels
In summary there are small and restricted parts of New Zealand where conditions may be suitable for camels. These are regions in Northland, such as Ninety Mile beach, where the climate (warm and dry) and topography (open sand dunes) could provide suitable camel habitat. Climate change may increase the suitability of some environments to camels.
Identification, Capture and Eradication of camels
Camels are able to be easily located. They are large (1.8-2.3 m shoulder height) and very distinctive and recognizable animals. They are larger than both cattle (up to 1.3 m) and horses (up to 1.85 m). Given their preference for open country they will be relatively easy to locate, especially in comparison to other large wild animals in New Zealand which prefer forested or mountainous habitats.
Camels are also relatively slow breeding. Gestation takes between 360-440 days and females generally give birth every two years to one infant (Nowack, 1999). Animals with low levels of breeding are far more at risk of extinction from human hunting (Barnosky et al, 2004) as in the case of wild Bactrian camel populations which are currently under severe threat from human hunting amongst other things (Reading et al, 1999).
We predict that eradication will not be difficult. This is based on the limited suitable habitat for camels in New Zealand. Additionally these areas are predicted to only be areas of open country making it an easy for humans to travel through with good visibility making eradication possible by shooting or other means.
12.1.7 In conclusion we do not predict that either the detection of camels or their eradication, should it be required, will be difficult.
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Summary of the Ability to form a self-sustaining population
In summary there are few locations in New Zealand suitable for camels and these locations are restricted in size. It is unlikely camels will be able to exceed the minimum viable population size for a self-sustaining population to form. If a self- sustaining population were to occur it would be restricted to very specific areas of New Zealand.
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Appendix 5 Australian Vertebrate Risk Assessment
Background to Vertebrate Pest Risk Assessment
Since the HSNO Act came1996 came into force more than 10 years ago, ERMA New Zealand has not received or processed a release application for a vertebrate. Taking guidance from our experience with release applications for plants which require a weed risk assessment we decided that a similar approach should be taken with this application. Although little has been done in this area, the Australians have produced an assessment tool for vertebrates (Bomford, 2003). The assessment consists of three parts: the information set, the risk assessment, and the determination of the Vertebrate Pest Committee (VPC) Threat Category. This process was followed as prescribed by Bomford (2003).
We note that the Australian authorities have undertaken risk assessments for Llama in New Zeeland and Camels in Australia. The llama was assessed of having a low chance of establishment in New Zealand, scoring 0 out of 13. Camels were assessed as having a moderate risk of establishment in Australia scoring 7 out of 16 (Bomford, 2008).
We have modified the Australian system where appropriate to deal with New Zealand conditions, these are indicated in the appropriate sections.
Information Set
Species to be categorised
Common name: dromedary camel, one-humped camel, camel
Scientific name: Camelus dromedarius
Classification: class Mammal, order Artiodactyla, family Camelidae
Present VPC Threat Category: Australian pest status 2 (moderate pest) (Bomford 2003).
Brief description of animal’s appearance:
―Single hump. Head and body length: 10 feet [3 m]. Shoulder height: 6-7 feet [1.8- 2.2 m]. Weight:1000-1500 pounds [450-680 kg]. Body is carried on long, slender legs ending in two toes beneath which is a broad, callous and elastic pad. Neck and head are both elongated. Upper lip is deeply cleft. Short tail. Eyes are heavily lashed. Ears are haired. Nostrils are slit-like. Coloration is fawn or beige. Coat is smooth and shorter than that of the Bactrian camel, but equally woolly.‖ (Oakland Zoo, No date).
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Ability to harm people
Is the animal ever aggressive?
Camels have been domesticated since at least 4000BC (Long, 2003) and despite a belief that they are bad-tempered those people who work with camels consider that only frightened or mistreated animals kick or spit and that they very rarely bite people (Explore the Outback, 2004-2008). Professor Yadil of Ben-Gurion University has worked with camels since 1969 and notes that they tend to be good-tempered, patient and intelligent (Yadil, 2003). He also reports that aggressive behaviour usually occurs during the breeding season and is focussed on other male camels although occasionally an attack on a human may occur (Yadil, 2006).
Are there any records of the species injuring people?
There is little evidence that camels have deliberately caused human death. A death was reported in Queensland, by a pet camel, in 2008 (MailOnline, 2007). The camel was a young male kept as a pet that killed its owner while over-excited. However there was uncertainty as to whether she died as a result of the action of the camel or from a heart attack (Williams, 2007). An expert in handling camels in Australia, Paddy McHugh, is quoted as saying ―…I can count on one hand the number of people that have been killed by camels in Australia in the past 100 years‖ (MailOnline, 2007).
