environmental risk management authority decision - EPA NZ [PDF]

Apr 16, 1999 - following an additional information request under section 52(1) of the HSNO Act 1996. The application was

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ENVIRONMENTAL RISK MANAGEMENT AUTHORITY DECISION Application code

NOR99001

Application type

Release from containment any New Organism under section 34(1)(b) of the Hazardous Substances and New Organisms (HSNO) Act 1996.

Applicant

Hawke‟s Bay Pipfruit IFP Group 20

Organism

Pseudaphycus maculipennis (Mercet 1923) (Hymenoptera: Encyrtidae)

Purpose

To release from containment the insect Pseudaphycus maculipennis for biological control of the obscure mealybug Pseudococcus viburni (Signoret 1875) (Hemiptera: Pseudococcidae).

Date application received

16 April 1999

Hearing date

09 May 2000

Considered by

A Special Committee of the Authority appointed under section 19(2)(b) of the HSNO Act 1996.

ERMA New Zealand contact

Anne Rose

Decision The application to release from containment the new organism, Pseudaphycus maculipennis (Mercet 1923) (Hymenoptera: Encyrtidae) is granted in accordance with section 38(1)(a) of the HSNO Act. As required under section 38(2), there are no controls on this approval.

Purpose of Application The application is for approval to release from containment the insect parasitoid P. maculipennis, for biological control of obscure mealybug, P. viburni. P. viburni is a polyphagous, cosmopolitan pest with a worldwide distribution. P. viburni was first identified in New Zealand in 1922 and has been a significant pest of pipfruit, particularly in Hawke‟s Bay, since the late 1960s. P. viburni is difficult for pipfruit growers to control because it is cryptic in nature, infesting the calyx of fruit, which makes it difficult to achieve adequate spray coverage. The honeydew produced by P. viburni leads to the development of sooty mould, making fruit unsaleable. Lesser levels of infestation create grading and packing difficulties for export packhouses. Organophosphate insecticides have been the basis of insect control in export apple crops for the last 30 years. These provided effective control of a wide range of insect pests including mealybugs, but since the early 1990s P. viburni has become increasingly resistant to this group of insecticides. There are no alternative insecticides for export apple crops that can be used between flowering and harvest, and this situation is unlikely to change. P. maculipennis is a minute wasp (adults are approximately 1.0-1.5 mm in length). It lays eggs in one developmental stage of the mealybug (usually the third instar, although second instars and

adults are also attacked) and emerges from the next (usually the adult mealybug), killing the host at the same time. One or more progeny may emerge from a single host, depending on host size and perhaps other stimuli at oviposition.

Application Process The application was formally received on 16 April 1999 and verified on 21 December 1999 following an additional information request under section 52(1) of the HSNO Act 1996. The application was publicly notified on 22 January 2000 in The Dominion, The New Zealand Herald, The Press and The Otago Daily Times. Public submissions closed on 03 March 2000. Seven submissions were received, listed in Annex 1. Two submitters requested to be heard at a public hearing in support of their submission. The documents available for the evaluation and review of the application by ERMA New Zealand included the application and appendices (including supporting documentation), public submissions, submissions and comment from other government agencies, and additional information requested by the Authority under section 58 of the HSNO Act from the applicant and other parties. The Authority appointed a Special Committee (the Committee) to determine the application in accordance with section 19(2)(b) of the HSNO Act. The Committee included five members of the Authority: Dr Oliver Sutherland (Chair), Mr Bill Falconer, Mrs Helen Hughes, Professor Colin Mantell and Dr Lindie Nelson, as well as one external member, Dr Murray Parsons (expert in Māori culture and traditions).

Hearing A public hearing was held on 09 May 2000 at the ERMA New Zealand offices in Wellington. Presentations The following parties made presentations to the Committee: For the applicant: 1. Dr Ian Warrington 2. Dr Doug King 3. Mrs Diana Gillum 4. Dr Jim Walker 5. Mr John Charles

CEO (HortResearch) Research & Development Manager (ENZA Ltd) Pipfruit grower and applicant representative Senior Scientist (HortResearch) Senior Scientist (HortResearch)

For ERMA New Zealand: 1. Anne Rose

Project Leader (ERMA New Zealand)

Environmental Risk Management Authority Decision: Application NOR99001

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For Ngā Kaihautū Tikanga Taiao1: 1. John Hohapata-Oke Submitters: 1. Clare Millar 3. Kevin Smith

Ngā Kaihautū Tikanga Taiao Department of Conservation Witness: Lisa Sinclair Royal Forest & Bird Protection Society of New Zealand Inc.

Further information Additional information sought after the hearing and considered by the Committee included: i.

An independent appraisal of the taxonomic status of Pseudococcus zelandicus from Dr DJ Williams (The Natural History Museum, London). This information was sought from Dr Williams on 19 May 2000, to which he responded on 07 June 2000. An additional query was sent to Dr Williams on 08 June 2000, to which he responded on 28 June 2000.

ii. Geographic and habitat details of Pseudococcus zelandicus, based on specimens held in the New Zealand Arthropod Collection and the Natural History Museum, London, England. This information was collated by ERMA New Zealand. The information was forwarded to parties2 to the application on 21 July 2000 for comment by 28 July 2000.

