FORM NOR Application for Approval to IMPORT for RELEASE OR

ER-AF-NOR-1-2 09/05

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 Cotesia urabae for biological control of the pest gum leaf skeletoniser.

Applicant Organisation: Scion (Forest Research Institute Ltd) ERMA Office use only

Application Code: Formally received:____/____/____

ERMA NZ Contact: Initial Fee Paid: $

Application Status:

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

IMPORTANT

1. An associated User Guide is available for this form. You should read the User Guide before completing the form. If you need further 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 HSNO Act 1996.

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 NO1R. If you are making an application to field test a genetically modified organism use Form NO-04.

3. The form replaces all previous versions of Form NOR. Old versions should not now be used. You should always check with ERMA New Zealand or on the ERMA New Zealand website for the most up-to-date versions of this form.

4. 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.

5. This application form may be used to seek approvals for importing or releasing more than one new organism where the organisms are of a similar nature. 6. 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.

7. 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.

8. 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.

9. Unless otherwise indicated, all sections of this form must be completed for the application to be progressed.

10. Please provide an electronic version of the completed application form, as well as sending a signed hard copy. Until a signed hard copy of the application is received, ERMA New Zealand will not be able to process your application.

11. 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. This application form was approved by the Chief Executive of ERMA New Zealand on 20 September 2005. ERMA New Zealand 20 Customhouse Quay, PO Box 131 Wellington, NEW ZEALAND Telephone: 64-4-916 2426 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 Scion Postal Address Private bag 3020, Rotorua, New Zealand Physical Address Sala Street, Rotorua, New Zealand Phone 07 343 5899 Fax 07 343 5333 E-mail [email protected]

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 Lisa Berndt Position Scientist Address Private bag 3020, Rotorua, New Zealand Phone 07 343 5775 Fax 07 343 5333 E-mail [email protected] Alternative contact: Name Richard Hill Position Consultant to Scion and author of the application

Address Private bag 4704, Christchurch New Zealand Phone 03 325 6400 Fax 03 325 0274 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.

Not applicable. The applicant is not situated overseas.

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.

To import and release the parasitoid Cotesia urabae (Hymenoptera: Braconidae) as a biological control agent for gum leaf skeletoniser, Uraba lugens (Lepidoptera: Noctuidae).

2.2 Provide a short 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 research can understand the reasons for the release.

The gum leaf skeletoniser, or GLS (Uraba lugens) is an Australian moth that became established in New Zealand around 2001. It feeds on eucalypt trees and several ornamental species. Periodic outbreaks of GLS in Australia cause moderate damage to eucalypts in both native and plantation forests, even though its numbers are restricted by parasitoids and predators. Without those natural enemies GLS is expected to be more abundant and outbreak more often in New Zealand than it does in its native range. Currently in Auckland, Waikato and Bay of Plenty, climate studies suggest that it will spread as far as Southland.

There are almost 25,000 ha of eucalypt plantations in New Zealand, mostly used for wood pulp, but also for production of hardwood timber, small-scale agroforestry, erosion control, firewood production, and in the future for novel fuel production systems, and for carbon sequestration. GLS is expected to defoliate trees, kill saplings, and reducing growth rates. Extending the time needed for eucalypts to reach maturity would badly affect the economics of this industry. As well as for forestry, eucalypt trees and other species susceptible to GLS are planted widely as amenity trees in urban areas

for shade and shelter, and as street plantings. Many affected trees in Auckland City are already being treated to protect amenity values, but there have been no reports of damage in plantation forests so far.

Caterpillars of GLS have hairs or bristles containing venom that causes a painful sting and an itchy welt that can last for days. Even cast skins can be dangerous. GLS outbreaks will therefore pose a real risk to human health, especially to small children in backyards, schools and parks where eucalypts are commonly grown.

As part of a MAF Sustainable Farming Fund project, the Gum Leaf Skeletoniser Stakeholder Group (represented by Scion, formerly the New Zealand Forest Research Institute Ltd.) wishes to introduce Cotesia urabae from Australia, a parasitoid that attacks and kills GLS larvae. Successful biological control would reduce GLS caterpillar numbers, reduce the number of encounters between humans and caterpillars, and so reduce the incidence of allergic responses. Successful biological control of GLS would have economic benefits by reducing the substantial costs associated with: Extension of rotation time caused by periodic defoliation of eucalypt plantations Maintaining the utility of eucalypts for wood and pulp production Maintaining the utility of eucalypts for novel biofuel production and carbon sequestration Reducing the costs of protecting or replacing amenity trees The key potential adverse effects identified are: Direct damage to the fauna by attack on non-target insects, and Indirect effects on ecosystems by altering ecological relationships.

This application argues that there are significant economic gains to be made from biological control of GLS, while the risks and costs associated with the introduction of Cotesia urabae are low. C. urabae has only been recorded from GLS in Australia. In laboratory tests to assess risk to non-target species, adult C. urabae attacked and laid eggs in several non-target species, but did not complete development on any of them. The application concludes that C. urabae is unlikely to develop significant populations on any host other than GLS.

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 you about obtaining agreement to switch from full (unconditional) to conditional release.

Application is sought for full (unconditional) release of Cotesia urabae. There are no known significant risks to introducing Cotesia urabae and therefore no conditions are required.

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.

Cotesia urabae is a recognised species (Austin and Allen, 1989) and no sub-specific entities are known.

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: Hymenoptera Suborder: Apocrita Superfamily: Ichneumonoidea Family: Braconidae Subfamily: Microgastrinae Genus: Cotesia Species: urabae Austin & Allen 1989 (Trans. Roy. Soc. South Australia 113, 169-184) Common name(s), if any:

No common name has been applied to this species

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

C. urabae is an hymenopteran parasitoid of moth larvae

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

Not relevant.

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

The biological control programme against gum leaf skeletoniser is novel. C. urabae is not known to occur outside its native range in Australia.

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.

Cotesia urabae

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(s) is pathogenic or a potential pest or weed. This information should be relevant to the identification of the risks of the organism(s) (section 6 of this form).

3.4.1 Biology and ecology of the pest

This is a summary of the biology and ecology of GLS and its parasitoid in Australia and New Zealand. Additional detail can be found in Appendix 2 and In Berndt & Allen (in press).

3.4.1.1 Population dynamics and pest status of GLS in Australia Taxonomy In a recent revision of relationships within the super-family Noctuoidea, Lafontaine and Fibiger (2006) placed GLS (Uraba lugens) in the subfamily Nolinae within the family Noctuidae. The arctiids and lymantriids were also transferred to the Noctuidae as subfamilies (Arctiinae and Lymantriinae). However other reviews of this group continue to treat Nolinae as a family (Nolidae). While there is ongoing disagreement in the taxonomic community as to whether these groups are families or subfamilies, the relationships of species within and between the groups remain the same. Here we follow Lafontaine and Fibiger (2006) as their phylogeny provides the clearest understanding of these relationships. There is only one other Uraba species known in Australia.

Distribution and phenology GLS is able to tolerate a wide range of climatic conditions, from warm and dry areas of mainland Australia, to cool and wet subalpine areas in Tasmania (Kriticos et al., 2007). It has been found in all states and territories of Australia except the Northern Territory (Berndt & Allen, in press). GLS can have either one or two generations per year (univoltine or bivoltine). This seems to be determined to a large extent by climate (Farr, 2002; Berndt & Allen, in press). Campbell (1962) identified two biological forms. Tasmanian populations of GLS have characteristics of the ‘highland’ form with

clumped eggs and a univoltine phenology (Berndt & Allen, in press). New Zealand populations of U. lugens are of the ‘coastal/inland’ form and are bivoltine. The parasitoids to be released in New Zealand will be collected from Tasmania.

Biology The moths lay eggs in batches of 20-500. Host selection in U. lugens is primarily made by the ovipositing female, as newly hatched larvae are vulnerable to desiccation and do not disperse. The first five larval stages feed gregariously on the upper and lower surface of gum leaves producing the typical ‘skeleton’. Larger larvae feed individually and consume the entire leaf blade down to the mid-rib (Berndt & Allen, in press). Mature larvae wander to find a pupation site on the ground or in the tree in bark or leaf litter where a cocoon is spun, incorporating the hairy, cast larval skin and surrounding material for camouflage. Adults do not have functional mouthparts and thus do not feed (Berndt & Allen, in press). They live from 3-12 days at 20 0C (Berndt & Allen, in press).

Parasitoids and predators Twenty two primary parasitoids of GLS have been recorded in Australia, most of which attack larvae and pupae. (Berndt & Allen, in press). At least two (Cotesia urabae and Dolichogenidea eucalypti) are thought to be restricted to GLS and these have been investigated as possible biological control agents in New Zealand (Berndt et al. 2007). Allen (1990a) suggested that the numerous ant species present in eucalypt trees may have contributed to the high level of GLS mortality observed. Intense ant predation of this type is not known in New Zealand, and without it, more GLS larvae may survive, increasing the pest problem here.

Food plants and pest status of GLS in Australia GLS is recorded from at least 103 myrtaceous tree species in its native range, mostly in the genus Eucalyptus (Berndt & Allen, in press). Of these, 11 species have sustained significant damage, 32 are considered good hosts, and the remainder are recorded as minor hosts or there is little information on host suitability (Berndt & Allen, in press). Uraba lugens was first recorded as an important defoliator by Froggatt (1900) and in New South Wales causes occasional severe damage to E. saligna,

E. fastigata and E. grandis (Berndt & Allen, in press), all of which are commercially important in New Zealand forestry. Since 1919 there have been 11 recorded outbreaks in the E. camaldulensis forests of the Murray Valley region (Victoria and New South Wales), and up to 40,000 ha of forest defoliated on at least two occasions (Campbell, 1962; Berndt & Allen, in press). Uraba lugens is also a widespread and serious pest in southern Queensland primarily on Eucalyptus crebra, E. melanophloia, and E. tereticornis (Brimblecombe, 1962; Berndt & Allen, in press). Brimblecombe (1962) reported periodic outbreaks at approximately 10 year intervals in southern Queensland, including a 2500 sq km outbreak in 1960. Between 1982 and 1988, a severe outbreak of U. lugens defoliated over 300,000 ha of native E. marginata and Corymbia calophylla forest in Western Australia (Farr et al., 2004; Farr, 2009; Berndt & Allen, in press), and it is commonly found on amenity plantings of E. globulus (Berndt & Allen, in press). In Tasmania, U. lugens is widespread in native forests and urban trees with occasional outbreaks in plantations (de Little et al., 2008, Berndt & Allen, in press). In these plantations attack is usually heaviest in the outer three to four rows of trees. This is probably due to the night flying moths using roads and firebreaks as flight paths, and possibly the quality of foliage decreasing further into the plantation stand, due to lower light penetration (D. de Little , pers. comm.).

Severe defoliation can occur in young E. nitens plantations, with between 3-17% mortality recorded following two seasons of defoliation. The primary hosts of U. lugens in Tasmania are E. nitens, E. obliqua, E. delegatensis, (Berndt & Allen, in press) and E. globulus (de Little et al., 2008). No analysis has been made of the economic effects of this species in Australia, although large areas of managed natural forest have been defoliated (Brimblecombe, 1962; Farr et al., 2004; Berndt & Allen, in press).

3.4.1.2 Population dynamics and pest status of U. lugens in New Zealand Affinities with the New Zealand fauna GLS belongs to the subfamily Nolinae of the family Noctuidae. (Table 1). There are no native Uraba species in New Zealand, and there is only one native species in the subfamily, Celama parvitis. This is the only species present in New Zealand that is closely related to U. lugens. It is known from Nelson, Lake Wakatipu, Otago Peninsula (Berndt & Allen, in press), and can be locally common in the northern

and eastern parts of the South Island (Chris Green, DoC, pers. comm., 2003, Brian Patrick, pers. comm. 2009). In the North Island it is found rarely in Wairarapa and Lake Waikaremoana. Overall it is not considered to be in danger of extinction (Brian Patrick, pers. comm. 2009).

Predicted impact of the pest in New Zealand In a laboratory study of the suitability of 18 highly valued eucalypt species as food for larvae, E. nitens, E. nicholii and E. fastigata were found to be most at risk (Berndt and Allen, in press). GLS has been recorded on 53 tree species In New Zealand, mainly from the genus Eucalyptus. Twenty four of the records are new, and have not been recorded as hosts of in Australia. Significant damage has only been recorded on B. pendula in summer (John Bain, Scion, pers. comm.).

