Discussion paper Oct 2007

Stronger Measures Essential To Stop Didymo Reaching the North Island

– a discussion paper –
16 October 2007

Introduction
Stronger more stringent and effective measures must be taken to keep Didymo out of the North Island. A clear government policy that effectively ring fences the North Island is needed as soon as possible.
The problem
  • Disappointingly, Biosecurity NZ’s (BNZ’s) measures designed to isolate and control the spread of Didymo have insufficient rigour. BNZ’ s main awareness and prevention policies; are : an education and awareness campaign, the “Check Clean Dry” Campaign, designed to raise awareness and encourage anglers and other freshwater users to use recommended cleaning procedures. Ufortunately, this campaign has not resulted in the changes sought. For instance, a high percentage of anglers know about Didymo and how to guard against spreading it, but few are taking the essential preventative action. [1].
  • The second major plank of the BNZ policy has been the establishment of Regional Stakeholder and Partner Groups, which have
    been funded to manage Didymo related actions regionally. Both the Advocates and the NZ Federation of Freshwater Anglers are participants in respective Regional Partnership Groups, which have done fine work in developing Didymo Incursion Response Plans. In terms of awareness and prevention strategies however, our experience is that these groups are not in a strong enough position to bring about actions of the sort that many members of the group consider necessary. The limitations of the BNZ policy framework is one of the factors that makes it difficult for these groups to make a difference. Given the inadequacy of the BNZ policy there is an urgent need for more rigorous, carefully targeted strategies to be introduced as soon as possible. Stronger measures must be introduced to protect New Zealand’s fresh water. Didymo is the current concern and urgent action must be taken to control it, but unwanted pests will continue to plague NZ‘s fresh waters, and under present BNZ policy we do not have the necessary protection mechanisms.

    • The matter of immediate concern and urgency is that of putting controls in place to prevent the spread of Didymo to the North Island. Didymo has become epidemic in the South Island and rigorous North island protection measures are a matter of urgency.

    The purpose of this paper

    This paper has been developed by committee members of The Advocates for the Tongariro River and of the NZ Federation of Freshwater Anglers, as a means of stimulating discussion and generating the kind of measures essential to protecting NewZealand’s fresh water. Both our organisations are committed to assisting in the anti Didymo campaign through networking ideas that may generate action.

    The second section of the paper lists some broader freshwater matters for discussion.

    Essential Didymo prevention measures

    This paper proposes six new policy measures. Although each of the initiatives will stand alone, the impact will be significantly greater and enduring if implemented collectively.

    The measures proposed and outlined below, are:

    1. Placing a barrier (ring-fence) around the North Island;
    2. Ring-fencing the Taupo Cattchment Fishery
    3. Introducing a “Clean Gear Licence”;
    4. Placing a ban on felt soled boots
    5. Implementing a new and effective awareness campaign;
    6. Commissioning well funded research.
    In the appendix, (page eight) we propose an approach for protecting the Taupo Catchment Fishery, should Didymo be found in the North Island.

    1. Ring fencing the North Island

    Putting a bio security barrier around the North Island is both urgent,
    and essential, as exists and operates effectively in other parts of the world[2]
    Live Didymo cells are in effect aquatic hitchhikers. The cells can survive for weeks in damp or wet fishing equipment, clothing and kayaks, boats and absorbent materials, such as felt soles, and in doing so can be spread and over long distances, adapt and contaminate the next body of water.

    We need rigorous bio security checks and controls on gear being bought into New Zealand in order to preventing the movement of such pests across international borders, and it is encouraging that BNZ is implementing such measures this month. However, we must not stop at that as controls at international barriers are not enough. Given the out of control spread of Didymo throughout the South Island, best use must be made of the natural barrier that exists between the North and South Islands as a control measure to prevent a North Island invasion. A bio security barrier must be put in place within New Zealand at domestic airports and ferry terminals in order to intercepted and treat freshwater gear moving within New Zealand.

    The consequence of continuing to allow a free flow of fresh water gear within New Zealand is likely to have dire consequences for the future of New Zealand’s freshwater, and the associated businesses, economies and recreation.

