APP203542 Horehound BCA Submissions

12 July 2018

Under section 34 of the Hazardous Substances and New Organisms Act 1996 Volume 2 of 3

To introduce two moths (Wheeleria spilodactylus and Chamaesphecia mysiniformis) for the biocontrol of horehound (Marrubium vulgare)

Submission Number Submitter Submitter Organisation

SUBMISSION127305 Dawn and David Sangster

SUBMISSION127306 Bill Bayfield Environment Canterbury

SUBMISSION127307 Pat Garden Avenel Station

Department of Conservation - National SUBMISSION127310 Rod Hitchmough Office

SUBMISSION127311 Will and Emily Murray Glenmore Station

SUBMISSION127312 John Gardner

SUBMISSION127313 Daniel Maxwell Hurunui Adverse Events Committee

SUBMISSION127314 Jerry Hurst

SUBMISSION127315 John Murray

SUBMISSION127316 Gordon & Spin Lucas Nine Mile Pastoral Ltd

1 SUBMISSION 127305

SUBMISSION FORM For Hazardous Substance and New Organism Applications

Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected]

Once your submission has been received the submission becomes a public document and may be made publicly available to anyone who requests it. You may request that your contact details be kept confidential, but your name, organisation and your submission itself will become a public document.

Submission on application number: Name of submitter or contact for APP203542 joint submission: Organisation name Dawn & David Sangster (if on behalf of an organisation): Postal address: 834 Ranfurly - Patearoa road RD 4 Ranfurly 9398 Central Otago

Telephone number: 027 4447731

Email: [email protected]

I wish to keep my contact details confidential

The EPA will deal with any personal information you supply in your submission in accordance with the Privacy Act 1993. We will use your contact details for the purposes of processing the application that it relates to (or in exceptional situations for other reasons permitted under the Privacy Act 1993). Where your submission is made publicly available, your contact details will be removed only if you have indicated this as your preference in the tick box above. We may also use your contact details for the purpose of requesting your participation in customer surveys.

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt.nz 2

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: (further information can be appended to your submission, see footnote). We support the introduction of the 2 moths to help control horehound.We have approximately 150ha of lucerne on our property which we make into baleage for winter feed.Although we have some irrigation lucerne is critical for providing high quality feed on the dryland area of our farm'. We have noticed that the horehound population is growing and it seems to spread to other paddocks including permanent pasture.We have sprayed our lucerne paddocks in the past with to try and control the horehound but it was very hard on the lucerne as well and delayed the spring growth by 2 months.The effects of the spray only lasted 3 years and then the hore hound repopulated the area. The horehound is making grazing lucerne very difficult as stock grazing it seem to spread it. The burr of the plant devalues the wool of the sheep and is very nasty for young lambs.We also farm goats and hore hound present in their mohair fleece renders it invaluable as it cannot be scoured out.At present mohair returns are on average $15/kg as opposed to wool which is $3/kg.

All submissions are taken into account by the decision makers. In addition, please indicate whether or not you also wish to speak at a hearing if one is held. I wish to be heard in support of my submission (this means that you can speak at the hearing) I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing) If neither box is ticked, it will be assumed you do not wish to appear at a hearing.

I wish for the EPA to make the following decision: Introduce the 2 moths.

1 Further information can be appended to your submission, if you are sending this submission electronically and attaching a file we accept the following formats – Microsoft Word, Text, PDF, ZIP, JPEG and JPG. The file must be not more than 8Mb.

