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: Importation and release of two moths, Cochylis atricapitana and Platyptilia isodactyla, for the biological control of the pasture weed ragwort

Applicant Organisation: West Coast Ragwort Control Trust

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 West Coast Ragwort Control Trust

Postal Address c/o New Zealand Landcare Trust P O Box 39-141 Harewood CHRISTCHURCH

Physical Address

Phone (03) 962 9555

Fax (03) 962 9555

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 Jono O‟Connor

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

Position Chairman, West Coast Ragwort Control Trust

Address c/o New Zealand Landcare Trust P O Box 39-141, Harewood, CHRISTCHURCH

Phone (03) 789 7001

Fax (03) 789 7001

E-mail [email protected] - phone preferred or

Alternative contact Name Richard Hill

Position application author

Address Richard Hill & Associates Ltd Private Bag 4704, CHRISTCURCH

Phone (03) 325 6400

Fax (03) 325 2407

E-mail [email protected]

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

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

Name > n/a

Position > n/a

Address > n/a

Phone > n/a

Fax > n/a

E-mail > n/a

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

Application for approval to import for release or release FORM NOR from containment any new organism including a genetically modified organism but excluding conditional Page 5 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 the West Coast Ragwort Control Trust to import for release two new moths, Cochylis atricapitana (Tortricidae) and Platyptilia isodactyla (Pterophoridae), for the biological control of the pasture weed ragwort.

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.

Ragwort (Senecio jacobaea Linnaeus; Asteraceae) is one of the most serious weeds affecting pastoral agriculture in New Zealand today. It occurs in dense stands, replacing productive pasture species, and control is costly. Ragwort foliage contains toxic pyrrolizidine alkaloids. Grazing animals suffer cumulative chronic liver damage and failure. Cattle and deer avoid ragwort, and the grass that grows near it, reducing pasture productivity. Sheep will graze ragwort, but long exposure results in chronic liver damage and early death. Ragwort can be lethal to horses (Wardle 1987, DEFRA 2005). Dairy farmers on the West Coast alone are spending approximately $0.8 m annually to maintain production and avoid animal intoxication. Ragwort is worst in areas with greater than 800mm of rain annually, but it occurs nationwide. Ragwort was ranked amongst the top three herbaceous weeds by 30 of 53 hill country farmers surveyed recently. It is considered sufficiently serious that ragwort management is a feature of the Regional Pest Management Strategies of every region in New Zealand (Rahman & Popay 2001). In a survey of dairy farmers, ragwort was considered significantly more important than any other weed (Bourdôt et al 1994). If neighbouring land is ragwort-free, landholders are required to clear ragwort from a 20-50m boundary strip, and in some areas of some regions it is an offence 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 6 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

allow ragwort on your property at all. Ragwort does not significantly affect native ecosystems, but departments such as the Department of Conservation (DoC) act as good neighbours, and also undertake control (Tom Belton, Ian Popay, Department of Conservation, pers. comm.). The costs of complying with ragwort management requirements are high. It is not usually a problem in closely- managed pastures, but is difficult to control on extensive hill country.

Successful biological control of ragwort is being achieved in most parts of New Zealand following the release of ragwort flea beetle in 1983 (Appendix B). Ragwort infestations are no longer common in many areas, and any outbreaks tend to be short-lived because flea beetle populations respond rapidly. Successful control is reducing the need to apply herbicides, and may lead to the eventual relaxation of mandatory management requirements (such as those of Environment Waikato 2005). Unfortunately there are parts of the country where flea beetle populations have not established, or perform poorly. The reason for this is unknown. Here ragwort has never been under biological control. Land managers must apply herbicides (Auckland Regional Council 2004), or bear the economic losses that ragwort causes. Ragwort is not controlled biologically in West Coast, Southland and parts of the North Island.

The West Coast Ragwort Control Trust seeks to import two moths, Cochylis atricapitana and Platyptilia isodactyla, as biological control agents for ragwort in areas where flea beetle is ineffective. These species originally come from Europe, where their larvae can be found burrowing into the crown and/or the developing stems of ragwort. Both have been introduced to Australia where larval feeding stunts the growth of plants, reduces seed production, kills seedling rosettes, and populations of damaging rosettes are beginning to decline (D. McLaren, Department of Natural Resources and Environment, pers. comm.; McLaren et al 2000). C. atricapitana has also been released in North America.

The risk that these insects might damage desirable plants was assessed carefully before the moths were released in Australia (McLaren et al 2000) and Canada (Schroeder et al 1989), and additional tests on New Zealand native species have been completed (Appendix C,D). There is a low risk of damage to individual plants, and insignificant risk that either species would harm populations of native plants if released in New Zealand. Experience in Australia suggests that biological control of ragwort in New Zealand is achievable. The social and economic benefits of this would be large.

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.

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

This is not an application for conditional release. Section 38D of the HSNO Act lists possible controls that the Authority might impose. None of these appears relevant to this application. The only purpose for this introduction is the biological control of ragwort. Its purpose is to enable release of both control agents, and eventually to establish self-perpetuating, self-dispersing populations of each in New Zealand. Initial releases will be made in western South Island, but it is almost certain that eventually these insects will become established throughout New Zealand, wherever ragwort grows.

If the establishment of these insects follows the same pattern as occurred in Australia it may be several years before populations establish at release sites and assessment of impact or non-target effects can begin. It is unlikely that any conditions of release could be maintained for a long period. Conditional release implies that the insects can be contained and recovered or eradicated if conditions are not met. Containment requires detection, and the applicants do not believe that it is practical to detect or contain either species with current technology.

Evidence presented in this application indicates that the likely environmental, economic and cultural risks and costs associated with the release of these species are outweighed by the potential benefits, and there do not appear to be circumstances that would justify limiting the distribution of the insects spatially or temporally. The process of release and monitoring outlined in Section 4 would not be enhanced by placing conditions on release.

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

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

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

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

Both organisms are specified at the species level.

Populations of both species will be sourced from exotic populations established in Australia, not from the European home range. These are the same populations that were used to conduct host-range testing in New Zealand. The population of Cochylis atricapitana released in Australia was originally sourced from a population at Salamanca, Spain in 1985, and Platyptilia isodactyla was sourced from a population at Lugo, Spain in 1988.

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:

Species 1: Class: Insecta Order: Lepidoptera Family: Tortricidae Subfamily: Cochylinae Tribe: Cochylini Genus: Cochylis Species: atricapitana (Stephens 1852).

Common name(s), if any:

Ragwort crown borer

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

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

Insect (moth)

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

From a field population established in Tasmania

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

C. atricapitana was released in Australia in 1987. The petition for this release is attached (Vaysierres 1985). It was also released in Canada in 1990. It is established and abundant in both countries. Sources of information about the biology and ecology of this species are limited. All are attached.

Species 2: Class: Insecta Order: Lepidoptera Family: Pterophoridae Subfamily: Platyptiliinae Tribe: Genus: Platyptilia Species: isodactyla (Zeller 1852)

Common name(s), if any:

Ragwort plume moth

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

Insect (moth)

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

From a field population established in Tasmania

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

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

The epithet „isodactylus‟ is common in the literature. This is an obsolete agreement with the genus Pterophorus, to which P. isodactyla once belonged (R. Hoare, Landcare Research, pers. comm.).

Platyptilia isodactyla was released in Australia in 1999. The petition is attached (McLaren 1997). Sources of information about the biology and ecology of this species are limited. All are attached.

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.

Ragwort crown borer, Cochylis atricapitana (Stephens 1852). Insecta: Lepidoptera: Tortricidae.

Ragwort plume moth, Platyptilia isodactyla (Zeller 1852). Insecta: Lepidoptera: Pterophoridae

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).

Cochylis atricapitana, Ragwort crown borer

Description Cochylis atricapitana is a small tent-winged moth with a wingspan of 12–16 mm and body length of 8–10 mm. The forewings have irregular brown marks flecked with black and grey on a white or yellowish white background. In females the white tends to pink. The hind wings of the male are white suffused with grey lines while those of the female are dark grey. Adults rest on ragwort plants during

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

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

the day. They are nocturnal, particularly active at dawn and dusk, and can be light trapped (McLaren 1992, McLaren et al. 2000).

Cochylis atricapitana larvae feed exclusively in the crown of ragwort rosettes, and up into the stem as plants begin to bolt around December and January. C. atricapitana overwinters as a larva in the plant, usually in the fourth or fifth instar. The yellowish brown pupa is 7–8 mm by 1.5–2.0 mm and enclosed in a white cocoon. The summer generation pupates in the plant and the autumn generation in the soil in the following spring.

Eggs are laid in the crown or on the underside of leaves. Eggs are laid in spring (September/October) summer (December/January) and autumn (March/April) (McLaren et al. 2000). Over a lifetime adult females can lay a mean of 158 ± 92 eggs (range to 355, McLaren 1992). In laboratory culture adults seem to feed rarely, if at all (H. Gourlay, Landcare Research. pers. comm.).

There are five instars. Young larvae of the first generation mine a leaf and then the mid-vein, working towards the stem. The older larvae either mine up the stem or rarely climb it to feed on the developing shoots and flowers. Mining causes growing stems to thicken and the leaves to bunch. Last-generation larvae mine the rosette root crown, but not the roots. The small central leaves of attacked rosettes stop growing and have a small amount of black faeces at their base. Larvae pupate within the plant (McLaren 1992).

Developmental characteristics The growth rates and environmental limits for Cochylis atricapitana development have not been defined. Larval growth is completed in 33 days at 24ºC. There are three generations per year (McLaren 1992, McLaren et al. 2000).

Native distribution Cochylis atricapitana is widely distributed in Europe between 36ºN to 59ºN, and from Ireland to Siberia (Schroeder et al. 1989). This distribution covers a wide range of climates, suggesting that there will be no latitudinal limit to the lowland distribution of C. atricapitana in New Zealand. The distribution and abundance of ragwort appears to be limited by rainfall (Wardle 1987), and presence or absence of ragwort is likely to be the strongest determinant of C. atricapitana distribution and abundance in New Zealand.

Establishment and dispersal Cochylis atricapitana was released in Australia in 1987 (McLaren et al 2000) and in Canada in 1990 (Julien & Griffiths 1998). It has been distributed widely in Victoria (since1987) and in Tasmania (since1994) since its release in Australia. Five years after release in Victoria C. atricapitana had established at only 8% of release sites, but by 1999, 8 years after release, this had risen to 22%, and at one site C. atricapitana had spread from the release point and could be found over 10km2. It took 11 years for the moth to build to population levels sufficient to exert impacts on ragwort size and number 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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

(McLaren et al 2000). Five years after its release in Tasmania, C. atricapitana had firmly established at only 15% of the 27 release sites assessed, and dispersal was estimated at 200m in 3 years (McLaren et al 2000).

Establishment and spread has been more rapid in Canada. Since its release it has established strongly in Nova Scotia, New Brunswick and British Columbia (except in the interior at an altitude of 1,500m). This moth spread up to 15 km in 5 years after release in Nova Scotia and controlled ragwort at the release site within 5 years (Harris; Julien & Griffiths 1998).

Host records Cochylis atricapitana is generally considered to be monophagous (McLaren 1992). In Europe the recorded hosts for C. atricapitana are Senecio jacobaea, Hieracium and Hypericum, but these two latter records are thought to be misidentifications of the moths Cochylis hybridella (Hübner.) and C. dubitata (Hübner.), which are known to feed on these hosts (Harris). Representatives of these plant genera were tested and were not attacked (Appendix C). In field surveys conducted in Europe, C. atricapitana was only found on S. jacobaea, and not S. erucifolius (even when growing in mixed infestations), S, aquaticus, S. alpinus, S. fuchsia or S. cineraria (Schroeder et al. 1989).

Impact Larval mining in young stems thickens them and suppresses flowering. Mining of older stems and rosette root crowns tends to kill them (Harris). At one site, 10 years after release, McLaren et al. (2000) measured 40% reduction in the height (and presumably seed production) of flowering plants caused by C. atricapitana damage, and a significant reduction in both size and survival of rosettes. As yet there have been no studies to determine the effect of C. atricapitana on ragwort population dynamics.

Affinities with New Zealand fauna The Tortricidae is a large moth family in New Zealand, and species have a wide range of population characteristics, host-ranges and ecologies. There are relatively host-specific, abundant pests such as codling moth, generalist pests such as light brown apple moth, and far less abundant rare and endangered species. There are no other species of the Cochylis genus in New Zealand (Dugdale 1988).

There are known parasitoids of New Zealand tortricid species, including species introduced for biological control but it is not possible to predict which if any would attack Cochylis atricapitana here, or the intensity of that attack. Eggs might be at risk from resident egg parasitoids or predators, and pupae on the surface of the crown of the plant or on the soil surface might be available to parasitoids (although the exposed pupae of the introduced tortricid Cydia succedana appear to be immune from such attack (H. Gourlay, Landcare Research, pers. comm.). Larvae are almost always inside the plant, and unavailable to most generalist larval parasitoids. The native blue borer (a species of moth) Patagoniodes farinaria Turner (Pyralidae) also occurs in ragwort stems, and it 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

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

conceivable that its parasitoids (Syrett 1983) might also attack C. atricapitana. However, only one incidence of C. atricapitana larval parasitism had been reported in Australia by 1999, 12 years after the release of C. atricapitana (McLaren et al 2000).

C. atricapitana moths are crepuscular or nocturnal, but roost on ragwort plants during the day. Moths will be susceptible to general predators such as spiders, and fantails (Rhipidura fuliginosa (Sparrman)), have been observed to eat moths (McLaren et al 2000).

There are already several species feeding in the crowns and stems of ragwort in New Zealand. As ragwort is exotic, the primary host or hosts of the blue borer must be native Senecio species, not ragwort. Larvae of the blue borer attack the stems of bolting ragwort plants in both Australia and New Zealand. Larvae of Cochylis atricapitana will compete with this native moth, and successful control of ragwort would reduce the habitat available to blue borer.

Longitarsus jacobaeae (Waterhouse) (Chrysomelidae) (the ragwort flea beetle) was introduced to New Zealand in 1983, and exerts control on ragwort in many parts of New Zealand (Appendix B). Larvae feed in the crown and roots of ragwort plants, but tend to feed at the extremities of the root system. Larvae of Cochylis atricapitana feed at the top of the crown and in the stem, as do larvae of Platyptilia isodactyla. It is generally agreed that competition between these species and Longitarsus species is limited by spatial partitioning of the below-ground parts of the plant, and all species coexist in ragwort populations in Australia and Canada (J Ireson, Tasmanian Institute of Agriculture, D McLaren, Department of Natural Resources and Environment; P Harris, R. deClerke-Floate, Agriculture Canada, pers. comm., Appendix A – submissions and emails). In their native range P. isodactyla and C. atricapitana also appear to coexist within sites, and there appears to be no exclusion of either species ecologically (D. McLaren, Department of Natural Resources and Environment, J. Ireson, Tasmanian Institute of Agriculture, pers. comm.).

Platyptilia isodactyla, ragwort plume moth

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

Description Platyptilia isodactyla is a plume moth (wings permanently positioned horizontally to the abdomen) measuring 9 mm long with a wingspan of 21 mm. The wings are pale brown in colour with dark bands at the ends and variable “V” or double “V” shaped dark brown bands approximately one-third of the wing length from the wing tip. The body and legs are lighter brown. The forewing is divided into two lobes and the hindwing into three feather-like plumes. The middle and hindwings are very long and have prominent spines. The moth has a characteristic resting posture with the body and fully outstretched wings forming a „T‟ shape, the forewing covering the hindwing, and the hindlegs raised and extended parallel with the body. Males have longer, thinner abdomens. The moths are crespuscular or nocturnal (Ireson et al. 2003). In laboratory culture adults seem to feed rarely, if at all (H. Gourlay, Landcare Research. pers. comm.).

Platyptilia isodactyla larvae feed exclusively in crown and down into the fleshy root of ragwort rosettes and bolting plants. Small larvae overwinter in the root crown of ragwort plants. Larvae complete development in spring and pupate. Pupae can be found inside the plant or in litter or soil surrounding the plant. Females each lay approximately 100 eggs. The eggs are flat and ovoid, and are laid on the underside of leaves. Newly hatched larvae tunnel along the leaf petioles into the crown and roots, which are progressively hollowed out (McLaren 1997). Larvae are entirely herbivorous.

Developmental characteristics The growth rates and environmental limits of Platyptilia isodactyla have not been defined. Egg development takes 10 to 14 days at ambient temperatures. There are five larval instars. Pupation lasts about one week. P. isodactyla has two generations a year (McLaren et al 2000).

Native distribution The native range in Europe is from Scotland and Norway to North Africa, and East to Siberia (McLaren 1997). This distribution covers a wide range of climates, and this suggests that there will be no latitudinal limit to the distribution of Platyptilia isodactyla in New Zealand. The distribution and abundance of ragwort appears to be limited by rainfall (Wardle 1987), and the presence or absence of ragwort is likely to be the strongest determinant of Platyptilia isodactyla distribution and abundance in New Zealand. It is characteristically found in wet environments in Europe, and is expected to perform well on ragwort on wet soils in Tasmania (Ireson et al 2003) and perhaps also on the west coast of New Zealand.

Establishment and dispersal Platyptilia isodactyla was released in Victoria in 1999 and Tasmania in 2000. It has been distributed widely in ragwort infested areas. Surveys at five initial releases sites in Tasmania after 2-3 years confirmed establishment, and showed that the moth was dispersing at approximately 400m/year (Ireson et al 2003). It is also established in Victoria (D. McLaren, Department of Natural Resources and Environment, pers. comm.). 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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Host records The most common host plant of Platyptilia isodactyla in its country of origin is Senecio aquaticus Hill or “marsh ragwort”. Senecio aquaticus is taxonomically very close to and will hybridise with ragwort (S. jacobaea), producing plants exhibiting intermediate characters (Emmet & Heath 1989). Marsh ragwort is present in Levin, Nelson and Buller, and perhaps Auckland and Southland (Webb et al. 1988). It grows in wet areas. It may prove to be an alternative host that may improve the chances of establishment and survival of P. isodactyla on the West Coast. Senecio aquaticus is a minor weed in New Zealand (Webb et all 1988).

Impact The damage caused by mature larvae feeding on the roots is severe and is usually sufficient to kill the plant; a ragwort plant can be entirely destroyed by only two or three larvae in the course of their development (Ireson et al. 2003). As yet there have been no studies of the impact of this insect on the population dynamics or pest status of ragwort.

Affinities with New Zealand fauna There are 11 species of Platyptilia in New Zealand of which 10 are native (Dugdale 1988) and none are pests. These species are considered monophagous or oligophagous, and none have been recorded on ragwort (Syrett 1983). However, Platyptilia sp. larvae have been recorded on flowers of Celmisia sp., and related pterophorids have been taken on other native Asteraceae (B. Patrick, Otago Museum, pers. comm.). There are no recorded parasitoids of Platyptilia species in New Zealand (J. Berry, Landcare Research, pers. comm.). There are no known pathways for interaction between P. isodactyla and native Platyptilia species through sharing host plants, habitats or parasitoids.

Eggs might be at risk from resident general egg parasitoids or predators, and pupae on the surface of the crown of the plant or on the soil surface might be available to general parasitoids. Larvae are almost always inside the plant, and unavailable to most generalist larval parasitoids. The native blue borer Patagoniodes farinaria Turner (Pyralidae) also occurs in ragwort stems, and it is conceivable that its parasitoids (Syrett 1983) might also attack P. isodactyla. No larval parasitoids have yet been recorded in Australia even though blue borer is also native there (D. McLaren, Department of Natural Resources and Environment, pers.comm).

P. isodactyla moths are crepuscular or nocturnal, but roost on ragwort plants during the day. Moths will be susceptible to general predators such as spiders (McLaren et al 2000), and perhaps birds.

There are already several species feeding in the crowns and stems of ragwort in New Zealand. As ragwort is exotic, the primary host or hosts of the blue borer must be native Senecio species, not ragwort. Larvae of the blue borer attack the stems of bolting ragwort plants in both Australia and New Zealand. Larvae of Platyptilia isodactyla will compete with this native moth, and successful control of ragwort would reduce the habitat available to blue borer. 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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Longitarsus jacobaeae (Waterhouse) (Chrysomelidae) (the ragwort flea beetle) was introduced to New Zealand in1983, and exerts control on ragwort in many parts of New Zealand (Appendix B). Larvae feed in the crown and roots of ragwort plants, but tend to feed at the extremities of the root system. Larvae of Cochylis atricapitana feed at the top of the crown and in the stem, as do larvae of Platyptilia isodactyla (which also feed in the roots). It generally agreed that competition between these species and Longitarsus species is limited by spatial partitioning of the below-ground parts of the plant, and all species coexist in ragwort populations in Australia (J Ireson, Tasmanian Institute of Agriculture, D McLaren, Department of Natural Resources and Environment, pers comm.). (See Appendix B). In their native range P. isodactyla and C. atricapitana) also appear to coexist within sites, and there appears to be no exclusion of either species ecologically (D. McLaren, Department of Natural Resources and Environment, J. Ireson, Tasmanian Institute of Agriculture, pers. comm.).

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.

No inseparable organisms are known for either species.

Mounted specimens for both species will be submitted to Dr R. Hoare, Landcare Research to confirm identification. Thirty mid-size larvae of each species will be dissected from plants, smeared, and submitted to Biodiscovery NZ (Dr P. Wigley) for examination for unwanted associated micro- organisms. Both species will be reared through a full generation in quarantine to isolate and eliminate any associated parasitoids or predators (H. Gourlay, Landcare Research, pers, comm.). No associated species were encountered when populations were imported into containment in 2003. Laboratory cultures in Australia and New Zealand (J. Ireson, Tasmanian Institute of Agriculture, D McLaren, Department of Natural Resources and Environment, H Gourlay, Landcare Research, pers comm.) have remained robust and fecund, with no indication of ill health.

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:

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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.

Cochylis atricapitana is not genetically modified. Platyptilia isodactyla 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

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.

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). 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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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.

Both species were imported into containment at the Landcare Research containment facility at Lincoln in 2003 for further evaluation. Both populations have since been destroyed. There is no population of either species in New Zealand. The approvals for introduction into containment were:

1. ERMA approval code NOC002282-3 (application code NOC03006)- Application to import into containment for later release beneficial insects Cochylis atricapitana (Stephens, 1852) (Lepidoptera: Tortricidae) and Platyptilia isodactylus (Zeller, 1852) (Lepidoptera: Pterophoridae)

2. MAF Import permit 2004022275.

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.

C. atricapitana and P. isodactyla will be imported as adults from a laboratory culture in Tasmania founded from insects collected at or near the same site as the populations used for recent host-range testing. Once post-importation requirements have been met, the insects will be removed from the insect quarantine facility at Lincoln and mass-reared by Landcare Research staff on behalf of the applicant. Successful rearing and release methods have been developed in Australia (Ireson et al 2003, McLaren 1992), but were refined during the period of containment at Lincoln in 2004. One generation of each species will be reared on potted ragwort plants in containment, and once biosecurity clearance is obtained, emerging adults of the F1 generation will be removed from quarantine.

Moths will be transported to the West Coast in 30cm-tall, 20-cm diameter plastic cylinders containing ragwort vegetation to provide humidity, 75 moths per container. Release methods will be based on those used successfully to achieve successful establishment in Australia (Ireson et al 2003, McLaren 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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1992). Four sites on the West Coast have been selected. Adults (150) and larvae (400-600 larvae in 10 infested plants) will be released, each species at two exclusive sites. Releases are planned for February/March 2006.

Current funding for this project does not extend beyond June 2006. Landcare Research has undertaken to monitor the establishment of the two species until March 2008.

When larvae of Cochylis atricapitana or Platyptilia isodactyla are present in ragwort plants, visible frass accumulates on stem nodes and amongst the leaf bases on crowns. In February/March 2007, the four sites will be visited and ragwort plants will be sampled for the presence or absence of C. atricapitana or P. isodactyla. At least 100 ragwort plants will be examined for larval presence. Ten 5 minute vegetation samples will be taken at each site using a sweep net to check for the presence of adult moths. If no larvae or moths are found, the four sites will be sampled again in February/March 2008. The opportunity to monitor possible impacts on non-target plants is limited, as no native Senecio species are known at the proposed release sites.

Once established, it is likely that populations of both species will grow for some years before approaching maximum density. In Nova Scotia populations of C. atricapitana built rapidly within 5 years (Harris), but in Australia population establishment and dispersal occurred only slowly (McLaren et al 2000). It has been 5 years since P. isodactyla was released in Australia, but establishment has not yet even been confirmed at most sites (J. Ireson, Tasmanian Institute of Agriculture, D. McLaren, Department of Natural Resources and Environment, pers comm.). Significant investment to evaluate the field effectiveness of either agent before the agents achieved maximum potential would be inefficient and counterproductive. Any further steps to gain funding to monitor the performance of either species will be considered only once full establishment is confirmed.

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

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

The objective of introducing C. atricapitana and P. isodactyla to New Zealand is to establish self- sustaining populations on the West Coast of the South Island. It is expected that the insects will eventually colonise ragwort populations throughout New Zealand, contributing to the suppression of ragwort populations and the maintenance of weed control everywhere. It is not expected that any populations will be considered undesirable because both species pose only low risk to native plant populations, to the current level of ragwort control, and to the integrity of native ecosystems and processes (see section 7.7).

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.

Not applicable

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

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

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

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

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

The levels of magnitude and probability of risks, costs and benefits listed in the tables are: Probability Magnitude A = very unlikely 1 = minimal effect B = unlikely 2 = minor effect C = 50:50 likelihood 3 = moderate effect D = Likely 4 = major effect E = Very likely 5 = massive effect

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. 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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List risks and costs, and benefits, separately.

Risks and costs:

The effects on the environment if biological control of ragwort using these two species was successful are as follows:

POTENTIAL RISK RISK EFFECT OF METHOD USED TO ASSESSMENT OF RISK AND

TO: RISK IDENTIFY RISK ITS EFFECT

PROBABILITY MAGNITUDE Life-supporting Temporary Excessive Brainstorming, A 1 Insignificant risk – A capacity of baring of water runoff previous temporary, very small water, soil and ground by applications effect. air ragwort loss Incr. stocking Decline in Brainstorming C 2 Stocking rate increase less rate raises water quality than 5%, see section 7 faecal runoff Capacity of No issues related to people to environment provide for the wellbeing of future generations Sustainability of Feeding on Reduced Experimentation, B 3 See section 7 and native and native plants viability of consultation, appendices valued native plant literature, introduced flora populations and fauna Less ragwort less pollen for Consultation, D 2 See section 7 native bees, brainstorming such as L. paahaumaa Fewer Fewer native Brainstorming, D 3 See section 7 ragwort for herbivores consultation, native literature herbivores Gaps appear Replacement Brainstorming A 3 Insignificant risk - there is in pasture by a worse no worse weed in pastures sward weed Insects Increased Brainstorming, D 1 Interaction with native become density of previous ecosystems limited, See abundant predators applications section 7 feeding on moths alters native food web 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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Larvae alter Brainstorming, B 2 Larvae feed internally and food web as previous less available to natural prey for applications enemies, patchy parasitoids distribution, see section 7 and predators Eggs alter Brainstorming, D 1 Neither species adds food web as previous significantly to pool of prey for applications available lepidopterous parasitoids eggs, patchy distribution, and predators see section 7 Ecotype that Unexpected Previous A 3 Release population was not non-target applications obtained from same locality tested is damage to as test population. released valued plants and/or See section 4.1 alterations to food webs Swift Unexpected Previous A 1 Insignificant risk - rate of evolutionary non-target applications change would be slow, change in damage to such loss of specificity insect valued plants never observed host- and/or specific insects alterations to food webs Release of Suppression Previous A 3 No associated organisms associated or extinction of applications known, parasitoids will be organisms valued flora excluded in containment, and fauna see Section 3.5 Moths feed Competition Brainstorm A 1 Insignificant risk – Adults on nectar with native forage little if at all. nectar-feeding insects Maintenance of No specific Ragwort not prevalent in native habitats risks native habitats identified Intrinsic value Fewer Reduced Brainstorm C 2 Native insects on ragwort of ecosystems insects on above ground reduced, see section 7 ragwort faunal biodiversity Moths feed Competition Brainstorm A 1 Insignificant risk – do not on nectar with native forage much as adults. nectar-feeding insects Pollination of Brainstorm A 1 Insignificant risk - do not weeds forage much as adults Inherent Moths Hybrids form consultation A 2 Insignificant risk - both valid Genetic interbreed with native species diversity species Animal or plant See above Not a plant disease vector health

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Benefits:

POTENTIAL BENEFIT EFFECT OF BENEFIT METHOD USED ASSESSMENT OF

BENEFIT TO: TO IDENTIFY BENEFIT AND ITS

BENEFIT EFFECT

PROBABILITY MAGNITUDE Life-supporting Less herbicide Reduced drift and air Brainstorming D 4 At least 1,000 ha capacity of applied by air or pollution sprayed by air on water, soil and from the ground West Coast alone, air see section 7. Reduced herbicide in Brainstorming D 4 See section 7 waterways Previous applications Reduced herbicide Brainstorming D 2 Benefit uncertain residue in soil see section 7 Less volatile Reduced air quality Brainstorming A 1 Benefit insignificant alkaloids over ragwort infestation Less fertiliser use Better retention of Brainstorming C 1 Improvement fertiliser uncertain but small Increased Better stewardship of Brainstorming A 2 Improvement not productivity and riparian areas significant profitability Capacity of Introduces Faunal aesthetics Brainstorming A 1 Insignificant benefit; people to provide attractive moths improved accrues to few for the wellbeing of future generations Sustainability of Less ragwort, Reduced grazing Brainstorming D 3 See section 7 native and fewer native pressure on native valued insects that attack hosts of herbivores. introduced flora it and fauna More moths in Increased population Brainstorming D 1 Insignificant effect environment density of native predatory species Platyptilia attack Attacks S. aquaticus, Brainstorming B 2 S.a is a minor weed; on exotic non- may attack S. S. m. is not yet target plants madagascariensis present in NZ Maintenance of No specific Ragwort not native habitats benefits identified prevalent in native habitats Intrinsic value of Improved pasture Increased ecosystem Brainstorming D 4 See section 7 ecosystems growth productivity Increased below Brainstorming C 2 See section 7 ground biodiversity Inherent genetic No specific diversity benefits identified Animal and plant No specific To native animals health benefits identified 20 Customhouse Quay, Cnr Waring Taylor & Customhouse Quay PO Box 131, Wellington Phone: 04-916 2426 Fax: 04-914 0433 Email: [email protected] Website: www.ermanz.govt.nz

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6.2 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. The effects on human health and safety if biological control of ragwort using these two species was successful are as follows:

Risks and costs: A http://www.google.com search using keywords „ragwort human‟ generated 16,900 entries. There are many references to the impairment of liver function by poisoning with pyrrolizidine alkaloids, but the importance of this for human health appears to be unproven.

A http://www.pubmedcentral.com/ search yields no significant accounts of human effects of Cochylis or Platyptilia species.

POTENTIAL RISK RISK EFFECT OF RISK METHOD USED ASSESSMENT OF

TO: TO IDENTIFY RISK AND ITS

RISK EFFECT

PROBABILITY MAGNITUDE Public health Clouds of moths Physical nuisance to Brainstorming, A 1 Insignificant risk - humans overseas population of moths consultation will not grow large enough, no record in Australia Fear of insects Brainstorming, A 2 Insignificant risk - previous very few people applications affected

Increased moth scales Increased allergic Brainstorming A 1 Insignificant risk - responses moth scales not a major allergen now, little increase in overall density of all moths Less ragwort Less available as herbal previous A 1 Insignificant risk - medicine applications world supply not significantly affected Reduced opportunity for previous A 1 Insignificant risk - commercial NZ herbalist applications demand tiny, ragwort still available 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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Benefits:

POTENT BENEFIT EFFECT OF BENEFIT METHOD USED TO ASSESSMENT OF IAL BENEFIT TO: IDENTIFY BENEFIT AND ITS

BENEFIT EFFECT

PROBABILITY MAGNITUDE Public health Less ragwort Reduced dermal Brainstorming A 1 Insignificant, not poisoning from currently important weeding ragwort

Overall reduction in Brainstorming A 1 Insignificant, not alkaloids in meat and currently seen as a milk significant problem Overall reduction in Brainstorming, B 2 minimal, not alkaloids in honey consultation currently seen as a significant problem Less herbicide Less operator Brainstorming, Minimal if applied exposure to consultation operational safety herbicides requirements are implemented

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.

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Risks and costs:

Key environmental outcomes Significant Significant Comment Risk or Benefit? cost? The continued and improved availability, No No The insects will only attack ragwort. Decline quantity and quality of traditional food in ragwort might improve the quality of resources (mahinga kai) mahinga kai but benefit not significant The continued availability, quantity and No No This might be enhanced by the successful quality of traditional Maori natural biological control of ragwort but benefit not resources significant The retention of New Zealand’s diverse No No This could be enhanced by the successful range of indigenous flora and fauna biological control of ragwort but benefit not significant The protection of indigenous flora and No No This would be enhanced by the successful fauna valued by Maori biological control of ragwort but benefit not significant.

The purity of water (inland and coastal) No Yes The reduction in herbicide use resulting from and the need to retain and extend its successful biological control could reduce productive and life-sustaining capacity. pesticide runoff in water. The purity of land and the need to retain No Yes The reduction in herbicide use resulting from and extend its productive and life- successful biological control could reduce sustaining capacity pesticide load on soils. The purity of air and the need to retain No Yes The reduction in herbicide use resulting from and extend its productive and life- successful biological control could reduce sustaining capacity pesticide drift The purity of human health and well-being No No The moths will not pose any health risk to humans. Neither insect bites, stings, or causes disease. Successful biological control could reduce human exposure to pesticides but benefit not significant. The restoration and retention of natural No No Natural habitats would be enhanced by the habitats suppression of ragwort

Benefits:

No specific benefits were identified in the course of consultation apart from those listed in the table, which are detailed in Section 7. The benefits that would accrue to Māori from the control of ragwort are the same as those for the general community. Agriculture is the cornerstone of the Māori economy, and is estimated to be worth $1B annually (Mana News, RNZ, May 2005).

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

Risks and Costs:

POTENTIAL RISK RISK EFFECT OF RISK METHOD USED TO ASSESSMENT OF TO: IDENTIFY RISK RISK AND ITS

EFFECT

PROBABILITY MAGNITUDE Capacity of Less veterinary Vet. incomes and Brainstorming, A 1 Insignificant risk - people to advice on ragwort employment reduced Consultation ragwort related provide for the poisoning work is an wellbeing of insignificant part of future vet business generations Damage to non- Reduced revenue to Brainstorming, B 1 Insignificant risk - target ornamental growers, or previous no non-target plants replacement cost applications attack expected Less ragwort Less work for spray Brainstorming C 2 Most work done on operators farm See section 7 Competition with Suppression of Brainstorming B 4 Not expected, See ragwort flea beetle beetle leads to less section 7 control of ragwort nationwide Less ragwort Less pollen and Brainstorming, D 2 See section 7 nectar for consultation, honeybees literature Reduced biomass Brainstorming, D 1 Insignificant risk - for sheep grazing literature ragwort replaced by other forage

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Benefits:

POTENTIAL BENEFIT EFFECT OF BENEFIT METHOD USED TO ASSESSMENT OF

BENEFIT TO: IDENTIFY BENEFIT AND ITS

BENEFIT EFFECT

PROBABILITY MAGNITUDE Life-supporting Less mowing and Reduced petrol use, Brainstorming A 2 Benefit exists, but capacity of pasture less frequent soil small relative to water, soil and renovation disturbance other on farm costs air Capacity of Less ragwort Reduced control Brainstorming, E 4 Assuming ragwort people to costs farmer survey controlled, see provide for the section 7 wellbeing of future generations Improved farm Brainstorming, E 3 Assuming ragwort incomes farmer survey controlled, see section 7 Improved farm Brainstorming, E 3 Assuming ragwort productivity farmer survey controlled, see section 7 Improved land Brainstorming, A 2 Insignificant benefit values consultation – not seen as driver of price Reduced veterinary Brainstorming, D 1 Costs currently not and medical bills consultation large Increased Brainstorming D 2 Dependent on employment increased farm incomes Less ragwort More pasture D 4 See section 7 Reduced animal D 1 Insignificant intoxication, benefit, See section improved animal 7 health Reduced mortality in C 1 Insignificant horses benefit, See section 7 Reduced alkaloid C 1 Insignificant levels in honey benefit, See section 7 Reduced taint of milk C 1 Insignificant benefit, See section 7 More cows/sheep D 4 See section 7 Dept of C 2 See section 7 Conservation’s reputation as ‘good neighbour’ improved Fewer costs to C 2 See section 7 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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occupiers for ‘boundary control’ Less herbicide Increased production C 3 See section 7, used through reduced reduced spraydrift, clover damage and increased production from reduced clover damage Reduction in costs of D 4 See section 7 herbicide use

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

List risks and costs, and benefits, separately.

Risks and Costs:

No cultural, social, ethical or spiritual risks and costs have been identified apart from those addressed elsewhere in section 6. Details of consultation with māori can be found in Section 7, and in Appendix A (consultation with māori).

Benefits:

No cultural, social, ethical or spiritual risks and costs have been identified apart from those addressed elsewhere in section 6. Details of consultation with māori can be found in Section 7, and in Appendix A (consultation with māori).

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:

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Benefits:

None 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 most important direct risk to the environment is the possibility that the insects might harm native plant populations. Other risks are that the moths could adversely affect native insect populations through competition, reduce the productivity of honeybees through competition, or reduce existing ragwort control through competition with other ragwort control agents.

The risk that either Cochylis atricapitana or Platyptilia isodactyla will adversely affect populations of New Zealand native or economically valued plants is considered low. In the laboratory moths laid eggs on some New Zealand plants, and completed development when transferred to others, but could not lay eggs and then complete development on any plant other than ragwort. Larvae that began 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

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feed on non-target plants died before reaching a damaging size, and plants recovered. The evidence for this interpretation is strong, and is based on a multitude of laboratory and field studies (see Appendices C and D).

Potential impact of Cochylis atricapitana on non-target plants All information on the host plant range of C. atricapitana and the methods used to obtain that information is provided in Appendix C.

Studies on the potential host range of this species began with a field study in Europe, followed by laboratory studies in Europe (Cullen 1985, Schroeder et al 1989, Vaysierres 1985). Host-range tests using New Zealand native plants were conducted in containment in New Zealand. Finally, two field studies were conducted in Australia many years after C. atricapitana was released there (Snell & McLaren unpubl., pers. comm., Ireson 2005). The methodologies for laboratory testing and field studies are presented in Appendix C, as are the justifications for selecting host plants for testing. The performance of C. atricapitana on non-target plants is detailed there, and results are summarised in the table below.

Literature records indicated that C. atricapitana was monophagous on ragwort, Senecio jacobaea in Europe, its native range (Schroeder et al 1989). A field study there found no moths attacking a range of closely related Senecio species, even when growing in mixed populations, confirming literature records. However, when newly hatched larvae were transferred to several of these plants in the laboratory, many completed development. These results suggested that transferring newly-hatched larvae onto plants in the laboratory provided a longer list of potential hosts than actually occurred in the field (Appendix C, Schroeder et al 1989).

CAB International Institute of Biological Control researchers rejected oviposition tests as a valid means of checking potential host range because in the laboratory moths appeared to discriminate poorly when laying eggs. For example, eggs were sometimes deposited on the wooden cages. The larval transfer tests alone were considered a valid determinant of environmental safety because the ability to complete larval development is crucial to the establishment of a self-sustaining population on a non-target plant, no matter where the moths lay eggs.

In total, 100 plant species have been tested. Laboratory tests conducted in Europe showed that C. atricapitana could not develop on 40 plant species belonging to 24 families other than the Asteraceae (the family to which ragwort belongs), nor could it utilise 22 plant species of 12 tribes of the Asteraceae. These tests strongly indicated that the host range of C. atricapitana was restricted to the tribe Senecioneae within the Asteraceae family (Cullen 1985, KTRI 1985, Vaysierres 1985).

Thirty-eight taxa within the tribe Senecioneae have been tested, including 19 species native to New Zealand (Wagstaff & Breitwieser 2002). Oviposition tests were added to the methodology when C. atricapitana was introduced into containment in New Zealand for final evaluation. An array of test 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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designs was developed to test the ability of moths to discriminate between plants when laying eggs in a range of conditions (Appendix C). However, as predicted by European researchers, moths did not select carefully where eggs were laid, although apart from one or two eggs laid on other species, oviposition was restricted to Senecio species (see table below). Moths laid eggs on six native species, but few eggs were laid compared to ragwort controls (Tables 3-7 of Appendix C).

Eggs laid on test plants were allowed to hatch, but no hatching larvae completed development. Newly-hatched larvae transferred to test plants could not complete development, with two exceptions: one adult (which died on emergence) was reared on cut foliage of Senecio banksii (as opposed to potted plants on which none emerged). No eggs were laid on S. banksii in any tests (Appendix C, Tables 3-6). Adult moths were also reared on the foliage of four European species closely related to ragwort, as described above.

The few eggs laid on potted native plants in laboratory tests hatched. Although this was not observable, larvae attempted to establish in the stems and crown of tests plants. Despite this, no plants were damaged or killed by larval feeding, and continued to grow. This was presumably because larvae failed to establish on test plants, or having established within the stems died before reaching damaging size.

Summary of outcome of all C. atricapitana host-range testing trials, 1985-2005. The rationale for selection of host plants is discussed in Appendix C. Superscript figures refer to the same-numbered tables in appendix C. (* = also present in New Zealand; LI = first instar or first larval stage)

In tests, Cochylis atricapitana was capable of Laying eggs Partial Developing to Laying eggs Using plant in on test plant development adult following the field Test plants in lab as larva development following release Tribe Senecioneae European species Senecio jacobaea control S. erucifolius Not tested Yes 2 Yes 2 Not tested S. alpinus Not tested Yes 2 Yes 2 Not tested S. aquaticus Not tested Yes 2 Yes 2 Not tested S. squalidus Not tested Yes 2 Yes 2 Not tested S. paludosus Not tested No No S. cineraria Not tested Yes 2 No 2 Not tested

North American species Senecio jacobaea control Not tested Yes 2 Yes 2 S. leucostachys Not tested No No S. cruentus ( =Pericallis) Not tested No No S. pauperculus Not tested No No 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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S. canus Not tested No No S. integerrianus Not tested No No

Australian species Senecio jacobaea control Yes Yes 1 Yes 1 Not tested 40-80% infested S. madagascariensis Not tested No No 1 1 Adult crossed S. pinnatifolius No Yes Yes No and laid eggs S. p. var. lanceolatus Not tested Yes 1 Yes 1 Not tested S. p. var. dissectifolius Not tested No No S. p. var. maritimus Not tested No No S. macrocarpus Yes No No S. linearifolius* Not tested No No No S. quadridentatus* Not tested Yes 1 No No S. glomeratus* Not tested No No No S. minimus* Not tested Not tested Not tested Not tested No S. hispidulus * Not tested Yes 1 No S. cruentus (=Pericallus) Not tested Yes 1 No S. cineraria Not tested Yes 1 No

New Zealand species Senecio jaccobaea control Yes 3-7 Yes 8-11 Yes 8-11 Not tested S. lautus No No No Not tested S. glomeratus No No No Not tested S. cineraria No Yes9 Yes9 Not tested S. minimus Yes 3, 4, 5 Yes 8 No Not tested S. wairauensis Yes3, 4, 5, 6, 7 Yes 8 No Not tested S. carnosulus Yes 3, 5 No No Not tested 8 8 S. banksii No Yes Cut leaves only Adult died S. rufiglandulosus Yes 3, 4, 6, 7 No No Not tested S. glaucophyllus Yes 3, 4 Yes 8 No Not tested S. dunedinensis Yes 7 Yes No Not tested Brachyglottis bellidioides No No No Not tested B. repanda No No No Not tested B. greyii No No No Not tested B. perdicioides No No No Not tested B. compacta No No No Not tested Abrotanella caespitosa No No No Not tested Dolichoglottis lyallii No No No Not tested

Other tribes within the

Asteraceae Senecio jacobaea control Yes 1,2 Yes 1,2 Not tested 22 species in 12 tribes Not tested No No Not tested Families other than the

Asteraceae Senecio jacobaea control Yes 1,2 Yes 1,2 Not tested 40 species in 24 families Not tested No No Not 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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C. atricapitana has been released in Australia (1987) and Canada (1990). No adverse effects of those releases have been reported since then (P. Harris, D. McLaren, Department of Natural Resources and Environment pers comm.). Two post-release field studies have been conducted in Australia. McLaren (unpubl manuscript, pers. comm.) sampled ragwort plants and five native Senecio species over two years at sites in Victoria where C. atricapitana was known to exist. The plants sampled included S. pinnatifolius (on which a few larvae had completed development in lab tests) and two other species that are also native to New Zealand. C. atricapitana larvae were found in around 35% of ragwort rosettes, and almost 70% of bolting plants, but never in native Senecio plants. C. atricapitana has not established populations on native Senecio species since its release in Australia 18 years ago, even though moths laid eggs and/or developed on several of these species (especially S. pinnatifolius) in laboratory tests (Appendix C).

In a second survey, Ireson (2005) sampled plants of ragwort and S. quadridentatus (also native to New Zealand, and a sister species of S. dunedinensis; see section 7.5) at sites in Tasmania where C. atricapitana had been released 5-9 years previously. Five early instar larvae of C. atricapitana were recovered from the soil or surrounds of 60 S. quadridentatus plants, but there was no sign of current or previous damage on any of the plants sampled (295 larvae were recovered from 60 neighboring ragwort plants). This suggests that some eggs may be laid on S. quadridentatus, but that larvae cannot establish and complete development on plants in the field.

C. atricapitana was originally selected as a control agent for ragwort in Australia because it was thought to be monophagous on this weed. After 20 years of research in both the laboratory and in the field, there is no compelling evidence to refute this. To pose a risk to native Senecio populations in New Zealand, C. atricapitana would need to find the host plant lay eggs develop successfully to produce fertile adults lay eggs on the host plant once more develop an expanding population.

Marohasy (1986) stated that the conditions necessary for maintenance and fixation of the type of genetic difference in a control agent that would result in a „host shift‟ are very stringent. These conditions include: low mobility of the agent, improved survival on the new host plant, independent regulation of populations on the different hosts, or possibly geographic isolation.

C. atricapitana is a mobile moth that has performed marginally on all test plants, and the risk of colonisation of non-target Senecio species in New Zealand is regarded as very low. By Marohasy‟s criteria, the risk of a true „host shift‟ onto native species is negligible. However, tests cannot rule out the possibility that occasional eggs may be laid on a limited number of non-target plant species, and that larvae may feed there briefly. 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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Potential impact of Platyptilia isodactyla on non-target plants All available information on the host plant range of Platyptilia isodactyla and the methods used to obtain that information are provided in Appendix D, and are summarised in the table below.

Studies on the potential host range of this species include a field study in Europe and laboratory studies in Australia and Europe (McLaren 1997). Host-range tests using New Zealand native plants were conducted in containment in New Zealand. Finally, two field studies were conducted in Australia 5-6 years after P. isodactyla was released there (Snell & McLaren unpubl. MS, pers. comm., Ireson 2005). The methodologies for laboratory testing and field studies are presented in Appendix D, as are the justifications for selecting host plants for testing. The performance of Platyptilia isodactyla on non-target plants is detailed there, and results are summarised in the table below.

As it was with Cochylis atricapitana, Australian researchers working at home and in Europe discounted oviposition tests as a means of checking potential host range because in the laboratory moths appeared to discriminate poorly when laying eggs. The larval transfer tests were considered the best determinant of environmental safety because the ability to complete larval development is crucial to the establishment of a self-sustaining population on a non-target plant, no matter where the moths lay eggs. Oviposition tests were conducted only on those plant species which supported significant larval development. However, a comprehensive set of oviposition tests were conducted on native species in New Zealand (Appendix D).

In total, 63 plant taxa have been tested against Platyptilia isodactyla. Tests conducted in Australia and Europe showed that newly hatched P. isodactyla larvae could not inhabit and develop on 28 plant species belonging to 16 families other than the Asteraceae. Similarly, larvae could not utilise 13 plant species of 9 tribes of the Asteraceae. These tests strongly indicated that the host range of P. isodactyla was restricted to the tribe Senecioneae.

Thirty-four species within the tribe Senecioneae have been tested, including 12 of the 18 Senecio species native to New Zealand. Oviposition tests were employed more in New Zealand tests than in Australian research. Several designs were employed in New Zealand tests to observe the ability of moths to discriminate between plants in a range of conditions (Appendix D). However, as predicted, moths did not select carefully where eggs were laid, although apart from one or two eggs laid on other species, oviposition was restricted to Senecio species (see table below).

Moths laid eggs on a number of native species, usually at levels far less than on ragwort controls, but approaching 20% of controls on occasions (Tables 4-6 of Appendix D). When the eggs laid on potted plants hatched, or when newly hatched larvae were placed onto plants, all larvae failed to complete development on any test plants except the European species S. cineraria, a garden species that is naturalised and spreading in New Zealand (H. Gourlay, Landcare Research, pers. comm). As

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larvae fed inside the stems and crowns of the plants, there was no opportunity to observe the stage at which larvae died.

In Australian tests, single moths were reared from S. linearifolius and S. cruentus (garden cineraria) even though there were apparently no eggs laid on the plants from which these larvae could have hatched. It is likely that these larvae wandered to these plants from elsewhere (Appendix D). More significantly, occasional larvae completed development on S. madagascariensis (a European weed), S. cineraria, on S. pinnatifolius and on Arrhenectites mixta (two Australian native species). Development success never exceeded 7% of larvae, compared with 36-88% on ragwort.

Summary of the outcome of all Platyptilia isodactyla host-range testing trials The rationale for selection of host plants is discussed in Appendix D. Superscript figures refer to the same-numbered tables in appendix D. (* = also present in New Zealand; ? = result questionable, see text; LI = first instar or first larval stage, LII = second instar or second larval stage)

In tests, Platyptilia isodactyla was capable of Laying eggs Partial Developing Laying eggs Using plant on test plant development as to adult following in the field Test plants in lab larva (beyond development following LII) release Tribe Senecioneae European species Senecio jacobaea control Yes 4,5,6 Yes 2,7 Yes 2,7 S. madagascariensis No 4 Yes 2 Yes 2 7 7 S. cineraria Yes 5, 6 Yes Yes S. cruentus ( =Pericallis) No 4 ?Yes4 ?Yes4 Yes S. vulgaris Not tested No2 No 2

Australian species Senecio jacobaea control Yes4 Yes2,3,4 Yes2,3,4 Yes S. pinnatifolius var alpinus Yes 4 Yes2,4 Yes2 S. p. var. pinnatifolius Yes4 Yes2,4 Yes2,4 S. p. var. dissectifolius No4 Yes2 Yes2 S. p. var. maritimus Yes4 Yes2,4 Yes2,4 S. pinnatifolius Not tested Yes2,3 Yes2 Yes No 2,3 2,3 S. macrocarpus Not tested Yes No S. linearifolius* No4 Yes2 ?Yes4 Not tested No S. quadridentatus* Yes4 Yes2,3 No2,3 No S. glomeratus* Not tested No2,3 No2,3 S. minimus* Not tested No2,3 No2,3 No S. hispidulus* Not tested Yes2,3 No2,3 S vellioides Not tested No2 No2 S. odoratus Not tested Yes2 No2 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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S. biserratus* Not tested No2 No2 S. vagus Not tested No2 No2 S. pterophorus Not tested Yes3 No3 S. squarrosus Not tested No2 No2 Arrhenectites mixta Yes4 Yes2 Yes2 Not tested Bedfordia arborescens Not tested No2 No2 2 2 Flaveria australasica Not tested Yes No

New Zealand species 5,6 8 8 Senecio jacobaea control Yes Yes Yes 5,6 S. lautus Yes Not assessed No S. glomeratus Yes 5,6 Not assessed No 5,6 S. minimus Yes Not assessed No S. wairauensis Yes 5,6 Not assessed No 5,6 S. carnosulus Yes Not assessed No 5 S. banksii Yes Not assessed No 5 S. rufiglandulosus Yes Not assessed No S. glaucophyllus Yes 5 Not assessed No 6 S. dunedinensis Yes Not assessed No 5,6 Brachyglottis bellidioides Yes Not assessed No B. repanda Yes 5 Not assessed No 5 B. greyii Yes Not assessed No B. perdicioides No 5 Not assessed - 5 B. compacta Yes Not assessed No Abrotanella caespitosa Not tested Not tested Not tested Dolichoglottis lyallii Yes 5 Not assessed No

Other tribes within the

Asteraceae 1 1 Senecio jacobaea control Yes Yes 1 1 13 species in 9 tribes Not tested No No

Families other than

Asteraceae 1 1 Senecio jacobaea control Not tested Yes Yes 1 1 28 species in 16 families No No

P. isodactyla was released in Australia in 1999. No adverse effects of those releases have been observed since then (J. Ireson, Tasmanian Institute of Agriculture, D. McLaren, Department of Natural Resources and Environment pers comm.). Two post-release field studies have been conducted in Australia. Snell and McLaren (unpublished manuscript, pers. comm..) sampled ragwort plants and five native Senecio species over two years at sites in Victoria where P. isodactyla was known to exist. The plants sampled included S. pinnatifolius (on which a few larvae had completed development in lab tests) and two other species that are also native to New Zealand. P. isodactyla has 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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been released in Victoria for only five years, and few larvae were found in ragwort rosettes or bolting plants. They were never found in native Senecio plants. It may be too early to be certain, but P. isodactyla has not established populations on native Senecio species since its release in Victoria 5 years ago, even though moths laid eggs and/or developed on several of these species (especially S. pinnatifolius) in laboratory tests (Appendix D).

In a second survey, Ireson (2005) sampled plants of ragwort and S. quadridentatus (also native to New Zealand, and a sister species of S. dunedinensis) at sites in Tasmania where P. isodactyla had been released approximately 1-4 years previously. Very few life stages of P. isodactyla were recovered from the soil or environs of either S. quadridentatus plants (0 larvae) or ragwort controls (42 larvae, pupae or pupal cases) but there was no sign of current or previous damage on any of the S. quadridentatus plants sampled.

To pose a risk to native Senecio populations in New Zealand, P. isodactyla would need to find the host plant lay eggs develop successfully to produce fertile adults lay eggs on the host plant once more develop an expanding population.

Marohasy (1986) stated that the conditions necessary for maintenance and fixation of the type of genetic difference in a control agent that would result in a „host shift‟ are very stringent. These conditions include: low mobility of the agent, improved survival on the new host plant, independent regulation of populations on the different hosts, or possibly geographic isolation.

P. isodactyla was able to utilise several Australian members of the tribe Senecioneae in laboratory tests, but poorly. One of these species was Senecio pinnatifolius. In a „generation‟ test, researchers tried but failed to maintain a population of P. isodactyla for two generations on S. pinnatifolius in a large cage (Appendix D). The same applied when garden cineraria, Pericallis cruentus, was presented. P. isodactyla was unable to colonise either species. P. isodactyla is a mobile species. By Marohasy‟s criteria, the risk of a true „host shift‟ onto native species is negligible, and these results support the view that P. isodactyla will not be able to colonise non-target plants in New Zealand. However, tests cannot rule out the possibility that occasional eggs may be laid on a limited number of non-target plant species, that larvae may feed there briefly, and that occasional adults may emerge from Senecio cineraria.

Competition with native insects and honeybees Moths normally feed on nectar. Both Cochylis atricapitana and Platyptilia isodactyla can be reared effectively in captivity without access to a nectar substitute such as honey and water (J. Ireson, Tasmanian Institute of Agriculture, D. McLaren, Department of Natural Resources and Environment, 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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H. Gourlay, Landcare Research, pers. comm.). This suggests that moths feed little if at all in the field, and so will compete poorly with native insects and honeybees for nectar resources. If flower visitation is rare, then the influence of moths on rates of pollination will be insignificant.

Indirect effects The introduction of Cochylis atricapitana and Platyptilia isodactyla could indirectly affect the environment either by modifying the way other species in the ecosystem interact, or through the consequences of reducing the amount of ragwort present.

Indirect effects on flora and fauna The establishment of C. atricapitana and P. isodactyla in New Zealand would introduce a new element to the ecosystems surrounding ragwort plants and populations. The introduced species would add to the biomass of insects in the environment, and these would be available to parasitoids and predators. This food web would be altered if changes in the abundance of resident natural enemies generated by the addition of the two moth species had a significant adverse effect on populations of native insects, or on the animals or plants on which they feed.

Ragwort is a species typical of grasslands, and particularly of disturbed sites. It rarely impinges significantly on native habitats except in riverbeds, river margins, and amenity areas (I. Popay, Department of Conservation, pers. comm.). This means that there is only limited opportunity for ragwort or its natural enemies to interact with the flora and fauna of native habitats. For this reason alone, the risk of C. atricapitana and P. isodactyla significantly affecting food webs in native habitats is considered to be insignificant.

Eggs of both C. atricapitana and P. isodactyla are laid on the leaf surface, and would be available to those egg parasitoids and predators that frequent pastures in New Zealand. Little is known of this fauna. Pupae can be found inside the plant or in the litter around the base (Section 3.4), and would be moderately susceptible to generalist parasitoids and predators, but it is not known which if any could take advantage of this food source. Larvae feed internally and are rarely available to generalist parasitoids and predators. Moths would be available to spiders and perhaps birds.

Ragwort distribution is patchy, does not form monocultures, and does not form a predominant part of the plant biomass at a landscape level. It is unlikely that the addition of ragwort specialist herbivores would add significantly to the prey biomass in the pasture ecosystem, and so indirect effects on other prey species or plants is likely to be minimal. The risk of indirect effects on non-target species in pastoral or native habitats is considered insignificant.

No associated organisms have been identified for either organism. See section 3.5.

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The Department of Conservation does not see ragwort as a key species in the maintenance of native habitats (Ian Popay, Tom Belton, Department of Conservation, pers. comm.).

Indirect effects of reducing the incidence of ragwort in the environment Successful biological control could reduce the amount of ragwort in grasslands by at least 70%. This has already been achieved by ragwort fleas beetle in many parts of New Zealand (Appendix B). Sheep graze ragwort, and biological control would reduce the amount of this forage available. Other plant species would replace ragwort and provide alternative forage. The net effect would be temporary, and the risk insignificant.

Increased higher quality forage, and reduced risk of animal poisoning could lead to increased stocking rate, increasing grazing pressure and the rate of water runoff, increasing faecal matter, and decreasing water quality. The increase in stocking rate is likely to be 5% or less (Appendix B), and the increase in resulting problems smaller. Although this effect is likely on occasions, the magnitude of the possible effect is minimal and the risk low.

Less ragwort would reduce the pool of pollen and nectar available for native insects and honey bees. Ragwort is abundant only locally, and provides a relatively small proportion of the total available pollen and nectar available at a landscape level. Ragwort would be replaced in part by pollen and nectar-bearing plants such as legumes. The effect is not unlikely, but the size of the effect minimal. The risk is regarded as low.

Several native herbivores feed on ragwort (Syrett 1983), and reducing the abundance of ragwort will reduce the abundance of these insects species and hence faunal biodiversity in pastoral ecosystems. Native Senecio species are the natural hosts for these herbivores, not ragwort (Syrett 1983). Reduction of ragwort can therefore be seen as both a cost and a benefit to the biodiversity of pastoral ecosystems.

Benefits: Ragwort is not prevalent in native habitats, and the direct benefits to be gained from reducing ragwort infestations are therefore small. The costs (and potential benefits) to the Department of Conservation of successful biocontrol are not directly related to maintaining biodiversity (Section 7.5). Reducing ragwort density may even reduce damage to native Senecio species caused by native insects (see above).

If biological control of ragwort was successful there would be indirect environmental benefits from reducing weed management inputs. Less herbicide would be applied to farmland, roadsides, riparian strips and amenity areas. There is very little information available about the fate of herbicides in the New Zealand environment, but reduction in the use of herbicide would also reduce the amount of herbicide drifting in the air, lodging in soils, and running to waterways. The extent to which this is a current problem is uncertain. A survey

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conducted in West Coast (Appendix B) indicated that the average dairy farmer spent $980 on herbicide to treat ragwort, and the estimated amount for the region‟s dairy farms alone was $314,000.

Less mowing of ragwort would reduce use of fossil fuel. Fewer fertilizer applications might be needed to maximize production from other plants on infested land. Both effects are likely to be sporadic and of overall marginal benefit compared to other issues.

Where ragwort is abundant, native insects such as Patagoniodes farinaria build to larger numbers than if they were feeding on rare native hosts. This may create unnaturally high grazing pressure on any native Senecio species growing near infested ragwort. Reducing ragwort density by biological control could reduce the abundance of these insects in modified habitats, and reduce the effect on native plants. It is not known whether this theoretical effect exists, or what its magnitude might be.

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 significant risks identified (see section 6.2)

Benefits: Successful control of ragwort would reduce the amount of herbicide applied to dairy pastures in New Zealand, and so reduce the frequency of exposure of farmers and spray operators to the toxic elements of herbicides. Assuming that herbicides are currently applied according to label requirements and in accordance with requirements for occupational safety, the benefits to human health are presumably marginal. There have been informal reports of human poisoning resulting from absorption of ragwort alkaloids through the skin while pulling plants. If true, biological control of ragwort would reduce the incidence.

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. 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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Consultation with Māori: Ragwort is a problem nationwide, and even though releases of these insects are planned for West Coast in the first instance, it is likely that both species will eventually colonise ragwort throughout the country. Consultation was therefore conducted nationally.

Local rūnanga of Ngāi Tahu were initially consulted when the organisms were introduced into secure containment at Lincoln for host-range testing research in 2003. This led to modifications in the planned testing. The results of host-range testing and the plans for preparing the application were presented to the new organisms committee of Kaupapa Taiao, Ngāi Tahu on 6 April 2005.

An information pack was prepared. The document described how the applicant intended to assess the risks, costs and benefits surrounding the proposed introduction of Cochylis atricapitana and Platyptilia isodactyla in the application, and asked each organisation to identify any issues that were inadequately, or not covered in those plans. Information sheets about safe practice of biological control of weeds were included. Recipients were given the option of responding by form letter (a self-addressed envelope was included), by email, by phone, and were invited to seek more interaction with the applicants. The offer to meet kanohi ki te kanohi was not explicit, but such meetings would have been undertaken willingly had respondents requested it. The information pack was circulated to a list of 133 iwi, hapū, individuals and māori organisations (18 of which are papatipu rūnanga of Ngāi Tahu). This list was supplied by ERMA New Zealand. The packs were distributed in early April, and responses were requested by 27 May (6 weeks). The information pack is reproduced in appendix A. Five information packs were returned address unknown but were sent to new addresses. Eventually only two packs remained undeliverable.

The applicants recognised that if permission to release was granted, then initial releases would be made on the West Coast, and manawhenua would lie with the two rūnanga of that area (Te Rūnanga o Makaawhio and Te Rūnanga o Kati Waewae). All papatipu rūnanga of Ngāi Tahu were included in the general consultation process. Makaawhio and Kāti Waewae were also kept informed by phone, and Kāti Waewae met with representatives of the West Coast Ragwort Control Trust on 14 June 2005.

Email, written, and verbal responses were received from 16 sources (12% of those consulted). Ngāi Tahu provided a formal response on behalf of its constituent rūnanga, and taking this into account the response rate was 9%. In none of the written responses, or the follow up phonecalls was a specific request made for face to face meetings. A response from Ngāti Porou is expected shortly.

The applicant entered into dialogue on all specific issues raised by respondents. The actual responses (and the resulting dialogue with the applicants) can be found in Appendix A (consultation with māori). Seventy copies of one response were provided to a komiti for distribution amongst constituent whānau 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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A pānui was placed on the „Hot Topics‟ area of the Federation of Māori Authorities website (www.foma.co.nz/) seeking input from readers to include in the final application. The Environment Bay of Plenty Māori Consultative Committee was made aware of the proposal.

The applicant will contact all parties again once the application is available for public comment. The relevant sections of the application will be provided, and they will be invited to make a public submission

Risks and costs: As in previous applications to introduce new organisms, there was a fundamental distaste for the introduction of exotic organisms, but it was acknowledged that the benefits of biological control could outweigh this as long as the process was environmentally safe. A recurring theme during consultation was the role of māori as kaitiaki, and the concern for maintaining the connectedness of „nature‟. All sought reassurance that this proposal would have a minimal environmental „footprint‟ (Appendix A).

Risk to non-target plants The greatest direct risk to the New Zealand environment is that Cochylis atricapitana and Platyptilia isodactyla will form permanent populations on native plants. This fear was expressed by most respondents.

The range of hosts on which the agent can develop in the field has been assessed carefully, not only by Landcare Research, but by authorities in Australia (Platyptilia) and Australia and Canada (Cochylis) before introduction there. Landcare Research tested most of the native ragwort-relatives. Moths of both species can lay eggs on plants other than ragwort, but when those eggs hatch, larvae cannot develop fully on any native plants. Scientists in Australia have recently looked closely in the field for any attack on non-target species that larvae fed on briefly in the laboratory. No significant attack was found. We think that this wealth of information is convincing.

There is minimal risk that either moth will colonise valued plants if released in New Zealand. The experimental evidence to support this is in Appendices C & D, and is summarised in section 7.1.

Modification of the food chain No species is an island. Introducing any new species to an ecosystem alters relationships between trophic levels, and alters the distribution of strands in the food web. Several respondents identified the stability of these relationships in native habitats as a key issue (Appendix A). Ragwort is not common in or around native habitats, and so any influences from the introduction of these species is likely to be minimal. Addition of a new species usually introduces an additional resource for parasitoids and predators. This might vary the intensity of encounters in other parts of the food web. In this case, most life stages of Cochylis and Platyptilia occur within the crowns and stems of ragwort 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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plants, and are not available to generalist parasitoids and predators. Even in modified habitats such as pastures, the influence on food webs of introducing these two species is expected to be negligible. This issue is discussed in more detail in section 7.1.

Risks from ‘associated organisms’ Any parasitoids and predators that might accompany shipments of insects from Australia will be found and eliminated in quarantine before release. No micro-organisms have been identified in either species. Laboratory cultures in Australia, New Zealand and/or Canada have remained vigorous and long-lived, with no sign of reduced life-span, increased mortality of reduced fecundity. These are strong signs of good health, and there is no indication of associated disease. A proportion of the imported moths will be sacrificed and diagnosed to search for any unexpected „associated organisms‟.

No other risks and costs specific to māori were identified. Section 7 discusses further risks and costs to New Zealand and New Zealanders.

Benefits: To mahinga kai and the natural environment One respondent requested that the application not overestimate the direct benefits that ragwort control would have for the natural environment, and for mahinga kai. This is correct. The Department of Conservation controls ragwort using herbicides, but not for biodiversity reasons (see section 7.1). It is often common in riverbeds, often in National Parks, ragwort does not seriously impact on ecosystem values in native habitats. Successful biological control would have little direct benefit (see section 7).

To land and water quality Whether farmers trying to maximise pasture production on dairy farms or staff trying to limit spread in Aoraki National Park, there is widespread use of herbicides to suppress ragwort in New Zealand. A range of products are available for broad-acre spraying, spot application or as granules to kill individual rosettes. There is little information available about whether these herbicides have significant adverse effects in soils or waterways, but this was clearly the belief of respondents. Cochylis atricapitana and Platyptilia isodactyla kill plants, reduce plant size and height, and reduce seed production. The case for improved ragwort control through insect damage reducing the amount of herbicide applied is made in section 7.2. Reduced herbicide usage would reduce the pesticide load on soils and waterways.

Better than other control options Several respondents expressed the view that if ragwort control was required, then biological control was a preferred option to alternative technologies such as genetic manipulation or the use of toxins (herbicides). Successful biological control would reduce the use of herbicides in New Zealand (see Section 7.1) 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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Economic benefits The consultation did not identify specific ways in which introduction of these two moth species could provide economic benefits to māori. Perhaps the request for information in this area was not given sufficient prominence. Agriculture is though to make up 66% of the māori economic base (website of the Federation of Māori Authorites) and dairy farming is a core part of that investment. The benefits that would accrue to New Zealand agriculture are discussed in Section 7.4. These benefits would accrue proportionately to māori farmers.

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.

Risks and Costs: Costs of introducing the agents The total cost of developing and releasing the two agents is budgeted at $403,000, of which all but $51,000 are sunk costs. No other direct economic costs associated with introduction are anticipated

Indirect costs resulting from reducing the incidence of ragwort The net indirect costs of successful control of ragwort are probably minimal. Successful control would result in less work for vets attending cases of animal intoxication. This effect is likely, but such callouts are rare, and the economic losses to vet services nationwide would not be significant (Gary Dew, Grey Veterinary Clinic, pers. comm.). Successful control of ragwort would reduce the work available to agricultural contractors and helicopter operators in ragwort-prone areas (Appendix B). However, most on-farm ragwort control is carried out by farmers and their staff (Biosecurity Officers from various regional councils, Appendix A – consultation with regional councils), and this would limit the cost to contractors. It would also increase the productivity of on-farm labour. This represents a transfer of benefit from the contracting business to the farm.

Reduction in nectar and pollen for honeybees Reduction in the incidence of ragwort will reduce the numbers of nectar-bearing flowers available to honeybees. Less pollen will be available for honeybees to harvest to feed larvae in the hive. Ragwort flowers in January and February when many other pollen sources are available, and when the demand 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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for pollen in hives is not high (B. Donovan, beekeeper, pers. comm.). The reduction in pollen available to bees would not be a significant cost to beekeeping. The pool of nectar available to bees would also be reduced. Ragwort nectar contains pyrrolizidine alkaloids that are concentrated in honey derived from ragwort flowers, and produce a dark, waxy inedible honey - “…if you have not encountered it, ragwort honey has an obnoxious taste and smell. It still stays with me the time I waved around a pot on the coach to the honey show many years ago” (http://www.gbka.co.uk/news- letters/news_archives/2003/12-03.htm). Small amounts of ragwort nectar can taint otherwise valuable honey, although the presence of alkaloids at these levels is not known to be a health hazard. Ragwort honey would still be valuable to feed the hive, but is detrimental to honey production for sale. Ragwort is generally regarded as a contaminant by beekeepers, and there would be no net adverse effect to beekeepers from reducing the availability of ragwort nectar.

Potential loss of existing level of ragwort control provided by Longitarsus jacobaeae (ragwort flea beetle) At present, Longitarsus jacboaeae (Waterhouse) (Chrysomelidae) is providing control of ragwort in many parts of the country. The scientific evidence for that claim has not been published well, but the experiences of land and weed managers are compelling (Appendix B). Is there a risk that the introduction of P. isodactyla and C. atricapitana will compromise the level of ragwort control already achieved by L. jacobaeae, and reduce current economic benefits? The case for improving ragwort control is detailed in Appendix B.

The purpose of this application is to establish biological control of ragwort in areas where L. jacobaeae is not providing that control, such as West Coast and Southland. Clearly, in these areas there will be no effective competition with L. jacobaeae.

McEvoy et al (1991) concluded that L. jacobaeae infestation was responsible for the successful biological control of ragwort in Oregon by causing a sharp decline in the populations of small ragwort plants. However, on large plants the load of beetle larvae was less (number of larvae per gram of host plant dry matter was negatively correlated with plant size), and so large plants were likely to be more resilient to control by L. jacobaeae. This suggests that there is room for P. isodactyla and C. atricapitana to colonise larger plants without competing with L. jacobaeae. However, larvae of P. isodactyla and C. atricapitana feed in plants at all stages from small rosettes to flowering plants.

P. isodactyla, C. atricapitana and L. jacobaeae all feed in the below-ground portion of ragwort plants. In rosettes, C. atricapitana larvae feed in the crowns of the plant while P. isodactyla feeds beneath the crown in the roots. In bolting plants P. isodactyla remain in the roots, while C. atricapitana feed in the crown but also migrate into the stem. L. jacobaeae larvae feed in the roots of both rosettes, and bolting plants, but tend to be at the extremities, whereas P. isodactyla feed in the body of the rootstock. These species appear to partition the root/crown/stem habitat. All three species coexist in Europe.

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In Canada C. atricapitana is considered to contribute to control in areas where L. jacobaeae activity is curtailed in autumn, but also in sites where the two species coexist and both contribute to control (Harris). C. atricapitana also coexists with Longitarsus species in Tasmania and Victoria, and the same view is held by researchers there (D. McLaren, Department of Natural Resources and Environment, J. Ireson, Tasmanian Institute of Agriculture, pers. comm.). P. isodactyla has been released in Australia only, and populations have yet to peak. All species appear to coexist in Australia, as they do in their native European range (D. McLaren, Department of Natural Resources and Environment, J Ireson, Tasmanian Institute of Agriculture, pers. comm.).