Relevant Legislative Criteria The application was lodged pursuant to section 34(1)(b) of the HSNO Act. The decision was determined in accordance with section 38, taking into account minimum standards under section 36, additional matters to be considered under section 37, and matters relevant to the purpose of the Act, as specified under Part II of the HSNO Act. Consideration of the application followed the relevant provisions of the Hazardous Substances and New Organisms (Methodology) Order 1998 (the Methodology).

Background to Biological Control Biological control, as envisaged in this application, involves the introduction of a natural enemy to control an exotic pest. The natural enemy is usually sourced from the area of origin of the pest, in an attempt to re-establish a natural association. Biological control programmes can be aimed at insect pests and weeds and can involve predators, parasites, herbivores or pathogens to control the pest organism.

Ngā Kaihautū Tikanga Taiao has been formally established under clause 42 of the First Schedule to the Hazardous Substances and New Organisms Act 1996, as a Māori advisory committee, to advise the Authority on how to take account of issues of concern to Māori (particularly in relation to sections 6(d) and 8 of the Act). 1

Parties: Including submitters, the applicant and relevant Government agencies from whom comment on the application was received. 2

Environmental Risk Management Authority Decision: Application NOR99001

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While not always able to bring insect or weed populations down to below threshold damage levels, biological control in combination with other cultural or pest management techniques often gives growers an opportunity to reduce reliance on pesticides. This can have benefits in relation to human health and safety, environmental pollution, development of pesticide resistance, reduction in chemical residues and improved access to premium export markets. However, besides the ability of a biological control agent to establish successfully and reduce target pest populations, a key issue is its target-specificity and the risk of undesirable attack on non-target species. To determine the host range of the potential biocontrol agent, and hence the risk to non-target species that its release might incur, host-specificity testing is undertaken, either overseas or in containment in New Zealand. The potential agent is confined with either a non-target species alone (no-choice) or with both the target and a non-target species (choice) and any attack on the non-target species is recorded and assessed. Usually a range of taxonomically closely-related native and exotic species are tested, as well as other species that are less closely-related but that are significant for their biodiversity and/or economic value. While such tests establish the likely host range of the biocontrol agent, they cannot totally preclude any risk to populations of desirable non-target species. Biological control has formed an integral part of the management of invertebrate pests and weeds in New Zealand from the very early developments of European agriculture in this country. Almost all of the crops grown are of overseas origin and their associated insect pests and weeds have established without most of their natural enemies. For this reason, the importation of natural enemies from the area of origin of these pests has been an important option for control. New Zealand‟s first biocontrol agent, a predatory ladybird beetle, was released in 1874 to control exotic pest aphids. By 1990, a total of 221 species had been deliberately introduced and released for biological control of insect pests and weeds. Seventy-five of these have become established. Several sectors of the agricultural and horticultural industries have developed integrated pest management (IPM) programmes utilising biocontrol agents together with other management techniques, and biological control can be a component of pest management in organic production.

Terminology The Committee has assessed effects in terms of the likelihood of the effect being realised, and the magnitude of the effect. The likelihood of the effect being realised has been assessed on a five point qualitative scale: very unlikely, unlikely, possible, likely, and very likely. The magnitude of adverse effects has been assessed on a five point qualitative scale: minimal, minor, moderate, major and massive. These scales are for comparative purposes only, and only relate to this application. A more complete description of the qualitative scales used to describe the likelihood and magnitude of effects is provided in Annex 2.

Key Issues The Committee considers that the key issue associated with the release of P. maculipennis is the potential adverse effect on native fauna arising from non-target parasitism of Pseudococcus zelandicus Cox 1987 (Pseudococcidae), an endemic mealybug. Should any significant parasitism of P. zelandicus occur, this would pose a risk to New Zealand‟s endemic biodiversity and to species regarded as taonga by Māori.