July 2016 EPA0190 SUBMISSION 127306

SUBMISSION FORM For Hazardous Substance and New Organism Applications

Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected]

Submission on application APP203542 number: Name of submitter or contact for Bill Bayfield joint submission: Organisation name Environment Canterbury (Canterbury Regional Council) (if on behalf of an organisation): Postal address: PO Box 345 Christchurch 8140

Telephone number: 03 345 9316

Email: [email protected]

I wish to keep my contact details confidential

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt.nz 2

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: (further information can be appended to your submission, see footnote). The Canterbury Regional Council supports the application by the Horehound Biocontrol Group to import and release Wheeleria spilodactylus (horehound plume moth) and Chamaesphecia mysiniformis (horehound clearwing moth) as a biological control tool for horehound in NZ. Horehound is a common and widespread weed in the dry hills and high-country of Canterbury. It is a problem in lucerne crops and dry, open pastureland and seed heads attach to sheep’s wool reducing the value. The planting of lucerne crops is becoming common practice in the Canterbury high-country and the spread and impact of horehound is increasing. While there are a number of herbicides that provide effective treatment on horehound they also kill the desirable species which limits the use of this control tool. The addition of a biological control tool would provide a useful, low-impact alternative for managing this plant pest.

I wish for the EPA to make the following decision: Approve the introduction of two moths (Wheeleria spilodactylus and Chamaesphecia mysiniformis) as biocontrol agents for the weed horehound (Marrubium vulgare).

July 2016 EPA0190 SUBMISSION 127307

SUBMISSION FORM For Hazardous Substance and New Organism Applications

Submission on application APP203542 number:

Name of submitter or contact for Pat Garden joint submission:

Organisation name (if on behalf Avenel Station of an organisation):

Postal address: c/o 1167 Teviot Road Millers Flat RD2 Roxburgh 9572

Telephone number:

Email:

I wish to keep my contact details confidential

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt. nz 2

Submission Form

I support the application Yes I oppose the application I neither support or oppose the application

The reasons for making my submission are: (further information can be appended to your submission, see footnote). Avenel Station is located on the Lammerlaw Range above Millers Flat in Central Otago. It runs from 250m asl to 1000m asl. Rainfall varies over the station but at lower altitudes it averages 600mls pa. The lower country dries out in the summer and to manage these drier areas, 45 ha of lucerne has been established with further plantings planned Horehound has two serious impacts: it competes for space by colonising the open nature of the lucerne sward and the seed burrs seriously contaminate wool. It is impossible to blanket spray the area with chemical as the lucerne plant is not tolerant of any chemical able to suppress horehound, leaving individual spot spraying the only possibility. This is not a feasible option as the rapidly expanding area makes it totally uneconomic. As the area is increasingly colonised, the impact on contaminated wool becomes more serious resulting in an inability to graze woolly sheep through late summer/autumn. This progression results in a need to spray out the horehound and the lucerne, then spell the area for two years before resowing. This renewal process has to happen well before the normal lifetime of a lucerne stand has passed, resulting in a seven year life compared to an expected 10yr life. This early renewal requires an extra third of the total area to provide a given area allocated towards lucerne and increases the establishment costs spread over the lifetime of the stand. In summary, Horehound dramatically increases the annual maintenance costs of a lucerne stand, it lowers the Dry Matter yield, it requires a greater net application of chemical, it shortens the stand life and contaminates wool, either to woolly lambs sent to the works or to the wool shorn on the property. A reduction of vigour through biocontrol would greatly assist in its management.

All submissions are taken into account by the decision makers. In addition, please indicate whether or not you also wish to speak at a hearing if one is held. I wish to be heard in support of my submission (this means that you can speak at the hearing) I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing) X If neither box is ticked, it will be assumed you do not wish to appear at a hearing.

I wish for the EPA to make the following decision: That approval under the Hazardous Substances and New Organisms Act (HSNO Act) to import and release two moths, Wheeleria spilodactylus and Chamaesphecia mysiniformis, as biological control agents for the weed horehound (Marrubium vulgare), be given.

Once youJuly have 2016 completed EPA0190 this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected] SUBMISSION 127310

Thank you for the opportunity to comment on application APP203542 Horehound BCA.

The Department of Conservation supports the proposed introduction and release of the moths Wheeleria spilodactylus and Chamaesphecia mysiniformis) for the biocontrol of the weed horehound (Marrubium vulgare).

The combination of very narrow host specificity in the native ranges of these species, and their success as biocontrol agents in Australia with no records of attacks on non-target species, combined with only distant taxonomic relationships between any native species and horehound, means that we agree that the likelihood of non-target impacts is extremely low.

Effective biological control of horehound would benefit conservation areas as well as agricultural activities.

Having said that about this particular case, I would like to make the point that we consider that in general there is too much reliance on overseas information and too little testing of potential New Zealand hosts (species related to the target species) in recent BCA applications I have seen. Our support for this particular application should not be taken for support for that approach in general.

I do not wish to appear at any hearing that may be organised for this application.

Regards Rod Hitchmough Scientific Officer (Biosecurity) Department of Conservation—Te Papa Atawhai National Office, PO Box 10 420, Wellington 6143 18-32 Manners St, Wellington 6011 Cell: 027 408 3481 T: +64 4 471 3249 F: +64 4 381 3057 www.doc.govt.nz

1 SUBMISSION 127311

SUBMISSION 127312 *V Environmental # ?S"^^ihority SUBMISSION FORM For Hazardous Substance and New Organism Applications

Once you nave completed this form

Send by post to: Environmental Protection Authority Private Bag 63002 Wellington 6140 OR email to- &>,b-, isions Sepa govt nz

Once your submission has been received the submission be^craes a public document and may be made publicly available to anyone who requests it. You may request that your contact details be kept confidential, but your name, organisation and your submission itee!f wiil become a public document.

Submission on application number: Name of submitter or contact for Joint submission: Organisation name (ifori behalf of an organisation): Postal address:

Telephone number

Emaii:

ID keep my contact details confidential

The EPA will deal with any persona! information you supply in your submission in accordance with the Privacy Act 19S3. v*ve will use your contact details for the purposes of processing the application that it relates to (or in exceptionai situations for other reasons permitted under the Privacy Act 1993). Where your submission is made publicly available, your contact details will be removed only if you have indicated this as your preference in the tick box above. We may also use your contact details for the purpose of requesting your participation in customer surveys.

The EDA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available ir. response to a request under the Official Information Act 1982.

NewZesi wi Sovemrnent www.epa.oovt.nz 1

Submission Form

support the application

• I oppose the application

• I neither support 01 oppose the application

The reasons for making my submission are1: (further information can be appended to your submission, see footnote).

U/LyoL i§ $preaJ"y fr^tMu, At t*Sc ffee^Lrh c~-^[fjias&r if h h&c-o^e &sh*jes c*?t~*v fe-yer^' Hea/ii ^"l+y

All submissions are taken into account by the decision makers. In addition, please indicate whether or not you also wish to speak at a hearing if one is held.

• I wish to be heard In support of my submission finis means that you can speak at the hearing)

0-1 dc not wish to be heard in support of my submission (this means that you cannot speak at the hearing) If neither box is ticked, it will be assumed you do not wish to appear at a hearing.

! wish fcr «w Fr.« v make the following decision: To I,

1 Further information car. be appended to your submission, if you are sending this submission electronically and attaching a file we accept the following formate -- Mi5!'5§9ft Wsrel, Text, PDF, ZIP, JPEG and JPG The fite must be not more than OMb.

J* July 2016EPA0190 SUBMISSION 127313

29th May 2018

Daniel Maxwell Mount Sandford Farm 738 Kaiwara Road, RD2 Cheviot 7382

To whom it may concern Environmental Protection Authority Private Bag 63002 Wellington 6140

Submission in support of the introduction and release of Plume and Clearwing Moths to combat Horehound My name is Daniel Maxwell. I am a meat and wool farmer in Cheviot, and an active member of the rural communities in Hurunui and in the North Canterbury province. I am writing on behalf of the members of the Hurunui Adverse Events Committee (previously Hurunui drought response committee), as well as the rural community in North Canterbury, who support the proposal to introduce and release the Plume and Clearwing moths to combat horehound in New Zealand.

