Search BIREA:

View:   short pages · print version

Applying for general release or release with controls

top

Preparing to make an application

The following guidance is given for the development and preparation of an application to the EPA to import for release, or release from containment, or release with controls predators, parasitoids, herbivores or pathogens for the purpose of biological control of a plant, animal or disease. This advice does not apply to genetically modified new organisms, or to introduction of a new organism under emergency, or to the introduction of any material for medical or veterinary purposes.

In the course of introducing a new biological control agent, the applicant may need to import the organism into containment for further evaluation of efficacy of the biological control agent, and host range specificity testing.

In order to determine whether the organism proposed for introduction is indeed a new organism, applicants should refer to the EPA web page . It is also possible to submit an application to or not.

The steps in the process of applying for approval to introduce a new biological control agent for general release (with and without controls) are as follows:

  1. Selection of the biological control agent
  2. Pre-application consultation with
    • EPA staff
    • DOC
    • MPI
    • Maori
    • Other stakeholders and interest groups
  3. Preparation for an application
  4. Identification and assessment of risks and benefits
  5. Formal receipt of application
  6. Post-application processes
  7. Public submissions on the application
  8. Staff assessment report (report prepared by the EPA)
  9. Public hearing (if required) before the Authority
  10. Consideration by decision-making committee
  11. Decision
  12. Notification of Decision

As much as the content of the proposal is important, it is the quality of the process by which the application is prepared that will give the EPA confidence that the applicant has addressed all relevant factors. Gaining that confidence is likely to reduce statutory delays and ensure the rapid evaluation of the proposal. For that reason, it is important for applicants to be thorough, frank, open and inclusive when assembling the information that EPA requires. The first step in preparing an application should be to contact an EPA New Organisms Advisor [http://www.epa.govt.nz/Contact-us/Pages/Contact-us.aspx] and develop a dialogue.

For most applications to import a new organism the primary concern is the risk that the organism will form an unwanted population in New Zealand, that will have adverse environmental effects.

Clause 33 of the Methodology states:

"When considering an application, the Authority must have regard to the extent to which the following risk characteristics exist:
(a) Exposure to risk is involuntary
(b) The risk will persist overtime
(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 means of managing the potential adverse effects."

In accordance with clause 33 of the Methodology, the Authority is likely to be more cautious and risk averse according to the extent to which these risk characteristics exist.

New organisms released as biological control agents will usually exhibit all of these characteristics because that is what the applicant intends. To become successful, the agent must establish, populations must be self-sustaining, and biological control agents must spread to attack the host in its entire range. In considering risks for biological control agents, the EPA have to balance the acceptable characteristics intended for a beneficial biological control outcome with those risks which relate to unintended outcomes. top

Selection of a biological control agent

Although it is discussed briefly elsewhere, it is beyond the scope of this document to review how to select organisms to be biological control agents for pests, diseases or weeds except as these issues influence risk assessment and the application process. top

Pre-application consultation

Consultation is the continuous dialogue that takes place between an applicant and those who might have an opinion about the proposal, both for and against. Consultation does not mean negotiating consensus or agreement, but does mean:

Public participation and consultation are key requirements of the EPA process. An open and transparent consultation process is likely to expedite the consideration of an application by reducing interactions between the applicant, the EPA, and/or potential submitters.

Effective consultation before and during the application process, is likely to reduce the level of opposition to the application, or if not, it will better inform the process. Applicants are therefore advised to identify all those with a significant interest in the outcome in the application at the outset, and enter into dialogue at an early stage of project development. This should include organisations that are expected to oppose the concept as well as likely supporters. top

Consultation with the EPA

The key relationship is with EPA staff [http://www.epa.govt.nz/Contact-us/Pages/Contact-us.aspx]. Once you have confirmed that an application is pending, you will be assigned a New Organisms Advisor who will facilitate the application process. The EPA Maori Policy and Operations team will provide advice on consultation with Maori and developing dialogue with Iwi and Maori organisations.

