SUBMISSION ON APP202334 – Application to import ESTEEM fungicide . from TE RŪNANGA O NGĀI TAHU by Dr Oliver Sutherland presentation by Gerry Te Kapa Coates Member, HSNO komiti
THE NGĀI TAHU TAKIWĀ Over 90% of the South Island & over 40% of NZ land mass. • Ngāi Tahu is the third largest Māori tribe in Aotearoa with over 54,000 members. • Our takiw ā extends from Kaikoura in the north, to Rakiura (Stewart Island) in the south, including the West Coast, TeTai Poutini. • Te Rūnanga o Ngāi Tahu constitutes 18 Rūnanga 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 takiw ā 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 RŪNANGA O NGĀI TAHU HSNO KOMITI • 7 Members • Responsible for monitoring new EPA applications • By HSNO Policy Statement 2008
THE POLICY a) Evaluate issues of importance to Ngāi Tahu b) Identify and assess effects (risks and benefits), from a Ngāi Tahu perspective c) Identify options to avoid or minimise adverse effects on Ngāi Tahu values d) Identify outcomes important to Ngāi Tahu (e.g. environmental, cultural, health and well-being, economic). Ngāi 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.
NGĀI TAHU VALUES Whanaungatanga (family) Respect, foster and maintain important relationships within the organisation, within the iwi and within the community. Manaakitanga (looking after our people) Respect each other, iwi members and all others in accordance with our tikanga (customs). Tohungatanga (expertise) Pursue knowledge and ideas that will strengthen and grow Ngāi Tahu and our community. Kaitiakitanga (stewardship) Work actively to protect the people, environment, knowledge, culture, language and resources important to Ngāi Tahu for future generations. Tikanga (appropriate action) Strive to ensure that Ngāi Tahu tikanga of is actioned and acknowledged in all of our outcomes. Rangatiratanga (leadership) We will strive to maintain a high degree of personal integrity and ethical behaviour in all actions and decisions we undertake.
ISSUES CONSIDERED • Lack of culturally relevant information in applications. • Difficulties of assessing highly technical applications . • Time and cost burden to Te Rūnanga o Ngāi Tahu of assessing 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 are cultural and Treaty concerns reflected in EPA decisions on applications
TREATY CONSIDERATIONS • Te Rūnanga o Ngāi Tahu is statutorily recognised as the representative tribal body of Ngāi Tahu Whānui under section 6 of Te Rūnanga o Ngāi Tahu Act 1996. • This means we exercise kaitiakitanga over our takiw ā . • The EPA must be ever mindful of its responsibilities for ‘active protection’ under Te 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 requiring testing and research to be carried out on impacts of hazardous substances on 'down-stream' taonga native species and ecosystems , in a similar manner to that required for introduced bio-controls. The lack of , or access to any testing or research data is a major shortcoming in most Applications.
SUBMISSION ON APP202334 – Importation of ESTEEM fungicide We oppose the introduction of ESTEEM, a suspension concentrate containing 5% polyoxin D zinc salt 5SC fungicide: • The application totally fails to identify and address potential risks to Māori culture and values from the use of this product and, and in this respect, the application does not comply with the requirements of section 7.3 of the form. • In the Application form we found four references to a confidential appendix in section 3.4 (physical and chemical properties of the substance) and another in 3.6 (composition details of the formulated substance). This provides submitters with no information regarding the components of 95% of the product
SUBMISSION ON APP202334 – cont. 1 • No data at all – or comment – is provided regarding the aquatic toxicity of the formulated substance or for several other hazard categories. • The application states (7.1) that “Although treated produce will enter the human and animal food chain, this does not present a risk to the purchaser. This is because Esteem …rapidly degrades in the environment and what is remaining is anticipated practically non- toxic”. No evidence by way of hard data substantiates this statement. • The further statement that the product’s safety to the environment is supported by “a number of dedicated ecotoxicology studies” is worthless without data and/or references to back it up.
SUBMISSION ON APP202334 – cont. 3 • The applicant has made no attempt or effort to identify, quantify and address any of the possible risks to Māori from the use of this product. The four bland sentences provided in no way constitute an analysis or assessment of the potential “risks, costs and benefits which arise from the kaitiaki relationship of Māori and their culture to the environment” as required by section 7.3 of the application form. Ngāi Tahu are deeply concerned at this casual approach to a major issue.
SUBMISSION TO EPA ON APP202334 The HSNO komiti wrote to the EPA aout the shortfalls in this application on 19 August 2015:, raised it again at a meeting on 16 September and received a reply to our letter on 28 October which said:
ANALOGIES FROM THE PAST Tribal leader Matiaha Tiramorehu lodged the first protest over breaches of faith concerning land sale contracts in Te Wai Pounamu in a letter from Moeraki on 22nd October, 1849: “This is the commencement of our speaking (or complaining) to you, Governor Eyre; and although you should return to England, we shall never cease complaining to the white people who may hereafter come here .” This was the beginning of the Ngāi Tahu Claim (Te Kereme) which was finally settled in 1998.
SUMMARY We request the Application not be approved by the DMC because of failures of process and because the Application does not: • Make any attempt or effort to identify, quantify and address potential risks to Māori culture and values . • Provide sufficient ecotoxicological data regarding the use and edgradation of the product. • Ensure that data that has once again been accepted as a “Confidential Appendix” which submitters had no access to, despite numerous pleas to cease this practice be made available. “There are some choices you can only make once. You can't go back to where you made a choice and then take the other one.” ― Mary Hofffman
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