FORM NOR

Application for approval to

IMPORT FOR RELEASE OR RELEASE FROM CONTAINMENT ANY NEW ORGANISM INCLUDING A GENETICALLY MODIFIED ORGANISM BUT EXCLUDING CONDITIONAL RELEASE AND RAPID ASSESSMENT

[Short title is: New Organism Unconditional Release]

under section 34 of the Hazardous Substances and New Organisms Act 1996

Application Title: Release of the boneseed leafroller for biological control of boneseed

Applicant Organisation: Environment Canterbury

ERMA Office use only

Application Code: Formally received:____/____/____

ERMA NZ Contact: Initial Fee Paid: $

Application Status:

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 1 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

IMPORTANT

1. An associated User Guide is not yet fully developed. If you need guidance in completing this form please contact ERMA New Zealand.

2. This application form covers importation for release or release from containment of any new organism (i.e. full or unconditional release) including genetically modified organisms but excluding conditional release and rapid assessment, under section 34 of the Act

3. If you are making an application to import for release or release from containment any new organism with controls (i.e. conditional release) use Form NOCR. If you are making an application to import for release a new organism that is not a genetically modified organism by rapid assessment use Form NORA. If you are making an application to field test any new organism use Form NO4.

4. You should periodically check with ERMA New Zealand or on the ERMA New Zealand web site for new versions of this form.

5. You can talk to an Applications Advisor at ERMA New Zealand who can help you scope and prepare your application. We need all relevant information early on in the application process. Quality information up front will speed up the process and help reduce costs.

6. This application form may be used to seek approvals for importing more than one new organism where the organisms are of a similar nature. 7. Any extra material that does not fit in the application form must be clearly labelled, cross-referenced, and included as appendices to the application form.

8. Commercially sensitive information must be collated in a separate appendix. You need to justify why you consider the material commercially sensitive, and make sure it is clearly labelled as such.

9. Applicants must sign the form and enclose the correct application fee (plus GST). The initial application fee can be found in our published Schedule of Fees and Charges. Please check with ERMA New Zealand staff or the ERMA New Zealand website for the latest schedule of fees. We are unable to process applications that do not contain the correct initial application fee.

10. Unless otherwise indicated, all sections of this form must be completed for the application to be progressed. 11. Please provide an electronic version of the completed application form, as well as sending a signed hard copy.

12. Note: Applications for full (unconditional) releases (this form) shall be publicly notified by the Authority under section 53(1)(b) and may go to a hearing pursuant to section 60 of the Act. You can get more information by contacting us. One of our staff members will be able to help you. ERMA New Zealand 20 Customhouse Quay, PO Box 131 Wellington, NEW ZEALAND Telephone: 64-4-916 2426 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 2 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Facsimile: 64-4-914-0433 E-mail: [email protected] www.ermanz.govt.nz

Section One – Applicant Details

1.1 Name and postal address in New Zealand of the organisation or individual making the application:

Name > Environment Canterbury

Postal Address > P O Box 345 CHRISTCHURCH

Physical Address > 58 Kilmore Street CHRISTCHURCH

Phone > (03) 365 3828

Fax > (03) 365 3194

E-mail >

1.2 If application is made by an organisation, provide name and contact details of a key contact person at that organisation This person should have sufficient knowledge to respond to queries and have the authority to make decisions that relate to processing of the application.

Name > Raymond Keith Maw

Position > Senior Resource Management Planner 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 3 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Address > P O Box 345 CHRISTCHURCH

Phone > (03) 371 7187

Fax > (03) 365 3194

E-mail > [email protected]

1.3 If the applicant is an organisation or individual situated overseas, provide name and contact details of the agent authorised to transact the applicant’s affairs in relation to the application This person should have sufficient knowledge to respond to queries and have the authority to make decisions that relate to processing of the application.

Name > N/A

Position > N/A

Address > N/A

Phone > N/A

Fax > N/A

E-mail > N/A

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 4 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Section Two – Purpose of the Application and Reasons for Requesting a Full (Unconditional) Release This form is to be used for a standard (publicly notified) application (i.e. other than by rapid assessment), to import for release, or release from containment, any new organism (including a genetically modified organism). It is not intended to cover conditional releases.

2.1 Give a short summary statement of the purpose of this application to be used on ERMA New Zealand’s public register – Maximum 255 characters (including spaces and punctuation) Briefly describe the organism(s) to be imported for release or released from containment and the purpose(s) for which you wish to release the organism(s). Note: An organism is „released‟ when it is not required to be held in a containment facility registered by the Ministry of Agriculture and Forestry. Once released it is no longer considered a new organism.

Approval to import for release a South African moth, the boneseed leafroller (Tortrix s.l. sp. "chrysanthemoides"), that is not currently present in New Zealand, for the purpose of biological control of boneseed (Chrysanthemoides monilifera ssp. monilifera).

2.2 Provide a brief description of the background and aims of the proposal suitable for lay readers Describe in less than one page the rationale for the proposal to release these organisms, including the potential use for the organism(s), so that people not directly connected with the application can understand the reasons for the release.

Boneseed is a bushy South African shrub that grows 2-3 metres high. It has thick, leathery leaves with slightly toothed edges, and masses of bright yellow daisy-like flowers in the spring, followed by clusters of fruit that turn black when ripe. The single seed inside is very hard and the colour of bone, hence the name. Tens of thousands of these seeds can be produced during the lifetime of a boneseed bush. Boneseed is a very hardy shrub and can grow in a variety of soils. It is frost- resistant, and tolerant of semi-shade, drought and salty environments (Weiss 1986). In New Zealand, boneseed occurs mainly in coastal habitats throughout the North Island, and in Nelson/Marlborough, the Port Hills around Christchurch, and Anderson's Bay in Dunedin, in the South Island (Webb et al. 1988).

In New Zealand, boneseed has the potential to cause substantial environmental damage (Syrett 1999). It invades plant communities on coastal cliffs and dune-lands, and inland grassland and shrub areas. Dense thickets of boneseed can form which displace native vegetation and shade out native seedlings. The long-term impact of boneseed on native biodiversity may be much more serious than that of a weed such as gorse because there is little native seedling recruitment under a pure stand of boneseed.(McAlpine & Timmins 2002). 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 5 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Although boneseed was first recorded as naturalised in New Zealand in 1870 (Webb et al. 1988) it is only in recent years that it has been recognised as a serious problem weed (Syrett 1999). To help control this increasingly serious weed, we would like to import from South Africa the boneseed leafroller, a moth that helps to naturally control boneseed in its native habitat in South Africa. Boneseed leafroller caterpillars web leaves together to form a shelter, and feed on leaf material from within this shelter (Scott and Adair 1990). Biological control is an appropriate control strategy for New Zealand because in many places boneseed is invading natural areas where herbicide use is likely to damage native plants. The scale of the problem, and the fact that many boneseed infestations are in areas that are difficult to work in (e.g. steep slopes) means that manual control is often not feasible (Syrett 1999). Biological control aims to limit the growth and reproduction of boneseed so it becomes less competitive and is no longer a risk to our environment.

The scientific name of boneseed is Chrysanthemoides monilifera subspecies monilifera. The genus Chrysanthemoides comprises only two species, Chrysanthemoides incana (which is not present in New Zealand) and Chrysanthemoides monilifera). In South Africa the boneseed leafroller is known to feed on only these two species. The boneseed leafroller was released in Australia in April 2000. The host specificity of the boneseed leafroller was further tested during 2001 on plants of relevance to New Zealand. The results of this testing added to the evidence already available from field observations in South Africa, and host specificity testing conducted for Australia, that the boneseed leafroller is not expected to feed on any plant species in New Zealand other than boneseed.

Boneseed can be controlled by herbicides or by stock grazing when the plants are small. However, infestations occur in locations where herbicide application or grazing is neither feasible nor desirable. Introducing the leafroller will cater for control in those situations and it will reduce the need for herbicide in other situations as well.

An indicative map showing those regional councils that have identified the presence of boneseed in their area, and the regions where the release of the leafroller is most likely to undertaken, is shown as follows:

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 6 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 7 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

2.3 Set out the reasons for this application being for a full (unconditional) release rather than for a conditional release Set out the reasons for this application being for full (unconditional) release rather than for conditional release. Under section 38B of the HSNO Act the Authority may consider an application for full (unconditional) release as if it were for conditional release (i.e. conditions can be set), with the agreement of the applicant. You should provide sufficient information to enable the Authority to decide whether or not it should approach the applicant with a view to obtaining agreement to switching from full (unconditional) to conditional release.

Under Section 38D of the HSNO Act, controls that the Authority may impose on a conditional release approval include, but are not limited to, the following:

(a) Controlling the extent and purposes for which organisms could be used (b) Requiring any monitoring, auditing, reporting, and record-keeping (c) Imposing any obligation to comply with relevant codes of practice or standards (for example, to meet particular co-existence requirements): (d) Requiring contingency plans to be developed to manage potential incidents: (e) Limiting the dissemination or persistence of the organism or its genetic material in the environment: (f) Requiring the disposal of any organisms or genetic material (g) Limiting the proximity of the organism to other organisms, including those that could be at risk from the conditionally released organism: (h) Setting requirements that must be met for any material derived from the organism: (i) Imposing obligations on the user of an approval, including levels of training or knowledge, limits on the numbers of users who may hold an approval, and the persons that they could deal with in respect of the organism: (j) Specifying the duration of the approval or of a control before requiring review by the Authority, and the nature of that review.

The controls listed above have been considered and we are of the opinion that none of these controls need to be imposed in order to improve the efficacy of the boneseed leafroller or mitigate any risk. The objective of introducing the boneseed leafroller to New Zealand is to establish self- sustaining populations in all areas of New Zealand affected by boneseed. Even if there were reasons for a conditional release to be considered, the mobility of the boneseed leafroller would make secure containment in the field impractical. Therefore we are applying for a full (unconditional) release.

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 8 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Section Three – Information on the Organism(s) to be Released and any Inseparable Organisms If the application is for release of more than one organism, information must be provided separately for each organism. If there are commercial reasons for not providing full information here alternative approaches must be discussed with and agreed by ERMA New Zealand.

3.1 State the taxonomic level at which the organism(s) to be released are to be specified If the taxonomic level is higher or lower than “species”, provide reasons for this. The reasons should take account of the need to adequately describe the risk.

Species

3.2 Give the unequivocal identification of the organism(s) to be released Please provide details of the following:

Latin binomial, including full taxonomic authority (e.g. ----- Linnaeus 1753) class, order and family:

Class: Insecta Order: Lepidoptera Family: Tortricidae Subfamily: Tortricinae Tribe: Archipini Genus: Tortrix s.l. Species: sp. "chrysanthemoides"

This species has not yet been formally named. It was initially identified as belonging to the genus Tortrix but more recent examination of material by a tortricid expert (Dr Marianne Horak, CSIRO, Australia) has indicated that it almost certainly does not belong to the genus Tortrix (Edwards 1993). This species is currently being referred to as Tortrix s.l. sp. "chrysanthemoides", (s.l. = “sensu lato” or “in the wider sense”. The use of “chrysanthemoides” identifies the organism at the same level as a species that is associated only with the plant genus Chrysanthemoides. This species has also been referred to as “Tortrix” sp. in the literature.

Dr Marianne Horak is satisfied that the boneseed leafroller is a specific entity. While it would be possible to give this species a formal name now, the opinion from taxonomists is that this would not be appropriate. Marianne is of the view that, rather than rush to give this species a name, it would be better to wait for a revision of the African Archipini (the tribe to which the boneseed 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 9 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

leafroller belongs) to establish the generic placement and formally describe the species. Jozef Razowski, a lepidopterist in Krakow, Poland, is currently working on a revision of the African Archipini but this is likely to take quite a few years to complete. Given the way boneseed is spreading in New Zealand, the regional councils wish to proceed with a biological control programme without further delay. We are convinced that this is a sensible decision, and that the proposed biocontrol agent is a valid species despite the lack of a formal genus and species name.

John Dugdale, a tortricid expert in New Zealand, agrees with Marianne that there is no scientific point in manufacturing a name, especially as nomenclatural changes will undoubtedly occur later. Providing a name now will only reiterate a status that is already encapsulated in the name “boneseed leafroller”. The entity of choice here, that feeds only on the shrub genus Chrysanthemoides, can be defined by its host plant and there is clearly sufficient evidence from thorough ecological studies that this entity is distinct from other related species (John Dugdale, Landcare Research, pers. comm. [a]).

Common name(s), if any:

Boneseed leafroller

Type of organism (e.g. bacterium, virus, fungus, plant, animal, animal cell):

Insect (moth)

Strain(s) and genotypes(s), if relevant:

N/A

Other information, (e.g. information on consideration of the organism(s) by other states, countries or organisations):

The boneseed leafroller has been released in Australia as a biological control agent for boneseed (refer to Section 3.4).