Economic analysis of the benefits and costs of the proposed project is vital to a successful application. However, the nature and extent of that analysis will vary from case to case depending on the quality of the economic data available for analysis. There is little value in undertaking exhaustive analysis if the base data are poor or unreliable because the conclusions will be questionable. Consult EPA staff to discuss the level of analysis that is appropriate to the quantity and quality of the data available.

Strong evidence of the importance of the pest and the potential impact of the proposed biological control agents are powerful components of an application. If adequate information does not already exist, applicants should consider commissioning research in this area before the application is completed. top

Consultation with the Department of Conservation

The Department of Conservation (DOC) administers legislation that has direct relevance to the application of biological control in New Zealand. The Conservation Act 1987 was developed to promote the conservation of New Zealand's natural resources including management for conservation purposes of all land and natural resources held under the Act. The National Parks Act 1980 directs to preserve native plants and animals and remove introduced ones from National Parks, as far as is possible, and to preserve soil, water and forest conservation values. Similarly, the Reserves Act 1977 seeks the preservation of representative natural ecosystems or landscapes and the survival of indigenous species of flora and fauna, both rare and commonplace. DOC is also charged with safe-guarding some absolutely protected wildlife throughout New Zealand under the Wildlife Act 1953. Under these statutes DOC has an active role in protecting New Zealand's unique biota and ecosystems, and the provision of recreational opportunities.

Section 58 of the HSNO Act specifies that the Authority:

"Shall consult with all departments or Crown entities notified of the application in accordance with section 53 (4) of this Act and, where any application is for approval to import, develop, field test, or release a new organism, have particular regard to any submissions made by the Department of Conservation."

Consequently, DOC needs to advise the Authority so that possible impacts on the New Zealand environment, flora or fauna (directly or indirectly) which are likely to result from the introduction of a new organism are fully considered. DOC is likely to have particular concerns where the biological control agent will come into intimate contact with native ecosystems, for example when the target is a pest of indigenous landscapes, or the biological control agents are likely to be abundant and ubiquitous. Conversely, DOC is likely to have less concern where agents can be shown to be restricted to modified habits such as agricultural landscapes.

Applicants should consult with DOC as early as possible as any issues raised may be complex.

Manager, Biosecurity Section
Research, Development & Improvement Division
Conservation House
PO Box 10-420, 18-32 Manners Street
Wellington 6011
top

Consultation with Iwi and Maori organisations

The HSNO Act requires the EPA to make informed decisions in relation to the interests of Maori, and it is the responsibility of the applicant to provide sufficient information to make that decision. Experience from recent considerations suggests that most of the issues that concern Maori are the same practical concerns as those of the wider population. However, these are often cast in a context that is specific to Maori, and unfamiliar to the wider public. Issues also arise that are specific to the Maori world view, and that view may well vary from one iwi/hapu/whanau to another. In order to capture and address these ideas to the satisfaction of the EPA it is essential to enter into comprehensive consultation with Maori. Consultation must be carried out at a national level unless a case can be made that the eventual distribution of the control agent will be geographically limited.

The Ministry for the Environment [http://www.mfe.govt.nz/publications/rma/guidelines-tangata-whenua-dec03/html/page4.html] has further useful information and discussion of what constitutes effective consultation.

As an example of how an iwi might view an application to introduce a biological control agent, Table 3 indicates how Ngai Tahu structures consideration of such a proposal against a series of cultural values. In addressing these, Ngai Tahu staff would consider:

Table 3: Major values & issues for Ngai Tahu associated with hazardous substances, new organisms and genetic modification
Whakapapa How does the application affect Whakapapa? Consider the integrity of atua, genealogical links, creation, as well as what whakapapa tells us about what is appropriate for the species involved and who has the rights to decide on this appropriateness.
Rangatiratanga How does the application affect the iwi's Rangatiratanga? Has there been adequate information provided, consultation, involvement, and/or recognition? Does this allow the iwi to uphold its mana or the resource used/affected?
Kaitiakitanga How does the application affect the Iwi's Kaitiakitanga? What are the responsibilities of the iwi in regards to this application. Will the mauri of the resource involved be affected? What effect does this have on the long term wellbeing of the wider iwi, the land or the resources affected? Are there alternatives?
Mahinga Kai Does the application affect any Mahinga Kai, taonga species or valued flora, fauna or ecosystem? What is the effect on the abundance of the mahinga kai? What is the effect on the ability of the wider iwi to undertake mahinga kai? Does the application affect the integrity of the mahinga kai? Also consider long term sustainability; future concerns.
Kawa/Tikanga What traditions, whakatauaki, tikanga and kawa apply or are affected by the application?
Matauranga Is M�tauranga or intellectual property of the iwi affected?