    Existing regulation could be adapted

    Domestic border controls of the sort proposed above could be applied under the recent amendment BNZ has
    made to the Import Health Standards.[3]. The amendment will empower MAFBNZ staff, from Mid October this year, to check and treat all freshwater gear coming into NZ. We applaud this initiative, and want to see it applied within New Zealand as well as at our international borders.

    Further amending the Import Health Standards to make the measures applicable at our domestic airports and ports, is a logical and essential extension of the steps BNZ is taking at our international airports/ports. New Zealander travellers unwittingly carrying Didymo between rivers and lakes within NZ are as much of a risk as anglers (and others) travelling internationally.

    Since it is the North Island waters that urgently need protection, the border control measures at this stage at least, would we suggest, be applied in the South Island at all departure points, when travellers with freshwater gear, etc and a North Island destination check in . At the Picton ferry terminal there would be a dedicated “bio security lane” with a drive through spraying system for “at risk” vehicles and boats, as well as procedures for declaring, checking and treating gear.

    Cost of ring fencing the North Island .

    Significant costs would be associated with this measure, mainly job creation and related staff training costs. Dedicated employment positions, in many cases part time, would need to be established at each point of departure from the South Island.

    However, the costs of not implementing this measure and having Didymo (and other such organisms) take hold in North Island waters would be vast and far reaching. For example, the Taupo Catchment Fishery and the business, industry and tourism associated with it, has an economic value of upwards of $100 million per annum[4].

    Establishing a North Island ring fence, in summary

    In our view, and indeed in the view of a great number of New Zealanders we have spoken to, putting a bio security barrier between the South and North Island
    is essential. Such a measure needs to be the centrepiece of a rigorous new policy framework. Procedures being introduced by BNZ at NZ’s international airports from mid October 2007 need to be adapted (following amendment to the regulation) so that the same procedures can be applied to travel within NZ, between the North and South Islands.

    2 Protecting the Taupo Catchment Fishery

    A second layer of contol needs to be put around the Taupo Catchment Fishery (TCF) in line with the significance of this area.

    Why single out this area for special protection?

    The reasons for proposing this extra level of protection include the following:

    Because of its’ reputation as a fishery and the fact that it provides all year fishing it has a very high volume of angling traffic through its rivers and lakes, thus equating with very high risk of Didymo incursion.

    Secondly, science has established that the environmental conditions in the region’s rivers are ideal for Didymo.

    Under Treaty of Waitiangi provisions it is a major food source and a significant taonga for people of Ngati Turangitukua and Ngati Tuwharetoa.

    As a wild trout nursery it of particular value.

    Its worth in economic and tourism terms is widely acknowledged. The TCF and the business, industry and tourism associated with it, has an approximate economic value of upwards of $100 million per annum

    All steps must be taken, therefore, to afford this area special protection

    Declaring a “controlled area”.

    Provisions for creating a controlled boundary around a high value area already exist in the Bio Security Act, in the form of what is termed a “controlled area” [5].

    However, the legislation currently enables such designation only after Didymo, or a like pest, has been found in the area.