North Canterbury is vulnerable to drought It is no secret that North Canterbury's climate is prone to drought. We have just emerged from our last serious drought, which lasted for 3 years, and most farms will need another 3-5 fortunate seasons to get back to where they were pre-drought. The financial impact over the whole community has been significant, not just the farmers; some say perhaps this is the new normal due to the effects of climate change.

Dryland farmers in North Canterbury grow Lucerne to mitigate drought effects Through our experience we learnt we must drought-proof our farming systems effectively, if we are to farm in a dry environment in the future. One way of doing that is to change some of our pasture to a plant species for our livestock which is suited to a lower rain fall as irrigation is not an option for most farmed land in the Hurunui District (the District). A very popular plant that ticks that box is the legume Lucerne. There is over 150,000 hectares grown in New Zealand currently (data collected from Lincoln University).

In dry conditions Lucerne will still flourish right beside a paddock of traditional pasture species that will be dry and unproductive. This is largely due to the long tap root enabling the Lucerne plant to be much more efficient in accessing moisture that other plants can't.

The other benefit is Lucerne provides high quality feed for longer periods than traditional grasses for ewes during lactation therefore enabling Iambs to get to a saleable weight before Christmas time when it is generally getting dry. This helps the farmer get down to manageable numbers of Iambs for the dry summer.

Horehound impedes the growth of Lucerne For many years the horehound has been a problematic weed for farms in the Hurunui District (the District). Nationwide the horehound has cost the farming sector approximately 6.85 million per year (data collected from Landcare research).

The trouble is when the Lucerne goes dormant in the winter horehound plants establish and, before you know it, the horehound is out of control and there is no labelled chemical available that is safe to spray the Lucerne paddock out with. Since horehound has been in New Zealand for decades and sheep carry the seed from place to place, there is a lot of seed sitting in the ground waiting for an opportunity to germinate. Current options to combat Horehound in lucerne are inefficient There are two options available:

Optionl Grubbinq: Cost of grubbing .5 ha hr @ $35/hr =$70/ha annually. (Data collected from local farmers)

This method is time consuming, expensive and frustrating as the horehound plants only seem to reappear in those areas within 12 months.

Option 2 Spot spraying: Cost of spot spraying $70/ha annually. (data collected from local farmers)

This method is also expensive and puts the Lucerne plant at risk as the chemical is off label.

A scene that is becoming all too common with many Lucerne paddocks in our province This Lucerne paddock (grazed) in the picture below went through a 2-year brassica crop programme to get on top of the weeds with several applications of chemical in that time. It was sprayed once in August 2016, and again in October 2016, at a cost of 145/ha per application. This Lucerne paddock was drilled November 2016.

This photo was taken on the 7th of April 2018, only 17 months after the lucerne was drilled. The darker green srubs are Horehound.

It cost a total of $723/ha to establish the Lucerne, excluding the 2 years of brassica crops. You would normally expect to get 10+ years out of a good stand of Lucerne; however, these stands won't last much longer than 2.

Horehound plant count 250 plants/ha including small plants. $950/ha Cultivated (for example). Horehound in traditional pasture is costly to combat During the last drought a lot of the existing permanent pasture temporarily and permanently died off leaving bare patches where the horehound has now got established. It is possible to safely spray out of pasture but most of these plants have now seeded down and spread so they will keep reappearing for years and restrict further lucerne development.

On the 6 September 2016 we sprayed 18 ha of horehound off stock camps and permanent pasture at a cost of $95/ha (see invoice below).

