To import for release and/or release from containment any new organism under section 34 of the Hazardous Substances and New Organisms Act 1996

Transcription

1 DECISION Date 17 Application code Application type Applicant APP To import for release and/or release from containment any new organism under section 34 of the Hazardous Substances and New Organisms Act 1996 Horticulture New Zealand Inc. Date application received 27 January 2016 Date of Hearing 4 May 2016 Date of Consideration 11 May 2016 Considered by Purpose of the application The new organism approved A decision-making committee of the Environmental Protection Authority (the Committee) 1 : Dr Kerry Laing (Chair) Dr Deborah Read Dr Ngaire Philips Dr Max Suckling (special member) Dr Geoff Ridley (special member) To release from containment the psyllid parasitoid Tamarixia triozae into New Zealand to assist with the biological control of the tomato potato psyllid (Bactericera cockerelli) Tamarixia triozae Burks 1943 (Hymenoptera: Eulophidae) 1. Summary of decision 1.1 Application APP to import for release and/or release from containment Tamarixia triozae (Burks 1943) was lodged under section 34 of the Hazardous Substances and New Organisms (HSNO) Act 1996 (the Act). 1.2 The application was considered in accordance with the relevant provisions of the Act and of the HSNO (Methodology) Order 1998 (the Methodology). 1.3 The Committee has approved the application without controls in accordance with section 38(1)(a) of the Act. 1 The Committee referred to in this decision is the subcommittee that has made the decision on the applications under delegated authority in accordance with section 18A of the Act.

2 2 2. Application process Application receipt 2.1 The application was formally received for processing on 27 January Purpose of the application 2.2 The applicant, Horticulture New Zealand Inc., sought approval to release Tamarixia triozae as a biological control agent (BCA) for the tomato potato psyllid (TPP; Bactericera cockerelli). Public notification 2.3 Section 53(1)(b) of the Act requires that an application under section 34 of the Act must be publicly notified by the Environmental Protection Authority (EPA). 2.4 The application was publicly notified by placing a notice on the EPA website on 11 February In accordance with section 53(4) of the Act, letters or s were sent notifying the Minister for the Environment, the Ministry for Primary Industries (MPI), the Department of Conservation (DOC), and other government departments, crown entities, and local authorities who have expressed an interest in being notified about applications for non-genetically modified new organisms. Māori organisations, nongovernment organisations and stakeholders who have expressed an interest in being notified about applications for non-genetically modified new organisms were also directly notified. All these parties had an opportunity to comment on the application in accordance with section 58(1)(c) of the Act and clause 5 of the Methodology. 2.6 Section 59(1)(c) of the Act requires an application to be open for the receipt of submissions for 30 working days from the date of public notification. The submission period closed on 24 March Submissions from members of the public 2.7 The EPA received 35 submissions during the public notification period. 2.8 One late submission was received from Tāhuri Whenua Inc. Section 59(4) of the HSNO Act provides that EPA may extend a time period or waive a timeframe provided that no parties are unduly prejudiced. The EPA decided to accept that late submission, and waived the timeframe within which submissions must be received as it was found that no party was unduly prejudiced. 2.9 Thirty-two submitters were in support of the application. Two submitters, Tāhuri Whenua Inc. and Whatitiri Organics, neither supported nor opposed the application Two submitters, the Department of Conservation and the Ngāpuhi HSNO Komiti, opposed the application. The Ngāpuhi HSNO Komiti noted in their submission that the risks to Māori have not been fully investigated and requested that the application be withdrawn.

3 3 Comments from MPI and DOC 2.11 In accordance with section 58(1)(c) of the Act, the Ministry for Primary Industries (MPI) and the Department of Conservation (DOC) were advised of, and provided with the opportunity to comment on, the application MPI did not make any comments on the application DOC opposed the application because they considered that T. triozae does not meet the minimum standards in the HSNO Act (section 36). DOC were concerned that the host range testing did not adequately demonstrate that all native psyllids in the Triozidae family will not be susceptible to parasitism by T. triozae. DOC noted that there are 50 known endemic Triozidae species and they are concerned that T. triozae may establish in areas where some of these endemic psyllids live. DOC noted that endemic psyllid species are particularly significant for their biodiversity and scientific value, in addition to being unique globally as they only exist in New Zealand The Committee is satisfied that the submission from DOC have been considered in making this decision. Reports providing advice to the Committee 2.15 The EPA Staff Assessment Report was provided under section 58(1)(a) of the Act. It was published on the EPA website and the applicant and submitters were informed of its availability on 19 April Ngā Kaihautū Tikanga Taiao (NKTT) chose not to prepare a report on the application. Hearing 2.17 Section 60(c) of the Act requires that a hearing be held if a person who has made a submission stated in that submission that he or she wishes to be heard. Ten submitters requested the opportunity to speak to their submission at a hearing. Those submitters were Gerry Te Kapa Coates (Te Rūnanga o Ngāi Tahi), Ruepena and Esteta Kovati (Kovati-Tam Yam Gardeners), Lex Dillon (Under Glass Karaka Ltd and Under Glass Bombay Ltd), Violet Walker and Bryce Smith (Ngāpuhi), Tony Norton (Nortona Ltd), Simon Watson (New Zealand Hothouse Ltd), Stuart Attwood (Southern Paprika Ltd), Chris Green and Verity Forbes (DOC), Nick Roskruge (Tāhuri Whenua Inc.) and Ben Smith (Turners & Growers Global Ltd) Section 59(1)(d) of the Act requires that the hearing commence not more than 30 working days after the closing date for submissions. The hearing was held on 4 May 2016 at the Clifton Conference Centre, Majestic Centre, in Wellington Chris Green and Verity Forbes (DOC), Gerry Te Kapa Coates (Ngāi Tahu), Stuart Attwood (Southern Paprika), Lex Dillon (Under Glass), Tony Norton (Nortona), Nick Roskruge (Tāhuri Whenua) and Ben Smith (T & G Global) appeared at the hearing to speak to their individual submissions Ruepena and Esteta Kovati, Simon Watson, Violet Walker and Bryce Smith chose not to exercise their right to attend the hearing and speak to their submissions.

4 The applicant was represented by Stephen Ogden and Sally Anderson (Market Access Solutionz Ltd), Mike Chapman (Horticulture New Zealand), Chris Claridge and Stuart Wright (Potatoes New Zealand), Helen Barnes (Tomatoes New Zealand), John Seymour (Vegetables New Zealand) and Robin Nitschke (Tamarillo Growers Association). John Charles (Plant and Food Research) and Chris Nixon (New Zealand Institute of Economic Research) appeared as expert witnesses for the applicant. Information available for the consideration 2.22 The information available for the consideration comprised: the application the EPA Staff Assessment Report submissions comments received from DOC (Chris Green) information obtained during the hearing The Committee considered that it had sufficient information to assess the application although it recognised some areas of uncertainty. The Committee waived any requirements where the application may not have met legislative information requirements. Matters for consideration 2.24 The Committee considered the application in accordance with section 38 of the Act, taking into account the matters specified in sections 36 and 37, relevant matters in Part 2 of the Act, and the Methodology Each point is addressed in the following sections of this decision Specific points raised by submitters (either in their submission or during the hearing) are addressed where appropriate throughout this decision. 3. Summary of appearances and information discussed at the hearing Presentations from the applicant party at the hearing 3.1 Stephen Ogden introduced the application to the Committee and noted that the presentations from the applicant party, including the grower organisations and expert witnesses, would elaborate on the drivers of, and benefits to, the horticulture industry that supports the release of T. triozae to control TPP in New Zealand. Dr Ogden noted that TPP was first recorded in New Zealand in 2006 in tomato greenhouses in Auckland causing yellowing and curling of leaves, and related serious effects such as plant death. MPI has since found TPP to be distributed throughout the country. Dr Ogden noted the appearance of a disease called Zebra Chip that was first recorded in the USA in potato plants. This disease was linked with the appearance of TPP in crops but little was known about the causal agent. 3.2 Dr Ogden described the life cycle of TPP and noted that the psyllid can have up to five generations per year. The causal agent of Zebra Chip disease has since been identified to be the bacterium Candidatus Liberibacter solanacearum or Lso that is transmitted by the psyllid to a plant when it feeds from the phloem. Dr Ogden noted that the use of insecticides to control TPP in horticulture crops has led to an

5 5 interruption of integrated pest management (IPM) programmes, for example, potato growers in Canterbury did not need to use insecticides pre TPP but now had an extensive insecticide programme, and that growers would like to return to IPM to improve their management of TPP and other pests. 3.3 Dr Ogden outlined the investments that the horticulture industry have made towards improving TPP management and control, including research projects to identify the best insecticides to control TPP, potential biological control targets and development of IPM tools that incorporate insecticides with lower toxicity profiles and better spray application mechanisms. Dr Ogden noted that after 10 years of research, a single all-encompassing solution for TPP has not been identified and there was heavy reliance on insecticides, with associated risks. He noted further that T. triozae could be part of solution to combat TPP, which may include biological control options as well as crop management tools and new insecticides. The industry would like to use T. triozae as part of an IPM programme alongside existing beneficial organisms and new emerging more benign chemicals in crops and orchards. He further noted that the industry will be working with Plant and Food Research as part of a three-year research programme supported by the Ministry of Primary Industries through the Sustainable Farming Fund to monitor the dispersal of T. triozae at pre-identified release sites, contingent upon approval for release. 3.4 Mike Chapman of Horticulture New Zealand provided an overview of the size of the horticulture industry in New Zealand. Mr Chapman noted that the industry fully supports the use of a biocontrol agent to assist with the control of TPP and is committed to using sustainable solutions, which include IPM programmes, to manage pests. Mr Chapman highlighted the economic importance of the horticulture industry to New Zealand noting the value of domestic and export sales to be $2 billion and $5 billion from 5,500 commercial growers, respectively. 3.5 Chris Claridge, CEO Potatoes New Zealand, presented on the economic and business impacts of TPP on the potato industry in New Zealand. Mr Claridge noted that there are 170 commercial growers in New Zealand that employ approximately 2,500 people. He noted the current total value of the potato industry, which includes processors McCains, Talleys, Mr Chips, Bluebird and ETA, is $814 million. He noted that TPP was estimated to cost the industry about $25 million per annum according to a report published in The use of T. triozae as part of an IPM programme to supress TPP pressures in potato crops would represent significant costs savings to the industry. Mr Claridge presented information on the potato production area and noted that about one-third of potatoes are sold as fresh potatoes for table-top consumption and two-thirds are sold for processing for crisps and frozen fries. Potato exports for the processing market are valued at $110 million per annum along with $20 million for fresh potatoes. Mr Claridge noted that the presence of TPP and Lso (that cause the diseases psyllid yellows and Zebra Chip, respectively) interrupt the supply chain in that they impact the processing area where there are direct costs attributed to interruption of processes and intermittent failures in production. He further noted that there is a direct correlation between the industry s ability to grow its export market and the use of IPM programmes. 3.6 Stuart Wright, Chairman of Potatoes New Zealand, spoke from the potato seed growers perspective. Mr Wright noted that TPP and Zebra Chip have affected the industry in different ways. He further noted

6 6 that in 2006 he did not use any chemical sprays to control pest insects but in this year alone they have had to use seven sprays costing about $500 per ha to manage TPP. He explained the use of IPM programmes that incorporate softer chemicals in the early stages of the growing season when TPP levels are still low and broad-spectrum agrichemicals at the height of the season when TPP numbers are abundant. Tamarixia triozae will allow them to minimise the use of insecticides to only those that are compatible with IPM practice so that they can implement a programme that runs across the whole growing season. 3.7 Helen Barnes, Business Manager of Tomatoes NZ, presented an overview of the fresh tomato industry. Ms Barnes noted that the farm gate value of fresh tomato product is $100 million per year, which equates to $130 million to $150 million in retail value. The industry exports to Australia, Japan and the Pacific Rim. She noted that Australia and Japan have increased their compliance requirements, which include monitoring, for tomato exports in order to minimise the chances of TPP being introduced to those countries. Ms Barnes noted that Tomatoes NZ aims to double the value of the sector by 2020 and that sustainable pest control is critical to achieving that target. Tomato growers have low tolerance to TPP because of the presence of Lso which kills plants. Ms Barnes described current management strategies to control TPP which include inspection and removal of infected plants and spray applications. She noted that tomatoes are a 10-month crop plant which requires multiple management options over the growing season. She further noted that IPM programmes have been disrupted by the arrival of TPP and that the total cost of TPP to growers is estimated at $761,000 per year. The principal benefit of T. triozae to the greenhouse industry will be the release of the BCA outside greenhouses which, concomitantly, will reduce TPP pressures inside greenhouses. 3.8 Helen Barnes also presented an overview of the process tomato sector in New Zealand. TPP is costing this sector an estimated $378,500 annually on insecticide use alone. The process tomatoes sector note that the single biggest risk to the industry of no or limited access to sustainable pest control methods is the potential loss of the process sector market to Australia. 3.9 John Seymour, General Manager Vegetables New Zealand, reported on the impact TPP has had on the greenhouse capsicum industry. Mr Seymour noted that the commercial value of the capsicum sector is over $63 million, with $28 million specifically grown for export markets. The phase reduction of agrichemical use in greenhouse capsicum IPM programmes and the inability of the industry to use a range of BCAs is having a negative impact on the competitive position of export growers. Mr Seymour noted that lower capsicum yield volumes and poorer fruit quality from restricted IPM programmes have caused significant increases in costs per unit. He noted that globally there is increasing demand for biologically controlled environments in food production sectors. He presented examples from Holland, Korea and Mexico where the use of BCAs in capsicum IPM programmes has led to significant reductions in agrichemical use. This has given those countries a competitive advantage over other countries including New Zealand because they are seen to be producing environmentally safe food Robin Nitschke, New Zealand Tamarillo Growers Association, noted that in December 2008 a grower first informed the Tamarillo Growers Association of symptoms similar to Lso infection that were

7 7 observed in his orchard. The infection was confirmed to be due to Lso vectored by TPP. Mr Nitschke told the Committee that there were 200 tamarillo growers producing 900 tonnes valued at $4 million per year up to The size of the industry shrank to 22 growers producing approximately 200 tonnes valued at $1 million following the discovery of Lso in tamarillo trees. Mr Nitschke noted that the typical insecticides used in orchards were not having any effects on TPP. The industry resorted to using organophosphates which were not sustainable and only seen as a short term solution while research was being undertaken on new chemicals. They identified five out of 11 chemicals that showed promise to kill TPP and on the back of insecticide use developed an IPM programme, based on prevention, observation and intervention. Mr Nitschke noted that tamarillo trees are particularly susceptible to TPP infestation in that fewer TPP individuals on a tamarillo tree create more damage than a larger number of TPP on potato, tomato or capsicum plants. He noted that the chemicals that are used in the spray programme are three to four-times the cost before TPP arrived in tamarillo orchards. Mr Nitschke summarised the benefits that the introduction of T. triozae would have for tamarillo growers. They include reducing the pressures of TPP in orchards which will reduce the transmission of Lso to uninfected trees, reduce the number of calendar sprays, in addition to reducing the potential of resistance developing from repeated use of insecticides Dr Sally Anderson, Research Advisor at Market Access Solutionz, presented an overview and evaluation of submissions received. Dr Anderson noted that the common themes from the supporting submissions included reduced reliance on broad-spectrum insecticides, return to IPM programmes, and improved environmental and economic outcomes for grower businesses. She summarised some of the issues that were raised by submitters: adequacy of the host range testing, ecosystem effects, risks to Māori and to taonga species, and whether she believes benefits to Māori have been satisfactorily demonstrated. Dr Anderson summarised the opposing submissions and provided responses to the issues that were raised John Charles, Senior Scientist at Plant and Food Research, appeared as an expert witness for the applicant. Mr Charles provided a written statement outlining his expertise and a summary of insect host selection processes and experimental methodology as background information to the report on host range testing by Dr Robin Gardner-Gee (Plant and Food Research). The Chair of the Committee sought clarification from Mr Charles that this statement did not contain any new information and noted that it is appropriate for the statement to be taken into consideration as part of his expert presentation as it contains higher level information that is only supplementary to the information presented in the application Mr Charles stated that the selection of non-target species and methodology in Dr Gardner-Gee s report aligned with contemporary thinking and best practice in parasitoid biocontrol science. He noted that biocontrol operates on populations and that experiments on parasitoid behaviour are constrained by the physical requirements of containment testing. Laboratory testing cannot quantify all risks, including predicting the likelihood of displacement of native species, due to the complexity of the natural environment. Laboratory experiments however can give an indication of possible risk. Mr Charles then

8 8 provided his response to the submission from DOC which opposed the application on the grounds that insufficient host range testing was conducted. He noted that the host range tests did not imply that T. triozae will preferentially seek out native psyllids in the natural environment if it is approved for release simply because two of the four tested native Triozides were susceptible to parasitism by T. triozae. Mr Charles noted that parasitoids rely on a series of hierarchical behavioural steps that utilise a mixture of physical and chemical signals to locate hosts and that all these steps need to occur for a parasitoid to successfully parasitise its host. He also noted that there are limitations to what can be achieved in the laboratory. Insect behaviours and the biotic and abiotic interactions in the environment are complex and therefore additional host testing in containment would probably not have provided extra information to more confidently quantify the risk from this BCA. Mr Charles argued that although the tests showed that T. triozae can successfully complete its life cycle on Trioza panacis, first generation off-spring T. triozae were of lower fitness and therefore this psyllid is unlikely to be able to sustain a permanent population of T. triozae if the parasitoid encounters the species in the wild. Mr Charles ended his presentation by noting that most native psyllids were not tested and that a more comprehensive testing regime would need to have considered every native psyllid species. However, Mr Charles concluded that such a comprehensive regime would not have been logistically or financially feasible and reiterated his comment that further testing was unlikely to have more confidently quantified risk Dr Stephen Ogden commented on a question regarding the mentioned budgetary constraints around host range testing in the report. Dr Ogden noted that the host testing was one component of an overarching research programme with Plant and Food Research as the research provider on TPP. He noted that the testing was considered satisfactory for meeting the objectives of the research programme and that if high levels of non-target parasitism were recorded, further testing would have been considered Chris Nixon (New Zealand Institute of Economic Research) presented the main points from his economic assessment on the introduction of T. triozae to control TPP in New Zealand. Mr Nixon noted the advantages of cost-benefit analysis within the context of this application. He noted the use of science to determine the likely impacts of the introduction of the BCA and to develop an understanding of the potential risks via host rang testing. By using wide confidence intervals in their economic analysis based on literature and interviews with scientists and the industry, they determined that there is more uncertainty associated with the release of T. triozae than actual identified risk. Mr Nixon discussed the consequences of the gradual withdrawal of selected insecticides from the market over 20 years and new learnings by the horticulture industry to manage TPP. He also noted the uncertainties (impact of the BCA on crops and on native psyllids) and the costs associated with the eradication of T. triozae if it is shown to have adverse effects on native species. Mr Nixon recognised the push from government to increase growth and the export market s demand for reducing chemicals in the environment.

9 9 Presentation by EPA Staff 3.16 Dr Clark Ehlers (Senior Advisor, New Organisms) presented a summary of the EPA Staff Assessment Report focussing on the benefits, risks and costs of T. triozae, and assessing the parasitoid against the minimum standards in the Act. The staff assessment discussed the information provided in the application, information readily available in scientific literature, and information submitted to the EPA via public submissions. The EPA staff assessed the potential benefits and positive effects of introducing T. triozae, including its use in IPM practice and effects on TPP pressure, as well as the economic benefits. The report also considered potential risks and costs (adverse effects) associated with the introduction of T. triozae. The potential adverse effects assessed included the risk of the BCA parasitising and killing native psyllid species which may jeopardise New Zealand s biodiversity and the potential adverse indirect effects on ecological processes such as food webs. The staff assessment concluded that the cumulative benefits of releasing T. triozae to control TPP are significant and the cumulative adverse effects are negligible. The staff assessment also considered that T. triozae meets the minimum standards as stated in the HSNO Act. Record and summary of presentations from submitters at the hearing Department of Conservation 3.17 Dr Chris Green presented the submission from the Department of Conservation noting that, whilst DOC supports the potatoes, tomatoes, capsicum and tamarillo industries IPM focus to become more competitive and reduce chemical use, DOC believes that IPM cannot be implemented at the expense of significant risk to New Zealand s valuable and unique biota. DOC considers that T. triozae may cause displacement of native species in their natural habitat and has the potential to have adverse effects on New Zealand s inherent genetic diversity. Dr Green noted the effects might be significant, however, it is difficult to determine the significance of impact with accuracy given the limited amount of host testing that was undertaken on native Triozid psyllid species. DOC does not support the release of T. triozae into New Zealand until further research is undertaken which demonstrates that the parasitoid would not pose a threat to native psyllids. Dr Green explained why DOC consider the host range testing to be inadequate to describe the host range that T. triozae might have in the New Zealand environment. DOC considers that there is scientific and technical uncertainty regarding the use of this BCA in New Zealand. DOC has concerns regarding the lack of scientific knowledge and evidence regarding the parasitoid s impact on endemic psyllids within the Triozidae family. DOC does not consider that T. triozae meets the minimum standards, specifically: section 36(a) whether T. triozae will cause any significant displacement of any native species within its natural habitat; and section 36(d) cause any significant adverse effects to New Zealand s inherent genetic diversity. DOC requested that the application be declined on the basis that most native psyllid species were not tested and the risk to native species cannot be accurately described. They consider that T. triozae may indeed cause displacement of native species in their natural habitat and that these effects may be significant. DOC added that is difficult to determine the significance of impact on native psyllids with accuracy given that only four of the 50 native Triozid species were tested. Dr Green presented DOC s legal mandate to

10 10 provide input to New Organisms applications and provided an overview of DOC s involvement in weed biological control through the National Biocontrol Collective where research and scientific analyses underpin a robust case for new biocontrol agents. Te Rūnanga o Ngāi Tahu 3.18 Gerry Te Kapa Coates presented Ngāi Tahu s submission. Mr Coates outlined the Ngāi Tahu value system, which includes whanaungatanga (family), manaakitanga (looking after their people), kaitiakitanga (stewardship) and tikanga (appropriate action). Mr Coates also discussed the role the Ngāi Tahu HSNO Komiti plays in monitoring EPA applications. Mr Coates noted that the application categorised the risk that T. triozae may pose to significantly displace native species in their natural habitats as low, and further noted that they were reassured by the statement of support from Professor John Trumble (Department of Entomology, University of California at Riverside) in the application. Mr Coates noted that a persuasive case for risks and benefits has been made and that Ngāi Tahu support the application being approved. Mr Coates noted that they consider that post-release monitoring should be included as a condition to an approval. Stuart Attwood, Southern Paprika Ltd 3.19 Stuart Attwood (Southern Paprika Ltd) noted that they have 23 ha of glasshouses growing capsicums for export to Japan, Australia, Canada and the Pacific Islands as well as supplying the local market. Southern Paprika employs more than 120 full-time staff and contributes $10 million p.a. to the Warkworth economy where it has been operating for 17 years. The company makes $28 million in annual sales and has contributed approximately $200 million in foreign exchange to New Zealand since it started operating. Mr Attwood noted that TPP is the single worst pest problem to capsicum growers. They use scouting crews to locate TPP in glasshouses. He noted that finding individual TPP insects before plants are infected with Lso is complicated by the small size of the insect. He further noted they risk losing an entire crop if TPP is not rapidly detected and that they have to spray when TPP is shown to be present in a glasshouse. TPP has impacted the industry s ability to use current methodologies that minimise the impact pest management has on the environment. This has resulted in a return to calendar spraying to prevent the effects of TPP. Mr Attwood pointed out that export markets, especially Japan, are sensitive to chemical residues on capsicums and when pesticide maximum residue limits have been exceeded they have suspended exports. The use of chemicals to manage pests in capsicum glasshouses is affecting the ability of the industry to compete internationally. Mr Attwood noted that he is concerned about growers reliance on insecticides to control TPP and that the use of BCAs is crucial to future proof the industry. Lex Dillon, Under Glass Ltd 3.20 Lex Dillon presented a submission from Under Glass Ltd, the production arm of NZ Hothouse. They oversee 20 ha of tomato growing glasshouses and employ staff in the Franklin district. They export to a number of markets including Australia, Singapore, North America and Taiwan. Mr Dillon noted that IPM is a mixture of concept and ideas and the use of T. triozae will aid in the re-

11 11 establishment of programmes in their glasshouses that rely on a number of control strategies. He also noted that any reduction in TPP pressure by T. triozae, even at the lower scale, will be regarded as beneficial as this could be sufficient to overcome the pest in an integrated management approach. Mr Dillon noted that there is a drive internationally for BCA-based programmes and that the future for New Zealand businesses relies on having access to BCA options to compete with other producing countries. As certain classes of chemicals are phased out and others become ineffective, the industry need more tools for IPM programmes to work optimally and consider that T. triozae will be a crucial component within such programmes. Tony Norton, Nortonta Ltd 3.21 Tony Norton presented the submission on behalf of Nortonta Ltd, a Canterbury based grower producing over 600 tonnes of tomatoes annually. They employ 10 staff and have been in the business for 20 years. Mr Norton noted that they support sustainable biological control options for pest management and, whilst they have BCA options for whitefly control, there is no BCA available for TPP in New Zealand. Therefore they have to resort to chemical control. This is affecting their profitability and hence their ability to employ more staff. Tāhuri Whenua Inc 3.22 Dr Nick Roskruge presented the submission from Tāhuri Whenua Inc. Tahuri Whenua Incorporated Society is a National Māori Vegetable Growers Collective representing Māori interests in the horticulture sector. Dr Roskruge presented an overview of the collective and stated that there are over 400 members nationwide which represent Māori interests in taewa (Māori potato) and horticulture. The collective actively consider economic and commercial opportunities, educate future generations of land managers and look towards integrating mātauranga Māori with contemporary horticulture practice. He outlined the impacts TPP has had on traditional crops noting the psyllid s adverse effects on whakapapa and manaakitanga. Dr Roskruge presented questions and comments from members about T. triozae noting in particular that members are cautious given the unquantified benefits to the Māori economy and whether the parasitoid will fully solve the TPP issue. Tāhuri Whenua acknowledged the beneficial outcomes this BCA may bring Māori growers and recognised the need to weigh risks and benefits. Dr Roskruge wanted applicants to note that they should involve Māori at an early stage when developing new biocontrol programmes On questioning, Dr Roskruge explained that he had not observed any TPP impacts on poroporo collected from the wild, noting that as far as he was aware there is still plenty available. In addition, he confirmed that he had not observed any impact on kūmara from TPP. Turners and Growers Global Limited 3.24 Ben Smith from T&G Global Ltd noted that they grow 28 ha of glasshouse tomatoes and employ 300 people at five locations. T&G also trade tomatoes and capsicums from grower partners and pack and market potatoes. Mr Smith provided an outline of their local pest situation where large areas of potatoes and tomatoes are grown in close proximity and whitefly and TPP are common pests of both crops. Mr

12 12 Smith explained that the use of agrichemicals against TPP has had the unintended consequence of whitefly developing resistance to insecticides. Average losses due to TPP are between 3% and 8% but this has, at times, peaked at 50%. The direct costs to manage the psyllid are made up of monitoring costs, agrichemical applications, compliance related expenses and losses incurred due to TPP and Lso infection. Mr Smith noted that the benefits of introducing T. triozae would include easier access to markets, less risk of border intercepts of TPP and reduced potential for harm to the environment and sprayer operators through lower agrichemical use if it is successful. T&G would return to IPM use with the release of T. triozae. They would release T. triozae around glasshouses to prevent TPP from building to large populations in the environment and then entering glasshouses in large numbers, coupled with releases of Encarsia (BCA for whitefly) and Tamarixia inside glasshouses when required. If approved, they propose to monitor pest and BCA populations and would utilise soft chemicals when necessary The hearing was adjourned on 4 May 2016, and closed on 11 May The Committee would like to thank all people who submitted the information used in making this decision. Public submissions provide a focus for the Committee on points that need clarification, and the Committee found the submissions and the applicants responses very helpful in its consideration of the application. 4. Organism description 4.1 The organism approved for release is: Taxonomic Unit Class Order Family Genus Classification Insecta Hymenoptera Eulophidae Tamarixia Species triozae (Burks, 1943) Common name Tamarixia triozae 4.2 Tamarixia triozae is a parasitoid wasp that attacks the fourth to fifth instar TPP nymph using its ovipositor to deposit eggs on the ventral surface of the nymph. When an egg hatches, the T. triozae larva develops externally on the surface of the nymph, feeding on the underside whilst it excavates the body of the nymph. The T. triozae larva then pupates inside the empty cavity to emerge as an adult wasp. 4.3 The Committee noted that T. triozae is known to be one of the most abundant parasitoids of TPP in its native range, the USA and Mexico.

13 13 Host range of T. triozae 4.4 Host range testing was undertaken by Plant and Food Research in containment. The testing demonstrated that of the eight tested psyllids (seven native and one exotic beneficial psyllid), two native psyllid species, both in the Triozidae family, are susceptible to attack by the parasitoid. They are Trioza curta and Trioza panacis. Five native psyllids (three species in the Psyllidae family and two species in the Triozidae family) and the exotic psyllid (broom BCA in the Psyllidae family) were not parasitized and fell outside the fundamental host range of the parasitoid. 4.5 Mortality rates of T. curta were significantly higher when T. triozae was given a choice between TPP and the native species compared to background mortality. No juvenile parasitoids emerged from parasitised T. curta suggesting that this psyllid will not act as an ecological host for the BCA. 4.6 Trioza panacis is within the physiological host range of the parasitoid as this psyllid supported the emergence of parasitoids. However, the rate of egg laying on T. panacis was low and parasitoids that emerged had reduced ability to produce further offspring compared to its target host TPP. Predicted mortality rates of T. panacis psyllids were not significantly different from background mortality. 4.7 The Committee noted that the testing regime was in accordance with best practice methodology but gave consideration to the number of psyllid species tested. 4.8 The Committee noted the concern by DOC that the host range testing did not include a sufficient number of native species to adequately demonstrate the host range of the parasitoid. As a result, the Committee considered whether the number of psyllids selected for testing was sufficient to demonstrate potential non-target effects. 4.9 The Committee acknowledged that there is limited information available on the geographic distribution of New Zealand s psyllids which may have complicated the selection of representative psyllids for testing. The Committee considered the role of habitat and geographical factors in selection, thus the Committee noted the role host plants play in governing distribution and migratory behaviour of psyllids. The Committee noted that there are no native psyllids that are known to use any of the plant species within the families of plants that are hosts to TPP. The Committee considered that this indicates that native psyllids and TPP do not share common habitat and geographical distributions and will not routinely come in close contact with one another Further, the Committee considered that host switching will normally only occur if target and non-target species exist in areas that are in close proximity to one other. Any non-target interactions are further mitigated by host-food plant-complex chemical cues that are recognised by parasitoids to locate a host and successfully parasitise it. Common habitat and geographical features of psyllids may have underpinned the selection of candidate psyllids for testing, however, the Committee noted that these features were not applicable in the case of TPP and native psyllids and therefore those features were not suitable in the selection of test species The Committee noted that not all native psyllids were included in the host range testing design but accepted that it would not have been possible to conduct host range testing on all known native psyllids.

14 14 The Committee inferred from the host range testing, and information discussed at the hearing, that T. triozae is capable of parasitising some native psyllids, but noted that there is uncertainty regarding the full extent of its host range. The Committee took this uncertainty into account when considering the application. 5. Inseparable organisms 5.1 No inseparable organisms associated with T. triozae were identified. 6. Assumptions for risk assessment 6.1 The Committee noted that there is uncertainty about whether or not T. triozae will successfully establish in New Zealand, and have an impact on TPP. The Committee considered that if T. triozae does not establish, there will not be any significant effects (adverse or beneficial) from the release. Conversely, if T. triozae establishes successfully and develops self-sustaining populations, any potential effects will be at their greatest. Therefore, the Committee considered the minimum standards and assessed the risks, costs, and benefits of releasing T. triozae, working on the assumption that T. triozae will establish and develop self-sustaining populations. 7. Minimum Standards 7.1 The Committee considered whether T. triozae meets the minimum standards as specified in section 36 of the Act; specifically whether T. triozae could: (a) cause any significant displacement of any native species within its natural habitat; or (b) cause any significant deterioration of natural habitats; or (c) cause any significant adverse effects on human health and safety; or (d) cause any significant adverse effects to New Zealand s inherent genetic diversity; or (e) cause disease, be parasitic, or become a vector for human, animal, or plant disease, unless the purpose is to import or release an organism to cause disease, be a parasite, or a vector for disease. Potential to cause significant displacement of any native species within its natural habitat 7.2 The Committee considered the potential for T. triozae to cause any significant displacement of any native species within its natural habitat. The Committee considered that displacement of native species could occur through competition with a native species in its natural habitat, or through parasitism of a native psyllid species in its natural habitat. Potential displacement of native species through competition 7.3 The Committee noted that while some generalist predators feed on TPP, they do not rely on TPP as their only source of food. The Committee therefore considered that reductions in TPP populations due to T. triozae will not displace native predatory species since there are no organisms present in New Zealand that are reliant solely on TPP as a food resource.

15 The Committee also noted that native parasitoids have not been recorded parasitizing TPP, therefore T. triozae will not be displacing any native parasitoids through attacking TPP. 7.5 The Committee concluded that T. triozae will not cause significant displacement of any native species within its natural habitat through competition. Potential displacement of native species through non-target parasitism of native species 7.6 In considering the potential for T. triozae to displace native species through parasitism of those species, the Committee considered the host range testing undertaken by Plant and Food Research, noting the limitations of the research including the number of native species tested. The Committee also considered the ecological range and host seeking behaviour of T. triozae, and the environmental factors that would impact on that behaviour. 7.7 The Committee noted that displacement of native species through non-target parasitism was a particular concern raised by the Department of Conservation in their submission and presentation at the hearing. 7.8 The Committee heard that, under laboratory conditions, T. triozae is able to parasitise two of the seven native species that were included in the host range testing experiments. This suggests that T. triozae may also be able to parasitise other native psyllids in the Triozidae family that were not tested. The host range testing also demonstrated that while T. triozae was able to complete development on Triozae panacis, the off-spring produced were less fit, indicating that T. panacis is unlikely to be a suitable host for sustaining a permanent population. 7.9 The Committee noted concerns raised by DOC that the host range testing included only a small proportion of native psyllids, and recognised that there are limitations in the knowledge about native psyllids. The Committee also accepted that it would not be feasible to conduct host range testing on all known native psyllids, and recognised that the true ecological host range of T. triozae could not be demonstrated using laboratory tests The Committee noted that parasitoids such as T. triozae use a variety of chemical and physical cues to locate and parasitise their hosts, including cues from the psyllids host (food) plants and from the psyllids themselves. This means that T. triozae will be attracted to environments where TPP s food plants are located The Committee also noted that, in the event all the steps to host acceptance on non-target psyllids are met, the possibility for non-target species to underpin parasitoids invading native habitats where they may encounter other native psyllids will be low The Committee noted that TPP is primarily found in highly modified horticultural environments. This is because TPP s food plants in New Zealand belong to the Solanaceae (nightshade) and Convolvulaceae (morning glory) families, and these are predominantly found in horticulture crop systems and environments that are in proximity to crop environments, such as shelter belts and field margins. The Committee also noted that native psyllid species are unlikely to frequent horticulture crop and border

16 16 environments since the plants found in those environments are not their preferred food. However, the Committee recognised that there is potential for some overlap in the distribution of TPP and native psyllids in the landscape, which would provide an opportunity for T. triozae to parasitise native psyllids, provided they were a suitable host The Committee acknowledged that there is limited information on the demography, life history and host preferences of New Zealand native psyllids available, especially of psyllids that are rare and threatened. The Committee noted that, notwithstanding the limitation of our knowledge, the ability of the parasitoid to shift its host preference to non-target psyllids will depend on TPP and other psyllids sharing a host or using hosts that occur in close proximity to one another The Committee found that there is potential for individuals of native psyllids to be parasitised by T. triozae, particularly when native species appear in the modified horticultural environments. However, the Committee considered that impacts on individuals are not likely to have a population level effect, so would not be significant The Committee concluded that T. triozae is not likely to cause any significant displacement of any native species within its natural habitat through parasitism of a native psyllid species. Potential to cause significant deterioration of natural habitats 7.16 The Committee considered the potential for T. triozae to cause any significant deterioration of natural habitats The Committee considered that T. triozae will not have adverse effects on the modified crop environment where it will suppress TPP, however the effects on unmodified natural environments are uncertain and difficult to predict when ecological studies have not been undertaken. The Committee noted that ecosystems are compensatory and adaptive and that any effects will be restricted to crop and wider crop border habitats where T. triozae is expected to be confined to. The Committee noted that it is unlikely for the parasitoid to assert significant effects outside of managed habitats where TPP is routinely present The Committee concluded that T. triozae is not likely to cause any significant deterioration of natural habitats. Potential to cause significant adverse effects on human health and safety 7.19 The Committee considered the potential for T. triozae to cause any significant adverse effects on human health and safety, noting T. triozae is not known to pose any risks to people The Committee concluded that T. triozae is not likely to cause any significant adverse effects on human health and safety. Potential to cause significant adverse effects on New Zealand s inherent genetic diversity 7.21 The Committee considered the potential for T. triozae to cause any significant adverse effects on New Zealand s inherent genetic diversity through hybridisation with native species.

17 The Committee noted that it is unlikely for the parasitoid to hybridise with Tamarixia species that are present in New Zealand. The Committee acknowledged that there is limited information available to determine native Tamarixia species distribution or abundance, however, no Tamarixia species were found to parasitise TPP in New Zealand. The Committee considered that this indicates that T. triozae is not likely to encounter other Tamarixia species in the crop and crop border habitats where it forages for TPP and therefore opportunities for hybridisation will not arise 7.23 The Committee concluded that T. triozae is not likely to cause any significant adverse effect to New Zealand s inherent genetic diversity. Potential to cause disease, be parasitic, or become a vector for disease 7.24 The Committee considered the potential for T. triozae to cause disease, be parasitic, or become a vector for human, animal, or plant disease, resulting in damage to species other than TPP The Committee noted that T. triozae is not known to cause disease or be a vector for animal, plant or human disease in its native habitat. The Committee also noted that the intended purpose of the release of T. triozae is controlling TPP through parasitism The Committee concluded that T. triozae is not likely to cause disease, be parasitic, or become a vector for diseases, except where it is intended to control TPP through parasitism. Conclusion on the minimum standards 7.27 The Committee was satisfied that T. triozae meets the minimum standards set out in section 36 of the HSNO Act. 8. Ability of the organisms to establish a self-sustaining population and ease of eradication 8.1 In accordance with section 37 of the Act and clauses 10(e) and (f) of the Methodology, the Committee took into consideration the ability of T. triozae to form undesirable self-sustaining populations, and the ease of eradication of such populations. 8.2 The Committee noted that the intention of the importation and release of T. triozae is to establish selfsustaining populations, in order to control TPP throughout the year during the growing season on crops and in the winter months on overwintering plants such as boxthorn. Furthermore, they considered that for a self-sustaining population of T. triozae to be undesirable, it would need to be causing undesirable and adverse effects. The predicted effects that self-sustaining populations of the parasitoid is expected to have in horticulture crop environments will be desirable and, since it is expected to maintain selfsustaining populations in the cropping and related habitats only, it is unlikely to exert significant adverse effects away from modified habitats. 8.3 The Committee concluded that it is improbable that T. triozae would form an undesirable self-sustaining population, as it is unlikely that T. triozae will cause significant adverse effects if released into the New Zealand environment.

18 The Committee noted that it would be very difficult to eradicate T. triozae in the event that an undesirable self-sustaining population did establish. 9. Identification and assessment of potentially significant adverse effects 9.1 The Committee considered the potential risks and costs of the release of T. triozae, including any potentially significant adverse effects on the environment, human health and safety, society and communities, the market economy, and Māori culture, traditions, and the principles of the Treaty of Waitangi (Te Tiriti o Waitangi). Adverse effects caused by non-target parasitism of native or beneficial exotic psyllids 9.2 The Committee considered the potential for T. triozae to parasitise and kill native psyllids in New Zealand which may jeopardise our biodiversity by posing risks to populations of rare/threatened psyllids. 9.3 As discussed above, the Committee noted that T. triozae has been demonstrated to be capable of parasitising at least two native Triozid psyllids in laboratory conditions. The Committee also noted that parasitoid wasps such as T. triozae employ a number of physical and chemical cues to locate their host insects in the natural environment which may not be operable in the artificial laboratory environment. In addition, laboratory-based testing cannot adequately represent population dynamics of native species in the environment but it can serve as guidance to determine a worst case scenario when full attack on a non-target species occurs. 9.4 The Committee also noted the habitat and geographical distributions of TPP and native psyllids and their host plants, the use of physical and chemical signals when T. triozae searches for TPP, and the low numbers of native psyllids in crop systems and concluded that any adverse effects on native psyllids that are found in high and variable densities across native landscapes will be negligible. 9.5 The Committee considered the potential adverse effects T. triozae might have on populations of rare or threatened native psyllids where T. triozae disperse beyond crop and related modified environments into native habitats is where the chance of encountering rare psyllids increases. The Committee noted that there is minimal information available on population size, population dynamics, dispersal rates and distribution of host plants of rare or threatened native psyllids. Further, the Committee considered the potential for irreversible damage to occur to populations of rare or threatened native psyllids if T. triozae attacked these psyllids. The Committee considered the probability of this occurring by recognising the size of native alpine and sub-alpine habitats where most native psyllids live in New Zealand. Populations of rare or threatened species are irregularly distributed throughout native habitats and climatic conditions at higher altitudes will discourage T. triozae penetrating these habitats as TPP s host plants are grown in high abundance in lowland vegetable cropping and fruit orchard areas. The Committee concluded that while there is potential for individuals of native psyllid species to be parasitised by T. triozae, resulting in the death of those individuals, the risk of significant adverse effects on any native species, that is population level effects, is very low. However, the Committee

19 19 acknowledged that there is uncertainty in this regard, so could not conclude that those potential adverse effects would be negligible. Indirect adverse effects caused by interference with ecosystem functions 9.6 The Committee considered the potential for T. triozae to cause non-target effects on ecosystem processes such as food webs and hyperparasitism rates where the parasitoid is expected to establish. 9.7 The Committee considered whether there are any other organisms that depend on the same resource as T. triozae does. The Committee noted that there are no parasitoids that attack TPP and that general predators are the only insects recorded feeding on TPP in New Zealand. The Committee concluded that reductions in populations of TPP due to activity of T. triozae will not adversely affect other organisms because there are no other organisms in New Zealand that share this resource with T. triozae. 9.8 The Committee considered the impact that hyperparasitism of T. triozae might have on valued insects that are hosts to the same hyperparasitoids in crop and border environments. The Committee noted that plant species diversity is low in vegetable crop or fruit orchard habitats and thus the number of species that are normally found in these habitats are also limited. This minimises the likelihood of elevated levels of hyperparasitoids that build on T. triozae to suppress other organisms that are susceptible to the same parasites in production landscapes. The Committee noted that there is higher species diversity in areas that border horticulture crops where T. triozae is also expected to establish. The Committee noted that in the absence of local ecological studies, it is difficult to predict whether any valued species in these border modified habitats may be vulnerable to hyperparasitism. 9.9 The Committee also considered the potential of other Tamarixia species that are present in New Zealand to cross-breed with T. triozae and the role of T. triozae to be a vector of disease The Committee concluded that, in the absence of specific information, any adverse effects on New Zealand s ecosystem functions resulting from the release of T. triozae will be localised and contained with no or very little discernible ecosystem impact and therefore they considered any effects to be negligible. Potential adverse effects on Māori culture, traditions, and Te Tiriti o Waitangi 9.11 The Committee took into account the possible effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga, and the principles of the Treaty of Waitangi (Te Tiriti o Waitangi) The Committee noted that the applicant engaged with Māori via the EPA s Te Herenga 2 network and iwi/māori organisations working specifically with HSNO and horticulture issues The Committee noted that the Ngāi Tahu HSNO Komiti and Tāhuri Whenua Inc. have both voiced concerns that Māori will not be able to continue growing taewa, kūmara and poroporo in traditional pesticide-free growing units due to the effects of TPP. This hampers the ability of Māori to provide food 2 Te Herenga is made up of Māori resource and environmental managers, practitioners, or experts who represent their iwi, hapū, or Māori organisation on matters of relevance to the activities and decision making of the EPA.

20 20 for whanau and hapū. The Committee also noted that some Māori have concerns about the potential risks of releasing T. triozae to whole ecosystems The Committee noted that the application to release T. triozae is broadly consistent with the principles of kaitiakitanga and manaakitanga since T. triozae is expected to benefit people and the environment, and provides for a softer option than insecticides for managing TPP The Committee noted that no risks to native or taonga species, ecosystems and traditional Māori values, practices, health and well-being were identified in the application, or through the public submissions. After assessing all the information, the Committee did not identify any adverse effects on the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga. 10. Identification and assessment of potentially significant beneficial effects 10.1 The Committee considered the potential benefits of the release of T. triozae, including any potentially significant beneficial effects on the environment, human health and safety, society and communities, the market economy, and Māori culture, traditions, and the principles of the Treaty of Waitangi (Te Tiriti o Waitangi) In doing so, the Committee noted that T. triozae, is intended to be a biocontrol agent for TPP, acting to reduce the pressure of this pest on potato, tomato, capsicum and tamarillo crops. Tomato potato psyllid in New Zealand 10.3 The Committee noted that TPP was first detected in New Zealand in 2006 and by 2011 was considered to be wide-spread throughout solanaceous crop growing areas of the North Island and specific regions of the South Island. The Committee noted that TPP is a serious pest of solanaceous plants, in particular plants that have economic value including potatoes, tomatoes, eggplants, capsicums and tamarillos. TPP is known to feed, oviposit, and complete part of its life cycle on vegetable/fruit plants during the growing season, whilst it overwinters on non-crop evergreen hosts, such as boxthorn and other nightshade or morning glory non-crop plants, that grow near crop areas in field margins, hedges and shelter belts The Committee noted that feeding by TPP causes a disease called psyllid yellows when it injects saliva into the plant. The disease is systemic which means it can infect the whole plant. Symptoms can include yellowing of leaf edges, upward cupping of leaves, premature ageing and plant death. The Committee further noted that solanaceous plants affected by psyllid yellows can exhibit up to an 80% decrease in yields. Further, TPP is known to vector a bacterial pathogen, Lso, which may inhabit the phloem of plants that TPP fed on. The disease that Lso causes is known as Zebra Chip which damages potato tubers, making them unfit for the market and can kill solanaceous plants The Committee noted that there are currently limited strategies available to control TPP and Zebra Chip. The Committee noted that monitoring and tracking of the insect is an essential first step to manage infestations in crops. Furthermore, the Committee noted that insecticides have become the norm to

21 21 provide control against TPP and that multiple foliar applications of broad-spectrum insecticides per calendar year are required to provide consistent knockdown effects. The Committee considered the information submitted by growers and noted that a number of submitters outlined their concerns about the potential development of resistance against widely used insecticides, the effects of chemical residues on market access and the detrimental effects of chemicals on beneficial insects that can act as BCAs in crops. Potential benefits from T. triozae parasitising TPP 10.6 The Committee noted that the applicant identified reduction in TPP numbers, which will reduce pest and disease pressures on potato, tomato, capsicum and tamarillo crops, to be the primary potential benefit from the release of T. triozae. The Committee also noted that the successful use of T. triozae will have flow-on benefits in that growers will be able to return to using other beneficial insects that will reduce their reliance on broad-spectrum insecticides, and Māori will retain their ability to grow crops, allowing them to return to traditional cultivation methods. A decrease in reliance on broad-spectrum insecticides, coupled with an increase in use of other beneficial insects, also has the potential to reduce the level of insecticide resistance in other pest insects such as whitefly. Furthermore, the Committee noted the economic benefits to the horticulture industry by reducing the cost of chemical control, increases in yield and quality of vegetables, better returns to growers and improvements to local and regional economies overall. The Committee considered the individual benefits identified by the applicant and presented at the hearing below. Benefits of T. triozae through reducing TPP pressure 10.7 The Committee considered the efficacy of T. triozae to determine if the proposed benefits may eventuate. The Committee noted that there is uncertainty regarding the expected levels of establishment of T. triozae in New Zealand and limited information available in the public domain on parasitism rates. The Committee noted the use of T. triozae in North American greenhouses, parasitism levels recorded in field crops in the USA and Mexico, and parasitism rates found in contained host range testing performed in New Zealand. The Committee also considered the life history parameters of T. triozae, its ability to curb transmission of Zebra Chip by parasitising Lso-infected TPP nymphs that will be searching for new host plants, and suppression of TPP numbers that overwinter on evergreen perennial plants before they invade crops Based on the information the Committee had available, the Committee considered that T. triozae is likely to be a viable BCA for TPP that would support the horticulture industry s efforts to counteract the damage to vegetable and fruit crops in New Zealand. The Committee recognised that T. triozae alone will not be a complete solution for the impacts of TPP, but will be an additional tool that can be used in a variety of ways depending on the industry. The Committee also noted that growers have commented that any reduction in TPP pressure by T. triozae, even at the lower scale, will be regarded as beneficial as this could be sufficient to overcome the pest in an integrated management approach.

22 22 Benefits of increased use of IPM 10.9 Following on from considering the proposed primary benefit, the Committee examined the potential flow-on benefits that may result from the use of T. triozae. Firstly, the Committee considered the benefits of IPM programmes and whether T. triozae will contribute to IPM efforts within the horticulture industry The Committee noted that information submitted to the EPA from growers shows that the horticulture industry is committed to using an integrated approach to pest management, particularly the use of beneficial insects and softer chemical options. The Committee also noted that the presentations from growers and grower organisations at the hearing reiterated an over-reliance on broad-spectrum insecticides to control TPP which is allowing other pests such as whitefly to develop insecticide resistance. In addition, increased reliance on chemical control has the potential to adversely affect exports to our primary export markets due to levels of insecticides on vegetables/fruits exceeding maximum residue levels The Committee noted that submitters commented on the advantages that IPM offers and that T. triozae will allow growers to return to using other beneficial insects too The Committee recognised the benefits of IPM such as the reduction in broad-spectrum insecticide use, instead favouring beneficial insects and improving environmental and economic outcomes, such as increases in market share. The Committee concluded that T. triozae will allow growers to re-establish IPM in affected crops and reap the benefits that IPM practice offers. Benefits to Māori and their cultivation of traditional crops The Committee considered the potential benefits of T. triozae on taewa growing units at marae gardens where food is grown for cultural and community use The Committee noted the adverse effects TPP and Lso have had on taewa in particular but also on kūmara, where it had been vulnerable to TPP s effects, and acknowledged Māori support for a biocontrol option for TPP The Committee commented on the Māori economy and noted that it is mostly a social economy that embeds whakapapa and manaakitanga, and traditional foods are key to managing relationships within and between whanau, hāpu and iwi. The Committee recognised the benefits T. triozae will have in reducing TPP pressures on cultural crops that are traditionally grown without pesticide intervention. Benefits to market economy from the release of T. triozae The Committee noted that the proposed economic benefits of TPP biocontrol include reduced control costs, reduced quality losses, increased yields and increased price per kilogram through the production of higher quality crops. Further, the Committee noted the indirect economic benefits that are less quantifiable in term of dollar values, including increases in export growth and local and regional economic growth.

23 The Committee considered the economic impact that TPP and Lso have had on the horticulture industry. A number of growers noted in their submissions that having access to T. triozae might mean that they will be able to produce better quality vegetables or fruits with lower amounts of agrichemicals. This, in turn, will benefit their businesses, benefit local and regional economies through employment and use of service providers in their areas, and contribute to New Zealand s export growth target The Committee considered the economic assessment that was undertaken by the New Zealand Institute for Economic Research (NZIER) on the release of T. triozae. They noted that the benefits outweigh the costs on all accounts, considering worst case benefit scenarios and elevated costs associated with T. triozae in the NZIER report and expert witness presentation by Chris Nixon. The Committee noted there are uncertainties regarding the use of T. triozae in New Zealand, including establishment and efficacy rates against TPP, and the potential for adverse effects and degree of those effects if T. triozae has off-target effects on native species (i.e. cost implications to eradicate the parasitoid). Conclusion on benefits of introducing T. triozae to control TPP and Lso The Committee found that T. triozae has the potential to result in significant benefits to the horticulture industry through the suppression of TPP on tomato, potato, capsicum and tamarillo crops. This will reduce reliance on broad spectrum insecticides, and reduce the impact of TPP and the pathogen it vectors on those crops. This has the potential flow on benefits of enabling an increase in use of other beneficial insects in their IPM programmes, and a reduction in insecticide resistance in other pest insects such as whitefly. There are also potential benefits to Māori, including enabling them to protect their valuable taewa crops and return to organic cultivation of traditional crops. These beneficial effects will also have beneficial consequences for the economy, including the Māori economy The Committee concluded that these benefits are potentially significant (non-negligible). 11. Weighing of beneficial and adverse effects 11.1 In accordance with section 38(1) of the Act the Committee considered whether the positive effects of the introduction of T. triozae outweighed the adverse effects of the introduction The Committee found that the potential positive effects (benefits) of introducing T. triozae primarily arise from the suppression of TPP on tomato, potato, capsicum and tamarillo crops. The Committee noted that the magnitude of the beneficial effects will depend on the efficacy of T. triozae in suppressing TPP, which will depend on a number of factors including the crop and how T. triozae is introduced and managed. The Committee considered that the combined potential benefits of introducing T. triozae are significant and non-negligible The Committee considered that the primary concern relating to introducing T. triozae is potential parasitism of native species. They found that while there is potential for individuals of native psyllid species to be parasitised by T. triozae, resulting in the death of those individuals, the risk of significant adverse effects on any native species, that is population level effects, is very low.

24 The Committee noted that there is uncertainty regarding the range/number of native psyllids that may be susceptible to attack from T. triozae, and gave consideration to clauses of the Methodology. They recognised that there would be little value in seeking additional information on this matter from the applicant, and decided to proceed with the information available The Committee found that due to uncertainty regarding the level of adverse effect that T. triozae could have on native psyllids, they could not conclude that the risks were negligible (clause 26 of the Methodology). Therefore, the Committee gave consideration to clause 27 of the Methodology. In this instance the Committee confirmed their finding that T. triozae will not cause any of the effects in the minimum standards (section 36 of the HSNO Act), and weighed the risks against the benefits The Committee found that the benefits of releasing T. triozae outweighed the adverse effects. 12. Achieving the purpose of the Act 12.1 The purpose of the Act is to protect the environment, and the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances and new organisms (section 4 of the Act) In order to achieve the purpose of the Act, when considering the application the Committee recognised and provided for the following principles (section 5) of the Act: the safeguarding of the life-supporting capacity of air, water, soil and ecosystems 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 The Committee took into account the following matters when considering the application in order to achieve the purpose of the Act (sections 6, 7 and 8 of the Act): the sustainability of all native and valued introduced flora and fauna the intrinsic value of ecosystems public health the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga the economic and related benefits and costs of using a particular hazardous substance or new organism New Zealand s international obligations the need for caution in managing adverse effects where there is scientific and technical uncertainty about those effects the principles of the Treaty of Waitangi (Te Tiriti o Waitangi) The Committee is satisfied that this decision is consistent with the purpose of the Act and the above principles and matters. Any substantive issues arising from the legislative criteria and issues raised by submitters have been discussed in the preceding sections of this decision.

25 Decision 13.1 After reviewing all of the information contained in the application, the Committee was satisfied that the application met the requirements of section 34 of the Act. In any event, in accordance with section 59(3)(a)(ii), the Committee waives any information requirement that has not been met The Committee considered that the threshold for approval under section 38 of the Act has been met. It is satisfied that the organism meets the minimum standards set out in section 36 of the Act, and that the beneficial effects of the organism outweigh the adverse effects of the organism, taking into account all of the following: all the effects of the organism and any inseparable organisms the matters in section 37 of the Act the relevant matters in Part 2 of the Act the Methodology The Committee decided to approve the import for release and/or release from containment of Tamarixia triozae under section 38(1)(a) of the Act. The Committee noted that in accordance with section 38(2) of the Act, the approval has been granted without controls The Committee noted that under section 38(3) of the Act, if T. triozae has not been released within five years of the date of this decision, this approval for release will lapse. However, any person may apply before the expiry of the time limit for an extension of that time limit for a further period of up to five years The Committee has waived the requirement under section 38(4) of the Act, to notify the Authority of the release of T. triozae The Committee would like to thank everyone who provided information that has been used in making this decision. 17 Dr Kerry Laing Chair, Decision Making Committee Environmental Protection Authority Date Organism Tamarixia triozae Burks 1943 (Hymenoptera: Eulophidae) Approval code NOR100160