APP203875 Submissions Compilation.Pdf

APP203875 German and Common wasps BCA Submissions 11 November 2020

Under section 34 of the Hazardous Substances and New Organisms Act 1996 Volume 1 of 1 to release 2 parasitoids, Metoecus paradoxus and Volucella inanis, as biological control agents for the invasive German and common wasps

Submission Number Submitter Submitter Organisation

SUBMISSION127659 Clinton Care

SUBMISSION127660 Member of Public 01

SUBMISSION127661 Peter King

SUBMISSION127662 Rod Hitchmough Department of Conservation

SUBMISSION127663 Member of Public 02

SUBMISSION127664 Linde Rose

SUBMISSION127665 Andrew Blick

SUBMISSION127666 Shane Hona Bay of Plenty Regional Council

SUBMISSION127667 Bryce Buckland

SUBMISSION127668 Jono Underwood Marlborough District Council

SUBMISSION127669 Kane McElrea Northland Regional Council - Whangarei

SUBMISSION127670 Member of Public 03

SUBMISSION127671 Davor Bejakovich Greater Wellington Regional Council

SUBMISSION127672 Margaret Hicks

SUBMISSION127673 Jenny Dymock Northland Regional Council - Whangarei

SUBMISSION127674 Member of Public 04

SUBMISSION127675 Roger Frost

SUBMISSION127676 Ricki Leahy Trees and Bees Ltd

SUBMISSION127677 Barry Wards Ministry for Primary Industries

SUBMISSION127678 Member of Public 05

SUBMISSION127679 Jan O'Boyle

1 Submission Number Submitter Submitter Organisation

Apiculture New Zealand Science and SUBMISSION127680 Sue Carter Research Focus Group

SUBMISSION127681 Andrea Dorn

SUBMISSION127682 Benita Wakefield Te Rūnanga o Ngāi Tahu

SUBMISSION127683 Emma Edney-Browne Auckland Council

SUBMISSION127684 David Hunter Excell Biosecurity

SUBMISSION127685 Member of Public 06

The Moths and Butterflies of New SUBMISSION127686 Jacqui Knight Zealand Trust

SUBMISSION127687 Clifford Mason

SUBMISSION127688 Derek Craig Oak and Thistle Ltd

SUBMISSION 127659

Diane Totton

From: Microsoft Authenticator Sent: Monday, 28 September 2020 11:31 am To: submissions Subject: Re: APP203875. Open for Public Submissions - German and common wasps biological control agent

Diane, But about our native wasps ???

And we have THREE species of Paper wasps. ..Asian, European, Australian paper wasps in NZ .... they need be EDRAICATED out of New Zealand, please !

We can completely edraicate the Germany wasps and Common wasps out of New Zealand, with VASPEX which are carried to nests be workers and fed to larvaes. Vaspex kills all wadps and their larvaes.

Regards

Clinton Care.

r SUBMISSION 127660 APP203875 - Common and german wasp BCA

Submission Reference no: 1

Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes The reason I support this application is that we run an organic mico-orchard, of 0.5ha in the North Waikato. This produces 3-4 ton of citrus each year. A trivial amount compared to the total production of citrus in NZ. But it makes a difference to our family budget, and also our customers in Auckland really enjoy the high quality product that is much sweeter than other commercially available citrus. I am not completely against wasps. The asian paper wasps do provide an ecosystem function on our land. They predate on caterpillars and other pest insects. Thus provide some benefit. However once the giant willow aphid came down into the Waikato a few years ago, we got a massive increase in the number of over wintering queens in our firewood pile. And if it was not for someone in the neighbourhood carrying out active pest control (I suspect Vaspex) we would have been over run with wasps, both german and asian paper wasps. This is a problem for us, as we are very limited in what pest control options we can employe. Being an organic operation we are limited to mechanical destruction (works for paper wasps at night, but not german). Thus we really don't have an means of control, except for relying on our neighbours to be undertaking the poisoning operations. Therefore I fully support the wise introduction of a predator that would keep the wasp population in balance.

Clause 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. Position No I do not wish to speak about my submission at the hearing Notes I am happy to speak to the hearing if the powers that be, have questions for me. I am expecting my submission is simple and straight forward so no verbal submission would be required.

The submitter have elected to withhold their personal details from publication. SUBMISSION 127661 APP203875 - Common and german wasp BCA

Submission Reference no: 2 as above, PETER JOHN KING P.O. Box 2753, CHRISTCHURCH CANTERBURY New Zealand Ph: 03-3662761 DAY 03-3125869 NIGHT [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes I have seen a nest that had been killed and dug out in Kent UK that was 2 metres deep and a meter dia. I have seen another in Germany that was several times bigger.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes They are dangerous, ground nests allow of a walker to descend into them if trodden on, with fatal results.

From: Rod Hitchmough [mailto:[email protected]] Sent: Monday, 28 September 2020 11:34 am To: submissions ; Aubanie Raynal Cc: anima Lim [email protected]; Barry Wards ( MPI ) ; Verity Forbes Subject: RE: APP203875. Open for Public Submissions. Common and German wasps BCA

Dear EPA

Thank you for the opportunity to comment on APP203875 Common and German wasps BCA.

DOC is strongly supportive of the proposed release of these two BCAs.

Common and German wasps, as well as being a health hazard and severe nuisance to humans, very severely impact native biodiversity by preying on native invertebrates and small vertebrates and depleting the available honeydew supplies in forests. Their predation directly impacts threatened species, causing further decline, and their feeding on both invertebrates and honeydew causes severe shortages of food for birds and reptiles at critical periods of their annual breeding cycle, thereby causing declines in those species as well. Therefore any effective and safe control measure for these wasps is very welcome.

The research on these two BCAs has been thorough, and we consider that it has clearly demonstrated that there is no risk to species other than the wasps themselves. Therefore we support approval for these BCAs to be released as soon as possible.

Regards

Rod Hitchmough Scientific Officer (Biosecurity) Department of Conservation—Te Papa Atawhai National Office, PO Box 10 420, Wellington 6143 18 Manners St, Wellington 6011 Cell: 027 408 3481

www.doc.qovt.nz

Please can you let us know whether or not you wish to attend any hearing that may be held.

Sorry, I always forget that. We don't want to trigger a hearing, but if one is held, we would like to present evidence.

1 SUBMISSION 127663 APP203875 - Common and german wasp BCA

Submission Reference no: 3

New Zealand

Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I oppose the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes Bad idea. Introducing another species means eventually it also will become invasive. Remember the weasels that were brought to combat the rabbits. I don't know why we still use this 19th century methods.

The submitter have elected to withhold their personal details from publication. SUBMISSION 127664 APP203875 - Common and german wasp BCA

Submission Reference no: 4

Linde Wild Rose 404A Pt Chevalier Rd Auckland New Zealand [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes I farm Monarch butterflies and wasps are devastating those populations as well bees and many other insect populations and other methods are not effective.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes I farm Monarch butterflies and wasps are devastating those populations as well bees and many other insect populations and other methods are not effective

Submission Reference no: 5

Andrew John Blick 108 Whangamoa Drive Okere falls 3074 Rotorua Bay of plenty New Zealand Ph: 0273951629 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I oppose the application Notes Wasps are condoned out of hand without proper holistic assessment.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes Having overcome my fear of wasps I respect them as an amazing insect that has important role in nature where ever it lives. Before any decision is made a proper assessment should be done. Sadly in this court of execution, I am doubtful a proper hearing will be held.

Clause 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. Position Yes I wish to speak about my submission at the hearing Notes I am cautious, I have spoken out before against the release of the Buddlea weevil. This release was based on biased poor science but even though the release was delayed a year, it still went ahead. Now I don't see anywhere near the numbers of red admiral butterflies around most probably because one of their important food sources is gone. All your decisions seem short sighted and narrow focused. I don't imagine it will be much different for wasps. The weight of bureaucracy is against them. In my organic garden, in summer there can be up to half a dozen wasps nests, wasps patrol the brassicas and remove many of the white butterfly larvae. That's just one example of something beneficial they do. Wasps, ants, bees and stinging nettle all contain types of formic acid. Rudolf Steiner describes formic acid as a quickener of life, that is essential for ALL life. To my knowledge no research has been done on this in NZ. So many unknowns. Wasp venom, which contains formic acid is possibly as good or if not better than bee venom as a medicine. Too many unknowns. You cannot just write off any animal because you are scared of it. SUBMISSION 127666 APP203875 - Common and german wasp BCA

Submission Reference no: 6

Shane Hona, Bay of Plenty Regional Council (Shane Hona) PO Box 364, Whakatane, 3158 Bay of Plenty New Zealand Ph: 0800884880 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes Wasps are a pest in the Bay of Plenty Region. They negatively impact both people and the environment, so we support the release of these biocontrol agents to help control wasps.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes Wasps are a pest in our region and we get many calls from the public regarding issues with wasps and requests for wasp control. If these biocontrol agents are released and prove successful then this should reduce the negative impacts of wasps on people and the environment in the Bay of Plenty Region.

Clause 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. Position No I do not wish to speak about my submission at the hearing Notes SUBMISSION 127667 APP203875 - Common and german wasp BCA

Submission Reference no: 7

Bryce Buckland, Bryce Buckland 1 Avalon Place Nelson New Zealand Ph: 0274860298 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes If, as it appears, that due diligence is done on the safety of the release of the proposed Vespulid Wasp parasites and there being no other impediment to their release, it is time that strenuous efforts were now made to effect better control on these pests.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes After Ship Rats, I rate both Vespulid Wasp species as the 2nd worst pest in our Native Beech Forest and I have pressed DOC for years to try to get them recognised as a real threat to our Native species. It is well understood the financial cost of allowing Vespulid Wasps to continue to damage our Natural environment and coupled with losses to Agriculture, Farming, Viticulture, Forestry, Beekeeping and Tourism. I understand cost our economy in excess of $160, million annually. As there is no apparent benefit in Wasp activity it seems to sensible to prevent Wasps from exerting such a high profile on our Country and that we take all prudent steps to reduce their impact. In Native Beech Forests the toll taken on Birdlife is huge and the Wasp annual cycle coincides with the breeding cycle of our most precious Native Birdlife. I have seen in Nelson Lakes National park and elsewhere, the effect high wasp numbers inflict on Native Birds as they begin to starve when Wasp activity increases. The Forest is alive and humming with Wasps who provide nothing beneficial to our natural environment. We can never exert comprehensive control on Wasps by killing Wasp nests manually or by the use of fipronil based toxins, as these are very costly and must be provided at the exact time each year by licensed operators while only providing control over the immediate area of application and too late in the season to be beneficial in Native Birds nesting period. Wasps continue their devastation outside the treated area and progress to produce more Queens to hibernate ready for the next season. This cycle must be broken and it seems that a selection of parasitics invaders is a very wise investment in the future wellbeing. As we try to move towards a predator free environment by 2050 the control of Vespulid Wasps without the use of toxins and huge costs of control if suitable pest parasites are available that do not threaten other species in New Zealand, we should make all effort to have them released.

Clause 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. Position No I do not wish to speak about my submission at the hearing Notes SUBMISSION 127668 APP203875 - Common and german wasp BCA

Submission Reference no: 8

Marlborough District Council (Jono Underwood) PO Box 443 Blenheim Marlborough New Zealand Ph: 021869808 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes The environment in Marlborough, particularly the Marlborough Sounds, provides a favourable habitat for Vespula wasps because of mild winters, a lack of natural wasp predators and plentiful food supply. Consequently, over the summer season in Marlborough, Vespula wasps build to extremely high numbers. These wasps are much more than a nuisance in that they build to such numbers that they commonly make places such as parks, forests and beaches virtually impossible to enjoy. In addition, when they reach numbers like that, they are also responsible for immense damage to terrestrial ecosystems. This can be by way of direct predation of invertebrates and also consuming food sources such as beech honeydew that would otherwise be utilised by native species. Vespula wasps also cause a degree of wider impacts on productive systems such as honey production, likely to be covered by other submitters. Being such a widely established invasive invertebrate, intervention options available to Marlborough District Council as the authority with regional leadership responsibilities under the Biosecurity Act 1993, are severely limited. Actions are limited to individuals, agencies or communities undertaking control operations to protect their asset - be it a high value biodiversity area, a bay, an island or recreational area. This is carried by using currently registered insecticide products. The operations are aimed at eliminating nests within a discrete area to alleviate the issues with high wasp numbers. However, at the landscape scale, Vespula wasps continue to have plenty of land area to continue thriving until control effort wanes and they can move back in. This is where the use of classical biological control agents are strongly desirable to act out in the landscape, persisting and impacting on the success of the host species. Manaaki Whenua/Landcare Research is internationally recognised for very robust science selecting and sourcing biological control agents to ensure they will not cause undesirable impacts. This application is one of these examples where there has been very robust science take take place. Given the impacts being felt by Marlborough ecosystems and communities due to Vespula wasps, the lack of any landscape scale tools for management and the robust science demonstrating the specificity of these agents, Marlborough District Council supports this application.

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]

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Submission on application APP203875 number: Name of submitter or contact for Kane McElrea joint submission: Organisation name Biosecurity Working Group (if on behalf of an organisation): Postal address: 36 Water St, Whangarei

Telephone number: 0274393774

Email: [email protected]

I wish to keep my contact details confidential

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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 SUBMISSION 127669

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). Please see attached 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: The Biosecurity Working Group, would like the Environmental Protection Authority to approve the release of both the wasp- nest beetle, Metoecus paradoxus, and the hoverfly, Volucella inanis into New Zealand

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 SUBMISSION 127669

Submission on Application Number APP203875

The Regional Sector - Biosecurity Working Group, (a collective of all 16 regional and unitary authority biosecurity representatives and experts), are writing in support of Tasman District Council's application to release the wasp-nest beetle, Metoecus paradoxus, and the hoverfly, Volucella inanis, as biological control agents for the invasive German and common wasps, Vespula germanica and V. vulgaris.

The German and common wasps are social wasps that were accidently introduced into New Zealand in the 1940s (German wasp) and 1970-80s (common wasp). Both species are now widespread throughout New Zealand and can reach extremely high densities (e.g. 33 wasp nests per hectare in the beech forests of the upper South Island). They have significant environmental, economic and human health impacts in New Zealand. The common wasp has been listed as one of the top 100 world’s worst Invasive Alien Species by the IUCN Invasive Species Specialist Group in 2014.

Considerable research has been conducted into developing tools for the broadscale control of German and common wasps in New Zealand. This includes the development of the insecticide Vespex (0.1% w/w fipronil) and the release of a parasitoid wasp (Sphecophaga vesparum). While Vespex can successfully reduce wasp numbers, it is expensive, labour intensive to use, and is only effective late in the season when foraging workers are collecting bait. Furthermore, it cannot be used easily over large and inaccessible areas and can pose some risk to non-target species. S. vesparum was released in New Zealand in 1985. Unfortunately, it appears to have only established at two sites and has had little impact on wasp numbers at these sites.

Prior to submitting this application, Manaaki Whenua - Landcare Research undertook considerable research, on behalf of the applicant, to identify biocontrol agents which will successfully control social wasps without impacting on native species or valued introduced species (e.g. honeybees and bumblebees). Key points of this research are:

 The wasp-nest beetle is an obligate parasitoid that is specific to wasps in the subfamily Vespinae. This species intricate life history and biological characteristics preclude other hosts;  The hoverfly is an obligate ectoparasitoid of Vespula spp. wasp larvae. It has never been found to be associated with any other social Hymenoptera than the subfamily Vespinae in its native range;  There are no native wasps in the family Vespidae in New Zealand;  The only native social Hymenoptera in this country are the ants. M. paradoxus and V. inanis have never been reported as parasitising ants nests; and  There is no evidence from within the home range of M. paradoxus and V. inanis that these species will parasitise honeybee or bumblebee nests.

The applicant has undertaken a risk/benefit analysis of releasing the wasp-nest beetle and hoverfly. They concluded that the potential cumulative benefits will outweigh the potential cumulative risks. We have reviewed their analysis and support this conclusion.

We consider that if the release of the wasp-nest beetle and the hoverfly proves successful, it will result in a cost-effective, long-term and sustainable approach to managing German and common wasps. This will lead to:

 Reduced social and economic impacts associated with these wasps;  Improved ecosystem functioning of natural habitats; and  Improved protection of New Zealand’s iconic native species. SUBMISSION 127669

The Biosecurity Working Group, would therefore like the Environmental Protection Authority to approve the release of both the wasp-nest beetle, Metoecus paradoxus, and the hoverfly, Volucella inanis into New Zealand. SUBMISSION 127670 APP203875 - Common and german wasp BCA

Submission Reference no: 9

Submitter Type: Not specified Source: Email Overall Position:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes See attached

The submitter have elected to withhold their personal details from publication. SUBMISSION 127670

Support for the Application

I support the proposal to release both wasp parasitoids, Volucella inanis and Metoecus paradoxus. The effects of these organisms is likely to be complementary to current methods of wasp control, and the environmental side effects of their release may be less than the side effects of using fipronil- based insecticides for that purpose.

These parasitoids will affect wasp nests at a different time of year (earlier in the season) and in a broader range of places (including in remoter areas) than pesticides are generally used.

Although there may be a partial replacement of Vespula wasps with Polistes paper wasps as a consequence of biocontrol, the overall effect will almost certainly be a lower environmental impact from pest wasps.

There are many areas where it is impractical or uneconomic to control wasps with pesticides, so a reduction of wasp populations in these areas must have benefits both for the environment and for remote-area recreationalists.

I know from my own experience that high wasp densities can be a significant discouragement to the recreational use of certain areas at certain times of year. This issue is particularly true for places where wasp numbers are high but control is too expensive or impractical. It can lead to the circular logic that wasp control is not prioritised because recreational use is low, and recreational use is low because wasp populations are high and uncontrolled. That might change if wasp numbers in remote areas are significantly reduced.

A reduction in wasp numbers in places where control is currently undertaken might also allow some pest control efforts to be diverted to other species.

Even in areas where wasp control is undertaken, exclusion zones need to be incorporated to avoid (for example):

- Areas too close to water (a big factor if wasps are feeding on willow aphid and the willows are in a wetland or over water).

- Areas too close to beehives (which could be affected by insecticides, but which are also significantly impacted by wasps).

- Areas where landowner permission cannot be easily obtained (depending on what sections of the Biosecurity Act are applicable).

Biocontrol is not affected by such exclusion zones, and will therefore assist conventional pest control.

SUBMISSION 127671

SUBMISSION FORM

Once you have completed this form Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140 OR email to: [email protected]

Submission on application 203875 number: Name of submitter or contact for Davor Bejakovich, Manager, Biosecurity joint submission: Organisation name Greater Wellington (if on behalf of an organisation): Postal address: Greater Wellington Regional Council, PO Box 40 847 Upper Hutt 5140

Telephone number: 06 826 1518, 027 262 3062

Email: [email protected]

I wish to keep my contact details confidential

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 SUBMISSION 127671

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: Greater Wellington (GW) supports the proposal to release the two parasitoids Metoecus paradoxus (wasp nest beetle) and Volucella inanis (parasitoid fly) as biological control agents for the invasive German and common wasps. Wellington region only has moderate wasp densities, but for the regions of New Zealand such as Marlborough where numbers are high to extreme each summer, this will be an invaluable tool if successfully established. That the agents are mobile and capable of dispersing over the landscape is very much in their favour. The impacts of German and common wasps are many: environmentally, they affect food supply for native insects, birds and lizards, attack beehives (with financial as well as pollination consequences), and act as a key agent of biodiversity decline. (see reference 1). For humans: these wasps present a very real health and safety risk - on average there are over 1050 ACC claims per year for wasp stings. $130 million is spent annually on managing the effects of invasive wasps At present, control measures are the labour intensive deployment of pesticides in conservation areas, and poisoning of nests as and when found. Treated areas are soon recolonized. The two biocontrol species proposed for release will help to bring populations down to more manageagle levels, if successful. This could result in beneficial effects such as increased invertebrate prey resources for native birds; more honeydew available for native species in beech forests; reduced contamination of the environment from poison baits and nest poisoning; a reduction in stings; reduced predation on bees and hive robbing; reduced management costs; increased pollination. This is balanced by envisaged potential adverse effects such as the possibility of replacement invasion by other social wasps; biocontrol agents targeting other species; food web interactions to the detriment of native species. In the GW Regional Pest Management Plan 2019-2039 (RPMP), the German and common wasps (as well as Australian and Asian paper wasps) are under a sustained control programme for which the objective is to sustainably control wasps to protect environmental and public health values in the Wellington region. We require land occupiers to destroy all wasp nests on their property following receipt of a written direction, to ensure the removal of the health and safety hazard associated with wasp nests.We have stated that we will release biological control agents for the control of wasps where appropriate. In 2019/20 year, GW received 24 wasp enquiries from the public, but also poisoned numerous nests encountered by staff carried out field work. GW staff became registered users of Vespex in 2018/19. Biosecurity staff trialled the product in random sites to test its effectiveness, as experience from other organisations indicates that outside of beech forests with little other food available, Vespex is of limited use. Our trial resulted in less wasp nests in the general area where we used it in an area of beech forest. One of our concerns is that giant willow aphid (Tuberolachnus salignus) infestations in the region are likely to drive wasp numbers up if combined with the right climatic conditions. The aphids secrete large amounts of honeydew on willow trees, creating a food source for wasps, which leads to increased wasp activity near areas with willow trees. Treatment options vary depending on the site, but it should be noted that this is a situation in which biocontrol agents could substantially help. Although a parasitoid wasp was approved by EPA to control the giant willow aphid in November 2019, this agent will take time to become abundant and widespread; whilst the agents proposed for the German and common wasp are in a similar position, the effect on the three pest species may prove synergistic. As with all biocontrol, following the release there will be no control over the parasitoids, meaning that the testing and management needs to be thorough prior to the release. GW supports the processes of the Environmental Protection Authority and the Ministry for Primary Industries for the importation and release of new organisms, and trusts that due

September 2012 EPA0190 SUBMISSION 127671

Submission Form diligence will be followed in the assessment of risk by these agencies. As with any introduction, once the organisms are successfully introduced, there is little or no ability to control or manage the organisms in their wild state. GW is a contributor to and participant in the National Biological Control Collective (NBCC), and supports the establishment of biocontrol species. Successful biocontrol agents for the german and common wasps would ease the reliance on pesticides for control purposes. Through the NBCC GW is involved in a growing number of biocontrol projects and believes it is an essential part of the future of pest plant management in New Zealand. With finite resources to control an ever-growing number of problem species, and growing expense and public resistance to traditional chemical control, biocontrol is a cost effective and largely publicly acceptable technique. Reference 1 - https://www.landcareresearch.co.nz/uploads/public/Events/Link-series/Reducing_Pain_Pest_Wasps.pdf

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)

I wish for the EPA to make the following decision: Greater Wellington Regional Council supports the proposal to release the two parasitoids, Metoecus paradoxus and Volucella inanis for the control of the invasive wasps, Vespula germanica and V. vulgaris . Establishment of these species as effective agents will greatly assist with the long-term, national management of the German and common wasps.

September 2012 EPA0190 SUBMISSION 127672 SUBMISSION 127672 SUBMISSION 127672 SUBMISSION 127672 SUBMISSION 127672 SUBMISSION 127673 APP203875 - Common and german wasp BCA

Submission Reference no: 10

Dr J J Dymock, Northland Regional Council 36 Water St Whangarei 0110 Northland New Zealand Ph: 09 4701200 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes Submission by the Northland Regional Council in support of the application, APP203875, to release two parasitoids, Metoecus paradoxus and Volucella inanis, as biological control agents for the invasive German and common wasps. Effect on human health A proportion of Northlanders experiencing wasp sting injuries have allergies to wasp venom and can develop severe adverse reactions to wasp venom. Horticulture is increasingly important to the Northland and New Zealand economy. Northland produces 45% of NZ’s $100M export avocado and 3.5M trays of green and gold kiwifruit are grown annually. Other important orchard crops are citrus and blueberries. Vespid wasps can be encountered in horticultural activities in Northland such as pruning and fruit picking and packing. In Northland, German wasp (Vespula germanica) nests can survive winters due to benign climate conditions and continue to grow to reach large proportions. These can be disturbed during earthworks and on farms. Risks of injury when destroying these large nests are considerable. Disturbing vespid wasps and their nests in natural areas (bush walks, picnic areas, recreational activities) poses a risk to Northlanders and the tourism sector. Effect on Northland honey production Vespid wasps have a detrimental effect on honey production in Northland due to predation of hives by wasps and competition for nectar sources. Apiculture statistics from MPI show that in 2017, Northland, Auckland, Hauraki Plains produced 2,025 tonnes of honey from the New Zealand total of 14,855 tonnes (13.6% of the NZ total of which 8,450 tonnes were exported), comprising 18% hives in New Zealand. Effects on native biota Host specificity Metoecus paradoxus and Volucella inanis have never been recorded attacking solitary bees and wasps in the Northern Hemisphere which indicates that it is unlikely that they will prey on native solitary bees and wasps in New Zealand. Effects on pollination Pollen requirements of the biocontrol agents proposed for introduction (if any for M. paradoxus) will be very small relative to those of introduced bumble bees (4 Bombus spp.) and the European honeybee, Apis mellifera. Conclusion Northland Regional Council supports the application (APP20375) to release two parasitoids, Metoecus paradoxus and Volucella inanis, as biological control agents for the invasive German and common wasps.

Clause 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. Position No I do not wish to speak about my submission at the hearing Notes SUBMISSION 127674 APP203875 - Common and german wasp BCA

Submission Reference no: 11

Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes I think this is a great idea.

The submitter have elected to withhold their personal details from publication. SUBMISSION 127675 APP203875 - Common and german wasp BCA

Submission Reference no: 12

Roger Frost, R & S Frost (Roger Frost) 100 Upper Buller Gorge Road, PO Box 148, Murchison Tasman District New Zealand Ph: 03 523 9371 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes We own a 277ha property with a whole of property Queen Elizabeth II Protected Open Space covenant in perpetuity. We live on the property and also lease out 35ha of paddocks for summer grazing by beef cattle. Introduced Vespula wasps are probably the most damaging exotic predators on our property by reason of their biomass and breadth of impact. Their effect is such that it we see less than a handful of white butterflies each year in our home vegetable garden. Over the past two years we have used Vespex to control wasps in those parts of our property that have the most extensive areas of beech forest. This has been an expensive effort and requires waiting until wasp numbers have reached a significant level, during which time they will have impacted on honeydew based food webs and prey species populations and the food webs they contribute to. During dry springs and summers wasp before we started using Vespex wasp numbers in pasture vegetation would reach "carnivorous locust-like plague" proportions as they searched very actively for invertebrate prey. Native butterflies are rarely seen on our property. The only ones we see infrequently are those that are vagrants blown in from Australia - Painted Ladies and Meadow Argus, and those that actively disperse widely including Red and Yellow Admirals. We see no coppers, nor blues. I have watched a wasp struggle on the ground with a honeybee, cutting it into three sections and flying away with each section separately. In the last 3 years I have been searching for populations of Forest Ringlet butterfly in the Nelson-Tasman region in areas in which the larval host plants occur and particularly in places where historically they have been recorded or collected. All of the locations where I have found the species are above the altitudinal limits of Vespulid wasps. Previous locations below this limit have revealed no current evidence of this species.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes 1. Biological control has the greatest potential for long term, low cost, self expanding control in the absence of gene-editing techniques. 2. Reducing wasp populations is likely to be critical for the survival and recovery of many native species that are preyed upon by wasps or depend upon species that are preyed upon, directly or indirectly. 3. Likewise, reducing wasp populations is likely to be critical for the survival and recovery of many native species that depend upon beech honeydew directly or indirectly. It may also be critical in the long term for the health and survival of beech populations themselves. 4. The risk that the proposed control agents will impact negatively on native species would appear to be remote and insignificant compared to the number of species that are impacted negatively by wasps.

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]

Submission on application APP203875 number: Name of submitter or contact for Ricki Leahy joint submission: Organisation name Trees and Bees Ltd (if on behalf of an organisation): Postal address: PO Box 9 Murchison

Telephone number: (Requested to be kept confidential)

Email: (Requested to be kept confidential)

I wish to keep my contact details confidential

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). I have been keeping bees in the Murchison district for 40 years and have always had significant problems with both the Common and German wasps which thrive and grow into a massive predatory force due to the honeydew in the beech forests throughout our local area and indeed the wider areas of the upper South Island. Each season the wasps develop huge numbers of strong nests and quickly become overpopulated and out of balance in the environment threatening and effecting not only our beehives but also any creature that the wasps can overcome and use as a food source. It is a massive task and cost for us to defend our bees from the wasps each year. We constantly monitor our apiary sites for wasp numbers and control the wasps by using poisoning methods. We normally need to repeat up to three times to maintain control as more wasps appear and fill the 'wasp vacuum' we create.

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: We have always supported any effort to find biological controls because although with effort we can defend and protect our hives in the apiary we simply don't have any control of where the bees fly while foraging. If the wasp populations in these uncontrolled foraging areas were controlled by biological agents such as the wasp-nest beetle Metoecus paradoxus and the hoverfly, Volucella inanis, then the wasp populations probably wouldn't reach those rediculous plague proportions. Neither would those areas that we do poison become reinfested so vigorously. I fully support the introduction of these two biological control agents and have no concerns that they may have any detrimental effects on bees, either the native or honey bees. The information suggests that a successful introduction would become a huge contribution to the effective control in keeping wasp numbers to a more acceptable environmental balance.

July 2016 EPA0190

Comments Form to the EPA for New Organism Applications

Application code(s): APP203875 Applicant name: Tasman District Council Contact: Dennis Bush-King Application: To release the parasitoids Volucella inanis and Metoecus paradoxus as biological control agents for the German and common wasps, Vespula germanica and V. vulgaris. EPA contact: Aubanie Raynal Date: 3/10/2020 MPI response coordinator: Barry Wards (Principal Adviser Biosecurity HSNO) Option to speak at hearing: No

Scope of comments MPI submits these comments for consideration to the EPA on the following basis (where relevant to the type of application): ▪ Clarity of information provided by the applicant; ▪ Information that MPI considers should be taken into consideration by the EPA; ▪ Adequacy of the proposed containment system, including suggestions for controls and/or amendments to proposed controls; ▪ Enforceability of any proposed controls; and ▪ Whether MPI supports / opposes the application or is neutral. Matters relating to the application that are not within the scope of these comments may be provided to the EPA separately.

Comments General The applicant wishes to release from containment the parasitoids Volucella inanis (a hoverfly) and Metoecus paradoxus (Wasp-nest beetle) as biological control agents for the German and common wasps, Vespula germanica and V. vulgaris. The applicant has provided a substantial amount of information relating to the proposed release and has consulted widely with relevant stakeholders. MPI agrees with the applicant that the biosecurity risks of releasing the parasitoids are likely to be negligible and supports the application. The applicants consider that the successful establishment of these two biocontrol agents is likely to provide ‘minor to moderate benefits to the New Zealand environment, economy and society’. MPI agrees with this assessment and considers that it is likely that in future these agents may become part of an integrated management program for social wasps. The applicants cite research suggesting that a range of tools will be needed to achieve an adequate reduction in wasp abundance. These agents have not been used for biocontrol of Vespula spp. wasps anywhere else in the world so there is no documented proof of their efficacy and it is difficult to predict this. If release and establishment results in high levels of parasitism in wasp nests, MPI agrees that this will result in reducing German and common wasp numbers and, therefore, reduce damage to New Zealand ecosystems,

MPI Comments – APP203875 Page 1 of 2

reduce current control costs and reduce the negative impacts on human health and well-being. In addition, any reduction in wasp numbers will reduce the impacts on bee colonies through predation on hives and honey loss, thereby benefiting New Zealand’s apiculture industry.

Application comments s3 The applicant has provided strong evidence relating to the highly specific biology of both parasitoids on Vespula spp. Based on this, MPI agrees that the biosecurity risks of the parasitoids release are low and it is highly unlikely that species (indigenous and exotic) other than V. germanicus and V. vulgaris in New Zealand will be impacted. Being an obligate parasitoid, Volucella inanis will be dependent on the targeted species for survival. The application does not provide sufficient information indicating that successful establishment of the parasitoids will result in high levels of parasitism in wasp nests leading to even a moderate reduction in wasp populations. They state that ‘the fecundity of both species is fairly high’, citing that ‘the reproductive capacity of M. paradoxus is high, with females producing up to 700 eggs each’. However, beetle numbers in Vespula spp. nests have been reported to be fairly low (1-25 individuals per nest) but, as the applicant suggests, nests are not the habitat niche of adult beetles. They do provide some indication that the presence of the parasitoids in Vespula spp. nests in the UK results in relatively low densities in their native range (s2.3.4.1) compared to their invasive range, suggesting that specialist natural enemies play a role in regulating Vespula spp. populations and cite relevant nest survey data to support this. However, the data (Table 2) only reports the numbers and percentages of nests parasitized, not the numbers and percentages of parasitoids in nests – such figures would indicate whether the presence of the parasitoids is having any impact of wasp populations in the native environment and, therefore, what might be expected upon release in New Zealand. Consequently, while the applicant states that ‘successful biological control would drive wasp populations down, possibly to low levels – resulting in coexistence at a new low equilibrium’, MPI considers that the evidence provided in the application to support this is not strong. MPI notes that, in contrast to nearly all recent biological control agent applications, no host range testing has been carried out for these two agents. The exception is that 6 Volucella adults were tested against one non-target species (Bombus terrestris) for one hour. No testing of Metoecus is mentioned in the application. Therefore, the evidence for host specificity given here is less robust than in most recent applications, where more or less extensive host range testing is done in quarantine or overseas. The evidence given in this application is almost all based on absence of evidence in the literature, on survey information in some cases and also on a reasoned argument regarding the biology and behaviour of the agents. Although MPI believes that this evidence is sufficient to determine that the risk is negligible, the case for host specificity would be stronger had the usual host range tests for prospective biocontrol agents been undertaken.

MPI Comments – APP203875 Page 2 of 2 APP203875 - Common and german wasp BCA

Submission Reference no: 13

Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes I support the NZ Moths & Butterflies Trust (mainly Monarch butterflies interest me.)

The submitter have elected to withhold their personal details from publication. APP203875 - Common and german wasp BCA

Submission Reference no: 14

Jan O'Boyle, Jan O'Boyle Box 92,Rawene Northland New Zealand Ph: 094053804 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes These wasps are a huge pest here in Northland. Biocontrol will help us control them and conserve our native butterflies.

10 November 2020 [email protected]

Environmental Protection Authority of NZ Private Bag 63002 Wellington 6140

Submission on Application to release two new biocontrols to combat wasps

Apiculture New Zealand (APINZ) represents the interests of beekeepers and honey bees in New Zealand. Beekeeping is now one of New Zealand’s fastest growing export enterprises and presently supplying the world with high value honey products

The value of the apiculture industry to the NZ economy includes honey exports ($425 million year ended August 2020), as well as an overall industry value of $5 billion derived directly from honey and other bee products, and indirectly through pollinating horticultural and agricultural crops

1. Wasps are a significant pest for the beekeeping industry particularly in certain geographical areas. The annual colony loss report run by Landcare research (https://www.mpi.govt.nz/protection-and-response/readiness/beebiosecurity/bee-colony- loss-survey/) shows that wasps are the cause of death for between 9.6 and 12.1% of managed honeybee hives in recent years). The 2019 NZ Colony Loss Survey reported the loss of 81,965 honeybee colonies. Wasps accounted for 9.6% of those losses (~7869 colonies) and is ranked the third or fourth highest cause of loss in these surveys.

2. Based on the number of hives killed by wasps in 2019 (~7869 colonies) the value of lost production and replacement of beehives lost to wasps is estimated based on current hive values and returns for honey to cost the industry close to 4 million annually. This does not consider lost production due to the effects of wasps on bees leaving the hive or foraging in the general environment resulting in reduced honey production or pollination.

3. APINZ supports this application to import two new biocontrol’s (Volucella inanis and Metoecus paradoxus) for vespula wasps. This is due to the likely positive benefits to the apiculture industry and the industries that it supports. While the current use of other controls such as Vespex have been used by beekeepers, a more widespread suppression of wasp populations through the introduction of these biocontrol’s would be beneficial to the health and production of beehives therefore increasing profitability. This would be through: a. Decreasing total hive deaths potentially by 12% (based on colony loss survey data) b. Increasing productivity of hives for both honey production and pollination by reducing attack by wasps due to lower requirement for bees to defend hive. c. Reduction in hive management required in high wasp population areas to prevent robbing. d. Reduction in pest control costs to beekeeper e.g. baiting with Vespex e. Improvement to the general foraging environment of honey bees particularly in beech forests and river beds.

Apiculture New Zealand PO Box 10792, Wellington 6143, New Zealand

+64 4 471 6254 | www.apinz.org.nz | [email protected]

4. Based on the risk assessment provided in the application document we see limited adverse effects to the health of honey bees through the introduction of these biocontrol’s into New Zealand. One consideration is the potential competition with honeybees for food resources by Volucella inanis where the adult feeds on nectar and pollen. Based on the risk analysis this is unlikely to have a significant effect on beehive health and production due to limited population size of the biocontrol and the fact that there are already a number of introduced and native hoverfly species present in New Zealand.

5. Thank you for considering our submission. We do wish to make an oral submission.

This submission is presented by Apiculture New Zealand on behalf of its Science and Research Focus Group. Members of the Apiculture New Zealand Science and Research Focus Group include: Barry Foster (Chair) Dr Oksana Borowik Dr Mark Goodwin Martin Laas Don MacLeod John Mackay Dr John McLean Dr Pike Stahlmann-Brown

Apiculture New Zealand PO Box 10792, Wellington 6143, New Zealand

+64 4 471 6254 | www.apinz.org.nz | [email protected]

APP203875 - Common and german wasp BCA

Submission Reference no: 15

Andrea Dorn, Andrea Christine Dorn 89A St Johns Rd Auckland New Zealand Ph: 095285610 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes We MUST get rid of these destructive, damaging wasps at all costs. They literally are destroying the beautiful Monarch Butterflies in Auckland. There are an huge number of Swan Plants all around and not a single caterpillar , chrysalis or Monarch Butterfly to be seen!! The wasps descend on any that may be there and decimate what would be an exquisite piece of Nature.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes It literally ''breaks my heart'' to see the obliteration of the Monarch Butterfly species in many, many parts of Auckland. Get rid of the wasps PLEASE!!! Many thanks, Andrea

He tono nā

ki te ENVIRONMENTAL PROTECTION AUTHORITY

e pā ana ki te SUBMISSION ON APP20875 – To release 2 parasitoids, Metoecus paradoxus and Volucella inanis, as biological control agents for the invasive German and common wasps

Date: 10/11/20

Authors: Dr Benita Wakefield and Stephanie Dijkstra Ngāi Tahu HSNO Kōmiti members

Sponsored by Trudy Heath, General Manager Te Ao Turoa, Te Rūnanga o Ngāi Tahu

Moemoea (Lament) Mātakitaki au ki te takutai o te raki ki te pōkaikura e tauawhitia mai. Look to the north where the coast Ko Uenuku e tīwhanawhana ai ki runga that embraces us glows a sacred red. ko te Rau o Tītapu ki mua. ‘Tis Uenuku that arches on high Ka whakapiki te hā ki te taumata kōrero and our leaders who move to the fore. kia whakapuakiakihia mai ngā maunga The essence of our ancestors rises up to the pepeha. pinnacle of oratory Ko tōku maunga Kākāpō e tū ake rā. as our mountains are recalled to remind us ko ahau te tangata e whakatika ki runga of whence we came. Tū te ihiihi There stands the mountain of the treasured Tū te wanawana Kākāpō Tū te mauri ki waho `tis I who can stand and claim my place. Tū te mauri ki roto. I feel the dread Tāpuketia au kia mārama ai taku titiro I feel the awesome prestige Ki aku umu tangata. As the life force is established Puritia, tāwhia kia ita from within and without. Te mana tīpuna Bury me there so that I may gaze upon Te mana whenua those lands Te mana tangata Through the strength of my people. Kia tūturu Hold fast and firm Āwhiti whakamaua To my inherited authority Kia tina To my rights to this land Tina! To my rights as a person Hui eee Tāiki ee!

Whakatauki (Proverb) ”Te Toto o te tangata, he kai; te oranga o te tangata e whenua” While food provides the blood in our veins, our health is drawn from the land

Contents

1 Tāhuhu Korero (Introduction) ...... 2 2 Statutory obligations to Ngāi Tahu ...... 2 3 Description of Application APP203875 ...... 3 4 Position of Te Rūnanga o Ngāi Tahu on Application APP203875 ...... 4 5 Reasons for position on application APP203875 ...... 4 Te Ao Tūroa (Environment) ...... 5 Ōhanga (Economy) ...... 5 Hauora (Public Health) ...... 6 He Tāngata (People and Communities) ...... 6 Kaitiakitanga (Guardianship) ...... 6 Te Tiriti o Waitangi (Treaty Principles) ...... 7 6 Conclusions...... 7 7 Recommendation ...... 8

1. Tāhuhu Korero (Introduction)

Ngāi Tahu HSNO Kōmiti The Te Rūnanga o Ngāi Tahu HSNO Committee is mandated by Te Rūnanga o Ngāi Tahu. The members of the committee are appointed by Te Rūnanga based on their knowledge and expertise in the areas of hazardous substances and new organisms.

Ngāi Tahu Values All Te Runanga o Ngai Tahu activities are informed by the following values: Whanaungatanga (family) Respect, foster and maintain important relationships within the organisation, within the iwi and within the community. 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 of 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. Statutory obligations to Ngāi Tahu

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:

Section 3 of the Act: This Act binds the Crown and every person (including any body politic or corporate) whose rights are affected by any provisions of this Act. Section 15(1) of the Act: Te Rūnanga o Ngāi Tahu shall be recognised for all purposes as the representative of Ngāi Tahu Whānui. The Charter of Te Rūnanga o Ngāi Tahu (1993, as amended) constitutes Te Rūnanga as the kaitiaki of the tribal interest. Te Rūnanga respectfully requests that this response is accorded the status and weight due to the tribal collective, Ngāi Tahu Whānui, currently comprising over 70,000 members registered in accordance with section 8 of the Act. Under the HSNO Act, the environmental and cultural health and well-being of Māori, and Treaty of Waitangi outcomes and values, must be taken into account when making decisions about introducing and using hazardous substances or new organisms into New Zealand. Section 5(b) of the Act provides (amongst other things) for the: “Maintenance and enhancement of the capacity of people and communities to provide for their own economic, social and cultural well-being”. Section 6(d) of the Act requires that the Environmental Protection Authority of New Zealand (EPA), when exercising functions under the Act, take into account: “The relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued ﬂora and fauna, and other taonga”. Section 8 of the Act requires that all persons exercising functions under the Act take into account: “…the Principles of the Treaty of Waitangi” including the recognition of the special relationship between the Crown and tangata whenua.

3. Description of Application APP203875

Wasps (Vespula spp.) are significant pests in New Zealand resulting in damage to ecological systems and human health issues. New Zealand does not have any native wasp populations or native predators of wasps allowing unchecked population growth. In beech forests in the top of Te Waipounamu densities can reach 33 wasp nests per hectare (average 12), equating to approximately 10,000 workers per hectare. Additionally, wasps are significant predators of native invertebrates; including bees, weta and spiders. Additionally, wasps significantly out- compete native bee species, consuming 99% of the honeydew available in beech forests during the 4 months their populations are active. Honeydew is an important food source for many taonga species; such as tūi, kākā, bellbirds and silvereyes, as well as lizards and insects. German and common wasps are highly aggressive and therefore the risk of people receiving multiple stings is very high. This increases the risk of a severe allergic reaction resulting in hospitalization or fatalities.

Both suggested biocontrol insects are native to the United Kingdom, where they have been observed to control wasp numbers through larval predation. Neither has been utilised in biocontrol applications before, but studies conducted by Manaaki Whenua have shown that they have high parasitism rates in their native environment, making them good candiates for wasp control in New Zealand. The hover fly (V. inanis) lays eggs in or near the wasp nest. The larvae then feed on wasp larvae, killing them. Each larva will feed on at least two wasp larvae before developing into an adult. Each adult female hoverfly will produce 300-600 eggs. The wasp nest beetle (M. paradoxus) lays its eggs outside the nest in wood pulp. The eggs then hatch, and the first-stage larvae attach themselves to passing wasps foraging for wood pulp and are transported into the nest. The beetle larvae then feed on the wasp larvae in the nest. It is hoped that introduction of both parasitoids will have a synergistic effect and therefore prove a more effective control on wasp population numbers.

4. Position of Te Rūnanga o Ngāi Tahu on Application APP203875

Over the years, Te Rūnanga o Ngāi Tahu (TRoNT) has consistently advocated for methods of pest and weed control that have reduced negative impacts on the environment. We are therefore generally supportive of any proposal which might decrease the burden of pesticide residues in the environment. However, there needs to be adequate consideration of the potential risks of any biocontrol, such as off-target effects, ecological niche escape or food web disruption. When a new exotic organism is introduced as a biocontrol to New Zealand, we need to ensure there is minimal disruption to indigenous fauna and flora. The amount of environmental harm caused by wasps through invertebrate predation and honeydew consumption is significant and therefore reduction of wasp numbers will give significant environmental benefits. Host range testing conducted on both V. inanis and M. paradoxus showed a high level of specificity, with no parasitism of non-wasp species. Additionally, the introduction of an effective biocontrol will reduce insecticide use and therefore reduce the chemical burden on the environment. For these reasons, we support the introduction of APP203875. We wish to be heard in support of our application.

5. Reasons for position on application APP203875

We approach this application under a Kaupapa Māori lens, that includes assessment of the effects of biocontrol method in six key areas. These include Te Aō Tūroa, Ōhanga, Hauora, He Tāngata, Tikanga ā iwi, Te Tiriti o Waitangi.

Te Ao Tūroa (Environment)

Te Ao Tūroa refers to the natural world, encompassing taonga species, te mana o te wai (all water bodies; ie: sea, freshwater, wetlands, estuaries), ngahere (native forest, bush), ecosystems and biodiversity.

Within the Nelson/ Tasman district the common wasps (Vespula vulgaris) and German wasps (V. germanica) have a massive impact on native insects and birds, especially in honey dew beech forest. The biomass of wasps in the Nelson Lakes region, at peak wasp abundance, was calculated to be higher than that of combined biomass of all birds, stoats, rats and possums in the area. With no natural predators, social wasps have quickly gained a strong foothold in Aotearoa’s ecosystem. The bait Vespex® has been used within the Nelson/ Tasman region where the pest wasp is rampant but this bait is highly toxic. This bait and toxin combination are targeted and has been an effective treatment that kills entire wasp nests. There will be a need to continue applying the Vespex® bait in order to prevent the wasp population from taking a stronghold within the region.

Introducing a new exotic organism as a biocontrol is a long-term strategy which will require sufficient time to become established. There needs to be closer monitoring in the establishment of these bio-control organisms to ensure there is minimal disruption to indigenous fauna and flora. We understand that the high level of specificity between a parasitoid and its host is unlikely to attack other species. However, this method has yet to be tested sufficiently within the natural environment and there is uncertainty around the long-term effects on fauna and flora.

Ōhanga (Economy)

The Ngāi Tahu economy allows for self-determination of Papatipu Rūnanga in the realisation of their aspirations. Specifically, we refer to the Apicultural and tourism industry and recreational pursuits where Ngai Tahu and Papatipu runanga have major share-holding investments and interests.

Wasps are a nuisance and a human health hazard, and so affect outdoor activities (particularly where numerous), which in turn affects recreation, tourism and other economic activities. In addition, wasps can have direct impacts on the primary sector, particularly through their effect on honeybees (Apis mellifera).

The Apicultural industry within NZ is a thriving industry valued at 5 billion in 2019 and is more than just about honey and bee products. The honeybees (such as, Apis mellifera) play a critical role in pollinating pastoral clover for nitrogen regeneration, specialised small seed crops, berry, stone fruit and pip fruit orchards. In 2019, honey exports had increased and the numbers of honey bee keepers registered were at their peak. The rampant infestation of wasps continues to have an adverse impact. Pest wasps and their effects on beekeeping has cost

millions of dollars to invest in methods such as baiting to prevent hive losses, honey production losses and the wider impacts on the horticulture and agricultural economy. In 2019, the infestation of wasps on the general public has continued to be a nuisance factor especially in public recreational areas. Within the Tasman / Nelson region there is a high density of pest wasps within areas near the upper South Island beech forest and other hot spots in the country such as the Waitakere Ranges, Craigieburn Area and Waikaremoana catchment. The pest wasps are a nuisance and have affected outdoor recreational activities (particularly where wasps are dense), which in turn affects recreation, tourism and other economic activities.

Hauora (Public Health)

The health and wellbeing of Ngāi Tahu whanau is interconnected with the health of the environment, in that mahinga kai (traditional food), and rongoa (traditional medicine) sources need to be free of toxins. Taonga – tuku – iho are prized resources passed down through the generations which Nga Papatipu Runanga in particular, continue to access and utilise for mahinga kai, medicinal purposes, for producing woven products and other uses. The pest wasp's stinger contains venom that is transmitted to people during a sting. The ability of wasps to sting multiple times in conjunction with the aggressive nature of wasps significantly increases the likelihood of being stung. It's also possible to have a serious reaction if you're allergic to the venom. Between 2014 and 2019 ACC recorded and average of 1,055 claims per year due to wasp stings. Maori whanau health statistics indicate there is a likelihood that whanau are struggling with multiple social and poor health issues such as asthma, high blood pressure, diabetes, obesity and other health conditions. It is the pepi, (infant), tamariki (children) and kaumatua (esteemed elders) who are especially vulnerable, and a wasp sting could acerbate other health conditions such as asthma or skin allergies leading to primary and secondary healthcare, or in rare cases, fatalities.

He Tāngata (People and Communities)

The broader social influences on a community which might include; recreational spaces, employment, housing, land usage, and other areas. The threat of a wasp sting in areas with high populations of wasps will reduce the utilisation of recreational spaces by whanau.

Kaitiakitanga (Guardianship)

Kāitiakitanga is about our responsibility as Te Rūnanga o Ngāi Tahu, both tribally and in our communities, to assess the cultural acceptability of a proposed activity. We are a part of the landscape and therefore have a responsibility to ensure its sustenance for this generation and for those to come.

The relationship between kaitiaki and taonga can be layered and complex. Different kaitiaki have different degrees of responsibility for taonga such as the kaitiaki of plants and mātauranga associated with them. The kaitiaki relationship can relate to the sustainability of the taonga itself, or it its components within the taonga that make it up, or to species, biota and environment surrounding the taonga. The use of “natural” bio-controls is far more acceptable than chemical pesticides. However, investing in biocontrol organisms is a long-term strategy that requires enough planning and monitoring to ensure the effective eradication of the pest wasp population.

Te Tiriti o Waitangi (Treaty Principles)

The Crown has an obligation to honour the Waitangi Treaty principles of Partnership, Participation and Protection. The Ngai Tahu Settlement Act explicitly lists flora and fauna that are considered taonga to the iwi. This is not an intended to be an exhaustive list, as any organism sourced within Ngai Tahu takiwā may be considered taonga, and at a minimum require some level of consultation. Consultation with Treaty partner TRONT/ Ngā Papatipu rūnanga in relation to their taonga and the proposed application requires contact in the earliest stages of the application process through to its submission and, if approved, mutual agreement on conditions and ongoing monitoring mechanisms to ensure beneficial outcomes are achieved. We were pleased to note that a Maori reference group was established in 2014 that included Te Herenga, Ngai Tahu and other iwi. In more recent times, we also acknowledge the efforts taken by the applicant to consult with the wider eight Iwi groups within the Tasman/ Nelson District. It is our hope that these various discussion and consultations held with Maori community and Iwi groups will continue on through the implementation and monitoring phases in the establishment of the bio-control organisms. We note the concerns of manawhenua in Te Tau Ihu; including an increase in food competition for native pollinators, long term monitoring to ensure parasitism of native species doesn’t occur (especially bees) and failure of previous wasp biocontrol measures. These are concerns that are shared by Ngāi Tahu.

6. Conclusions

Over the years, Te Rūnanga o Ngāi Tahu (TRoNT) has consistently advocated for methods of pest and weed control that have reduced negative impacts on the environment. We recognise the merits of establishing bio-control organisms to eradicate the pestwasp population. Wasps are a nuisance to tourist visitors and people. They are a worry to tourist operators, unwelcome guests at summer picnics and barbecues and other social or recreational pursuits. No-one finds a wasp sting a fun experience. The venom from a wasp sting contains several toxins that can cause a hypersensitive or allergic reaction in some instances and for vulnerable Maori whanau this could acerbate other health conditions.

Wasps are a major problem in some beech forests especially in the Tasman/ Nelson District where they consume massive amounts of honeydew. Honeydew is produced by a native scale insect and is an important food for native birds, bats, insects and lizards. Wasps also eat huge numbers of native insects and have even been seen killing newly hatched birds. By eating so much, they upset the natural food chain of the forest and adversely impact on native fauna and flora.

The introduced pest wasp continues to cost New Zealand’s economy millions of dollars a year to cover in baiting and the economic losses felt within the tourism and recreational areas. The horticultural, farming and apicultural industries who are heavily reliant on the native bees for honey, beekeeping, pollination of pastural clover and seedlings will continue to suffer losses caused by the infestation of wasp dense populations especially within the Tasman/ Nelson region.

The studies conducted on the viability of using M. paradoxus and V. inanis to control the wasp populations seems promising, however, we request that long term monitoring be required to both measure effectiveness and ensure that these parasitoids remain specific to Vespula. For these reasons, we support the introduction of APP203853. We do not wish to be heard in support of our application.

7. Recommendation

We recommend that this application be accepted, subject to long term monitoring. Ngai Tahu iwi would like to be advised of the timeframes of when these new bio-control organisms will be released into the environment and will be seeking more information on how this new organism will be monitored.

APP203875 Vespula wasp BCA - Auckland Council Officer submission

Ka mihi ake ai ki ngā maunga here kōrero, ki ngā pari whakarongo tai, ki ngā awa tuku kiri o ōna manawhenua, ōna mana ā-iwi taketake mai, tauiwi atu. Tāmaki – makau a te rau, murau a te tini, wenerau a te mano. Kāhore tō rite i te ao.

I greet the mountains, repository of all that has been said of this place, there I greet the cliffs that have heard the ebb and flow of the tides of time, and the rivers that cleansed the forebears of all who came those born of this land and the newcomers among us all. Auckland – beloved of hundreds, famed among the multitude, envy of thousands. You are unique in the world.

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This is an ‘officer only’ submission. The officer generally supports the application to introduce Volucella inanis and Meteocus paradoxus as biocontrol agents to reduce the presence and impacts of Vespula wasps in Aotearoa / New Zealand.

Vespula wasps are widely recognised as one of the most impactful and prevalent insect pests in the Tāmaki Makaurau / Auckland region and are the cause of frequent public enquiries to Auckland Council. In 2018, 290 wasp-related service orders were raised, this increased to over 350 service orders the following year, indicating an upward trend in wasp abundance within the region (recognising this may also include service orders relating to Polistes wasps). The ecological, economic, social nuisance and human health impacts, as documented in the application, have been pervasive in both ecologically vulnerable habitats and synanthropic habitats throughout the region. These landscape-scale impacts are only expected to worsen as Vespula wasp numbers increase, particularly in the absence of an impactful, cost-effective, long-term and sustainable management tool. Due to their widespread naturalisation, it is considered unfeasible to eradicate Vespula wasps at a regional scale and instead management efforts, namely chemical control, have been reprioritised towards protecting sites of high ecological value, e.g. the Waitākere ranges or at public sites where there may be a high risk to human health. The use of an effective biological control programme is welcomed as another tool in the long-term management of Vespula spp. and will hopefully complement localised chemical control efforts to reduce their distribution throughout the region. Supporting this initiative is also in line with our ten-year objective in the new Auckland Regional Pest Management Plan to ‘sustainably control’ Vespula wasps by reducing their spread and impacts across the Tāmaki-Makarau Auckland region.

Other considerations:

• There is increasing public concern that non-target impacts to native species are not well mitigated or understood. This poses a risk to the social licence for using biocontrol more broadly, including for management of pest plants. Further, insect agent / insect pest biocontrol is anecdotally considered to be riskier than insect agent / plant pest biocontrol. Therefore, it is expected that an extra layer of caution should be applied when considering release of invertebrate agents, even when there is a compelling ecological and/or economic case for their use. In this instance, while it is accepted that the life history traits of both species are highly specialised to only attack Vespula spp., it is believed that this could have been better substantiated via a more extensive use of host- specificity trials. Specifically, testing for non-target impacts using native solitary bee larvae (in line with the host- specificity trial demonstrated for Bombus spp.) in conjunction with native range records would better alleviate any public concerns around non-target impacts in an Aotearoa / New Zealand setting. • There is an increasing social and political appetite to implement long-term monitoring, including outcome and non-target monitoring, when releasing a new biocontrol agent. This is to ensure 1) any detrimental ecological impacts are recorded and subsequently mitigated, 2) the social licence to use biocontrol is not lost and 3) ecological, social and economic benefits are well quantified. It is commended that a post-release long-term monitoring programme has been broadly outlined as part of this application and the officer implores that a number of measures are also considered as part of this approach, as below.

Relief sought

In addition to monitoring the population of the proposed biocontrol agents, the impacts on the host, and the presence of agents in neighbouring honeybee hives, the officer wishes the addition of the below measures to be considered in the long-term monitoring programme:  impacts on non-target native solitary and other introduced bee populations. Although the risk of non-target attack by each agent is considered to be low, it is important to try and verify this in the field post-release to demonstrate ‘proof of concept’ to the public and increase the rigour of host-testing in future biocontrol projects.  any replacement type effects amongst introduced social wasps due to the reduction in abundance of Vespula spp. e.g. localised abundance levels of Polistes spp, or within the Vespula genus itself.  beneficial ecological outcomes at various trophic levels, including impacts on honeydew levels in beech systems heavily impacted by wasps. Outcome monitoring is often forgotten when ‘telling the story’ about biocontrol effectiveness. Although it potentially may be difficult to quantify in some instances, outcome monitoring can again demonstrate the long-term, far reaching and sustained positive impacts of biocontrol as a pest management tool.

Lastly, if this application is approved, it is requested that Auckland Council is kept up to date with any long-term monitoring results or other updates to ensure we can best communicate these with local stakeholders and mana whenua in Tāmaki-Makaurau.

Thank you for the opportunity to provide feedback on this application.

Ngā mihi nui, Emma Edney-Browne | Regional Advisor - Pest Management Natural Environment Design | Environmental Services Level 2S Bledisloe Building, 24 Wellesley Street, Auckland Visit our website: www.aucklandcouncil.govt.nz

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APP203875 - Common and german wasp BCA

Submission Reference no: 16

Excell Biosecurity (David Hunter) 312 Upper Church Road Banks Peninsula New Zealand Ph: 0274374743 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes I support the introduction of these two parasites for the Common and German wasps. Both of these wasp species are of no use of any kind in New Zealand, in fact they goth have enormous adverse affects to the New Zealand fauna and flora as well as the public in New Zealand virtually anywhere in an outdoor environment. Having had to poison hundreds of wasp nests around schools, playing fields, roadsides and in houses the release of these parasites should make a really important difference to the wasp population in New Zealand. In my experience the successful use of Vespex seems to be limited to areas of thick native bush, in rural areas and in cities wasps seem to have enough food sources as not to require the baits used for Vespex poisoning, the finding and poisoning of nests can be at times slow and sometimes a painful. The introduction of these parasites will be a very welcome addition for wasp control.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes To back the introduction of these parasite species

Clause 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. Position No I do not wish to speak about my submission at the hearing Notes Your submission to APP203875 - Common and german wasp BCA

Reference no: 17

Clause What is your position on the application? Position I support the application Notes Provided the proposed biocontrol agents establish successfully and effectively suppress Vespula spp. populations, with minimal negative impacts for native species and ecosystems, they will be a valuable tool for conservation in Aotearoa. The prospect of suppression of Vespula spp. populations at either a regional or national scale via biocontrol agents is exciting for conservation in Aotearoa, both from ecological and volunteer management perspectives. I support the release of the proposed biocontrol agents in Aotearoa, provided the points listed in the next section are adequately addressed.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes The management of Vespula spp. and the release of biocontrol agents are both high priorities for conservation in Aotearoa. As noted in the application, Vespula spp. have wide reaching and well documented negative impacts on a range of native species in Aotearoa. The context for this submission is the relevance this application has to my current role as Programme Manager for the Ark in the Park, Waitākere Ranges, Auckland. I am currently employed by Forest & Bird, and the Ark is a partnership with Auckland Council which protects 2270ha of the Waitākere Ranges Regional Park. I have a background in pest management (primarily pest plants), and an MSc in Biosecurity and Conservation from the University of Auckland. At present, Ark in the Park volunteer activity is put on hold during the summer when Vespula spp. activity is the highest. This reduces the programmes efficiency, as it limits capacity to provide protection for the Ark which is home to many native species including reintroduced North Island kōkako, toutouwai/North Island robin, Hochstetter’s frog, and pekapeka/long-tailed bats. Previous control at the Ark has been undertaken, including a trial of Vespex, however this has not yet been adequately successful. Documents/reports may be available on request. I have some points for consideration, before any releases of biocontrol agents occur: 1. A greater focus on monitoring the outcome of the release of the biocontrol agents. The application noted that juvenile life stages will likely be difficult to monitor, but as both proposed agents have an adult stage capable of flight, this presents an opportunity for flight intercept traps to be employed. Furthermore, informed citizen science such as a portal for conservation managers to report sightings would assist in tracking the rate of spread of released biocontrol agents. 2. The application understandably focuses on the impacts in beech forests. Long term monitoring of impacts (both negative and positive) should ideally consider the full habitat range of Vespula spp., particularly given that the impacts noted in the submission (eg. costs to industries) appear to be based on nationwide impacts. 3. Further NZ specific information would be beneficial. As noted in the application, once biocontrol agents are released, subsequent eradication is an unlikely option. Further trials, such as those conducted prior to releasing biocontrol agents to manage pest plants, would be beneficial to strengthen the application. 4. While there was a detailed focus on the potential impacts of the juvenile stages of each proposed agent (as these are the stages which interact with Vespula spp.), there was little information regarding the adult stages of the two species. While the applicants may have sufficient information available to be confident that the adult stages will not have a negative impact in Aotearoa, this could be more strongly addressed in the application or subsequent communications. Trials or research noting that the adult stages will not cause significant damage to native ecosystems, or occupy niches which negatively affect native species based on their physical and ecological characteristics, would be ideal. For example, noting what physical niche(s) the adult stage of each species occupies (e.g. are they generalists, do they occupy burrows in tree trunks, etc.). 5. Generally, an increased and planned focus on post-release monitoring of the biocontrol agents and their impacts would be beneficial not only for Aotearoa, but global conservation efforts. The application notes that Vespula spp. are a pest species in other locations, and also that the proposed biocontrol agents have not yet been utilised elsewhere. Any information learned from the management of Vespula spp. in Aotearoa which is relevant in other contexts should ideally be shared, to benefit global conservation efforts. This could be achieved by a manner of cost-effective methods, such as by encouraging conservation groups to report findings, or supporting a research student to monitor the agents post-release. 6. I am not aware of the breadth of pathogen screening which occurs before organisms are imported to Aotearoa. It is important to ensure that the pre-importation screening for pathogens includes screening for any organisms which may impact native plant species, as other insects are known to be vectors not only for vertebrate pathogens which are often a focus, but also plant pathogens such as Dutch Elm Disease.

Clause 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. Notes None. You have elected to withhold your personal details from publication. APP203875 - Common and german wasp BCA

Submission Reference no: 18

Jacqui Knight, Moths and Butterflies of New Zealand Trust PO Box 44100, Pt Chevalier Auckland 1246 Auckland New Zealand Ph: 027 481 4811 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes Our wish for the EPA is to make the following decision: Approve use of the introduction of this biological control.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes The Moths and Butterflies of NZ Trust's vision is to ensure that NZ’s ecosystem supports thriving butterfly and moth populations. Our mission is to engage with New Zealanders to ensure our biodiversity promotes a thriving moth and butterfly population. Our members are particularly concerned with the devastating effect that social wasps are having on our butterflies. Whatever is affecting our butterflies is no doubt affecting our moth species of which there are thousands, with scientists stating that there are potentially many unidentified moth species. An example of a species under threat is the endemic forest ringlet, Dodonidia helmsii. Also known as Helms’ butterfly it is a rare member of the Nymphalidae family endemic to NZ. It was first described by Richard William Fereday from a specimen collected in the Paparoa Range by naturalist Richard Helms of Greymouth. The species was properly named in 1884 by Arthur Gardiner Butler because it resembled the Asian ‘Dodona’ species and it is the only species in its genus. The forest ringlet has undergone a documented decline and is now occupying less than 10% of its former range.It is understood that the butterfly was once common in NZ but it has become significantly rarer over the last 50 years. It is not known what is affecting the numbers of the forest ringlet but one of the prime suspects is social wasps. What affects numbers of this butterfly undoubtedly will also be reducing numbers of some of our moth species. The MBNZT is undertaking a major project to learn more about the forest ringlet and ensure that its decline is reversed. We would therefore endorse any biological control being introduced to reduce numbers of Vespula species, providing the applicant has done a thorough investigation of any possible adverse effects. It would appear from the documentation that the potential negative impacts have been thoroughly investigated.

Submission Reference no: 19

Clifford Paul Mason 21 Voelas Road, Lyttelton Christchurch/Canterbury New Zealand Ph: (03) 3288 538 or (09)480 5756 or 027 303 5033 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I oppose the application Notes

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes The introduction of any alien organism to New Zealand compromises ecological integrity. The effects upon target organisms, trophic webs and many other ecosystem components or properties are difficult to judge. The ability of the proposed agents to reduce the abundance of the pest organisms to a degree that is ecologically and economically significant is unproven.

Clause 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. Position Yes I wish to speak about my submission at the hearing Notes I may negate this wish when I have reviewed all of the submissions that may be received and the EPA staff assessments APP203875 - Common and german wasp BCA

Submission Reference no: 20

Derek Craig, Oak & Thistle Ltd (Derek Craig) 1/56 Quadrant rd, Onehunga Auckland New Zealand Ph: 0275250877 [email protected] Submitter Type: Not specified Source: Web Form Overall Position:

Overall Notes:

Clause What is your position on the application? Position I support the application Notes I support the application to release two social wasp parasitoids into the wild.

Clause The reasons for making my submissions are: (Any supporting documents can be attached at the end of this submission) Notes I believe the release of the two new parasitoids will lower the harm done to native invertebrates through competition for food resources and direct removal of native invertebrates through hunting.