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 10 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

3.3 Provide unique name(s) for the new organism(s) to be released These name(s) will be on the public register and should clearly identify the organism.

Boneseed leafroller (Tortrix s.l. sp. "chrysanthemoides") Insecta: Lepidoptera: Tortricidae.

3.4 Characteristics of the organism(s) to be released Provide information on the biology, ecology and the main features or essential characteristics of each organism(s) to be released. Provide information on affinities of the organism(s) with other organism(s) in New Zealand. You should also indicate whether the organism is pathogenic or a potential pest or weed. This information should be relevant to the identification of the risks of the organism (section 6 of this form).

Characteristics:

Adult – forewing colour variable but usually mottled earthy brown with a darker narrow zigzag band extending at around 60 degrees to the costa. Mean forewing length 9.5 mm (range 7.9– 10.6 mm) (n = 30). Forewings are narrowly triangular with an acute apex (wing tip). Forms with uniformly mottled forewings also frequently occur. The hindwing is bone coloured with weakly marked eye spots towards the outer margin.

Eggs – pale yellow when first laid, turning to orange. Flat, oval (length 0.7– 1.4 mm, width 0.6– 1.1 mm) with reticulate surface ridges. The area between the ridges is covered in a dense scurf of crystal-like scales, a feature that distinguishes the boneseed leafroller from other species. The egg batch consists of rows of eggs side by side, forming an irregular shape, and is covered with a transparent film secreted by the female during egg laying.

Larvae – first- and second-instar larvae are olive green with indistinct tuberculae (raised, hardened skin patches appearing as white spots) on all abdominal segments. In later instars (III–VI) the head, thoracic shield, and anal plate are black, and the abdomen is dark olive brown to black, paler on the underside, with white tuburculae in parallel rows along the length.

Pupae – light to dark brown, average length 10.57 mm (range 8.3–12.0 mm) (n = 96), with a row of small spines on the upper side of each segment of the abdomen, and hooked spines on the anal segment.

Note: Preserved boneseed leafroller specimens have been lodged in the New Zealand Arthropod Collection (Landcare Research) and these specimens have been examined by John Dugdale, a tortricid (leafroller) expert (John Dugdale, Landcare Research, pers. comm. [b]).

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 11 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

The boneseed leafroller belongs to the family Tortricidae (leafrollers – moka/tikopa). Tortricids are often called bell moths because when at rest the wings of many species form a neat bell shape. The caterpillars are fast movers and can go in reverse. Most leafroller caterpillars make themselves a safe home by rolling or folding up leaves and tying them with silken webbing that they produce from their mouths. Formerly, Māori looked out for these folded leaves, to collect and eat the caterpillars, naming them moka or tikopa (from kopa meaning bent or folded). Other tortricid caterpillars tunnel into fruit, seeds, or soft stems (Crowe 2002).

About 5000 species of tortricids are known worldwide. In New Zealand there are 211 morphologically or pheromonally defined entities (morpho- and phero-species) recorded within the family Tortricidae. There are 194 endemic tortricid “species” (91.9%), and five naturally indigenous species (2.4%). Naturally indigenous species are those that are shared with Australia and that were discovered in New Zealand, feeding on indigenous or endemic plants, at the beginning of European settlement. There are 12 species (5.7%) that are adventive since European settlement and are reliant on adventive hosts. Seven of those 12 adventive species are self-adventive, and five were assisted to New Zealand by humans, either accidentally (four species) or intentionally (one species – the gorse biological control agent Cydia succedana).

The host range of 57 tortricid species in New Zealand (27%) is unknown. One hundred and fifteen species (54.5%) are known to be specialist feeders (a narrow host-range – often restricted to just one genus or species), 33 species (15.6%) are known to be generalist feeders (a wide host-range), and six species (2.8%) are known to be detritivores (feeding on dead organic matter) (John Dugdale, Landcare Research, pers. comm.).

Some tortricids in New Zealand, including several endemic species, are pests, damaging orchard fruit or foliage, and plantation forests. Some of the common pest species are: codling moth – Cydia pomonella (adventive); light brown apple moth – Epiphyas postvittana (adventive); black-lyre moth – Cnephasia jactatana (endemic); blackheaded leafroller – Ctenopseustis obliquana (endemic); brownheaded leafroller – Ctenopseustis herana (endemic); greenheaded leafroller – Planotortrix excessana (endemic).

Ecology:

In Western Cape Province, South Africa, the boneseed leafroller is multivoltine with three generations per year. Adults, which are primarily nocturnal, oviposit on the upper and lower leaf surfaces, and eggs take about 8–10 days to hatch in the laboratory (20–22°C). The average number of eggs laid per female is about 200. In the field, newly hatched larvae may drift on short silken threads if disturbed or where suitable foliage is not immediately available. Boneseed leafroller larvae web leaves together to form a shelter, and feed on leaf material from within this shelter. Young larvae prefer the soft tips of branches, but larger larvae can web together older leaves further down the stems giving them the capacity to defoliate whole plants. Pupation occurs inside a loose silken cocoon within this feeding shelter. Development time from hatching to the emergence of adults takes about 6 weeks at 20–22°C, and both male and female adults live for about 10–12 days. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 12 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

In South Africa, this species is found throughout the entire range of the two Chrysanthemoides species (C. monilifera and C. incana), along the coastal belt from Western Cape Province to southern Mozambique. It appears to have excellent powers of dispersal (Scott & Brown 1992). Outbreaks of boneseed leafrollers occur periodically on Chrysanthemoides in South Africa, and in severe infestations virtually every growing tip can be occupied by a larva. Infestations of this degree not only result in severe defoliation of the plants, but also inhibit flowering as the young buds are consumed (Scott & Brown 1992).

Although it is not possible to predict with certainty the efficacy of a specific biocontrol agent, some insight into its potential performance can be gained from experience overseas, both in its country of origin and in countries to which the agent has been introduced. The boneseed leafroller is considered to be the most damaging insect found on the two species of Chrysanthemoides (C. monilifera and C. incana) in South Africa, and has a significant influence on their population dynamics (Scott & Adair 1990). Boneseed leafroller outbreaks occur periodically on Chrysanthemoides in South Africa, and can lead to complete defoliation and death of plants. Persistent defoliation by the boneseed leafroller is expected to reduce the threat of boneseed in New Zealand by lowering seed production and shoot and root growth rates, and sometimes killing entire bushes, as occurs in South Africa. The reduced "fitness" and lowered canopy cover of boneseed are expected to facilitate the establishment of co-occuring native plants in New Zealand that are presently being out-competed by boneseed.

The genus Chrysanthemoides, to which boneseed belongs, is one of six genera in the tribe Calenduleae (Asteraceae) that are native to South Africa (Weiss 1986). It comprises only two species, C. monilifera and C. incana. However, six subspecies of C. monilifera have been described. C. monilifera has been introduced into a number of countries including Australia, Italy, St Helena, and France (Weiss 1986; Scott 1996). The one subspecies established in New Zealand (which is also found in Australia) is C. monilifera ssp. monilifera (L.) Norl., commonly known as boneseed, and occasionally referred to as salt bush. A second subspecies, C. monilifera ssp. rotundata (DD.) Norl. (bitou bush), is established in Australia, where both subspecies are weedy (Weiss 1986). In New Zealand, boneseed occurs mainly in coastal habitats throughout the North Island, and in Nelson/Marlborough, the Port Hills around Christchurch, and Anderson's Bay in Dunedin, in the South Island (Webb et al. 1988).

Boneseed and bitou bush are the subjects of an active biological control programme in Australia. Biocontrol agents already introduced to Australia, or being considered for introduction, for the control of boneseed are:

the boneseed leafroller (Tortrix s.l. sp. "chrysanthemoides") the Chrysanthemoides tip moth (Comostolopsis germana) a seed-feeding tephritid fly (Mesoclanis magnipalpis) a mite (Aceria neseri). a rust fungus (Endophyllum osteospermi) three leaf-feeding beetles (Chrysolina picturata, Chrysolina sp. A, and Chrysolina sp. B) 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 13 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

The Chrysanthemoides tip moth, Comostolopsis germana, that feeds on the tips of boneseed foliage, is now established in Australia but it suffers badly from ant predation. The seed-feeding fly Mesoclanis magnipalpis has been released in Australia but its establishment status is not yet known. Safety testing of the leaf buckle mite Aceria neseri has been completed in Australia and an application for release in Australia will be submitted soon. The Australians have also made considerable progress on the host-range testing of the boneseed rust fungus Endophyllum osteospermi. Further testing of this pathogen will be required but it is on hold at present. Three leaf-feeding beetles (Chrysolina picturata, Chrysolina sp. A, and Chrysolina sp. B) have also been released in Australia but they don't appear to have established, probably due to predation (Raelene Kwong, KTRI – New South Wales, Australia, pers. comm.).

The boneseed leafroller was released in Australia in April 2000. Although establishment has been confirmed, populations are still generally low, probably due to parasitism and predation. A predation trial in Tasmania and Victoria found there were many predators, including ants, predatory mites, and spiders, attacking eggs and larvae (Ireson et al. 2002). In Australia, boneseed is a host to scale insects that attract ants, and where large numbers of ants occur, there has been no success in establishing the boneseed leafroller. Attempts are now made to exclude ants from release bushes by putting a band of grease around the stem, after first skirting and pruning. Releases in winter could also be attempted, when ants are not so active (Raelene Kwong, KTRI – New South Wales, Australia, pers. comm.). The ant fauna of New Zealand is more benign than that of Australia and we don't expect ants to be such a problem here. Predation by ants in Australia is probably the main reason that the ragwort biocontrol agent Tyria jacobaeae (cinnabar moth) has been a lot less successful in Australia than in New Zealand (Pauline Syrett pers. comm.).

The invertebrate fauna associated with boneseed in New Zealand was surveyed in 1999–2000 (Winks & Fowler 2000). Invertebrate parasitoids and predators were recorded in order to gain information on factors that may affect any future biological control introductions. This study showed that boneseed is attacked by a wide range of native and exotic invertebrates in New Zealand. However, no specialised boneseed feeding invertebrates were found during this survey, and there was no evidence that any of the invertebrate biological control agents introduced to Australia had established in New Zealand by "accident". The most obvious feeding damage observed on boneseed foliage in New Zealand was caused by the adults of the garden weevil, Phlyctinus callosus (native to South Africa), and, to a lesser extent, Fuller's rose weevil, Asynonychus cervinus (native to South America). Larvae of both weevil species feed on plant roots but they were not searched for during this survey. Adult weevil feeding damage was sometimes severe, with up to 25% of the foliage of some boneseed plants consumed. Generally, however, the damage was far less severe, and it was common for about 2–5% of the foliage to have been consumed. Fourteen other species of herbivorous beetles (native and exotic) were also detected in the survey, but due to their relatively low numbers, and often small size, their combined effect was probably minimal. Leafroller caterpillars (Tortricidae), of several species, were occasionally found tying boneseed leaves together with white silken webs, but they appeared to produce only minor damage overall. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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During the survey of invertebrate fauna associated with boneseed in New Zealand, parasitoids were reared from a variety of caterpillar species collected from boneseed, including tortricid species (the family to which the boneseed leafroller belongs). Some of these parasitoids are likely to affect the boneseed leafroller if it is released in New Zealand. In South Africa the boneseed leafroller is subject to high levels of parasitism by an egg parasitoid (Trichogramma sp.), by 11 species of larval parasitoids (Bethylidae, Braconidae – 8 species, Ichneumonidae, Tachinidae), and a pupal parasitoid, Arctia sp. (Tachinidae). Egg parasitism by Trichogramma sp. may reach greater than 90% in the second and third generations of the boneseed leafroller each year, and larval parasitism can range from 30 to 70% over most of the year. It is considered that a temporary escape from the parasite load contributes to the observed outbreaks in South Africa (Edwards & Adair 1999).

Argentine ants, Linepithema humile, were recorded from three sites during the survey of the invertebrate fauna associated with boneseed in New Zealand. It was noted that at the three sites, where large numbers of Argentine ants were present, scale insects (Coccidae) were particularly common. Argentine ants are known to farm sap-feeders, such as scale insects, by providing protection from predators and parasites, in order to gain access to their carbohydrate- rich secretions (honeydew) (Gullan 1997). Argentine ants can reach very high densities in New Zealand, and they are able to outcompete most other ant species (Harris 2001). As well as feeding on carbohydrate, such as honeydew, Argentine ants feed on protein, which could take the form of a wide range of invertebrates. It was noted that where there were large numbers of Argentine ants, the numbers and diversity of other invertebrates (apart from scale insects) was greatly reduced. Judging by experiences in Australia with ants, the future distribution and abundance of Argentine ants in New Zealand could be very significant for the prospects of the boneseed leafroller.