Another perspective on on consultation with Maori is presented in the background information, along with a valuable table of the types of issues that might arise at various stages of a project, and how to address them.

There is no fixed method for consulting with Maori. The Te Herenga network is a network of key contacts within the Maori community who are involved in environmental issues and who potentially have an interest in the HSNO Act. In earlier applications to ERMA New Zealand two distinctly different methods have been employed. One applicant employed a consultant to convene five regional hui nationwide to discuss the issues surrounding biological control and the proposal at hand face to face. A wide range of iwi/hapu/whanau/organisations within the network were invited to attend. The opinions voiced at those hui were summarised and presented to the ERMA New Zealand as the results of a nationwide consultation process. Several other applicants wrote to all entities of the Te Herenga network and provided information about biological control, and about the proposed control agents. Correspondents were invited to enter into dialogue with the applicant within 6 weeks. Further correspondence and phone conversations followed, and the opinions voiced were presented to ERMA New Zealand as the product of nationwide consultation. Although fundamentally different in approach, ERMA New Zealand considered both to be adequate methods.

Nga Kaihautu Tikanga Taiao is the statutory Maori advisory committee to the EPA. Kaupapa Kura Taiao is the Maori Unit within the Agency charged with providing the Authority with Maori advice on specific applications and is also responsible for implementing the Maori participation programmes. The EPA staff are available to assist applicants in the design and implementation of a consultation strategy, and applicants are advised to make contact on this at an early stage. top

Consultation with other organisations

Applicants are advised to inform other organisations and stakeholders of their intention to apply for the introduction of a biological control agent, and should seek input to assist in the assessment of risks and benefits. It is important to gain perspectives from these organisations and in particular those that are likely to oppose an introduction. The applicant should develop a list of such organisations and stakeholders on a case-by-case basis, but this could include:

top

Information required

The EPA requires the applicant to provide comprehensive information about the identity, biology and ecology of the biological control agent, so that it can adequately analyse the risks, costs and benefits associated with an application. top

Taxonomy and biology

The EPA must be certain that the species proposed for release has been, and can be accurately identified. This normally requires the applicant to provide a unique and unequivocal Latin binomial (with authority and date) for any new organism for which an application is received, and communication confirming that the agent has been assigned to that taxon. Any known variation within the species should be presented in the application. Formal classification is not essential as long as the applicant can provide evidence from recognised authorities to satisfy the EPA that the species is a unique entity. For example, the HSNO Committee approved release of the un-described boneseed leaf roller, Tortrix sensu lato sp. "chrysanthemoides".

Authority names for species can be found in a variety of sources, including on the internet. For example:

top

Natural host range

New organisms alter the relationships within in food webs through herbivory, competition, predation, parasitism. Biological control agents with a narrow host range are likely to alter food web relationships in a new environment less than biological control agents with a wider range, and so pose less risk of adverse environmental effects. The first step in assessing the environmental safety of a biological control agent is therefore to determine the range of hosts attacked by the proposed biological control agent in its natural host range.

The sources for information about the taxonomy, biology and distribution of species are large and diverse. There are regions of the world, such as Europe, where the biota is well-known and well-documented. Information may be available from published accounts and national databases. Species may be well-known in the scientific literature, perhaps through previous use as a biological control agent, or in other studies. Free web search engines such as Google Scholar [http://scholar.google.com] may access these papers. Subscriber web search engines and specialist sources such as the 'Web of Science' or 'Web of Knowledge' may reveal these and related references. CAB Abstracts is probably the leading English language abstracting service for agricultural literature.

