Staff Assessment Report APP203875

Home , Epipompilus, Forest ringlet, Insect sting allergy, Lasioglossum sordidum, Metoecus, Metoecus paradoxus

Staff Assessment Report

APP203875:

An application to import and release two biological control agents to control German and common wasps.

Purpose To release two parasitoids, Metoecus paradoxus and Volucella inanis, as biological control agents for the invasive German and common wasps (Vespula germanica and V. vulgaris).

Application number APP203875

Application type Notified, Full Release

Applicant Tasman District Council

Date formally received 14 September 2020

1 EPA advice for APP203 875

Executive Summary and Recommendation

In September 2020, the Tasman District Council on behalf of the Vespula Biocontrol Action Group submitted an application to the Environmental Protection Authority (EPA) seeking pre-approval to release two biological control agents (BCAs) for the German wasp and the common wasp. The research and background study was conducted by Manaaki Whenua Landcare Research New Zealand Limited.

The application was publicly notified. The EPA received 30 submissions, 25 submissions supported the application, two submissions neither supported nor opposed and three submissions opposed the application.

The EPA assessed the risks, costs and benefits of the release of the two BCAs in the context of the environment, market economy, people and communities, public health and on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna, and other taonga.

Regarding the environment, we assessed that the benefits from the release of the BCAs would be highly likely to improve biodiversity and reduce the amount of fertiliser used by the pastoral sector. We noted that the impact would be major in areas highly infested by wasps. We concluded that the release of these BCAs could potentially have a high impact on the environment with the decrease of chemical usage and the re-emergence of the native biodiversity.

Regarding the economy, we assessed the benefits would be highly likely to have minor to moderate regional economic impact for apiarists and farmers depending on the degree of infestation, via the reduction of wasp impact cost on bees and the increase of honey production. In addition, the increase in natural pollination would reduce the quantity of fertiliser and sowing needed by the pastoral industry. We noted that the BCAs are also likely to have a minor to moderate regional impact on the tourism industry with the sustainability of tourist attractions and the decrease of the cost associated with the management of wasps. We concluded that the release of the two BCAs could have a low to medium impact on the market economy depending on the region and the level of wasp infestation.

Regarding public health benefits, we considered that if the introduction of the two BCAs is successful, there is likely to be a reduction in the number of people encountering pest wasps. This in turn is likely to reduce the number of severe allergic reactions leading to death and traffic accidents attributed to wasps. However, casualties would not be eliminated from the release of the BCAs. We concluded that from the individual’s perspective, the benefits could be significant for those who are highly allergic to wasps, whereas it would be low at the general community level.

Regarding people and communities, the release of the BCAs is likely to have moderate impacts locally where large wasp infestations exist. Overall, the level of benefits on the community would be low to medium at the local and national levels.

Regarding the risk for the environment, we assessed that the release of the two BCAs is unlikely to impact the amount of pesticides used in organic gardens or to impact native species or valued exotic species due to the host specificity of the two BCAs. We noted that V. inanis is likely to increase competition for pollen and nectar and could have a minor impact on the food-webs, however, we considered that the mitigation of wasp populations would have lesser adverse effects. We noted that the two BCAs are highly unlikely to hybridise with native species in the absence of species in the same genus. We concluded that any adverse effects on the environment would be minimal to minor and the effects are expected to be low.

Regarding the economy, we concluded that the release of the BCAs is likely to have a minimal adverse impact on pesticides sellers and a minor adverse impact on pest control companies especially

EPA advice for APP203 875

for regions highly infested by wasps. Overall, we concluded that the level of risks on New Zealand’s market economy is low.

Regarding public health, we considered that the release of the two BCAs is highly improbable to have adverse effects as neither BCAs sting or are known to vector diseases. The overall level of risks is assessed to be negligible.

The application was also assessed against the minimum standards in the HSNO Act, and the EPA concluded that the two BCAs meet the minimum standards. The potential risks to Māori interests from the release of the BCAs are likely to be acceptable in terms of Māori cultural beliefs and environmental frameworks.

We found the benefits of the release of the two BCAs outweigh the risks and costs. We recommend the decision-making committee approve the release of Metoecus paradoxus and Volucella inanis as biological control agents for Vespula germanica and V. vulgaris.

EPA advice for APP203 875

Contents

Purpose of this document ...... 6

Application process ...... 6

Submissions ...... 6 The target hosts ...... 7 Vespula vulgaris ...... 8

Biology and ecology ...... 8

Habitats and distribution ...... 9

Vespula germanica ...... 10

Biology and ecology ...... 11

Habitats and distribution ...... 11

Current strategies to control V. vulgaris and V. germanica ...... 12 The proposed biological control agents ...... 14 Volucella inanis (Linnaeus, 1758)...... 14

Metoecus paradoxus (Linnaeus, 1761) ...... 15

Acclimation to New Zealand ...... 17 Host specificity ...... 18 Phylogeny ...... 18

Behaviour: social versus solitary ...... 19

Life cycle ...... 20

Nesting ...... 21

Habitat ...... 21

Mimicry ...... 22

Host-range testing ...... 23

Conclusion ...... 23 Risk assessment ...... 24 Potential benefits from the release of the BCAs ...... 24

Environment ...... 24

Economy ...... 28

Public health ...... 32

EPA advice for APP203 875

People and communities ...... 33

Potential risks from the release of the two BCAs ...... 34

Environment ...... 34

Economy ...... 37

Public health ...... 37

Conclusion on benefits and risks assessment ...... 38

Relationship of Māori to the environment ...... 40

Summary of the applicant’s engagement with Māori ...... 40

Submissions from Māori on this application ...... 40

Kaupapa Kura Taiao cultural risk assessment ...... 40

Assessment against the Minimum Standards...... 42 Recommendation...... 43

References ...... 44 Appendix 1: Summary of submissions ...... 49 Appendix 2: Māori Perspectives Report (MPR) ...... 52

EPA advice for APP203 875

Purpose of this document

The Tasman District Council applied to the Environmental Protection Authority (EPA) seeking approval to release the hoverfly, Volucella inanis, and the beetle, Metoecus paradoxus, as biological control agents (BCAs) for German and common wasps (Vespula germanica and V. vulgaris) in New Zealand. Manaaki Whenua Landcare Research New Zealand Limited has prepared and managed the application process on behalf of the applicant.

This document has been prepared by EPA staff to advise the Decision-making Committee on our assessment of the risks and benefits of the release of M. paradoxus and V. inanis. The document discusses the information provided in the application, information readily available in scientific literature, and information submitted to the EPA during the public notification process.

Application process

The applicants lodged an application with the EPA on 14 September 2020 under section 34 of the Hazardous Substances and New Organisms (HSNO) Act (the Act).

The application was publicly notified, and open for submissions for 30 working days on 28 September 2020 as required by section 53(1)(b) of the Act. The submission period ended on 10 November 2020.

Submissions

The EPA received 30 submissions on this application. The submissions are summarised in Appendix 1, with 25 submissions supporting the application, two neither opposed nor supporting, and three submissions opposed to the application.

In addition to the submissions, the EPA received supportive and non-supportive comments via social media channels. People opposed to the release mentioned the risk of the new organisms changing their behaviour to target native species or their potential to disturb the ecosystem equilibrium such as the introduction of possums and stoats. Whereas people in support underlined the adverse impacts of wasps as well as the need of a robust study to ensure that the BCAs will not target native species once established.

We received submissions from regional councils, Te Rūnanga o Ngāi Tahu, the Department of Conservation (DOC), the Ministry for Primary Industries (MPI) and individuals. Since seven submitters requested to be heard, a hearing will be held for this application.

Submissions from DOC and MPI

As required by the Act and the Hazardous Substances and New Organisms (Methodology) Order 1998, MPI and DOC were notified of the application and provided with the opportunity to comment.

EPA advice for APP203 875

MPI supported the application. They considered that the biosecurity risks of releasing the parasitoids are likely to be negligible whereas, the benefits to the New Zealand environment, economy and society are likely to be minor to moderate. If the BCAs established in high numbers it would reduce damage to New Zealand ecosystems, control costs and negative impacts on human health and well-being as well as benefiting New Zealand’s apiculture industry. However, MPI noted that the application did not provide sufficient information on the BCAs impact on wasp populations. In addition, they noted that the lack of host range testing makes the evidence case less robust compared to previous full release BCA applications (submission 127677).

DOC strongly supported the release of the two BCAs due to the adverse impact of Vespula wasps on New Zealand biodiversity and the high host specificity of the BCAs demonstrated by the applicant (submission 127662). The target hosts

In New Zealand, five social wasp species in the Vespidae family have been accidentally introduced: the Asian paper wasp (Polistes chinensis), the Australian paper wasp (Polistes tasmaniensis humilis), the European paper wasp (Polistes dominula), the German wasp (Vespula germanica) and the common wasp (Vespula vulgaris).

The German and the common wasps are widespread throughout New Zealand and are considered a nuisance (Department of Conservation 2006). These two wasp species are very similar in appearance with characteristic black and yellow colouration. Distinguishing marks include a black mark behind the eye of the common wasp and almost parallel black rings on the abdomen, whereas the German wasp usually has V-shaped rings with distinct black dots (Fig. 1).

Figure 1: Difference between the common (left) and German wasps (right) (Source: https://www.gopest.co.nz/wasp-control)

Vespula wasps are eusocial1 insects with an annual life cycle. The colony builds a nest with honeycomb-like cells made of a mixture of plant fibres and salivary secretions. On average, V. vulgaris and V. germanica nest produce between 11,000 and 13,000 workers and 1,000 to 2,000 queens in a season (Kyd Beth 2015).

1 Eusocial insects: insects that live in a colony with only some individuals capable of reproducing. Usually there is a division of labour with different individuals undertaking different roles, such as defence or foraging (e.g. bees, ants and wasps). 7

EPA advice for APP203 875

New Zealand has one of the highest densities of German and common wasps in the world (Barlow et al. 1996) attributed to the lack of predators, plentiful available resources, a mild climate and their capacity to produce thousands of queens per nest (Donovan 1991). They are particularly abundant where honeydew, produced by indigenous scale insects (Coelostomidiidae) and the giant willow aphid (Tuberolachnus salignus) are present in copious quantities (Brown & Groenteman 2017).

Vespula wasps forage proteins from a wide range of insects (dead or alive) and human food (meat and fish), as well as carbohydrates through nectar, honeydew, honey produced by bees and scavenged human food (jam and fruit juice) (Spurr 1995).

Their high numbers and voracious appetite cause adverse effects on our biodiversity as well as on recreational activities and the economy (MacIntyre & Hellstrom 2015).

Vespula vulgaris

Vespula vulgaris (Table 1) is a medium sized social wasp with workers measuring 11 - 14 mm long.

Table 1: Taxonomic classification of Vespula vulgaris.

Taxonomic Unit Classification

Order Hymenoptera

Suborder Apocrita

Infraorder Aculeata

Superfamily Vespoidea

Family Vespidae

Genus Vespula

Species V. vulgaris (Linnaeus, 1758)

Common name Common wasp, European wasp, common yellow-jacket

Biology and ecology

The annual lifecycle of V. vulgaris begins in early spring (late September to early October) when single-mated queen wasps emerge from hibernation searching for a suitable place to start building their nests to lay eggs. Common wasps build their nests anywhere that is dry and undisturbed. They can be found in lofts, sheds, old animal burrows in the ground, inside cavity walls and chimneys (T.E.R.R.A.I.N. 2017).

After 30 days, the first batch of offspring, containing only sterile female adult workers, emerge and take over the foraging, brood care and nest building from the queen who remains in the nest to lay on average 100 eggs per day (Wasp removal UK 2011).

EPA advice for APP203 875

The workers bring prey to the nest to feed the carnivorous hatching larvae. In return, the larvae regurgitate parts of the prey, producing a sugary liquid to feed the workers. After a couple of weeks, the larvae spin a cap on top of their cells and pupate (Wasp removal UK 2011).

The colony continues to grow towards the end of summer – beginning of autumn where it reaches its maximum size. At this stage, the queen lays sexual brood, producing 1000 to 1500 new queens. It is believed that once these virgin queens and male drone wasps leave the nest, they navigate to particular mating areas where drones will only mate with virgin queens from other nests to avoid interbreeding (Wasp removal UK 2011).

Vespula vulgaris forages more on shrubs and tree saplings mainly targeting Diptera and Araneae. Harris and Oliver estimated that the species collects an average of 600g of prey per nest per season (Harris & Oliver 1993).

The drones die after mating whereas the mated queens hibernate over winter. In the absence of larvae in the existing nest, workers are left without food and foraging becomes erratic. The colony starts to decline and the nest dies (Wasp removal UK 2011). However, in warmer climates, such as in New Zealand, nests of V. vulgaris have been observed to stay active during winter but do not seem to produce queens and drones the following year (Plunkett et al. 1989).

Habitats and distribution

Nearctic Palearctic Neotropical Afrotropical Oriental Australian

Holarctic

Figure 2: Realms of the world (Wikipedia based map)

Vespula vulgaris are found in a wide range of habitats, from managed forests (including plantations and orchards), urban and peri-urban areas, to natural forests (including scrub and shrublands) (CABI 2009).

The original distribution range of V. vulgaris was the Holarctic region (Fig. 2) suggesting that the species can tolerate a plethora of climates. Vespula vulgaris established in Australia before 1961 and by 1973 it was present in Hawaii, United States.

EPA advice for APP203 875

One or more fertilised queens are believed to have arrived in New Zealand on ships or aircraft as early as 1921. The common wasp was considered established in 1978 in Wellington and spread rapidly. In 1983, it was observed in Dunedin and locally abundant in Christchurch. (Donovan 1984). A 1990 map of V. vulgaris distribution in New Zealand shows how widespread the species is (Fig. 3).

Figure 3: Distribution of Vespula vulgaris in 1990 (Source: MWLR).

Vespula germanica

Vespula germanica (Table 2) workers are medium sized wasps (12-15 mm in length), slightly bigger than V. vulgaris.

Table 2: Taxonomic classification of Vespula germanica.

Taxonomic Unit Classification

Order Hymenoptera

Suborder Apocrita

Infraorder Aculeata

Superfamily Vespoidea

Family Vespidae

Genus Vespula

Species V. germanica (Fabricius 1793)

Common name German wasp, European wasp

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Biology and ecology

Vespula germanica shares a similar life-cycle to V. vulgaris. Every colony starts with a single queen emerging from hibernation at the beginning of spring. The queen starts building its nest to lay eggs and rears the first brood of workers. After developing into adults, the first batch of workers replace the queen as the foraging force and continue building combs. From this point, the queen’s sole purpose is to produce eggs to rapidly expand the worker population.

At the end of summer, when the colony reaches the size of a football with several thousand adult workers, the queen stops producing workers and lays sexual brood on larger combs. Finally, when the virgin queens and drones leave the nest, the colony cohesion breaks down and starts to decline (Manaaki Whenua Landcare Research 2014).

Single-mated queens hibernate over winter in well-insulated environments such as leaf litter, under tree bark or crevices in buildings. The queens emerge in spring and start searching for a hidden site to build their nests such as underground, behind retaining walls and rockeries in gardens, cavity walls or roof spaces buildings and abandoned burrows of rodents and rabbits (CABI 2008). They mainly build their nests below ground.

German wasps can be found in cultivated land, rails and roadsides, urban and peri-urban areas, buildings, natural forests and riverbanks (CABI 2008).

Vespula germanica collects three times more prey than V. vulgaris, with an average of 1800g of prey per nest per season. The species forages more commonly amongst the forest litter to find protein and similarly to V. germanica target mainly Diptera and Araneae prey (Harris & Oliver 1993).

In New Zealand, 10 percent of V. germanica colonies have been found overwintering (Harris 1996). German wasps have also been observed reusing an existing nest with young queens returning to their nest to lay eggs. This perennial behaviour helps nests to reach prodigious sizes, ranging from a football-sized with a few thousand cells to a few metres with hundreds of thousands of cells (Department of Conservation 2017). One of the world's largest wasp nest (3.75 metres tall and 1.7 metres wide and about 5.5 metres in circumference) was discovered at Waimaukau (near Auckland) in 1963 (Department of Conservation 2017).

Habitats and distribution

German wasps are found in many types of temperate habitats. They occur in forests (natural and exotic), shrubland, and in urban and agricultural areas (New Zealand Plant Conservation Network 2008).

Vespula germanica is a species of Palaearctic origin (Fig. 2). It is native to Europe, northern Africa and Asia, and was introduced to North America, Chile, Argentina, Iceland, Ascension Island, South Africa, Australia and New Zealand. However, the species has not yet reached its full potential as it could establish in many other parts of the world such as western USA, Mexico, areas in Central America and South America, eastern Brazil, western Russia, north-western China, Japan, the Mediterranean coastal regions of North Africa, and parts of southern and eastern Africa (De Villiers et al. 2017).

EPA advice for APP203 875

It was first recorded in New Zealand in 1944, then in Australia (1959), South Africa (1972), United States (New York 1891, Maryland 1968, California 1991), Canada (1971), Chile (1974) and Argentina (1978) (Spradbery & Dvorak 2013).