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Five species of mealybug within the genus Pseudococcus are recorded to be present in New Zealand. Four of these species, namely P. longispinus, P. viburni (synonym P. affinis), P. calceolariae (synonym P. similans) and P. hypergaeus are exotic species that are considered pests or potential pests of fruit crops in New Zealand. The sole native species is Pseudococcus zelandicus. P. zelandicus was not included in the host-range tests, therefore there is uncertainty as to whether P. maculipennis could parasitise the native mealybug. Concern about adverse effects on P. zelandicus was raised by a number of submitters. The Committee considered that non-target parasitism of P. zelandicus depends on both its susceptibility and exposure to the parasitoid (P. maculipennis). The Committee evaluated susceptibility on the basis of the known host range of P. maculipennis overseas, host-range test results, and existing knowledge of the taxonomy of P. zelandicus. Exposure was evaluated on the basis of information about habitat and geographic separation. As discussed below, the Committee concluded that P. zelandicus is very unlikely to be susceptible to sustained parasitism by P. maculipennis and the magnitude of the effect of any occasional attack would be minimal. Under these circumstances, absence of host-range test data on P. zelandicus does not cause a level of uncertainty sufficient to decline this application. Host range of P. maculipennis The applicant states that Hymenoptera in the family Encyrtidae, to which the genus Pseudaphycus belongs, are among the most host-specific parasitoids known, especially those that attack mealybugs (Moore 1988). Worldwide, all species of parasitoids in the genus Pseudaphycus are restricted to hosts in the family Pseudococcidae, to which P. viburni belongs. P. maculipennis has only been recorded to parasitise P. viburni in the field: on this evidence P. maculipennis displays monophagy. Field studies by HortResearch have shown that exotic mealybugs are attacked by exotic parasitoids, while native mealybugs are attacked by native parasitoids. These data (Charles 1993) and those of Noyes (1988), based on almost 100 years of collecting, indicate that monophagy or very narrow oligophagy is the norm among encyrtids that attack mealybugs. HortResearch concludes that co-evolution has resulted in a highly adapted physiology that allows survival of the parasitoid in a particular mealybug but not others. Such advanced co-adaptation is not easily broken or changed. Host-range testing The applicant reports that host-specificity tests have been carried out against 17 species in 15 genera in Europe, Australia and New Zealand. These tests also show that P. maculipennis is effectively monophagous, and conforms to the global norm for Encyrtidae that attack mealybugs. In „no-choice‟ host-range tests conducted in New Zealand by HortResearch on behalf of the applicant, five non-target species were tested: three native mealybug species that are commonly found in the vicinity of pipfruit orchards (Paracoccus zelandicus, Dysmicoccus ambiguous and Balanococcus diminutus) as well as two exotic mealybugs present in pipfruit crops in New Zealand (Pseudococcus longispinus and P. calceolariae). In these tests, P. longispinus was the only non-target species attacked (at a level of approximately 8.7%). An average of 1.8 parasitoids emerged from each infested P. longispinus, whereas 3.1 parasitoids emerged from each infested P. viburni. The applicant concludes that these data show that P. longispinus is a highly unfavourable host.

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The Committee considers that non-target parasitism of P. longispinus by P. maculipennis in the field would not be an adverse effect, as P. longispinus is an exotic pest of crops including pipfruit, citrus, persimmon and grapes in New Zealand. P. longispinus was also included in both the Australian and Netherlands host-range tests, however it was not attacked in either case. This result suggests differences in the testing methodology or ecotype differences between either the parasitoids or host mealybugs used in overseas tests, compared with those used in New Zealand. The applicant has confirmed that the parasitoid ecotype used in all host-range tests were the same and all sourced from the same California insectiary. The applicant was unable to test the only known native species of Pseudococcus (P. zelandicus), as several searches for specimens were unsuccessful. The Committee accepts that P. zelandicus may be difficult to find in the field, because it appears to occur in low numbers on a few plant species at subalpine altitudes (refer to habitat and geographic separation section). The applicant may, however, have been able to conduct field searches that were better targeted in order to collect the insect. Taxonomy The applicant considers there is significant doubt that P. zelandicus is in fact a species of Pseudococcus, suggesting that it may be more appropriately removed to the genus Chorizococcus. Should P. zelandicus not belong to the genus Pseudococcus it could be considered less likely to be susceptible to attack by P. maculipennis. The Committee sought clarification of the taxonomic status of P. zelandicus from Dr DJ Williams (research associate of the Natural History Museum, London), a world authority on Pseudococcidae. Dr Williams confirmed, following examination of the specimen held at the Natural History Museum, that although P. zelandicus is unusual for the genus Pseudococcus, it is nonetheless best left in that taxon. Dr Williams noted that “In most species of Pseudococcus there are more cerarii, usually as many as 17 pairs, and the circulus, if present, is normally larger and divided by the intersegmental line. P. zelandicus may have affinities with Chorizococcus but the last 3 pairs of cerarii in P. zelandicus are on sclerotized areas and at least the penultimate pair and sometimes the third pair possess auxiliary setae. These are not characters associated with Chorizococcus” (correspondence dated 07 June 2000). The Committee accepts Dr Williams‟ view that P. zelandicus is best considered as being within the genus Pseudococcus. Although Dr Williams does not consider that P. zelandicus belongs in the genus Chorizococcus, he made particular note of the taxonomic similarities between the genera Pseudococcus and Dysmicoccus (which has seven endemic species in New Zealand). Dr Williams asserts that the taxonomy of the genera Pseudococcus and Dysmicoccus is „confused‟ and that “the assignment of many species to both genera is arbitrary at present” (correspondence dated 28 June 2000). Dr Williams notes that from DNA and other evidence there is little difference between the genera Pseudococcus and Dysmicoccus though their type specimens are distinct. He noted that “At present, Pseudococcus and Dysmicoccus are regarded as distinct genera and are separated by the presence of oral rim ducts in Pseudococcus and their absence in Dysmicoccus” but added that “I understand that unpublished data on DNA studies conducted in Australia, indicate that there is little difference in specimens selected from species assigned to Pseudococcus and Dysmicoccus” (correspondence dated 07 June 2000). Regarding the taxonomic similarity between Pseudococcus and Dysmicoccus, Dr Williams stated that “if P. maculipennis does not parasitise Dysmicoccus ambiguous, I doubt very much if the other six