    We propose that this provision be amended, to enable “controlled area” status to be accorded before Didymo reaches a high value area. This would mean that appropriate prevention measures, such as those contained in BNZ provision for inmplementation after incursion, can be put into effect as stinngent protection. There seems little sense in waiting until the damage is done. It is essential the TCF be given “controlled area” designation before a Didymo incursion.
    A “controlled area” provides two way protection
    Making the TCF a “controlled area, will give the befefits of a two-way filter. This means that on the one hand, if the first North Island Didymo incursion is in the TCF area, ring-fence protection strategies inplace in this area will dramatically increase the odds in favour of containing Didymo and preventing it s spread to other North Island rivers. On the other hand, the controlled area provisions will also act as a filtering out mechanism when anglers are coming into the TCF.
    incentives for prevention
    Didymo is different from other incursions dealt with by BNZ and therefore, BNZ needs different mechanisims to deal with it. For example, BNZ normally deals with invasive pests (e.g. varroa bee mite) which affect one industry (honey factories). The operators there can recognise the full weight of the implications of a pest gaining a foothold and so hardly need public awareness campaigns and incentives for implementing controls. In such cases the impact is felt in raw economic terms by those directly involved, putting livelihoods at stake. With regard to Didymo there is not the same industry based incentives nor is there direct impact on the angling public, who does not fully appreciate the implications of casual indifference.
    The idea of ring-fencing high value areas is not new.
    We have in NZ several examples of high value areas that have been “ring fenced”. For example, various islands and parts of the mainland have been declared free from pests, e.g. Maungatautari in the Waikato, Tiritirimatanga in the Hauraki Gulf; Kapati Island off Waikanae.
    Cost associated with “controlled area” status
    To assertain a realistic cost assessment of implementing ring-fencing measures in the TCF, careful cost/benefit and risk/value analysis will be necessary. And to give a true picture the analysis must take into account the values inherent in the fishery, the high levels of exposure to the risk of incursion, and the long term flow on costs if the TCF is left unprotected.
    Making the TCF a “controlled area, in summary
    Implementing this policy proposal needs serious consideration right now. We cannot afford the consequences of delay.

    3. A Clean Gear Licence

    The second of the initiatives we propose goes hand-in-hand with the domestic border control or ring fencing measure proposed above. For instance, when travellers have had their gear checked at an airport or ferry terminal, they will be issued with a Clean Gear Licence (CGL) A Clean Gear Licence would also be issued in tandem with the issuing of a fishing licence in any part of New Zealand, or must be shown in order to be able to purchase a fishing licence.
    Safeguard our rivers by looking after your gear
    As Didymo is often invisible to the naked eye, it can be spread unknowingly. When this fact is put alongside the characteristic, “she’ll be right “attitude, the common response is not to bother. The intention of this CGL proposal is to establish as a widely accepted norm among users of freshwater, the practice of “safeguarding our rivers by looking after your gear”. It is worth noting that Australia puts NZ to shame in the approach it takes to Didymo. For instance, Australian anglers who regularly fish in New Zealand are increasingly asking the motels and fishing gear retailers in NZ to look after their gear between trips rather than have it subjected to the stringent deconination procedures at borders in Australia.
    What is a Clean Gear Licence?
    A Clean gear Licence would be in effect a decontamination certificate and a statement of intent to use decontamination procedures as required.
    Getting a Clean Gear Licence
    For anglers[6] getting a clean gear licence would mean:
  • having gear cleaned when purchasing a fishing licence, or on check-in to travel to a North Island destination;
  • agreeing to use the recommended cleaning methods after/between fishing different rivers;
  • receiving an pack of pertinent well presented information;
  • there would have to be
    • approved fishing licence providers;
    • a credit card sized card (CGL);
    • a plastic pouch for the CGL, with BNZ’s required
      decontamination procedures printed on it

    The declaration on the licence card would read something like this:
    “Clean Gear Licence: (Insert name……..) My fishing gear has been cleaned and I will take the action specified on the CGL pouch to avoid spreading Didymo and other unwanted freshwater organisims”. This would be signed and dated by the angler and the approved fishing licence provider.

    Amending the Fishing Licence regulations
    Changes will be required to the fishing licence regulations to make the CGL a prerequisite to obtaining a licence to fish, and to impose fines if fishing without a CGL. While we recognise that politicians may be, loathe to stepping in and regulating what is seen as a bastion of freedom, the impact of not doing so will be detrimental and far-reaching.
    Costs of implementing a CGL
    Obtaining a CGL as outlined would be quick and simple thus minimising compliance costs for both the licence providers and anglers. Other costs such as provision of the licence cards and information packs would be minimal. Costs associated with regulation change will be absorbed as part of public service business.
    Increased surveillance necessary
    DoC and Fish and Game field staff need to interact with anglers and other users much more frequently than at present – perhaps so often that on any one day an angler has a high (100%) chance of being approached by a DoC or Fish and game field official.
    The Clean Gear Licence, in summary
    “Safeguarding our waters by taking care of your gear” has to become the accepted mantra, and a Clean Gear Licence a preqequisite to obtaining a fishing licence.


    4. Keep Felt Soles out of New Zealand Waters

    Banning felt soles from use in NZ Freshwater would be a small but significant measure in helping to future-proof our waters against a host of undesirable and damaging pests and weed.
    The ideal host for aquatic hitchhikers
    Taking felt soles out of New Zealand waters altogether would significantly reduce the risk of spreading unwanted fresh water organisims[7]. The thick layer of felt provides an ideal condition for moving unwanted aquatic life around the world. Didymo cells for example, which are absorbed into the felt, can survive in those damp conditions for long periods; can adapt to new environments as they have in NZ, and will continue to contaminate. It appears that, increasingly scientists are tending to find correlations between arrival of unwanted organisms in various parts of the world, and an increase in the use of felt soles.
    Managing the safety factors
    Felt has been considered to provide more sure footing when wading especially in rocky rivers. However, manufacturers, aware of the need to take felt out of the equation are now producing rubber-soled boots with good non-slip properties. Discussions between NZ retailers and overseas manufacturers on the need for alternative materials are well advanced. Safety is therefore unlikely to be compromised by a ban on felt soles.
    Associated costs
    Cost associated with banning felt soles is minimal when compared with the potential of felt, as a carrier, to cause long-term harm. We recommend that anglers who currently have felt soled boots would have the soles replaced at no cost to them.[8]

    Felt soles in summary
    Allowing felt soles to be used in NZ’s fresh water is bad practice in terms of bio security risks, and needs to be stopped. NZ can take a lead role in having felt soles banned internationally, an initiative, which would be
    in everyone’s best interests.[9]

    5. A New Awareness Campaign

    The Marine Safety Authority has successfully shifted the norm regarding the wearing of lifejackets by NZ boat users. They did this through a television and poster campaign featuring a well known and widely respected New Zealander. Using Colin Meads to get recreational boaties to put on life jackets has been a very successful means of penetrating attitudes relating to that particular safety issue. There was approximately a 75% increase in the wearing of lifejackets over the time of the campaign. The same approach would succeed in getting anglers and others to make the changes necessary to protect our waters against Didymo and like fresh water pests.

    Have a well known, respected Kiwi give the message
    A significant number of anglers and other fresh water still have their heads in the sand and have yet to be persuaded that the “she’ll be right” approach is no longer good enough.[10] Unlike boat users, the impact of irresponsible behaviour in relation to a freshwater epidemic such as Didymo goes well beyond themselves and those with them at the time.
    A new awareness campaign in summary
    We strongly recommend advancing from the “Check Clean Dry” to a NZ wide high profile “Celebrity Campaign,” featuring someone like Anton Oliver and/or Sir Edmund Hillary, as soon as possible.

    6. Research into the Ecology of Didymosphenia geminata (Didymo) Little is known

    A commitment to ongoing research is the final of the measures we consider essential. There are many as yet unanswered questions about Didymo and its impact. We propose that a well funded research approach aimed at fully understanding the ecology of Didymo be undertaken at the highest level of scientific capability. We appreciate the research work done to date by NIWA and other agencies but it is not sufficient nor is the funding adequate.
    Proposed approach and benefits and costs
    By taking an ecological approach, much could be learned about the range of Didymo, especially its likely reaction to different habitats and environments. Therein may lie a way of (i) keeping the pest out of the North Island, and, (ii) controlling the impact and spread in the South Island. The use of the copper citrate complex is unlikely to be effective. The immediate and long term benefits of high quality research will far outweigh cost, particularly given the high level of international interest in NZ as a leader in this research field.

    Research in summary

    There is much to gain from making research as proposed in this paper, a priority.

