AND. Hearing 5: Beds of Lakes and Rivers, Wetlands and Biodiversity, Discharges to Land. Summary of Evidence of David Charles Havell

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1 BEFORE THE HEARING PANEL IN THE MATTER OF the Resource Management Act 1991 AND IN THAT MATTER OF The Proposed Natural Resources Plan for the Greater Wellington Region Hearing 5: Beds of Lakes and Rivers, Wetlands and Biodiversity, Discharges to Land Summary of Evidence of David Charles Havell on behalf of the Minister of Conservation (submitter no.75) Topic: Wetlands and Biodiversity (agrichemical use in wetlands) Dated: 12 April 2018 Department of Conservation P O Box WELLINGTON Solicitor: May Downing/Katherine Anton Telephone: mdowning@doc.govt.nz David Havell GW Evidence Agrichemicals DOC

2 SUMMARY OF EVIDENCE OF DAVID CHARLES HAVELL 1. My full name is David Charles Havell. 2. I provide this summary statement of evidence to summarise the key matters within my primary statement of evidence dated 26 March This summary statement of evidence also includes appendices 1 and 2 of my primary statement of evidence as they did not present clearly in my pre-circulated statement. THE DEPARTMENT OF CONSERVATION S ROLE 4. To protect conservation values in the Wellington Region, the Department manages a range of serious environment pest plants such as gorse, crack willow, pampas, hornwort, blackberry, Japanese honeysuckle, yellow flag iris, and alder. Many of the pest plants we control are listed as unwanted organisms by Ministry for Primary Industries (MPI). These pest species may alter the ecological dynamics of wetland ecosystems, change the character of the wetland vegetation and suppress native biodiversity. 5. There are several broad categories of management methods to control pest plants, each have their strengths and weaknesses. Physical control methods such digging and cutting can be simple and focused, but can be time consuming, spread pests, and damage the area though trampling of plants and substrate; Biocontrol is usually pest specific, self-dispersing and self- managing and can reduce pests to low levels, but may be slow, may not remove all target pests, and is sometimes affected by the local ecology and other pest management; Agrichemical use (granules, spraying, cut and paste), can be effective and specific, but agrichemicals may spread beyond the target area, damage non-target plants, reduce habitat, and adversely affect other organisms besides plants. 6. DOC has a set of Standard Operation Procedures (SOP) for pest plant management as well as specific SOP s for wetlands. Staff and others working under DOC are expected to follow the New Zealand Standard for agrichemical use (NZS 8409:2004 Management of Agrichemicals) and EPA approval conditions. 7. The EPA sets conditions for the use of agrichemicals in New Zealand. Under EPA approvals the number of agrichemicals which can be used over and into water is limited, and to varying extent, there are controls on use such as training and competency requirements, incident reporting, annual monitoring reports, monitoring plans, neighbour notifications, frequency and rate limitations, timing and signage 1

3 requirements. In addition, under the most recent approvals, DOC and other permission holders are required to undertake a risk assessment around every application of agrichemicals. 8. A site risk assessment and a risk management plan to manage agrichemicals use, is a critical process for managing adverse agrichemical impacts on the environment and conservation values. Spray plans like those outlined by NZS 8409:2004 but extended to include detail on the environmental values at a site and the procedures to avoid, eliminate and mitigate adverse impacts from agrichemicals are equivalent to EPA risk assessment required for using some agrichemicals into and over water. RULE 105 Outstanding issues from the Minister s perspective 9. The outstanding issues concern clauses (i) and (j) in Rule R105. That is should a resource consent be required if the aerial application of agrichemical and use of machinery follows EPA permissions, manufacturer advice, follows NZS8409:2004 where applicable, follows a risk management plan and is intended to manage pest plant impacts which put at risk the values of the wetland as indicated by a wetland restoration plan, especially where the aerial application of agrichemicals is not widely dispersive. 10. It is my opinion that clauses Rule R105(i) and (j) should be removed, or only apply where a risk management plan such as a spray plan based upon NZS8409:2004 (included as appendix 4 in my primary evidence) or wetland restoration plan has not been developed or followed. 11. In some situations, such as where the control targets are in difficult and sensitive spots aerial application methods are more appropriate rather than trampling through fragile vegetation. 12. Not all aerial application methods are widely dispersive and following appropriate best practice such as limiting flights to suitable weather conditions, using appropriate adjuvants and equipment should limit spray drift and off target damage and spray movement. 13. Potential damage to wetlands by management operations can be managed through risk management plans and a wetland restoration plan. 14. Spray drift which affects neighbouring properties is inconsistent with good practice. There are guidelines in NZS8409:2004 to reduce spray drift. 2

4 15. Dr Crisp s comments, and the retention of clauses (i) and (j) in Rule R105 do not take into account improvements in the use of aerial spraying technologies such as small aerial spray units, i.e. drones. 16. In large scale management operations, agrichemicals permitted for use in wetlands are most likely to indirectly affect bird and other species populations through habitat collapse rather than direct toxicity effects. In my view, balancing biodiversity values such as exotic dominated vegetation versus fauna values is best managed through wetland restoration/management plans. Areas of alignment 17. I support the permitted use of agrichemicals in wetlands in conjunction with a spray plan /environmental assessment and risk management plan, and compliance with EPA permissions and conditions. The wording of clause (h) could be altered to reflect EPA terminology, that is into and over water rather than surface water. 18. I support clauses (f) and (g) to the extent that it also addresses the matters raised in the evidence on behalf of the Director-General of Conservation by Philippe Gerbaux. DAVID HAVELL, DATED this 12 th day of April

5 Appendix 1: Approval letter from EPA to use Metsulfuron, Tricolpyr, Haloxyfop, and Imazapy 4

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8 Appendix 2: Approval letter from EPA to use Aquathol (Endothall) 7

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