3.5 Identify and characterise any inseparable organisms Inseparable organisms are those which are inherently associated with the main organism e.g. gut bacteria in an animal.

The boneseed leafroller is not known to host any inseparable organisms.

If approval is given to import the boneseed leafroller for release in New Zealand, a colony will be established in a rearing facility in South Africa, using specimens collected from the same area that specimens were collected from for host range testing (western Cape Province, South Africa). Captive-reared material will be imported from South Africa as 5th and 6th instar larvae (other life stages, e.g. adults and pupae, do not withstand travel very well) into secure quarantine containment in New Zealand, in the Ministry of Agriculture and Forestry Regulatory Authority (MAFRA) approved facility No. 644 at Lincoln. Procedures for the quarantine containment of the boneseed leafroller will be as required by the MAFRA Standard 154.02.08: Standard for Invertebrate Quarantine Facilities, and Landcare Research's operating procedures 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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as contained in the “Quarantine and Containment Manual” (Gourlay 2001). Pursuant to Section 40 of the Biosecurity Act 1993, Mr Hugh Gourlay is the registered manager of this facility. The facility complies with the standards set out in the Third Schedule, Part II of the HSNO Act 1996. Operating under these regulations, the facility offers a high level of security with low levels of risk.

Any parasitoid, predator, or organism capable of generating an epizootic (parasitic from the outside or on the surface) is most unlikely to pass undetected through the quarantine containment procedures required by the Ministry of Agriculture and Forestry (MAF) in accordance with an Import Health Standard issued under the Biosecurity Act 1993. The Import Health Standard will specify a period during which the species will be reared in quarantine containment. A sample of specimens will be tested for the presence of pathogens. Voucher specimens will be lodged in the New Zealand Arthropod Collection (NZAC) and taxonomic identification by a specialist lepidopteran taxonomist will be conducted while the insects are still in containment. Provided results of the pathogen testing are negative, and the insects are confirmed to be the correct species, application will be made to MAF for permission to release the boneseed leafroller from quarantine containment.

Note: The boneseed leafroller will be imported into quarantine containment in New Zealand only after ERMANZ has deemed it to be a suitable species to be released in the New Zealand environment. Subsequently it will be the responsibility of MAF to grant permission to release the boneseed leafroller from quarantine containment, once they are satisfied that all quarantine requirements have been met.

3.6 If the organism to be released is a genetically modified organism, provide details on the development of the organism If the organism to be released is a genetically modified organism, state whether the development of the organism was carried out under a HSNO approval. If this was the case, provide the approval number and translate the relevant details to the headings below. If the genetically modified organism is to be imported for release, also provide this information on its development to the extent possible under the following headings:

Identify the category of the host organism (i.e. category 1 or 2) and genetic modification (i.e. category A or B) involved in the development of the organism with reference to the HSNO (Low-Risk Genetic Modification) Regulations 2003. Please explain your characterisation.

N/A

Vector system(s) used in development of the genetically modified organisms.

N/A 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Type and source of additional genetic material.

N/A

Use of special genetic material: please complete this table by marking the correct box

Yes No Were native flora or fauna used as host organism(s)? N Was genetic material from native or valued flora and fauna used? N If native flora and fauna were involved, were the species N concerned indigenous to New Zealand? Was human genetic material involved? Answer Yes if human N genetic material in any form was used, i.e. obtained directly from humans (either Māori or non- Māori from a gene bank, synthesised, copied and so on). Was genetic material obtained directly from human beings? N If Yes, provide additional details below.

If the genetic modification involves DNA of human origin, provide details of from where the material was obtained (including provenance and/or informed consent), and whether approval was obtained from an Ethics Committee, and/or whether consultation with Māori has taken place.

N/A

Other relevant details (such as what techniques or experimental procedures were used, whether any unusual manipulations were carried out, and how the foreign genetic material is expressed).

N/A

3.7 Does the organism have any other HSNO containment approvals not covered in 3.6 (e.g. import into containment, field test, or conditional release approval)? State whether the organism to be released has any other HSNO containment approvals. If this is the case, provide the approval number(s) and give brief details of those approvals.

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No. The organism to be released does not have any other HSNO containment approvals.

Section Four – The Proposed Release Programme (and Monitoring) Provide full details of your intended release programme e.g. information on the breeding and culture, and the life- stage and number of the organisms to be released; timing and location(s) of release etc. Also provide information on any post-release monitoring you intend to carry out.

4.1 Proposed release programme

If approval is given to import the boneseed leafroller for release in New Zealand, a colony will be established in a rearing facility in South Africa, using specimens collected from the same area that specimens were collected from for host range testing (western Cape Province, South Africa). Captive-reared material will be imported from South Africa as 5th and 6th instar larvae (other life stages, e.g. adults and pupae, do not withstand travel very well) into secure quarantine containment in New Zealand (see Section 3.5). Once permission has been granted by MAF to release the boneseed leafroller from quarantine containment, a colony will be established in a Landcare Research rearing facility. Mass rearing of the boneseed leafroller for release will be conducted according to the methods outlined in Winks et. al. 2002. The locations, numbers, timing, and methods of releases will be determined collaboratively by staff from Landcare Research, regional councils, the Department of Conservation, iwi throughout New Zealand, and colleagues in South Africa and Australia, bearing in mind post-release monitoring requirements.

4.2 Post release monitoring

It is important that biological control programmes are effectively monitored after the release of agents and if approval is given for the release of the boneseed leafroller in New Zealand a detailed monitoring programme will be devised to assess its establishment and impact. When chosing initial release sites for the boneseed leafroller, consideration will be given to the monitoring programme. Releases will be made at selected sites, and other matched sites will be randomly allocated as “control” sites. All boneseed leafroller release sites will be visited at least once during the first two years after release to record the number of boneseed leafrollers found (adults, larvae, or pupae) and the distances that these were found from the point of release. More intensive monitoring to gain quantitative information on the impact that the boneseed leafroller is having on boneseed will be carried out at selected sites. The number of sites selected for intensive monitoring will be finalised once it has been confirmed what resources will be available for post release monitoring. Monitoring will be done by Landcare Research staff in collaboration with staff from regional councils, the Department of Conservation, and iwi throughout New Zealand.

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Section Five – Establishment and Eradication of Undesirable Self- sustaining Populations Information under this heading is required so that the Authority can take account of the matters set out in section 37 of the Act.

5.1 Ability of organism(s) to establish an undesirable self-sustaining population Describe any ability of the organism to establish an undesirable self-sustaining population. This may include, but not be restricted to, information on the time taken for the organism(s) to become established, the likely geographical spread of the organism(s), and effects of variations in climate and altitude on the establishment, distribution, abundance and biology of the organism(s). Explain why such a population would or would not be undesirable. For a full (unconditional) release the issue of (un)desirability is crucial, because in many cases the establishment of a self-sustaining population will be expected (e.g. a bio-control release).

The objective of introducing the boneseed leafroller to New Zealand is to establish self- sustaining populations in all areas of New Zealand affected by boneseed. Therefore we are applying for a full (unconditional) release. The potential risks and benefits associated with the introduction of the boneseed leaf roller to New Zealand have been systematically identified and assessed, and are presented in this application. The main benefit of introducing the boneseed leafoller to New Zealand is expected to be to the natural environment, and will arise from reducing the adverse effects of boneseed. The most important risk identified is potential damage to non-target plants, but the evidence presented in this application indicates that this risk is negligible.

5.2 Ease of eradication of an undesirable self-sustaining population Information under this heading should be provided unless the information under section 5.1 clearly indicates that establishment of an undesirable self-sustaining population is highly improbable.

The establishment of an undesirable self-sustaining population of the boneseed leafroller in New Zealand is highly improbable as detailed in this application. If permission is given for the release of the boneseed leafroller in New Zealand, large numbers will be released over a wide geographic range of New Zealand, and it is likely that they will establish. Once established they would be extremely difficult and costly to eradicate, but it is extremely unlikely that there would be any reason to attempt to eradicate them.

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Section Six - Identification of Risks, Costs, and Benefits Risk means the combination of the magnitude of an adverse effect and the probability of its occurrence. Cost means the value of a particular adverse effect expressed in monetary or non-monetary terms. Benefit means the value of a particular positive effect expressed in monetary or non-monetary terms. In this part of the form you are required to identify the risks, costs and benefits of the organism(s) in the context of the application.

A very broad approach should be taken to this, so that a wide range of possibilities are canvassed. In the first instance you are required to identify all potential risks, costs and benefits whether you consider them to be non- negligible or not. This should be carried out for inseparable organisms as well as for the principal organism. To do this effectively you should consider both the source of the risk (or hazard) and what is at risk (or area of impact). You should also consider the route (or exposure pathway) between the source and the area of impact.

Essentially what you should end up with is a very brief description of the risks, costs and benefits (e.g. the potential for the pathogenic micro-organism (hazard) to have adverse effects on human health (area of impact) from consumption of the organism (exposure pathway). A more detailed assessment of these and other matters will be required in the next section (section 7).

Once you have considered all possibilities then you should clearly identify those risks, costs and benefits which warrant further more detailed assessment (in section7). If you consider that the effects identified do not warrant detailed assessment, explain why.

You can refer to the ERMA New Zealand Technical Guides “Identifying Risks for Applications” and “Risks, Costs and Benefits for Applications for further information and guidance on completing this section. These are available from the ERMA New Zealand website or in hard copy on request. Please undertake your identification of risks, costs and benefits under each of the following headings (areas of impact) which reflect those matters referred to in Part II of the HSNO Act:

6.1 Identification of effects on the environment (in particular on ecosystems and their constituent parts) Taking particular account of sections 5(a), 6(a) and 6(b) of the Act, list the environmental risks, costs and benefits associated with the organism(s) to be released and any inseparable organisms. Risks, costs and benefits in this category include those relating to the life supporting capacity of air, water, soil and ecosystems; the sustainability of native and valued introduced flora and fauna; the maintenance of natural habitats; the intrinsic value of ecosystems; New Zealand‟s inherent genetic diversity; and animal or plant health.

List risks and costs, and benefits, separately.

Risks and costs:

Possible adverse effects on the environment and ecosystems

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Possible Direct effects The new species attacks non-target plants The wrong species is released due to incorrect identification An ecotype of the species is released that behaves differently from that used in host range testing Evolutionary change of the host range of the biocontrol agent leads to non-target attack Accidental release of associated organisms (predators, parasitoids, or pathogens)

Possible Indirect effects

The sudden removal of boneseed from ecosystems leading to an increase in soil erosion The replacement of boneseed with other weeds The new species becomes established as a new element of the New Zealand fauna and has an adverse effect on indigenous biodiversity through a "dilution" effect The introduced species becomes an alternative host for parasitoids, predators, or diseases thereby affecting existing food webs The new species reduces the availability of nectar or pollen for other invertebrates or birds The new species increases pollination of other weed species An adverse effect is caused by competition with existing natural enemies of boneseed The new species interbreeds with existing species The new species is a vector of diseases that are harmful to elements of the environment

Benefits:

Possible beneficial effects on the environment and ecosystems

The replacement of existing boneseed infestations with more-desirable plants Reduced invasion of boneseed into vulnerable habitats Reduced use of herbicides Assistance with the spread of the boneseed rust fungus (Endophyllum osteospermi) if it is released in New Zealand

6.2 Identification of effects on human health and safety (including occupational exposure) Taking particular account of section 6(c) of the Act, list any potential risks, costs and benefits to human health that may be related to the release of the organism(s) in New Zealand. Consider the impact on people associated with the release programme as well as the wider community.

List risks and costs, and benefits, separately. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Risks and costs:

The new species is directly harmful to humans (e.g. it bites, stings, and is poisonous) The new species is indirectly harmful to humans (e.g. it is a vector of human diseases) The new species annoys people with its offensive odour

Benefits:

Reduction in herbicide use (beneficial to spray operators and the general public) Reduction of accidents relating to boneseed control operations

6.3 Identification of effects 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 (taking into account the principles of the Treaty of Waitangi) Taking account of sections 6(d) and 8 of the Act, list any adverse and beneficial effects 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 (taking into account the principles of the Treaty of Waitangi). In this area it is especially important to indicate the extent to which the effects reflect the expressed views of the Māori community. However, details on these views and how they were obtained should be dealt with under the assessment section (section 7).

List risks and costs, and benefits, separately.

Risks and costs:

In assessing the potential issues of significance to Māori, information was obtained from ERMA New Zealand staff, from ERMA New Zealand policy documents, and from direct consultation with iwi throughout New Zealand. Table 6 summarises potential issues of significance to Māori associated with the proposed introduction of the boneseed leafroller to New Zealand. No significant risks or costs have been identified.

Benefits:

The successful establishment of the boneseed leafroller in New Zealand should benefit flora and fauna of importance to Māori by suppressing boneseed.

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6.4 Identification of economic and related effects Taking particular account of section 6(e) of the Act, list the economic risks, costs and benefits that might arise to New Zealand. Include related effects (e.g. scientific knowledge), which are likely to have economic or related value.

List risks and costs, and benefits, separately.

Risks and Costs:

The new species causes economic damage to ornamental plants or plants of importance to agriculture, horticulture and forestry The new species feeds on nectar, causing economic losses to beekeepers from competition

Benefits:

A reduction in the populations, vigour, and spread of boneseed leading to a reduced cost of current control methods

6.5 Identification of cultural, social, ethical and spiritual effects Taking particular account of section 5(b) and the full definition of “Environment” in section 2 of the Act, list any adverse and beneficial impacts on people and communities that might arise and relate to their capacity to provide for their own social and cultural wellbeing both now and into the future. Also list any ethical or spiritual risks, costs and benefits that might arise as per section 68(1)(a) of the Act. Indicate what steps have been taken to assist the identification of the effects in this area, for example, was there any community involvement? However, details on this should be dealt with under the assessment section (section 7).

List risks and costs, and benefits, separately.

Risks and Costs:

No adverse cultural, social, ethical, and spiritual effects were identified to result from the introduction of the boneseed leafroller to New Zealand.

Benefits:

There are potential benefits from increased conservation values placed by individuals and communities on ecosystems were boneseed has been replaced by other species, and in particular native species. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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6.6 Identification of other effects (including New Zealand’s international obligations) List any remaining adverse and beneficial affects not already covered including any effects on New Zealand‟s international obligations (as per section 6(f) of the Act).

List risks and costs, and benefits, separately.

No other matters are known to apply.

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Section Seven – Assessment of Potential Non-negligible Risks, Costs and Benefits This section entails detailed assessment of those effects identified in section 6 that you consider to be non- negligible. The assessment should describe the nature of the effects and should discuss, in more detail than in section 6, the source of the effects and the pathways leading to them. Assessment also entails providing an estimate of the likelihood of occurrence (which may be measured as frequency or probability) and the magnitude of the outcome if the effect should occur. The degree of uncertainty associated with the assessment should also be analysed. The factors set out in clause 33 of the HSNO (Methodology) Order 1998 which outlines various risk characteristics that will influence the decision-makers approach to risk should be referred to. These include characteristics such as the risk will persist over time or the potential adverse effects are irreversible. In such instances the Authority will be more cautious and risk averse when considering such matters.

You should carry out your assessment taking into account the matters regarding undesirable self-sustaining populations set out in section 37 of the Act (and addressed in section 5 of this form). ERMA New Zealand uses qualitative scales for assessing effects which may be of some use to you in completing this section – please refer to the ERMA New Zealand Technical Guide “ Decision Making: techniques for identifying, assessing and evaluating risks, costs and benefits” for further details. Please cover all of these issues under each of the following headings (areas of impact) which reflect those matters referred to in Part II of the HSNO Act:

7.1 Assessment of effects on the environment (in particular on ecosystems and their constituent parts) Assess the risks, costs and benefits associated with the organism(s) to be released and the ways that they might adversely affect or improve/enhance (in the case of benefits) the New Zealand environment e.g. the life supporting capacity of air, water, soil and ecosystems; the sustainability of native and valued introduced flora and fauna; natural habitats and the intrinsic value of ecosystems; New Zealand‟s inherent genetic diversity; animal or plant health.

Assess risks and costs, and benefits, separately. Where benefits and risks are linked, state this (e.g. a bio- control which has an impact on both the target organism (benefit) and non-target organisms (risk)).

Risks and costs:

Direct effects A potential adverse effect of any biological control programme is direct impact on non-target species, and this is always the subject of testing to establish whether this risk is significant. Types of tests may include oviposition tests, adult feeding tests, and larval development tests. These tests may be "choice" (where the target species is present) or "non-choice" (were the target species is not present). Tests may be done in a quarantine laboratory, or in the native range in the open or in cages. The type of tests done depend on many factors, particularly the biology of the agent. In most phytophagous (plant-feeding) insects the larval food is determined primarily by the ovipositing adult female, not by the juvenile stages, and the process of host

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selection is used by most biological control workers as the most important indicator of host range (Heard 1997).

Testing of every possible species against a proposed biocontrol agent is not possible and an internationally recognised procedure has been devised to determine whether the proposed new organism is safe to release. Potential control agents are tested with a range of plant species selected according to criteria established by Zwölfer & Harris (1971) and Wapshere (1974, 1975), and revised by Forno & Heard (1997). The predictability of this procedure is well established and unexpected effects have been minimal. Over 1150 releases of more than 365 species of insects and pathogens for control of 133 weeds in 75 countries have been made (Julien & Griffiths 1998), and where the protocols have been applied correctly, impact on non- target plants has been negligible (McFadyen 1998).

The boneseed leafroller was selected as a potential biocontrol agent for boneseed in New Zealand because it is regarded as being specific to the two species of the genus Chrysanthemoides and the risk to other biota in New Zealand is considered to be negligible (as explained below). This high specificity was determined firstly by thorough ecological studies. Extensive quantitative searches were undertaken by the Australian CSIRO Biological Control Unit based at the University of Cape Town, South Africa, for the Australian biological control of boneseed programme. Searches were undertaken in South Africa over a 2-year period on 126 plant species growing in close proximity to C. monilifera and C. incana plants infested with the boneseed leafroller. It was found that the leafroller did not attack any other plant species, even in situations where numbers were high enough to severely defoliate or kill the nearby Chrysanthemoides hosts (Edwards & Adair 1999).

Extensive host-range testing has been conducted on the boneseed leafroller for the Australian biological control of boneseed programme, including laboratory larval development tests (choice and no-choice) and open-field testing in South Africa (Edwards & Adair 1999). Ninety-six plant species from 31 families were tested, including 50 species from the family Asteraceae to which boneseed belongs (Edwards & Adair 1999) (Appendix 2 of this application). In laboratory tests, feeding occurred on a number of non-target test-plants, a result that was completely inconsistent with the high level of specificity observed in the field in South Africa. This necessitated the use of extensive open-field testing in South Africa to examine the oviposition behaviour of adult females and the host choice behaviour of larvae (Edwards & Adair 1999). The conclusion drawn from these field tests was that the boneseed leafroller is specific to the two species of the genus Chrysanthemoides (C. monilifera and C. incana). Non-target oviposition and very limited survival of larvae may occur on Calendula (marigolds) in the field but only in situations where these plants grow in very close proximity to C. monilifera (Note: Calendula is in the same tribe (Calenduleae) as C. monilifera). The boneseed leafroller was released in Australia in April 2000.

In the field, insects go through two stages of host selection, choice of oviposition site by females, and choice of feeding site by larvae. Extended host ranges under laboratory conditions are not unusual in the evaluation of biocontrol agents (Cullen 1990; Wapshere 1989). Laboratory testing conditions can remove essential cues required by the agent for host selection 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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and produce a physiological feeding range that exceeds the natural range. Open-field testing provides a sensitive and powerful tool for host specificity determination and is often the only means of clarifying ambiguous laboratory results (Clement & Cristofaro 1995; Briese 1999). However, open-field tests are not commonly undertaken because of the much higher expense involved compared with laboratory testing procedures. In the case of the boneseed leafroller, open-field testing was the only method of ascertaining the true feeding range of this species.

The host specificity of the boneseed leafroller was further tested during 2001, using an oviposition field test, to determine its suitability as a biocontrol agent for boneseed in New Zealand (Winks et al. 2002). Landcare Research carried out this work in South Africa, in conjunction with the CSIRO Biological Control Unit based at the University of Cape Town, South Africa. Ten test-plant species plus boneseed were used in the host range testing for New Zealand (Table 1). The list of test plants was developed in consultation with Landcare Research botanist Dr I. Breitwieser.

Table 1. Plant species used for testing the host specificity of the boneseed leafroller for New Zealand

Family Subfamily Tribe Species

Asteraceae Asteroideae Anthemideae Cotula turbinata

Astereae Bellis perennis Erigeron karvinskianus

Calenduleae Chrysanthemoides monilifera ssp. monilifera

Eupatorieae Liatris spicata Gnaphalieae Ozothamnus leptophyllus

Pseudognaphalium luteoalbum Heliantheae Bidens pilosa

Senecioneae Brachyglottis greyi

Cichorioideae Arctotideae Arctotis angustifolia Lactuceae Sonchus oleraceus (puha)

The Asteraceae family is divided into three subfamilies, the Barnadesoideae, the Asteriodeae, and the Cichorioideae. There are no representatives of the subfamily Barnadesoideae in New Zealand. For an insect such as the boneseed leafroller, where a high degree of host specificity 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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is expected, testing would normally concentrate on plants of importance to New Zealand (as natives, crops, or ornamentals) from the same subfamily (Asteroideae) and tribe (Calenduleae) as the target weed. There are no native New Zealand representatives of the tribe Calenduleae, and the two most commonly grown ornamentals from the tribe, Calendula officinalis (marigolds) and Osteospermum fruticosum (dimorpotheca), were both tested for the Australian biological control programme. Representative genera were selected from other tribes in the Asteraceae for the New Zealand host specificity testing, and particular emphasis was placed on the subfamily Asteroideae to which boneseed belongs. The results of this field test (Winks et. al. 2002 – Appendix 1 of this application) add to the evidence already available from field observations in South Africa, and host specificity testing conducted for Australia, that the boneseed leafroller is expected to feed only on boneseed in New Zealand.

Correct identification of the proposed biocontrol agent is critical, and taxonomic identification by a specialist lepidopteran taxonomist would be conducted on the insects while they are being held in quarantine, in accordance with an Import Health Standard issued by MAF under the Biosecurity Act 1993. Voucher specimens of boneseed leafroller adults from quarantine would be lodged in the New Zealand Arthropod Collection (NZAC). Based on MAF import requirements it is very unlikely that a species other than the intended biocontrol agent would be released.

Ecotype variability of the proposed biocontrol agent needs to be considered. Host range testing of the boneseed leafroller for both the Australian and New Zealand boneseed programmes was conducted using specimens collected from the vicinity of Cape Town, South Africa. Specimens imported for release in New Zealand would be collected (and laboratory reared in South Africa) from the same area as the specimens used in the host range tests. It is therefore considered that adverse effects caused by ecotype variability of the proposed biocontrol agent are very unlikely.

Host range testing of the boneseed leafroller has demonstrated that, given the current host- range, attack on non-target species is very unlikely. In terms of the future, evolutionary change in host range obviously occurs, but it is gradual, in very small steps. The time frame for any evolutionary change would be very long term and would probably only occur under heavy selection pressure, and probably only if the weed became very rare. The nature of co-evolution between plants and their specialised herbivores means that any such changes affect relationships with very closely related species rather than more distantly related species. Thus any future change to the boneseed leafroller is more likely to affect its relationship with other species of the tribe Calenduleae than more distantly related species. There are no native members of this tribe in New Zealand, and few introduced species of economic importance in the tribe. Thus the possibility of the boneseed leafroller switching from feeding on boneseed to cause significant damage to non-target plants is considered to be very unlikely.

The risk of accidental release of associated organisms such as predators, parasites, or pathogens is extremely low due to the quarantine containment procedures required by the Ministry of Agriculture and Forestry (MAF) in accordance with an Import Health Standard issued under the Biosecurity Act 1993 (refer to Section 3.5). 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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There is a hypothetical possibility that boneseed could develop resistance to a biocontrol agent such as the boneseed leafroller, but the agent is also capable of evolution so as to track changes in the host. Evolution of new resistant forms of weeds has not been recorded in weed biological control programmes. The risk is thus considered to be insignificant.

Indirect effects It is possible to construct a number of hypothetical scenarios in which the introduction of the boneseed leafroller could have indirect effects on ecosystems in New Zealand. However, it would be very difficult to reliably define the likelihood of those scenarios, or to predict whether the outcomes of most of those scenarios will be adverse or beneficial. This is because knowledge of existing community interactions in New Zealand ecosystems is incomplete, and there is little measure of the natural spatial and temporal variation in those interactions. Without that background information, reliable prediction of the secondary impacts of adding an introduced control agent is not possible. Worldwide, this information is only fragmentary. Experimental studies are rare, and normally involve removing species from communities, not adding them. The effect of an agent could be determined experimentally, but only after the agent was released, and such an experiment would compare communities in which the agent was released with agent-free communities. Such a study would be major undertaking involving many staff, and would probably take ten or more years to complete.

Potential adverse indirect effects could result either from the addition of the agent itself to the invertebrate fauna, or from the reduction in the abundance of the target weed (Fowler et al. 2001). The scenarios that seem both reasonable and foreseeable are listed below and summarised in Table 2.

