Decision

Date 7 January 2020

Application number APP203950

To import for release any new organism under section 34 of the Application type Hazardous Substances and New Organisms Act 1996

Applicant New Zealand Plant Producers Incorporated (NZPPI)

Date Application received 9 December 2019

Acting Chief Executive, Environmental Protection Authority Considered by (EPA)

To release the tropical houseplant Rhaphidophora tetrasperma, Purpose of the application otherwise known as Philodendron ‘Minima’ or Mini Monstera, without controls

The new organism approved Rhaphidophora tetrasperma Hook.f.

Summary of the decision

Application APP203950, to import for release Rhaphidophora tetrasperma is approved, without controls, having been considered in accordance with the relevant provisions of the Hazardous Substances and New Organisms (HSNO) Act 1996 (the Act) and the HSNO (Methodology) Order 1998 (the Methodology). 1 Application and consideration process Legislative criteria for application 1.1 The application was lodged pursuant to section 34(1)(a) of the Act. Unless otherwise stated, references to section numbers in this decision refer to sections of the Act. The decision was made in accordance with section 35, taking into account additional matters to be considered under section 36, and matters relevant to the purpose of the Act, as specified under Part 2 of the Act. 2

Decision APP203950 1.2 Consideration of the application followed the relevant provisions of the Methodology. Unless otherwise stated, references to clauses in this decision refer to clauses of the Methodology.

Receipt of application 1.3 Application APP203950 was formally received by the Environmental Protection Authority (EPA) for consideration on 9 December 2019.

Statutory criteria for pathway assessment – s35(1) 1.4 The decision to undertake a rapid assessment under section 35(1) of the Act has been delegated to the EPA’s Manager of New Organisms (MNO). The MNO has assessed the application against the statutory criteria in section 35(2) and 35(3) of the Act and concluded that it is reasonable to assume that it meets the criteria for a rapid assessment. Therefore, a rapid assessment under section 35 of the Act is appropriate.

Decision-maker 1.5 In accordance with section 35(2) and 35(3) of the Act, the EPA has delegated to me, the acting Chief Executive, the power to conduct a rapid assessment under section 35 of the Act.

Purpose of the application 1.6 The applicant, New Zealand Plant Producers Incorporated (NZPPI), applied to the EPA to import for release the tropical plant species, Rhaphidophora tetrasperma, for commercial purposes to diversify New Zealand’s indoor tropical plant market.

2 The organism 2.1 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.

2.2 Taxonomy of Rhaphidophora tetrasperma:

Clade: Monocots

Order: Alismatales

Family: Araceae Genus: Rhaphidophora

Species: tetrasperma Hook.f.

2.3 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 on disturbed, dry to wet tropical forests on sandstone and granite (Kew, 2019).

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Decision APP203950 2.4 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.

2.5 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).

Comments from DOC and MPI 2.6 In accordance with section 58(1)(a) of the Act, the Department of Conservation (DOC) and the Ministry for Primary Industries (MPI) were provided with the application and asked for comment.

2.7 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.

2.8 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 stated that the intention of using R. tetrasperma for indoor purposes should greatly reduce the likelihood of illegal dumping but not preclude it entirely.

2.9 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).

2.10 DOC stated that they do not oppose the release of R. tetrasperma.

2.11 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.

2.12 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.

2.13 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

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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Decision APP203950 R. tetrasperma particularly in relation to hardiness, temperature requirements and its ability to thrive outside its known natural distribution.

2.14 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.

2.15 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.

Information available for the consideration 2.16 The information available for my consideration comprised:  the application and references provided therein;  the EPA Staff Assessment Report;  comments received from DOC and MPI; and  a memorandum from the EPA to support decision-making. 3 Consideration Sequence of consideration 3.1 In accordance with clause 8 of the Methodology, the information provided from the sources listed in section 2.16 above was considered when reaching this decision, followed by the taxonomy/identification and the biological characteristics of the organism.

3.2 In accordance with section 35 (rapid assessment of risk for importation of new organisms) of the Act, potentially significant risks have been identified and assessed, with particular reference to the matters set out in sections 35 and 36 of the Act. The matters set out in Part 2 of the Act, were also considered. Any Part 2 matters requiring further discussion are detailed below.

Is R. tetrasperma an unwanted organism? 3.3 Rhaphidophora tetrasperma is not an unwanted organism as defined under the Biosecurity Act.

Ability to form self-sustaining populations and ease of eradication 3.4 In accordance with section 35(2)(b)(i) of the Act, the ability of the organism to establish a self- sustaining population, and the ease of eradication of such a population should it establish has been considered.

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Decision APP203950 3.5 I considered the possibility that should R. tetrasperma be approved for release without controls in New Zealand, it would permit any individual in New Zealand to import this species for private use or wholesale distribution for both indoor and outdoor settings.

3.6 The scientific literature on R. tetrasperma is scarce. No information was found to support R. tetrasperma being an invasive or pest species.

3.7 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.

3.8 The equatorial climate of Peninsular Malaysia and south Thailand, where R. tetrasperma is endemic, is comparable to United States Department of Agriculture (USDA) Hardiness Zone 13. New Zealand’s maximum Hardiness Zone rating is 11.

3.9 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.

3.10 As mentioned in para. 2.5, 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.

Impact on New Zealand environment 3.11 Only two species of Rhaphidophora are on MPI’s Plant Biosecurity Index: R. decursiva and R. laciniata and there is no evidence to suggest that they are invasive or causing any direct or indirect adverse effects in New Zealand’s natural environment.

3.12 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.

3.13 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. As discussed in para 3.8 and 3.9, 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. The potential for R. tetrasperma to cause adverse effects on the environment by causing deterioration of natural habitats is negligible.

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Decision APP203950 3.14 Given the assessment above on the adverse effects to the environment, I considered that the potential of R. tetrasperma to displace or reduce native or valued flora and fauna species is highly improbable.

Ability to be disease-causing 3.15 It is reasonable to assume that R. tetrasperma will not be disease-causing or be a parasite, or be a vector or reservoir for human, plant, or animal disease. There is no evidence to suggest that R. tetrasperma is disease-causing in its native tropical habitat. This species, similar to other Rhaphidophora species, is commercially cultivated for domestic use in indoor settings such as homes and private functions e.g. weddings. No toxicity to animals or humans has been reported.

3.16 Rhaphidophora tetrasperma is not known to cause or be a vector of any disease. Should APP203950 to release R. tetrasperma in New Zealand be approved, MPI will undertake comprehensive biological screening to ensure that any imported R. tetrasperma plants do not have any unwanted diseases or organisms. Therefore, I consider it is highly improbable that R. tetrasperma can cause disease, be parasitic or become a vector for animal or plant disease.

Ability to have adverse effects on human health and safety or the environment 3.17 Rhaphidophora tetrasperma is not considered to cause significant adverse effects on human health and safety. I conclude that the adverse effects on human health and safety from the release of R. tetrasperma are negligible

Adverse effects on Māori 3.18 The potential for the release of R. tetrasperma to result in adverse effects on Māori and their culture and traditions taken into account in accordance with sections 5(b), 6(d) and 8 of the Act.

3.19 Kaupapa Kura Taiao, which advises the EPA on Māori issues, stated that Māori may have concerns with the release of R. tetrasperma due to the uncertainty about the reproductive capacity of the plant and the potential impact of climate change that may assist the plant to establish and propagate in the environment.

3.20 Kaupapa Kura Taiao expressed concerns in relation to allowing the release of a species without any public notification nor engagement with Māori

3.21 Kaupapa Kura Taiao stated that R. tetrasperma may have a negative impact on papatūānuku (land and soils) and ngā otaota (plants). From a Māori perspective, a significant concern relates to the accidental importation of several thousand R. tetrasperma plants and sale of over 500 individual plants at retail stores without any form of public input. They are concerned that granting this approval may undermine confidence in the HSNO system and raise questions about the obligation importers have to accurately describe the products they are bringing in.

3.22 Kaupapa Kura Taiao stated that Māori would need to have confidence in the claims made in the application and believe that R. tetrasperma may have an adverse impact on papatūānuku (land

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Decision APP203950 and soils) and ngā otaota (plants) due to uncertainty over the ability of R. tetrasperma to establish and propagate in the future when climate change has a greater effect.

3.23 Kaupapa Kura Taiao concluded that APP203950 is unlikely to significantly affect the ability and capacity of Māori to maintain their economic, social and cultural wellbeing.

3.24 Kaupapa Kura Taiao also concluded that APP203950 may have an 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.

4 Evaluation against the Rapid Assessment Criteria Minimum standards - section 36 of the Act 4.1 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.

4.2 In respect of each element of section 36, 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. Rapid assessment of risk section 35(2) of the Act and Minimum Standards section 36 4.3 Under section 35(2) of the Act, the application may be approved without controls if the criteria set out in this sub-section are met. Each of these criteria is briefly considered below, drawing on material from the above sections on the identification and assessment of risks.

4.4 In accordance with section 35(2)(a) of the Act, R. tetrasperma is not an unwanted organism as defined under the Biosecurity Act. Additionally, R. tetrasperma does not appear on the Second Schedule of the Act, Prohibited New Organisms.

4.5 In respect of each criterion listed in section 35(2)(b), I consider that it is:

 highly improbable that, after release, R. tetrasperma could form self-sustaining populations anywhere in New Zealand, taking into account the ease of eradication.  highly improbable that R. tetrasperma could displace or reduce a valued species.  highly improbable that R. tetrasperma could cause deterioration of natural habitats.

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Decision APP203950

 highly improbable that R. tetrasperma will be disease-causing or be a parasite, or be a vector or reservoir for human, plant or animal disease.  highly improbable that R. tetrasperma will have any adverse effects on human health and safety or the environment. Rhaphidophora tetrasperma has been present in New Zealand since April-May 2019 when 10,000 cultures were unintentionally imported. In August 2019, over 500 young R. tetrasperma plants were sold at retail stores across New Zealand.

Overall evaluation of risks and adverse effects 4.6 The risks posed by the application are negligible, and the requirements of section 35 (criteria for rapid assessment) and section 36 (minimum standards) are met.

4.7 Further, I note that Kaupapa Kura Taiao has concluded that the cultural risk to Māori (in terms of sections 5(b) and 6(d) of the Act) from this application is uncertain because of the uncertainty about the reproductive capacity of the plant and the potential impact of climate change that may assist the plant to establish and propagate in the environment. In this regard, I note that based on the scientific evidence discussed above I have concluded that this risk is highly improbable

5 Decision 5.1 It is determined that:

 Pursuant to section 35(3)(a) of the Act, Rhaphidophora tetrasperma proposed to be imported is not an unwanted organism under the Biosecurity Act.

 The organism satisfies the criteria set out in section 35(2)(b) of the Act.

5.2 I approve the application to release Rhaphidophora tetrasperma under section 35(2) of the Act.

7 January 2020

Siobhan Quayle Date Acting Chief Executive Environmental Protection Authority

Organism Approval code

Rhaphidophora tetrasperma NOR100172

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Decision APP203950 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

January 2020