1. SUBMISSION ON APP202663 – Application to import and release the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica as biological control agents for the weed tutsan (Hypericum androsaemum). from TE RŪNANGA O NGĀI TAHU GERRY TE KAPA COATES MEMBER, HSNO KOMITI

2. Slide 2 Extends from Kaikoura in the north to Rakiura (Stewart Island) in the south, including the West Coast, TeTai Poutini. Te Rūnanga o Ngāi Tahu constitutes 18 Rūnanga representing geographical areas, generally based around traditional settlements. THE NGĀI TAHU TAKIWĀ “Te Puna Waimaraarie, Te Puna Hauaitu, Te Puna Karikari” The pools of frozen water; The pools of bounty; The pools dug by the hand of humans ” - Rakaihautu Over 90% of the South Island & over 40% of NZ land mass.

3. Slide 3 Kia tuohu koutou, Me he mauka teitei, Ko Aoraki anake. “If you must bow your head then let it be to the lofty mountain Aoraki” Our takiwā

4. TE RŪNANGA O NGĀI TAHU HSNO KOMITI 7 Members Responsible for monitoring new EPA applications By HSNO Policy Statement 2008

5. THE POLICY a)Evaluate issues of importance to Ngāi Tahu b)Identify and assess effects (risks and benefits), from a Ngāi Tahu perspective c)Identify options to avoid or minimise adverse effects on Ngāi Tahu values d)Identify outcomes important to Ngāi Tahu (e.g. environmental, cultural, health and well-being, economic). Ngāi Tahu have a unique body of knowledge and practice relating to the environment and the relationship of people to the environment. This knowledge and practice can complement scientific knowledge, and provide better understandings of the effects of hazardous substances and new organisms on the environment and our communities.

6. ISSUES CONSIDERED Lack of culturally relevant information in applications. Difficulties of assessing highly technical applications. Time and cost burden to Te Rūnanga o Ngāi Tahu of assessing applications, particularly when applicants provide insufficient information on issues of cultural importance Pollution of the natural environment from the storage, use and disposal of hazardous substances. Potential effects on native species (positive and adverse) from the use and disposal of hazardous substances. Risk to human health, posed by the storage, use or disposal of hazardous substances, directly or indirectly (e.g. bioaccumulation in mahinga kai species and subsequent human consumption). Cultural and environmental effects of transport of hazardous substances. Long term effects of hazardous substance use. Risks of emergencies or accidents from the manufacture, use, disposal and transport of hazardous substances. How are cultural and Treaty concerns reflected in EPA decisions on applications

7. TREATY CONSIDERATIONS Te Rūnanga o Ngāi Tahu was statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of Te Rūnanga o Ngāi Tahu Act 1996. This means we exercise kaitiakitanga over our takiwā. The EPA must be ever mindful of its responsibilities for ‘active protection’ under Te Tiriti o Waitangi. Active protection needs to operate in terms of Te Tiriti, not through general concerns about health and safety issues and mechanisms. The EPA’s role must also include requiring testing and research to be carried out on impacts of hazardous substances on 'down- stream' taonga native species and ecosystems, in a similar manner to that required for introduced bio-controls. The lack of, or access to any testing or research data is a major shortcoming in this Application.

8. SUBMISSION ON APP202663 – Application to import and release the moth Lathronympha strigana and the leaf beetle Chrysolina abchasica to control the weed tutsan (Hypericum androsaemum). We support the introduction of these two insects – one from Europe and the other from Georgia, to New Zealand for the following reasons: We have been convinced that the weed tutsan poses a serious risk to the environment in Aotearoa, including our own rohe. As farming is a part of Ngāi Tahu’s commercial activities we would naturally support any tools that improve its outcomes.

9. SUBMISSION ON APP202663 – cont. 1 We note that tutsan is regarded as more invasive than either tradescantia or Chinese privet, and only slightly less invasive than gorse or pampas. The application is generally a succinct and persuasive case for the benefits as compared with the risks which are said to be “highly unlikely”. The fact that consultation with Māori relating to these biocontrols predictably received little response should not be taken to mean that Māori have no concerns, either pro or con.

10. SUBMISSION ON APP202663 – cont. 2 We believe that monitoring of the establishment and possible spread of these biocontrols should be included as a control condition, although the commitment of the TAG collective to this is welcome. We note also that there is no option of later eradication should risks become apparent over time.

11. SUMMARY We request the Application be approved because: A persuasive case for risks and benefits has been made. An commitment to monitoring the possible spread of these biocontrol insects should be included as a condition since the TAG acknowledges a commitment to this. “There are some choices you can only make once. You can't go back to where you made a choice and then take the other one.” ― Mary Hofffman