SUBMISSION ON APP202336 –
Application to import GF-2687
herbicide.
from
TE RŪNANGA O NGĀI TAHU
by Dr Oliver Sutherland
presentation by
Gerry Te Kapa Coates
Member, HSNO komiti
THE NGĀI
TAHU
TAKIWĀ
Over 90% of the South Island
& over 40% of NZ land mass.
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Ngāi Tahu is the third largest Māori tribe in Aotearoa with over 54,000 members.
Our takiwā 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.
NGĀI TAHU VALUES
Whanaungatanga (family)
Respect, foster and maintain important relationships within the
organisation, within the iwi and within the community.
Manaakitanga (looking after our people)
Respect each other, iwi members and all others in accordance with our tikanga (customs).
Tohungatanga (expertise)
Pursue knowledge and ideas that will strengthen and grow Ngāi Tahu and our community.
Kaitiakitanga (stewardship)
Work actively to protect the people, environment, knowledge, culture, language and resources
important to Ngāi Tahu for future generations.
Tikanga (appropriate action)
Strive to ensure that Ngāi Tahu tikanga of is actioned and acknowledged in all of our outcomes.
Rangatiratanga (leadership)
We will strive to maintain a high degree of personal integrity and ethical behaviour in all actions
and decisions we undertake.
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 is 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 most Applications.
SUBMISSION ON APP202336 –
Importation of GF-2687 herbicide
We do not oppose the introduction of GF-2687 herbicide
for ground application, but do oppose its aerial
application:
• We find that a persuasive case has been made for the
benefits of GF-2687 as a herbicide.
• The Applicant has made a considerable effort to
consult with iwi and Ngāi Tahu over this Application
since March 2015. Additional information was also
provided for our consideration and we regard this as
an innovative precedent.
• However information on the other ingredients and
impurities of GF-2687 was not provided.
SUBMISSION ON APP202336 – cont. 1
• We believe that a strong case for aerial delivery
has not been made in the Application, with just
two sentences devoted to it saying this method
“will only be used occasionally”.
• Risks associated with aerial application include:
– Spray drift (depending on the buffer zones applied).
– Run-off into adjoining water courses (mobility of GF2687 in soil is not addressed).
– Risks to the gathering of mahinga kai such as
watercress from aquatic contamination.
ISSUES OF CONCERN TO NGĀI TAHU
Some examples from the Waikato of farm drains, and their
proximity to crops treated with spray.
ISSUES OF CONCERN TO NGĀI TAHU (2)
Examples from South Canterbury of proximity of waterways to
crops potentially treated with spray.
ISSUES OF CONCERN TO NGĀI TAHU (3)
Pictures from an aerial spraying demonstration by helicopter
in 2014 at Ardmore airfield.
ISSUES OF CONCERN TO NGĀI TAHU (4)
RISKS OF AERIAL SPRAYING
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Waterways: Not just domestic water supply sources are of interest.
People: Any owner within 2.5 km of a spraying boundary must be notified wouldn’t include Māori unless they are “owners”).
Adjacent crops: Can put biomarkers into spray to verify any allegations of cross
boundary spraying.
Droplet size is very important. The larger the droplet the faster it falls and the less
spray drift occurs.
Spraying parameters: The helicopter generally sprays at an altitude of 70 feet, and
flies around 80 knots (40 metres/sec).
Spray drift: There is always some spray drift, and a buffer zone is the best means
of mitigation.
Placement: Most operators have GPS systems for accurate placement. New
differential GPS have much better accuracy and can be corrected for errors, and
can switch satellites to counteract errors.
Accreditation: Only 50% of operators are Growsafe Aircare certified (National
Certificate of Aerial Application) to NZS 8409:2004. The accreditation system has
met some resistance but is generally acknowledged to have raised standards.
SUMMARY
We suggest the Application be approved by the
DMC but without approving aerial application
because :
• Unquantified risks are associated with aerial
application that include:
– Spray drift.
– Run-off into adjoining water courses.
– Risks from aquatic contamination for Māori
gathering of mahinga kai.
“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