What is the body weight range of adults?
Adult camels can weigh 300-690 kg.
Does the animal have organs capable of inflicting harm?
Camels do not have specific organs for inflicting harm but are capable of inflicting bite wounds that can in some circumstances require surgery particularly in the case of children (Suess et al, 2004). There is no data on the number of injuries inflicted by camels but it is unlikely to be any greater than those caused by horses, cattle, sheep or deer in New Zealand. To give some comparison for the number of animal related injuries that occur in New Zealand; for the year 2001-02, 58 regional authorities reported 3,020 dog attacks on people, which extrapolated to 3,435 across New Zealand. In the same period 8,677 accident compensation claims resulting from dog bites were lodged with ACC (DIA, 2003). It is highly unlikely that camel related injuries would ever be more than an occasional incident.
If the species release toxins that could harm people, is an antivenin available, and where?
Camels do not produce toxins harmful to people.
Could irresponsible use of products taken from captive individuals of the species (ie toxins) pose a public safety risk?
Camels do not produce any products that could be considered to be a public safety risk if used irresponsibly.
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World Distribution
Provide a map of current world geographic range of the species, separately marking native and exotic range.
Camels are found throughout Saharan and sub-Saharan north Africa, the Middle East as far east as north-western India. All camels found in this range are considered domesticated (Huffman, 2004). There are no camels found in the Americas. The Australian feral population is derived from domesticated camels that were released when no longer required by the transport industry. The Australian population is limited to the most arid regions of Australia (Siebert and Newman, 1989; Edwards et al, 2008).
Figure 1: Map of camel populations round the world (from Huffman (2004))
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Figure 2 Map of Australian camel distribution (from Edwards et al, 2008).
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List the countries where the species occurs naturally and also separately list any countries where the species has been successfully introduced and now occurs in the wild.
Camels only exist as domestic animals in their ‗natural‘ range. The countries in which camels naturally occur are: North Africa (Saharan and sub-Saharan Near and Middle East Africa) Algeria Afghanastan Chad Armenia Djibouti Azer Egypt Azerbaijan Eritrea Bahrain Ethiopia Georgia Kenya India (north-west border states: Jammu and Libya Kashmir, Himachal Pradesh, Punjab, Mali Haryana, Rajasthan, and Gujar) Mauritania Iran Morocco Iraq Niger Kazakhstan Senegal Kuwait Somalia Kyrgyzstan Sudan Lebanon Tunisia Pakistan Western Sahara Qatar Israel Russia (Caucasus region) Jordan Syria Saudi Arabia Tajikistan Yemen Turkey Oman Turkmenistan United Arab Emirate Uzbekistan
Camels have been introduced and have become established in the wild in Australia. Here they are limited to the arid deserts of Western Australia, South Australia, and the Northern Territory, with a small outlier in the dry interior of Queensland.
Migratory Behaviour
Is this species a regular migrant in any part of its native range?
In the native range there are no migratory populations of camels known. In Australia the only introduced population known camels are nomadic wandering in search of feed and water and may wander over areas of 450-7000km2 (Edwards et al, 2008). There may be seasonality to this wandering pattern that could be interpreted as migratory.
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Diet Group
Is the species carnivore/ herbivore/ omnivore and if a carnivore/ herbivore is it a generalist or a specialist?
Camels are strict herbivores with a broad, generalised browsing diet. They have a requirement for halophytes, salt containing plants, which can contribute 15% of their diet (Edwards et al, 2008).
Habitat
Can the species live in human-modified habitats?
In its ‗native‘ range camels are domesticated and tend to live in close proximity to people. In Australia camels have formed feral populations which are in the some of the driest and remotest parts of the content and not found in human-modified landscapes. Although they can live in a range of arid and semi-arid habitats their preference, in Australia, is for open bushland. This preference is attributed to rich and varied food supply regardless of season, open vegetation that provides easy observation of threats and the presence of shade trees in summer. Australian dense bushlands are generally avoided except for carving females seeking cover (Edwards et al, 2008).
Pest Status Overseas
Is this species considered a pest or has it ever been recorded causing damage to agriculture, livestock, poultry or forestry, or to native plants or animals or their habitats or otherwise disturbing natural communities?
Yes, camels are considered a moderate pest in Australia (Bomford, 2003). In arid Australia camels are considered capable of causing local extinction of preferred food species and to cause significant damage to marshland plants by congregating around waterholes during dry seasons (Edwards et al, 2008). There is no indication of camels having a serious impact on any agricultural sector other than at a nuisance level by breaking down fences and waterhole damage. The only figure available for economic damage is A$200, 000 pa. This compares with A$500,000 for feral horses, A$66.3 million for feral dogs, and A$106.5 million for feral pigs (Edwards et al, 2008).
