APPLICATION FORM Release

To obtain approval to release new organisms (Through importing for release or releasing from containment)

Send to Environmental Protection Authority preferably by email ([email protected]) or alternatively by post (Private Bag 63002, Wellington 6140) Payment must accompany final application; see our fees and charges schedule for details.

Figure 1. Tree privet displacing coastal pohutukawa forest.

Application Number

APP202262

Date

13 January 2015

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Application Form Approval to release a new organism

Completing this application form

1. This form has been approved under section 34 of the Hazardous Substances and New Organisms (HSNO) Act 1996. It covers the release without controls of any new organism (including genetically modified organisms (GMOs)) that is to be imported for release or released from containment. It also covers the release with or without controls of low risk new organisms (qualifying organisms) in human and veterinary medicines. If you wish to make an application for another type of approval or for another use (such as an emergency, special emergency, conditional release or containment), a different form will have to be used. All forms are available on our website. 2. It is recommended that you contact an Advisor at the Environmental Protection Authority (EPA) as early in the application process as possible. An Advisor can assist you with any questions you have during the preparation of your application including providing advice on any consultation requirements. 3. Unless otherwise indicated, all sections of this form must be completed for the application to be formally received and assessed. If a section is not relevant to your application, please provide a comprehensive explanation why this does not apply. If you choose not to provide the specific information, you will need to apply for a waiver under section 59(3)(a)(ii) of the HSNO Act. This can be done by completing the section on the last page of this form. 4. Any extra material that does not fit in the application form must be clearly labelled, cross- referenced, and included with the application form when it is submitted. 5. Please add extra rows/tables where needed. 6. You must sign the final form (the EPA will accept electronically signed forms) and pay the application fee (including GST) unless you are already an approved EPA customer. To be recognised by the EPA as an ‘approved customer’, you must have submitted more than one application per month over the preceding six months, and have no history of delay in making payments, at the time of presenting an application. 7. Information about application fees is available on the EPA website. 8. All application communications from the EPA will be provided electronically, unless you specifically request otherwise. Commercially sensitive information

9. Commercially sensitive information must be included in an appendix to this form and be identified as confidential. If you consider any information to be commercially sensitive, please show this in the relevant section of this form and cross reference to where that information is located in the confidential appendix. 10. Any information you supply to the EPA prior to formal lodgement of your application will not be publicly released. Following formal lodgement of your application any information in the body of this application form and any non-confidential appendices will become publicly available.

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Application Form Approval to release a new organism

11. Once you have formally lodged your application with the EPA, any information you have supplied to the EPA about your application is subject to the Official Information Act 1982 (OIA). If a request is made for the release of information that you consider to be confidential, your view will be considered in a manner consistent with the OIA and with section 57 of the HSNO Act. You may be required to provide further justification for your claim of confidentiality. Definitions

Restricting an organism or substance to a secure location or facility to prevent Containment escape. In respect to genetically modified organisms, this includes field testing and large-scale fermentation

Any obligation or restrictions imposed on any new organism, or any person in relation to any new organism, by the HSNO Act or any other Act or any Controls regulations, rules, codes, or other documents made in accordance with the provisions of the HSNO Act or any other Act for the purposes of controlling the adverse effects of that organism on people or the environment

Any organism in which any of the genes or other genetic material:  Have been modified by in vitro techniques, or Genetically Modified  Are inherited or otherwise derived, through any number of replications, from Organism (GMO) any genes or other genetic material which has been modified by in vitro techniques

As defined in section 3 of the Medicines Act 1981 Medicine http://www.legislation.govt.nz/act/public/1981/0118/latest/DLM53790.html?src=qs

A new organism is an organism that is any of the following:  An organism belonging to a species that was not present in New Zealand immediately before 29 July 1998;  An organism belonging to a species, subspecies, infrasubspecies, variety, strain, or cultivar prescribed as a risk species, where that organism was not present in New Zealand at the time of promulgation of the relevant regulation;  An organism for which a containment approval has been given under the HSNO Act;  An organism for which a conditional release approval has been given under the HSNO Act;  A qualifying organism approved for release with controls under the HSNO New Organism Act;  A genetically modified organism;  An organism belonging to a species, subspecies, infrasubspecies, variety, strain, or cultivar that has been eradicated from New Zealand;  An organism present in New Zealand before 29 July 1998 in contravention of the Animals Act 1967 or the Plants Act 1970. This does not apply to the organism known as rabbit haemorrhagic disease virus, or rabbit calicivirus A new organism does not cease to be a new organism because:  It is subject to a conditional release approval; or  It is a qualifying organism approved for release with controls; or  It is an incidentally imported new organism

Qualifying Organism As defined in sections 2 and 38I of the HSNO Act

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Application Form Approval to release a new organism

To allow the organism to move within New Zealand free of any restrictions other Release than those imposed in accordance with the Biosecurity Act 1993 or the Conservation Act 1987

As defined in section 2 of the Biosecurity Act 1993 Unwanted Organism http://www.legislation.govt.nz/act/public/1993/0095/latest/DLM314623.html?src= qs

As defined in section 2(1) of the Agricultural Compounds and Veterinary Medicines Act 1997 Veterinary Medicine http://www.legislation.govt.nz/act/public/1997/0087/latest/DLM414577.html?sear ch=ts_act%40bill%40regulation%40deemedreg_Agricultural+Compounds+and+ Veterinary+Medicines+Act+_resel_25_a&p=1

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Application Form Approval to release a new organism

1. Applicant details

1.1. Applicant

Company Name: Waikato Regional Council

Contact Name: Darion Embling

Job Title: Biosecurity Officer

Physical Address: 401 Grey Street, Hamilton

Postal Address: Private Bag 3038, Waikato Mail Centre, Hamilton 3240

Phone (office and/or mob): 07 859 0999

Fax: 07 859 0998

Email: [email protected]

1.2. New Zealand agent or consultant (if applicable)

Company Name: Richard Hill & Associates

Contact Name: Richard Hill

Job Title: Principal

Physical Address: 237 Ashgrove Tce, Christchurch 8024

Postal Address (provide only if not the same as the physical):

Phone (office and/or mob): 03 332 2543 or 021 1376 919

Fax: N/A

Email: [email protected]

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Application Form Approval to release a new organism

2. Information about the application

2.1. Brief application description Approximately 30 words about what you are applying to do

An application to introduce the privet lace bug (Leptophya hospita) as a biological control agent for the weed privet (Ligustrum spp.)

2.2. Summary of application Provide a plain English, non-technical description of what you are applying to do and why you want to do it

There are four species of privet in New Zealand. Ligustrum ovalifolium and L. vulgare are naturalised but are not currently regarded as significant weeds in New Zealand. Two are considered to be serious weeds. Chinese privet (L. sinense) and tree privet (L. lucidum) are native to China and were introduced to New Zealand as ornamental plants and as hedging. Both became naturalised in New Zealand in the 1950s (Webb et al. 1988). Chinese privet and tree privet are now abundant in the North Island and are spreading. They invade native plant communities, replacing native shrubs and small trees and stopping the regeneration of native seedlings. Both are abundant in urban areas and are thought by many to cause or to worsen allergies such as hay fever and asthma.

Both privets occur in the north of the South Island but are a biosecurity issue in the North Island. Privet is named in the regional pest management strategies of nine regions from the West Coast northwards. In some regions the strategy aims to eliminate the threat, at least locally, but for most regions privet is too abundant to achieve significant reduction in pest status using conventional means. The National Biocontrol Collective represents 12 regional councils/unitary authorities and the Department of Conservation (DOC). It has determined that biological control is the most likely means of achieving environmentally acceptable and cost-effective management for privet in New Zealand. Waikato Regional Council makes this application on their behalf. Landcare Research staff provided the research described in the application. Richard Hill & Associates prepared the application and manages the application process.

Landcare Research has identified several potential control agents that could work together for control of the two privet species. This application proposes the introduction of the first agent, privet lace bug, Leptophya hospita. Lace bugs feed on leaves, and in large numbers can cause defoliation. Biological control is an appropriate tactic to use against this weed because agents are self-dispersing and can locate isolated or sparse host plants that are inaccessible to weed managers. The aim of the programme overall is to:

 Remove a significant proportion of the foliage every year, directly reducing the shading effect that causes the decline of underlying plants

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Application Form Approval to release a new organism

 Reduce the ability of plants to produce seeds that could be spread by birds  Reduce the growth, productivity and flowering of the plant, reducing any effects on allergies. Section 5 of the application explains the expected positive effects of biological control of privet, including:

 Long-term mitigation of damage to New Zealand's native ecosystems  Reduced invasion of un-infested sites, and spread within existing sites  Reduced control costs to managers of reserved land and to the general public  Improved allocation of resources necessary to maintain New Zealand’s biodiversity values  Improvements in human health. Because introduced natural enemies can become permanently established in the environment, their effects are widespread and persist from year to year. Introduced natural enemies must therefore be safe if this weed management tactic is to be environmentally acceptable. Significant adverse effects on environmental or economic values would occur if the privet lace bug attacked valued non-target plants, whether native or introduced. Privet belongs to the olive family (Oleaceae). There are only four native species in this family, but several related species have ornamental or economic value in New Zealand, including olives. Evidence presented in the application shows that native plant species and olives will not be at risk. The closest relative to privet growing in New Zealand is lilac, which is a prized ornamental species that also provides nectar for butterflies. This is not a primary host for the lace bug, but might be subject to incidental feeding damage where privet lace bugs are abundant nearby. No other ornamental species are at risk. No other adverse environmental, economic, cultural or social effects are considered significant. The potential effects on Māori cultural values are discussed in Section 4.