Environmental Risk Management Authority Decision: Application NOR99001

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species of Dysmicoccus in NZ would be parasitised” (letter dated 28 June 2000). Hence, and by implication, the Committee considers if the New Zealand dysmicoccids and pseudococcids are not well separated taxonomically, then failure of the parasitoid to attack D. ambiguous provides some reassurance that it would not attack P. zelandicus. Dr Williams also asserts in both letters his view that he “doubts very much that Pseudaphycus maculipennis would [parasitise] Pseudococcus zelandicus”. In discussion with the Committee, he clarified that this conclusion is a professional judgement, based on evidence of the parasitoid‟s host-specificity, and the unusual characteristics of P. zelandicus as a Pseudococcus species. Habitat and geographic separation A key issue determining the relative impact on non-target hosts is the degree of environmental overlap in space (habitat, latitude and altitude), as this influences the exposure of non-target hosts to the parasitoid. The applicant asserts that P. viburni and P. zelandicus have no recorded host plants in common and are generally found in different habitats. Since 1922, P. viburni has been recorded only from exotic plants in modified habitats, from the north of the North Island to at least as far south as Central Otago in the South Island. In contrast, P. zelandicus has only been recorded on native plants in subalpine habitats (Astelia nervosa (synonym A. cockaynei) (Liliaceae), Microlaena sp., M. avenacea, and Poa cita (Poaceae) (synonym P. laevis) (Cox 1987)). P. viburni has not been recorded on any hosts in the Liliaceae and Poaceae plant families. The Committee notes that there is overlap in the ecological range of the host plants of P. viburni and P. zelandicus. In this situation, exposure of P. zelandicus to the parasitoid cannot be ruled out. P. zelandicus is thought to be widely dispersed in both the North and South Islands, although it appears that it is only found in low numbers. A total of 22 specimens of P. zelandicus have been recorded in the literature. Cox (1987) lists 12 females in the type series collected from Minginui State Forest, Otupaka Clearing, Taupo by John Dugdale in 1977. These specimens are held in the New Zealand Arthropod Collection, Mt. Albert, Auckland, and the Natural History Museum. Cox (1987) lists a further 10 females (non-type series), collected from the Taupo, Nelson, Kaikoura, Buller and Central Otago localities. Collection records of P. zelandicus suggest that its natural habitat is the subalpine zone (ie above the tree line but below permanent snow line), eg Mt Arthur (Nelson): altitude approximately 1200m; Rock & Pillar Range (Central Otago): altitude approximately 1000-1045m; and Minginui (Taupo): altitude approximately 600m. The Committee notes that species in the genera of the host plants of P. zelandicus are commonly grown in low altitude gardens. However there are no records of P. zelandicus being found on plants in home or public gardens, or in agricultural environments. The Committee concludes that P. zelandicus is very uncommon in modified habitats and may be restricted to subalpine habitats. It is possible that P. viburni and P. maculipennis could occasionally survive in subalpine habitats, thereby exposing P. zelandicus to potential attack by the parasitoid, although the evidence of known host range of P. maculipennis suggests that attack is unlikely. In the unlikely event of occasional attack, the Committee considers that the magnitude of the effect of the parasitism on P. zelandicus populations would be minimal, because the subalpine habitat in which P. zelandicus is known to exist is extensive and because the host plants of P. zelandicus are common in subalpine areas. Both aspects indicate a large potential population reservoir, regardless of whether P. zelandicus itself is common or sparse.

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Habitat separation serves to minimise the opportunity for P. maculipennis to behaviourally or genetically adapt to P. zelandicus over time through constant exposure. The Committee considers that the recorded monophagy of P. maculipennis in field records and the high degree of hostspecificity among Encyrtidae that attack mealybugs provide additional reassurance that P. maculipennis will remain monophagous. The Committee acknowledges that it is impossible to predict the rate of evolution of host range for biological control agents in the long-term. The coincidence in the environment of new behaviours, suitable physiological compatibility, and establishment of new genetic traits within a parasitoid population would be important in determining host range extension. Host range extension would be more likely to include species that are closely related to existing hosts, and occur in the same habitat. However, the Committee considers it is very unlikely that there would be any adverse effect on native mealybugs in the long term due the high degree of hostspecificity in the parasitoid, taxonomic differences as identified by Dr Williams, and substantial habitat separation.

Potential Effects The Committee has categorised potential adverse and beneficial effects of this application into environmental, human health, cultural and economic effects. Benefits associated with the release of P. maculipennis are considered to be dependent on the parasitoid establishing and exerting control over P. viburni. Based on results of biological control programmes overseas (France and the Republic of Georgia), laboratory tests, and results of biological control programmes involving Encyrtidae in general, the applicant expects P. maculipennis to establish and spread throughout the range of obscure mealybug in New Zealand, reaching some ecological stability about five years after release. While knowledge of hostparasitoid relationships can assist in establishing a biocontrol agent, the degree of control is largely unpredictable because it is largely a function of the particular parasitoid-host-environment combination (P. Cameron, expert reviewer). Although the potential efficacy is unknown, the Committee considers that it is likely the parasitoid would establish and exert a degree of biological control of P. viburni, and that achievement of at least 25% control of P. viburni infestation five years after release is plausible. It is considered that efficacy of P. maculipennis against P. viburni would be likely to continue in the long term. Environmental Effects The Committee has considered potential adverse and beneficial environmental effects of releasing P. maculipennis on flora, fauna and ecosystem integrity. Adverse environmental effects The potential adverse impacts on the endemic mealybug, P. zelandicus, were identified as a primary concern. As discussed above, the Committee considers that it is very unlikely that parasitism of P. zelandicus by P. maculipennis would occur in the field, based on information on the known host range of P. maculipennis overseas, host-range test results, and existing knowledge of the taxonomy and habitat of P. zelandicus in New Zealand. The Committee recognises that submitters have raised concerns about additional non-target effects. Given the incomplete state of knowledge of the insect fauna in New Zealand, a concern that naturally arises from this application is the possible existence of undiscovered and/or undescribed species of Pseudococcus in addition to P. zelandicus. The Committee considers that in Environmental Risk Management Authority Decision: Application NOR99001

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this instance it must reach a decision on the basis of the known, but incomplete, taxonomy and description of New Zealand‟s invertebrate fauna. The Committee also notes that future biological control programmes that might involve the introduction of a mealybug species for weed control should consider the potential for parasitism by P. maculipennis if it is released and establishes. The Committee also recognises that submitters have raised concerns about indirect environmental effects of releasing P. maculipennis. The Committee notes that: Apart from parasitism of P. viburni, there is no evidence to suggest that P. maculipennis is capable of attacking, biting, stinging, forming swarms of nuisance value, or acting as a vector of animal or plant pathogens, other than passively as it moves around in the environment, possibly picking up fungal spores etc, in the way that all similar insects might do. Therefore it is very unlikely that P. maculipennis could represent a threat to animal or plant health. It is very unlikely that P. maculipennis would interbreed with other insect species in New Zealand, given there are no native or introduced species of Pseudaphycus recorded to be present in New Zealand. It is very unlikely that P. maculipennis would compete with or displace native natural enemies of insects (including parasitoids and predators). There are no records that P. viburni is attacked by specialist natural enemies in New Zealand. Although generalist predators may occasionally attack P. viburni, it is not considered that a generalist insect would be dependent on P. viburni for population survival. The applicant states that all native mealybugs are subject to native parasitoids, although the Committee notes that there are no specific records of native parasitoids of P. zelandicus. The Committee considers that non-target parasitism of P. zelandicus is very unlikely and, consequently, that displacement of any native parasitoid is equally unlikely. There is no evidence to suggest that P. maculipennis could contribute to deterioration of natural ecosystems. P. viburni and other mealybugs in the Pseudococcidae are phytophagous (ie herbivorous), therefore reduction in their populations is unlikely to threaten plant survival directly and, therefore, the survival of any other insects, birds etc that depend upon those plants. Beneficial environmental effects The Committee considers there is a risk to biodiversity, including populations of beneficial and native insects, arising from the particular insecticide used to control P. viburni (broad-spectrum organophosphate) and patterns of its use (several sprays each season). Use of broad-spectrum organophosphates in the pipfruit industry is expected to decline in the future due to development of insecticide resistance in P. maculipennis. Hence adverse environmental effects of spray programmes to control obscure mealybug are likely to decline in future unless replacement sprays have similar, or worse, environmental effects. Nevertheless, the Committee considers that, as long as the parasitoid exerts some degree of control over P. viburni, reduced insecticide use in the pipfruit industry is likely. Consequently reduced environmental pollution such as harmful soil residues, and reduced adverse effects on non-target organisms, such as mortality of native and valued insects inhabiting modified environments, are expected.

Environmental Risk Management Authority Decision: Application NOR99001

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The Committee notes that the New Zealand Fruitgrowers Federation and Lincoln University identified benefits to the environment from reduced chemical sprays in their submissions. The Ngatiwai Trust Board and Te Rünanga o Ngäi Tahu also acknowledged these potential benefits. Human Health Effects The Committee has considered potential beneficial and adverse effects of releasing P. maculipennis on human health. As noted above, the Committee considers that, as long as the parasitoid exerts some degree of control over P. viburni, benefits to human health will arise from reduced insecticide use. Reduced insecticide use is likely to result in reduced pesticide residues on pipfruit for consumption, reduced exposure of spray operators, orchard workers and bystanders to insecticides, and reduced spray-drift from orchards. The Committee notes that P. maculipennis does not attack, bite or sting people, form swarms of nuisance value, or act as a vector of human pathogens. Therefore it is very unlikely that P. maculipennis could represent a threat to human health. Cultural Effects The Committee considered potential effects associated with releasing P. maculipennis on the relationship of Māori and their culture and traditions, with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna, and other taonga (section 6(d) of the HSNO Act). In doing so, potential adverse impacts on non-target species and particularly indigenous flora and fauna, were identified as primary concerns. No separate or distinct cultural or spiritual concerns were raised (ie outside the concerns about environmental impacts). The Committee considers that the applicant‟s consultation on this application has been as extensive as could be reasonably expected. The consultation was based on a nationwide list of key iwi contacts, provided by ERMA New Zealand, with an emphasis on Bay of Plenty, Whangarei, Gisborne, and Hawke‟s Bay. The applicant sent out letters to 37 iwi and Māori groups and received back eight responses. Of the responses, three opposed the application, three did not oppose, and two requested further information. In addition, public submissions were received from Ngatiwai Trust Board and Te Rünanga o Ngāi Tahu. The Ngatiwai Trust Board commented in their submission that “While the Unit endorses the use of biocontrol instead of pesticides we do not support the introduction of any exotic species that potentially could become an environmental problem in the future.” Ngāi Tahu commented in their submission that “New Zealand has a unique and precious environment with a much vaster array of indigenous plants, insects, and animals than possibly any other country in the world. This uniqueness has suffered a great deal of damage in the past through introduced species…Ngāi Tahu wish the Authority to take a conservative approach to this matter and not consider it in isolation”. The Committee has taken into account the views of Ngā Kaihautü Tikanga Taiao, which stated in its report to the Authority that “The submissions from iwi organisations favour biological control if it will reduce the use of many insecticides. There is a basic concern centred around preserving native species from introduced parasitoids and there is a belief that introducing more insects will be detrimental to native species in the long run” and that “Ngā Kaihautü Tikanga Taiao recommends that further testing of the impact of the insect parasitoid Pseudaphycus maculipennis on native mealy bugs takes place before it is released from containment.” Although all Māori would be concerned about significant adverse effects to native and valued species, the Committee considers that significant non-target parasitism of P. zelandicus and

Environmental Risk Management Authority Decision: Application NOR99001

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adverse effects on other flora and fauna by P. maculipennis are very unlikely in the field. The Committee therefore considers there would be no significant adverse effects to the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, valued flora and fauna, and other taonga from the release of P. maculipennis. The Committee recognises there is a lack of awareness about biological control in general among Māori, and endorses the applicant‟s intention for a biocontrol education programme for Māori. HortResearch, on behalf of the applicant, has noted that discussions have been initiated with the New Zealand Māori Council to this end. HortResearch has stated a commitment to develop an education package regardless of the outcome of this application. The Committee also recognises that HortResearch, on behalf of the applicant, intends to conduct post-release monitoring of environmental effects, including non-target parasitism, as part of their proposed release programme. Post-release monitoring is also important should the release fail, as it will be valuable to understand and record the scientific reasons for this outcome. While the Committee cannot attach controls to the release of a new organism, it endorses the applicant‟s intention to follow through with monitoring and make these results available to iwi. Economic Effects The Committee has considered potential effects of releasing P. maculipennis on the economy, particularly the pipfruit sector. It is noted that P. viburni is a major pest of commercial pipfruit orchards and is currently controlled by broad-spectrum organophosphate insecticides, or insect growth regulators in orchards where obscure mealybug is developing resistance to organophosphates. P. maculipennis would assist organic pipfruit growers who currently have no effective natural control options for P. viburni. Mealybug resistance to organophosphate spray was first detected in 1993, in Hawke‟s Bay. Since then it has become widespread in Hawke‟s Bay orchards and is now developing in Nelson orchards. The applicant has noted that the pipfruit industry has only one product remaining that is still effective for mealybug control, „Applaud‟. This is a selective insect growth regulator pesticide that does not affect many important beneficial insects. However „Applaud‟ cannot be used to control mealybugs after flowering because its residues, which are highly persistent on fruit, are unacceptable in major export markets such as the USA. The applicant asserts that no new, highly effective products for mealybug control are likely to be available to New Zealand apple growers in the near future, noting that investment on mealybug control in New Zealand apple crops is not economically viable for large multi-national agrichemical companies. Given the decreasing effectiveness and acceptability of organophosphate sprays, there is likely to be increasing fruit loss and increased use of insect growth regulators, along with increased costs of fruit residue management. Should the biocontrol agent establish, its principal benefit would be in reversing or stemming the foreseeable downward trend in export value for pipfruit. The downward trend is attributable to rising fruit damage and loss, increases in mealybug control costs, and restricted access to premium export markets. The Committee considered the monetary cost-benefit analysis developed by ERMA New Zealand, showing a positive net present value across a range of six scenarios over a twenty-year time horizon. The scenarios are developed from two levels of costs and losses attributable to P. viburni, and three levels of efficacy of P. viburni control by P. maculipennis. The „low‟ efficacy profile was based on 25% control of P. viburni infestation 5 years after release. The „high‟ efficacy profile was based on 75% control after 5 years. While recognising the uncertainty attached to the actual figures, and noting the underlying assumptions, the Committee is satisfied that the

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monetary benefits substantially outweigh the monetary costs even under conditions of low efficacy and low costs and losses. The Committee also notes that these scenarios may underestimate the net present value since they assume a constant level of annual fruit damage, whereas increasing difficulties with mealybug control are likely to lead to rising levels of annual fruit damage. Even under conditions of low efficacy and low costs and losses, the Committee considers that direct monetary benefits from the introduction of P. maculipennis to the pipfruit industry would be expected from: Reduced losses due to fruit damage. Reduced insecticide costs associated with control of obscure mealybug Reduced post-harvest and residue-management costs identification, shipping penalties, and cool storage costs)

(including

mealybug

Other potential economic benefits include: Enhanced effectiveness of IPM programmes for pipfruit crops. Organophosphates that are currently used to control P. viburni, damage beneficial insects that form part of the IPM approach. Improved access to premium export markets. The growing demand in export markets for fruit free of pesticide residues means that such fruit could be expected to sell for higher prices. Reduced P. viburni damage to other horticultural crops, including citrus and grapes, and ornamentals. A viable option to control P. viburni for organic growers. Slower increase of P. viburni resistance to existing insecticides. The Committee notes that the New Zealand Fruitgrowers Federation, Lincoln University and MAF identified industry benefits from reduced chemical sprays in their submissions. Te Rünanga o Ngāi Tahu also acknowledged this potential benefit. The Committee considers that there is a persuasive economic case for the introduction of P. maculipennis. Monetary benefits from this biological control programme would be expected to accrue primarily to growers and other parties directly involved in the pipfruit industry.