The introduction and establishment of V. germanica began in Hamilton where seven nests were reported in 1945, possibly due to an accidental importation of queen wasps hibernating on wooden crates containing spare aircraft parts from the United Kingdom. The German wasp quickly spread throughout the North Island with more than 6,000 nests recorded in 1951 (Thomas 1960) and reached the South Island by the mid-1950s.

A 1990 map of the New Zealand distribution of V. germanica shows how widespread the species is (Fig. 4).

Figure 4: Distribution of Vespula germanica in 1990 (Source: MWLR).

Despite being established in New Zealand more than 30 years prior to the common wasp, the German wasp had been almost totally displaced by the common wasp by 1990 in honeydew beech forests and accounted for a higher proportion in rural areas later in the South Island (Clapperton et al. 1994). The success of common wasps over German wasps is attributed to their efficiency to harvest honeydew (Manaaki Whenua Landcare Research 2014).

Current strategies to control V. vulgaris and V. germanica

Vespula wasps are highly invasive species and considered as significant pests in New Zealand. They are predominantly controlled by chemical methods. However, these methods are limited in their efficacy when infestations are either inaccessible or inconspicuous and by the lack of workforce to administer chemical pesticides.

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Physical control

Physical control involves removing nests. Early wasp nests are difficult to locate as they are small and hidden, whereas developed and growing nests are busy with worker wasps however they are more dangerous to approach without appropriate safety equipment.

An effective option to control pest wasp populations would be to target hibernating queens and therefore reduce the breeding source. In 1948, the New Zealand Department of Agriculture offered a financial reward in exchange for each queen killed. However, despite the 118,000 queens collected that year, it had no significant effect on the population density as every single remaining queen was able to produce a thousand queens the following year (Thomas 1960).

Chemical control

Various household products and pesticides are available in New Zealand, however, these products are not wasp specific, can be dangerous for other non-target organisms and increase environmental toxicity. In addition, these products have a limited impact on localised wasp populations.

In 2015, the company Merchento, in conjunction with DOC, developed bait stations suited to treat large areas infested with wasps. The protein based bait, Vespex, is highly attractive for Vespula wasps but not for bees. Vespex also has a very low toxicity level for other organisms, including people (Merchento 2015).

Vespex is a slow-acting pesticide which wasps gather from bait stations and bring back to their nests where it is shared through the colony including the queen. Only a small quantity of Vespex is required to destroy a whole nest. The product is highly effective in summer when wasps have a high demand for protein (Merchento 2015). In 2015, trials in five locations across the South Island achieved between 95 to 100 percent eradication (Department of Conservation 2016). However, trials have shown that baits are unsuccessful to target early nests as queens and early season wasps have low requirements for proteins (Merchento 2015).

Mr Buckland, Mr Frost, and the Biosecurity Working Group (a collective of all 16 regional and unitary authority biosecurity representatives and experts) mentioned the high cost of controlling wasps with chemicals such as Vespex and their localised action. They also noted that the timeframe of chemical efficacy happens after the wasps have already impacted prey populations, honeydew production and the bird nesting season (submission 127667, 127675, and 127669).

Despite their effectiveness, pesticides have a localised and seasonal impact. Furthermore, they require an annual application due to the reinvasion by queen wasps the following spring (Manaaki Whenua Landcare Research 2014). Therefore, these type of controls require a high labour cost and inaccessible wasp populations remain a threat for biodiversity as well as a source of continuous invasions.

Biological control

Biological control agents (BCAs) to control Vespula species have been used previously in New Zealand with limited success.

EPA advice for APP203 875

Since 1985, a small parasitoid wasp, Sphecophaga vesparum vesparum, has been released to control populations of V. germanica and V. vulgaris. Despite its wide release, its establishment has only been confirmed in two sites (Pelorus Bridge – Marlborough, and Ashley Forest – Canterbury). However, the increased population of the parasitoid since the first release on these two sites did not show a reduction in wasp nest density (Beggs et al. 1996). In 2016, a wasp nest was found highly infested by Sphecophaga in View Hills (Canterbury) but two years later none were found during a survey in the same area (Brown 2018).

Another BCA subspecies of Sphecophaga, S. v. burra, adapted to a different climate, was also imported. First in 1979, but the population was extinct in 1982. The BCA was released again between 1991 and 1996 in seven sites across the two main islands. However, in 2001 no evidence of the BCA subspecies’ establishment was found (Beggs et al. 2002).

Despite these examples, biological control is still considered as the only viable option to achieve long-term and financially viable suppression of wasp densities in native ecosystems due to the widespread nature of the problem. The proposed biological control agents

Volucella inanis (Linnaeus, 1758)

Species within the family Syrphidae are known as flower flies or hoverflies because they are frequently seen visiting flowers. Some mimic the colouration of wasps or bees to ward off predators (Azmeh 1999).

Adults feed on nectar and pollen and are important pollinators while larvae devour a wide range of food including aphids, caterpillars and other small insects. Some flower hoverfly species (e.g. Episyrphus balteatus) who prey on pest insects such as aphids and Figure 5: Volucella inanis by B. Brown wasps are used as BCAs (Sengupta et al. 2016; Singh & Singh 2016).

Volucella inanis (Table 3) is a large hoverfly (15-16 mm length). Its black and yellow colours greatly resemble wasps (Fig. 5). Their physical mimicry with wasps is associated by potential predators as an undesirable, unpalatable prey with a noxious sting.

The species has a Palearctic distribution (Fig. 2) with observations throughout Europe, the Mediterranean sea as well as from Asia to the Pacific coast (van Veen 2004; Khaghaninia et al. 2010). It occurs mainly in summer (June to early September), at almost all altitudes where forest is present (De Groot 2012).

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Volucella inanis is an obligate ectoparasite2 and has been found in association with social wasps, in particular V. vulgaris and V. germanica (table 2 of the application form). The hoverfly uses host odour and visual cues to find a suitable host nest (Rupp 1989).

Table 3: Taxonomic classification of Volucella inanis.

Taxonomic Unit Classification

Order Diptera

Family Syrphidae

Sub-family Eristalinae

Tribe Volucellini

Genus Volucella

Species Volucella inanis (Linnaeus, 1758)

Synonyms Musca inanis, Musca annulata, Volucella annulata

Females must approach the nest of Vespid wasps to deposit their eggs at the nest entrance, or inside if there are no guard wasps and only a few workers remain. On average, a female carries 300 - 660 eggs and lays up to 150 eggs in one spot (Rupp 1989). The applicant reported that in the wild, females V. inanis were not recognised as a threat to wasps when approaching a nest (pers. observations).

Larvae are flat to fit into the space between the cell wall of a comb and the host larva on which they feed. According to their life cycle, one V. inanis larva needs to consume at least two wasp larvae to complete its development inside the wasp comb. The BCA was found from June to the end of September in V. germanica nests, but the main season extends from mid-July to the end of August in Europe (Ball & Morris 2000). The mature hoverfly larva leaves the cell and burrows into the ground beneath the host nest for diapause (Rupp 1989).

Metoecus paradoxus (Linnaeus, 1761)

Species in the Metoecus genus are exclusively solitary, idiobiont parasitoids3 of eusocial Vespidae. The wasp-nest beetle, M. paradoxus, is known to parasitise species in the subfamily Vespinae (Table 1 of the application form), with a preference for the common wasp, V. vulgaris (Heitmans & Peeters 1996).

2 a parasite, such as a flea, that lives on the outside of its host. 3 Idiobiont parasitoids are those that prevent further development of the host after initial parasitisation 15

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Metoecus paradoxus (Table 4) is a medium sized (about 10 mm) parasitoid beetle (Fig. 6) (Heitmans & Peeters 1996; Van Oystaeyen et al. 2015). Adults have variable colour patterns but have a characteristic small black head, slender feathery- like antennae and wings which do not completely cover the abdomen. This wasp-nest beetle is widely distributed in Europe, from Finland to Spain and Great Britain to Azerbaijan (Batelka 2007). Figure 6: Metoecus paradoxus by B. Brown Female M. paradoxus are short-lived (6 - 12 days) and are thought not to feed (Heitmans & Peeters 1996; UK Beetles ND). In the United Kingdom, they lay batches of 10 to 50 tiny eggs in crevices of decaying wood in late summer and autumn. Each female can produce several hundred eggs during its lifetime (UK Beetles ND).

The eggs hibernate before hatching the following spring or summer. When a worker wasp comes to collect decaying wood, the small triungulin4 larva (about 0.5-0.75 mms) uses its long legs provided with suckers to climb onto its host and be carried to the wasp’s nest (Van Oystaeyen et al. 2015). However, observations showed that wasp-nest beetle larvae respond to any objects or insects approaching, indicating a lack of host selection. The high fecundity of the female beetle counter balances the chance for the larvae to starve on the wrong carrier or never encounter a potential host (Heitmans & Peeters 1996).

Once in the nest, the M. paradoxus larva enters a brood cell and waits as an endoparasite for its host to moult four or five times before it starts feeding on it as an ectoparasite. The development may be completed in 24 days (UK Beetles ND).

Studies of M. paradoxus in Europe show that the beetle can be found in other Vespula nests with a high preference for V. vulgaris. This inclination for V. vulgaris could be explained by the behaviour of common wasps that collect decaying wood to build nests whereas German wasps rasp wood from lamp posts and scaly-barked trees (Fordham 1961; Heitmans & Peeters 1996).

Once inside the wasp’s nest, the beetle larva searches for a suitable brood cell to parasitise. It starts as an endoparasite before becoming an ectoparasite from the second larval stage. A wasp- nest beetle larva needs 3.5 weeks and one full-grown wasp larva to complete its development (Heitmans & Peeters 1996).

After the pupation, the adult beetle bites around the cap and then quickly exits the nest using chemical mimicry to leave the colony undetected (Bonckaert 2011; Van Oystaeyen et al. 2015).

4 Triungulin: a larva that is the first larval stage of various hypermetamorphic beetles, is active with well-developed legs but during later development becomes legless and parasitic, and in the best-known forms feeds on eggs of bees, wasps, or locusts. 16

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Metoecus paradoxus is univoltine5 in the United Kingdom but is believed to have two generations annually in warmer climates (UK Beetles ND). A summary of the literature by Heitmans & Peeters shows that the number of specimens found in V. vulgaris and V. germanica nests remains low (1- 25 beetles), and only few cases with more than 50, independently to the size of the nest (Heitmans & Peeters 1996). However, according to the applicant, the low number of beetles in the nest is expected as adults exit the nest soon after hatching. Indeed, wasps continuously collect decaying wood to extend their nest size during summer, bringing the triungulin larva to their nests throughout the season (application form p.21).

Table 4: Taxonomic classification of Metoecus paradoxus.

Taxonomic Unit Classification

Order Coleoptera

Family Ripiphoridae

Sub-family Ripiphorinae

Tribe Macrosiagonini

Genus Metoecus

Species Metoecus paradoxus (Linnaeus, 1761) Synonyms Metoecus abdominalis, M. affinis,

M. angulatus, M. antoniae Acclimation to New Zealand

The two BCAs, V. inanis and M. paradoxus, are widely distributed in their native ranges and do not appear to be habitat-specific. Therefore, their adaptation to New Zealand’s climate is not considered as a barrier to their establishment.

5 Univoltine: species producing one brood in a season and especially a single brood of eggs capable of hibernating. 17

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Host specificity

Despite many studies on Hymenoptera and their parasitoids in Europe (Tscharntke et al. 1998; Holzschuh et al. 2009; Sobek et al. 2009; Holzschuh et al. 2010; Krewenka et al. 2011; Gresty 2017), the presence of V. inanis and M. paradoxus have never been reported or observed outside Vespula species (Heitmans & Peeters 1996; Van Oystaeyen et al. 2015). The co- evolution of the two BCAs with Hymenoptera insects and their presence in only Vespidae family species appears to indicate host specificity.

Host-specific parasitoids tend to share similar life-history traits with their target hosts or exist in a common habitat. The study of the phylogeny between our native species and the target hosts, as well as the comparison of their behaviour, nesting habits, and life cycle, assisted us to highlight potential similarities. The chemical mimicry of the BCAs is also viewed as a clue to their host specificity.

Phylogeny

Hymenoptera is one of the four mega-diverse insect orders, with more than 153,000 described species (Peters et al. 2017). It is divided into two suborders, Apocrita, including ants, wasps and bees, and Symphyta, including sawflies (Table 5).

Our comparison focused on native species in the infraorder Aculeata that contains the superfamily of the target host species, Vespoidea. As the result of a recent phylogeny update of stinging wasps (Branstetter et al. 2017) many families (Formicidae, Pompilidae, Scoliidae, Sierolomorphidae and Tiphiidae), previously under Vespoidea, were elevated to the rank of superfamilies (Branstetter et al. 2017; Vanoye-Eligio et al. 2020).

In New Zealand, the population of Aculeate fauna is described as poor, with 65 genera and only 135 species (Ward 2013). A few native species can be found in the superfamilies Apoidea (Donovan 2007), Formicoidea (Don 2007), Pompiloidea (Harris 1987) and Chrysidoidea (Olmi 2007), but none have been reported in the superfamily Vespoidea (Valentine & Walker 1983). The only Vespoidea species present in New Zealand are five undesirable self-introduced social wasps (paragraph 11).

We considered the phylogeny of some valued exotic species that play a significant role for New Zealand economy such as honeybees and bumblebees in the superfamily Apoidea, however, none of them are in the superfamily Vespoidea.

Species belonging to different superfamilies are not considered closely related. Therefore, based on the phylogeny of the Aculeata, we determined that no native species and valued exotic species are related closely enough to the target-host to be considered at risk by the release of the two BCAs.

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Table 5: Taxonomic classification of Hymenoptera according to Branstetter et al. 2017

Order Order Suborder Suborder Infraorder Infraorder Superf amily Superf amily

Hymenoptera Symphyta Parasitica ‘Parasitic wasps’

Apocrita Aculeata Chrysidoidea (cuckoo wasps and allies) ‘Stinging wasps’ Vespoidea (potter, paper, and other wasps) Sierolomorphoidea Tiphioidea Thynnoidea Pompiloidea (spider wasps) Scolioidea (scoliid wasps and allies) Formicoidea (ants) Apoidea (speciform wasps, bumblebees and bees)

Behaviour: social versus solitary

Eusocial insects, such as Vespula wasps, are characterised by high cooperation among colony members, the division of labour between many sterile workers and a reproductive queen and the overlap of generations (Fletcher & Ross 1985).

No native social bee or wasp species have been described in New Zealand (Beggs 2000). Furthermore, the majority of native Apocrita insects are parasitoid wasps (Early 2007) or solitary species (Donovan 1980; Harris 1987). Some native bees, such as Lasioglossum sordidum (superfamily: Apoidea, family: Halictidae), can be described as primitively eusocial or quasisocial6 with several females from different generations working from the same nest, however, each female has its own cell(s) and lay its own egg(s) (Donovan 2007; Hart 2007; Roubik 2012).

New Zealand also has a few valued exotic social species that play an important part in the pollination of crops and native plants such as honeybees and bumblebees (Butz Huryn 1995). The long term and large scale survey done by the National Bee Unit in the United Kingdom (appendix 3 of the application form), showed that V. inanis and M. paradoxus were never found in beehives. While the no-choice test (paragraphs 98-99) indicated that bumblebee larvae are not a target for the hoverfly. However, in the absence of host test ranging for the beetle, we could not exclude bumblebees as a potential host for M. paradoxus based on their behaviour similarities with the target host.

6 Quasisocial: An association of females, all of which are mated and able to lay eggs 19

EPA advice for APP203 875

Based on the behaviour of V. inanis and M. paradoxus regarding honeybees, and the absence of native social Hymenoptera in New Zealand, we considered that the release of the two BCAs would not represent a risk for native solitary insects or valued exotic social species, except, potentially, for bumblebees.

Life cycle

As described earlier (paragraphs 18-23 and 28-33) queen social wasps emerge from hibernation in spring to build nests and are quickly replaced by the first generation of workers. The workers take over the food gathering, brood caring and nest expansion, while the queen remains in the nest to lay eggs (Manaaki Whenua Landcare Research ND). We noted that the Vespula life cycle is similar to honeybees and bumblebees. However, as mentioned in paragraph 78, the study of honeybees in the United Kingdom showed that the two BCAs do not target this valued exotic species. In addition, the applicant’s host range testing demonstrated that V. inanis is not attracted to bumblebee larvae.

Solitary native bees and wasps spend most of their lifetime constructing and provisioning their nests (Morato & Martins 2006). Each female collects pollen, nectar, or insects (depending on the species) to deposit in a cell, before laying one egg and closing the entrance (Donovan 1980). Once the egg hatches, the larva feeds on the food left in its cell and spins a cocoon. The larva remains in the cell before emerging as an adult the next summer.

