Dear Environmental Protection Authority,

Are pest contractors working on contract for regional councils, and/or regional councils themselves, required by law to report all aerial 1080 operations conducted by or for them, and accidents/incidents within those operations, to the EPA?

Is there a time restriction for this to be done in order to be included in your annual reports? Whose responsibility is it - the pest contractor or the council?

Is failure to do this a breach, and if so, what action is taken?

I'm conscious that your 2017 annual report states that there were no aerial 1080 operations done by regional councils.
I know this is incorrect and as the Chair of the Environmental and Services Performance Committee for Waikato Regional Council, it concerns me that data is missing from your reports. Do you have anyone checking regional councils' PPCA plans for instance or prompting them for information before you produce your annual reports? Do you amend your annual reports in any way if you are given data about livestock deaths in council operations after reports have been produced? Is the government given updated information about operations and incidents that have been omitted?

I see that there have been a number of years that the EPA has reported as many as a third of 1080 aerial operations having incidents or misapplications of bait. For example 2016 and 2011. This seems like a large proportion of incidents and errors with bait application. Is this of concern to you? Please advise what action has been taken or is about to be taken regarding this concerning level of errors within operations.

I have had direct contact with farmers who have told me stories that are different to what has been reported by pest contractors especially in terms of pilots flying through no-fly zones and dropping bait on livestock. This should be of concern to MPI not only in terms of animal welfare legislation but also in terms of our meat export reputation. How do you check that pest contractors are giving you accurate information? Do you randomly contact farmers for instance? Is action taken against pest contractors who misrepresent a poisoning operation?

I commented recently to the media about a third of 1080 aerial operations having incidents and accidents with bait ending up in places it shouldn't. Up until then, you had always included a summary of incident details in your annual report. Since then, your latest annual report on 1080 drops has left out these details. Why did you decide to omit the summary? I feel it was a helpful section that enabled people to quickly see if information had been accurately reported to you. Failure to include this will lead to more lack of transparency in aerial 1080 operations and inability for councillors and other decision-makers to appropriately assess the risk of 1080 poison within our communities.

Many thanks in advance for answers to these questions.

Yours faithfully

Kathy White