SUBM ISSION ON APP201941 Importation of RANM AN containing active - PowerPoint PPT Presentation

SUBM ISSION ON APP201941 – Importation of RANM AN containing active ingredient cyazofamid, for use as a foliar applied fungicide. from TE R Ū NANGA O NG Ā I TAHU by Gerry Te Kapa Coates M ember, HSNO Komiti

THE NG Ā I TAHU TAKIW Ā Waihao Over 90% of the South Island & over 40% of NZ land mass. Extends from Kaikoura in the north to Rakiura (Stewart Island) in the e R ū nanga o Ng ā i Tahu south, including the West Coast, T eTai Poutini. T constitutes 18 R ū nanga representing geographical areas, generally based around traditional settlements. “ Te Puna Waimaraarie, Te Puna Hauaitu, Te Puna Karikari” The pools of frozen water; The pools of bounty; The pools dug by the hand of humans ” - Rakaihautu Slide 2

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

TE R Ū NANGA O NG Ā I TAHU HSNO KOM ITI • 6 M embers • Responsible for monitoring new EP A applications • HSNO Policy Statement

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

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

TREATY CONSIDERATIONS • e R ū nanga o Ng ā i Tahu was statutorily recognised as T the representative tribal body of Ng ā i Tahu Wh ā nui e R ū nanga o Ng ā i Tahu Act 1996. under section 6 of T • This means we exercise kaitiakitanga over our takiw ā . • The EPA must be ever mindful of its responsibilities for ‘active protection’ under T e Tiriti o Waitangi. • Active protection needs to operate in terms of Te Tiriti , not through general concerns about health and safety issues and mechanisms. • The EPA’s role must also include finding ways to acknowledge, test and do research on the impacts of hazardous substances on 'down-stream' taonga native species including threatened species and ecosystems , in a similar manner to that required for introduced bio-controls.

SUBM ISSION ON APP201941 – Importation of RANM AN We oppose the introduction of the insecticide Ranman ( for use as a foliar applied fungicide that will be used to control sucking pests in horticultural crops primarily potatoes and onions) to New Zealand for the following reasons: • The application does not provide a persuasive case for the benefits as against any risks (little supporting evidence is provided apart from in a confidential appendix). • Toxicity of this new fungicide (and) insecticide with the active ingredien t cyazofamid raises serious concerns over risks to bees in particular, and to the aquatic environment , and should demand that extensive testing be undertaken by the applicant, or as is now proposed by the EP A using precautionary safety factors to safeguard native species.

SUBM ISSION ON APP201941 – cont. 1 General comments on the application: • As in many previous applications it is impossible to evaluate the evidence and truth of the claims made with almost all the data being in a Confidential Appendix. The US EPA data sheet goes some way to remedying this. • The International Regulatory status of the product is unclear. • RANM AN appears to comprise 400 grams per litre of the active ingredient cyazofamid , but no details are given of the rest of the ingredients in the formulation . • Potential risks associated with the four primary metabolites resulting from the degradation of the active ingredient cyazofamid in soil or water is difficult to assess because these chemicals were not named in the Application. However at least one (CCIM ) appears to be more acutely toxic than the active ingredient itself.

SUBM ISSION ON APP201941 – cont. 2 Specific comments: • Risks and benefits: The benefits cited are “ new chemistry which minimises the risk of disease resistance developing.” In fact this will only delay the onset of the risk. There are significant risks the substances will not be applied consistent with good practice and label instructions – especially for off label crops, and for bee protection. M ā ori Consultation: It is asserted without any evidence that “ the • applicant is unaware of any significant or adverse impact that importation, release and use of the substance would have on M aori cultural, spiritual, ethical and socio-economic values.” The assertions made about impacts on M ā ori can not be supported. • Quantification: There is no quantitative information on the benefits to be gained from the use of RANM AN or what the rationale is for adding another fungicide to the existing armoury of tools.

SUBM ISSION ON APP201941 – cont. 3 Risks of ground spraying : • – Waterways: Contamination of domestic water supplies especially waterways such as farm drains and streams from run-off as well as spray drift is particularly of concern to M ā ori who gather mahinga kai. – Adjacent crops and plants: Native plants such as watercress are just as important to M ā ori as commercial crops. • Ng ā Kaihaut ū report: None apparently done.

SUM M ARY We request the Application be declined because: • The Applicant appears to have taken a too casual approach to the information requirements. • No persuasive case including quantification of benefits has been made. • The supporting evidence provided is in a confidential appendix not available to submitters except by proxy in the Staff Evaluation report, or by inference from the US EP A data sheet. • The toxicity of this insecticide to bees , and the absence of any testing or evaluation of the impact on native species raises serious concerns over risks to the aquatic environment, and to people.