Targets for biological control often originate from regions where the flora and fauna are poorly known and recorded. In this case the applicant must resort to the primary sources such as individual scientists in the region, collections, or to undertake or contract research in the native range in order to elicit the information that the EPA requires to make an informed determination. top

Biotypes

The biological characteristics of populations vary. Where variation expresses itself as a consistent and measurable difference between populations, these can sometimes be called biotypes � a subset of individuals that are morphologically similar to but physiologically different from other members of the species. Form, strain, ecotype or variant are similar terms, and the difference between a biotype and a sub-species is not always clear.

Biological control agents introduced to a new country are normally collected in the home range of the pest from one or a small range of source populations. This limited gene pool becomes the founding population for a wide range of environmental conditions in the new environment. Being aware of the variation that exists within a species, and selecting the appropriate source of the control agent can be important to maximising the chance that the control agent will succeed in its new environment, and that its host range can be predicted accurately.

In biological control, there can be biotypes for host range, environmental limits, phenology, and even in breeding systems. A new strain of Microctonus aethiopoides was released in New Zealand recently for the control of clover root weevil. See Biocontrol of clover root weevil [http://www.epa.govt.nz/new-organisms/popular-no-topics/Pages/biocontrol-of-clover-root-weevil.aspx]. A Moroccan biotype of the species had been released in New Zealand years earlier to control the related Sitona discoideus, but this strain did not effectively attack the clover root weevil. Other biotypes in Europe attacked the weevil, but research showed mating between the two biotypes produced hybrids with poor efficacy against target hosts, and given that the Moroccan biotype attacked several native weevil genera in New Zealand, there were serious reservations about introducing the European biotype. Concerns were overcome with the identification of a parthenogenetic strain of European M. aethiopoides from Ireland, which has little risk of hybridisation, and a narrower host range than the Moroccan biotype (Goldson et al. 2003, Gerard et al. 2006, McNeill et al. 2006.

Strain differences may explain the attack of Cydia succedana (a control agent for gorse) on Lotus when it was released in New Zealand, a phenomenon that was not predicted by safety-testing (Fowler et al. 2003). It is now acknowledged good practice in New Zealand to introduce control agents for weeds from a population or biotype equivalent to that used for safety-testing research. top

Climatic/environmental suitability

Knowledge about the geographic and altitudinal distribution of a control agent in its region of origin may define the climatic limits within which the organism can live and reproduce. Successful biological control requires the introduced control agent to establish, and then to thrive sufficiently to control the target pest. The likelihood of both is advanced by selecting the founding population in the home range of the pest from a climate closely matching the climate (temperature and rainfall patterns) into which the agent will be released. Photoperiod may provide important cues that synchronise the life histories of agent and target, so the latitude of the source may also be important.

Selecting the correct source may be straight forward if the target pest occupies a limited geographical range in New Zealand. However, if the target is widespread then (given New Zealand's wide latitudinal range and varied climates) selection of the correct source may be difficult. Does a single population have a sufficient range of traits to perform at its best in a range of climates? Is the agent sufficiently physiologically plastic to quickly adapt to a wide range of climates? Are populations in different regions adapted to local climates? If this is the case, then founding populations would have to be sourced from more than one climate to succeed across the range of environments present in New Zealand. This approach is complicated by the possibility of differing host range between agent populations in the native range (see above).

There is little generalised theory to assist biological control practitioners in making these decisions, and judgments about how many populations should be sourced and from where must be made on a case by case basis, using information sources such as those outlined above.

While temperature is probably the dominant driver in determining the size that populations can attain, rainfall can be a determinant of initial establishment. Gorse spider mites sourced from southern England were introduced to New Zealand to attack gorse in 1988 (Hill et al. 1989). Following release it was noted that mites could not establish in western and northern areas of New Zealand, and this was attributed to poor adaptation to heavy rainfall. Further strains of mites were introduced from the wet, northwest coast of Spain and Portugal, and gorse spider mite subsequently established throughout New Zealand (Hill et al. 1993). top

Previous use as a biological control agent, and efficacy in that use

Previous use as a control agent elsewhere in the world will be one of the best predictors of the likely behaviour of a control agent on release in New Zealand. A world catalogue of control agents for weeds and their targets current to 1996 has been published by Julien et al. (1999), and information about all programmes can be accessed from this catalogue. Information about other biological control programmes is more dispersed. A database of projects conducted in New Zealand is under construction for this site. Literature and unpublished material produced in the past 20 years are likely to be accessible via web search engines, but the search results will not be comprehensive. Information from earlier documents will need to accessed via long-term abstracting services such as CAB Abstracts or BIOSIS (see above) or through CAB regional reviews such as Greathead (1971), Kelleher and Hulme (1984) and Cameron et al. (1989), or through primary published sources. Thompson and Simmonds (1964-1965) and Herting and Simmonds (1972) have published catalogues of the parasites and predators of the arthropods of the world. top

Performance of related agents

Related organisms tend to have similar biological characteristics, although this is not universally true. Nevertheless, the behaviour and performance of congeneric species elsewhere may provide insights into the likely consequences of release of a new species in New Zealand. The possible sources for such information are discussed above. top

Identification and assessment of risks, costs and benefits

Risk, cost and benefit analysis forms the core of the data upon which the Authority will decide whether or not to approve an application. Risks, costs and benefits to the environment may arise both directly from the introduction of individuals of a new organism and indirectly from their effects on ecosystem relationships (including human activities). The applicant must provide sufficient evidence to enable the Authority to make a decision. top

Risks and costs

All foreseeable and reasonable effects of the proposal must be identified systematically to ensure that nothing is left unconsidered. Those that are considered likely to have significant effect must then be assessed. The applicant must explain how the risk identification was conducted, and explain the basis on which some risks were eliminated as insignificant. Risk is assessed by combining estimates of likelihood and consequence. Both the magnitude and probability of the adverse effect need to be described for a risk to be properly assessed. In some cases, the likelihood or probability may depend on a complex pathway between the source of the risk and the adverse effect. Risks and costs should be quantified where possible, in either monetary or non-monetary terms. However, quantitative analysis is unlikely to be helpful if there is little data to apply to the problem, if the effect is likely to be highly variable, or where there is uncertainty about the likelihood of the effect occurring. On the other hand, if the potential risk or cost is likely to be large and likely, data should be sought to quantify that risk.

The central issue for every application to introduce a biological control agent will be the risk, and consequences of attack on native and valued introduced fauna and flora. Other effects directly associated with the introduction of a population of the biological control agent might be competition with, or displacement of, resident species, or the effect on predators or alternate hosts. Indirect effects of introducing the biological control agent might include changes in the populations of other species through food webs or tri-trophic effects. Other indirect effects may result from the suppression of the host, for example land instability following weed control. Applicants should identify risks, cost and benefits de novo for each proposed agent. top

Benefits and cost-benefit analysis

As with risks and costs, the importance of the benefits is a function of the magnitude of the benefits and the likelihood that those benefits will be achieved. Monetary benefits accrue from reduction in control costs and/or increase in productivity.

The magnitude of benefits must be a marginal estimate, in other words, what is the value of the improvement over and above the current scenario? The likelihood of achieving those benefits is dependent on the maximum predicted efficacy of the biological control agent, and the frequency (spatially or temporally) with which those benefits will accrue.

Cost-benefit analysis can be a useful way of summarising the beneficial effects of a biological control agent over time where there is good information about the expected effects of the biological control agent. Where cost-benefit analysis is used, the expected benefits will commonly be discounted over time, so that short-term benefits are given greater weight than long-term benefits. The discount rate will have a significant effect on the present value of future benefits of biological control agents because in most cases there will be a long lead time before benefits are fully realised, and it may also be a long time before any effect will be observed.

This approach is not mandatory, as a reliable analysis relies heavily on good data and assumptions. Where these are not available, discussion of the benefits under various scenarios is sufficient. Non-monetary benefits can also be captured in this way.

It is advisable to consult the EPA, or submit a draft before submitting the application to ensure that risk, cost and benefit analysis is adequate. top

Release with Controls

The HSNO Act was amended in 2003 to include an option for applicants, where appropriate, to apply for conditional release, or release with controls. If such an approval is given, then the release is subject to controls which are intended to manage risk.

If an applicant is using previous applications as a guideline, be aware that until 2003 applicants could only choose to apply for fully contained approvals (including field trials) or full (unconditional) releases with no controls. The release with controls approvals are intended to fill the gap between containment and full (unconditional) release approvals by allowing controls to be imposed on how new organisms are used.

An applicant may wish to seek a release with controls for a variety of reasons. If the applicant chooses to propose controls in a release with controls application for a new organism, the HSNO Committee can then impose any type of controls it considers appropriate to manage risks (see section 38D). In making its decision the HSNO Committee will take account of the controls it intends to impose in deciding whether the organism:

The duration of the controls for a conditional release [http://www.legislation.govt.nz/act/public/1996/0030/latest/DLM383543.html] may be finite, if the HSNO Committee considers that an expiry date is warranted. Alternatively, if considered appropriate, an approval can be set in perpetuity. If the conditional release approval is set to expire, which is unlikely for a biological control agent, depending on the control it must be possible to recovery or destroy the organisms. In this case the HSNO Committee will set conditions that ensure that all new organisms for which a release with controls approval has been granted can be identified and located at the time of expiry. This will include heritable material viable at the expiry of an approval. If the EPA cannot be assured that all organisms can be located, then no approval will be given.

In the case of a release with controls, the organism remains a "new organism" when all controls have expired, and a new HSNO approval would be needed for its continued use. However, it is possible to set controls 'in perpetuity'. top

Completing the general release and release with controls application forms

Here you will find information and helpful links to assist you to complete the EPA application form for the introduction and release of a new organism as a biological control agent:

Contact with the EPA

As early as possible in a biological control programme, potential applicants are strongly advised to enter into a dialogue with EPA staff to discuss the likely timeframe, the appropriate level and style of consultation, and the type and breadth of data that will be required for a successful application. It cannot be stressed strongly enough that early contact with the EPA will facilitate the process and avoid later delays if extra information is required.

Resources

Under Popular new organism topics [http://www.epa.govt.nz/new-organisms/popular-no-topics/Pages/biological-control-agents.aspx] you will find a list of biological control agents that have been approved, and the documentaion associated with them. It can be helpful to look at some examples of successful applications. Also, information on biological control releases that have been made in the past can be found in BCANZ [http://b3.net.nz/bcanz/] where you can search either for species that have been introduced, or the targets of biological control introductions.top

Sections of the application forms

Guidance given here relates to the forms for release applications [http://www.epa.govt.nz/new-organisms/find-application-form/all-applications/Pages/new-organism-release.aspx] and release with controls [http://www.epa.govt.nz/new-organisms/find-application-form/all-applications/Pages/new-organism-release-with-controls.aspx] applications as indicated.

Section 1: Applicant details

Section 2: Information about the application

Section 2.1 asks for a 'brief application description'. You are asked for a brief statement about what you are applying to do. This statement will be used by the EPA as a short stand-alone descriptor, and should be of the form "...seeks approval to import to release (or release from containment) ... for the biological control of ...".

Section 2.2 asks for a plain English summary of what you want to do and why. So here you would expand on the statement above and explain further about the pest problem, current situation with management of the pest and how the introduction of this biological control agent will improve the options for pest management. There may be other aspects of the application that could be briefly covered here in non-technical language.

Section 2.3 requires a more detailed and technical account of the aims of the release in the context of the biological control programme, the environment into which it is intended to be released, the anticipated spread of the organism and intended outcome of the release.

Section 3: Information on the organism to be released (release and release with controls)

Section 3.1 requires the applicant to provide comprehensive information about the identity, biology and ecology of the biological control agent, so that it can adequately analyse the risks, costs and benefits associated with the biological control agent.

The applicant must provide an unequivocal identification of the biological control agent, including the higher taxonomic description from class to genus, and specify any distinct genotypes or strains involved.

Applicants should provide as much information as possible about the biological characteristics of the organism, including:

Section 3.2 ask whether the organism is subject to other legislation. This is generally not applicable to biological control organisms.

Section 4: Maori Engagement

Here it is necessary to discuss whether there has been any interaction with Maori about the application and if so, what the ourcomes of that engagement were. EPA should be consulted for advice in completing this section, but there is useful guidance information on the EPA website on Engaging with Maori for Applications to the EPA [http://www.epa.govt.nz/te-hautu/info-applicants/tips_engagement/Pages/default.aspx]. top

Section 5: Risks, costs and benefits (release and release with controls)

This is one of the most important sections of the application. In this section it is necessary to outline the potential risks and costs of introducing the biological control agent (negative effects), and the benefits of the release (positive effects). When considering risks, reference to Section 36 Minimum Standards of HSNO is useful. So the applicant needs to consider whether the biological control agent could cause significant displacement of any native species within its natural habitat (e.g. via non-target parasitism, competition, predation, hybridization etc.). The meaning of the word 'significant' in this context has not been defined, but needs to be considered case-by-case.

The benefits of the proposed introduction are often not covered well by applicants, especially the economic benefits. This is particularly difficult if the target is an environmental pest rather than a pest in the productive sector. Benefits can include improved production, reduction in costs of chemical control, safety to employees etc. It can be useful to consult similar successful application that can be found on the EPA website.

When considering both risks, costs and benefits the form asks applicants to provide an indication of the likelihood that each identified risk and benefit will be realized, and if it was, the magnitude of the adverse/beneficial impact. This helps also to identify the costs. Also it is important to address in this context is who will bear the risk and cost, and who will benefit.

Also to be considered are any adverse impacts on society and communities, human health issues that could result from the release of the new organism, the cultural impacts, and NZ's international obligations (e.g. Convention on Biological Diversity).

The full results and interpretation of any laboratory testing, such as host range testing that has been carried out in containment should be given in this section, to support the risk assessment in particular. Reports, publications etc. of such tests should be provided with the application along with the results from stakeholder consultation. top

Section 6: Pathway determination and rapid assessment (release; Section 8 for release with controls)

Section 6B 6.4 is relevant to biological control agents. It provides for new organisms (excluding GMOs) that can be shown to highly unlikely not to establish self-sustaining populations anywhere in New Zealand, and that fully meet Section 36 Minimum Standards. This type of rapid assessment has not been applied for or implemented to date for a biological control agent, but it is not inconceivable that it could be in the future. For example, a biological control agent intended for glasshouse use, that can be shown incapable of surviving outside of that environment, could qualify for rapid assessment, as long as it also met all Minimum Standards.

Section 6: Proposed controls (release with controls)

There are a number of reasons why an applicant might want to propose controls. These can only be imposed if the intention is to mitigate risks which have been noted in Section 5. Controls can include provenance of the biological control agent, so future importations will be restricted to a particular country or region. The reason for this might be to ensure that agents will have the same host range characteristics as those that have been tested in containment. An example of this is the approval for the Irish biotype of Microctonus aethiopoides for biological control of Sitona obsoletus (previously known as Sitona lepidus). Not only do the controls specify that further imports must come from Ireland, but also that they need to be demonstrated to be parthenogenetic. The following is taken from 'Appendix 1 Control' of the Decision document:

All individual Microctonus aethiopoides being assessed for parthenogenesis should be derived from or reared from Sitona lepidus collected in the field in Ireland. Each individual parasitoid should be exposed to 30-40 Sitona Lepidus weevils for 48 hours in cages furnished with white clover. All M. aethiopoides progeny derived from this exposure to S. lepidus should be female, the gender having been determined by microscopic examination using the descriptions of Loan 1975. Determination of parthenogenesis shall be verified for at least two consecutive generations. Where parthenogenesis is determined in New Zealand, as opposed to overseas, testing should be done in a containment facility registered according to the MAF/ERMA New Zealand Standard 154.02.08.