Is the species a social nuisance or danger because of any other behaviour?
This was reviewed by Edwards et al (2008) and although there are reports of the occasional car accident, broken fences, and the breaking of sinks and toilet pans to get at water the damage is minimal.
Land Degradation and Damage to plants, Crops and Pastures from grazing and/or browsing?
As already notes camels can alter vegetation by selective browsing and damage natural waterhole vegetation by congregating during the dry season. There is no indication that there is any significant damage to crops however, a survey of pastoralists found 32% considered that there was a negative effect on cattle production through competition for food and water which was valued at A$3.42 million (Edwards
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et al, 2008). Conversely 5000 camels are being used in Queensland to control woody weeds such as prickly acacia (Acacia nilotica), mesquite (Prosopsis spp.) and parkinsonia (Parkinsonia aculeata) on pastoral land. There is no indication that camels spread weeds.
Harm to Animals
Does the species attack or prey on domestic or commercial animals?
No.
Does the species attack or prey on wildlife?
No.
If a mammal, can the species climb trees?
No.
Diseases and Parasites
Is the species susceptible to, or could it transmit, any diseases or parasites that can harm people?
Some camels have been reported as having brucellosis and TB. However, camels are unlikely to be anymore a source of pest and disease than any other livestock species. Camel diseases in Central Australia, such as those caused by internal parasites, sarcoptic mange, ringworm, nasal bots and Corynebacterium abscesses are common worldwide and readily treatable (Brown, 2004). In the case of TB it would appear that camels will only become infected if in close proximity to infected cattle and that they do not act as a reservoir of infection (Brown, 2004). The Australian camel population, both domestic and feral, are free from most serious diseases of livestock.
Competition for Resources
Could wild populations of the species use any resources that might cause it to compete with livestock?
As noted above camels are considered by some pastoralists to compete with cattle in arid Australia (Edwards et al, 2008). This claim has not been quantified.
Could wild populations of the species use the same resources as New Zealand native species?
Camels are creatures of dry arid environments and New Zealand does not have an equivalent habitat. It is unlikely that they would compete with native wildlife.
What nest sites can the species use?
Not applicable.
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Damage to Wetlands and Rivers
Does the species nest, shelter or feed in or around marshes or swamps?
Camels will congregate around water holes during a dry season.
Does the species nest, shelter or feed in or around estuaries?
No.
Does the species nest, shelter or feed in or around lakes ponds or dams?
Camels will congregate around water sources during a dry season.
Does the species nest, shelter or feed in or around rivers, channels or streams?
Camels will congregate around water sources during a dry season.
Does the species nest, shelter or feed in or around banks of water bodies?
Camels will congregate around water sources during a dry season.
Does the species nest, shelter or feed in or around coastal beaches or sand dunes?
Yes
Does the species construct burrows or dig near or around waterways?
No.
Does the species eat or disturb wetland vegetation?
As noted above camels will congregate around water during dry seasons and as there is usually vegetation around such water sources significant damage can be done (Edwards et al, 2008).
Could the species cause pollution of water bodies?
During dry seasons camels have been known to become mired in swampy ground around water sources. If an animal is unable to extract itself they have been known to die and pollute the water source (Edwards et al, 2008).
Damage to buildings, structures or equipment.
Could the species deface or physically damage buildings?
During dry seasons camels have been reported to drink from outside sinks, taps, and toilet bowls. In the process these can be damaged (Edwards et al, 2008).
Could the species damage fences?
Camels are known to damage fence when trying to reach food or water. The dog proof fence that extends from Queensland to the Great Australian Bight (South
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Australia) has approximately A$43,000 damage done to it annually by camels (Edwards et al, 2008).
Could the species damage equipment?
It is estimated that over the 2.22 million km2 range of camels in Australia they do A$2.4 million of infrastructural damage to pastoral properties. This includes damage to fences, yards, and water equipment (Edwards et al, 2008).
Hybridisation
Could the species hybridise with any New Zealand native species?
No.
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Vertebrate Pest Risk Assessment
The assessment requires the calculation of a score for each of the following questions. Justification for each score is provided.
A1, Risk to people from individual escapees (0-2)
This question only applies to animals that have escaped from captivity. We are unaware of any evidence or reports of camels causing injury from either unprovoked attacks on people or to animal handlers during routine work with camels. The few injuries we are aware of are related to males during the breeding season. Therefore we have scored this 0.
A2, Risk to public safety from individual captive animals (0-2)
This question assesses the risk from the irresponsible use of products from captive animals, such as toxins, and does not include injury resulting from the handling of animals. We are unaware of any evidence or reports that camels causing such injuries. Therefore we have scored this 0 (highly unlikely or not possible).
B1, Degree of climate match between species overseas range and New Zealand. (1-6)
This question requires the uses of CLIMATE software package to compare climates. We have not done this but rather compared the distribution of all known camel populations from around the world (Huffman, 2004; Edwards et al, 2008) using major climatic ‗regions‘ based on the Köppen classification (Peel, Finlayson, McMahon, 2007; Bureau of Meteorology, 2008). In Australia camels are restricted largely to desert regions with some spill-over into the surrounding arid grassland. Similarly in their natural range camels are found in Saharan and sub-Saharan Africa, arid to semi- arid Middle-east. There is no record of camels being found in the temperate classification to which New Zealand, southeast Australia and Tasmania are assigned. Therefore we have scored this 1 (very low).
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Figure 3: Map of climate classification of Australia (Bureau of Meteorology, 2008)
Figure :4 Map of Australian camel distribution (from Edwards et al, 2008).
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Figure 5: New Zealand has a similar temperate classification to which New Zealand, southeast Australia and Tasmania (from Peel, Finlayson, McMahon (2007))
Figure 6: Map of camel populations round the world (from Huffman (2004))
Map from Huffman (2004) showing that the distribution of camels in North Africa and the Middle East have similar climates to Central Australia and not New Zealand (compare Peel, Finlayson, McMahon (2007) and do not match the New Zealand climate.
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In addition we have mapped the Australian distribution onto New Zealand using Climatch. This resulted in a very low match between the Australian distribution and New Zealand. Of the total 4711 datapoints in New Zealand only 38 scored a 5/10 similarity score with the majority 2997 rated as 0/10 similarity.
Figure 7. Australian sites used for climate match
Figure 8. Australian climate match with New Zealand
B2, Exotic population established overseas (0-4)
This question is to establish whether or not exotic populations have established on land masses greater than 50,000 square kilometres (Tasmania is 67,800 square kilometres). The scoring is weighted towards establishment on land masses greater than 50,000 square kilometres. This is appropriate for assessing risk to the Australian mainland but not to New Zealand so we have removed this section from the model and adjusted it accordingly.
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B2, Exotic population established overseas (0-4)
This question is to establish whether or not exotic populations have established on land masses greater than 50,000 square kilometres (Tasmania is 67,800 square kilometres). The scoring is weighted towards establishment on land masses greater than 50,000 square kilometres. This is appropriate for assessing risk to the Australian mainland but not to New Zealand so we have removed this section from the model and adjusted it accordingly.
B3, Taxonomic score (0-1)
Camels are mammals so automatically score 1.
B4, Non-migratory behaviour (0-1)
Camels are non-migratory so automatically score 1.
B5, Diet (0-1)
Camels are generalist browsers so automatically score 1.
B6, Lives in disturbed habitat (0-1)
Feral camels are almost exclusively found in undisturbed habitats in Australia however in their natural range they are domesticated and will be found close to human habitation. Therefore we have scored this 0.
C1, Taxonomic group (0-4)
Camels belong to Artiodactyla so automatically score 2.
C2, Overseas range size (0-2)
Camels range over 3 million square kilometres in their natural range and and 2 million square kilometres in Australia. This is less than 10 million square kilometres so score 0.
C3, Diet and feeding (0-3)
Camels are primarily a browser so score 3.
C4, Competition with native fauna for tree hollows (0-2)
Camels do not use tree hollows so score 0.
C5, Overseas environmental pest status (0-3)
Camels are considered a moderate pest in Australia (Bomford, 2003) therefore we have scored this 2.
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C6, Climate match to areas with susceptible native species or communities (0-5)
This question is linked to B1. Our analysis is that there is no climate match between New Zealand and the current natural and feral range of camels therefore they are highly unlikely to threaten susceptible native species or communities. We have scored this 0.
C7, Overseas primary production pest status (0-3)
There is little data on the damage caused by camels but it appears that known damage is to fences and water supplies during drought (Edwards et al, 2008). As this damage is indirect and we have scored this as 1.
C8, Climate match to susceptible primary production (0-5)
As already noted in B1 and C6 there is not a climate match between New Zealand and the natural and feral range of camels. Therefore we have scored this 0.
C9, Spread disease (1-2)
As it is likely that camels will only be imported from Australia we have only considered the health of the Australian population. The Australian population is remarkably free of disease as a result of quarantine as a result of early quarantine efforts in Australia. As any importation into New Zealand from anywhere in the world will require suitable quarantine developed under the Biosecurity Act it is highly unlikely that these camels will carry any pest or disease into New Zealand. Mammals automatically score 2 however we believe that this is too high given the known health of the Australian population.
