ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
Application code
NOR00001
Application category
Import for release any New Organism under section 34(1)(a) of
the Hazardous Substances and New Organisms (HSNO) Act 1996.
Applicant
Hieracium Control Trust
Purpose
To import for release the insects Macrolabis pilosellae (Binnie
1878), Cheilosia urbana (Meigen 1822) and Cheilosia
psilophthalma (Becker 1894) for the purpose of biological control
of hawkweeds, Hieracium spp.
Date application received
17 November 2000
Hearing date
02 May 2001
Considered by
The Non-GMO New Organisms Standing Committee of the
Authority appointed under section 19(2)(b) of the HSNO Act
1996.
Decision
The following organisms are approved for release, in accordance with section 38(1)(a) of the
HSNO Act:
Common name
Taxonomic name
Authority
Family
hieracium gall fly
Macrolabis pilosellae
Binnie 1878
Cecidomyiidae
crown-feeding hover fly
Cheilosia psilophthalma
Becker 1894
Syrphidae
root-feeding hover fly
Cheilosia urbana
Meigen 1822
Syrphidae
As specified under section 38(2) of the HSNO Act, there are no controls on this approval.
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), as specified
in more detail below.
Purpose of Application
The application is to seek approval to import for release three insects in the order Diptera for
biological control of hawkweed, Hieracium species (Asteraceae), with the aim to establish
permanent populations in the field.
Hieracium species are perennial rhizomatous herbs comprising a total of 850 to 1,000 species
worldwide. The genus Hieracium is split into two subgenera:
i. Subgenus Pilosella: stoloniferous species (stolons are produced from the basal rosette
that are horizontal and bear small erect or spreading leaves. Vegetative spread may thus
be considerable); originally from western Europe and the United Kingdom.
ii. Subgenus Hieracium: tap-rooted generally annual species (stout leafless underground
rhizomes may occur); originally circum-polar in the Northern Hemisphere.
Several Hieracium species of Eurasian origin have become weeds in pastures and
conservation areas in New Zealand and North America (Grosskopf et al 2000). Ten
Hieracium species are recorded to be present in New Zealand (Webb et al 1998): five each in
of the subgenera Pilosella and Hieracium. At the time the Hieracium biocontrol programme
was initiated, the applicant considered four Hieracium species to be serious weeds of hill and
high country pastoral areas, as well as conservation land through large areas of New Zealand:
Common name
field hawkweed
mouse-ear
hawkweed
king devil
tussock hawkweed
Taxonomic name
Hieracium caespitosum
Hieracium pilosella
Taxonomic Authority
Dumort. (1827)
Linnaeus (1753)
Sub-genus
Pilosella
Pilosella
Hieracium praealtum
Hieracium lepidulum
Gochnat (1908)
(Stenstroem) Omang (1905)
Pilosella
Hieracium
These four species were introduced from Europe between 1878 and 1946. At least two other
species are now considered to have weedy potential in New Zealand: H. auranticum and H. x
stoloniflorum (a hybrid). The New Zealand distribution and habitat preferences of weedy
Hieracium species are detailed in Annex 1 of this decision, based on Webb et al (1998) and
information provided by the applicant.
Hieracium species are likely to have been spread initially in New Zealand as contaminants of
grass seed from the United Kingdom. The presence of Hieracium in New Zealand was not
thought to be a threat until their weed potential was commented upon in the 1920s.
Remaining relatively rare until the 1950s, Hieracium species have since spread in dramatic
fashion, initially associated with open ground in tussock grasslands in a partly degraded state
(McMillan 1991).
The Hieracium Control Trust was established in 1993 after the need for establishment of a
Hieracium biological programme was identified at a meeting between the South Island High
Country Committee of Federated Farmers, Landcare Research and AgResearch. The mission
statement of the Trust is to ensure the development and implementation of biological control
of Hieracium, and restoration of affected areas.
Landcare Research and CABI Bioscience (CAB International, UK) identified M. pilosellae,
C. psilophthalma and C. urbana as being part of a suite of six potential control agents likely
to have the greatest impact as biological control agents for the four Hieracium species that
were considered to be weeds at the time the Hieracium biocontrol programme was initiated.
The characteristics, mode of action and potential efficacy of the flies (M. pilosellae, C.
psilophthalma and C. urbana) are summarised below and in Annex 2 of this decision:

M. pilosellae adults are less than 2mm in length and the larvae induce the production
of galls (in which the larvae feed and pupate), in leaves at stolon tips and in
developing rosettes of H. praealtum, H. pilosella and H. caespitosum. M. pilosellae
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is likely to complete three generations per year (between summer and autumn) and
over-winter as pupae. It is noted that in November 1998 the Authority approved the
importation into containment of M. pilosellae for host range testing (application
code NOC98001).

C. urbana adults are 7-8mm in length, and the larvae feed externally on the roots of
the host plant (in the soil). C. urbana develops on all four weedy Hieracium species
and is likely to complete one generation per year and over-winter as pupae.

C. psilophthalma adults are also 7-8mm in length and the larvae feed on the
aboveground parts of the host plant (at the rosette centre, base of stolons, in leaves,
leaf axils and in stolon tips). C. psilophthalma develops on all four weedy
Hieracium species and is likely to complete one generation per year and over-winter
as pupae.
Two other insect biological control agents of Hieracium species are already present in New
Zealand:

hieracium plume moth, Oxyptilus pilosellae Zeller (Lepidoptera: Pterophoridae)
(establishment not confirmed after release at one site in 1998), and

hieracium gall wasp, Aulacidea subterminalis Niblett (Hymenoptera: Cynipidae)
(establishment confirmed after 39 releases between 1998 and 2000).
In addition, two pathogens of Hieracium are recorded in New Zealand:

rust fungus, Puccinia hieracii var. piloselloidarum.(present in at least 35 sites in the
South Island and 4 sites in the North Island, as well as being actively spread by
landowners), and

powdery mildew, Erysiphe cichoracearum (confirmed throughout much of the
South Island since 1997, but is not considered as a biological control agent by the
applicant, as it is not recorded to be host-specific).
Application Process
Application receipt
The application was formally received on 17 November 2000 and verified on 19 January
2001 following an additional information request under section 52(1) of the HSNO Act 1996.
Public notification
In notifying receipt of the application, sections 53, 54 and 58(1) of the HSNO Act and clauses
2(2)(b), 5 and 7 of the Methodology were taken into account. Various government
departments and agencies, including relevant central government, territorial authorities,
Universities and Crown Research Institutes, were notified of the receipt of the application and
provided with an opportunity to comment or make a public submission on the application.
The application was publicly notified on 20 January 2001 in The Dominion, The New
Zealand Herald, The Press and The Otago Daily Times. Public submissions closed on 05
March 2001. Six submissions were received, listed in Annex 3. Two submitters requested to
be heard at a public hearing in support of their submission.
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Information available for consideration
The staff of ERMA New Zealand prepared an Evaluation and Review (E&R) Report to assist
and support decision-making by the Committee, by consolidating and evaluating the relevant
information in a format and sequence which is consistent with the decision-making
requirements of the HSNO Act and of the HSNO (Methodology) Order 1998. Recognised
techniques were used in identifying, assessing, and evaluating the relevant information, as
required under clause 24 of the Methodology. Techniques for identifying and preparing
information on risks, costs and benefits were based on internal procedures as specified in the
ERMA New Zealand Technical Guide publications. Potential effects were identified by staff
through a process of brainstorming at project team meetings and by reviewing the
application, submissions and expert advice sought on the application, as well as comparison
with other applications to release biological control agents.
Dr Jim Cullen (Chief of Entomology Division, Commonwealth Scientific and Industrial
Research Organisation (CSIRO), Australia) provided external advice regarding
environmental effects. Bevan Tipene-Matua (Lecturer, Māori Department, University of
Canterbury) provided external advice regarding Māori cultural effects. ERMA New Zealand
considered the external advisors as experts in their relevant professional fields. The advice
received from the external experts was incorporated into the E&R Report as appropriate.
The documents available for the evaluation and review of the application by ERMA New
Zealand included: the application (including supporting documentation), public submissions,
submissions and comment from government agencies [received from the Department of
Conservation (DoC) and the Otago Regional Council], and additional information requested
from the applicant under section 58 of the HSNO Act. Additional information was requested
from the applicant on 27 February 2001 to clarify some issues raised as a result of the
application, including efficacy of biological control agents and re-vegetation of pasture and
conservation areas. The applicant provided the following responses:
i.
biological control agent life cycle diagrams, received 07 March 2001,
ii.
a report prepared on behalf of the applicant by Dr David Scott, AgResearch,
received 07 March 2001, and
iii.
a report prepared by the applicant and Landcare Research, received on 12 March
2001.
The Committee considered the information provided by the applicant was relevant and
appropriate to the scale and significance of the risks, costs, and benefits associated with the
application (as required by clause 8 of the Methodology).
The evidence available for consideration of the application comprised that detailed above, as
well as information presented at the public hearing.
Decision-Making Committee
The application was considered by the New Organisms Standing Committee (the Committee)
of the Environmental Risk Management Authority (the Authority) appointed in accordance
with section 19(2)(b) of the HSNO Act. The Committee comprised the following members:
Mrs Helen Hughes (Chair), Mr John Maasland and Dr Lindie Nelson.
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Hearing
A public hearing was held on 02 May 2001 at the Canterbury Agricultural Science Centre,
Lincoln, Canterbury (in accordance with sections 60 and 61 of the HSNO Act and clause
2(2)(b) of the Methodology).
The following parties made presentations to the Committee:
For the applicant:
1. Mr John Aspinall
2. Dr David Scott
4. Dr Pauline Syrett
5. Dr Colin Meurk
Chairman (Hieracium Control Trust)
Technical Advisor to the Hieracium Control Trust &
Honorary Research Fellow
Technical Advisor to the Hieracium Control Trust &
Research Associate, Landcare Research
Insect Ecologist (Landcare Research)
Botanist (Landcare Research)
Witnesses for the applicant:
1. Mr Lindsay Smith
Insect Ecologist (Landcare Research)
3. Dr Brian Molloy
For ERMA New Zealand:
1. Anne Rose
2. Dr Jim Cullen
3.
Janet Gough
For Ngā Kaihautū Tikanga Taiao1:
1. Dr Murray Parsons
Submitters:
1. Alastair Ensor
Project Manager (ERMA New Zealand)
External Advisor: environmental effects (Chief of
Entomology Division, CSIRO, Australia)
Senior Analyst: social & community effects, economic
effects & overall evaluation (ERMA New Zealand)
Ngā Kaihautū Tikanga Taiao
Chairman, South Island High Country Committee of
Federated Farmers, and also representing Federated
Farmers head office.
Consideration of the application (approach & sequence)
In accordance with clause 24 of the Methodology, the approach adopted by the Committee is
to look sequentially at identification, assessment and evaluation of risks, costs and benefits.
Those risks identified as significant were assessed in accordance with clause 12. Costs and
benefits were assessed in accordance with clause 13.
In assessing risks, minimum standards (section 36 of the Act), the ability of the organisms to
establish undesirable self-sustaining population, and ease of eradication of any such
populations (sections 37 and 44 of the Act), were considered.
1
Ngā Kaihautū Tikanga Taiao has been formally established as a Māori advisory committee under clause 42 of the
First Schedule to the HSNO Act, 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 HSNO Act).
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The Committee's approach to risk was established in light of the risk characteristics of the
organisms (clause 33 of the Methodology). Taking account of the risk characteristics of the
organisms, the combined impact of risks, costs and benefits was evaluated in accordance with
clause 34.
The identification of risks, costs & benefits
Risks and associated costs identified for further assessment and evaluation were as follows
(taking into account clauses 9 and 10 of the Methodology, which incorporates sections 5, 6, 8
and 37 of the Act):

