APP202663 Tutsan Biological Control - Submissions

To introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan (Hypericum androsaemum) under section 34 of the Hazardous Substances and New Organisms Act 1996 Volume 1 of 1

11 March 2016

Contents

SUBMISSION 111593 Walter W King: The Proprietors of Hauhungaroa 1c Incorporation

SUBMISSION 111594 Davor Bejakovice: Greater Wellington Regional Council

SUBMISSION 111595 Grant and Sheryl Fraser

SUBMISSION 111596 Christopher Houston: Beef + Lamb New Zealand

SUBMISSION 111597 Warren Furner: Ruapehu District Council

SUBMISSION 111598 Lyn Neeson: Ruapehu Federated Farmers

SUBMISSION 111599 Cushla Chubb

SUBMISSION 111600 Gerry Coates: Te Runanga o Ngai Tahu

SUBMISSION111601 Jenny Dymock: Northland Regional Council Submission

SUBMISSION111602 Fiona McTavish: Bay of Plenty Reg Council

SUBMISSION111603 Philippa Rawlinson: Federated Farmers of New Zealand

SUBMISSION111604 David Havell: Department of Conservation

SUBMISSION111605 John Liddle: Nursery and Garden Industry Assn NZ

www.epa.govt.nz SUBMISSION 111593

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]

Once your submission has been received the submission becomes a public document and may be made publicly available to anyone who requests it. You may request that your contact details be kept confidential, but your name, organisation and your submission itself will become a public document.

Submission on application APP 202663 - Tutsan BCA number: Name of submitter or contact for Walter W Kingi joint submission: Organisation name The Proprietors of Hauhungaroa 1c Incorporation (if on behalf of an organisation): Postal address: P.O. Box 7043 Tikipunga WHANGAREI 0144

Telephone number: 0274 980750

Email: [email protected]

I wish to keep my contact details confidential

The EPA will deal with any personal information you supply in your submission in accordance with the Privacy Act 1993. We will use your contact details for the purposes of processing the application that it relates to (or in exceptional situations for other reasons permitted under the Privacy Act 1993). Where your submission is made publicly available, your contact details will be removed only if you have indicated this as your preference in the tick box above. We may also use your contact details for the purpose of requesting your participation in customer surveys.

The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission available in response to a request under the Official Information Act 1982.

www.epa.govt.nz 2

Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: To publically support the excellent work of the Tutsan Action Group.

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: To introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan (Hypericum androsaemum) ASAP.

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.

September 2012 EPA0190 SUBMISSION 111594

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 PP202663 number: Name of submitter or contact for Davor Bejakovich, Manager, Biosecurity joint submission: Organisation name Greater Wellington Regional Council (if on behalf of an organisation): Postal address: Greater Wellington Regional Council, PO Box 41 Masterton 5840

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 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: Greater Wellington Regional Council (GWRC) supports the proposal to introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents to assist with the management of tutsan (Hypericum androsaemum). An effective biocontrol agent for tutsan will help to slow the spread and impact of this highly invasive species. Tutsan is a well established species throughout New Zealand and is a significant problem in the central north island. It invades pastoral country and regenerating scrublands and forest and the seed is readily spread by birds and through soil and water. Under the GWRC Regional Pest Management Plan (RPMP), GWRC staff and contractors undertake a range of pest plant management. Tutsan is listed in the GWRC RPMP as a NPPA species, meaning that staff inspect nurseries for the sale of this species and control it in high biodiversity sites as required. It currently has a very limited distribution in the Wellington region. Any reduction in the reproductive abilities of tutsan will slow its ability to spread into our region. As with all biocontrol, following the release there will be no control over the moth and beetle, meaning that the testing and management needs to be thorough prior to the release. GWRC 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 diligence will be followed in the assessment of risk by these agencies. As with any introduction, once the organism is successfully introduced, there is little or no ability to control or manage the organism in its wild state. GWRC is a contributor to and participant in the National Biological Control Collective (NBCC), and supports the establishment of biocontrol species. A successful biocontrol agent for tutsan would ease the reliance on manual removal of the plant and herbicides. Through the NBCC GWRC 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. The successful establishment of these biocontrol agents for tutsan would help to ease the reliance on herbicides for control of this highly invasive species.

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)

September 2012 EPA0190 3

Submission Form

I wish for the EPA to make the following decision: Greater Wellington Regional Council (GWRC) supports the proposal to introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents to assist with the management of tutsan (Hypericum androsaemum). An effective biocontrol agent for tutsan will help to slow the spread and impact of this highly invasive species. Establishment of these species as biocontrol agents will greatly assist with the long-term, national management of tutsan.

September 2012 EPA0190 SUBMISSION 111595

SUBMISSION 111596

13 January 2016

Sarah Fish Application Lead Environmental Protection Authority

By email to: [email protected]

Dear Sarah,

RE: Beef + Lamb New Zealand submission in support of Application APP202663 to introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan Hypericum androsaemum

Beef + Lamb New Zealand (B+LNZ) is the farmer-owned organisation representing New Zealand’s 12,300 commercial sheep and beef farming businesses. We are funded under the Commodities Levies Act 1990 through a levy paid by producers on all cattle and sheep commercially slaughtered in New Zealand. Our purpose is to help sheep and beef farmers make informed business decisions and promote their collective interests. The value of the New Zealand red meat sector is around NZ$8.5 billion (for 2013-2014) and is New Zealand’s second largest export earner.

As described in the application and supporting documents, tutsan (Hypericum androsaemum) is a serious pasture pest and invasive environmental weed with significant and growing impacts on farm production and the environment. In recognition of this, B+LNZ has supported the applicant (Tutsan Action Group) in its endeavours to reduce or eliminate the damage tutsan causes, predominantly on hill country farms.

B+LNZ has reached the understanding that the potential benefits of biocontrol by releasing these insect pests of tutsan are considerable and that the risks are negligible. Accordingly, we believe the case in favour of the Panel approving Application APP202663 is compelling and is supported by B+LNZ on behalf of the sheep and beef farming sector.

Please do not hesitate to contact me should you have any questions concerning this submission. We look forward to learning the Panel’s decision in due course.

Yours sincerely,

Chris Houston BSC MSc DLSHTM PhD Manager – Technical Policy Beef + Lamb New Zealand

beef + lamb new zealand ltd level 4, wellington chambers, 154 featherston street, wellington 6011, new zealand po box 121, wellington 6140, new zealand freephone 0800 beeflamb (0800 233 352) email [email protected] website www.beeflambnz.com

SUBMISSION 111597

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 APP202663 number: Name of submitter or contact for Warren Furner joint submission: Organisation name Ruapehu District Council (if on behalf of an organisation): Postal address: Private bag 1001 Taumarunui 3946

Telephone number: 07 8958188

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.

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Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: The Ruapehu District Council has been supportive of the work of the Tutsan Action Group since its inception and has committed financial resourcing for the TAG to progress its research and to provide technical and scientic advice to Council.

The District Council has limited resources and is burdened by a significant rural road reserve land holding. much of which is unformed and non maintained and presents a significant plant pest risk. Tutson is one such plant pest risk where sustained plant pest control programmes are beyond the means of our community to fund..

Therefore, our Council has welcomed the support of the group and has been able to make small but meaningful progress with its contractors when undertaking limited plant pest management programmes and vegetation control measures along is rural road network.

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: To approve the application with appropriate conditions in place to ensure risk to our environment is minimised.

September 2012 EPA0190 SUBMISSION 111598

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 number: Name of submitter or contact for Lyn Neeson joint submission: Organisation name Ruapehu Federated Farmers (if on behalf of an organisation): Postal address: 1651 Tokirima road Taumarunui

Telephone number: 07893857

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.

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Submission Form

I support the application

I oppose the application

I neither support or oppose the application

The reasons for making my submission are1: As President of Ruapehu Federated farmers and a local farmer, I have been involved in this application and successful search for a biological control for the invasive weed that is Tutsan. Most of my members (169 farmers, 75% of the farmers in Ruapehu) have contributed in kind and with financial support to this application. Tutsan is an invasive weed that is spread by birds, machinery (paticularly road side mowers), and rivers. It grows under shade and in pasture. If it gets established it is extremely hard to get rid of. I personally have spent many hours and dollars spraying it, using back pack and gorse gun trying to keep it off my hills. I am still going back to the first place I saw it grow and flower (on a road side in the mowers' path) in 2005 and finding small plants. Some of my members pay up to $30,000.00 annually to try and manage it and the average cost (after consultation with my members) is $15000.00 It requires an expensive chemical to actually kill it, which also can damage native fauna. The most effective method is by helicopter and it is now more of a problem on some farms than gorse. It is rampant underneath plantation forests, where it can not be sprayed. A biological management tool would be much more efficient and with much less impact on surrounding plants. The fact that it first establishes itself in very difficult to access areas means that it is difficult to eradicate, or even manage. I farm beside the Ohura and Whanganui rivers. I have tried to spray it from the river and by climbing down the banks. It is well established on the banks of both rivers and only a biological control will have any real impact.

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: Ruapehu Federated Farmers stongly supports this application

September 2012 EPA0190 SUBMISSION 111599

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 APP202663 number: Name of submitter or contact for Cushla Chubb joint submission: Organisation name (if on behalf of an organisation): Postal address:

Telephone number:

Email:

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: In our district of Oparau we have seen an astounding increase and spread of Tutsan. Tutsan is very prevalent on our roadside and this has highlighted a number of issues for our local District Council. The roadside mowing and spraying program is now under review due to my husband and I voicing our concerns - in particular mowing Tutsan in seed state. With our farming business we also have an astounding increase of Tutsan along our river banks. With the spraying regulations outined by our Regional Council, the control of Tutsan along the river banks is "delicate." Within the past 18 months Tutsan is now growing in areas of manuka and blackberry on our farm. This is having a huge impact on our business as we farm with the policy of minimal use of chemicals for both land and animals, however we have had to adjust our policy due to the increase of Tutsan. Our spraying costs are now increasing annually and our focus is more on the Tutsan which in turn means the gorse and blackberry are not being addressed as much as we would should. The increase use of chemicals is a serious concern for me personally as I am allergic/sensitive to chemicals. We are aware that spraying Tutsan is only controlling this weed and unfortunately no eradicating Tutsan. We have definitely seen a marked increase of Tutsan throughout many parts of the North Island where previously no Tutsan was growing.

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: I request that the EPA approve the release of the beetle - Chrysolina abchasica and the moth - Lathronympha strigana in New Zealand

September 2012 EPA0190 SUBMISSION 111600

He tono nā

ki te ENVIRONMENTAL PROTECTION AUTHORITY

e pā ana ki te SUBMISSION ON APP202663 – Application to import and release the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan (Hypericum androsaemum).

February 2016

Contents

1. EXECUTIVE SUMMARY

2. ABOUT TE RŪNANGA O NGĀI TAHU

3. TE RŪNANGA STATEMENTS OF POSITION

4. RECOMMENDATIONS ON APP202663

Author–Gerry Te Kapa Coates Ngāi Tahu HSNO Komiti

Sponsor – Kara Edwards General Manager – Te Ao Tūroa | Te Kaihautū o Te Ihu Waka I Te Rūnanga o Ngāi Tahu [email protected] I Phone 03 366 4344 I PO Box 13-046 I Christchurch

Support – conditional request to be heard Te Rūnanga o Ngāi Tahu may wish to appear to speak to this response if a hearing is requested by other submitters.

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1. EXECUTIVE SUMMARY

Te Rūnanga o Ngāi Tahu holds long-standing concerns over the introduction of new biocontrols unless the risks are properly assessed, as opposed to any perceived benefits. Whilst the benefits supporting the introduction of new biocontrol agents are often self-evident they must be clearly and explicitly spelt out, as well as being persuasive. At the same time, the risks must be fully documented and measures to mitigate their impact fully argued. The application is succinct about the benefits and categorises risks as “unlikely”. Tutsan is prevalent in some parts of the Ngāi Tahu takiwā, although the North Island is the principal site of main concern. However we are pleased that the Applicant has recommended using a monitoring programme of the effectiveness of the biocontrol introduction.

Our submission generally supports the Application subject to some concerns mentioned later. We do not necessarily wish to be heard in support of our submission, particularly if we are the only submitter. However although we support the kaupapa, there are some points we have made in our submission that we consider may be worth making in person at a Hearing, should a decision be made for a hearing be held. In that case we reserve the right to request to be heard.

2. TE RŪNANGA O NGĀI TAHU

2.1 This response is made on behalf of Te Rūnanga o Ngāi Tahu (Te Rūnanga). Te Rūnanga is statutorily recognised as the representative tribal body of Ngāi Tahu Whānui and was established as a body corporate on 24th April 1996 under section 6 of Te Rūnanga o Ngāi Tahu Act 1996 (the Act). We note the following relevant provisions of our constitutional documents:

a. Section 3 of the Act States: This Act binds the Crown and every person (including any body politic or corporate) whose rights are affected by any provisions of this Act.

b. Section 15(1) of the Act states: Te Rūnanga o Ngāi Tahu shall be recognised for all purposes as the representative of Ngāi Tahu Whānui.

c. The Charter of Te Rūnanga o Ngāi Tahu (1993, as amended) constitutes Te Rūnanga as the kaitiaki of the tribal interest.

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2.2 Ngāi Tahu is the third largest Māori iwi in Aotearoa with a membership of over 54,000 who whakapapa to an ancestor in the 1848 census of tūpuna. Its takiwā (area of influence) extends from Kaikoura in the north, to Rakiura (Stewart Island) in the south, including the West Coast, TeTai Poutini. This comprises over 90% of the South Island or over 40% of the NZ land mass. Te Rūnanga o Ngāi Tahu is statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of Te Rūnanga o Ngāi Tahu Act 1996. This means it exercises kaitiakitanga over this takiwā.

2.3 Te Rūnanga o Ngāi Tahu constitutes 18 Rūnanga representing geographical areas, generally based around traditional settlements.

2.4 Ngāi Tahu Values which dictate its approach to all issues are as follows:

a. Whanaungatanga (family) Respect, foster and maintain important relationships within the organisation, within the iwi and within the community. b. Manaakitanga (looking after our people) Respect each other, iwi members and all others in accordance with our tikanga (customs). c. Tohungatanga (expertise) Pursue knowledge and ideas that will strengthen and grow Ngāi Tahu and our community. d. Kaitiakitanga (stewardship) Work actively to protect the people, environment, knowledge, culture, language and resources important to Ngāi Tahu for future generations. e. Tikanga (appropriate action) Strive to ensure that Ngāi Tahu tikanga of is actioned and acknowledged in all of our outcomes. f. Rangatiratanga (leadership) Strive to maintain a high degree of personal integrity and ethical behaviour in all actions and decisions we undertake.

2.5 Te Rūnanga respectfully requests that this response is accorded the status and weight due to the mana whenua status of the tribal collective, Ngāi Tahu Whānui.

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3. TE RŪNANGA STATEMENTS OF POSITION ON APP202663

3.1 General position on biological control 3.1.1 Over the years, Te Rūnanga o Ngāi Tahu (TRoNT) has consistently advocated for methods of pest and weed control that have the least negative impacts on the environment. We are thus generally supportive of any proposal which may decrease the burden of pesticide residues or their breakdown products on the biotic and abiotic environments, and look favourably on more benign options including biological controls, provided the risks of their introduction are negligible. 3.1.2 A key consideration regarding the introduction of a new exotic organism to control an already present exotic pest/weed, as is proposed in this application, is the risk posed by the new introduction. TRoNT has in the past supported the introduction of biological control agents for the weed tradescantia, Japanese Honeysuckle and wooly nightshade, where the biological control agents posed insignificant risk. We note that tutsan is regarded as more invasive than either tradescantia or Chinese privet, and slightly less invasive than gorse or pampas. However TRoNT also strongly opposed the introduction of a new insect for the control of tomato white fly in greenhouses on the grounds of the risk of it establishing externally. We also note that in the case of both the proposed biocontrol insects once they are introduced there is no prospect of reversing that decision. Hence the decision must take into account all risk factors. 3.1.2 Generally speaking, TRoNT encourages the development of a ‘soft’ approach to pest and weed management, although we recognise that sometimes – for example possums and stoats – such an approach is not yet feasible. 3.2 Māori Reference Group 3.2.1 A Māori Reference Group (MRG) was formed in 2014 specifically to consider such biocontrol applications. Dr Oliver Sutherland from the Ngāi Tahu HSNO Committee was appointed as a member of the group (in place of the writer of this submission who was unable to attend the first meeting), 3.2.2 The aims of biological control – which were fully supported by the MRG and by Ngāi Tahu – are to reduce risk and reverse harm from damaging organisms, as one of the tools for pest management. The MRG developed some core principles which have also been referred to in the Application. Our summary of them is as follows:

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MRG PRINCIPLES:

a) Kaitiakitanga

There is a well-recognised kaitiakitanga responsibility for Māori to manage the natural resources within and beyond their hapū and iwi boundaries for the benefit of future generations.

b) Manaakitanga

Biocontrol agents pose the potential to both positively impact by aiding in the restoration of balance, and negatively impact by disturbing it further. Good decision-making is thus crucial. If appropriate, regional councils and the Department of Conservation should work with iwi and hapū in their areas on pest management strategies that include monitoring impacts in terms of manaakitanga.

c) Broad biophysical considerations

Māori will be concerned to know the anticipated and unanticipated potential impact of the introduction of biocontrol agents across the breadth of trophic and ecosystem levels.

d) Specific impacts on culturally valued species

The reference group recognised that standard host range testing and taxonomical analysis provides data that gives some assurance that any direct adverse effect from the non-target feeding and hybridisation of native species is likely to be minimal.

However the research methodology and results do little to address indirect impacts to culturally valued species. In particular, the MRG noted examples of pest weed species that now fill potentially beneficial niches for native species arising from the decline or displacement of native habitats.

It is thus important to continue to monitor potential effects (adverse and otherwise) of biocontrol species on a range of closely related native species. We note that this is briefly addressed in this the application.

Selected recommendations

• Applicants should map the existence and extent of each pest weed species in applications so that Māori are able to consider impacts at their specific rohe level. This has been done in this Application at the macro level.

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• Applicants should provide comment on or model the potentially broader trophic impacts of introducing a biological control agent. • Applicants should provide information about the potential beneficial role a pest weed species may have for local populations of native species. This has been done in this Application in general terms. • Applicants should provide comment on any relevant native habitat restoration plans that would manage the depletion or removal of weed species providing beneficial effects to native species. This was not specifically commented on. • Applicants should ensure recognition and assessment of impacts (both positive and negative) against appropriate national and regional Treaty principles and provisions.

3.3 Tutsan as a weed

3.3.1 The seriousness of the presence of tutsan (Hypericum androsaemum), particularly on agricultural and conservation land is argued persuasively in the application.

3.3.2 Tutsan Action Group (TAG), which was formed in 2007 as a collaboration between Horizons Regional Council (HRC), the Department of Conservation (DOC) and farmers concerned about the increasing spread of tutsan in the Ruapehu area now has over 100 contributing farmer members, including Māori farmers. As farming is a part of Ngāi Tahu’s commercial activities we would naturally support any tool that improves its outcomes.

3.4 Assessment of risks costs and benefits 3.4.1 The proposal is to introduce Lathronympha strigana (from Europe) and Chrysolina abchasica (from Georgia in the Caucasus) as biocontrol insects. 3.4.2 The risk to non-target native species is claimed to be low. Tests conducted by Landcare on four native Hypericum species recognised in New Zealand (Heenan 2008) indicated they were safe from significant damage. We note the Application says that “significant adverse effects on valued native plants are highly unlikely.” Some indication of quantum of risk even here would be useful. 3.4.3 Pre-application consultation with Māori relating to these biocontrols predictably received little response. However the Māori Reference Group principles listed earlier have addressed potential concerns to some extent. 3.4.4 The need for post-release monitoring and measurement of the impact of the effects on both tutsan and susceptible native plants of the same or similar genus to Hypericum

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androsaemum. The commitment of the TAG collective to the evaluation of target and non- target effects of the biological control agents when this is appropriate is welcome. 3.4.5 On the question about “the ease with which the new organism could be recovered or eradicated” it is noted by the Applicant that “once established eradication of either species would prove technically difficult” and that “it is likely that a population would be judged undesirable only once the population density grew, too late for eradication to be feasible.” It is thus important for the EPA’s Decision-Making Committee to make a wise and sensible decision based on the risk assessments.

4. CONCLUSIONS

4.1 We aware that Landcare Research and Richard Hill are very experienced in research in this area and have previously engaged in consultations with Ngāi Tahu. 4.2 We believe that this Application has sought to remedy the perceived lacks of past applications to a major extent, although there is still an area of risk that is unquantified. 4.3 Ngāi Tahu supports the Application since it appears that our major concerns of monitoring of the outcomes of the long term effects of the successful introduction of these two insects will be carried out. 4.4 We reserve our right to be heard, but only if a hearing is convened for other submitters.

5. RECOMMENDATION

Te Rūnanga o Ngāi Tahu supports the Applicant’s proposal to introduce Lathronympha strigana (from Europe) and Chrysolina abchasica (from Georgia in the Caucasus) as biocontrol insects.

Gerry Te Kapa Coates MNZM Member, Ngā Tahu HSNO Committee

Email: [email protected] Mobile: 021 355099

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SUBMISSION 111601

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 APP202633 number: Name of submitter or contact for J J Dymock, D S McKenzie joint submission: Organisation name Northland Regional Council (if on behalf of an organisation): Postal address: Private Bag 9021 Whangarei Mail Centre Whangarei 0148

Telephone number: (09)4701200

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 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: A survey of tutsan populations in Northland in December 2015 and January 2016 by the NRC has shown that tutsan is widespread on roadsides in the higher rainfall areas of Northland but does not invade pasture, with the exception of a severe infestation of improved pasture in South Hokianga (similar to those described for the Central North Island/King Country). 1) NRC supports the application to release the moth, Lathronympha strigana , as a biocontrol agent of tutsan as endemic and native Hypericum species did not support development of the moth in host specificity tests. Tutsan vs Lathronympha strigana (H. minutiflorum – endemic - Not tested) Mean no. eggs laid Mean no.eggs laid % larval survival from choice test - no choice -choice with tutsan tutsan 97.4 H. involutum (native) 0.4 1.8 0 H. pusillum (native) 3.2 0.6 0 H. rubicundulum (endemic) 2.2 0 -

2) NRC has reservations about the introduction of the beetle, Chrysolina abchasica, for biocontrol of tutsan for the following reasons. a) eggs were laid by Chrysolina abchasica and 12% of eggs completed development on the endemic H. rubicundulatum used as a surrogate in host specificity tests for the “critically endangered” H. minutiflorum, which was not tested. 4% of larvae (one larva only) shifted to H.rubicundulatum completed development. Table below is compiled from host specificity report by Landcare Research Chrysolina abchasica vs native and endemic Hypericum species.(Endemic H. minutiflorum not tested) Mean no. eggs laid % of eggs laid that Starvation test (larvae shifted to test plant to (choice with tutsan) completed development complete development tutsan 15.7 82% 76% H. pusillum (native) 3.4 9% 4% (one larva) H.rubicundulum (endemic) 2.7 12% 4% H. involutum (native) 0 Larvae died b) Data on the phenology and population density of the endemic H. minutiflorum, listed by DoC in 2012 as “threatened, nationally critical” is deficient. Newly described in 2008, H. minutiflorum is currently known from the central North Island Volcanic Plateau, and may be naturally uncommon. We recommend that a study on population phenology of the endemic H. multiflorum and H. rubicundulum be undertaken. Such a study would determine the degree of overlap in time and space (if any) of the endemic Hypericum species with the target tutsan as potential hosts for C. abchasica. c) Self-sustaining populations of Chrysolina (hyperici and quadrigemina ) on non-target, native Hypericum involutum have been documented in Central Otago. Two adults were seen, the occasional egg and some first instar larvae feeding on leaves

September 2012 EPA0190 3

Submission Form

(Ronny Groenteman pers.com.). Populations of St John’s Wort are now very low throughout New Zealand due to herbivory by the two Chrysolina beetle species (successful biocontrol) so the fact that populations of Chrysolina spp. can be sustained on an alternative, low density, non-target host is significant. We are not comfortable with the level of risk to endemic and native Hypericum species indicated by the results of the host specificity tests undertaken to date.

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: Approve the release the moth, Lathronympha strigana , as a biocontrol agent of tutsan That host specificity tests be undertaken to determine whether the endemic Hypericum minutiflorum is a host for the beetle, Chrysolina abchasica, and undertake more detailed host specificity testing on the other native and endemic Hypericum spp. to confirm the level of non-target host utilisation by C. abchasica..

September 2012 EPA0190 SUBMISSION 111602

Your Ref: Our Ref: A2282117

10 February 2016

Environmental Protection Authority [email protected]

Dear Sir/Madam

Bay of Plenty Regional Council’s submission to the Tutsan Biological Control Agent (APP202663)

I write in response to your email dated Tuesday, 1 December 2015.

Thank you for the opportunity to comment on the application to introduce a moth (Lathronympha strigana) and a leaf beetle (Chrysolina abchasica) as biological control agents for the weed tutsan (Hypericum androsaemum.

The Bay of Plenty Regional Council does not wish to be heard on this submission.

For matters relating to this submission, please contact Kataraina Belshaw at [email protected] or 0800 884 881 ext. 9323.

Our Organisation

The Bay of Plenty Regional Council is responsible for the sustainable management of resources within the Bay of Plenty region. Our role is determined by Central Government through statutes such as the Local Government Act and the Resource Management Act, and is different from that of territorial authorities (district and city councils). Some of our key roles are:

• Regional planning for land, water quality and air quality; • Setting environmental management policies for the region; • Allocation of natural resources; • Flood control; • Natural hazard response; • Soil conservation; • Pest control / biosecurity; • Public transport; • Strategic transport planning; • Regional economic development; and • Strategic integration of land use and infrastructure.

Summary

We support the general intent of this application. Please find our detailed comments in the table attached. We trust you find them constructive.

Yours sincerely,

Fiona McTavish General Manager Strategy

BOPRC ID: A2282117 Bay of Plenty Regional Council’s submission to the Tutsan Biological Control Agent (APP202663) BAY OF PLENTY REGIONAL COUNCIL’S SUBMISSION TO THE TUTSAN BIOLOGICAL CONTROL AGENT (APP202663)

Reference Position Recommendation APP 202663 Bay of Plenty Regional Council are required, under the Biosecurity Act 1993, Approve the application to release the to provide regional leadership on Biosecurity related issues. biocontrol agents Lathronympha strigana While not listed under the current Regional Pest Management Plan for the and Chrysolina abchasica to control Bay of Plenty 2011-2016, tutsan has been identified as an increasing Tutsan (Hypericum androsaemum) biosecurity issue in the region. Its distribution and density continues to increase to the point where it is fairly common around the region and in sites, dominates the landscape. Tutsan is easily spread via human activity including mowing as well as via birds and possibly possums. It is a significant agricultural pest in parts of New Zealand and invades regenerating sites forming dense stands. Tutsan is known to invade and dominate pastural land, it is unpalatable, and potentially poisonous to stock and reduces pastoral productivity. It is notoriously difficult to control, few herbicides are effective and the timing of application has a significant bearing on success. Landowners in the region are currently having to invest significant time and effort to control tutsan and often with varied results at certain sites. It is also becoming increasingly common along roadsides were it is being spread via management activities. Logistically these sites are difficult to manage, especially if conscious of the spread of tutsan seed. Having another form of control is important to prevent the continued spread and impact of this invasive species. Bay of Plenty Regional Council is a member of the National Biocontrol Collective (NBC). The NBC fund research into biocontrol agents for problematic species. As a member we work closely with Landcare Research and understand the biocontrol programme and the rigour involved in the testing of agents. BOPRC feel the benefits of approving both agents are potentially significant and the risks are near negligable. We feel the testing involved in ensuring the agents pose no risk to desirable species is rigorous. We feel these agents are very important to add to the potential management options for tutsan where few other effective methods exist. We feel without these agents, landowners in the Bay of Plenty region could be at risk of requiring to invest significantly in the control of tutsan to ensure their land is productive.

BOPRC ID: A2282117 SUBMISSION 111603 SUBMISSION

To: Environmental Protection Authority

Submission on: Application APP202663

Date: 10 February 2016

Contact: Philippa Rawlinson

Policy Advisor

Federated Farmers of New Zealand

m: 021 512 971 p: (03) 357 9457

e: [email protected]

Federated Farmers wishes to be heard in this matter

1 SUBMISSION TO THE ENVIRONMENTAL PROTECTION AUTHORITY ON APP 202663

1. FEDERATED FARMERS SUBMISSION

1.1. Federated Farmers welcomes the opportunity to make this submission to the Environmental Protection Authority (EPA) on APP202663, to introduce the moth Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan Hypericum androsaemum.

1.2. Tutsan was first introduced as an ornamental garden plant, but has evolved into serious agricultural and environmental weed throughout the central North Island and has the potential to spread throughout New Zealand. Tutsan is a serious weed pest which has invaded valuable pastures, plantation forestry and Department of Conservation land.

1.3. Existing methods for controlling Tutsan are ineffective, inadequate and uneconomic, and are now unable to stop the spread of the invasive weed. The introduction of biological control methods is therefore seen as a cost-effective and environmentally friendly way of controlling Tutsan.

1.4. After consultation with its membership Federated Farmers supports the application to introduce the moth Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan Hypericum androsaemum.

2. TUTSAN

2.1. Tutsan is a serious agricultural and environment weed that has spread throughout the central North Island onto valuable pasture, plantation forestry and Department of Conservation land, after being introduced as an ornamental garden plant.

2.2. Tutsan tolerates a wide range of soil types and temperatures and can form a dense cover that smothers existing plants and inhibits the growth of other plants and/or pasture. Tutsan has adapted to grow in full shade, which means it is uncontrollable in forests until harvest, by which time it has run rampant.

2.3. The spread of Tutsan is further exacerbated because the weed produces hundreds of thousands of seeds which are dispersed by birds and remain viable in the ground for many years.

2.4. Estimates have the cost of controlling Tutsan varying between $10,000 and $30,000 per annum per farm in the Central North Island. These costs vary depending on farm location and how close to a river or forest the farm is. One farmer has spent $100,000 trying to get pasture back from Tutsan infestation. These figures do not include the loss of productive capability of land infested with Tutsan and will vary according to farm type and typography.

3. EXISTING TUTSAN CONTROL METHODS

2 3.1. The responsibility for controlling Tutsan falls on farmers as landowners and the preferred methods of control vary. Individual Tutsan plants can be controlled by pulling them out as they emerge, but for larger infestations chemical control is the only option.

3.2. Aerial spray application on hill country or on inaccessible locations can be financially unviable and some regional plans restrict the use of anything but spot spraying to protect beneficial or native plants from accidental spraying.

3.3. Methods of chemical control of Tutsan are financially unsustainable, are not effective and can have adverse effects on non-target plants or insects. The one chemical that is registered for use on Tutsan has a poor effect on clover as it can take up to 15 months to recover.

3.4. Further, if a complete kill is not successful using chemicals, Tutsan can re-sprout and the cost of chemical application effectively becomes a waste. Sometimes multiple chemical applications are required as one spray does not kill. Persistence is required.

3.5. Physically pulling or spot spraying Tutsan on hilly country, on difficult or inaccessible locations, also poses a number of health and safety risks for farmers.

4. BIOLOGICAL CONTROL OPTIONS FOR TUTSAN

4.1. Biological control is the process where one organism is used to control another. The beauty of the system is that once established, pest control on the target organism continues as long as the population of the control agent is maintained.

4.2. The applicants intend to introduce the moth Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan. The beetles will work to remove Tutsan foliage, which will reduce the shading effect on desirable plant species and limit the production of seeds which are dispersed by birds aiding the spread of the weed.

4.3. Biological control of invasive weeds is a beneficial option for farmers because it does not add to, and can reduce the burden of any chemical applications. Further it can reduce the impact of chemical application on beneficial pollinators, insects and other non-target plants.

4.4. Federated Farmers supports the introduction of the moth Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan, because existing methods of chemical and manually pulling weeds out are proving to be ineffective, inadequate and uneconomic.

4.5. Federated Farmers do wish to convey that any new biological agent needs to be managed in such a way that resistance does not become a problem, nor does the population become unmanageable. We urge caution with interaction between other species. We support the work and research Landcare Research plan to undertake to ensure this does not occur.

5. CONCLUSION

3 5.1. Federated Farmers welcomes the application to introduce the moth Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan Hypericum androsaemum.

5.2. Existing methods used to control Tutsan are proving to be ineffective, inadequate and uneconomic and now unable to stop the spread of the increasingly invasive agricultural and environmental weed. It is also imperative that farmers have another tool in the toolbox for controlling Tutsan when existing methods of control are proving less than successful.

5.3. Federated Farmers supports the application to Lathronympha strigana and the leaf-feeding beetle Chrysolina abchasica as biological control agents for the weed Tutsan Hypericum androsaemum, provided they are managed in such a way that resistance and over population does not become a problem.

6. FEDERATED FARMERS

6.1. Federated Farmers of New Zealand is a primary sector organisation that represents farmers, beekeepers and other rural businesses. Federated Farmers has a long and proud history of representing the needs and interests of New Zealand farmers.

6.2. The Federation aims to add value to its members’ businesses. Our key strategic outcomes include the need for New Zealand to provide an economic and social environment within which:

6.2.1. Our members may operate their businesses in a fair and flexible commercial environment;

6.2.2. Our members families and their staff have access to services essential to the needs of the rural community; and

6.2.3. Our members adopt responsible management and environmental practices.

4 SUBMISSION 111604

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 APP202663 Tutsan number: Name of submitter or contact for David Havell joint submission: Organisation name Department of Conservation (if on behalf of an organisation): Postal address: Private Bag 68908 Newton Auckland 1145

Telephone number: 09 307 4865;

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 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:

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: To approve the application to introduction and release of Lathronympha strigana. To decline the application to introduce and release Chrysolinia abchasica.

September 2012 EPA0190 Submission on Application APP202663 to approve Release of Lathronympha strigana and Chrysolinia abchasica for the biocontrol of Tutsan (Hypericum androsaemum)

Statutory Role of the Department of Conservation

The Department of Conservation (DOC) has a statutory role under various acts to protect and advocate for natural heritage which includes native species and ecosystems. Under this role the department carries out control of pest species and supports the development of additional management tools to reduce the impact of pest species and improve management outcomes.

In addition where the introduction and release of new organisms may have an adverse impact on natural heritage, the Department will make submissions on proposed release of new organisms and their potential adverse impacts on natural heritage.

DOC and the National Biocontrol Collective

The Department of Conservation is a member of the National Biocontrol Collective and provides funding support to the collective. The Biocontrol Collective works with Landcare Research to develop biocontrol agents for pests, of which the application to introduce biocontrol agents for tutsan is one. DOC also provides information on the impacts of plant pests and departmental weed programmes which may be used in applications to the EPA for the release of biocontrol agents. In general DOC supports the introduction of biocontrol agents where robust research shows the agents will not have an adverse impact on natural heritage and there are benefits for natural heritage from the release of a particular biocontrol agent.

Tutsan

Tutsan is regarded as more invasive and damaging to natural heritage than either tradescantia or Chinese privet, and slightly less damaging than gorse or pampas in DOC weed prioritising systems. Tutsan can form dense patches in forest understorey and can also form patches on stream banks and along forest edges and roads.

Tutsan is widely distributed on public conservation land, there are over 100 sites where tutsan is present including at least 30 high priority biodiversity-ecological sites where threatened species and ecosystems at risk from tutsan are present. Tutsan occurs in areas where native hypericums species are present. Tutsan is widely adapted to the New Zealand environment, occurring from Northland to Stewart Island.

DOC manages tutsan in at least 20 sites for both regional pest management strategies and protection of biodiversity values. Management varies from ongoing surveillance in old control sites, manual control, and control with herbicides such as glyphosate, triclopyr, picloram, aminopyralid, and metsulfuron, applied as sprays, basal sprays, gels and granules.

Successful control of tutsan is limited by:

 ongoing persistence of tutsan patches for over 10 years despite intensive management,  widespread distribution of tutsan patches and long distance dispersal of seed from those patches for over 700 metres,  tutsan resistance to fungal biocontrol agents, and  that herbicide control methods kill other plant species besides tutsan .

James and Rahman further discuss limitations of current tutsan management methods, (https://www.nzpps.org/journal/68/nzpp_681240.pdf) .

Biocontrol agents

Tutsan biocontrol agents should improve tutsan management by extending control to more tutsan sites than currently managed, and should reduce the spread of tutsan by reducing seed production. Biocontrol agents should also reduce the competiveness of tutsan by reducing tutsan growth and opening up tutsan patches to invasion.

Lathronympha strigana

Lathronympha strigana is a common moth species in Europe. Larvae and adults have been recorded on St John’s wort, tutsan and other hypericum species. Landcare testing indicates that Lathronympha strigana has low risk to native hypericum species as while eggs were laid on native hypericum species, larvae did not survive or develop on native species. In Landcare Research trials Tutsan was the preferred host for egg laying over St John’s wort and more larvae developed to maturity. As St John’s Wort is a common host for Lathronympha strigana in Europe, the strain of Lathronympha collected from tutsan in Georgia would appear to better adapted to tutsan than other hypericum species.

Chrysolinia abchasica

Testing by Landcare Research indicates that female Chrysolinia abchasica will lay eggs on native hypericums and that larvae will reach maturity but not survive to produce offspring. Given that some Chrysolinia abchasica can survive to maturity on native hypericum by consuming hypericum plant material there is some risk to native hypericums. The risk is not that Chrysolinia abchasica will form self sustaining populations on native species but that chrysolinia will disperse from adjacent tutsan and St John’s wort and damage native hypericum by reducing their competiveness and ability to produce seed. This is most likely to occur in areas where tutsan and native hypericums occur together such as in the central North island and Rangitoto Island.

Most native hypericums are threatened in New Zealand; Hypericum minutiflorum is nationally critical, Hypericum involutum is declining, and Hypericum rubicundulum is nationally vulnerable. Hypericum pusillum which is not threatened, is not dominant in the plant communities in which it occurs. In comparison to tutsan, native hypericums are small herbs and may be susceptible to heavy grazing. Compared to the biocontrol agents introduced to control tradescantia and privet, the potential impact of Chrysolinia abchasica on native flora is much higher. Threatened species are related to the target species, though in a different section and with different plant traits, and the control agents will target native species, though not in preference to the target species. Chrysolinia species have been effective in reducing St John’s wort in New Zealand so it is possible that a biocontrol agent could have a serious impact on a native hypericum if the biocontrol agent is as well adapted to native hypericums as Chrysolinia abchasica is to tutsan. Landcare research has undertaken research to rank the threat of Chrysolinia species to non target hypericums. Chrysolinia abchasica ranks below Chrysolinia biocontrol agents already in New Zealand as a threat to native hypericums. In addition, the impact of current Chrysolina biocontrol agents on some native hypericum species was also evaluated and determined as insignificant. Thus it is possible that Chrysolinia abchasica will have low impact on native hypericums.

However, given that:

 not all native hypericums were used in feeding and other research, (H.minuitifolium and H Involutum were not included);  most native hypericums are threatened species;  in the second feeding trial over 20% of chrysolinia larve reached maturity on H. rubicundulum, and over 10% of larvae on H. pusillium;  there is no information on the effect of Chrysolinia abchasica on the growth and seed production or health of native hypericums; the Department does not support the release of Chrysolinia abchasica until the impact of Chrysolinia abchasica on the growth and seed production of native hypericums is confirmed as insignificant. We consider this approach is consistent with the precautionary section 7 of the HSNO Act 1996, which advocates caution in the face of scientific and technical uncertainty.

Native hypericums classified as nationally critical and nationally vulnerable are already at risk of extinction and we would not wish to increase the risk of extinction through addition pest burden from biocontrol agents such as Chrysolinia abchasica.

Conclusion

Tutsan is a significant threat to New Zealand natural heritage as well as the agricultural systems. The introduction of biocontrol agents will have benefits in reducing the impact of tutsan, if the effect of biocontrol agents is similar to the impact of biocontrol agents on St John’s wort. The Department supports the introduction and release of Lathronympha strigana given it is unlikely to have adverse impacts on native hypericum species and if successful will enhance current tutsan management. Chrysolinia abchasica is also likely to be a successful biocontrol agent, however we do not support its release until further research shows the species has insignificant impact on native hypericums and does not exacerbate the current threat status of native hypericum species.

SUBMISSION 111605

Email response to: [email protected]

Re: Application APP202663: To introduce the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan Hypericum Androsaemum

A note regarding application APP202663 from:

Dr John Liddle; Chief Executive Nursery and Garden Industry New Zealand (NGINZ)

NGINZ appreciates the opportunity to comment on this matter.

We do not wish to be heard as part of the submission process.

Ornamental Hypericum species are grown by nurseries and cut flower growers in New Zealand. The total value of the annual crop is estimated to be very low.

NGINZ recognises the benefits that can be provided where biological control agents for pest plants and supports initiatives where clear advantages can be demonstrated and impacts on the industry are negligible.

Having read and considered the Application documents prepared by the EPA and Landcare Research (Richard Hill and others) NGINZ does not anticipate any significant impacts on nursery production in New Zealand as a result of the proposed release of the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan Hypericum Androsaemum.

NGINZ does however have concern regarding potential localised spill-over effects on other less palatable native host species under high population densities of Chrysolina abchasica on its preferred host, tutsan Hypericum Androsaemum. While the tests indicate that fewer individuals survived to adult on two native species tested, the individuals did consume the native Hypericum species H. pusillum and H. rubicundulum.

The applicant notes the equivalent combined risk scores for host-range tests performed on the established lesser St John’s wort beetle Chrysolina hyperici and the greater St John’s wort beetle C. quadrigemina, were much higher than for C. abchasica. Landcare, however reports that experience has shown that the impacts on H. pusillum and H. involutum in New Zealand are considered “trivial”, and NGINZ leaves the Decision committee to consider the evidence carefully and determine if the levels of risk and the possibility of unforeseen impacts justifies the release of Chrysolina abchasica.