1. The rapid and uniform destruction of boneseed infestations over a short period could lead to an increase in erosion on some erosion-prone slopes currently infested by boneseed. There is also the possibility of an increased rate of water runoff, and decline in water quality. However, boneseed is a woody perennial, and it is unlikely that successful biological control would lead to rapid, wholesale death of mature plants (within a single season for example) over a wide area. It is more likely that heavy foliage damage would lead to reduced growth, shoot dieback, and the death of a small proportion of mature plants annually, leading to a slow decline in plant density. Even if an agent killed an entire plant it would not immediately remove it, and the dead material would continue to hold the soil surface for a period. On most erosion-prone slopes, reduction in the density of boneseed as a result of biological control will result in complementary invasion by other plant species.

2. A fear that is sometimes expressed is that when a weed has been successfully controlled it may be replaced by another weed that is even more damaging, and indeed in some cases, control of one weed has resulted in its replacement by another (McEvoy & Coombs 1999). Manipulation studies in vegetation have repeatedly shown that elimination of one component species results in an increase in species already present to fill the gaps (Likens 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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1985). The particular plant species that replace boneseed will be site-specific, depending on the suite of plants present at (or being dispersed into) the site. Should other weeds replace boneseed, it is likely that benefits would be reduced rather than there being any particularly adverse effect. Groves (1991) has emphasised the importance of promoting competing native plants in conjunction with biological control programmes in natural ecosystems. Therefore, if biological control reduces the competitive ability of boneseed in infested areas, revegetation with native species should be encouraged. This would apply especially to areas of high conservation or scenic value, and to areas with a scarcity of native plants available to "fill the gaps".

3. Some ecologists fear that the continual release of biocontrol agents will have an adverse effect on indigenous biodiversity through a dilution effect. This fear is unfounded because the main source of additions to the fauna comes from unscreened, accidental introductions. The exotic insect fauna of New Zealand is estimated to be about 13% of the total New Zealand insect fauna. About 2.5% of the exotic insect fauna of New Zealand has been released for biological control purposes, and about 1% of the exotic insect fauna has been released for the purpose of biological control of weeds (Emberson 1999). However, the naturalised flora is now greater in number of species than the indigenous flora, and continues to grow (Williams & Lee, 2002). In addition to the naturalised flora there are at least 20,000 plant species (that have had minimal screening for weediness) now in cultivation.

4. An introduced plant-feeding species might affect existing food webs if its population increased to the extent that it became an important alternative host for parasitoids, predators, or diseases that might in turn outbreak, and have an abnormally high impact on their usual hosts. However, the introduced species could also possibly enhance the populations of rare native parasitoids and predators. It is likely that any effects on existing food webs would be minimal as the boneseed leafroller is likely to make up only a small proportion of the total available prey.

5. The risk of the boneseed leafroller significantly reducing the availability of nectar or pollen for invertebrates and birds is considered minimal as it is unlikely that the moths will add significantly to the biomass of the fauna (birds, bees, flies, wasps, moths, butterflies, bumblebees, etc.) that already utilise flower resources.

6. An increase in other weed populations through increased pollination by the boneseed leafroller is possible although the impact of this effect is likely to be minimal compared to that of other pollinators.

7. Competition with, or displacement of, existing natural enemies of boneseed in New Zealand is unlikely to cause any significant adverse effect. The invertebrate fauna associated with boneseed in New Zealand was surveyed in 1999–2000 (Winks & Fowler 2000). The survey showed that boneseed is utilised by a wide range of native and exotic invertebrates in New Zealand but damage is usually not severe. Most of the damage observed on boneseed 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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could be attributed to non-native invertebrates generally regarded as “pest” species (e.g. the garden weevil, Phlyctinus callosus (native to South Africa), and Fuller's rose weevil, Asynonychus cervinus (native to South America).

8. Boneseed is not known to provide valuable habitat for native species in New Zealand. The likely gradual decline in boneseed populations and consequent recolonisation by other plants means native fauna currently associated with boneseed would be very unlikely to be disadvantaged.

9. The decline of boneseed may lead to a loss of food for vertebrates. Most vertebrates tend to be dietary generalists and, as such, do not often rely exclusively on a particular weed species as a food source (Stanley & Fowler 2004; Stanley & Fowler submitted). The species benefiting from weed invasions are usually common generalists that would not be driven to extinction by reduction or eradication of the weed (Schiffman 1997). Although particular species may be found to benefit from weed species, the overall biodiversity of systems usually decreases rapidly as a result of the weed invasion (Griffin et al 1989; Braithewaite et al. 1989; Samways et al. 1996; Ekert & Bucher 1999).

In most cases, weeds are not essential resources, and use of weeds by native vertebrate species is usually the result of availability or preference rather than dependence. Exotic weed species may provide sub-optimal food and habitat for native fauna relative to native plant species (Williams & Karl 2002).

Weed exploitation by native species may also have a number of cascade effects on ecosystems: 1) increase the spread of weeds in natural areas through fruit consumption and seed dispersal (Williams and Karl, 1996); 2) native bird species may no longer fulfil their function as pollinators and dispersers of native plant species (Pooley, 1993; Scott- Shaw, 1999); 3) extra resources provided by weed species could result in unnaturally high population numbers of some vertebrate species, which could in turn result in detrimental economic (orchard pests) and ecological (predation, competition with native species) consequences (Major et al., 1996; Bomford and Sinclair, 2002).

The benefits of removing boneseed, in terms of biodiversity gains and increases in native bird populations, outweigh any negligible benefits boneseed might have as a food source for birds.

DOC currently undertakes large boneseed control operations using herbicides in high value sites for native vertebrates, such as Tiritiri Matangi Bird Sanctuary. Boneseed has not been identified as an important food source for native or introduced bird species, even where it is abundant in bird sanctuaries. There is no information on which (if any) bird species consume boneseed fruit, although DOC would like this information to be able to predict weed spread. DOC view birds feeding on boneseed fruit as a negative impact on biodiversity by facilitation of boneseed invasion of coastal vegetation through seed dispersal (Helen Lindsay, pers. comm.). Similarly, on the Port Hills of Christchurch, observation 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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suggests boneseed provides low scrub cover for a large number of birds, particularly exotic species. Fantails, silver eyes and finches also frequent boneseed habitat. However, there is no specific dependence on boneseed and the birds merely use it because of its presence. There is an abundance of alternative, and more desirable, habitat available on the Port Hills. Rodents, particularly mice, use boneseed cover in a similar manner to birds (Andrew Crossland, Christchurch City Council, pers. comm.).

10. Interbreeding or hybridisation of the boneseed leafroller with species already present in New Zealand is considered to be highly unlikely. John Clearwater, a former HortResearch scientist, was able to get attempted cross-mating between the closely related endemic taxa Ctenopseustis and Planotortrix, but small structural differences stopped insertion of the spermatophore (John Dugdale, Landcare Research, pers. comm.). These two taxa are considerably more closely related than the boneseed leafroller is to other leafroller species in New Zealand (John Dugdale, Landcare Research, pers. comm. [c]).

11. It is possible that the boneseed leafroller could assist the spread of some plant diseases (e.g. rust fungi) by transporting spores. However, it is likely that any effects of this would be minimal, as the boneseed leafroller would make up only a small proportion of the total fauna of a particular area.

Table 2. Systematic identification and assessment of risks to the environment and ecosystems associated with the proposed introduction of the boneseed leafroller to New Zealand.

POTENTIAL RISK EFFECT OF METHOD USED ASSESSMENT RISK TO: RISK TO IDENTIFY OF RISK AND RISK ITS EFFECT Sustainability of New species Suppression or Common sense Very unlikely. If native and valued attacks desirable extinction of assessment, some feeding did introduced flora plants native and valued consultation with occur on desirable and fauna introduced flora weed ecologists, plants, damage is and fauna weed controllers, likely to be minimal botanists, and entomologists in Crown Research Institutes, DOC, regional councils Wrong species is Suppression or " Very unlikely. released due to extinction of Identification by a incorrect native and valued specialist identification introduced flora taxonomist would and fauna be conducted on the insects while in quarantine

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Table 2 cont. An ecotype of the Suppression or " Very unlikely. species is released extinction of Specimens will that behaves native and valued come from the differently from that introduced flora same area as the used in host range and fauna specimens used in testing the host range tests Evolutionary Suppression or " Very unlikely change in host extinction of range of the native and valued biocontrol agent introduced flora and fauna

Accidental release Suppression or " Very unlikely of associated extinction of organisms native and valued (predators, introduced fauna parasitoids, or pathogens) New species feeds Suppression or " The magnitude of on nectar or pollen extinction of the effect is likely native and valued to be minimal introduced nectar or pollen-feeding fauna Loss of habitat for Suppression or " Effect likely to be native and valued extinction of minimal as introduced flora and native and valued recolonisation by fauna caused by a introduced fauna other plants is decline in boneseed likely if there is a decline in boneseed Loss of food for Suppression or “ Effect likely to be vertebrates extinction of minimal as vertebrates alternative food sources are available. Interbreeding of Suppression or " Unlikely. The new new species with extinction of species belongs to existing species native and valued a different lineage introduced fauna in the Archipini tribe to existing species in NZ. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Table 2 cont. New species Suppression or " Effects likely to be assisting the spread extinction of minimal of plant disease native and valued (e.g. rust fungi) introduced flora

New species Competes with " Effects likely to be becomes native and valued, minimal established as a introduced fauna new element of the fauna Life-supporting Sudden removal of Erosion following Common sense Any effects likely capacity of air, boneseed from increased bare assessment, and to be temporary water, soil and ecosystems ground consultation with and minor ecosystems weed ecologists, weed controllers, botanists, and entomologists in Crown Research Institutes, DOC, regional councils " Increased rate of " Any effects likely water runoff, to be temporary decline in water and minor quality

Replacement of Economic and " It is likely that boneseed with environmental benefits would be other weeds costs reduced rather than there being any particularly adverse effect New species Increased hosts " Likelihood of risk becomes for parasitoids, uncertain – established as a predators, and magnitude of new element of the diseases effect likely to be fauna adversely affects minor food web

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Table 2 cont. Intrinsic values of New species Dilution of native Common sense Effect likely to be ecosystems becomes common biodiversity by assessment, and minimal element of the introduced consultation with fauna species weed ecologists, weed controllers, botanists, and entomologists in Crown Research Institutes, DOC, regional councils New species feeds Increase in weed " Effect likely to be on nectar or pollen populations minimal compared through increased with that of other pollination pollinators

Benefits:

It is rare for a single biological control agent to be completely successful alone although one agent may have by far the greatest impact. The boneseed leafroller is one of at least eight potential biological control agents that singly or together could reduce the impact of boneseed on the New Zealand environment. We aim to import the minimum number of agents necessary to control boneseed and we have endeavoured to ascertain which agents are likely to be the most effective in New Zealand (refer to Section 3.4). If the boneseed leafroller is released in New Zealand its impact will be monitored thoroughly (refer to Section Four) before a decision is made whether or not to import additional agents for boneseed.

It is not possible to predict with certainty the population levels that might be achieved by the boneseed leafroller in New Zealand because we cannot predict the response of populations in New Zealand once freed from their South African predators, parasitoids, and diseases, and whether natural enemies already resident in New Zealand will adopt the boneseed leafroller into their host range. Similarly, how the boneseed leafroller will interact with other potential biological control agents that might be introduced is unpredictable because the same uncertainties apply to each agent.

The first measure of success of a biological control programme is whether the introduced agents have established or not. There is a strong correlation between agent establishment and investment in release and redistribution strategies. Prior to 1989, the establishment rate for 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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weed biocontrol agents released in New Zealand was 44%. However, the establishment rate of agents released since 1989 has risen to 94% (Syrett et al. 2000). This probably reflects the much greater effort – releasing agents more times and at more sites – than was previously the norm, due to the introduction of a nationwide technology transfer programme.

It is considered likely that the boneseed leafroller will establish in New Zealand, and contribute to a reduction in the vigour and spread of boneseed. Successful control would be achieved if competitiveness of boneseed were reduced sufficiently to allow other vegetation to coexist or to become dominant. This could lead to boneseed becoming a benign component of ecosystems, and lead to its eventual replacement by more-desirable plants.

Current control methods for boneseed include spraying with a woody-weed herbicide, manual removal, or cutting the trunk and painting the surface with herbicide. Reduced herbicide use would lead to reduced adverse impacts on non-target organisms (collateral damage) and reduced pollution of soil, air, and water. Because biocontrol agents usually take a considerable time to multiply and build populations large enough to have a severe impact on their host plant, this allows other plant species to gradually replace the weed. This contrasts with the use of herbicides, which may produce large areas of bare ground, thus creating an opportunity for other invasive species to move in, and increasing the risk of soil erosion.

The introduced biocontrol agent could act as an additional food source and therefore enhance the populations of rare parasitoids and predators that may attack them, although this effect is likely to be minimal (but very uncertain).