Several larvae completed development on three native species (Metrosideros umbellata, M. carminea, Nothofagus truncata – rata and beech) in laboratory tests, but there is little or no evidence that moths lay eggs on these native trees (Berndt & Withers, 2009). However, there is a risk of damage to non-target trees like these if hungry larvae migrated from defoliated gum trees. Pohutukawa has been recorded in the field as a host of U. lugens although this seems to only occur through ‘spill-over’ feeding as larvae move from nearby eucalypts (Berndt & Withers 2009), and has not yet significantly affected those trees.

The next most closely related subfamily present in New Zealand is the Arctiinae. New Zealand has four endemic species, and one introduced weed control agent within this subfamily (Table 1). Of these, none are recognised as rare or endangered (Chris Green, DoC, pers. comm., 2003). Further discussion of the relatedness of the GLS to the New Zealand moth fauna can be found in Appendix 2.

Present and future distribution in New Zealand GLS was first identified outside its native Australia in 1997 from specimens collected in 1992 at Mount Maunganui. It was eradicated, but a second population covering 11,000 ha was detected in Auckland in 2001 (Berndt & Allen, in press, Ross 2003). Expenditure on GLS research and management from 2003-2006 totalled $3.25 million (Mark Ross, MAFBNZ, pers comm.). As of 2009 it is widespread

throughout the Auckland region and also present in Waikato and Bay of Plenty regions. Undetected populations may exist further afield. GLS is expected to spread within New Zealand, and has potential to reach all eucalypt growing areas of the country (Kriticos et al. 2007) except alpine areas above 600 m, areas of high rainfall on the west coast of the South Island, and cold, dry areas in Central Otago (Kriticos et al. 2007). TABLE 1: The New Zealand species within the family Noctuidae that are most closely related to gum leaf skeletoniser

Species Subfamily Status Host plant Reason for inclusion Celama parvitis Nolinae Endemic Native everlasting Same subfamily daisy

Metacrias Arctiinae Endemic On many grasses and Close subfamily strategica herbs

Nyctemera Arctiinae Endemic common on ragwort, Close subfamily annulata cineraria, groundsel etc

Metacrias huttoni Arctiinae Endemic On many grasses and Close subfamily herbs

Metacrias erichrysa Arctiinae Endemic On many grasses and Close subfamily herbs

Tyria jacobaeae Arctiinae Introduced Ragwort only Close subfamily biocontrol agent

Rhapsa scotosialis Hypeninae Endemic Leaflitter and mosses Related subfamily

Spodoptera litura Acronictinae Exotic pest Clover, horticultural Distant subfamily crops

Helicoverpa Heliothinae Exotic pest Horticultural grain Distant subfamily armigera conferta crops

Human assisted dispersal through movement of plant material, vehicles or equipment containing eggs, larvae or pupae is likely to accelerate natural dispersal from infested areas. Further details can be found in Berndt & Allen (in press).

As all continents have regions suitable for establishment (Kriticos et al., 2007), there is a risk of international dispersal from New Zealand with consequent trade risks.

Predicted pest status in New Zealand The susceptible hosts Eucalyptus nitens and E. fastigata are important commercial plantation and farm forestry species in New Zealand, where it is used to provide wood pulp for paper production, hardwood timber for joinery, furniture production and veneers, and for durable outdoor uses such as posts and rails. Gum trees provide additional benefits in agroforestry, and for honey production and coppicing. E. fastigata is a leading candidate for carbon sequestration and bioenergy forests (I. Nicholas, Scion, pers. comm. 2009, Appendix 1). No outbreaks of GLS have yet been recorded in plantation forests so there have not yet been any commercial effects on these species. Modelling suggests that significant growth losses can be expected (Potter et al. 2005).

An economic impact assessment has estimated the potential cost to the New Zealand production and amenity tree estates of GLS infestation over the next 20 years at $NZ100-$142 million (Journeaux 2003, Section 7.4).

In Tasmania, where clearfell forestry techniques resemble those used in New Zealand, severe defoliation can occur in plantation edges for a number of years following planting, and at one site it is common to see a 40m band of stunted and dead saplings surrounding mature forests. This edge effect could be of particularly important for small eucalypt forest blocks (Potter et al. 2005) which are common in New Zealand. There have been many outbreaks in natural eucalypt forests in Australia (see Section 3.4.1.1) and this wholesale defoliation could also happen here.

Troublesome populations have been recorded in amenity plantings in urban areas, where the threshold for adverse effects is relatively low. It has caused significant damage in New Zealand on Lophestemon confertus and a variety of Eucalyptus species (Simon Cook, Auckland City Council, pers. comm.).

Natural enemies observed in New Zealand Four parasitoids have been recorded form GLS in New Zealand (Mansfield et al. (2005) but attack is relatively uncommon, and the current impact of parasitism on GLS populations in New Zealand appears to be minor (Berndt & Allen, in press; Berndt, submitted manuscript).

Management options other than biological control Aerial application of insecticide appears to be the only feasible tactic should control of wide-scale GLS outbreaks be required in forests. Mansfield et al. (2006) examined the selectivity of available pesticides. Injection of systemic insecticide directly into tree trunks to control GLS feeding in the crowns of eucalypt trees has been adopted as a more environmentally and socially acceptable alternative, especially in urban areas (Gous and Richardson 2008). However, this method is labour- intensive and expensive, and is probably not economically efficient except for amenity plantings. Trapping of adults males using sex pheromones (Gibb et al. 2008) may have a role in managing damage to trees in some circumstances. Selection of resistant eucalyptus species is another tactic available to growers over the long term, but as GLS has such a wide host range, this would limit the ability of growers to select trees with appropriate site adaptations and wood properties.

3.4.2 Biology and ecology of the control agent 3.4.2.1 Biology and ecology in Australia Biology Adult C. urabae are 2.5-3.2 mm long, and have a black body with predominantly yellow–brown legs (Allen, 1990a). A female C. urabae lays eggs inside a GLS larva by jabbing its ovipositor into the body. One female has been found to carry up to 400 eggs (Berndt & Allen, in press). Cotesia urabae females are capable of attacking the same larva multiple times (L. Berndt, pers. obs.), but only a single

parasitoid individual ever completes development in each host larva. Parasitoid larvae are likely to compete within the hosts, using large jaws to kill other larvae present, as happens in other Cotesia species.

Cotesia urabae larvae emerge from late stage host larvae and pupate alongside the host in a tightly woven sulphur-yellow pupal cocoon in a loose surrounding silk matrix. The host larva dies at this point. The time the larval stage spends developing inside the host varies considerably, ranging from 14 days during summer to 20 days during winter. Adult emergence occurs approximately 8 days after pupation and an adult survives for 27 days on average (Allen, 1990a).

Life cycle and population dynamics in Australia Cotesia urabae forms part of a large complex of 11 primary parasitoids of U. lugens, many of which are polyphagous (Allen, 1990a). Parasitism never accounted for more than 50% of all mortality in Allen’s (1990a) study but he observed 25% predation of parasitoid cocoons, probably by ants , a phenomenon that has not been observed in New Zealand. If ants are the issue, parasitoid numbers and the level of GLS control achieved here is likely to be higher here than is observed in Australia. Parr (2009) collected and reared U. lugens larvae from 14 sites in Tasmania from December 2008 to February 2009. Parasitism by C. urabae averaged 22.4% of larvae (2-72%) where the parasitoid was present. Like Allen (1990a), she found high levels of mortality that were not related to parasitism (41.4%; range 0-100%). C. urabae was reared from larvae collected at 7 of the 14 sites. C. urabae populations are subject to hyperparasitoids in Australia (Berry & Mansfield, 2006).

3.4.2.2 Likely biology and ecology in New Zealand Affinities with New Zealand fauna Four species of Cotesia are known from New Zealand (Austin & Dangerfield, 1992; Berry, 1997) all of which have been introduced for the biological control of various lepidopteran pests (Cameron et al., 1989). The four species include, Cotesia glomeratus (introduced for the biological control of white butterfly, Pieris rapae ); Cotesia kazak (tomato fruitworm, Heliothis armigera conferta); Cotesia rubecula (white butterfly, Pieris rapae) and Cotesia ruficrus (pest noctuids) (Jo Berry, Landcare

Research, pers. comm., 2003; Cameron et al., 1989; Cameron et al., 1995). It is possible that other species of Cotesia may exist in New Zealand, including undescribed endemic species, however this genus has not been revised recently (Jo Berry, Landcare Research, pers. comm., 2003).

Predicted performance in New Zealand Withers (2003) predicted that the introduction of C. urabae into New Zealand free of competitors and free of hyperparasitoids (Berry & Mansfield, 2006) would significantly increase the overall mortality of U. lugens due to parasitism over that observed in Australia. Detailed field studies in South Australia have revealed complex interactions between U. lugens and its array of natural enemies (Allen, 1990a,b). The system to which the parasitoid will be introduced is much simpler. Our belief is that this will result in higher populations of the parasitoid, and hence greater parasitism of U. lugens larvae in New Zealand than has been observed in South Australia because C. urabae would be freed from competition from the other parasitoids of GLS in Australia, hyperparasitoidism on Cotesia species in New Zealand appears to be less important than the same affect on C. urabae in Australia, and because predation is an important mortality factor for C. urabae pupae in Australia but not for Cotesia pupae in New Zealand.

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

We accept that the species to be imported may have inseparable organisms, but the biosecurity requirements imposed under the Biosecurity Act will regulate these organisms.

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.

Not applicable. The organism is not genetically modified

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

Not applicable. The organism is not genetically modified

Type and source of additional genetic material.

Not applicable. The organism is not genetically modified

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

Yes No Were(was) native flora or fauna used as host organism(s)? Was genetic material from native or valued introduced flora and fauna used? If native flora and fauna were involved, were the species concerned endemic to New Zealand? Was human DNA or cell lines used that are of known Māori origin? Was genetic material obtained directly from human beings? If Yes, provide additional details below.

If the genetic modification involves DNA of human origin, provide details of 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. Consultation with Māori will only be required if the human DNA or cell lines are of known Māori origin. Where consultation has occurred, ensure you append any relevant information to the application including consultation feedback, minutes of meetings or other correspondence.

Not applicable

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).

Not applicable. The organism is not genetically modified

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(s) 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.

Permission to import Cotesia urabae into containment was granted under Approval Code NOC00229.

Section Four – Establishment and Eradication of a Self-Sustaining Population Information under this and the next heading is required so that the Authority can take account the matters set out in section 37 of the Act.

4.1 Ability of organism(s) to establish a self-sustaining population Describe any ability of the organism to establish a 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 any situations where the establishment of this(these) organism(s) as a self-sustaining population would not be undesirable, along with the likelihood of each possibility. 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 is to establish self-sustaining populations of Cotesia urabae that will exert biological control over GLS wherever it occurs. The pest itself is expected to eventually colonise eucalypt trees throughout their range in New Zealand, and as the parasitoid comes from Tasmania, it is not expected to be limited by climatic conditions within that range. Once established, C. urabae is expected to limit the rate at which populations of this pest can expand from their current limited distribution, and eventually to limit the frequency and intensity of outbreaks throughout New Zealand.

4.2 Ease of eradication of a self-sustaining population Information under this heading must be provided although ERMA New Zealand understands this application seeks approval to import an organism for release or release from containment. Describe the ease of eradication of the population, including the methods to be used, likely costs, and the likelihood of total eradiation of the population.

Opportunities for eradication following release will be limited. Given the small number of individuals that are to be released initially, the small size of adult parasitoids and the fact that larval development occurs hidden within host larvae, it is unlikely that this control agent will be recovered in the field before two generations are completed and populations grow. Adult braconids fly actively and are small enough to be carried far by the wind. After two years it is conceivable that viable populations could exist several km from the point of releases, making eradication practically impossible. As Cotesia species are obligate parasitoids of lepidopterous larvae, aerial application of Bt across a wide area might reduce the populations of larval hosts sufficiently to cause the extinction of low, dispersing populations of C. urabae.

Section Five – 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, and why.