The data from the host range tests, an assessment of the beneficial and adverse effects of the proposal, and the results of consultation are summarised in the application, and the information on which this summary is based can be found on the Landcare Research website at http://www.landcareresearch.co.nz/science/plants-animals- fungi/plants/weeds/biocontrol/approvals/current-applications.

2.3. Background and aims of application This section is intended to put the new organism(s) in perspective of the wider activitie(s) that they will be used in. You may use more technical language but all technical words must be included in a glossary.

Background

This application seeks to introduce the privet lace bug, Leptophya hospita Drake & Poor (Tingidae). This represents the first step in a biological control programme for privet weeds in New Zealand. Conventional management methods such as herbicide application and physical removal can effectively moderate weed impacts locally (McGregor 2000), but this approach is time and resource intensive, and is not practical across the full distribution of the weed. Privet weeds grow among native vegetation and there is a high risk of non-target damage when herbicide is applied in such habitats.

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Application Form Approval to release a new organism

Effective herbicide use is restricted in urban and peri-urban areas where the effects of privet are often worst felt. Biological control is considered the most effective and sustainable option for control for privet because control agent populations can maintain themselves from year to year and act at a landscape level.

Biology and pest status

Two species of privet are weedy in New Zealand. Chinese privet (Ligustrum sinense Lour.) is a small tree that grows to 5 m high. Its leaves are dull green and it has white, heavily scented flowers from September to December. It has been naturalised in New Zealand since 1950. Tree privet (Ligustrum lucidum W.T. Aiton) is a large tree that grows up to 10 m high (Wilcox 2000). Its leaves are oval and glossy with long clusters of small, fragrant, cream-coloured flowers from November to March. Both species are common in the North Island, but particularly abundant from the Bay of Plenty northwards (Waikato Regional Council 2011). The fruits of all privets are bluish or purplish-black. Privets are particularly invasive because these fruits are consumed by birds, which spread the seed. Privet seedlings tolerate shade, and can also grow successfully in the understorey of the forest. There tree privet can replace mid-canopy trees in the forest and may completely dominate an area of forest in time (Figure 1). Chinese privet is lower in stature but can displace the shrub layer in forests. It also spreads in farm hedges, along roadsides, stream-sides, wastelands and disused railway lines and forest remnants. It is an acknowledged weed in Australia (Biosecurity Queensland 2013) and is present on some Pacific islands. It displaces the shrub layer of forests and woodlands in Argentina and has invaded river and stream floodplains, lake shores, and the edges of swamps and marshes in the south-eastern USA. Greene and Blossey (2012) report that Chinese privet occupies large areas of forest there and it is a strong driver of vegetation change, and negatively affects a range of native species (Hanula et al. 2009). In a study for the applicant, Grove and Clarkson (2005) studied a range of sites in the Waikato and found that Chinese privet was capable of forming a mono-specific canopy or sub-canopy in less than 15 years following disturbance, and contributes to a reduction in floristic diversity. They concluded that privet appeared capable of forming vast dense thickets with low floristic diversity in New Zealand in the future, just as it has in the USA (Greene & Blossey 2012).

The pollen of both species is said to cause allergies such as hay fever and asthma, but this is not a universally accepted view. Some claim that as the plant is insect-pollinated, there is no free-floating pollen to cause allergic responses. However, if the pollen is not taken away by insects, the position of the anthers allows the pollen to be dispersed by the wind, and privet pollen can indeed be abundant in air. An Australian study showed that privet pollen was among the most abundant of all airborne pollens in south-west Sydney. Furthermore, pollen of olive (Olea europaea), which is closely related to privet, is an important cause of hay fever and asthma in the Mediterranean area (McGregor 2000). Some believe the heavy scent of the flowers alone is a trigger for allergic responses to pollens of other plants. This debate is discussed further in Section 5.2.2.

Privet control is difficult because many of the sensitive habitats it invades preclude blanket spraying and make individual plants hard to find. Seedlings can be pulled or dug out, while older plants can be

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Application Form Approval to release a new organism cut down but the stumps must be treated with herbicide to prevent re-sprouting. Standing trees can also be poisoned by making a series of downward-sloping holes or cuts around the trunk and filling these with herbicide (‘stem injection’). This may be the most cost effective and safe method for herbicidal control of trees (McGregor 2000) but is labour-intensive so is not feasible over wide areas.

Potential for safe biological control

Privet is considered to be a serious weed in the USA (Greene & Blossey 2012), and the lace bug is being considered there as a biocontrol agent. Some of the information presented in this application is drawn from that programme (Zhang et al. 2011, 2012).

Once established, introduced natural enemies become permanent components of the ecosystem, and their effects are widespread and persistent from year to year. Biocontrol agents must therefore be safe to introduce, and in particular must not:

 Significantly affect populations of valued plants, whether native or non-native  Significantly displace native species in trophic webs. The ability of natural enemies to attack new hosts is strongly influenced by the evolutionary history of those potential hosts (Briese 2005), and history shows that plants closely related to the target plant are the species most likely to be damaged by control agents (Sheppard et al. 2005). It is essential to understand the relationships between the target plant and its relatives, particularly those that are economically or culturally significant. There are approximately 40 species of Ligustrum species that are native across Europe to eastern Asia and south to Queensland (Webb et al. 1988). These belong to the Oleaceae, a family that includes many economically and culturally significant trees. The only indigenous Oleaceae are four species of Nestegis: N. cunninghamii (Hook.f.) L.A.S.Johnson (maire, maire raunui, black maire), N. lanceolata (Hook.f.) L.A.S.Johnson (maire rauriki, white maire), N. montana (Hook.f.) L.A.S.Johnson (rōroro, narrow-leaved maire), and N. apetala (Vahl) L.A.S.Johnson (coastal maire). Naturalised species of Oleaceae in New Zealand, other than Ligustrum spp., include ash (Fraxinus excelsior L.), five species of jasmine (Jasminum spp.), African olive (Olea africana = Olea europaea L. subsp.cuspidata), lilac (Syringa vulgaris L.) and forsythia (Forsythia suspensa (Thunb.) Vahl (McGregor 2000). Many cultivars of these species are grown as ornamentals, and the European olive (Olea europaea L. subsp. europaea) is an increasingly important crop; conversely, the jasmines can be weedy. Lilac is the species most closely related to the privets (Landcare Research 2014e) and is a valued ornamental plant. Sections 5.1.2 and 5.3.2 present evidence from laboratory experiments that significant adverse effects on valued plants are highly unlikely, and the data on which that conclusion are based can be found on the Landcare Research website (Zhang et al. 2012; Landcare Research 2014e).

Assessment of risks, costs and benefits

The potential risks, costs and benefits of the proposed introduction to New Zealand of Leptophya hospita and the possible reduction in the abundance and vigour of privet have been identified by

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Application Form Approval to release a new organism literature review and by consultation with stakeholders (Landcare Research 2014a). The significant effects identified are addressed in Section 5. Other background information and references on which this application is based can also be found on the Landcare Research website (Landcare Research 2014 a–e). The potential effects on Māori cultural values are discussed in Section 4.

3. Information about the new organism(s)

3.1. Name of organism Identify the organism as fully as possible

Non-GMOs - Provide a taxonomic description of the new organism(s). GMOs – Provide a taxonomic description of the host organism(s) and describe the genetic modification. Both -  Describe the biology and main features of the organism including if it has inseparable organisms.  Describe if the organism has affinities (e.g. close taxonomic relationships) with other organisms in New Zealand.  Could the organism form an undesirable self-sustaining population? If not, why not?  How easily could the new organism be recovered or eradicated if it established an undesirable self-sustaining population?

Taxonomic description

Class: Insecta

Order: Hemiptera

Family: Tingidae

Genus: Leptophya

Species: hospita Drake & Poor 1937

(Drake CJ, Poor ME (1937). Tingitidae from Malaysia and Madagascar (Hemiptera). Philippine Journal of Science 62: 1–19.)

Biology and main features of the organism

Leptophya hospita is being considered as a biological control agent for Chinese privet in the USA. Zhang et al. (2011) present information about this lace bug. Both adults and young stages (nymphs) of L. hospita extract the content of privet leaf (mesophyll) cells, leading to a bleached appearance of leaves and dieback of branch tips. Insects were studied in the laboratory at 24–26°C. Females lay an average of 240 eggs (range 39–575) and continue to lay eggs until death. Adults lived 75 days on average (range for females, 27–150 days). Eggs are imbedded inside the leaf/stem tissue. The lace

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Application Form Approval to release a new organism bug has five nymphal stages, with the mean duration of the life cycle from egg to new adult being 25 days. The pre-oviposition period is 12 days (range 9–17 days). In China only adults were present on foliage in late fall and again in early spring, suggesting they overwinter as adults, possibly on the ground. Under laboratory conditions the lace bug has overlapping generations throughout the year on potted L. sinense. It is not certain how many generations would occur in the field in New Zealand, but in the field in China it is present as both immature and adult stages for 7 months from early spring. Given the observations in its native range, at least two generations are likely in New Zealand.

Species of this genus of lace bug appear to be specific to a narrow range of hosts. The recorded hosts of L. hospita in China are all species in the genus Ligustrum. There are nine Leptophya species in the United States, all of which are restricted to plants belonging to the family Oleaceae (i.e. Chionanthus, Forestiera, and Fraxinus) (Zhang et al. 2011).

Ligustrum hospita appears to be a good potential control agent for privet species because it appears to be host specific, has multiple generations per year, and a high reproductive rate. In the process of rearing lace bugs in the laboratory, an anthocorid bug was observed feeding on nymphs (Zhang et al. 2011), indicating that predation by resident hemiptera might occur in New Zealand.

