APPLICATION FORM Release

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

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

Application Number

APP201894

Date

18 November 2016

www.epa.govt.nz 2

Application Form Approval to release a new organism

Completing this application form

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

9. Commercially sensitive information must be included in an appendix to this form and be identified as confidential. If you consider any information to be commercially sensitive, please show this in the relevant section of this form and cross reference to where that information is located in the confidential appendix. 10. Any information you supply to the EPA prior to formal lodgement of your application will not be publicly released. Following formal lodgement of your application any information in the body of this application form and any non-confidential appendices will become publicly available. 11. Once you have formally lodged your application with the EPA, any information you have supplied to the EPA about your application is subject to the Official Information Act 1982 (OIA). If a request

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Application Form Approval to release a new organism

is made for the release of information that you consider to be confidential, your view will be considered in a manner consistent with the OIA and with section 57 of the HSNO Act. You may be required to provide further justification for your claim of confidentiality. Definitions

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

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

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

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

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

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

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Application Form Approval to release a new organism

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

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

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

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Application Form Approval to release a new organism

1. Applicant details

1.1. Applicant

Company Name: (if applicable) Margot Forde Germplasm Centre

Contact Name: Kioumars Ghamkhar

Job Title: Director

Physical Address: AgResearch Limited, Tennent Drive, Palmerston North

Postal Address (provide only if not the same as the physical): AgResearch Limited, Private Bag 11008, Palmerston North

Phone (office and/or mobile): 06 3518182

Fax:

Email: [email protected]

1.2. New Zealand agent or consultant (if applicable)

Company Name:

Contact Name:

Job Title:

Physical Address:

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

Phone (office and/or mobile):

Fax:

Email:

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Application Form Approval to release a new organism

2. Information about the application

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

The release of 18 grass species closely related to perennial ryegrass is requested to provide New Zealand researchers and forage grass breeders with important and essential new genetic resources to improve pastoral production and reduce the impact of pests, diseases and climate change.

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

Exports produced from New Zealand pastures were worth $19.5 billion, over 27.5% of New Zealand’s export earnings in 2015-16 (NZTE 2016), and the most frequently sown grasses in these pastures are the ryegrasses (Stewart 2006).

Perennial ryegrass ( perenne L.) generates $14 billion of value for New Zealand’s economy each year ((Nixon 2015). To improve production and nutritional value, and reduce the vulnerability of New Zealand pastures to future problems of pests, diseases and climate change, it is essential that an appropriate set of genetic resources from L. perenne and its wild relatives are available as genetic tools for future research and forage cultivar development in New Zealand. In preparation for adaptation to these changes and challenges in the future, these wild close relatives and their specific traits and genes are needed for integration in and crossbreeding with perennial ryegrass. These traits/genes, e.g. drought tolerance, pest and disease resistance, nutrient use efficiency, will be transferred into the perennial ryegrass genome by backcrossing the products of cross breeding with ryegrass a few times to keep the ryegrass base and also bring in the traits of interest. These wild relatives will not be grown to become new forage species.

Currently only a few species of wild relatives of L. perenne are permitted in New Zealand (MPI 2016a). We seek permission to make 18 selected species from the wild relatives of perennial ryegrass (Table 1), currently not permitted in New Zealand, available to researchers and breeders. Without these species New Zealand researchers will not have the genetic tools available to remain world leaders in plant breeding and pasture focussed research.

The main factor in the continuing international competitiveness of the New Zealand livestock industry is the low cost of feed. In New Zealand, animals generally obtain their feed by grazing year round in pastures. However, feed costs are rising forcing New Zealand to continue innovating in order to stay ahead of the game. Our meat and dairy-based industries are competing in a global market place – one that is changing due to globalisation, free trade agreements and accelerated technological

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Application Form Approval to release a new organism development. If we do not continue to invest in our future and greater productivity we risk losing the advantages that are critical when competing on a global stage.

Table 1. Wild relatives of Lolium perenne sought for release in this application.

Genus Species Origin Lolium Lolium canariense Steud. Spain and Portugal Synonym: Lolium edwardii H.Scholz, Stierst. & Gaisberg Lolium saxatile H. Scholz & S. Scholz Spain Lolium persicum Boiss. & Hohen. (Persian ryegrass)* Caucasus, Mid- and West Asia; Indian subcontinent Micropyropsis Micropyropsis tuberosa Romero Zarco & Cabezudo Morocco and Spain Festuca altaica Trin. ex Ledeb. (Northern Rough fescue). Russia, Mongolia, Synonym: Festuca scabrella Torr. ex Hook. Kazakhstan, China, Canada, USA Festuca altissima All. (wood fescue). Europe, Caucasus, Mid- and Synonym: Festuca sylvatica Vill. West Asia Festuca caerulescens Desf. Spain and Italy Festuca drymeja Mert. & W.D.J. Koch (including Festuca Europe, Caucasus, lasto). Synonyms: Drymochloa drymeja (Mert. & W. D. J. Dagestan, Western Asia; Koch) Holub. and Festuca montana M. Bieb. Northern Africa Festuca durandoi Clauson Synonym: Festuca spadicea subsp. Spain, Portugal, Algeria, durandoi (Clauson) Jahand. & Maire Morocco and Tunisia Festuca fontqueri St.-Yves Synonym: Festuca yvesii Litard. Morocco Festuca kingii (S. Watson) Cassidy (spike fescue), USA Synonyms: Hesperochloa kingii (S. Watson) Rydb, Leucopoa kingii (S. Watson) W. A. Weber and Poa kingii S. Watson Festuca mairei St.-Yves (atlassvingel – Swedish) Algeria and Morocco Festuca paniculata (L.) Schinz & Thell. Spain, Italy, Austria, Algeria, Synonyms: Festuca baetica (Hack.) Hack. ex Asch. & Morocco and Tunisia Graebn., and Festuca spadicea L. ) Festuca pseudeskia Boiss Spain Festuca pulchella Schrad Italy and Austria Festuca scariosa (Lag.) Pau Spain and Morocco Synonym: Festuca granatensis Boiss. Festuca spectabilis Jan South East Europe Festuca subulata Trin. (bearded fescue) Canada and USA Festuca triflora Desf. Synonym: Festuca patula Desf. Spain, Algeria and Morocco

*Withdrawn from the original application due to high weed risk status

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Application Form Approval to release a new organism

The species listed in this application are distant relatives of New Zealand’s species of the Festuca as they belong to the broad-leaved group of the genus (Figures 1 &2). Therefore, it is extremely unlikely that they will crossbreed with the New Zealand species of the genus or the so called fine-leaved group in figures 1 and 2. The large insert of the Eskia/Amphigens sections between the two groups within the phylogenetic tree confirms that crossbreeding between the species in this application and the New Zealand endemic species is unattainable (Figures 1 &2).

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Application Form Approval to release a new organism

A

B

Figure 1. Phylogenetic tree of festucoid grasses based on nuclear ITS and chloroplast trnL-F sequences (Catalán et al. 2004) Blue box – group of interest in this application; Red box –position of NZ native Festuca species within the phylogenetic tree; Blue arrows – wild species subject to this application; Blue and patterned arrows – taxonomic synonyms of (or the same species as) species of interest; Red arrows – cultivated species.

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Application Form Approval to release a new organism

Figure 2. Phylogenetic tree for Festuca including New Zealand native species in bold (Lloyd et al. 2007)

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It is believed the risk surrounding the introduction of these new species would be small and manageable, similar to that of the introduction of accessions from overseas of permitted species. We have been concerned about the weed risk of Lolium persicum as a known weed of cereal crops in other regions of the world (Banting & Gebhardt 1979; Beckie et al. 2013; Holman et al. 2004) and believe it to be prudent to not include this species for release in New Zealand. However we have included this species into our weed risk assessment in Section 5 to demonstrate the relative weed risk that L. persicum has compared to the 18 other species in this application. No species from the Tribe , which includes Festuca, Lolium and Micropyropsis, are listed by the National Pest Plant Accord as a significant pest plant (MPI 2016b).However, this does not imply no risk at all as some of the most economically damaging weeds are not listed by this system, either. Department of Conservation has other criteria for risk assessment, for example, it considers tall fescue (Festuca arundinacea) an important environmental weed. This species is the most important forage species world-wide from the Festuca genus. Likewise, perennial ryegrass (Lolium perenne), the most economically valuable plant species in New Zealand with over $15b value per annum is also listed by DOC as an environmental weed (Howell 2008).

Hybrids between different species within the same genus are known as inter-specific hybrids or crosses. Hybrids between close or sister genera are known as inter-generic hybrids. Hybridisation between plant species occurs frequently in nature. There is evidence that in certain environments some hybrids may be more fit than their parental taxa (Rieseberg 1995; Thompson & Lumaret 1992) Inter-specific hybridisation between perennial ryegrass and its relatives has already begun in the USA, UK, Europe and, more recently, Australia for improved biotic and abiotic tolerance (Thomas et al. 2003), water deficit stress tolerance (Barnes et al. 2014; Humphreys et al. 1997; Lesniewska et al. 2001), winter hardiness/frost tolerance (Humphreys et al. 1997; Lesniewska et al. 2001; Xiong et al. 2007), fibre components and crude protein (Xiong et al. 2006). In Australia, forage breeding to introduce aluminium tolerance from the grass species Phalaris arundinacea into P. aquatic has produced an acid soil and aluminium tolerant phalaris cultivar (Culvenor & Simpson 2014). Further, AgResearch and Margot Forde Germplasm Centre have a successful history and ongoing program of integrating useful traits from the close wild relatives of white clover (Trifolium repens) into this forage species. Some examples include crossing T. repens and T. uniflorum for improving phosphorus use efficiency (Nichols et al. 2014a) and drought tolerance (Nichols et al. 2014b) or T. repens and T. occidentale for improving drought tolerance (Hussain & Williams 2013). In T. occidentale hybrids with white clover, this improvement has been attributed to a vigorous root system, while differences in physiology as well as root traits were observed in T. uniflorum hybrids with white clover. Another example is the cross between T. repens and T. ambiguum for improving drought tolerance and virus resistsnce in white clover (Widdup et al. 2003). The risk of not allowing researchers to have access to these genetic resources is that New Zealand falls behind in the fields of pasture improvement, and that researchers do not have the tools available to adequately overcome any current or future challenges to our pastoral economy (Lancashire 2006). Many of the proposed species in Table 1 have

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Application Form Approval to release a new organism high potential of drought and heat tolerance and incorporation of their tolerance traits into ryegrass can add significantly to the performance of ryegrass in warmer and drier areas of the country.

It is our intention that the species in Table 1 be provided to researchers at AgResearch to enable them to make inter-specific hybrids between L. perenne and other closely related and cultivated species such as F. arundinacea and F. pratensis and their wild relatives to test beneficial traits and productivity in the environment unconstraint by conditions and controls that prevail in containment (laboratory or field test) that restrict full evaluation.

2.3. Background and aims of application

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

Germplasm Centre

All sown pastures in New Zealand consist of exotic species, and native species play almost no role in sown pasture (Lancashire 2006). The native tussock grasslands of the South Island and Central Volcanic Plateau are grazed but are highly modified and of relatively minor importance to the animal production industries nationally. All plants used to feed New Zealand livestock come from overseas (Lancashire 2006). The Margot Forde Germplasm Centre (MFGC) has been importing exotic germplasm for over 70 years for evaluation under local conditions to test their suitability for New Zealand pasture systems and prior to the 1990s many researchers imported exotic species for evaluation (including some species in this application). A large part of the collection remains unexplored as the current regulatory environment prohibits effective evaluation in real pastoral farmland environments.

Retention of a well-characterised seed collection of grassland species in New Zealand is an essential national strategy to ensure the long term genetic protection of New Zealand’s grassland-based economy. This argument is presented in more detail by Williams (1996). The strategic importance of this collection is supported by its inclusion in the New Zealand Biodiversity Strategy (MFE 2000), Theme 4: Conservation and use of genetic resources and by the listing of the Centre as a nationally important database and collection by the Ministry of Business Innovation and Employment (MBIE).

With the reluctance of New Zealand society to accept genetic engineering technologies it is essential that researchers have access to, and can effectively evaluate, new and unique natural germplasm under real farm conditions. Researchers must be able to continue to meet the needs of New Zealand’s agricultural sector and provide solutions to current and future biotic and abiotic stresses.

DairyNZ has a stated goal to increase productivity by $110 per hectare per year (DairyNZ 2014). Similarly, MPI has an “Export Double” goal, which involves doubling exports by 2025 (SSC 2016). Achieving these goals requires more productive pastures. This cannot be achieved without the ability to use all of the naturally occurring genetic resources available.

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Application Form Approval to release a new organism

Cultivated Lolium and Festuca species

The genus Lolium contains two widely cultivated temperate species, Lolium multiflorum (Italian or annual ryegrass) and Lolium perenne (perennial ryegrass) (Cai et al. 2011). Festuca arundinacea (tall fescue) is the most important forage species world-wide from the Festuca genus (Yamada 2011). Festuca pratensis (meadow fescue) is one of the most widely used forage grasses in cooler climates due to its generally high level of winter stress tolerance (Yamada 2011). The importance of these species to New Zealand agriculture is reflected in the fact that they collectively make up 95% of the grass component of New Zealand pasture systems (Alan Stewart, PGG Wrightsons, pers comm.).

Wild relatives

The cultivated species of Festuca and Lolium are not the only species likely to have agronomic potential in New Zealand (Cai et al. 2011; Yamada 2011). It is in the context of the importance and high value of the species listed above, we seek full release of the closely related wild relatives of Lolium and Festuca. Species closely related to current Festuca and Lolium species would be used directly in plant breeding programmes to develop new pasture varieties (Charmet et al. 1996). Worldwide, wild, uncultivated relatives have been used extensively in research and plant breeding programmes in many other species, including rice, wheat, tomato and brassicas to name a few (Tanksley & McCouch 1997).

Taxonomy and phylogenetics

With the advancement of molecular techniques it has become easier to accurately classify grass species into closely related clades (Catalán et al. 2004; Inda et al. 2014; Lloyd et al. 2007). Twenty additional Festuca, Lolium and Micropyropsis species have been identified as closely related to permitted Festuca and Lolium species by DNA sequence analysis of ITS and trnL-F sequences (Catalán et al. 2004; Charmet et al. 1996; Hand et al. 2010; Inda et al. 2014). Phylogenetic analysis allows species to be verified, and identifies species closely related to the agronomically important species listed above. Regular taxonomic reviews often result in changes to the individual placement of species within a clade, but species generally remain within the same clades.

The taxonomic classifications and names used in this application are those agreed between the Royal Botanic Gardens, Kew and Missouri Botanical Garden, as outlined in the following website: http://www.theplantlist.org/. Where necessary a few of the common synonyms are provided to help assist with literature search.

The wild relatives of perennial ryegrass we seek to release are listed in Table 1. Modern molecular and taxonomic information show that the genus Lolium is derived from an ancestral Festuca pratensis form (Fig. 3). The genus Micropyropsis is similarly derived from Festuca pratensis (Fig. 2).There are nine New Zealand native Festuca species which all fall outside the “broad-leaved” clade (Fig. 3).

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Application Form Approval to release a new organism

Figure 3. Phylogenetic tree of Lolium species (Charmet et al. 1996)

Aim

The aim of this application is to obtain full release of species listed in Table 1 with the exception of L. persicum due to the high risk of weedy behaviour by this species. All these species are classified within clade B in Figure 1. Access to these species is vitally important as these species almost certainly have the potential to increase agricultural production and ensure the future of New Zealand agriculture is protected against current and future abiotic and biotic stresses. These species need to be evaluated in New Zealand conditions to assess their agronomic potential. Recently described Lolium saxatile has been included in this application (Scholz & Scholz 2005). Micropyropsis tuberosa has been shown to be closely related to Festuca and Lolium and has been included (Fig. 1).

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3. Information about the new organism(s)

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

Non-GMOs - Provide a taxonomic description of the new organism(s).

GMOs – Provide a taxonomic description of the host organism(s) and describe the genetic modification.

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

The new organisms comprise species of Festuca, Lolium and Micropyropsis located in the “broad- leaved” clade of the Festuca phylogenetic tree (Fig. 1), and are considered not present in New Zealand (MPI 2016a; 2016b). The following genera and species descriptions were adapted from GRASSBASE (Clayton et al. 2006).

Festuca Festuca (fescues) are a genus of flowering plants belonging to the (grass) family. They are evergreen or herbaceous perennial tufted grasses with a height range of 10–200 cm and they occur on every continent. The genus is closely related to ryegrass (Lolium), and recent evidence from phylogenetic studies, using DNA sequencing, shows that the genus lacks monophyly. As a result, plant taxonomists have moved several species, including Festuca arundinacea (tall fescue) and Festuca pratensis (meadow fescue), from the genus Festuca into the genus Lolium. Because the is complex it is not clear how many true species belong to the genus, but estimates range from over 400 to over 500. Some fescues are used as ornamental and turf grasses and others as pasture and hay for livestock due to it being a highly nutritious stock feed. Fescues are common on golf courses in the United States and United Kingdom, usually beyond the second cut in the rough. Fescue is readily established on bare ground, out-competing other plants and persisting over several years, and so is often used in soil erosion control programs. Tall fescue (F. arundinacea) is good for this purpose, and one cultivar, 'Kentucky 31', was used in land reclamation during the Dust Bowl of the 1930s in the United States. A useful split occurs in Festuca between “broad ” and “fine leaf” clades. The group closest to Lolium is the broad leaf clade, a much younger clade largely restricted to the Eurasian region than the fine leaf clade, which has a cosmopolitan distribution (including New Zealand).

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Lolium Lolium (ryegrasses) are a genus of nine species of tufted grasses in the Poaceae family. They are characterized by bunch-like growth habits. These plants are native to Europe, Asia, northern Africa and the Canary islands, but some species are widely cultivated and naturalised worldwide. Ryegrasses are naturally diploid, with 2n = 14, and are closely related to Festuca. The genus contains some species which are important grasses for both lawns, and as pasture and for grazing and hay for livestock due to its high nutritional value. Ryegrasses are also used in soil erosion control programs. It is the principal grazing grass in New Zealand where some 10 million kilograms of certified seed are produced every year. There are a large range of cultivars. The primary species found worldwide and used for as both lawns and forage are Lolium perenne (perennial ryegrass) and Lolium multiflorum (Italian ryegrass). Like many cool-season grasses of the Poaceae family, it hosts symbiotic fungal endophytes Epichloë or Neotyphodium. Lolium temulentum (already naturalised in New Zealand), can be a weed which can impact on the production of wheat and other crops.

Endophyte The new species are very likely to contain some naturally occurring symbiotic endophytes. These endophytes would be an additional source of genetic resources for New Zealand’s agriculture. MPI will be notified if any new organisms are identified in accordance with the Terms and Conditions for use of the Margot Forde Germplasm Centre Post Clearance Conditions (MPI 2016c).

Taxonomy and biology of the 18 species of interest plus L. persicum

Festuca altaica Trin. ex Ledeb. (Northern Rough fescue). Synonym: Festuca scabrella Torr. ex Hook.  HABIT Perennial; caespitose. Butt sheaths persistent and investing base of culm; with compacted dead sheaths. Culms 60–100 cm long. Lateral branches lacking. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 0.5 mm long. Collar glabrous. Leaf-blades erect; involute; 2.5–4 mm wide; stiff. Leaf- blade surface scabrous; glabrous.  Inflorescence a panicle. Peduncle antrorsely scabrous above. Panicle open; elliptic; dense; 10–15 cm long. Primary panicle branches appressed, or ascending; 1–2 -nate. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 5–7 fertile florets; with diminished florets at the apex. Spikelets oblong; laterally compressed; 10–12 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 5 mm long; 0.75 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 6–7 mm long; 0.9 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume apex acute.  FLORETS Fertile lemma lanceolate; 7–8 mm long; chartaceous; without keel; 5 -veined. Lemma lateral veins distinct. Lemma surface scaberulous. Lemma apex acute; muticous. Palea 1 length of lemma; 2 - veined. Palea keels scabrous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3.5–4.5 mm long.  FRUIT Caryopsis with adherent pericarp. Hilum linear.  Chromosome number 2n = 28 and 56 have been recorded

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 DISTRIBUTION Asia-temperate: Siberia, Soviet Far East, Soviet Middle Asia, China, and Mongolia. North America: Subarctic, western Canada, eastern Canada, northwest USA, north-central USA, and northeast USA.  NOTE This is circumpolar in high latitude regions with climates very different to New Zealand with colder winters. The species is likely to be very winter hardy and dormant. This would be potentially useful for regions with more frequent frost in future.

Festuca altissima All. (wood fescue). Synonym: Festuca sylvatica Vill.  HABIT Perennial; caespitose. Culms erect; 50–120 cm long; 3–4 -noded. Leaf-sheaths without keel; smooth, or scaberulous; glabrous on surface. Ligule an eciliate membrane; 3–5 mm long. Leaf-blades 20– 60 cm long; 4–14 mm wide. Leaf-blade surface smooth, or scaberulous. Leaf-blade margins scaberulous. Leaf-blade apex attenuate.  INFLORESCENCE Inflorescence a panicle. Panicle open; ovate; effuse; nodding; 10–18 cm long; 8–12 cm wide. Primary panicle branches spreading; 2 -nate. Panicle branches smooth, or scaberulous. Spikelets solitary. Fertile spikelets pedicelled. Pedicels 1.5–15 mm long.  FERTILE SPIKELETS Spikelets comprising 2–5 fertile florets; with diminished florets at the apex. Spikelets oblong, or cuneate; laterally compressed; 5–8 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet; thinner than fertile lemma. Lower glume lanceolate; 2–3 mm long; 0.6–0.8 length of upper glume; membranous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 3–4 mm long; 0.7–0.8 length of adjacent fertile lemma; membranous; without keels; 1-veined. Upper glume lateral veins absent. Upper glume apex acute.  FLORETS Fertile lemma lanceolate; 4–6 mm long; chartaceous; without keel; rounded except near apex; 3 -veined. Lemma surface scaberulous. Lemma apex acute; muticous. Palea 1 length of lemma; 2 -veined. Palea keels scaberulous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Lodicules 2; oblong; membranous; 2-toothed. Anthers 3; 2.5–3 mm long. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; hairy at apex. Hilum linear; 0.7–0.8 length of caryopsis.  Chromosome number 2n = 14  DISTRIBUTION Europe: northern, central, southwestern, southeastern, and eastern. Asia-temperate: Siberia, Soviet Middle Asia, Caucasus, and western Asia.

Festuca caerulescens Desf.  HABIT Perennial; caespitose. Butt sheaths thickened and forming a bulb; persistent and investing base of culm; with fibrous dead sheaths. Basal innovations intravaginal. Culms 60–130 cm long. Culm-internodes smooth. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 0.5–1 mm long; truncate, or obtuse. Leaf-blades linear; flat; 4–25 cm long; 1–2 mm wide. Leaf-blade venation comprising 7–11 vascular bundles. Leaf-blade surface ribbed; grooved adaxially; glabrous.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear; loose; 5–10 cm long. Panicle axis pubescent. Panicle branches straight. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–6 fertile florets; with diminished florets at the apex. Spikelets elliptic; laterally compressed; 10–13 mm long; 2–3 mm wide; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 4.5–5.5 mm long; 0.75 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acuminate. Upper glume oblong; 5.5–6.5 mm long; 0.7–0.8 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume apex acuminate.  FLORETS Fertile lemma lanceolate; 6–7 mm long; 2 mm wide; chartaceous; without keel; 5 -veined. Lemma lateral veins prominent. Lemma apex attenuate; mucronate. Palea 2 -veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3. Ovary pubescent on apex.

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 FRUIT Caryopsis with adherent pericarp; hairy at apex. Hilum linear.  Chromosome number 2n = 14  DISTRIBUTION Europe (warmer and drier regions): southwestern and southeastern. Africa: north.

Festuca drymeja Mert. & W.D.J. Koch (including Festuca lasto). Synonyms: Drymochloa drymeja (Mert. & W. D. J. Koch) Holub. and Festuca montana M. Bieb.  HABIT Perennial; caespitose. Cataphylls evident. elongated. Butt sheaths persistent and investing base of culm; with fibrous dead sheaths. Basal innovations extravaginal and intravaginal. Culms erect; 70–130 cm long. Leaf-sheaths open for most of their length; with flat margins. Ligule an eciliate membrane; 1.5–3 mm long; lacerate. Leaf-blades flat; 20–30 cm long; 6–15 mm wide. Leaf-blade venation without layer of subepidermal sclerenchyma masking vein striation. Leaf-blade surface scabrous. Leaf- blade margins scabrous.  INFLORESCENCE Inflorescence a panicle. Panicle open; pyramidal; nodding; 10–30 cm long. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 4–6 fertile florets; with diminished florets at the apex. Spikelets elliptic, or oblong; laterally compressed; 7–8 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; dissimilar; shorter than spikelet. Lower glume lanceolate; 3 mm long; 0.7– 0.8 length of upper glume; scarious; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 3.6–3.9 mm long; 0.7–0.8 length of adjacent fertile lemma; scarious; without keels; 1–3 -veined. Upper glume apex acute.  FLORETS Fertile lemma lanceolate, or ovate; 4.2–5 mm long; chartaceous; keeled; lightly keeled; 5 - veined. Lemma surface scabrous. Lemma apex obtuse, or acute; muticous. Palea 1 length of lemma; 2 - veined. Palea keels scaberulous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; hairy at apex. Hilum linear; 0.5 length of caryopsis.  Chromosome number 2n = 14  DISTRIBUTION Europe (hot summer and cold winter regions): central, southeastern, and eastern. Africa: north. Asia-temperate: Caucasus and western Asia.

Festuca durandoi Clauson Synonym: Festuca spadicea subsp. durandoi (Clauson) Jahand. & Maire  HABIT Perennial; caespitose. Butt sheaths thickened and forming a bulb. Basal innovations intravaginal. Culms 50–110 cm long. Culm-internodes smooth. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 0.4–4.6 mm long; bilobed. Leaf-blades filiform; convolute; 10–45 cm long; 0.4–1 mm wide. Leaf-blade venation without layer of subepidermal sclerenchyma masking vein striation. Leaf-blade surface glabrous. Leaf-blade margins smooth.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear, or oblong; dense; 8–20 cm long. Panicle axis smooth. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–5 fertile florets; with diminished florets at the apex. Spikelets lanceolate; laterally compressed; 7.5–10 mm long; 3.5–5.5 mm wide; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 3.5–5.1 mm long; 0.7–0.9 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume oblong; 5–6 mm long; 0.7–0.8 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume apex acute.  FLORETS Fertile lemma lanceolate; 6–7.5 mm long; chartaceous; without keel; 5 -veined. Lemma surface scaberulous. Lemma apex acute, or acuminate. Palea 2 -veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 2.5–4 mm long. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; glabrous. Hilum linear.  Chromosome number 2n = 28  DISTRIBUTION Europe: southwestern.

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Festuca fontqueri St.-Yves Synonym: Festuca yvesii Litard.  HABIT Perennial; caespitose; clumped loosely. Stolons present. Basal innovations extravaginal and intravaginal. Culms erect, or geniculately ascending; slender; 20–40 cm long; 2–3 -noded; with 0.25–0.33 of their length below uppermost node. Culm-internodes striate; smooth; distally glabrous. Culm-nodes black. Leaf-sheaths tubular for much of their length; with 0.75–1 of their length closed; without keel; striately veined; smooth; glabrous on surface to pubescent. Ligule an eciliate membrane; 1 mm long; erose; truncate. Leaf-blades flat, or conduplicate; 5–10 cm long; 1.5–2.5 mm wide. Leaf-blade midrib conspicuous. Leaf-blade venation with 10–16 secondary veins; 3 subepidermal sclerenchyma strands (midrib & margins). Leaf-blade surface ribbed; glabrous, or pubescent; hairy adaxially. Leaf-blade margins scabrous. Leaf-blade apex abruptly acute, or acute.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear, or lanceolate; 3–8 cm long. Primary panicle branches 1–2 -nate; 1.5–4 cm long; bearing 2–4 fertile spikelets on each lower branch. Panicle branches scaberulous. Spikelets solitary. Fertile spikelets pedicelled. Pedicels tip rectangular.  FERTILE SPIKELETS Spikelets comprising 3–7 fertile florets; with diminished florets at the apex. Spikelets lanceolate, or elliptic; laterally compressed; 7 mm long; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes 0.6–0.7 mm long; scaberulous.  GLUMES Glumes persistent; dissimilar; shorter than spikelet. Lower glume linear; 3–3.5 mm long; 0.75 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume surface smooth, or asperulous. Lower glume apex acute. Upper glume lanceolate; 4–4.5 mm long; 0.75–0.9 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume surface smooth, or asperulous. Upper glume apex acute.  FLORETS Fertile lemma lanceolate; 5 mm long; 1.5–2 mm wide; chartaceous; without keel; 5 -veined. Lemma surface scaberulous; rough above. Lemma apex dentate; 2 -fid; awned; 1 -awned. Principal lemma awn from a sinus; 2 mm long overall. Palea 1 length of lemma; 2 -veined. Palea keels scabrous. Palea apex dentate; 2 -fid. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3 mm long. Ovary glabrous.  FRUIT Caryopsis with adherent pericarp; sulcate on hilar side; glabrous. Hilum linear; 0.66 length of caryopsis.  DISTRIBUTION Africa: north.

Festuca kingii (S. Watson) Cassidy (spike fescue), Synonyms: Hesperochloa kingii (S. Watson) Rydb, Leucopoa kingii (S. Watson) W. A. Weber and Poa kingii S. Watson  HABIT Perennial; caespitose; clumped densely. Butt sheaths persistent and investing base of culm; with compacted dead sheaths. Culms erect; 30–60 cm long. Culm-internodes smooth, or scaberulous. Lateral branches lacking. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 0.5–2 mm long; pubescent on abaxial surface; erose. Leaf-blades erect; flat, or involute; 3–6 mm wide; stiff; glaucous. Leaf-blade surface glabrous.  INFLORESCENCE Dioecious. Inflorescence a panicle. Panicle contracted; lanceolate; 10–20 cm long. Primary panicle branches appressed; bearing spikelets almost to the base. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–5 fertile florets; with diminished florets at the apex. Spikelets ovate; laterally compressed; 10–12 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 4–6.5 mm long; 0.66– 1 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 4–6.5 mm long; 0.75–0.9 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume apex acute.  FLORETS Fertile florets female. Fertile lemma ovate; 6–7 mm long; chartaceous; keeled; lightly keeled; 5 -veined. Lemma lateral veins obscure. Lemma surface scaberulous. Lemma apex acuminate; muticous. Palea 1 length of lemma; 2 -veined. Palea keels scabrous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3 mm long.  FRUIT Caryopsis with adherent pericarp. Hilum linear.

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 MALE Male inflorescence similar to female. Male spikelets resembling female.  Chromosome number 2n = 56  DISTRIBUTION North America: northwest USA, north-central USA, and southwest USA.

Festuca mairei St.-Yves (atlassvingel – Swedish)  HABIT Perennial; caespitose; clumped densely. Butt sheaths persistent and investing base of culm; with compacted dead sheaths. Basal innovations intravaginal. Culms 50–100 cm long. Lateral branches lacking. Leaf-sheaths smooth; glabrous on surface. Ligule a ciliolate membrane; 2 mm long; lacerate; truncate. Leaf-blades flat, or involute; 30–50 cm long; 3–5 mm wide. Leaf-blade midrib conspicuous. Leaf- blade venation with 7–9 secondary veins; without layer of subepidermal sclerenchyma masking vein striation. Leaf-blade surface scabrous; rough adaxially; glabrous. Leaf-blade margins scabrous. Leaf-blade apex attenuate.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear; 15–20 cm long. Primary panicle branches 1–2-nate; bearing spikelets almost to the base. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 4–5 fertile florets; with diminished florets at the apex. Spikelets elliptic; laterally compressed; 8 mm long; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes 0.8 mm long; smooth.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 4–4.5 mm long; 1 length of upper glume; scarious; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume surface asperulous; rough above. Lower glume apex acute. Upper glume lanceolate; 4–4.5 mm long; 0.7– 0.8 length of adjacent fertile lemma; scarious; without keels; 3 -veined. Upper glume surface asperulous; rough at apex. Upper glume apex obtuse.  FLORETS Fertile lemma lanceolate; 5.5–6 mm long; chartaceous; keeled; lightly keeled; 5 -veined. Lemma surface asperulous. Lemma apex acute; muticous, or mucronate. Palea 2 -veined. Palea keels scabrous. Palea surface scaberulous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3 mm long. Ovary glabrous.  FRUIT Caryopsis with adherent pericarp; oblong; sulcate on hilar side. Hilum linear; 0.5 length of caryopsis.  Chromosome number 2n = 28  DISTRIBUTION Africa: north.

Festuca paniculata (L.) Schinz & Thell. Synonyms: Festuca baetica (Hack.) Hack. ex Asch. & Graebn., and Festuca spadicea L. )  HABIT Perennial; caespitose. Butt sheaths thickened and forming a bulb; persistent and investing base of culm; with fibrous dead sheaths. Basal innovations intravaginal. Culms 60–120 cm long. Culm-internodes smooth. heterophyllous being wider on the culm. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 0.5–2.5 mm long; bilobed. Leaf-blades filiform; convolute; 14–82 cm long; 0.5–1 mm wide. Leaf-blade venation with continuous uniform subepidermal sclerenchyma layer on the underside. Leaf-blade surface scabrous; rough adaxially, or on both sides; glabrous. Leaf-blade margins smooth.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear, or oblong; dense; 8–20 cm long. Panicle axis smooth. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–5 fertile florets; with diminished florets at the apex. Spikelets obovate; laterally compressed; 7–11 mm long; 4–5 mm wide; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 4.5–6 mm long; 0.8– 0.9 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume primary vein smooth, or scaberulous. Lower glume lateral veins absent. Lower glume apex acute, or acuminate. Upper glume oblong; 5–7.5 mm long; 0.7–0.9 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume primary vein smooth, or scaberulous. Upper glume apex acute, or acuminate.  FLORETS Fertile lemma lanceolate; 7–8.5 mm long; chartaceous; without keel; 5 -veined. Lemma midvein scaberulous. Lemma apex acute, or acuminate. Palea 2 -veined. Apical sterile florets resembling fertile though underdeveloped.

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 FLOWER Anthers 3; 2.5–3.5 mm long. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; glabrous. Hilum linear.  Chromosome number 2n = 14, 28  DISTRIBUTION Europe: central, southwestern, and southeastern. Africa: north.

Festuca pseudeskia Boiss  HABIT Perennial; caespitose; clumped densely. Cataphylls evident. Rhizomes short. Butt sheaths purple. Basal innovations extravaginal. Culms 20–40 cm long. Leaf-sheaths open for most of their length; glabrous on surface. Ligule an eciliate membrane; 2–3 mm long; lacerate; truncate. Leaf-blades aciculate; conduplicate; angular in section; 1–2 mm wide; firm; glaucous. Leaf-blade venation comprising 9–15 vascular bundles; with 7 inner ridges; with sclerenchyma strands below veins and above all veins. Leaf- blade surface smooth; glabrous. Leaf-blade apex pungent.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear, or oblong. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets with diminished florets at the apex. Spikelets oblong; laterally compressed; 5–8 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume ovate; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex obtuse. Upper glume ovate; chartaceous; without keels; 3 -veined. Upper glume apex obtuse.  FLORETS Fertile lemma ovate; 3.5–3.9 mm long; chartaceous; without keel; 3 -veined. Lemma lateral veins obscure. Lemma apex acute; muticous. Palea 2 -veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3.  FRUIT Caryopsis with adherent pericarp; obovoid. Hilum linear; 1 length of caryopsis. Disseminule comprising a caryopsis.  DISTRIBUTION Europe: southwestern.

Festuca pulchella Schrad  HABIT Perennial; caespitose; clumped loosely. Rhizomes short. Basal innovations extravaginal. Culms 25–55 cm long. Leaf-sheaths tubular for much of their length; with 0.5–0.75 of their length closed; glabrous on surface. Ligule absent. Leaf-blades flat, or convolute; 2–5 mm wide. Leaf-blade venation with sclerenchyma strands below veins and above all veins; subepidermal sclerenchyma attached to veins above and below (primary veins only).  INFLORESCENCE Inflorescence a panicle. Panicle open; ovate; bearing few spikelets. Primary panicle branches spreading. Panicle branches flexuous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets with diminished florets at the apex. Spikelets oblong; laterally compressed; 7–8 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 4.6–4.9 mm long; 0.8–0.9 length of adjacent fertile lemma; chartaceous; without keels; 3-veined. Upper glume apex acuminate.  FLORETS Fertile lemma oblong; 5.8–6 mm long; chartaceous; without keel; 5 -veined. Lemma surface scabrous. Lemma apex acute; muticous. Palea 2-veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3. Ovary glabrous.  FRUIT Caryopsis with adherent pericarp; obovoid. Hilum linear. Disseminule comprising a caryopsis.  DISTRIBUTION Europe: central, southwestern, and southeastern.

Festuca scariosa (Lag.) Pau Synonym: Festuca granatensis Boiss.  HABIT Perennial; caespitose. Basal innovations extravaginal and intravaginal. Culms erect; 60–110 cm long; 3–4 -noded; with 0.5–0.66 of their length below uppermost node. Lateral branches lacking. Leaf- sheaths open for most of their length; with 0.05 of their length closed; smooth; glabrous on surface. Ligule an eciliate membrane; 4–6 mm long; lacerate; acute. Leaf-blades conduplicate; 30–50 cm long; 1–1.2 mm

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wide; stiff. Leaf-blade venation with 13–17 secondary veins; without layer of subepidermal sclerenchyma masking vein striation, or with continuous uniform subepidermal sclerenchyma layer on the underside. Leaf-blade surface scabrous; rough adaxially; glabrous. Leaf-blade apex attenuate.  INFLORESCENCE Inflorescence a panicle. Panicle open; linear; interrupted; 15–50 cm long; 1–2 cm wide. Primary panicle branches appressed, or ascending; 2–3 -nate; bearing spikelets almost to the base. Panicle axis smooth. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–6 fertile florets; with diminished florets at the apex. Spikelets elliptic; laterally compressed; 5 mm long; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes scaberulous.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 2.5–3.5 mm long; 0.8–0.9 length of upper glume; scarious; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; 3–4 mm long; 0.7–0.8 length of adjacent fertile lemma; scarious; without keels; 1 -veined. Upper glume lateral veins absent. Upper glume apex acuminate.  FLORETS Fertile lemma oblong; 3.5–4 mm long; scarious; without keel; 5 -veined. Lemma surface scaberulous. Lemma apex entire, or dentate; 3-fid; obtuse; muticous, or mucronate. Palea 2 -veined. Palea keels scabrous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 2 mm long. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; obovoid; 2 mm long; hairy at apex. Hilum linear; 0.4–0.5 length of caryopsis.  Chromosome number 2n = 14  DISTRIBUTION Europe: southwestern. Africa: north.

Festuca spectabilis Jan  HABIT Perennial; caespitose. Butt sheaths distinctly ribbed; persistent and investing base of culm; with compacted dead sheaths. Basal innovations extravaginal. Culms 80–100 cm long. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane. Leaf-blades flat, or conduplicate; 1–3 mm wide; glaucous. Leaf- blade venation with sclerenchyma strands below veins and above all veins; subepidermal sclerenchyma attached to veins above and below. Leaf-blade surface ribbed; scabrous; rough adaxially.  INFLORESCENCE Inflorescence a panicle. Panicle open; ovate; nodding; 9–30 cm long. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets with diminished florets at the apex. Spikelets oblong; laterally compressed; 7–10 mm long; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume lanceolate; chartaceous; without keels; 3 -veined. Upper glume apex acute.  FLORETS Fertile lemma oblong; 5.8–7.6 mm long; chartaceous; without keel; 5 -veined. Lemma lateral veins prominent. Lemma surface scabrous. Lemma apex acuminate; muticous. Palea 2 -veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; obovoid. Hilum linear. Disseminule comprising a caryopsis.  Chromosome number 2n = 28  DISTRIBUTION Europe: southeastern.

Festuca subulata Trin. (bearded fescue)  HABIT Perennial; caespitose. Culms erect; 50–100 cm long. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane. Leaf-blades 10–25 cm long; 3–10 mm wide; flaccid.  INFLORESCENCE Inflorescence a panicle. Panicle open; ovate; effuse; nodding; 15–40 cm long. Primary panicle branches spreading, or reflexed; 2–3 -nate; 5–15 cm long. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 2–5 fertile florets; with diminished florets at the apex. Spikelets oblong, or cuneate; laterally compressed; 7–10 mm long; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes eventually visible between lemmas.

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Application Form Approval to release a new organism

 GLUMES Glumes persistent; similar; shorter than spikelet; thinner than fertile lemma. Lower glume lanceolate; 3 mm long; 0.6 length of upper glume; membranous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acuminate. Upper glume lanceolate; 5 mm long; 0.9–1 length of adjacent fertile lemma; membranous; without keels; 1 -veined. Upper glume lateral veins absent. Upper glume apex acuminate.  FLORETS Fertile lemma lanceolate; 5–6 mm long; chartaceous; without keel; rounded except near apex; 5 -veined. Lemma surface scaberulous; rough above. Lemma apex attenuate; awned; 1 -awned. Principal lemma awn 5–20 mm long overall. Palea 1 length of lemma; 2 -veined. Palea keels scaberulous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Lodicules 2; membranous. Anthers 3. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; hairy at apex. Hilum linear.  Chromosome number 2n = 28  DISTRIBUTION North America: Subarctic, western Canada, northwest USA, southwest USA, and Mexico. South America: southern South America.

Festuca triflora Desf. Synonym: Festuca patula Desf.  HABIT Perennial; caespitose. Butt sheaths thickened and forming a bulb. Basal innovations intravaginal. Culms 60–130 cm long. Culm-internodes smooth. Leaf-sheaths glabrous on surface. Ligule an eciliate membrane; 1.5–4.6 mm long; truncate, or obtuse. Leaf-blades linear; flat; 8–41 cm long; 2–7 mm wide. Leaf-blade venation comprising 12–26 vascular bundles. Leaf-blade surface scabrous; glabrous. Leaf- blade margins scabrous.  INFLORESCENCE Inflorescence a panicle. Panicle open; elliptic, or ovate; loose; 10–30 cm long. Panicle axis smooth. Panicle branches scabrous. Spikelets solitary. Fertile spikelets pedicelled.  FERTILE SPIKELETS Spikelets comprising 3–6 fertile florets; with diminished florets at the apex. Spikelets elliptic; laterally compressed; 10–13 mm long; 2–3 mm wide; breaking up at maturity; disarticulating below each fertile floret.  GLUMES Glumes persistent; similar; shorter than spikelet. Lower glume lanceolate; 4.5–5.5 mm long; 0.75 length of upper glume; chartaceous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acuminate. Upper glume oblong; 5.5–6.5 mm long; 0.7–0.8 length of adjacent fertile lemma; chartaceous; without keels; 3 -veined. Upper glume apex acuminate.  FLORETS Fertile lemma lanceolate; 7.5–8.5 mm long; chartaceous; without keel; 5 -veined. Lemma surface scabrous. Lemma apex attenuate. Palea 2-veined. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3.5–4 mm long. Ovary pubescent on apex.  FRUIT Caryopsis with adherent pericarp; hairy at apex. Hilum linear.  Chromosome number 2n = 14  DISTRIBUTION Europe: southwestern. Africa: north.

Lolium canariense Steud. Synonym: Lolium edwardii H.Scholz, Stierst. & Gaisberg

 HABIT Annual. Culms erect, or geniculately ascending; 30–67 cm long; 3–4 -noded. Culm-internodes smooth, or scaberulous; distally glabrous. Leaf-sheaths loose; glabrous on surface. Leaf-sheath auricles falcate; 0.5–2.5 mm long. Ligule an eciliate membrane; 1–2 mm long; truncate, or obtuse. Leaf-blades 5– 21 cm long; 1.5–5 mm wide. Leaf-blade surface smooth, or scaberulous; rough adaxially. Leaf-blade apex attenuate.  INFLORESCENCE Inflorescence composed of racemes. Peduncle smooth, or scaberulous above. Racemes 1; single; bilateral; 10–20 cm long; bearing 7–15 fertile spikelets on each. Rhachis semiterete; 0.8–1.1 mm wide. Spikelet packing adaxial; regular; 2 -rowed. Spikelets appressed; solitary. Fertile spikelets sessile.  FERTILE SPIKELETS Spikelets comprising 5–9 fertile florets; with diminished florets at the apex. Spikelets oblong; laterally compressed; 6–24 mm long; 1–4 mm wide; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes 0.8–4 mm long (0.25–0.33 length of lemma).

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Application Form Approval to release a new organism

 GLUMES Glumes one the lower absent or obscure; persistent; reaching apex of florets, or exceeding apex of florets; similar to fertile lemma in texture. Upper glume lanceolate; 3–28 mm long; 1 length of spikelet; coriaceous; without keels; 5–7 -veined. Upper glume surface smooth, or asperulous. Upper glume apex entire, or erose; obtuse, or acute.  FLORETS Fertile lemma lanceolate; 3–10 mm long; 0.7–1.5 mm wide; coriaceous; much thinner above; without keel; 1–5 -veined. Lemma surface glabrous, or puberulous. Lemma apex erose; obtuse; awned; 1 -awned. Principal lemma awn subapical; flexuous; 2.5–15 mm long overall. Palea 1 length of lemma. Palea keels scaberulous. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Lodicules 2; 0.8–1.1 mm long; membranous. Anthers 3; 1.3–2.9 mm long. Ovary glabrous.  FRUIT Caryopsis with adherent pericarp; ellipsoid; 3.5–4.5 mm long. Hilum linear.  DISTRIBUTION Africa: Macaronesia.

Lolium persicum Boiss. & Hohen. (Persian ryegrass) This species was initially included in the application but after consultation with AgResearch’s weed scientists and assessment of its weedy behaviour in North America was withdrawn in the new application.

Lolium saxatile H. Scholz & S. Scholz Scholz and Scholz (2005) have published a description of this new species.

Micropyropsis tuberosa Romero Zarco and Cabezudo. Note: Endangered species with population in decline suggesting no weedy behaviour. Margot Forde Germplasm Centre has an agreement with Spain to be a duplicate seed repository of this rare plant.  HABIT Perennial. Culms 30–100 cm long; swollen at the base; forming an ovoid corm, or moniliform corms. Ligule an eciliate membrane. Leaf-blades 10–25 cm long; 2–3 mm wide.  INFLORESCENCE Inflorescence composed of racemes. Racemes 1; single; bilateral; 10–30 cm long; bearing 6–17 fertile spikelets on each. Rhachis semiterete. Spikelet packing broadside to rhachis; distant. Spikelets appressed; solitary. Fertile spikelets pedicelled. Pedicels oblong; 0.5 mm long.  FERTILE SPIKELETS Spikelets comprising 3–13 fertile florets; with diminished florets at the apex. Spikelets oblong; laterally compressed; 10–26 mm long; breaking up at maturity; disarticulating below each fertile floret. Rhachilla internodes 1.5–2 mm long; eventually visible between lemmas.  GLUMES Glumes persistent; similar; shorter than spikelet; thinner than fertile lemma. Lower glume elliptic; 3.5–5 mm long; 0.7 length of upper glume; membranous; without keels; 1 -veined. Lower glume lateral veins absent. Lower glume apex acute. Upper glume elliptic; 5–7 mm long; 1 length of adjacent fertile lemma; membranous; without keels; 3 -veined. Upper glume apex acute.  FLORETS Fertile lemma elliptic; 5–7 mm long; chartaceous; without keel; 5 -veined. Lemma apex acute; awned; 1 -awned. Principal lemma awn subapical; 2–6 mm long overall. Palea 1 length of lemma; 2 - veined. Palea keels ciliolate. Apical sterile florets resembling fertile though underdeveloped.  FLOWER Anthers 3; 3 mm long. Ovary glabrous.  FRUIT Caryopsis with adherent pericarp; ellipsoid; 4 mm long.  DISTRIBUTION Europe: southwestern.

Biology and main features of new organism The new organisms are forage grasses of the Lolium, Festuca and Micropyropsis genera. These species have great potential as new species for forage cultivar development through traditional plant breeding programmes (Cai et al. 2011; Yamada 2011). Unrestricted access to this material from the germplasm centre will be beneficial to public good and applied sciences across a wide range of disciplines. The biology of each species has been outlined above.

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Affinities of new organism with other organisms in New Zealand The species described above are closely related to agronomically valuable pasture species (Catalán et al. 2004). The new organisms are likely to have an affinity for interspecific hybridisation with species that are present in New Zealand and are utilised extensively for their production value (e.g. L. perenne, F. arundinacea and F. pratensis), allowing hybrid breeding programmes to develop and progress. There are nine endemic Festuca species in New Zealand, all in the “fine-leaf” clade (Fig. 1 red box; Fig. 2) (Edgar & Connor 2010; NZPCN 2016). Seven of these species are tussock grasses occurring on off- shore islands, or mainland alpine or coastal cliff environments which are not used in agriculture in New Zealand (Edgar & Connor 2010; NZPCN 2016). One of the remaining species, Festuca deflexa, is cleistogamous and does not cross pollinate with other plants of any species (Edgar & Connor 2010; NZPCN 2016). The other, Festuca multinodis, is generally found in marginal environments, such as cliffs, bluffs and mountainsides (Edgar & Connor 2010; NZPCN 2016). Regardless, all New Zealand native species are distantly related to the broad leaved species subject to this application (Fig.1 blue box; Fig. 2). It is therefore highly unlikely that the new organisms and native New Zealand Festuca species would hybridise naturally. We found no literature to support hybridisation of New Zealand native fescues with exotic Festuca species.

Undesirable self-sustaining populations It is likely that new organisms will be largely unimproved and adapted to their natural climates and environments, rather than New Zealand climates and environments. Therefore it is unlikely that they would form undesirable self-sustaining populations. Once the species have been improved by selection for growth and production in New Zealand conditions, it is anticipated that the new varieties could form self-sustaining populations. These populations would be desirable as they will be in target agricultural environments.

Eradication These genera are from Tribe Poeae, of Family Poaceae. No species from this tribe are listed by the National Pest Plant Accord as a significant pest plant (MPI 2016b). As some other species of Festuca and Lolium are considered as weeds, general practices used to control and eradicate permitted Festuca and Lolium species would be suitable methods for eradication of the new organisms, if necessary.

3.2. Regulatory status of the organism

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

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

☐ Yes ☒ No

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

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☐ Yes ☒ No

4. Māori engagement

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

A Māori reference group (MRG) was set up to discuss the proposal and identify concerns and benefits to Māori from the proposal to release new grass species in this application. A whole day meeting was held on 9 May 2016 at the Grasslands Research Centre, AgResearch, Palmerston North. People present at the meeting were Dr Kioumars Ghamkhar (Director, Margot Forde Germplasm Centre), Zane Webber (Senior Technician, Margot Forde Germplasm Centre), Julian Jackson (Senior Advisor, Kaupapa Kura Taiao - Māori policy and operations, EPA) and the members of the MRG: Bill Blake (Kaumatua from Te Herenga network), Dr Nick Roskruge (Institute of Agriculture and Environment, Massey University), Dr Amanda Black (Bio-Protection Research Centre, Lincoln University), Hoani Ponga (Te Tumu Paeroa). Discussions were around four key areas of concern:

 Economic, social and cultural well-being of Māori;

 Working with Māori to develop relationships and opportunities;

 Observing tikanga Māori, and;

 Communicating the proposal to Māori.

The MRG was given two weeks to report to the EPA regarding their view of the proposal as a guide for the applicant regarding how to proceed with Māori engagement during the application process and afterwards, if an approval to release the grass species is obtained (Appendix 1). In response to this report, the applicant has prepared a document to address the recommendations, concerns and list the benefits to Māori (Appendix 2). In summary, these are the highlights of the response to the MRG report:

 AgResearch will be working with Māori to develop relationships and opportunities for introducing new germplasm including the 18 new grass species.

 AgResearch has communicated the proposal to Māori before submission to EPA by approaching two Māori entities.

o The first entity was Ngati Pahauwera Commercial Development Ltd (NPCD). The applicant presented a case for this application and in attendance in AgResearch’s Grasslands campus were NPCD’s Chair Lu McDonnell, – Chief Operating Officer, Luke Hansen and Project Manager, Bonny Hatami. The visitors also were given a tour of MFGC and other hybrid products developed from wild relatives of white clover.

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The visitors verbally supported the application and assured the applicant of formal support after the public notification.

o The second entity was Ngai Tahu Farming Ltd. AgResearch’s Māori Agribusiness staff briefly discussed the application with Craig Osborne and Shane Kelly and the applicant sent a summary of the application (Appendix 3) to these individuals who represent the Ngai Tahu Farming Ltd and asked for their feedback. While verbal agreement, in principle, has been obtained, no formal feedback has been received yet.

 Communication to Māori will continue during the submissions period, once the application is publically notified and, if the application is approved, after a public hearing.

 During the application process, AgResearch’s MFGC Director and Māori Agribusiness Portfolio leader will be in close communication to engage and inform Māori of the benefits of this application and address their potential concerns about the proposal.

 AgResearch has listed potential economic, social, and cultural wellbeing benefits of this proposal for Māori and will communicate this with them. AgResearch will also work with Māori to realise some of these benefits where feasible.

 AgResearch acknowledges the potential issues that may arise from the release of the new grass species and will diligently observe and monitor the import, research and growing of these species and their new hybrids to mitigate any potential issues and risks.

Consultation with the EPA’s National Māori network Te Herenga1

A summary of the application was also circulated to Te Herenga (Appendix 3). We have not heard any comments or feedback yet by the time the application was submitted.

5. Risks, costs and benefits

Provide information of the risks, costs and benefits of the new organism(s).

These are the positive and adverse effects referred to in the HSNO Act (Act, H.S.N.O. 1996). It is easier to regard risks and costs as being adverse (or negative) and benefits as being positive. In considering risks, cost and benefits, it is important to look at both the likelihood of occurrence (probability) and the potential magnitude of the consequences, and to look at distribution effects (who bears the costs, benefits and risks).

1 Te Herenga is made up of Māori resource and environmental managers, practitioners, or experts who represent their iwi, hapū, or Māori organisation on matters of relevance to the activities and decision making of the EPA.

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Consider the adverse or positive effects in the context of this application on the environment (e.g. could the organism cause any significant displacement of any native species within its natural habitat, cause any significant deterioration of natural habitats or cause significant adverse effect to New Zealand’s inherent genetic diversity, or is the organism likely to cause disease, be parasitic, or become a vector for animal or plant disease?), human health and safety, the relationship of Māori to the environment, the principles of the Treaty of Waitangi, society and the community, the market economy and New Zealand’s international obligations.

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

Beneficial or positive effects

The considerable challenges that current researchers face in acquiring and effectively evaluating novel genetic material cannot be understated (Lancashire 2006). In the past, researchers had full access to novel germplasm, however, the lack of control led to some very serious environmental weed problems such as wilding tree species (introduced for timber and erosion control) and gorse (introduced as a hedge plant). While sustainable farming and better management of the currently used forage species is one of the approaches to keeping New Zealand’s agricultural sector internationally competitive, the ability of researchers to have access to important new genetic resources for plant breeding and research is essential for adaptation to climate change and still having a competitive edge in a global market.

New Zealand’s “clean green” international image is threatened by the scale and level of nitrogen leaching. Also, NIWA predicts that by 2050, New Zealand’s East coast will receive up to 15% less rainfall specifically in the North Island. The mono-culture of ryegrass or bi-culture of ryegrass-white clover may well suit many agricultural regions of New Zealand but it has been prescribed to extended areas outside its comfort zone. This has resulted in more nitrogen and phosphorus fertiliser input and less production. Roots in ryegrass are not deep enough to access water in lower layers of soil in drier regions.

Access to new germplasm will give the researchers in New Zealand the opportunity to exploit the wild relatives of perennial ryegrass for traits of economic value as well as adaptation to harsher environments. For example, later flowering is a desirable trait for drier areas as an early end to the rain season negatively affects late flowering and high biomass producing species (Richards 1996). Incorporating the wild alleles may be of vital value in maintaining and adapting the viability of ryegrasses in an uncertain climatic future. Root depth and structure varies among different species and the wild relatives of many agronomic crops and forages have deeper and/or thicker roots leading to persistence and/or drought tolerance. This has been observed in the wild relatives of white clover (Nichols 2012) and wheat (Yao et al. 2005).

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Drought tolerance is a trait that can be improved by incorporating the genome of the relatives of perennial ryegrass into the species. This is already proven by crossing Festuca and Lolium species and creating Festulolium interspecific hybrids with increased drought tolerance (De Keyser et al. 2012). Another potentially very useful trait for a drier and warmer East coast is heat tolerance. Interspecific hybrids between ryegrass and its wild relatives may result in increased heat tolerance partially due to incorporation of thicker leaves into ryegrass germplasm and reducing transpiration and/or evaporation. Increased heat tolerance after interspecific hybridisation has been observed in turf grasses before (Goldman & Sims 2005), which are close relatives of forage grasses. There are also suggestions in the literature regarding the effect of interspecific hybridisation on the improvement of disease resistance in grasses (Belanger et al. 2004) including wheat (Friebe et al. 1993; Person- Dedryver et al. 1990). Nutrient use efficiency can also potentially be improved by hybridisation of perennial ryegrass with its wild relatives. In the literature, phosphorus use efficiency in clover hybrids (Nichols & Crush 2014), winter hardiness and increased crude protein in ryegrass hybrids (Jones & Humphreys 1993; Xiong et al. 2007; Xiong et al. 2006; Zwierzykowski et al. 1998) nitrogen, phosphorus and potassium uptake in sugarcane and its sister genera (intergeneric crosses) have been shown. All these new traits will help in reducing farm input, be it water, nitrogen, micronutrients or other fertilisers and even the need for spraying farms with antifungal, insecticide or herbicide agents. The latter being specifically true as the new traits may strengthen these hybrids for more competition with problematic pasture weeds such as ragwort (Jacobaea vulgaris), Nodding thistle (Carduus nutans), buttercups ((Ranunculus acreis, R. sardous, R. repens) and Dandelion (Taraxaxum officinale) among the broadleaf weeds and also C4 grass weeds such as summer grass (Digitaria sanguinalis) and yellow bristle grass (Setaria pumila) (Trevor James, AgResearch weed scientist, Pers. Comm.).

Livestock farming, New Zealand’s main economic drive, is leaving a considerable amount of environmental footprint through methane nitrous oxide emissions. The New Zealand government has very recently (5 Oct. 2016) signed the Paris Agreement on Climate Change, which requires the government to act on reducing New Zealand’s environmental footprint. Currently, perennial ryegrass is the main forage species used in livestock farming in New Zealand. Although the methane mitigation from rumen when the livestock are fed by perennial ryegrass (methanogenic potential of perennial ryegrass) is not extremely high (Banik et al. 2013), diversity for this trait between species is well recognised in the literature (Banik et al. 2013; Bodas et al. 2008; García-González et al. 2008; Meale et al. 2012) . Access to the wild relatives of perennial ryegrass will also allow researchers to screen these species for their methanogenic potential from rumen for future emissions reduction of different scenarios of ryegrass × wild relative crosses to prepare New Zealand for an even cleaner and greener agricultural practice. Being able to screen these options for less methane emission from the ruminants’ gut is extremely important as the New Zealand government has committed itself to reducing the environmental footprint of farming practice in the country. Initiatives such as Global Research Alliance for pilot studies that address mitigation of emissions from livestock is an example of this. The Global Research Alliance was established in 2009 and aims to find ways to grow more food without

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Application Form Approval to release a new organism increasing greenhouse gas emissions. Perennial ryegrass in its current form produces 36 mL/g DM of methane compared to 27-31 in subterranean clover and 11 in Biserrula pelecinus (a species not permitted in New Zealand) (Banik et al. 2013). Considering the possibility of candidate metabolite discovery for this trait in biserrula (Ghamkhar et al. 2016), research on this species in New Zealand will potentially bring New Zealand in the forefront of methane mitigated agriculture.

The vast majority of commercial cultivars of perennial ryegrass have been bred from a narrow basis of germplasm originating from UK and Spain. Within that 3 sources dominate in New Zealand: a few older ecotypes from the original UK commercial introductions in the 1800s, a single paddock at Mangere and 2 accessions from NW Spain (Stewart 2006). This suggests that the widely used perennial ryegrass used today is not as diverse as it should be and this may leave NZ agriculture more vulnerable to ecological disasters such as new disease and pest incursions and also to climate change. It will be important in the longer term that New Zealand diversifies this basis. The main benefit of having research access to the new organisms would be the development of new forage cultivars. New forage cultivars would result in higher yields leading to increased production on farm, improved or novel quality traits with animal and human health benefits, pest and disease resistances, and climate and environmental tolerances. Pests and diseases cost the country an enormous amount (Giera & Bell 2009), as do extreme weather conditions such as drought, flooding or cold. The 2013 drought was widely reported to cost the economy between one and two billion dollars (Bill English, various media reports). New species and varieties, which have better nutrient efficiency, could result in lower fertiliser applications, and a reduction in the issues associated with fertiliser application. The economic increase associated with development of new varieties would provide employment opportunities throughout the agricultural industry. New varieties could increase New Zealand’s significant share of the global seed market (Sanderson et al. 2012), further enhancing New Zealand’s economy.

Adverse effects including risks and costs

Any new organism is potentially a weed. More specifically, all domesticated forage grasses have weed status outside of the pastoral environment (Randall 2012). The cost of weed eradication is high and difficult to measure. However, while importing new organisms is a potential risk, it is also an opportunity. Only very aggressive weeds should not be allowed in the country as the risks and costs of these species are high, although Department of Conservation even considers tall fescue (Festuca arundinacea) an important weed, despite its agricultural value and benefits (Williams & Timmins 1990). In this proposal we have removed L. persicum from the original application exactly for this reason and also the fact that it has herbicide resistance and is a prolific seed producer. This, however, does not guarantee the other species listed in this proposal present no risk as weeds in future. However, for the rest of the species in this list, a few points must be considered:

1. These species will be used to cross and backcross with perennial ryegrass and this will dilute their undesirable traits, including their environmental weed status or their propensity to become weeds, in a controlled manner (see the diagram below for an example of backcrossing for a dominant trait).

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2. A slight potential of weedy traits are necessary for any agricultural crop or forage species to be able to compete in the new environment and be economically viable. Examples of these weedy traits that also make grasses better forage species include aggressive tiller or shoot production, ability to colonise new sites, adaptability, and fast growth rate.

3. For an informed evaluation of the traits of interest, these grasses and their hybrids with perennial ryegrass must be grown and screened in the field under real pasture conditions as results obtained and observed in the glasshouse or in field test-controlled trials mostly do not translate to actual pasture environments, specifically for abiotic traits such as drought tolerance and persistence traits in general and that is why the majority of researchers around the world are keen to phenotype their plants in the field (http://www.plant- phenotyping.org/ippn-survey2016). The introductions proposed are closely related to exotic grass species already in cultivation in New Zealand and research will be undertaken before these grasses and any hybrids are put into large scale commercial use.

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4. The hybrids of all proposed species in this application with perennial ryegrass must be screened side by side for an accurate comparative study without having a gap within this group of species. If this is not the case, the evaluation will not be valid and/or the most important genes or traits may be missed or not detected and therefore the expensive practice of hybridisation and screening may become too risky with minimum value and based on pure chance. This is because there is no preference across the proposed species and they all have equal potential for ryegrass improvement.

New Zealand has an ambitious target of significantly increasing its dairy and meat production in the next 10 years. There are only limited options to achieve this target:

1. Genetically modified ryegrass and white clover

2. Pushing ryegrass and white clover beyond their comfort zones and regions hence more irrigation, nitrogen leaching and ground water pollution.

3. Interspecific hybridisation for incorporating desirable traits to ryegrass and white clover.

The third option is the lowest risk option for the environment within the current climate of New Zealand society’s public opinion regarding the use of GMOs and environmentally unsustainable agricultural practices. This option will potentially enable New Zealand to prepare itself for more environmentally friendly forages by choosing species with minimal need to fertiliser input and maximum tolerance to drought and minimum methane output for future inter-specific hybridisation products. However, this will only be possible if New Zealand researchers have access to germplasm to screen for these traits and grow the new grass species and any new hybrids unrestricted under actual farm conditions.

Business analysis and financial estimates of costs and benefits

We have identified one area of unfavourable impact and three main areas of favourable impact for our proposal to bring wild grass relatives of ryegrass into New Zealand.

Unfavourable impact: potential increase in New Zealand’s weed burden

In the event some varieties are developed from species included in this application (or hybrids derived from those varieties), they could increase the weed burden in New Zealand, with economic impacts on productive land, environmental impacts on native landscapes and aesthetic impacts on urban and other modified landscapes. While weed impacts can be very substantial (with the impact of Californian Thistle alone being estimated at about $700m p.a., for example (Bourdôt et al. 2016) and an earlier study estimating the total cost of animal and plant pests at over $2 billion p.a. (Giera & Bell 2009)) they are also very difficult to quantify. We have therefore not attempted to do so. We can, however, note the following:

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1. The most economically valuable plant species in New Zealand is ryegrass, at about $14 billion of value per year (Nixon 2015). Any future new cultivars developed via crosses between ryegrass and the new species in this application would complement this value rather than reduce it (see below).Weed scientists at AgResearch have assessed the new species as not being high risk weeds for other economically-important plants such as Pinus radiata, grapes or kiwifruit based on the distribution and weediness of these grass species. We will pay particular attention to the potential impact of the species in this application as weeds of maize, wheat and barley (together estimated at being worth $1.5 billion p.a. to New Zealand (ibid)) before their cultivars are released in coordination with Plant and Food Research.

2. Grasses are not major weeds of New Zealand native landscapes with a few exceptions. Spartina- a weed of intertidal zones (DoC 2016) and Giant reed (Arundo donax)- a weed of rivers and stream margins that can block waterways and increase flooding and fire risk (MPI 2009a) are two examples, Also, the pampas grass (Cortaderia selloana) from South America, is similar in appearance to the native grass toetoe (Cortaderia splendens, C. fulvida, C. richardii, C. toetoe, C. turbaria), but is a serious weed in northern parts of the country (LandcareResearch 2016). It can suppress the growth of other species and is also a fire hazard (MPI 2009b). Another grass weed in New Zealand is cane grass (Phragmites australis), which is part of the National Interest Pest Response programme in New Zealand. It can crowd out native plants and reduce the numbers of insects and birds in wetland habitats (MPI 2014). The species in this application are not well-suited to any of the environments listed above.

3. Existing aesthetic impacts of weeds and pests are reflected in the household and private sector including primary industries expenditure on weed and pest control, which was estimated at $42m p.a. in 2008/09 (Giera & Bell 2009, p.37). It is unlikely that the species included in this application would add materially to that cost. This is because the species in this application are closely related to perennial ryegrass and therefore are unlikely to add significantly to the weed burden in New Zealand over and above existing grasses.

4. The Weed Risk Assessment table (Appendix 4) based on Australian standards suggest that only Lolium persicum should be considered a high risk weed and rejected for entry to the country and all other species should have a chance for assessment and evaluation as species with scores 5 or lower are grouped in this category. The fact that these species will prefer Australian conditions for potentially growing as weeds more than New Zealand’s climate should also be taken into account. This is due to the drier climate in Australia and therefore less competition between these grass species and other species that grow better in New Zealand.

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Favourable impact: potential increase in the value of pastoral production

The value of additional perennial ryegrass pasture production in the 2015/16 season varied from $0.17 to $0.45 per kg of dry matter (kgDM) for the upper North Island between seasons, with other regions having even wider variations in forage value over the year(Peel & Ludemann 2015, p.14). Breeding new ryegrass cultivars for the upper North Island that had the same total production over the year as current varieties but had more production in early spring ($0.45/kgDM) and less in late spring ($0.17/kgDM) would add $0.28 to the value of every kilogram of dry matter production that was moved from late to early spring or $0.20 to the value of every kilogram of dry matter that was moved from late spring to either summer or autumn.

As an illustration, for the Upper North Island, moving 100 kgDM/ha (i.e. less than 1% of typical production) from late spring to summer or autumn would add $20/ha/yr of economic value to a dairy farm. Similar changes across the 1.74 million effective hectares of all dairy farms in New Zealand (LIC & DairyNZ 2015, p.14) would be worth $34.8 million p.a. to the industry.

Favourable impact: potential increased resilience to drought

Drought in New Zealand has its greatest impact on the pastoral sector. The economic impact of New Zealand’s 2013 drought was estimated at 0.6% (Kamber et al. 2013) or 0.7% of gross domestic product (GDP) (The Treasury 2013), i.e. about $1.5 billion for that calendar year. New Zealand’s 2007/08 drought was estimated to have had on-farm costs of $1.2 billion in that year and a further $0.7 billion the following year, with an additional $0.9 billion in off-farm costs (Butcher Partners Ltd 2009, p.18). The 1997/98 drought had an impact of about 0.9% on GDP (RSNZ 1998). As a result of climate change, New Zealand’s regions are expected to spend 5 to 20% more time in drought between 2030 and 2050, compared to the 20th century (Clark et al. 2011, p.26).

The impact of drought on New Zealand’s economy could be reduced by increasing the diversity of pastoral plants, especially by incorporating drought-tolerant alleles into the new breeding lines. If we take $1.5 billion as a typical cost of a major drought and assume there is an average 7-year interval between such droughts, if a modest 10% reduction in the impact of major droughts could be achieved due to greater pasture diversity by introducing more drought-tolerant cultivars to New Zealand’s pastoral systems, that would be worth an average of about $20 million p.a. of GDP.

Favourable impact: potential increased resilience to pests and diseases

New Zealand’s ryegrass pastures pose a significant economic risk if their narrow genetic base and diversity leads to a lack of resilience to pests and diseases because ryegrass generates $14 billion of value for New Zealand’s economy each year (Nixon 2015). A comparison can be drawn with the impact of Pseudomonas syringae pv. actinidiae (Psa-V) on the kiwifruit industry. Since it was first found in 2010, Psa-V has resulted in the removal of almost all the Hort 16A kiwifruit variety in New

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Zealand, which represented almost all of the 22 million trays of gold kiwifruit harvested out of the 98.5 million trays of kiwifruit grown in New Zealand in 2009/10 (Zespri 2010, p.1). The 15-year net present value of the recovery cost was estimated at $740 million (Greer & Saunders 2012, p.46). Payments made to New Zealand growers in 2009/10 were $849 million (Zespri 2010, p.1) so the estimated long- term cost of eliminating 21% of plants in the industry was approximately the “farmgate” value of the industry.

The chance of a disease or pest devastating New Zealand ryegrass in a similar way to Psa-V and Hort 16A kiwifruit is very difficult to estimate and the recovery profile from a ryegrass disease or pest would be quite different, depending on the characteristics of the disease or pest and differences between the rates at which grass can be re-sown and kiwifruit vines can be grafted or planted and grow to be productive. However, a disease or pest of ryegrass in New Zealand, will have more impact than the 21% of kiwifruit that was affected by Psa-V and this greater breadth of impact could put the total cost of such an event into the tens of billions of dollars. Current diseases such as crown rust are already reducing the dry matter yield in ryegrass by 37% and spring regrowth as much as 23% and stem rust reducing seed yield by 50% in Victoria, Australia (Clarke 1999). A similar scenario in New Zealand would be disastrous for the economy. Such an event could therefore have an economic impact on New Zealand an order of magnitude greater than the estimated $16 billion cost of a large foot and mouth outbreak (Forbes & van Halderen 2014, p.5) because the value of ryegrass in New Zealand economy is estimated at $15 billion p.a.

Caveats

Forage Value Index economic values are calculated at the margin so estimates of value gained or lost due to changed pasture production in a given season becomes less accurate as the amount of change increases.

Some of the economic values noted above relate to GDP while others relate to farm income or farm surplus, and so are not directly comparable.

The impact estimates shown here are based on the maximum impact. In practice the speed with which that impact could be approached would be limited by:

1. the time required to breed and commercialise new cultivars of ryegrass, and

2. the rate at which new cultivars will be taken up, which will be limited by the rate of re-grassing. Re-grassing rates are about 3-4% per annum but the Pasture Renewal Charitable Trust and others are working to encourage farmers to increase their rates of re-grassing (PRCT 2009).

Risk of hybridisation with native New Zealand grasses

We have ensured that all the proposed species for introduction are distantly related to native species and there is no evidence or information to suggest that the fine-leaved native species will hybridise

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Weed Risk Assessment (WRA; See Appendix 4)

Due to the lack of a New Zealand-specific WRA model, the Australian WRA was used to assess the potential of the 19 species listed in this application (including the withdrawn species L. persicum for benchmarking) for being a weed (DAWR 2015; Gordon et al. 2008). Festuca arundinacea, a broad- leaved fescue species well distributed within New Zealand and Lolium perenne or perennial ryegrass, were also evaluated in this WRA for comparison. Australian weed scientists at the Department of Agriculture were also consulted during this process.

From the Australian WRA:

‘Scores are tallied once all the information is entered into the system and the questions are answered. The total score for a species relates to an import policy recommendation. The threshold values for policy recommendations are: • Threshold 1: score of less than 1 => the plant species will be accepted for importation • Threshold 2: score of greater than 6 => the plant species will be rejected for importation • Threshold 3: score between 1 and 6 => the plant species will be rejected for importation pending further evaluation. Threshold scores for policy recommendations were developed during testing and calibration of the system. During the development of the WRA system, 370 species, ranging from environmental and agricultural weeds to benign and beneficial plants, were used to test it. The system was judged on its ability to correctly reject weeds, accept non-weeds and generate a low proportion of species requiring further evaluation.’

While the majority of the species in this application scored medium for weediness potential (between 1 and 6; Appendix 4), Festuca arundinacea scored 16 and Lolium perenne scored 11, same weed risk level as L. persicum (Table 2). Under the Australian WRA model, all species in this application would be considered semi-weedy, and subject to further evaluation. However, this system is only developed for Australian hot and dry conditions and many of the questions in this WRA do not apply to New Zealand, yet we used the worst case scenario scores for Australian conditions, which should not really be the final criterion for the decision making but rather used as a guide only. We suggest New Zealand’s cooler and wetter climate dramatically reduces the risks of all species in this list. While this change will not affect the importation decisions on thresholds 1 and 2, it will have a significant effect on importation decisions for the species in threshold 3 allowing these species to be accepted for importation without a need for further evaluation. As a rule of thumb, species in thresholds 2 and 3 have the traits that will make them good and persistent grasses either as weeds or effective pasture grasses and those in threshold 1 are very unlikely to establish in New Zealand as wild types, but they have specific traits that are very valuable to use in interspecific hybrids with perennial ryegrass. These

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Table 2. Summary of the scores from the Weed Risk Assessment system.

Species Score Lolium canariense 2.5 Lolium saxatile 2.5 Lolium persicum* 11 Micropyropsis tuberosa 2.5 Festuca altaica 3 Festuca altissima 5 Festuca caerulescens 5 Festuca drymeja 5 Festuca durandoi 5 Festuca fontqueri 5 Festuca kingii 4 Festuca mairei 5 Festuca paniculata 5 Festuca pseudeskia 5 Festuca pulchella 5 Festuca scariosa 5 Festuca spectabilis 5 Festuca subulata 5 Festuca triflora 5 Festuca arundinacea† 16 Lolium perenne† 11

*Withdrawn from the original application due to high weed risk status † Widespread in New Zealand as major forage species

Reducing the risks by climate matching of typical sites for the listed species

The following are climate matches for typical sites within the species range using Climex Computer software, a package developed in Australia using monthly temperatures and rainfall. Mean monthly temperatures (min and max) and mean monthly rainfall were used at the level of 0.7 (effectively a 0.7 correlation). For each species, only those parts of the range with the mildest winters and mildest summers and within the rainfalls- closest to NZ conditions were chosen for the climate match studies. Climate matching for Lolium perenne and Festuca arundinacea, broad-leaved species widely distributed in New Zealand, were used for comparison.

In summary, this section explores the potential adaptability of the species of interest in this application to New Zealand’s climatic conditions and the traits of interest in these species, which can potentially add value to New Zealand’s agricultural and environmental practices.

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1 Lolium perenne

Distribution of a typical northern temperate species such as perennial ryegrass. This species is suitable for and grown in New Zealand

2 Festuca arundincea

Distribution of a typical more heat tolerant temperate species like tall fescue. This species is also suitable for and grown in New Zealand.

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3 Festuca altaica A species of Russia/North America/Mongolia, including West & East Siberia, Altai, Far east, Jungaria- Tarbagatai. It occurs on stony slopes, rocks, screes and pebbles; up to upper (bald) mountain belt.

The sites chosen for collecting this species will be in valleys rather than at altitude in the mountains. Akmolinsk in the Altai region

Oleminsk in Far East Russia

This species is adapted to very cold winter zones and not maritime climates like New Zealand. When integrated into the ryegrass breeding program, it will bring the winter hardiness and frost tolerance trait into the new cultivars.

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4 Festuca altissima From Central Norway, Estonia, and Central Ural southwards to Northern Spain, Northern Greece and South Central Russia, Caucasus: Ciscaucasia, Dagestan, East-South Transcaucasia, Altai, Deciduous woods. Bronnoysond, Central Norway

Pamplona, 463m North Spain

The range of this species is vast, being mainly in northern Europe and Russia but parts of its southern range overlap (to a certain degree) with parts of New Zealand. It is adapted to deciduous woods, and southern forms of this species could be expected to grow in parts of New Zealand, although probably not aggressively. The reason it has not been introduced accidently is probably due to its lack of presence in agricultural habitats.

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5 Festuca caerulescens Spain/Algeria/Tunisia/Italy, glaucous blue coloured leaves typical of dry Mediterranean habitats Alger

Madrid

This Mediterranean species is growing in regions drier than New Zealand. It could be expected to grow in New Zealand but probably only in very dry East Coast regions and not aggressively due to the abundance of its favourable steep lands. Drought tolerance is the trait of interest for integrating alleles from this species into ryegrass mainstream cultivars in future.

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6 Festuca drymeja

Eastern Central Europe and Balkan Peninsula; Southern Italy and Sicilia Forest glades up to middle mountain belt. Caucasus, Central Europe, Mediterranean, Asia Minor, Iran (Northwestern), deciduous woods. Palermo Sicily

Sarajevo Balkans

This species grows in zones with drier and colder winter than New Zealand. However, some forms grow in warm winter zones (Sicily). This second type could be expected to grow in New Zealand but probably only in very dry East Coast regions. Drought tolerance of this species will be the target trait for integration into ryegrass.

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7 Festuca durandoi

Mountains of Spain and Portugal - On the Red List for Spain, so very rare Avila Spain 1183m

This species is very rare and as a mountain species of Spain and Portugal is a poor fit for New Zealand. Very unlikely to be adapted to New Zealand. However, its adaptation to steep land is of value to New Zealand’s mid-high rainfall hill country.

8 Festuca fontqueri

Morocco (Rif Atlas, Middle Atlas, High Atlas and Anti-Atlas) – restricted range

This species has a restricted range in the Mediterranean climates of Morocco. It will probably grow in New Zealand but not aggressively, as it has a restricted distribution even in its origin. Its adaptation to dry lands and water use efficiency is the trait of interest in this species for integration into ryegrass cultivars in the hill country.

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9 Festuca kingii

USA, Moist to dry grassland, rolling hills, open ridges or talus slopes to 11000 feet. Oregon, Nevada, Colorado, Idaho, Montana, Utah, Wyoming, Nebraska. Burns Eastern Oregon

A species of dry grasslands with colder winters, will probably grow in the New Zealand mountain valleys. Drought and cold tolerance are the traits of interest in this species for improving perennial ryegrass.

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10 Festuca mairei

Algeria/Morocco - Atlas mountains

This species grow in the Mediterranean climates of Morocco and Algeria. It will probably grow in New Zealand’s hill country. Drought tolerance is the trait of interest in this species.

11 Festuca paniculata Rocky ground and dry grassland, mainly in the mountains. S. Europe, eastwards to Bulgaria, and extending northwards to S. Austria

Plovdiv Bulgaria

This species will probably grow in New Zealand but not aggressively as it is adapted to dry mountains. Drought tolerance and growth in steep land are the traits of interest.

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12 Festuca pseudeskia

Mountains of Southern Spain, Screes and rocky pastures. This species will probably grow in New Zealand.

13 Festuca pulchella

Alps and Jura Mountains, Eastern Carpathians

A high altitude growing species likely to be adapted to mountainous regions of New Zealand.

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14 Festuca scariosa

Mountains of Southern and Eastern Spain

This species will probably grow in New Zealand but not aggressively as it is adapted to dry mountains. Drought tolerance and growth in steep land are the traits of interest.

2000m Gore Ethiopia

15 Festuca spectabilis

Mountain species in Albania, Bulgaria, Greece and Italy -

The interest in this species will be for the purpose of integration into the ryegrass cultivars from the valley regions rather than high mountains, but the species may be adapted to mountainous regions of New Zealand.

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16 Festuca subulata

Subartic, western Canada, northwest USA, southwest USA, Mexico, southern South America

Forest and woodland. Occurring both sides of the Cascade Mountains, in moist dry areas, often along stream banks or in forest meadows.

Forms of this species from milder coastal areas may be adapted to New Zealand.

17 Festuca triflora

Europe/North Africa, Southwest Europe. Shady places. Mountains of S, SE, & C. Spain.

Ability to grow in steep land and shade tolerance are the trait of interest. As a mountain species it is likely to be adapted to the mountainous regions of New Zealand.

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18 Lolium canariense

Canary Islands/Cape Verde, low altitude annual species.

Mediterranean annual species and not adapted to New Zealand. However, its strong drought tolerance is a trait of interest for the drier eastern coast of New Zealand.

19 Lolium persicum

Middle East origin, now a widespread annual but never reported in New Zealand.

Middle eastern annual likely to adapt to any environment including New Zealand. High risk and therefore withdrawn from our final list.

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20 Lolium saxatile

Canary Islands: Jandia massifat the southern end of Fuerteventura and Famara massif north Lanzarote

High altitude species. Unlikely to be adapted to the colder mountainous regions of New Zealand compared to its origin. Its high drought tolerance and growth in steep land are the traits of interest for use in New Zealand’s summer dry hill country.

21 Micropyropsis tuberosa

Morocco/Spain only occurs at 3 locations, endangered.

Freshwater swamps, riverbeds, sometimes ecotones between heathers and freshwater swamps

A red listed species in Spain and therefore not an aggressive species at all. Water-logging tolerance is the trait of interest for high rainfall regions of New Zealand.

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6. Pathway determination and rapid assessment

Under sections 38I and 35 of the HSNO Act your application may be eligible for a rapid assessment. The pathway for your application will be determined after its formal receipt, based on the data provided in this application form. If you would like your application to be considered for rapid assessment (as per the criteria below), we require you to complete one of the below sections. Fill in the section that is relevant to your application only. 6A. New organism that is or is contained within a veterinary or human medicine (section 38I)

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

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

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

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

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

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

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7. Other information

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

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

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

Confidential data as part of a separate, ☐ Yes ☒ No identified appendix

Supplementary optional information attached:

 Copies of additional references ☐ Yes ☒ No

 Relevant correspondence ☒ Yes ☐ No Letter and email of support from Federated Farmers and DairyNZ

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

If you are not an approved customer, payment of fee will be by:  Direct credit made to the EPA bank ☒ Yes ☐ No account (preferred method of payment) ☐ Payment to follow Date of direct credit:

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

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

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

☒ I am making this application, or am authorised to sign on behalf of the applicant or applicant organisation. ☒ I have completed this application to the best of my ability and, as far as I am aware, the information I have provided in this application form is correct.

18/11/2016

Signature Date

Request for information waiver under section 59 of the HSNO Act

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

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

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

References

Act, H.S.N.O. 1996. Hazardous Substances and New Organisms Act. Wellington, New Zealand. www.legislation.govt.nz/act/public/1996/0030/latest/DLM381222.html.

Banik, B.; Durmic, Z.; Erskine, W.; Ghamkhar, K.; Revell, C. 2013. In vitro ruminal fermentation characteristics and methane production differ in selected key pasture species in Australia. Crop and Pasture Science 64: 935-942.

Banting, J.; Gebhardt, J. 1979. Germination, afterripening, emergence, persistence and control of Persian darnel. Canadian Journal of Plant Science 59: 1037-1045.

Barnes, B.D.; Kopecký, D.; Lukaszewski, A.J.; Baird, J.H. 2014. Evaluation of turf-type interspecific hybrids of meadow fescue with perennial ryegrass for improved stress tolerance. Crop Science 54: 355-365.

Beckie, H.J.; Lozinski, C.; Shirriff, S.; Brenzil, C.A. 2013. Herbicide-resistant weeds in the Canadian Prairies: 2007 to 2011. Weed technology 27: 171-183.

Belanger, F.; Bonos, S.; Meyer, W. 2004. Dollar spot resistant hybrids between creeping bentgrass and colonial bentgrass. Crop Science 44: 581-586.

Bodas, R.; López, S.; Fernández, M.; García-González, R.; Rodríguez, A.B.; Wallace, R.J.; González, J.S. 2008. In vitro screening of the potential of numerous plant species as antimethanogenic feed additives for ruminants. Animal Feed Science and Technology 145: 245- 258.

Bourdôt, G.W.; Hurrell, G.A.; Trolove, M.; Saville, D.J. 2016. Seasonal dynamics of ground cover in Cirsium arvense – a basis for estimating grazing losses and economic impacts. Weed Research n/a-n/a.

Butcher Partners Ltd 2009. Regional and national impacts of the 2007–2009 drought. Report Ministry of Agriculture and Forestry.

Cai, H.; Stewart, A.; Inoue, M.; Yuyama, N.; Hirata, M. 2011. Lolium. pp. 165-173. In: Wild Crop Relatives: Genomic and Breeding Resources. Springer,

Catalán, P.; Torrecilla, P.; Rodrıguez, J.A.L.; Olmstead, R.G. 2004. Phylogeny of the festucoid grasses of subtribe Loliinae and allies (Poeae, ) inferred from ITS and trnL–F sequences. Molecular phylogenetics and evolution 31: 517-541.

Charmet, G.; Balfourier, F.; Chatard, V. 1996. Taxonomic relationships and interspecific hybridization in the genus Lolium (grasses). Genetic Resources and Crop Evolution 43: 319- 327.

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Clark, A.; Mullan, B.; Porteous, A. 2011. Scenarios of Regional Drought under Climate Change. Report National Institute for Water and Atmospheric Research.

Clarke, R. 1999. Rusts in ryegrass. Accessed: 31/10/2016. http://agriculture.vic.gov.au/agriculture/pests-diseases-and-weeds/plant-diseases/pastures- diseases/rusts-in-ryegrass

Clayton, W.; Harman, K.; Williamson, H. 2006. GrassBase-the online world grass flora.

Culvenor, R.; Simpson, R. 2014. Persistence traits in perennial pasture grasses: the case of phalaris (Phalaris aquatica L.). Crop and Pasture Science 65: 1165-1176.

DairyNZ 2014. DairyNZ 2013/14 Annual report. Report DairyNZ.

DAWR. 2015. Weed risk assessment system. Accessed: 30/11/2016. http://www.agriculture.gov.au/biosecurity/risk-analysis/weeds/system/weed_risk_assessment

De Keyser, E.; Van Laere, K.; Fariaszewska, A.; Baert, J.; De Riek, J. 2012. Drought Tolerance in: Interspecific Hybridization and Candidate Gene Isolation.

DoC 2016. War on Weeds. Report Department of Conservation.

Edgar, E.; Connor, H.E. 2010. Flora of New Zealand-Vol. V: Gramineae. Manaaki Whenua Press, Landcare Research,

Forbes, R.; van Halderen, A. 2014. Foot-and-Mouth Disease Economic Impact Assessment: What it means for New Zealand. Report No. Technical Paper No: 2014/18. Ministry for Primary Industries.

Friebe, B.; Jiang, J.; Gill, B.; Dyck, P. 1993. Radiation-induced nonhomoeologous wheat- Agropyron intermedium chromosomal translocations conferring resistance to leaf rust. Theoretical and Applied Genetics 86: 141-149.

García-González, R.; López, S.; Fernandez, M.; Bodas, R.; González, J.S. 2008. Screening the activity of plants and spices for decreasing ruminal methane production in vitro. Animal Feed Science and Technology 147: 36-52.

Ghamkhar, K.; Rochfort, S.; Banik, B.; Revell, C. 2016. Metabolomics for Methane Mitigation: A Case Study in Biserrula (Biserrula pelecinus L.). pp. 271-275. In: Breeding in a World of Scarcity. Springer,

Giera, N.; Bell, B. 2009. Economic Costs of Pests to New Zealand. Report No. Technical Paper No: 2009/31. MAF Biosecurity New Zealand.

Goldman, J.; Sims, P. 2005. Production of an interspecific hybrid between Texas and Argentine bluegrass. Plant breeding 124: 419-420.

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Gordon, D.R.; Onderdonk, D.A.; Fox, A.M.; Stocker, R.K. 2008. onsistent accuracy of the Australian weed risk assessment system across varied geographies. Diversity and Distributions 14: 234-242.

Greer, G.; Saunders, C. 2012. The costs of Psa-V to the New Zealand Kiwifruit Industry and the Wider Community. Report Agribusiness and Economics Research Unit, Lincoln University.

Hand, M.L.; Cogan, N.O.; Stewart, A.V.; Forster, J.W. 2010. Evolutionary history of tall fescue morphotypes inferred from molecular phylogenetics of the Lolium-Festuca species complex. BMC evolutionary biology 10: 1.

Holman, J.D.; Bussan, A.J.; Maxwell, B.D.; Miller, P.R.; Mickelson, J.A. 2004. Spring Wheat, Canola, and Sunflower Response to Persian Darnel (Lolium persicum) Interference 1. Weed technology 18: 509-520.

Howell, C. 2008. Consolidated list of environmental weeds in New Zealand. Science & Technical Pub., Department of Conservation,

Humphreys, M.; Thomas, H.-M.; Harper, J.; Morgan, G.; James, A.; Ghamari-Zare, A.; Thomas, H. 1997. Dissecting Drought-and Cold-Tolerance Traits in the Lolium-Festuca Complex by Introgression Mapping. The New Phytologist 137: 55-60.

Hussain, S.W.; Williams, W.M. 2013. Trifolium occidentale: a valuable genetic resource for white clover improvement. pp. 309-310. In: 22nd International Grasslands Congress.

Inda, L.A.; Sanmartín, I.; Buerki, S.; Catalán, P. 2014. Mediterranean origin and Miocene– Holocene Old World diversification of meadow fescues and ryegrasses (Festuca subgenus Schedonorus and Lolium). Journal of biogeography 41: 600-614.

Jones, M.; Humphreys, M. 1993. Progress in breeding interspecific hybrid ryegrasses. Grass and Forage Science 48: 18-25.

Kamber, G.; McDonald, C.; Price, G. 2013. Drying out: Investigating the economic effects of drought in New Zealand. Report No. AN2013/02. Reserve Bank of New Zealand.

Lancashire, J. 2006. The value of exotic germplasm to the NZ livestock industry. Grassland Research and Practice Series 12: 5-9.

LandcareResearch. 2016. Toetoe. Accessed: 30/10/2016. http://www.landcareresearch.co.nz/science/plants-animals-fungi/plants/ethnobotany/weaving- plants/information-sheets/toetoe

Lesniewska, A.; Ponitka, A.; Slusarkiewicz-Jarzina, A.; Zwierzykowska, E.; Zwierzykowski, Z.; James, A.R.; Thomas, H.; Humphreys, M.W. 2001. Androgenesis from Festuca pratensis [times] Lolium multiflorum amphidiploid cultivars in order to select and stabilize rare gene combinations for grass breeding. Heredity 86: 167-176.

LIC; DairyNZ 2015. Dairy Statistics 2014/15. Report LIC.

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Lloyd, K.M.; Hunter, A.M.; Orlovich, D.A.; Draffin, S.J.; Stewart, A.V.; Lee, W.G. 2007. Phylogeny and biogeography of endemic Festuca (Poaceae) from New Zealand based on nuclear (ITS) and chloroplast (trnL–trnF) nucleotide sequences. Aliso: A Journal of Systematic and Evolutionary Botany 23: 406-419.

Meale, S.; Chaves, A.; Baah, J.; McAllister, T. 2012. Methane production of different forages in in vitro ruminal fermentation. Asian-Australasian journal of animal sciences 25: 86.

MFE. 2000. The New Zealand Biodiversity Strategy. Accessed: 30/02/2016. http://www.mfe.govt.nz/publications/biodiversity/new-zealand-biodiversity-strategy

MPI. 2009a. Giant reed. Accessed: 30/10/2016. http://www.biosecurity.govt.nz/pests/giant- reed

MPI. 2009b. Pampas. Accessed: 30/10/2016. http://www.biosecurity.govt.nz/pests/pampas- grass

MPI. 2014. Phragmites. Accessed: 30/10/2016. http://www.biosecurity.govt.nz/pests/phragmites

MPI 2016a. Plant Biosecurity Index. MPI, New Zealand.

MPI. 2016b. NPPA Plant Listing. Accessed: 30/10/2016. http://www.biosecurity.govt.nz/pests/surv-mgmt/mgmt/prog/nppa/list

Nichols, S. 2012. Introgression of root and shoot characteristics in Trifolium repens x Trifolium uniflorum interspecific hybrids. Lincoln University,

Nichols, S.; Crush, J. 2014. Novel approaches to improving growth of pasture legumes at low phosphorus levels. pp. 197-202. In: Proceedings of the New Zealand Grassland Association.

Nichols, S.; Crush, J.; Ouyang, L. 2014a. Phosphate responses of some Trifolium repens× T. uniflorum interspecific hybrids grown in soil. Crop and Pasture Science 65: 382-387.

Nichols, S.; Hofmann, R.; Williams, W. 2014b. Drought resistance of Trifolium repens× Trifolium uniflorum interspecific hybrids. Crop and Pasture Science 65: 911-921.

Nixon, C. 2015. How valuable is that plant species? Application of a method for enumerating the contribution of selected plant species to New Zealand’s GDP. Report New Zealand Institute for Economic Research.

NZPCN 2016. Flora Database. New Zealand.

NZTE. 2016. Exports - Top 20 commodities. Accessed: 10/11/2016. https://www.nzte.govt.nz/en/invest/statistics/#toc-exports-top-20-commodities

Peel, S.; Ludemann, C. 2015. Forage Value Index Handbook. Report DairyNZ.

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Person-Dedryver, F.; Jahier, J.; Miller, T. 1990. Assessing the resistance to cereal root-knot nematode, Meloidogyne naasi, in a wheat line with the added chromosome arm 1HchS of Hordeum chilense. Journal of Genetics & Breeding 44: 291-295.

PRCT 2009. Growing New Zealand’s economy - one paddock at a time. Pasture Renewal Charitable Trust,

Randall, R.P. 2012. A global compendium of weeds. Department of Agriculture and Food Western Australia,

Richards, R. 1996. Defining selection criteria to improve yield under drought. Plant growth regulation 20: 157-166.

Rieseberg, L.H. 1995. The role of hybridization in evolution: old wine in new skins. American Journal of Botany 82: 944-953.

RSNZ 1998. 1997/98 El Niño: lessons and opportunities. Royal Society of New Zealand, Wellington, New Zealand.

Sanderson, K.; Dustow, K.; Dixon, H. 2012. Economic impact assessment of arable production. Report Arable Food Industry Council.

Scholz, S.; Scholz, H. 2005. A new species of Lolium (Gramineae) from Fuerteventura and Lanzarote (Canary Islands, Spain). Willdenowia 281-286.

SSC 2016. Performance Improvement Framework (PIF) review of the Ministry for Primary Industries Ed. SSC New Zealand.

Stewart, A.V. 2006. Genetic origins of perennial ryegrass (Lolium perenne) for New Zealand pastures. Grassland Research and Practice Series 12: 55-62.

Tanksley, S.D.; McCouch, S.R. 1997. Seed banks and molecular maps: unlocking genetic potential from the wild. Science 277: 1063-1066.

The Treasury 2013. Budget Economic and Fiscal Update 2013 - Economic Impacts of the Drought. The Treasury, Wellington, New Zealand.

Thomas, H.M.; Morgan, W.G.; Humphreys, M.W. 2003. Designing grasses with a future – combining the attributes of Lolium and Festuca. Euphytica 133: 19-26.

Thompson, J.D.; Lumaret, R. 1992. The evolutionary dynamics of polyploid plants: origins, establishment and persistence. Trends in ecology & evolution 7: 302-307.

Widdup, K.; Hussain, S.; Williams, W.; Lowther, W.; Pryor, H.; Sutherland, B.; Moot, D. 2003. The development and plant characteristics of interspecific hybrids between white and caucasian clover. pp. 143-148. In: Legumes for dryland pastures. Proceedings of a New Zealand Grassland Association (Inc.) Symposium held at Lincoln University, 18-19 November, 2003.

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Williams, P.; Timmins, S.M. 1990. Weeds in New Zealand protected natural areas: a review for the Department of Conservation. Department of Conservation,

Williams, W. 1996. Genetic resources of temperate native and low‐input grasses in New Zealand and Australian collections. New Zealand Journal of Agricultural Research 39: 513- 526.

Xiong, Y.; Fei, S.-z.; Arora, R.; Brummer, E.C.; Barker, R.E.; Jung, G.; Warnke, S.E. 2007. Identification of quantitative trait loci controlling winter hardiness in an annual× perennial ryegrass interspecific hybrid population. Molecular Breeding 19: 125-136.

Xiong, Y.; Fei, S.-z.; Brummer, E.C.; Moore, K.J.; Barker, R.E.; Jung, G.; Curley, J.; Warnke, S.E. 2006. QTL analyses of fiber components and crude protein in an annual× perennial ryegrass interspecific hybrid population. Molecular Breeding 18: 327-340.

Yamada, T. 2011. Festuca. pp. 153-164. In: Wild crop relatives: genomic and breeding resources. Springer,

Yao, Y.; Ni, Z.; Zhang, Y.; Chen, Y.; Ding, Y.; Han, Z.; Liu, Z.; Sun, Q. 2005. Identification of differentially expressed genes in leaf and root between wheat hybrid and its parental inbreds using PCR-based cDNA subtraction. Plant molecular biology 58: 367-384.

Zespri 2010. Annual Report. Report Zespri Group Limited. https://www.zespri.com/ZespriInvestorPublications/annual-report-2010-11.pdf [Accessed 27 February 2016]

Zwierzykowski, Z.; Tayyar, R.; Brunell, M.; Lukaszewski, A. 1998. Genome recombination in intergeneric hybrids between tetraploid Festuca pratensis and Lolium multiflorum. Journal of Heredity 89: 324-328.

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Appendix 1. Report of the Māori Reference Group (MRG) on the application

Report of the Māori Reference Group (MRG) for the AgResearch Proposal to Release 19 Species of Grass

MRG Workshop Date & Location: 9 May 2016, Grasslands Research Centre, Palmerston North

MRG Composition

Bill Blake Kaumatua from Te Herenga network Dr Nick Roskruge Institute of Agriculture and Environment, Massey University Dr Amanda Black Bio-Protection Research Centre, Lincoln University Hoani Ponga Te Tumu Paeroa

MRG Purpose

1. The purpose of this Māori reference group (MRG) is to consider the potential risks and impacts on Māori interests associated with the AgResearch proposal to release 19 species of grass into the New Zealand environment.

2. AgResearch is currently preparing an application to the Environmental Protection Authority (EPA) for this proposal under the Hazardous Substances and New Organisms Act 1996. The MRG will provide advice and information to the applicant (AgResearch) and the EPA regarding risks and impacts on Māori interests to improve robustness of this application.

Key Issues

3. The MRG focussed on four key areas of concern under the following headings:  Economic, social and cultural well-being of Māori;  Working with Māori to develop relationships and opportunities;  Observing tikanga Māori, and;  Communicating the proposal to Māori.

4. The MRG also raised a number of general issues concerning the proposal which are summarised towards the end of the report.

Economic, social and cultural well-being of Māori

5. The application should address what the implications are for the economic, social and cultural well-being of Māori. AgResearch should recognise that Māori have a multifaceted interest in land extending across these well-beings, including their spiritual connection. There should be a specific focus on the relationship of Māori to their land.

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6. Māori have a strong interest in this proposal, in particular regarding what it means for the Māori economy and livelihoods based on pastoral agriculture. Māori farming entities will be impacted by this proposal. There are substantial Māori land holdings throughout the country and Māori are prevalent players in the agricultural sector. For example, Atihau- Whanganui Incorporation is a 42,000 ha Māori sheep and beef enterprise. There are many others like this across the country.

7. Māori will want to know how the proposal would affect Māori communities and what it offers in terms of development and other benefits for Māori. They will be interested in the implications for Māori in terms of any positive or negative transformation of agricultural practices, employment, training and technology requirements, social change, potential investment and development of business opportunities, and impacts on businesses and industries associated with the agricultural sector, regional economies and rural communities.

8. Will the proposal induce any change in the environment or agricultural sector that could affect any of the foregoing matters? How will it affect productivity of Māori land and the ability of Māori to access or develop employment opportunities and rural services (e.g. farming, trades, rural contracting and advisory services), exercise customary practices and enjoy traditional lifestyles? How will the proposal affect culturally significant plants used for rongoā (medicine) and other purposes?