Risks (and associated costs) to the environment, including invasion of other weeds,
potential non-target effects, deterioration of natural habitats, release of incorrect
species and ability to cause or vector animals or plant pathogens or parasites, or
affect New Zealand's inherent genetic diversity (by interbreeding, competition or
displacement of native or valued species).

Risks (and associated costs) to Māori and their culture and traditions

Risks (and associated costs) to human health

Risks (and associated costs) to society and communities

Risks (and associated costs) to the economy, including an export Hieracium seed
industry
Benefits identified for further assessment and evaluation were as follows (9 and 10 of the
Methodology, which incorporates sections 5, 6 and 8 of the Act):

General issues relating to the extent of benefits, including efficacy of the biological
control agents, extent to which the agents complement those already present in New
Zealand, and post-release management of the biological control programme.

Benefits to the environment, including the threat of target Hieracium species,
reduced soil erosion and improved water quality, reduction in use of herbicides and
effects on predators and parasites.

Benefits to Māori and their culture and traditions, including increasing the protection
of the mauri of valued flora and fauna, land, waterways and air.

Benefits to human health, including reduction in use of herbicides

Benefits to society and communities, including increased pastoral production

Benefits to the economy, including increased pastoral production and tourism.
Assessment of adverse effects (risks & costs)
The Committee has categorised potential adverse effects of this application into
environmental, Māori cultural, human health, society and community, and economic areas of
effect. Adverse effects are defined as including risks and costs.
Potential adverse effects arising from the matters set out in clauses 9 and 10 of the
Methodology were considered particularly in terms of the requirements of clauses 12, 13, 14
and 34 of the Methodology. Factors taken into consideration included the probability of
occurrence and the magnitude of adverse effects, whether or not they are monetary, the
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distribution of costs over time, space and groups in the community, and use of common units
for measurement. The degree of uncertainty attached to evidence relating to adverse effects
was taken into account, as required under clauses 16, 25 and 29-32 of the Methodology.
Where qualitative assessment was required, probability was expressed as the likelihood of the
effect occurring. Annex 4 contains the qualitative descriptions used in this decision for scales
of likelihood and magnitude of adverse effects.
In considering potential adverse effects, the Committee has taken into account the nature and
characteristics of the organisms, the applicant's assessments, the relevance of submissions
received and the E&R Report prepared by staff, as required under clauses 2(c), 15 and 22 of
the Methodology.
The evidence available to assess adverse effects was largely scientific in nature and was
considered in terms of clause 25(1) of the Methodology. This evidence comprised that
provided by the applicant, submitters and additional evidence set out in the E&R Report
prepared by staff. The scientific evidence relevant to the consideration was not generally in
dispute so in this respect, clauses 29 and 30 of the Methodology did not apply.
Adverse environmental effects
Following the Methodology, clauses 9(a), 9 (c) and 10 are considered particularly relevant to
the assessment of environmental effects, such as effects on native species, natural habitats,
ecosystems, and inherent genetic diversity.
Invasion of other weeds
The Committee notes that should successful biological control of the target Hieracium
species be achieved, a worst-case scenario is that another weed becomes the dominant
vegetation to the same, or a greater, extent than Hieracium species do currently (clause 12(a)
of the Methodology). Such consequences could affect the overall benefit of the biological
control programme.
The Committee notes experiments conducted by Landcare Research suggest that replacement
by weeds following Hieracium control is unlikely in the short term (compared with pasture
and native species). However, the Committee notes that a number of variables apply in this
case that make prediction of plant revegetation dynamics difficult, including the variation in
habitats involved, and the number of potential weeds (other than the target Hieracium
species) that could invade such habitats given an increased opportunity. Ecological
considerations of plant invasion include factors such as soil fertility, moisture (rainfall) and
temperature (altitude, aspect and slope) as well as the interaction of grazing or disturbance on
plant growth, species niches, long-range dispersal, relative abundance of species and
dominance/ diversity relationships (Scott 1997). Therefore any plant invasion is likely to vary
with site ecology and land management practices. A different set of scenarios is possible in
each habitat and region, depending on the level of control of each Hieracium species and the
surrounding weed reservoir and the length of time the weed has been in present in New
Zealand (clause 12(e) of the Methodology).
In considering the magnitude of potential adverse effects (clause 12(b) of the Methodology)
should other weeds become dominant, the Committee notes that the benefits of the biological
control programme would be reduced rather than there being any particular adverse effect.
The Committee notes experiments conducted by Landcare Research, indicating that in
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tussock areas, initial regeneration is likely to be inter-tussock species (ie exotic grasses,
native grasses and herbs) rather than new tussocks. In some situations tussock may not reestablish. Dr Meurk, representing the applicant, noted at the hearing that the habitats in
question are relatively harsh, therefore successional changes in vegetation are very slow (ie
over decades rather than years), as lichens, algae and mosses give way to colonisation by
vascular and then herbaceous plants (ie both indigenous and naturalised).
In this case, where there is a complex of closely related Hieracium species and where the
impacts on each species by the biocontrol agents may differ, the replacement of one
Hieracium species by another is possible. The likelihood of this event would depend on
current and future projected distributions of the different Hieracium species. As detailed
above, H. pilosella is one of the most prominent plants in many grassland communities in the
drier hill country regions of the South Island and central North Island. The issue of what
species might replace H. pilosella is critical in terms of the invasiveness of H. pilosella and
the total land area concerned. In comparing Hieracium species (eg those with close ecological
similarities) with the level of predicted biological control of each species, the Committee
considers that in open tussock grasslands, there is long-term potential for H. pilosella to be
replaced by H. stoloniflorum to some extent. Other species that grow in open tussock habitats
(ie H. praealtum and H. caespitosum) are likely to be subject to biological control to a similar
level as H. pilosella.
Based on results of host-range tests, H. lepidulum will not be subject to the same degree of
attack as other weedy Hieracium species. H. lepidulum, the only tap-rooted annual among the
weedy Hieracium species of concern in New Zealand, is the most widespread species in open
forests, forest clearings, margins and wetter tussock grasslands. The Committee considers it
has potential to become more of a problem in conservation areas where the upright plant
would not be subject to forage pressure. As noted above, H. lepidulum has also been
identified as very aggressive in certain types of limestone, where it is displacing rare native
plants that are highly localised in distribution.
In considering the options and proposals for managing these risks (clause 12(d)), the
Committee acknowledges that controls cannot be attached to the release of new organisms.
The general management of the biological control programme, including post-release
monitoring, is considered relevant, and is discussed below under the assessment of beneficial
effects. Pasture management will have a major bearing on consequences of successful control
of Hieracium species on farmland. The applicant provided additional information on likely
pasture management practices, specifying that they expect strategic grazing will be part of the
managed re-vegetation phase to reduce seed production of remaining Hieracium species, and
to reduce the establishment of woody weeds eg sweet briar and wilding trees. Irrigation
and/or cultivation will sometimes be part of the re-vegetation phase. The rapid invasion of
Hieracium species over pastoral tussock grasslands in the 1950s has been attributed to, or at
least compounded by, the detrimental effects of overgrazing, tussock burning, tussock grubs,
and feral rabbits (McMillan 1991). The Committee accepts that there have been changes in
land management practices since this time, when rapid Hieracium invasion was compounded
by factors such as overgrazing, tussock burning and feral rabbits (McMillan 1991). The
applicant noted at the hearing that farmers are unlikely to overgraze pasture or burn revegetated tussock lands unless a very strong tussock cover or significant invasion of woody
weeds develops.
On balance, the Committee considers replacement of Hieracium species by forage species
and other weeds is likely, and by native species to a limited extent. Adverse environmental
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consequences could range in impact from minor to major depending on the plant species
involved, but are unlikely to be any worse than the present effect of Hieracium species.
Based on a combining likelihood and magnitude values, the Committee considers the risks
associated with replacement of Hieracium species are low to moderate (clause 12(c)).
Non-target effects
An important consideration related to any biological control programme is the potential for a
biological control agent to attack non-target species, thus leading to adverse effects. In this
case, adverse effects could occur if one or more of the biological control agents could
potentially attack native or valued plants outside the group of target weedy Hieracium species
(clause 12(a) of the Methodology).
It is noted that DoC, the Entomological Society, Federated Farmers and the National
Beekeepers' Association raised the issue of host-specificity in their submissions. The
National Beekeepers' Association were the only submitter group with concerns about hostrange tests.
It is standard practice to conduct a testing program to establish the degree of host-specificity
of a proposed biological control agent. In this case, the applicant conducted host-range tests
according to the centrifugal phylogenetic approach (Wapshere 1974) which depends on the
known relationship of host range to taxonomic affinity of the potential hosts (as detailed in
section 5.4.3 of the E&R Report) (clause 12(e) of the Methodology).
In considering the probability of occurrence of non-target effects (clause 12(b)), the
Committee notes that all species of Hieracium (tribe Lactuceae, subfamily Cichorioideae) are
exotic to New Zealand, therefore native species are very unlikely to be at risk. Choice tests
and no-choice tests were conducted for all three biocontrol agents, concentrating on plants of
the genus Hieracium and then on the most closely related species, ie of other genera in the
Lactuceae, species of the related tribe, the Carduae within the Cichorioideae. A total of 69
species (21 native to New Zealand) were tested for M. pilosella, 71 species (21 native to New
Zealand) for C. urbana and 66 (16 native to New Zealand) for C. psilophthalma. Host records
from Europe were also available as additional field evidence. In no case was any significant
development recorded on any other species outside the genus Hieracium. Host-range tests
show that M. pilosella is confined to species of the subgenus Pilosella within Hieracium and
the two Cheilosia species attack species in both the subgenera present in New Zealand but
showing a preference for species in the subgenus Pilosella. Field observations in Europe
confirm that M. pilosella is only found on species of the subgenus Pilosella. Field records for
the two Cheilosia species are less complete, but they are readily found in H. pilosella and
never in plants of other genera. Insofar as the standard methodology is acknowledged as a
reliable predictor of host range, the Committee considers this part of the assessment to be as
comprehensive as is reasonable and practicable.
The Committee considers the three biological control agents are very likely to be hostspecific to Hieracium species, based on overseas field records, host specificity testing results,
and relatedness of native and valued plants to Hieracium species. The Committee therefore
considers that if the insects fail to establish on Hieracium species they would also fail to
establish in New Zealand.
