FORM NOR
Application for approval to
IMPORT FOR RELEASE OR RELEASE FROM CONTAINMENT ANY NEW ORGANISM INCLUDING A GENETICALLY MODIFIED ORGANISM BUT EXCLUDING CONDITIONAL RELEASE AND RAPID ASSESSMENT
[Short title is: New Organism Unconditional Release]
under section 34 of the Hazardous Substances and New Organisms Act 1996
Application Title: Release of a leaf weevil for biological control of buddleia
Applicant Organisation: Forest Research
ERMA Office use only
Application Code: Formally received:____/____/____
ERMA NZ Contact: Initial Fee Paid: $
Application Status:
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 1 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
IMPORTANT
1. An associated User Guide is not yet fully developed. If you need guidance in completing this form please contact ERMA New Zealand.
2. This application form covers importation for release or release from containment of any new organism (i.e. full or unconditional release) including genetically modified organisms but excluding conditional release and rapid assessment, under section 34 of the Act
3. If you are making an application to import for release or release from containment any new organism with controls (i.e. conditional release) use Form NOCR. If you are making an application to import for release a new organism that is not a genetically modified organism by rapid assessment use Form NORA. If you are making an application to field test any new organism use Form NO4.
4. You should periodically check with ERMA New Zealand or on the ERMA New Zealand web site for new versions of this form.
5. You can talk to an Applications Advisor at ERMA New Zealand who can help you scope and prepare your application. We need all relevant information early on in the application process. Quality information up front will speed up the process and help reduce costs.
6. This application form may be used to seek approvals for importing more than one new organism where the organisms are of a similar nature.
7. Any extra material that does not fit in the application form must be clearly labelled, cross-referenced, and included as appendices to the application form. 8. Commercially sensitive information must be collated in a separate appendix. You need to justify why you consider the material commercially sensitive, and make sure it is clearly labelled as such.
9. Applicants must sign the form and enclose the correct application fee (plus GST). The initial application fee can be found in our published Schedule of Fees and Charges. Please check with ERMA New Zealand staff or the ERMA New Zealand website for the latest schedule of fees. We are unable to process applications that do not contain the correct initial application fee.
10. Unless otherwise indicated, all sections of this form must be completed for the application to be progressed. 11. Please provide an electronic version of the completed application form, as well as sending a signed hard copy.
12. Note: Applications for full (unconditional) releases (this form) shall be publicly notified by the Authority under section 53(1)(b) and may go to a hearing pursuant to section 60 of the Act. You can get more information by contacting us. One of our staff members will be able to help you. ERMA New Zealand 20 Customhouse Quay, PO Box 131 Wellington, NEW ZEALAND Telephone: 64-4-916 2426 Facsimile: 64-4-914-0433 E-mail: [email protected] www.ermanz.govt.nz
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 2 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Section One – Applicant Details
1.1 Name and postal address in New Zealand of the organisation or individual making the application:
Name >Forest Research (attention: Nod Kay)
Postal Address >Private Bag 3020, Rotorua
Physical Address >Sala St., Rotorua
Phone > (07) 343 5899
Fax > (07) 348 0952
E-mail >[email protected]
1.2 If application is made by an organisation, provide name and contact details of a key contact person at that organisation This person should have sufficient knowledge to respond to queries and have the authority to make decisions that relate to processing of the application.
Name >Dr Richard Hill
Position >Consultant entomologist to Forest Research for the purpose of this application.
Address >Richard Hill & Associates, Private Bag 4704, Christchurch
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 3 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Phone >03 325 6400 or 03 332 2543
Fax >03 325 2074
E-mail >[email protected]
1.3 If the applicant is an organisation or individual situated overseas, provide name and contact details of the agent authorised to transact the applicant’s affairs in relation to the application This person should have sufficient knowledge to respond to queries and have the authority to make decisions that relate to processing of the application.
Name > N/A
Position >
Address >
Phone >
Fax >
E-mail >
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 4 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Section Two – Purpose of the Application and Reasons for Requesting a Full (Unconditional) Release This form is to be used for a standard (publicly notified) application (i.e. other than by rapid assessment), to import for release, or release from containment, any new organism (including a genetically modified organism). It is not intended to cover conditional releases.
2.1 Give a short summary statement of the purpose of this application to be used on ERMA New Zealand’s public register – Maximum 255 characters (including spaces and punctuation) Briefly describe the organism(s) to be imported for release or released from containment and the purpose(s) for which you wish to release the organism(s). Note: An organism is „released‟ when it is not required to be held in a containment facility registered by the Ministry of Agriculture and Forestry. Once released it is no longer considered a new organism.
>Approval is sought by Forest Research to release the new organism Cleopus japonicus Wingelmüller (Coleoptera: Curculionidae) from containment. This leaf-feeding weevil has been identified as one of several insect species that show promise as biological control agents for the increasingly serious weed buddleia (Buddleja davidii).
2.2 Provide a brief description of the background and aims of the proposal suitable for lay readers Describe in less than one page the rationale for the proposal to release these organisms, including the potential use for the organism(s), so that people not directly connected with the application can understand the reasons for the release.
>Buddleia (scientific name Buddleja davidii Franchet) is a garden escape that is spreading in New Zealand, and is an environmental and economic threat. It is the most serious weed of new pine plantations in eastern central North Island, and its impact is likely to spread. It germinates and grows better on gravely areas than any of its native competitors. As a result, it is pushing out the flora and fauna of stream beds and margins in places such as Te Urewera National Park, and even threatens iconic lakeside and river landscapes around Queenstown. In most places buddleia is too far out of control for conventional control measures to be practical on their own.
The leaf-feeding weevil Cleopus japonicus has been identified as the most promising of several insect species that could help to suppress damage from the weed biologically. The weevil is from China, where buddleia is its natural host plant. Buddleia leaf weevil was imported from China into containment at Rotorua in 1993, and its suitability for release has been under evaluation since then.
All risks posed by the proposed release of the buddleia leaf weevil, including those of particular importance to Māori, have been identified and assessed. Experiments have been carried out in China and New Zealand to 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 5 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
estimate the range of plants on which this weevil can feed and lay eggs. These experiments showed that the weevil could attack other Buddleja species in New Zealand, but not B. salvifolia, a useful plant for bees. The studies also conclude that the risk to other environmentally and economically important plants in New Zealand from introducing the weevil is low. Other risks that might arise, either from the introduction of the agent or from control of buddleia, are assessed in this application. None were found to be significant.
The potential benefits of the introduction have also been evaluated. Experiments indicate that this insect could reduce the vigour of buddleia, possibly below damage thresholds in plantation forests with potential economic benefits to the forestry industry of $0.5 – 2.9 million per annum. Weevil damage also has the potential to reduce the competitive effects of buddleia, conserve native vegetation, and partially restore natural forest succession processes, resulting in non-monetary benefits to native biodiversity, ecosystem health, and spiritual values of importance to Māori.
If successful biological control of a weed is to be achieved, it is normal practice to introduce a number of complementary agents. The leaf weevil is the first control agent to be proposed for buddleia control in New Zealand, but applications for the release of complementary agents (e.g. Mecysolobus erro, Zhou et al. 1998) may follow in future years.
2.3 Set out the reasons for this application being for a full (unconditional) release rather than for a conditional release Set out the reasons for this application being for full (unconditional) release rather than for conditional release. Under section 38B of the HSNO Act the Authority may consider an application for full (unconditional) release as if it were for conditional release (i.e. conditions can be set), with the agreement of the applicant. You should provide sufficient information to enable the Authority to decide whether or not it should approach the applicant with a view to obtaining agreement to switching from full (unconditional) to conditional release.
>The purpose of the application is to release the control agent, and eventually to establish self-perpetuating populations wherever buddleia grows in New Zealand. Even if there were reasons for conditional release to be considered, the size and mobility of buddleia leaf weevils makes secure containment in the field impractical.
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 6 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Section Three – Information on the Organism(s) to be Released and any Inseparable Organisms If the application is for release of more than one organism, information must be provided separately for each organism. If there are commercial reasons for not providing full information here alternative approaches must be discussed with and agreed by ERMA New Zealand.
3.1 State the taxonomic level at which the organism(s) to be released are to be specified If the taxonomic level is higher or lower than “species”, provide reasons for this. The reasons should take account of the need to adequately describe the risk.
>The organism is identified to „species‟
3.2 Give the unequivocal identification of the organism(s) to be released Please provide details of the following:
Latin binomial, including full taxonomic authority (e.g. ----- Linnaeus 1753) class, order and family:
>Cleopus japonicus Wingelmüller 1938 Class: Insecta Order: Coleoptera Family: Curculionidae Sub-family: Curculioninae Tribe: Cionini
Common name(s), if any:
>buddleia leaf weevil
Type of organism (e.g. bacterium, virus, fungus, plant, animal, animal cell):
>Insect
Strain(s) and genotypes(s), if relevant:
>N/A
Other information, (e.g. information on consideration of the organism(s) by other states, countries or organisations):
>Identification is documented in Appendix 1. The population to be introduced to New Zealand was collected from a single population in Zhang Jie Jai National Park, Hunan Province, Peoples Republic of China (China). 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 7 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
3.3 Provide unique name(s) for the new organism(s) to be released These name(s) will be on the public register and should clearly identify the organism.
>Cleopus japonicus Wingelmüller (Coleoptera: Curculionidae), buddleia leaf weevil.
3.4 Characteristics of the organism(s) to be released Provide information on the biology, ecology and the main features or essential characteristics of each organism(s) to be released. Provide information on affinities of the organism(s) with other organism(s) in New Zealand. You should also indicate whether the organism is pathogenic or a potential pest or weed. This information should be relevant to the identification of the risks of the organism (section 6 of this form).
>The distribution of C. japonicus in its native range appears to follow that of its host B. davidii (N. Kay, Forest Research, personal communication), which is now confined to S and SW China. B. davidii has been recorded from SE Asia in the past, but the current distribution of both host and insect in China is not well-known. Cleopus japonicus has been recorded on buddleia in Sichuan Province (Kay 1991). This area experiences harsh climatic extremes, suggesting that neither cold winters nor hot summers should stop this insect establishing wherever buddleia grows in New Zealand.
The genus Cleopus has a wider distribution, for example C. solani and C. pulchella occur in Europe.
Buddleia leaf weevils are brown, and approximately 4 mm long. Weevils fly readily, are active, and tend to congregate in the shelter of buds. Teneral (newly emerged) adults are voracious, and can consume 1–2 cm2 of leaf tissue within the first week (T. Withers, Forest Research, unpublished data). After the initial high feeding activity, adults tend to consume approximately 1 cm2 of leaf tissue per week for the rest of their relatively long adult lives (sometimes over 300 days). Adults begin to mate after 5 days, and after 20 days begin laying eggs (approximately 0.5 mm in diameter) singly into the upper surface of undamaged buddleia leaves of any age. The lifetime egg production averages 130 eggs per female, but one female laid 250. Eggs hatch after 14 days. Newly emerged larvae are 1–2 mm long and cream in colour. Larvae „graze‟ the upper surface of leaves, leaving only the lower hairy epidermis intact as a „window‟ (Zhang et al. 1993). The soft-bodied larvae are covered with mucus, and leave a trail of „slime‟ as they move. Most complete the four larval stages within 14 days (Zhang et al. 1993), by which time each has consumed 2–3.5 cm2 of leaf tissue (T. Withers, Forest Research, unpublished data). Larvae can slowly move as far as 1m to locate suitable leaf tissue. Heavily- damaged leaves wither, and the feeding of 1–3 larvae can cause the death of a 25-cm-tall buddleia plant (Xiao Xi Zhang, Nanjing Agricultural University, personal communication). Larvae are 5 mm long and translucent brownish-green in colour. Mature larvae spin silken cocoons that are firmly attached to the leaf or stem, or to leaf litter at the base of the plant. The cocoon hardens and turns brown. Within this puparium weevils develop
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 8 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
for 14 days (N. Kay, Forest Research, personal communication) before emerging. At 16 C, the development time from egg to adult is 53 days.
Cleopus japonicus has at least two generations each year, but larvae and adults are most common in spring and autumn. In China, high temperatures and long days (over 16 hours of sunlight per day) switch on a reproductive diapause that halts reproduction in high summer. If daily mean temperatures are below 20 C, as is the case everywhere in New Zealand, this does not happen. This suggests that if released here, this weevil may produce a further generation in mid-summer.
Kay (1991) observed severe damage by C. japonicus to 1-m-tall buddleia plants at one site in China, and noted that it seemed particularly suited to attack small plants in damp situations. Xiao Xi Zhang (Nanjing Agricultural University, personal communication) observed that buddleia rarely grew taller than 2 m because of insect attack. While C. japonicus clearly damages buddleia plants in China, how this damage affects the population dynamics of the plant has not been formally studied there.
It is inherently uncertain whether the level of damage observed in China will be reached or exceeded in New Zealand, because of uncertainty in: Whether C. japonicus will establish in New Zealand Where it will establish in New Zealand How large C. japonicus populations will become in New Zealand How damaging C. japonicus will be on New Zealand genotypes of buddleia in different habitats.
Cleopus japonicus belongs to the tribe Cionini of the sub-family Curculioninae of the family Curculionidae. There are no Cleopus species already resident in New Zealand or any genera in the same tribe (using the higher classification of Alonzo-Zarazaga and Lyal 1999). Kuschel (1995) would also support this interpretation. While there are no closely related indigenous weevils, the large sub-family Curculioninae is well represented in New Zealand (B. Barratt, AgResearch, personal communication).
Two biotypes of the parasitoid Microctonus aethiopoides have been introduced to attack two pest weevils. Experiments were conducted in quarantine to determine whether adult buddleia leaf weevils were susceptible to this species. Laboratory studies indicated that under caged conditions the parasitoids originating from Morocco attempted to lay eggs into buddleia leaf weevil adults as readily as into their true host, the sitona weevil. The Irish strain was significantly less attracted to leaf weevil adults than to its host, clover root weevil. Despite these observations, there was no evidence that eggs were laid, and no parasitoids were ever reared from adult buddleia leaf weevils. There was no evidence that probing reduced the lifespan of buddleia leaf weevils (M. McNeill, AgResearch, personal communication; Appendix 1). A third introduced parasitoid of weevils (Microctonus hyperodae) was not tested.
Three native parasitoids (Microctonus zealandica, M. alpinus, M. falcata) and one exotic parasitoid (Perilitus coccinellae) have been recorded attacking adult weevils in New Zealand. It is not known whether buddleia leaf weevils will be susceptible to attack from these parasitoid species.
Buddleia leaf weevil lays eggs into leaves, and so do indigenous leaf-mining weevils (B. Barratt, AgResearch, personal communication), and two pest leaf-feeding weevils. There are no native egg parasitoids known that 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 9 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
could attack leaf weevil eggs. However, Anaphes nitens is a small parasitoid of weevil eggs that was introduced from Australia in 1927 to successfully control the gum tree weevil, a serious forestry pest (Nuttall 1989). It is not known whether this insect will attack buddleia leaf weevil eggs.
Buddleia leaf weevil has leaf-feeding larvae. There are no indigenous weevils with leaf-feeding larvae, although a number of species have larvae that live in flowers or other neighbouring plant parts. There are no indigenous parasitoids known from these species that could attack leaf weevil larvae. The only two weevils known in New Zealand that have leaf-feeding larvae are the exotic vegetable weevil Listroderes sp., and gum tree weevil Gonipterus scutellatus. There are no larval parasitoids recorded for either weevil (Ferguson 1989, Nuttall 1989). Predatory pentatomid bugs have been recorded feeding on larvae of gum tree weevil (Valentine 1967), and buddleia leaf weevil larvae might be susceptible also.
Buddleia leaf weevils sometimes pupate in the litter on the soil, as do many indigenous weevils. Nothing is known of the natural enemies of weevil pupae in New Zealand.
Little is known about the patterns of parasitism or general predation of any stage of the life history of any weevil in New Zealand forests, and no firm conclusions can be drawn on how C. japonicus might interact with other species on or under buddleia bushes. Possible interactions with elements of the New Zealand flora and fauna are discussed further in Section 7.
With the possible exception of generalist leafrollers (T. Withers, Forest Research, personal communication), no native insects are commonly recorded from buddleia (Kay and Smale 1990). Buddleia leaf weevil will not compete with, or displace, native herbivores.
The sole foreseeable use for this species in New Zealand is for biological control of buddleia. Successful biological control would be achieved if partial or total defoliation of buddleia plants led to the death of a proportion of young plants, and reduced growth rate, vigour and reproductive capacity of mature plants.
There are no members of the same genus in New Zealand and there is no prospect of this insect interbreeding with another species.
Intensive searches using CABI databases revealed no literature concerning the ecology of Cleopus species except references to Forest Research research on C. japonicus.
3.5 Identify and characterise any inseparable organisms Inseparable organisms are those which are inherently associated with the main organism e.g. gut bacteria in an animal.
>Parasitoids known to attack C. japonicus in China (Kay 1991) were eliminated in laboratory culture in Nanjing Agricultural University (NAU) before the insects were shipped to New Zealand, and none of these have been encountered in breeding colonies in containment at Forest Research in Rotorua. Larval smears 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 10 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
were assessed for micro-organisms at NAU. Larval, pupal and adult smears were taken from the culture at Forest Research, and examined by staff of Biodiscovery NZ. They were unable to detect the presence of insect pathogenic micro-organisms (Appendix 1). Cultures breeding in containment at Forest Research remain strong and fecund.
3.6 If the organism to be released is a genetically modified organism, provide details on the development of the organism If the organism to be released is a genetically modified organism, state whether the development of the organism was carried out under a HSNO approval. If this was the case, provide the approval number and translate the relevant details to the headings below. If the genetically modified organism is to be imported for release, also provide this information on its development to the extent possible under the following headings:
Identify the category of the host organism (i.e. category 1 or 2) and genetic modification (i.e. category A or B) involved in the development of the organism with reference to the HSNO (Low-Risk Genetic Modification) Regulations 2003. Please explain your characterisation.
>Cleopus japonicus is not genetically modified
Vector system(s) used in development of the genetically modified organisms.
>N/A Type and source of additional genetic material.
> N/A
Use of special genetic material: please complete this table by marking the correct box N/A
Yes No Were native flora or fauna used as host organism(s)? Was genetic material from native or valued flora and fauna used? If native flora and fauna were involved, were the species concerned indigenous to New Zealand? Was human genetic material involved? Answer Yes if human genetic material in any form was used, i.e. obtained directly from humans (either Māori or non- Māori from a gene bank, synthesised, copied and so on). Was genetic material obtained directly from human beings? If Yes, provide additional details below.
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 11 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
If the genetic modification involves DNA of human origin, provide details of from where the material was obtained (including provenance and/or informed consent), and whether approval was obtained from an Ethics Committee, and/or whether consultation with Māori has taken place.
>N/A
Other relevant details (such as what techniques or experimental procedures were used, whether any unusual manipulations were carried out, and how the foreign genetic material is expressed).
>N/A
3.7 Does the organism have any other HSNO containment approvals not covered in 3.6 (e.g. import into containment, field test, or conditional release approval)? State whether the organism to be released has any other HSNO containment approvals. If this is the case, provide the approval number(s) and give brief details of those approvals.
> A copy of the import permit for this population (93/INV/12) can be found in Appendix 1. The population to be released is currently housed at the Invertebrate Quarantine and Containment Rooms at the Forest Research Quarantine Facility approved as a containment facility (Ref no. 2746) at the premises of Forest Research Institute, Rotorua.
Section Four – The Proposed Release Programme (and Monitoring) Provide full details of your intended release programme e.g. information on the breeding and culture, and the life-stage and number of the organisms to be released; timing and location(s) of release etc. Also provide information on any post-release monitoring you intend to carry out.
> Forest Research‟s strategy for releasing control agents will only be finalised once it has been confirmed what resources will be available. The agent will be released at as many places throughout New Zealand as such resources allow. At the very least, 100 adults will be released onto buddleia plants at two sites in Whakarewarewa and Kaingaroa forests in 2004. These sites will be visited four times per year for 3 years to assess whether the weevil has established.
It will not be possible to estimate the likely success of this project until the performance of the agent can be assessed following release in New Zealand. Post-release monitoring is planned for 2004–2007. Forest Research is currently developing a model of C. japonicus population dynamics, and intends to integrate this with a process-based model of buddleia growth and the predicted effects of herbivory on that growth funded by a Foundation for Research, Science and Technology contract CO4X0302. Once the weevil is established in New Zealand, the growth of populations at least one site will be measured, and observations will be compared to model predictions. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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The presence or absence of C. japonicus on non-target species of Scrophulariaceae growing beneath and around buddleia will be monitored at two sites four times per year from 2004–2007. Any effects on non-target plants will be recorded, and compared with experimental predictions (Appendix 2). Funding for this longer-term research will be sought from FRST, and from forestry companies through the recently-formed Forest Health Research Group.
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 13 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Section Five – Establishment and Eradication of Undesirable Self-sustaining Populations Information under this heading is required so that the Authority can take account of the matters set out in section 37 of the Act.
5.1 Ability of organism(s) to establish an undesirable self-sustaining population Describe any ability of the organism to establish an undesirable self-sustaining population. This may include, but not be restricted to, information on the time taken for the organism(s) to become established, the likely geographical spread of the organism(s), and effects of variations in climate and altitude on the establishment, distribution, abundance and biology of the organism(s). Explain why such a population would or would not be undesirable. For a full (unconditional) release the issue of (un)desirability is crucial, because in many cases the establishment of a self-sustaining population will be expected (e.g. a bio-control release).
> The concept of „escape‟ implied in this question are not relevant to this application, as the primary reason for the application is to release the control agent, and to establish self-perpetuating populations wherever buddleia grows in New Zealand.
5.2 Ease of eradication of an undesirable self-sustaining population Information under this heading should be provided unless the information under section 5.1 clearly indicates that establishment of an undesirable self-sustaining population is highly improbable.
N/A
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 14 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Section Six - Identification of Risks, Costs, and Benefits Risk means the combination of the magnitude of an adverse effect and the probability of its occurrence. Cost means the value of a particular adverse effect expressed in monetary or non-monetary terms. Benefit means the value of a particular positive effect expressed in monetary or non-monetary terms. In this part of the form you are required to identify the risks, costs and benefits of the organism(s) in the context of the application.
A very broad approach should be taken to this, so that a wide range of possibilities are canvassed. In the first instance you are required to identify all potential risks, costs and benefits whether you consider them to be non-negligible or not. This should be carried out for inseparable organisms as well as for the principal organism. To do this effectively you should consider both the source of the risk (or hazard) and what is at risk (or area of impact). You should also consider the route (or exposure pathway) between the source and the area of impact.
Essentially what you should end up with is a very brief description of the risks, costs and benefits (e.g. the potential for the pathogenic micro-organism (hazard) to have adverse effects on human health (area of impact) from consumption of the organism (exposure pathway). A more detailed assessment of these and other matters will be required in the next section (section 7).
Once you have considered all possibilities then you should clearly identify those risks, costs and benefits which warrant further more detailed assessment (in section7). If you consider that the effects identified do not warrant detailed assessment, explain why.
You can refer to the ERMA New Zealand Technical Guides “Identifying Risks for Applications” and “Risks, Costs and Benefits for Applications for further information and guidance on completing this section. These are available from the ERMA New Zealand website or in hard copy on request. Please undertake your identification of risks, costs and benefits under each of the following headings (areas of impact) which reflect those matters referred to in Part II of the HSNO Act:
6.1 Identification of effects on the environment (in particular on ecosystems and their constituent parts) Taking particular account of sections 5(a), 6(a) and 6(b) of the Act, list the environmental risks, costs and benefits associated with the organism(s) to be released and any inseparable organisms. Risks, costs and benefits in this category include those relating to the life supporting capacity of air, water, soil and ecosystems; the sustainability of native and valued introduced flora and fauna; the maintenance of natural habitats; the intrinsic value of ecosystems; New Zealand‟s inherent genetic diversity; and animal or plant health.
List risks and costs, and benefits, separately.
Risks and costs:
>The Department of Conservation, all regional councils, Royal Forest and Bird, Te Urewera National Park and the East Coast Hawkes Bay Conservation Board were approached for comment (Appendix 1). All of the risks and costs that have been identified are listed in Table 1, and the likelihood and magnitude of each effect is briefly assessed. The most important direct effect assessed further in Section 7 is the possibility that weevils 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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could damage native plants or valued exotic species. Possible indirect adverse environmental risks could flow either from successful biological control of buddleia or from the effects of inserting a novel weevil population into the New Zealand ecosystem. Section 7.1 assesses whether rapid changes in buddleia infestations resulting from biological control could adversely impact on stream hydrology and water quality, or whether the introduction of C. japonicus populations could adversely affect food chains and ecosystem structure. There is uncertainty whether these latter effects would be adverse or beneficial to the environment of New Zealand.
Benefits:
>Benefits of this proposal to the environment and to ecosystem processes arise from the potential reduction in the vigour and abundance of buddleia in both native and modified habitats. It is uncertain whether some of the possible effects identified in Table 1 would be adverse or beneficial to the environment. Potential benefits could also arise from improved aesthetics and landscape values (Section 7.1)
The considerable potential benefits are largely non-monetary.
6.2 Identification of effects on human health and safety (including occupational exposure) Taking particular account of section 6(c) of the Act, list any potential risks, costs and benefits to human health that may be related to the release of the organism(s) in New Zealand. Consider the impact on people
associated with the release programme as well as the wider community.
List risks and costs, and benefits, separately.
Risks and costs:
> All of the risks and costs that have been identified are listed in Table 1, and the likelihood and magnitude of each effect is briefly assessed. No non-negligible effects were identified.
Adult insects will be reared on potted plants in the laboratory, and then released from a small box onto buddleia bushes. No adverse risks specifically related to the rearing and release process have been identified.
If C. japonicus populations were high, adult weevils might be sufficiently abundant to cause a nuisance indoors. Larvae have a slimy covering, and might cause offense if someone brushed against infested leaves. Both effects would only be true in rare or local cases, where buddleia grew near a habitation. The risk is therefore regarded as unlikely and minor.
Buddleja species play a minor role in the ethnopharmacology of several areas of the world. Leaves and roots are used as an antiseptic, as a diuretic and for other uses (Houghton 1984). There are a significant number of papers describing research to isolate the active constituents of buddleia that cause these effects. None of this research occurs in New Zealand. Successful biological control of buddleia would limit the minimal and as yet 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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speculative, future use of buddleia for this purpose. This effect could be mitigated by protecting plants from C. japonicus attack.
Benefits:
>Successful biological control of buddleia might reduce the use of herbicide in the community, and might reduce the likelihood of industrial accidents related to forest tending practices (such as spraying, chain saw use, slashing). Although both effects are not unlikely, the overall effect would be minor. No non-negligible benefits were identified.
6.3 Identification of effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna and other taonga (taking into account the principles of the Treaty of Waitangi) Taking account of sections 6(d) and 8 of the Act, list any adverse and beneficial effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna and other taonga (taking into account the principles of the Treaty of Waitangi). In this area it is especially important to indicate the extent to which the effects reflect the expressed views of the Māori community. However, details on these views and how they were obtained should be dealt with under the assessment section (section 7).
List risks and costs, and benefits, separately.
Risks and costs:
> Details of consultation with Māori organisations can be found in Appendix 1. All of the risks and costs that have been identified are listed in Table 2, with a brief assessment of each effect.
Benefits:
> Reducing the abundance and vigour of buddleia in riparian habitats would restore native flora and fauna, and hence the mauri of those species. No other specific direct benefits to Māori culture, traditions, and other taonga from the introduction of C. japonicus have been identified, except for the benefits from buddleia suppression on Māori forestry (Section 7.3). All other indirect and direct economic and environmental benefits of this proposal presented in Section 7 accrue as much to Māori as to the wider New Zealand community.
6.4 Identification of economic and related effects
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Taking particular account of section 6(e) of the Act, list the economic risks, costs and benefits that might arise to New Zealand. Include related effects (e.g. scientific knowledge), which are likely to have economic or related value.
List risks and costs, and benefits, separately.
Risks and Costs:
> All of the risks and costs associated with economic and related effects that have been identified are listed in Table 1, or are mentioned elsewhere in Section 6.
Benefits:
>Potential economic benefits from reducing the impact of buddleia on the New Zealand forest industry are assessed in Section 7.4.
6.5 Identification of cultural, social, ethical and spiritual effects Taking particular account of section 5(b) and the full definition of “Environment” in section 2 of the Act, list any adverse and beneficial impacts on people and communities that might arise and relate to their capacity to provide for their own social and cultural wellbeing both now and into the future. Also list any ethical or spiritual risks, costs and benefits that might arise as per section 68(1)(a) of the Act. Indicate what steps have been taken to assist the identification of the effects in this area, for example, was there any community involvement? However, details on this should be dealt with under the assessment section (section 7).
List risks and costs, and benefits, separately.
Risks and Costs:
> All of the risks and costs that have been identified are listed in Tables 1 & 2, and the likelihood and magnitude of each effect is briefly assessed. Results indicate that it is likely that C. japonicus will lay eggs on and larvae will complete development on ornamental species within the genus Buddleja (Appendix 1). The effects of this on the garden industry and gardeners is assessed in Section 7.5. If C. japonicus populations were high, adult weevils might be sufficiently abundant to cause a nuisance indoors. Larvae have a slimy covering, and might cause offense if someone brushed against infested leaves. Both effects would only be true in rare or local cases, where buddleia grew near a habitation. The risk is therefore regarded as unlikely and minor.
Benefits:
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>Apart from those considered elsewhere in Section 6, and in Tables 1 and 2, no benefits have identified. successful control of buddleia would limit or eliminate the spread of buddleia into areas of high landscape value.
6.6 Identification of other effects (including New Zealand’s international obligations) List any remaining adverse and beneficial affects not already covered including any effects on New Zealand‟s international obligations (as per section 6(f) of the Act).
List risks and costs, and benefits, separately.
Risks and costs:
>No other risks and costs have been identified.
Benefits: >No other benefits have been identified.
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Section Seven – Assessment of Potential Non-negligible Risks, Costs and Benefits This section entails detailed assessment of those effects identified in section 6 that you consider to be non-negligible. The assessment should describe the nature of the effects and should discuss, in more detail than in section 6, the source of the effects and the pathways leading to them. Assessment also entails providing an estimate of the likelihood of occurrence (which may be measured as frequency or probability) and the magnitude of the outcome if the effect should occur. The degree of uncertainty associated with the assessment should also be analysed. The factors set out in clause 33 of the HSNO (Methodology) Order 1998 which outlines various risk characteristics that will influence the decision-makers approach to risk should be referred to. These include characteristics such as the risk will persist over time or the potential adverse effects are irreversible. In such instances the Authority will be more cautious and risk averse when considering such matters.
You should carry out your assessment taking into account the matters regarding undesirable self-sustaining populations set out in section 37 of the Act (and addressed in section 5 of this form). ERMA New Zealand uses qualitative scales for assessing effects which may be of some use to you in completing this section – please refer to the ERMA New Zealand Technical Guide “ Decision Making: techniques for identifying, assessing and evaluating risks, costs and benefits” for further details. Please cover all of these issues under each of the following headings (areas of impact) which reflect those matters referred to in Part II of the HSNO Act:
7.1 Assessment of effects on the environment (in particular on ecosystems and their constituent parts) Assess the risks, costs and benefits associated with the organism(s) to be released and the ways that they might adversely affect or improve/enhance (in the case of benefits) the New Zealand environment e.g. the life supporting capacity of air, water, soil and ecosystems; the sustainability of native and valued introduced flora and fauna; natural habitats and the intrinsic value of ecosystems; New Zealand‟s inherent genetic diversity; animal or plant health.
Assess risks and costs, and benefits, separately. Where benefits and risks are linked, state this (e.g. a bio- control which has an impact on both the target organism (benefit) and non-target organisms (risk)).
Risks and costs:
> Direct effects The greatest direct risk to the New Zealand environment is the possibility that C. japonicus might damage non- target plants such as natives or desirable exotics. This risk has been examined experimentally by testing whether C. japonicus can lay eggs on a range of plant species, and whether larvae transferred onto test-plants can feed and complete development. A full account of the methodology employed, and the results of the tests are presented in appendix 2. The methods used were consistent with those recently recommended by Withers et al. (1999). Test plants were selected using the internationally accepted “centrifugal phylogenetic system” guidelines (Wapshere 1974), based on the premise that plants more closely related to the target weed are more likely to be attacked by an insect than those that are less closely related. The host-plant testing concentrated on species that are closely related to buddleia, but a number of less closely related native and economically important species were also tested. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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Buddleia leaf weevil adults could not lay eggs on, or feed on any of the 35 species belonging to 24 families outside the Scrophulariaceae and Buddlejaceae that were presented in preliminary tests in China, or in tests conducted in New Zealand. Although the range of species used was smaller, starvation tests indicated that newly hatched larvae could not develop on plants this distantly related to buddleia. These results strongly suggest that there is negligible risk that environmentally or economically important New Zealand plant species outside the Scrophulariaceae or Buddlejaceae are at any risk from this insect.
Weevils did not lay eggs on any of the 11 native species of the family Scrophulariaceae presented in tests (8 genera, including 4 species of Hebe). Cleopus japonicus is therefore incapable of colonising these species and building damaging populations.
Even if eggs are laid on a host plant, damaging populations can only arise if hatching larvae can produce fertile adults to further build the population. There are approximately 100 species of Hebe in New Zealand, and over 15% of these were tested in either oviposition or larval starvation tests. Newly hatched larvae transferred to the foliage of 14 Hebe species died quickly (with one exception) without completing development, and these species too appear safe from colonisation from C. japonicus. Larval tests on other species belonging to native genera confirmed the conclusion from oviposition tests that there is little risk that populations of this weevil could colonise other native Scrophulariaceae.
Adult weevils were observed to take small sample bites from the leaves of some native species in the family Scrophulariaceae, but no eggs were laid. There was no adult feeding or oviposition on seven other native species that commonly grow in New Zealand in the same forest ecosystems as buddleia.
Larvae transferred onto native plants in the family Scrophulariaceae were unable to feed at all on 7 of the 11 species presented. There was slight feeding on two species before larvae died, and 20% of larvae completed development on two species, G. elatinoides and L. lineata.
No eggs were laid on any native species (including Glossostigma elatinoides and Limosella lineata), and so it is very unlikely that first or second stage C. japonicus larvae would encounter such plants. Despite the larval feeding noted in experiments, we conclude that it is very unlikely that C. japonicus could develop self- sustaining populations on any native plant species, and that the risk of incidental damage to natives from vagrant larvae is both unlikely and small.
Tests were conducted on a range of plant species not native to New Zealand. Thirteen Buddleja species were tested. Most have some value as ornamental species, and as shelter and bee fodder (B. salvifolia). The performance of C. japonicus varied greatly between Buddleja species. Adults fed poorly, and failed to oviposit on B. salvifolia. Larval mortality was high. Larvae also fed poorly on B. auriculata, B. parviflora, B. globosa, and B. madagascariensis, and larval mortality was high. However, for the remaining eight species tested, adults were able to oviposit on the test species to a lesser or greater extent and at least some larvae completed development to become adults.
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Experiments suggest that, if released in New Zealand, C. japonicus could produce self-sustaining populations on Buddleja species other than B. davidii. The ecological and economic consequences of this vary from species to species. Some are valued plants, others potential weeds. B. salvifolia flowers in spring, and is valued as fodder for bees (Kay and Smale 1990). No eggs were laid on B. salvifolia, and it is unlikely that this species would be colonised by B. davidii. Although relatively unattractive in the presence of B. davidii, B. lindleyana, B asiatica, and B. madagascariensis also supported complete development of this insect. These species are considered strongly invasive on the west coast USA (Randall and Marinelli 1996), and foliage damage to these species may limit the development of this potential in New Zealand. Five species of Buddleja have already partially naturalised in New Zealand, including B. globosa, and B. madagascariensis. B. globosa was also adequate as a host in experiments. Randall and Marinelli (1996) did not consider this species invasive, and attack by C. japonicus may limit any potential ornamental value this species has. In fact, Buddleja species do not appear to be highly valued as ornamentals (see section 7; Appendix 1).
Eight additional exotic plant species belonging to the family Scrophulariaceae were tested, including four common exotic ornamentals (Mimulus sp., Phygelius capensis, Antirrhinum cv., and Nemisia cv. (common names: monkey musk, Cape fuchsia, snapdragon, and nemisia). Although these and native species in the Scrophulariaceae appeared immune from C. japonicus attack, the European species Verbascum virgatum (moth mullein) and Scrophularia aquatica (water figwort) appeared to be at least partial hosts. V. virgatum is the host of a related Cleopus species in Europe and C. pulchella has been recorded on B. davidii in Europe.
In the absence of buddleia, tests showed that adult weevils nibbled foliage of other species. This is common in weevils. Similarly, newly hatched larvae often undertook exploratory feeding before dying of starvation. In neither case was wholesale damage to non-target foliage ever recorded in tests. Nevertheless, both weevil larvae and adults are capable of causing incidental damage to non-target plants.
Cleopus japonicus larvae rarely move far, and are not prone to being dislodged. Nevertheless, it is conceivable that if larval populations on a buddleia bush became large or if the bush became defoliated, exploratory feeding on plants by wandering weevil might occur on plants up to 1 m away from the host. If eggs can only be laid in buddleia leaves, any theoretical damage by moving larvae would be restricted to plants growing beneath or touching buddleia plants.
Similarly, the exploratory feeding damage caused by individual adult weevils is insignificant. However, the purpose of this introduction is to develop populations of weevils large enough to severely damage buddleia. Foliage of species of the Scrophulariaceae growing in the immediate vicinity of buddleia infestations may accumulate damage from vagrant adult weevils. As these plants are not attractive as oviposition sites, this damage is likely to be light, incidental and certainly local.
Indirect effects Possible indirect adverse environmental risks could flow either from successful biological control of buddleia or from the effects of inserting a novel weevil population into the New Zealand ecosystem. Possible risks are listed in table 1, and the significant risks are discussed in this section.
Foliage of Buddleja asiatica, B. curviflora and other species has been used by indigenous populations in Asia to stupefy fish (Houghton 1984). This capability may be present in B. davidii foliage although no such effect 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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has been reported in the recent scientific literature (CABI Abstracts 1990–). Leaves falling naturally into infested waterways may be affecting fish welfare. If so, and if C. japonicus caused increased leaf fall into streams, then activity against fish in buddleia-infested streams might increase. Although it is possible that such an increase in the rate of leaf abscission could occur, the effect would be localised, and the marginal increase in risk is considered minor.
If biological control caused catastrophic damage to buddleia populations in stream beds and margins, loss of cover could lead to changes in stream insolation, erosion, decline in water quality, and associated hydrological effects (Table 1). The likelihood of such a catastrophic (as opposed to gradual) reduction in buddleia survival and biomass is extremely low. Any effects would be temporary and localised until alternative vegetation colonised the stream margins. The overall risk is therefore considered minimal.
The establishment of C. japonicus in New Zealand would introduce a new element to ecosystems existing in and around buddleia plants and populations. With the possible exception of generalist leafrollers (T. Withers, Forest Research, personal communication), no native insects are commonly recorded from buddleia (Kay and Smale 1990). C. japonicus populations on buddleia will not therefore displace any similar native or exotic species. However, populations will add to the biomass of insects in the environment. This population will be available to resident native and exotic predators and parasitoids.
Secondary effects could ensue if changes in the abundance of resident predators and parasitoids generated by utilisation of the weevil population had an adverse effect on populations of native insects (Table 1). Given the unique biology of the buddleia leaf weevil, and its taxonomic distance from native weevils (section 10), it is unlikely to interact with indigenous, host-specific, or near-specific parasitoids and predators of weevils in New Zealand. Generalist predators or parasitoids may be able to use buddleia leaf weevil, although the slimy covering on larvae may confer partial protection.
The introduction of C. japonicus larvae and adults to New Zealand will increase the number of prey available to general predators. This could lead to greater predation in the ecosystem generally, particularly within or bordering the buddleia stand. However, C. japonicus will make up only a small proportion of the total number of insects in the environment, and so the marginal increase in prey biomass will be very small.
The potential indirect effects of introducing C. japonicus (whether beneficial or adverse) will be insignificant unless populations of the weevil become large. As C. japonicus is host-specific, populations will only be large where buddleia is abundant. Here ecosystems and ecosystem processes such as predation and parasitism will already be heavily modified by the presence of the weed. Any adverse effects directly attributable to the presence of the weevil are likely to be insignificant by comparison. Where buddleia is uncommon, weevil populations will be small and localised, and any risks to native fauna through secondary non-target impacts will be minimal.
In all of the scenarios proposed above and in Table 1, uncertainty surrounding the likelihood and magnitude of the effects is large. It is even difficult to predict whether most effects are likely to be adverse or beneficial, and in some of those scenarios it is reasonable to assume that this will vary from place to place and from time to time. There has been no research in this area that is directly relevant to biological control of weeds, and it is difficult to imagine how research of general application could be conceived. Uncertainty in this area is 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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therefore considered unmanageable, but in general, the magnitude of the risks is predicted to be minor to minimal.
Benefits:
> Benefits of this proposal arise from the potential reduction in the vigour and abundance of buddleia in natural habitats. Flood events produce fresh alluvial deposits in the New Zealand streams and riverbeds. Erosion in forests and falling trees also create bare soil in light gaps. Originally, these deposits were colonised by a range of native herbs and grasses, and by native woody shrubs such as kanuka and tutu. Now adventive species often take root in such areas. If it is present, buddleia is particularly aggressive, and quickly displaces all other species, including the natives. Because it is relatively short-lived (around 30 years), the time required for succession to native vegetation through buddleia is shorter than through native nurse crops such as kanuka (80– 100 years). While this could be regarded as a good thing, succession through buddleia is not the natural process. It displaces the native pioneer plants along with the insects, fungi and other organisms normally associated with those plants. Where disturbance is frequent, colonisation can be initiated again and again, prolonging buddleia dominance, and eliminating natives from parts of the ecosystem (Smale 1990a, b; Kay and Smale 1990). Brockerhoff et al (1999) have shown that feeding by C. japonicus can reduce the vigour, height and leaf area of small buddleia plants. In the field this would reduce the competitive ability of buddleia, increasing the probability of coexistence between buddleia and native species, replacing weeds with native plants, and partially restoring the natural succession process.
Buddleia populations are expanding rapidly in the Queenstown Basin. It is spreading down the Kawerau River, and threatens to invade Southland (Dr Carol West, Regional Scientist, DoC, Invercargill, personal communication). It is also spreading north along the lakeshore. It therefore threatens the integrity of the iconic Routeburn and Dart river valleys, and the value of tourism in the Glenorchy area.
7.2 Assessment of effects on human health and safety (including occupational exposure) Assess any potential risks, costs and benefits to human health that may be related to the release of the organism(s) in New Zealand. If effects in this area are likely to be significant a full health assessment as set out in the relevant ERMA New Zealand technical guide may be warranted.
Assess risks and costs, and benefits, separately.
Risks and costs:
>No non-negligible effects have been identified
Benefits:
> No non-negligible effects have been identified
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7.3 Assessment of effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna and other taonga (taking into account the principles of the Treaty of Waitangi) Assess the adverse and beneficial effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna and other taonga (taking into account the principles of the Treaty of Waitangi). If there are potentially non-negligible effects to consider in this area, it is expected that consultation will have occurred with Māori. Give details of this in the space provided (see the User Guide for what is required).
Assess risks and costs, and benefits, separately.
Consultation with Māori:
> In 2000, 15 major iwi were contacted and asked to comment on the proposal to release C. japonicus for buddleia control. Considerable background information was provided. Two iwi responded to that approach and after correspondence with Forest Research staff one chose to oppose the proposal and the other requested that more consideration be given to safety of the agent (Appendix 1).
This proposal was presented and discussed at a joint meeting of the Māori Regional Representative Committees of Environment Bay of Plenty in 2002. Participants represented tāngata whenua from the areas currently most affected by buddleia.
In 2002, with the advice of ERMA NZ, the views of tāngata whenua on the effect of introducing the leaf weevil were canvassed before this application was written. Fifty-two iwi, hapu and rūnanga were approached for advice on what issues to address in the proposal. The information provided, and the list of organisations consulted can be found in Appendix 1. Responses were obtained from two of these organisations, and their responses can also be found in Appendix 1. Both organisations have been provided with further information on the issues raised, and a draft copy of this application in case they wish to respond further during public consultation.
In response to pre-application consultation, One iwi asked that the application fully explain the effect that buddleia might have on indigenous flora and fauna, and hence on mahinga kai, natural resources and other taonga tuku iho, wāhi tapu, and wāhi taonga. They were willing to accept biological control as a last resort over herbicides or GM solutions, but highlighted concerns over potential adaptation, interbreeding, and risks to non-target species and ecosystems. The other iwi that responded strongly opposed the proposal, labelling the idea repugnant. They cited the panoply of exotic pests in New Zealand as examples to demonstrate how introductions go wrong, and suggested that adaptation to alternative hosts was likely. They suggested that human labour was a more appropriate approach to buddleia control.
These were the only responses received. We interpret this as either tacit approval of the risk assessment approach that was outlined in the consultation document, or a choice to defer comment until the application became available for public consultation (Appendix 1). It is likely that the breadth of views within the Māori community about the propriety of introducing new organisms to New Zealand is as diverse as it is in the New Zealand community as a whole. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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Risks and costs:
>The key concern of both iwi was the host-specificity of the buddleia leaf weevil, any potential it might have to damage native species, and the impact this might have on habitats. These risks are assessed carefully in Sections 7.1 and in Appendix 2. The safety record of intentional introductions for the biological control of weeds around the world is good. Of over 400 introductions made for this purpose, it seems that only two cases are likely to result in significant damage to non-target plants, and neither of these cases happened in New Zealand (Fowler et al 2000). Many insects (perhaps most) can only feed on one or a few plants. For example, monarch butterflies only feed on swan plants, and the caterpillar that attacks kawakawa leaves does not attack surrounding plants. It is only insects such as these, feeding on a limited range of plants that are considered for biological control of weeds in the first place. Then experiments are designed using proven methods to check further that the insect doesn‟t pose a significant threat to plants in the target country (Appendix 2). There has never yet been a record of a weed biological control insect „adapting‟ to new hosts (Marohasy 1998), and it is more difficult for a specialist insect like this weevil than for insects with a wide host-range (for example, monarch butterfly has not „adapted‟ to new plants). Nevertheless, as with any of the thousands of insect species already resident in New Zealand, the possibility of such a shift occurring over distant evolutionary time cannot be ruled out. This weevil has no close relatives in New Zealand, and interbreeding is not possible.
The alternatives to biological control for the management of buddleia are herbicides and mechanical or manual control. It costs approximately $1,000 per day to apply control measures for scrub weeds such as buddleia from the ground. This applies to the costs of a contactor applying herbicide (including costs of herbicide, equipment, labour), or a 5-person ground crew cutting plants and killing the stumps (including costs of labour, supervision, health and safety, equipment, transport, training etc). The area that can be treated in a day by a ground crew ranges from 0.5 ha per day for dense scrub weed, to 5 ha per day for areas with sparse cover. Where buddleia is at low plant density, or is at the edge of an expanding range, treatment by ground crew is good practice to stop the spread of seed and new plants, and to limit occupation of the habitat. Biological control cannot achieve this. However, buddleia is a widespread weed, occupying many thousands of hectares, and is spreading. It is colonising and threatening habitats that are remote from human activity. The scale of the problem and the inaccessibility of most infestations makes reliance on conventional control tactics to suppress the impact of buddleia impractical.
In addition to the issues raised during consultation, the risks that the introduction of C. japonicus might pose to Māori environmental, cultural, and spiritual values are identified and evaluated in Table 2. Research indicates that the risk that C. japonicus will colonise and form viable populations on any indigenous plants valued by Māori is low (Appendix 2; section 7). Experiments suggest that there is a small risk of damage to plants growing next to, or beneath buddleia, but not further away. The risk of direct impact on flora and fauna, habitats, mahinga kai, and hence their spiritual essence is therefore considered low. Indirect effects are more difficult to predict. The new insects may become prey for exotic and indigenous parasitoids and predators, in the immediate vicinity of buddleia (where the leaf weevil may be common) but the interactions further afield will be negligible. The introduction of a buddleia-feeding insect will also alter the way in which buddleia interacts with other plants and animals. It is likely that buddleia has already severely modified most heavily infested ecosystems by reducing the biomass and diversity of other plants, displacing food for indigenous 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
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herbivores, parasitoids and predators, and by changing soil chemical processes. The nature and intensity of any ecosystem disruption will probably be variable from place to place, and from time to time. Introducing C. japonicus into such a changeable system is unlikely to induce any change in ecosystem function that could be reliably measured. However, the most likely scenario is that the effects of the weevil on buddleia will partially or wholly restore ecosystem balance to pre-buddleia levels by making buddleia less competitive over time. The weevil might therefore contribute to the restoration of mahinga kai, the re-establishment of valued plants and the associated fauna, and maintain the life-sustaining capacity of water and soil. It is difficult to conceive of a scenario (including replacement by another weed) where introduction of biological control could make the current situation worse.
Benefits:
> Benefits of this proposal would accrue if the weevil reduced the adverse effects of buddleia. Buddleia is abundant in the Central North Island, but is spreading further (Appendix 1). It can invade disturbed land anywhere, but is most common on stream banks and beds, the natural habitat of many native plant species valued by Māori. There it pushes out native colonisers such as kanuka, and flax. Some of these native species are of limited distribution, and so buddleia has the potential to cause extinction, at least locally. Buddleia modifies stream environments, perhaps irreversibly, and so has a profoundly adverse effect on mahinga kai, on other natural habitats, on associated plants, on indigenous flora and fauna, and on the purity of land and water. Biological control agents could reduce the competitive ability of buddleia, and limit those adverse effects.
Buddleia limits the profitability of forestry in the central North Island (section 7), including many forests owned or operated by Māori. Biological control by C. japonicus has the potential to reduce the costs of weed control in forests, increasing returns to Māori forestry. Benefits in the plantation environment might be limited if buddleia was replaced by another weed, but evidence suggests that (along with pampas) buddleia is the scrub weed most damaging to pine trees in the Central North Island (Richardson et al 1999).
Partial restoration of natural regeneration will increase the diversity of native flora and fauna, and will benefit the mauri of that flora and fauna. Buddleia infestation is limiting access by Māori up several rivers in Te Urewera National Park (Appendix 1).
7.4 Assessment of economic and related effects Assess the potential magnitude and distribution of the economic and related risks, costs and benefits. Effects on third parties and to New Zealand of the proposed release need to be specifically evaluated. If economic effects are significant applicants should provide a cost benefit analysis. Guidance on the requirements for cost benefit analyses are set out in the relevant ERMA New Zealand Technical Guide.
In this case it is still helpful to assess risks and costs, and benefits, separately but if possible these assessments should be drawn together into an overall cost benefit analysis. As a part of this, estimate net benefits.
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> Forest Research estimates the costs of the project from its initiation in 1990 to the present at $600,000. The maintenance, rearing and initial release of the weevil to December 2004 is estimated to cost a further $140,000. From January 2005 to July 2007 the expenditure on buddleia research specifically related to monitoring weevil performance and the assessment of impacts is estimated at $180,000 under FRST contracts COX0302 and CO4X0202. No other significant economic costs are envisaged.
Benefits:
> Monetary benefits would result if biological control reduced the current costs of managing buddleia. Benefits can be calculated as the reduction in control costs incurred by individuals, organisations, regional councils, the Department of Conservation, and to production gains in the forestry industry.
Fourteen regional and unitary authorities were asked to describe the status of buddleia within their regions, and what costs buddleia imposed on ratepayers. Eleven responded (Appendix 1). Buddleja davidii is present in all authority areas except Southland. It is uncommon in some regions, but widespread in others. All surveyed were aware of the problem, and were taking appropriate action. In regions where it is common or abundant, buddleia is not a priority for control, but only because the problem is so large that such action is considered both impractical and too costly. It is therefore not listed in any regional pest management strategy except to ban it from sale, or to allow surveillance and risk assessment. No regional councils are expending significant sums of money on control because buddleia is either effectively contained by small expenditure, or is too large to justify the expenditure that would be required to have a significant impact. Regional councils could not estimate private expenditure within the region. Horizons mw reported that buddleia is scattered through most river systems in the region, including the Rangitikei, Wanganui and Manawatu rivers, and is spreading (Appendix 1).
The Department of Conservation (DoC) was unable to estimate the national cost of buddleia control operations because costs are recorded by site rather than on a weed-by-weed basis. However, 10 of 13 conservancies actively control buddleia to some degree (K. McAlpine, DoC, personal communication).
The inability of Regional Councils and DoC to define current expenditure makes estimation of potential savings to these organisations from successful biological control of buddleia difficult. The cost of deploying a contractor or a work team is similar, and is estimated at $1,000 per day. For the purpose of this analysis it is assumed that the total annual effort applied to buddleia control by organisations other than the forest industry in New Zealand is approximately 100 days, and that the potential saving from successful control of buddleia is approximately $100,000 per annum. $1000 to 10,000 is expended annually in Te Urewera alone (T. Withers, Forest Research, personal communication)
Buddleia is a well-established and widespread plant pest of exotic forestry in the Bay of Plenty Region. Control is necessary so that new rotation forestry planting can establish. Buddleia is also well established within indigenous forests of the Bay of Plenty Region. It typically infests skid sites and other disturbed areas
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of cut-over forest (e.g. Kaimai-Mamaku Forest Park) or slip sites and creek beds of undisturbed forest (e.g. Te Urewera National Park, Smale 1990a).
Biological control of buddleia would generate the largest economic benefit by reducing the losses in exotic forest productivity attributable to buddleia competition, and reducing the costs of buddleia control. Forest Research staff estimate that forestry companies are currently spending $0.5 million annually in the central North Island in control measures aimed primarily at buddleia. Estimating the costs of buddleia to plantation forestry is not a straightforward exercise. Accurate assessment requires consideration of:
The distribution and abundance of buddleia within the plantation forestry estate. The effect of buddleia on tree growth and survival and the costs of removing buddleia. The response of buddleia and other vegetation to the treatment (i.e. biocontrol).
There are limited quantitative data to carry out an analysis of this type. Therefore a simple approximation has been made to give an idea of the likely scale of costs.
There has not yet been a national survey of buddleia distribution within New Zealand (B. Richardson, Forest Research, personal communication) although one is planned. Personal observation and information on buddleia ecology suggests that its potential range would encompass most if not all of the plantation forestry estate. At present, buddleia is probably most widespread in the Central North Island / Bay of Plenty, and only this region is considered in the following analysis.
The area of the Central North Island planted in trees is approaching 600,000 ha. It is conservatively assumed that buddleia is a problem in 10% of this region (60,000 ha).
A number of studies have demonstrated the competitive effects of buddleia on young radiata pines (Richardson et al. 1996, 1999). Weeds reduce growth rates of trees, and this is reflected in a 1–4 year delay in reaching harvestable size. There are heavy opportunity costs for such delay (Richardson and West 1993). Stands growing in the presence of buddleia are likely to have their growth severely restricted and tree mortality may occur. Therefore benefits from removing buddleia are likely to be at the high end of the range reported by Richardson and West (1993) as long as it is not replaced by a plant that is equally competitive.
In Central North Island forests, buddleia normally dominates other weeds as successfully as it does pine trees, but biological control of buddleia could change which weed achieves dominance. Heavy destruction of buddleia in the first years of forest establishment could allow an equally damaging weed such as broom or pampas grass (Richardson et al. 1996) to emerge in its place. This would be no more damaging to pine production than buddleia domination, but at the same time there would be no economic benefits from biological control of buddleia. In fact, laboratory studies indicated that moderate levels of C. japonicus infestation would result not in massive plant mortality of buddleia, but more likely in suppression of buddleia growth in young plants (Brockerhoff et al. 1999). With growth and biomass accumulation suppressed by biological control, buddleia could continue to dominate other weeds, especially if biological control was most active in older plants (after other weeds were suppressed). In this scenario, there would be benefits from successful control, but probably towards the lower end of the range (1–2 years delay in rotation as opposed to
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3–4 years). In reality, it is likely that the benefits of biological control are likely to vary both spatially and temporally.
A range of possible growth-benefit scenarios have been used to calculate the economic benefits of biological control of buddleia to plantation forestry. Calculation of the change in net present value for stands given weed control is not straightforward and answers vary considerably with assumptions relating to treatment costs, timing of treatments, interest rates, harvest age, and log prices. Table 3 presents a range of values for possible economic benefits (in terms of net present value) from successful buddleia biocontrol. Benefits were calculated using net stand values at harvest of either $40,000/ha or $50,000/ha; interest (discount) rates of 7, 8, and 10%, and growth benefits equivalent to 0.5, 1, or 2 years‟ time gain on a 28-year rotation. Given the good growth and low harvesting costs for many sites in the Central North Island, a stand value of $50,000/ha is probably not unreasonable.
Table 3: Net present value of a 0.5 - 2 year tree growth benefit on a 28-year rotation from biological control of buddleia (Mark Kimberley, Forest Research, personal communication).
Years gained 2 1 0.5 2 1 0.5 Value at harvest 50000 50000 50000 40000 40000 40000
7% discount rate 1152 556 274 934 451 222 8% discount rate 1013 487 239 820 394 193 10% discount rate 757 361 176 612 291 142
On top of the gains mentioned above, it would be expected that if biological control was successful there would be a reduction in other treatment (e.g. herbicide) costs between the time of planting and year 2. This saving would effectively be added directly to the NPV since it occurred at the beginning of the rotation. Assuming a saving of between $100/ha and $200/ha, the overall gain in NPV for the scenarios in Table 3 range from $1352 (at the most optimistic) to $242 (for the most pessimistic).
Applying these figures to 60,000 ha of affected land, buddleia control would give a total return of between approximately $15 and $81 million. This translates to an annual economic benefit of control in the Central North Island of between approximately $0.5 million and $2.9 million.
There is a growing and lucrative market for oil and honey derived from kanuka (Kunzea ericoides). Both have medicinal value. Not all plants contain the same levels of bioactive compounds, and some of the best sources of high-quality extracts appear to be in eastern North Island. Harvesting kanuka products is a small but growing industry in an otherwise economically depressed area. Buddleia threatens, and is replacing kanuka stands in eastern North Island, reducing the supply of bioactive kanuka, and the potential of the industry. Unlike Buddleja salvifolia, B. davidii is not considered a particularly useful plant by beekeepers (Appendix 1). However, buddleia is displacing other nectar-bearing plants that are important to the industry,
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such as manuka (Leptospermum scoparium). Little is known about the value of this effect on the beekeeping industry.
Biological control has been successful in controlling or partially controlling a wide range of pest plants both in New Zealand and overseas (McFadyen, 1999; Fowler et al. 2000). None of the case studies helps predict the likely success of biological control of buddleia. However, Brockerhoff et al. (1999) have shown by experiment that C. japonicus larvae are capable of causing significant reduction of buddleia vigour at population levels that might reasonably be expected in the field if the leaf weevil established. Despite that, it is uncertain whether this single agent can provide the level of control required to achieve these benefits. The introduction of additional control agents is being considered for that reason.
Overall cost benefit analysis:
>No significant on-going economic costs have been identified for this project (Table 1). The only significant monetary cost identified is therefore the one-off cost of $320,000 for completing the introduction of buddleia leaf weevil and monitoring its effects until 2007.
Ongoing economic benefits arise if the buddleia leaf weevil reduces the annual costs that buddleia poses to the forest industry and to organisations such as regional councils and DoC who have responsibility for eradicating the weed, or managing it to non-damaging levels in sensitive areas. The level of this benefit is estimated at $0.5 to 3 million per annum for the forest industry, and $100,000 for the annual costs to other organisations. Both figures can be regarded as highly conservative, as the first only considers costs incurred in forests of the central North Island, and the second is probably increasing as the buddleia problem expands, and as awareness of the risk posed by buddleia grows.
The proportion of the benefit that can be captured varies with the level of biological control that is achieved. This cannot be predicted with any certainty (See Section 7.7). If there was no biological control, costs of conventional buddleia control and losses to forestry would be as stated, and no benefits would accrue. Moderate biological control may be sufficient to remove buddleia as a significant competitor for pine trees, allowing capture of a significant proportion of the estimate production losses discussed above. This effect is unlikely to be linear. At small levels of defoliation, effects are likely to be insignificant. At some as yet unknown level of defoliation, the growth rate of buddleia would dip below that of the trees, effectively removing buddleia as a significant competitor for trees. Suppression of buddleia to low abundance and vigour would probably eliminate most but not all expenditure on herbicides. It is likely that the levels of control achieved would vary from place to place and from year to year, and so all scenarios may be simultaneously true.
Overall, the lack of on-going costs of the proposal suggests that the long-term net benefit to cost ratio for the release of buddleia leaf weevil is likely to be positive at all levels of control.
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7.5 Assessment of cultural, social, ethical and spiritual effects Assess the magnitude and distribution of any adverse and beneficial impacts on people and communities that adversely affect or maintain/enhance (in the case of beneficial impacts) their capacity to provide for their own social and cultural wellbeing both now and into the future. Also assess any ethical or spiritual risks, costs and benefits that might arise. If social effects in particular (although it may apply to other effects also) are likely to be significant, a full impact assessment may need to be carried out. Refer to the relevant ERMA New Zealand Technical Guides for assistance. If community consultation has been carried out to assist the assessment, provide information on how this was done and the results.
Assess risks and costs, and benefits, separately.
Community Consultation:
> The New Zealand Garden Industry Association was consulted, and responses were obtained from members (Appendix 1). No significant concern was expressed over potential losses to the industry from B. davidii inability to sell buddleia species that are susceptible to the leaf weevil. The commercial sale of B davidii is already banned by most regional councils.
Potential adverse risks are largely non-monetary, except for the costs of herbicide to protect ornamental buddleia species from damage in home gardens (Table 1).
Risks and Costs:
> It is not unlikely that damage by C. japonicus could cause occasional unsightly damage to some ornamental species of buddleia, reducing aesthetic enjoyment. This risk could be mitigated by using insecticides, or by replanting with alternative, resistant buddleia species. B. davidii is often called butterfly bush because butterflies commonly forage on the flowers in late summer. Very successful control of buddleia could reduce public enjoyment of aggregations of butterflies on buddleia. Protection of ornamental buddleias from C. japonicus using insecticides could impose a small annual cost to growers. Similarly, damage to ornamental buddleia might be sufficiently severe to require replacement with non-susceptible species. Members of the New Zealand Garden Industry Association who responded expressed no significant concern over potential losses to the industry from inability to sell buddleia species that are susceptible to the leaf weevil (Appendix 1).
Potential adverse risks are largely non-monetary, except for the costs of herbicide to protect ornamental buddleia species from damage in home gardens (Table 1).
Benefits:
>No benefits were identified over and above those assessed elsewhere in Section 7.
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7.6 Assessment of other effects (including New Zealand’s international obligations) Assess any remaining adverse and beneficial effects not already covered including any effects on New Zealand‟s international obligations. Specify any relevant international agreements.
Assess risks and costs, and benefits, separately.
Risks and costs:
>No additional risks or costs were identified.
Benefits:
> No additional benefits were identified
7.7 Overall evaluation of risks, costs and benefits It is the role of the Authority to decide whether the positive effects (benefits) of the release outweigh the adverse effects (risks and costs). However, if you have a view on the relative importance of the different risks, costs and benefits and how they should be brought together in the overall evaluation of your application then please state that here.
>The largest risk posed by this proposal is the possibility that buddleia leaf weevil might damage non-target plants. Research suggests that the weevil is host-specific, and the risk of significant damage to non-target native plants is judged to be low. This is a non-monetary risk. Consultation suggested that potential damage to other buddleia species is not a significant cost to the community. No significant monetary risks resulting from this proposal were identified.
Beneficial effects relate not to the introduction of the weevil, but to the reduction in costs that potential biological suppression of the weed might bring. Potential benefits are both non-monetary and monetary. Environmental gains would be made from even moderate suppression of buddleia through reduced competition of buddleia with native riparian plants, and recovery in the flora and fauna associated with those plants. The buddleia problem is increasing, and the value of potential non-monetary benefits from biological control is increasing with it. Monetary gains would accrue through reduced control costs, and through improved growth rates of plantation trees (Section 7.4). Estimates of the monetary costs of buddleia are based on limited information, and buddleia is spreading. It is likely that these costs (and hence potential benefits) will increase with time.
The net benefit/cost ratio for both monetary and non-monetary effects if this proposal is considered to be positive at all levels of biological control.
Uncertainty
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The environmental and economic costs and benefits described (Tables 1 & 2) will only be realised if C. japonicus establishes in New Zealand, and then reaches population densities that effectively suppress the adverse effects of buddleia. If populations do not establish, or remain small, then potential costs reduce, as do the value of benefits. Both may become insignificant. Syrett et al. (2000) estimated that the historical rate of establishment of biological control agents introduced to New Zealand for weed control is 76–94%. Fowler et al. (2000) concluded that at least partial success was achieved in 86% of weed biocontrol projects undertaken in New Zealand. However, these statistics do help predict the future success of individual projects such as this one, or whether any particular insect will establish on release. This is inherently uncertain. If the weevil becomes established, the equilibrium density that leaf weevil populations achieve will be affected by susceptibility to (currently unknowable) native and exotic diseases, predators, and parasitoids present in the New Zealand environment, response to target weed biotype, response to spatial variation in microclimates, and other factors. Until C. japonicus is released from containment, it will not be possible to reasonably assess this uncertainty.
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Section Eight – Satisfaction of the Section 36 Minimum Standards Satisfaction of the minimum standards in section 36 of the Act is a requirement for approval and will always be considered prior to the overall assessment and weighing of risks to, costs and benefits. Provide a statement in each subsection below on satisfaction of the minimum standards. Cross reference as appropriate (i.e. no need to repeat) to the detailed identification and assessments of risks set out in sections 6 and 7 above.
8.1 Displacement of native species State (with reasons) whether the new organism is likely to cause any significant displacement of any native species within its natural habitat.
>Surveys indicate that the insects currently feeding on buddleia are generalist species with alternative hosts, including several native pests of horticulture (Dr T. Withers, Forest Research, personal communication). Kay and Smale (1990) record no other native insects from buddleia. On existing information, decline in buddleia biomass will not therefore cause a significant displacement of any native species.
8.2 Deterioration of natural habitats State (with reasons) whether the new organism is likely to cause any significant deterioration of natural habitats.
>Rapid destruction of buddleia infestations could lead to erosion of stream banks and decline in water quality. Any such effect would be temporary until other vegetation occupied gaps. In fact, any decline in buddleia infestations is likely to be slow, allowing gradual replacement of vegetation in riparian areas. This effect is therefore considered very unlikely (see Table 1; Section 7.1).
8.3 Adverse effects on human health and safety State (with reasons) whether the new organism is likely to cause any significant adverse effects on human health and safety.
> The buddleia leaf weevil does not sting, bite, or have an offensive odour. A literature search revealed no records of any Cleopus species causing adverse human health effects („PubMed‟ database, 1960s – present). It is not a recorded vector of, or reservoir for, any known disease. The leaf weevil has been reared in containment at Forest Research for many generations without causing any health effects for experimenters (see Table 1).
8.4 Adverse effect to New Zealand’s inherent genetic diversity State (with reasons) whether the new organism is likely to cause any significant adverse effect to New Zealand‟s inherent genetic diversity.
>This species has no close relatives in New Zealand, and there is no prospect of interbreeding with native insects.
8.5 Causing disease, being parasitic, or becoming a vector for disease
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State (with reasons) whether the new organism is likely to cause disease, be parasitic, or become a vector for human, animal, or plant disease. If, however, the purpose of the importation or release is to import or release an organism to cause disease, be a parasite, or a vector for disease all you need to do is state that.
>Weevils are not parasitic, and are not considered to be primary vectors of plant diseases. C. japonicus has been in laboratory culture for many generations, and in that time has been reared exclusively on B. davidii. This population will not introduce an exotic plant disease on release.
Intensive searches using CABI and Medline databases revealed no literature concerning Cleopus species except references to this project.
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Section Nine – Additional Information
9.1 Do any of the organism(s) need approvals under any other New Zealand legislation or are affected by international obligations? For example, indicate whether the organism may be subject to other New Zealand legislation, e.g. the Biosecurity Act 1993, or Animal Welfare Act 1999; or if the organism(s) are listed in CITES, then approval is required from both the importing and exporting countries.
The population currently in containment was imported under import permit (93/INV/12). No other requirements for approvals or international obligations are known.
9.2 Have any of the new organism(s) in this application previously been considered in New Zealand or elsewhere? For example, has the organism(s) been previously considered for import (e.g. under the Plants Act)?
This organism has not been considered for release in any other country or for release in New Zealand at any other time.
9.3 Is there any additional information that you consider relevant to this application that has not already been included?
While the adverse risks identified in this proposal (including risks to human health and native species) are considered small (Sections 6 & 7), any effects will be persistent, irreversible, and widespread. There will be no practical options for wide-scale management of the risks outlined once populations of C. japonicus are established in New Zealand.
9.4 Provide a glossary of scientific and technical terms used in the application
> Adventive: A foreign species that is established outside of cultivation Diapause: A state resembling hibernation, but in summer Ethnopharmacology: Study of plant constituents and drugs used in traditional medicine Facultative: Performing in a particular way sometimes, but not always Family: A group of related tribes Genus (plural - genera): A group of related species Herbivory: Feeding on plants Parasitoid: A parasite of insects that kills its host stage
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Pathogenic: Causing disease RPMS: Regional Pest Management Strategy Species: A like group of individuals that cannot interbreed with any other group Tribe: A group of related genera
9.5 List of appendices. List any appendices included with this application. Any information that is commercially sensitive or additional material included with the application (such as details of consultations, referenced articles) should be contained in appendices. The main application should refer to the relevant appendices but be able to be read as a stand-alone document.
> Appendix 1 Pre-application consultation Scope of consultation Organisations consulted Summary of responses Responses from Ngāti Apa, Ngāi Tahu and Tainui The Consultation Document Import permits CVs in support of unpublished data Supporting information Proof of identification of imported insects Disease status of imported insects Report on the impact of buddleia on forestry production Report on susceptibility of C. japonicus to Microctonus aethiopoides Other correspondence
Appendix 2 Experimental assessment of the host-specificity of Cleopus japonicus Wingelmüller
9.6 References. Please include a list of the references cited in and supplied with this application form. Originals of the references must be supplied in full. Where the reference supplied is an extract from a book only the specific pages quoted must be supplied.