The reason for the control relating to parthenogenesis is that previous research (Goldson et al. 2003) had shown that hybridization between M. aethiopoides from Morocco, which was a sexually reproducing biotype introduced to control Sitona discoideus, with other European strains, compromised the efficacy of both biological control agents. So a parthenogenetic strain avoided this possibility. See more information on this.

Section 7: Other information (release; Section 9 for release with controls)

This section provides an opportunity for applicants to provide any further information that will assist with the application, for example any ethical consideration. It is recommended that applicants discuss this with EPA staff to see whether there is any relevant information that could be provided here. top

Post-application processes

After the application has been submitted and notified, the following steps take place:

  1. Public submissions on the application: there will be a deadline by which submissions from stakeholders and the public must be received. The submission period is 30 working days.
  2. Staff Assessment Report: this is a report prepared by the EPA which will be made available to the applicant and submitters from the EPA website [http://www.epa.govt.nz/Pages/default.aspx].
  3. A public hearing will be held before the Authority if any submitter states that they wish to be heard.
  4. A Decision will be reached by the Authority and the applicant will be notified within 30 working days following a consideration.

See the following EPA document: What are the steps for processing an application? [http://www.epa.govt.nz/new-organisms/about/Pages/steps-processing-applications.aspx]. top

References

Cameron P.J., Hill R.L., Bain J. and Thomas W.P. (1989). A review of biological control of invertebrate pests and weeds in New Zealand 1874-1987. CAB International Wallingford, UK and DSIR, New Zealand.

Fowler S.V., Gourlay A.H., Hill R.L. and Withers T. (2003). Safety in New Zealand weed biocontrol: a retrospective analysis of host-specificity testing and the predictability of impacts on non-target plants. Pp. 265�270 in Proceedings of the XI International Symposium on Biological Control of Weeds, Canberra, Australia, 2003, J.M. Cullen, D.T. Briese, D.J. Kriticos, W.M. Lonsdale, L. Morin and J.K. Scott (Ed.).

Gerard P.J., McNeill M.R., Barratt B.I.P. and Whiteman S.A. (2006). Rationale for release of the irish strain of Microctonus aethiopoides for biocontrol of clover root weevil. New Zealand Plant Protection 59: 285-289.

Goldson S.L., McNeill M.R. and Proffitt J.R. (2003). Negative effects of strain hybridisation on the biocontrol agent Microctonus aethiopoides. New Zealand Plant Protection 57: 138-142.

Greathead D.J. (1971). A review of biological control in the Ethiopian region. Commonwealth Institute of Biological Control Technical Communication 5: 1-162.

Herting B. and Simmonds F.J. (1972). A Catalogue of Parasites and Predators of Terrestrial Arthropods. Section A. Host or prey/enemy. Vol. II. Homoptera. CIBC. 210 pp.

Hill R.L., Gourlay, A.H. and Wigley P. (1989). The introduction of gorse spider mite Tetranychus lintearius for biological control of gorse. Proceedings of the 42nd New Zealand Weed and Pest Control Conference: 137�139.

Hill R.L., Gourlay, A.H. and Winks, C.J. (1993). Choosing gorse spider mite strains to improve establishment in different climates. In: Proceedings of the 6th Australasian Grasslands Invertebrate Ecology Conference, R.A Prestidge (Ed.). AgResearch, Hamilton, New Zealand.

Julien, M. and Griffiths M.W. (1999). Biological Control of Weeds. A World Catalogue of Agents and their Target Weeds. CABI Publishing, Wallingford, UK. 223 p.

Kelleher J.S. and Hulme M.A. (1984). Biological control programmes against insects and weeds in Canada 1969-1980. CAB, Farnham Common, UK. 410 pp.

McNeill M.R., Proffitt J.R., Gerard P.J. and Goldson S.L. (2006). Collections of Microctonus aethipopoides Loan (Hymenoptera: Braconidae) from Ireland. New Zealand Plant Protection 59: 290-296.

Thompson W.R. and Simmonds F.J. (1964-1965). A Catalogue of the Parasites and Predators of Insect Pests. Commonwealth Agricultural Bureaux, Bucks, United Kingdom.

top