5.1 Rearing and release Larvae of GLS will be collected in Tasmania in December 2010, and reared in Tasmania until parasitoids emerge from larvae and pupate. Parasitoid cocoons will be shipped to the quarantine facility at Scion in Rotorua. Ten percent of the imported prepupae, or pre-pupae formed in the first laboratory generation will be examined by authorities for the presence of micro-organisms likely to cause disease in the parasitoid population. Once post-importation requirements have been met (probably after one generation) the C. urabae population will be removed from the quarantine facility. Releases will begin in January 2011, at two sites in the Auckland region, as part of a MAF Sustainable Farming Fund project.

5.2 Post-release monitoring Establishment of the parasitoid will be confirmed by rearing GLS caterpillars collected from the release sites on at least two occasions in the first year to check whether parasitoids emerge. To check whether non-target species have been attacked, 100 caterpillars of other moth species will be collected from trees, shrubs and herbs growing within a 20 m of each release point, and reared to check for parasitism.

Beyond these initial surveys, post-release monitoring of the performance of Cotesia urabae will be undertaken under FRST Programme C04X0807 “Biosecurity, Protection and Risk Management of NZ Forests”. As a first step, the impacts of C. urabae on GLS larval populations will be measured by June 2012. It is intended that monitoring of the performance of C. urabae will lead to the development of an integrated pest management strategy for GLS. Scion expects that the impact of GLS on eucalypt and other susceptible trees will have been reduced to insignificance by 2015 as a result of management tools developed as part of this programme. Other components of IPM, including the role of mixed tree species will also be considered as part of this programme.

Section Six - Identification of adverse and beneficial effects (risks, costs, and benefits)

This section must include information on the adverse and beneficial effects referred to in the HSNO Act. Adverse effects include risks and costs, and beneficial effects are described as benefits. For convenience adverse effects are at times referred to simply as risks. All effects should be described in terms of the magnitude of the effect if it should occur and the likelihood of occurrence. Monetary and non-monetary effects should be considered, and a comment should be included on the distribution of the adverse and beneficial effects across affected parties.

In this part of the form you are required to identify the potential adverse and beneficial effects (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 is canvassed. In the first instance you are required to identify all potential adverse and beneficial effects (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 potential adverse and beneficial effects (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 potential adverse and beneficial effects (risks, costs and benefits) that are considered to be potentially significant and warrant further more detailed assessment (in section 7). 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 potential 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 potential adverse and beneficial effects, separately. If you decide that some of them are not potentially significant and do not require further assessment, indicate why you have reached this conclusion.

Risks:

Source of potential risk Severity Likelihood Score Comments

C. urabae damages populations of Moderate Very B See Section 7.1.1.1 non-target native Lepidoptera unlikely

GLS density decreases, reducing Moderate Very B Limited use of GLS by native species prey for native predators and unlikely currently, See Section 7.1.1.2 parasitoids

C. urabae becomes a host for Moderate Very B See Section 7.1.1.3 indigenous predators and unlikely hyperparasitoids, leading to significant apparent competition with native insects

C. urabae competes significantly Moderate Very B Limited use of GLS by native species with indigenous parasitoids and unlikely currently, See Section 7.1.1.4 predators for GLS as a food source

Decline in GLS density increases Minor Unlikely B Eucalypts not commonly contiguous with eucalypt biomass, raising fire risk for native vegetation, See Section 7.1.1.5 native vegetation and watercourses

Reduction in GLS density reduces Minor Unlikely B Effect likely to be small ,and only relevant stem death, leading to significantly to birds that inhabit eucalypt forests, See fewer holes available for native Section 7.1.1.6 parrots, and dead wood available to native insects

Host range of the parasitoid evolves Major Highly B See Section 7.1.1.7 in the medium term to cause Improbable significant adverse effects on non- target organisms

C. urabae hybridises with indigenous Major Highly B See Section 7.1.1.8 Cotesia species improbable

Benefits:

Source of potential benefit Advantage Likelihood Score Comments

C. urabae causes significant decline in Moderate Very B Not a parasitoid of pest Lepidoptera, other pest Lepidoptera unlikely see Section 7.1.2.1

Decreased damage to eucalypts Minor Likely B Healthier eucalypts provide more protects the ecosystem services that shade for watercourses, floral trees provide to the environment resources for native species, perches for birds and shelter for bark inhabiting species, see Section 7.1.2.2

C. urabae provides extra food for Minor Unlikely B Theoretical target for hyperparasitoids, native parasitoids See Section 7.1.2.3

6.2 Identification of potential 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 potential adverse and beneficial effects separately. If you decide that some of them are not potentially significant and do not require further assessment, indicate why you have reached this conclusion.

Risks:

No significant risks identified

Benefits:

Source of potential benefit Advantage Likelihood Score Comments

Lower GLS larval density reduces Minor Likely B Significant reduction in future risk , incidence of serious skin irritations although the current number of cases is low, See Section 7.2.2.1

Biological control of GLS reduces Minor Likely B Expected outcome, but current pesticide use and exposure of the pesticide use small, See Section 7.2.2.2 public and operators to insecticides

6.3 Identification of potential effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued introduced 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 potential adverse and beneficial effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued introduced 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 expressed views of the Māori

community during your consultations with them. However, details on these views and how they were obtained should be dealt with under the assessment section (section 7). List risks, costs, and benefits, separately. If you decide that some of them are not potentially significant and do not require further assessment, indicate why you have reached this conclusion.

6.3.1 Risks: Consultation over this and previous applications identified a range of potential adverse effects that Māori wished to be addressed in the application: Risk to the safety of native and exotic Lepidoptera Risk that biological control does not succeed in New Zealand Risk of evolution of host-range that could cause problems in the future Risks associated with the introduction of any and all exotic organisms to Aotearoa. In addition, respondents wished the following issues to be addressed: What Māori peer review is there? Need for monitoring Need for appropriate cultural protocols for the introduction and release of new organisms Who carries the risk? The need for caution 6.3.2 Benefits: As well as adverse effects, respondents listed the following potential benefits: Protection of Māori-owned eucalypt forests that support community well-being. Protection of eucalypts as food for native birds Protection against incidental attack by GLS on pohutukawa and other native plants Protection against the health risk to Māori of allergic reactions to GLS larvae.

6.4 Identification of potential effects on the market economy 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.

Risks:

Source of potential risk Severity Likelihood Score Comments

Biological control of GLS reduces Minimal Likely B Although real. The overall value of management operations, and the this shift is not large. Current incomes of pesticide retailers, operations valued at $60-65K , see applicators, and tree managers Section 7.4.1.1

Introduced parasitoid Moderate Very unlikely B See Section 7.1.1.1, 7.4.1.2 significantly reduces populations of biological control agents for weeds, and other valued insects

Benefits:

Source of potential benefit Advantage Likelihood Score Comments

Biological control of GLS leads to Moderate Likely C The major monetary benefit from shorter eucalypt crop rotation this proposal. See Section 7.4.2.1 time and higher quality wood

Biological control of GLS leads to Minor Likely B GLS prefers feeding on the most increased confidence of the valuable eucalypt species. GLS is forestry industry to plant eucalypt potentially serious, but not currently species for paper, timber, carbon a key pest in eucalypt forestry. Other sequestration and posts issues may have more bearing on forester confidence. See Section 7.5.2.2

Biological control of GLS increases Minor Likely B A subtle intangible benefit, See potential for sustainable forest Section 7.4.2.3 production and ability to comply with FSC certification

Biological control of GLS leads to Minor Likely B A likely consequence of control, reduced GLS management costs although the frequency and extent of for territorial authorities, schools, spraying is currently small, See horticulturalists and forest-based Section 7.4.2.4 effluent managers

Biological control of GLS results in Minor Likely B Eucalypts not greatly valued for healthier eucalypt trees in the contribution to landscape or as an environment, improving erosion control species so benefit is ecosystem services, landscape limited. Shading of waterways, better values, and erosion control binding of pastoral phosphate, shelter for stock, would be recognised benefits, but value uncertain. See Section 7.4.2.5

6.5 Identification of potential effects on society and communities 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 issues or considerations 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, or consultation? However, details on this should be dealt with under the assessment section (section 7).

Risks:

Source of potential risk Severity Likelihood Score Comments

C. urabae adds another Minor Unlikely B This view held by some but most will unwanted exotic species to the regard establishment as beneficial. NZ fauna Intentional release is a minor pathway for establishment of exotic insects and contributes few new immigrants, see Section 7.5.2.1

Benefits:

Source of potential benefit Advantage Likelihood Score Comments

Successful control of GLS Moderate Likely C Significant benefit of programme, see maintains New Zealand Section 7.5.3.1 backyards free of significant animal dangers and safeguards the traditional outdoor way of life

Improved eucalypt tree health Minor Likely B Significant benefit of programme, but resulting from GLS control leads eucalypts not commonly the primary to healthier, better quality tree for recreation use and marginal eucalypts as amenity plants and effect small nationally, see Section 7.4.2 shade trees for schools, campgrounds, parks etc

Ethical issues and considerations: No ethical issues have been identified

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

None identified

Section Seven – Assessment of potentially significant adverse and beneficial effects (risks, costs and benefits)

This section entails detailed assessment of those effects identified in section 6 that you consider to be potentially significant. 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 magnitude of the outcome if the effect should occur, and the likelihood of occurrence (which may be measured as frequency or probability). 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 also 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 4 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) that reflect those matters referred to in Part II of the HSNO Act:

7.1 Assessment of potentially significant effects on the environment (in particular on ecosystems and their constituent parts) Assess the potentially significant adverse and beneficial effects 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 adverse and beneficial effects (risks and benefits), separately. Where benefits and risks are linked, state this (e.g. a biological control agent which has an impact on both the target organism (benefit) and non-target organisms (risk)).

7.1.1 Risks and costs

7.1.1.1 Introduction of C. urabae leads to damage to populations of non-target native Lepidoptera Cotesia urabae would adversely affect environmental values if it attacked non-target native Lepidoptera with sufficient intensity to cause population decline in those species. The magnitude of such a non-target effect would be moderate. However, on the balance of evidence, this scenario is considered very unlikely because: Field records in the home range indicate that C. urabae is specific to gum leaf skeletoniser in Australia (Austin & Allen, 1989; Andy Austin, University of Adelaide, pers. comm., Appendix 1)

Laboratory experiments conducted in containment showed that the parasitoid preferred to attack and lay eggs in GLS rather than in related Lepidoptera (Appendix 2)

None of the non-target moth larvae tested in these laboratory trials supported full development of the parasitoid from egg to adult. None are yet known to be adequate physiological hosts.

It follows that populations of C. urabae are unlikely to persist in New Zealand away from trees infested with GLS. Any adverse environmental effects will therefore decline with distance from such infestations

The applicant has completed a long-running series of complex laboratory experiments to test the capability of C. urabae to find, attack and develop on targets other than GLS. The results of these experiments are summarised here, but full details of the experimental design, and the full results of that research can be found in Appendix 2. Field observations were also made in Tasmania to reinforce the results of lab testing.

The non-target moths tested are listed in Table 2. For parasitoids of this type, the non-target species most likely to be attacked are those most closely related to the primary host (Godfray, 1994). The selection of which moth species of the noctuid family should be tested was therefore based on their relatedness to GLS (Lafontaine and Fibiger, 2006; Section 3.4.1.1). There are at least 138 native noctuid species in New Zealand, most of which belong to the Trifine noctuids (lower branches of Figure 1). These were considered too unrelated to warrant detailed testing, but Helicoverpa armigera and Spodoptera litura were tested as representative species of this group. Of the quadrifine noctuids (upper branches of Figure 1), all endemic or valued species were tested, except those in the subfamily Hypeninae. The larvae of this group are nocturnal and probably live in the leaf litter, and so are unlikely to ever encounter C. urabae. The species tested include the sole New Zealand representative of the Nolinae (Celama parvitis) and all of the New Zealand resident endemic Arctiinae (Table 1, Section 3.4.1.1, page 12).

Following current thinking in the host range testing literature (e.g. Van Driesche and Murray, 2004; van Lenteren et al. 2006; papers of Cameron et al.), three test designs were selected to provide robust data on the behavioural and physiological host range of C. urabae (Berndt et al. 2007).

The sequential no–choice tests revealed what happened when C. urabae were closely confined with test larvae in a simple arena. Adult parasitoids oriented towards and showed attack behaviour on all of the species presented. Dissection of a sample of the larvae presented to parasitoids indicated that this behaviour resulted in eggs being deposited in all but one of the closely related species, but not in the two trifine noctuid species Helicoverpa armigera and Spodoptera litura. This reinforces the view that the host range of this parasitoid is limited to the quadrifine noctuids (Figure 1).