C10, Harm to property (0-3)
As noted in C7 camels do cause damage to fences and water sources during drought but this is poorly quantified but is likely to fall into the $1 - 10 million category so is scored 1.
C11, Harm to people (0-5)
There is no evidence or record of wild camels causing harm or annoying people; or acting as a reservoir or vector for parasites or disease that affect people. Therefore we have scored this 0.
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VPC Threat Category
Factor Descriptor Score A1 Risk to people from individual escapees (0-2) 0 A2 Risk to public safety from individual captive animals (0-2) 0
Stage Risk to public safety from captive or released individuals: A = A1 0 A + A2 (0-4) B1 Degree of climate match between species overseas range and New 1 Zealand (1-6) B2 Exotic population established overseas (0-4) B3 Taxonomic class (0-1) 1 B4 Non-migratory behaviour (0-1) 1 B5 Diet (0-1) 1 B6 Lives in disturbed habitat (0-1) 0
Stage Establishment risk score: B = B1 + B3 + B4 + B5 + B6 (1-10) 4 B C1 Taxonomic group (0-4) 2 C2 Overseas range size (0-2) 0 C3 Diet and feeding (0-3) 3 C4 Competition with native fauna for tree hollows (0-2) 0 C5 Overseas environmental pest status (0-3) 2 C6 Climate match to areas with susceptible native species or communities 0 (0-5) C7 Overseas primary production pest status (0-3) 1 C8 Climate match to susceptible primary production (0-5) 0 C9 Spread disease (1-2) 2 C10 Harm property (0-3) 1 C11 Harm people (0-5) 0 Stage Pest risk score for birds, mammals, reptiles and amphibians: 11 C C = C1 + C2 + C3 + C4 + C5 + C6 + C7 + C8 + C9 + C10 + C11 (1-37)
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Our scoring of camels produced: Risk to public safety – 0 Risk of establishing a wild population – 4 Risk of becoming a pest following establishment – 11
A score of 0 for risk to public safety considers camels to be not dangerous. A score of 4 for risk of establishing a wild population means that there is a low establishment risk. A score of 11 for risk of becoming a pest following establishment means that there is a moderate pest risk. Thus a score of ‗not dangerous‘, ‗low‘ and ‗moderate‘ equals a VPC Threat Category of Moderate. Given the lack of a climate match and the low score for risk of establishment it is our opinion that the scoring is conservative and that only one combination of risk scores out of 48 leads to a VPC Threat Category of Low.
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Appendix 6: Summary of consultation with District and Regional Councils, Non-Governmental Organisations and Iwi/Māori
Table 1 Regional councils consulted and feedback received.
Council Requested Application Summary of Feedback Ashburton District Council Auckland City Council Auckland Regional Council Banks Peninsula District Council Buller District Council Canterbury Regional Council Carterton District Council Central Hawke's Bay District Council Central Otago District Council Chatham Islands Council Christchurch City Council Clutha District Council Dunedin City Council Environment Bay of Plenty Notes two issues Environment Canterbury Environment Southland Do not oppose, note biosecurity Environment Waikato issues, make recommendations Far North District Council Franklin District Council Gisborne District Council Gore District Council Greater Wellington Regional Council No opinion, questions raised Grey District Council Hamilton City Council No opinion, Camels are low risk Hastings District Council Hauraki District Council No opinion, recommendations Hawke's Bay Regional Council made Horizon's Regional Council Horowhenua District Council Hutt City Council Hurunui District Council Invercargill City Council Kaikoura District Council Kaipara District Council Kapiti Coast District Council Kawerau District Council Mackenzie District Council Manawatu District Council No opinion, No concerns Manukau City Council Marlborough District Council No opinion, No concerns Masterton District Council Matamata-Piako District Council Napier City Council Nelson City Council
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Council Requested Application Summary of Feedback North Shore City Council Northland Regional Council Opotiki District Council Otorohanga District Council Otago Regional Council Palmerston North City Council Papakura District Council Porirua City Council Queenstown-Lakes District Council Rangitikei District Council Rodney District Council Rotorua District Council Ruapehu District Council Selwyn District Council South Taranaki District Council South Waikato District Council South Wairarapa District Council Southland District Council Southland Regional Council Stratford District Council Taranaki Regional Council Tararua District Council Tasman District Council Taupo District Council Tauranga City Council Thames-Coromandel District Council Timaru District Council Upper Hutt City Council Waikato District Council Waimakariri District Council Waimate District Council Waipa District Council Wairoa District Council Waitakere City Council Waitaki District Council Waitomo District Council Wanganui District Council Wellington City Council West Coast Regional Council Western Bay of Plenty District Council Westland District Council Whakatane District Council Whangarei District Council
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Table 2 Non-Governmental Organisations consulted and feedback received.
NGO Requested Application Summary of Feedback Action for Environment Inc. Baywatch Hawkes Bay Environment Group Buller Conservation Group Coromandel Watchdog of Hauraki Dunedin Environment Centre East Coast Bays Coastal Protection Society Eastern Bay of Islands Protection Society Eco (Environment and Conservation
Organisation of NZ) Ecologic Foundation Engineers for Social Responsibility Environment Centre Northland Environmental Futures Oppose, no benefits Federated Farmers No opinion, raised biosecurity issues Forest and Bird Oppose, environmental concerns Far North Environment Centre Friends of Golden Bay Friends of Nelson Haven and Tasman Bay Friends of the Earth - NZ Friends of the Shoreline National Council of Women of NZ Nelson Environment Centre South Coast Environment Society Te Aroha Earthwatch Thames Coast Preservation and Protection
Society Wildlife Society, NZVA
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Table 3. Response from Applicant led Iwi/Māori consultation9
Iwi/Māori Location Summary of Feedback Respondent No.
1 Raglan Oppose – have the potential to form self sustaining populations; displace native species, deteriorate natural habitats; adverse effects on human health and safety; effects on NZ inherent genetic diversity; possible vector for disease
2 Wellington Oppose – NZ landscape has already been dramatically changed by introduction of browsing & grazing animals - can‘t support a new species as need to enhance native flora & fauna
3 Wellington No opinion - requested further contact from applicant
4 Huntly No opinion - requested further contact from applicant
5 West Coast, South No opinion - requested further information; identified the Island need for an AEE and Cultural Impact Assessment as this is a new animal
6 Rotorua No opinion - requested further contact from the applicant
Table 4. Response from Agency led Iwi/Māori consultation
Iwi/Māori Location Summary of Feedback Respondent No.
7 Oppose - Potential risk of establishment of feral population; animal welfare; object to the granting of a full unconditional Christchurch release
8 (same as 6 above) Rotorua No opinion - requested further information
9 (same as 3 above) Wellington No opinion - requested a condition – sterilisation
10 Tauranga Oppose – desecration of waahi tapu area
11 Far North Oppose – novelty only; don‘t add to the natural environment in any way; potential worsen position of endangered endemic species; no korero on camels in our culture
12 Far North Oppose – don‘t want them in the North; don‘t want to have to police potential risks; pest; against full release
13 Gisborne Oppose – management by iwi of their cultural and natural resources will be severely impacted; would like to receive updates on progress
14 Far North Oppose – leave in their own country
9 In addition to the 18 responses from the first (applicant) round of consultation 12 of which stated they had no issues or comments to make and 6 of which stated they had no issues but wished to be informed on the progress of the project.
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15 Kaitaia No opposition
16 Tūrangi No issue
17 Far North No opinion – foreign animal altering the natural environment; might consumption of camel meat (alien to diet) impact on health & wellbeing of Maori; prefer to create economic growth via own natural resources; possible threat to native plants & animals; Treaty issues (indigenous human rights to natural resources and equitable wealth sharing between Government and Maori)
18 (same as 1) Raglan Oppose: rapid assessment process inappropriate; doesn‘t meet the requirements of the Methodology and Part 2 HSNO Act; dispute ease of eradication and camel management by DoC/local government; lack of full assessment on environmental effects eg on native birds, sand dunes; animal welfare and human health issues; Māori cultural issues; Treaty issues
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Appendix 7 MAF and DOC comments on the application and ERMA New Zealand Agency Response
Both MAF and DOC were given a chance to comment on the final application and the Agencies draft ecological risk assessment. The draft ecological risk assessment was provided to enable these Agencies to use the information contained within it to enhance their commentary as well as providing feedback to the Agency on any areas they had missed.
MAF response to application and draft ecological risk assessment
1. [Application] Section 4, Pg 12: As noted by the applicant, if the application is approved, the camels could not be imported for release into New Zealand without approval from MAF Biosecurity New Zealand. This approval will not be forthcoming in the absence of a relevant import health standard for camels. Although the applicant is anticipating that an existing import health standard for llamas and alpacas may be adapted for camels, the timetable for this, or the development of a separate import health standard, may be some time distant. MAF would need to ensure that a comprehensive risk assessment on camels had been carried out prior to any development of a new import health standard or modification of an existing one.
ERMA New Zealand notes this comment. 2. Draft risk assessment, Section 2.1.1, Pg 2: It is noted that the following references have not been listed in the reference section: Edwards et al, 2004; Naturebase, 2008, Edwards et al, 2008.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. These drafting errors will be corrected in the final Agency review report. 3. Draft risk assessment, Section 3.2.1, Pg 5: With the exception of Duncan et al, all the first set of references relate to establishment of birds. It would be helpful to explain how these are relevant to camels. Hayes, K R; Barry, S C (2008) Are there any consistent predictors of invasion success? Biological Invasions 10(4): 483-506. and Lockwood, J L; Cassey, P; Blackburn, T (2005) The role of propagule pressure in explaining species invasions. Trends in Ecology & Evolution 20(5): 223-228 are useful reviews across organism type.
ERMA New Zealand used these references in its draft ecological risk assessment as it is aware that birds are one of the most studied organisms with regard to factors determining successful invasion hence why they make up a significant number of references cited in this sentence. However, ERMA New Zealand would like to point out that this section is a background section and later case studies explore mammal specific issues. ERMA New Zealand has additionally looked at the references cited by MAF and included these in its assessment. 4. Draft risk assessment, Section 3.4.6, Pg 9: The word “carving” in the last sentence should be “calving”.
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ERMA New Zealand notes and acknowledges that this word was misspelt in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 5. Draft risk assessment, Section 3.4.11, Pg 9: The NIWA reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 6. Draft risk assessment, Section 3.8.2., Pg 11: It would be helpful to include comparable NZ climate data to support the statement in the first sentence.
ERMA New Zealand believes it is common knowledge that New Zealand has a high proportion of high latitude mountainous areas (similar to the Andes) in comparison to hot desert areas (similar to central Australia) which have both a warm and dry climate and open sand dune like topography. Therefore ERMA New Zealand has not included climatic data. 7. Draft risk assessment, Section 3.8.2., Pg 11: The Castillo-Ruiz and Lundrigan, 2007 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 8. Draft risk assessment, Section 3.8.2., Pg 11: The word “wooden” in the last sentence should by “woody”.
ERMA New Zealand notes and acknowledges that this word was misspelt in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 9. Draft risk assessment, Section 3.8.5., Pg 11: The Fraser and Parkes, 2005 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 10. Draft risk assessment, Section 3.8.6., Pg 11: The DOC, 2008 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA
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New Zealand could have missed. This mistake will be corrected in the final Agency review report. 11. Draft risk assessment, Section 3.8.7., Pg 11: The Fleury, 2006 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 12. Draft risk assessment, Section 3.8.8., Pg 12: Bullet point 1 – the definition in para 3.1.2 says without human interference – does shooting and capture constitute interference?
ERMA New Zealand agrees that the population was not self-sustaining in the presence of pressure from land development, increased competition with the activities of people, capture and hunting and that this drove down the number of wild horses and reduced their range to a fraction of its original extent. The wording has been modified to reflect this more clearly. 13. Draft risk assessment, Section 3.8.10., Pg 12: The Fraser and Parkes, 2005 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 14. Draft risk assessment, Section 3.8.12., Pg 12: The Gardiner, 2001 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 15. Draft risk assessment, Section 4.1.1., Pg 13: The Kohler-Röllefson, 2005 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 16. Draft risk assessment, Section 4.1.2., Pg 13: The Unklesbay, 1992 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA
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New Zealand could have missed. This mistake will be corrected in the final Agency review report. 17. Draft risk assessment, Section 4.1.2., Pg 13: The “Siebert” reference is listed as “Shiebert” in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 18. Draft risk assessment, Section 4.1.4., Pg 14: The Landsberg et al, 2001 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 19. Draft risk assessment, Section 4.1.5., Pg 14: The Rogers, 1991 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 20. Draft risk assessment, Section 4.2.2., Pg 15: The Department of Conservation, 2006 reference is not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 21. Draft risk assessment, Section 4.3.1., Pg 15: Weeds could also be spread in the dung.
ERMA New Zealand agrees and this assessment has now been added to the Agency review report. 22. Draft risk assessment, Section 4.3.2., Pg 15: The Roy et al, 2004 and Gouldthorpe, 2006 references are not in the reference list.
ERMA New Zealand notes and acknowledges that a number of references were missing in the draft ecological risk assessment but points out that the document referred to was only an early draft to enable MAF to identify additional issues ERMA New Zealand could have missed. This mistake will be corrected in the final Agency review report. 23. Draft risk assessment, Section 4.4.4., Pg 16: Not all nesting sites of rare New Zealand shorebirds are intensively managed so the word “some” should be inserted.
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ERMA New Zealand agrees with this comment and has amended accordingly. 24. Draft risk assessment, Section 4.6.1., Pg 17: It may be better to state that the effects may not be not be long term provided they are eradicated.
ERMA New Zealand believes that if a self-sustaining population was unable to form then the effects would be localised but not long term. We have therefore kept this text as is, however MAF is correct that if a self-sustaining population were to form then the damage would be long term only if eradication was not successful.
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Department of Conservation response to application and draft ecological risk assessment Summary 1. The Department of Conservation could find no significant evidence to oppose this application. We found varying information that demonstrates that feral camels cause a negative impact in Australia. However we acknowledge that the New Zealand experience is likely to be different, due to our smaller size and lack of arid environments.
ERMA New Zealand notes this comment and agrees that camels do pose problems in Australia and that while there are lessons we can take from their experience, the environmental conditions in Australia are radically different to those of New Zealand. Purpose Statement 2. The Department appreciates the applicant is aware that this application goes beyond their own venture, and will allow anyone, anywhere to import these camels into New Zealand (subject to import requirements). As such, we encourage the Authority to consider all areas of New Zealand as being potentially exposed to camels should this application be approved.
ERMA New Zealand notes this comment. 3. We question how the quoted figure of “more than $240,000” as gross income in the first year was reached? There is no indication of demand for camel trekking in New Zealand, let alone in the Bay of Plenty. As horse trekking numbers have been quoted, we consider it relevant to point out that some of the areas the horses go may not be accessible to camels, given their larger size.
ERMA New Zealand notes that the applicant has conservatively based their gross income on the formula: $50 fee per person per ride; 2 people per camel x 6 camels x 2 per day x 5 days per week x 40 weeks. It is difficult to assess this figure but we do note they wish to only trek on areas accessible to camels. Organism Description 4. The Department has no concerns over the description of the organism. Application type 5. The criteria for a „full release by rapid assessment‟ application include the organism‟s ability to form a self sustaining population, taking into account the ease of eradication. We accept that biologically camels are likely to be comparatively easy to eradicate, given their large size and relatively low reproductive rate. However we question whether the criterion would be met in a social sense. The Department has faced significant social pressure and criticism for the management of feral Kaimanawa horses, often leading to a smaller number removed than originally intended and/or more costly options required to be used. It is possible that DOC (and other agencies, such as local governments, involved in eradication programmes) may face the same social pressure over any necessary camel eradication programmes. Furthermore, any eradication programme is likely to be costly, with the most successful method likely to be shooting them – either from a helicopter or the ground.
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ERMA New Zealand notes the points raised. We agree that social pressures could influence the ease of eradication and have added in an assessment of camels being beneficial to society and community due to their use as pets or valued species. This analysis has been used to clarify the possibility that social pressure will affect the ease of eradication. Risks to the environment 6. We do have concerns for our conservation areas, given the Department of Environment and Conservation in Western Australia states that camels pose a direct threat to areas of high conservation value10. Their interpretation of research from the Northern Territory showed that, in some areas, two camels every square kilometre is enough to cause environmental degradation, and may also be enough to cause species loss or decline11. In our opinion this suggests that it does not necessarily take large numbers of camels to cause environment damage. Camels have been observed to eat the fruit, leaves and stems of many shrubs and have badly damaged some native trees in Australia12. Their long legs and neck will enable them to reach a higher browse height than any of the mammals already introduced and now wild in New Zealand, adding to the browsing pressure already experienced via wild goats and deer.
ERMA New Zealand has assessed the risk of damage to flora and fauna from camel grazing and trampling (see 8.22 to 8.2.21). 7. The Department of Conservation and the Animal Health Board (AHB) have for many years been involved in a programme to eradicate bovine tuberculosis from New Zealand. A major problem is the feral population of brush-tailed possums that act as hosts for this disease. The World Organisation for Animal Health (OIE) lists camels as a host for bovine tuberculosis13. It would be a concern if this approval resulted in a population that acted as a further reservoir for this disease, and hindered the Bovine Tb eradication programme.
ERMA New Zealand has assessed the risk to human health from bovine tuberculosis in sections (8.3.5 to 8.3.8 ). We note that it is a known host but not a known vector meaning it is unlikely to spread bovine tuberculosis to other animals.
10 http://www.dec.wa.gov.au/science-and-research/animal-research/feral-camels-in-western-australia/impacts-and-control- measures.html [cited 4 Feb 2009] 11 http://www.dec.wa.gov.au/science-and-research/animal-research/feral-camels-in-western-australia/impacts-and-control- measures.html [cited 4 Feb 2009] 12 http://www.agric.wa.gov.au/content/pw/vp/fer/f12200.pdf [cited 4 February 2009] 13 http://www.oie.int/eng/ressources/BOVINETB_EN_DC.pdf [cited 11 February 2009]
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Appendix 8 References contained within this Report
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