APP203514 Soil fungus import and release Submissions 29 November 2018 Under section 34 of the Hazardous Substances and New Organisms Act 1996 Volume 1 of 1 To import and release the arbuscular mycorrhizal fungus Glomus iranicum var. tenuihypharum in New Zealand Submission Number Submitter Submitter Organisation SUBMISSION 127379 Clinton Care SUBMISSION 127403 Ian Dickie SUBMISSION 127407 Gerry Coates Te Runanga o Ngai Tahu SUBMISSION 127408 Peter Buchanan Landcare Research NZ Ltd SUBMISSION 127409 Rod Hitchmough Dept of Conservation SUBMISSION 127410 Cliff Mason 1 SUBMISSION 127379 From: Account Update [mailto:[email protected]] Sent: Friday, 19 October 2018 10:28 PM To: submissions <[email protected]> Subject: Re: APP203514 Application open for public submissions - Soil fungus Hi Diane, Regarding importation and release the arbuscular mycorrhizal fungus Glomus iranicum var. tenuihypharum in New Zealand... I think ... be careful about exotic soil fungus as it may kill native worms and earthworms or other fungus in soil. One of our native worm were imported to Britain and these worms ate many earthworms in British soil. Try testing the exotic soil fungus in a large pot of soil, with earthworms. Yours Sincerely Clinton Care. 1 SUBMISSION 127403 SUBMISSION FORM For Hazardous Substance and New Organism Applications Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected] Once your submission has been received the submission becomes a public document and may be made publicly available to anyone who requests it. You may request that your contact details be kept confidential, but your name, organisation and your submission itself will become a public document. Submission on application APP203514 number: Name of submitter or contact for Prof. Ian A. Dickie joint submission: Organisation name (if on behalf of an organisation): Postal address: School of Biological Sciences, University of Canterbury Private Bag 4800 Christchurch 8140 Telephone number: 033692268 Email: [email protected] I wish to keep my contact details confidential The EPA will deal with any personal information you supply in your submission in accordance with the Privacy Act 1993. We will use your contact details for the purposes of processing the application that it relates to (or in exceptional situations for other reasons permitted under the Privacy Act 1993). Where your submission is made publicly available, your contact details will be removed only if you have indicated this as your preference in the tick box above. We may also use your contact details for the purpose of requesting your participation in customer surveys. The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982. www.epa.govt.nz 2 Submission Form I support the application I oppose the application I neither support or oppose the application The reasons for making my submission are1: (further information can be appended to your submission, see footnote). In my professional opinion as a researcher with 18 years of experience in mycorrhizal fungi, and over 10 years of experience working with invasive species in New Zealand, the proposal has over-stated the benefits of this introduction and under-stated the potential for harm. Please see attached document for my complete assessment of the proposal. All submissions are taken into account by the decision makers. In addition, please indicate whether or not you also wish to speak at a hearing if one is held. I wish to be heard in support of my submission (this means that you can speak at the hearing) I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing) If neither box is ticked, it will be assumed you do not wish to appear at a hearing. I wish for the EPA to make the following decision: The application should be declined. Please see the attached document for further information. 1 Further information can be appended to your submission, if you are sending this submission electronically and attaching a file we accept the following formats – Microsoft Word, Text, PDF, ZIP, JPEG and JPG. The file must be not more than 8Mb. July 2016 EPA0190 Hazardous Substances and New Organisms Environmental Protection Authority Private Bag 63002 Wellington 6140 [email protected] Re: APP203514 Application open for public submissions - Soil fungus I am writing this submission in opposition to APP203514, a proposal to introduce Glomus iranicum var. tenuihypharum (syn. Dominikia iranica), on the basis of my professional expertise as Professor of Microbial Ecology at the University of Canterbury and a project leader at the Bio-Protection Research Centre. The views I present are my own, informed by my research experience, specifically in the area of mycorrhizal ecology, including publications on invasive mycorrhizal fungi and the risks associated with introducing fungal symbionts. The proposal is to introduce Glomus iranicum var. tenuihypharum, which forms arbuscular mycorrhizal associations with plants. The fungus was isolated in Spain, but the same species has been found in multiple countries. A mixture of this variety of fungus with clay has been patented (US2017/0188587). It should also be noted that the species name provided in the application is no longer current, as Glomus iranicum is now understood to be Dominikia iranica (Blaszkowski et al. 2015). I make the following notes about this proposed introduction: 1. The benefits of this introduction are overstated and risks are considerable Arbuscular mycorrhizal fungi are naturally present in soils, with multiple species typically co- occurring. As a group, these fungi are highly beneficial to most plants and are an important component of the soil ecosystem, including enhancing soil structure. There is no question that arbuscular mycorrhizal symbioses are beneficial under most natural circumstances. Nonetheless, arbuscular mycorrhizal fungi are already present in the majority of soils at levels sufficient to meet plant needs for mycorrhizal associations. In the relatively uncommon situation where mycorrhizal inoculum potential in soils is low (e.g., following a Brassica rotation or agricultural conversion from pine plantation), there are already available products. Mycorrhizal inoculum products are sold worldwide, including in New Zealand. These include Mycormax (https://www.rd2.co.nz/product/mycormax-2/), and Myco-Gro (http://flrc.massey.ac.nz/workshops/15/Manuscripts/Paper_Monk_2015.pdf). Other, already-available, products claim to enhance indigenous arbuscular mycorrhizal inoculation potential of agricultural soils (http://biostart.co.nz/products/soil-microbial- activators/mycorrcin/). As such, the introduction of this new species would not provide a service that is currently lacking in New Zealand. There is a long history of many mycorrhizal inoculum products failing to show much benefit to plants under field conditions. This often reflects problems with storage and shipping of inoculum, and/or inappropriate application. Further, the presence of established fungal communities in soils is a strong barrier to successful introduction and maintenance of introduced strains. Finally, in many agricultural settings, the overall benefits of mycorrhizal fungi to plants may be small, with a recent comprehensive review finding little evidence that farmers need be concerned about mycorrhizas under typical farm conditions (Ryan and Graham 2018). This largely reflects the high carbon cost of supporting mycorrhizal fungi, and relatively minor benefits under high P conditions. There are also reports that arbuscular mycorrhizal fungi can become parasitic on agricultural crops (Hendrix et al. 1992), particularly under high nutrient situations (Buwalda and Goh 1982; Peng et al. 1993; Ryan and Graham 2002; Lekberg and Koide 2005; Grace et al. 2009). At least one recent study has found that the abundance of Glomus iranicum is negatively correlated with wheat production in organic agriculture, which the authors attribute to a high carbon demand of the fungus from the host (Dai et al. 2014). As such, it cannot be assumed that introducing Glomus iranicum will enhance agricultural productivity, and, indeed, there is some evidence that it could put agricultural productivity at risk. 2. The fungus will spread widely In the submission to introduce the species, it is claimed that “its spread is confined to the application zone”. This is not supported by scientific evidence, and I suggest that Glomus iranicum is almost certain to spread beyond the site of introduction. Arbuscular mycorrhizal fungi produce spores and hyphal fragments that are dispersed by soil and root movements, rodents (Mangan and Adler 1999), birds (Nielsen et al. 2016; Correia et al. 2018), and wind (Warner et al. 1987; Egan et al. 2014; de Leon et al. 2016). The suggestion in the application that fungi only spread by root-to-root contact is provably false on the basis of scientific literature. Any applied spores are therefore likely to spread widely into adjacent ecosystems. The plant-host specificity of arbuscular mycorrhizal fungi is low, hence once they disperse it is highly likely that the fungus will associate with a broad range of plants, including in native ecosystems. 3. There will likely be impacts on native fungal communities Fungi, like all organisms, compete