> Alonzo-Zarazaga, M.A.; Lyal, C.H.C. 1999. A world catalogue of families and genera of Curculionoidea (Insecta: Coleoptera). Entomopraxis, Barcelona, Spain.
Brockerhoff, E.G.; Withers, T. M.; Kay, M.; Faulds, W. 1999. Impact of the defoliator Cleopus japonicus (Coleoptera: Curculionidae) on Buddleia davidii in the laboratory. Proceedings of the 52nd New Zealand Plant Protection Society :113–118. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 38 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Connor H.E.; Edgar, E. 1987. Name changes in the indigenous New Zealand flora, 1960–1986 and Nomina Nova IV, 1983–1986. New Zealand Journal of Botany 25: 115–170.
Ferguson, A.M. 1989. Listroderes difficilis Germain, vegetable weevil (Coleoptera: Curculionidae). In: Cameron P.J.;
Hill, R.L.; Bain, J.; Thomas, W.P. A review of biological control of invertebrates pests and weeds in New Zealand 1874– 987. Technical Communication, CABI International Institute of Biological Control 10: 97–100.
Fowler, S.V.; Syrett, P.; Hill R.L. 2000. Success and safety in the biological control of environmental weeds in New Zealand. Austral Ecology 25: 553–562.
Houghton, P.J. 1984. Ethnopharmocology of some Buddleja species. Journal of Ethnopharmacology 11: 293–308.
Kay, M. 1991. The buddleia biocontrol programme, Unpublished Forest Research progress report.
Kay, M.K.; Smale, M.C. 1990. The potential for biological control of Buddleia davidii Franchet in New Zealand. In: C. Bassett, L.J. Whitehouse, and J.A Zabkiewicz (eds) Alternatives to the Chemical Control of Weeds. FRI Bulletin 155: 29–33.
Kuschel, G. 1995 A phylogenetic classification of Curculionoidea to family and subfamily level. Biology and phylogeny of Curculionoidea: Proceedings of the XVIII International Congress of Entomology, July 1988. 5–36.
Marohasy, J. 1998. The design and interpretation of host specificity tests for weed biological control with particular reference to insect behaviour. Biocontrol New and Information 19: N13–N20.
McFadyen, R.E.C. 1999. Biological control of weeds. Annual Review of Entomology 43: 369–398.
Nuttall, M.J. 1989. Gonipterus scutellatus Gyllenhal, gum tree weevil (Coleoptera:Curculionidae). In: Cameron P.J.;
Hill, R.L.; Bain, J.; Thomas, W.P. A review of biological control of invertebrates pests and weeds in New Zealand 1874 – 1987. Technical Communication, CABI International Institute of Biological Control 10: 276–269.
Randall, J.M.; Marinelli, J. 1996. Invasive plants – Weeds of the global garden. Brooklyn Botanic Gardens, 111 p.
Richardson, B.; West, G. 1993. Radiata growth trends following weed control. In: Proceedings, Paper presented at Weedworks „93, Forest Research Institute, Rotorua.
Richardson, B.; Vanner, A.; Ray, J., Davenhill, N.;Coker, G. 1996. Mechanisms of Pinus radiata growth suppression by some common forest weed species. New Zealand Journal of Forestry Science 26: 421–437.
Richardson, B., Kimberley, M., Ray, J.W., Coker, G.W. 1999. Indices of interspecific plant competition for Pinus radiata in the Central North Island of New Zealand. Canadian Journal of Forest Research 29: 898–905.
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 39 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Smale, M.C. 1990a. Ecological role of buddleia (Buddleja davidii) in streambeds in Te Urewera National Park. New Zealand Journal of Ecology 14: 1–6.
Smale, M.C. 1990b. Buddleia – a growing weed problem in protected areas. What‟s New in Forest Research no. 185., Forest Research, Rotorua.
Syrett, P.; Briese, D. T.; Hoffman, J. H. 2000. Success in biological control of terrestrial weeds by arthropods. In: Gurr, G.; Wratten, S. (eds), Biological control: measures of success. Kluwer, Dordrecht, The Netherlands. Pp. 189– 230 Valentine, E.W. 1967. A list of the hosts of entomophagous insects of New Zealand. New Zealand Journal of Science 10: 1100–1210.
Wapshere, A.J. 1974. A strategy for evaluating the safety of organisms for biological weed control. Annals of Applied Biology 77: 201–211.
Webb, C.J.; Sykes, W.R.; Garnock-Jones, P.J. 1988. Flora of New Zealand Volume IV. Naturalised pteridophytes, gymnosperms, dicotyledons. Botany Division DSIR, Christchurch, New Zealand.
Zabkiewicz, J. A.; Richardson, B.; Kay, M. 1998. Pre-release evaluation of the efficacy of a weed biocontrol agent in relation to Pinus radiata productivity. Pp. 372–375 In: Wagner, R.G.; Thompson, D.G. (Comp.); Third International Conference on Forest Vegetation Management: Popular Summaries. Forest Research Information paper No. 141, Ontario Forest Research Institute. Sault Ste. Marie, Ontario, Canada.
Zhang, X. Xi,; Y. Zhou, W.; Kay, M. 1993. Cleopus japonicus, a potential biocontrol agent for Buddleja davidii in New Zealand. New Zealand Journal of Forestry Science 23: 78–83.
Zhou, Wei Jun.; Zhang, Xiao Xi; Xi, Yi Yuan; Kay M. 1998. Biological and ecological studies of long-leg weevil, Mecysolobus erro (Pascoe) (Coleoptera: Curculionidae) in China. Unpublished report to Forest Research.
Section Ten – Application Summary Summarise the application in clear, simple language that can be understood by the general public. Include a description of the organism(s) to be released, and any risks, costs and benefits associated with their release. Any consultation that was undertaken should be noted. This summary will be used to provide information for those people and agencies who will be notified of the application (e.g. Ministry of Agriculture and Forestry, Department of Conservation, Ministry for the Environment etc) and for members of the public who request information. Do not include any commercially sensitive information in this summary – this should be attached as a separate appendix and clearly marked “confidential”.
>Buddleia (Buddleja davidii) is a serious weed of natural environments and forestry in eastern central North Island, but it is spreading widely, even into the far south. It colonises gravels and stony soils better than most native plants can, and is steadily pushing out native plants and other organisms from the beds and banks of some streams and rivers in places like Te Urewera National Park. It has begun to spread on the shores of Lake Wakatipu, and the gravel expanses of the southern rivers are at future risk. In the central North Island it ranks
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 40 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
with pampas as the most damaging competitor affecting young pine trees, and is estimated to cause $0.5 to 2.9 million annually in control costs and lost production.
Buddleia is already too widespread, too abundant, and too inaccessible for conventional control methods alone to be practical in providing good control. Forest Research has initiated a biological control project for Buddleia. The aim is to use insect populations to damage the weed, and to suppress its vigour and abundance wherever and whenever it occurs in New Zealand. For this reason, the application is for unconditional release from containment of the first biological control agent for this weed. The agent is an insect called Cleopus japonicus, or buddleia leaf weevil. It is a small (5mm) brown weevil that produces similar-sized, slug-like larvae that consume the leaves of buddleia, reducing growth rate, and killing small plants. It originates from China, where it has only been recorded from buddleia. It was imported into containment from China in 1993, and has been under evaluation since then. C. japonicus has not been genetically modified
If successful biological control of a weed is to be achieved, it is normal practice to introduce a number of complementary agents. The leaf weevil is the first control agent to be proposed for buddleia control in New Zealand, but others (for example another weevil, Mecysolobus erro) may also be considered.
Before the application was written, we consulted the community to seek information, and to ask what issues were important to the community. We contacted 52 iwi, hapu, Rūnanga, and other Māori organisations. The largest issue raised by the three respondents was that the agent may not be safe. This and the other issues raised are addressed in the application. We also consulted regional councils, the Department of Conservation and several NGOs and producer organisations.
All risks posed by the proposed release of the buddleia leaf weevil, including those of particular importance to Māori, have been identified and assessed. Experiments have been carried out in China and New Zealand over a number of years to determine the range of plants on which this weevil can feed and lay eggs. It is likely that the weevil would attack other Buddleja species in New Zealand, but not B. salvifolia, a useful plant for bees. The studies conclude that the risk to environmentally and economically important plants in New Zealand outside the Scrophulariaceae and Buddlejaceae is nil or low. Research suggests that the risk of the weevil developing a permanent population on related native Scrophulariaceae is low, but both larvae and adults nibble foliage in exploratory feeding. It is possible that plants growing in close proximity to buddleia plants might suffer low levels of leaf damage from vagrant weevils and larvae. Other adverse economic and environmental risks that might arise either from the introduction of the agent, or control of buddleia were evaluated, and are presented in this application. None were found to be significant.
The potential benefits of the introduction have also been evaluated. Weevil damage has the potential to reduce the competitive effects of buddleia, conserve native vegetation, and partially restore natural forest succession processes, resulting in heavy non-monetary benefits to native biodiversity, ecosystem health, and spiritual values of importance to Māori. Experiments indicate that this insect could reduce the vigour of buddleia below damage thresholds in plantation forests with potential economic benefits to the forestry industry of $0.5 – 2.9 million per annum. Costs of control currently undertaken by DoC and regional councils are conservatively estimated at $100,000 per annum. This could be reduced by successful biological control. Overall, the benefits to the economy and ecosystem health in New Zealand from introduction of this weevil are considered to greatly outweigh the very small risk that non-target plants may be damaged. 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz
Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 41 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996
Checklist
Please check and complete the following before submitting your application:
All sections completed Yes Appendices enclosed Yes/ NA* Confidential information identified and enclosed separately Yes/NA Copies of additional references attached Yes/NA Cheque for initial fee enclosed (incl. GST) Yes/No If “yes”, state amount: $………. Direct credit made to ERMA bank account: Yes/No If „yes” give date of DC …/…/… and amount: $………. Application signed and dated Yes Electronic copy of application e-mailed to ERMA New Zealand Yes
*NA – not applicable
† The cost of the application (our fee) can be found on our web site under new organism applications.
Signed: Date:
20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz