Submissions

Federated Farmers Submission on “Streamlining the regulatory regime for pest control” consultation document

Federated Farmers supports the proposal to streamline – for defined circumstances - the regulatory regime for pest control with respect to the application of certain Vertebrate Toxic Agents using section 360(1)(h) of the Resource Management Act 1991.

The Federation supports the scope of Parts 1 – 3 of the proposal, being applicable to:
[Part 1] A VTA that has been through a full assessment under section 28A (Determination of applications) or section 69 (Reassessment) of the HSNO Act (1996) OR
[Party 2] A VTA that has been through a rapid assessment under section 28A (Rapid assessment for importation or manufacture of hazardous substances) provided a full assessment under section 29 or 63 has been completed for the active ingredient in the formulation.
[Part 3] Brodifacoum use compliant with the conditions of registration placed on the relevant products and used in off-shore islands or within fenced sanctuaries.

The Federation further supports that the regulation include conditions around obtaining occupier permission, providing information to councils about planned operations and requiring compliance with HSNO controls. While outside the scope of the current consultation process, the Federation notes that the s 360(1)(h) RMA regulatory option may also usefully be considered for the management of other significant pests using agents other than VTA’s providing that the necessary (eg) HSNO assessment process has been followed.

These matters are discussed in more detail in the submission and the Federation would be pleased to discuss these issues if necessary, with David Burt the contact person at Federated Farmers in the first instance.