It is noted that ecotype variability (ie local genetic variation in organisms) between the
insects included in host range tests and those imported for release could undermine the
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conclusions drawn from the host-range testing. At the hearing, Dr Pauline Syrett representing
the applicant, confirmed that the insects imported into New Zealand would be collected from
the same field sites and by the same organisation (CABI Bioscience in Switzerland), as
insects used in host range tests. Under these circumstances, the Committee expects any
adverse effects arising from ecotype variability would be minimal.
If there were any non-target damage on native species in New Zealand, it would be classed as
having moderate magnitude, but taking into account the host specific nature of the proposed
biological control agents the Committee considers that non-target effects would be very
unlikely to occur. The Committee therefore considers the risks associated with non-target
effects are low to moderate (clause 12(c)). As noted in relation to invasion of other weeds, the
general management of the biological control programme, including post-release monitoring,
is considered relevant (clause 12(d)), and is discussed below under the assessment of
beneficial effects (post-release management).
Deterioration of natural habitats (soil erosion)
The possibility of a rapid decline in the target Hieracium species due to biological control (ie
at a rate more rapid than it can be replaced by the growth of other plant species) was
considered. In considering the nature of adverse effects (clause 12(a) of the Methodology), if
patches or clumps of a Hieracium die and disintegrate as a result of successful biological
control, it could lead to exposure of soil to erosion by wind and rain (McMillan 1991).
Biological control is generally a slow process. In general, for pasture weeds, gradual decline
allows steady replacement by other species already present. In considering the probability of
occurrence of non-target effects (clause 12(b)), the Committee notes that experiments
conducted by Landcare Research on the effects of simulated decline of Hieracium species
suggest that any effect of biological control on vegetation composition and ground cover is
likely to be slow – years or decades rather than months (clause 12(e) of the Methodology).
Even if an agent kills a plant, it does not remove it. This is illustrated already in herbicide
trials or drought killing of Hieracium plants, where the dead material continues to hold the
soil surface for a period. The Committee also notes photographs provided by the applicant at
the hearing demonstrating that forage grasses and weeds do re-establish where Hieracium
infestation has broken up and disintegrated naturally.
The growth form of the target Hieracium species and the biology of the biological control
agents (ie leaf galls produce a progressive weakening and the Cheilosia species only have one
generation per annum) suggest that slow decline in Hieracium populations would be the case
here if the programme is successful. Thus the effect on removal of ground cover and potential
soil erosion is likely to be minimal.
The Committee considers that deterioration of natural habitats due to soil erosion following
successful biocontrol is very unlikely, as rapid removal of Hieracium species from the
environment and associated soil erosion is likely to be minimal. The Committee therefore
considers the risks associated with non-target effects are low (clause 12(c)).
Release of incorrect species
The importance of correct identification of the proposed biological control agents has been
recognised. In considering the nature of potential adverse effects associated with incorrect
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identification (clause 12(a) of the Methodology) the Committee notes that incorrect insect
species could be released.
The Committee has taken into account probability and magnitude of potential adverse effects
(clauses 12(b) and 12(c) of the Methodology) associated with release of incorrect species. It
is considered very unlikely that insect species other than those specified would be released, as
taxonomic identification by a recognised specialist would be conducted during the first
generation the insects were held in quarantine, in accordance with an Import Health Standard
issued by MAF under the Biosecurity Act 1993 (clause 12(e) of the Methodology).
The magnitude of the adverse effects from an incorrect release could be minimal to major,
depending on the species released. In the unlikely event that identification by a recognised
entomologist was incorrect, the species released would be likely to be very closely related to
the approved species (ie gall flies or hover flies in the same genus). At the extreme, the
consequences of incorrect identification could be moderate to major (ie widespread,
irreversible and lead to decline or loss of native plant species). Although it is possible that
exotic gall flies or hover flies closely-related to those approved could successfully attack
native plant species, the Committee notes that insects would not pass successfully through the
programme to breed populations for release in a contained situation (ie either in a laboratory
or plant-house type facility), unless they attacked the target Hieracium species. Therefore an
insect with a significantly different host range would be unlikely to be released in the field.
The Committee notes that it is essential that the likelihood of incorrect identification is
reduced to a very low level by the application of good processes. Although a release approval
does not include the possibility of controls to manage risks (clause 12(d) of the
Methodology), the Committee stresses the importance of accurate taxonomic identification
during quarantine. Taking into account import requirements under the Biosecurity Act, the
Committee considers the risk of release of an incorrect species is low.
Ability to cause or vector animal or plant parasites or pathogens
In considering the nature of potential effects (clause 12(a) of the Methodology) the
Committee notes that insect eggs, larvae and pupae imported from Europe into quarantine,
could feasibly be contaminated with animal or (more likely) plant pathogens that were
present casually on the host plants in Europe. In relation to threats to animal or plant health
the insects are not known to host any inseparable organisms. The insects would be subject to
requirements under an Import Health Standard (issued under the Biosecurity Act 1993) that
would specify a period during which the insect species would be reared in quarantine to
ensure that no hyperparasites or pathogens were present (clause 12(d) of the Methodology).
There is no evidence to suggest that the insects could become vectors of insect-borne animal
or plant pathogens, other than passively as they move around in the environment, possibly
picking up fungal spores etc, in the way that all similar insects might do. The Committee does
not consider such risk would be any higher in this case than any other similar organisms
imported into New Zealand (clause 12(e) of the Methodology).
In view of the importation and quarantine regime required by MAF, the Committee considers
it is very unlikely that pathogens or parasitoids would be imported and released. The
applicant also has a strong self-interest in avoiding release of hyperparasites or pathogens of
the insects as this could adversely affect the success of the biological control programme. In
the unlikely event that inseparable organisms were released with the biological control
Environmental Risk Management Authority Decision: Application NOR00001
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agents, the magnitude (clause 12(b) of the Methodology) could range from minimal to major,
depending on the particular organisms involved. The Committee notes that any inseparable
organisms would be likely to be host-specific and therefore unlikely to affect other than very
closely related insect species, which are limited or non-existent in New Zealand. In
accordance with clause 12(c) of the Methodology, the Committee considers the risk that the
insects would cause disease is insignificant. Taking into account import requirements under
the Biosecurity Act, the Committee considers the risk that the insects would vector animal or
plant pathogens or parasites is low.
Ability to interbreed and adversely affect New Zealand's inherent genetic diversity
In considering the nature of potential adverse effects to New Zealand's genetic diversity
under clause 12(a) of the Methodology, the Committee notes that should any of the biological
control agents interbreed with native insects, there is a risk that native biodiversity could be
decreased.
The species of Cecidomyiidae in New Zealand are not well described, but 14 genera are
recorded in the literature, most of which are of worldwide distribution (clause 12(e) of the
Methodology). The Committee considers it is very unlikely that M. pilosella will interbreed,
as the genus Macrolabis is not otherwise recorded in New Zealand (clause 12(b) of the
Methodology).
Neither the genus Cheilosia nor the tribe Cheilosiini to which it belongs, are recorded to
occur in New Zealand (clause 12(e) of the Methodology). The Committee considers it is very
unlikely that C. urbana and C. psilophthalma could interbreed with other insects in New
Zealand (clause 12(b) of the Methodology).
In accordance with clause 12(c) of the Methodology, the Committee considers the risk to
New Zealand's inherent genetic diversity from the biological control agents interbreeding
with valued or native insects is insignificant.
Competition or displacement
The ability of the biological control agents to adversely affect native or valued flora or fauna
through competition or displacement has been considered (clause 12(a) of the Methodology).
The Committee considers competition with, or displacement of, existing natural enemies of
the target or non-target plants is very unlikely.
In considering the risks of competition, the Committee notes research findings (clause 12(e)
of the Methodology) that apart from the two insect biological control agents of Hieracium
species already present, no significant insect damage has been observed on Hieracium
species in New Zealand, suggesting that any damage by resident invertebrates is incidental
(Syrett & Smith 1998). The proposed species for introduction are likely to be complementary
to the biocontrol agents already introduced (including the rust fungus) and to each other. Any
impacts on existing natural enemies would be minimal. The Committee considers attack of
non-target plants (and therefore adverse impacts on existing natural enemies of non-target
plants) is very unlikely. The Committee also considers it is unlikely that the biological
control agents could significantly adversely affect native invertebrate species as so few have
Environmental Risk Management Authority Decision: Application NOR00001
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been found to use target Hieracium species as host plants. Thus competitive exclusion of
native insect species is very unlikely (clause 12(b) of the Methodology).
Hieracium plants are not recorded to represent a valuable habitat for native species in New
Zealand. The likely gradual decline in Hieracium populations and consequent recolonisation
by other plants also means native fauna currently associated with Hieracium would be very
unlikely to be disadvantaged. Any adverse habitat effects are likely to be minimal and short
term (clause 12(b) of the Methodology).
The possibility has been raised that if one or more of the biocontrol agents increases to a
significant population level, it may be parasitised or preyed on by a native parasite or
predator, whose population would in turn, increase. If the population of the biological control
agent then declined suddenly as a result of Hieracium control, it is possible that the parasite
or predator would exert pressure in the short-term back to its original hosts. This could
conceivably have a severe depressive effect on that parasite's or predator's presumably native
normal host. The Committee notes this type of possibility cannot be ruled out, but considers
impacts at other trophic levels are unlikely and would have minor impact (ie localised and
short-term in nature) (clause 12(b) of the Methodology).
In summary, the Committee considers the risks associated with competition or displacement
of native or valued flora or fauna are insignificant (clause 12(c) of the Methodology).
Adverse Māori cultural effects
The Committee has considered potential adverse effects associated with releasing the three
biological control agents 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, and clause 9(c)(iv) of the Methodology). The Committee considers
that the applicant’s consultation with Māori to establish the potential effects of introducing
the three biological control agents on the relationship of Māori with their taonga was
adequate. No submitters identified cultural issues associated with the application.
In considering the nature of potential cultural effects (clause 12(a) of the Methodology) the
Committee has taken into account the views of Ngā Kaihautū Tikanga Taiao, which stated in
its report to the Authority:

Ngā Kaihautū acknowledges that the cultural and spiritual aspects of introduced
biological control agents are still being determined by Māori, as stated by the
applicant (clause 12(e) of the Methodology).

Many of the concerns expressed about biocontrol issues have to do with the
knowledge that some organisms released in the past although intended for biological
control have subsequently become agents or pests threatening the native flora and
fauna. For this reason an integral part of the research requirements of all scientists
must include the ability and willingness to communicate openly, honestly and freely
with all New Zealanders about their research, including its potential risks as well as
the benefits.
The Committee concludes that given the risks posed by the target Hieracium species to native
and valued flora and the intrinsic value of ecosystems in New Zealand and the absence of
identifiable adverse effects on Māori culture attributable to releasing the proposed biological
control agents, that adverse effects of release on Māori taonga are very unlikely (clause 12(b)
Environmental Risk Management Authority Decision: Application NOR00001
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of the Methodology). The Committee therefore considers risks to Māori culture associated
with the application are low (clause 12(c) of the Methodology). While the Committee cannot
attach controls to the release of a new organism, it endorses the applicant's intention to follow
through with monitoring (at least in the short-term) and hopes it will make these results
available to iwi (clause 12(d) of the Methodology).
Adverse human health effects
Clauses 9(c)(iii), 10(c), 10(g) and 12 of the Methodology are considered to be particularly
relevant to the assessment of human health effects, including effects on public health and
safety. The Committee did not identify any significant potential adverse effects on human
health and safety associated with this application.
Adverse social & community effects
Clauses 9(b) and 12 of the Methodology are considered to be particularly relevant to the
assessment of beneficial social and community effects, including effects on the maintenance
and enhancement of the capacity of people and communities to provide for the reasonably
foreseeable needs of future generations. The Committee did not identify any significant
adverse social or community effects associated with this application.
Adverse economic effects
Clauses 9(b) and 9(c)(v) of the Methodology are considered particularly relevant to the
evaluation and consideration of adverse economic effects, including effects on the
maintenance and enhancement of the capacity of people and communities to provide for their
own economic wellbeing.
The Committee considers that relevant adverse economic effects are limited to adverse
potential effects on a small export industry for Hieracium seeds, should the biological control
programme be successful at reducing Hieracium populations (clause 12(a) of the
Methodology). The applicant estimated the capitalised (ie multi year) value of the seed
industry at $7,000 in the long term (with an uncertainty range of $0-15,000). No evidence
was presented to suggest that the seed industry was larger or had a greater value (clause 12(e)
of the Methodology).
The Committee notes that the adverse economic effects of successful biological control will
be born by different parties than those who receive the benefits. While this is, in principle, an
undesirable distributional consequence, the Committee notes that there were no submissions
received (no evidence was presented) suggesting opposition from the Hieracium seed
industry to the application.
The Committee considers that a successful biological control programme could substantially
reduce the value of the Hieracium seed industry (clause 12(b) of the Methodology).
Nevertheless the Committee is satisfied that if benefits to the pastoral sector materialise, they
will exceed the costs imposed on the export Hieracium seed industry (refer to overall
evaluation, below). Therefore, economic risks associated with the application are considered
low (clause 12(c) of the Methodology).
Environmental Risk Management Authority Decision: Application NOR00001
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Assessment of beneficial effects
The Committee has categorised potential beneficial effects of this application into general (ie
over-arching), environmental, Māori cultural, human health, society and community, and
economic areas of effect. A “benefit” is defined in clause 2 of the Methodology as “the value
of a particular positive effect expressed in monetary or non-monetary terms”.
Potential beneficial effects arising from the matters set out in clauses 9 and 10 of the
Methodology were considered particularly in terms of the requirements of clauses 13, 14 and
34 of the Methodology. Factors taken into consideration included the probability of
occurrence and the magnitude of beneficial effects, whether or not they are monetary, the
distribution of benefits over time, space and groups in the community, and use of common
units for measurement. The degree of uncertainty attached to evidence relating to beneficial
effects was taken into account, as required under clauses 16, 25, 31 and 32 of the
Methodology. Where qualitative assessment was required, probability was expressed as the
likelihood of the effect occurring. Annex 4 contains the qualitative descriptions used in this
decision for scales of likelihood and magnitude of beneficial and adverse effects.
In considering potential beneficial effects, the Committee has taken into account the nature
and characteristics of the organisms, the applicant's assessments, the relevance of
submissions received and the E&R Report prepared by staff, as required under clauses 2(c),
15 and 22 of the Methodology.
The evidence available to assess beneficial effects included scientific information and
reference to other values and matters relevant to Part II of the HSNO Act and was considered
in terms of clause 25(2) of the Methodology. This evidence comprised that provided by the
applicant, submitters and additional evidence set out in the E&R Report prepared by staff.
General issues relating to extent of benefits
Efficacy of biological control agents
Benefits associated with the release of the three biological control agents are dependent on
the insects establishing and exerting control over the target Hieracium species. The
Committee considers that the efficacy of the biological control agents is relevant to the
evaluation of all beneficial effects, ie those grouped under environment, human health, Māori
culture, society and community, and economic effects. Estimates of risks, costs and benefits
used for the purposes of evaluation are uncertain, in particular because the potential
effectiveness of the biological control agents in New Zealand conditions is uncertain, as is the
total present and future damage attributable to the target hosts. The Committee considered
that this uncertainty did not increase the overall risk, since it relates to the materiality of
benefits rather than the occurrence of adverse effects.
Although noting difficulties with rearing Cheilosia species the Committee considers there is a
reasonable prospect all three biological control agents would successfully establish, in view
of the introduction regime proposed by the applicant (in conjunction with Landcare Research,
their science provider). The Committee notes the experience of Landcare Research at
researching, rearing, establishing and monitoring populations of biological control agents.
Landcare Research manages the distribution of biological control agents via technology
transfer programmes with regional councils, DoC, Landcorp Farming Ltd, community groups
and forestry companies.
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Although the insects have not been used in biological control programmes overseas (therefore
no field efficacy data is available), evidence from field observations in Europe, laboratory
observations, and biological control programmes involving flies from both families
Cecidomyiidae (gall flies) and Syrphidae (hover flies), leads the Committee to consider that
the insects are likely to provide a degree of control of Hieracium species in the long-term (ie
up to 20 years) by reducing the vigour and competitiveness of the plants. This may take the
form of slowing or halting infestation of Hieracium into new areas, slowing or halting any
increase in density of infestation in existing areas, or even reducing the existing area of
Hieracium cover. Specific benefits related to slowing, halting or reducing Hieracium
infestation are discussed below.
Extent to which the biological control agents subject to this application complement
those already present in New Zealand
The Committee was concerned that the benefits of introducing the three biological control
agents over and above those provided by the existing Hieracium biological control (ie O.
pilosellae, A. subterminalis and P. hieracii var. piloselloidarum) were not clear. The
Committee therefore considered a key factor associated with benefits was the extent to which
the proposed and existing control agents complemented each other.
In general, the use of a suite of biological control agents is considered advantageous in terms
of keeping pressure on the plant under changing conditions, in different seasons and in
different regions. Records show that M. pilosellae, C. psilophthalma and C. urbana feed on a
broader range of Hieracium species than the biological control agents already present in New
Zealand. The Committee has also taken into account the insect life cycles and mode of attack
of the agents (as detailed in Annex 2 of this decision) and considers their different hostranges and modes of action would provide complementary control of the target Hieracium
species.
The Committee notes that competition, particularly indirect competition, is possible.
However, only under particular and relatively rare conditions, might an ineffective biological
control agent decrease the population of a more effective agent, eg by rendering a valuable
resource (part of the plant) unavailable at a critical time. The fact that one species survives at
the expense of another is more likely to be the case if resources (ie the target) is significantly
reduced. The Committee considers that deleterious competition is very unlikely to occur in
this case.
The Committee notes it is possible the adult insects could play a role in transmitting spores or
propagules of the rust fungus P. hieracii var. piloselloidarum between H. pilosella plants,
which would be beneficial for Hieracium control.
Overall, the Committee considers the complex of three biological control agents are likely to
act in a complementary fashion (with each other as well as with the three biological control
agents already present in New Zealand) to achieve a degree of biological control of the target
Hieracium species.
Post-release management of the biological control programme
The Committee notes the importance of on-going post-release monitoring in biological
control programmes to record efficacy and non-target effects. While the Committee cannot
Environmental Risk Management Authority Decision: Application NOR00001
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attach controls to the release of new organisms, it acknowledges that monitoring protocols are
currently being established and endorses the applicant’s intention to follow through with
monitoring, at least in the short-term.
The Committee notes the comments presented by Mr Ensor of the South Island High Country
Committee at the hearing, that farmers strongly support the Hieracium Control Trust and
have invested considerable money into the biological control programme. The Committee
considers the Hieracium Control Trust, funded by groups such as farmers, local government,
DoC, MAF and agricultural industry, have a large vested interest in establishing the
biological control agents.
The fact that the Hieracium Control Trust is coordinated with many professional
organisations in agriculture and conservation (as detailed above) provides confidence that
land management issues are likely to be subject to coordinated and ongoing discussion and
research with experts in a range of fields. However, the Committee notes that the Hieracium
Control Trust is likely to scale-down gradually over 3-5 years from the establishment phase
of the biological control programme, especially should significant control of Hieracium
species be achieved. Acknowledging that the Hieracium Control Trust is both a community
programme, as well as being associated with many central and local government agencies,
the Committee supports any initiatives involving these parties to take over responsibility for
the management of the programme in the future.
Based on comments by Dr Molloy (representing the applicant) at the hearing, the Committee
notes concern that DoC may not be directly involved in establishment of the biological
control agents post-release. Therefore the Committee has substantial reservations whether
active spread of the biological control agents on the conservation estate will occur.
Beneficial environmental effects
A concern relating to consideration of benefits was establishing the existence of potential
environmental benefits to controlling Hieracium species. The threat of Hieracium species to
the environment is discussed below, along with assessment of specific potential beneficial
effects to the environment.
The Committee notes that DoC, Federated Farmers and the South Island High Country
Committee identified benefits to the environment from controlling Hieracium species in their
submissions.
Threat of Hieracium species to the environment
The Committee considered the extent to which Hieracium species pose risks to biodiversity
and the intrinsic value of ecosystems in New Zealand. Evidence presented to the Committee
demonstrates that Hieracium species can dominate a wide range of habitats (as detailed in
sections 1.1, 5.4.2 and 5.4.3 of the E&R Report, and summarised in Annex 1 of this
decision).
Hieracium species are recorded as dominant, conspicuous, or common over more than 40%
of the total hill and high country area of the South Island, and are also well established in the
Central North Island, at least as far north as Taupo, and east into Hawke's Bay. The potential
for species in this genus to further invade native habitats, including grasslands, shrublands
and forest margins, spread into new regions such as the Wairarapa and southern Hawke's
Environmental Risk Management Authority Decision: Application NOR00001
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Bay, and increase density in areas already infested, is also noted. Mr Ensor of the South
Island High Country Committee presented information at the hearing that there are
approximately 3.5 million hectares of tussock grassland in the South Island, two-thirds of
which is in the conservation estate and 1 million hectares in pastoral leases.
Field observations of H. pilosella in New Zealand show its mat-like growth can form a virtual
monoculture over large areas. Hieracium has the ability to survive to the detriment of
surrounding tussocks and other plants, particularly where soil moisture and nutrients are
limited. Hieracium species can reduce soil pH and are considered to exhibit allelopathy (ie
production of chemicals that inhibit growth of other species of plants) in certain situations, eg
immediately after droughts (noted in the hearing presentation by Dr Scott, representing the
Hieracium Control Trust). The Committee accepted that Hieracium species can successfully
out-compete many other species in a range of high and hill country habitats.
H. pilosella establishes on moderately fertile undisturbed topsoil, in over-grazed short
tussock grasslands and is very drought tolerant. Once a plant has established, local spread is
vegetative. The spreading stoloniferous patch formation of H. pilosella displaces resident
vegetation and its low growth habit limits stock grazing. There are no real limitations to seed
spread (by wind, animals etc) in terms of geographic spread.
In drier districts, H. pilosella and to some extent H. praealtum have displaced many native
species, including large herbs such as short and tall tussocks and can exclude native shrubs
such as Discaria toumatou (matagouri) and Melicytus aplinus. In moister to higher rainfall
districts, H. praealtum, H. caespitosum and H. lepidulum now dominate the groundlayer of
montane and subalpine shrublands, and the floor of beech and mixed conifer/hardwood
forests, usually at the expense of native herbaceous plants. Endemic plants confined to
limestone habitats are under severe threat from H. pilosella, and in places H. lepidulum, with
both species invading all available niches, replacing rare native species and/or preventing
their further recruitment (noted in the hearing presentation by Dr Molloy).
It is generally well accepted that where plant diversity declines (and particularly where there
is a virtual monoculture), it is an indicator that associated invertebrate diversity is also likely
to decline. Invertebrates that are quite host-specific would be particularly under threat.
Examples of native insects in this category may include some scarab beetles, weevils and
pollinating moths. Consequent food chain effects are likely to impact on higher order
organisms, such as birds (including kea and falcon), skinks, etc.
The Committee is satisfied Hieracium species pose a direct threat to biodiversity and
indigenous ecosystems. In reaching this conclusion, the Committee notes the current lack of
successful methods to control Hieracium species. There is no herbicide available that is
highly selective for the weeds, therefore a broad-band herbicide is required. Chemical control
is prohibitively expensive for all but a few high-productive areas. Grazing management may
have some influence over the rate of spread of Hieracium species in farmed land, but the lowgrowing habit of H. pilosella, in particular, reduces the effectiveness of grazing management.
Fertiliser is also recorded to control Hieracium predominance in pasture, however like
chemical control, it is only financially viable for certain areas. It was noted by Dr Scott in his
hearing presentation that he has tested more than 20 plant species over a 15-year period,
seeking to identify a pasture species that can out-compete Hieracium in low-input agricultural
conditions, but without success. It is the consensus of the Hieracium Control Trust and
associated expert advisors, that biological control offers the best hope of controlling
Environmental Risk Management Authority Decision: Application NOR00001
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Hieracium species. In conservation areas none of the alternative control methods (grazing
management, herbicide use, or fertilisers) are viable.
In considering the distribution of beneficial environmental effects (clause 13(b) of the
Methodology) it is emphasised by the Committee that the natural spread of natives is likely to
be slow and it is more likely that other introduced species would dominate (the potential for
exotic grasses to establish is discussed below, under beneficial economic effects, and the
potential for weeds to establish is discussed above, under adverse environmental effects).
However, native plants that are already present in, or bordering, Hieracium–infested areas
may extend their range and/or density if competition is reduced. Species likely to benefit
include those present in tussock grasslands, montane and subalpine shrublands, and beech
and mixed conifer/hardwood forests. Areas affected would include conservation lands,
National Parks, forest reserves, scenic reserves, scientific reserves, and retired farmland.
The Committee considers that given partial biological control of target Hieracium species in
the long term, a low level of natural revegetation with native species might be possible over a
widespread area, and more concentrated active revegetation would be possible through
localised conservation projects. Although it is speculative to consider that native plant
populations would increase significantly, a reduction in Hieracium populations may alleviate
direct threats to vascular plants currently under habitat pressure. Minor benefits to native and
valued flora and fauna may also arise due to a more diverse exotic plant species composition.
On balance, the benefits associated with enhanced native biodiversity may range from minor
(ie localised) to major (ie potential to be widespread, alleviate threats to specific native
species, and prevent species loss in the wild). The Committee considers at least minor
biodiversity benefits are likely.
Reduced soil erosion & improved water quality
It is possible that replacement of Hieracium species by more desirable plants could lead to
improved water quality through slowed water run-off and reduced erosion. However,
replacement by tussock species, which have a known water-holding capacity, is likely to be
slow (refer to section 5.4.2 of the E&R Report).
If there is regeneration by native plant species, there are likely to be beneficial indirect effects
in reducing soil temperatures and increasing its organic content. The Committee also notes
that because of the low-growing habit of Hieracium species, the wind can get closer to the
ground, causing some soil erosion where there is bare soil.
Because it is difficult to predict what plants would establish should Hieracium species be
removed, the Committee notes it is difficult to predict if replacement plants would reduce
water run-off and erosion. On balance the Committee considers benefits are likely to be
minor in the long-term (ie localised with some beneficial flow-on effects).
Reduction in use of herbicides
The Committee notes that herbicides are not commonly used to control Hieracium species as
they are expensive, and have the disadvantage of removing clover from pasture. However,
when used, herbicides are likely to present a threat to non-target species, including native
vegetation. By decreasing the need for herbicide use, threats to native vegetation are likely to
be reduced. Based on the fact that herbicide use for Hieracium control is not frequent or
Environmental Risk Management Authority Decision: Application NOR00001
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widespread, the Committee considers that on balance, the benefits from reduced herbicide use
would be minimal to minor (ie localised).
Effect on predators & parasites
It has been identified that the presence of biological control agents could act as an additional
food source and therefore enhance populations of rare native predators and parasites that may
attack them. For this to be a real benefit the agents would need to have increased to a
significant population size and native predators and parasites would need to be quite
specialised. On the evidence from other projects using Cecidomyid species, increased
populations of native parasites are possible, but whether they would be rare parasites is not
possible to say at this stage. Too high a level of predation or parasitism would be detrimental
to the effectiveness of the biocontrol agents. On balance, the Committee considers the
benefits to rare native predators and parasites would be minimal (ie short term and localised),
and very uncertain.
Beneficial Māori cultural effects
The Committee has considered potential adverse effects associated with releasing the three
biological control agents 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, and clause 9(c)(iv) of the Methodology). The Committee considers
that the applicant’s consultation with Māori to establish the potential effects of introducing
the three biological control agents on the relationship of Māori with their taonga was
adequate. No submitters identified cultural issues associated with the application.
The Committee has taken into account the views of Ngā Kaihautū Tikanga Taiao, which
stated in its report to the Authority:

Ngā Kaihautū believes that the biological control of Hieracium species as presented
in this application is likely to increase the protection of the mauri (spiritual integrity
or life-force) of valued flora and fauna, and of the mauri of land, waterways, air and
other taonga.

However Ngā Kaihautū acknowledges that the cultural and spiritual aspects of
introduced biological control agents are still being determined by Māori, as stated by
the applicant.

Ngā Kaihautū notes that the applicant has observed that the general issues of
biological control need to be discussed in a wider forum. Ngā Kaihautū encourages
the applicant and associated scientific research organisations, to maintain close and
continuing links with Māori organisations to enable progress reports on the
monitoring of biocontrol issues to be freely discussed and debated.

Many of the concerns expressed about biocontrol issues have to do with the
knowledge that some organisms released in the past although intended for biological
control have subsequently become agents or pests threatening the native flora and
fauna. For this reason an integral part of the research requirements of all scientists
must include the ability and willingness to communicate openly, honestly and freely
with all New Zealanders about their research, including its potential risks as well as
the benefits.
Environmental Risk Management Authority Decision: Application NOR00001
Page 20 of 34
As noted above, the Committee recognises that the applicant intends to conduct post-release
monitoring of the insects as part of the proposed release programme. 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 hopes it will make these results available to relevant iwi.
The Committee considers this application may have downstream benefits for the relationship
of Māori and their culture and traditions with valued flora and fauna, as the successful control
of the target Hieracium species would enhance native species (eg by reducing competition of
Hieracium species with native flora, some of which are highly endangered).
The Committee’s duty includes taking into account the relationship of Māori with valued
flora under section 6(d) of the HSNO Act. The Committee believes that approving the release
of the organisms would promote protection of native flora, based on the evidence at the
hearing, that native flora are at risk of local extinctions from the effects of Hieracium species,
and the fact that Hieracium is continuing to spread.
The Committee concludes that given the potential risks posed by the target Hieracium species
to native and valued flora and the intrinsic value of ecosystems in New Zealand and the
absence of identifiable adverse effects on Māori culture attributable to releasing the proposed
biological control agents, the effect of release on Māori taonga will, if anything, be positive.
Beneficial human health effects
Clauses 9(c)(iii), 10(c), 10(g) and 12 of the Methodology are considered to be particularly
relevant to the assessment of beneficial human health effects, including effects on public
health and safety.
The Committee has considered potential effects of releasing the three biological control
agents on human health. Any reduction in use of herbicides to control the target Hieracium
species may have beneficial health effects. No other potentially significant human health
effects were identified. However, there is no quantitative information in the application as to
the extent of current herbicide use for Hieracium control. The Committee believes that the
quantity of herbicide used is low, given the limitations of use identified by the Mr John
Aspinall, representing the Hieracium Control Trust, at the hearing. The public health benefits
of the introduction of the three flies from reduced herbicide use are therefore assessed to be
minimal.
Beneficial social & community effects
Clauses 9(b) and 12 of the Methodology are considered to be particularly relevant to the
assessment of beneficial social and community effects, including effects on the maintenance
and enhancement of the capacity of people and communities to provide for the reasonably
foreseeable needs of future generations.
Beneficial effects on communities resulting from increases in productivity are dependent on
the efficacy of the biological control agents and revegetation with suitable pastoral plant
species, and would only be realised in the long-term.
Overall, the Committee considers the potential social and community benefits associated with
successful biological control would be minimal to minor (ie localised in area and number of
individuals affected), uncertain, and likely to have a long lead-time (up to 20 years).
Environmental Risk Management Authority Decision: Application NOR00001
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Beneficial economic effects
Clauses 9(b) and 9(c)(v) of the Methodology are considered particularly relevant to the
evaluation and consideration of beneficial economic effects, including effects on the
maintenance and enhancement of the capacity of people and communities to provide for their
own economic wellbeing and related benefits.
Introduction and establishment of the biological control agents may result in economic
benefits to high-country pastoral farmers and nature tourism operators. Non-monetary
benefits to the biophysical environment have been discussed earlier.
Pastoral production
The Committee notes that Federated Farmers (National), the Federated Farmers South Island
High Country Committee and the Otago Regional Council have expressed support for the
introduction of the biocontrol agents on the basis of the potential for increased pastoral
production. The Committee notes the view expressed in the hearing presentation by Mr Ensor
of the South Island High Country Committee, that farmers consider the biological control
programme will have been a success if it halts further spread of the target Hieracium species.
The applicant states that an estimate (McMillan 1991) placed one million stock units
potentially at risk due to reduced pasture production attributable to invasion of Hieracium
species. This represents a loss of up to $76 million per year.
The applicant has undertaken a cost-benefit analysis estimating the benefits of biological
control to the pastoral sector, after taking into account the costs to the Hieracium seed
industry. The Committee notes that while there is the potential for economic benefit to New
Zealand through increased production on lands currently adversely affected by Hieracium
species, there is substantial uncertainty about the likelihood and magnitude of this benefit.
The uncertainty relates principally to the likelihood of the agents’ exerting effective control
and factors affecting the replacement of Hieracium by other plant species. If the agents
become established and reduction in Hieracium occurs, moderate benefits are likely if pasture
revegetation is actively managed. However, if reduction in Hieracium occurs with little active
pasture revegetation, only minimal to minor economic benefits are likely.
Tourism (related to scenic & aesthetic values)
The applicant has noted that tussock landscapes have scenic and aesthetic value for travellers,
tourists, and residents of the hill and high country (non-use values). Landscape values were
also identified in the submission from Federated Farmers.
The spread of Hieracium species in these areas is associated with reduction in native tussock
and herb species, and a reduction in these values. There may therefore be economic benefits
if Hieracium control is successful, related to increased tourism associated with improved
scenic and aesthetic values. The Committee notes the indirect nature of these potential
benefits.
As detailed above, there is uncertainty about the species likely to replace Hieracium and it is
speculative to consider that native plants will increase significantly, at least in the short to
medium term. Therefore, the Committee considers that potential economic benefits relating
Environmental Risk Management Authority Decision: Application NOR00001
Page 22 of 34
to improved scenic and aesthetic values would be minimal to minor (ie localised in area and
number of individuals affected), and likely to have a long lead-time (up to 20 years).
Minimum standards
Under section 36 of the HSNO Act and clause 10 of the Methodology, the Committee is
required to decline the application if the new organisms are likely to fail to meet specified
minimum standards.
The Committee considered the minimum standards and is satisfied that release of the three
biological control agents would not fail to satisfy these standards. As discussed above under
assessment of adverse environmental effects, the insects are very unlikely to cause significant
displacement of native species within their natural habitat, or interbreed with any native
species and adversely affect New Zealand’s inherent genetic diversity. Significant
deterioration of natural habitats is considered very unlikely as the insects are host-specific to
Hieracium species and rapid removal of the target weeds from the environment is very
unlikely.
As discussed above under assessment of adverse environmental and human effects, it is also
very unlikely that the insects could represent a threat to human, animal or plant health (apart
from attack of target Hieracium species). In relation to threats to animal or plant health the
insects are not known to host any inseparable organisms and there is no evidence to suggest
that they could become active vectors of insect-borne animal or plant pathogens. Once in
New Zealand, the insects could conceivably passively disperse plant pathogens already
present in the country, possibly picking up fungal spores, etc, in the way that all similar
insects might do. Because the insects are very likely to be host-specific, it is unlikely they
would transmit diseases to non-target plant species. It is possible the adult insects could play
a role in transmitting spores or other viable propagules of the rust fungus P. hieracii var.
piloselloidarum between H. pilosella plants, which would be considered beneficial.
Ability of the organisms to establish undesirable selfsustaining populations & ease of eradication of any such
populations
In accordance with sections 44 and 37 of the HSNO Act, the Committee considered the
ability of the biological control agents to establish undesirable self-sustaining populations,
and the ease with which such populations could be eradicated. In evaluating these matters, the
Committee took into account the nature of the organisms.
As specified above, the purpose of the biological control programme is to establish selfsustaining populations of M. pilosellae, C. psilophthalma and C. urbana in the field.
Considering the large area covered by target Hieracium species (including the remoteness
and steep topography of much of the terrain) it is very unlikely that eradication measures (eg
application of insecticide) would be feasible, if self-sustaining populations establish.
However, the Committee considers the establishment of self-sustaining populations would
not be undesirable.
Environmental Risk Management Authority Decision: Application NOR00001
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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 the key potential risks associated with the biological control
programme are: (i) non-target effects (ii) replacement of the target weeds with other weed
species. The Committee accepts that these risks would be involuntary, could persist over
time, could be subject to spread and could be irreversible. The Committee considers the
public do have some understanding of biological control and potential non-target effects.
The Committee is willing to tolerate these risk characteristics because the key risks identified
are considered to be very unlikely to eventuate. In the event that other weed species replace
the target Hieracium species, the Committee considers there would be potential for their
control in the long-term. Furthermore, should the insects become established and contribute
to control of Hieracium species, environmental and economic benefits are likely.
Overall evaluation of risks, costs & benefits & 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)(a): To import for release 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 the three biological control
agents is to establish self-sustaining populations in the uncontrolled environment.
Establishment of a self-sustaining population would be desirable and irreversible in
nature.
4.
The Committee, in reaching its decision under clause 36(2)b of the Methodology,
records that it has applied the balancing tests in section 38 of the HSNO Act and clause
26 of the Methodology. The following criteria in the HSNO Act and Methodology have
been particularly relied on:
Environmental Risk Management Authority Decision: Application NOR00001
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5.

Section 5(b) – to achieve the purpose of the Act and to recognise and provide for the
maintenance and enhancement of the capacity of people and communities to provide
for their own economic, social, and cultural wellbeing and for the reasonably
foreseeable needs of future generations;

Section 6 and in particular section 6(c) (public health) and 6(d) (the relationship of
Māori and their culture and traditions with their ancestral lands ... and other taonga)
and (e) (the economic and related benefits to be derived from the use of the new
organism);

Section 8 – the principles of the Treaty of Waitangi;

Clause 26 - The Committee formed the view that risks associated with the release of
M. pilosellae, C. psilophthalma and C. urbana are negligible and furthermore that
benefits outweigh the costs. Therefore the Committee has considered this application
in terms of clause 26 of the Methodology.

Clause 9(b) [equivalent of section 5(b)] and 9(c) [equivalent of section 6]; clause 10
[equivalent of sections 36 and 37]; clause 12 – evaluation of assessment of risks;
clause 13 – evaluation of assessment of costs and benefits; clause 21 – the decision
accords with the requirements of the Act and regulations; clause 22(1) – the
evaluation of risks, costs and benefits – relevant considerations; clause 24 – the use
of recognised risk identification, assessment, evaluation and management
techniques; clause 25 – the evaluation of risks; clause 26 – risks are negligible and
costs are outweighed by benefits; and clause 29 (a) - determination of materiality
and significance of scientific uncertainty; clause 33 – risk characteristics; and clause
34 – the aggregation and comparison of risks, costs and benefits.
In evaluating risks, costs and benefits associated with the application, the Committee
concludes that:

Key potential risks are (i) non-target effects (ii) replacement of the target weeds with
other weed species.

It is very unlikely that a species other than M. pilosellae, C. psilophthalma and C.
urbana would be released due to incorrect identification, as taxonomic identification
by a recognised specialist would be conducted during the first generation the insects
were held in quarantine containment (in accordance with an Import Health Standard
issued by MAF under the Biosecurity Act 1993).

The three biological control agents are not known to host any inseparable organisms.
Any insect populations imported for release would be required to be free of
hyperparasites and pathogens in accordance with an Import Health Standard.

There is no evidence to suggest that the biological control agents could become
vectors of insect-borne human, animal or plant pathogens, other than passively as
they move around in the environment, possibly picking up fungal spores etc, in the
way that all similar insects might do.

Results from host-range testing provide a very high level of confidence that the three
biological control agents are specific to Hieracium species. Insects imported for
release will be collected from the same field-sites as those used for host-range
testing, so risks associated with ecotype variability will be minimal.

Replacement of Hieracium species by forage species and other weeds is likely, and
by native species to a limited extent. Adverse environmental consequences could
Environmental Risk Management Authority Decision: Application NOR00001
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range in impact from minor to major, depending on the plant species involved, but
are unlikely to be any worse than the present effect of Hieracium species.

Hieracium species are a serious threat to biodiversity and indigenous and pastoral
ecosystems integrity.

M. pilosellae, C. psilophthalma and C. urbana are likely to be complementary in
action to the agents already present in New Zealand (ie O. pilosellae, A.
subterminalis and P. hieracii var. piloselloidarum) for the biological control of
Hieracium species, given their temperature and moisture parameters and modes of
attack.

The risks to the relationship between Māori 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. Apart from
a general opposition to the importation of new species into the environment, no
separate or distinct cultural or spiritual concerns were identified. The extinction of
native and valued flora and ecosystems effects from Hieracium invasion is likely to
have a greater adverse impact on taonga Māori than the introduction of the three
biological control agents into the environment.

Benefits associated with the release of the three biological control agents are
dependent on the insects establishing and exerting control over Hieracium species.
The estimates of level of benefit are uncertain because the efficacy of the agents is
uncertain and it is difficult to calculate the total present and potential future adverse
impacts of Hieracium species on the environment, human health, culture and
economy. Nevertheless should the agents establish and control Hieracium spread,
benefits are expected to accrue to high country pastoral farmers and to the
conservation estate. Economic benefits are likely to accrue primarily to the high
country pastoral farmers, mainly as increases in production. The financial benefits to
the industry are likely to exceed the financial costs of importing, breeding and
releasing the biological control agents.

There may also be environmental benefits to native biodiversity and ecosystems
integrity from controlling Hieracium species. The extent of these benefits depends
on how native plant species regenerate if Hieracium is controlled, and whether or
not other weedy species take advantage of this removal. Benefits are expected to be
minor to moderate (ie low level of natural re-vegetation over a widespread area, with
some flow-on effects).

If the insects do not establish, the Committee considers that it is very unlikely that
the release would have any adverse effects, because it is very unlikely there will be
any significant non-target attack of native plants.

The Committee concludes that, should the biological control agents establish and
exert control on Hieracium, positive net benefits would occur although their
magnitude is very uncertain. Should the agents not establish or be ineffective, the net
benefits would be negative. However, given the absence of significant risks
associated with failed introduction of the agents, the costs of such a failure in the
Hieracium control programme would fall entirely on the applicants. It is self-evident
from the application to import the agents, that the Hieracium Control Trust is willing
to assume this financial risk.
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
Environmental Risk Management Authority Decision: Application NOR00001
Page 26 of 34
Committee considers that the positive (beneficial) effects of releasing M. pilosellae, C.
psilophthalma and C. urbana outweigh the adverse effects.
The application to release from containment the new organisms, M. pilosellae, C.
psilophthalma and C. urbana, 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 M. pilosellae, C. psilophthalma
and C. urbana shall lapse five years after the date of the approval, unless the organisms are
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 M. pilosellae, C.
psilophthalma or C. urbana in accordance with this approval shall notify the Authority within
one month after the date of release.
Name
Chair
Special Committee of the Authority
Date
Environmental Risk Management Authority Decision: Application NOR00001
Page 27 of 34
References
Grosskopf, G., Lucas, C. and Brockington, M. 2000. Investigations on potential biological
control agents of hawkweeds, Hieracium spp. Annual Report 2000. CABI International.
McMillan, G. 1991. Hawkweed Report. Hieracium – an ecological perspective. Journal of
the New Zealand Mountain Lands Institute review 48:8-20.
Scott, D. 1997. Ecological consideration in plant invasion. Proceedings of the International
workshop on biological invasions of ecosystems by pests and beneficial organisms. Tsukuba,
Japan, pp 128-142.
Syrett, P. and Smith, L. A. 1998. The insect fauna of four weedy Hieracium (Asteraceae)
species in New Zealand. New Zealand Journal of Zoology 25: 73-83.
Wapshere, A. J. 1974. A strategy for evaluating the safety of organisms for biological weed
control. Annals of Applied Biology 77: 201-211.
Webb, C. J., Sykes, W. R. and Garnock-Jones, P. J. 1988. Flora of New Zealand. Volume IV.
Naturalised Pteridophytes, Gymnosperms, Dicotyledons. Botany Division, Department of
Scientific and Industrial Research, New Zealand.
Environmental Risk Management Authority Decision: Application NOR00001
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Annex 1: New Zealand distribution & habitat of weedy Hieracium species (Webb et al 1988)
Common
name
Orange
hawkweed
Hieracium species
Sub-genus Distribution in NZ (1988)
Origin
Habitat
H. auranticum L.
(1753)
Pilosella
North Island: Manawatu (Feilding)
South Island: Nelson, Canterbury,
Westland (Otira), Otago, Southland
Stewart Island: Halfmoon Bay
Europe, 1911
Field
hawkweed
H. caespitosum
Dumort. (1827)
Pilosella
South Island: Marlborough, Canterbury,
Otago (Old Man Range)
Europe, 1940
mouse-ear
hawkweed
H. pilosella L.
(1753)
Pilosella
North Island: Rotorua, Volcanic Plateau,
Lake Waikaremoana, Kaimanawa and
Ruahine Ranges, Hawke's Bay
South Island: Marlborough, Canterbury,
Westland (Douglass R.), Otago,
Southland
Europe, North
& Central
Asia, 1878
king devil
H. praealtum
Gochnat (1908)
Pilosella
North Island: Volcanic Plateau (between
Tokoroa and Taupo)
South Island: Nelson (Glenhope),
Marlborough (Mt Richmond),
Canterbury, Westland, Otago.
Europe, 1924
Waste land, grassland, scrub, tussock grassland,
roadsides, lawns, gardens, and pastures.
Applicant notes: It is palatable to both cattle & sheep
therefore more of a problem in conservation areas
than grazed areas. Ecology akin to H. caespitosum.
Grassland, scrub, tracksides, riverbanks, forest
margins, roadsides, pastures.
Applicant notes: slightly lower drought tolerance,
low-fertility tolerance & potential growth c.f. H.
pilosella. More erect growth habit than H. pilosella,
hence more influenced by grazing.
Prominent weed of high country pastures & tussock
grasslands. Tussock grasslands, lawns, waste land, river
terraces, roadsides, rock outcrops, pastures.
Applicant notes: Has been in NZ longest and is most
widespread & invasive. Very drought tolerant (~700900mm rainfall zone). Moderate fertility species. Low
growth habit reduces influence of grazing.
Grassland, scrub, stony sites, waste land, roadsides,
pasture, occasionally in wet sites.
Applicant notes: Higher fertility, moister sites than
H. pilosella. More upright and amendable to grazing.
Can be a major weed of conservation areas.
Environmental Risk Management Authority Decision: Application NOR00001
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Common
name
-
Hieracium species
Sub-genus Distribution in NZ (1988)
Origin
Habitat
H. x stoloniflorum1
Pilosella
North Island: Taranaki, Wellington City
South Island: Marlborough (Pelorous
Sound), Canterbury, Westland (Otira),
Otago (Oamaru, Queenstown).
Gardens, waste land, roadsides, grassland, forest and
scrub.
Tussock
hawkweed
H. lepidulum
(Stenstroem)
Omang (1905)
Hieracium
North Island: Taranaki
South Island: Nelson, Marlborough,
Canterbury, Otago.
Central
Europe, NW
Russia, but the
hybrid
possibly arose
spontaneously
in NZ, 1988
Central &
North Europe,
1946
1
Grassland, roadsides, riverbanks, riverbeds and gold
tailings, beech forest, scrub, pine forests.
Applicant notes: Grows in more moist and shaded
sites than H. pilosella. Most widespread species in
open forests, forest clearings, margins & wetter
tussock grasslands. Plants of subgenus Hieracium die
following flowering.
H. stoloniflorum is a hybrid between H. auranticum and H. pilosella and perpetuates itself apomictically (ie a plant producing viable seed without
fertilisation). It is intermediate in characteristics between its two parents. The hybrid is likely to have come from Europe (where it is
recorded in major flora publications) and may also have generated naturally in New Zealand in areas where the distribution of parent
species overlap.
Environmental Risk Management Authority Decision: Application NOR00001
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Annex 2: Potential efficacy of biological control agents
against Hieracium species
Hieracium
species
H. pilosella
H. praealtum
H. caespitosum
H. lepidulum
H. auranticum*
Agents proposed for release
Gall midge Root
Crown
feeding
feeding hover
hover fly
fly
M. pilosellae C. urbana C.
psilophthalma
++
+
+
-
Mode of action Forms galls
at stolon tips
of biological
& rosette
control agent
centres in
which larvae
feed. Several
generations/
year
++
++
++
++
++
++
++
++
+
++
Larvae
Larvae feed in
feed
the crown of
externally the plants
on roots
Root fungus
Past introductions
Plume moth Gall wasp
P. hieracii var.
piloselloidarum
O. pilosellae A.
subterminalis
++
-
++
+
++
+
+
++
++
Attacks above
ground parts of
the plant & only
some forms of
H. pilosella.
Low intensity
but continuously
present
Caterpillars
attack above
ground parts
of the plants
Forms galls at
the end of
stolons,
affecting
vegetative
reproduction
++
+
+/-
Insect feeds and develops on the species of Hieracium, equivalent to level on H. pilosella
Insect feeds and develops on the species of Hieracium, but to a less extent than that on H. pilosella
No, or minor, feeding and development of biological control agent on the species of Hieracium
*
Note that the applicant did not consider that H. auranticum was a weed concern in New Zealand when
the Hieracium Control Trust's biological control programme was initiated
Environmental Risk Management Authority Decision: Application NOR00001
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Annex 3: List of submitters on Application NOR00001
No.
Submitter Name
Organisation/
Contact
Position on
application
Wish to be
Heard?
Department of Conservation
Michael Cameron
support
No
Entomological Society of New
Zealand
Chris Green
not specified
No
3
Federated Farmers
Susan Redward
support
Yes
4
National Beekeepers' Association
Jane Lorimer
not specified
No
5
Otago Regional Council
Selva Selvarajah
support
No
6
South Island High Country
Committee
Bob Douglas
support
Yes
1
2
Environmental Risk Management Authority Decision: Application NOR00001
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Annex 4: Qualitative scales for describing effects
Adverse effects
Qualitative assessments use words to describe the 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. The following sets of word scales are used:
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
Equally likely or unlikely
50:50 chance of occurring
Likely
Will probably occur at some time
Very likely (almost certain) Is expected to occur
Table 2: Magnitude of adverse effect
Descriptor
Examples of descriptors for type and extent of adverse effect
Minimal
slight or insignificant, repairable or reversible, very localised (affecting
only a few individuals, single plants/animals or individual businesses), no
flow-on effects, acute rather than chronic, not affecting native or valued
species
Minor
small, reversible and short term, localised to small land area or local
community, acute, possible affecting valued species but not native species
Moderate
medium or mid range, largely but not completely reversible or medium
term effect, some limited flow-on effects, slight effect on native species,
affecting plants/animals/people/small industry over a wide area, but not
necessarily over the whole country
Major
large, long term effect, but no species loss, affecting the whole country,
both acute and chronic health effects possibly leading to small number of
deaths or reduced life expectancy,
Massive
huge and widespread, irreversible, national impact, considerable secondary
effects, acute and chronic health effects leading to deaths, species loss,
serious social and cultural damage with displacement of persons and loss of
livelihood, major economic disaster
Environmental Risk Management Authority Decision: Application NOR00001
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Beneficial effects
The word scale used to describe the likelihood of beneficial effects is the same as stated in
Table 1 above. A qualitative assessment to describe the magnitude of beneficial effects has
been made. The following word scale is used:
Table 3: Magnitude of beneficial effect
Descriptor
Examples of descriptors for type and extent of beneficial effect
Minimal
slight or insignificant, short term, very localised (affecting only a few
individuals, single plants/animals), no flow-on effects
Minor
small, reversible, localised to small land area, a group of individuals,
a single company/organisation or a local community
Moderate
medium or mid range, medium term, affecting
plants/animals/people/small industry over a wide area, but not
necessarily over the whole country, some flow-on effects, regional
short/medium term reduction in a weed/pest
Major
large, affecting large communities and industries, some national
impact
Massive
huge and widespread, long term, national impact, extensive
secondary or flow-on effects, eradication of a weed/pest, large
increases in employment, development of a new industry
Environmental Risk Management Authority Decision: Application NOR00001
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