- 1l\l~lce '~or ~~I C'y I~ lior¢ r.ek, .k 0,A0~

CHRISTCF(ttRC H 25 Aviation nrivo Tax Invoice Harewood Aviation Park Christchurch 7676 V P.O. Box 36-450 HELICOPTERS Merivale Christchurch 814fi Phone: (03)359-0470 Email: philippa(,Vchchheli nz To: Daniel Maxwell 738 Kaiwara ltd Tax Invoice No: 1082 RD2 ate: 61()ct/2016 Cheviot GST Number: 119.414-105

0wriptlon Qty Rate Amount ~'0W IK•HR:; Sprayinfj 18 ha hnwhound and It, ha givphosate `l1 aros 34 x)0.00 $1700. a osatu 80 10.15 $828.00 ?4 17 54 13.00 $ 702.0x} 44I9kin Adjuvant 3 0.00 $27 00 12 "11)"iliconv F'c!netr,rnt 6 19.50 $1 17.0}0 a1voulfron .9 50.00 $45 00 1"5-

Sub Total $3,419.04) LIST $`,12.8.`, Total $3,931.8`i

Payment by bank trnnRfer to nccounl• 06 0821 0764286 00

Payment duo by the 20th of the month following. Interest Is charged on overdue amounts at 2% per month L . ~or J fe- THANK YOU FOR YOUR BUSINESS _Aq 5 / 14(^ Two further examples demonstrate current methods are inefficient and expensive

The photo taken below shows a paddock that was sprayed successfully on 6 September 2016. As you can see the horehound has comeback almost as thick as it was prior to spraying only 19 months later.

This photo taken on 10 April 2018

The next photo, below, shows an area that was also sprayed on 6 September 2016. The photo was taken on the 23 October 2017, only 13 months later. This area has been sprayed again since this photo was taken. Horehound has a significantly negative effect on Wool Because each horehound plant has thousands of seeds the impact on the wool industry is costly. The seed gets into the wool and devalues the wool due a factor known as Vegetable Matter.

Dave Burridge, South Island wool sales manager for PGG Wrightson, explains the impact of horehound on our wool industry;

12" April ENS

S'UBJEC'T: HOREHOUND CEO TAIN- ';ATIO LN WOOL GRONI-1'rr LN NEW ZEALA.N- D

Contanuuation of horehound seed heads in greasy wool is regarded by the wool trade

as major fa7ilt especially in crass-bred+;;ool (SY c of the total ,Olrame of wool grrown in Yev, Zealand). Horehound pLarts are largely now re-stricted to cerfa a area:, nairdy in dreer park of New Zealand, especially if the is Lower levels of cultivation. The major issue with horehound cantam;nation in +.,coL is its ability for the geed bead, to "hook off" -t+.,rcol as a sheep makes contact itL this p.,ant u'liilst grazing. Its f ndamer tal mechanism. for dispersal Hei with its des.gn of capturing hooks that, latch on passing LiVestock especially woohy sheep. Onae latched on the seed heads can star: on until such tin-3 the filament component breaks off and the seed head drops to the ground.

If' orehound is present on the 4f ooll during shearing, and goes forward for father prozessitfa, the seed head pra-67es to be .per; difficult to remove and can Staff' intact n-ith the drool until end stag= processing whereby it can affect the 'final product. This is especially true with the cross-bred wool produced in 1117ew Zealand due to the fact that there as no default prozeis to rerY crve such saed heads during die I.V oolen Process of bmiing cross-bred wool into carpet ;yarn.

If there is a high level of seed bead contamination, there is process called carbonization during the wool yzouriag stage; tv ch ire.-oh-es a batch ofcentarninated „gaol going throug;:c an acid bath to burn off the fibres holding the seed lead to the wool uithout rhmixg= the %irool itself. 71us uncur= f =her tie aelar a and adds cost to prCCessing.

It is ditficWt to estimate the cast to fannners and to the industry ii 1~Ie•.+.• Zealand but to those farmers that have hcaebound established un their pa-stares and their wool test

results short- readings of more than 0.5° a of lead heads ara likel•.• to fincuz dLsCounts t rpically of between 20 to 80c k; gsy depending on the le:-el of ctntarnination. For the average size wool clip (2 003 full vo ol. ev.-ea), this amounts to beh,.-reen $2000 to $730", per shearing.

D.a .'e Biundge Sth Island's', ooi Sales' miaaer

PCiOI&TrLghtsr;nV Wool 503 Blenheim Rd [email protected] 027479377 We support the introduction of Plume and Clearwing moths to combat Horehound The financial impact of Horehound is high on our local and national economy; it has also had a substantially negative effect on our wool industry. It can't be managed economically and practically in Lucerne, and it has become more widespread during and after North Canterbury's last drought.

We believe for continued successful establishment of Lucerne the Hurunui District, and the wider North Canterbury province, desperately need a biological control.

We are aware, through research and testing at Landcare, that Plume and Clearwing moths are effective, practical and sustainable measures to address Horehound. We urge the EPA to support and import these moths to help the rural sector to thrive in a safe and cost-effective manner.

We attach an appendix of North Canterbury farmers, Local residents and Adverse committee members who also support the importation of these moths.

Yours faithfully

Daniel Maxwell Member - Hurunui Adverse Events Committee

Co signed

Winton Dailey Chairman - Hurunui Adverse Events Committee

Chairman - Hurunui Dryland Landcare Group -7.

Appendix — Farmers and residents who support our submission

Name Address Title and/or Associations Graham Grigg Amuri Farmer, Member Hurunui adverse events committee Sam Sheild Cheviot Farmer

Terri Anderson Wanaka MPI, Member Hurunui adverse events committee Nick Hamilton Omihi Farmer, Member Hurunui adverse events committee Jo Buckner Christchurch MPI, Member Hurunui adverse events committee Jenny Ridgen Christchurch MPI, Member Hurunui adverse events committee James Hoban Waipara Farmer, Member Hurunui adverse events committee Ian Page Cheviot Vet, Member Hurunui adverse events committee Doug Archbold Christchurch Rural support, Member Hurunui adverse events committee

Bridget & Buzz Frame Scargill Farmer, Member Hurunui adverse events committee

John & Rose Stevenson Cheviot Farmer Lynda Murchison Waipara Farmer, North Canterbury Federated farmers past president

John Murchison Waipara Farmer Don & Kate Anderson Cheviot Farmer Dan Hodgen Hawarden Farmer, Federated Farmers Meat & Wool National executive, Hurunui adverse events committee Chris Hewett Cheviot Farmer

Geoff O'Carroll Cheviot Farmer Andy Fox Scargill Farmer, Member Hurunui adverse events committee James Maxwell Scargill Farmer Tom Maxwell Scargill Farmer Rob & Denise Norrie Cheviot Farmer Simon Lee Cheviot Farmer,B & L farmer council Tom Ensor Cheviot Farmer Hugh Dampier Crosley Cheviot Farmer,B & L farmer council Henry Sheild Cheviot Farmer,B & L farmer council Beau Sheild Cheviot Farmer ~s'

Lorretta Dobbs Christchurch MPI, Member Hurunui adverse events committee Jody Horrell Cheviot Farmer John Ladley Christchurch NZ Beef & Lamb, Hurunui adverse events committee Dave Burridge Christchurch PGG Wrightson Wool Jamie McFadden Cheviot Owner of Hurunui Natives Rob & Kirsty Maxwell Amberly Farmer Richard & Jane Maxwell Cheviot Farmer Roger Chambers Amberly Agronomist Farmlands George Black Waikari Farmer Kelly Morris Hawarden Senior farm consultant Ravensdown Jack Ramsey Hawarden Farmer Craig Williamson Christchurch Bank Manager Rabobank Appearance confirmed by email:

Hi Diane, I am sure he would want to. Do you know a date of the hearings please ? Irrespective of all that, and to be clear, I will confirm that either Dan, Ben, or myself will speak to our submission. Please advise of hearing dates if they have been set. Regards Winton. Sent from my iPad

On 4/07/2018, at 11:48 AM, Diane Totton > wrote:

From: Diane Totton Sent: Wednesday, 4 July 2018 11:41 AM To: '[email protected]' > Subject: Submission on Horehound weed

Good morning Winton,

The attached submission was received by the EPA on 11 June. It was not formally accepted as a submission because it omitted to state whether or not the Hurunui Adverse Events Committee wishes to attend a hearing and speak to the submission, which is a statutory requirement for submissions.

We wrote to Daniel Maxwell to ask him for this information but we have not heard back and we now understand him to be away until 18 July.

As a co-signatory to the submission we are now approaching you requesting an answer to the following statement:

* I wish to be heard in support of my submission (this means that you can speak at the hearing) OR * I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing)

Submissions close on 11 July so we would appreciate receiving your response before then to enable us to add this submission to the material that will be forwarded to the decision-makers.

Thank you for your assistance in this matter.

Kind regards

Diane Totton Applications Administrator

1 SUBMISSION 127314

SUBMISSION FORM For Hazardous Substance and New Organism Applications

Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected]

Submission on application number: Name of submitter or contact for Jerry Hurst joint submission: Organisation name (if on behalf of an organisation): Postal address: Elgin View 80 Clarkesfield Road 7 RD Waimate

Telephone number: 0276890400

Email: [email protected]

I wish to keep my contact details confidential

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt.nz 2

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: (further information can be appended to your submission, see footnote). Horehound has become our biggest problem weed In the last 5 years .It has gone from small patches on dry ridges to infesting lucern and some young pasture paddocks.When it gets established in fertile open lucern paddocks it goes to another level of growing compared to the plants on native ridges. The major costs are the spraying out and re drilling of good stands of lucern due to infestation of horehound and the continous spot spraying and hand grubbing to try and keep new paddocks clean. The major devaluation of wool contaminated with seed and the complication of management by not being able to graze certain paddocks when the horehound is in seed. I believe the horehound has gone to another level in the last two years which is obivious when driving around the countryside. I think it is much worse than a lot of farmers realise even on there own farms..

I wish for the EPA to make the following decision: To allow and fasttrack the biological control

July 2016 EPA0190 SUBMISSION 127315

SUBMISSION FORM For Hazardous Substance and New Organism Applications

Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected]

Submission on application APP203542 number: Name of submitter or contact for John Murray joint submission: Organisation name (if on behalf of an organisation): Postal address: The Wolds Station PO Box 154 Lake Tekapo 7945

Telephone number: 0272941443

Email: [email protected]

I wish to keep my contact details confidential

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt.nz 2

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: (further information can be appended to your submission, see footnote). Horehound is an increasing problem with the potential to cause as much harm to biodiversity as Wilding trees and Hawkweeds,

I wish for the EPA to make the following decision: That the EPA alows the release of the two moths applied for. My reasons for suppoprting this application are;

We are increasingly finding horehound spreading into uncultivated tussock grasslands from stock camps. While we try to control the spread mostly by spot spraying, we are not winning due to the extensive nature and inaccessability of parts of the property. Horehound spread is displacing indigenous vegetation and will have an increasing effect on landscape values as well. The spraying also has an impact by killing non target species. Hard grazing is not a viable option here as it would take out tussocks and other biodiversity as well. Effective hard grazing would also require sub-divisional fencing which is expensive and would require a hard to get resource consent ( In parts of this property new sub-divisional fencing is non complying in the current district plan). De stocking is not an option to slow the spread, it would result in a ten fold increase in wilding tree spread.

We face an increasing problem in lucerne stands with early replacement of stands and a lot of spot spraying having a large economic impact. The cost would be in the tens of thousands of dollars.

July 2016 EPA0190 3

Submission Form

For anyone wishing to use horehound for medicinal or other uses such as beer, the moths will not cause the extinction of horehound. I am not aware of any comercial cultivation of horehound but an insecticide could control the moths and would require a lot less chemical than farmers and others are currently using.

July 2016 EPA0190