Larvae from these tests were reared to compare development success of C. urabae on larvae of Uraba lugens and on test larvae. Of the 53 Celama parvitis larvae that were reared, none produced parasitoids. Only 7 cocoons were produced from the 458 larvae of Metacrias erichrysi and M. huttoni tested. Pupae within these cocoons did not complete development to become adults, which may further indicate inadequacy of Metacrias erichrysi and M. huttoni as hosts for C. urabae. Even though development was not successful, C. urabae killed these 7 larvae, but if repeated in the field, mortality at this frequency would not adversely affect populations of these native species.

High mortality of test larvae from other causes obscured clear conclusions, but overall, only 0.7% of the test larvae that were exposed to attack and then reared died as a result of C. urabae emergence compared with 19.9% of the GLS control larvae reared.

Figure 1: Phylogenetic tree of the Noctuidae, after Figure 28 in Lafontaine and Fibiger (2006). Subfamilies enclosed in a rectangle have New Zealand endemic representatives (Dugdale, 1988). Those enclosed with an oval have only exotic or cosmopolitan representatives in New Zealand (Dugdale, 1988) and were not tested. Numbers refer to the morphological features that define that clade. Refer to Lafontaine and Fibiger (2006) for further details.

Field studies conducted in Tasmania indicate that laboratory tests probably overestimate the field host range of C. urabae. As none of the New Zealand non-target species are present there, the research subject was Nyctemera amica, an Australian species very closely related to the New Zealand

endemic arctiine N. annulata. C. urabae showed attack behaviour towards N. amica in laboratory tests in Tasmania just as it did towards N. annulata in the New Zealand research. However, field surveys found no evidence to suggest that C. urabae attacks N. amica in the wild in Tasmania, even though this species occurs on plants growing under eucalypt trees infested with and the parasitoid (R. Parr, unpublished data, 2009). In addition, no other Lepidoptera larvae collected on or near these eucalypts have been found to have evidence of attack by C. urabae.

By definition, host range tests such as those described in Appendix 2 can only provide negative evidence, and cannot prove that other species would not be attacked if C. urabae was released in the field. To establish a persistent population on a non-target host in New Zealand, Cotesia urabae would need to overcome all of the following hurdles: 1. Locate suitable prey over a long distance in time and space 2. Locate prey at close range 3. Exhibit appropriate behaviours to attack the host larva and successfully deposit an egg 4. Hatch and develop, overcoming the immune responses of the host 5. Emerge from the host, pupate and develop into an adult parasitoid 6. Produce fertile eggs and 7. Repeat steps 2-6 sufficiently well to produce a growing population Failure at any of these steps would preclude that species as an adequate host for the parasitoid in New Zealand. Cotesia urabae could not progress beyond step 4 on any of the non-target species presented.

None of the species presented to C. urabae proved to be fully adequate physiological hosts for the parasitoid. Coupled with the other behavioural and ecological constraints that are likely to minimise interactions between this parasitoid and non-target hosts (Appendix 2), we have concluded that death of non-target larvae from C. urabae attack is likely to be rare (except possibly in close proximity to eucalypt trees), and it is very unlikely that such attack could lead to adverse effects on populations of non-target Lepidoptera.

Lack of successful attack by C. urabae on non-target species in these tests is strong evidence that the field host range lies within the Noctuidae. It follows that non-Noctuid moths and butterflies, including the monarch butterfly and the red and yellow admirals (Nymphalidae), are not at risk of attack by C. urabae.

7.1.1.2 Successful reduction in GLS density by biological control significantly reduces prey that support populations of native predators and parasitoids If any native parasitoid or predatory species currently relied significantly on GLS, then the magnitude of the effect of reducing GLS populations by biological control would be moderate. However, the probability of moderate effects is considered very unlikely because when C. urabae is released: 1. The geographical distribution of GLS (and any effects) will still be limited to northern North Island 2. Any effects will be localised to the vicinity of GLS populations, and so to the vicinity of eucalypts 3. No critically affected species have been identified or suggested

If any adverse effect on native parasitoid and predator populations proved to be real, then this would only occur in the immediate vicinity of trees that host GLS, not across all ecosystems. Mansfield et al. (2005) recorded 6% parasitism by the native pupal parasitoid Anacis sp. and attack by two other Ichneumonids. Nothing is known about the biology of Anacis, but the other species are thought to be generalist parasitoids and so are unlikely to be reliant on GLS as prey (Berndt and Allen, in press). Two native bugs (Oechalia schellenbergii and Cermatulus nasalis; Pentatomidae) have been recorded as predators of GLS in Australia and are also common in New Zealand (Berndt & Allen, in press). These too are generalist species, and it is unlikely that GLS forms a significant prey source.

There is a counter-argument. If the presence of GLS as prey artificially increased the abundance of native natural enemies, then this could have an adverse effect on populations of true native hosts (apparent competition). Such an effect would be mitigated by successful biological control.

7.1.1.3 C. urabae establishes on release and becomes a host for indigenous natural enemies, leading to significant apparent competition with native insects and 7.1.1.4 C. urabae establishes on release and competes significantly with indigenous parasitoids and predators for GLS as a food source

If the abundance of generalist predators and hyperparasitoids in the environment increased significantly as a result of feeding on C. urabae, and this led to increased attack on native species (apparent competition) then the magnitude of the adverse effect on trophic webs could potentially be moderate. Similarly, high populations of C. urabae could compete directly with native parasitoids, with moderate adverse effects. However, these outcomes are considered to be very unlikely because: 1. GLS has few known generalist predators and parasitoids (Berndt & Allen, in press, Mansfield et al. 2005), and the rate of parasitism is low (Berndt, in MS; Section 7.1.1.2). 2. There appear to be no native larval parasitoids with which C. urabae would compete directly. Mansfield et al. (2005) found no native larval parasitoids of GLS. Further collections of over 6000 GLS larvae from throughout the current range of GLS have also failed to produce native parasitoids (L. A. Berndt unpublished data). 3. The extent of any significant adverse effects will be restricted to the vicinity of GLS host trees (as argued in Section 7.1.1.1). 4. The eggs and larvae of C. urabae only occur within GLS larvae and are not available for separate predation. 5. When the pupa forms it essentially replaces the parasitised GLS larva, thus changing the form but not the quantity of biomass available to predators. Predation of Cotesia cocoons appears to be rare in crops (Graham Walker, Plant and Food Research, Auckland, pers. comm., Appendix 1). 6. Adult C. urabae fly and are very active. They could become prey for spiders but are unlikely to be susceptible to other predators. 7. Adults are minute and would contribute little prey biomass to the ecosystem compared to biomass of alternative prey for predators and are unlikely to significantly alter trophic relationships (e.g. Withers, 2001). 8. Hyperparasitoids of braconids do not appear to be common in modified habitats (John Charles, Peter Lo, Plant and Food Research, pers. comm., Appendix1) except late in the season, and are not thought to have significant impact on the efficacy of their hosts as control agents

(Graham Walker, Plant and Food Research, Auckland, pers. comm., Appendix 1; Cameron & Walker, 2002).

7.1.1.5 Decline in GLS density increases eucalypt biomass, raising fire risk for native vegetation and watercourses The magnitude of this risk is considered to be minor, and the likelihood of increased fire damage is considered unlikely. GLS outbreaks such those observed in Australia are expected to occur in New Zealand, and resulting defoliation will reduce the biomass of eucalyptus foliage in New Zealand. This will reduce fire risk to some extent, and this benefit of GLS will be smaller if biological control reduces GLS larval density.

Unlike in Australia, Eucalyptus species are not considered to be a greater fire risk in New Zealand than other forest vegetation such as pine trees (Ian Nicholas, Scion, pers. comm.). Changes in fire risk related to occasional and localised GLS outbreaks on eucalypts will therefore be only marginally important to vegetation security. The suggested environmental impact would be localised at rare margins between eucalypts and native vegetation.

7.1.1.6 Successful reduction in GLS density by biological control reduces stem death, leading to significantly fewer holes available for parrots and dead wood available to native insects There is considerable stem death visible on eucalypt trees due to past depradations of other pests (Lisa Berndt, Scion, pers. comm.). GLS reduces growth, but has not yet been observed to cause the widespread and significant dieback of eucalypt trees that would add significant numbers of nest holes, or extra dead wood for insects.

Biological control of GLS might limit the future availability of dead stems, but will not reduce an existing resource. The magnitude of this effect is therefore considered to be minor, and it is considered unlikely. See Appendix 1 for additional comments on the significance of this effect by Rod Hay (Department of Conservation, pers. comm.) and Ecki Brockerhoff (Scion, pers. comm.).

7.1.1.7 Host range of the parasitoid evolves in the medium term to cause significant adverse effects on non-target organisms

Although the evolution in the foreseeable future of biological characteristics that could lead to significant adverse environmental effects is a major issue, it is highly improbable that this will occur.

Unlike host-specific plant-eating insects, where speciation usually follows the same track as the evolution of the host plant, lineages of parasitoids sometimes show biological innovations, such as unexpected changes in host, life history, or habitat choice (Godfray, 1994). However, these radical changes occur only infrequently in the evolutionary history of a clade, over multi-millennial time frames. It is no more likely that C. urabae would undergo such a stepwise change than any of the thousands of native parasitoid species. The increase in the risk of adverse effects resulting from a stepwise expansion of host range that would result from the introduction of this parasitoid is insignificant.

7.1.1.8 C. urabae establishes on release and hybridises with indigenous Cotesia species, reducing resilience of native genetic diversity The consequences for the genetic integrity of the New Zealand fauna of active hybridisation between Cotesia urabae and native Cotesia species would be major, but hybridisation is considered to be highly improbable. Prof. Andy Austin (The University of Adelaide, pers. comm., Appendix 1), who described this parasitoid, considers the chance of hybridisation with local species to be extremely remote for several reasons: While it can be distinguished from the exotic C. kazak and C. marginiventris only by its cocoon and its host association (each is host specific), C. urabae is morphologically distinct from all other species native to the region (Austin and Allen, 1989).

Some native species produce multiple offspring from one host larva. Such large differences in physiology would preclude reproductively successful hybrids

C. urabae produces a single, fluffy, yellow cocoon, unlike that of any other known New Zealand braconid (including C. kazak).

C. urabae is associated with a eucalypt-feeding host and probably utilises eucalypt-associated chemicals in host finding. As eucalypts are not native to New Zealand, native species will not use these mechanisms to mediate social behaviours such as mate-finding.

Polydnaviruses mediate successful host use and are highly specific to individual species (Whitfield, 2000). This too would limit the likelihood of hybridisation.

7.1.2 Benefits

7.1.2.1 C. urabae causes significant decline in pest Lepidoptera Although this effect would have moderate benefits, it is considered a very unlikely outcome. Host- range tests indicate that Cotesia urabae is either functionally host-specific, or has a very narrow host range. There are no pest species in New Zealand that are closely related to U. lugens. The closest relatives are the many noctuid pests belonging to the trifine clades of the family (Figure 1). The larvae of H. armigera and S. litura were not susceptible to C. urabae attack in tests (Appendix 2), indicating that larvae of the trifine clades are not adequate physiological hosts for the parasitoid.

7.1.2.2 Successful reduction in GLS density by biological control decreases damage to eucalypts and protects the ecosystem services that trees provide to the environment Gum trees provide ecosystem services in both urban and rural areas including provision of nectar as food for birds and bees, providing shade and shelter, enhancing landscape values and landscape architecture, controlling erosion, and generally providing habitat diversity (Nicholas, 2009). These values are already under threat within the current distribution of GLS, especially in urban Auckland where pest management is undertaken to protect those values (See Section 7.4).

This beneficial effect is considered likely, but as the distribution of the pest is currently limited, the magnitude of the benefits that biological control of GLS could achieve is considered to be minor. Should GLS reach its predicted distribution (Kriticos et al., 2007), then the environmental value of the ecosystem services under threat would be substantial, and the potential benefits could increase to become moderate.

7.1.2.3 C. urabae provides extra food for native parasitoids The occurrence of this effect is therefore considered to be very unlikely, and the magnitude of the benefit to be minor for the reasons stated in Section 7.1.1.5.

7.2 Assessment of potentially significant effects on human health and safety (including occupational exposure) Assess any potentially significant adverse and beneficial effects on 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 potentially significant adverse and beneficial effects, separately.

7.2.1 Risks and costs

None identified

7.2.2 Benefits

7.2.2.1 Lower GLS larval density reduces incidence of serious skin irritations The hairy larvae of Uraba lugens also have short, stiff bristles that are hollow and contain venom that is injected on contact with the skin. Contact with the bristles can cause immediate sharp pain, which can be severe. Local pain is followed flat itchy welts that may remain visible for weeks (erucism), and cause distress for several days (Derraik, 2006). The effects can be particularly painful and distressing for children (Derraik, 2007). Even cast skins of U. lugens retain the ability to envenomate. Until the establishment of GLS, there were no lepidopteran larvae in New Zealand (native or introduced) that produced this effect. Eucalypt trees are often planted as shade trees around schools and other child- centred activities. Erucism will also pose a significant health risk to workers in eucalypt forests.

The frequency of erucism in New Zealand will be proportional to the number of larvae in trees near human activity. It is likely that parasitism by C. urabae would benefit human health by reducing the number of larvae in the environment, and hence reducing the probability of encounter. The current magnitude of this benefit is considered to be minor because GLS is not yet widely established. If this pest establishes as far south as Southland (Kriticos et al., 2007), and if periodic outbreaks occur here as they do in Australia (Brimblecombe, 1962), then the incidence of GLS-induced erucism will increase nationwide, and the magnitude of the benefit could rise to become moderate.

7.2.2.2 Biological control of GLS reduces exposure of the public and operators to insecticides GLS-infested amenity trees in Auckland City and are treated by injection of systemic insecticide directly into tree trunks to kill pests in the canopy (Gous and Richardson, 2008). This is the only control method currently in use (Simon Cook, Auckland City Council; pers. comm., Appendix 1). It virtually eliminates exposure of the general public to pesticides, although stem injectors must still handle organophosphate insecticides (Erika Commers, pers. comm., Appendix 1). It is not an economic option for GLS control in eucalypt plantations. The addition of GLS as another pest of eucalypts could increase frequency of aerial application and the range of chemicals applied in the future, exposing the public to greater amounts of pesticide than is presently the case. If so, then biological control is likely to reduce the frequency of applications and reduce public exposure to pesticides. The magnitude of benefits to the public and to operators from successful biological control would be minor because: Eucalypt plantations are not prevalent in the New Zealand landscape Treatment would only be in response to a GLS outbreak Applications would be conducted in a manner that minimised such effects.

7.3 Assessment of potentially significant effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna and other taonga (taking into account the principles of the Treaty of Waitangi) Assess the potentially significant adverse and beneficial effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi 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, and any information obtained from this consultation should be appended to the application. Give details of this in the space provided (see the User Guide for what is required).

Assess potentially significant adverse and beneficial effects, separately.

7.3.1 Consultation with Māori:

Consultation was conducted nationally, but with emphasis on iwi, hapū, and Māori organisations and individuals in the North Island (particularly in the Auckland region), where the pest is most abundant and where initial releases are planned.

A letter or email (Appendix 1) requesting dialogue over this proposal was sent to over 162 organisations and individuals belonging to the ERMANZ Māori National Network. The proposal was also briefly presented at the National Network Hui at Te Puea Marae, Mangere in September 2009, and additional input was obtained there. As the first releases of the control agent are expected to be made in parks of Auckland City and Manukau City, Ngāti Whātua o Ōrakei and Tainui were asked to suggest additional routes for consultation locally. On advice, the tangata whenua contacts listed on the Auckland Regional Council website that had not been contacted by other means were contacted by email. These 9 additional marae belonged to Ngāti Wai, Ngāti Whātua, Pare Waikato, and Pare Hauraki. The Mana whenua forum of Manukau City Council was contacted for advice on how to consult locally, and this dialogue continues. Tainui distributed the information to further marae in the Auckland area. At each stage, at least six weeks were allowed for response.

Thirteen responses were received, ranging in depth from acknowledgements to detailed submissions. A digest of those responses can be found in Appendix 1. Many of the issues raised in this and previous consultations have been common concerns for both tangata whenua and the general populace. Some issues raised during this consultation are dealt with elsewhere in Section 7. All organisations and individuals consulted will be informed when the application has been submitted and opened for public submissions.

7.3.2 Risks and costs: Respondents raised the following potential adverse effects that might follow the introduction: 7.3.2.1 Effects on the Environment Safety of both native and exotic Lepidoptera from attack Potential overlaps between the parasitoid and native parasitoids in habit and/or ecological niche? Evidence that the parasitoid poses little or no risk to populations of non-target Lepidoptera is developed in Section 7.1.1.1, based on the detailed study presented in Appendix 2 and in references cited there. Indirect effects on other species are discussed in 7.1.1.

Ecological evidence derived from studies conducted in Australia may not be relevant in New Zealand Impacts such as climate change on the maintenance of the parasitoid?

Climate and the natural enemies of GLS in New Zealand may well differ from those in Australia, and so the population dynamics of neither pest nor parasitoid in New Zealand can be predicted with certainty. However, it is not the size of the parasitoid population that poses a potential risk in New Zealand, but host selection behaviour. The host-seeking behaviour and physiology of parasitoids are genetically ‘hard-wired’, and are fundamentally independent of climatic conditions. It is extremely unlikely that the parasitoid will choose a significantly different array of hosts in New Zealand than it would in Australia.

Is biological control of insects successful in New Zealand? Cameron et al. (1993) report that partial to complete success has been achieved in biological control programmes targeting 24 insect and mite pests of field, fruit or greenhouse crops, pasture and forestry in New Zealand, and substantial success is claimed for a further 16 pests, an overall success rate for New Zealand of 42% of biological control projects completed. Complete success of biological control has been claimed for five forest pests (75% of projects). The resulting economic gains have been quantified for few of these projects. Cameron et al. (1993) point out that the benefit to New Zealand of these programmes is underrated because there are no longer outbreaks to remind people how serious and costly many of these pests were (Withers, 2003). Hill & Allan (1989) estimated that control of armyworm, Mythimna separata, by Cotesia ruficrus alone saved NZ$4.5-10 million per year, but few estimates of economic benefit have been made.

Cotesia kazak and C. rubecula are very closely related to C. urabae, and were introduced to New Zealand in 1977 and 1993 for the control of H. armigera and Pieris rapae (corn earworm and white butterfly.) Both have been successful in exerting partial control over their target pest (Cameron et al., 2006; Cameron and Walker, 2002), and neither species has been reared from any non-target larva. C. rubecula has proven to be host-specific in the field, even though this could not be conclusively demonstrated in the laboratory prior to release (Cameron et al. 1995).

Could the control agent evolve to generate adverse effects? The risk that C. urabae could evolve to attack other species in the future is discussed in Section 7.1.

Because of inherent uncertainty, several of the respondents urged caution in the approval of this introduction (Appendix 1). Consultation over recent applications also raised the potential adverse effects arising from genetic manipulation (there is none, see Section 3.6), and interbreeding (see Section 8.4).

7.3.2.2 Effects on kaitiakitanga

There should be no further introduction of exotic organisms Increasing reliance upon the introduction of exotic biocontrols

Several respondents expressed a philosophical and principled opposition to the introduction of exotic organisms. This is very eloquently expressed in one extract in Appendix 1. This view is also held by many members of the general public, and is discussed further in Section 7.5. Others based opposition to introduction on the evidence of adverse effects of past introductions, but the examples provided were not of biological control agents.

GLS is new to Aotearoa, and is itself changing, or about to change the existing balance between living things. Biological control seeks to restore equilibrium by limiting the frequency and severity of the irruptions typical of this pest in its native range. C. urabae was selected as an appropriate control agent for GLS because it is functionally host-specific (section 7.1.1.1), and by definition will only occur where its host does. It is not expected to occur in native habitats except where these abut eucalypt trees. It will have a small ‘ecological footprint’, and is unlikely to significantly change relationships between organisms in native habitats (See Section 7.1.1.2).

Consultation on previous applications also raised the potential effect on taonga species. C. urabae is not expected to adversely affect populations of any native species (Section 7.1.1.3-5). Previous responses have also stressed the necessity for adequate monitoring and reporting of the effects of control agents following release. A monitoring programme is presented in Section 5.2. Concern has also been expressed about protocols for caring for the mauri and tapu associated with the transfer

and release of new organisms. Scion intends to consult with hapū in Rotorua and Manukau City to ensure that appropriate processes are agreed.

7.3.2.3 Effects on health and well-being No potential adverse effects of the proposal on human health were presented.

7.3.2.4 Effects on Te Tiriti o Waitangi

Is there Māori peer review of the application, and the release decision? The adequacy of treatment in the application of issues important to Māori will be assessed by ERMANZ staff, and the advisory group to the Authority, Ngā Kaihautū Tikanga Taiao.

Who carries the risk for adverse effects resulting from the introduction of a biological control? Whom or what will control the ‘control’ Once the Crown (in the form of its Agency ERMA) has approved release of a new organism, subsequent mitigation of any adverse effects related to the exercise of that approval will fall to the Crown.

7.3.2.5 Effects on Māori economic and iwi/hapū development

Could businesses based on local ngahere be affected if significant non-target effects became evident? Populations of the control agent are not expected to persist in the forest (See section 7.1), and so non-target effects on either ngahere or associated businesses are improbable.

7.3.3 Benefits: Respondents raised the following potential beneficial effects that might follow the introduction:

7.3.3.1 Effects on Environment One respondent stated that the introduction of C. urabae would be beneficial if it protected flowering gums which are important as food for Tui in the Manawatu. (also see Section 7.1). Introduction was also considered beneficial if this protected rata and pohutukawa, although the risk to these species is not considered to be high (Potter et al., 2005).

7.3.3.2 Effects on kaitiakitanga No particular benefits were identified

7.3.3.3 Effects on health and well-being One respondent recognised that GLS control would directly benefit Māori health, through reduced incidence of allergic reactions to caterpillars (see Section 7.2). It is not known whether this would be more or less important for Māori than for the general populace.

7.3.3.4 Effects on Te Tiriti o Waitangi No specific benefits were identified

7.3.3.5 Effects on Māori economic and iwi/hapu development One correspondent stated that forestry interests provide the resources to support local communities, including health programmes (Appendix 1). GLS threatens eucalypt forestry, and hence the sustainability and well-being of associated communities. Respondents did not provide any information on the value of eucalypt hardwood forestry to Māori communities.

7.4 Assessment of potentially significant effects on the market economy Assess the potentially significant adverse and beneficial effects on the market economy. 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 ERMA New Zealand Technical Guide on Economic risks.

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

7.4.1 Risks and costs 7.4.1.1 Biological control of GLS reduces management operations, and the incomes of pesticide retailers, applicators, and tree managers Although successful control of GLS by Cotesia urabae is likely to reduce the current demand for control operations, the magnitude of the adverse effect to contractors and operators is considered to be minimal. Auckland City Council is the only organisation currently undertaking management of gum leaf skeletoniser, or of infested trees. This work is being conducted by a single contractor, for which this is not its only work stream.

7.4.1.2 Introduced parasitoid significantly reduces populations of biological control agents for weeds, and other valued insects Consistent attack by C. urabae on biological control agents would potentially have moderate adverse effects on weed control and hence on the market economy, but this is considered to be very unlikely. Cinnabar moth (Tyria jacobaeae) is an introduced biological control agent for ragwort (Jacobaea vulgaris) but is not the key agent in that successful control (Richard Hill, pers. comm.). Cotesia urabae is capable of laying eggs in cinnabar moth larvae, although this species is significantly less attractive for oviposition than GLS (Appendix 2). No larvae successfully completed development indicating that this is not an adequate host for the parasitoid. There is no evidence that unsuccessful attack increased mortality of larvae in tests (Appendix 2). Other Lepidoptera introduced to New Zealand for biological control of weeds, are far less related to GLS than those tested, and the risk of attack to these species is minimal (see Section 7.1.1.1).

7.4.2 Benefits

7.4.2.1 Biological control of GLS leads to shorter eucalypt rotation time and higher quality wood Assuming the damage levels predicted by Journeaux (2003), the magnitude of the benefits of successful biological control of GLS would be moderate. It is likely that this control agent will provide significant benefit to the forestry industry if released in New Zealand.

