EPA Staff Assessment Report on application APP203950

To import for release tetrasperma

17 December 2019

Application number: APP203950

to release the tropical houseplant Rhaphidophora Purpose: tetrasperma, otherwise known as Philodendron ‘Minima’ or Mini , without controls

Applicant: New Zealand Producers Incorporated (NZPPI)

Application Lead: Gabi Hidvegi

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EPA staff assessment report for application APP203950

ADVICE TO THE DECISION MAKER

Executive summary and recommendation

On 9 December 2019, the Environmental Protection Authority (EPA) formally received an application from New Zealand Plant Producers Incorporated (NZPPI) (the applicant) to import and release Rhaphidophora tetrasperma. The organism, a tropical plant species native to Southeast Asia is intended to be imported and released for commercial purposes. The application to import and release Rhaphidophora tetrasperma was lodged pursuant to section 34 of the Hazardous Substances and New Organisms (HSNO) Act 1996 (the “HSNO Act”).

Based on the information in the application and from other published sources, we found, based on:

 its reliance on a specialised pollinator,  no evidence of reproduction via seed dispersal outside its native habitat,  no reports of closely related such as R. decursiva being invasive in New Zealand despite years of presence,  significant climatic differences between its native habitat and New Zealand,  ease of eradication, that it is highly improbable that Rhaphidophora tetrasperma could form a self-sustaining population and have significant adverse effects on the health of the public, any valued species, natural habitats, or the environment.

Therefore, we recommend that the application is approved.

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Table of Contents

Executive summary and recommendation ...... 2

Table of Contents ...... 3

Purpose of this document ...... 4

Application summary ...... 4

The organism: Rhaphidophora tetrasperma ...... 4

Māori considerations ...... 5

Summary of information from other agencies ...... 8

Rapid Assessment criteria to be considered ...... 9

Conclusion and recommendation ...... 10

References ...... 12

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Purpose of this document 1. This Staff Assessment Report was prepared by Environmental Protection Authority (EPA) staff to assist the decision-maker in considering application APP203950. It contains information from the applicant and other readily available sources, and it sets out the statutory criteria applicable to the consideration of this application under the HSNO Act.

Application summary 2. On 9 December 2019, the Environmental Protection Authority formally received an application from New Zealand Plant Producers Incorporated (NZPPI) seeking approval to import and release Rhaphidophora tetrasperma under section 34 of the Hazardous Substances and New Organisms (HSNO) Act 1996. If approved for importation and release, Rhaphidophora tetrasperma will be imported and sold for commercial purposes. The application was lodged pursuant to section 34 of the HSNO Act.

The organism: Rhaphidophora tetrasperma 3. Rhaphidophora tetrasperma is a tropical plant species native to Malaysia and Indonesia and is limited to Peninsular Malaysia (Kelantan and Perak regions) and the far south of Thailand. It is known by many names including Philodendron ‘Minima’ or ‘Mini monster’. of Rhaphidophora tetrasperma: Clade: Monocots

Order:

Family: Genus: Rhaphidophora

Species: tetrasperma Hook.f.

4. Rhaphidophora tetrasperma is one of approximately 100 species within the genus Rhaphidophora which is one of the largest aroid genera in tropical Asia (Boyce, 1999). It occurs naturally in disturbed, dry to wet tropical forests on sandstone and granite (Kew, 2019).

5. It is a small to medium-sized, slender, heterophyllus1 climbing liane2 reaching up to five metres in length. Scientific reports on this species are limited and details of its reproductive biology are absent.

6. The scientific literature suggests that species within the Aroideae genera require specialised pollinators from Hymenoptera to facilitate seed production (Gibernau, 2011). Without its co- evolved pollinating insects and therefore the ability to set seed, the plants cannot reproduce so it is considered that R. tetrasperma will not be able to establish self-sustaining populations in New Zealand. Furthermore, fruiting of R. tetrasperma has not been observed from specimens at Kew Gardens, United Kingdom (Kew, 2019).

1 Heterophyllus: having the foliage leaves of more than one form on the same plant or stem. 2 Liane: a climbing or twining plant

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Māori considerations 7. As specified in Part 2 of the HSNO Act (Purpose of Act), the EPA must recognise and account for (among other things) several principles and matters of relevance to Māori, particularly as they relate to:  the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social, and cultural well-being and for the reasonably foreseeable needs of future generations (section 5(b))  the relationship of Māori and their culture and traditions with the ancestral lands, water, sites, wāhi tapu, valued flora and fauna, and other taonga (section 6(d))  the principles of the Treaty of Waitangi (Te Tiriti o Waitangi) (section 8) 8. The assessment of these principles and matters of relevance to Māori was undertaken by the EPA’s Māori advisory Policy and Operations group, Kaupapa Kura Taiao. The full text of this assessment is reproduced below. APP203950 Release without controls of Rhaphidophora tetrasperma

Māori Perspectives Report (MPR)

for Non-Notified, Release of a Qualifying Organism Application

Executive Summary

Kaupapa Kura Taiao (the EPA’s Māori Policy and Operations team) has undertaken an assessment to consider potential impacts of the release without controls of the Rhaphidophora tetrasperma on the economic, social, and cultural well-being of Māori, and the relationship of Māori with the environment, pursuant to sections 5(b), 6(d) and 8 of the HSNO Act.

Māori may have concern about the release without controls of the Rhaphidophora tetrasperma given their uncertainty about its effect on the relationship of Māori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga. This stems from uncertainty about the reproductive capacity of the plant and the potential impact of climate change. A further concern would be about allowing the release of an accidently imported plant without the full scrutiny of a public notification and the precedent it sets for the next time an importer decides to bring it on purpose. The applicant has stated that there has been no engagement with Māori on the basis that it is not a species about which Māori would raise concerns.

Ngā Mātāpono o Te Tiriti o Waitangi (the Principles of the Treaty of Waitangi) have been considered in relation to this application – Māori may have concern about the extent to which their interests are protected in relation to this application

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Ngā here ture (Statutory obligations)

Section 5(b) provides that to achieve the purpose of the Act, the decision maker must recognise and provide for the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social, and cultural wellbeing and for the reasonably foreseeable needs of future generations.

Section 6(d) of the Act obliges all persons exercising functions, powers, and duties under the Act, to achieve the purpose of the Act, to take into account the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga.

In accordance with section 8, the decision maker is required to take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi).

The Treaty principles most relevant to assessing and deciding this application are:

 Māori interests are being actively protected in relation to this application.

 The decision makers on this application are making a decision informed by a Māori perspective.

 The EPA considers it is acting in good faith, and is acting reasonably and fairly, in respect of this application. Mātauranga Māori and tikanga Māori are being respected.

Assessment of impacts on cultural receptors

Impact on Papatūānuku (Land and soils) The introduction of Rhaphidophora tetrasperma may have a negative impact on Papatūānuku. From a Māori perspective, a significant concern may be around the fact that several accidents have already resulted in the sale of these plants without any form of public input. The use of the rapid pathway to retrospectively legitimise these imports may undermine confidence in the HSNO system and raise questions about the obligation importers have to accurately describe the products they are bringing in.

The application uses the single example of a related plant, Rhaphidophora decursiva, which is present in New Zealand, to suggest the plant is unlikely to set seed in the current New Zealand climate and lacks specialised pollinators to assist with reproduction. While the plant is intended for use in offices and domestic spaces, Māori may have concerns about its reproductive capacity should it be released more widely, including around pollination and the impact of future climate change on the plant. A slight increase in temperature could alter the distribution of the plant and the areas to which it may spread. Māori would need to have confidence in the claims made.

Impact on Ngā otaota (Plants)

Based on the comments in above, the introduction of Rhaphidophora tetrasperma may have a negative impact on ngā otaota.

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Impact on Ngā manu, me ngā ngārara (Birds and reptiles)

There is uncertainty about the impact the introduction of Rhaphidophora tetrasperma may have on ngā manu, me ngā ngārara.

Impact on Te Aitanga Pepeke (Arthropods)

There is uncertainty about the impact the introduction of Rhaphidophora tetrasperma may have on Te Aitanga Pepeke.

Impact on Ngā wai koiora (Aquatic habitats)

The introduction of Rhaphidophora tetrasperma is not likely to have a negative impact on ngā wai koiora.

Impact on Taha hauora (Human health and well-being)

The introduction of Rhaphidophora tetrasperma is not likely to have a negative impact on taha hauora.

Impact on kaitiakitanga and manaakitanga (resource guardianship and due care)

Uncertainty about the reproductive capacity of the plant and the potential impact of climate change following the introduction of Rhaphidophora tetrasperma may have a negative impact on kaitiakitanga and manaakitanga.

Ngā hua (Benefits)

The applicant intends to release Rhaphidophora tetrasperma without controls to domestic and office spaces.

 The introduction of Rhaphidophora tetrasperma is not likely to benefit the social wellbeing of Māori

 The introduction of Rhaphidophora tetrasperma is not likely to benefit the cultural wellbeing of Māori

 The introduction of Rhaphidophora tetrasperma is not likely to benefit the economic wellbeing of Māori

Analysis of impact

The benefits to Māori associated with this application are negligible and don’t outweigh any impacts to Māori.

The overall impact on the relationship Māori have with their environment and taonga are uncertain and may negatively impact the ability of Māori to exercise kaitiakitanga.

The overall impact on Māori economic wellbeing (arising from the impact on the environment and taonga) is likely to be negligible. It is likely there are no benefits or adverse effects to impact Māori economic wellbeing.

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The overall impact on Māori social wellbeing (arising from the impact on the environment and taonga) is likely to be negligible. This includes impacts on Māori ways of life and taha hauora (human health and well-being). It is likely there are no benefits or adverse effects to impact Māori social wellbeing.

The overall impact on Māori cultural wellbeing (arising from the impact on the environment and taonga) is likely to be negligible. This includes potential impacts Māori may experience in relation to their customary practices, traditions, beliefs, institutions, and lore. It is likely there are no benefits or adverse effects to impact Māori cultural wellbeing. Te Tiriti o Waitangi

The Principles of the Treaty of Waitangi have been considered in relation to this application and the areas where Māori may have concerns under the Treaty Principles, are as summarised below.

 Māori interests are being actively protected in relation to this application – the potential impact on the ability to exercise kaitiakitanga.

 The decision makers on this application are making a decision informed by a Māori perspective – areas where Māori may have concern are noted in this report.

The EPA considers it is acting in good faith, and is acting reasonably and fairly, in respect of this application. Mātauranga Māori and tikanga Māori are being respected. Kupu whakatepe (Conclusion)

Impact on the maintenance and enhancement of the capacity of people and communities to provide for their own economic, social and cultural well-being

This application is not likely to significantly affect the ability and capacity of Māori to maintain their economic, social and cultural wellbeing.

Impact on the relationship of Māori and their culture and traditions with their environment and taonga This application may have an affect the relationship of Māori and their culture and traditions with their environment and taonga, including culturally significant species, resources, and places, and the customary values, practices and uses associated with these taonga.

Dated: 12 December 2019 Summary of information from other agencies 9. The Department of Conservation (DOC) and the Ministry for Primary Industries (MPI) were given the opportunity to comment on the application. 10. DOC stated that R. tetrasperma could potentially establish in the natural environment for example Northland, but, not in other regions of New Zealand under current temperatures. Climate change could however alter the risk of this species and enable it to establish elsewhere. 11. DOC stated that R. tetrasperma is likely to grow at sites where it has been dumped but there are no obvious pathways for spread from these sites and growth is not likely to be vigorous. DOC

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stated that the intention of using R. tetrasperma for indoor purposes should greatly reduce the likelihood of illegal dumping but not preclude it entirely. 12. DOC stated that they consider the likelihood of this species becoming a serious environmental weed to be low (but not zero and with the proviso that climate change could heighten the risk). 13. DOC stated that they do not oppose the release of R. tetrasperma.

14. MPI referenced two blogs by Lucas (2019) and Russell (2018) which stated that growers consider R. tetrasperma to be ‘very invasive despite the fact it is considered moderately rare in nature’. This statement referred to greenhouse experiences in temperate environments; however, could be relevant to outdoor conditions in mild to tropical climates. 15. MPI noted that another related member of the monsteroid family, Monstera deliciosa, has become mildly invasive in many areas of New Zealand, even though (apparently) it is not known to set seed in the absence of a pollinator similar to R. tetrasperma.

16. MPI noted that the applicant has stated that ‘there are no known risks from the release of R. tetrasperma in New Zealand’. MPI noted that while this may be true, very little is known about R. tetrasperma particularly in relation to hardiness, temperature requirements and its ability to thrive outside its known natural distribution. 17. MPI stated that it is unlikely that R. tetrasperma will propagate through the production of seed and the applicant provides good evidence to support this contention. Propagation through cuttings is obviously readily possible and it appears that this is a key means of producing further plants in commercial trade settings. MPI noted that it is entirely possible that R. tetrasperma could naturally propagate via stem segmentation through natural breakage of internodes particularly when placed into novel environments where seed propagation is unfavourable.

18. MPI noted that while information regarding this species is relatively poor, it appears that it has the capability to survive in a wide variety of climatic conditions in New Zealand, even those at low temperatures. MPI concluded that if R. tetrasperma does establish, it may be relatively easy to eradicate but this is an entirely unknown factor given the paucity of information on the species.

Assessment of the risk of Rhaphidophora tetrasperma release against the Rapid Assessment criteria 19. Under section 35(3)(b) of the Act, the application may be declined, if the organism is likely to fail the minimum standards specified in section 36 of the Act. Each of the minimum standards is briefly considered below, drawing on the material addressed in the above sections on the identification and assessment of risks for the proposed introduction. 20. In respect of each element of section 36, based on the available evidence I consider that R. tetrasperma is:  not likely to cause significant displacement any native species within the natural habitat;  not likely to cause significant deterioration of natural habitats;  not likely to cause significant adverse effects to human health and safety;  not likely to cause any significant adverse effects to New Zealand’s inherent genetic diversity; and  not likely to cause disease, be parasitic, or become a vector for human, animal, or plant disease

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21. It is highly improbable that R. tetrasperma could form an undesirable self-sustaining population that would have significant adverse effects on the health and safety of the public, any valued species, natural habitats or the environment, given that:  The native geographic distribution of R. tetrasperma is in the tropical south-eastern Asian countries of Malaysia and Indonesia. The natural habitats that it thrives in are dry to wet rainforests that have high humidity, high annual average rainfall of 2,500mm and an average temperature of 27ºC. The temperature in its native climate does not fall below 18ºC even during the cooler season. New Zealand’s climate is therefore an unsuitable habitat.  As information on this species is limited, we can use a related tropical Rhaphidophora species, Rhaphidophora decursiva as a proxy for R. tetrasperma. Rhaphidophora decursiva is a tropical species which has been present in New Zealand for many years, produces flowers and survives outdoors in Northland. Despite its natural distribution in tropical Asia, ability to produce flowers and survive in the New Zealand environment, R. decursiva has not been observed to set seed which suggests that this species is sterile and native pollinators are incompatible. There is no evidence to suggest that either R. tetrasperma or R. decursiva naturally reproduce via stem segmentation.  Without its co-evolved pollinating insects and ability to set seed, it is considered that Rhaphidophora plants are incapable of reproducing and therefore, unable to establish self- sustaining populations in New Zealand.  To cause deterioration of natural habitats in New Zealand, R. tetrasperma would have to form self-sustaining populations that are not easily eradicated and become invasive. It is highly improbable that R. tetrasperma could form self-sustaining populations anywhere in New Zealand given the climatic unsuitability and lack of specific pollinators that it evolved in conjunction with.  No native Rhaphidophora species exist therefore, hybridisation with native species is not a concern. At a population level and across geographic scales it is highly improbable for R. tetrasperma to displace the value of native species and cause significant adverse effects to New Zealand’s inherent genetic diversity.  Rhaphidophora tetrasperma is not known to cause or be a vector of any disease, therefore, the risk to public health is negligible.

Conclusion and recommendation 22. In order to reproduce and set seed, R. tetrasperma is considered to have a co-evolved, specific pollinator in its native habitat of Southeast Asia. Without this pollinator, it is unable to set seed and reproduce as no successful efforts outside its native habitat have been documented. It is unknown what R. tetrasperma’s pollinating species is, however, as it is considered to have co-evolved with this species and it has been unsuccessful in reproducing outside Asia, the pollinator must be only present in its native habitat of tropical Southeast Asia. Reproductively, New Zealand is unsuitable for R. tetrasperma to establish self-sustaining populations as its co-evolved pollinator is absent.

23. Its native habitat of Southeast Asia is tropical with high average temperatures that do not fall below 18ºC and 2500mm of annual rainfall of which, New Zealand has no similar environment. Climatically, New Zealand is unsuitable for R. tetrasperma to establish self-sustaining populations.

24. The closely related species R. decursiva which originates from the tropics has been present in New Zealand for years and is not considered or listed as invasive. In relation to R. decursiva, there are no reports of any deterioration of natural habitats, displacement of native or beneficial

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species, significant adverse effects to New Zealand inherent genetic diversity or adverse impacts on people and public health. We believe that R. tetrasperma will have the same risk profile given the similarities in phylogeny, tropical origins, climatic suitability and no reported environmental risks associated with either species. This species does not naturally reproduce via stem segmentation, therefore, any dispersal and establishment of R. tetrasperma via this method will only occur through human intervention. 25. Furthermore, should any cuttings of R. tetrasperma be negligently discarded, it may have the capacity to grow in isolated areas. When taking into consideration the lack of a co-evolved pollinator, New Zealand’s unsuitable climate for tropical plants and the ease of eradication, R. tetrasperma should not have the means to form self-sustaining populations, become an invasive pest or be the causal agent for deterioration of native habitats and species. 26. Thus, we recommend that this application to import and release Rhaphidophora tetrasperma be approved.

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References

Boyce, P.C. 1999. The genus Rhaphidophora Hassk. (Araceae-Monsteroideae-Monstereae) in Peninsula Malaysia and Singapore. Gardens’ Bulletin Singapore. 51: 183-256.

Gibernau, M. 2011. Pollinators and visitors of Aroid inflorescences: an addendum. Aroideana. 34: 70- 83.

Kew, 2019. Royal Botanic Gardens Kew Science: Plant of the World online. Accessed on 3 December 2019: http://powo.science.kew.org/taxon/urn:lsid:ipni.org:names:88594-1

Lucas, S. 2019. Rhaphidophora tetrasperma Hook. F. The Exotic Rainforest. Retrieved on 16 December 2019: http://www.exoticrainforest.com/Rhaphidophora%20tetraspema%20pc.html Russell, E. 2018. Plant profile: Rhaphidophora tetrasperma. Retrieved on 16 December 2019: https://www.stamenandstemblog.com/blog/rhaphidophoratetrasperma

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