    In Conclusion

    Didymo is a serious threat to NZ;’s fresh water environment and the economic social and ecological values integral to it. With the trout fishing season in most of New Zealand rivers are now open for another year, there is a flow of anglers and wet gear and boats (and the probability of live Didymo cells), moving unchecked, between South and North Island rivers and lakes. It is nonsense to let this continue. Serious threats need rigorous responses. The BNZ campaign has to be much more strident than at present and there needs to be opportunities to introduce even stronger measures in areas of particular value or significance.
    Recommendations:
    The Advocates for the Tongariro River, (Inc) and the New Zealand Federation of freshwater Anglers, recommend:
  • Ring Fencing the North Island by extending the amendment to the Import Health Standards announced by Biosecurity NZ on 17 September 2007 to all South Island departure pointsarture points;
  • Ring-fencing the Taupo catchment Fishery;
  • Introducing a Clean Gear Licence;
  • Imposing a ban on felt soled boots
  • Launching a NZ wide high profile awareness campaign featuring a NZ Celebrity;
  • Commissioning well funded research aimed at an ecological understanding of Didymo and its impact; and
  • taking action on 1 to 6 with urgency.
    • 15 October 2007
    Advocates for the
    Tongariro River
    PO box 335
    Turangi
    See paper 2 – “Broader Freshwater Recreational Issues for Discussion”, below
    [1] The following extract from BNZ’s press release (25th September 07) acknowledges the failure of its “Check Clean Dry” awareness policy: “We have beenfrustrated in the past with the number of anglers who know about Didymo but still do not clean their equipment. I would ask every angler this season to think how he or she could ensure that they do not put our fisheries at risk. It is not a big effort to clean your equipment, but it is very necessary, not just for Didymo but other aquatic pests as well.”
    BNZ Press release of 25th
    September 2007

    [2] Iceland has a policy of not allowing any used fishing gear into the country unless the traveller presents a Decontamination Certificate to biosecurity staff upon arrival. The certificate confirms that all freshwater gear has been cleaned using a procedure specified by Iceland, by an approved person, (a vet) in the country the traveller has come from. Iceland has no freshwater pests and is ensuring that the status quo continues.

    [3] BNZ recently announced that “From mid October 2007 MAFBNZ’s Import health standards associated with animals or water will be updated to require MAFBNZ staff to treat all used freshwater fishing equipment they determine or suspect is NOT COMPLETELY DRY (inside and out), regardless of whether it has been cleaned before coming to New Zealand.” BNZ 17 September 2007 This regulation needs to be made applicable to domestic ports and airports.

    [4] Revenue generated per annum by theTaupo Fishery and associated activities should be available through Biosecurity NZ‘s updated assessment of costs relating to Didymo. Figures held by DoC Turangi are 1990’s estimates

    [5] “High value” is the term used by BNZ as part of the provisions enabling controls to be implemented in an area once a pest such as Didymo has been confirmed in those waters. The status of “high value” can be contingent upon one or more of a range of values being deemed intrinsic to a particular waterway.

    [6] Other freshwater recreational sporting groups would be encouraged to implement a “Clean Gear Licence”

    [7] Results of tests done for BNZ by NIWA Scientist Barry Biggs in 2006 showed felt soles on fishing boots to hold live Didymo cells for significantly longer period of time than soles made of leather or rubber.

    [8] Replacement cost, which would be minimal, would come from the BNZ Contingency Fund

    [9] Ref SIMMS advert in Fish and Game Magazine of August 2007

    [10] Ref footnote 1, page 1 (as recently passed in the House?) It being noted that ‘NZ Federated Farmers’ have supported this.

    Discussion paper 2:

    Broader freshwater recreational issues for discussion
  • Access – what is the National Party’s stand on ‘Public Access’
  • register of unformed official roads must be established. What is the Parties stand here?
  • Recognition that Didymo impacts on industry as well as recreation – agree.
  • Preservation of recreational aspects of rural lifestyles, especially fresh water based ones – where does the party stand here.
  • NZ’s abundance of freshwater. Where does the party stand with ‘privatisation of water’ via ‘tradeable or transferable water rights? Managing this very valuable resource to everyone’s advantage, we consider this very important
  • Alternative methods of power generation (to hydro?)
    • These are other matters we would like Shane Ardern to comment on:
    Ian Rodger

    Howick

    (09)534 7104

    (0274)996 000

     

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