Staff Assessment Report

APP201955: An application to release Tamarixia triozae as a biological control for the tomato potato psyllid (Bactericera cockerelli)

April 2016

Purpose To release from containment the psyllid parasitoid Tamarixia triozae into New Zealand to assist with the biological control of the tomato potato psyllid (Bactericera cockerelli)

Application number APP201955

Application type Notified, full release

Applicant Horticulture New Zealand Inc.

Date formally received 27 January 2016 2

EPA advice for application APP201955

Executive Summary and Recommendation

In January 2015, Horticulture New Zealand Inc. applied to the Environmental Protection Authority (EPA) to introduce the psyllid parasitoid Tamarixia triozae as a biological control agent (BCA) for the tomato potato psyllid (TPP; Bactericera cockerelli). The application was submitted on behalf of Potatoes New Zealand Inc., Tomatoes NZ Inc., Heinz-Wattie’s NZ Ltd, Vegetables NZ Inc., and NZ Tamarillo Growers Association Inc.

We examined the efficacy of T. triozae to control TPP and curb transmission of Candidatus Liberibacter solanacearum, the causal agent of Zebra Chip disease, to horticulture crop plants, and the beneficial and adverse effects on the environment, market economy and on Māori and their relationship to the environment.

Our assessment found that we consider it likely that the release of T. triozae will improve management of TPP which will support development of new integrated pest management (IPM) programmes. We consider it likely that IPM programmes will reduce applications of broad-spectrum insecticides which will improve the environmental impact of horticulture practices. We also consider the use of T. triozae will benefit Māori who use traditional (organic) pest control methods to cultivate taewa, kūmara and poroporo.

We consider reductions in costs to control TPP and Zebra Chip and improvements in yield and crop quality as a result of improved management of TPP to be important to future proof New Zealand’s horticulture industry. We considered the information presented in the application strongly suggests that there is likely to be benefits to the market economy from the release of T. triozae.

The applicant considered that the most significant adverse effects of releasing T. triozae are the risks of the parasitoid attacking and parasitizing native psyllids. The applicant presented evidence from host range testing which showed that two native psyllids in the same family as TPP are susceptible to attack. We consider the results to reveal that Trioza panacis is within the physiological host range of T. triozae, however, first–generation development tests showed that parasitoid offspring fitness is compromised by using T. panacis as a host. We argue that this is a low rank host which will not support successive generations of T. triozae.

We considered the mortality rate of the other impacted psyllid, T. curta, in the tests. We consider that mortality at the level predicted should be viewed in light of the test conditions and field conditions that T. triozae will encounter, as well as population dynamics of the psyllid in its natural habitat governed by its food plant preferences.

We consider that T. triozae will not actively seek out non-target native psyllids anywhere in New Zealand since the parasitoid uses a number of cues to locate TPP. TPP and native psyllids do not share the same host plants and therefore are not commonly found in the same habitat. This creates environmental refuges for native psyllids who are predominantly found in native unmodified habitats away from intensively manged habitats. We note that despite the potential for T. triozae to encounter non-target psyllids in environments that border horticulture crops it is unlikely for the parasitoid to have significant adverse effects on native psyllids.

April 2016 3

EPA advice for application APP201955

After completing our risk assessment and reviewing available information, we consider that the cumulative adverse effects of releasing T. triozae to control TPP are negligible and the cumulative benefits significant.

We consider that T. triozae meets the minimum standards as stated in the HSNO Act.

We recommend that the application be approved.

April 2016 4

EPA advice for application APP201955

Table of Contents

Executive Summary and Recommendation ...... 2 Table of Contents ...... 4 1. Purpose of this document ...... 6 2. Application process ...... 6 3. Submissions ...... 6 4. Submissions from DOC and MPI ...... 7 5. Background on the target pest - TPP ...... 8 Tomato potato psyllid and the pathogen it vectors are serious threats to plants of economic value in the solanaceous family ...... 8 6. Description of organism proposed to be introduced ...... 12 7. Risk assessment assumptions ...... 14 8. Assessment of the potential benefits and positive effects of introducing T. triozae ...... 15 Potential beneficial effects of T. triozae through reducing TPP pressure ...... 15 Potential benefits to New Zealand’s market economy by releasing T. triozae and reducing the effects of TPP and Zebra Chip ...... 19 9. Assessment of the potential risks and costs associated with the introduction of T. triozae ...... 24 Understanding the host range of T. triozae ...... 24 Our assessment of the potential risks and costs to native and beneficial psyllids from the release of T. triozae ...... 32 10. Our assessment of the potential indirect adverse effects on ecosystem functions such as food webs ...... 35 TPP as a shared resource ...... 35 Hyperparasitism of T. triozae and the effects of ‘apparent competition’ ...... 35 Tamarixia triozae as a vector or source of disease ...... 37 Potential for hybridisation ...... 37 Our conclusion of the potential indirect adverse effects...... 37 11. Conclusion on benefits and risks assessment ...... 38 12. Relationship of Māori to the environment ...... 39 13. Minimum Standards ...... 45 Consideration of whether T. troizae is likely to cause any significant displacement of any native species within its natural habitat ...... 45 Consideration of whether T. triozae is likely to cause any significant deterioration of natural habitats ...... 46

April 2016 5

EPA advice for application APP201955

Consideration of whether T. triozae is likely to cause any significant adverse effects on human health and safety ...... 46 Consideration of whether T. triozae is likely to cause any significant adverse effect to New Zealand’s inherent genetic diversity ...... 46 Consideration of whether T. triozae is likely to cause disease, be parasitic, or become a vector for human, animal or plant disease ...... 47 Conclusion on the minimum standards ...... 47 14. Recommendation ...... 47 15. References ...... 48 Appendix 2: Submission from Department of Conservation ...... 68

April 2016 6

EPA advice for application APP201955

1. Purpose of this document

On 27 January 2016, Horticulture New Zealand Inc. applied to the Environmental Protection Authority (EPA) to introduce the psyllid parasitoid Tamarixia triozae as a biological control agent (BCA) for the tomato potato psyllid (TPP; Bactericera cockerelli).

The application was submitted on behalf of the potato, tomato (greenhouse and field tomatoes), capsicum and tamarillo industries represented by Potatoes New Zealand Inc., Tomatoes NZ Inc., Heinz-Wattie’s NZ Ltd, Vegetables NZ Inc., and NZ Tamarillo Growers Association Inc.

This document has been prepared by EPA staff to advise the Decision-making Committee on our risk assessment for the release of T. triozae. The document discusses the information provided in the application, information readily available in scientific literature, and information submitted to the EPA via public submissions.

2. Application process

Horticulture New Zealand Inc. lodged an application with the EPA seeking approval to release T. triozae under section 34 of the Hazardous Substances and New Organisms (HSNO) Act (the Act).

The application was publicly notified and opened for submissions on 11 February 2016, for 30 working days as required by section 53(1)(b) of the Act.

3. Submissions

The EPA received 36 submissions. Thirty-two submitters are in support, two submitters oppose and two submitters neither supported nor opposed the application. Ten submitters indicated that they wish to be heard in support of their submission at a hearing (Table 1). Table 1: Summary of submitters that wish to speak to their submissions at a hearing Submitter Position

Ngāi Tahu HSNO Komiti Support

Kovati-Tam Yam Gardens (R. & E. Kovati) Support

New Zealand Hothouse (L. Dillon) Support

Ngāpuhi HSNO Komiti Oppose

Nortona Ltd (T. Norton) Support

New Zealand Hothouse (S. Watson) Support

Stuart Attwood Support

Department of Conservation (V. Forbes and C. Green) Oppose

Tāhuri Whenua Inc. (National Māori Vegetable Growers Collective) (N. Neither support nor oppose Roskruge)

April 2016 7

EPA advice for application APP201955

Submitter Position

Turners & Growers Global Ltd (B. Smith) Support

A summary of submissions received is appended in Appendix 1.

4. Submissions from DOC and MPI

As required by the Act and the Hazardous Substances and New Organisms (Methodology) Order 1998, the Ministry for Primary Industries (MPI) and the Department of Conservation (DOC) were notified of the application and provided with the opportunity to comment.

MPI did not make any comments on the application.

DOC opposes the application because they consider T. triozae does not meet the minimum standards. DOC notes that, on balance, they agree that the host testing completed indicates that all known native species within the Psyllidae family are unlikely to be adversely affected by T. triozae. However, they are concerned for the psyllids in the family Triozidae. They note that there are 50 endemic species within the family Triozidae, and are concerned that T. triozae could establish in areas where Triozidae species are found given their distribution overlaps with TPP. DOC did not consider the host testing to be sufficient to confidently state that Trioza panacis may be the only endemic psyllid in the family Triozidae that is likely to be vulnerable to T. triozae parasitism. DOC states that endemic species are particularly significant for their biodiversity and scientific value, and because they are unique.

DOC further submitted that they would expect to see a comprehensive analysis of host plant identification and distribution for crop and non-crop species. DOC’s full submission can be found in Appendix 2.

April 2016 8

EPA advice for application APP201955

5. Background on the target pest - TPP Tomato potato psyllid and the pathogen it vectors are serious threats to plants of economic value in the solanaceous family

Distribution of TTP Tomato potato psyllid (TPP) Bactericera cockerelli (Sulc) (Hemiptera: Triozidae) is endemic to North America and is distributed throughout the central, south and north-western United States, central and western Canadian provinces as well as Mexico. The organism is also present in a number of Central American countries (Butler and Trumble 2012).

TPP was first reported in New Zealand, in tomato glasshouses in South Auckland, in April 2006 and was considered to be established throughout solanaceous crop growing areas of the North Island and in specific regions of the South Island by 2011 (Thomas, Jones et al. 2011). The spread of TPP within New Zealand is likely due to a combination of natural and human mediated dispersal (Teulon, Workman et al. 2009).

A paper presented at the 2015 New Zealand Plant Protection Society meeting noted that the numbers of TPP trapped on yellow sticky traps placed in potato fields in Canterbury each week between January and February have increased from less than five TPP/trap/week in 2008 to more than 35 TPP/trap/week in 2015 (Vereijssen, Barnes et al. 2015). The reasons for the increase in TPP pressure in Canterbury are not clear and further research is delving into local TPP population dynamics and landscape ecology.

A paper published by the then Ministry of Agriculture and Forestry considered that TPP might plausibly have been introduced by the smuggling of primary host material into New Zealand that bypassed the biosecurity system (Thomas, Jones et al. 2011).

Biology of TTP TPP is a polyphagous insect that is able to ovipost and complete life cycles on about 40 host species. The importance of host plants to TPP relates to abundance, preference and proximity to agriculture areas (Wallis 1955 in Butler and Trumble 2012). TPP prefers plant species in the Solanaceae family (also known as the nightshades), an economically important family of flowering plants, including annual and perennial herbs, shrubs and trees. Solanaceous crops generally refer to the genera Solanum (eggplant and potato), Lycopersicon (tomato) and Capsicum (peppers).

TPP is known to feed, oviposit and complete life cycles on crop plants during the summer growing season and overwinter on non-crop evergreen host plants that grow in proximity to production areas.

TPP has three life stages: egg, nymph and adult. Eggs are deposited on the upper and lower surfaces of leaves of host plants, and take 3-15 days to hatch. The nymph has five instars and development can vary from 12-44 days (average 15.4 days). The first four instars can take 2.4 – 2.8 days to complete and the fifth instar averages 4.9 days (Yang and Liu 2009). The nymphs prefer the lower

April 2016 9

EPA advice for application APP201955

surface of the leaf (abaxial) and seldom move from that position (Lehman 1930 in Butler and Trumble 2012) (Figure 1). An adult can live between 19 and 97 days depending on temperature, host plant, sex, and geographic origin of populations. TPP uses odorant sex attraction to mate and adult females can lay eggs three days after emergence. The oviposition period lasts 21.5-27.8 days during which females produce fertile eggs after a single mating. A female can lay an average up to 330 eggs over her lifetime (Knowlton and Janes 1930 in Butler and Trumble 2012).

TPP is adapted to survive in warm but not hot temperatures. Both adults and nymphs are cold tolerant. In North America, TPP migrates north from its overwintering and breeding areas in the south into the north-western states of the USA and Canada to escape hot temperatures. Cool weather during migrations has been associated with outbreaks of the insect (Munyaneza 2012).

TPP are phloem feeders. Phloem is the vascular tissue responsible for the transportation of sugars from photosynthetic leaf cells to non-photosynthetic root cells. Adult TPP feed primarily on the underside of leaves of their host plants (Butler and Trumble 2012).

Figure 1 TPP nymphs on the abaxial surface of a potato plant leaf (photo credit: Ward Stepman, BCP Ltd)

TTP causes disease The feeding by TPP adults and nymphs on their host plants causes a disease called “psyllid yellows” when the insect injects saliva into the plant. This disease is systemic which can infect the whole plant. Symptoms of psyllid yellows include reduction in growth, yellowing of leaf edges, upward cupping of leaves, enlarged nodes, aerial tubers, premature senescence and plant death (Butler and Trumble 2012). Tomato and potato plants affected by the psyllid yellows can exhibit up to an 80% decrease in yields (Liu and Trumble 2007). Figure 2 compares healthy potato leaves with psyllid yellows affected potato plants.

April 2016 10

EPA advice for application APP201955

Figure 2: Health potato foliage on the left and psyllid yellows affected potato foliage on the right (photo credit: Sally Anderson)

TTP is a vector for disease The causes of a disease that was first characterised by symptoms that develop in potato tubers, including browning of vascular tissue, necrotic flecking of internal tissues and streaking of the medullary ray tissues, was unknown until 2008. The disease is known as Zebra Chip and studies in the US and New Zealand showed that it is associated with a previously undescribed species of bacterium, Candidatus Liberibacter solanacearum, referred to as Lso. This bacterium was found to inhabit the phloem of plants that showed feeding activity by TPP. Studies confirmed the link between TPP and Lso and the pathogen was shown to be transmitted to TPP both vertically (transovarially from infected parent to offspring) and horizontally (from feeding on infected plant hosts) (Munyaneza 2012).

TPP is a natural vector of the bacterium Lso (Liefting et al. 2009 in Thomas, Jones et al. 2011). Since Lso was first identified to be the causal agent of Zebra Chip in potatoes, multiple studies have documented Lso infection in other solanaceous crop and non-crop plants, including tomato, tamarillo and black nightshade (Butler and Trumble 2012).

Current strategies to control TPP and Zebra Chip There are currently limited strategies available to control TPP and Zebra Chip.

All management strategies for Zebra Chip are targeted against TPP. Monitoring of the insect is essential to effective management of the pest and the disease it spreads (Munyaneza 2012). Daniel Sutton of Fruitfed Supplies submitted that there has been greater focus on monitoring and tracking of populations of TPP in crops (submission 111660; Appendix 1). This entails the weekly replacement and analysis of yellow sticky traps around the edge of the crop and inspection of plants to record numbers and life stages of TPP. The continued monitoring is important to garner greater understanding of the insect. Mr Sutton further noted that though the greater understanding has helped the industry to consider biological control tactics, the impact of TPP has necessitated the application of insecticides at least once per week for the majority of the crop life.

April 2016 11

EPA advice for application APP201955

TPP is commonly controlled by insecticide application. A number of authors have noted that even with insecticides the psyllid is difficult to manage because it is hard to get good coverage, especially with contact insecticides, which is important since psyllids are generally found on the underside of leaves (Nansen, Vaughn et al. 2010, Butler and Trumble 2012).

Studies on the effectiveness of different types of insecticides showed that the widely used broad- spectrum insecticides imidacloprid, thiamethoxam (neonicotenoids) and abamectin had the highest and consistent rate of TPP knockdown effects in potato plants (Gharalari, Nansen et al. 2009, Butler, Byrne et al. 2011, Prager, Vindiola et al. 2013). Multiple foliar applications per calendar year of neonicotenoid insecticides per growing season (averaging 9.5 applications per growing season) are required to manage TPP and Zebra Chip in potato fields in some states of the US (Lewis, Bible et al. 2013). There are at least another 10 insecticides that are routinely used to control TPP. They are predominantly broad-spectrum but harbour different toxicity profiles. The effects of these insecticides on T. triozae were tested in a laboratory study (Liu, Zhang et al. 2012). The study found that some of the most common used chemicals had the most significant deleterious effects on T. triozae and other beneficial insects which makes them the least useful in integrated pest management (IPM) programmes against TPP. In comparison, insecticides with lower toxicity profiles had less harmful effects on the parasitoid BCA and have potential for use in IPM programmes.

A number of submitters have noted their concern regarding the impact broad-spectrum insecticides have on beneficial organisms in crops (including other BCAs), in addition to the effects of resistance to widely used chemistry and effects of insecticide residues on export market access (see Appendix 1). This issue of TPP building resistance against neonicotinoid pesticides was also reported by Liu et al. (2012) and Prager et al. (2013).

The use of predatory beneficial organisms already present in horticulture crops are increasingly being recognised as important agents against TPP in New Zealand. Spiders, brown lacewings, small hover flies and 11-spotted ladybirds were recorded in potato fields in South Auckland feeding on TPP nymphs (MacDonald, Walker et al. 2010). The optimal use of these naturally occurring agents relies on conservation practice by which broad-spectrum insecticide use is minimised when predatory insect populations are at their highest. Predator numbers are highest in the early summer and may provide control of TPP in its early infestation phase into crops. Predator numbers decline in mid to late summer in potato fields and therefore may not provide sustained control when TPP is at its highest infestation levels (Walker, MacDonald et al. 2011).

There are also several fungi that are known to attack TPP. Commercial formulations of entomopathogenic fungi were tested against TPP and researchers found significantly reduced plant damage and symptoms of Zebra Chip in potato plants (Lacey, Liu et al. 2011). Entomopathogens could be utilised as part of an integrated system that include other tools to manage TPP, however, their compatibly with non-target organisms such as predators and parasitoids of TPP must be considered within the context of an IPM programme (Mauchline, Stannard et al. 2013).

April 2016 12

EPA advice for application APP201955

6. Description of organism proposed to be introduced

The organism proposed to be introduced to help control TPP and Zebra Chip is Tamarixia triozae (Burks) (Hymenoptera: Eulophidae). It is a primary parasitoid of TPP in the USA and Mexico.

Tamarixia triozae is an idiobiont parasitoid because it prevents the further development of TPP nymphs to its next instar after initial parasitisation. The wasp attacks fourth to fifth instar TPP nymphs using its ovipositor and then deposits eggs on the ventral surface of the nymphs (Rojas, Rodríguez- Leyva et al. 2014). When an egg hatches, the T. triozae larva develops externally on the surface of the nymph feeding on the underside whilst it excavates the inside of the body of the nymph, it then pupates inside the empty cavity to emerge as an adult wasp. The total development time (egg to larva to pupa to adult) for females were 12 days and for males 11.6 days.

Tamarixia triozae females are reproductively fertile between 12 and 29 days. In laboratory studies females laid an average of 165.4 eggs over that time (range 98 – 279) and the sex ratio favoured females (86%). The mean number of eggs laid per day per female over her lifetime was 7.7. Each female parasitized between 85 and 241 nymphs during her lifetime (Rojas, Rodríguez-Leyva et al. 2014).

The parasitoid also feeds on TPP to obtain protein for egg production. In another study, T. triozae females fed on an average of 181 TPP nymphs and laid 130 eggs during their life span (Ceron- Gonzalez et al. 2014 in Rojas et al. 2014).

Tamarixia triozae has been cited as one of the most abundant parasitoids of TPP in field samples from the USA and Mexico (references in (Rojas, Rodríguez-Leyva et al. 2014).

Distribution and capacity of Tamarixia triozae to establish in New Zealand The parasitoid is found in the mid-west of the United States and central Mexico thus has a preference for warm to hot and drier environments (Zuparko, De Queiroz et al. 2011).

A report commission by the New Zealand Tamarillo Growers Association, Potatoes NZ and Heinz- Watties NZ into the ability of T. triozae to establish here in New Zealand noted that survival in dry environments do not necessarily preclude survival in more moist environments (Logan and Gardner- Gee 2012). The report also noted that TPP shares a similar distribution in North America to T. triozae and thus may be considered to prefer similar conditions. In New Zealand however, TPP is found in areas that are wetter than the mid-west of the United States and Mexico. The report mentions that T. triozae is tolerant of colder temperatures (-5°C and below) based on collection localities at higher altitudes in the USA. The wasp may enter a diapause phase to survive chilling conditions.

Logan and Gardner-Gee (2012) modelled the potential establishment and distribution of T. triozae in New Zealand using models that consider alternative responses to temperature and moisture. The researchers noted that there was minimal developmental data available in literature to use in models therefore they relied on life history data of another Tamarixia species that has a similar geographic span as T. triozae and laboratory data from Rojas (published in 2014) conducted at a single

April 2016 13

EPA advice for application APP201955

temperature (26°C). The models indicated that the east coast of the South Island is probably suitable for T. triozae. It is probable that the wasp can also establish in areas of the east coast of the North Island, particularly Hawke’s Bay, the Auckland region, Waikato and Manawatu when the lack of tolerance of T. triozae to moist conditions is relaxed.

April 2016 14

EPA advice for application APP201955

7. Risk assessment assumptions

Our assessment of the benefits and risks associated with the release of T. triozae to control TPP is based on the assumption that the parasotoid will successfully establish in the New Zealand environment and develop self-sustaining populations.

If T. triozae does not establish in New Zealand there is no risk. Conversely, if T. triozae establishes large populations, the frequency of potential risks, discussed in our assessment below, increases. At the same time, the benefits will also increase with larger populations since the parasitoid will need to reach high numbers to cause optimum damage to TPP in order to be beneficial. Therefore an assessment made on full establishment makes it easier for us to determine if the benefits truly outweigh the risks, or vice versa.

April 2016 15

EPA advice for application APP201955

8. Assessment of the potential benefits and positive effects of introducing T. triozae

The applicant identified the following benefits from the release of T. triozae to be used as a biocontrol agent of TPP:  reduction of TPP in New Zealand which will reduce pest and disease (via Lso transmission) pressures on tomato, potato, capsicum and tamarillo crops,  improved IPM programmes for the affected horticulture crops by using natural enemies of TPP, including T. triozae, in combination with insect-compatible chemicals,  reduced reliance on broad-spectrum insecticides to control TPP in the horticulture industry,  Māori will retain the ability to grow taewa, kūmara and poroporo crops for amenity and cultural reasons, allowing a return to traditional and/or organic cultivation methods,  economic benefits to the horticulture industry by reducing the cost of chemical control, savings in vegetable yields and quality losses due to TPP damage and Zebra Chip disease, and better returns to growers overall.

We developed impact pathways to guide our assessment of the potential positive effects that the introduction of T. triozae to New Zealand might have. The pathways demonstrate what we consider to be the ultimate benefits that may follow the introduction of T. triozae (see Figure 3).

Figure 3: Our assessment pathway to demonstrate the ultimate positive effects that may follow the release and establishment of T. triozae

Potential beneficial effects of T. triozae through reducing TPP pressure

The applicant proposed that Tamarixia triozae will assist with controlling TPP in tomato, potato, capsicum and tamarillo crops, which will improve management of TPP-related damage and Zebra

April 2016 16

EPA advice for application APP201955

Chip disease in the New Zealand horticulture industry. They provided reasons why they believe the benefits from releasing T. triozae will occur and contended that the benefits will be significant.

We assessed the efficacy of T. triozae in parasitizing TPP to establish whether the proposed benefits will occur, and the level of benefits that may eventuate.

We have reviewed the literature and note that there is limited information available on the efficacy of T. triozae available. Tamarixia triozae is not currently used in formal biological control programmes anywhere and most information on parasitism levels are obtained from observations in its native habitat, from laboratory studies and from assessing success rates using other Tamarixia wasps in biocontrol programmes elsewhere.

In the past, T. triozae has demonstrated effective control of TPP in capsicum greenhouse crops in Canada in augmentative releases. Tamarixia triozae was released, often in large numbers, over a growing season in 2001 and 2002 (Workman and Whiteman 2009). Pest pressure by TPP decreased significantly in British Columbia greenhouses during 2002 and 2003 so that T. triozae releases were discontinued in 2003 (Mason and Gillespie 2013). Data on the percentage of TPP mortality due to T. triozae parasitism is not available in the literature.

In its native range, parasitism levels of TPP in tomato, capsicum and potato crops in Southern California and Texas were less than 20% in 2009/2010, whilst parasitism rates varied between 70 and 80% in horticultural crops in Mexico where insecticides were not extensively used (Butler and Trumble 2012, Liu, Zhang et al. 2012, Rojas, Rodríguez-Leyva et al. 2014).

Laboratory-based host range testing performed in New Zealand showed that predicted mortality of immature TPP insects from attack by T. triozae varied between 26 and 35%, compared to mortality rates of up to 7% due to other causes (Gardner-Gee 2012).

Tomato potato psyllid is known to use evergreen perennial non-crop plants in the Solanaceae family including poroporo and weedy plants such as African boxthorn (Lycium), Jimson weed (Datura stramonium) and apple-of-Peru (Nicandra) as alternative hosts, which can support various life stages of the psyllid during autumn to spring (Martin 2008, Butler and Trumble 2012, Vereijssen, Jorgenson et al. 2013). These non-crop plants can often be found in shelter belts, field margins and other modified areas in close proximity to potato, tomato, capsicum and tamarillo crops, which make these host plants ideal for sustaining TPP levels into the growing season (Vereijssen, Jorgenson et al. 2013).

We consider that parasitism of TPP by T. triozae on these non-crop plants will greatly benefit the control of TPP during the winter months by supressing the number of psyllids that overwinter in shelter belts and other modified and natural environments that border crop environments, such as field margins, weed stands, shrub areas and forest remnants. This will reduce the number of psyllids that migrate into horticulture crops in summer.

April 2016 17

EPA advice for application APP201955

We consider that life history parameters of T. triozae show that the parasitoid has almost twice the potential for population increases compared to TPP (Rojas, Rodríguez-Leyva et al. 2014). This suggests that the parasitoid can build to large self-sustaining populations on TPP as it has faster generation times (i.e. the average time span between two consecutive generations) and population doubling times than TPP. This shows good potential for T. triozae to become an effective biocontrol agent against TPP.

We consider that T. triozae will be successful in curbing the transmission of the bacterium Lso (Candidatus Liberibacter solanacearum), the causal agent of Zebra Chip disease, by parasitizing immature TPP insects that may have acquired the disease via transovarial transmission. This will reduce the number of Lso-infected TPP adults that will be searching for new host plants.

We reviewed the results of biocontrol programmes where other Tamarixia species were released to control pest insects. Tamarixia radiata was first released in 2011 in southern California to control its host, Asian citrus psyllid, a pest of citrus orchards. Post release assessments, at 11 sites comprising orange, lemon, lime and grapefruit trees where the parasotoids were first released, were undertaken between 2011 and 2014. The researchers found that Tamarixia appeared to have established in southern California and is likely controlling psyllid numbers in citrus orchards. They found parasitism rates to vary greatly across study sites - as low as 15% at some sites and as high as 60% at other sites. The researchers noted that Argentine ants may play a role in predating T. radiata when it attempts to parasitise immature psyllid insects, thus hindering biocontrol efforts at some sites (Kistner and Hoddle 2015).

We consider that, based on the information currently available, T. triozae is likely to be a viable biocontrol agent for TPP and that release of the wasp has potential to significantly aid in the horticulture industry’s efforts against this pest. The next section will elaborate on some of these benefits, including the development of IPM programmes that are beneficial to affected growers by reducing the need for reliance on cost-prohibitive broad-spectrum insecticides and improving environmental impacts.

Benefits of increased use of Integrated Pest Management (IPM) for potato, tomato, capsicum, and other solanaceous crops We consider that the horticulture industry in New Zealand is supportive of environmentally conscious IPM programmes and that this parasitoid will allow for better TPP management later in the growing season when the numbers of generalist predators of TPP decline, and when used in conjunction with insecticides with lower toxicity profiles. The use of natural enemies is currently curtailed by the need to control TPP using broad-spectrum insecticides.

We note growers who are facing damage caused by TPP and Zebra Chip support the release of T. triozae and integration of the parasitoid in integrated pest management programmes to control this pest, as well as other pests.

April 2016 18

EPA advice for application APP201955

Simon Watson (Managing Director, NZ Hothouse Ltd) submitted that the release of T. triozae will allow growers to return to their preferred pest control method which is IPM. Mr Watson further submitted that “IPM is a much more sustainable and environmentally friendly method of pest control”. He noted that IPM will result in improved environmental outcomes through reduction in reliance on broad-spectrum insecticides and use of selective chemistry that is compatible with IPM. Broad-spectrum chemistry is increasingly losing efficacy as more pests develop resistance to those currently licenced for use in New Zealand. Mr Watson stipulated that “the introduction of Tamarixia would remove the efficacy issue and provide a much stronger platform for growers to operate their IPM platforms”. He also noted that broad-spectrum pesticide residues on produce can adversely affect access to our export markets (submission 111656; Appendix 1).

Daniel Sutton of Fruitfed Supplies submitted that the change to using broad-spectrum insecticides following the establishment of TPP in New Zealand has had a negative impact on many non-target organisms, many of which can offer biological control functions in crops (submission 111660; Appendix 1).

A number of other submitters also commented on the advantages that IPM offers and that T. triozae will afford growers an opportunity to return to IPM practices (Appendix 1). We consider that the horticulture industry not only recognises but needs the market and environmental values that IPM offers. Enabling the industry to manage TPP and other pests of horticulture crops with techniques that lower the chemical burden on the environment is a shared goal of growers and industry representatives.

We consider that the release of T. triozae will assist to re-establish IPM in TPP affected crops with the development of new IPM programmes leading to reductions in broad-spectrum insecticide use.

Benefits to amenity gardeners and cultivation for cultural use Tomato potato psyllid and the Zebra Chip disease it vectors have had a devastating effect on commercial Māori potato or taewa growing units (such as marae gardeners in the North Island) with crop losses up to 90%. This has culminated in the inability to supply taewa for cultural use, economic gain or as carry over seed tubers for future seasons (Puketapu and Roskruge 2011).

Taewa are traditionally grown without pesticide application, and uses fertiliser that is made from compost which makes it especially vulnerable to TPP infestation.

Kūmara and poroporo (an uncultivated crop with uses such as flavouring in hangi) are also susceptible to TPP.

We note the applicant has consulted with a number of iwi/Māori groups directly, as well as the EPA’s Te Herenga network. The applicant received responses from Ngāi Tahu, Ngāpuhi, Tāhuri Whenua and Ngāti Whātua Ōrāki. There were positive responses from all groups. Ngāpuhi and Ngāti Whātua Ōrāki, in particular, noted that they support the application to release T. triozae, and back control strategies that use “softer chemicals”, therefore reducing the need for broad-spectrum insecticides.

April 2016 19

EPA advice for application APP201955

Ngāti Whātua Ōrāki also noted that this biocontrol programme will have a significant economic impact (to assist with the fight against TPP). Ngūpuhi subsequently submitted to the EPA that they request the applicant to provide further evidence that risks to Māori have been fully investigated.

We consider that the release of T. triozae will help growers of traditional Māori solanaceous crops to control TPP, allowing Māori and other amenity gardeners to return to traditional and organic control methods.

Conclusions on the benefits of using T. triozae to control TPP We consider it likely that the release of T. triozae will improve management of TPP. This will support development of new IPM programmes to be introduced to mitigate TPP pressures on affected horticulture crops. We also consider it likely that such IPM programmes will reduce the application of broad-spectrum insecticides which will improve the environmental impact of horticultural practices, in addition to providing benefits to traditional Māori food growers. We consider the magnitude of the beneficial effects using T. triozae as a biocontrol agent against TPP to be minor to moderate that is dependent on levels of parasitism and reductions in transmission of Lso to healthy plants. Furthermore, the environmental impacts of using this biological control agent in an IPM programme will have differing local and regional benefits depending on the intensity of insecticide use by horticulture farmers. We consider that there will be significant benefits from using T. triozae as a biocontrol agent. Potential benefits to New Zealand’s market economy by releasing T. triozae and reducing the effects of TPP and Zebra Chip

The applicant proposed economic benefits of TPP biocontrol including reduced control costs, reduced yield and quality losses, and increased prices per kilogram through the production of high quality crops. The potential for the horticulture industry to reduce the use of pesticides to control TPP, which would enable them to introduce cost-effective ‘soft chemicals’ and natural enemies into their pest management programmes, is also considered an important underpinning economic factor for growers.

The applicant further noted that there are also other indirect economic benefits that are less quantifiable such as increase in export growth for horticultural industries, opportunities for these industries to contribute to local and regional economies, and so on.

We considered the economic impact that TPP/Zebra Chip has on the potato, tomato and capsicum industries. Potato growers surveyed in 2011 noted that the pest has elevated the costs of production and has had a destabilising effect on the industry (Kale 2011). The cost to growers is an additional $21.6m per year, which includes costs related to impacts on crops (including reduced yield, raw material downgrading, and costs incurred to make up for losses), control costs (additional insecticide use, spray applications), and other psyllid related expenses such as an increase in seed costs and a detrimental impact on markets. The costs to potato processors and seed industries due to the impact of TPP are $5.3m per year. Potatoes New Zealand estimated that approximately $1m is required for

April 2016 20

EPA advice for application APP201955

research into TPP and other costs additional to the research funded by voluntary contributions of growers.

Eight tomato (53% of glasshouse tomato industry) and six capsicum (78% of capsicum industry) growers were surveyed in 2011 regarding the impact of TPP on their industries (Market Access Solutionz Ltd 2011). Estimated economic impacts on the glasshouse tomato and capsicum industries were $3.9 to $16.8m and $1.3m per annum, respectively, due to lost income from quality impacts and increase in costs associated with spraying and pest monitoring. These economic impacts were considered to be approximately 5% and 2.1% of the value of the two industries, respectively.

The EPA received 23 submissions from growers and grower organisations that provided evidence to demonstrate the magnitude of the adverse economic effects TPP has had on the horticulture industry (Appendix 1). Most submitters noted that since TPP established in their crops their businesses have suffered crop losses which have negatively affected crop quality and led to reduced yields. They also noted that TPP has resulted in increasing costs as they are forced to use broad-spectrum insecticides more regularly to control TPP’s effects. A number of submitters pointed out that TPP is having an adverse impact on their export market.

Stuart Attwood (Southern Paprika Ltd) noted that “any TPP incidence in the glasshouse becomes a risk for market access to our overseas trading partners” (submission 111663). Tony Hendrikse (Eurogrow Potatoes Ltd) submitted that New Caledonia cancelled an order for seed potatoes this year due to their perceived risk of the introduction of TPP or Lso. He noted that the value of that order is worth FOB $260,000 annually (submission 111641). Simon Watson (Managing Director, NZ Hothouse Ltd) submitted that the NZ Hothouse Group of companies operates business throughout the Pacific, Asia and Australasia. Mr Watson maintained that having access to a biocontrol agent (T. triozae) will mean that they are able to grow their export business by being able to offer produce that has “far lower” levels of agrichemicals. Table 2 shows an overview of growers that supplied details of the size of their operations, losses and cost incurred due to TPP. Table 2: Summary of submissions that supplied data of the size of grower operations, losses and costs incurred since TPP and Zebra Chip established in New Zealand Number of Increases in Number of local/regional Losses/reductions costs (monitor Business/Submitter direct service due to TPP and & control of employees providers; spend Zebra Chip TPP) on vendors

47% (seed costs; Eurogrow Potatoes 5 - 30% (seed sales) from 2008 to 2016)

Tam Yam - 12 - -

April 2016 21

EPA advice for application APP201955

Number of Increases in Number of local/regional Losses/reductions costs (monitor Business/Submitter direct service due to TPP and & control of employees providers; spend Zebra Chip TPP) on vendors

25% (crop losses per 15; spends approx. $600/ha per year year); 30% in yield $2m per year on more for Gropak Ltd 16 loss (approx. equipment and pesticides than $350,000 in annual services in the region before TPP lost production)

60% (crop losses per Hohepa Homes - - - year)

4; spends approx. $900/ha per year $1.5m per year on more for Hira Bhana & Co Ltd 50 equipment and pesticides than services before TPP

20% (crop losses per $600/ha per year year); 15% in yield 2; spends approx. more for Clint Smythe 10 loss (approx. $50,000 $500,000 per year pesticides than in annual lost before TPP production)

Numerous service providers in the 20% (crop losses per Underglass Karaka Ltd region; affiliated year); 5-10% in yield and Underglass 190 companies (150-180 loss ($1.8m - $3.0m - Bombay Ltd (NZ staff) in in annual lost Hothouse Group) administration, production) packing and logistics

Spends approx. $25,000 per annum on crop scouting 5% (crop loss per $800/ha per year services of local year); 5% in yield loss more for A S Wilcox 170 suppliers and $5,000 ($500,000 in annual pesticides than per annum on trials lost production) before TPP on best management practices

8 tonne per acre crop $1,200/ha per Spends approx. loss per year; 30% in year more for Corbett Bros 10 $200,000 per annum yield loss ($800,000 pesticides than within the region in annual lost before TPP production)

10% (crop loss per $500/ha per year 2; spends approx. year); 10% in yield more for Growing Fare 2 $20,000 per annum loss ($5,000 in annual pesticides than within the region lost production) before TPP

April 2016 22

EPA advice for application APP201955

Number of Increases in Number of local/regional Losses/reductions costs (monitor Business/Submitter direct service due to TPP and & control of employees providers; spend Zebra Chip TPP) on vendors

40% (crop loss per $500-700/ha per 2; spends approx. year); 15% in yield year more for Freshpik Farms Ltd 4 $100,000 per annum loss ($250,000 in pesticides than in the region annual lost before TPP production)

10% (crop loss per Curious Croppers 4 - - year)

$400/ha per year Spends approx. 15% in yield loss more for Midway Farm Darfield 7 $800,00 per annum ($300,000 in annual pesticide than in the region lost production) before TPP

Independent economic assessment The New Zealand Institute of Economic Research (NZIER) performed an assessment of the economic benefits and costs of T. triozae to the affected industries (Nixon 2014). The NZIER determined that the total quantifiable benefits to the potato, tomato, capsicum and tamarillo industries to be between $7.8m and $24.9m per annum over 20 years to reflect the long term impacts of introducing T. triozae. This was considered to be an estimate based on a 5 and 20% (for both potatoes and tamarillos) and 20 and 50% (for both tomatoes and capsicums) likelihood of the benefits occurring. These benefits were reductions in insecticide spray applications and in crop impacts with resulting improvements in crop yield and quality. The NZIER did not quote any dollar estimates to express the beneficial impacts on amenity gardeners, Māori-grown crops, export growth and regional development but noted that the release of T. triozae may contribute towards achieving these unquantified benefits.

The costs associated with the release of Tamarixia and potential adverse effects it may cause were expressed in terms of the funds that New Zealand is willing to invest to curb biodiversity loss. The NZIER adopted this approach since T. triozae may be able to parasitise native psyllid species as was shown in host range testing performed in containment (Gardner-Gee 2012) and discussed below (paragraphs 9.6-9.30). The costs reflect the dollar amount society is willing to pay to prevent the loss of a native psyllid by eradicating T. triozae from New Zealand if it is shown to heavily parasitise a native organism. The NZIER estimated the costs to curb biodiversity loss to be $3.4m based on the amount spent by the Department of Conservation and Vegetables New Zealand to eradicate the pest great white butterfly that first arrived in New Zealand in 2010. The incursion of the butterfly threatened a number of native brassica species and had the potential to harm commercial brassica crops as well.

There is also an approximate cost of $300,000 to mass rear and release T. triozae in New Zealand so that the parasitoid can establish here, if approved for release.

April 2016 23

EPA advice for application APP201955

The benefits to cost ratio of releasing T. triozae was determined to be 2.1 at the lower end and 6.8 at the higher end. The authors noted that their economic assessment relied on a number of assumptions that were derived from international studies, a limited number of New Zealand studies, opinion from scientists, and interviews with industry. Therefore, their report should be considered a conservative estimate of the economic benefits and costs of introducing T. triozae since there are a number of uncertainties that needed to be taken into consideration, including establishment and efficacy of T. triozae against TPP in New Zealand, and the potential adverse effects and the degree of those effects to New Zealand’s biodiversity.

Conclusions the economic benefits of T. triozae We consider the information presented in the application strongly suggests that there is likely to be benefits to the market economy from the release of T. triozae. We note that the economic benefits should be treated as cautiously moderate but that the benefits outweigh the costs on all accounts, considering worst case benefit scenarios and elevated costs associated with Tamarixia, as reported by the NZIER (Nixon 2014). We consider the benefits to our market economy to have minor to moderate consequences given the regional beneficial economic effects that may have national implications. The magnitude of the economic benefits are conservatively estimated given the uncertainties regarding the degree of the benefits occurring.

We consider the proposed economic benefits to be significant since reductions in the costs to control TPP/Zebra Chip and improvements in crop yield and quality as a results of improved management of TPP to be vital to bolster and future proof New Zealand’s horticulture industry.

April 2016 24

EPA advice for application APP201955

9. Assessment of the potential risks and costs associated with the introduction of T. triozae

Potential adverse effects on native psyllid species The applicant considered that the most significant cost of releasing T. triozae in New Zealand would be the risk of Tamarixia parasitizing and killing native psyllid species, which may jeopardise our biodiversity.

We developed impact pathways to guide our assessment of the potential adverse effects that the introduction of T. triozae may have on native psyllids and any additional effects (Figure 4).

Figure 4: Our assessment pathway to demonstrate the potential adverse effects on native psyllid populations that may follow the release and establishment of T. triozae

Other potential adverse effects on the environment In addition to any potential adverse effects on native psyllids, we also consider whether T. triozae may have adverse indirect effects on ecological processes such as host-parasite relationships and food webs in Section 10. Understanding the host range of T. triozae

The adverse effects that the T. triozae may have on non-target psyllids is determined by identifying its host range through testing that is usually performed in containment, and by surveying the native habitat of the parasitoid to assess the range of hosts on which it can complete its life cycle on to successfully emerge as an adult.

Host range testing for T. triozae was performed by Dr Robin Gardner-Gee at The New Zealand Institute for Plant and Food Research (Gardner-Gee 2012). The host range testing methodology and findings are summarised in the following sections.

Selection of test species for host range testing Contemporary biological control practice requires that a list of test species for host specificity testing of invertebrate agents to control arthropods should include species of taxonomic (phylogenetic)

April 2016 25

EPA advice for application APP201955

affiliations with the target as well as ecological and biogeographical affinities. Biogeographical factors include overlapping distribution patterns between the candidate agent and species in its receiving environment. Ecological features of the agent in its native range and of species in its receiving environment include, for example, feeding niches. Species of economic or iconic value are often included in host range testing (van Lenteren, Cock et al. 2006). Species that have endangered or threatened status, or are recognised as being keystone species in ecological services should also be considered during testing of candidate agents.

The selection of invertebrate biocontrol agents is often complicated by the lack of knowledge of arthropod phylogeny and dispersal rates in new environments (Kuhlmann, Schaffner et al. 2005). However, the selection of test species and testing regime should maximise the chance of detecting non-target effects and reveal the mechanisms of interaction, if any, between the agent and non-targets (Barratt, Howarth et al. 2010).

We consider that a test species list and choice of testing regime should be supported by objective and justified reasoning that includes phylogenetically related species, species of ecological affinity to the target and any safeguard species (i.e. threatened, endangered, economically or culturally valued).

Hosts in the native range The selection of non-target psyllid species for testing was based firstly on knowledge of the host range of T. triozae in its native range, the US. Tamarixia triozae is known to attack 13 psyllid species belonging to the psyllid families of the Calophyidae, Psyllidae and Triozidae in the USA (Zuparko, De Queiroz et al. 2011). There are 302 species of psyllids recorded in the Nearctic ecozone, which is North America excluding eastern Mexico, southern Florida, and the Caribbean (Hodkinson 1988). As a result, we consider that T. triozae has a limited host range confined to three psyllid families in its native habitat.

Potential hosts in New Zealand New Zealand has several native species that belong to two of the three psyllid families: the Psyllidae and Triozidae. Furthermore, there is one known exotic beneficial psyllid, the broom psyllid biocontrol agent Arytainilla spartiophila in New Zealand that belongs to the Psyllidae family (Hayes 2005). A first short list of 68 species was drawn up based on phylogenetic affinity to TPP that belongs to the Triozidae family.

The selection of the final eight test species (seven native and one exotic beneficial) in the two families were based on ecological relevance, availability and ease of rearing following consultation with psyllid taxonomist Pam Dale. The species included native psyllid species that may occur in lowland modified productive environments such as potato or tomato fields and surrounding landscapes, including shelterbelts, forest reserves, roadside areas and unused pastoral land. The selection process also considered ecological relevance of the species and eliminated psyllids species that may not be susceptible to T. triozae attack due to protective structures formed by the psyllids (i.e. gall formers) or

April 2016 26

EPA advice for application APP201955

are found in isolated areas only where TPP does not exit (e.g. the Subantarctic Islands – the southernmost group of New Zealand’s outlying islands).

Finally, there are a number of rare psyllid species for which there are minimal records and limited or no specimens available. Therefore, it is not always possible to include rare species in host testing. The rare or at risk psyllids described in the host testing report (Gardner-Gee 2012) were excluded, in addition to other species in the Triozidae and Psyllidae families that are not common in the Auckland region where the test species were collected.

Psyllids selected for host range testing The eight psyllids tested were: Trioza panacis (houpara psyllid); Trioza vitreoradiata (pittosporum psyllid); Trioza curta (pōhutukawa psyllid); Trioza “Ohumata”; Ctenarytaina clavata (manuka psyllid); Acizzia dodonaeae (akeake psyllid); Psylla apicalis (kowhai psyllid); and the exotic beneficial Arytainilla spartiophila (broom psyllid).

We note that it was not feasible to include all or a large percentage of New Zealand psyllids in the testing for pragmatic reasons and due to financial constraints. The collection of psyllids that are found in the Auckland area only stem from the prevalence of TPP in this area where large tomato and potato operations exist. If T. triozae is approved for release, it will more likely encounter these psyllids in the Auckland area where TPP is found.

Does this apply to elsewhere where, if approved, T. triozae will also be released (e.g. in the Hawke’s Bay or Canterbury)? The four species tested in the Trioza genus (Triozidae family) represent the 50 native Trioza species due to their phylogenetic affinity with other Trioza species and to TPP. For the same reason, the three native Psyllidae species tested represent New Zealand’s 11 native Psyllidae species.

We consider that the tested species’ phylogeny adequately represents native psyllid species in the two families notwithstanding their geographic locations. There is limited information available on the geographic distribution and movements of native psyllids which complicates the selection of geographically relevant psyllid species for host testing given the large number of species in New Zealand.

We consider the selection of test species to be consistent with best practice reported in biocontrol literature. Every application to introduce a new entomophagous BCA (agents that feed on insects) should be considered on a case- by-case basis as every agent, its host, the host’s host-plant species and the receiving environment are unique with their own interdependent characteristics. However, literature does provide guidance to the selection process of test species (e.g. (Haye, Goulet et al. 2005, Kuhlmann, Schaffner et al. 2005, Hoddle and Pandey 2014).

Moreover, host-plant species of TPP in New Zealand belong to the Solanaceae (nightshades or potato family of flowering plants), Convulvulacaea (morning glory family of flowering plants) and the Lamiaceae family which consists of herbs or shrubs (Martin 2008). We consider that T. triozae will

April 2016 27

EPA advice for application APP201955

forage for TPP where its host plants are found in modified productive systems, like potato or tomato fields and surrounding field margins, shelterbelts, hedges and shrublands where non-cropping host plants grow. As New Zealand native psyllids are not known to utilise any plant species within those three families as a host (Dale 1985 in Gardner-Gee 2012), we consider that there is no direct danger of T. triozae attacking specific native psyllids that should be considered as candidate host testing species based on overlapping foraging behaviour.

Furthermore, in a survey of potato plants between 2009 and 2010 in Pukekohe, South Auckland, researchers reported numerous catches of TPP, especially between mid-January to mid-February, and occasional catches of a Ctenarytaina psyllid species which is normally found on eucalyptus trees, an undescribed exotic species recorded previously from Casuarina host trees, and the native pittosporum psyllid (Trioza vitreoradiata) that is usually associated with its host plant, karo (Pittosporum crassifolium) (Walker, MacDonald et al. 2011). We consider that this survey of insect fauna in areas where potato crops are grown supports the assertion that native psyllids do not reside in or use solanaceous crop plants as hosts for reproduction or food.

Host range testing The host range tests were performed according to best practice methodology in design and number of replicates (Van Driesche and Murray 2004). The testing design followed a logical sequential assessment of T. triozae’s behaviour in the laboratory: (i) no-choice oviposition (egg-laying) tests to define its fundamental host range; followed by (ii) no-choice and choice oviposition tests; (iii) tests to establish emergence of parasitoids from their hosts came next and; (iv) an assessment of the fitness of any first generation parasitoids reared from non-target psyllids and TPP.

The tests were designed to predict whether or not a test species is likely to be a field host, however, conditions in a laboratory cannot duplicate field conditions, therefore, the results and their implications should be interpreted appropriately. A summary of the results follows below.

During the no-choice tests (i), T. triozae oviposited on two non-target psyllids: Trioza curta (6% of nymphs were parasitized) and Trioza panacis (2% were parasitized) compared to 30 and 12% on TPP nymphs in positive control experiments respectively.

Further testing was performed on T. curta, T panacis and TPP (positive controls) only since the no- choice tests defined the fundamental host range of T. triozae. Therefore TPP, T. curta and T. panacis is the sum of all species which the agent can use as a host, since when the parasitoid is not given a choice and will therefore either attempt to use the non-target as a host or dump its eggs (Barratt, Berndt et al. 2007).

Further no-choice tests followed on the three psyllid species as well as choice oviposition tests (ii). T. triozae oviposited on T. curta, T. panacis and TPP, but laid fewer eggs on the two non-target species. The results from this test showed that while T. triozae parasitized T. curta and T. panacis

April 2016 28

EPA advice for application APP201955

where it is not given a choice, T. triozae preferentially parasitizes TPP when given a choice between the target pest and other psyllids.

Emergence tests (iii) showed that no juvenile T. triozae parasitoids emerged from T. curta nymphs thus it could not complete development on T. curta and suggests that it is not a suitable host for T. triozae to complete life cycles on. Tamarixia triozae, on the other hand, consistently emerged from TPP nymphs.

Adult T. triozae emerged from parasitized T. panacis nymphs indicating that development of T. triozae was possible on this host.

The first-generation evaluation (iv) tested the fitness of first generation female T. triozae that emerged from T. panacis. Tamarixia triozae that developed on the non-target psyllid produced significantly fewer adult parasitoids than those that developed on TPP, suggesting that T. panacis is less likely to support a second generation of T. triozae.

Predicted mortality from the no-choice and choice tests The percentage of T. panacis nymphs that died due to exposure to T. triozae was modelled by counting the number of psyllid nymphs alive and dead after 48 hours in the no-choice and choice tests (ii). The parasitoid had no significant effect on mortality of T. panacis compared to background mortality, i.e. where no parasitoids were present in test cages (Table 3).

Tamarixia triozae did affect T. curta mortality as there was a significant increase in mortality in the choice tests compared with background mortality: 21% died due to T. triozae versus 12% of T. curta nymphs died due to other causes (Table 3).

Twenty-six to 35% of TPP nymphs died due to the being parsitised by T. triozae compared to 4 and 8% of TPP nymphs died in the absence of T. triozae.

Table 3: Predicted percentage mortality of target and non-target nymphs from no-choice and choice cage tests T. curta as non-target psyllid T. panacis as non-target psyllid Test type Non-target Target (TPP) Non-target Target (TPP)

Negative control (background 12 7 8 4 mortality)

Choice 21 26 5 32

No choice 18 35 13 30

April 2016 29

EPA advice for application APP201955

Synthesis of host range testing results The results from the screening and mortality predictions from no-choice and choice tests (i; ii), emergence (iii), and first-generation (iv) tests provided the following delineation of T. triozae’s host range in New Zealand:  Five native psyllids (three species in the Psyllidae family and two species in the Triozidae family) and one exotic beneficial psyllid (the broom psyllid biocontrol agent) will not be attacked by T. triozae in the field as they fall outside the fundamental host range of the parasitoid.  Tamarixia triozae oviposited on T. curta and T. panacis indicating that they may be also be acceptable as hosts to the parasitoid in the field.  Mortality of T. curta was significantly higher when the parasitoid was given a choice between TPP and the native species compared to background mortality. However, no juvenile parasitoids emerged from any parasitized T. curta nymphs. This suggests that T. curta will not act as a field host for the parasitoid, however, it may be susceptible to attack by T. triozae which could lead to its death in the field. The implications are considered below.  Mortality of T. panacis due to the parasitoid was not significantly different from background mortality. T. panacis did support the emergence of parasitoids but the rate of egg laying on T. panacis was low and the parasitoids that emerged had reduced ability to produce further offspring compared to its target host TPP.

We consider the results from the host range testing reveal that T. panacis is within the physiological host range of T. triozae, as it can support development of the parasitoid, which means that it may be attacked in the field. The first-generation tests showed that parasitoid offspring fitness is compromised by using T. panacis as a host, therefore, it can be argued that T. panacis is a low rank host which will not support successive generations of T. triozae. Moreover, the host plant of T. panacis is the native tree houpara (Pseudopanax lessonii) but it can also use other native plants in the family Araliaceae, including the common and toothed lancewood. Houapara is commonly found in coastal forests especially in the northern part of the North Island (T.E.R: R.A.I.N. 2014). Therefore, the common geographical locations of host plants of T. panacis and the host plants of TPP in cropping environments do not overlap, but interactions may take place in environments that border production landscapes.

The host range tests predicted that up to 21% of T. curta (pōhutukawa psyllid) may die when T. triozae is given a choice between this non-target psyllid and TPP. Twelve percent of T. curta died due to other causes. We consider that mortality at this level should be viewed in light of the test conditions and the field conditions that T. triozae will encounter, as well as population dynamics of the psyllid in the natural environment. The parasitoid will not always be presented with a choice of hosts in the natural environment, and not in such close physical proximity as found in laboratory testing conditions. Tamarixia triozae employs a number of cues (based on TPP’s host plants - solanaceous crops) to locate TPP individuals when foraging for hosts in crop systems geographically separated from environments where native psyllids live. This suggests that T. triozae will not actively seek out T. curta

April 2016 30

EPA advice for application APP201955

whose preferred host plant is the pōhutukawa tree. This psyllid may also use other plants in the Myrtaceae plant family such as the Northern and Southern rātā. We consider that the mortality rate of the pōhutukawa psyllid, as predicted in the laboratory testing, is a conservative estimate which, given the complex set of interactions in the environment, may be a worst case scenario.

We consider that T. triozae will not actively seek out non-target native psyllids anywhere in New Zealand since the parasitoid uses a number of cues to locate TPP (see paragraphs 9.35-9.39). TPP and native psyllids do not share the same host plants and therefore are not commonly found in the same habitat. There are areas where host plants of TPP and native psyllids share common areas such as borders zones to horticulture crops including field margins, shelter belts, weed stands and forest remnants. These common areas are not the primary or only habitats for either TPP or native psyllids and therefore any interactions between T. triozae and native psyllids will occur on an ad hoc basis mitigated by chemical cues and host acceptance. The creation of refuges for native psyllids facilitated by chemical stimuli that T. triozae use to locate TPP and geographical separation of cropping systems from natural habitats preferred by native psyllids are discussed below.

Parasitoid foraging behaviour The ability of T. triozae to locate its host is considered important when the risk that parasitoids may pose non-target species is assessed (Follett, Duan et al. 2000). Parasitoid searching efficiency is central to parasitoid-host population dynamics (Vet 2001). Tamarxia triozae has to deal efficiently with distributions of its host TPP and TPP’s host plants in space and time and this is where plants play an important role in guiding foraging behaviour. Plant volatile chemicals, often released when plant-eating insects or herbivores feed on a plant, lead parasitoids to the immediate environment where its host resides. These chemical cues have also been shown to act at longer distances to attract parasitoids to the preferred food plants of their hosts (Vet and Dicke 1992).

Research suggests that plants that do not release recognisable chemical cues will be searched less by parasitioids seeking a host (Geervliet, Verdel et al. 2000). This creates a refuge for non-target insects that use different plants as hosts, for food and shelter.

Parasitoitds have also been shown to increase their searching efficiency for food plants that will increase the chance of encountering their host. This behaviour has been demonstrated in the laboratory by Geervliet, Vreugdenhil et al. (1998). The white butterfly parasitoid wasp, Cotesia glomerata (Hymenoptera: Braconidae), increased its attack rates on its host, the large white butterfly (Pieris brassica Lepidoptera: Pieridae), by learning to fly to the host’s food plants. This indicates that the parasitoids can distinguish between plants on which they have experienced a higher density of their host, and plants with a lower density of the host.

Parasitoids are also attracted by the volatile chemicals (pheromones) that their hosts emit and can guide them to find their host at shorter distances, but if there are higher densities of the host, pheromones can also play a role as long distance cues (Vet 2001). How T. triozae locates TPP has not been investigated, however, studies on a related parasitoid indicate how Tamarixia parasitoids

April 2016 31

EPA advice for application APP201955

may use chemicals to search for a host. Tamarixia radiata was shown to be attracted to the volatiles emitted by nymphs of its host, the Asian citrus psyllid (Diaphorina citri Hemiptera: Psyllidae) (Mann, Qureshi et al. 2010). Olfactory testing on this parasitoid further revealed that it is the interaction between the Asian citrus psyllid nymphs and citrus plants that induces the release of plant volatiles that attract the parasitoid to the psyllid’s host plants over long distances.

We consider that current research suggests that T. triozae utilises olfactory reception to locate hosts via volatile chemicals emitted from, or feeding activity on, solanaceous plants. These chemicals can be sensed over longer distances on air currents and direct the searching behaviour of the parasitoid to immediate areas where TPP are found. Over shorter ranges, T. triozae further rely on its sense of smell to locate TPP facilitated by the chemical signals that TPP emits to attract the opposite sex (Guédot, Horton et al. 2010) or from TPP nymphs when feeding on foliage (observed in (Mann, Qureshi et al. 2010) for another parasitoid-host system).

Environmental refuges We considered whether there are surveys of horticultural environments where native and exotic psyllids may both be periodically found. This may further guide our understanding of whether TPP and other psyllids share common territories. In a survey of potato plants between 2009 and 2010 in Pukekohe, South Auckland, researchers reported numerous catches of TPP and occasional catches of a Ctenarytaina psyllid species which is normally found on eucalyptus trees, an undescribed exotic species recorded from Casuarina host trees, and the native pittosporum psyllid (Trioza vitreoradiata) that is usually associated with its host plant, karo (Pittosporum crassifolium) (Walker, MacDonald et al. 2011). Two other adult psyllids that were not able to be identified were also caught. The pittosporum psyllid was tested in laboratory host range testing and was not used by T. triozae as a host (Gardner- Gee 2012). We therefore consider that this psyllid will not be in danger of being parasitized by T. triozae if the parasitoid encounters it when searching for TPP in potato crops.

We could not find further information on the occurrence of native or exotic psyllids (other than TPP) on horticultural and other non-crop solanaceous plants in New Zealand.

New Zealand’s psyllids are predominantly a cold-adapted shrub-land fauna (Dale 1985 in Gardner- Gee 2012). Up to 57% of native psyllid species are widespread and a number of species are endemic to New Zealand. Furthermore, 25 native psyllid species are found from lowland to alpine environments and another 17 species from lowland to sub-alpine. Approximately 70% of native psyllid fauna occurs in alpine to sub-alpine environments.

We considered the possibility of T. triozae dispersing beyond cropping systems, commonly found at low altitudes, into environments where it may encounter native psyllids (Figure 5). We note that the parasitoid could migrate into environments where it can encounter native psyllids. We consider that any adverse effects on native psyllids will be minor here, because alpine and sub-alpine habitats are extensive, native psyllid populations are known to be irregularly distributed in these habitats which may hold large population reservoirs of native species, climatic conditions found at higher altitudes will

April 2016 32

EPA advice for application APP201955

discourage T. triozae, and because TPP’s food plants are predominantly grown in lowland areas. Therefore, we consider that unmodified habitats and higher elevated environments create refuges for native psyllids.

Figure 5: Representation of the geographical separation of potato crops, border habitats including field margins, shelter belts, weed stands, shrublands and forest remnants, and unmodified habitats at higher elevation that create natural environmental refuges for native psyllids

Our assessment of the potential risks and costs to native and beneficial psyllids from the release of T. triozae

We note that there is uncertainty regarding the potential adverse effects that T. triozae might have on native psyllids in crop-border environments where TPP overwinters, but also in environments further removed from crops where we expect T. triozae will migrate to and may encounter other psyllids. This uncertainty is due to the difficulty in predicting population effects on non-target species before an agent is released, in addition to understanding the impact a parasitoid may have when parasitizing native insects for which we have limited or no life table data.

Notwithstanding this uncertainty, we considered the potential for adverse effects to occur to native psyllids in crop environments where we expect T. triozae to establish and exert the biggest effects on the environment; and the potential for adverse effects to occur to native psyllids in native (unmodified) environments.

April 2016 33

EPA advice for application APP201955

We took into account the following elements to determine the likelihood and magnitude of adverse effects on native species in the cropping environment:  The results of the host range testing demonstrated T. triozae-host acceptance that showed T. triozae will not form self-sustaining populations on any other species other than TPP. If an attacked species does not support sustainable development of the parasitoid, then it cannot be considered as a host from an ecological perspective. Moreover, we understand that host recognition and acceptance, in addition to predicted numbers of parasitized TPP nymphs, demonstrated in artificial containment conditions can lead to overestimation of host-range.  Tamarixia triozae operates in cropping environments where high densities of TPP’s host plants are found and is unlikely to be attracted to native environments due to its olfactory response to TPP’s host plants.  Tamarixia triozae will employ chemical cues to forage for TPP in the immediate environment where its food plants are present.  Native psyllids are found in low numbers in crop systems.  We surmise that there are low incidences of solanaceous non-crop host plants for TPP and host plants for native psyllids overlap in crop-border areas, in addition to limited temporal or spatial psyllid overlap, creating refuges for native psyllids.

We consider that despite the potential for T. triozae to encounter non-target psyllids in crop systems and border environments, it is unlikely for T. triozae to have significant adverse effects on native psyllids in those environments. Any adverse effects will be minimal as we expect those effects to have highly localised and contained impacts, affecting a few individual members of a population of native psyllids in the event T. triozae locates and accepts them as hosts. As a result, we consider that there are negligible risks to native psyllids in cropping environments.

We consider that there is habitat and geographic separation between native environments where native psyllids may be found and modified habitats where horticulture crops and associated non-crop plants are found.

We note that T. triozae may disperse beyond the cropping environment into modified and unmodified habitats to areas at higher altitude where larger population densities of native psyllids may be found. We consider that there needs to be environmental overlap in habitat, latitude and altitude for T. triozae to attack a native psyllid, thus T. triozae will need to first locate and then accept a native psyllid as its host. We consider that it is unlikely for attacks on native psyllids to occur in native environments away from crop systems (see paragraph 9.43) but they may occur occasionally if all the barriers leading up to host acceptance are overcome.

The fitness of any T. triozae offspring, in the event of the parasitoid accepting a non-target host, will be compromised and therefore parasitizing non-target psyllids will not lead to increases in T. triozae numbers in natural habitats. Therefore we consider that it is unlikely that there will be population level impacts on native psyllids that have high populations numbers distributed over large areas in natural

April 2016 34

EPA advice for application APP201955

habitats and that any such adverse effects will have minor consequences. We consider these effects to be negligible.

We note the possibility that rare or threatened psyllid species can be found in lowland shrublands, as well as in sub-alpine to alpine regions of New Zealand for which we have limited or no data available of their population densities, dispersal trends or life tables. We therefore recognise the irreversible effects that parasitism of rare psyllids might have on their populations.

We took into consideration the sequential steps that need to take place in order for T. triozae to reach and then parasitise a rare psyllid and we consider that this is very unlikely to occur. The magnitude of attacks on rare or threatened psyllids may be minimal where only a few individuals are impacted to major where all or most psyllid individuals of a threatened species are impacted. We expect these effects to be negligible to low.

April 2016 35

EPA advice for application APP201955

10. Our assessment of the potential indirect adverse effects on ecosystem functions such as food webs

We considered the potential indirect non-target effects the introduction of T. triozae might have on ecosystem processes in or near habitats where the biocontrol species will establish.

We consider these indirect effects to include:  the impacts on other insects that depend on the same resource T. triozae depends on  the impact that hyperparasitism of T. triozae consequentially might have on valued insects that are hosts to the same hyperparasitoids (also called ‘apparent competition’ where a species increases in number that, in turn, results in the increase in the number of hyperparasitoids in the area that attack this species which puts pressure on another species that can also be attacked by the same hyperparasitoid)  the potential of T. triozae to harbour pathogens that, once released, may introduce disease to New Zealand  the risk of T. triozae cross-breeding with other Tamarixia wasps in New Zealand and thus compromising our inherent genetic diversity. TPP as a shared resource

The biocontrol of TPP by T. triozae in conjunction with the use of IPM strategies is expected to result in the reduction of TPP numbers in vegetable crops.

We consider whether this may result in depleting a resource that is shared by other parasitoid species. No parasitoids were found attacking TPP in potato fields in South Auckland (Walker, MacDonald et al. 2011). There is one known Tamarixia species in New Zealand and it is not recorded attacking TPP (Research 2009, Gardner-Gee 2012). There are records of ladybirds, flies and lacewings predating TPP (Walker, MacDonald et al. 2011). They are general predators and do not rely solely on TPP for food. This shows that there are no species that rely only on TPP for their food. Therefore, we consider that reductions in populations of TPP will not adversely affect other organisms since there are no organisms present in the New Zealand environment that share resources with T. triozae. Hyperparasitism of T. triozae and the effects of ‘apparent competition’

Tamarixia triozae has been shown to be a host to some parasites in its native range in the United States. Researchers found incidences of small parasitic Encarsia wasps (Hymenoptera: Aphelinidae) hyperparasitising T. triozae on tomato and bell pepper in Southern California (Butler and Trumble 2011). No mention is made of the impact the hyperparasitoids had on the fitness of T. triozae or on its control of TPP. Whilst hyperparasitoids can either be obligate (they depend on a suitable host to complete life-cycles) or facultative (they do not rely on a host to complete life-cycles), the Encarsia species detected on T. triozae is not host specific.

Further literature searches revealed that there are other records of hyperparasitoids that attack Tamarixia species. For example a Pteromalidae wasp was found to reproduce on Tamarixia radiata (a

April 2016 36

EPA advice for application APP201955

BCA from Pakistan released in the USA to control Asian citrus psyllid) (Bistline-East and Hoddle 2014). An Aphelinidae and Aprostocetus wasp was also found to parasitise T. radiata in its native range (Hoddle, Hoddle et al. 2013). These hyperparasitoid wasps are known to have broad host ranges. They are used as biocontrol agents against scale insects and flies, such as whiteflies. Whiteflies in particular are major pests of horticulture crops, therefore, it is expected that T. triozae will encounter hyperparasitoids in vegetable crops if approved for release.

The horticulture environment is dynamic which facilitates many interactions between species. The introduction of a new species to this environment will add an additional layer of interaction between species but without a complete understanding of local food webs and population sizes of predator, parasitoid and prey the magnitude of effects of any new organism on the receiving environment remains unknown. Intensively managed ecosystems such as agroecosystems and horticulture systems are expected to harbour smaller species diversities compared to unmodified natural habitats that have higher plant diversities, according to contemporary ecological thinking (Albrecht, Duelli et al. 2007). Correspondingly, decreasing insect species richness at lower trophic levels (i.e. the bottom of the food chain) will also reduce species richness at higher trophic levels (e.g. predators and parasitoids). This reduces opportunity for interaction at the higher trophic levels.

We consider that this suggests that in horticulture systems there will be less opportunity for hyperparasitoids to interact with species other than their primary hosts (as biocontrol agents) or other organisms that are usually found here for food/shelter and which they can parasitize. Species diversity in the intensively managed environment of a potato/tomato/capsicum field is expected to be low since it is only organisms that depend on these plants we expect to be routinely present at high numbers. We expect that T. triozae will build to high populations in horticulture systems on TPP. Any interactions T. triozae has with hyperparasitoids may allow for elevated levels to build, but we consider that this will not lead to significant effects on other vulnerable species since diversity is low and transient in managed habitats. Higher abundance of hyperparasitoids as a result of ‘apparent competition’ may, in turn, lead to higher levels of attack on their primary hosts: organisms that attack potato, tomato or other vegetable crops.

We consider that there may be higher species diversities in areas that border horticulture crops (including field margins, shelter belts, weed stands, forest remnants, etc.) since these areas contain higher plant diversities. We expect that there may be opportunity for indirect effects on other species in these habitats since TPP can use non-crop plants that are found in border areas. Tamarixia triozae will follow TPP into these habitats and may exert indirect effects via ‘apparent competition’ on other species that use non-crop plants for food and/or shelter. In the absence of local ecological study, it is difficult to determine whether any species susceptible to elevated pressures of hyperparasitism are keystone species, i.e. they are organisms with community-wide effects that are disproportionately large relative to the organisms’ abundance (Pearson and Callaway 2003). This makes it challenging to assess whether there might be any keystone-level effects from ‘apparent competition’ in field margins and other border environments.

April 2016 37

EPA advice for application APP201955

Tamarixia triozae as a vector or source of disease

The host-range testing report note that there were no signs of any viruses, fungi or other pathogens in smears made from T. triozae bred from the imported T. triozae stock during standard examination for internal pathogens (Gardner-Gee 2012). It is also expected that, if approved, all T. triozae will have to meet strict provisions of the Biosecurity Act before being released. Potential for hybridisation

There is at least one known species of Tamarixia in New Zealand (Landcare Research 2009). There is little information available in the public domain on the biostatus, habitat and parasitism preference of this Tamarixia sp. In the absence of specific information it is difficult to determine whether T. triozae will come into regular contact with this Tamarixia sp. in our environment but given that this species is not known to attack TPP it is expected that it will not frequent areas where solanaceous crops are grown. We consider that this suggests that there will be limited opportunities for T. triozae to cross- breed with other Tamarixia species. Our conclusion of the potential indirect adverse effects

Having regard to the information discussed above, we consider that is unlikely for T. triozae to have indirect adverse effects on ecosystem processes and functions, including its ability to have significant adverse effects on our native genetic diversity. The consequences of any such effects will be minimal to minor as effects will be localised and contained with no discernible ecosystem impact. The effects are expected to be negligible.

April 2016 38

EPA advice for application APP201955

11. Conclusion on benefits and risks assessment

After completing our risk assessment and reviewing the available information, we consider that the cumulative adverse effects of releasing T. triozae to control TPP are negligible (negligible to low levels of risk) and the cumulative benefits are significant (low to medium levels of benefit) (Table 4). Therefore, our assessment is that the benefits from the release of T. triozae outweigh the risks.

Table 4: Summary of our assessment of the benefits, risks and costs associated with the release of T. triozae to control TPP. Conclusion Potential outcomes Likelihood Consequence (Level of benefit/risk)

Assessment of benefits

The benefits of using T. triozae to Significant (low improve management of TPP, IPM use Likely Minor to moderate to medium) and to Māori food growers

Significant (low Benefits to the market economy Likely Minor to moderate to medium)

Assessment of adverse effects

Adverse effects to native psyllids in crop Negligible Unlikely Minimal & border systems (negligible)

Adverse effects to native psyllids in Unlikely Minor Negligible (low) native (unmodified) habitats

Adverse effect to rare or threatened Negligible to Low Very unlikely Minimal to major psyllids (negligible to low)

Indirect adverse effects on ecosystem Negligible Unlikely Minimal to minor processes (negligible to low)

April 2016 39

EPA advice for application APP201955

12. Relationship of Māori to the environment

The potential effects of T. triozae on the relationship of Māori to the environment have been assessed in accordance with sections 5(b), 6(d) and 8 of the Act. Under these sections all persons exercising functions, powers and duties under this Act shall recognise and provide for the maintenance and enhancement of people and communities to provide for their cultural well-being, and; take into account the relationship of Māori and their culture and traditions with their ancestral lands, water, taonga and the principles of the Treaty of Waitangi (Te Tiriti o Waitangi). Summary of the applicant’s engagement with Māori

The applicant engaged with Māori via the EPA’s national Te Herenga1 network and iwi/Māori organisations working specifically on HSNO issues.

Consultation with Te Herenga The EPA furnished Te Herenga with a summary document of the application on 11 December 2015.

Feedback was received from Ngāi Tahu and from Ngāti Whātua Ōrākei.

Ngāti Whātua Ōrākei noted in their response to the applicant that they are normally opposed to more introductions of new species, however, there is a strong economic and environmental case for the introduction of T. triozae and have no opposition but only tautoko (support) for this project.

Consultation with iwi/Māori organisations Three organisations were contacted by the applicant on 13 November 2015: Ngāpuhi HSNO Komiti, Ngāi Tahu HSNO Komiti and Tāhuri Whenua Inc. Soc. (National Māori Vegetable Growers Collective).

We consider the applicant has taken positive steps to ensure Māori are consulted and have participated with Māori during the application process.

Ngāpuhi HSNO Komiti Ngāpuhi requested copies of the draft application form and supporting documents from the applicant, followed by a requested for further information to the applicant to clarify some of the concerns they identified.

Ngāpuhi released its initial report to the applicant on 16 December 2015. They found in their assessment that the introduction of T. triozae will not result in a decline of native psyllid species within the natural habitat, or cause significant deterioration of natural habitats. They also consider the introduction of T. triozae is not likely to have an impact on the relationship between Māori and the

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.

April 2016 40

EPA advice for application APP201955

culture and traditions with ancestral lands, water, waahi tapu and valued flora and fauna and other taonga.

Ngāpuhi noted to the applicant that it will make a submission on the application once it is notified by the EPA and if any details change or new research becomes available they reserve the right to reconsider their assessment.

Ngāpuhi subsequently authored a submission to the EPA noting that they oppose the application due to new evidence becoming available to them. They requested the applicant to provide further evidence that the risks to Māori have been fully investigated and mitigated.

Ngāi Tahu HSNO Komiti The applicant provided a draft application and supporting documents to Oliver Sutherland after initially contacting Ngāi Tahu with a summary document. Dr Sutherland requested further information from the applicant which they provided. Subsequent correspondence with the applicant noted that Ngāi Tahu is supportive of the application to import T. triozae.

Ngāi Tahu noted in their submission to the EPA that they support the application since it appears that their major concerns of significant displacement of native psyllid species within their natural habitat or significant deterioration of natural habitats have been tested and assessed. They further noted that they appreciate the applicant engaging with Māori before submitting an application to the EPA and were reassured by the applicant’s responses to their questions.

Ngāi Tahu noted their concern to ensure the production of traditional Māori food sources (taewa, kūmara and poroporo) which are traditionally grown without pesticides continue to be sustainable.

Tāhuri Whenua Inc. Soc. The National Māori Vegetable Growers Collective maintains a collection of both taewa and kūmara as well as a number of other traditional food plants. The collection is a living collection whereby samples of cultivars are grown at a number of sites across the country to ensure Māori have access to these foods every season.

Nick Roskruge (Chairman) submitted to the EPA that TPP has presented the biggest challenge to the Collective in recent years, both economically and culturally. The presence of TPP and Zebra Chip have affected all growers across the North Island and further south, reducing yields by up to 90%. A secondary issue Dr Roskruge identified is the inability to retain seed from infected crops. He noted that Māori’s ability to grow taewa has been severely compromised by TPP/Zebra Chip and is also adversely impacting on future opportunities.

Culturally, TPP has affected many whanau and hapū in their ability to contribute these traditional foods to important occasions. This impacts on their manaakitanga and mana. Dr Roskruge states that for Māori the ability to produce and provide food resources is an important element to cultural life.

April 2016 41

EPA advice for application APP201955

Dr Roskruge notes that the benefits of introducing T. triozae are clearly evident to the Tāhuri Whenua Collective however they are divided on the potential risks to whole ecosystems. Dr Roskruge submitted a number of questions to the applicant to clarify some of the issues. The Collective gives their tacit support based on the questions being considered. Relationship of Māori to the Environment – Assessment by Kaupapa Kura Taiao – EPA Māori Policy and Operations

Kupu arataki (context) Māori need to have confidence that releasing T. triozae will not generate potential cultural risk. Cultural risk includes any negative impacts to treasured flora and fauna species, the environment, and the general health and well-being of individuals and the community.

In general, the introduction of new organisms has the potential to inhibit the ability of Māori to fulfil their role as kaitiaki. This is particularly relevant when considering the guardianship of land and waterways and the need to protect the mauri (life principle) of Te Marae o Rongo (cultivation activities) and Te Marae o Tāne (terrestrial ecosystems), in particular species associated with mahinga kai (food resources), rongoā (medicine) and kōrero ō mua (traditional narratives).

Te Marae o Tāne (terrestrial ecosystems) It would appear that controlling TPP by conventional means (i.e. repeatedly spraying with insecticides) is labour intensive, impractical and uneconomic. Furthermore, any insecticide that poses risk to taonga tūturu (cultural and environmental treasures, indigenous and protected species) may be regarded as undesirable from a Māori point of view. Taonga tūturu have special significance in terms of roles in Māori lore, customary practices, usages and traditions.

Any momo taketake (indigenous species) in New Zealand is regarded by Māori as being taonga or culturally significant due to being part of the natural order of things established by Tāne and other tutelary beings. While New Zealand has four momo taketake in the psyllid whānau, none of these are expected to be impacted by T. triozae. There are no native or introduced parasitoids currently in New Zealand that attack TPP.

Tamarixia triozae is not likely to be hosted by culturally significant plants that native psyllids such as the pittosporum psyllid are found on e.g. karo (Pittosporum crassifolium), kōhūhū (Pittosporum tenuifolium) and tarata (Pittosporum eugenioides). Karo was used by Māori to treat sore throats and boost immunity, and its seeds were used to produce a black or dark blue dye. According to Ngāi Tahu, a sprig of kōhūhū was commonly used by tohunga in ceremonial proceedings such as the birth of a child, or in lifting tapu restrictions. Kōhūhū was also used to treat itch, eczema of the scalp and other skin diseases. Fragrant plants were sought-after by Māori for use as scent or body lotion. Lemon- scented tarata (Pittosporum eugenioides, common name lemonwood) was commonly used, as it was widely available. Its resinous sap and crushed leaves were mixed with plant oils such as tītoki and kohia. Tarata was also used by Māori in scented garlands.

April 2016 42

EPA advice for application APP201955

Māori may be concerned to protect other psyllids that have been introduced into New Zealand for the purpose of ecological restoration. One of these is the broom psyllid (Arytainilla spartiophila) which is native to the Mediterranean region and has been used in New Zealand since 1992 to control the introduced European broom (Cytisus scoparius), a pestilential invasive leguminous shrub. If releasing T. triozae has an adverse impact on controlling European broom, Māori would likely view as this outcome as being detrimental. However, as noted by Ngāi Tahu, broom has become a significant food source for kererū, a bird that has considerable cultural importance.

Te Marae o Rongo (cultivation) The potential impacts on commercial horticultural operations and domestic gardens of releasing T. triozae fall within the domain of Te Marae o Rongomatāne (cultivation activities). Rongomatāne is the deity of cultivated food, as opposed to wild foods. Māori have a strong interest in commercial cropping and home gardening of food and ornamental plants.

Controlling TPP by releasing T. triozae will produce substantial economic benefits for those engaged in horticultural industries and the food supply chain, many of whom are Māori, as TPP infestation can result in crop losses of up to 90%.

As Tāhuri Whenua has noted in their submission, the taonga food items taewa (Māori potatoes) and kūmara (sweet potato) are particularly susceptible to TPP. Where taewa and kūmara is grown for family, friends and marae this occurs in small scale operations where there is a preference for traditional (organic) methods and avoidance of chemical spraying. Other culturally significant plants in the solanum whānau susceptible to TPP include the poroporo (kangaroo apple) and raupeti (black nightshade), both of which are rongoā and kai species that grow in the wild.

Tamarixia triozae is likely to benefit home gardeners particularly those growing potato, tomato, capsicum, tamarillos, eggplant and other solanaceous plants including ornamental species by enhancing the ability of people to provide for whānau and derive enjoyment from productive home gardening.

Te Marae o Whiro (disease) Disease and pestilence belongs to the domain of Whiro (divinity of evil) who is engaged on an unending quest to destroy humankind, plants and creatures created by Tānemahuta (divinity of the forest). Māori would support eradicating the introduced bacterial disease kōwhai kutu peke (Candidatus liberibacter solanacearu; Lso), of which TPP is a vector.

Kaitiakitanga (guardianship and stewardship) This proposal is broadly consistent with principles of kaitiakitanga – 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.

April 2016 43

EPA advice for application APP201955

As a general principle, introducing momo rāwaho (exotic species) into the New Zealand environment is culturally undesirable. However, T. triozae’s direct impact on momo taketake (indigenous species) is relatively benign and may be beneficial to indigenous plants and ecosystems

Reliance on insecticides to control TPP is not sustainable in the long term. Since T. triozae will establish self-sustaining populations, it will continue to deliver benefits on an intergenerational basis. T. triozae will address an economic and environmental problem as well as contribute to the social and cultural well-being of people and communities (e.g. those working in the horticultural sector) into the future. Thus, the basic premise of kaitiakitanga is met.

Manaakitanga (due care) This proposal is broadly consistent with principles of manaakitanga. In the context of horticultural operations, where the impacts of T. triozae are manifest, manaakitanga means acting with beneficial purpose, caring for and protecting the health and well-being of people and the environment and is important for enhancing the mana of those engaged in farming activities.

Manaakitanga extends to physical, spiritual and economic well-being – which can manifest in dimensions of taha hauora (human health). The latter concerns are dealt with in the following section below.

Releasing T. triozae provides an alternative to insecticides and may reduce the chemical burden on land where TPP susceptible crops are grown. Biological control has the additional benefit of reducing the need to store agrichemicals on-site that have the potential to harm workers and tamariki (children). Furthermore, it could also lessen potential for harmful agrichemicals to enter waterways and adversely affect culturally significant species used for kai, rongoā and other customary purposes. As releasing T. triozae will benefit people and the environment, and provides a softer option for managing TPP, this application aligns with principles of manaakitanga.

Taha hauora (human health) No adverse impacts on taha hauora (human health) are anticipated as a result of releasing T. triozae. Keeping TPP in check will have a positive effect on the dimensions of taha wairua, taha hinengaro and taha whānaunga particularly amongst those who have to deal with TPP infestation and its consequences such as horticulturalists and gardeners.

Taha wairua is spiritual health and well-being obtained through the maintenance of a balance with nature and the protection of mauri. Restoring ecological equilibrium by controlling an invasive and damaging psyllid will enhance taha wairua. Not releasing T. triozae could further adversely affect people’s relationship with the environment when things are out of balance and change is occurring i.e. damage to plants, unproductive crops.

Taha hinengaro is mental health and well-being and the capacity to communicate, think and feel. This is about how Māori see themselves in this universe, their interaction with that which is uniquely Māori and the perception that others have of them. Thus, doing what is right in terms of tikanga Māori and

April 2016 44

EPA advice for application APP201955

mātauranga Māori by suppressing TPP will engender a sense of validation and respectability. Releasing T. triozae may enhance mood and reduce stress of those whose livelihoods are associated with growing, supplying and selling solanaceous crops such as potatoes, tomatoes, capsicum and tamarillos.

Taha whānaunga is about the ability to interact with, and be connected to, people and things that foster a sense of belonging, enjoyment, well-being and safety. This includes domestic activities such as gardening, sharing produce with whānau and consuming the fruits of one’s labour - which are a source of satisfaction and good health. This is important in the context of whānau and kāinga (home setting).

Release of T. triozae is likely to have negligible impact on taha tinana - physical health and well-being.

Ētahi atu mea (other matters) It is anticipated the release of T. triozae will enhance the ability of Māori to express their culture and continue customary practices.

It is noted the proposal is supported by Tāhuri Whenua (The National Māori Vegetable Growers Collective), Ngāi Tahu HSNO Komiti, as well as Potatoes New Zealand Inc, Tomatoes NZ, Vegetables NZ Inc, Heinz-Wattie’s NZ Ltd and the NZ Tamarillo Growers Inc. This helps to assure Māori that the proposal has been prepared in a diligent manner with thorough consideration of environmental implications and is likely to be efficacious.

Kupu whakatepe (conclusion) Based on the information provided, the application to release T. triozae will produce considerable benefits, and overall is likely to have a positive effect on Māori interests and the relationship of Māori to the environment.

We consider that the general release of T. triozae into the New Zealand environment is unlikely to breach the principles of the Treaty of Waitangi, including the principle of active protection.

April 2016 45

EPA advice for application APP201955

13. Minimum Standards

Prior to approving the release of new organisms, the EPA is required to determine whether the organisms meet the minimum standards set out in section 36 of the Act. Our assessment of T. triozae against the minimum standards is set out below. Consideration of whether T. troizae is likely to cause any significant displacement of any native species within its natural habitat

We consider that T. triozae insects will be attracted to environments where TPP’s food plants are found. The attraction to and migration between these environments will be mediated by volatile chemicals that are emitted by these food plants and when TPP interacts with its food (9.35-9.39). It is unlikely for T. triozae to be attracted to native environments away from where solanaceous crops are grown as abundant food plants for TPP are found in horticulture crop systems during the growing season and neighbouring environments such as field margins and shelter belts during winter months where non-crop hosts such as boxthorn and other evergreen perennial plants are present (Vereijssen, Jorgenson et al. 2013).

Native psyllids do not frequent horticulture crop systems since they do not use solanaceous plants for food or to complete life cycles. Native psyllids prefer native environments away from managed systems where plant diversity is low. Native psyllids and TPP therefore inhabit environments that are geographically removed from each other. Significant overlap in time and space would need to occur for T. triozae wasps to feed on and parasitize native psyllids to have significant effects on native species in their environment.

We further note that all the steps that lead up to successful host acceptance will need to have taken place before T. triozae will parasitize a non-target psyllid. The results from the host range testing indicate that T. triozae is not able to use other psyllids to produce fit and healthy offspring on (9.4- 9.34). We consider that non-target psyllids are not ecological hosts for T. triozae, and thus will not underpin new T. triozae propagules invading native environments.

We consider that native psyllids will be sheltered from T. triozae in environmental refuges created by climate, elevation, size of a refuge, native population variations across a refuge and food plant preferences of native and TPP psyllids (9.40-9.43). The host seeking behaviour of T. triozae that is expected to lead a wasp to food plants where TPP are found and then to locate individual TPP insects will also mitigate the risk of the wasp attacking non-target psyllids (9.35-9.39).

The ability of parasitoids to shift host preference to non-target hosts is postulated to depend on species sharing a host plant, or a host that is in close proximity to the host plant of the target (Follett, Duan et al. 2000). We consider that this is unlikely to occur as host plant preferences of native psyllids and TPP are different and it is improbable for significant host overlap to occur in and around managed ecosystems. There may be instances where T. triozae will be in direct contact with non-target psyllids but this will be localised to crop and related non-crop plants around horticulture habitats.

April 2016 46

EPA advice for application APP201955

DOC noted in its submission that they do not believe T. triozae meets the minimum standards as they consider the applicant did not convincingly demonstrate that T. triozae would not cause significant displacement of native psyllid species within its natural habitat. We acknowledge the limitation of knowledge of our native invertebrates, in particular native psyllids. We balanced that limitation with the assumption that T. triozae will primarily live in modified environments as that is where its preferred host lives. We consider that despite the potential for T. triozae to attack non-target psyllids where habitats overlap, it could not form self-sustaining populations on non-target species and any non- target feeding will be localised and atypical of the preference of the wasp. There is not likely to be any significant displacement of any native species within its natural habitat as T. triozae is not expected to impact native populations at a population or species level. Consideration of whether T. triozae is likely to cause any significant deterioration of natural habitats

We consider that reductions in TPP numbers due to the activity of T. trioze will not lead to a deterioration of the modified horticulture cropping environment. The effects that the introduction of a new organism could have on unmodified natural environments are uncertain in the absence of ecological study. We note that there might be ‘ripple effects’ that accompany the development of self- sustaining T. triozae populations in the receiving habitat. We consider ecosystem changes to be compensatory and adaptive to these effects which will be contained to horticulture crops and surrounding environments that border crops.

Tamarixia triozae is unlikely to assert significant effects outside of managed habitats where TPP is routinely present and therefore we consider that T. triozae is not likely to cause significant deterioration of natural habitats. Consideration of whether T. triozae is likely to cause any significant adverse effects on human health and safety

There are already many species of native and introduced wasps in New Zealand and they are not known to adversely affect human health. We consider that there is no evidence that T. triozae could cause any significant effects on human health and safety. Consideration of whether T. triozae is likely to cause any significant adverse effect to New Zealand’s inherent genetic diversity

As noted in paragraph 10.10, we consider that it is unlikely for T. triozae to mate with a Tamarixia species already present in New Zealand. The applicant noted that there might be a native Tamarixia species present in New Zealand however there is limited information available to determine the demography or population abundance of this species. No Tamarixia species were found to parasitise TPP in the New Zealand environment and thus we consider that T. triozae will not encounter another Tamarixia sp. in its preferred habitat.

April 2016 47

EPA advice for application APP201955

We consider that T. triozae is unlikely to cause any significant adverse effects to New Zealand’s inherent genetic diversity. Consideration of whether T. triozae is likely to cause disease, be parasitic, or become a vector for human, animal or plant disease

We consider that there is no evidence that T. triozae could cause disease, be parasitic or become a vector for human, animal or plant disease, except where it is intended to parasitise its host. Conclusion on the minimum standards

We consider that T. triozae meets the minimum standards as stated in the HSNO Act.

14. Recommendation

Our assessment has found that the benefits of releasing T. triozae outweigh any identified risks or costs. We also found that T. triozae meets the minimum standards set out in section 36 of the HSNO Act. We therefore recommend that the application be approved.

April 2016 48

EPA advice for application APP201955

15. References

Albrecht, M., P. Duelli, B. Schmid and C. B. Müller (2007). "Interaction diversity within quantified insect food webs in restored and adjacent intensively managed meadows." Journal of Animal Ecology 76(5): 1015-1025.

Barratt, B., L. Berndt, S. Dodd, S. Ferguson, H. RL, J. Kean, T. DAJ and T. Withers. (2007). "BIREA - Biocontrol Information Resource for EPA applicants." Retrieved 21 January, 2016, from http://b3.net.nz/birea/index.php.

Barratt, B., F. Howarth, T. Withers, J. Kean and G. Ridley (2010). "Progress in risk assessment for classical biological control." Biological control 52(3): 245-254.

Bistline-East, A. and M. S. Hoddle (2014). "Chartocerus sp. (Hymenoptera: Signiphoridae) and Pachyneuron crassiculme (Hymenoptera: Pteromalidae) are Obligate Hyperparasitoids of Diaphorencyrtus aligarhensis (Hymenoptera: Encyrtidae) and Possibly Tamarixia radiata (Hymenoptera: Eulophidae)." Florida Entomologist 97(2): 562-566.

Butler, C. D., F. J. Byrne, M. L. Keremane, R. F. Lee and J. T. Trumble (2011). "Effects of insecticides on behavior of adult Bactericera cockerelli (Hemiptera: Triozidae) and transmission of Candidatus Liberibacter psyllaurous." Journal of Economic Entomology 104(2): 586-594.

Butler, C. D. and J. T. Trumble (2011). "New records of hyperparasitism of Tamarixia triozae (Burks) (Hymenoptera: Eulophidae) by Encarsia spp. (Hymenoptera: Aphelinidae) in California." Pan-Pacific Entomologist 87(2): 130-133.

Butler, C. D. and J. T. Trumble (2012). "The potato psyllid, Bactericera cockerelli (Sulc)(Hemiptera: Triozidae): life history, relationship to plant diseases, and management strategies." Terrestrial Arthropod Reviews 5(2): 87-111.

Follett, P. A., J. Duan, R. H. Messing and V. P. Jones (2000). "Parasitoid drift after biological control introductions: Re-examining Pandora's box." American Entomologist 46(2): 82-94.

Gardner-Gee, R. (2012). Risks to non-target species from the potential biological control agent Tamarixia triozae, proposed for use against Bactericera cockerelli in New Zealand: A summary of host-range testing, The New Zealand Institute for Plant and Food Research Limited 22.

Geervliet, J. B., M. S. Verdel, H. Snellen, J. Schaub, M. Dicke and L. E. Vet (2000). "Coexistence and niche segregation by field populations of the parasitoids Cotesia glomerata and C. rubecula in the Netherlands: predicting field performance from laboratory data." Oecologia 124(1): 55-63.

Geervliet, J. B., A. I. Vreugdenhil, M. Dicke and L. E. Vet (1998). "Learning to discriminate between infochemicals from different plant-host complexes by the parasitoids Cotesia glomerata and C. rubecula." Entomologia Experimentalis et Applicata 86(3): 241-252.

April 2016 49

EPA advice for application APP201955

Gharalari, A., C. Nansen, D. Lawson, J. Gilley, J. Munyaneza and K. Vaughn (2009). "Knockdown mortality, repellency, and residual effects of insecticides for control of adult Bactericera cockerelli (Hemiptera: Psyllidae)." Journal of Economic Entomology 102(3): 1032-1038.

Guédot, C., D. R. Horton and P. J. Landolt (2010). "Sex attraction in Bactericera cockerelli (Hemiptera: Triozidae)." Environmental Entomology 39(4): 1302-1308.

Haye, T., H. Goulet, P. Mason and U. Kuhlmann (2005). "Does fundamental host range match ecological host range? A retrospective case study of a Lygus plant bug parasitoid." Biological Control 35(1): 55- 67.

Hayes, L. (2005). The biological control of weeds book Te Whakapau Taru: A New Zealand Guide. Lincoln, Landcare Research Manaaki Whenua.

Hoddle, M. S. and R. Pandey (2014). "Host range testing of Tamarixia radiata (Hymenoptera: Eulophidae) sourced from the Punjab of Pakistan for classical biological control of Diaphorina citri (Hemiptera: Liviidae: Euphyllurinae: Diaphorinini) in California." Journal of economic entomology 107(1): 125- 136.

Hoddle, C. D., M. S. Hoddle and S. V. Triapitsyn (2013). "Marietta leopardina (Hymenoptera: Aphelinidae) and Aprostocetus (Aprostocetus) sp. (Hymenoptera: Eulophidae) are Obligate Hyperparasitoids of Tamarixia radiata (Eulophidae) and Diaphorencyrtus aligarhensis (Hymenoptera: Encyrtidae)." Florida Entomologist 96(2): 643-646.

Hodkinson, I. (1988). "The nearctic Psylloidea (Insecta: Homoptera): an annotated check list." Journal of Natural History 22(5): 1179-1243.

Kale, A. (2011). "Report on the economic and business impacts of potato psyllid on the potato industry." Prepared for Potatoes New Zealand.

Kistner, E. J. and M. S. Hoddle (2015). Biological control of the Asian Citrus Psyllid shows promise in southern California's residential landscapes. CAPCA Adviser, University of California Riverside: 50- 54.

Kuhlmann, U., U. Schaffner and P. G. Mason (2005). Selection of non-target species for host specificity testing of entomophagous biological control agents. Second International Symposium on Biological Control of Arthropods, Davos, Switzerland.

Lacey, L. A., T. X. Liu, J. L. Buchman, J. E. Munyaneza, J. A. Goolsby and D. R. Horton (2011). "Entomopathogenic fungi (Hypocreales) for control of potato psyllid, Bactericera cockerelli (Šulc) (Hemiptera: Triozidae) in an area endemic for zebra chip disease of potato." Biological Control 56(3): 271-278.

Landcare Research (2009) Checklist of New Zealand Hymenoptera v.7.0. Retrieved 4 April 2016 from http://www.landcareresearch.co.nz/resources/collections/nzac/holdings/primary-type-specimens- hymenoptera/checklist-hymenoptera

April 2016 50

EPA advice for application APP201955

Lewis, O., J. Bible, E. Jones, G. Michels and T. Amarillo (2013). "Evaluating the Efficacy of Insecticides and Insecticide Regimes to Control Bactericera Cockerelli (Hemiptera: Triozidae)." 2013 ZEBRA CHIP REPORTING SESSION: 77.

Liu, D. and J. T. Trumble (2007). "Comparative fitness of invasive and native populations of the potato psyllid (Bactericera cockerelli)." Entomologia experimentalis et applicata 123(1): 35-42.

Liu, T.-X., Y.-M. Zhang, L.-N. Peng, P. Rojas and J. T. Trumble (2012). "Risk assessment of selected insecticides on Tamarixia triozae (Hymenoptera: Eulophidae), a parasitoid of Bactericera cockerelli (Hemiptera: Trizoidae)." Journal of economic entomology 105(2): 490-496.

Logan, D. and R. Gardner-Gee (2012). CLIMEX models for Tamarixia triozae. A report prepared for New Zealand Tamarillo Growers Association Inc., Plant & Food Research: 34.

MacDonald, F., G. Walker, N. Larsen and A. Wallace (2010). "Naturally occurring predators of Bactericera cockerelli in potatoes." New Zealand Plant Protection 63: 275.

Mann, R., J. Qureshi, P. Stansly and L. Stelinski (2010). "Behavioral response of Tamarixia radiata (Waterston)(Hymenoptera: Eulophidae) to volatiles emanating from Diaphorina citri Kuwayama (Hemiptera: Psyllidae) and citrus." Journal of insect behavior 23(6): 447-458.

Martin, N. A. (2008). "Host plants of the potato/tomato psyllid: a cautionary tale." The Weta 35(1): 12-16.

Market Access Solutionz Ltd (2011). Evaluation of the Impacts of Tomato Potato Psyllid on the tomato and capsicum industries. Report prepared for the Fresh Tomato and Fresh Vegetable Product Groups: 12.

Mason, P. G. and D. R. Gillespie (2013). Biological Control Programmes in Canada 2001-2012, CABI.

Mauchline, N., K. Stannard and S. Zydenbos (2013). "Evaluation of selected entomopathogenic fungi and bio-insecticides against Bactericera cockerelli (Hemiptera)." N. Z. Plant Prot 66: 324-332.

Munyaneza, J. E. (2012). "Zebra chip disease of potato: biology, epidemiology, and management." American Journal of Potato Research 89(5): 329-350.

Nansen, C., K. Vaughn, Y. Xue, C. Rush, F. Workneh, J. Goolsby, N. Troxclair, J. Anciso and X. Martini (2010). "Spray coverage and insecticide performance." 2010 ZEBRA CHIP REPORTING SESSION: 78.

Nixon, C. (2014). New Zealand Institute of Economic Research Report to Tamarixia Working Group: Economic assessment of Tamarixia trioze, NZIER: 24.

Pearson, D. E. and R. M. Callaway (2003). "Indirect effects of host-specific biological control agents." Trends in Ecology & Evolution 18(9): 456-461.

Prager, S. M., B. Vindiola, G. S. Kund, F. J. Byrne and J. T. Trumble (2013). "Considerations for the use of neonicotinoid pesticides in management of Bactericera cockerelli (Šulk)(Hemiptera: Triozidae)." Crop Protection 54: 84-91.

April 2016 51

EPA advice for application APP201955

Puketapu, A. and N. Roskruge (2011). "The tomato-potato psyllid lifecycle on three traditional Maori food sources." Agronomy New Zealand 41: 167-173.

Rojas, P., E. Rodríguez-Leyva, J. R. Lomeli-Flores and T.-X. Liu (2014). "Biology and life history of Tamarixia triozae, a parasitoid of the potato psyllid Bactericera cockerelli." BioControl 60(1): 27-35.

Teulon, D., P. Workman, K. Thomas and M. Nielsen (2009). "Bactericera cockerelli: incursion, dispersal and current distribution on vegetable crops in New Zealand." New Zealand Plant Protection 62: 136-144.

T.E.R: R.A.I.N. (2014) Pseudopanax lessoni (Houpapa). Retrieved 11 January 2016. http://www.terrain.net.nz/friends-of-te-henui-group/trees-native-botanical-names-m-to- q/pseudopanax-lessonii-houpapa.html

Thomas, K., D. Jones, L. Kumarasinghe, J. Richmond, G. Gill and M. Bullians (2011). "Investigation into the entry pathway for tomato potato psyllid Bactericera cockerelli." New Zealand Plant Protection 64: 259-268.

Van Driesche, R. and T. Murray (2004). "Overview of testing schemes and designs used to estimate host ranges." Assessing host ranges for parasitoids and predators used for classical biological control: a guide to best practice, RG Van Driesche and R. Reardon (Ed.) USDA Forest Service, Morgantown, West Virginia: 68-89.

Van Lenteren, J. C., M. J. Cock, T. S. Hoffmeister and D. P. Sands (2006). "Host specificity in arthropod biological control, methods for testing and interpretation of the data." Environmental impact of invertebrates for biological control of arthropods. Methods and risk assessment. CABI Publishing, Wallingford, UK: 38-63.

Vereijssen, J., A. Barnes, N. Berry, G. Drayton, J. Fletcher, J. Jacobs, N. Jorgensen, M. Nielsen, A. Pitman and I. Scott (2015). "The rise and rise of Bactericera cockerelli in potato crops in Canterbury." New Zealand Plant Protection 68: 85-90.

Vereijssen, J., J. Jorgenson, N. M. Taylor, A.-M. Barnes, R. C. Butler, N. Berry, I. A. W. Scott, S. Thompson and M. M. Davidson (2013). Movement of Bactericera cockerelli in the New Zealand environment. Zebra Chip Conference. San Antonio, Texas.

Vet, L. E. (2001). "Parasitoid searching efficiency links behaviour to population processes." Applied Entomology and Zoology 36(4): 399-408.

Vet, L. E. and M. Dicke (1992). "Ecology of infochemical use by natural enemies in a tritrophic context." Annual review of entomology 37(1): 141-172.

Walker, G., F. MacDonald, N. Larsen and A. Wallace (2011). "Monitoring Bactericera cockerelli and associated insect populations in potatoes in South Auckland." New Zealand Plant Protection 64: 269-275.

Workman, P. and S. Whiteman (2009). "Importing Tamarixia triozae into containment in New Zealand." New Zealand Plant Protection 62: 412.

April 2016 52

EPA advice for application APP201955

Yang, X.-B. and T.-X. Liu (2009). "Life history and life tables of Bactericera cockerelli (Homoptera: Psyllidae) on eggplant and bell pepper." Environmental Entomology 38(6): 1661-1667.

Zuparko, R. L., D. L. De Queiroz and J. La Salle (2011). "Two new species of Tamarixia (Hymenoptera: Eulophidae) from Chile and Australia, established as biological control agents of invasive psyllids (Hemiptera: Calophyidae, Triozidae) in California." Zootaxa 2921: 13-27.

April 2016 53

EPA advice for application APP201955 Appendix 1: Summary of submissions

# Submitter Support/ Summary of submission Oppose

111608 Lynda Hanna Support Release of T. triozae will potentially benefit the business and there is very little that they can do to combat TPP and the destruction it does to their tomato crops. This involves monitoring for TPP in their crop which requires experienced staff. If TPP is observed they have to cut infested plants out of the crop. There is very little they can do to try and contain the spread of disease TPP brings. They have to use disinfectant after they have handled infected plants. There is potential to lose entire crops if an individual does not take TPP seriously and react quickly.

111609 Steven Groenhart Support Support for tamarillo growers to allow them to use a natural parasite in their crop and improving viability of the businesses

111610 Alex McDonald Ltd (Kerry Support Insecticide control of TPP in seed potatoes is expensive and difficult due to available chemistry Hughes) which impacts our environment. Requires another control option to reduce spray applications.

111612 Karamea Tomatoes (Rochelle Support Fighting insects with chemicals is expensive and unhealthy. A biocontrol option would be welcome. Trethowen)

111616 Whatitiri Organics (Bonny Neither support Delay the acceptance of a new biological control agent until the currently registered products on Faulkner-Alexander) or oppose the commercial market are given a fair trial.

111620 Marilou Castaneda Support Introduction of T. triozae will control TPP that determines yield of greenhouse/field tomatoes and potato crops. This will reduce the use of synthetic pesticides that is contributing to greenhouse effects. This will produce safe, quality produce for consumers and reduce production costs.

April 2016 54

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111630 Gourmet Mokai Ltd, Gourmet Support TPP is a major problem in greenhouse crops. There are no good biocontrol agents for TPP in New Paprika Ltd, Gourmey Waiuku Zealand. The chemicals for TPP control are limited and over use of existing pesticides is leading to Ltd (Roelf Schreuder) TPP developing resistance. Mechanical means of control such as sticky traps are insufficient. He would like to see the introduction of T. triozae as it will reduce chemical inputs which benefits food safety. This will also result in better products for the export market.

111635 Ngāi Tahu HSNO Komiti (Gerry Support The Komiti is concerned for the domestic market of the potato, tomato, capsicum and tamarillo Te Kapa Coates) industries ($451m) which make up part of the nation's staple foods. The Komiti is also concerned to ensure the production of Māori food sources (taewa, kumara and poroporo) which are traditionally grown without the aid of herbicides and pesticides continues. The Komiti supports the application since it appears that their major concerns of significant displacement of native psyllid species within their natural habitat or significant deterioration of natural habitats have been tested and assessed. They appreciate that the applicant engaged with Maori including Ngāi Tahu and answered their queries fully. The Komiti noted that the applicant did not specifically comment on the potential broader trophic impacts of introducing a BCA or assess the agent against national and regional Treaty principles. They noted that it is important to monitor potential impacts post release of a new BCA.

April 2016 55

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111636 Nursery and Garden Industry Support The NGINZ does not anticipate major impacts on nursery production in New Zealand as a result of (NGINZ, John Liddle) the proposed use of T. triozae. The NGINZ anticipates that there may be some benefits to home gardeners. Their specific interest relates to the use of T. triozae to help control TPP in outdoor crops and home gardens. T. triozae would add to the suite of natural agents assisting to reduce TPP pressures. The NGINZ notes that the host testing does not predict with complete certainty which native psyllids are likely to be suitable hosts. However, the NGINZ notes the testing completed strongly indicates low likelihood of T. triozae causing significant displacement of native species or significant deterioration of natural habitats. The NGINZ believes that any potential loss of biodiversity of native psyllid species can and must be off-set by the unquantifiable benefits including gains for home gardeners and in particular the restoration of the opportunity for traditional Maori food growers to retain the ability to grow their corps sustainably - something that will be aided by the biocontrol of TPP.

111637 Abma Hothouse Tomatoes (Dany Support The business grows 4000sqm tomatoes in the Waikato. Abma) Any action that promotes reducing the amount of spray on crop is welcomed. The business spray Agri50 on a weekly basis to stop TPP getting established. They still find insects and since they have started doing this they lose 200-400 plants in a season but the spraying affects their Encarsia numbers.

April 2016 56

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111641 Eurogrow Potatoes Ltd (Tony Support The business use 13 seed growers in Canterbury to produce seed for supply to growers Hendrikse) throughout New Zealand and for export. The business employs 5 direct staff and their employment is dependent on the long term viability of the company. TPP has significant impacts on the business and the release of T. triozae will benefit their business and the wider community both in economic and environmental terms. TPP has cost their business significantly. For example, this year New Caledonia cancelled its order for seed potatoes from them due to the perception of the risk of introduction of TPP and/or Lso. This oder alone is worth FOB $260,000 annually. Since TPP has established in New Zealand the cost of seed potatoes has increased significantly This has been in response to growers incurring greater costs for monitoring and control of TPP. For the period from 2008 to 2016 seed cost increase to the business has been approx. 47%. A primary component of this is compensation paid to growers for costs incurred to monitor and control TPP. There has been a 30% decline in seed sales as customers exit the industry due to claiming to no longer be financially viable. The major reasons are increase cost of TPP control and impact of Zebra Chip. The potato industry's 2013 strategic plan aims to double the value of fresh and processed New Zealand based exports by 2025. This is heavily reliant on export markets. T. triozae will allow the industry to pursue opportunities for export growth since the presence of TPP/Zebra Chip limits their access to seed potato export markets.

April 2016 57

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111642 Kovati-Tom Yam Gardens Support The business is self-employed and uses the services of 12 local vendors along with spending on (Reupena & Eseta Kovati) equipment and other services. The release of T. triozae will benefit their business since the BCA will reduce crop losses by improving control of TPP and reducing transmission of Lso. Since TPP became established their business has suffered crop losses and affects tomato growth and production. They currently use Neem-oil and Eco-oil but sometimes it is too late once TPP has made contact with plants. The use of the same insecticides is leading to resistance. The use of T. triozae will lead to a return to IPM practices which are beneficial to the business and environment. Monies saved can be used for employing more staff and increased investment in local the economy.

111643 Gropak Ltd (Alan Buchanan) Support The business employs 16 staff, utilises the service of 15 local vendors and spend approx. $2m per year in the region. The release of T. triozae will reduce crop losses by improving control of TPP and reduce transmission of Lso. Since TPP established the business has experienced crop losses per year of 25%. Their yields have been down by 30% which has resulted in approx. $350,000 in lost earning. T. triozae will result a reduction in production costs particularly around the application of pesticides which is currently $600/ha per year more than before TPP became established. Improved outcomes will allow the business to pursue improved opportunities for export growth as the presence of TPP and Zebra Chip currently impacts their access to fresh potato export markets. They have the potential to employ 10 additional staff in next 5 years due to the use of T. triozae and its ability to control TPP.

April 2016 58

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111644 Southern Belle Orchard (Frans Support The business is passionate about sustainable farming practices, and part of their business is de Jong) producing spray free capsicums for the New Zealand market. Their greenhouse has been severally affected by TPP over last few years. This has resulted in them having to use insecticides. Mr De Jong noted that it is of the utmost importance to be able to use predator insects in a responsible way to eliminate insect pests. The use of chemicals is only a last resort and will usually result in a lot of harm to indigenous biology.

111645 Hohepa Homes (Andrew Black, Support The business estimates that that since TPP established they have suffered crop losses per year of greenhouse grower) 60%. The release of T. triozae into greenhouses or into surrounding environments will reduce crop losses by improving control of TPP. Achieving improved crop quality and yields and resulting increase $/kg for crops will benefit the whole community through staff wages, investment in capital equipment and on-going support for local services.

111646 Hira Bhana & Co Ltd (Bharat Support The business employs 16 direct staff, uses services of 4 local vendors along with spending approx. Bhana) $1.5m per year in the region on other services. The release of T. triozae will result in a reduction in production costs particularly around the application of pesticides which is currently $900/ha/year more than before TPP. Improved environmental outcomes from the release of T. triozae will also come through a reduction in reliance on broad spectrum chemistry and use of insecticides that are more compatible with IPM.

April 2016 59

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111647 Clint Smythe Support The business employs 10 direct staff, use services of 2 local vendors along with spending approx. $500,000 per year in the region. The business estimates that since TPP established they have suffered crop losses of 20% each year. Their yields have been down by 15% which has resulted in approx. $50,000 per annum in lost earnings. The introduction of T. triozae will result in a reduction in production costs particularly around the use of pesticides which is currently $600/ha/year more than before TPP. It will allow growers to return to IPM practices. The presence of TPP and Zebra chip limit their access to fresh potato export markets. The note that they may be able to employ an additional 2 staff in next 5 years due to the control that T. triozae may offer and associated savings in production costs.

111648 Underglass Karaka Ltd and Support The businesses employ 190 direct staff and contractors, and use the services of numerous Underglass Bombay Ltd (Lex vendors along with spending approx. $11.7 million per year within the region. There are also Dillon) affiliated companies that employ a further 150 to 180 staff in administration, packaging and logistics. Reductions in production volumes directly affect these businesses as well. Managing Director Lex Dillon estimates that since TPP established their businesses have suffered crop losses per year of up to 20%. Their yields have been down between 5 and 10% on average which equates to average annual lost production value of between $1.8 and $3m. The use of T. triozae will result in a reduction in production costs, particularly around the application of agri-chemicals. T. triozae will assist them to return to higher levels of IPM practices which benefit production volumes and the environment. Prior to the arrival of TPP, New Zealand had a full IPM system that resulted in years when they did not need to apply a single pesticide spray.

April 2016 60

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111649 Jay D Consulting Ltd (Jon Support Achieving improved crop quality and production and the resulting increased $30/tonne for crops Davison) will benefit the whole community. The use of T. triozae will result in increased employment opportunities and contribute to local and regional economies that support the horticulture industry. It may provide their business with the ability to employ 50% more staff in next 5 years.

111650 A S Wilcox (Bryan Hart) Support The business employs 170 direct staff, utilising crop scouting services of local consultants costing approx. $25,000 per year, along with spending approx. $5,000 per year on trials on best management practices within the region. TPP has caused crop loses per year of 5%, and their yields have been down 5% which have resulted in approx. $500,000 per annum in lost earnings. T. triozae will allow them to return to IPM practice and reduce the production costs around the application of pesticides which is currently approx. $800/ha/year more than before TPP. The resulting reduction in pesticide use will also benefit beneficial insects to control pests at the low pest pressure shoulders early and late season.

111651 Foundation for Arable Research Support T. triozae will result in a reduction in production costs, particularly around the application of (Nick Pyke) pesticides which is currently significantly higher with sometimes 5 to 6-times more insecticides applied than before TPP. The proposed introduction of T. triozae is based on significant and complete scientific review by scientists with considerable experience in biocontrol and in management of pests. FAR have been involved in research on TPP in potatoes over the last two years and see the introduction of T. triozae as an integral component of on-going efforts to provide enduring TPP management solutions.

111652 Ngāpuhi HSNO Komiti (Violet Oppose The Komiti requests that the application be withdrawn until further evidence has been provided that Walker & Bryce Smith) risks to Māori have been fully investigated and mitigated.

April 2016 61

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111653 Nortonta Ltd (Tony Norton) Support Established Canterbury based commercial tomato grower producing over 600 tonnes of tomatoes annually. The business employs up to 10 staff. The release of T. triozae either into glasshouses or into surrounding environment will reduce our crop losses by improved control of TPP and reduction in transmission of Lso.

111654 Corbett Bros (Ian Corbett) Support The business employs 10 staff, along with spending approx. $200,000 per year within the region. Since TPP established the business has suffered crop losses of 8 tonne per acre per year. Their yields have been down 30% which have resulted in approx. $800,000 in lost earnings. T. triozae will result in a reduction in production costs particularly around the application of pesticides which is currently $1200/ha/year more that before TPP. The BCA will also allow a return to IPM practices which are beneficial to staff and the environment. Mr Corbett estimates that they will be able to employ an additional 3 staff in the next 5 years due to the use of T. triozae.

111655 Growing Fare (Graeme Fair) Support The business employs 2 direct staff, uses the services of 2 local vendors along with spending approx. $20,000 per year within the region on equipment and services. Mr Fair estimates that they have lost 10% of their crops since TPP established Their yields have been down 10% each year which resulted in approx. $5,000 in lost earnings. T. triozae will result in production cost reductions particularly around the application of pesticides which is currently approx. $500/ha/year more than before TPP.

April 2016 62

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111656 NZ Hothouse Ltd (Simon Support The NZ Hothouse Group operates a fresh produce export business throughout the Pacific, Asia Watson) and Australasia. Having access to T. triozae will result in a growth of their export business by being able to offer produce that has far lower levels of agrichemicals. T. triozae will result in a return to their preferred pest control method of IPM. IPM is a much more sustainable and environmentally friendly method of pest control. Improved environmental outcomes will also come through a reduction in reliance on broad-spectrum insecticides, and the use of selective chemistry compatible with IPM will benefit the whole community. Broad-spectrum chemistry is increasingly losing efficacy as more and more pests develop resistance to those currently licensed for use.

111657 Freshpik Farms (Mike Moleta) Support The business employs 4 direct staff, uses the services of 2 local business along with spending approx. $100,000 per year within the region. Since TPP established the business has suffered crop losses per year of up to 40%. Their yields have been down an average of 15% which has resulted in approx. $250,000 in lost earnings since TPP established. T. triozae will result in a reduction in production costs particularly around the application of pesticides which is currently $500-700/ha/year more than before TPP. Mr Moleta notes that the BCA will allow them to return to IPM and that control of TPP will result in increased employment opportunities and contribution to local and regional economies. He anticipates that it will provide the business with the potential to employ 1 or 2 new staff in the next 5 years.

April 2016 63

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111658 Organic Farm NZ (Jim Bennett) Support The arrival of TPP in New Zealand has resulted in significant difficulties for those growing solanaceous plant crops, in particular those who manage their crops according to organic practices. Home gardeners whether organic or not have experienced the same problems. The release of T. triozae is welcome since IPM is consistent with organic practices. Mr Bennett however notes the potential threat to native species from the release of T. triozae. Organic Farm NZ supports the release of the parasitoid and concept of IPM but they would like to see more research done on the threat to native psyllids.

111659 Tane Partnership (Simon Support As a grower Mr Campbell relies on chemicals to control TPP. This is expensive and harmful. There Campbell) is a concern that TPP might establish resistance to chemicals over time. He believes T. triozae can be used in an IPM programme that will reduce the cost of control and its effects.

111660 Fruitfed Supplies (Daniel Sutton) Support Since the arrival of TPP in New Zealand, there has been a considerable increase in the number of insecticide applications required to control pest infestations and to limit the infection of Lso. Along with increased use of insecticides that has also been a change from the use of selective insecticides which target pests such as aphids and potato tuber moth to broad-spectrum insecticides. This has led to a greater negative impact on many non-target organisms, many of which can offer biological control. There has been a greater focus on monitoring and tracking of populations of TPP in crop. This requires weekly replacement and interpretation of yellow sticky traps from around the edge of the crop and inspection of plants within the crop to get a record of numbers and life stages of TPP. With the increased monitoring and understanding of the pest, potato growers have been moving towards a more integrated approach to controlling TPP. However, even with greater understanding of this pest and naturally occurring biocontrol agents, insecticide applications remain as high as once per week. Opportunities exit to improve TPP control by increasing effect of the biological component which can in part be achieved by introducing new BCAs such as T. triozae. By increasing the effectiveness of biological control agents we can expect to see increased potato yields and reduction in amount of chemicals being applied.

April 2016 64

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111661 Curious Croppers (Anthony Support The business employs 4 direct staff. Tringham) Mr Tringham estimates that since TPP established their business has suffered crop losses per year of 10%. T. triozae will result in a reduction in production costs particularly around the application of pesticides, and will allow a return to IPM which will benefit the staff and environment.

111662 Midway Farm Darfield (Anne and Support The business employs 7 direct staff, uses the services of local consultants/professionals along with Jason Hann) spending approx. $800,000 per year within the region on equipment and other services. The release of T. triozae will benefit the business and the wider community in both economic and environmental terms. Their yields have been down 15% which has resulted in approx. $300,000 in lost earnings per annum since TPP established. T. triozae will result in reduction in production costs particularly around the application of pesticides which is currently $400/ha/year more than before TPP. T. triozae will allow the business to pursue improved opportunities for export growth as the presence of TPP and Zebra Chip limit their ability to export seed potatoes to New Caledonia.

April 2016 65

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111663 Southern Paprika Ltd (Stuart Support The business has 23 ha of glasshouses growing capsicums for the export market to Japan, Attwood) Australia and Canada, as well as supply to local market. They produce in excess of 6000 tonnes each year and employ 140 people. The impact of TPP on their crop has been huge and continue to be the dominant pest problem. They are seeing an increasing trend of their export and local markets to provide fruits with lower levels of insecticide residue and for this reason the horticulture industry is endeavouring to control pests with the introduction of beneficial insects (BCAs). With the significant increase in TPP pressure this has meant there is now a heavy reliance on insecticide programmes as there are no insects available to control TPP. Any TPP in the glasshouse becomes a risk for market access to their overseas trading partners. The on-going withdrawal of agrichemicals from the New Zealand market now leaves us with very little options for complete control and heavy reliance on a limited number of products which could result in future chemical resistance. All capsicum growers have increased their scouting/monitoring regimes and also the number of scouts to increase the chance of early detection of TPP. All growers strive to reduce the total number of spray applications in an effort to maximize production. Growers could spray an additional 7 application for TPP control but would rather use BCAs.

111665 Tāhuri Whenua Inc. Soc. (Nick Neither support TPP has presented the biggest challenge to the Collective in recent years both economically and Roskruge) or oppose culturally. TPP and Zebra Chip has affected growers across the North Island and some further south, reducing yields by up to 90%. A secondary issue is the inability to retain seed from infected crops. Māori’s ability to grow taewa have been compromised which is affecting their ability to contribute food to important occasions. The Collective recognize the benefits of the application. It is the effects on whole ecosystems that they are somewhat divided as a roopu however they give their tacit support based on questions being considered.

April 2016 66

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

111666 Turners & Growers Global Ltd. Support T&G operates 28 ha of glasshouse tomatoes in 5 locations in New Zealand. It employs 300 people (Ben Smith) in the covered crop division of the business. Additionally, T&G packs and markets other affected crops such as capsicums and potatoes where they employ 44 people in packing and marketing. Mr Smith estimates that since TPP established their business has suffered crop losses per year averaging 3-8% Maximum losses of an individual crop has been as high as 50%. The additional costs for TPP control are for insecticides, and labour for crop scouting and spray application. Furthermore, applying any spray to a high performing greenhouse crop results in indirect yield losses as a result of the water required to carry the insecticide to the target during any spray application. This is believed to be because an active crop that is photosynthesizing changes to one that is inactive and is not having gas exchange happening at the leaf surface. Moreover, introducing water intro crop for spray provide pathogenic fungi and opportunity to grow due to raised humidity. The economic value of each spray application is difficult to quantify. As a rule of thumb used by growers, each spray application in a week costs 5% of production that week so the cumulative effects of spray applications across a crop that spans 50 weeks of the year can be considerable. Having more environmentally sustainable crops has two economic benefits: 1. Market access to export markets is made easier as reliance on agrichemicals decrease 2. Allow better marketing claims to be made about products in competitive export markets A primary spin-off benefit (from the use of T. triozae to control TPP) is the effects on the management of greenhouse whitefly. An IPM programme for whitefly can be upset when TPP enters crop (because of the use of broad-spectrum insecticides). Having complimentary BCAs for each pest will strengthen the overall IPM program for whitefly, and reduce insecticide resistance that come from over-reliance on agrichemicals. There is also a secondary spin-off benefit for the management of greenhouse whitefly (from the use of T. triozae to control TPP). In some areas glasshouse tomatoes and crops of potatoes are adjacent to one another and they share populations of TPP and whitefly. As a consequence of what became best available practice for TPP in potatoes, the whitefly on potato crops were exposed to sub-lethal doses of insecticides. Whitefly are renowned as being quick to evolve and develop resistance. In the Pukekohe area, most agrichemicals in the IRAC group that were once

April 2016 67

EPA advice for application APP201955 # Submitter Support/ Summary of submission Oppose

effective against populations of whitefly now has underlying levels of resistance to it. Therefore, TPP on potato crops have caused the whitefly on tomato crops to develop resistance. Mr Smith notes that this has caused whitefly damage amounting to millions of dollars in crop damage over the last two seasons. The benefits of providing potato growers with a more sustainable management tool for TPP will lead to more sustainable management of whitefly in greenhouse tomatoes.

April 2016 68

EPA advice for application APP201955

Appendix 2: Submission from Department of Conservation

Appended

April 2016 SUBMISSION 111664

DOC comments on EPA new organism for release application

24th March, 2016

Application number: APP201955 Applicant: Horticulture New Zealand Inc. on behalf of the potato, tomato (greenhouse and field tomatoes), capsicum and tamarillo industries represented by Potatoes New Zealand Inc., Tomatoes NZ Inc., Heinz-Wattie’s NZ Ltd, Vegetables NZ Inc., and NZ Tamarillo Growers Association Inc Application purpose: to release from containment the psyllid parasitoid Tamarixia triozae into New Zealand to assist with the biological control of the tomato potato psyllid (Bactericera cockerelli). Submission period closes: 24 March 2016

Thank you for the opportunity to comment on this application. Please note we wish for a DOC representative to speak at the public hearing in support of the Department’s comments. Please advise us of the hearing date and location.

General comments The overall purpose of this application is to introduce the parasitoid Tamarixia triozae into New Zealand (NZ) to achieve more effective and sustainable management of TPP. The intention is for this parasitoid to be mass reared by commercial operators and released primarily into outdoor areas growing potato, tomatos and tamarillos.

In general, where a control agent is environmentally safe (and preferably monophagous), the Department supports the concept and practice of Integrated Pest Management programmes that result an increase of pest control efficiency, efficacy and a reduction of broad-spectrum insecticides. This application however, deals with a control agent that is clearly polyphagous – utilizing a range of psyllid hosts which are found on a wide range of plants and forms. T. trioze has the potential to adversely harm native biota, the risks of which for various reasons, have not been comprehensively assessed.

Assessment of risk to conservation values The Department supports rigorous research and host-testing to ensure a high level of host- specificity (inter alia) for proposed biocontrol agents used against pests and is concerned about any new organism release that does not meet the minimum standards of the HSNO Act.

Minimum standards The Department does not believe T. triozae meets the minimum standards. In our view, the applicant has not convincingly demonstrated that T. triozae would not cause one or both of the following:  cause any significant displacement of any native species within its natural habitat  cause any significant adverse effect to New Zealand’s inherent genetic diversity

Our comments follow.

1. On balance we agree the host range testing completed indicates that the species we know about within the family Psyllidae are unlikely to be adversely impacted by T. triozae.

2. There are 50 endemic species within the family Triozidae. The application has acknowledged the parasitoid could establish in areas where Triozidae endemic species are found given their distribution overlaps with TPP. Of these 50 species, only four were tested for their suitability as hosts. The parasitoid showed an interest in two (50%) of these four (Trioza curta and Trioza panacis), successfully emerging from one (parasitized T. panacis). These results indicate the parasitoid’s clear interest in our native Triozides family representatives. From this limited host testing, we cannot confidently state T. panacis is likely to be the only species vulnerable to T. triozae parasitism. We believe the testing done is insufficient to provide confidence that minimum standards have been met for native species within the Triozidae family.

3. We would expect a new organism release that potentially impacted on these species to be supported by robust host testing and a comprehensive analysis of host plant identification and distribution (including crop and non-crop species) so the likely spread and impact could be ascertained, to inform the decision. Non-target native psyllid species on non-crop host species and their distributions need to be factored into the assessment. The focus on lowland agricultural crops is too indiscriminate for an irreversible new organism introduction. Endemic species are particularly significant because, apart from their intrinsic, biodiversity and scientific values, they are globally unique. This obligates us with a duty of care to consider protection measures for them where feasible.

4. We argue the decision to exclude three sub-groups from the Genus Trioza – a genus containing a range of species of preference for T. triozae parasitism - on the grounds that these sub-groups are not well represented around Auckland, is a short-sighted view and lacks rigour. Budget constraints are unfortunate, but should not be used as a reason for perfunctory decisions where consequences may be irreversible. We consider that more tests are required on additional native Triosid psyllids that overlap with the likely distribution of T. triozae throughout New Zealand, not just around Auckland.

5. It does not follow that because “T. triozae is an obligate parasitoid which relies on psyllid hosts for its survival” that “the likelihood that T. triozae will cause significant displacement of non-target native psyllid species that are not its preferred host is … highly unlikely” (p 19). The likelihood of displacement and other adverse impacts can only be convincingly predicted by rigorous host testing and/or field studies.

6. Given the very limited level of host testing on native Triozidae we do not support the conclusion near the end of Secction 5.2.1 (p 45) “We can only conclude that T. triozae may parasitise a small proportion of native psyliids in the Triozidae family. Given the indication that T. panacis is not an optimal host, we consider that the likelihood that non-target parasitism by T. triozae might result in population level effects and significant displacement of native psyllid species is low”.

7. Finally, we note that the adult female T. triozae is a predator (p 13) as well as a parasitoid. The report states the female uses her ovipositor to stab and mutilate the TPP nymph, to enable feeding on haemolymph. The host feeding of the TPP nymph stages by female T. triozae are said to be as significant as parasitism in harming TPP. It does not appear as DOC-2716772 Page 2 of 3

though NZ’s native Triozidae species have been tested for vulnerability to predation. We consider this a significant gap in meeting the minimum standards.

Conclusion Given: a. most native species were not represented in host testing so we cannot accurately predict which NZ species are likely to be suitable hosts for the parasitoid b. non-target native psyllid species on non-crop host species have been insufficiently factored into the assessment c. the limited host testing done on native Triozid species demonstrates 50% are likely to be adversely impacted via parasitism where distribution overlaps d. predation levels on NZ native species has not been assessed at all the Department urges the EPA to consider this application using a precautionary approach. Although we understand TPP is a serious economic pest that needs more innovation and management options, there is considerable scientific and technical uncertainty on T. triozae’s impact, particularly for native Triozid species. Accordingly, the Department requests the EPA declines this application until further research shows a T. triozae release will have insignificant impact on native Triozid species.

Kind regards,

Verity Forbes Technical Advisor - Biosecurity Threats (National) Kai-mātanga Matua, Koiora Mōrearea Department of Conservation Te Papa Atawhai

Contributor: Dr Chris Green – Technical Advisor Threats (entomology)

DOC-2716772 Page 3 of 3