If either P. isodactyla or C. atricapitana larvae are present in sufficient numbers in plants to suppress populations of L. jacobaeae, it is also likely that the damage caused by those larvae will replace or enhance the level of control achieved by Longitarsus jacobaeae. At field scale, coexistence of these natural enemies is likely to be moderated by environmental variables. Species are likely to partition the available host plant material physically by feeding site, climatically by subtle variations in developmental and activity rates from time to time and place to place, and spatially through variations in ragwort density, neighboring vegetation, microclimates and other site variables. Even if these species competed within individual plants, at an ecosystem level the effects on ragwort control are likely therefore to be additive rather than subtractive. The risk to the level of control currently provided by L. jacobaeae is considered to be low.

The literature provides very few examples anywhere of asymmetric competition, that is competition that strongly benefits one anatagonist over another (Strong et al 1984). In a recent review, Reitz and Trumble (2002) found only 42 cases of competitive displacement in the entomological literature, and only one involving insects feeding within a plant. Biological control of weeds normally involves the introduction of more than one control agent (Julien and Griffiths 1988). There are no examples of projects where the introduction of subsequent agents has reduced the overall level of control achieved.

Benefits: Benefits of reduced intoxication Ingestion of ragwort causes the intoxication and death of stock such as cows and horses, but acute events are rare, and the benefits achieved from reducing such events are not significant nationally (Gary Dew, Grey Veterinary Clinic, pers. comm.). Ragwort poisoning also causes chronic health defects in animals, but little is known about the value of this nationally.

Increased productivity of pastures and reduced control costs on the West Coast and in New Zealand A survey of the cost of the ragwort problem to the dairy industry on the West Coast was conducted and the results are presented in Appendix B. Two methods were used. 1. Calculating the cost of conventional control currently undertaken to maintain the health and productivity of dairy cows in the region. 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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2. Estimating the likely increased production if ragwort was no longer a weed.

The estimate for the total annual cost of ragwort control operations on West Coast dairy farms (based on 2001/02 estimates of land in dairy production) was $737,000. This estimate is considered conservative because: It does not include control costs other than labour and herbicide (cost of capital, cost of operating machinery, cost of small spray devices etc) Helicopter expenditure is probably underestimated

Assuming that improved, cost-free ragwort control allowed an increase of just 0.05 stock units (SU) per ha (or 2.4%), increased production of $1.28M would accrue to West Coast dairy farmers (Appendix B).

Ragwort is a key weed in Southland, another emerging dairy-farming region. As on the West Coast, ragwort is not controlled biologically in Southland (P Ayson, Southland Regional Council, pers. comm.). Unlike the West Coast Regional Council survey, there has been no farmer survey of infestation and expenditure in Southland. Assuming that the pattern of incidence of ragwort, the levels of per ha expenditure and frequency of treatment in Southland are the same as in West Coast, the current annual expenditure on ragwort on dairy farms in Southland is estimated at $1,558,000.

The damage caused by ragwort on dairy farms varies throughout New Zealand because in many cases ragwort flea beetle is already providing adequate biological control (Biosecurity Officers, Appendix A – consultation with regional councils, Appendix B). There is little hard information about what proportion of land in dairy production is still treated annually to control ragwort (Biosecurity Officers, various regional councils, pers. comm. Appendix A). Using the same assumptions listed above, the annual cost of treatment could range from $195,000 (1% of the effective ha in dairy production) to $1,945,000 (10%) (Appendix B, land use figures from Department of Statistics website.).

The annual cost of controlling ragwort on land in active dairy production alone in New Zealand is therefore estimated at $2.5m to $4.2m. This is an underestimate of the total spent on ragwort control annually in New Zealand. Ragwort is also controlled on other farming systems (sheep and beef farms, deer farms etc), to conform to boundary clearance requirements of Regional Pest Management Strategies (Biosecurity Officers pers. comm..), and elsewhere (I Popay, T Belton, Department of Conservation; R. Jackson, Timberlands West Coast, pers comm.). The annual costs of these operations have not been estimated and are not included.

Reduced damage to clovers and other pasture legumes from spraying ragwort Clovers fix nitrogen and are vital to maximise biomass production. Clovers are highly susceptible to most herbicides used for ragwort control, and any herbicide application reduces clover populations. Collateral damage is worst in heavy ragwort infestations where ragwort control is achieved by using 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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boom sprayers or aerial application. Successful biological control of ragwort would remove the need for herbicide application, conserve legumes, and improve pasture productivity. Moderate levels of biological control could reduce ragwort populations in some pastures to a point where spot spraying could be employed instead of broadcast application, reducing costs, minimising non-target damage to clovers, and improving the sustainability and productivity of pastures. This outcome is likely, with moderate benefits.

Reduced herbicide use for ragwort control on amenity land and around boundaries Most Regional Councils require occupiers to clear ragwort from areas bordering neighbouring properties that are free of ragwort, even when this provides no economic benefit to the occupier (Appendix B). Many also require clearance from waterway margins and road frontages. Larger landholders such as the Department of Conservation and forest plantations also need to comply even though there are no production or conservation values benefit. The cost of complying with the requirements of Regional Pest Management Strategies (RPMS) is almost impossible to estimate, but must be substantial. Successful biological control of ragwort would eventually allow Regional Councils to drop boundary clearance requirements from strategies, saving those costs.

Overall cost benefit analysis: The economic costs associated with introducing Cochylis atricapitana and Platyptilia isodactyla are not considered to be significant.

Realisation of the benefits depends on the level of control likely to be achieved by Cochylis atricapitana and Platyptilia isodactyla, and the likelihood of achieving that level of control. A cost benefit analysis of the introduction, establishment and benefit of introducing the two agents is provided in Appendix B. It is summed over a 20-year horizon using 3 discount rates. Three levels of control are considered. The likelihood of achieving 20% control of ragwort using these insects is conservatively thought to be 80%, 50% chance of achieving 50% of available benefits and 80% chance of achieving 20% control.

West Coast (Tables 1-3 Appendix B) Discount rate/level of 20% control 50% control 80% control control 2% $884,000 $2,315,000 $3,947,000 7% $342,000 $1,018,000 $1,814,000 12% $92,000 $429,000 $837,000

At all discount levels and at all levels of control the introduction of the two species appears to have long-term economic benefit to dairy farming alone on the West Coast. There are additional and significant unestimated benefits of biological control of ragwort: Increased pastoral production from reduced collateral herbicide damage to nitrogen-fixing clovers. 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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Increased stocking rates as a result of increased pasture productivity Significant benefits would accrue to Department of Conservation, Local Authorities and occupiers through reduction in treatment on boundaries and waterways. This benefit would accrue but only if biological control was so successful that ragwort was removed from Regional Pest Management Strategies, and boundary clearance was no longer required. Ragwort is controlled on farms other than dairy farms. Successful control would provide savings there as well. The value of this has not been estimated.

Although there are no plans to do this at present, the control agents could be transferred to other parts of New Zealand, and similar economic gains could be made there. The same analysis was carried out if biological control was expanded to Southland and the dairy pasture elsewhere in New Zealand where ragwort is not already controlled by ragwort flea beetle (appendix B). Two scenarios were used; 1% of pasture, and 10% of pasture. These estimates too are underestimated, as described above.

West Coast, Southland and 1% of remaining dairy pasture in New Zealand (Tables 4-6 Appendix B) Discount rate/level of 20% control 50% control 80% control control 2% $3,391,000 $8,225,000 $13,739,000 7% $1,559,000 $3,845,000 $6,533,000 12% $716,000 $1,852,000 $3,232,000

West Coast, Southland and 1% of remaining dairy pasture in New Zealand (Tables 7-9 Appendix B) Discount rate/level of 20% control 50% control 80% control control 2% $5,893,000 $14,125,000 $23,515,000 7% $2,776,000 $6,667,000 $11,244,000 12% $1,339,000 $3,274,000 $5,624,000

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

Assess risks and costs, and benefits, separately.

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Community Consultation: This is a community-based initiative funded by the Sustainable Farming Fund. It was initiated by four well-advertised public meetings on the West Coast. A Trust was formed, and is supported by funding or in kind support from the West Coast Development Trust, the Landcare Trust, Timberlands West Coast, Dexcel Ltd (West Coast), Royal Forest and Bird Protection Society, West Coast Regional Council, NuFarm, Westland Milk Products, FITT Meat and Wool NZ Ltd, and the Department of Conservation. The formation of the Trust, and the plans to introduce these agents have been the subject of four press releases.

Information packs (Appendix A) were sent to the following organisations without response: Royal Forest and Bird Protection Society Beekeepers Association of New Zealand Federated Farmers of New Zealand

The information pack was sent to the Department of Conservation, and a response was received (Appendix A). Further information was sought from Westland Conservancy and Head Office (Tom Belton, Paul Craddock, Ian Popay, pers, comm.) (Appendix A – consultation with other organisations).

Biosecurity officers of 6 Regional councils were questioned about ragwort management in their region (Appendix A), and others were solicited for general comments on the state of ragwort control in New Zealand (Appendix B)

Risks and Costs: Apart from the issues already addressed in section 6 and 7, no additional cultural, social, ethical or spiritual risks and costs have been identified

Benefits: Apart from the issues already addressed in section 6 and 7, no additional cultural, social, ethical or spiritual benefits have been identified.

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 issues have been identified 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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Benefits: No additional issues have been 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.

Assessing the positive and adverse effects of introducing these two species is simpler than for biological control agents for most weeds. Ragwort very largely inhabits modified habitats, particularly farmland, and is not normally found in pristine native habitats. Interactions with intact native ecosystems and ecological processes are therefore limited, and most adverse effects and benefits normally associated with such interactions can be discounted. Because of this, there was less concern from māori about introducing a new element to the fauna, and less concern from DoC regarding secondary effects of introduction (Section 7.1). On the other hand, ragwort has no redeeming features or positive values in any habitat. It is a serious problem to the dairy industry, and must be controlled there to maintain production and animal health. Potential benefits of biological control can therefore be estimated as the control costs that would reasonably be replaced by biological control.

Little is known about how much ragwort costs the farming industry. The economic assessment of costs presented in this application has deliberately omitted costs to farming systems other than dairying. This was to make it clear that the potential nationwide benefits of the proposal underestimated the true picture in New Zealand. Ragwort is a serious issue for hill country farmers, for deer farmers, for land occupiers, and other land managers, but the information about the costs of damage caused is anecdotal. The costs to these sectors must be substantial, but are not claimed in the economic analysis.

Against this conservative estimate of potential benefit, two possible adverse effects need to be examined closely: 1. Risk of damage to non-target plants - Strong evidence is presented that both species are sufficiently safe to introduce to New Zealand (Section 7.1) 2. Risk of loss of control of ragwort control by ragwort flea beetle – Experience in Australia and Canada (and the native range) suggests that these species co-exist, and partition the host plant resource (Section 7.1). The presence of all three species is likely to damp current oscillations in ragwort populations under the influence of ragwort flea beetle alone (Appendix B).

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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.

No significant displacement of any native species in its native habitat is envisaged either from the interaction of the two moths species with elements of the native flora or fauna (see section 7), or from the expected reduction in ragwort abundance.

Successful biological control of ragwort may partially displace native insects, but not in native habitats. Several native insects that normally feed on native Senecio species have incorporated ragwort growing in modified habitats into their host range. These included the blue stem-borer Patagoniodes farinaria, the stem-mining fly Melanagromyza senecionella, and the native bee “L. paahaumaa” (B. Donovan unpublished manuscript name). Less ragwort would see a greater proportion of individuals using their native hosts.

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

Reduction in ragwort abundance is unlikely to impact significantly on natural habitats or processes. Ragwort tends to colonise pastures and disturbed or bare ground. While it may colonise naturally bare native habitats such as riverbeds, it is not closely associated with intact native habitats (T.Belton, I Popay, Department of Conservation, pers comm).

Neither insect is expected to damage native plant species, and therefore will not impact negatively on natural habitats.

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

No significant effects on human health and safety are expected from the introduction to New Zealand of Cochylis atricapitana or Platyptilia isodactyla. Neither species can attack, sting, bite, or has an offensive odour, and neither is known as a vector of human diseases. Many similar and related species already occur in New Zealand without raising such concerns.

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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.

There are no other species of Cochylis in New Zealand (Dugdale 1988), and no resident species in the subfamily Cochylinae. It is extremely unlikely that C. atricapitana could or would mate with a species of another genus, and successful hybridisation is impossible.

Dugdale (1988) nominated 10 native species of Platyptilia in New Zealand. There is nothing known to suggest that these native species interbreed or hybridise (R Hoare, Landcare Research, pers. comm.). Interbreeding or hybridisation between these native species and the European species P. isodactyla is considered to be even more unlikely. None of these Platyptilia species has been recorded on ragwort (R Hoare, Landcare Research; B. Patrick, Otago Museum, pers. comm.).

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

Neither species is parasitic, or capable of directly transmitting human or animal diseases. It is possible that the moths could assist the spread of some plant diseases (e.g. rust fungi) by transporting spores. However, this is no more likely than for any other moth exhibiting the same capability. These species will make up only a small proportion of the total moth fauna presumably capable of carrying spores, and any additional effects of this would be minimal.

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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.

Neither species is subject to CITES regulations. Both will be imported from populations in Australia, which is outside their native range. An import permit will be required under the Biosecurity Act 1993.

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 is the first time that these species have been proposed for introduction to New Zealand for release (but see section 3.7).

Cochylis atricapitana was introduced to Australia in 1987 and to Canada in 1990 (Julien and Griffiths 1998). Platyptilia isodactyla was introduced to Australia in 1999 (McLaren et al. 2000).

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

No

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

Assessment measuring impacts of biocontrol agents Abdomen hind section of an insect‟s body Biennial Taking two years to develop and seed Biological control the use of one living organism to control another Bolting Growing a central stem from the centre of a rosette Co-evolution where two organisms have evolved together and each influence the evolution of the other Crepuscular active at dawn and dusk 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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Crown the centre of the rosette, the top of the root Development test How far can a larva develop before dying when fed on a test plant – as opposed to a „starvation test‟ Dorsal relating to the upper surface Endemic naturally occurring in a country and nowhere else Epizootic parasitic on animals (including insects) from the outside or on the surface Frass larval faecal material Food web the feeding relationship between various species living together in one area, the interaction of plants, herbivores, their parasitoids, predators and diseases. Genus (plural Genera) A natural grouping of related species Herbivorous Feeding on plants Host range the range of plants that a biocontrol agent can feed and reproduce on Host specificity testing testing to find out the host range of a potential biocontrol agent Indigenous native, but may occur elsewhere. Instar growth stage of an insect (in between moults), e.g. newly hatched = first instar Lag phase the period before a species becomes invasive in a new environment Larva(e) juvenile stage(s) of an moth Lateral relating to the side Monophagous Feeding on only one species of plant Multivoltine Having multiple generations per year Oligophagous Feeding on just a few closely related species of plants Oviposit lay eggs Parasitoid an insect that feeds and develops on or within another living host insect. It completes its own development on a single host, which it kills in the process Phenology The life history of the insect and how it reacts to environmental variables such as temperature Phytophagous plant feeding Pyrrolizidine alkaloids chemicals produced by ragwort to deter grazing insects and animals feeding; toxic to mammals Pupa(e) stage of insect development between larva and adult Rosette juvenile plant, before the central tall flower stalk begins to grow

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Species A morphologically, behaviourally, or ecologically distinct group of individuals that can only breed successfully with its own kind Starvation test Does a newly-hatched larva die rather than feed on a test plant – as opposed to a „development test‟ Sympatry overlapping of natural ranges Taxa In this context, the total of species and variants of species Tribe A natural grouping 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 A Consultation with the community before application The scope of consultation Consultation with māori Consultation with Regional Councils Consultation with other organisations Personal communications Submissions and other emails The „Information Pack‟ Appendix B The bionomics and economics of ragwort control in New Zealand Appendix C The host-range of Cochylis atricapitana as revealed by host-range testing Appendix D The host-range of Platyptilia isodactyla as revealed by host-range testing

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.

Auckland Regional Council 2004. Ragwort. http://www.arc.govt.nz/

Belcher RO, 1993. The „Senecio aff. lautus‟ complex (Asteraceae) in Australia. I Criteria for exclusion of Lautusoid Senecio of Australia from Senecio lautus sensu stricto of New Zealand. Australian Systematic Botany 6: 359-63.

Bourdôt G, Saville D, Sunckell A, 1994. Ragwort and Californian thistle – most important weeds in dairy pasture? Proceedings of the 47th New Zealand Plant Protection Conference: 88-90.

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

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

Cullen JM, 1985. Supplementary testing of Cochylis atricapitana Stephens, a candidate for the biological control of Senecio jacobaea. Unpublished report.

DEFRA 2005. Ragwort http://www.defra.gov.uk/rural/horsetopics/ragwort.htm

Dugdale JS, 1988. Lepidoptera: annotated catalogue, and keys to family-group taxa. Fauna of New Zealand 14. 1988.

Emmett AM, Heath J, 1989. The Moths and Butterflies of Great Britain and Northern Ireland. Vol 7, part 1. Harley Books. Not provided.

Environment Waikato 2005. Ragwort. http://www.ew.govt.nz/enviroinfo/pests/plants/ragwort.htm

Harris P, date unknown. Cochylis atricapitana (Stephens). Root-crown feeding moth http://res2.agr.gc.ca/lethbridge/weedbio/agents/acocatr_e.htm

Ireson J, 2005. Monitoring host specificity of field populations of the ragwort plume (Platyptilia isodactyla) and the ragwort stem an crown boring moth (Cochylis atricapitana) in Tasmania: Observations on Senecio quadridentatus. Unpublished client report to Landcare Research, 10p.

Ireson J, Holloway R, Chatterton W, 2003. Establishment and dispersal of the ragwort plume moth, Platyptilia isodactyla (Zeller), for the biological control of ragwort in Tasmania. Final Report UT11062.

Julien MH, Griffiths MW, 1998. Biological control of weeds: A world catalogue of agents and their target weeds, 4th edition. Wallingford, UK:CAB Iinternational Publishing. Marohasy J, 1996. Host shifts in biological weed control: real problems, semantic difficulties or poor science? International Journal of Pest Management 42: 71-75.

McEvoy P, Cox C, Coombs E, 1991. Successful biological control of ragwort, Senecio jacobaea by introduced insects in Oregon. Ecological Applications 1(4): 430-442.

McGregor PG, 2001. Biological control of ragwort: assessing the impact of ragwort flea beetle (Longitarsus jacobaea (Coleoptera: Chrysomelidae). Unpublished Landcare Research client report LC0102/019.

McLaren DA, 1992. Observations on the life history and establishment of Cochylis atricapitana (Lep: Cochylidae), a moth used for biological control of Senecio jacobaea in Australia. Entomophaga 37: 641-648.

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 62 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

McLaren DA, 1997. Application for approval to release the ragwort plume moth, Platyptilia isodactyla (Zeller) in Australia. Unpublished report, Department of Natural resources and Environment, Keith Turnbull Research Institute.

McLaren DA, Ireson JA, Kwong RM, 2000. Biological control of ragwort in Australia. In: Proceedings of the Xth International Symposium on Biological control of weeds (ed. Neal R. Spencer) pp 67-79. Montana State University, Bozeman, Montana, USA.

Rahman A, Popay I, 2001. Emerging weeds. . http://www.maf.govt.nz/mafnet/rural-nz/sustainable- resource-use/land-management/emerging-weeds

Reitz SR, Trumble JT 2002. Competitive displacement among insects and arachnids. Annual review of Entomology 47: 435-465.

Schroeder D, Harris P, Iselin P. 1989. Investigations on Cochylis atricapitana (Stephens) (Lep: Cochylidae), a candidate agent for the biological control of Senecio jacobaea L (Compositae) in North America. Unpublished Client report, CAB International International Institute of Biological Control.

Smith L, 2003. Investigation of ragwort flea beetle (Longitarsus jacobaeae, Coleoptera:Chrysomelidae) establishment success in Westland and Tasman. Landcare Research Contract Report LC0203/181 to the West Coast Ragwort Control Trust.

Strong DR, Lawton JH, Southwood R, 1984. Insects on Plants - Community Patterns and Mechanisms. Oxford: Blackwell Scientific Publications.

Snell KA, McLaren DA, unpublished MS. Biological control of ragwort (Senecio jacobae): monitoring for non-target impacts of Cochylis atricapitana and Platyptilia isodactyla on native Australian Senecio species

Syrett, P 1983. Biological control of ragwort in New Zealand: a review. Australian Weeds. 2(3): 96- 101.

Vaysierres JF, 1985. Application for introduction into quaranatine of Cochylis atricapitana Stephens, a biological control agent for ragwort (Senecio jacobaea). Unpublished report.

Wagstaff SJ, Breitweiser I, 2002. Phylogenetic relationships of New Zealand Asteraceae inferred from ITS sequences. Plant Systematic Evolution. 231:203-224.

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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Wagstaff SJ, Breitweiser I, 2004. Phylogeny and classification of Brachyglottis (Senecioneae, Asteraceae): an example of a rapid species radiation in New Zealand. Systematic Botany 29(4): 1003-1010.

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

Wardle D, 1987. The ecology of ragwort (Senecio jacobaea L.) – a review. New Zealand Journal of Ecology 10: 67-76.

Webb C, Sykes W, Garnock-Jones P. 1988. Flora of New Zealand vol. 4 – Naturalised Pteridophytes, Gymnosperms and Dicotyledons. Christchurch, New Zealand: DSIR Botany Division.

Withers TM, Browne LB, and Stanley JM, (eds) 1999. Host specificity testing in Australasia: towards improved assays for biological control. Brisbane, Australia: Department of Natural Resources and Mines.

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”.

The West Coast Ragwort Control Trust wishes to introduce two moths to help control ragwort; the ragwort crown moth and the ragwort plume moth.

Ragwort has been a serious weed in New Zealand for over 100 years. It is a tall, yellow-flowered weed that can form a sea of colour in pastures, or disturbed ground throughout the country. Ragwort initially grows as a rosette up to 50 cm across, and at high density these bunch together to suppress all other plant species, severely affecting pasture production. When there are just a few plants farmers can grub or spot-treat plants, but at high density farmers have no choice but to blanket, or even aerial spray to alleviate the problem. This has side-effects such as death of clovers and other useful plants in pastures, and exposure of the environment to toxic chemicals. Ragwort foliage is packed with alkaloids that poison grazing animals, causing liver failure and other long-term health problems. Sheep are more resistant, and can be used to control ragwort, but ragwort can be lethal to horses. Cows avoid eating ragwort is they can, and won‟t eat the grass around it, further reducing production. It is a problem in most farming systems, especially deer, and hill country farming. Ragwort nectar can even ruin a honey crop. Ragwort is regarded as such a threat to the agricultural community 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

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all regional councils force farmers to manage ragwort so they won‟t infest neighbouring properties. The māori community has been consulted on the proposal to introduce these insects, and comment has been gained from a range of community sources.

Ragwort might colonise riverbeds and banks, and disturbed areas such as slips, but the Department of Conservation does not believe that ragwort interacts significantly with native ecosystems. The potential gains are to the agricultural sector, while the only significant risks lie in the possibility of the new insects damaging native plant populations.

This is not the first attempt at biological control of ragwort. The ragwort problem in most parts of the country has declined markedly over the last 5-10 years because of the ragwort flea beetle, introduced to New Zealand in 1983. Control has clearly failed in many places however, even in regions where the flea beetle has been generally successful. The reasons for this are unclear. The flea beetle has never been a success on the West Coast, and this is why the Trust is seeking an alternative. The ragwort crown moth has been introduced to Canada, where it has worked with flea beetle to achieve ragwort control in Nova Scotia. It was released in Australia 1987. Numbers are building, and it is beginning to affect ragwort populations. The ragwort plume moth has been introduced to Australia more recently. In its native range it likes marshy areas, and should be well suited to West Coast. The three agents are expected to complement each other in the field, to produce better control nationwide than currently exists. The insects feed in different parts of the plant, will have different habitat requirements, and population size will probably vary from year to year because of different climate requirements. What won‟t change is their host range.

The host-range of these moths has been tested extensively, not only in experiments in a close containment facility in New Zealand, but in tests conducted before release in Canada and/or Australia. The tests show that there is a very low risk that these insects would colonise and damage desirable species such as native plants if released in New Zealand. Field studies in Australia show that native ragwort species there are not at risk following the release of the ragwort crown moth and plume moth. The agents are considered safe, and both are expected to eventually distribute themselves throughout New Zealand.

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 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 65 release and rapid assessment, under section 34 of the Hazardous Substances and New Organisms Act 1996

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:

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