Submission date: 30 July 2009
Submitted to: Ministry of Agriculture and Forestry Biosecurity
The New Zealand Conservation Authority (the Authority) has repeatedly over the last decade expressed its alarm and frustration at the disinterest at departmental and Government level in preventing the damage to indigenous biodiversity caused by Undaria pinnitifida.
In the context of the current consideration of options to commercialise this seaweed now that it is naturalised in New Zealand, the Authority wishes to once again highlight the characteristics of this seaweed which led to its declaration as an unwanted organism:
The risks and possible environmental and cultural impacts of Undaria which will occur whether cultivated or not are considered to be -
Undaria behaves differently outside its native environment and any assumptions that are based on such behaviour are likely to prove to be erroneous.
The Authority therefore takes issue with the statement in the Discussion Document that “Undaria is likely to have moderate adverse impacts on the values that marine biosecurity aims to protect”. It is the Authority’s view that the impacts on conservation values are likely to be serious in the long term.
As stated in the Discussion Document, there is a risk that allowing greater commercial utilisation could increase the rate of spread of Undaria and increase its abundance in the areas where it is harvested.
The Authority has particular concern that if commercial harvesting is provided for any of the Undaria species that are already in New Zealand, there will be subsequent pressure to import new varieties with superior consumption qualities, which may prove to be even more aggressive than the strains already present. The favoured Japanese food variety is not currently in New Zealand but each Government’s desire to promote exports may be used as a reason to bypass sound biosecurity processes and underplay or undervalue the impact on indigenous biodiversity values.
If any commercial farming of Undaria is allowed, the Authority requests that a precautionary approach be taken and that it be confined to one existing infested area where there is already permitted marine farming (the Marlborough Sounds) to allow further evaluation of effects on indigenous ecosystems.
If any commercial farming of Undaria is allowed, it should be integrated with control programmes, and the farmers should be required to pay for monitoring the effects on indigenous biodiversity, and contribute to its protection including restoration through a resource utilisation royalty.
In conjunction with any change to the current management of Undaria, there need to be processes put in place which control the movement of all vessels and marine equipment operating in Undaria-infested waters. Lack of such measures to date have resulted in massive spread of this pest to pristine environments including the Snares and Great Barrier Islands. It is very important that every effort is made to prevent its spread to other high-value pristine areas such as the Chatham Islands, which have endemic algal fauna, other subantarctic islands, and Fiordland.
The Authority is opposed to the lifting of unwanted organism status. If, nevertheless, this is to occur, it should be only after a National Pest Management Strategy is in place so that control action is not left to the discretion of individual regions.
Finally, the Authority cautions against the commercial use of invasive species. Such use creates vested interests that later may create opposition to future efforts to control or eradicate the pest, should technical advances prove that practicable. New Zealand has a long history of such phenomena, and should be wary of providing financial incentives for invasive species.
In conclusion, the Authority considers that the potential impacts of commercial farming of Undaria have been down played. The Authority supports Option One and strongly opposes Option Three.