Recommendations

1. Indicate what changes to farming practices and the agricultural sector, if any, are anticipated as a result of releasing these 19 species of grass.

2. If possible, provide information and statistics on:  Māori land holdings in pastoral uses.  Number of Māori employed in the agricultural sector and upstream / downstream industries e.g. dairy, meat and wool processing industries.  Economic value of Māori agricultural production.

Working with Māori to develop relationships and opportunities

9. AgResearch has indicated that it has not yet initiated a conversation with Māori regarding this proposal, as they preferred to seek advice from the MRG before engaging with Māori.

10. There are opportunities for AgResearch to grow relationships with Māori and involve them in various components of the proposal e.g. development, implementation and monitoring. Māori have extensive expertise across the pastoral sector that AgResearch could harness, including mātauranga Māori (traditional knowledge and experience), which would benefit the proposal. AgResearch needs to indicate how they will involve Māori in the proposal going forward. The nature of that engagement can range from advisory roles to collaboration and partnership. More broadly, AgResearch should consider how Māori can be involved in AgResearch’s core activities. Engagement should be facilitated in accordance with AgResearch’s current relationships and protocols with Māori rather than any duplication of roles.

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11. Māori could be involved with the proposed Canterbury site where introduced grasses will be trialled in environmental conditions similar to their place of origin. Conversations about this involvement with Māori need to commence now in order to build those connections and key strategic relationships.

12. AgResearch could work with champions i.e. engage highly capable Māori groups and/or individuals to deliver key work streams and provide project leadership. The MRG advises care during the screening process of selecting champions as AgResearch could run the risk of positioning the champion/s of trying to be everything to everyone.

13. Relationships are extremely important to Māori. Developing and maintaining relationships with Māori is vital, in this regard, for AgResearch to have access to direct Māori input to canvass their views and provide guidance on matters that have an impact on them. Robust and sustained relationships will create launching pads for subsequent projects of strategic benefit to Māori. Ongoing dialogue and the formation of key strategic relationships with Māori should not start and end at each project.

14. AgResearch should engage with Māori regarding the grasses proposal as early as possible. The Māori Agribusiness portfolio at AgResearch and the Kaupapa Kura Taiao team at the EPA can help to identify which Māori groups might be engaged and how best to achieve this.

15. AgResearch has indicated they are hoping to involve Māori advisory groups in future work, including further applications to the EPA, and would like to establish one for the germplasm centre. This is strongly encouraged by the MRG.

Recommendations

3. Identify any opportunities for developing relationships and working with Māori groups including entities such as: Iwi organisations with farming interests; Māori farms or collectives that have capacity to engage; Te Tumu Paeroa, and; the Federation of Māori Authorities.

4. Identify elements of the proposal that Māori groups might be engaged in e.g. trial sites / pilot projects, monitoring programmes.

Observing tikanga Māori

16. The application should recognise and understand how tikanga Māori (Māori customary practice) applies to the proposal. This includes acknowledging the obligations that Māori have to land, the environment and the agricultural sector as kaitiaki. Exercising kaitiakitanga is stewardship and guardianship, enabling the protection of resources for the current and future welfare of people and the environment. Kaitiakitanga seeks to maintain balance and harmony within the environment from a perspective of intergenerational sustainability. AgResearch needs to indicate how the proposal contributes to kaitiakitanga and the relationship of Māori to the environment.

17. In terms of practical implementation of tikanga Māori, those going overseas to undertake work associated with the proposal should be blessed before departing New Zealand. Any seeds or material sourced from overseas should be blessed upon arrival in New Zealand as should any facilities utilised for their storage or management. This is done in accordance

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with the practice of manaakitanga to welcome something new into the country and remove any tapu that may compromise its existence or purpose.

18. The applicant should apply tikanga Māori consistently across the proposal including its international operations, in particular ensuring that interactions and relationships with indigenous people wherever they may be around the world working with the applicant are based on manaakitanga principles. Manaakitanga is about showing respect, care, hospitality, generosity and goodwill to others based on mana enhancing behaviour and approaches. It is about valuing people and relationships, and reciprocating benefit to those from whom benefits are derived. Likewise, kaitiakitanga principles should be reflected in any international components of the proposal.

Recommendations

5. Acknowledge the close relationship that Māori have to the land and the role that Māori have as kaitiaki exercising kaitiakitanga.

6. Indicate how tikanga Māori will be applied to the proposal e.g. blessing of seeds or people travelling, and showing manaaki to indigenous people involved with the proposal.

Communicating the proposal to Māori

19. AgResearch needs to consider how they are going to present this proposal to the Māori community of interest. The proposal must be compelling i.e. clearly demonstrate the benefits and risks to Māori in order for them to make an informed decision. It is important to acknowledge that Māori, on a treaty basis, is an integral partner to this proposal and will want to know how it specifically contributes to environmental and economic development interests and other opportunities in the future.

20. The proposal would benefit from a change in emphasis: conserving species appears to be a key focus but when considered from a holistic Māori perspective this is not a compelling argument, it should be about creating opportunities. However, if the proposal is essentially all about financial returns then the application should be frank about this.

21. Receptiveness to the proposal could be enhanced by making it relevant to the audience, particularly Māori engaged in farming activities. This could include highlighting threats or issues that the proposed introduced grasses might potentially address, for example, improving resilience of pasture to drought and climate change, inhibiting erosion and keeping soil on hills, and/or providing higher nutritional value for stock. People are then better able to understand what is in it for them.

22. If AgResearch is intending to work with a number Māori groups on this application, it would be desirable to prepare a strategy to implement this. Consideration will need to be given to who, what and how information will be communicated. AgResearch’s Māori Agribusiness portfolio and the EPA can provide further advice and guidance on this aspect of the proposal.

23. It is suggested that when communicating with Māori, AgResearch pares down the science and renders it as accessible as possible. Information should be presented in plain English language set at the reading level of 12 years of age (civil service standard for public

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information)2 supported by graphics so that it can be readily understood by the widest possible audience. The information should be in an electronic format enabling it to be distributed to, and viewed on, home computer systems.

24. The proposal could be sent out to Te Herenga – a national network of Māori environmental practitioners and resource managers administered by the EPA, to provide an opportunity for them to feed into the pre-application stage.

25. AgResearch needs to be prepared for an element of concern from Māori and therefore should have responses ready for queries. Māori will want answers regarding how their concerns will be mitigated or addressed; AgResearch needs to think short and long term – out to the 100 year horizon as any introduction of new grasses will be interpreted as a permanent result, hence impacts beyond the current generation will exist.

Recommendations

7. Prepare a summary of the proposal that is easy to understand and can be circulated easily via electronic media (see footnote 1).

8. Prepare a strategy for engaging Māori on the proposal including information regarding how Māori concerns and issues will be addressed.

9. Forward the draft proposal to the EPA for circulation to Te Herenga network.

General Issues

26. The issues identified below are of interest to Māori and may be fleshed out in the application. These issues may raise both positive and negative discussion points:  Weed potential / weed pressure from the new species  Potential effect on stock management  Contribution to land and resource sustainability outside of agriculture  Ecosystem considerations and any impacts on native flora and fauna  Conservation and biosecurity issues  Hybridisation potential

27. Introducing new grasses is a one-off opportunity inherently carrying risk. New Zealand agriculture already relies on introduced grass systems to which AgResearch is proposing to add another layer. AgResearch should identify how the proposal fits into the broader biosecurity and agricultural picture, and whether it is economic or sustainable for the country. This includes AgResearch identifying how to mitigate any concerns as well as risk. What potential issues might arise from the introductions over the next 5, 20 and 100 years?

2 http://www.write.co.nz/Resources/Writing+tips.html http://www.write.co.nz/Resources/Plain+English+articles.html

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28. AgResearch needs to consider any management costs that New Zealand is left with following the introductions and where these are likely to fall i.e. central government, councils, landowners, land users, sector groups or iwi. Conversely, AgResearch should also clearly identify who is going to profit from the proposal.

29. Māori submitters to this proposal would find it challenging to respond adequately to an application covering 19 grass species. Nineteen species is probably too many for a single application, as it would be demanding for the applicant or any other party to make a detailed assessment of each of the 19 different species or the cumulative effect they may have. AgResearch should consider submitting a smaller application.

30. If the application for 19 species is unsuccessful AgResearch has indicated informally that their Plan B is to reapply for the lowest risk plants i.e. Plan B is based on the risk profile.

Recommendation

10. Provide information on risks, costs and benefits in relation to: Weed potential / weed pressure from the new species; Potential effect on stock management; Contribution to land and resource sustainability outside of agriculture; Ecosystem considerations and any impacts on native flora and fauna; Conservation and biosecurity issues, and; Hybridisation potential.

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Appendix 2. Response to the MRG report

Application for the Release of 19 Grass Species

- Māori Engagement Plan

Application Number: APP201894

Date: August 2016

Authors: Tina Eden, Chris Koroheke and Kioumars Ghamkhar

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CONTENTS

1...... AIM ...... 69 2...... PROPOSAL BACKGROUND ...... 69 3. WORKING WITH MĀORI TO DEVELOP RELATIONSHIPS AND OPPORTUNITIES ...... 70 4...... COMMUNICATING THE PROPOSAL TO MĀORI ...... 71 5...... OBSERVING TIKANGA MĀORI ...... 71 6...... ECONOMIC, SOCIAL AND CULTURAL WELLBEING OF MĀORI ...... 71 7...... POTENTIAL ISSUES THAT MAY ARISE ...... 73 7.1 Will the grasses be genetically modified? 73 7.2 Weed pressure from the new species 73 7.3 Impacts on native flora and fauna 74 7.4 Contribution to land and resource sustainability 74

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1. AIM

The aim of this document is to show how AgResearch plan to engage with Māori and will endeavor to consider how the proposal may impact the economic, social and cultural wellbeing of Māori. Additionally, this report will highlight the potential environmental concerns that Māori as Kaitiaki of Aotearoa may want addressed during the engagement process.

2. PROPOSAL BACKGROUND

This proposal requests the release of 19 exotic wild grass species which are closely related to perennial ryegrass, into New Zealand. This will enable NZ researchers to look for beneficial traits in those grasses to incorporate into ryegrass which currently struggles to persist in many farming regions of NZ. The proposed grasses have been suggested as having potentially desirable traits that available ryegrass cultivars lack. The ultimate objective is a forage grass breeding programme aspiring to improve the nutritive value of NZ ryegrass pastures and their resilience to drought, climate change, pests and diseases. In due course, the new cultivars would be more robust therefore increasing pasture production with reduced farmer inputs, leading to economic and/or environmental gains.

All conventional farming forage and pasture plants in NZ are exotic. Annual ryegrass and perennial ryegrass (Lolium), along with tall fescue and meadow fescue (Festuca) are not native and make up 95% of the grass component of NZ pasture. Although ryegrass is the most widely sown pasture species in NZ, it is not well adapted to our summer-dry agricultural regions. The majority of perennial ryegrass cultivars available to farmers have been bred from a narrow basis of germplasm so are not as diverse as they should be. This lack of diversity poses a significant risk, as a disease, pest or climate change could affect all ryegrass in NZ. However, NZ researchers have the ability to identify beneficial traits in closely related grasses that could be incorporated into the mainstream cultivars to develop new and improved, pasture varieties. AgResearch and the Margot Ford Germplasm Centre have the expertise and experience that can be applied to develop grasses that are better suited to NZ’s stressed farming environments. Therefore the ability to access the wild relatives of ryegrass to select for their traits that are adapted to harsher environments will improve pasture persistence and could reduce the current dependency on irrigation, fertiliser and pesticides enabling more sustainable farming practices.

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AgResearch acknowledges the role of tangata whenua as kaitiaki and commits to engage and understand the concerns, challenges and opportunities this application may raise for iwi, hapu and whanau and the significant agribusiness interests that they align to in their various capacities as trustees, owners, shareholders and kaitiaki.

3. WORKING WITH MĀORI TO DEVELOP RELATIONSHIPS AND OPPORTUNITIES

It is envisaged that Māori will be involved in this proposal at a number of levels. In accordance with the principles of kaitiakitanga and manaakitanga, we will develop tikanga around the project that is appropriate to the kaupapa and reflects the holistic relationship of tangata whenua with Papatuanuku and Aotearoa. AgResearch will incorporate tikanga into the project that acknowledges perspectives from a tangata whenua world view which enhances and supports the kaupapa, the people involved and the activities they discharge.

In order to address the obligation of consultation with Māori, AgResearch will undertake the following steps:  Seek advice from EPA on the design of a process that identifies the right people, interests, networks and agribusinesses.  Work with EPA to ensure that the priority activities are well understood and actioned.  Communicate with the interested parties and identified groups.  In consultation with the EPA, AgResearch may table the report at a meeting of Te Herenga and be prepared to discuss the proposal in person, supply supporting information and respond to any ongoing issues as required.  Identify a network of Māori agribusinesses and engage with them to inform and respond to any interest that is generated.  Farmers in the network will be invited to learn more about how science research can address the issues that as kaitiaki, they must consider.  Farmers will be invited to participate in the trials in collaboration with AgResearch to observe results and understand first hand.  The new hybrids could be trialled on Māori land where environmental conditions will test their robustness.

This collaboration is likely to require project managers as well as farm staff to conduct or oversee the trials. The trials create an opportunity for the sharing of knowledge that may lead to improved farm performance. This aspect of the collaboration could be formalised and developed further.

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4. COMMUNICATING THE PROPOSAL TO MĀORI

AgResearch recognises that Māori are an integral partner to this proposal not only as kaitiaki but also as significant contributors to New Zealand’s agricultural industry. It is important that Māori particularly in their role as kaitiaki and dairy and red meat producers are aware of any potential economic and environmental impacts this proposal could have as well as future opportunities, so an informed decision can be made.

In order to taper the engagement process with Māori, we will undertake the following activities and processes: • Summarise the proposal information in lay people terms avoiding the use of science jargon, clearly identifying the risks and benefits particularly at an on farm level so any implications can be understood by a wide audience. • The proposal could be sent out to Te Herenga – a national network of Māori environmental practitioners and resource managers administered by the EPA to provide an opportunity for them to feed into the pre- application stage. • AgResearch’s Māori Agribusiness portfolio and the EPA will work together to prepare a strategy in order to engage with a number of Māori groups after the submission of this proposal. The proposal can be further discussed at the hui with key AgResearch representatives available to address any queries.

5. OBSERVING TIKANGA MĀORI

At AgResearch, we acknowledge Matauranga Māori and are learning how to work with holders of this particular knowledge. The relationship of Māori to the land and their role as both provider and kaitiaki is also acknowledged. We will seek the guidance of EPA and Te Herenga in the development and observation of appropriate tikanga, working with both staff and Māori representatives.

When interacting with Māori groups and international contacts, AgResearch will be guided by the principle of manaakitanga by being respectful to all involved in this project and continuing the good relationships that will develop as a result of this project.

6. ECONOMIC, SOCIAL AND CULTURAL WELLBEING OF MĀORI

New Zealand is the largest sheep meat and dairy exporter in the world with Māori shareholders having 12% of NZ’s sheep and beef units, 30% of NZ’s lamb production and 10% of NZ’s dairy production. Hence Māori are prevalent players in the agricultural sector and have substantial land holdings throughout the country. For example, Atihau-Whanganui Incorporation is a 42,000 ha sheep and beef enterprise with over 206,000 stock units. There are many other Incorporations like this across the country. Māori have a significant

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The majority of this primary production is heavily reliant on ryegrass which is not well adapted to NZ’s summer-dry hill country and dairy regions. For Māori Agribusiness to remain internationally competitive, the cost to produce stock feed must be kept down. The release of the proposed 19 grass species will enable the initial studies for the development of grasses more tolerant to disease, pests and drought which will lead to greater pasture production and persistence being of great economic value. Additionally, grasses requiring less nitrogen input, having minimal methane output and deeper root systems will deliver huge benefits to the environment as nitrogen leaching, methane emissions and soil erosion can potentially be reduced.

This proposal therefore contributes to kaitiakitanga by improving farm sustainability, as these hybrid grasses may be more tolerant to the NZ summer-dry farming environments therefore requiring less pasture renovation, less irrigation and less fertiliser input. In 2015, the FoMA farms alone (115,000 ha) applied over 29,000 tonnes of fertiliser, 7,000 tonnes of lime and dolomite and renovated almost 3,000 ha of pasture. Reducing these figures across all Māori land holdings will have significant economic and environmental benefits.

Profitable and sustainable farming through the adoption of these improved hybrid cultivars can lead to greater opportunities for Māori as their landholdings are further developed. An example of this are the 2015 Ahuwhenua Trophy winners whose farming practices enabled them to reduce debt, purchase further land and not only implement, but achieve all aspects of their farming development programme. As these farming enterprises become profitable, employment opportunities also become available. The hybrid grasses this proposal aims to develop will improve the economic, social and cultural wellbeing of Māori by delivering tools and materials for innovative farming, enabling Māori to become even greater contributors to New Zealand’s Primary Industry.

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7. POTENTIAL ISSUES THAT MAY ARISE

The following issues are of interest to Māori and are likely to be raised during the consultation and engagement process. Each issue has been addressed according to their possible negative and positive impacts. These issues will also be included in all interactions with Māori.

7.1 Will the grasses be genetically modified? Positive: No. Rather than genetically modifying the species currently established in NZ, AgResearch plans to cross-pollinate these plants with other exotic grasses which have the traits that imported ryegrass lacks. This is, basically, using the same principles of traditional breeding as implemented by ancient farmers in the Middle East and the Central and South Americas. There are 19 exotic ryegrass relatives that have been identified as having these desirable traits. By developing cultivars that can better compete with weeds, require minimal amounts of fertiliser, have maximum tolerance to drought and have reduced methane output, NZ agriculture can better prepare for current or future challenges to our pastoral economy.

7.2 Weed pressure from the new species Negative: Once approval for the proposed grasses have been granted, it is possible that other organisations could also import the seed. Although AgResearch plans to breed out potential negative traits in the wild grasses under controlled field conditions, other companies may not. There is therefore a risk that the wild grasses may enter the natural environment by other entities.

Positive: None of the species proposed for release are listed by the National Pest Plant Accord as a significant pest plant. It is likely that the new grasses in this application will be wild and adapted to their natural climates and environments, rather than New Zealand’s, at least initially. Therefore it is unlikely that they would form undesirable self-sustaining populations. These species are not being imported to be used on their own credit. They are going to be used as hybrids with ryegrass and over generations of backcrossing to ryegrass, their unwanted traits will be selected against. Once the species have been improved by selection for growth and production in NZ conditions, it is anticipated that the new varieties would form self-sustaining populations because in fact they are improved ryegrass hybrids rather than new species. These populations would be desirable as they will be in target agricultural environments.

Fescue is readily established on bare ground, out-competing other plants and persisting over several years, so it is often used in soil erosion control programs. These weedy traits would be beneficial to breed into ryegrass where it currently struggles to persist in summer-dry regions.

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7.3 Impacts on native flora and fauna Negative: It is possible that the new species or hybrids may be co-hosts of diseases that the native grasses are carriers of. If so, the new grasses could be susceptible to disease. However, trials to determine this can be conducted during the screening process.

Positive: The 19 wild grasses proposed for release are closely related to the Festuca and Lolium species currently sown in NZ pastures, so they should hybridise easily in the research facility. However, New Zealand’s nine native Festuca species are very distantly related to the exotic species in this application, therefore it is highly unlikely that they would hybridise naturally. Since the importation of ryegrass in the 1800s, no cases of exotic Festuca and Lolium grasses hybridising with the NZ native fescues have been recorded. Seven of New Zealand’s nine native species are tussock grasses occurring on off-shore islands, or mainland alpine or coastal cliff environments which are not used for agriculture in NZ. One of the remaining species is generally found in marginal environments, such as cliffs, bluffs and mountainsides. The last is cleistogamous and does not cross pollinate with other plants of any species.

7.4 Contribution to land and resource sustainability Positive: Incorporating beneficial traits into ryegrass will not only help to protect New Zealand’s farming economy, but also help to reduce farmer input contributing to land and resource sustainability. Current reliance on irrigation, fertilisers, fungicides, insecticides and herbicides could be reduced with the development of more resilient and productive pastures. This would have huge benefits to the environment and to New Zealand’s “clean green” international image.

At present, there is a heavy reliance on ryegrass in many areas outside its comfort zone. This has resulted in more nitrogen and phosphorus fertiliser input to compensate for lower production in these regions. In turn, this has led to nitrogen leaching into waterways and the eutrophication of rivers and lakes. With plant breeding, there is the possibility that new hybrids could have increased nutrient use efficiency which may reduce the reliance on nitrogen and its downstream negative impacts.

The need to irrigate pastures in many summer-dry regions due to the unsuitability of currently available ryegrass cultivars also has negative environmental impacts. The demand on our water resources is likely to increase with climate change. It is predicted that between 2030 and 2050, New Zealand’s regions will spend 5 to 20% more time in drought compared to the 20th century. For example, NIWA predicts that by 2050, the East Coast of the North Island will receive up to 15% less rainfall. The impact of drought on our water resource could be reduced by incorporating adaptability and persistence traits such as drought tolerance into the new breeding lines. This is essential as the roots in ryegrass are not deep enough to access water in lower layers of soil in drier regions.

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Application Form Approval to release a new organism

Ultimately, the ability to select for traits from wild relatives of ryegrass that are adapted to harsher environments will improve pasture persistence and could reduce the current dependency on irrigation, fertiliser and pesticides enabling more sustainable farming practices.

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Application Form Approval to release a new organism

Appendix 3. Summary of this application sent to Te Herenga

Summary of the application for the release of 19 new grass species that are relatives of perennial ryegrass (Lolium perenne)

Background

Exports produced from New Zealand pastures were worth $22.2 billion, that is over 43% of New Zealand’s export earnings, in 2014. The most frequently sown grasses in these pastures are the ryegrasses. Perennial ryegrass or Lolium perenne in particular generates $14 billion of value for New Zealand’s economy each year. To improve production and nutritional value, and reduce the vulnerability of New Zealand pastures to future pests, diseases and climate change, it is essential that an appropriate set of genetic resources from L. perenne and its wild relatives are available for research and development in New Zealand. This will allow researchers at AgResearch to cross-breed ryegrasses that are present in New Zealand with new grass species by naturally integrating beneficial traits into ryegrass cultivars (also called hybrids).

Currently only a few species of wild relatives of L. perenne are permitted in New Zealand. Without the introduction of new species New Zealand researchers will not have the genetic tools available to remain world leaders in plant breeding and pasture focussed research. The main factor in the continuing international competitiveness of the New Zealand livestock industry is the low cost of feed. In New Zealand, animals generally obtain their feed by grazing year round in pastures. However, feed costs are rising forcing New Zealand to continue innovating in order to stay ahead of the game. Our meat and dairy-based industries are competing in a global market place – one that is changing due to globalisation, free trade agreements and accelerated technological development. If we do not continue to invest in our future and greater productivity we risk losing the advantages that are critical when competing on a global stage.

Objective

We propose to release 19 new grass species closely related to perennial ryegrass and currently held in containment at AgResearch in Palmerston North for researchers to make hybrids between ryegrasses and their closely related relatives to test for traits that could improve productivity in the pasture environment. We would like to study the new hybrids under real pasture conditions to allow us to select the best cultivars for further development and commercialisation, something that we cannot achieve in containment.

The potential beneficial effects of the proposal to release 19 new grass species

The considerable challenges that our researchers face in obtaining and effectively evaluate novel genetic material cannot be understated. While sustainable farming and better management of the currently used forage species is one approach to keeping New Zealand’s agricultural sector internationally competitive, the ability of researchers to have access to important new genetic resources for plant breeding and research is essential to adapt plants to climate change and protect against diseases whilst still having a competitive edge in a global market.

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Application Form Approval to release a new organism

The impact of drought on New Zealand’s economy could be reduced by increasing the diversity of pastoral plants, especially by incorporating drought-tolerant traits from a new species into breeding lines. If we take $1.5 billion as a typical cost of a major drought and assume there is an average seven-year interval between such droughts, a modest 10% reduction in the impact of major droughts could be achieved due to greater pasture diversity by introducing drought-tolerant cultivars to New Zealand’s pastoral systems. That could be worth an average of about $20 million per annum of GDP.

The chance of a disease devastating New Zealand ryegrass in a similar way to Psa wiping out the gold variety kiwifruit Hort16A is difficult to estimate. However, a disease of ryegrass could affect ryegrass in New Zealand more than the 21% of kiwifruit that was affected by Psa and this greater impact could put the total cost of such an event into the tens of billions of dollars. Current ryegrass diseases such as crown rust are already reducing the dry matter yield in ryegrass by 37% and spring regrowth as much as 23% and stem rust reducing seed yield by 50% in Victoria, Australia. A similar scenario in New Zealand would be disastrous for the economy. Such an event could therefore have an economic impact on New Zealand an order of magnitude greater than the estimated $16 billion cost of a large foot and mouth outbreak because the value of ryegrass in New Zealand economy is estimated at $15 billion p.a.

The value of additional perennial ryegrass pasture production in the 2015/16 season varied from $0.17 to $0.45 per kg of dry matter (kgDM) for the upper North Island between seasons, with other regions having even wider variations in forage value over the year. Breeding new ryegrass cultivars for the upper North Island that had the same total production over the year as current varieties but had more production in early spring ($0.45/kgDM) and less in late spring ($0.17/kgDM) would add $0.28 to the value of every kilogram of dry matter production that was moved from late to early spring or $0.20 to the value of every kilogram of dry matter that was moved from late spring to either summer or autumn.

The majority of dairy and meat production on Māori land is heavily reliant on ryegrass which is not well adapted to NZ’s summer-dry hill country and dairy regions. For Māori Agribusiness to remain internationally competitive, the cost to produce stock feed must be kept down. The release of the proposed 19 grass species will enable the initial studies for the development of grasses more tolerant to disease, pests and drought which will lead to greater pasture production and persistence being of great economic value. Additionally, grasses requiring less nitrogen input, having minimal methane output and deeper root systems will deliver huge benefits to the environment as nitrogen leaching, methane emissions and soil erosion can potentially be reduced. This proposal contributes to kaitiakitanga by improving farm sustainability, as these hybrid grasses will be more tolerant to the NZ summer-dry farming environments therefore requiring less pasture renovation, less irrigation and less fertiliser input. In 2015, the FoMA farms alone (115,000 ha) applied over 29,000 tonnes of fertiliser, 7,000 tonnes of lime and dolomite and renovated almost 3,000 ha of pasture. Reducing these figures across all Māori land holdings will have significant economic and environmental benefits.

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Access to new grass germplasm will give researchers in New Zealand an opportunity to exploit the wild relatives of perennial ryegrass for traits of economic value, as well as adaptation to harsher environments and resistance to diseases.

The worst potential outcome to this proposal is an increase in New Zealand’s weed burden

There is a possibility that some cultivars developed from cross-breeding the 19 species in the application with perennial ryegrasses may show weedy traits. These cultivars once released in our environment may have adverse impacts on productive land and in native habitats if these cultivars grow unchecked in the environment. While the impact of weeds can be significant (for example, the impact of Californian thistle alone being estimated at about $700m p.a.) the potential adverse economic impacts of new cultivars are difficult to quantify. We note that the most economically valuable plant species in New Zealand is L. perenne ryegrass, valued at about $14 billion of value per year. Any future new cultivars developed via crosses between ryegrass and the new species in this application would complement this value rather than reduce it. Weed Scientists at AgResearch have assessed the new species as not being high risk weeds for other economically-important plants such as Pinus radiata, grapes or kiwifruit, the three main forestry and horticultural products in New Zealand. We will pay particular attention to the potential impact of the species in this application as weeds of maize, wheat and barley in coordination with scientists at Plant and Food Research before their cultivars are made available commercially. Furthermore, we believe the risk surrounding the introduction of these new species would be manageable, similar to that of the introduction of permitted grass species as the 19 species in this application are not close relatives of the endemic Fetuca (Tussock) species in New Zealand. Therefore, the new species cannot cross-breed with native grasses.

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Application Form Approval to release a new organism Appendix 4. WRA for the species of interest in this application, scored based on Australian dry conditions. Species F. altaica F. altissima F. caerulescens F. drymeja F. durandoi F. fontqueri F. kingii F. mairei F. paniculata F. pseudeskia F. pulchella F. scariosa F. spectabilis F. subulata F. triflora L. canariense L. persicum L. saxatile M. tuberosa F. arundinacea Lolium perenne C/name Author AS Biogeography/historical 1 1.01 Y N N N N N N Y N N N N N N N N N N N Y Y Domestication/cultivation 1.02 Y Y Y 1.03 N Y Y 2 2.01 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 Climate and distribution 2.02 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 2 2 2.03 Y N 2.04 N 2.05 N N N N N N N Y N N N N N N N N N N N Y Y 3 3.01 Y N N N N N N Y N N N N N N N Y N N Y Y Weed elsewhere 3.02 Y N 3.03 Y Y Y 3.04 Y Y Y 3.05 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y

Biology/Ecology 4 4.01 N N N N N N N N N N N N N N N N N N N N N Noxious traits 4.02 N N N N N N N N N N N N N N N N N N N N N 4.03 N N N N N N N N N N N N N N N N N N N N N 4.04 N N N N N N N N N N N N N N N N N N N N N 4.05 N N N N N N N N N N N N N N N N N N N N Y 4.06 N 4.07 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y 4.08 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y N 4.09 N N N N N N N N N N N N N N N N N N N N N 4.1 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y N 4.11 N N N N N N N N N N N N N N N N N N N N N 4.12 N N N N N N N N N N N N N N N N N N N N N 5 5.01 N N N N N N N N N N N N N N N N N N N N N Plant type 5.02 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y 5.03 N N N N N N N N N N N N N N N N N N N N N 5.04 N N N N N N N N N N N N N N N N N N N N N 6 6.01 N N N N N N N N N N N N N N N N N N N N Reproduction 6.02 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y 6.03 N N 6.04 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y N N N N N N 6.05 N N N N N N N N N N N N N N N N N N N N N 6.06 N N N N N N N N N N N N N N N N N N N Y N 6.07 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 7 7.01 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Dispersal 7.02 N N N N N N N N N N N N N N N N N N N N N 7.03 N N N N N N N N N N N N N N N N N N N Y Y 7.04 N N N N N N N N N N N N N N N N N N N N N 7.05 N N N N N N N N N N N N N N N N N N N N N 7.06 N N 7.07 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y 7.08 Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y Y 8 8.01 N N N N N N N N N N N N N N N N N N N N N Persistance 8.02 Y Y 8.03 Y N Y Y 8.04 N Y 8.05 Outcome Score 3 5 5 5 5 5 4 5 5 5 5 5 5 5 5 2.5 11 2.5 2.5 16 11 Statistics: score B/G 0 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1.5 9 1.5 1.5 14 10 U 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1 B/E 1 1 1 1 1 1 0 1 1 1 1 1 1 1 1 -1 0 -1 -1 0 0 count B/G 5 3 3 3 3 3 3 4 3 3 3 3 3 3 2 3 5 3 3 9 9 U 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 11 12 B/E 18 18 18 18 18 18 19 18 18 18 18 18 18 18 18 18 19 18 18 23 22 Tcount 34 32 32 32 32 32 33 33 32 32 32 32 32 32 31 32 35 32 32 43 43 agr 2 4 4 4 4 4 3 4 4 4 4 4 4 4 4 1.5 7 1.5 1.5 10 9 sector env 5 7 7 7 7 7 7 7 7 7 7 7 7 7 7 4.5 9 4.5 4.5 13 8

December 2013 EPA0322 SUPPLEMENTARY INFORMATION

-----Original Message----- From: Dave Hodges [mailto:[email protected]] Sent: Wednesday, 7 September 2016 1:59 p.m. To: Ghamkhar, Kioumars Subject: RE: Seeking letters of support for an application for releasing 19 grass species

Hi Koumars

Thanks for providing me the application summary and the chance to talk to you about it. After considering the information presented and discussed, I'm comfortable that AgResearch has considered the biosecurity risks of the proposal and have made amendments to reduce these risks compared to what was proposed in earlier drafts of the project.

At this point I’m happy to support the proposal.

Regards

Dave

Dave Hodges Project Manager, Biosecurity – Plants and Pests Research and Development DairyNZ Cnr Ruakura & Morrinsville Roads | Newstead | Private Bag 3221| Hamilton 3240 | NEW ZEALAND MOB +64 027 801 5921 | Web www.dairynz.co.nz | www.GoDairy.co.nz | www.getfresh.co.nz

-----Original Message----- From: Ghamkhar, Kioumars [mailto:[email protected]] Sent: Tuesday, 6 September, 2016 11:56 a.m. To: Dave Hodges Subject: RE: Seeking letters of support for an application for releasing 19 grass species

Hi Dave

Thank you for your interest.

I have attached the summary. Please let me know if you need more information.

Regards Kioumars

From: Ghamkhar, Kioumars [mailto:[email protected]] Sent: Monday, 22 August 2016 4:20 p.m. To: Lisa Harper; [email protected]; Subject: Seeking letters of support for an application for releasing 19 grass species

Dear all

I am finalising an application to EPA (summary attached) to release 18 wild relative species of tall fescue and perennial ryegrass for cross breeding with ryegrass and interspecific hybridisation for a future ready agriculture in NZ.

The final submission date will be in November and your letters of support for this application would be appreciated at that time.

Please read the attached document and let me know if you have any questions or whether you support this application.

Best regards Kioumars Ghamkhar (PhD, MSc, BSc Plant Evolutionary Genetics & DDP Business & Management) Director, Margot Forde Forage Germplasm Centre, Forage Science

[cid:[email protected]] T 64 6 351 8182 M +64 2179 8182 E [email protected] Grasslands Research Centre Tennent Drive, Private Bag 11008, Palmerston North 4442, New Zealand www.agresearch.co.nz SM facebook.com/agresearch twitter.com/AgResearchNEWS

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