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
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
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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 for resources. If successfully introduced Glomus iranicum will inevitably compete with other fungi for space on plant roots (Wilson 1984; Hepper et al. 1988) and potentially for soil resources. Thus the introduction of Glomus iranicum is likely to reduce populations of native arbuscular mycorrhizal fungi, many of which species are still unknown to science. High populations of Glomus iranicum may also support parasites and pathogens that impact directly on native arbuscular mycorrhizal fungi (pathogen spill-over and spill-back).
4. The introduction may compromise native fungal genetics In addition to ecological interactions (competition, pathogen spill-over and spill-back), introduced Glomus iranicum may have the potential to hybridize with native fungi. The reproductive life-cycle of Glomus remains unknown. While arbuscular mycorrhizal fungi have a high production of asexual spores, there is some evidence that sexual reproduction may also take place. Further, arbuscular mycorrhizal fungi such as Glomus are able to show anastomosis, where hyphae of more than one individual fuse and share cellular contents (Parniske 2008). It has been (controversially) suggested that this can lead to fungal spores containing nuclei from multiple species. Given how little is known about the reproductive cycle of Glomus, these potential impacts remain difficult to quantify, but should be considered in detail before permitting any new species introductions.
5. The introduction is likely to change plant communities Arbuscular mycorrhizal fungi show a degree of plant-host preference, with different species of fungi occurring on different plant hosts (Martinez‐Garcia et al. 2015). Fungi may also differ in the degree to which they benefit one plant host over another. It is widely recognized that arbuscular mycorrhizal fungi can cause growth depressions in some plant species and that benefits provided to plants are highly unequal across plant species (Klironomos 2003; Schwartz et al. 2006). The spread of Glomus iranicum is therefore likely to cause changes in the competitive hierarchies of plants, allowing some plant species to become more dominant at the expense of others. This is particularly a risk in terms of facilitating non-native plant invasions. The introduction of non-native fungi is considered to be responsible for facilitating the invasion of wilding pines (Pinus contorta) and other invasive plants in New Zealand (Dickie et al. 2010; Dickie et al. 2017), a process that has also been observed in international research (Hynson et al. 2013; Hayward et al. 2015).
6. The introduction will be irreversible Introducing fungi would likely be an irreversible decision. There are no known examples where an introduced fungus has been successfully eliminated once established (Dickie et al. 2016). Hence, should Glomus iranicum be introduced, it will likely be impossible to remove the species at a later date. The suggestion from the proposal that removing plant roots and spraying fungicide would eradicate Glomus iranicum is based on the assumptions that (a) there will be no spread, (b) all roots can be physically removed from soil, and (c) that fungicide is effective against Glomus. None of these assumptions have been shown to be true. In summary, the benefits of allowing this introduction are likely to be minimal, the risk of spread and impacts on native fungal and plant communities are high, and any introduction will likely be an irreversible decision. The application to introduce the organism under-states the potential for spread, fails to consider potential impacts on native plant and fungal communities, and incorrectly states that removal would be possible. From my professional viewpoint, the risks are vastly greater than any potential benefits from this proposed introduction. On that basis, and on the basis of a fairly extensive scientific literature on the topic of invasive mycorrhizal fungi (Schwartz et al. 2006; Nunez and Dickie 2014; Nunez et al. 2015; Dickie et al. 2016; Dickie et al. 2017), I believe the application should be declined.
Signed,
Ian Dickie, Professor of Microbial Ecology, School of Biological Sciences, University of Canterbury
References
Blaszkowski J, Chwat G, Góralska A, Ryszka P, Kovács GM 2015. Two new genera, Dominikia and Kamienskia, and D. disticha sp. nov. in Glomeromycota. Nova Hedwigia 100: 225–238. Buwalda JG, Goh KM 1982. Host-fungus competition for carbon as a cause of growth depressions in vesicular-arbuscular mycorrhizal ryegrass. Soil Biology and Biochemistry 14: 103–106. Correia M, Heleno R, da Silva LP, Costa JM, Rodríguez‐Echeverría S 2018. First evidence for the joint dispersal of mycorrhizal fungi and plant diaspores by birds. New Phytologist Dai M, Hamel C, Bainard LD, Arnaud MS, Grant CA, Lupwayi NZ, Malhi SS, Lemke R 2014. Negative and positive contributions of arbuscular mycorrhizal fungal taxa to wheat production and nutrient uptake efficiency in organic and conventional systems in the Canadian prairie. Soil Biology and Biochemistry 74: 156–166. de Leon DG, Moora M, Öpik M, Jairus T, Neuenkamp L, Vasar M, Bueno CG, Gerz M, Davison J et al. 2016. Dispersal of arbuscular mycorrhizal fungi and plants during succession. Acta oecologica 77: 128–135. Dickie IA, Bolstridge N, Cooper JA, Peltzer DA 2010. Co-invasion by Pinus and its mycorrhizal fungi. New Phytologist 187: 475–484. Dickie IA, Bufford JL, Cobb RC, Desprez‐Loustau M, Grelet G, Hulme PE, Klironomos J, Makiola A, Nuñez MA et al. 2017. The emerging science of linked plant–fungal invasions. New Phytologist 215: 1314–1332. Dickie IA, Nuñez MA, Pringle A, Lebel T, Tourtellot SG, Johnston PR 2016. Towards management of invasive ectomycorrhizal fungi. Biological Invasions 18: 3383–3395. Egan C, Li D-W, Klironomos J 2014. Detection of arbuscular mycorrhizal fungal spores in the air across different biomes and ecoregions. Fungal Ecology 12: 26–31. Grace EJ, Cotsaftis O, Tester M, Smith FA, Smith SE 2009. Arbuscular mycorrhizal inhibition of growth in barley cannot be attributed to extent of colonization, fungal phosphorus uptake or effects on expression of plant phosphate transporter genes. New Phytologist 181: 938–949. Hayward J, Horton TR, Pauchard A, NUNez MARTINA 2015. A single ectomycorrhizal fungal species can enable a Pinus invasion. Ecology 96: 1438–1444. Hendrix JW, Jones KJ, Nesmith WC 1992. Control of pathogenic mycorrhizal fungi in maintenance of soil productivity by crop rotation. Journal of Production Agriculture 5: 383– 386. Hepper CM, Azcon‐Aguilar C, Rosendahl S, Sen R 1988. Competition between three species of Glomus used as spatially separated introduced and indigenous mycorrhizal inocula for leek (Allium porrum L.). New Phytologist 110: 207–215. Hynson NA, Merckx VSFT, Perry BA, Treseder KK 2013. Identities and distributions of the co-invading ectomycorrhizal fungal symbionts of exotic pines in the Hawaiian Islands. Biol Invasions Klironomos JN 2003. Variation in plant response to native and exotic arbuscular mycorrhizal fungi. Ecology 84: 2292–2301. Lekberg Y, Koide RT 2005. Is plant performance limited by arbundance of arbuscular mycorrhizal fungi? A meta-analysis of studies published between 1988 and 2003. New Phytologist 168: 189–204. Mangan SA, Adler GH 1999. Consumption of arbuscular mycorrhizal fungi by spiny rats (Proechimys semispinosus) in eight isolated populations. Journal of Tropical Ecology 15: 779–790. Martinez‐Garcia LB, Richardson SJ, Tylianakis JM, Peltzer DA, Dickie IA 2015. Host identity is a dominant driver of mycorrhizal fungal community composition during ecosystem development. New Phytologist 205: 1565–1576. Nielsen KB, Kjøller R, Bruun HH, Schnoor TK, Rosendahl S 2016. Colonization of new land by arbuscular mycorrhizal fungi. Fungal Ecology 20: 22–29. Nunez MA, Dickie IA 2014. Invasive belowground mutualists of woody plants. Biological Invasions 16: 645–661. Nunez MA, Dimarco RD, Dickie IA, Pauchard A 2015. ¿ Qué puede salir mal?: Los riesgos de introducir microorganismos del suelo de la Antártida en América del Sur. Bosque (Valdivia) 36: 343–346. Parniske M 2008. Arbuscular mycorrhiza: the mother of plant root endosymbioses. Nature Reviews Microbiology 6: 763. Peng S, Eissenstat DM, Graham JH, Williams K, Hodge NC 1993. Growth depression in mycorrhizal citrus at high-phosphorous supply. Plant Physiology 101: 1063–1071. Ryan MH, Graham JH 2002. Is there a role for arbuscular mycorrhizal fungi in production agriculture? Plant and Soil 244: 263–271. Ryan MH, Graham JH 2018. Little evidence that farmers should consider abundance or diversity of arbuscular mycorrhizal fungi when managing crops. New Phytologist Schwartz MW, Hoeksema JD, Gehring CA, Johnson NC, Klironomos JN, Abbott LK, Pringle A 2006. The promise and the potential consequences of the global transport of mycorrhizal fungal inoculum. Ecology Letters 9: 501–515. Warner NJ, Allen MF, MacMahon JA 1987. Dispersal agents of vesicular-arbuscular mycorrhizal fungi in a disturbed arid ecosystem. Mycologia 721–730. Wilson JM 1984. Competition for infection between vesicular‐arbuscular mycorrhizal fungi. New Phytologist 97: 427–435.
SUBMISSION 127407
He tono nā
ki te ENVIRONMENTAL PROTECTION AUTHORITY
e pā ana ki te SUBMISSION ON APP203514 – For approval to release the arbuscular mycorrhizal soil fungus Glomus iranicum var. tenuihypharum.
26 November 2018
Author – Gerry Te Kapa Coates Ngāi Tahu HSNO Komiti
Sponsor – Kara Edwards General Manager – Te Ao Tūroa | Te Kaihautū o Te Ihu Waka I Te Rūnanga o Ngāi Tahu [email protected] I Phone 03 366 4344 I PO Box 13-046 I Christchurch
Oppose – conditional request to be heard
Contents
1. EXECUTIVE SUMMARY 2. ABOUT TE RŪNANGA O NGĀI TAHU 3. TE RŪNANGA STATEMENTS OF POSITION 4. RECOMMENDATIONS ON APP203514
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1. EXECUTIVE SUMMARY
Over the years, Te Rūnanga o Ngāi Tahu (TRoNT) has advocated for restraint in approving new organisms, particularly those resulting from genetic modification or those that can form self- sustaining populations. We are usually generally supportive of any proposal which may decrease the burden of pesticide residues or their breakdown products on the biotic and abiotic environments. In this case the applicant has been quite open that they are applying for the approval to release a new micro-organism, an arbuscular mycorrhizal fungus (AMF) (Glomus iranicum tenuihypharum) in New Zealand “to start to commercialize our products, based on this AMF, in the New Zealand’s market.” They say this is “related to the great market opportunity that New Zealand” linking it to guaranteeing a sustainable future. The applicant has provided no economic estimates of the potential benefits to New Zealand or commented on any possible environmental risks and costs.
Pre-application attempts at consultation with Māori relating to this biocontrol agent were carried out with Māori, including Ngāi Tahu, questioning whether competition with any native Glomus spp. might occur and whether there could be any deleterious effect on native fauna and flora. We believe these risks should have been assessed and where possible been adequately quantified and compared with the benefits.
The AMF is stated not to be a genetically modified organism. It can be used for soil stabilization or as a plant improver through soil maximization and protection with a reduced need for fertilisation. It can be applied through irrigation systems, or in a powder form designed to be used as a seed coating or in a microgranular form designed to be applied through an applicator directly in the planting furrow. The AMF cannot develop outside a host plant and dissemination of the arbuscular mycorrhizal fungus is low since they are lacking aerial spores and only propagate by contact of the spores, the vesicles or the mycelium with the roots of a new host plant. However we wonder if it can also be disseminated – like Kauri dieback disease in NZ – by human and animal traffic.
Our submission generally opposes the Application on the grounds that provided it is primarily for the economic benefit of the applicant’s company as well as for the soil health benefits. No need has been demonstrated and no commentary on the possibility of using NZ Native species of such fungi was provided.
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2. TE RŪNANGA O NGĀI TAHU
2.1. This response is made on behalf of Te Rūnanga o Ngāi Tahu (Te Rūnanga). Te Rūnanga is statutorily recognised as the representative tribal body of Ngāi Tahu Whānui and was established as a body corporate on 24th April 1996 under section 6 of Te Rūnanga o Ngāi Tahu Act 1996 (the Act). We note the following relevant provisions of our constitutional documents:
a) Section 3 of the Act States: This Act binds the Crown and every person (including any body politic or corporate) whose rights are affected by any provisions of this Act.
b) Section 15(1) of the Act states: Te Rūnanga o Ngāi Tahu shall be recognised for all purposes as the representative of Ngāi Tahu Whānui.
c) The Charter of Te Rūnanga o Ngāi Tahu (1993, as amended) constitutes Te Rūnanga as the kaitiaki of the tribal interest.
2.2. Ngāi Tahu is the third largest Māori iwi in Aotearoa with a membership of almost 60,000 who whakapapa to an ancestor in the 1848 census of tūpuna. Its takiwā (area of influence) extends from Kaikōura in the north, to Rakiura (Stewart Island) in the south, including the West Coast, Te Tai Poutini. This comprises over 90% of the South Island or over 40% of the NZ land mass. Te Rūnanga o Ngāi Tahu is statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of Te Rūnanga o Ngāi Tahu Act 1996. This means it exercises kaitiakitanga over this takiwā.
2.3. Te Rūnanga o Ngāi Tahu constitutes 18 Rūnanga representing geographical areas, generally based around traditional settlements.
2.4. Ngāi Tahu Values which dictate its approach to all issues are as follows:
· Whanaungatanga (family) Respect, foster and maintain important relationships within the organisation, within the iwi and within the community.
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· Manaakitanga (looking after our people) Respect each other, iwi members and all others in accordance with our tikanga (customs). · Tohungatanga (expertise) Pursue knowledge and ideas that will strengthen and grow Ngāi Tahu and our community. · Kaitiakitanga (stewardship) Work actively to protect the people, environment, knowledge, culture, language and resources important to Ngāi Tahu for future generations. · Tikanga (appropriate action) Strive to ensure that Ngāi Tahu tikanga is actioned and acknowledged in all of our outcomes. · Rangatiratanga (leadership) Strive to maintain a high degree of personal integrity and ethical behaviour in all actions and decisions we undertake.
2.5. Te Rūnanga respectfully requests that this response is accorded the status and weight due to the mana whenua status of the tribal collective, Ngāi Tahu Whānui.
3. TE RŪNANGA STATEMENTS OF POSITION ON APP203514
3.1. General position on new organisms Over the years, Te Rūnanga o Ngāi Tahu (TRoNT) has advocated for restraint in approving new organisms, particularly those resulting from genetic modification or those that can form self-sustaining populations. We are usually generally supportive of any proposal which may decrease the burden of pesticide residues or their breakdown products on the biotic and abiotic environments. In this case the applicant has been open that they “are applying for the approval to release a new micro-organism, an arbuscular mycorrhizal fungus (AMF) (Glomus iranicum tenuihypharum) in New Zealand to start to commercialize our products, based on this AMF, in the New Zealand’s market. The fact that we want to release our products in New Zealand are related to the great market opportunity that New Zealand represents and to the improve (sic) of agricultural systems to guarantee a sustainable future.”
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In other words this fungus that was originally endemic in Spain is being introduced primarily for business reasons, and our task is to assess whether:
· There is any risk from introducing such a new organism into New Zealand. · Whether there are any benefits to be gained from such an introduction. · Whether such beneficial outcomes can be gained by using similar NZ sourced fungi of the same genera.
3.2. Māori Reference Group A Māori Reference Group (MRG) was formed in 2014 specifically to consider biocontrol applications. The aims of biological control – which were fully supported by the MRG and by Ngāi Tahu – is to reduce risk and reverse harm from damaging organisms, as one of the tools for pest management. The MRG developed some core principles which have also been referred to in the Application. They also apply to this type of application where a new organism is to be introduced ostensibly to improve the fertility of soil.
The species Glomus iranicum has not been detected in New Zealand so far, but this does not mean it is exotic since closely phylogenetic species have been found. This may be related to the lack of studies carried out in New Zealand or to a misidentification of the species. The applicant says that “non-target effects of biofertilizers are often small and transient, the soil system has been found to be resilient to perturbations caused by introduction of exogenous AMF.”
Our summary of the principles for biocontrol – which also apply to new organisms – were as follows:
3.2.1. MRG PRINCIPLES:
Kaitiakitanga
There is a well-recognised kaitiakitanga responsibility for Māori to manage the natural resources within and beyond their hapū and iwi boundaries for the benefit of future generations.
Manaakitanga
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Biocontrol agents pose the potential to both positively impact by aiding in the restoration of balance, and negatively impact by disturbing it further. Good decision-making is thus crucial. If appropriate, regional councils and the Department of Conservation should work with iwi and hapū in their areas on pest management strategies that include monitoring impacts in terms of manaakitanga.
3.2.2. Broad biophysical considerations
Māori will be concerned to know the anticipated and unanticipated potential impact of the introduction of biocontrol agents across the breadth of trophic and ecosystem levels.
Specific impacts on culturally valued species
The reference group recognised that standard host range testing and taxonomical analysis provides data that gives some assurance that any direct adverse effect from the non- target feeding and hybridisation of native species is likely to be minimal.
However the research methodology and results do little to address indirect impacts to culturally valued species.
It is thus important to continue to monitor potential effects (adverse and otherwise) of new introduced supposedly beneficial species on closely related native species.
Selected MRG Recommendations
i) Applicants should provide comment on or model the potentially broader trophic impacts of introducing a biological control agent. This has been done in the Application to some degree. ii) Applicants should provide information about the potential beneficial role a new introduced species may have for local populations of native species. This has been done in this Application in general terms. iii) Applicants should ensure recognition and assessment of impacts (both positive and negative) against appropriate national and regional Treaty principles and provisions.
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3.3. Ngāi Tahu Comments on the Application
General aspects
3.3.1. Biological activities in soil can play a vital part in nutrient cycling and availability to plants and in soil structure, contributing to soil health. Sustainability in land-use requires minimising soil degradation and adapting soil management practices to conserve and augment soil resources.
3.3.2. The Applicant says that the Glomus species is “found all over the world in soil or in edible roots (carrots for example and no case of toxicity, pathogenicity or mention of a glomus toxin can be found in the literature and no signs of toxicity have been seen in research or technical personnel working on the endomycorrhiza during personnel monitoring.” Glomus iranicum var. tenuihypharum is stated not to be a genetically modified organism, the particular strain was isolated from a soil with high salinity in Spain. High salinity in soils is usually a significant drawback for agriculture significantly reducing foliar growth.
3.3.3. Also as an obligatory symbiont, this species, like other Glomalean fungi, cannot develop outside a host plant and dissemination of the arbuscular mycorrhizal fungus is low since they are lacking aerial spores and only propagate by contact of the spores, the vesicles or the mycelium with the roots of a new host plant. Therefore, its dissemination in the environment is limited to the application zone. We wonder however if it can also be disseminated like Kauri dieback disease in NZ by human and animal traffic. Reports apparently show that organic and mineral fertilisation, tilling, monoculture and other agricultural practices all negatively affect AMF abundance and general biodiversity.
3.3.4. AMF can be used for soil stabilization or as a plant improver through:
· Soil maximization and protection with a reduced need for fertilisation.
· Increasing tolerance to drought and/or salinity.
3.3.5. The applicant has developed several formulations: a powder form applied through irrigation systems; a powder form designed to be used as a seed coating; and. a microgranular form designed to be applied through an applicator directly in the furrow.
3.3.6. Where soil conditions have been degraded by the intensive use of chemicals and bad agricultural practices they can be rejuvenated by inoculating the soils with microorganisms, such as G. i. tenuihypharum. The applicant says that such usage is certified in several countries for the use in organic agriculture.
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3.3.7. The applicant says that G. i. tenuihypharum is unable to form self-sustaining populations as an obligate symbiont, depending on association with plant roots to complete their life cycle. However its eradication can be simply achieved by the complete removal of all the roots from the soil, and/or application of soil sanitisation treatments such as fumigation or fungicides.
Māori engagement
3.3.8. The applicant says that Iwi and Māori communities were contacted, as advised by their EPA consultant. This included emails presented to both the Ngāi Tahu and the Ngāpuhi HSNO Komitis and also Ngāti Huarere ki Whangapoua representatives for consultation, They say they received two replies. “Ngāi Tahu showed a deep interest in the introduction of our Glomus spp. into the New Zealand environment. The only concerns were about the competition with native Glomus spp. and any deleterious effect on native fauna and flora.” They say an explanatory answer about these concerns was presented, although we have no record of this, and they say no answer was obtained thus concluding the consultation.
3.3.9. A similar answer was apparently obtained from the Te Herenga network although this correspondence was not included in the application.
Risks, costs and benefits
3.3.10. The applicant says “The effects of mycorrhizal associations on agricultural and horticultural systems are almost all potentially beneficial.” The non-beneficial elements were not identified. “Non-nutritional” effects in stabilizing soil aggregates, and in preventing erosion, and alleviating negative effects induced by salinity” are mentioned however.
Monitoring the release
3.3.11. If the release is approved then a monitoring plan to check the AMF’s efficacy and confirm it does not spread should be carried out by the applicant or another contracted party.
4. CONCLUSIONS AND RECOMMENDATIONS
4.1. Te Rūnanga o Ngāi Tahu holds long-standing concerns over the introduction of new organisms unless the risks are properly assessed, as opposed to any perceived benefits. Generally we have ended up supporting such applications particularly if they are for
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biocontrol. However in this case where the application is primarily for the economic advantage of the applicant and no compelling positive case or need for the introduction is made at best we can remain neutral or oppose the application.
4.2. Because this fungus is being introduced primarily for business reasons, as well as some unquantified soil benefits, our task is to assess whether:
· There is any risk from introducing such a new organism into New Zealand. · Whether there are any benefits to be gained from such an introduction. · Whether such beneficial outcomes can be gained by using similar NZ sourced fungi of the same genera.
4.3. We believe the question of risk has not been adequately addressed in the application. It is not sufficient to assert that “The effects of mycorrhizal associations on agricultural and horticultural systems are almost all potentially beneficial” without identifying what the non-beneficial effects are. Furthermore the benefits to NZ need to be quantified in some way, as well as attributed to a new or existing need.
4.4. The question we raised in pre-application consultations regarding whether “competition with native Glomus spp. and any deleterious effects on native fauna and flora” were likely to arise, have not been satisfactorily answered.
4.5. In this case Ngāi Tahu has decided to oppose the Application on the grounds that an economic case has not been made for the introduction of a new exotic organism for soil stabilization or as a plant improver. In our view the risks that have been alluded to such as effects being “almost all potentially beneficial” have not been stated or quantified.
4.6. We have therefore decided to Oppose this application and to reserve our right to be heard and to make any concerns we have in person, if a hearing is convened for other submitters.
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5. RECOMMENDATION
5.1. Te Rūnanga o Ngāi Tahu Opposes the Applicant’s proposal to release the arbuscular mycorrhizal soil fungus Glomus iranicum var. tenuihypharum.
Gerry Te Kapa Coates MNZM Member, Ngā Tahu HSNO Committee
Email: [email protected] Mobile: 021 355099
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SUBMISSION 127408
SUBMISSION FORM For Hazardous Substance and New Organism Applications
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Submission on application APP203514 number: Name of submitter or contact for Peter Buchanan joint submission: Organisation name Manaaki Whenua - Landcare Research (if on behalf of an organisation): Postal address: Private Bag 92170, Auckland 1142
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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). The application relates to an organism that is new to New Zealand, but consideration is also needed of the patented product(s) that contain this organism The host range of G. iranicum var. tenuihypharum is reported to be large, but is unknown. The variety is reported to be cosmopolitan, but evidence for this is not provided. The patented product contains various biocides (chemicals and live organisms) that will need to be assessed by EPA The potential competition and other effects of the new organism on native Glomus and other mycorrhizal fungi cannot be assumed or assessed. Claims of easy eradication of the new organism if required appear to be unrealistic. The carrier materials comprise about 96-99% of the product but are unlikely to be sterile? Is there a risk of importation of unknowns as contaminants? I note that while the accepted name for Glomus iranicum is now Dominikia iranica, the variety in question, var. tenuihypharum, has not (yet) been recombined in Dominikia. Please see additional information and commentary appended to this submission.
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: I think this organism, and the patented products that contain it, pose unacceptable biosecurity and biodiversity risk to NZ, I request that EPA declines this application.
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 Additional comment relating to my Submission on EPA Application no. APP203514
The following is additional information and commentary to be appended to my submission.
I first refer to selected quoted text from the EPA Application by pagination or by sections (where pagination is disrupted, eg, reverting to “10” at p. 16 …), followed by Comments.
Also attached is detail and questions relating to the composition of the patented product containing Glomus iranicum var. tenuihypharum, and to details about the marketed product MycoUp.
Extracted text from APP203514: p. 7. “Being an obligatory symbiont, this species, like other Glomalean fungi, cannot develop outside a host plant.” …. “its dissemination in the environment is limited to the application zone.”
Comment: Spores of this fungus exist external to the host and hence can be moved in soil. Evidence that such spores can be viable is implicit in the development of Symborg’s products. Host range is unknown, and in the NZ context unknowable. The “application zone” could be of small to large scale depending on how the farmer, orchardist, gardener, nurseryman, or perhaps restoration planter chooses to apply the product. In the Safety Data Sheet relating to Symborg’s MycoUp product that contains this organism, I note a warning to avoid spread and runoff into waterways (see below).
p. 10-11. “According to this phylogeny Glomus indicum and Glomus achrum are the closest relatives. At the NCBI server (genebank) about fifty sequences of uncultured Glomus spp. clones can be found with a very high similarity (99%) to the sequence of the SYMBORG strain investigated here. It seems therefore, that the new taxon has a cosmopolitan distribution and a wide host range. The most similar sequences were retrieved from samples from Japan (Ogura-Tsujita et al., 2013; Yamato et al. 2011), New Zealand (Russel & Bulman 2005), Africa (Merckx & Bidartondo, 2008) and from North America (Appoloni et al. 2008).”
Comment: While allegedly a cosmopolitan variety, the applicant does not supply evidence to substantiate this distribution. Sequence data is indicated as “similar” to that of other taxa, though the latter remain discriminated as separate species. Its host range is unknown, though alleged to be large. The New Zealand Glomus species referred to are 2 native species associated with a liverwort (Russell & Bulman 2005).
Comment: The applicant’s assessment of close relatives of G. iranicum var. tenuihypharum needs to be considered in light of the statement from the authors who described G. iranicum. Those authors wrote: “G. iranicum has no apparent molecular relatives among described Glomus spp.” https://www.tandfonline.com/doi/full/10.3852/09-302
Section 5 - Potential beneficial effects:
“Moreover, the presence of several variants of Glomus sp. in New Zealand was reported recently (Johansen et al., 2015) in a study to identify the presence of mycorrhizal fungi in the coastal and sand dunes areas, indicating that the presence of AMF is beneficial for maintaining plant vigour and for the dune restoration efforts.” Comment: NZ’s native arbuscular mycorrhizal fungi (AMF) are beneficial and important. Introduction of exotic species may result in competition with and/or displacement of native species.
Section 5 - Potential adverse effects:
“We should consider that arbuscular mycorrhizal fungi dated from 450 million years ago and had followed the natural evolution of most of the plant species until today. So, the use of Glomus iranicum var. tenuihypharum do not cause diseases, do not stablish parasitic relationships nor become a vector for animals or plants.”
Comment: Natural evolution of native AMF and native plants is positive, but introduction of exotic AMF to a new ecosystem does not bring guaranteed overall advantage.
“In conclusion, the introduction of Glomus iranicum var. tenuihypharum in New Zealand do not pose any risks to the environment and human health and safety neither to cause any significant displacement of any native species within its natural habitat, cause any significant deterioration of natural habitats or cause significant adverse effect to New Zealand’s inherent genetic diversity, or is the organism likely to cause disease, be parasitic, or become a vector for animal or plant disease. In fact, the introduction of Glomus iranicum var. tenuihypharum will contribute to improve plant growth, the soil characteristics and recolonization of the soil by native species by providing better soil conditions, which will provide a sustainable environment, meeting the principles of the Treaty of Waitangi and satisfy the relationship of the Māori to the environment.”
Comment: Statements concerning impact on the NZ environment cannot be tested. For example, the following statement cannot be verified: “… neither to cause any significant displacement of any native species within its natural habitat, cause any significant deterioration of natural habitats or cause significant adverse effect to New Zealand’s inherent genetic diversity”.
Section 5 - Potential to harm native plants and to displace native soil microbes
“According to literature, there is no reference to any negative effects regarding the introduction of AMF in the soil, displacement of native species within the natural habitat nor causing deterioration of natural habitats. In this sense, the New Zealand’s inherent genetic diversity will remain unharmed. However, if there is any possible impact of the introduction of Glomus iranicum var. tenuihypharum on soil biodiversity, considering the soil treated and the limited dissemination capacity of Glomalean fungi, would be limited to a soil that had already an impoverished biodiversity. Furthermore, the application of Symborg's products is indicated to drip irrigation systems or to seed coating, which limits even more the area of application of our Glomus. However, any problem associated with our Glomus, could be easily fixed with a soil's sanitation to eliminate the Glomus.”
Comment: Use of the product cannot be limited to only soils with impoverished biodiversity. Sales of Symborg’s products such as MycoUp could occur beyond farming to include nurseries and restoration activities in native ecosystems.
Comment: It is important to also consider the composition of the whole product. By weight, the fungal inoculum in the product makes up 0.05% to 4.0% (see patent details below), meaning that 96.0 to 99.95% of the product comprises 2:1 smectite clays as a carrier. What is the biodiversity of this clay material? Earlier experience with a rival imported mycorrhizal inoculum product in the NZ market place yielded a range of viable fungi and bacteria (identities not determined) as contaminants of the carrier material. These organisms are also introduced to NZ soils whenever that product is used. Does the Symborg product have viable spores of other species of fungi and bacteria? (See also Patent Claims 11, 13 below)
Section 6.4. Discuss if it is highly improbable, after taking into account the proposed controls, that the organism after release:
“…. Moreover, the eradication of Glomus iranicum var. tenuihypharum is as simple as removing the plant roots completely from the soil and an after-application of a fungicide to guarantee the elimination.”
Comment: Sales and application of Symborg’s product range is highly likely to be of a scale far beyond a small number of discrete plants, and hence removal of inoculated plant roots seems impracticable in the event that elimination of the fungus is required.
“Although the species Glomus iranicum has not been detected in New Zealand so far, it does not mean it is exotic since closely phylogenetic species has been found. As mentioned in most of the references, there is a lot of misidentification of microbial species worldwide, and the fact that our Glomus was never identified in New Zealand may be related with the lack of studies carried out in New Zealand or to misidentification of the species.”
Comment: The applicant suggests that G. iranicum could occur in NZ, although there has been no attempt (eg, by the applicant) to locate it. But the applicant is not here commenting on the subject of this application which is their patented var. tenuihypharum (of G. iranicum). Again, no work has been undertaken by the applicant to look for the relevant variety in NZ.
Composition of Patented Product
The following provides the Abstract and extracted Claims concerning Symborg’s patented product, based on patent information at https://patents.google.com/patent/WO2015000612A1/en. Of particular relevance are the following claims:
Claim 5: Composition includes 0.05% to 4% by weight of Glomus propagules. Ie, smectite clays and other materials constitute 96-99.95% of the product
Claims 9-14: Composition includes a range of biocidal chemicals and viable organisms. Are these chemicals (Claims 10, 12, 14) approved in NZ? Are all organisms incorporated as biofungicides and bioinsecticides (Claims 11, 13) approved for importation into NZ?
Claim 15: Composition includes a bio-stimulant bacterium “Pasteuria sp.” Is this a new organism?
“Abstract
Glomus iranicum var. tenuihypharum var. nov. strain deposited under BCCM deposit number 54871, comprising the sequence identified by SEQ ID NO: 1; composition comprising said strain and 2:1 smectite clays and use thereof as bio-stimulant. The invention also discloses a composition comprising said strain, fungicides, bio-fungicides, insecticides, bio-insecticides, nematicides and bio-nematicides.”
19 CLAIMS
1. - Glomus iranicum var. tenuihypharum var. nov. strain deposited under BCCM deposit number 54871, characterized in that it comprises the sequence identified by SEQ ID NO: l . 2. - Composition characterized in that it comprises a strain of Glomus iranicum var. tenuihypharum var. nov. deposited under BCCM deposit number 54871 comprising the sequence identified by SEQ ID NO: 1 and 2: 1 smectite clays. 3. - Composition according to claim 2, characterized in that said 2: 1 smectite clays are dioctahedral or trioctahedral. 4. - Composition according to claim 2, characterized in that said 2: 1 smectite clays are selected from the group consisting of sepiolite, attapulgite, nontronite and saponite. 5. - Composition according to one of claims 2 or 3, characterized in that the concentration of said Glomus iranicum var. tenuihypharum var. nov. strain is between 0.05 and 4% by weight. 6. - Composition according to claim 5, characterized in that said concentration is between 0.1 and 3% by weight. 7.- Composition according to any of claims 2 to 6, characterized in that the form of presentation of said composition is powder, emulsifiable concentrate or granules. 8. - Composition according to any of claims 2 to 7, characterized in that said composition is a liquid, a solid or a gel. 9. - Composition according to any of claims 2 to 8, characterized in that it comprises at least one fungicide, at least one bio-fungicide, at least one insecticide, at least one bio-insecticide, at least one nematicide and/or at least one bio-nematicide. 10.- Composition according to claim 9, characterized in that said fungicide is 20 selected from the group consisting of Maneb, Mancozeb, Metalaxyl-Ridomil, Myclobutanil, Olpisan, Propamocarb, Quintozene, Streptomycin, Sulfur, Thiophanate- methyl, Thiram, triforine, Vinclozolin, Zinc white, Zineb, Ziram, Banrot, Fixed copper, Chlorothalonil, Chlorothalonil, Captan, Chloroneb, Cyproconazole, Zinc ethelene, bisdithiocarbamate, Etridiazole, Fenaminosulf, Fenarimol, Flutolanil, Folpet, Fosetyl- AL and Iprodione. 11. - Composition according to one of claims 9 or 10, characterized in that said fungicide is selected from the group consisting of Trichodermas sp, Bacillus subtilis, Bacillus licheniformis, Bacillus pumilus, Bacillus amyloliquefaciens, Streptomyces sp, Coniothyrium minitans and Pythium oligandrum. 12. - Composition according to any of claims 9 to 11, characterized in that said insecticide is selected from the group consisting of organophosphate, carbamate and neonicotinoid. 13. - Composition according to any of claims 9 to 12, characterized in that said bio- insecticide is selected from the group consisting of Bacillus sp. Chromobacterium sp., Beauveria sp. and Metarhizium sp. 14. - Composition according to any of claims 9 to 13, characterized in that said nematicide is organophosphate or carbamate. 15. - Composition according to any of claims 9 to 14, characterized in that said bio-stimulant is Pasteuria sp. 16. - Method for obtaining a composition according claims 2 to 15, characterized in that it comprises: (a) coating inoculation of a seed of a host plant with the Glomus iranicum var. tenuihypharum var. nov. strain deposited under BCCM deposit number 54871, (b) cultivating said plant in watering cycles of between 7 to 10 days on a reproduction substrate comprising smectite clays in a percentage above 52% of the total weight of said substrate, (c) discontinuing said watering for a period equal to or greater than 20 days, (d) removing the aerial part of the plant and removing the substrate and 21 (e) milling said substrate below 80 microns at a temperature between 25 and 30° C to obtain said composition. 17. - Use of the composition according to any of claims 2 to 16 as bio-stimulant. 18. - Use according to claim 17, characterized in that said composition is applied to the plant by means of seed treatment, root treatment, roots embedded in an emulsion, addition to irrigation water, irrigation, application of powder to the root system or application of emulsion injected into the root system.
Composition of Symborg’s product MycoUP
The following provides data for Symborg’s product MycoUP – extracted from: https://s3-us-west-1.amazonaws.com/www.agrian.com/pdfs/MycoUp_MSDS.pdf
Section 1 - on the concentration of Glomus spores in the product (12,000 propagules per 100 mls); Section 13 - warning about spread into waterways
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SUBMISSION 127409