Affinities of the organism

Related species Tanybyrsa cumberi is the only native tingid species known in New Zealand (Larivière & Larochelle 2004). It occurs in native habitats over a similar geographic range to privet, and is thought to feed on Astelia species. Three other tingid bugs are present in New Zealand. The exotic species Stephanitis rhododendri, which has been present in New Zealand since the 1950s, is restricted to attacking rhododendron species growing in non-native habitats. The tingid bug Gargaphia decoris was released in New Zealand in 2010 for the biological control of woolly nightshade (Solanum mauritianum) (http://www.epa.govt.nz/new-organisms/popular-no-topics/Pages/biocontrol-for-woolly- nightshade.aspx). This has established in New Zealand and has caused severe defoliation of woolly nightshade at one site; the same type of damage that Leptophya hospita could potentially cause to privet (http://www.landcareresearch.co.nz/publications/newsletters/biological-control-of- weeds/issue-69/lace-bug-does-best-in-shade)

Predators and parasitoids A small parasitic wasp (family Mymaridae) has been recorded from the eggs of Tanybyrsa cumberi (May 1977). No specimens with this host association were listed in the catalogue of New Zealand Mymaridae (Noyes & Valentine 1989), and so the identity and likely host range of this parasitoid remain uncertain. The potential for apparent competition between privet lace bug and the native tingid through shared parasitism is discussed in Section 5.1.2.

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Application Form Approval to release a new organism

Winks et al. (2012) surveyed the fauna associated with Ligustrum sinense and L. lucidum at 39 sites from Northland to Buller. Spiders were abundant at all sites and would likely prey upon lace bugs if the opportunity arose. Other species that could be regarded as potential predators of lace bugs (including predatory bugs, ants and earwigs) were relatively rare. Generalist predators identified during this survey could affect lace bug population dynamics, but the ability of such species to build large populations (make a numerical response) in the presence of abundant lace bugs is uncertain.

Could the organism form an undesirable self-sustaining population?

The object of introducing the privet lace bug is to establish a self-sustaining population contributing to the suppression of Chinese and tree privet populations anywhere in New Zealand. No populations of the lace bug established here are expected to be undesirable because it will not adversely affect native plants, it is not expected to have any other significant adverse environmental effects, nor to remove options for growing ornamental plants for sale (see Sections 5.3 and 5.4).

Ease of eradication of an undesirable population

Not Applicable

3.2. Regulatory status of the organism

Is the organism that is the subject of this application also the subject of:

An innovative medicine application as defined in section 23A of the Medicines Act 1981?

No

An innovative agricultural compound application as defined in Part 6 of the Agricultural Compounds and Veterinary Medicines Act 1997?

No

4. Māori engagement

Discuss any engagement or consultation with Māori undertaken and summarise the outcomes. Please refer to the EPA policy ‘Engaging with Māori for applications to the EPA’ on our website (www.epa.govt.nz) or contact the EPA for advice.

Members of the National Biocontrol Collective plan to submit seven applications to EPA over the next 18 months to introduce control agents to assist in the pest management of seven environmental and agricultural weeds. Māori views on these proposals have been sought by four routes:

1. Consultation with members of Te Herenga

2. Consideration of issues raised in previous similar applications

3. Consideration by a reference group

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4. Ongoing consultation at a regional level.

Consultation with Te Herenga

The EPA's national network Te Herenga comprises approximately 80 iwi, hapū or Māori organisation representatives with national geographic coverage. In accordance with EPA advice, information about each of the applications was distributed to members of Te Herenga in August 2014 inviting dialogue and feedback on all seven proposals. The network will be contacted again 4 weeks before the submission of each application.

The information disseminated to Te Herenga described how the applicant intended to assess the risks, costs and benefits associated with the proposed introductions and invited members to identify any issues they would like to have addressed in the applications. The seven proposals include the release of agents to manage privet, Japanese honeysuckle, moth plant, Lagarosiphon major (a water weed), old man’s beard, wild ginger and field horsetail.

No responses have been received concerning the proposed introduction of privet lace bug. With one exception, no benefits to Māori have been identified over and above benefits to New Zealand as a whole. The restoration of Hikuai Ti Kouka Reserve was first initiated by Ngāti Hei who have plans to restore the site. The Tairua catchment is of great significance to Ngāti Hei as there are traditional travel routes and six pa sites within 1 km of the restoration site (Andy Wills, Waikato Regional Council, Hikuai Ti Kouka Reserve, pers. comm.). …When we initially kicked off the control we controlled a 1.5-hectare area of privet, convolvulus and honeysuckle but mainly privet, using a 14-tonne excavator with a mulching head on it. The cost was $10,000. Another 1.5-hectare area was controlled the following year for the same cost. It should be noted that we were controlling large trees, some up to 4 metres in height, in areas [where] there was very little native. The rest of the privet control has been a lot more selective. Some areas have been sprayed, others controlled via cut and paste so as not to damage the native vegetation. The Hikuai Reserve is a total area of 13 hectares in size. This financial year we will be looking at selectively controlling the privet over an approximate 8-hectare area; the contractor has quoted $6,500 for controlling just the privet. Even after this control I imagine we would spend at least $5,000 each year for the next few years to get on top of the privet, over the 13-hectare area. It should be noted we have used native plants and planted grass as a tool to suppress the privet; this is also effectively a cost to controlling the privet.

Members of Te Herenga will also be specifically informed by the EPA when each application is open for public submission, and will be able to comment on how the applicant has addressed issues raised during consultation.

Issues raised in previous consultations

Privet has not been the target for biological control in New Zealand before, and there are no additional communications that relate directly to this proposal. However, this application is similar to other applications to introduce new insects submitted over the last seven years. Communication with Māori over these applications has produced comments that are relevant here. These have been summarised on the Landcare Research website (Landcare Research 2014c). The key areas identified in consultations over this period are:

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 Possible direct effects on native plant species (see Section 5.1.2)  Possible indirect effects on native flora and fauna, and other valued species (see Sections 5.1.2, 5.3.2)  The need to monitor future effects (see Section 7)  Predictability of effects (see Section 5.1.2)  Specific benefits to Māori (see above)  Effects on cultural and spiritual values (see below)  Integration of control methods, and indigenous solutions  Herbicides and biological control  Aversion to the introduction of new organisms  Lack of capacity precludes comment

Restoration forms part of an integrated strategy for fighting privet in New Zealand (Section 5.3.1), along with surveillance, eradication and containment where DOC, regional councils and other weed managers see these strategies as appropriate. However, privet affects environmental values beyond the physical reach of human intervention, and biological control is the last available tactic in such places. Surveys of the natural enemies of privet in New Zealand found no native species that were damaging to the weed (Winks et al. 2012). No indigenous solutions to the problem are known. A strong theme in submissions on previous applications concerning biological control has been recognition that biocontrol could reduce herbicide loads in the environment. Like the general public, some Māori do not agree with the deliberate introduction of any new organisms.

Māori Reference Group

Given the suite of applications, the applicant requested the support of the EPA to convene a Māori reference group (MRG) to discuss the potential issues of significance to Māori surrounding the proposed applications. The MRG is made up of four members with expertise and/or experience relevant to the proposals and they will be compiling a report to consider potential Māori interests across the breadth of the proposals. They are not appointed to represent specific iwi interests. After undertaking a review of the information available to date on the proposals, the MRG identified a number of initial draft principles or themes that apply to biological control proposals generally (Landcare Research 2014b). This is regarded as a living document and will be updated on the website as the principles are developed further by the MRG. The key principles identified so far include:

 Kaitiakitanga responsibility of Māori to manage natural resources within and beyond hapū and iwi boundaries  Whakapapa as the foundation for kaitiakitanga, and the need to consider the potential impacts of biocontrol agents across the breadth of trophic and ecosystem levels  Requirement for applicants to provide comment and/or data to evaluate potential impacts  Need to define the regional scope of effects, and effectively consider effects on iwi and hapū at a local level

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 Desirability of making vegetation restoration an integral component of biocontrol  Demonstration of the potential benefits to native species With reference to the initial draft principles, the MRG specifically noted that the proposed introduction of privet lace bug may have significant direct beneficial effects on culturally valued species, and indirect benefit to the wider native ecosystem. The MRG also noted that the host range testing and taxonomic analysis provide some assurance that the risks of non-target feeding on valued plants and hybridisation with native species are likely to be minimal.

The reference group noted that

1. Privet threatens the shrub and herb layer of the ngahere, the source of many plants used for rongoa.

2. The presence of weeds like privet within the margins of the ngahere adversely affects our appreciation of the forest environment

3. Privet produces allelopathic chemicals that wash off the leaves and can suppress plants beneath (see Section 5.1). The fate of these chemicals in soil and water is uncertain, but they are not natural in the forest environment

Regional consultation

Waikato Regional Council is informing its own iwi liaison network about this application. The network has been asked to facilitate and collate information about hapū and iwi interests and priorities, especially those related to any pest management priority agreements or Treaty of Waitangi settlement responsibilities. This dialogue is expected to continue through the development of the agent and initial releases.

No feedback has yet been received via this route. Any issues brought to the attention of the applicant will be made available to EPA, for consideration by the decision-making committee.

5. Risks, costs and benefits

Provide information of the risks, costs and benefits of the new organism(s). These are the positive and adverse effects referred to in the HSNO Act. It is easier to regard risks and costs as being adverse (or negative) and benefits as being positive. In considering risks, cost and benefits, it is important to look at both the likelihood of occurrence (probability) and the potential magnitude of the consequences, and to look at distribution effects (who bears the costs, benefits and risks). Consider the adverse or positive effects in the context of this application on the environment (e.g. could the organism cause any significant displacement of any native species within its natural habitat, cause any significant deterioration of natural habitats or cause significant adverse effect to New Zealand’s inherent genetic diversity, or is the organism likely to cause disease, be parasitic, or become a vector for animal or plant disease?), human health and safety, the relationship of Māori to the environment, the principles of the Treaty of Waitangi, society and the community, the market economy and New Zealand’s international obligations.

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You must fully complete this section referencing supporting material. You will need to provide a description of where the information in the application has been sourced from, e.g. from in-house research, independent research, technical literature, community or other consultation, and provide that information with this application.

The potential risks, costs and benefits were identified by literature review, by public consultation and by review of issues raised in the last 11 applications to ERMA/EPA to introduce biocontrol agents for weeds. All effects identified during this process are listed on the Landcare Research website (Landcare Research 2014a). Those effects considered to be potentially significant are highlighted on that list, and only those effects are addressed here (Section 5).

The effects are associated with:

1. The proposed introduction to New Zealand of the control agent Leptophya hospita

2. The proposed reduction in the abundance and vigour of privet species

5.1 Potential effects on the environment

5.1.1 Potential beneficial effects on the environment The introduction of Leptophya hospita would benefit the environment if feeding by nymphs and adults caused defoliation of Chinese and/or tree privet that:

 Maintained regeneration of native seedlings and conserved plant and animal biodiversity in native habitats by reducing the shade cast by privet in native habitats  Limited the displacement of native undergrowth and trees currently growing in affected habitats, by reducing growth rate of privet  Limited the spread and establishment of privet by reducing fruit production. Chinese privet has invaded over one million forested hectares over a wide latitudinal range of the USA, especially in the south-east (Greene & Blossey 2012). A range of studies there have shown that Chinese privet has a negative effect on native biodiversity at both local and landscape levels. In a study of 12 field sites in South Carolina, Greene and Blossey (2012) showed that L. sinense was a strong driver of vegetation change, and that, once established, it could reduce or eliminate remaining native plant diversity at those sites and prevent recovery of the forest. Exclusion of light appeared to be the mechanism by which privet reduced growth and survival of other seedlings.

Chinese privet has been naturalised in the USA for much longer than in New Zealand, and invasion into sensitive habitats is further advanced there. However, Chinese privet appears to be on the same ecological trajectory in New Zealand. Grove and Clarkson (2005) undertook a study of the ecology of Chinese privet in several forest types in the Waikato Region. They found that privet persisted in relatively deep shade, and negatively influenced plant species richness in the forest understorey. It was able to form a monospecific canopy or subcanopy in less than 15 years following disturbance of the native understorey. Seedlings also established under intact forest cover but at a slower rate. This dominance was achieved by shading of competing seedlings, but there was some evidence of allelopathy (chemical suppression of other seedlings). Privet seedlings were abundant under a

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Chinese privet canopy, and from this, coupled with observations of reduced native biodiversity, they concluded that (as in the USA) privet was able to persist in shade and arrest forest succession. Tree privet has been observed growing over 15 m tall; overtopping mature canopy trees (DOC 2014), and has a ‘weediness score’ of 32 (out of 36), an even higher score than Chinese privet (25).

In Australia, privet seedlings growing in dense shade can survive long periods of unfavourable conditions such as low light and water shortage. Growth under these conditions is restricted, but faster than that of the surrounding vegetation, particularly in low light. These young privets can also outnumber native species by ratios of several hundred to one; and when growth accelerates with any increase in light (due to activities such as weeding or clearing), the young privets rapidly become dominant (NSW 2010).

The Department of Conservation reports that privet species are known to occur on at least 30 national priority ecological management units, and in 70 other reserved areas (DOC 2014). Occurrence may well be under-reported. In the Waikato Region it is found in sensitive wetlands, and nationally it occurs in a range of habitats that are naturally rare in New Zealand. It threatens restoration projects (see Section 5.3.1), and occurs at several sites where nationally critically threatened plants grow (DOC 2014). Privets fruit heavily and can be spread long distances by birds. Privet saplings have been observed invading regenerating mānuka bush from roadside infestations several kilometres away (DOC 2014).

The current response to these threats is discussed further in Section 5.3.2.

Although the literature implicates privet as a cause of biodiversity loss (e.g. references in Greene & Blossey 2012), Blanchon et al. (2011) unexpectedly found no loss of beetle diversity under tree privet compared with regenerating forest in Auckland. They concluded that site management tactics may have conserved beetle species.

The New Zealand Plant Conservation Network undertook a poll of its members in 2012 to identify New Zealand’s 10 worst weeds. Tree privet was voted seventh (Trilepidea, e-newsletter 110).

Conventional control methods can ameliorate the threat of privet in high value urban reserves, but at high cost (see Section 5.3.2). Successful biological control would complement or replace existing control efforts, and also reduce environmental effects of privet currently inaccessible to managers.

Zhang et al. (2011) found the privet lace bug to be abundant in its native range, often causing heavy bleaching of privet leaves and premature defoliation. This effect could be greater in New Zealand because, in the absence of its specialist natural enemies, lace bug populations could be greater than in its native range.

Feeding by other lace bugs is capable of causing severe leaf-fall in host plants (http://www.landcareresearch.co.nz/publications/newsletters/biological-control-of- weeds/issue-69/lace-bug-does-best-in-shade; Bain 2007), and the lantana lace bug, Teleonemia scrupulosa, has contributed to biological control of Lantana camara in several parts of the world (Broughton 2000).

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5.1.2 Potential adverse effects on the environment The establishment of L. hospita in New Zealand would have adverse effects on the environment if feeding by adults and nymphs:

 Reduced populations of native plants  Interfered significantly with trophic webs. Biological control of Chinese privet and tree privet would have adverse effects if it:

 Facilitated the establishment of worse weeds  Significantly reduced the food supply for native birds.

Native plant populations Laboratory tests were conducted in the USA (Zhang et al. 2012) and in containment in New Zealand (Landcare Research 2014e) to determine which plants could be used by Leptophya hospita if it was released in New Zealand. The host range tests were conducted in accordance with accepted best practice for the selection of test plants (Wapshere 1974; Briese 2005; Sheppard et al. 2005), and the methods and results of these tests have been summarised in two unpublished reports (Zhang et al. 2012; Landcare Research 2014e). These have been peer-reviewed and those reviews have been provided to EPA. The host range of L. hospita is discussed more fully in Section 5.1.2.

Laboratory tests to describe the host range of the lace bug were conducted with privet present (choice tests) and with privet absent (no-choice tests). No-choice host range tests define the fundamental host range of an insect, that is, all those plant species that could physiologically support development from egg to adult. No-choice feeding tests require the insects to feed or die, and represent the ‘maximum challenge’ to the host selection behaviour of insects. No-choice oviposition tests require the female to either lay eggs or never lay eggs. As a result this type of test can sometimes produce ‘false positives’ because, when confined, the control agent will sometimes try to use a plant that it would not use in the field. No-choice tests can therefore overestimate the true host range of insects. This is because in a confined test arena it cannot use other behaviours such as dispersal to leave an unacceptable plant in search of a preferred host.

Plants that are demonstrated not to be ‘fundamental hosts’ by no-choice host range tests are not at risk of attack by a proposed control agent.

Positive use of a test plant in no-choice tests must be interpreted carefully. Additional testing (e.g. oviposition tests) or analysis of quantitative no-choice data is used to refine the risk to plants shown to be fundamental hosts. The realised host range comprises those plant species that are actually utilised in the field (Landcare Research 2014e).

Privets belong to the tribe Oleae within the olive family (Oleaceae). From tests conducted in the USA, Zhang et al. (2012) concluded that the fundamental host range of L. hospita is restricted to plants within the tribe Oleae (see also Section 5.3.2). It follows that no New Zealand native plants outside

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Application Form Approval to release a new organism that tribe would be at risk, and so testing of New Zealand plants was restricted to species within the family.

There are only four native species in Tribe Oleae: Nestegis cunninghamii (maire, black maire), N lanceolata (white maire), N. montana (narrow-leaved maire), and N. apetala (coastal maire). Privet lace bugs were imported to a Landcare Research containment facility and all four Nestegis species were tested (Landcare Research 2014e). When confined to test plants in the absence of privet, adult lace bugs caused small feeding spots on Nestegis spp. leaves, but significantly fewer spots were observed on maire leaves than the number of spots observed on privet leaves in controls (Table 1). Maire leaves are therefore not preferred food for the lace bugs. No eggs were laid on any of the four Nestegis species (Table 1). Together these results indicate that there is no significant risk that the lace bug could build permanent populations on maire capable of damaging plants or reducing populations of the natives. Incidental damage to the leaves of Nestegis species could only occur where privet heavily infested with mobile lace bugs grew in close proximity to maire. This effect is not considered to be nationally significant because:

 Most Nestegis species will not be growing next to a privet  The host range tests indicate that these are not preferred hosts, and therefore probably unattractive to dispersing adult bugs.

Table 1. Results of tests to measure the feeding and egg-laying of adult lace bugs when confined on four species of Nestegis (maire) in the absence of privet. Test plant Mean no. feeding Mean no. eggs counted Mean no. adults marks (±SE) (±SE) reared (±SE)

Ligustrum sinense 92.63 (9.23) 14.00 (3.72) 43.13 (6.18) Nestegis apetala 45.25 (2.75) 0 (0.00) 0 (0.00) Nestigis cunninghamii 11.50 (3.62) 0 (0.00) 0 (0.00) Nestegis lanceolata 10.00 (2.86) 0 (0.00) 0 (0.00) Nestegis montana 7.50 (3.52) 0 (0.00) 0 (0.00)

Trophic webs A trophic web is the notional representation of all of the biotic interactions affecting the population of a single species, in this case interactions between privet lace bugs and potential parasitoids, predators, and diseases.

‘Apparent competition’ between two species occurs when both are preyed upon by the same natural enemy. For example, if species A and species B were both prey for a predator or parasitoid, a population increase of A could lead to an increase in predator or parasitoid numbers, which in turn could exert unnatural pressure on populations of species B.

A native mymarid egg parasitoid is known to attack the only native tingid bug, Tanybyrsa cumberi (May 1977). Apparent competition between privet lace bug and the native tingid might occur if the parasitoid attacked both species, built to unnaturally large populations on privet lace bug, and spilt

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Application Form Approval to release a new organism over to alter or suppress the population dynamics of the native tingid. The host range of the parasitoid is not known, but even if the privet lace bug fell within the host range of the native parasitoid, apparent competition is likely to be limited. Tanybyrsa cumberi feeds on Astelia spp., and given the minute nature of the parasitoid, it is likely that apparent competition could only occur where the lace bug populations co-occurred, that is, where Astelia grew in close proximity to privet. Astelia species occur widely in the North Island, as does privet. However, most Astelia will not be growing in or near privet, and the consequences of apparent competition for populations of T. cumberi are therefore likely to be insignificant.

As part of the development of this biological control project, a survey of the invertebrate fauna and fungi associated with privets at 39 sites (34 for fungi) in New Zealand was carried out between July 2009 and May 2012 by Landcare Research for regional councils and the Department of Conservation (Winks et al. 2012). Potential predators of lace bugs (including spiders, predatory bugs, ants and earwigs) were present at low levels. The injection of lace bug populations into this ecosystem could provide additional prey biomass and potentially increase general predator pressure on other insects. However, they found no notable native species using privet that could be at risk from such apparent competition. Any such effects would be restricted to insects on plants growing with the privet, and effects would fall way quickly with distance from the host.

In summary, population densities of privet lace bugs capable of interacting significantly with populations of other animals will only be found in close proximity to privet plants, the only hosts on which it can build populations. As a result, no significant disturbance of ecological relationships is expected in New Zealand. If L. hospita fails to achieve high densities in New Zealand, any potential adverse effects will be correspondingly smaller. Leptophya hospita is highly host specific and will not interact significantly with any native plant species or the fauna associated with them. When privet invades habitats it heavily modifies interactions between species, and any reduction in the weed’s survival, vigour or density caused by damaging levels of lace bug attack will tend to restore trophic webs to a pre-invasion state.

Could decline in privet abundance lead to invasion by worse weeds? The greatest threat to the New Zealand natural estate are weeds of forest margins, land on which native vegetation is regenerating, or of native habitats characterised by plants of low stature (such as dunes). These areas are characterised by high rates of disturbance and, as a result, relatively high levels of incident light. Disturbed areas are dynamic, and what mix of native and exotic vegetation dominates succession will vary from place to place. Successful biological control of privet in disturbed habitats would allow its displacement by other species, but it is not clear which potential replacement weeds would be better or worse than privet at displacing regenerating native plants.

Privets are unusual because their seedlings can establish and grow on the forest floor in low light intensity (Grove & Clarkson 2005). This allows privets to establish and eventually displace the shrub understorey (in the case of Chinese privet), and with tree privet, even to slowly displace the canopy

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(Grove & Clarkson 2005). Few other weeds in New Zealand can germinate and succeed in such low light environments to displace shrubs and trees as privet does, so none would have a worse effect on forest ecosystems.

Could decline in privet significantly reduce the food available to native birds? Tree and Chinese privet are common in the upper North Island and fruit in autumn. Thrushes, starlings and blackbirds are known to be the major dispersers of privet seeds in the UK (Williams & Karl 1996), and this is likely to be true in New Zealand. There are four endemic frugivorous birds in New Zealand (kereru, tui, bellbird, kokako) and one other native species (silvereye). Reduction in fruit/seed production through biological control of Chinese and tree privet could adversely affect the fitness of any native bird species that currently rely on privet fruits as a food source. It is considered unlikely that any of these species rely on privet because:

 In a Nelson study, L. sinense fruits were abundant from April to June. They were consumed by blackbirds and thrushes, were observed only once in the faeces of silvereye, and never in tui or bellbird (Williams & Karl 1996).  Endemic tui and bellbirds appear to have a strong preference for indigenous over adventive fruits (Williams & Karl 1996).  Common native plants such as Coprosma robusta fruit abundantly at the same time of year as L. sinense.  Fruits form only a part of the overall diet of the honeyeaters (nectar, honeydew and invertebrates), silvereyes (invertebrates) and kokako (invertebrates, other plant parts).  Kereru fly long distances every day to seek food and it is highly unlikely that privet is a limiting food resource for this species.  Although expanding its range and abundance, native fruiting plants are also usually abundant in habitats where privet grows.

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5.2 Potential effects on human health

5.2.1 Potential beneficial effects on human health Successful biological control of privet would benefit human health if reduction in flowering by L. hospita feeding reduced the effects of privet pollen on respiratory health.

The role of privet in the onset of respiratory problems such as asthma and hay fever (Figure 2) is controversial. Some claim that privet is not wind-pollinated, and that the role of privet pollen as an airborne allergen has been overstated. On the other hand, privet pollen has been found to be one of the more abundant pollens in the air in a Sydney study, and the pollen of the olive, which is closely related to privet, is an important cause of respiratory problems in the Mediterranean (references in McGregor 2000).

Figure 2. Flowering privet hedges can affect respiratory function of some people.

Pendino et al. (2011) found that 60% of a sample of 100 children presenting at a clinic in Argentina with respiratory issues tested positive for aero-allergens in skin scratch tests. The largest proportion were allergic to dust mites (58%) and 13% were allergic to pollens. Of the species presented, L. lucidum pollen proved the most allergenic, as it had in their previous study. They also noted that in Argentina (as in New Zealand), many people attribute sudden asthma attacks during the flowering period to privet.

Allergy NZ were asked to comment on whether privet was regarded as a significant cause of allergies in New Zealand, and if so, how much. Several of their clinical advisors responded (Landcare Research 2014d). I don’t think any of us think privet is a significant allergen. People are irritated by it – I have always assumed by volatiles – like rape in Europe/UK I think. We don’t skin test for it now – although I have done in the past (essentially always negative). I have just completed a small study for the Waikato & Hawke’s Bay City Council on privet allergy ... Privet is not a significant cause of allergies in NZ... small study out of about 40–60 subjects who thought they were reacting to privet none was truly allergic to privet. Only two subjects had minor sensitisation to privet...with other more significant reaction to other pollens. All had alternative explanations for their alleged privet reactions.

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It appears that privet is not regarded by clinicians as a major issue relative to other allergens such as grass pollens and dust mites, but it is nevertheless strongly perceived as a real issue for many New Zealanders suffering from allergic responses especially in urban areas. Waikato Regional Council receives around 1500 calls per year with people concerned that privet is causing their allergies. Also: …the Hawke’s Bay Regional Council receives over 800 phone calls per year complaining about Privet, either on their property or their neighbours’, affecting their health or their family’s health. (Landcare Research 2014d) Privet is a problematic weed species during the spring and dry summer periods in the Gisborne Region particularly where infestations are established near residential or outlying communities. The region has a high proportion of the population that succumb to respiratory ill health and Privet is one plant that the public identify as being a cause for their ill health (Landcare Research 2014d).

The heavy perfume may well be the trigger for discomfort, not the pollen (see Figure 2). Nevertheless, for those affected, reduction in privet flowering resulting from biological control would be an important personal benefit, if not necessarily a major national health benefit. The applicant considers that successful biological control is likely to provide a potential benefit, but the magnitude of that benefit is classed as minimal to minor.

5.2.2 Potential adverse effects No potential adverse effects on human health have been identified that are specifically related to the privet lace bug.

The sycamore tingid, Coryrthuca ciliata, established in Europe in 1964, and builds to very large numbers in plane trees overhanging outdoor cafes and the balconies of urban apartments. The insects fall on people below. Dutto and Bertero (2013) reported three cases of small hives in subjects exposed to these large tingid populations in Italy. The skin response was consistent with a simple inflammatory response to an external irritation, probably related to a bite or to injected saliva. The bite itself was painless, or not noticeable, and the symptoms were ‘scarcely or not at all itchy and spontaneously cleared up in all cases within 24 hours’. They described such response to plant-feeding insects as ‘fairly infrequent’ events.

The applicant considers it unlikely that privet lace bug would have such an effect in New Zealand because:

 This appears to be the only recorded case of tingids affecting humans

 Researchers working with this species in culture in New Zealand have reported no such effects

 The privet tingid may become abundant in urban privet hedges, but the association with humans is unlikely to be as close or intense as the exposure to sycamore tingid on European boulevards.

Extracts of privets have been used for medical purposes overseas (McGregor 2000). The availability in New Zealand of privets for this purpose would not be significantly compromised by biological control.

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5.3 Potential effects on the market economy

5.3.1 Potential beneficial effects on the market economy Successful biological control of privet species would benefit the market economy if it reduced the vigour and abundance of privet and:

 Reduced the annual costs of organisations and individuals currently investing in privet management.  Increased the productivity of farming and forestry. Feeding by L. hospita could contribute to that control.

Could biological control reduce privet management costs? Tree privet and Chinese privet are controlled to maintain biodiversity values, to reduce spread leading to deterioration of habitats, and to mitigate human health effects. Successful biological control of Chinese privet and tree privet would largely take away the need for investment in privet management by land managers and occupiers. The current value of this investment therefore represents the upper bound for the annual economic value of biological control of privet.

Some of these control operations are undertaken by organisations that can identify the real costs of privet management and some examples are presented here. However, much of the cost for privet management nationally falls to individual occupiers, or is expended within the wider weed control budgets of organisations and community groups. Estimating this cost accurately is difficult, but the following observations are made.

Privets feature in the regional pest management plans of most North Island regional councils. As the plants are widespread and common, most plans do not require occupiers to undertake control or boundary clearance, but assist communities to minimise the adverse effects of the weed on the environment or on public health. The cost to councils or occupiers of this approach is unclear, but substantial.

Chinese privet and tree privet are classed as surveillance plants in Auckland, and cannot be sold, propagated or distributed. The cost of managing tree privet in the Auckland Domain alone is $10,00 to $20,000 annually (DOC 2014).

Privet is designated in urban areas as a Total Control (Service Delivery) plant pest in the Hawke’s Bay Regional Pest Management Strategy 2013. The Hawke’s Bay Regional Council will arrange and pay to remove privet from private property if a valid complaint is received. This costs the council over $120,000 per annum in contractor’s costs and staff time (Darin Underhill, Hawke’s Bay Regional Council, pers. comm.).

Privets are hard to kill and some programmes initiated by DOC in 2002 are still active in 2014. Privet species are managed by DOC in at least 10 ‘site-led’ weed projects. In three programmes where costs can be determined, DOC estimates that control takes 5–16 hours, or a maximum cost of $670 per

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Application Form Approval to release a new organism hectare. Weed management programmes where privet species are managed as part of a weed complex vary from $1,000 to $33,000 per year (DOC 2014).

A cost–benefit analysis supporting the Bay of Plenty Regional Pest Management Plan estimates the net present value of the impacts of privet at $6 million (minimum $1.4m, maximum $25m) over 50 years (S. Grayling, pers. comm. in Landcare Research 2014d)

Both privets are widespread across the Waikato Region (Figure 3). The Waikato Regional Pest Management Plan nominates ‘sustained control’ as the management strategy to limit spread and population increase, and the weeds are only actively monitored in some community-initiative areas. The regional council takes action only if there is a health complaint and the complainant provides an allergy test to prove that privet is causing the health issue (see section 5.2.1). Historically the regional council has spent approximately $15,000 per year, but this sum does not reflect the effects of privet in the region.

Chinese privet Tree privet

Figure 4. Distribution of privet in Waikato Region (DOC 2014).

Chinese privet is present in 444 QEII National Trust covenants, and tree privet is present in 193. Over half of those records are from the Waikato Region. The weed status of privet in those covenants is not well known, but in all cases privet is controlled or eradicated where possible. The cost of this to managers of the covenants is not known, but in total must be considerable. Since 2010 the Trust has co-ordinated one externally funded project that specifically targeted tree privet, and another that targeted Chinese privet and Japanese honeysuckle. The investment by the partners in these two control projects is in the order of $2,000 (Gareth Eloff & Genevieve Bannister, QEII National Trust, pers. comm.).

Horizons Regional Council identified one privet control project conducted by Ruapehu District Council that cost $5,000.

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The Bay of Plenty Regional Council receives about 100 calls per year regarding privet as an allergen. As for most other regional councils in the North Island, both privets are too widespread to warrant specific action. All three species are listed as Restricted Pests under our current RPMP… this means the plant is either too widely spread, therefore fails the cost–benefit analysis, or its environmental impacts are not deemed high enough to warrant active management … Privet is relatively widespread… Restricted pests are not required to be controlled by landowners and BOPRC’s role is to provide advice and education to those wanting to control the pests of their land. Due to the classification in the RPMP, BOPRC do not collect information on spatial distribution or control effort either internally or externally ... I imagine all territorial authorities would undertake some form of control, particularly for privet. (Landcare Research 2014d)

Costly privet control is necessary for successful habitat restoration. The managers of Hikuai Ti Kouka Reserve (see Section 4) and two other community-driven restoration projects have described the costs and resources committed to privet control. The main weeding task is spraying, digging and pulling privet, although Barrett Bush has many other weeds also. Privet requires a constant weeding programme to keep some control over the weed. We have managed to eliminate most of the larger seeding privet but birds seem to be constantly reseeding the Bush. In terms of a costing I would suggest if an hourly figure of say $20 was a labour cost, the total financial cost could be 216 hrs x $20 = $4,320 (Warren Stace, Barretts Bush). …since early 2009 my notes on finances indicate the following costs in round figures. Grants: DOC weed control $9K (incl mulcher hire), DOC Mulcher hire $10K, Lion Mulcher hire $7K, WEL Mulcher hire $5K, Waikato Regional Council Weed and predators $5K. So approx $35K for the mechanical removal and mulching of about 4–5 acres of solid privet, but worth it considering the endless input required by volunteers. This excludes the dollar value of all the volunteer time in pulling, scarfing and cutting/poisoning the privet. I did estimate the hours volunteers put in over 2 years at $15 per hour per person and it was many $000s (Alan Leadley, Pukemokemoke Trust, undated).

In summary, there is a lack of comprehensive data with which to reliably estimate the national cost of privet control. However, the few case studies presented here note ongoing annual costs of at least $150,000. As this figure takes no account of the costs incurred by occupiers or other land managers (including territorial authorities), the annual cost of privet management is likely to be many times this figure. Considerable sums are also invested in specific privet management projects. With the increasing prevalence of these weeds, the number of such projects is unlikely to decrease. The maximum benefit that could be achieved by biological control of Chinese privet and tree privet is therefore large but uncertain, as is the potential contribution of privet lace bug to that control. The applicant considers the potential maximum economic benefit is moderate, and it is likely that at least some of that potential benefit will be realised by the establishment of the privet lace bug.

Could biological control improve productivity of farming and forestry? Consultation with Federated Farmers of New Zealand and the New Zealand Forest Owners Association indicates that privets are not a significant production issue for farming or forestry (Landcare Research 2014d). ‘Good neighbour’ responsibilities are likely to impose labour and material costs to individual occupiers in these industries. These costs are not known, but are likely to be minimal.

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5.3.2 Potential adverse effects on the market economy The establishment of L. hospita would have adverse effects on New Zealand’s market economy if feeding by adults and nymphs resulted in:

 Significant foliar damage to valued non-native plant species, compromising their ornamental value  Significant revenue losses to the nursery industry  Significant losses in revenue to the olive industry  Significant costs associated with replacing privet hedges.

Risk to valued non-target plants that are not native As described in Section 5.1.2, laboratory tests to describe the host range of the lace bug were conducted with privet present (choice tests) and with privet absent (no-choice tests). No-choice host range tests define the fundamental host range of an insect, that is, all those plant species that can physiologically support development from egg to adult.

Zhang et al. (2012) reported the results of tests to determine the host range of the privet lace bug. These are summarised and discussed in Landcare Research (2014e). The results of no-choice tests indicated that the fundamental host range of L. hospita is confined to the tribe Oleae (Figure 4). Plants of ornamental value in New Zealand such as Fontanesia, Forsythia, and Jasminum fall outside this tribe and are not at risk. Within the tribe Oleae, the genera Olea and Osmanthus are also not fundamental hosts of L. hospita and can be discounted as potential field hosts.

Most Fraxinus species (ash) and Forestiera species tested did not support development, but on those that did, reproduction and survival was poor. These species are therefore highly unlikely to support lace bug populations capable of causing significant damage to leaves of ash trees. Similarly, the two species of Chionanthus (fringetrees) tested supported development but performance was poor. It is highly unlikely that any of these species would be a field host, but incidental attack through spillover of lace bugs to plants growing in close proximity to large lace bug populations on privet is possible. Such situations would be rare, as these species are not common garden plants, and would rarely grow near privet. These data raised no major concern for the NGIANZ (Landcare Research 2014e).

Laboratory tests of the fundamental host range of a control agent tend to overestimate the likely realised host range on release. The recorded host range of L. hospita in its native range does not include any of the species shown to fall within the fundamental host range in these tests (Zhang et al. 2012; Landcare Research 2104e).

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Application Form Approval to release a new organism

Figure 4. The molecular phylogeny of the Oleaceae superimposed with the ability of species to support fundamental development of Leptophya hospita (green and N; no development; orange and S, some but not all species in the genus supported development: Red and A, all species tested in the genus supported development (Landcare Research 2014e).

Lilacs (Syringa spp.) belong to the sub-tribe Ligustrinae, and are the closest known relatives to privet (Figure 4). Zhang et al. (2012) found that four species of lilac supported complete development of the privet lace bug, but with significantly lower success than on privet controls. Not all cultivars grown in New Zealand were included in these tests. Lace bugs were imported into containment in New Zealand and two trials were completed on local cultivars. The methods, results and statistical analysis of these trials have been reported by Landcare Research (2014e). There were significantly fewer feeding marks on leaves of lilac cultivars than on controls, indicating that these are un-preferred as a food source (Table 2). Eggs were laid into the plant material and counts were unreliable, but it is clear that privet lace bugs can lay eggs on lilac. Survival of immature stages was poor on all New Zealand cultivars of lilac compared with privet controls, and few adults were reared. When these were placed back onto lilac, performance was equally poor in the second generation. These results indicate that it is highly unlikely that privet lace bug could colonise isolated lilac plants and establish a viable, potentially damaging population. The risks to lilac are discussed further in Section 5.4.2.

No Syringa species are recorded as hosts of L. hospita in China, the native range of the lace bug, Chinese and tree privet and lilac species (Landcare Research 2014e).

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Application Form Approval to release a new organism

Table 2. Survival and reproduction success of Leptophya hospita on Chinese privet and four cultivars of lilac in two tests conducted in containment in New Zealand. (Results and statistical analysis can be found in Landcare Research 2014e.) Test plant Mean no. feeding Mean no. eggs Mean no. adults Mean no. adults marks (±SE) counted (±SE) reared (±SE) reared –second generation (±SE)

Ligustrum sinense 149.78 (15.84)a 14.11 (2.80) 52.50 (6.4)a 28.25 (6.25)a

Syringa xjosiflexa 38.10 (8.39)b 11.30 (2.30) 6.20 (2.80) b 0.00 (0.00) b ‘Bellicent’

Syringa xlaciniata 46.00 (7.40) b 11.10 (2.10) 3.6 (0.90) b 0.33 (0.19) b

Ligustrum sinense 150.20 (15.18) a 21.90 (3.41) a 25.30 (3.93) a 19.25 (4.52) a Syringa hyacinthiflora 20.00 (4.03) b 3.00 (1.37) b 3.50 (1.82) b 0.00 (0.00)b Syringa vulgaris 32.33 (5.90) b 13.83 (1.92) b 4.50 (1.39) b 0.40 (0.40) b

Cost to the nursery industry All growers protect their nurseries from damage from pests, so direct economic losses from attack by biocontrol agents during production of stock is highly unlikely. However, the Nursery and Garden Industry Association of New Zealand felt that reduction in the visual appeal of any garden species by biological control would lessen demand, reducing revenues for growers and retailers (Landcare Research 2014d). This is not considered likely because the privet lace bug is sufficiently host-specific that significant damage to valued non-native plant species is highly unlikely (see above). Few nurseries grow lilac and it is expensive to produce. The value of lilac to the trade is probably much less than $100,000 (NGINZ in Landcare Research 2014e; see Section 5.4.2).

Effect on olive yields Zhang et al. (2012) confined adult lace bugs onto the foliage of European olives (Olea europea). In the absence of privet there was trace feeding on olive leaves by the adults but no eggs were laid. Without such oviposition lace bugs could not build a self-supporting population on olives. It is possible that incidental damage to olive foliage could occur where lace bugs spilled over from heavily infested privet in close proximity to the olives, but it is highly unlikely that this trace damage could affect olive production even if privet was abundant nearby. Any adverse effects on leaves would be minimal, and could be mitigated by removing privet from within the plantation.

Damage to existing privet hedges Both tree privet and Chinese privet have been planted extensively in the past as amenity and hedge plants, and these hedges remain useful. If successful biological control of privet is achieved, these hedges will be severely damaged. Damage will reduce the efficiency of the hedges over time, necessitating replacement. A privet hedge may survive for 50–100 years, and many hedges are

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Application Form Approval to release a new organism approaching the 50-year age limit. Privet is no longer planted for hedging, and eventual replacement of privet hedges with other species is inevitable. However, it is likely that successful biological control of privet would bring forward the costs of replacing those hedges. Privet has no inherent advantage as a hedge plant over common replacements such as Pittosporum tenuifolium (McGregor 2000) so there is no technical barrier to replacement. There is already pressure to replace privet hedges in some communities because of the perceived health risk. The cost to communities of replacing hedges over coming decades is not known but the applicant considers the cost to be minimal.

5.4 Potential effects on society and communities

5.4.1 Potential beneficial effects for society and communities No nationally significant beneficial effects were identified. Successful biological control would benefit society and communities by:

 Improving conservation values (Section 5.1.1)  Improving the perceived quality of the conservation estate (Section 5.1.1)  Improving neighbourhood relationships strained over the health effects of privet (Section 5.2.1)  Improving efficient use of conservation volunteers and community resources. This benefit is discussed in Section 5.3.2.

5.4.2 Potential adverse effects for society and communities The biological control of privet would have adverse effects on society and communities if:

 Feeding by lace bug adults and nymphs resulted in significant loss of enjoyment by the public of the ornamental values of non-native plants  Feeding by lace bug adults and nymphs reduced the ability of lilacs to support butterfly populations. Non-native plants grown for ornamental purposes can be seen as part of New Zealand’s heritage, and should be valued along with other biodiversity (NGIANZ in Landcare Research 2014d). Lilac is highly prized, out of proportion to its abundance in gardens or its frequency in the garden trade. Gardeners have an emotional attachment to lilac for its beauty and its role as a butterfly plant. Biological control of privet would adversely affect society and communities if damage to lilac plants reduced the enjoyment of lilac blooms by gardeners, or the ability of lilacs to attract and support butterfly populations in gardens.

The limited ability of privet lace bug to utilise lilac species is discussed in Section 5.3.2. It is highly unlikely that privet lace bug would compromise the ability of gardeners to grow and appreciate lilacs for their ornamental value except in the immediate vicinity of heavily infested privet. In these rare circumstances, the adverse effects could be mitigated by treating the lilac with insecticide, or removing the privet. In growing lilac plants for sale, the nursery industry usually grafts budwood onto a robust related rootstock, often Ligustrum japonicum. Adventitious shoots sometimes grow from the rootstock,

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Application Form Approval to release a new organism which might intermingle with lilac stems. This could potentially place privet lace bugs in close proximity to lilac foliage. This is not expected to have a significant effect on lilac because lace bugs reproduce poorly on L. japonicum (Landcare Research 2014e), and because any effects could be mitigated by removing the unwanted stems growing from the rootstock.

Lilacs are relatively uncommon in New Zealand compared with other nectar sources available to butterflies (including buddleia species, which are much more common). It is therefore highly unlikely that reduction in lilac flowers could reduce butterfly populations below current levels. However, reduction in lilac flowering in a garden because of biological control could reduce the frequency of butterfly observations locally. This could only occur where lilac grew in close proximity to infested privet (see Section 5.3.2), and rare events could be mitigated either by treating or removing the privet.

The potential effects on society and communities are predicted to be minimal and highly unlikely.

6. Pathway determination and rapid assessment

Under sections 38I and 35 of the HSNO Act your application may be eligible for a rapid assessment. The pathway for your application will be determined after its formal receipt, based on the data provided in this application form. If you would like your application to be considered for rapid assessment (as per the criteria below), we require you to complete one of the below sections. Fill in the section that is relevant to your application only.

6A. New organism that is or is contained within a veterinary or human medicine (section 38I)

6.1. Controls for organism Describe the controls you propose to mitigate potential risks (if any). Discuss what controls may be imposed under the ACVM Act (for veterinary medicines) or the Medicines Act (for human medicines)

Not Applicable

6.2. Discuss if it is highly improbable (after taking into account controls if any):  The doses and routes of administration of the medicine would have significant adverse effects on the health of the public or any valued species; and  The organism could form an undesirable self-sustaining population and have significant adverse effects on the health and safety of the public, any valued species, natural habitats or the environment Do not include effects of the medicine or new organism on the person or animal being treated with the medicine

Not Applicable

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Application Form Approval to release a new organism

6B. New organism (excluding genetically modified organisms) (section 35)

6.3. Discuss if your organism is an unwanted organism as defined in the Biosecurity Act 1993

Leptophya hospita is not an unwanted organism under the Biosecurity Act 1993.

6.4. Discuss if it is highly improbable, after taking into account the proposed controls, that the organism after release:

 Could form self-sustaining populations anywhere in New Zealand (taking into account the ease of eradication)  Could displace or reduce a valued species  Could cause deterioration of natural habitats,  Will be disease-causing or be a parasite, or be a vector or reservoir for human, animal, or plant disease  Will have adverse effects on human health and safety or the environment

 The purpose of the application is to establish self-sustaining populations of L. hospita wherever privet infestations exist, but none of these are expected to be undesirable (see Section 5).  The evidence presented in Section 5 indicates that no native plant species are at risk of attack by L. hospita. Valued exotic plant species are not at significant risk from this insect (Sections 5.1.2, 5.3.2). It is highly improbable that any native plant or invertebrate species would be significantly displaced (Section 5.1.2). There are no native invertebrate species commonly associated with privets that could be significantly displaced by the privet lace bug (Winks et al. 2012). The only native species in this family belongs to a separate genus. There is no possibility of hybridisation or adverse effect on the inherent genetic diversity of native tingids.  Any change in privet abundance resulting from biological control is likely to be gradual over years. It is highly improbable that this control agent will cause catastrophic decline in any privet infestation that might lead to rapid habitat change. Successful biocontrol is more likely to gradually restore habitat to a pre-infestation state.  Leptophya hospita is a plant-feeding insect. It is not a disease-forming organism or a parasite, and will not be a reservoir or a vector for diseases of vertebrates. Aphids and leafhoppers are renowned vectors of pathogens such as viruses and phytoplasmas because they carry these organisms between plants and inject them directly into the vessels of the plant (phloem or xylem) while feeding. Although they are true bugs, lace bugs (Tingidae) do not tap the vessels of plants. Instead they feed on mesophyll, consuming the cells between the top and bottom layer of the leaf (this leads to the pale feeding spots on leaves characteristic of tingid attack). Several tingids have been labelled as vectors of plant disease, not because they transmit disease from plant to plant, but because breaks in the leaf surface caused by lace bug feeding allow the passive invasion of adventitious fungi, some of which can be pathogenic (Bain 2007;

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Application Form Approval to release a new organism

Martinez et al. 2013). This is not a true vector. The frequency of colonisation by this route is related to the density of feeding scars on leaves. As this lace bug is specific to privets (see Section 5.3.2), it is highly improbable that it will facilitate pathogen invasion on any plants other than privet.  No credible mechanism for adverse effects of L. hospita on human health and safety has been identified.

7. Other information

Add here any further information you wish to include in this application including if there are any ethical considerations that you are aware of in relation to your application.

This application raises no known ethical considerations.

Post-release monitoring and measurement of impact

The development of biocontrol agents for weeds is funded by the National Biocontrol Collective. The collective has stated its commitment to the evaluation of target and non-target effects of the agents developed, as and when this is appropriate. Landcare Research will provide populations of L. hospita to the applicant, regional councils and other organisations, and will oversee agent release and follow- up. It is their practice to monitor release sites for the establishment of all biocontrol agents. Simple baseline estimates of weed abundance will be taken. If privet lace bugs become abundant, members of the collective will then undertake measurement of their effects. Landcare Research is focused on constant improvement in biological control of weeds practice in New Zealand, including world-leading research into minimising the interactions of introduced agents with existing trophic webs (Paynter et al. 2010; Fowler et al. 2012), better prediction of success (Paynter et al. 2012), how agents disperse (Paynter & Bellgard 2011), the accuracy of host range testing in predicting eventual host range following release (Paynter et al. in press) and monitoring safety of biological control in New Zealand (Paynter et al. 2004).

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Application Form Approval to release a new organism

8. Checklist This checklist is to be completed by the applicant

Application Comments/justifications

All sections of the application form completed ☑ Yes ☐ No or you have requested an information waiver (If No, please discuss with an under section 59 of the HSNO Act Advisor to enable your application to be further processed)

Confidential data as part of a separate, ☐ Yes ☐ No N/A identified appendix

Supplementary optional information attached:

 Copies of additional references ☑Yes ☐ No References provided

 Relevant correspondence ☑ Yes ☐ No Peer reviews provided

Administration Are you an approved EPA customer? ☑ Yes ☐ No If Yes are you an: Applicant: ☐ Agent: ☑

If you are not an approved customer, payment Payment already made of fee will be by:

 Direct credit made to the EPA bank ☑ Yes ☐ No account (preferred method of payment) ☐ Payment to follow th Date of direct credit: 30 November 2014

☐ Yes ☐ No  Cheque for application fee enclosed ☐ Payment to follow

Electronic, signed copy of application e-mailed ☑ Yes to the EPA

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Application Form Approval to release a new organism

Signature of applicant or person authorised to sign on behalf of applicant

I am making this application, or am authorised to sign on behalf of the applicant or applicant ☑ organisation.

I have completed this application to the best of my ability and, as far as I am aware, the ☑ information I have provided in this application form is correct.

Signature Date

Request for information waiver under section 59 of the HSNO Act

I request for the Authority to waive any legislative information requirements (i.e. concerning the ☐ information that has been supplied in my application) that my application does not meet (tick if applicable).

Please list below which section(s) of this form are relevant to the information waiver request:

Not applicable

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Application Form Approval to release a new organism

Appendices and referenced material (if any) and glossary (if required)

References

Bain J (2007). Corythucha ciliata, Sycamore lace bug. Forest Health News No. 172. 1 p.

Biosecurity Queensland (2013). Broad-leaved privet, Ligustrum lucidum. Factsheet. 2 p.

Blanchon D, Pusateri J, Galbraith M, Thorpe S (2011). Sampling indigenous ground-living beetles in a stand of non-native tree privet (Ligustrum lucidum) in New Zealand raises new management questions. Ecological Management & Restoration (Ecological Society of Australia) 12: 234–236.

Briese D (2005). Translating host-specificity test results into the real world: the need to harmonize the yin and yang of current testing procedures. Biological Control 35: 208–214.

Broughton S (2000). Review and evaluation of Lantana biocontrol programs. Biological Control 17: 272-286.

DOC (2014). Comments on the introduction of privet lace bug, a potential biocontrol agent. Letter from David Havell, Technical Advisor (Threats), Department of Conservation (in Landcare Research 2014d).

Dutto M, Bertero M (2013). Dermatosis caused by Corythuca ciliata (Say, 1932) (Heteroptera: Tingidae). Diagnostic and clinical aspects of an unrecognised peudoparasitosis. Journal of Preventive Medicine and Hygiene 54: 57–59.

Fowler SV, Paynter Q, Dodd S, Groentemann R (2012). How can ecologists help practitioners minimize non- target effects in weed biocontrol? Journal of Applied Biology 49: 307–310.

Greene BT, Blossey B (2012). Lost in the weeds: Ligustrum sinense reduces native plant growth and survival. Biological Invasions 14: 139–150.

Grove E, Clarkson BD (2005). An ecological study of Chinese privet (Ligustrum sinense Lour.) in the Waikato Region. Centre for Biodiversity and Ecology Research Contract Report No. 41 for Environment Waikato Regional Council.

Hanula JL, Horn S, Taylor JW (2009). Chinese privet (Ligustrum sinense) removal and its effect on native plant communities of riparian forests. Invasive Plant Science and Management 2: 292–300.

Landcare Research (2014a). Risks, costs and benefits of privet control. http://www.landcareresearch.co.nz/science/plants-animals-fungi/plants/weeds/biocontrol/approvals/current- applications/privet/beneficial-and-adverse-effects

Landcare Research (2014b). Report of the EPA Reference Group concerning biological control of weeds.

Landcare Research (2014c). Summary of responses to consultation with Te Herenga and others.

Landcare Research (2014d). Summary of responses to public consultation.

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Landcare Research (2014e). Host range testing of Leptophya hospita. http://www.landcareresearch.co.nz/science/plants-animals-fungi/plants/weeds/biocontrol/approvals/current- applications/privet/host-range-testing.

Larivière M-C, Larochelle A (2004). Heteroptera (Insecta: Hemiptera): catalogue. Fauna of New Zealand 50. Lincoln, Manaaki Whenua Press. 330 p.

Martinez LC, Plata-Rueda A, Agudelo O (2013). Efficacy of insecticides on Leptopharsa gibbicarina Froeschner (Hemiptera: Tingidae) applied by root absorption in oil palm. Persian Gulf Plant Protection 2: 10–17.

May BM (1977). The immature stages and biology of the lacebug Tanybursa cumberi Drake (Heteroptera: Tingidae). Journal of the Royal Society of New Zealand 7: 303–312.

McGregor P (2000). Prospects for biological control of privet (Ligustrum spp.) (Oleaceae). Landcare Research Contract Report LC9900/127, for Auckland Regional Council.

Noyes JS, Valentine EW (1989). Chalcidoidea (Insecta: Hymenoptera) – Introduction, and review of smaller families. Fauna of New Zealand 18. 96 p.

NSW Department of Primary Industries (2010). Privet (broad-leaf, small-leaf and European). Primefact 960. http://www.dpi.nsw.gov.au/agriculture/pests-weeds/weeds/profiles/privet.

Paynter Q, Bellgard S (2011). Understanding dispersal rates of invading weed biocontrol agents. Journal of Applied Ecology 48: 407–414.

Paynter, QE, Fowler SV, Gourlay AH, Haines ML, Harman, HM, Hona SR, Peterson PG, Smith LA, Wilson-Davey JRA, Winks CJ, Withers TM (2004). Safety in New Zealand biocontrol: a nationwide survey for impacts on non- target plants. New Zealand Plant Protection 57: 102–107.

Paynter Q, Fowler SV, Gourlay AH, Groentemann R, Peterson PG, Smith L, Winks CJ (2010). Predicting parasitoid accumulation on biological control agents of weeds. Journal of Applied Ecology 47: 575–582.

Paynter Q, Overton JM, Hill RL, Bellgard SE, Dawson MI (2012). Plant traits predict the success of weed biocontrol. Journal of Applied Ecology 49: 1140–1148.

Paynter Q, Fowler SV, Gourlay AH, Peterson PG, Smith LA, Winks CJ (In press). Relative performance on test and target plants in laboratory tests predicts the risk of non-target attack in the field for arthropod weed biocontrol agents. Biological control: doi: 10.1016/j.biocontrol.2014.10.007

Pendino P, Aguro C, Cavagnero P, Lopez K, Kriunis I, Molinas J (2011). Aeroallergen sensitization in wheezing children from Rosario, Argentina, World Allergy Organization Journal 4: 159-163. doi: 10.1097/WOX.0b013e318232df96.

Pukemokemoke Bush, undated. The David Johnstone Pukemokemoke Bush. http://www.doc.govt.nz/Documents/getting-involved/in-your-community/community-conservation- projects/pukemokemoke-bush-reserve/pukemokemoke-fights-privet.pdf

Sheppard AW, Heard TA, van Klinken RD (2005). Scientific advances in the analysis of direct risks of biological control agents to non-target plants. Biological Control 35: 215–226.

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Waikato Regional Council (2011). Privet, all privet (Ligustrum species). Biosecurity Series – Plant Pest Factsheet 8, Waikato Regional Council. 2 p.

Wapshere AJ (1974). A strategy for evaluating the safety of organisms for biological weed control. Annals of Applied Biology 77: 201–211.

Webb CJ, Sykes WR, Garnock-Jones PJ (1988). Flora of New Zealand. Volume 4. Naturalised pteridophytes, gymnosperms, dicotyledons. Christchurch, Botany Division, DSIR.

Wilcox M (2000). Tree privet (Ligustrum lucidum) – a controversial plant. http://bts.nzpcn.org.nz/bts_pdf/auck_2000_55_2_72-74.pdf

Williams PA, Karl BJ (1996). Fleshy fruits of indigenous and adventive plants in the diet of birds in forest remnants, Nelson, New Zealand. New Zealand Journal of Ecology 20: 127–145.

Winks CJ, Than DJ, Anand N, Bellgard SE (2012). Invertebrates and fungi associated with privet, Ligustrum spp. (Oleaceae), in New Zealand. Unpublished Landcare Research Contract Report LC1148. 42 p.

Zhang YZ, Hanula JL, Horn S, Braman SK, Sun JH (2011). Biology of Leptoypha hospita (Hemiptera: Tingidae), a potential biological control agent of Chinese privet. Annals of the Entomological Society of America 104:1327– 1333.

Zhang Y, Hanula J, Horn S, Sun J, Braman K (2012). Fundamental host range of Leptophya hospita (Hemiptera: Tingidae), a potential biological control agent of Chinese privet. Unpublished report, 25 p.

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