Due to the life cycle of solitary native species, if the two BCAs were approved to be released, they would need to overcome various obstacles to be successful of non-target attack and parasitism. First, the female BCA is unlikely to lay its eggs inside the native species’ nest due to their small entrance, therefore, the larva would need to crawl inside the tunnel, find an unsealed cell containing an egg, and remain undetected. Once the egg hatches, V. inanis larva would need to attach itself to the native larva, or, in the case of M. paradoxus, penetrate its integument which would be more difficult to do on a larva not closely restrained by the wall of its comb. Finally, V. inanis larva or the adult M. paradoxus, which are equipped to open a thin paper-like cap of a wasp cell, are unlikely to be able to remove a plug made of mud or mixed material (paragraph 87).

The life cycle of solitary native parasitoid wasps is also not compatible with the BCAs life cycle. Indeed, native parasitoids lay eggs directly on their hosts, either internally or externally, leaving no opportunity for the BCA larvae to feed on the native parasitoid larvae.

We noted that the tiny size of many native species (Early 2007) would be a limiting factor for the successful development of the BCAs. For this reason, we did not consider species in the superfamily Formicoidea (ants) as potential hosts.

Based on the differences of life cycles between native species and the BCA target hosts, we considered that if the release of the hoverfly and the beetle is approved, they would not find suitable non-target hosts among native species. However, despite the exclusion of valued exotic social insect species as potential targets (survey in the UK and host test ranging for V. inanis), we could not dismiss the potential risk of M. paradoxus targeting bumblebees due to the lack of data.

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Nesting

Species in the social wasp family Vespula use chewed plant and wood material to build their nest. The nest is an elaborate structure containing a large number of combs arranged in closely packed parallel rows with radial or bilateral symmetry around the initial cells (Theraulaz et al. 1998).

Conversely, female solitary bees and wasps predominantly burrow holes in sandy soils, decaying wood, or use pre-existing holes made by wood-boring insects. The number of individual cells per nest might vary between species and sometimes within species (Harris 1987, 1994; Don 2007; Donovan 2007; Olmi 2007). Each cell is sealed with mud or blocked with a plug made of a mix of material (e.g. rotten wood, plant fibres, sections of moss, etc.) (Harris 1987).

Some native Pompilidae species (superfamily: Pompiloidea), such as Epipompilus insularis, directly attach an egg on a paralysed spider. To compensate for the lack of protection, the larva spins a thick cocoon in an unsealed nest or under a curled leaf (Harris 1987). Other species, such as the pepsine spider wasps, Sphictostethus calvus, nest in decaying wood and therefore could be directly exposed to M. paradoxus larvae. However, in the hypothesis that the beetle larva would manage to parasitise a native species, we considered that the BCA would be unlikely to escape the thick cocoon or the sealed cell.

Similarly to pest wasps, bumblebees are also known to nest or hibernate in decaying wood (Heinrich 2012) putting them at risk of being targeted by M. paradoxus larvae. They build smaller nests than Vespula wasps, with disorganised cells made of wax produced first by the queen and then by the workers.

Based on the nesting habits of native Hymenoptera, we considered that they are unlikely to attract the two BCAs. We noted that despite the potential co-existence of some species with M. paradoxus larvae, the BCA is unlikely to successfully parasitise a native solitary species, however, some bumblebees nesting in decaying wood could become a successful non-target host.

Habitat

Due to the broad distribution (Figure 3 and 4) and continuous expansion (Lester & Beggs 2019) of Vespula wasps, their habitats are highly likely to overlap with the habitats of more native Hymenoptera species overtime. If the BCAs are approved to be released, their distribution should match the Vespula distribution. Nevertheless, we noted that the distribution and abundance of the majority of native Hymenoptera species remain unknown (Ward et al. 2014), making the assessment of potential impacts on native species challenging.

We noted that among valued exotic species, bumblebees who share some similarities with Vespula species (social behaviour, live cycle) could be targeted by the beetle larvae when building their nest in decaying wood as the BCA larvae appear to jump on any moving insect or object they encounter (Heitmans & Peeters 1996). However, we estimated that only a small portion of the bumblebee population could be affected as they are known to nest in various habitats such as lake and river margins, rough pastures and scrub (Goulson & Hanley 2004) and

EPA advice for APP203 875

build their nests in any suitably sized cavity above ground (rock wall, bird nest) or underground (old rodent nest, under tussock of grass) (Donovan & Wier 1978; Xerces Society ND). We considered that native species sharing the same habitats as the natural target host would expose them to the BCAs. However, as mentioned above, the life cycle, behaviour and nesting habits of known native species would limit the direct interactions with the BCAs. Furthermore, we noted that if the BCAs are not approved for release, the native species will continue to be targeted by V. germanica and V. vulgaris which are a threat to a plethora of invertebrates.

Mimicry

Social insects are known to share a chemical signature between individuals of the same colony which allow them to identify intruders (Dettner & Liepert 1994). The parasitoids proposed to control Vespula wasp populations have the ability to mimic their hosts, allowing them to approach and even infiltrate their host nests without being detected (Van Oystaeyen et al. 2015; Parmentier 2020).

Motoecus paradoxus produces a chemical mimicry that does not perfectly match V. vulgaris but is close enough to reduce aggression from workers and allow young adults to escape the wasp nest. According to Van Oystaeyen et al, the chemical signature of the wasp-nest beetle is the result of two processes. First, M. paradoxus larvae seem to passively acquire similar hydrocarbon compounds when feeding on their host larvae. This is demonstrated by some colony-specificity in the beetle larvae odour. Secondly, the stability of beetle chemical profile after isolation demonstrates a form of active mimicry. The study also found that the wasp-nest beetle share 51 hydrocarbon compounds with the common wasp and 34 with the German wasp (Van Oystaeyen et al. 2015).

Volucella inanis has two different forms of mimicry: physical and chemical. The most obvious being their visual mimicry of the social wasps with yellow and black stripes. However, this evolution is attributed to deter predators rather than to conceal their identity. Social wasps mainly use olfactory cues to identify members of their colony (Rupp 1989). Workers accept individuals with the same odour as members of the colony and reject or attack individuals with a different chemical proﬁle. The absence of contact for several months (overwinter) between the adult hoverfly and its host, and its ability to approach the nest without being perceived as a threat could be interpreted as evidence of active chemical mimicry. Furthermore, we noted that V. inanis larvae manage to crawl into the nest unnoticed which tend towards the hypothesis that they are able to secrete the chemical signature of their host before feeding on their larvae.

We considered that both BCAs are likely to have developed active chemical mimicry to be able to approach or leave the wasp nest without being noticed. The biosynthesis of specific host compounds is likely to be the result of the co-evolution between the BCA and its host and limited to closely related species (Dettner & Liepert 1994; Van Oystaeyen et al. 2015) suggesting the host specificity of the two BCAs.

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Host-range testing

Volucella inanis

The behaviour of V. inanis larvae was tested in New Zealand by Manaaki Whenua Landcare Research with a no-choice test on the common wasp, V. vulgaris, and the buff-tailed bumblebee, Bombus terrestris audax. The test involved dropping a hoverfly larva four centimetres from a brood of V. vulgaris or B. terrestris audax and observing its behaviour after one hour. The experiment was replicated six times for the two host species.

The results showed that all the V. inanis larvae exposed to the common wasp nest were found inside a wasp larva’s cell, whereas the ones exposed to the bumblebee’s nest died without trying to enter a cell. The test revealed that V. inanis larvae will not target bumblebees even in the absence of Vespula nests.

Metoecus paradoxus

No host-range testing for M. paradoxus was conducted. The applicant used the information found in the literature to conclude that the beetle is host-specific to species in the family Vespinae as the wasp-nest beetle has never been described parasitising species of another family. Studies have mainly observed M. paradoxus in V. vulgaris and less significantly in V. germanica (Van Oystaeyen et al. 2015). In the absence of native species in the family Vespinae in New Zealand as well as the absence of native social wasps, the applicant concluded that the release of the beetle M. paradoxus will not attack non-target species. Conclusion

After considering the phylogeny, behaviour, life cycle and nesting habits of the native species and exotic valued species, as well as the mimicry specificity of the two BCAs and the host range testing, we considered that the release of V. inanis and M. paradoxus are unlikely to target species outside the family Vespidae. Furthermore, we noted that in the unlikely event that the BCAs would manage to parasitise a native species, their development is unlikely to be successful.

Despite the active mimicry developed by M. paradoxus and its absence in the numerous studies on bumblebees we considered that they are more likely to be targeted by M. paradoxus larvae than other exotic valued species, as they share similar traits with social wasps (life cycle, nesting, behaviour). MPI noted that host range testing would have provided a stronger case (submission 127677). We concur that host range testing on bumblebee brood would have provided additional certainty in terms of the host specificity of M. paradoxus.

In their submissions, DOC and the Biosecurity Working Group (a collective of all 16 regional and unitary authority biosecurity representatives and experts) support the release of these two BCAs as, according to them, the research completed by Manaaki Whenua – Landcare Research demonstrated that the wasp-nest beetle and the hoverfly would only target Vespula species and will not be a risk for other species (submission 127662 and 127669).

EPA advice for APP203 875

We considered that the presence of the two BCAs would not increase the risks for native species or valued introduced species (excluding bumblebees nesting in decaying wood) and would help reduce the populations of their main threat, Vespula wasps.

Risk assessment

Our assessment of the benefits and risks associated with the release of the hoverfly, V. inanis, and the beetle, M. paradoxus, to control the German and common wasp is based on the assumption that these two BCAs successfully establish in the New Zealand environment and develop self-sustaining populations.

If the BCAs do not establish in New Zealand, there is no risk. Conversely, if they establish large populations, the frequency of risks, discussed in our assessment below, increases. At the same time, the benefits will also increase since the BCAs would need to reach high numbers to cause maximum damage to wasp populations in order to be beneficial. Therefore, an assessment made on full establishment makes it easier to determine if the benefits truly outweigh the risks or vice versa.

Assessment of risks and benefits

We assessed the risks and benefits of the release of V. inanis and M. paradoxus to the environment, market economy, human health, people and communities, and on Māori and their relationship to the environment. We only discuss the effects that we assessed to have a significant result. Therefore, those effects where the magnitude of the effect and likelihood of that effect occurring is improbable or speculative are not included in our assessment.

The risks and benefits would vary across the country according to the density of wasp populations and the main activities in the area. Potential benefits from the release of the BCAs

We identified the following benefits of releasing V. inanis and M. paradoxus in the New Zealand environment: o reduction of the wasp populations as well as the reduction of the rate of spread of German and common wasps at new sites o improvement of biodiversity and public health o reduction of reliance on chemicals which would reduce costs to land managers and decrease collateral damage to native organisms o reduce economic impacts on primary and tourism industries o enhance the experience of people visiting recreational areas.

Environment

The establishment of the BCAs in New Zealand is likely to improve biodiversity in regions highly infested by social wasps, and reduce the usage of chemicals in the long term.

EPA advice for APP203 875

Improve biodiversity

Wasps are known to profoundly impact the biodiversity in New Zealand by preying heavily on invertebrates and some vertebrates, as well as increasing the competition for nectar with native fauna.

In their native environments, social wasp populations are controlled by the presence of various insects (e.g. dragonflies, hornets, centipedes), birds (e.g. magpies, blackbirds, starlings) and mammals (e.g. badgers) (Manaaki Whenua Landcare Research 2014). However, in New Zealand, the lack of natural predators and the favourable climate help social wasp populations to reach record numbers.

German and common wasps are widely distributed and can be found in various environments across New Zealand. During summer, when wasp populations reach their peak abundance, their voracious appetite can cause significant damage to ecosystems through direct and indirect adverse effects (Hunt 1996). Their high numbers can remove a large part of the invertebrate community which is the foundation for the forest ecosystem through the continuous production and recycling of nutrients as well as providing food for insectivores (Hunt 1996). Indeed, 1.5 to 8.1 kilogrammes of invertebrates per ha/year, are consumed by wasps (Thomas et al. 1990; Barlow & Goldson 2002; Dixon 2018). They work as a murderous horde, dismantling prey far larger than themselves (Hunt 1996). Harris and Oliver found that wasps were responsible for collecting 12 000–75 000 prey/ha/season in semi-urban scrub and pasture habitats of the Hamilton area (Harris & Oliver 1993). In addition, wasp populations indirectly affect the microorganism community in the soil by reducing the amount of honeydew reaching the ground (Barlow & Goldson 2002; Beggs et al. 2002). In their submission, the Marlborough District Council underlined the immense damage to terrestrial ecosystems, via direct predation of invertebrates or indirectly by consuming honeydew, caused by the extremely high numbers of pest wasps in the region (submission 127668).

Studies have shown that smaller insects are more likely to survive longer than larger insects in wasp infested areas. However, in summer, when the wasp population reaches its peak, the survival rate of small insect is close to zero. According to Toft and Rees (1998), to improve the survival of vulnerable invertebrates the wasp populations would have to be reduced by at least 80%. By extrapolation, they suggested that the establishment of wasps in beech forests more than 40 years ago may already have removed vulnerable native taxa (Toft & Rees 1998; Beggs & Rees 1999). However, the applicant considers that any mitigation of wasp populations by the BCAs would be beneficial for the environment.

Mr Frost mentioned the disappearance of native butterflies on his property. He stated that only the vagrant species seems to infrequently appear whereas the forest ringlet butterfly previously present in the Nelson-Tasman region is now only found in higher altitudes where Vespula wasps do not thrive (submission 127675). Moths and Butterflies of New Zealand Trust noted the adverse impact of wasps on butterflies also mentioned the decline of the endemic forest ringlet butterfly (submission 127686). Whereas Ms Wild Rose (submission 127664), Ms O’Boyle (submission 127679) and Ms Dorn (submission 127681) mentioned the devastating impacts of wasps on the monarch butterfly and more broadly on insect populations.

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We noted that the decrease of social wasps would also reduce the competition for food between wasps and insectivores. Between 80 and 100% of the wasp’ diet includes spiders, caterpillars, ants, bees and flies, which overlap with the diet of some native birds such as riflemen (Acanthisitta chloris), fantails (Rhipidura fuliginosa), pied tits (Petroica macrocephala toitoi), grey warblers (Gerygone igata), and whiteheads (Mohoua albicilla) (Harris 1991; Barlow & Goldson 2002).

The release of the BCAs would also benefit nectar-feeding birds, lizards and insects (Moller & Tilley 1989). Indeed, honeydew produced by sap-sucking insects such as aphids (Aphidae) and scale insects (Coccidae) is a valuable resource for all kind of wildlife. Birds such as kākā (Nestor meridionalis), tūī (Prosthemadera novaeseelandiae), bellbird (Anthornis melanura), silvereyes (Zosterops lateralis) (Gaze & Cloud 1983), as well as nectarivorous insects and lizards such as the jewelled gecko (Naultinus gemmeus) also feed on nectar. However, during summer, wasps consume up to 90% of the honeydew available in beech forests, leaving scarce quantities of honeydew for other honeydew dependent organisms. Furthermore, their constant cropping decreases the sugar concentration of honeydew (Moller et al. 1991) leading honeybees, tui and bellbirds to change their feeding behaviour and avoid seeking honeydew during peak wasp season (Moller et al. 1991; Barlow & Goldson 2002).

Mr Buckland observed the synchronicity between the wasp life cycle and the breeding cycle of most of native birds. He underlined the adverse effects of wasps on birdlife in native beech forests where birds starve due to the high number of wasps (submission 127667).

Wasps are also believed to have a long term adverse impact on scale insect populations. In order to have access to more honeydew, wasps nip the ends off scale insects anal tubes, which eventually leads to their death (Hansford 2017). However, this aspect is not well documented in the literature to understand how much the scale insect population is affected.

Biological control is thought to be the only effective option for long-term sustainable management of wasps in isolated or hard to reach habitats. The benefits of the BCAs would be to enable access to hard to reach wasp nests and limit the opportunities of re-invasion.

The release of the two BCAs is strongly supported by DOC who considered that the common and German wasps “severely impact native biodiversity by preying on native invertebrates and small vertebrates and depleting the available honeydew supplies in forests. Their predation directly impacts threatened species, causing further decline, and their feeding on both invertebrates and honeydew causes severe shortages of food for birds and reptiles at critical periods of their annual breeding cycle, thereby causing declines in those species as well” (submission 127662).

The potential environmental benefits that may occur following the release of a BCA to mitigate wasp populations in New Zealand is highly likely to have a major impact on biodiversity abundance in beech forests and native environments where wasps are well represented. It is also likely to reduce future expansion or infestations of new areas by diminishing the numbers of queens and weakening the existing nests.

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Reduce chemical usages

The only effective method currently available on the market to control wasps is the use of pesticides. Accessible infested areas can be treated with baits such as Vespex (paragraph 43- 47) where only a small quantity of chemical bait is necessary to eradicate an entire wasp colony without any collateral damage to the environment and non-target species. However, as mentioned by Member of Public 06 (submission 127685), baits have a limited success and only work at the peak of the summer season when the colony consists of thousands of individuals which require and seek high levels of protein. Therefore, other pesticides are still required to control wasp populations in spring and autumn. These broad-spectrum chemicals can cause indirect adverse impacts in the surrounding environment and to non-target organisms.

In order to achieve the best results, pesticides would need to be run in parallel with biological control but in different areas to avoid adversely affecting BCA populations. As mentioned by Member of Public 03, the impact of the BCAs would be complementary to the current methods of wasp control (submission 127670). Indeed, in the short term, the BCAs would have a beneficial impact in inaccessible areas where they would not be affected by chemicals. In the long term, if the BCAs manage to keep the wasp populations under control, areas treated with chemicals will be less re-invaded by queens and therefore, the amount of chemicals used to kill wasps in accessible areas might decrease.

The Marlborough District Council uses chemicals to control wasp nests within a discrete area. However, wasps continue to thrive in the surrounding areas and come back as soon as the control effort wanes. Therefore, they support the introduction of BCAs to mitigate wasp populations outside their range of action (submission 127668).

Neonicotinoids, which are the most common active ingredients used in wasp pesticides, including Vespex, are highly controversial due to their impact on pollinators such as honeybees (Dixon 2018). They are also widely used by farmers as an effective way to control damaging seedling pests (Hopwood et al. 2013). In the absence of a safer pesticide alternative and despite the potential decrease of wasp pesticides in the long term, neonicotinoids will continue to be widely used by farmers and beekeepers (Morton 2018).

The reduction of pollinators induced by the presence of wasps has also an impact on the usage of fertilisers in paddocks. One of the most important pasture plants in New Zealand is white clover (Trifolium repens), thanks to its ability to fix nitrogen from the atmosphere due to the presence of nitrogen-fixing bacteria in its root nodules. When it dies or is consumed, nitrogen is released into the soil and feeds the grass around it. The more clover in a paddock, the less nitrogen fertiliser is required to assist in producing grass, therefore, reducing the cost for farmers (Science Learning Hub – Pokapū Akoranga Pūtaiao 2013). In 1969, a study on New Zealand pastoral farming estimated that between 120 and 200 units7/hectare of nitrogen could be required annually to replace the production of nitrogen obtained from well-managed grass/clover associations (Ball 1969). Indeed, if the BCAs are approved to be released, they will increase the number of pollinators which will increase the number of clover in the field which, in turn, will increase the nitrogen availability and therefore benefit grass.

7 A unit of nitrogen is the equivalent of a pound of elemental nitrogen. 27

EPA advice for APP203 875

The impact of the BCAs on wasps is likely to lead to an overall reduction in chemicals with the larger proportion of the reduction associated with fertiliser usage in agriculture rather than the reduction of pesticides used to control wasp populations. As a result, the release of the two BCAs would have a major impact on chemical usage.

Our conclusion of the potential environmental benefits from the release of the BCAs

The perceived environmental benefits would vary at the regional scale, with a higher impact on biodiversity and chemical usages in areas where wasp populations are heavily concentrated, such as beech forests in the Nelson region.

The release of the BCAs is likely to highly likely to reduce the amount of fertiliser used by the pastoral sector and improve biodiversity, with a major impact in highly infested environments.

We concluded that the release of these BCAs could potentially have a medium to high impact on the environment with the decrease of chemical usage and the re-emergence of native biodiversity.

Economy

The release of the two BCAs could have multiple beneficial impacts on the New Zealand market economy, including apiculture, agriculture and tourism.

In 2015, a full assessment of the economic impact of the German and common wasp in New Zealand estimated that wasps cost the national economy $133 million annually. The main impacts included $58m to the farming industry and $8.8m to apiculture, as well as $62m to clover and nitrogen fertiliser costs avoided due to the reduction of wasp populations (MacIntyre & Hellstrom 2015).

Apiculture

New Zealand’s apiculture industry is worth $5 billion through honey, bee products (e.g. pollen, wax, royal jelly, venom, propolis) and pollination of clover, crops and other plant species (Apiculture New Zealand 2019). The industry continues to grow to meet the high global demand for natural products (Table 6). In less than ten years, the number of hives has doubled (Ministry for Primary Industries 2018) and an additional 113,616 hives were registered between June 2018 and June 2019 (Apiculture New Zealand 2019).

Table 6: Key parameters of the New Zealand apiculture industry between 2010 and 2018 (Ministry for Primary Industries 2018).

2010 2018 Honey prices (NZ$/kg) - light clover honey 4 – 6 8.5 -12 7 – 37.5 12 - 135 - Manuka honey

Honey crop estimated (tonnes) 12,553 20,000

Number of hives < 400,000 881,185

Number of beekeepers 2,957 8,552

EPA advice for APP203 875

Despite its rapid development, the New Zealand apiculture industry is threatened by the increase of social wasps (Figure 7). In particular German wasps which are known to attack beehives to rob honey and kill bees and larvae for protein. Trees and Bees underlined the massive task and high cost of chemical application when attempting to defend bees against wasps (submission 127676).

According to Clapperton et al., 1.9% of hives were destroyed by wasps and a further 4.9% were affected in 1975. Ten years later, in the summers of 1985 and 1986, 8.13% then 9.35% of hives were destroyed or seriously affected by wasps (Clapperton et al. 1989). More recently, in 2018, it was estimated that on average 5% of hives were lost each year nationally but in high infested areas beekeepers can lose up to a third of their hives (Dixon 2018). The cost attributed to the replacement of hives was estimated at $3.6m per year (MacIntyre & Hellstrom 2015).

Apiculture New Zealand stated that wasps were ranked the third or fourth highest cause of honeybee colony loss with 9.6% for an estimated value of lost production (including replacement of beehives) at $4m in 2019 (submission 127680).

In addition to the replacement of destroyed hives, beekeepers have to cover the cost of chemicals used to protect bees from predators such as wasps. The price varies according to the environment (pastoral and horticultural areas versus forestry and native bush) and the number of hives owned by the beekeeper. On average, the cost was estimated at $5 per hive annually for a total annual management cost estimated in 2015 at $2.5m for the apiculture industry (MacIntyre & Hellstrom 2015).

Tree and Bees noted that the presence of wasps requires a massive task and cost, due to constantly having to monitor their apiary sites for wasps and the multiple chemical treatments (up to three times) per year needed to maintain control as more wasps appear and fill the 'wasp vacuum' they create. He also mentioned that the release of the BCAs will help control wasp population outside their reach which should limit future re-infestations (submission 127676).

Social Wasps

Increase food Predation on competition bees food

Decrease honey More bees to production protect ve production

Less pollination ollinate Figure 7: Direct and indirect impacts of wasps on the apiculture industry.

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However, since 2000, the main cause leading to bee colony loss is now attributed to the arrival of Varroa mite (Varroa destructor) and its ability to transmit diseases such as the deformed wing virus (DWV). In 2018, a survey found that 19.5% of hives destroyed were attributed to Varroa mites and 12.1% to wasps (Manaaki Whenua Landcare Research 2018). Chemicals are currently the only method available to treat Varroa mite. Therefore, the decrease of wasp populations would only eliminate a part of the cost of chemicals used to manage bee predators.

In areas with dense wasp populations, bees must also compete for food and spend more time and energy to defend their hives. As a consequence, they spend less time collecting pollen which impacts their production of honey and the pollination of flowers and crops (Figure 7) (Dixon 2018). With the decrease of wasps, bees would be able to focus more on harvest and increase their honey production for an annual gain value estimated at $2.7m (MacIntyre & Hellstrom 2015).

We considered that the release of the two BCAs is highly likely to reduce the cost attributed to the number of hives destroyed by wasps and to increase the national production of honey. However, the potential $8.8m saved each year due to the decrease of wasp populations represents less than 1% of the total revenue generated by the apiculture industry annually (MacIntyre & Hellstrom 2015).

We concluded that the release of these BCAs could have a moderate impact on the economy in regions infested by social wasps and a minor impact at the national scale.

Agriculture

The lack of pollinator insects in areas infested by social wasps has a massive impact on agricultural productivity where approximately 84% of the 300 commercial crops are pollinated by insects (mainly by honeybees) (Allsopp et al. 2008). As a result, farmers have to employ beekeepers to ensure the pollination of their crops and use fertiliser in their pastures.

In 2018, apiarists charged fruit growers $80 to $250 per hive. Pollination of kiwifruits was even more expensive, with a cost between $175 and $400. The price range varies depending on the region and the service provided by beekeepers (Ministry for Primary Industries 2018). The number of hives per hectare for a good pollination rate depends also on the type of crop, with an average of three to five hives per hectare. The exception is kiwifruit which requires eight to ten hives per hectare (Savoie et al. 1996; workshop 2017). In 2015, the total cost to pollinate crops was estimated at $740,000 per year (MacIntyre & Hellstrom 2015).

Furthermore, the lack of pollinators in clover fields increases the amount of fertiliser sprayed by pastoral farmers (paragraph 127). According to MacIntyre and Hellstrom (2015), the removal of wasp populations in New Zealand could avoid a $33.8m economic cost associated with the use of nitrogen fertiliser to assist in pollination and crop development.

The pastoral sector would also be beneficially impacted by the introduction of the BCAs with the increase of pollination and therefore the decrease of clover oversowing. The mitigation of wasp populations in New Zealand could avoid $28.2m on reseeding clover every five years (MacIntyre & Hellstrom 2015).

EPA advice for APP203 875

Member of Public 01, who runs an organic micro-orchard (0.5ha) in the North Waikato, supports the release of BCAs to mitigate wasp populations. As an organic farmer, the options available for pest control are limited to mechanical destruction. Therefore, he is currently relying on his neighbours undertaking poisoning operations to keep German and the Asian paper wasp populations under control (submission 127660).

Northland Regional Council noted that the economy of the region relies heavily on the horticulture sector, producing 45% of New Zealand’s $100m avocado export as well as 3.5 million trays of green and gold kiwifruits annually. They stated that the presence of wasps and the risk of being stung disrupt horticultural activities (submission 127673).

Wasps have been identified as a significant hazard for workers in forestry operations. Their presence is estimated to cost approximately $50,000 per incident for a forestry company, including the training of workers to respond to emergencies (anaphylactic shock), the disruption of production, and recovery from the incident. With an average of one incident every five years (MacIntyre & Hellstrom 2015).

Finally, the decrease of wasps would reduce the damage in crops such as grapes, apples, pears and plums (Archer & Halstead 2014). At the end of summer, wasps seek sugary substances to feed themselves as no larvae remain to produce food for the workers. In Australia, where social wasps are also a problem, V. germanica is responsible for 10-15% of yield losses in vineyards in the states of South Australia and Victoria (Cook 2019).

The release of the BCAs is highly likely to lead to the re-emergence of pollinators and have flow- on effects on the amount of fertiliser used. In total, the agricultural sector could gain $62.7m per year with the removal of wasps (MacIntyre & Hellstrom 2015). However, it represented less than 1% of the $28 billion of gross domestic product generated by the agriculture sector in 2016.

We concluded that the BCAs could have a moderate impact on the agricultural industry at the regional scale and a minor impact at the national scale.

Tourism

In 2018, the Institute for Economics & Peace ranked New Zealand as the second safest country in the world (Institute for Economics & Peace 2019). The absence of dangerous animals and unique environments are often described in tourist brochures. However, the presence of invasive wasp species damage native biodiversity and pose health risks to tourists who may be stung. These factors may contribute to an adverse change in perception about New Zealand’s natural environments and potentially damage the tourism industry (Barlow & Goldson 2002).

Tour operators directly impacted by the nuisance brought by the high number of wasps in some areas are forced to modify or even cancel their outdoor activities (D'adamo et al. 2002). Thirty years ago tramping, fishing and picnicking sites were starting to be overrun by pest social wasps, harassing trampers and making some areas in late summer unsafe for holidaymakers (Clapperton 1989; Hansford 2017).

Northland Regional Council noted the adverse effects of Vespid wasps in bush walks, picnic areas or recreational activities as they pose a risk to Northlanders and the tourism sector (submission 127673).

EPA advice for APP203 875

In the Nelson region, DOC staff and volunteers laid poison bait in popular tramping routes and camping areas. However, this operation must be done annually as treated areas are quickly reinvaded by queen wasps the following spring. The re-invasion of treated areas is discussed in submissions from Greater Wellington Regional Council (submission 127671), Tree and Bees (submission 127676), and Marlborough District Council (submission 127668). The work is supported by a crowdfunding campaign, Wasp Wipeout, that focuses on wasp control management in the Nelson Tasman and Marlborough Sounds (Hansford 2017).

The decrease of wasp populations is likely to restore businesses in the tourism industry with a minor regional economic impact according to the level of infestation of each region and a minimal impact at the national scale.

Our conclusion of the potential economic benefits from the release of the BCAs

The release of the BCAs is highly likely to have a minor to moderate regional economic impact for apiarists and farmers depending on the degree of infestation. The presence of BCAs would reduce the cost of wasp impact on bees and increase the production of honey. In addition, an increase in natural pollination is expected which would reduce the quantity of fertiliser and sowing need by the pastoral industry. The BCAs are also likely to have a minimal to minor regional impact on the tourism industry with the sustainability of tourist attractions and the decrease of the cost associated with the management of wasps.

We concluded that the decrease of wasp populations could have a low to medium impact on the market economy depending on the region and the level of wasp infestation.

Public health

The release of the two BCAs in New Zealand would improve public health by reducing the risk of wasp stings on people and animals.

Wasp stings are venomous and a small percentage of the human population (around 3 percent of adults) can develop a severe allergic reaction called anaphylaxis that can be life-threatening. The sting can cause various symptoms such as rash, swelling, shortness of breath and throat tightness. People who develop rapid and strong allergic reactions to the wasp sting require emergency medical treatment (Allergy New Zealand 2010).

The Bay of Plenty Regional Council received many calls from the public regarding issues with wasps and requiring wasp control, therefore, they support the release of the BCAs to control wasp populations (submission 127667). Similarly, the Auckland Council noted a 20% increase in the number of wasp-related service orders between 2018 and 2019 (submission 127683).

In New Zealand, approximately 1300 people seek medical attention and two to three people die from reactions to wasp stings annually (Hansford 2017; Southern Cross 2017). The number of claims and associated costs for wasp related injuries received by the Accident Compensation Corporation (ACC) during the last ten years showed a steady increase despite the high variation across the years (Chart 1). However, we noted that whether an injury is classified as being caused by a bee or a wasp is subjective to the claimant’s recollection of the incident and ability to identify bees from wasps and vice versa.

EPA advice for APP203 875

In his submission, Mr King, mentioned the fatal risk for walkers if they accidentally fall into a large wasp nest built in the ground if trodden (submission 127661)

Chart 1: Claims (including new claims and active claims) and associated costs for wasp related injuries registered by ACC for the last 10 years.

In summer, wasps can occasionally cause traffic accidents by distracting drivers. The fear of being stung by a wasp is enough for many people to lose control of their vehicles. In 2012 and 2013, wasps were the cause of several vehicular crashes that resulted in varying degrees of injury to the victims with no fatalities. Again, the number of accidents attributed to wasps may not be well represented as people easily mistake them with bees and the cause of fatal accidents can be misidentified (MacIntyre & Hellstrom 2015).

Our conclusion on the potential benefits for public health from the release of the BCAs

We considered that from the individual’s perspective, who is highly allergic to wasps, the release of the BCAs is likely to have a massive effect as the risk of death would be reduced but not eliminated. However, the reduction of encounters with wasps is likely to have a minor impact at the general community level.

We concluded that the level of benefits from increased control of wasps to an individual who can present anaphylaxis could be significant, whereas, the overall benefits to public health would be low.

People and communities

As mentioned in paragraphs 111-131, wasp populations have a devastating impact on ecosystems. The decrease of insects and birds make some tramping tracks less attractive for the public and the community. For example, beech forests in the Nelson region have a high density of wasps that can reach 10,000 individuals per hectare (Hunt 1996) making it difficult for people to walk through the forests in summer without being stung. The nuisance of wasps affects any outdoor activities including hunting, fishing, camping, tramping, gardening, etc.

EPA advice for APP203 875

The Marlborough District Council noted the adverse effects of the high number of wasps that make places such as parks, forests and beaches impossible to enjoy (submission 127668). The Auckland Council added that the widespread distribution of wasps force them to focus their management efforts on high ecological value sites or at public sites that are highly frequented (submission 127683). According to Member of Public 03, this situation leads to circular logic where areas highly infested by wasps are less frequented by the public and therefore fall off the council’s priority list (submission 127670).

Wasps are also problematic in urban areas where they build nests near people, increasing the risk of being stung. This is especially the case in autumn when the number of wasp larvae decrease and cannot produce enough food for the workers. The workers then need to find another food source and get attracted by any sugary food/drink, making outdoor recreational activities unpleasant.

Our conclusion on the potential benefits on people and communities from the release of the BCAs

The benefits of the release of the BCAs on the community would vary across the country, where regions with high wasp infestations like Nelson, would be the most affected.

The BCAs are likely to have minor to moderate impacts locally according to the degree of wasp infestations. Overall, the level of benefits on the community would be medium at the local level and low at the national level.

Potential risks from the release of the two BCAs

We identified the following risks from releasing the BCAs in the New Zealand environment: o reducing native species or valued exotic species through non-target attacks o altering food web interactions to cause significant displacement of native organisms through ‘apparent competition’ o increasing populations of pest insects previously targeted by social wasps o reduction in revenue for pest control contractors and, pesticides and fertilisers suppliers.

Environment

Biological control appears to be a less damaging approach to managing invasive species compared to chemical control, although the actions of the BCAs could negatively affect native or valued exotic flora and fauna. Therefore, the potential for the wasp-nest beetle and the hoverfly to have non-target effects must be carefully assessed to limit the risk.

We evaluated the potential impact of these two BCAs on pesticide usage due to the decrease of social wasps, on native and valued exotic species, and more broadly on food-webs, as well as the potential for the introduced species to hybridise with native species.

Increase in use of pesticides for gardeners

In summer, social wasps can be a good ally to gardeners when pests such as aphids, flies, caterpillars and other bugs damage crops. For that reason, Polistinae or Vespinae wasps were considered as potential BCAs in small farms and urban gardens in Brazil to reduce the use of pesticides (Prezoto et al. 2019). 34

EPA advice for APP203 875

During the public consultation we received a submission from Mr Blick who considers that wasps play an important role in his organic garden by killing white butterfly larvae (submission 127665). However, we noted that organic gardeners are unlikely to replace wasps by pesticides whereas professional gardeners are more likely to rely on pesticides to protect their crops.

We considered that the release of the two BCAs are only likely to increase pesticide usage in individual localised gardens previously infested by social wasps but with no discernible ecosystem impact, therefore the magnitude of the effects would be minor.

Vespula could be replaced by a worse pest

The mitigation of Vespula wasp populations could lead to the emergence of other exotic and invasive pests already present in New Zealand. As mentioned by Member of Public 03 (submission 127670) and the Auckland Council (submission 127683), the Polistes wasps (Asian, European and Australian paper wasp species), found in similar environments, could take advantage of the decrease of Vespula populations.

However, paper wasps appeared to be confined to margins and clearings, avoiding dense bush (Walsby 1995). Furthermore, being far less aggressive than Vespula wasps, they pose less risk to human health (Waikato Region Council 2016). They also build smaller nests with an average of 350 cells and have a narrower range of prey (Walsby 1995; Tasman District Council ND).

Although we assessed that other pests could replace Vespula wasps, the magnitude of the effects would be minor as the occupation of the Vespula niche by another wasp remains hypothetical. If this occurred, appropriate control measures for the new pests could be investigated.

Impact on native and valued exotic species

The wasp-nest beetle and the hoverfly may have adverse effects on non-target insects. These effects are determined by identifying their host range through testing (done only for V. inanis) as well as comparing the phylogeny, behaviour, life cycle and nesting habits between their target hosts and closely related native species or valued exotic non-target species (paragraphs 69- 104).

We noted that the closest native or valued exotic species are in different superfamilies than the target social wasps (Table 5). Furthermore, in New Zealand, most of native bee and wasp species are tiny, solitary, or parasitic (Thomas et al. 1990; Manaaki Whenua Landcare Research 2014) and would not support sustainable development of the BCAs. Therefore, it is unlikely that they can be considered as a host from an ecological perspective.

Other native and valued exotic species in the infraorder Aculeata, showing similar traits with the target hosts, were also not considered as potential non-target hosts based on the host specificity of the two BCAs. Indeed, based on the results of the host range testing for V. inanis (paragraph 98-99), the active mimicry developed by M. paradoxus (paragraph 95), and the absence of hosts outside the family Vespidae for both BCAs in the literature (see application form for references - table 1 for M. paradoxus and p17 for V. inanis), both BCAs appear to have a narrow host selection. However, we noted that bumblebees nesting in decaying wood could be targeted by the beetle BCA (paragraph 92).

EPA advice for APP203 875

Based on the information available, we considered that is unlikely for the two BCAs to target native or valued exotic species outside species in the family Vespidae. Any adverse effects will be minor as we expect those effects to have localised and contained impacts, affecting a few individual members of native Aculeata species in the event the BCAs locate and accept them as hosts.

Effects on food-webs

The existing interconnections between species are impacted by any changes in the ecosystem such as the decrease of wasp populations, the additional source of prey for insectivores or hyperparasitoids and the increasing competition for pollen and nectar with native or valued exotic species.

Among the submissions we received, Mr Mason (submission 127687) and Member of Public 02 (submission 127663) were opposed to the release of the BCAs due to the potential risks of these exotic organisms becoming invasive species or their potential interference in trophic webs.

There are no known native parasitoid or predator species targeting social wasps in New Zealand. Two exotic subspecies, Sphecophaga vesparum vesparum and Sphecophaga v. burra, were released as a BCA in 1985; however, they do not seem to have established. Furthermore, we noted that the bright yellow colours of the social wasps act as a warning and deter native insectivores. Therefore, we considered that the decrease of social wasp populations would not adversely affect any native species.

Similarly, the colouration of V. inanis that mimics social wasps should also deter predators, leaving M. paradoxus as the main potential new source of prey for general predators.

Regarding the competition for pollen and nectar, we noted that the hoverfly, V. inanis, is considered as an important pollinator species in Europe (Maritano 2020), whereas, M. paradoxus is not known to feed as an adult (Heitmans & Peeters 1996; UK Beetles ND). Therefore, we considered that the presence of adult V. inanis could increase the competition for nectar and pollen with native insects and valued exotic species. However, we noted that social wasps also feed on nectar and that the beneficial effects on the biodiversity attributed to the decrease of the wasp populations would outweigh the risk of the increase of competition for pollen and nectar from the BCAs.

The release of the BCAs may also impact food web interactions by reducing the pressure on other pest species controlled by wasps. Indeed, by preying on other insects, social wasps help to keep pest insect populations under control (Hadley 2019) and in their absence, insects such as the great white butterfly (Pieris brassicae) and aphid species may proliferate and cause greater damage to ornamental or horticultural species (MacIntyre & Hellstrom 2015; Hall 2018).

We concluded that the introduction of the BCAs is likely to change the food chain dynamic via a potential increase in competition for pollen and nectar. However, the consequences of any such effects will be minor as effects will be localised and contained with no discernible wider ecosystem impact.

We considered that the adverse effects of social wasps spreading in New Zealand that continue to build large populations would outweigh the adverse effects on the ecosystem from an additional species (V. inanis) feeding on pollen. 36

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Hybridisation of the BCAs with native species

In New Zealand, there are no native or introduced species in the same genus as the wasp-nest beetle, M. paradoxus, or the hoverfly, V. inanis. Species from different genera are not considered closely related enough to be able to hybridise.

Based on the information available, it is highly improbable that the release of these two BCAs would have adverse impacts on the ecosystem with no closely related native species to adversely affect the inherent genetic diversity of native beetles and flies. The magnitude of the effects would be minimal.

Our conclusion on the potential environmental risks posed by the BCAs

Taking into consideration the potential adverse effects on the environment following the release of the two BCAs in New Zealand, we considered that the BCAs are likely to impact the amount of pesticides used but only in localised gardens, and could be replaced by a worst pest. However, they are unlikely to impact native or valued exotic species via predation due to the host specificity of the two BCAs.

Despite the potential impacts on food-webs via pollen and nectar competition we considered that the mitigation of wasp populations with the release of the two BCAs would have greater benefits than the addition of a pollen competitor. We noted that with the absence of native species in the same genus as the two BCAs, it is highly improbable for them to hybridise with native species.

We concluded that any adverse effects on the environment would be minor and the effects are expected to be negligible to low.

Economy

The introduction of the biocontrol agents will help to reduce wasp populations and could adversely impact the market economy with the decrease of pesticide sales. However, most pesticides used to kill wasps are broad-spectrum chemicals and would continue to be bought to control and eliminate a number of other invertebrate pests.

Pest control companies could lose a part of their revenue with the decrease of intervention for controlling and eliminating wasp nests. The impact would be more apparent in regions where Vespula wasps are well represented such as Nelson and Tasman. According to the economic study done in 2015 on the cost of Vespula species in New Zealand, pest control companies generate around $1m per annum from wasp control products (MacIntyre & Hellstrom 2015).

Our conclusion on the potential economic risks posed by the BCAs

We concluded that the release of the BCAs is likely to have a minimal adverse impact on pesticides sellers and a minor adverse impact on pest control companies especially for regions highly infested by wasps.

The overall level of risks on New Zealand’s market economy is assessed to be low.

Public health

No public health risks have been identified with the introduction of the beetle, M. paradoxus, or the hoverfly, V. inanis, as they do not sting and are not known to transfer diseases.

EPA advice for APP203 875

The release of the two BCAs could impact the research on wasp venom which showed properties to combat cancer without interfering with normal cells. In his submission, Mr Blick mentioned the importance of wasp venom that contains formic acid and the lack of New Zealand research on the subject (submission 127665). However, we noted that social wasps are present in many places around the world and their decrease in New Zealand would not represent a shortage of venom for potential research.

Our conclusion on the potential risks on public health from the release of the BCAs

It is highly improbable that the release of the two BCAs would have adverse effects on public health. The impact of the BCAs would be minimal.

The overall level of risks on public health from the release of the two BCAs is assessed to be negligible.

Conclusion on benefits and risks assessment

After completing our risk assessment and reviewing the available information, the adverse effects of releasing M. paradoxus and V. inanis to control German and common wasps are assessed to be negligible to low, whereas the environmental and economic benefits, as well as benefits to the community and public health would be mainly low to high (Table 7).

Therefore, we assessed that the benefits from the release of the BCA outweigh the risks. However, we considered that M. paradoxus would require host range testing to unequivocally confirm its host specificity, especially in relation to verifying its inability to use bumblebees as a potential host.

EPA advice for APP203 875

Table 7: Summary of our assessment of the benefits, risks and costs associated with the release of M. paradoxus and V. inanis to control German and common wasps.

Potential outcomes Likelihood Consequence Conclusion Regional / national (level of risk / benefit)

Potential beneficial effects to the environment

Improve biodiversity Highly likely Major High

Reduce chemical usages Likely Major Medium

Potential beneficial effects to the market economy

Reduce cost for apiarists Highly likely Moderate / minor Medium

Increase revenue for farmers Highly likely Moderate / minor Medium

Restore revenue in tourism Likely Minor / minimal Low

Potential beneficial effects on public health

Reduce the risk of wasp stings Likely Massive (individual) / Low (community) to minor (community) significant (individual)

Potential beneficial effects on people and communities

Improve recreational activity Likely Minor / moderate Low to medium

Potential adverse effects on the environment

Increase chemical usage for gardeners Likely Minor Low

Vespula replace by worse pests Likely Minor Low

Impact on non-target species Unlikely Minor Low

Effects on food-webs Likely Minor Low

Hybridisation with native species Highly Minimal Negligible improbable

Potential adverse effects to the market economy

Decrease benefit for sellers and pest control Likely Minimal - Minor Low companies

Potential adverse effects on public health

Reduce research on wasp venom Highly Minimal Negligible improbable

EPA advice for APP203 875

Relationship of Māori to the environment

Summary of the applicant’s engagement with Māori

Information about the two BCAs proposed to mitigate social wasp populations was distributed in November 2019 to the EPA’s national network, Te Herenga, in order to ‘establish what areas of potential cultural risk should be addressed’ in the application. However, no feedback was received.

At the same period, the applicant, the Tasman District Council, contacted eight iwi in the South Island (Ngāti Tama ki Te Tau Ihu, Te Ātiawa o Te Waka-a-Māui, Ngāti Rārua, Ngāti Kōata, Ngāti Toa Rangatira, Ngāti Kuia, Ngāti Apa ki te Rā Tō, and Rangitāne o Wairau) and invited them to provide information or start a dialogue regarding the release of the two proposed BCAs. The Principal Manager, Policy, at Te Rūnanga o Ngāi Tahu, was also contacted.

One response was received from Te Ātiawa Manawhenua ki te Tau Ihu Trust. They raised concerns around the nature of control and the prospects and consequences of eradication, the extent of competition with resident pollinators, the risk to native bees, and previous biological control attempts and follow-up monitoring. The applicant answered these questions in the application form.

Submissions from Māori on this application

Te Rūnanga o Ngāi Tahu support the release of V. Inanis and M. paradoxus subject to long term monitoring (submission 127682). They acknowledge the adverse effects of social wasps on tourism, communities, health, the biodiversity (via disturbance of the food chain), and the economy (cost of baiting, lack of pollinators for the horticultural, farming and apicultural industries).

Kaupapa Kura Taiao cultural risk assessment

The potential effects on the relationship of Māori to the environment have been assessed in accordance with section 5(b), 6(d) and 8 of the Act. Under these sections, all persons exercising functions, powers and duties under this Act shall take into account the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna and other taonga, and the Treaty of Waitangi.

A summary of the full cultural risk assessment is prepared by Kaupapa Kura Taiao under s58(1)(a) of the Hazardous Substances and New Organisms Act is presented below (paragraph 216 to 229). The full report can be found in Appendix 2.

EPA advice for APP203 875

Analysis of impact

The benefits to Māori associated with this application are unlikely to outweigh any detrimental impacts to Māori.

The overall impact on the relationship Maori have with their environment and taonga is likely to be beneficial, and is likely to benefit the ability of Māori to exercise kaitiakitanga.

The overall impact on Maori economic wellbeing (arising from the impact on the environment and taonga) is likely to be beneficial.

The overall impact on Maori social wellbeing (arising from the impact on the environment and taonga) is likely to be beneficial. This includes impacts on Māori ways of life and taha hauora (human health and well-being).

The overall impact on Maori cultural wellbeing (arising from the impact on the environment and taonga) is likely to be beneficial. This includes potential impacts Māori may experience in relation to their customary practices, traditions, beliefs, institutions, and lore.

Te Tiriti o Waitangi (Treaty of Waitangi)

The Principles of the Treaty of Waitangi have been considered in relation to this application and no concerns arise under the Treaty Principles, as summarised below.

Māori interests are being actively protected in relation to this application.

The decision makers on this application are making a decision informed by a Maori perspective.

The EPA considers it is acting in good faith, and is acting reasonably and fairly, in respect of this application. Mātauranga Māori and tikanga Māori are being respected.

Kupu whakatepe (Conclusion)

Impact on the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social and cultural well-being

This application is likely to benefit the ability and capacity of Māori to maintain their economic, social, and cultural well-being.

Impact on the relationship of Māori and their culture and traditions with their environment and taonga

This application is likely to benefit the relationship of Maori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga.

Ngā Matapono o Te Titriri o Waitangi (Treaty of Waitangi principles)

The active protection principle: the Crown has a duty to actively protect Māori interests. No issues arise. The informed decision making principle: the Crown has a duty to make informed decisions. No issues arise. The partnership principle: to act fairly, reasonably, and in good faith. No issues arise.

EPA advice for APP203 875

Assessment against the Minimum Standards

Prior to approving the release of a new organism, the EPA is required to determine whether the two BCAs, M. paradoxus and V. inanis, meet the minimum standards set out in section 36 of the HSNO Act.

Can the BCAs cause any significant displacement of any native species within its natural habitat?

The applicant provided information from studies that indicated that the two candidate biological control agents are host-specific to social wasps in the family Vespidae.

Based on the absence of closely related wasps in New Zealand and the apparent host specificity, the ability for the two BCAs to cause significant displacement of any native species within its native habitat is considered very unlikely.

Can the BCAs cause any significant deterioration of natural habitats?

We considered the adverse indirect effects on ecosystem interactions, such as food webs, that could occur following the introduction of M. paradoxus and V. inanis (paragraphs 175 to 199). We concluded that it is unlikely the biological control agents would cause excessive pressure on native insect species or natural habitats through interactions such as competition with other insects for available food resources and for specialised insectivores feeding on wasps.

Can the BCAs cause any significant adverse effects on human health and safety?

There is no information to indicate that M. paradoxus and V. inanis would cause significant adverse effects on human health.

Can the BCAs cause any significant adverse effect to New Zealand’s inherent genetic diversity?

There are no native Meteocus or Volucella species present in New Zealand, therefore, it is very unlikely that the candidate agents could cross-breed naturally with native species thereby adversely affecting New Zealand’s inherent genetic diversity.

Can the BCAs cause disease, be parasitic, or become a vector for human, animal or plant disease?

There is no information to indicate that M. paradoxus and V. inanis would cause disease, be parasitic or become a vector for human, animal or plant disease.

Conclusion on the minimum standards

We consider that M. paradoxus and V. inanis meet the minimum standards as stated in the HSNO Act. Can the BCAs establish undesirable self-sustaining populations?

Section 37 of the Act requires the EPA to have regard to the ability of the organisms to establish undesirable self-sustaining populations and the ease with which the organisms could be eradicated if they established such a population.

EPA advice for APP203 875

We noted that the purpose of the application is to release the beetle M. paradoxus and the hoverfly V. inanis, to allow the organisms to establish self-sustaining populations and disperse to control the social wasps, V. vulgaris and V. germanica, in our environment. This is foundational of a classical biological control strategy and we therefore considered that any population of M. paradoxus and V. inanis, would not be undesirable.

The potential risks of the organisms are assessed above and were found to be low to negligible (Table 7). In the very unlikely event a population is shown to become undesirable it would be difficult and expensive to eradicate such a population as it would require the application of non- specific pesticides.

Recommendation

Our assessment has found that the benefits of releasing M. paradoxus and V. inanis, outweigh any identified risks or costs. We, therefore, recommend that the application be approved.

EPA advice for APP203 875

References

Allergy New Zealand, 2010. Insect sting allergy. Retrieved 14 August. Page last http://www.allergy.org.nz/A-Z+Allergies/Insect+sting+allergy.html Allsopp MH, De Lange WJ, Veldtman R 2008. Valuing insect pollination services with cost of replacement. PloS one 3(9): e3128. Apiculture New Zealand, 2019. Pī ā ora. Bees giving life. Retrieved 2 August. Page last https://apinz.org.nz/ Archer M, Halstead A 2014. Population dynamics of social wasps (Hymenoptera: Vespidae) in the Royal Horticultural Society’s garden at Wisley, Surrey. Entomologist’s Monthly Magazine 150: 19-26. Azmeh S 1999. Mimicry and the hoverfliesthesis, University of Nottingham Nottingham, UK. Ball R 1969. Legume and fertilizer nitrogen in New Zealand pastoral farming. Proceedings of the New Zealand Grassland Association. Pp. 117-126. Ball SG, Morris RK 2000. Provisional atlas of British hoverflies (Diptera, Syrphidae). Biological Records Centre, Centre for Ecology and Hydrology. Barlow ND, Goldson SL 2002. Alien invertebrates in New Zealand. Biological Invasions. CRC, Boca Raton: 195-216. Barlow ND, Moller H, Beggs JR 1996. A model for the effect of Sphecophaga vesparum vesparum as a biological control agent of the common wasp in New Zealand. Journal of applied ecology: 31-44. Batelka J 2007. Ripiphoridae (Coleoptera) of Greece and Turkey with notes on their distribution in the Eastern Mediterranean and some neighbouring countries. Acta Musei Moraviae, Scientiae Biologicae 92: 155-175. Beggs JR 2000. Impact and control of introduced Vespula wasps in New Zealand. Hymenoptera: Evolution, Biodiversity and Biological Control. CSIRO Publishing, Collingwood: 404-409. Beggs JR, Rees JS 1999. Restructuring of Lepidoptera communities by introduced Vespula wasps in a New Zealand beech forest. Oecologia 119(4): 565-571. Beggs JR, Harris RJ, Read PEC 1996. Invasion success of the wasp parasitoid Sphecophaga vesparum vesparum (Curtis) in New Zealand. New Zealand Journal of Zoology, 23:1, 1-9, DOI: 10.1080/03014223.1996.9518060. Beggs JR, Rees JS, Harris RJ 2002. No evidence for establishment of the wasp parasitoid, Sphecophaga vesparum burra (Cresson)(Hymenoptera: Ichneumonidae) at two sites in New Zealand. New Zealand Journal of Zoology 29(3): 205-211. Bonckaert W 2011. Conflict over male production in Vespinae wasps. Branstetter MG, Danforth BN, Pitts JP, Faircloth BC, Ward PS, Buffington ML, Gates MW, Kula RR, Brady SG 2017. Phylogenomic Insights into the Evolution of Stinging Wasps and the Origins of Ants and Bees. Current Biology 27(7): 1019-1025. Brown B, 2018. Wasp biocontrol update 13. Retrieved 22 July. Page last https://www.landcareresearch.co.nz/about/news/snippets/wasp-biocontrol-update-13 Brown B, Groenteman R 2017. Poster 31: Vespula biocontrol in New Zealand revisited. In: Manaaki Whenua Landcare Research ed. Butz Huryn VM 1995. Use of native New Zealand plants by honey bees (Apis mellifera L.): a review. New Zealand journal of botany 33(4): 497-512. CABI, 2008. Datasheet: Vespula germanica (German wasp). Retrieved 01 July. Page last https://www.cabi.org/isc/datasheet/56667#toDistributionMaps CABI, 2009. Datasheet: Vespula vulgaris (wasp, common). Retrieved 01 July. Page last https://www.cabi.org/isc/datasheet/56675#toDistributionMaps

EPA advice for APP203 875

Clapperton BK, Alspach PA, Moller H, Matheson AG 1989. The impact of common and German wasps (Hymenoptera: Vespidae) on the New Zealand beekeeping industry. New Zealand journal of zoology 16(3): 325-332. Clapperton BK, Tilley JAV, Beggs JR, Moller H 1994. Changes in the distribution and proportions of Vespula vulgaris (L.) and Vespula germanica (Fab.)(Hymenoptera: Vespidae) between 1987 and 1990 in New Zealand. New Zealand Journal of Zoology 21(3): 295-303. Clapperton K, 1989. Wasp warfare. Retrieved 16 August. Page last https://www.nzgeo.com/stories/wasp-warfare/ Cook DC 2019. Quantifying the potential impact of the European wasp (Vespula germanica) on ecosystem services in Western Australia. NeoBiota 50: 55. D'adamo P, Sackmann P, Corley JC, Rabinovich M 2002. The potential distribution of German wasps (Vespula germanica) in Argentina. New Zealand Journal of Zoology 29(2): 79-85. De Groot M 2012. rod volucella (diptera: Syrphidae) v Sloveniji. Acta entomologica slovenica 20: 2. De Villiers M, Kriticos DJ, Veldtman R 2017. Including irrigation in niche modelling of the invasive wasp Vespula germanica (Fabricius) improves model fit to predict potential for further spread. PLoS One 12(7). Department of Conservation, 2006. Introduced wasps. Retrieved 17 July. Page last https://www.doc.govt.nz/globalassets/documents/about-doc/concessions-and- permits/conservation-revealed/wasps-lowres.pdf Department of Conservation, 2016. Community push to wipe out wasps in Nelson-Tasman. Retrieved 08 July. Page last https://blog.doc.govt.nz/2016/12/22/community-push-to-wipe-out-wasps-in- nelson-tasman/ Department of Conservation, 2017. Animal pests: Wasps. Retrieved 10 July. Page last https://www.doc.govt.nz/nature/pests-and-threats/animal-pests/wasps/ Dettner K, Liepert C 1994. Chemical mimicry and camouflage. Annual review of entomology 39(1): 129-154. Dixon G, 2018. Wasps: The $2 billion threat to New Zealand's birds and bees. Retrieved 23 July. Page last https://www.noted.co.nz/planet/wasps-the-2-billion-threat-to-nzs-birds-and-bees/ Don W 2007. Ants of New Zealand. Otago University Press. Donovan B 1980. Interactions between native and introduced bees in New Zealand. New Zealand journal of ecology: 104-116. Donovan B 1991. Nest initiation by German and common wasp queens (Hymenoptera: Vespidae) and nest fate at Christchurch, New Zealand. New Zealand journal of zoology 18(2): 95-99. Donovan B, Wier S 1978. Development of hives for field population increase, and studies on the life cycles of the four species of introduced bumble bees in New Zealand. New Zealand journal of agricultural research 21(4): 733-756. Donovan BJ 1984. Occurrence of the common wasp, Vespula vulgaris (L.)(Hymenoptera: Vespidae) in New Zealand. New Zealand Journal of Zoology 11(4): 417-427. Donovan BJ 2007 Apoidea (Insecta: Hymenoptera). Fauna of New Zealand. Early J, 2007. Wasps and bees - Stinging wasps. Te Ara - the Encyclopedia of New Zealand. Retrieved 10 July. Page last https://teara.govt.nz/en/photograph/11150/german-wasp-and- common-wasp Fletcher DJ, Ross KG 1985. Regulation of reproduction in eusocial Hymenoptera. Annual review of entomology 30(1): 319-343. Fordham RA 1961. Notes on the German Wasp - Vespula germanica. Tuatara: Volume 9, Issue 1. University of Victoria. Gaze PD, Cloud MN 1983. Honeydew and its importance to birds in beech forests of south island, New Zealand. New Zealand journal of ecology 6: 33-37. Goulson D, Hanley ME 2004. Distribution and forage use of exotic bumblebees in South Island, New Zealand. New Zealand Journal of Ecology: 225-232. 45

EPA advice for APP203 875

Gresty C 2017. Effectiveness of UK agri-environment schemes in supporting cavity-nesting solitary beesthesis, University of Oxford. Hadley D, 2019. What good are wasps? Retrieved 4 September. Page last https://www.thoughtco.com/what-good-are-wasps-1968081 Hall A, 2018. Vulgar wasps. Retrieved 4 September. Page last https://www.wildernessmag.co.nz/vulgar-wasps/ Hansford D, New Zealand Geographic, 2017. The coming swarm. Retrieved 16 August. Page last https://www.nzgeo.com/stories/the-coming-swarm/ Harris AC 1987. Pompilidae (Insecta: Hymenoptera). Fauna of New Zealand 12. Harris AC 1994. Sphecidae (Insecta: Hymenoptera). Fauna of New Zealand 32. Harris R, Oliver E 1993. Prey diets and population densities of the wasps Vespula vulgaris and V. germanica in scrubland-pasture. New Zealand journal of ecology: 5-12. Harris RJ 1991. Diet of the wasps Vespula vulgaris and V. germanica in honeydew beech forest of the South Island, New Zealand. New Zealand journal of zoology 18(2): 159-169. Harris RJ 1996. Frequency of overwintered Vespula germanica (Hymenoptera: Vespidae) colonies in scrubland‐pasture habitat and their impact on prey. New Zealand Journal of Zoology 23(1): 11-17. Hart NH 2007. Industrious native bees: a case study in Whangareithesis, University of Auckland. Heinrich B 2012. The Bumblebee Colony Cycle. A World of Insects: 338. Heitmans WR, Peeters TM 1996. Metoecus paradoxus in The Netherlands (Coleoptera: Rhipiphoridae). Entomologische berichten-nederlandsche entomologische vereenigung 56: 109-117. Holzschuh A, Steffan-Dewenter I, Tscharntke T 2009. Grass strip corridors in agricultural landscapes enhance nest‐site colonization by solitary wasps. Ecological Applications 19(1): 123-132. Holzschuh A, Steffan‐Dewenter I, Tscharntke T 2010. How do landscape composition and configuration, organic farming and fallow strips affect the diversity of bees, wasps and their parasitoids? Journal of Animal Ecology 79(2): 491-500. Hopwood J, Hoffman Black S, Vaughan M, Lee-Mader E 2013. Beyond the birds and the bees. Effects of neonicotinoid insecticides on agriculturally important beneficial invertebrates. The Xerces Society for Invertebrate Conservation. Hunt R 1996. Bandits of the Beech Forest [Television documentary]. New Zealand: NZOnScreen. https://www.nzonscreen.com/title/bandits-of-the-beech-forest-1996/credits. Institute for Economics & Peace 2019. Global Peace Index 2019: Measuring Peace in a Complex World. Report. Khaghaninia S, Pour Abad RF, Ehteshamnia N 2010. Some of hoverflies fauna of subfamily Milesiinae (Diptera: Syrphidae) of Qurigol in East Azerbayjan province, Northwest Iran. Munis Entomology & Zoology 5: 911-916. Krewenka KM, Holzschuh A, Tscharntke T, Dormann CF 2011. Landscape elements as potential barriers and corridors for bees, wasps and parasitoids. Biological Conservation 144(6): 1816- 1825. Kyd Beth 2015. KiwiTech Bulletin N99: Wasps. Zespri Orchard Productivity Centre. Lester PJ, Beggs JR 2019. Invasion success and management strategies for social Vespula wasps. Annual Review of Entomology 64: 51-71. MacIntyre P, Hellstrom J 2015. An evaluation of the costs of pest wasps (Vespula species) in New Zealand. International Pest Control 57(3): 162. Manaaki Whenua Landcare Research, 2014. Wasps Web. Retrieved 10 July. Page last https://www.landcareresearch.co.nz/science/plants-animals- fungi/animals/invertebrates/invasive-invertebrates/wasps

EPA advice for APP203 875

Manaaki Whenua Landcare Research, 2018. 2018 Bee Colony Loss Survey. Retrieved 9 August. Page last https://www.landcareresearch.co.nz/science/portfolios/enhancing-policy- effectiveness/bee-health/2018-survey Manaaki Whenua Landcare Research, ND. Life cycle of a wasp. Retrieved 9 October. Page last https://www.landcareresearch.co.nz/discover-our-research/biosecurity/invasive- invertebrates/vespula-wasps/life-cycle-of-a-wasp/ Maritano U 2020. Hoverfly (Diptera: Syrphidae) assemblage of an oak–hornbeam in the Merlino Wood Natural Reserve and implications for its conservation. Biodiversity Data Journal 8. Merchento, 2015. Vespex, wasp bait technology. . Retrieved 08 July. Page last https://www.merchento.com/index.html Ministry for Primary Industries 2018. Apiculture - 2018 apiculture monitoring programme. Moller H, Tilley J 1989. Beech honeydew: seasonal variation and use by wasps, honey bees, and other insects. New Zealand journal of zoology 16(3): 289-302. Moller H, Tilley JAV, Thomas BW, Gaze PD 1991. Effect of introduced social wasps on the standing crop of honeydew in New Zealand beech forests. New Zealand journal of zoology 18(2): 171- 179. Morato EF, Martins RP 2006. An overview of proximate factors affecting the nesting behavior of solitary wasps and bees (Hymenoptera: Aculeata) in preexisting cavities in wood. Neotropical Entomology 35(3): 285-298. Morton J, 2018. Neonicotinoid ban in NZ could leave no alternatives for farmers - experts. Retrieved 31 July. Page last https://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=12043526 New Zealand Plant Conservation Network, 2008. Vespula germanica. Retrieved 12 July. Page last http://www.nzpcn.org.nz/threats_details.aspx?ID=18 Olmi M 2007. New Zealand Dryinidae and Embolemidae (Hymenoptera: Chrysidoidea): new records and description of Bocchus thorpei new species. Records of the Auckland Museum: 5-16. Parmentier T 2020. Guests of social insects. Encyclopedia of Social Insects, Springer. Peters RS, Krogmann L, Mayer C, Donath A, Gunkel S, Meusemann K, Kozlov A, Podsiadlowski L, Petersen M, Lanfear R 2017. Evolutionary history of the Hymenoptera. Current Biology 27(7): 1013-1018. Plunkett GM, Moller H, Hamilton C, Clapperton BK, Thomas CD 1989. Overwintering colonies of German (Vespula germanica) and common wasps (Vespula vulgaris)(Hymenoptera: Vespidae) in New Zealand. New Zealand journal of zoology 16(3): 345-353. Prezoto F, Maciel TT, Detoni M, Mayorquin AZ, Barbosa BC 2019. Pest control potential of social wasps in small farms and urban gardens. Insects 10(7): 192. Roubik DW 2012. Ecology and Social Organisation of Bees. eLS. Rupp L 1989. The central European species of the genus Volucella (Diptera, Syrphidae) as commensals and parasitoids in the nests of bees and social wasps: studies on host-finding, larval biology and mimicry. Albert-Ludwigs University, Freiburg-im-Breisgau, Germany. Inaugural Dissertation. Savoie B, Argall J, Clay H, 1996. Managing honeybee hives for the pollination of wild blueberries. Retrieved 6 August. Page last https://www2.gnb.ca/content/gnb/en/departments/10/agriculture/content/bees/managing.html Science Learning Hub – Pokapū Akoranga Pūtaiao, 2013. The role of clover. Retrieved 1 August. Page last https://www.sciencelearn.org.nz/resources/966-the-role-of-clover Sengupta J, Naskar A, Maity A, Hazra S, Mukhopadhyay E, Banerjee D, Ghosh S 2016. An Updated Distributional Account of Indian Hover flies (Insecta: Diptera: Syrphidae). Singh R, Singh G 2016. Aphids and their biocontrol. Ecofriendly Pest Management for Food Security, Elsevier. Pp. 63-108.

EPA advice for APP203 875

Sobek S, Tscharntke T, Scherber C, Schiele S, Steffan-Dewenter I 2009. Canopy vs. understory: Does tree diversity affect bee and wasp communities and their natural enemies across forest strata? Forest Ecology and Management 258(5): 609-615. Southern Cross, 2017. Medical library: Bee wasp sting allergies and analphylaxis. Retrieved 14 August. Page last https://www.southerncross.co.nz/group/medical-library/bee-wasp-sting- allergies-and-anaphylaxis Spradbery P, Dvorak L 2013. Invasive species compendium. CABI 4066. Spurr EB 1995. Protein bait preferences of wasps (Vespula vulgaris and V. germanica) at Mt Thomas, Canterbury, New Zealand. New Zealand Journal of Zoology 22(3): 281-289. T.E.R.R.A.I.N., 2017. Taranaki Educational Resource,Research, Analysis and Information Network. Wasp nests. Retrieved 08 July. Page last http://www.terrain.net.nz/friends-of-te-henui- group/bees-and-wasps/wasp-nests-photos-and-text.html Tasman District Council ND. Pest Wasps in Tasman - Nelson - What’s the Difference? Theraulaz G, Bonabeau E, Deneubourg JL 1998. The origin of nest complexity in social insects. Complexity 3(6): 15-25. Thomas CD, Moller H, Plunkett GM, Harris RJ 1990. The prevalence of introduced Vespula vulgaris wasps in a New Zealand beech forest community. New Zealand Journal of Ecology 13(1): 63- 72. Thomas CR 1960. The European wasp (Vespula germanica Fab.) in New Zealand. Department of Scientific and Industrial Research, New Zealand. Toft RJ, Rees JS 1998. Reducing predation of orb‐web spiders by controlling common wasps (Vespula vulgaris) in a New Zealand beech forest. Ecological Entomology 23(1): 90-95. Tscharntke T, Gathmann A, Steffan‐Dewenter I 1998. Bioindication using trap‐nesting bees and wasps and their natural enemies: community structure and interactions. Journal of applied ecology 35(5): 708-719. UK Beetles, ND. Ripiphoridae. Retrieved 4 June. Page last https://www.ukbeetles.co.uk/ripiphoridae Valentine EW, Walker AK 1983. Three families of Hymenoptera new to New Zealand. New Zealand Entomologist Vol. 7, No. 4. Van Oystaeyen A, van Zweden JS, Huyghe H, Drijfhout F, Bonckaert W, Wenseleers T 2015. Chemical Strategies of the Beetle Metoecus Paradoxus, Social Parasite of the Wasp Vespula Vulgaris. Journal of chemical ecology 41(12): 1137. van Veen MP 2004. Volucella. Hoverflies of Northwest Europe, KNNV Publishing. Pp. 223-225. Vanoye-Eligio M, Víctor HortaVega J, Vanoye-Eligio V, Rosas-Mejía M, Jaime Estrada Ramírez L 2020. Review of Occurrence of Vespoidea (Hymenoptera) in the State of Campeche, Mexico. Journal of Entomological Science 55(3): 366-381. Waikato Region Council 2016. Biosecurity series - animal factsheetWasps: Australian paper wasp (Polistes humilis), Asian paper wasp (Polistes chinensis), common wasp (Vespula vulgaris) and German wasp (Vespula germanica). Walsby J 1995. Paper wasps-guests or pests? New Zealand Geographic. Ward D, Early J, Schnitzler F-R, Hitchmough R, Stringer I 2014. The conservation status of New Zealand Hymenoptera. New Zealand Entomologist 35(2): 116-119. Ward DF 2013. Revision of Bethylidae (Hymenoptera) from New Zealand. New Zealand Entomologist 36(2): 107-130. Wasp removal UK, 2011. Life cycle of the Wasp (Vespula vulgaris, Vespula Germanica). Retrieved 1 July. Page last https://www.wasp-removal.com/wasp-lifecycle.php#waspfood workshop L, 2017. Bee fruitful. Pollination services. Retrieved 6 August. Page last http://www.leworkshop.co.nz/bee-pollination-hawkes-bay Xerces Society, ND. About Bumble Bees. Retrieved 18 November. Page last https://xerces.org/bumblebees/about

EPA advice for APP203 875

Appendix 1: Summary of submissions

# H Position Submitter Comments

Mr Care wonders why the eradication is not focused on paper wasps as Vespula wasps can be N Neither Clinton Care eradicated with Vespex.

127659

The submitter notes the benefits of the Asian paper wasps on his organic orchard. However, since N Support Member of Public 01 the massive increase of wasps due to the recent appearance of giant willow aphids, he relies on chemical treatments by neighbours to keep the wasp populations under control. Therefore he

127660 supports the release of the BCAs to keep the wasp populations under control.

N Support Peter King Mr King supports the release due to the danger wasp nests represent for humans.

127661

DOC DOC strongly supports the release of both BCAs due to the adverse effects of wasps on health and Y Support biodiversity. They note the host specificity of the BCAs. (Rod Hitchmough)

127662

The submitter does not support the application as previous introduction (weasels) have been a N Oppose Member of Public 02 failure.

127663

N Support Linde Wild Rose Ms Wild Rose supports the release due to the devastating impact of wasps on insects.

127664

Mr Blick opposes the release as wasps play an important role in his organic garden. He adds that Y Oppose Andrew Blick wasp venom could be use in medicine.

127665

Bay of Plenty The BoPRC supports the release of both BCAs to reduce the adverse effects of wasps on health and N Support Regional Council – BoPRC (Shane the environment on the region.

127666 Hona)

Mr Buckland supports the release of the BCAs underlying the financial cost of wasps on many N Support Bryce Buckland industries (Agriculture, Farming, Viticulture, Forestry, Beekeeping and Tourism), as well as their adverse effects on birdlife. He notes the limited impact of manual removal of wasp nests and the

127667 usage of pesticides with re-invasion the next season from non-treated areas.

MDC supports the release of the BCAs as Vespula wasps build to extremely large numbers in the region. They list the damages caused by wasps on the community and the effects on biodiversity. Marlborough District N Support Council – MDC Due to the wide distribution of wasps in the region, the council has to pick its battles and use (Jono Underwood) pesticides to eliminate nests within a discrete area. However, wasps continue to thrive outside these

127668 controlled areas and re-invade the treated areas the following summer. The council supports the use of these two host specific BCAs as a landscape scale tool.

The BWG supports the release of the two BCAs as Vespula wasps have significant environmental, Biosecurity Working economic and human health impacts in New Zealand. They note that chemical usage (e.g. Vespex) N Support Group – BWG (Kane is expensive, labour intensive and only effective late in the season, as well as limited to accessible McElrea) areas. They list the key points of the Manaaki Whenua - Landcare Research’s studies as well as the 127669 benefits the release will have in New Zealand.

The submitter supports the use of biocontrol agents as a complementary tool to control wasps. He notes that the BCAs would affect wasps at a different time of year in remote areas. He also notes that Polistes wasps could benefit from the control of Vespula wasps, however, with a lower impact on

the environment. Y Support Member of Public 03 He mentions the significant discouragement to the recreational use of certain areas at certain times of year due to wasps, leading to a circular logic where lower frequentation of recreational areas lead 127670 to de-prioritisation of control in the area. The submitter lists the zones where chemical controls cannot be used, underlying the absence of exclusion zones for the action of the BCAs.

EPA advice for APP203 875

GWRC notes the value of BCAs in regions where wasp numbers are high. They mention the adverse effects of wasps on biodiversity and health, as well as the cost to manage them. GWRC notes that usage of pesticides are labour intensive and continuous as treated areas are quickly recolonized.

Greater Wellington They list the benefits that could result from the introduction of the BCAs as well as the potential risks. Regional Council – N Support GWRC (Davor They mention that social wasps are under the Regional Pest Management plan 2019-2039. The

127671 Bejakovich) council recently started to successfully use Vespex to control wasps and they are concerned by the presence of giant willow aphids that could lead to an increase in wasp numbers. They added that testing and management needs to be thorough prior to the release as little can be done once the BCAs is established in the wild.

Ms Hicks notes the adverse effects of wasps but wonders if the BCAs are the right solution. She N Neither Margaret Hicks asks if the BCAs could pose problem in the future and if the EPA has any measure to prevent this.

127672

Northland Regional Council supports the application underlining the adverse effects of wasps on Northland Regional health, the horticulture industry, community, and honey production. They note that the BCAs are N Support Council (Jenny unlikely to attack solitary bees or wasps and that their pollen requirements are small compared to Dymock)

127673 introduced bumblebees and honeybees.

N Support Member of Public 04 The submitter supports the release.

127674

Mr Frost notes the damaging effects of wasps on his property through the decrease of native

butterflies such as the forest ringlet butterfly which is now only found above the altitude limits of Vespid wasps. He mentions the efficiency of Vespex only late in the season once wasps have Y Support Roger Frost already caused extensive environmental damage.

127675 He lists the economic and environmental benefits of using a long-term tool and notes the low potential adverse effects of the BCAs on native species compared to the impact of wasps.

Trees and Bees supports the release of the BCAs to protect honeybees from wasps. The decrease Trees and Bees Ltd of wasp populations would reduce the cost and time spend to protect the bees by controlling out of N Support (Ricki Leahy) reach populations and limiting re-infestation of chemically controlled areas They have no concern

127676 regarding potential adverse effects of the BCAs on native bees or honeybees

MPI supports the release of the BCAs due to the negligible biosecurity risks and the benefits on biodiversity, economy and health. They note the high specificity of both BCAs but underline the lack N Support MPI (Barry Wards) of information around the efficacy of the BCAs to reduce wasp populations as well as the lack of host

127677 range testing compared to previous applications.

N Support Member of Public 05 The submitter supports the release of the BCAs to protect monarch butterflies.

127678

Ms O’Boyle supports the release of the BCAs to control wasp populations and protect native N Support Jan O'Boyle butterflies.

127679

Apiculture New APINZ emphasises the importance of the apiculture industry for New Zealand‘s economy.

Zealand - APINZ on They support the release of the BCAs to protect beehives and the revenue they generate. They note Y Support behalf of its Science the geographical limitation of chemical control and welcome a more widespread suppression of wasp and Research Focus populations. APINZ lists the benefits of the decrease of wasps for the apiculture industry and note 127680 Group (Sue Carter) the limited risks for honeybees associated with the release of the BCAs.

Andrea Christine Ms Dorn supports the release of the BCAs to limit the adverse effects of wasps on the monarch Y Support Dorn butterfly.

127681

Te Rūnanga o Ngāi Tahu - TRoNT TRoNT supports the use of BCAs to control pests subject to long term monitoring. They noted the N Support (Dr Benita Wakefield major problem of wasps relates to risks on people, health, the tourism industry, biodiversity, primary and Stephanie industries. 127682 Dijkstra)

EPA advice for APP203 875

The officer of the Auckland Council supports the release of the BCAs as an additional long-term

management tool to help control wasps which are one of the most impactful insect pests in the Auckland Council region. The widespread distribution of Vespula wasps forces the council to focus on protecting sites N Support (Emma Edney- of high ecological value or frequented by the public. The officer noted the public is especially Browne) concerned by the application to release the BCAs to control other insects and that host specificity 127683 trials should be thorough and include the monitoring of the BCA population and impact at different levels on the food webs.

Excell Biosecurity Excell Biosecurity supports the release of the BCAs to reduce the adverse effects of wasps. The N Support (David Hunter) biocontrol agents would be a welcome addition for wasp control especially in rural areas and in cities where chemicals have a limited impact.

127684

The submitter considers the two BCAs as a valuable tool for conservation, provided their efficacy is observed in host-range testing and they have minimal adverse effects on non-target organisms. N Support Member of Public 06 She noted that trials of pesticides on wasps have not been successful and raises some points to consider before the release including a broader approach on the impacts, host range tests to

127685 strengthen the application, information on the adult BCAs impacts, post release monitoring, and pathogen screening.

Moths and Butterflies of New Ms Knight is concerned of the devastating impact of wasps on moths and butterflies such as the N Support Zealand Trust forest ringlet. The trust supports the release of the BCAs to reduce the number of Vespula species.

127686 (Jacqui Knight)

Mr Mason opposes the release of new organisms due to the potential disturbance of trophic webs. Y Oppose Clifford Mason He adds that the impact and efficacy is unproven.

127687

Oak & Thistle Oak & Thistle supports the release of the BCAs considering the potential beneficial impacts on native N Support Limited (Derek invertebrates. Craig)

127688

EPA advice for APP203 875

Appendix 2: Māori Perspectives Report (MPR)

This report is prepared by Kaupapa Kura Taiao under s 58(1)(a) of the Hazardous Substances and New Organisms Act 1996 (“the Act / HSNO”).

Executive Summary

Kaupapa Kura Taiao (the EPA’s Māori Policy and Operations team) has undertaken an assessment to consider potential impacts of the parasitoid hoverfly Volucella inanis and parasitoid wasp nest beetle (Metoecus paradoxus) as biological control agents (BCA) for common wasps (Vespula vulgaris) and German wasps (Vespula germanica) on the economic, social, and cultural well-being of Māori, and the relationship of Māori with the environment, pursuant to sections 5(b), 6(d) and 8 of the HSNO Act.

The Volucella hoverfly and wasp nest beetle BCAs are likely to benefit the relationship of Māori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga.

The Volucella hoverfly and wasp nest beetle BCAs are likely to benefit the ability and capacity of Māori to maintain their economic, social, and cultural well-being.

Ngā Mātāpono o Te Tiriti o Waitangi (the Principles of the Treaty of Waitangi) have been considered in relation to this application – no issues arise in this regard. 1. Purpose and scope of this MPR The purpose of this MPR is to inform the decision maker on the potential impacts on the relationship of Māori and their culture and traditions with their environment and taonga, and any issues that arise under the principles of The Treaty of Waitangi (Te Tiriti o Waitangi) from the application for the Volucella hoverfly (Volucella inanis) and wasp nest beetle (Metoecus paradoxus) BCAs. The MPR also provides advice to the decision maker on any potential impact on the capacity of Māori to maintain and enhance economic, social and cultural wellbeing.

The MPR is an assessment under s 6(d) and 8 of the Act. Advice is also provided on any implications arising under s 5(b) of the Act.

2. Ngā here ture (Statutory obligations) Section 5(b) provides that to achieve the purpose of the Act, the decision maker must recognise and provide for the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social, and cultural wellbeing and for the reasonably foreseeable needs of future generations.

Section 6(d) of the Act obliges all persons exercising functions, powers, and duties under the Act, to achieve the purpose of the Act, to take into account the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna, and other taonga.

In accordance with section 8, the decision maker is required to take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi).

The Treaty principles most relevant to assessing and deciding this application are:  The principle of active protection of Māori interests.  The principle of informed decision making.  The principle of partnership.

EPA advice for APP203 875

3. Nomenclature

This report hereafter refers to common wasps (Vespula vulgaris) and German wasps (Vespula germanica) together as ‘Vespula wasps’, unless when referring specifically to one of these two species.

The parasitoid hoverfly Volucella inanis is hereafter referred to as the ‘Volucella hoverfly’, and the parasitoid beetle Metoecus paradoxus is referred to as the ‘wasp nest beetle’.

4. Māori worldviews of insects and biocontrols Insects are culturally significant due to the part they play in kōrero o mua (traditional narratives) and Māori environmental lore. Kōrero o mua tell us that insects and other arthropods belong to a group within the domain of Tāne-mahuta (deity of humans, forests and forest dwelling species) known to Māori as Te Aitanga Pepeke (insect relatives) and Te Tini o Hakuturi (the multitude of bow-legged ones). The broad domain of Tāne is sometimes known as Te Marae o Tāne (literally ‘the precinct of Tāne’), which can be interpreted loosely from a western point of view as being terrestrial ecosystems. Te Aitanga Pepeke is a sub-group representing arthropods. The Vespula wasps, Volucella, and wasp nest beetle are all pepeke (insects) and therefore belong to Te Marae o Tāne (terrestrial ecosystems), and specifically Te Aitanga Pepeke.

Māori may also associate Vespula wasps with the domain of Whiro (the deity of darkness, evil, death and disease) due to the threat they pose to human and animals, ecosystems and individual species. Wasp infestations, and their consequential adverse effects on livelihoods and lifestyles, also fall within the domain of Whiro.

The interaction between Vespula wasps, Volucella hoverfly, and wasp nest beetle reflects the eternal struggle between Tāne and Whiro, where living things are always at risk of being compromised by misfortune and danger – good pitched against bad. This tension is recalled in korero o mua which recount that it was Whiro who, on his unending quest to destroy humankind, plants and creatures created by Tāne, sent an army of insects, birds and bats to kill Tāne when the latter climbed to the heavens to fetch the three baskets of sacred knowledge – which Whiro tried to get himself. However, Tāne called the winds to keep them away. As Tāne came back down with the baskets, Whiro sent out a swarm of beetles, but Tāne defeated them too. He took all of Whiro’s insects and birds to his forests, where they remain to this day. This story illustrates that good eventually triumphs over evil, and that long lasting change can be inspired by great leaders.

Plants, birds, forests, ecosystems, and the fauna inhabiting them also belong to the domain of Tāne- mahuta, along with the Vespula wasps, Volucella hoverfly, and wasp nest beetle. Māori value these things in a multifaceted way that recognises their tangible and intangible uses as well as historical and contemporary importance. Some plants and birds retain special significance even when their uses change or they are no longer used but have ‘remembered’ cultural value. This worldview respects past and evolving relationships between people and the natural world, and connects Māori with their culture and history. There is hardly a facet of classical Māori culture that did not somehow connect with biological resources and natural materials. Māori regard all native flora and fauna as taonga species and value exotic species for their many beneficial uses. In the latter case, this is because introduced species may offer new or different attributes that are useful and are therefore readily adopted. Biological control agents (BCAs) are an example of this.

Māori historically used BCAs, albeit on a domestic scale, to manage pests prior to European contact. For example, Māori are known to have kept karoro (black-backed gulls) as pets which they trained to eat caterpillars that infested kumara crops. Post-contact with Europeans, introduced animals became prominent in the everyday biosecurity of kāinga (homes and settlements). For example, when Māori 53

EPA advice for APP203 875

began to keep cats for their effectiveness in controlling mice and rats was well-known and appreciated by their owners. Similarly, in rural environments, dogs are used to hunt other pests such as mustelids, rabbits and possums. Dogs and cats help to suppress rodents and lower risk to poultry and eggs – valuable home-sourced food for rural whānau. Biological controls are also employed in contemporary gardens where companion planting is used to attract beneficial insects and repel pests.

5. Ngā wāpi i Aotearoa (Vespula wasps in Aotearoa) There are two species of Vespula wasps in Aotearoa, the common wasp and German wasp, both of which were accidentally introduced from their kāinga tūturu (true home, natural habitat) in Europe.

Vespula wasps are known to Māori as wāpi, a transliteration of the word ‘wasp’, and sometimes as katipō. Katipō in this instance means ‘inactive at night’, which describes the habit of Vespula wasps staying in their nests at night (not be confused with the native spider katipō, which means ‘night stinger’). The German wasp has occasionally been referred to in the past as pī Waikato (Waikato bee) due to their discovery near Hamilton in 1945.

Vespula wasps are widely distributed throughout Aotearoa including many offshore islands around the country. They build their paper mache nests in a variety of places in rural and urban environments, including cavities in the ground, in buildings and structures, in trees, and discarded equipment. Vespula species spread rapidly, as queen wasps in each nest can produce more than 1000 queens, each of which can start their own nests the following season. Around 10% of German wasp nests are known to over-winter, in some cases growing into huge perennial colonies.

5.1. Ngā pānga taiao (environmental impacts) Vespula wasps have generated the following issues:

 Substantial adverse impact on biodiversity and ecosystems across Aotearoa.

 Outcompeting other species for honeydew in beech forests which is an important food source for taonga species of birds and arthropods.

 Prey on a wide range of arthropods which are also a food source for taonga birds. These include many species that are culturally or economically important to Māori, some of which are declining or threatened species.

 Adverse impacts on honey production by killing honey bees and robbing honey from hives.

 Pose a significant public health hazard due to their aggressive nature particularly when nests are disturbed and viciously attack people or animals (pets).

 Diminish enjoyment of outdoor activities.

Vespula wasps are voracious predators of a wide range of pepeke (arthropods) that are culturally or economically significant to Māori including wētā, rō (stick insects), pūngāwerewere (spiders), kēkerengū (cockroaches), pōpokorua (ants), hiore kakati (earwigs), ngaro iro (blowflies, houseflies), tūpanapana (click bettles), kurikuri (ground beetles), kāwhitiwhiti (grasshoppers), kihikihi (cicadas), pāpaka nguturoa (weevils), mūmūtawa (ladybirds), ngaro tamumu (hoverflies), kuturiki (aphids), and pepe (moths and butterflies) as well as various other pāpapa (beetles) and ngarongaro (flies).

Some of the above-mentioned pepeke are beneficial. For example, pūngāwerewere (spiders), and mūmūtawa (ladybirds) prey on a range of pest insects and mites, while ngaro tamumu (NZ hoverflies) are pollinators.

EPA advice for APP203 875

Vespula wasps also prey on pī rāwaho (introduced bees) including pī honi (honey bees) and pī rorohū (bumble bees), which are economically important as pollinators and, in the case of honey bees, producers of honey. A significant number of Māori work with agricultural and horticultural systems or ecosystems where pollination is essential to the healthy functioning of those systems. Also, an increasing number of apiarists are Māori.

Beekeeping enables natural resources to be harvested without damaging ecosystems or needing to own the resources on which bees forage. It provides a source of employment and income that can support Māori wishing to live in their hau kāinga (traditional home communities) particularly in remote areas.

Vespula wasps reduce the food supply available for insect-eating taonga including tūī (parson bird), kākā (bush parrot), korimako (bellbird), riroriro (grey warbler), pīwakawaka (fantail), miromiro (tomtit), tauhou (waxeye), titipounamu (rifleman), mohua (yellowhead), pōpokokatea (whitehead), kōtare (kingfisher), as well as various moko (lizards). These wasps are known to kill fledgling birds in nests.

Since Vespula wasps populations are dense in beech forests and are efficient harvesters of honeydew, competition at the height of the wasp season is forcing nectar-feeding pī honi (honey bees), tūī (parson birds), and korimako (bellbirds) to change their feeding behaviours.

Impacts on taonga bird species are a serious matter for Māori. Manu (birds) have always had a prominent place in Te Ao Māori as a food resource, skins and feathers for clothing and personal ornamentation, environmental and seasonal indicators, spiritual guardians and many other tangible and intangible uses.

Manu (birds) are cherished by Māori for many reasons other than their instrumental value such as food and raw materials for clothing and adornment. For example, Māori observe characteristics in birds including the before-mentioned tūī (parson bird), kōtare (kingfisher), and pīwakawaka (fantail) that they use for describing human behaviour and attributes.

Great orators and singers are compared with the melodious tūī, as in the kīwaha (saying) ‘me he korokoro tūī’ (just like the throat of a tūī). Tūī are also highly regarded for their ability to mimic the sounds of other creatures and humans.

Māori admire the kōtare for being an alert sharp-sighted sentry. Its habit is to perch motionless at a good vantage point, then attack its prey swooping down in a sudden blur. A person who is alert and acts swiftly to seize an opportunity can be described as a kōtare. The word kōtare sometimes referred to elevated platforms in pā from which sentries watched out for enemies.

Pīwakawaka (fantails) have deep symbolic meaning in kōrero o mua (traditional narratives) and Māori lore. Pīwakawaka are associated with death; Māori regard them as a harbinger of death when seen inside a house. According to some traditions it was the fantail that caused Maui’s death which resulted in the mortality of humans.

5.2. Ngā pānga taha hauora (impacts on human health and well-being) In addition to driving ecological change, Vespula wasps are a nuisance in conservation areas, parks, open spaces, farms, orchards, gardens, and backyards in communities across the country.

Vespula wasps can be potentially life-threatening if victims have allergic reactions to stings or are stung repeatedly by a swarm of wasps. There are many cases of people or pets having been stung severely, and a human fatality resulted from an en-masse wasp attack in near Nelson. Therefore Vespula wasps pose a significant threat to taha hauora (human health and well-being), in particular the dimension of taha tinana (physical well-being).

EPA advice for APP203 875

Vespula wasps have a significant impact on outdoor work and enjoyment of recreational activities. They can be encountered by those undertaking farming and forestry-related work, pest management, track and facility maintenance in conservation areas, recreational activities including hunting, fishing, camping, tramping, bush walking, nature watching, picnicking, gardening, and following traditional Māori practices such as gathering kai (food), rongoā (medicine), kaka tipu (plant fibre), and rawa (materials) for raranga (weaving), pūeru (textiles), mahi toi (art), and whakarākei (ornamentation).

Being discouraged or not being able to undertake these activities due to wasp hazards may have an adverse effect on the taha hauora dimensions of taha hinengaro (mental and emotional well-being), taha wairua (spiritual well-being) and taha whanaunga – the responsibility to care for and share in the collective, including relationships, co-workers and social cohesion, and be connected to, people and things that foster a sense of belonging, enjoyment, well-being and safety.

5.3. Ngā pānga ōhanga (economic impacts) Vespula wasps have a significant impact on apiculture and agriculture. A survey has revealed these wasps are responsible for roughly 12% of honey bees hives destroyed, second only the Varroa mite (Varroa destructor) at 19.5%. If wasps were eradicated it is estimated around $33m expenditure could be saved on nitrogen-based fertilisers to assist pollination and crop growth.

The proposal to release Volucella hoverfly and wasp nest beetle would be reassuring to Māori involved in primary sector industries. Māori economic assets are currently valued at around 50 billion dollars, with a significant portion of this being in plant and biomass production. Agriculture and horticulture are keystones of Māori development. It is anticipated the Māori contribution to kiwifruit production may rise from 10% to around 20% over the next few years. Maintaining effective pollination is critical for this industry. Māori involvement in bee keeping has grown significantly in recent years.

Many Māori families and households depend on the primary sector industries for their livelihoods and well-being. Into the future, as the Māori economy continues to grow, Māori are likely to be increasingly represented in this sector. The Vespula wasps could potentially put these activities at risk with corresponding adverse economic and social impacts accruing to Māori.

5.4. Ngā tukanga hoepapa (eradication methods) Vespula wasps species are difficult to manage solely with wasp baits and other conventional control methods as their nests are often located in inaccessible and isolated places from where they are able to re-infest neighbouring areas. Furthermore, such methods are labour-intensive and costly. This means efforts to control Vespula wasps using conventional means are likely to be impractical, uneconomic and ultimately unsuccessful in the long term.

In general, Māori favour natural methods for solving environmental issues. Releasing the Volucella hoverfly and wasp nest beetle provides natural alternatives to chemical-based interventions. These BCAs offer a potentially effective tool for controlling the pervasive and destructive Vespula pests, and are self-perpetuating, sustainable options.

Māori need to have confidence that releasing the BCAs would be highly efficacious and not adversely affect Māori interests and the ecological, economic, social and cultural well-being of Aotearoa. Potential unintended outcomes are a concern for Māori, particularly in relation to effects on culturally significant and non-target species.

Some of the key concerns are:

 Potential for the BCAs to interbreed with similar native and introduced species, resulting in hybridisation, displacement, or decimation of the native species. 56

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 Potential for the BCAs to parasitise native insects.  Potential for the BCAs to interfere with existing biocontrol regimes.  Whether the BCAs would die out if Vespula wasps were eradicated (by whatever means).  It would be practically impossible to eradicate the BCAs once they have been released (if this was deemed desirable for whatever reason).  Uncertainty about how the BCAs would be affected by climate change. Māori will be interested to note the 1985 introduction of a parasitoid wasp, Sphecohaga vesparum vesparum, to control Vespula wasps was not successful, as it only established at two sites, and with little effect on target species.

6. Ko te Volucella hoverfly The Volucella hoverfly belongs to the Syrphidae group of insects. There are 91 species of Syrphidae flies in Aotearoa, none of which are associated with social wasps. The Volucella hoverfly specialises in parasitising common and German wasps in the larval stage, and the adults feed on nectar and pollen. It does not share close whakapapa or tikanga with its whanaunga in Aotearoa and is not likely to hydridise with, or displace, other hoverflies present in this country. The Volucella hoverfly does not have a Māori name.

7. Ko te wasp nest beetle The wasp nest beetle belongs to the Ripiphoridae family that consists of more than 400 species, all of which are parasitoids of other insects. There are presently five native species of ripiphorids in Aotearoa, none of which have ever been found in wasp nests. Wasp nest beetle only parasitises the Vespinae family of wasps. It primarily targets common wasps, but also attacks the nests of German wasps. It is thought that the adults insects do not feed. The wasp nest beetle also does not share close whakapapa or tikanga with its whanaunga in Aotearoa and is not likely to hydridise with, or displace, other ripihorids currently in this country. It does not have a Māori name.

8. Ngā pānga o ngā BCA (impacts of the BCAs)

8.1. Taiao (environment) Māori may be concerned about whether the beneficial arthropods pī honi (honey bees), pī rorohū (bumble bees), ngaro huruhuru (native bees), ngaro wīwī (hunting wasps), and ngaro whiore (ichneumonid wasps), pūngāwerewere (spiders), mūmūtawa (ladybirds), and ngaro tamumu (NZ hoverflies) are potentially vulnerable to the Volucella hoverfly and wasp nest beetle.

Surveys in the UK suggest Volucella hoverfly will not attack bee hives. Conditions in solitary bee nest holes in Aotearoa are likely not suitable for Volucella hoverfly invasion, and evidence suggests bumble bees are not likely to host them either. There have been no records of solitary wasp predation by the Volucella hoverfly.

Wasp nest beetle is exclusively found in nests of eusocial vespid wasps, and are not likely to expand their host range beyond these species. They have never been recorded in bee hives or bumble bee nests in their native range, and are unlikely to be hosted by solitary bees and wasps.

Both of the BCAs are so narrow in their choice of host that they are unlikely to harm other beneficial arthropods.

EPA advice for APP203 875

Although Volucella hoverfly adults eat nectar and pollen, they are not likely to generate significant competition for nectar and pollen resources with other pollinators such as pī honi (honey bees), pī rorohū (bumble bees), and ngaro tamumu (hoverflies).

The BCAs would benefit nector-feeding taonga by increasing availability of honeydew for tūī (parson bird), korimako (bellbird), kākā (bush parrot), and tauhou (waxeye), as well as bees. The proposal would also benefit a broad range of species that feed on pepeke including tūī (parson bird), kākā (bush parrot), korimako (bellbird), riroriro (grey warbler), pīwakawaka (fantail), miromiro (tomtit), tauhou (waxeye), titipounamu (rifleman), mohua (yellowhead), pōpokokatea (whitehead), kōtare (kingfisher), rakiraki (various ducks), and moko (lizards).

8.2. Kaitiakitanga and manaakitanga (environmental guardianship and due care) This BCA proposal is broadly consistent with practice of kaitiakitanga – stewardship and guardianship enabling the protection of resources for the current and future welfare of people and the environment. Kaitiakitanga seeks to maintain balance and harmony within the environment from a perspective of intergenerational sustainability.

As a general principle, introducing exotic species into the Aotearoa environment is culturally undesirable. However, releasing the Volucella hoverfly and wasp nest beetle would address a pressing environmental and economic problem, as well as contribute to the social and cultural well- being of the people and communities into the future.

This proposal is broadly consistent with practice of manaakitanga. In the context of BCAs, manaakitanga means acting with beneficial purpose, caring for and protecting the health and well- being of people and the environment and is important for enhancing the mana of those engaged in or affected by BCA activities.

Manaakitanga extends to physical, spiritual and economic well-being – which can manifest in dimensions of taha hauora (human health and well-being). The latter concerns are dealt with in the following section below.

8.3. Taha hauora (human health and well-being) The Volucella hoverfly and wasp nest beetle are harmless to humans. Since they are not parasitic on vertebrate species they are not able to vector disease to people, and animals such as pets and farm stock. They are not a stinging insects, so will not affect taha tinana (physical health).

No adverse impacts on taha hauora (human health) are anticipated as a result of releasing the Volucella hoverfly and wasp nest beetle.

Keeping Vespula wasps in check could have a positive effect on the dimensions of taha wairua and taha hinengaro, especially amongst those who live, work or play in wasp-plagued environments and have to deal with the consequences of infestation such as conservation workers, recreators, farmers and growers.

Taha wairua is spiritual health and well-being obtained through the maintenance of a balance with nature and the protection of mauri. Restoring ecological equilibrium by controlling an invasive and damaging insect pest will enhance taha wairua.

Taha hinengaro is mental health and well-being and the capacity to communicate, think and feel. This is about how Māori see themselves in this universe, their interaction with that which is uniquely Māori and the perception that others have of them. Thus, doing what is right in terms of tikanga Māori by suppressing Vespula wasps will engender a sense of validation and respectability.

EPA advice for APP203 875

8.4. Ngā hua (benefits) Releasing the Volucella hoverfly and wasp nest beetle has potential to result in the following benefits:

 Enhance biodiversity and species abundance in a wide range habitats and ecosystems, especially beech forests.  Facilitate recovery of arthropod populations and therefore food sources for insect-eating species.  Lower public health risk associated with wasp stings.  Enhance enjoyment of outdoor activities without having worry as much about aggressive wasps.  Produce social, economic, and operational benefits for those who would otherwise be at risk of being stung, many of whom are Māori.

9. Analysis of impact The benefits to Māori associated with this application are likely to outweigh any detrimental impacts to Māori.

The overall impact on the relationship Maori have with their environment and taonga is likely to be beneficial, and is likely to benefit the ability of Māori to exercise kaitiakitanga.

The overall impact on Maori economic wellbeing (arising from the impact on the environment and taonga) is likely to be beneficial.

10. Te Tiriti o Waitangi (Treaty of Waitangi) The Principles of the Treaty of Waitangi have been considered in relation to this application and no concerns arise under the Treaty Principles, as summarised below.

Māori interests are being actively protected in relation to this application.

The decision makers on this application are making a decision informed by a Maori perspective.

The EPA considers it is acting in good faith, and is acting reasonably and fairly, in respect of this application. Mātauranga Māori and tikanga Māori are being respected.

11. Kupu whakatepe (Conclusion)

11.1. Impact on the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social and cultural well-being This application is likely to benefit the ability and capacity of Māori to maintain their economic, social, and cultural well-being.

EPA advice for APP203 875

11.2. Impact on the relationship of Māori and their culture and traditions with their environment and taonga This application is likely to benefit the relationship of Maori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga.

11.3. Ngā Matapono o Te Titriri o Waitangi (Treaty of Waitangi principles) The active protection principle: the Crown has a duty to actively protect Māori interests.

No issues arise.

The informed decision making principle: the Crown has a duty to make informed decisions.

No issues arise.

The partnership principle: to act fairly, reasonably, and in good faith.

No issues arise.

Dated: 11/11/2020