The eucalypt forest estate is estimated to be 24,796 ha (MAF, 2008). At least seven Eucalyptus species are grown, almost all in the Central North Island and Southland, but E. nitens and E. fastigata predominate. The wood harvested from production forests is used primarily as chipwood and pulpwood for paper production. Eucalyptus can also be used for high value solid timber end uses such as flooring, furniture and other decorative uses, along with decking, naturally durable posts and cross-arms, retaining walls and landscape timbers. Hardwood imports valued at $20 million per annum fill many of these roles (Ian Nicholas, Scion, pers. comm., Appendix 1). Eucalypts could fill this market locally and on a sustainable basis but only if pest introductions can be controlled to a level where growth rates remain commercially viable (Dean Satchel, NZ Farm Forestry Association pers. comm., Appendix 1). The typical growing regime for trees grown for pulpwood production is a rotation of 12 years in the North Island, and 15 years in the South Island (Journeaux, 2003). Eucalypts

also have value when grown for agroforestry, bioenergy production, carbon sequestration, land treatment of waste and other uses (Nicholas, 2009).

All Eucalyptus species grown in New Zealand production forests appear to be susceptible to GLS. In Australia, episodic and widespread outbreaks of the pest have been recorded often (e.g. Berndt and Allen, in press; Farr, 2009; Brimblecombe 1962). It is common in one area of Tasmania to see Eucalyptus nitens plantations with a 40m edge zone of severely stunted and dead saplings (Potter et al., 2005). In relatively small plantations on a 12 year rotation, there is therefore definite risk of economic damage in Tasmania caused by GLS defoliation, although the exact interaction between GLS damage, environmental stresses, and production are unresolved. These outbreaks occur even in the presence of its natural enemies. Without them (Mansfield et al., 2005), we expect even greater frequency and intensity of defoliation, and proportionately greater economic losses (Journeaux, 2003) here than is known in Australia. The purpose of introducing of C. urabae to New Zealand is to regulate the pest, and to reduce the rate of spread of the pest southwards, delaying the onset of economic losses. Insect defoliation slows the growth rate of eucalypt saplings. The fiscal effect of extending the time required for trees to reach harvestable size is predicted to be a major adverse economic effect of GLS in New Zealand. Alternatively, the time to harvest could be maintained by controlling GLS larval populations below a damaging threshold using aerial application of pesticide, but with associated costs. Journeaux (2003) completed an economic assessment of the impact of GLS on production forestry in New Zealand. This analysis assumed that (Journeaux, 2003): GLS outbreaks would extend the rotation length to 14 years in the North Island, and 18 years in the South Island There would be costs of monitoring for outbreaks Alternatively, the eucalypt forest estate would be sprayed at two yearly intervals A cashflow was constructed for the standard 12 and 15 year rotations, and then adjusted for the simulated impact of GLS. The difference in Net Present Value (NPV) for eucalypt production per ha, with and without GLS, was calculated. These costs were then extrapolated across the projected range

of the pest, relative to the rate of southward spread of the pest, the gradual build up of adverse effects after first contact, and the distribution (area) of eucalypts region by region. The overall impact on the New Zealand eucalypt forest estate was calculated at $69.4 million. Prophylactic spraying of eucalypt forests to forestall GLS outbreaks and minimise rotation time would cost $40.3 million (Journeaux, 2003). Successful biological control of GLS by C. urabae would substantially or completely recoup these losses by restoring the rotation time, or removing the need for pesticide application,

Changes since 2003 in the assumptions and conditions for the cost/benefit analysis indicate that the figures may both under- and over-estimate the real value: 1. The per ha operational costs are likely to have increased since 2003. The 2003 values based on these costs may underestimate current value 2. A 2 or 5% discount rate may be more appropriate for forestry projects than the 10% rate used in this analysis (Janet Gough, ERMANZ, pers. comm.). Discount rate has a massive effect on the NPV calculated. In his sensitivity analysis conducted in 2003, Journeaux (2003) found that using a 5.6% discount rate (Govt 10-year bond rate) increased the calculated impact from $69.4 to $161.6 million. The 2003 estimate may underestimate the costs of GLS by a factor of two or more. 3. Journeaux’s (2003) model for the rate of spread and accumulation of impacts assumed that 10,000 ha of eucalypts would be affected by 2010, with maximum impact already achieved on approximately 100 ha in the Auckland region. Rate of spread appears to be on track (Table 10, Journeaux 2003), but as yet, no outbreaks have been observed. Population build-up may be slower than predicted, overestimating the value of impacts, or there may be under-reporting of effects. 4. The cost/benefit analysis was based on estimated national eucalypt forest of 46,000 ha (Journeaux, 2003) but latest statistics indicate an estate of 24,796 ha (although this estimate appears to include only those forests over 1000 ha, MAF, 2008). Part or much of this discrepancy can be ascribed to the harvest of mature eucalypt forest, without replacement (Lisa Berndt, Scion, pers. comm.). The 2003 area-based estimates of cost to eucalypt forestry may overestimate the costs of GLS by up to a half. For these reasons, predicted value of adverse effects of GLS to production forests is uncertain, but substantial.

7.4.2.2 Biological control of GLS leads to increased confidence of the forestry industry to plant eucalypt species for paper, timber, carbon sequestration and posts In addition to production forestry, Eucalyptus species that are susceptible to GLS attack are currently grown for a wide range of uses, such as agroforestry, honey production, and firewood (Nicholas, 2009; see Section 7.4.2). There is enormous potential for the development of new technologies based on eucalypt trees for land treatment of waste, extraction of biofuels and other bioenergy options, charcoal (Nicholas, 2009). Estimates of productivity per ha and potential for conversion to ethanol suggest that around 70,000 ha of plantation land would be required to provide biomass and generate sufficient ethanol for a 3.4% contribution of biofuels to total fuel consumption via a petrol-ethanol blend (http://www.scion.net.nz/Portals/0/SCIONBioenergyOptionsReport.pdf).

New Zealand is seeking forest sequestration solutions to mitigate the effects of global warming, and to meet the requirements of the Kyoto Protocols. Eucalypts are fast-growing, and accumulate carbon faster than native species or other plantation species such as radiata pine (Ian Nicholas, Scion, pers comm.). Defoliation by GLS outbreaks occur at landscape-scale and can last for several years (e.g. Farr 2009), reducing the rate of biomass accumulation and hence sequestration. Successful biological control would mitigate this effect.

Maintenance and future development of these initiatives is currently overshadowed by the imminent appearance GLS as a major pest of eucalypt trees in New Zealand. Control of GLS would increase the confidence of researchers and growers to move ahead with these exciting ideas. Even though it is likely that confidence would be increased, the magnitude of this benefit is considered to be minor because: The major driver of planting decisions will always be the economics of the system GLS is not the only pest attacking eucalypts Other sources of manageable forest biomass exist

7.4.2.3 Biological control of GLS increases potential for sustainable forest production and ability to comply with FSC certification Forest Stewardship Council (FSC) is an international standard setting organisation promoting responsible forest management (http://www.fsc.org/about-fsc.html ). FSC certification gives a

commercial advantage to eucalypt growers. There is a significant risk that resorting to pesticides for management of GLS could result in loss of FSC certification. Biological control will be a key component of any IPM strategy designed to successfully manage GLS under FSC regulation. It is likely that biological control would help maintain FSC certification, and maintenance of competitive advantage would be a minor benefit.

Spraying for GLS could also interrupt successful biological control of other key eucalypt pests, especially of Gonipterus scutellatus, Phylactaeophaga froggatti, and Paropsis charybdis (Withers, 2003).

7.4.2.4 Biological control of GLS leads to reduced GLS management costs for territorial authorities, schools, horticulturalists and forest-based effluent managers Successful biological control of GLS would limit the frequency and severity of GLS damage to amenity trees in Auckland, and largely mitigate the future losses calculated here. Journeaux (2003) found in his 2003 analysis that only 3% of the amenity trees in New Zealand were susceptible to GLS, so although this benefit is considered likely, the magnitude of the savings to land managers nationally is thought to be minor overall. The benefits from reduction in pesticide, compliance and safety costs may be minimal.

Eucalypts and other plants susceptible to GLS are used extensively in urban areas throughout New Zealand to improve climatic, air and water quality of urban areas, as well as the social and psychological well-being of urban dwellers (Journeaux, 2003). GLS threatens these values by causing defoliation, ill-thrift, and tree death. This incurs loss of public appreciation, as well as monetary costs associated with management of the pest and/or operations to maintain health and safety standards. The current expenditure on GLS management in Auckland City alone is $60-65,000 per annum (Simon Cook, Auckland City Council, pers. comm.). Amenity trees also provide the pathway by which GLS can directly affect human health (see Section 7.2).

Journeaux (2003) assessed the impact of GLS on the amenity value of these trees in two ways. The first approach assumed that spraying to control GLS across urban areas is not feasible, and so

modelled the cost of replacing the trees with species that are not susceptible to the pest. Assuming that 3% of New Zealand’s amenity tree estate comprised eucalypts, that trees would be replaced over a 15 year period, and assuming the rate of spread and impact model outlined by Journeaux (2003), the resulting NPV (10% discount rate) was $72.5 million. A second approach calculated the impact on tree amenity value, relative to the percent of trees attacked and the degree of damage. Using the same assumptions, and a moderate level of attack (20% damage) the NPV of loss of amenity value using this approach was $31.5 million.

7.4.2.5 Biological control of GLS results in healthier eucalypt trees in the environment, improving ecosystem services, landscape values, and erosion control Persistent attack by GLS would reduce the utility of eucalypts for these purposes, and successful biological control is likely to mitigate that effect. As GLS attack is likely to reduce rather than eliminate the value of eucalypts for erosion control, the magnitude of this effect is expected to be minor. Eucalypts are well suited to agroforestry and erosion control because the foliage shades pasture less than other tree species (http://www.mfe.govt.nz/publications/water/managing- waterways-jul01/case-study-15-jul01.pdf). Also see Section 7.2.

7.4.3 Overall cost benefit analysis: The benefit to the market from the introduction of C. urabae exceeds the costs even for pessimistic predictions of the outcome of this project.

Costs Except for the research and development costs, no significant direct costs to the market economy of introducing biological control of GLS were identified (Section 7.4.1). The (undiscounted) cost of introduction, management and assessment of the control agent to 2015 is $344,700 (Lisa Berndt, Scion, pers. comm.).

Benefits The monetary value of biological control lies in preventing or reducing the costs of GLS to plantation forestry and the amenity estate that were estimated by Journeaux (2003) and summarised in Sections

7.4.2.1 and 7.4.2.4. How much of that value can be realised depends on how successful C. urabae will be in managing the pest problem. Three other Cotesia species have been successfully established in New Zealand, all generating substantial control of their target pest (see Section 7.3). Table 2 estimates the potential benefits of biological control of GLS under four biological control scenarios – Total control, and 80% probability of agent establishment followed by 80, 40 or 20% mitigation of the costs likely to result from GLS damage. Costs to plantation forestry are adjusted for the revised estimate for area of eucalypt forests in New Zealand (MAF 2008, Section 7.4.2.), otherwise the assumptions are those of Journeaux (2003).

Level of Value ($M) realised through biocontrol at Value ($M) realised through biocontrol at biocontrol 5.6% discount rate 10% discount rate Plantation Forests + Forests + Plantation Forests + Forests + forests Treeby method replacement forests Treeby method replacement method method Total value of GLS 87.1 118.6 159.6 37.4 68.9 109.9 64% 55.7 75.9 102.1 23.9 44.1 70.3 40% 34.8 47.4 63.8 15.0 27.6 44.0 16% 13.9 19.0 25.5 6.0 11.0 17.6

Table 2. Potential monetary benefit accruing from four levels of biological control reducing the costs of GLS in one eucalypt forest rotation and in protection of the amenity tree estate, using two methods for estimating value of mitigation on amenity trees, and two discount rates.

Journeaux (2003) noted that an alternative to estimating the cost to the production forestry of extending rotation time was to protect the estate by prophylactic application of pesticide every two years. This appears to be economically efficient, but may have environmental and health costs (Section 7.4.2.). Table 3 presents the range of benefits of biological control if it replaced this pesticide regime in production forests.

Level of biocontrol Value ($M) of cost of pesticide Value ($M) of cost of pesticide treatment + treatment + Treeby method realised replacement method realised Total value of GLS 54.3 94.2 64% 34.8 60.3 40% 21.7 37.7 16% 8.7 15.1

Table 3. Potential benefits of biological control of GLS under three levels of control, using pesticides to prevent production losses in production forest (2008 area estimates).

The potential benefits of biological control of GLS estimated here are conservative because no account is taken of the costs of GLS to: The cost of medical events related to GLS

The value of woodlots and small farm forestry plots that are not included in the total plantation area estimated by MAF

Future economic value of eucalypts as substitutes for imported hardwoods

Future economic value of eucalypts for bioenergy and waste water treatment

Future economic value of eucalypts for carbon sequestration following the finalisation of the Emissions Trading Scheme

Benefits are also now underestimated because the costs of GLS management used by Journeaux (2003) are based on 2003 figures.

A major assumption made by Journeaux (2003) was that GLS would eventually affect all eucalypt trees in New Zealand. If only 10% of eucalypt trees were affected, one tenth of the monetary benefits of GLS biocontrol (Tables 2 and 3) would still exceed the monetary costs.

7.5 Assessment of potentially significant effects on society and communities 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 well-being both now and into the future. Also discuss any ethical or spiritual issues or considerations 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 potentially significant adverse and beneficial effects, separately.

7.5.1 Community Consultation: The applicant is acting for the Gum Leaf Skeletoniser Stakeholders Group, a group formed by MAF to oversee GLS research and management, and now managed as part of MAF Sustainable Farming Fund Project 07/042. The group itself comprises 44 representatives of three forestry organisations, six pest management and forestry companies, four regional councils, four territorial authorities and four science organisations, all of whom were invited to consult on this application. Staff of ERMANZ and DOC were consulted at the outset. Many other organisations and individuals have since been invited to consult on this proposal, including 15 Regional Councils, relevant government departments, NGOs and societies (41 groups), and interested members of the public (29 individuals). Stakeholders were from a wide variety of sectors and interest groups, including forestry, education, environment, conservation, health, farming, horticulture and bee keeping. Details of consultation with Māori can be found in Section 7.3.1. Further details of the scope of pre-application consultation and responses to consultation can be found in Appendix 1. Most issues raised are dealt with elsewhere in Section 7.

7.5.2 Risks and costs 7.5.2.1 C. urabae adds another unwanted exotic species to the NZ fauna Some feel strongly that there is no place in New Zealand for additional exotic organisms, and intentional introductions should not be permitted. This view was expressed by several respondents in consultation with Māori (see Section 7.3.2). The applicants feel that the introduction of an exotic organism to mitigate serious adverse effects caused by another is valid.

The adverse effect here is potential affront to societal attitudes. Opposition is strongly held by those who express it, but this is not a high profile issue. The effect is likely (since C. urabae is likely to establish), but the magnitude of the overall impact on society is considered to be minor.

7.5.3 Benefits:

7.5.3.1 Successful control of GLS maintains New Zealand backyards free of significant animal dangers and safeguards our traditional outdoor way of life

With the exception of spiders, bees and wasps, urban and domestic environments in New Zealand are essentially free of venomous organisms. This status is rare worldwide. GLS threatens to make backyards, schoolyards and public places less safe environments, especially for children, and especially during outbreaks (see Section 7.2). This threatens the current relatively carefree public attitude to the use of outdoor spaces for play and for leisure activities such as picnics. Even relatively low levels of attack by C. urabae would reduce the incidence of GLS and mitigate this effect. We consider this an important issue, and so the magnitude of the benefit is considered to be moderate. If C. urabae establishes, the benefit is considered to be likely.

7.5.3.2 Improved eucalypt tree health resulting from GLS control leads to healthier, better quality of eucalypts as amenity plants and shade trees for schools, campgrounds, parks etc These issues are covered in Section 7.4.2

7.5.4 Ethical issues and considerations: No ethical issues have been identified

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

Assess potentially significant adverse and beneficial effects, separately.

7.6.2 Risks: No effects have been identified

7.6.2 Benefits: No effects have been identified

7.7 Overall evaluation of adverse and beneficial effects (risks, costs and benefits) It is the role of the Authority to decide whether the beneficial 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.

The significant beneficial effects associated with the introduction of C. urabae all relate to mitigation of the adverse effects of its host through biological control. The monetary benefits devolve from

protection of the commercial value of Eucalyptus forests (Section 7.4.2.1-3) and the protection of the considerable amenity value of eucalypts and other host plants attacked by GLS (Section 7.4.2.4-9). Even pessimistic forecasts indicate that the future monetary benefits of the proposal outweigh the costs to completion (Section 7.4.3). The non-monetary benefits include the protection of the populace from erucism (Section 7.2.2), maintenance of confidence in the plantation forestry industry (Section 7.4.2.2), and the protection of the ecological value of eucalypts.

There appear to be no significant monetary costs associated with the proposal. Significant potential non-monetary risks and costs identified are the risk of damage to populations of desirable insects, especially native species, and adverse effects to ecological relationships between species (Section 7.1). Significant adverse effects to populations of native and other valued species are therefore considered unlikely because: There was no evidence that Cotesia urabae could complete development in non-target hosts, and there are strong indications that its field host-range will be restricted to its target pest (Section 7.1). If it is host-specific, the parasitoid is not expected to be found in significant numbers at any distance from populations of GLS, which in turn are largely restricted to Eucalyptus trees. Indirect adverse effects on ecological relationships are therefore expected to be highly restricted spatially (Section 7.1). No significant interactions between GLS and resident parasitoids and predators have been observed.

Consultation with Māori identified issues of cultural and spiritual significance to that community that must be taken into account (see Section 7.3). For the most part these are addressed throughout the application, but a particular concern about the possible effect of C. urabae on the inter-relatedness of all things must be taken into consideration.

The potential benefits of biological control of GLS may be under-estimated because:

Some beneficial effects (e.g. the incidence of erucism, or the appearance of ornamentals) are directly related to the number of larvae present, and even low parasitism could yield benefits. The future value of eucalypts for bioenergy, waste water treatment and Carbon sequestration have not been estimated (Section 7.5).

With climate change, areas that are currently predicted to support only one generation per year (Kriticos et al., 2007) could support two generations. In Western Australia outbreaks have been triggered by the occurrence of two consecutive warm winters, which allowed the populations to develop two generations per year rather than the usual one generation (Farr 2002).

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.

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

The risk of significant displacement of native species is considered to be negligible. Significant displacement could occur if Cotesia urabae: Caused direct damage to populations of a non-target species Directly out-competed a larval parasitoid that is already actively using GLS larvae in native habitats Indirectly influenced populations of hosts, parasitoids or predators as a result of apparent competition in native habitats.

The evidence presented in Appendix 2, and summarised in Section 7.1.1.1 indicates that C. urabae is functionally host-specific, and is very unlikely to adversely affect populations of other lepidopteran species. There is no risk of attack on species of other insect families. There appear to be no native parasitoids of GLS that could be significantly displaced by C. urabae. Risk analysis suggests that C. urabae populations will be spatially localised, and no pathways for indirect competition have been identified (sections 7.1.1.2 – 4)

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

The parasitoid will cause no deterioration in natural habitats because it will not inhabit natural habitats, it will not constitute a significant biomass in the environment, and because there seems to be no direct mechanism for the actions of this parasitoid to result in habitat deterioration

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

The risks of adverse effects on human health and safety are negligible. Cotesia urabae has never been recorded as biting or stinging people. Unlike flies or other nuisance insects, braconid wasps are unlikely to be attracted to human activities and cause a nuisance. On the contrary, control of the pest by this parasitoid would have significant beneficial effects to human health through reduction in the incidence of erucism (see Section 7.2).

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.

The introduction of Cotesia urabae to New Zealand would not significantly affect inherent genetic diversity. This adverse effect would result only if the parasitoid: 1. Caused extinction of a non-target host, or 2. Compromised native genomes by successfully hybridising with a native species.

As outlined in Section 8.1, this parasitoid is functionally host specific, and will not adversely affect populations of any other insect.

There is no reason to suggest that C. urabae could hybridise with other Cotesia species if released in New Zealand (Section 7.1). Austin and Allen (1989) clearly distinguish C. urabae from other Cotesia species known in Australia. Andy Austin (University of Adelaide, pers. comm., Appendix 1), states that a number of ecological and biological limitations make successful hybridisation with native Cotesia species in New Zealand improbable because: - members of this genus are often highly host specific

- they utilise specific polydnaviruses to overcome host immune defences

- C. urabae is associated with a eucalypt feeding host and probably utilises eucalypt associated chemicals in host finding

- It has not been recorded from any other lepidopteran larvae feeding on eucalypts

- It is probably very distantly related to any native Cotesia species.

- Although there are host specific strains in some Cotesia species, hybridisation (as far as he knows), is very rare and restricted to very closely related species – i.e. it is known in the C. flavipes complex.

8.5 Causing disease, being parasitic, or becoming a vector for disease State (with reasons) whether the new organism(s) 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.

Cotesia urabae is not a disease forming organism. It is not expected to be parasitic on any other lepidopteran species, and there is no risk of parasitism of any other family of insect or organism.

The parasitoid will vector a polydnavirus specific to itself to any larvae into which it deposits an egg, in order to suppress the host’s immune response to the parasitoid’s larva. Other transovariole disease organisms within C. urabae could be vectored in this way, but none are known.

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.

Importation of this species will be subject to an import permit to be issued by MAF under the Biosecurity Act 1993, and permission to release from containment will be subject to fulfilment of the conditions of that permit. Export from Tasmania was with the written approval of the Department of Primary Industry. No formal permit was required.

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

This parasitoid has not previously been considered for release as a biological control agent in any jurisdiction

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

No further information to be presented.

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

Abdomen hind section of an insect‟s body Adventive not native, introduced Apparent competition Competition between two species that are both preyed upon by the same predator. For example, species A and species B are both prey for predator C. The increase of species A will cause the decrease of species B because the increase of A‟s would increase the number of predator C‟s which in turn would hunt more of species B Arctiine pertaining to the subfamily Arctiinae of the moth family Noctuidae Assessment measuring impacts of biocontrol agents Biological control the use of one living organism to control another Biomass the bulk of biological material Braconid belonging to the parasitoid family Braconidae Containment held in a MAF approved facility without significant risk of escape Cultivar a horticultural form of a species

Dispersal the process by which populations spread out Dorsal relating to the upper surface Dorso-ventral from the back side to the front side Ecosystem a word to describe all of the interactions between organisms and their environment Endemic naturally occurring in an area but nowhere else Erucism allergic skin reaction to venom from the spines or hair of a caterpillar et al. and others Family a natural grouping of tribes or subfamilies Fecundity total egg production Genus (plural genera) a natural grouping of related species Habitat the environmental or ecological area within which an organism lives Herbivore feeds on plants Host range the range of organisms that a biological control agent can feed and reproduce on Host specificity testing testing to find out the host range of a potential biological control agent Hybridisation interbreeding of two species. Successful hybrids produce fertile offspring Hymenopteran belonging to the Hymenoptera (wasp families) Hyperparasitoid parasitoid of a parasitoid Indices of biodiversity numbers that summarise mathematically the number and abundance of species in a habitat Indigenous native, but may also occur elsewhere. Inseparable organism organisms within another that cannot live or be extracted from it Instar growth stage of an insect (in between moults), e.g. newly hatched = first instar Invertebrate a collective term for animals without backbones Kaitiaki guardian Kanohi ki te kanohi face to face (literally eye to eye) Larva(e) juvenile stage(s) of an insect, not resembling the adult Leachates chemicals flushed out by water Lepidopterous/an pertaining to the Lepidoptera (moth and butterfly families) Lymantriine pertaining to the subfamily Lymantriinae of the moth family Noctuidae Mahinga kai loosely, sources of food Mauri life force Microgastrine pertaining to the Microgastrinae subfamily of braconid wasps Micro-organisms very small usually single celled organisms

Mymarid belonging to the Mymaridae, a family of minute wasps whose larvae live inside insect eggs. Ngāhere a Māori word for forest Noline pertaining to the subfamily Nolinae of the moth family Noctuidae Nutrient cycling the process by which minerals essential for plant health move through an ecosystem, including plant growth, plant death and decomposition, transport in water etc. Oviposition egg-laying Parasitoid an insect that feeds and develops on or within another living host invertebrate. It completes its own development on a single host, which it kills in the process. Parasitoids can be solitary or multiple (producing one or many adults per host) pers. comm. personal communication Physiological host range the range of plants on which a newly hatched control agent can complete its development, and on which the resulting adults can lay eggs Rongoa traditional healing based on indigenous plants Silviculture the cultivation of forest trees Species a morphologically, behaviourally, or ecologically distinct group of individuals that can only breed successfully with its own kind Species richness the number of species present Takiwa Māori tribal district Thorax the part of the body between the head and the abdomen of an insect Tribe a natural grouping of genera Trophic web the feeding relationship between various species living together in one area, the interaction of plants, herbivores, their parasitoids, predators and diseases Uni/bi/multivoltine having one/two/many generations per year Urticating causing inflammation or itching Vector an animal that carries a disease from one organism to another

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 along with the cover page of the book.

Appendix 1 Consultation with the community prior to application

Appendix 2 Risks to non-target species from potential biological control agent Cotesia urabae against Uraba lugens in New Zealand

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.

Allen GR. 1990a. Uraba lugens Walker (Lepidoptera: Noctuidae): Larval survival and parasitoid biology in the field in South Australia. Journal of the Australian Entomological Society 29: 301-312. Allen GR. 1990b. The phenologies of Cotesia urabae, Dolichogenidea eucalypti (Hymenoptera: Braconidae) and their host Uraba lugens (Lepidoptera: Noctuidae) in the Adelaide region. Australian Journal of Zoology 38: 347-62. Allen GR & Keller MA. 1991. Uraba lugens (Lepidoptera: Noctuidae) and its parasitoids (Hymenoptera: Braconidae): temperature, host size and development. Environmental Entomology 20: 458-469. Austin AD & Allen GR. 1989. Parasitoids of Uraba lugens Walker (Lepidoptera: Noctuidae) in South Australia, with description of two new species of Braconidae. Transactions of the Royal Society of South Australia 113:169-184. Berndt LA. Submitted manuscript. Will competition from Meteorus pulchricornis (Wesmael) (Hymenoptera: Braconidae) limit the success of the potential biocontrol agent Cotesia urabae Austin & Allen (Hymenoptera: Braconidae). Submitted to Australian Journal of Entomology, November 2009. Berndt LA, Mansfield S & Withers TM. 2007. A method for host range testing of a biological control agent for Uraba lugens. New Zealand Plant Protection 60: 286-290. Berndt LA & Withers TM. 2009. Challenges in assessing risk posed by new forestry incursions: Uraba lugens as a case study. In: IUFRO International Forest Biosecurity Conference Popular Summaries (compilers M Richardson, C Hodgson & A Forbes) pp. 37-40. NZFRI Bulletin No 233. Berndt LA & Allen GR. In press. The biology and pest status of Uraba lugens (Walker (Lepidoptera: Nolidae). Submitted to Australian Journal of Entomology. Berndt LA, Withers TM, Mansfield S, Hoare RJB. 2009. Non-target species selection for host range testing of Cotesia urabae. New Zealand Plant Protection 62: 168-173. Berry JA. 1997. The nomenclature of the microgastrine braconid genus Apanteles (s.l.) (Hymenoptera: Braconidae) in New Zealand. New Zealand Entomologist 20: 49-50. Berry JA & Mansfield S. 2006. Hyperparasitoids of the gum leaf skeletoniser, Uraba lugens Walker (Lepidoptera: Nolidae), with implications for the selection of a biological control agent for Uraba lugens in New Zealand. Australian Journal of Entomology 45: 215-218. Brimblecombe AR 1962. Outbreaks of the eucalypt skeletoniser. Queensland Journal of Agricultural Science 19: 209- 217. Cameron PJ, Hill RL, Bain J & Thomas WP (Eds) A review of biological control of invertebrate pests and weeds in New Zealand, 1874-1987. CABI Technical Communication 10. Cameron PJ, Walker GP & Keller M. 1995. Introduction of Cotesia rubecula, a parasitoid of white butterfly. Proceedings of the 48th New Zealand Plant Protection Conference: 345-347. Cameron PJ & Walker GP. 2002. Field evaluation of Cotesia rubecula (Hymenoptera: Braconidae), an introduced parasitoid of Pieris rapae (Lepidoptera: Pieridae) in New Zealand. Environmental Entomology 31: 367-374. Cameron PJ, Walker GP, Herman TJB & Wallace AR. 2006. Incidence of the introduced parasitoids Cotesia kazak and Microplitis croceipes (Hymenoptera: Braconidae) from Helicoverpa armigera (Lepidoptera: Noctuidae) in tomatoes, sweet corn, and lucerne in New Zealand. Biological Control 39: 375-384. Campbell KG. 1962. The biology of Roeselia lugens (Walk.), the gum-leaf skeletoniser moth, with particular reference to the Eucalyptus camaldulensis Dehn. (red river gum) forest of the Murray River valley. Proceedings of the Linnean Society of New South Wales 87: 316-338.

Application for approval to import for release or release ER-AF-NOR-1-2 09/05 from containment any new organism including a genetically modified organism but excluding conditional Page 63 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1999 de Little DW, Foster SD & Hingston TL. 2008. Temporal occurrence pattern of insect pests and fungal pathogens in young Tasmanian plantations of Eucalyptus globulus Labill. and E. nitens Maiden. Papers and Proceedings of the Royal Society of Tasmania 142:61-69. Derraik J. 2006. Erucism in New Zealand: exposure to gum leaf skeletoniser (Uraba lugens) caterpillars in the differential diagnosis of contact dermatitis in the Auckland Region. Journal of the New Zealand Medical Association 119(1241), https://www.nzma.org.nz/journal/119-1241/2142/ (accessed 12 June 2009). Derraik J. 2007. Three students exposed to Uraba lugens (gum leaf skeletoniser) caterpillars in a west Auckland school. New Zealand Medical Journal 120, mo 1259, 2p. Farr JD 2002. Biology of the gumleaf skeletoniser, Uraba lugens Walker (Lepidoptera: Noctuidae), in the southern jarrah forest of Western Australia. Australian Journal of Entomology 41: 60-69. Farr JD, Swain D & Metcalf F. 2004. Spatial analysis of an outbreak of Uraba lugens (Lepidoptera: Noctuidae) in the southwest of Western Australia: does logging, vegetation type or fire influence outbreaks? Australian Forestry 67: 101-110. Farr JD. 2009. Gumleaf skeletoniser in the jarrah forest. Department of Environment and Conservation, Western Australia, Science Division, Information Sheet 12/2009, 2p. http://www.dec.wa.gov.au/component/option,com_docman/Itemid,1/gid,3483/task,doc_download/. Gibb AR, Suckling DM, Fielder S, et al. 2008. Major Sex Pheromone Components of the Australian Gum Leaf Skeletonizer Uraba lugens: (10E,12Z)-Hexadecadien-1-Yl Acetate and (10E,12Z)-Hexadecadien-1-ol. Journal of Chemical Ecology 34: 1125-1133. Godfray, HCJ. 1996. Parasitoids: Behavioural and Evolutionary Ecology. Princeton University Press. (selected passages). Gous SF & Richardson B. 2008. Stem injection to control herbivorous insects on Eucalyptus nitens. New Zealand Plant Protection 61: 174-178. Hill MG & Allan DJ. 1989. Mythimna separata (Walker), cosmopolitan armyworm (Lepidoptera: Noctuidae). P 107- 109 in Cameron PJ, Hill RL, Bain J & Thomas WP (Eds) A review of biological control of invertebrate pests and weeds in New Zealand, 1874-1987. CABI Technical Communication 10. Journeaux P. 2003. Economic assessment on the impact of the gum leaf skeletoniser, Uraba lugens in New Zealand. Ministry of Agriculture and Forestry. 27 pp. http://www.biosecurity.govt.nz/pests-diseases/forests/gum-leaf- skeletoniser/ecomomic-impact-assessment (accessed 18 May 2009). Kriticos DJ, Potter KJB, Alexander NS, Gibb AR & Suckling DM. 2007. Using a pheromone lure survey to establish the native and potential distribution of an invasive Lepidopteran, Uraba lugens. Journal of Applied Ecology 44: 853-863 Lafontaine JD & Fibiger M. 2006. Revised classification of the Noctuoidea (Lepidoptera) Canadian Entomologist 138: 610-635. MAF. 2008. National Exotic Forest Description (at 1 April 2008). http://www.maf.govt.nz/mafnet/publications/nefd/national-exotic-forest-2008/2008-nefd-contents.pdf Mansfield S, Kriticos DJ, Potter KJB & Watson MC. 2005. Parasitism of gum leaf skeletoniser (Uraba lugens) in New Zealand. New Zealand Plant Protection 58:191-196. Mansfield S, Withers TM, Gous SF, et al. 2006. Potential of selective insecticides for managing Uraba lugens (Lepidoptera: Nolidae) on eucalypts. Journal of Economic Entomology 99: 780-789. National Rural Fire Authority. Fire management for small forests. Page 4.Nicholas I. Accessed 2009. Best Practice with Farm Forestry Timber Species, no 2, Eucalypts. New Zealand Farm Forestry Association electronic handbook series, 16p.

Nicholas I. 2009. Identification of potential co-products from short-rotation crops grown as an energy source. Technical Review no. 2. IEA Bioenergy, Task 30. Short Rotation Crops for Bioenergy Systems. 19 p. Parr R. 2009. Host range and biology of the Uraba lugens parasitoid Cotesia urabae in Tasmania. Unpublished report to Scion, 14p. Potter K, Kriticos D, Watt M, Watson M, Withers T & Mansfield S. 2005. Uraba lugens (Nolidae): Impact assessment studies 2004/2005. Ross M. 2003. Gum leaf skeletoniser long-term management approved. Biosecurity 47: 8. Van Driesche, R.G., Murray, T.J., 2004. Overview of testing schemes and designs used to estimate host ranges. In: Van Driesche, R.G., Reardon, R., Eds.), Assessing host ranges for parasitoids and predators used for classical biological control: a guide to best practice. Forest Health Technology Enterprise Team, USDA Forest Service, Morgantown, West Virginia, USA, pp. 68-89. van Lenteren, J.C., Cock, M.J.W., Hoffmeister, T.S., Sands, D.P.A., 2006. Host specificity in arthropod biological control, methods for testing and interpretation of the data. In: Bigler, F., Babendreier, D., Kuhlmann, U., Eds.), Environmental impact of invertebrates for biological control of arthropods: methods and risk assessment. CABI Publishing, Wallingford, UK, pp. 38-63. Whitfield, JB 2000. Phylogeny of microgastroid braconid wasps, and what it tells us about Polydnavirus evolution. Pp. 94-105 in AD Austin & M Dowton (Eds) Hymenoptera: Evolution, Biodiversity and Biological Control. CSIRO Press: Canberra, Australia, 468p. Withers, T. 2003. The potential for biological control of Uraba lugens (Nolidae). Contract report for MAF, Forest Research, Rotorua

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”.

As part of a MAF Sustainable Farming Fund project, the Gum Leaf Skeletoniser Stakeholder Group (represented by Scion, formerly the New Zealand Forest Research Institute Ltd.) wishes to introduce a parasitoid from Australia that attacks and kills GLS larvae. The purpose of the introduction is to both reduce the number of caterpillars in New Zealand each year, and to reduce the frequency of future outbreaks.

Cotesia urabae is a small (3mm) black parasitoid in the wasp family Braconidae. Adults lay eggs into small caterpillars, and after developing, a single larva emerges through the side of the caterpillar to pupate, killing the host. It has several generations per year, and each female can carry up to 400 eggs.

Successful biological control would reduce GLS caterpillar numbers, reduce the number of encounters between humans and caterpillars, and so reduce the incidence of allergic responses. Successful biological control of GLS would have economic benefits by reducing the substantial costs associated with: Extension of rotation time caused by periodic defoliation of eucalypt plantations Maintaining the utility of eucalypts for wood and pulp production Maintaining the utility of eucalypts for novel biofuel production and carbon sequestration Reducing the costs of protecting or replacing amenity trees The risks, costs and benefits identified and addressed in the application were identified by contacting 160 Iwi, hapū and individuals belonging to the ERMA Māori National Network, and 149 other respondents

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/No If “yes”, state amount: $………. Direct credit made to ERMA bank account: Yes If „yes” give date of DC …/…/… and amount: $18,000 Application signed and dated Yes Electronic copy of application e-mailed to ERMA New Zealand Yes

*NA – not applicable † The cost of the application (our fee) can be found on our web site under new organism applications.

Signed: Date: