SUBMISSION ON APP202529 –
Application to import and release the
moth plant rust fungus Puccinia araujiae
as a biological control agent for the weed
moth plant, Araujia hortorum.
from
TE RŪNANGA O NGĀI TAHU
GERRY TE KAPA COATES
MEMBER, HSNO KOMITI
THE
NGĀI
TAHU
TAKIWĀ
Over 90% of the South Island
& over 40% of NZ land mass.
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.
“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
Slide 2
Our takiwā
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”
Slide 3
TE RŪNANGA O
NGĀI TAHU
HSNO KOMITI
• 7 Members
• Responsible for
monitoring new EPA
applications
• By HSNO Policy Statement
2008
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.
ISSUES CONSIDERED
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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
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 'downstream' 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.
SUBMISSION ON APP202529 –
Importation of moth plant rust fungus
We support the introduction of moth plant rust
fungus P.araujiae to New Zealand for the
following reasons:
• The application is generally a persuasive case
for the benefits compared with the risks.
• We have been convinced that the moth plant
is a weed that poses a serious risk to the
environment in Aotearoa.
SUBMISSION ON APP202529 – cont. 1
• We support the introduction of moth plant rust
fungus as an additional tool to be used with the
root-feeding larvae of the beetle Colaspis
argentinensis
• We believe that monitoring of the establishment
and possible spread of moth plant rust fungus is
needed as a control condition.
• Also the question of eradication if necessary
which was stated by the Applicant to be “not
applicable” needs to be addressed.
SUMMARY
We request the Application be approved
because:
• A persuasive case for risks and benefits has
been made.
• An additional condition of monitoring the
possible spread of moth plant rust fungus be
included.
• The question of eradication if necessary should
be addressed.
“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