If the rust fungus Endophyllum osteospermi is introduced to New Zealand for the biological control of boneseed, it is possible that boneseed leafroller adults could help to distribute rust spores. The likelihood and scale of this distribution is unknown.

Table 3. Systematic identification and assessment of benefits to the environment and ecosystems associated with the introduction of the boneseed leafroller to New Zealand.

POTENTIAL BENEFIT EFFECT OF METHOD ASSESSMENT BENEFIT TO: BENEFIT USED TO OF BENEFIT IDENTIFY AND EFFECT BENEFIT Sustainability Replacement of Enhanced Common sense This benefit is likely of native and existing sustainability of assessment, to occur but the valued boneseed native and valued research, and magnitude of the introduced flora infestations by introduced flora and feedback on effect is very and fauna more-desirable fauna previous difficult to predict plants applications for other biocontrol agents

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Table 3 cont. Reduced Enhanced " This benefit is invasion of sustainability of likely to occur but boneseed into native and valued the magnitude of vulnerable introduced flora the effect is very habitats and fauna difficult to predict The new Populations of " Likely but the species rare parasitoids magnitude of the becomes a and predators impact is common may benefit from probably minimal element of the an additional food fauna source Assists the Enhanced " The likelihood of spread of the sustainability of this is benefit and boneseed rust native and valued the magnitude of fungus (if it is introduced flora the effect are released in NZ), and fauna both very difficult leading to more- to predict effective control of boneseed Life- Reduction in the Reduced impacts " Likely supporting use of on non-target capacity of herbicides organisms, and air, water, soil reduced pollution and of soil, air, and ecosystems water " Reduced erosion " Likely to occur of bare ground resulting from herbicide use " Reduced " Likely to occur opportunity for other invasive species to invade bare ground resulting from herbicide use

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Intrinsic Reduction in the Restoration of " Likely to occur values of populations, ecosystems to a ecosystems vigour, and more natural state spread of boneseed

7.2 Assessment of effects on human health and safety (including occupational exposure) Assess any potential risks, costs and benefits to human health that may be related to the release of the organism(s) in New Zealand. If effects in this area are likely to be significant a full health assessment as set out in the relevant ERMA New Zealand technical guide may be warranted.

Assess risks and costs, and benefits, separately.

Risks and costs:

Possible adverse effects on human health No significant effects on human health and safety are expected from the introduction of the boneseed leafroller to New Zealand. It does not attack, sting, bite, or have an offensive odour, and it has no known potential as a vector of human diseases. It is similar in form and behaviour to other tortricids in New Zealand.

The boneseed leafroller is expected to establish desirable self-sustaining populations in the New Zealand environment wherever boneseed is common, and if attack on boneseed is severe, adult moths may become common at some locations. However, it is unlikely to form swarms of nuisance value. It is possible that members of the public could accidentally ingest a moth and choke, but this is considered unlikely. Moth scales can cause allergic reactions and respiratory problems when people are exposed to large amounts of them in a confined space (e.g. in an insect-rearing facility). However, the increase in the number of moth scales in the New Zealand environment that would result from the establishment of the boneseed leafroller would present a minimal risk to human health.

Immature stages (eggs, larvae, pupae) would generally be found only on the host plant, boneseed. It is possible that eggs, larvae or pupae could be ingested by humans, either accidentally or deliberately. Formerly, Māori used leafroller caterpillars as food, but this food source is no longer considered important and it is unlikely that boneseed leafroller larvae will be deliberately collected as food.

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Table 4. Systematic identification and assessment of risks to human health and safety associated with the proposed introduction of the boneseed leafroller to New Zealand. POTENTIAL RISK EFFECT OF METHOD USED ASSESSMENT RISK TO: RISK TO IDENTIFY OF RISK AND RISK ITS EFFECT Human health New species is Members of the Common sense Very unlikely harmful to humans public receive assessment, and bites or stings, consultation with swallow moths weed ecologists, and choke, or are weed controllers, poisoned. botanists, and entomologists in Crown Research Institutes, DOC, regional councils " Members of the " Very unlikely public develop allergic reactions and respiratory problems from increased moth scales in the atmosphere New species carries Levels of disease " Very unlikely disease harmful to in humans humans increase

Benefits:

Reduction in herbicide use could be beneficial to human health (both to spray operators and the general public). Also, as many boneseed infestations are on very steep slopes, current control methods could lead to injury or death if a weed controller slipped and fell. Details of the types of herbicides used, their advantages and their disadvantages are outlined in Appendix 6.

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Table 5. Systematic identification and assessment of benefits to human health and safety associated with the introduction of the boneseed leafroller to New Zealand.

POTENTIAL BENEFIT EFFECT OF METHOD ASSESSMENT BENEFIT TO: BENEFIT USED TO OF BENEFIT IDENTIFY AND EFFECT BENEFIT Human health Reduction in Beneficial to spray Common sense Likely to occur herbicide use operators and the assessment, general public research, and feedback on previous applications for other biocontrol agents Reduction in the Reduced injuries " Likely to occur need to control and deaths of weed boneseed in very controllers who slip steep situations and fall

7.3 Assessment of effects 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 (taking into account the principles of the Treaty of Waitangi) Assess the adverse and beneficial effects 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 (taking into account the principles of the Treaty of Waitangi). If there are potentially non-negligible effects to consider in this area, it is expected that consultation will have occurred with Māori. Give details of this in the space provided (see the User Guide for what is required).

Assess risks and costs, and benefits, separately.

Consultation with Māori:

In assessing the potential issues of significance to Māori, information was obtained from ERMA New Zealand staff, from ERMA New Zealand policy documents, and from direct consultation with iwi throughout New Zealand. Details of the proposal to release the boneseed leafroller were forwarded to 64 runanga throughout New Zealand on 21 January 2004. Each runanga was invited to respond by indicating whether they:

o Have no issues with the proposal; or o Have no issues, but would like to receive updates on the progress of this project o May have issues to raise and would like further information 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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o May have issues and would like to meet with you to discuss the proposal further.

A response was sought by 15 February 2004 and a further reminder by phone or fax was issued to those who did not respond by that date.

A total of ten responses have been received. Five runanga have no issues but would like to be kept informed. Two runanga do not have the resources to comment on national issues. One runanga is opposed to biological releases and need reassurance that there is a plan in place if things go wrong. One runanga requested further contact and one runanga requested a meeting.

The runanga requesting further contact has not responded to their suggestion of email contact. The runanga requesting a meeting did not respond to several contacts about confirming arrangements to meet, although further information was provided.

Risks and costs:

Table 6 summarises potential issues of significance to Māori associated with the proposed introduction of the boneseed leafroller to New Zealand. No significant risks or costs have been identified.

Table 6. Potential issues of significance to Māori associated with the proposed introduction of the boneseed leafroller to New Zealand

Significant adverse Comment Key Outcomes effect? Yes No

Environment and Ecosystems

The continued and improved  The insect proposed for availability, quantity and quality of introduction feeds only on a traditional food resources weed (boneseed) that is of no (mahinga kai) food value to Māori. The continued availability,  This will be enhanced by the quantity and quality of traditional successful biological control of Māori natural resources boneseed. The retention of New Zealand‟s  This will be enhanced by the diverse range of indigenous flora successful biological control of and fauna boneseed. The protection of indigenous flora  This will be enhanced by the and fauna valued by Māori successful biological control of boneseed.

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Table 6 cont. The purity of water (inland and  The reduction in herbicide use coastal) and the need to retain resulting from this introduction and extend its productive and may improve purity of water. life-sustaining capacity. The purity of land and the need  The reduction in herbicide use to retain and extend its resulting from this introduction productive and life-sustaining may improve purity of the land. capacity The purity of air and the need to  The reduction in herbicide use retain and extend its productive resulting from this introduction and life-sustaining capacity may improve purity of the air The purity of human health and  This insect will not pose any well-being health risk to humans. It does not bite, sting, or cause disease. The reduction in herbicide use resulting from this introduction may improve human health. The restoration and retention of  Enhanced natural habitats from natural habitats the suppression of boneseed.

Culture The recognition of Māori cultural,  No foreseeable effect spiritual, ethical, or socio- economic values The protection of the mauri of  “ peoples The preservation and  “ maintenance of traditional Māori knowledge by Māori The maintenance, expression  “ and control by Māori of their traditional practices, e.g. kaitiakitanga, tapu, rahui The protection of the mauri  “ (spiritual integrity or life-force) of valued flora and fauna The protection of the mauri of  “ land The protection of the mauri of  “ waterways (inland and offshore) The protection of the mauri of air  “ and other taonga 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Table 6 cont.

Health and well-being

The protection of taha wairua:  “ spirituality balance with nature, protection of mauri The protection of taha  “ whanaunga: responsibility to the collective, the capacity to belong, to care and to share The protection of taha hinengaro:  “ mental health and well-being, the capacity to communicate, to think and to feel The protection of taha tinana:  “ physical growth and development

Treaty of Waitangi

The relevance of unresolved  “ Treaty claims to the Waitangi Tribunal The continued ability of Māori to  “ exert their developmental right as implied by the Treaty where these are recognised by the Waitangi Tribunal

Benefits:

The successful establishment of the boneseed leafroller in New Zealand should benefit flora and fauna of importance to Māori by suppressing boneseed.

7.4 Assessment of economic and related effects Assess the potential magnitude and distribution of the economic and related risks, costs and benefits. Effects on third parties and to New Zealand of the proposed release need to be specifically evaluated. If economic effects are significant applicants should provide a cost benefit analysis. Guidance on the requirements for cost benefit analyses are set out in the relevant ERMA New Zealand Technical Guide.

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In this case it is still helpful to assess risks and costs, and benefits, separately but if possible these assessments should be drawn together into an overall cost benefit analysis. As a part of this, estimate net benefits.

Risks and Costs:

Possible adverse effects on the economy

It is very unlikely that there will be any adverse economic effects resulting from the introduction of the boneseed leafroller to New Zealand. The risk of non-target attack on commercially valuable plants is very low (see Section 7.1). The risk of this species significantly reducing the availability of nectar or pollen for bees from commercial hives, either through direct consumption by the moths or by a reduction of boneseed flowers, is very unlikely. The moths will not add significantly to the biomass of the fauna (birds, bees, flies, wasps, moths, butterflies, bumblebees, etc.) that already utilise flower resources, and it is likely that other flowering plants will largely replace boneseed infestations should biological control of boneseed be successful. Any effects of the boneseed leafroller will be localised (only where boneseed occurs).

Table 7. Systematic identification and assessment of risks to the New Zealand economy associated with the proposed introduction of the boneseed leafroller to New Zealand.

POTENTIAL RISK EFFECT OF METHOD USED ASSESSMENT RISK TO: RISK TO IDENTIFY OF RISK AND RISK ITS EFFECT Capacity of New species Economic Common sense Very unlikely people to provide attacks non-target damage to non- assessment, for economic plants target agricultural, research, and well-being forestry, or feedback on horticultural crops, previous and garden plants applications for other biocontrol agents New species feeds Loss to " The magnitude of on nectar or pollen beekeepers from the effect is likely competition with to be minimal bees

Costs:

The costs of implementing a biological control programme for boneseed in New Zealand are much reduced because much of the initial research and development has already been done for Australia. The estimated costs of introducing the boneseed leafroller to New Zealand, and 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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subsequent monitoring, are likely to be approximately $400,000 over 5 to 10 years. These costs will accrue to the applicant and other organisations that assist with funding this project, and government funding sources such as FORST (Foundation for Research Science and Technology).

Benefits:

Objective documentation and analysis of ecological and economic factors in biological control of weeds is crucial. Worldwide, there are numerous examples on the economic impacts of weeds, but very few studies on the economic benefits due to biological control. There is often a considerable time lag in gaining the necessary information as weed biocontrol programmes can take several decades to complete, and on completion of a programme there is often little incentive to spend more money to gain quality economic data on its efficacy (Syrett et al. 2000). Biological control of ragwort (Senecio jacobaeae) in Oregon, USA, is an example of a successful long-term project that has yielded ecological and economic benefits. The estimated annual benefit of the ragwort project in Oregon is more than US$5 million. The cumulative cost–benefit evaluation for the programme from 1974 to 1992 was estimated at US$1.5 million in programme costs and US$23.2 million in benefits, a 1:15 cost–benefit ratio. Non-market benefits include returns of desirable flora in habitats once dominated by ragwort, and a reduction in herbicide use in the environment (Coombs et al. 1996).

It is difficult to estimate the current “cost” to New Zealand of controlling boneseed by current methods. Attempts to control boneseed are currently being made by a diverse range of organisations (e.g. regional councils, DOC), volunteer groups, and private individuals. An advantage of biological control is that it is self-sustaining: once agents are established on a weed, their impact continues indefinitely, incurring no ongoing costs.

Table 8. Systematic identification and assessment of benefits to the New Zealand economy associated with the introduction of the boneseed leafroller to New Zealand.

POTENTIAL BENEFIT EFFECT OF METHOD ASSESSMENT BENEFIT TO: BENEFIT USED TO OF BENEFIT IDENTIFY AND EFFECT BENEFIT To provide Reduction in the Reduced cost of Common sense Likely to occur economic, well- populations, current control assessment, being vigour, and methods research, and spread of feedback on boneseed previous applications for other biocontrol agents

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Benefit/Cost Analysis

A case study based on the boneseed control programme in Canterbury is used to illustrate that the benefits to the environment outweigh the costs (Appendix 3). Boneseed is the subject of a Regional Pest Management Strategy (RPMS) in Canterbury. Under the RPMS, Environment Canterbury (ECan) aims to contain boneseed within its current core area on Banks Peninsula, and eventually reduce its density. ECan‟s proposed expenditure on this will range between $50,000 and $85,000 per annum over the next ten years. The outcomes from this expenditure will be no further spread of the weed, and a reduction in area affected by 20%.

An analysis of this programme involved comparing the proposed course of action against the likely future if the proposed action were not to take place. Comparing these two scenarios gives an indication of the net benefit associated with the leafroller introduction. Two scenarios are assessed for this analysis:

The “With” scenario where the biocontrol agent is introduced and the conventional control expenditure is continued. This is termed the “Biocontrol with Conventional Scenario”. The “Without” scenario where only conventional control is undertaken. This is termed the “Conventional” scenario.

Potential impacts arise primarily in respect of conservation values. The conservation values are measured by shadow pricing the benefits gained. Shadow pricing is a way of pricing the benefits through the equivalent cost of their achievement. In this case we know the expenditure being undertaken by ECan for a given outcome – the outcome being measured by a reduction in boneseed. We can say therefore that the value to ECan of reduced infestations of boneseed are worth more to them than the cost. This gives us a “shadow price” for the conservation gains from reduced boneseed infestation. This benefit is then compared against the cost of achieving a reduction in boneseed infestations that is equivalent to that achieved in each of the scenarios.

It is assumed that this value for conservation gain is equal to the average benefit from a reduction in boneseed. This is probably reasonable given the stage of control, but as boneseed becomes less extensive the marginal benefit from its removal may potentially change and the results here may overstate the conservation value.

The likely impact of biological control is also assessed at three levels. The base level is an 80 percent impact, 50 percent represents a low impact and 90 percent represents a high impact. The results (expressed in net present value) are as follows:

Comparison of Scenarios (Base Case) Scenario Benefit Cost Net Biocontrol with Conventional $1,020,000 $890,000 $130,000 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Conventional only $400,000 $640,000 -$240,000 Comparison Biocontrol vs. Conventional $620,000 $250,000 $370,000 Comparison of Scenarios (Low Impact) Scenario Benefit Cost Net Biocontrol with Conventional $770,000 $890,000 -$120,000 Conventional only $400,000 $640,000 -$240,000 Comparison Biocontrol vs. Conventional $370,000 $250,000 $120,000 Comparison of Scenarios (High Impact) Scenario Benefit Cost Net Biocontrol with Conventional $1,110,000 $890,000 $220,000 Conventional only $400,000 $640,000 -$240,000 Comparison Biocontrol vs. Conventional $710,000 $250,000 $460,000

The biocontrol introduction shows a benefit over the alternative of $370,000 (range $120,000 to $460,000), after costs have been taken into account. The results have been presented only for the Canterbury region. Boneseed is present in many other parts of the country, and it is likely that the leafroller agent will be effective in its control elsewhere, with little additional cost. The actual net benefit from its introduction would be expected to be considerably higher than has been demonstrated here.

Overall cost benefit analysis:

(a) Protection of indigenous ecosystems is enhanced. (b) Human health and safety is improved by the reduction in herbicide use. (c) The biological control introduction shows a benefit over the alternative of $370,000 (range $120,000 to $460,000), after costs have been taken into account.

7.5 Assessment of cultural, social, ethical and spiritual effects Assess the magnitude and distribution of any adverse and beneficial impacts on people and communities that adversely affect or maintain/enhance (in the case of beneficial impacts) their capacity to provide for their own social and cultural wellbeing both now and into the future. Also assess any ethical or spiritual risks, costs and benefits that might arise. If social effects in particular (although it may apply to other effects also) are likely to be significant, a full impact assessment may need to be carried out. Refer to the relevant ERMA New Zealand Technical Guides for assistance. If community consultation has been carried out to assist the assessment, provide information on how this was done and the results.

Assess risks and costs, and benefits, separately.

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It is very likely that there will be no adverse cultural, social, ethical, and spiritual effects resulting from the introduction of the boneseed leafroller to New Zealand.

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Table 9. Systematic identification and assessment of cultural, social, ethical, and spiritual risks associated with the proposed introduction of the boneseed leafroller to New Zealand.

POTENTIAL RISK EFFECT OF METHOD USED ASSESSMENT RISK TO: RISK TO IDENTIFY OF RISK AND RISK ITS EFFECT Capacity of New species Damage to non- Common sense Very unlikely people to provide attacks non-target target garden assessment, social, and plants plants research, and cultural well- feedback on being and previous foreseeable applications for needs of future other biocontrol generations agents.

Benefits:

There are potential benefits from increased conservation values placed by individuals and communities on ecosystems were boneseed has been replaced by other species, and in particular native species.

Table 10. Systematic identification and assessment of cultural, social, ethical, and spiritual benefits associated with the introduction of the boneseed leafroller to New Zealand.

POTENTIAL BENEFIT EFFECT OF METHOD ASSESSMENT BENEFIT TO: BENEFIT USED TO OF BENEFIT IDENTIFY AND EFFECT BENEFIT Capacity of Reduction in the Increased Common sense Likely to occur people to populations, conservation values assessment, provide social vigour, and placed by research, and and cultural spread of individuals and feedback on well-being and boneseed communities on previous foreseeable ecosystems where applications for needs of future boneseed has been other biocontrol generations replaced by other agents. species

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7.6 Assessment of other effects (including New Zealand’s international obligations) Assess any remaining adverse and beneficial effects not already covered including any effects on New Zealand‟s international obligations. Specify any relevant international agreements.

Assess risks and costs, and benefits, separately.

No other matters are known to apply.

7.7 Overall evaluation of risks, costs and benefits

It is the role of the Authority to decide whether the positive effects (benefits) of the release outweigh the adverse effects (risks and costs). However, if you have a view on the relative importance of the different risks, costs and benefits and how they should be brought together in the overall evaluation of your application then please state that here.

Potential adverse effects (risks) associated with the introduction of the boneseed leafroller to New Zealand have been systematically identified and assessed. Risks to the environment and ecosystems, human health and safety, Māori, the economy of New Zealand, and society and communities in general have been addressed. The most important risk identified was the potential for damage to non-target plants. However, the evidence presented in this application indicates that this risk is negligible.

The costs of implementing a biological control programme for boneseed in New Zealand are reduced because much of the initial research and development has already been done for Australia. The estimated costs of introducing the boneseed leafroller to New Zealand, and subsequent monitoring, are likely to be approximately $400,000 over 5 to 10 years. These costs will accrue to the applicant and other organisations that assist with funding this project, and government funding sources such as FORST (Foundation for Research Science and Technology).

Potential benefits associated with the introduction of the boneseed leafroller to New Zealand have also been systematically identified and assessed. The main benefit is expected to be to the natural environment and will arise from reducing the adverse effects of boneseed.

We are of the opinion that the potential positive effects (benefits) of the release of the boneseed leafroller in New Zealand far outweigh any potential adverse effects (risks and costs).

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Section Eight – Satisfaction of the Section 36 Minimum Standards Satisfaction of the minimum standards in section 36 of the Act is a requirement for approval and will always be considered prior to the overall assessment and weighing of risks to, costs and benefits. Provide a statement in each subsection below on satisfaction of the minimum standards. Cross reference as appropriate (i.e. no need to repeat) to the detailed identification and assessments of risks set out in sections 6 and 7 above. While this may be repetitive of Sections 6 and 7 it still needs to be done. Note the comment above about cross- referencing.

8.1 Displacement of native species State (with reasons) whether the new organism is likely to cause any significant displacement of any native species within its natural habitat.

Boneseed is not known to provide valuable habitat for native species in New Zealand. A gradual decline in boneseed populations due to biological control, and consequent recolonisation by other plants means native fauna currently associated with boneseed would be very unlikely to be disadvantaged. Competition with, or displacement of, existing natural enemies of boneseed in New Zealand is unlikely to cause any significant adverse effect. The invertebrate fauna associated with boneseed in New Zealand was surveyed in 1999–2000 (Winks & Fowler 2000). The survey showed that boneseed is utilised by a wide range of native and exotic invertebrates in New Zealand but damage is usually not severe. Most of the damage observed on boneseed could be attributed to non-native invertebrates generally regarded as “pest” species (e.g. the garden weevil, Phlyctinus callosus (native to South Africa), and Fuller's rose weevil, Asynonychus cervinus (native to South America).

8.2 Deterioration of natural habitats State (with reasons) whether the new organism is likely to cause any significant deterioration of natural habitats.

The rapid and uniform destruction of boneseed infestations over a short period could lead to an increase in erosion on some erosion-prone slopes currently infested by boneseed. There is also the possibility of an increased rate of water runoff, and decline in water quality. However, boneseed is a woody perennial, and it is unlikely that successful biological control would lead to rapid, wholesale death of mature plants (within a single season for example) over a wide area. It is more likely that heavy foliage damage would lead to reduced growth, shoot dieback, and the death of a small proportion of mature plants annually, leading to a slow decline in plant density. Even if an agent killed an entire plant it would not immediately remove it, and the dead material would continue to hold the soil surface for a period. On most erosion-prone slopes, reduction in the density of boneseed as a result of biological control will result in complementary invasion by other plant species.

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8.3 Adverse effects on human health and safety State (with reasons) whether the new organism is likely to cause any significant adverse effects on human health and safety.

No significant effects on human health and safety are expected from the introduction of the boneseed leafroller to New Zealand. It does not attack, sting, bite, or have an offensive odour, and it has no known potential as a vector of human diseases. It is similar in form and behaviour to other tortricids in New Zealand.

8.4 Adverse effect to New Zealand’s inherent genetic diversity State (with reasons) whether the new organism is likely to cause any significant adverse effect to New Zealand‟s inherent genetic diversity.

Interbreeding or hybridisation of the boneseed leafroller with species already present in New Zealand is considered to be highly unlikely. John Clearwater, a former HortResearch scientist, was able to get attempted cross-mating between the closely related endemic taxa Ctenopseustis and Planotortrix, but small structural differences stopped insertion of the spermatophore. These two taxa are considerably more closely related than the boneseed leafroller is to other leafroller species in New Zealand (John Dugdale, Landcare Research, pers. comm. [c]).

8.5 Causing disease, being parasitic, or becoming a vector for disease State (with reasons) whether the new organism is likely to cause disease, be parasitic, or become a vector for human, animal, or plant disease. If, however, the purpose of the importation or release is to import or release an organism to cause disease, be a parasite, or a vector for disease all you need to do is state that.

The boneseed leafroller is not parasitic. It is possible that the boneseed leafroller could assist the spread of some plant diseases (e.g. rust fungi) by transporting spores. However, it is likely that any effects of this would be minimal, as the boneseed leafroller would make up only a small proportion of the total fauna of a particular area.

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Section Nine – Additional Information

9.1 Do any of the organism(s) need approvals under any other New Zealand legislation or are affected by international obligations? For example, indicate whether the organism may be subject to other New Zealand legislation, e.g. the Biosecurity Act 1993, or Animal Welfare Act 1999; or if the organism(s) are listed in CITES, then approval is required from both the importing and exporting countries.

No.

9.2 Have any of the new organism(s) in this application previously been considered in New Zealand or elsewhere? For example, has the organism(s) been previously considered for import (e.g. under the Plants Act)?

The boneseed leafroller has been released in Australia as a biological control agent for boneseed (refer to Section 3.4).

9.3 Is there any additional information that you consider relevant to this application that has not already been included?

In accordance with the Biosecurity Act 1993, boneseed is subject to plant pest management strategies in various parts of New Zealand. It is listed as an unwanted organism and is thus banned from sale, propagation, and distribution throughout New Zealand.

Invertebrates imported into quarantine containment are bound by the Biosecurity Act 1993 under which disease and parasitoid screening is undertaken in order to gain a MAF Import Health Permit.

