APPLICATION FORM Containment

To obtain approval for new organisms in containment

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

Application Number

APP204231

Date

www.epa.govt.nz 2

Application Form Approval for new organism in containment

Completing this application form

1. This form has been approved under section 40 of the Hazardous Substances and New Organisms (HSNO) Act 1996. It only covers importing, development (production, fermentation or regeneration) or field test of any new organism (including genetically modified organisms (GMOs)) in containment. If you wish to make an application for another type of approval or for another use (such as an emergency, special emergency or release), a different form will have to be used. All forms are available on our website. 2. If your application is for a project approval for low-risk GMOs, please use the Containment – GMO Project application form. Low risk genetic modification is defined in the HSNO (Low Risk Genetic Modification) Regulations: http://www.legislation.govt.nz/regulation/public/2003/0152/latest/DLM195215.html. 3. It is recommended that you contact an Advisor at the Environmental Protection Authority (EPA) as early in the application process as possible. An Advisor can assist you with any questions you have during the preparation of your application including providing advice on any consultation requirements. 4. Unless otherwise indicated, all sections of this form must be completed for the application to be formally received and assessed. If a section is not relevant to your application, please provide a comprehensive explanation why this does not apply. If you choose not to provide the specific information, you will need to apply for a waiver under section 59(3)(a)(ii) of the HSNO Act. This can be done by completing the section on the last page of this form. 5. Any extra material that does not fit in the application form must be clearly labelled, cross- referenced, and included with the application form when it is submitted. 6. Please add extra rows/tables where needed. 7. You must sign the final form (the EPA will accept electronically signed forms) and pay the application fee (including GST) unless you are already an approved EPA customer. To be recognised by the EPA as an “approved customer”, you must have submitted more than one application per month over the preceding six months, and have no history of delay in making payments, at the time of presenting an application. 8. Information about application fees is available on the EPA website. 9. All application communications from the EPA will be provided electronically, unless you specifically request otherwise.

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Application Form Approval for new organism in containment

Commercially sensitive information

10. Commercially sensitive information must be included in an appendix to this form and be identified as confidential. If you consider any information to be commercially sensitive, please show this in the relevant section of this form and cross reference to where that information is located in the confidential appendix. 11. Any information you supply to the EPA prior to formal lodgement of your application will not be publicly released. Following formal lodgement of your application any information in the body of this application form and any non-confidential appendices will become publicly available. 12. Once you have formally lodged your application with the EPA, any information you have supplied to the EPA about your application is subject to the Official Information Act 1982 (OIA). If a request is made for the release of information that you consider to be confidential, your view will be considered in a manner consistent with the OIA and with section 57 of the HSNO Act. You may be required to provide further justification for your claim of confidentiality. Definitions

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

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

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

A new organism is an organism that is any of the following: • An organism belonging to a species that was not present in New Zealand immediately before 29 July 1998; • An organism belonging to a species, subspecies, infrasubspecies, variety, strain, or cultivar prescribed as a risk species, where that organism was not present in New Zealand at the time of promulgation of the relevant regulation; • An organism for which a containment approval has been given under the New Organism HSNO Act; • An organism for which a conditional release approval has been given under the HSNO Act; • A qualifying organism approved for release with controls under the HSNO Act; • A genetically modified organism; • An organism belonging to a species, subspecies, infrasubspecies, variety, strain, or cultivar that has been eradicated from New Zealand;

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Application Form Approval for new organism in containment

• An organism present in New Zealand before 29 July 1998 in contravention of the Animals Act 1967 or the Act 1970. This does not apply to the organism known as rabbit haemorrhagic disease virus, or rabbit calicivirus A new organism does not cease to be a new organism because: • It is subject to a conditional release approval; or • It is a qualifying organism approved for release with controls; or • It is an incidentally imported new organism

An individual or collaborative endeavour that is planned to achieve a particular Project aim or research goal

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Application Form Approval for new organism in containment

1. Applicant details

1.1. Applicant

Company Name: (if applicable) Manaaki Whenua – Landcare Research Ltd.

Contact Name: Hugh Gourlay

Job Title: Senior Researcher

Physical Address: 54 Gerald Street, Lincoln 7608

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

Phone (office and/or mobile): 03 321 9999

Fax: 03 321 9996

Email: [email protected]

1.2. New Zealand agent or consultant (if applicable)

Company Name:

Contact Name:

Job Title:

Physical Address:

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

Phone (office and/or mobile):

Fax:

Email:

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Application Form Approval for new organism in containment

2. Information about the application

2.1. Type of containment activity Tick the box(es) that best describe your application

Application type Type of new organism

☐ GMO Import into containment ☒ Non-GMO ☐ Develop in containment i.e. regeneration, fermentation GMO or genetic modification ☐ Non-GMO

☐ GMO Field test in containment ☐ Non-GMO

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

To import into containment exotic species to conduct biocontrol research for targeting multiple weed species in the Pacific region and in New Zealand.

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

The purpose of this application is to gain approval to import exotic plants into containment facilities operated by Manaaki Whenua – Landcare Research (MWLR) to conduct classical weed biocontrol research.

Research on the plant genera and species included in this application has two aims; (i) to develop classical biocontrol agents for high priority weeds in Pacific Island countries; (ii) to develop classical biocontrol agents for Pinus contorta (Pinaceae), a wilding pine in New Zealand.

Weed biocontrol in the Pacific

MWLR is working with the Ministry of Foreign Affairs and Trade (MFAT) and the Department of Conservation (NZDOC) to assist Pacific Island countries with invasive weed management. MWLR is the lead on a programme entitled Natural Enemies, Natural

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Application Form Approval for new organism in containment

Solutions (NENS), which will develop classical biocontrol agents to provide safe, cost- effective and sustainable solutions to weed problems in the region. In order to assist with the development of biocontrol agents to help manage invasive alien plants in the Pacific region, we will need to import live plant material and seeds to conduct host range testing of potential biocontrol agents. These plants do not grow in New Zealand. This research is essential to confirm that the agents can be used safely in the Pacific. This aspect of risk assessment can only be carried out in containment facilities in New Zealand, as these facilities are not available in Pacific Island nations.

MWLR is seeking a single, broad EPA approval that will avoid multiple EPA applications to import target weed (Appendix 1A) and test plant species (in 36 named genera with two synonyms included; Appendix 1B) into containment for Pacific weeds programmes planned over the next 5 to 10 years. This will allow for current and future Pacific weeds research programmes to import exotic plants under a single HSNO approval, with a single set of controls.

EPA/ERMA MWLR has previously issued generic EPA approvals for the import of any potential arthropod and fungal biocontrol agents (ERMA 100005 & 200019).

Wilding Pines project

The Arceuthobium (Viscaceae), commonly known as dwarf mistletoes, includes 26 species of parasitic plants that parasitise members of the conifer families, Pinaceae and Cupressaceae. Some Arceuthobium species/subspecies are highly host specific (Hawksworth & Wiens, 1996). Two dwarf mistletoe species in particular, Arceuthobium americanum and A. campylopodum subsp. tsugense (Viscaceae) (Appendix 1C) have potential as biocontrol agents for the wilding pine, Pinus contorta (Pinaceae). These two dwarf mistletoes pose no threat to conifer species that are grown commercially in New Zealand, such as radiata pine, Pinus radiata (Pinaceae) and Douglas fir, Pseudotsuga menziesii (Pinaceae). Arceuthobium americanum and A. campylopodum subsp. tsugense are classical candidate biocontrol agents and will need to be imported into containment in New Zealand for host range testing. This application proposes to import into containment two members of the genus Arceuthobium which are likely suitably host specific for release in New Zealand to control the wilding pine, P. contorta.

2.4. Background and aims of application

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

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Weed biocontrol in the Pacific

Invasive alien species are the leading driver of biodiversity loss in the Pacific and one of the biggest threats to sustainable development. They negatively affect ecosystem resilience, ecosystem services and future ability to adapt to climate change. Both the endemic biodiversity and primary production sectors of Pacific Island countries are under increasing pressure from a failure to adequately control established invasive species. The number of invasive species continues to increase as further exotic plants and animals become established. Further, global climate change will affect the distributions of invasive species and their interactions with other species.

New Zealand’s Ministry of Foreign Affairs and Trade (MFAT) has partnered with the Secretariat of the Pacific Regional Environment Programme, MWLR and the New Zealand Department of Conservation to assist a number of Pacific Island countries (Cook Islands, Niue, Republic of the Marshall Islands, Tonga, Tuvalu and Vanuatu) to take stronger action against invasive species to help protect their ecosystems and communities, and to build resilience to climate change. MWLR is the lead on a programme, Natural Enemies, Natural Solutions (NENS), which aims to develop classical biocontrol agents for high priority weeds in the region. MWLR is providing expertise and research support for the programmes focusing on classical weed biocontrol.

Manaaki Whenua – Landcare Research has an excellent safety record (>40 years) in weed biocontrol research in New Zealand. Following identical protocols and procedures currently used for evaluating potential biocontrol agents for New Zealand weeds, host range testing of potential agents for the Pacific region will be undertaken in MWLR containment facilities. Only a few of the target weeds or test plants are present in New Zealand. Live plant material and seeds from Pacific Islands and Australia will need to be imported into containment in New Zealand where they will be propagated to rear potential agents, and to experimentally assess their host ranges and thus their safety for release in Pacific Island countries. This research will require importing and holding in containment (i) some of the target weeds in order to test and/or maintain their biocontrol agents/natural enemies; and (ii) test plants selected for their phylogenetic relatedness to the target weeds, or for their economic importance in the region combined with their affinities to any of the target weeds.

This application proposes an EPA approval that includes the target weed species and representative plant species within the pertinent genera required for testing, based on their economic and/or or biodiversity value in the Pacific region. Due to the nature of the work and the duration of the NENS programme, a single broad HSNO approval for importing into containment several plant species, as well as members of several specified genera, will enhance progression of the research programmes, will streamline containment protocols, and will enable the NENS programme to target more weed species in the Pacific over the next 5-10 years.

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Application Form Approval for new organism in containment

A single, broad import approval for the importation of plants relevant to the Pacific weeds programmes is expected to strengthen and streamline containment compliance by reducing the administrative burden required to monitor compliance. It will also simplify the process of verification for MPI. A single HSNO approval to import all plant species required for biocontrol research on target weeds in the Pacific will avoid lengthy delays with research progress.

Weed biocontrol for Pinus contorta

Wilding pines, or wilding conifers, (pines, furs, larches and spruces) are spreading across the New Zealand landscape at an alarming rate. It is estimated that 20% of New Zealand will be invaded by wilding conifers within 20 years without appropriate management interventions.

Conifers were introduced to New Zealand in the 1880s and they have since spread from forest plantations, shelterbelts and erosion plantings to cover approximately 1.8 million hectares of land. Despite attempts at control, wilding conifers are spreading at a rate of 5% per annum (~90,000 ha per year). Without effective control, these invasive species will form dense forests with severe negative impacts on native ecosystems, scarce water resources and iconic New Zealand landscapes (http://doc.govt.nz/nature/pests-and- threats/weeds/common-weeds/wilding-conifers/). The management of wilding conifers is now of high priority in New Zealand, with Budget 2020 contributing $100 million over 4 years to expand the National Wilding Conifer Control Programme (http://mpi.govt.nz/biosecurity/long-term-biosecurity-management- programmes/wilding-conifers/).

Lodgepole pine, Pinus contorta is the most vigorous spreading conifer species in New Zealand. Pinus contorta is native to the Rocky Mountains in the north-west of North America and to Canada and was introduced to New Zealand to stabilise high country pasture which was eroding due to excessive burning, high stocking densities and the impacts of rabbits. Pinus contorta is a major threat to landscape and conservation values, biodiversity and agricultural productivity. Pinus contorta is the highest priority pest conifer being targeted for management and control.

Dwarf mistletoes of the genus Arceuthobium (Viscaceae) are obligate parasites of conifer species in the families Pinaceae and Cupressaceae. Arceuthobium species rely on their hosts for survival, support, mineral nutrients, a portion of their carbon requirements and water. In North America and Canada, dwarf mistletoes are destructive forest pests which parasitise commercially important conifer species. Timber losses arise from growth reduction, wood degradations and increased susceptibility of parasitized to insect and fungal infections. In extreme cases, whole plantations can be lost. Annual volume losses from dwarf mistletoe infections are estimated to be 3.8 million m3 in Canada and 11.3

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million m3 in the Western United States (Shamoun et al. 2003). Dwarf mistletoes are so problematic and costly for the forestry industries in North America and Canada that potential biocontrol agents for their management have been investigated (Sharmoun et al. 2003).

Most dwarf mistletoes typically occur on one conifer species or several species within a genus (Hawksworth & Wiens, 1996). Arceuthobium spp. therefore have excellent potential to be used as classical biocontrol agents for invasive conifers in New Zealand. Further, Arceuthobium spp. are attacked by a variety of insects and pathogens in their native range, which suggests that their impacts in their introduced range (i.e. New Zealand) could be significantly greater than in North America.

Two species in particular, A. americanum and A. campylopodum subsp. tsugense are promising candidate biocontrol agents for P. contorta. Arceuthobium americanum attacks P. contorta and P. banksiana (the principle hosts). However, a molecular analysis identified three distinct genetic races within A. americanum (Jerome & Ford, 2002), each associated with a different host taxon in regions of allopatry (P. banksiana, P. contorta var. latifolia and P. contorta var. murrayana). Hence, it is highly likely that these distinct host races of A. americanum will have a high degree of specificity to their principle hosts.

A seemingly host specific dwarf mistletoe, A. campylopodum subsp. tsugense ( = A. tsugense subsp. contortae) attacks P. contorta (the principle host) on the coastal areas of Washington in North America and in British Columbia, Cananda (Wass & Mathiasen, 2003) and thus also offers potential as a biocontrol agent for P. contorta in New Zealand. Genetic studies to match dwarf mistletoes with their P. contorta genotype/s in New Zealand will need to be conducted prior to importing A. americanum or A. campylopodum subsp. tsugense.

3. Information about the new organism(s)

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

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

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

Both - • Describe the biology and main features of the organism including if it has inseparable organisms. • Describe if the organism has affinities (e.g. close taxonomic relationships) with other organisms in New Zealand. • Could the organism form an undesirable self-sustaining population? If not, why not?

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• How easily could the new organism be recovered or eradicated if it established an undesirable self- sustaining population?

Kingdom: Plantae

Phylum: Angiospermae

Class: Dicotyledonae

Orders: Alismatales

Cucurbitales

Fabales

Lamiales

Myrtales

Solanales

Santalales

Families: Araceae

Asteraceae

Bignoniaceae

Convolvulaceae

Cucurbitaceae

Fabaceae

Lamiaceae

Malvaceae

Melastomaceae

Myrtaceae

Solanaceae

Viscaceae

Genera: Multiple, listed in Appendix 1B

Species: Multiple target weeds in the Pacific listed in Appendix 1A.

Candidate biocontrol agents of P. contorta listed in Appendix 1C:

Arceuthobium americanum

Arceuthobium campylopodum subsp. tsugense

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Some of the genera and species have taxonomic affinities with other plant genera in New Zealand, including indigenous and economically important species. However, since all the imported plant species will only be housed in MPI approved containment facilities, the risk of exposure to the New Zealand environment is negligible. Imported plant species for the Pacific programmes will be destroyed in containment immediately after the research is complete.

No inseparable organisms have been identified for the organisms listed in this application.

Despite precautions at the point of origin, some organisms (e.g. insects and plant pathogens) may be imported with the plant genera and species in this application. However, all importations of new plant species into New Zealand will be required to comply with the Ministry for Primary Industries (MPI) Import Health Standards. In most cases a phytosanitary certificate will be required and the plants/seeds will need to meet MPI Health Standards 155.02.04; 155.02.05 and 155.02.06. Further, MWLR containment procedures are sufficient to contain such organisms (see section 4.2).

All plant parts (stems/roots) will be thoroughly screened in containment upon arrival and all unintentional associated organisms such as insects and plant pathogens will be destroyed (MWLR operating manuals – Beever Pathogen Containment Facility and the David Miller Invertebrate Containment Facility).

3.2. Regulatory status of the organism

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

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

☐ Yes ☒ No

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

☐ Yes ☒ No

4. Information about the containment

4.1. For field tests: The nature and method of the field test Describe the nature and method of the field test and the experimental procedures to be used

Not applicable

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4.2. Proposed containment of the new organism(s) (physical and operational) Describe how you propose to contain the new organism(s) after taking into account its ability to escape from containment (i.e. the possible pathways for escape)

Manaaki Whenua – Landcare Research currently operates two containment facilities for the containment of invertebrates (MPI Standard 154.02.08), plant pathogens (MPI Standard 154.03.0) and exotic plants (MPI Standard 155-04-09). These facilities are regularly audited by MPI to ensure compliance with these operating standards, and are managed under two operating manuals, one for the David Miller Facility in Lincoln, and the other for the Beever Plant Pathogen Containment Facility in Auckland. These facilities are consistently used for host range testing of imported invertebrates and plant pathogens as potential biological control agents for alien invasive plants in New Zealand.

All plants species approved for importation will be contained to prevent the escape of plants (and their heritable material such as seeds, pollen, invertebrates, and micro-organisms housed within (5713/ATP26909). Containment is achieved by a combination of physical design specifications of the buildings, stringent laboratory operating procedures, and quality air flow and controlled access systems. Containment is also achieved through the identification of the pathways of escape, and by the application of procedures to prevent escape via these pathways. This is best achieved by following established procedures and protocols along with maintaining the integrity of the cages, rooms, building, doors, wastewater treatment equipment and air-filtration systems in the containment facility. These procedures follow best practice developed by MWLR and other containment facilities and are detailed in our containment manual (See Transitional and Containment Manual; March 2021; Arnaud Cartier and A. H. Gourlay).

Potential pathways of escape are:

Pathway Procedures to mitigate risk

Escape of organisms during During transport, all plants are housed in well labelled sealed transport to containment containers reducing the risk of escape. These containers facilities consist of three layers of sealed containment.

Accidental/unintentional Only authorised persons will be permitted entry who have removal by authorised received training in containment protocols reducing the risk of personnel escape. This includes maintenance contractors who are also trained in containment facilities prior to gaining access. All maintenance contractors are accompanied by authorised MW personnel when entering and exiting the buildings.

All authorised staff and contractors are required to wear protective clothing in the containment facility which is then

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removed prior to exiting, thus ensuring that pollen, seeds, spores and invertebrates are not inadvertently carried out on their persons.

Deliberate removal by Security measures in place mitigate the risk of unauthorised unauthorised personnel personnel gaining access to the facility. This includes controlled access with the use of swipe cards only issued to authorised containment facility users.

Escape from contaminated Heat sterilisation of all waste reduces the risk of organisms laboratory equipment and being accidentally released. waste All solid rubbish generated in the secure rooms is single- bagged and autoclaved. Liquid waste is heat treated and sterilised before being discharged into the wastewater system. All air circulating in the facility is expelled through medical grade Hepa® filters preventing the escape of airborne spores or pollen or seeds. The facility is kept in a clean and tidy condition with no unnecessary rubbish. Floors are mopped regularly. All rearing containers are sterilised between uses. The room is disinfected, thoroughly cleaned, and sterilised between projects.

Escape due to a failure of There is inbuilt redundancy in the containment design that containment barriers reduces the risk of machinery failure and therefore escape.

Escape from containment A fire contingency plan has been lodged with the local fire following natural disaster brigade listing how to deal with a disaster so as to prevent or minimise the chance of escape.

These risks are further addressed by:

• There are quality assurance systems in place for the facilities to achieve a level of containment that exceeds level PC2 and MAF standards. Additional containment features not mentioned above include: 1) directional negative air flow within the building leading to the corridor or wet lab areas; 2) HEPA filtration of all air exiting the building; 3) closed air circulation systems for each of the high-level containment growth rooms; 4) showering of personnel in the Beaver containment facility prior to exiting the containment rooms.

• The facilities are mechanically ventilated to ensure directional air flow is maintained. Growth-room air is extracted initially through a wire mesh designed to capture any invertebrate vectors. Each growth room (containment compartment) has a closed

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air recirculation system to prevent cross contamination between compartments, and re-circulated air is not released outside unless vented through a Hepa® air filter which filters air at the micron level, effectively capturing all spores and pollen and dust particles and anything larger. There are no external windows that open in either facility.

• The facilities have negative air pressure gradients ensuring that all air flows towards the inner corridor and wet laboratory areas, ensuring that no pollen, air borne seed, dust or potential invertebrate vectors can escape the facility when the doors are opened.

• Each facility has an airlock to ensure airborne seeds, pollen, spores and invertebrates are contained. Each airlock has a light trap to attract and trap any insects that may get into the airlock (or which may enter from the corridor).

• Certified users of the facilities are required to undertake annual refresher training and review of HSNO regulations.

• Plants that will be used for any of the Pacific region biocontrol projects will be propagated in the facilities. Any plants used for these projects will be grown and maintained in the containment rooms. When trials are complete, the rooms will be cleared of all material, cleaned and decontaminated according to procedures outlined in the facility operational manuals.

• No viable propagules or biological material will be removed from either containment facility without an approved Movement Request. Any material that is to be transported to an appropriate containment facility or shipped overseas to a suitable facility or for release in one of the PICTS will require a transfer approval. All organisms moved into or out of MWLR containment facilities will be double packaged and transported from the laboratories in accordance with Packaging Instruction No. 650 of the IATA Dangerous Goods Regulations. This involves shipping of plants and biocontrol agents in a leak-proof plastic container which are held in a chillibin and sealed shut with packaging tape.

• Any equipment leaving the facilities is decontaminated with either 70% ethanol spray and/or Sterigene solution following the appropriate procedures outlined in the facility manual to ensure no viable plant or other biological material leaves the facilities.

The likelihood of an escape (through accident or incident), from the PC2 transitional and containment facilities is negligible (see section 6). However, in the event of an escape, an organism escape contingency plan will be initiated (refer to Facility Manuals).

The risk of working with exotic organisms absent from the New Zealand environment is almost entirely mitigated through the level of containment achieved in MWLR’s

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containment facilities at Tamaki and Lincoln. Further, in the highly unlikely event of an escape from either facility, the plant populations could be eradicated with the use of physical removal, heat treatment or the application of an appropriate herbicide. All plant material cleared from the infected site/s would be burned, and monitoring of the site/s will be ongoing and conducted for several seasons to detect any plants that escape control, or to detect regeneration.

5. Māori engagement

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

Consultation with local Māori groups (Ngati Paoa, Ngati Tai Ki Tamaki, Ngāti Whātua Ōrākei Waikato Tainui, Ngāi Tahu) took place during March 2021 by email (Appendix 2). No issues were raised during consultation.

6. Risks, costs and benefits

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

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

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

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

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The potential risks, costs and benefits of the proposed introduction into New Zealand containment of several weeds being targeted for biocontrol in the Pacific, as well as their close relatives that are native to or economically important in the Pacific region, have been identified and considered. All effects considered to be significant are discussed below.

The primary risks are associated with the potential for the imported plant species or their heritable material, or any associated organisms to:

• ‘escape’ containment via a containment breach

• establish wild populations in New Zealand.

Potential costs are associated with eradicating plants and/or other organisms if a containment breach occurs.

The primary benefits are our ability to provide Pacific Island countries with tools to help minimise the negative impacts of invasive weeds that threaten their people’s livelihoods, the sustainability of their agriculture sector, food security, and their resilience to climate change impacts. Another benefit is the advancement of New Zealand’s foreign affairs aspirations.

6.1 Potential adverse effects on the environment (risks and costs)

Potential adverse effects on the environment, on New Zealand ecosystems and their constituent parts, could only occur if any of the imported plant species and/or their associated organisms ‘escaped’ MWLR containment facilities and established wild populations, potential adverse effects could be:

• Deterioration of ecosystems and loss of biodiversity if the plant population or associated organism cannot be eradicated from the environment. • Potential impacts on the health of our native and valued fauna. • Likely flow-on effects to the mauri (life force) of those species and the role of Māori as kaitiaki (guardians/stewards) in the maintenance and management of mauri.

A breach of containment enabling organisms to ‘escape’

It is highly unlikely that an imported plant species or any associated organisms would escape from containment. The containment facilities of MWLR, in which these exotic plant species will be housed, are strictly maintained in accordance with MPI standards and containment protocols laid out in Section 4.2. These specialist facilities are regularly approved to continue to operate via MPI auditing. Compliance audits which confirm that operations are following strict procedures is a confirmation that due procedures and processes are being followed to ensure that all species housed within the facility are effectively contained (Section 4.2).

All plant species imported into New Zealand under this approval (if issued) will be exclusively propagated and maintained in approved and audited PC2 containment facilities (see Section 4.2).

Establishment of wild plant populations in New Zealand in the event of an ‘escape’

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In the highly unlikely event that a plant or its heritable material (pollen, spores, seeds) escape containment, the risk of it establishing permanent populations in the New Zealand environment is low to negligible.

The risk directly associated with the plant species that will be imported into containment under this proposed approval are even more unlikely to establish in the New Zealand environment since their native and invasive ranges occur in tropical region/subtropical regions of the Pacific. The climate classifications of New Zealand, according to the Köppen- Geiger system are Cfb (oceanic climate) and Cfc (subpolar oceanic climate). The climate classification of the Pacific Island countries for which the proposed research is intended is Af (tropical rainforest climate). All of the plant species that will be imported into containment in New Zealand for these Pacific programmes are adapted to subtropical/tropical climates and are thus very unlikely to establish and thrive in the New Zealand environment. For imported plant species of tropical origin, the risk of establishment is likely to be in the orders of magnitude of lower than 1%. Only 10% of introduced species become naturalised in New Zealand and only 10% of naturalised species become invasive (the ‘tens rule’, Williams and West, 2000). This equates to only 1 percent of introduced plants becoming invasive weeds.

In the highly unlikely event that an incursion occurs, eradication is usually cost-effective and feasible, provided it is detected early. The success rate of eradicating weed infestations less than 1 ha in size is very high and takes, on average, 63 work hours (Rejmánek & Pitcairn 2002). In New Zealand, this would not cost more than a few thousand dollars.

The Arceuthobium spp. that would be imported into containment are intended for release in the New Zealand environment as biocontrol agents for the invasive, non-commercial wilding pine, Pinus contorta. Establishment of wild populations in the New Zealand environment is their intended purpose.

In summary, the likelihood of an undesirable species both escaping containment and subsequently establishing in New Zealand is extremely low. Should such an event occur, impacts could be mitigated by eradication, with associated costs. Should a species escape eradication, established populations could potentially have adverse ecological and economic effects. Although the magnitude of such an event would be minimal to moderate, the overall risk of such an unlikely event is negligible.

6.2 Potential beneficial effects

The New Zealand government is increasing its commitment to enhancing sustainable development in the Pacific region. The proposed work in this application forms part of an MFAT programme which aims to support developing countries in the Pacific in several key ways, one of which is improved management of invasive alien plant species. Importing, holding and investigating exotic plants and their natural enemies/biocontrol agents in containment forms the basis of New Zealand’s ability to assist countries in the Pacific with classical biocontrol of weeds. This pre-release research cannot be conducted elsewhere in the Pacific as the countries for which the biocontrol agents are intended lack containment facilities required to conduct the research safely and effectively.

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New Zealand’s involvement in these MFAT programmes also provides an opportunity to further increase the skills and knowledge of our researchers through the opportunity to work on a wider range of weed targets and to collaborate with international researchers. Overall, this will enhance our ability to protect New Zealand from weed invasions in the future.

The New Zealand government has committed $100 million over four years (2020-2024) to controlling wilding pines. Pinus contorta is the worst wilding pine. Targeting this species for biocontrol using host specific dwarf mistletoe species could significantly reduce future control costs for P. contorta in New Zealand, and would significantly reduce the threat of this species to New Zealand’s environment, biodiversity, and economy.

Parasitic plants such as the dwarf mistletoes, Arceuthobium spp. have never been used as classical biocontrol agents anywhere in the world, and thus New Zealand would lead a pioneering branch of this science.

7. Alternative methods and potential effects from the transfer of genetic elements This section is for developments of GMOs that take place outdoors and field tests of GMOs only

• Discuss if there are alternative methods of achieving the research objective. • Discuss whether there could be effects resulting from the transfer of genetic elements to other organisms in or around the site of the development or field test.

8. Pathway determination and rapid assessment This section is for the imports of GMOs only

Under section 42B of the HSNO Act your application may be eligible for a rapid assessment. The pathway for your application will be determined after its formal receipt, based on the data provided in this application form. If you would like your application to be considered for rapid assessment (as per the criteria below), we require you to complete this section.

8.1. Discuss whether the GMO(s) to be imported fulfil the criteria The criteria are: • The host organism(s) are Category 1 or 2 host organisms as per the HSNO (Low Risk Genetic Modification) Regulations • The genetic modifications are Category A or B modifications as per the HSNO (Low Risk Genetic Modification) Regulations and the modifications are not listed in the Schedule of these Regulations • The minimum containment of the GMO(s) will be as per the HSNO (Low Risk Genetic Modification) Regulations (PC1 or PC2 as per AS/NZS2243.3:2002)

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9. Other information

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

Appendix 1 A-C Plant genera and species for importation into containment for weed biocontrol research for the Pacific region and New Zealand.

1A List of target weeds in the Pacific region (none occurring in New Zealand)

Family Genus Species Common name Asteraceae Sphagneticola trilobata L. (1759) Singapore daisy, trailing daisy, wedeliae, creeping-oxeye, Bay Biscayne creeping-oxeye Mikania micrantha Kunth (1818) bitter vine, climbing hemp, American rope, mile-a-minute weed Parthenium hysterophorus L. (1753) famine weed, whitetop weed, Santa- Maria, Santa Maria feverfew Chromolaena odorata (L.) R.King & H.Rob Siam weed, triffid weed, Christmas (1970) bush, devil weed, Communist Pacha, common floss Bignoniaceae Tecoma stans (L.) Juss. ex Kunth yellow bells, yellow trumpetbush, (1819) yellow elder, ginger-thomas Decalobanthus peltatus (L.) A.R.Simões & Staples (2017)

Cucurbitaceae Coccinia grandis (L.) Voigt (1845) ivy gourd, scarlet gourd, tindora and kowai Falcataria moluccana (Miq.) Barneby & Moluccan J.W. Grimes Senna tora (L.) Roxb. (1832) sickle senna, sickle wild-sensitive plant, sickle pod, tora, coffee pod, foetid cassia Mimosa diplotricha C.Wright (1869) Giant sensitive plant, giant false syn. invisa Mart. Ex Colla sensitive plant, nila grass (1834) chinense (Osbeck) Mabb. (1989) Melastomataceae Clidemia hirta (L.) D.Don (1823) soapbush, Koster’s curse

Solanaceae Cestrum nocturnum L. (1753) Lady of the night, night-blooming jessamine, poisonberry diurnum L. (1753) Day-blooming jessamine, day cestrum, day-blooming jasmine

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1B List of plant genera which include some species not present in New Zealand

Order Family Genus

Alismatales Araceae Epipremnum Schott (1857)

Cucurbitales Cucurbitaceae Coccinia Wight & Arn. (1834)

Diplocyclos (Endl.) Post & Kuntze (1903)

Muellerargia Cogn. (1881)

Papuasicyos Duyfjes (2003) syn. Urceodiscus W.J. de Wilde & Duyfjes

Zehneria Endl. (1833) syn. Neoachmandra W.J. de Wilde & Duyfjes

Fabales Fabaceae Acacia Mill. (1754)

Albizia Durazz. (1772)

Archidendron F.Muell. (1865)

Archidendropsis I.C.Nielsen (1983)

Cathormion (Benth.) Hassk. (1855)

Desmanthus Willd. (1806)

Entada Adans. (1763)

Falcataria (I.C.Nielsen) Barneby & J.W.Grimes (1996)

Kanaloa Lorence & K.R.Wood (1994)

Mimosa L. (1753)

Pararchidendron I.C.Nielsen (1984)

Schleinitzia Warb. (1891)

Serianthes Benth. (1844)

Senegalia Raf. (1838)

Dolichandrone (Fenzl) Seem. (1862) Bignoniaceae

Clerodendrum L. (1754) Lamiaceae

Oxera Labill. (1824)

Rotheca Raf. (1838)

Volkameria L. (1754)

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Clidemia D.Don (1823) Myrtales Melastomataceae

Camonea Raf. (1836) Convolvulaceae

Decalobanthus Ooststr. (1936)

Distimake Raf. (1836)

Hewittia Wight & Arn.(1837)

Merremia Dennst. ex Endl. (1841)

Operculina Silva Manso (1836)

Polymeria R.Br. (1810)

Xenostegia D.F.Austin & Staples (1981)

Lycium L. (1753) Solanaceae

Nothocestrum A.Gray (1862)

1C List of species in the genus Arceuthobium which are candidate biocontrol agents for Pinus contorta in New Zealand

Order Family Genus Species

Santalales Viscaceae Arceuthobium americanum nutt. Ex A.Gray (1850) Arceuthobium campylopodum subsp. tsugense (Rosend.) Nickrent (2012) syn. tsugense subsp. contortae Wass & Mathiasen (2003)

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Appendix 2 Consultation email sent to local Māori groups (Ngati Paoa, Ngati Tai Ki Tamaki, Ngāti Whātua Ōrākei Waikato Tainui, Ngāi Tahu) of Tamaki and Lincoln in March 2021.

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

Application Comments/justifications

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

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

Supplementary optional information attached:

• Copies of additional references ☐ Yes ☒ No

• Relevant correspondence ☒ Yes ☐ No

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

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

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

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

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

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

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

14/7/2021

Signature Date

Request for information waiver under section 59 of the HSNO Act

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

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

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

Hawksworth FG, Wiens D, 1996. Dwarf Mistletoes: Biology, Pathology and Systematics. Agricultural Handbook 709. Washington DC, USA: United States Department of Agriculture Forest Service.

Jerome, CA, Ford, BA, 2002. The discovery of three genetic races of the dwarf mistletoe Arceuthobium americanum (Viscaeae) provides insight into the evolution of parasitic angiosperms. Molecular Ecology 11: 387-405.

Rejmánek, M, Pitcairn, M, 2002. When is eradication of exotic pest plants a realistic goal? Turning the tide: the eradication of invasive species. IUCN SSC Invasive Species Group, Gland, Switzerland and Cambridge, UK, pp. 249-253.

Shamoun, SF, Ramsfield, TD, van der Kamp, BJ, 2003. Biological control approach for management of dwarf mistletoes. New Zealand Journal of Forestry Science 33, 373-384.

Wass EF, Mathiasen RL, 2003. A new subspecies of hemlock dwarf mistletoe (Arceuthobium tsugense subsp. contortae, Viscaceae) from British Columbia and Washington. Novon 13: 268-276.

Williams JA, West CJ, 2000. Environmental weeds in Australia and New Zealand: issues and approaches to management. Austral Ecology 25, 425-444.

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