Minimum standards Section 36 of the HSNO Act requires the Committee to decline the application if the new organism is likely to: cause any significant displacement of native species within its natural habitat; or cause any significant deterioration of natural habitats; or cause any significant adverse effects on human health and safety; or cause disease, be parasitic, or become a vector for human, animal, or plant disease, unless the purpose of the importation or release of the new organism is to cause disease, be parasitic, or a vector for disease.

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The Committee considered the minimum standards in section 36 of the HSNO Act, and is satisfied that release of P. maculipennis would not fail to satisfy these standards. In particular, potential parasitism of P. zelandicus is considered very unlikely to cause significant displacement of this species, or its native predators or parasitoids, within their natural habitat. It is also very unlikely that P. maculipennis will interbreed with any native species and adversely affect New Zealand‟s inherent genetic diversity because there are no other species of Pseudaphycus in New Zealand. Significant deterioration of natural habitats could arise if P. maculipennis parasitised a non-target mealybugs that played a key role in keeping a weed or invasive plant species under control. No evidence of native mealybugs playing such a role in natural environments has been found.

Approach to risk Under clause 33 of the Methodology, the Authority must have regard to the extent to which the following risk characteristics exist: (a) exposure to the risk is involuntary (b) the risk will persist over time (c) the risk is subject to uncontrollable spread and is likely to extend its effects beyond the immediate location of incidence (d) the potential adverse effects are irreversible (e) the risk is not known or understood by the general public and there is little experience or understanding of possible measures for managing the potential adverse effects. The Committee considers that in this application the risk of non-target parasitism of the native mealybug is involuntary, will persist, is largely irreversible and uncontrollable, and is not particularly well understood by the general public. The Committee is willing to tolerate these risk characteristics because the probability of the adverse effect eventuating is considered very low and the benefits, should the biocontrol agent become established and exert control over P. viburni, are likely to be substantial.

Overall evaluation of risks, costs and benefits and conclusions 1.

Pursuant to section 38(1) of the HSNO Act, the Committee is satisfied that this application is for one of the purposes specified in section 34 of the Act, being section 34(1)(b): To release from containment any new organism.

2.

Pursuant to section 38(1)(a)(i) of the HSNO Act, the Committee is satisfied that the application should not be declined under the minimum standards specified under section 36 of the HSNO Act.

3.

In relation to the additional matters to be considered under section 37 of the HSNO Act, the Committee notes that the purpose of the release of P. maculipennis is to establish a selfsustaining population. Establishment of a self-sustaining population would be desirable and irreversible in nature.

4.

The Committee formed the view that not all the risks associated with the release of P. maculipennis are negligible. There is a risk that P. maculipennis may parasitise the non-target

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endemic mealybug, P. zelandicus. Therefore the Committee has considered this application in terms of clause 27(1) of the Methodology. 5.

In reaching its decision, the Committee noted that: The primary environmental concern was the potential adverse impact on the endemic mealybug, P. zelandicus. Significant non-target parasitism of P. zelandicus by P. maculipennis is very unlikely in the field, based on information on known host range of P. maculipennis overseas, host-range test results, and existing knowledge of the taxonomy and habitat of P. zelandicus in New Zealand. No other significant adverse environmental effects are considered likely. A recognised taxonomic specialist has confirmed the identification of the parasitoid held in quarantine containment by HortResearch as P. maculipennis. Therefore, it is extremely unlikely that a parasitoid other than P. maculipennis would be released. Release of inseparable organisms is very unlikely. P. maculipennis was imported into quarantine in December 1997, and held in containment since then. The population has been tested and remains free of hyperparasitoids and insect pathogens, as required by the Import Health Standard issued under by MAF under the Biosecurity Act 1993 (MAF permit number 19970011049). There is no evidence to suggest that P. maculipennis could become a vector of insectborne human, animal or plant pathogens, other than passively as it moves around in the environment, possibly picking up fungal spores etc, in the way that all similar insects might do. The risks to the relationship between Mäori and their taonga relate primarily to potential adverse impacts on non-target species and particularly indigenous flora and fauna. However, no significant adverse environmental effects are likely. No separate or distinct cultural or spiritual concerns have been identified. Benefits associated with the release of P. maculipennis are dependent on the parasitoid establishing and exerting control over P. viburni. From evidence provided by the applicant regarding P. maculipennis biological control programmes overseas and hostspecificity tests in containment, it is likely the parasitoid will establish and that a degree of biological control of P. viburni is likely. Efficacy against P. viburni is likely to continue in the long term. Reduced use of insecticides in pipfruit spray programmes is likely to result in health and environmental benefits. Human health benefits would eventuate through reduction of pesticide residues on pipfruit, reduced exposure of spray operators, orchard workers and bystanders to insecticides, and reduced spray-drift from orchards. Environmental benefits would result from a reduction in adverse effects of insecticides on non-target species, primarily in modified environments. This will enhance local biodiversity, including beneficial insects (eg other biological control agents) that are, at present, adversely affected by insecticides in pipfruit orchards. There is a persuasive economic case for the introduction of P. maculipennis for biological control of P. viburni. Monetary benefits will accrue primarily to the pipfruit industry. Monetary benefits include reduced fruit damage and loss, reduced insecticide and post-harvest management costs, enhanced effectiveness of IPM programmes,