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9.4 Provide a glossary of scientific and technical terms used in the application

Assessment measuring impacts of biocontrol agents Abdomen hindmost part of an insect‟s body Biological control the use of one living organism to control another Co-evolution where two organisms have evolved together and have each affected the evolution of the other Costa the leading edge of the wing Dorsal relating to the upper surface Endemic naturally occurring in a country and nowhere else Epizootic parasitic on animals (including insects) from the outside or on the surface Food web the feeding relationship between various species living together in one area Host range the range of plants that a biocontrol agent can feed and reproduce on Host specificity testing testing to find out the host range of a potential biocontrol agent Indigenous native to a country but may also be found naturally elsewhere Instar growth stage of an insect (in between moults), e.g. newly hatched = first instar Lag phase the period before a species becomes invasive in a new environment Larva(e) juvenile stage of an insect(s) Lateral relating to the side Multivoltine having more than one generation per year Oviposit lay eggs Parasitoid an animal (insect) that feeds and develops on or within another living host insect. It completes its own development on a single host, which it kills in the process Phytophagous plant feeding Pupa(e) stage of insect development between larva and adult Reticulate covered with a network of lines

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Seta(e) bristle, or “hair” Specificity a measure of the host range of a biocontrol agent on a scale ranging from an extreme specialist only able to complete development on a single species or strain of its host (monophagous) to a generalist with many hosts ranging over several groups of organisms (polyphagous). Spermatophore A packet of sperm produced by insects Vector an organism that can carry disease Ventral relating to the lower surface

9.5 List of appendices. List any appendices included with this application. Any information that is commercially sensitive or additional material included with the application (such as details of consultations, referenced articles) should be contained in appendices. The main application should refer to the relevant appendices but be able to be read as a stand-alone document.

Appendix 1: Testing the host specificity of the Chrysanthemoides Leafroller (“Tortrix” sp.) for New Zealand.

Appendix 2: Plant species used for testing the host specificity of the boneseed leafroller (Tortrix s.l. sp. "chrysanthemoides") for Australia.

Appendix 3: Cost Benefit Analysis.

Appendix 4: Invasiveness of boneseed (Department of Conservation)

Appendix 5: Iwi consultation

Appendix 6: Herbicide Control

Appendix 7: Pers. Comm. details

9.6 References. Please include a list of the references cited in and supplied with this application form. Originals of the references must be supplied in full. Where the reference supplied is an extract from a book only the specific pages quoted must be supplied.

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References

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Braithewaite, R.W., Lonsdale, W.M., Estbergs, J.A. 1989. Alien vegetation and native biota in tropical Australia: the impact of Mimosa pigra. Biological Conservation 48, 189-210.

Briese, D. 1999: Open field host-specificity tests: is “natural” good enough for risk assessment? In: Withers, T.M.; Brown, B.; Stanley J. ed. Host specificity testing in Australasia: towards improved assays for biological controls. CRC for Tropical Pest Management, University of Queensland. Brisbane, Australia.

Clement, S.L.; Cristofaro, M. 1995: Open-field tests in host-specificity deternination of insects for biological control of weeds. Biocontrol Science and Technology 5: 395–406.

Coombs, E.M.; Radtke, H.; Isaacson, D.L.; Snyder, S.P. 1996: Economic and regional benefits from the biological control of tansy ragwort, Senecio jacobaeae, in Oregon, In: Moran, V.C.; Hoffmann, J.H. ed. Proceedings of the IX International Symposium on Biological Control of Weeds, 19–26 January 1996, Stellenbosch, South Africa, University of Cape Town. Pp. 489– 494.

Crowe, A. 2002: Which New Zealand insect. Penguin Books, Auckland, New Zealand. 127 p.

Cullen, J.M. 1990: Current problems in host-specificity screening. In: Delfosse, E.S. ed. Proceedings of the VII International Symposium on Biological Control of Weeds, 6–11 March 1988, Rome, Italy. Ist. Sper. Patol. Veg. (MAF), Pp. 27–36.

Edwards, P.B. 1993: Research in South Africa on biological control agents for Chrysanthemoides monilifera. Proceedings of a National Workshop on Chrysanthemoides monilifera. Port Macquarie, Australia. Pp. 16–19.

Edwards, P.B.; Adair, R.J. 1999: Application for the release from quarantine of “Tortrix” sp., a potential biological control agent for Chrysanthemoides monilifera. Unpublished report: Keith Turnbull Research Institute, Victoria, Australia; and CSIRO, Canberra, Australia. 40 p.

Ekert, P.A., Bucher, D.J. 1999. Winter use of large-leafed privet Ligustrum lucidum (Family: Oleaceae) by birds in suburban Lismore, New South Wales. Proceedings of the Linnean Society of New South Wales 121, 29-38.

Emberson, R.M. 1999: Endemic biodiversity, natural enemies, and the future of biological control. In: Proceedings of X International Symposium on Biological Control of Weeds, 4–14 July 1999, Bozeman, Montana, USA. Pp. 875–880. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Forno, W.; Heard, T. 1997: Compiling a plant list for testing the host range of insects. In: Biological control of weeds: theory and practical application. Australian Centre for International Agricultural Research Monograph Series No. 49. Canberra, Australia. Pp. 71–75.

Fowler, S.V.; Memmott, J.; Paynter, A.W.; Sheppard, A.W.; Syrett, P. 2001: The scope and value of extensive ecological studies in the broom biological control program. In: Wajnberg, E.; Scott, J.K.; Quimby, P.C. ed. Evaluating indirect ecological effects of biological control. CABI Publishing, Wallingford, UK. Pp. 229–248.

Gourlay, H. 2001: Quarantine and containment manual. Landcare Research, Lincoln, New Zealand. 40 p.

Gullan, P.J. 1997: Relationship with ants. In: Ben-Dov, Y. ; Hodgson, C.J. ed. Soft scale insects – their biology, natural enemies and control. World Crop Pests Series, Elsevier Press, Amsterdam. Pp. 351–373.

Griffin, G.F., Stafford Smith, D.M., Morton, S.R., Allan, G.E., Masters, K.A.1989. Status and implications of the invasion of tamarisk (Tamarix aphylla) on the Finke River, Northern Territory, Australia. Journal of Environmental Management 29, 297-315.

Groves, R.H. 1991: Status of environmental weed control in Australia. Plant Protection Quarterly 6: 95–98.

Harris, R.J. 2001: Potential impact of the Argentine ant (Linepithema humile) in New Zealand and options for its control. Unpublished report, Landcare Research, Nelson, New Zealand. 31 p.

Heard, T. 1997: Host range testing of insects. In: Biological control of weeds: theory and practical application. Australian Centre for International Agricultural Research Monograph Series No. 49. Canberra, Australia. Pp.77–82.

Ireson, J.E.; Davies, J.T.; Chatterton, W.S.; Holloway, R.J. 2002: Attempts to establish biological control agents for boneseed in Tasmania. Proceedings of the Thirteenth Australian Weeds Conference. Perth, Australia. Pp. 407–411.

Julien M.H.; Griffiths, M. 1998: Biological control of weeds – a world catalogue of agents and their target weeds. 4th edition, CABI Publishing, Wallingford, UK. 223 p.

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McEvoy, P.; Coombs, E.M. 1999: Why things bite back: unintended consequences of biological weed control. In: Follett, P.A.; Duan, J.J. ed. Non-target effects of biological control. Kluwer Academic Publishers, Boston, Massachusetts, USA. Pp. 167–194. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 59 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Section Ten – Application Summary Summarise the application in clear, simple language that can be understood by the general public. Include a description of the organism(s) to be released, and any risks, costs and benefits associated with their release. Any consultation that was undertaken should be noted. This summary will be used to provide information for those people and agencies who will be notified of the application (e.g. Ministry of Agriculture and Forestry, Department of Conservation, Ministry for the Environment etc) and for members of the public who request information. Do not include any commercially sensitive information in this summary – this should be attached as a separate appendix and clearly marked “confidential”.

Boneseed is a bushy shrub that grows 2-3 metres high. It has thick, leathery leaves with slightly toothed edges, and masses of bright yellow daisy-like flowers in the spring, followed by clusters of fruit that turn black when ripe. The single seed inside is very hard and the colour of bone, hence the name. Tens of thousands of these seeds can be produced during the lifetime of a boneseed bush. Boneseed is a very hardy shrub and can grow in a variety of soils. It is frost-resistant, and tolerant of semi-shade, drought and salty environments.

In New Zealand, boneseed has the potential to cause substantial environmental damage. It invades plant communities on coastal cliffs and dune-lands, and inland grassland and shrub areas. Dense thickets of boneseed can form which displace native vegetation and shade out native seedlings. The long-term impact of boneseed on native biodiversity may be much more serious than that of a weed such as gorse. Native plant species can eventually regenerate through the relatively open canopy of mature gorse, but a pure stand of boneseed is closed and dark with little seedling recruitment evident.

Although boneseed was first recorded as naturalised in New Zealand in 1870 (Webb et al. 1988) it is only in recent years that it has been recognised as a serious problem weed. To help control this increasingly serious weed, we would like to import from South Africa the boneseed leafroller, a moth that helps to naturally control boneseed in its native habitat in South Africa. Boneseed leafroller caterpillars web leaves together to form a shelter, and feed on leaf material from within this shelter. Biological control is an appropriate control strategy for New Zealand because in many places boneseed is invading natural areas where herbicide use is likely to damage native plants. The scale of the problem, and the fact that many boneseed infestations are in areas that are difficult to work in (e.g. very steep slopes) means that manual control is often not feasible. Biological control aims to limit the growth and reproduction of boneseed so it becomes less competitive and is no longer a risk to our environment.

The scientific name of boneseed is Chrysanthemoides monilifera subspecies monilifera. The genus Chrysanthemoides comprises only two species, Chrysanthemoides incana (which is not present in New Zealand) and Chrysanthemoides monilifera (refer to Section 2.3). In South Africa the boneseed leafroller is known to feed on only these two species. Boneseed is the subject of an active biological control programme in Australia and extensive quantitative searches carried out by the Australian CSIRO Biological Control Unit based at the University of Cape Town, South 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 60 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Africa, failed to find the boneseed leafroller attacking any other plant species in South Africa. Searches were undertaken over a two-year period on 126 plant species growing near plants infested with the boneseed leafroller. No other plant species was found to sustain boneseed leafroller attack, even in situations where outbreak densities were high enough to severely defoliate or kill the nearby hosts. Extensive host range testing has also been conducted on the boneseed leafroller for the Australian biological control programme and the conclusion drawn was that the boneseed leafroller will feed on only the two Chrysanthemoides species. The boneseed leafroller was released in Australia in April 2000.

The host specificity of the boneseed leafroller was further tested during 2001 on plants of relevance to New Zealand (a selection of native New Zealand species and some ornamental introduced species) to determine its suitability as a biological control agent for boneseed in New Zealand. Landcare Research carried out this work in South Africa, in conjunction with the Australian CSIRO Biological Control Unit based at the University of Cape Town, South Africa. The results of this testing added to the evidence already available from field observations in South Africa, and host specificity testing conducted for Australia, that the boneseed leafroller is not expected to feed on any plant species in New Zealand other than boneseed.

Potential adverse effects (risks) associated with the introduction of the boneseed leafroller to New Zealand have been systematically identified and assessed, and are presented in detail in this application. Iwi (including 64 runanga throughout New Zealand) have been consulted on this proposal and the Department of Conservation have been informed. Risks to the environment and ecosystems, human health and safety, Māori, the economy of New Zealand, and society and communities in general have been addressed. The most important risk identified was the potential for damage to non-target plants. However, the evidence presented in this application indicates that this risk is negligible. Potential benefits associated with the introduction of the boneseed leafroller to New Zealand have also been systematically identified and assessed, and are presented in detail in this application. The main benefit is expected to be to the natural environment and will arise from reducing the adverse effects of boneseed.

Boneseed can be controlled by herbicides or by stock grazing when the plants are small. However, infestations occur in locations where herbicide application or grazing is neither feasible nor desirable. Introducing the leafroller will cater for control in those situations and it will reduce the need for herbicide in other situations as well. An economic evaluation of the introduction shows a benefit over the conventional use of herbicides of $370,000 (range $120,000 to $460,000), after costs have been taken into account (figures expressed as net present value).

We are of the opinion that the potential positive effects of the release of the boneseed leafroller in New Zealand far outweigh any potential adverse effects.

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 61 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

Checklist

Please check and complete the following before submitting your application:

All sections completed Yes Appendices enclosed Yes Confidential information identified and enclosed separately NA Copies of additional references attached Yes Cheque for initial fee enclosed (incl. GST) Yes If “yes”, state amount: $33,750 Direct credit made to ERMA bank account: ………. If „yes” give date of DC …/…/… and amount: Application signed and dated Yes Electronic copy of application e-mailed to ERMA New Yes Zealand

*NA – not applicable

The cost of the application (our fee) can be found on our web site under new organism applications.

Signed: J D Talbot Date:

Director Policy and Planning

20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz