Ko Matou Ko Nga Tino Rangatiratanga PO BOX 105, KAEO 0448 [email protected]
NGĀPUHI HSNO KOMITI
TE OPE TAUMATA HE RAWA MOREAREA HE HA KOIORA 18TH July 2015
ENVIRONMENTAL PROTECTION AUTHORITY
SUBMISSION ON APP202336
To import for release GF-2687, a wettable granule herbicide containing 200 g/kg halauxifen-methyl and 200 g/kg florasulam
for the control of broadleaf weeds in
cereals
SUBMISSION APP202336 2 CONTENTS:
1. NGAPUHI HSNO KOMITI STATEMENT 2. WHAKAHAU O TE NGAPUHI HSNO KOMITI
AUTHORS: VIOLET WALKER – CULTURAL COMPLIANCE MANAGER BRYCE SMITH – CULTURAL RELATIONS ADVISOR
(09) 4060341 PO BOX 105 KAEO 0448
0210341963 02102680918
SUBMISSION APP202336 3 1. MANA
We the Ngāpuhi HSNO Komiti are a collective group of environmental technicians/practioners covering a wide range of environmental matters and issues.
We have come together as a HSNO Komiti taking responsibility for all HSNO applications for this territory.
We have reviewed the APP202336 – To import for release GF-2687, a wettable granule herbicide containing 200g/kg halauxifen-methyl and 200g/kg florasulam for the control of broadleaf weeds in cereals.
We will address specifically the proposed “Arial Application” within this application.
2. RAHUI
We the Ngāpuhi HSNO Komiti cover the territory of the Northern part of the North Island
“I Raro Mai o Hauraki”.
This territory we will identify as tribal areas, Murewhenua, Te Taitokerau, Hokianga North and South, Kaipara, Tamaki Makaurau and the Eastern Islands.
In 2007 our Northern territory engaged with the reassessment application for 1080. It was identified that contractors tasked with the Arial application of 1080 within our Northern territory was inadequate.
In our Northern territory, strong opposition to local government departments, and their failure to regulate the Arial application of 1080, concluding in strong public protest action to obtain a “Zero
Tolerance” of the Arial application of 1080 and all other poisons and chemicals.
3. IHI
Currently we are a mandated authority that covers this entire Northern territory area with the support of and direction from Te Taumata Kaumatua o NgāPuhi nui tonu.
4. WEHI
Our communities within our territory both Maori and Other are fully aware of the five yearly monitoring reports commissioned and published on the EPA website for 1080, in particular Arial application.
Although the number of recorded breaches have lowered from 2008 – 2013, we still feel that more can be done to show commitment and responsibility to the public and our environment by
contractors, land-owners, government departments and the EPA to mitigate all potential hazards and ensure compliance is 100% achieved for Arial application of not only 1080 and GF-2687, but all chemical herbicides and poisons.
Although we acknowledge a lessoning of regulation breaches, we feel that these slight
improvements do not meet our Northern territory standard of “Zero Tolerance” to give consent to Arial application of GF-2687.
SUBMISSION APP202336 4 5. TIKA
Tangata Whenua issues identified within our Northern territory for all applications for hazardous substances, including GF-2687 requesting Arial application can be summarized in the following points:
(a) Failure to recognise untargeted species (b) Failure to recognise endangered species (c) Failure to recognise native species
(d) Failure to recognise and provide for, have particular regard for and take into account cultural use of water
(e) Failure to recognise and provide for, have particular regard for and take into account cultural Medicinal flora and fauna
(f) Failure to recognise and provide for, have particular regard for and take into account cultural and wild Kai harvesting practices
(g) Failure to recognise and provide for, have particular regard for and take into account Traditional Cultivating practices
(h) Failure to Consult with Tangata Whenua in an appropriate manner (i) Failure to acknowledge Tangata Whenua in an appropriate manner (j) Failure to address concerns within our communities that have been raised
(k) Failure To compensate, social, cultural, political, environmental, economic mistakes (l) Failure to recognise aviation laws and rules
(m)Failure to recognise labelling compliances
(n) Failure to take into account the principles of Te Tiriti o Waitangi
(o) Failure to recognise and provide for, have particular regard for and take into account our Maori Sites of significance
(p) Failure to recognise and provide for, have particular regard for and take into account our Matauranga Maori
6. PONO
Unfortunately at this time, any herbicide, including GF-2687 requiring Arial application within our Northern territory, the Northern part of the North Island as stated in (2 – Rahui), will be met with strong opposition.
We offer this advice to the applicant to consider.
That the use of Arial application devices for GF-2687 be seriously reconsidered in an attempt to mitigate, not the chemical GF-2687 at this point, but the negligence of the contractor/s that apply such chemicals.
7. TUPU
We fail to understand the reasoning, other than financial, for the applicant to introduce this new herbicide, when approved herbicides with a similar purpose already exist in New Zealand.
8. WAIRUA
Our Northern territory is the only area of our two islands that has short distances between our eastern and western coasts.
Our Northern territory has many significant cultural considerations in close vicinity.
SUBMISSION APP202336 5 The ability to control and or mitigate negative impacts of Arial application of GF-2687 unfortunately are unrealistic for our Northern territory.
9. AROHA
We support the NgāiTahu HSNO Komiti submission WHAKAHAU O TE NGAPUHI HSNO KOMITI
We oppose the Arial application of GF-2687 at this time for the Northern territory as expressed in the points made above.
Request that the EPA advise the applicant of the extensive list of approved alternative available herbicides within New Zealand
We request to be heard in support of our submission