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options to control obscure mealybug in organic orchards, and opportunities to maintain and expand access to high-value premium export markets. The financial benefits are likely to substantially exceed financial costs. The estimates of benefit are uncertain, because the potential efficacy of the parasitoid in New Zealand is unknown, and because it is difficult to calculate the total present and future damage to fruit attributable to P. viburni. However, if the parasitoid did not establish, the Committee considers that it is very unlikely that the release would have any adverse effects. No adverse effects are expected because the Committee considers that it is unlikely there will be any significant non-target parasitism of native species, including P. zelandicus. Having considered all the possible effects of the organism, any inseparable organisms and the matters in section 37, in accordance with section 38(1)(a)(ii) of the HSNO Act, the Committee considers that the potential positive effects of releasing P. maculipennis outweigh the potential adverse effects. The application to release from containment the new organism, Pseudaphycus maculipennis (Mercet 1923) (Hymenoptera: Encyrtidae) is thus granted in accordance with section 38(1)(a) of the HSNO Act. As required under section 38(2), there are no controls on this approval. Under section 38(3) of the HSNO Act, the approval to release P. maculipennis shall lapse five years after the date of the approval, unless the organism is sooner released, or the Authority, following an application by any person before the expiry of the time limit, extends the time limit for a further period of up to five years. Under section 38(4) of the HSNO Act, every person who releases P. maculipennis in accordance with this approval within five years after the date of the approval shall, unless the requirement is waived by the Authority, notify the Authority within one month after the date of release.

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References Charles, J.G. 1993. A survey of mealybugs and their natural enemies in horticultural crops in North Island, New Zealand, with implications for biological control. Biocontrol Science and Technology 3: 405-418. Cox, J. M. 1987. Pseudococcidae (Insecta: Homoptera). Fauna of NZ 11. DSIR Science Information Publishing Centre, Wellington, New Zealand, 230 pp. Moore, D. 1988. Agents used for biological control of mealybugs (Pseudococcidae). Biocontrol News and Information 9, 209-225. Noyes, J.S. 1988. Encyrtidae (Insecta: Hymenoptera). Fauna of NZ 13. DSIR Science Information Publishing Centre, Wellington, New Zealand, 188pp.

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Annex 1 List of submitters on Application NOR99001 No.

Name

Organisation

Position

Address

1

Ngatiwai Trust Board

Hori Parata

Resource Management Unit Convenor

PO Box 1332

WHANGAREI

No

2

Department of Conservation

Clare Miller

New Organisms Officer

PO Box 10 420

WELLINGTON

Yes

3

New Zealand Fruitgrowers Federation

Peter Silcock

Chief Executive

PO Box 2175

WELLINGTON

No

4

Lincoln University

Drs R M Emberson and R R Scott

Senior Lecturer in Entomology and Groups Leader, Ecology & Entomology Group

PO Box 84

Lincoln University

CANTERBURY

No

5

Te Rünanga o Ngäi Tahu

Linda Constable

Natural Resources Manager

Office of Te Rünanga o Ngäi Tahu

PO Box 13046

CHRISTCHURCH

No

6

Royal Forest & Bird Protection Society of New Zealand Inc

Kevin Smith

Conservation Director

PO Box 631

WELLINGTON

Yes

7

Ministry of Agriculture and Forestry Biosecurity Authority

Suzanne Main

Policy Adviser

PO Box 2526

WELLINGTON

No

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Request to be heard

Annex 2: Qualitative scales for describing effects Qualitative assessments use words to describe the probability or likelihood of the adverse effect occurring and the magnitude, or a measure of the severity of that adverse effect. These are combined to form a qualitative estimate of the level of risk. Tables 1-3 describe the word scales used for likelihood, magnitude of adverse effects and magnitude of beneficial effects. Table 1: Likelihood of effect Descriptor

Description

Very unlikely

Not impossible, but only occurring in exceptional circumstances

Unlikely

Could occur, but is not expected to occur under normal conditions

Possible

50:50 chance of occurring, or where there is insufficient information to judge likelihood otherwise

Likely

Will probably occur at some time

Very likely (almost certain)

Is expected to occur

Table 2: Magnitude of adverse effect Descriptor

Examples of descriptions

Minimal

Insignificant (repairable or reversible) environmental impact, no observable cultural effects, other effects slight (reversible) or very small

Minor

Reversible environmental impact, limited adverse cultural effects (affecting small area or localised community), other effects small and limited in scope

Moderate

Some slight effect on native species, adverse cultural effects to wider area but not considered serious, other effects medium or mid range

Major

Irreversible environmental effects but no species loss, adverse cultural effects widespread but remedial action available, other effects large

Massive

Extensive irreversible environmental effects, including species loss, adverse health effects, severe adverse cultural effects over whole country with no possible remedial action, other effects very large and widespread

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