1. EPA Hearing Submission 27 th July 2016 Application APP202774 EXIREL Aerial Application

2. Contents 1.Introduction 2.Hill Country farming and bees. 3.Hill Country cultivation characteristics. 4.The Agricultural world is not alike. 5.Hazardous Substance Environmental controls 6.Aerial Spray Drift Modelling 7.Bee Safe Controls

3. Hill Country Farming and Beekeeping Increasingly important for Manuka Honey harvest areas. Large numbers of beehives are now located on hill country farms Not all the paddock is cultivated, due to terrain. Remnants of pasture, clover, weeds, trees and shrubs provide refuges for bees to forage when in flower. Major problem Spring, Summer, Autumn – when the clover and weeds flower.

4. Matawai Area, near Motu River, Gisborne. 25/7/2016 Hingarae Road, Tihoi. Off SH32 Western Access, Taupo. 22/6/2016

5. Google Earth, Te Weta Road, Waikite Hill Country paddocks irregular shapes Gullies not cultivated Steep slope not cultivated Bio-diverse vegetation in uncultivated areas Hill country cultivation characteristics Trees and shrubs on steeper slopes

6. The Agricultural world is not alike EXIREL used solely on Cotton in Australia. Cotton Harvesting LakeTandou Farm, Menindee, SW NSW. Photo Stuart Envoy, NewsCorp Australia. 17/5/2014 http://www.theaustralian.com.au/business/cotton-crop-transforms-a-dry-lake-bed/story- e6frg8zx-1226920789559 Grazed kale Tuminui Station, SH 5 Rotorua. 11/7/2016. D.N.MacLeod

7. Hazardous Substance Environmental controls Must be practical – have to be implemented Must be clear – easily understood Must be measurable –indicators required Must be enforceable – WorkSafe inspectors are not agronomists or beekeepers. Controls must be effective in all Agriculture Environments Otherwise they are a waste of time

8. Spray Exirel® in flowering crops only after honeybee flights, unless spraying after daily honeybee flights is not possible.” It is ambiguous. It is not measurable. The label instruction is contradictory and invalidates good agricultural practice which the EPA is striving for.

9. “Ensure flowering weeds are removed before spraying Exirel® to avoid potential exposure of honeybees”. Not practical to implement. No time limit before spraying – can be weeks before. Flawed - it gives approval to spray flowering crops, but not spray flowering weeds. Does not recognise the difficulty of inspecting a paddock of brassicas for removal of flowering weeds.

10. How many folk does it to take to find flowering weeds in a crop? The search for Velvetleaf in Fodder Beet. Southland 2016 Source; Envirosouth, June 2016. Publication of Environment Southland Regional Council. Te Taia Tonga

11. Aerial spraying drift control modelling Appendix 1 supplied – insufficient data - 6 pages out 198! Not applicable in hill country - AGDISP and AGDRIFT should not be used in hill country applications. AGDRIFT ‘the current model assumes a flat earth and steady-state ambient conditions’. Teske et al. 2002. AgDRIFT: A MODEL FOR ESTIMATING NEAR-FIELD SPRAY DRIFT FROM AERIAL APPLICATIONS. Environmental Toxicology and Chemistry, Vol. 21, No. 3, pp. 659–671, 2002 Major limitations of the current algorithms are the assumptions of flat terrain and near-neutral atmospheric stability. EVALUATION OF THE AgDISP AERIAL SPRAY ALGORITHMS IN THE AgDRIFT MODEL Bird et al. Environmental Toxicology and Chemistry, Vol. 21, No. 3, pp. 672–681, 2002

12. What is a 100 metre downwind no spray zone in hill country? All to scale 1mm to 1 metres. Using 3 4 5 triangles. This is a schematic illustration only. Wind Flat Country Paddock fence. Hill Country – 3 scenarios

13. Bee Safety 1.Protecting bees and their hives from the harmful effects of pesticides. 2.Protecting the honey, pollen, propilis and wax produced by those hives from pesticide residues. April, 2016. Honey shipment rejected by Japan, due to residues of the fungicide carbendazim. The honey was extracted from hives in the ‘upper Rakaia’ area. Possible chemical use on flowering clover or brassica seed crops?

14. Bee Safe Controls Apply an insecticide when bees are not foraging in the area. Ensure the chemical has dried before foraging starts. Horticulture leads the way – no spraying between bud burst and petal fall. ApiNZ Recommendation; Do not spray when the crop is in flower or ‘in crop’ and/or neighbouring weeds are in flower! Apply a Section 49 control from the Hazardous Substances (Classes 6, 8, and 9 Controls) Regulations 2001. Reason: this is a default control for all Class 9.4 substances.

15. Thank you Apiculture NZ Technical Focus Group Barry Foster & Don MacLeod