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Evaluation & Review Report


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ERMA New Zealand
Evaluation & Review Report

Application for approval to import into containment Wollemia nobilis (Jones, Hill and Allen 1995), Araucariaceae

Application Code: NOC01006

Prepared for the



Environmental Risk Management Authority

1 Introduction

1.1Forest Research seeks approval to import into containment Wollemia nobilis (Jones, Hill and Allen 1995), Araucariaceae. This application is made under section 39(1) of the Hazardous Substances and New Organisms (HSNO) Act 1996. The purpose of the importation falls under section 39(1)(h): such purposes as the Authority thinks fit, and has relevance to section 39(1)(d): conservation of any genetic material. Wollemia nobilis was discovered in 1994 in Australia and is an endangered species in New South Wales listed under the Australian Endangered Species Protection Act 1992. Ex situ propagation is part of a species recovery plan of the New South Wales National Park and Wildlife Service. A contract for the development of vegetative propagation methods was awarded to the Queensland Forestry research Institute, Queensland Department of Primary Industries (QFRI). QFRI subcontracted this work to Forest Research because they are recognised as experts in pine plant formation research.

1.2The Authority has discretion as to whether or not receipt of an application to import into containment any new organism is publicly notified. In this case the application was not publicly notified (following the ERMA New Zealand Corporate Manual Item 3.2.23), as the organism is not genetically modified.

1.3The purpose of this Evaluation and Review Report is to assist and support decision-making by the Environmental Risk Management Authority (the Authority) by providing and consolidating technical and other advice. It does not make recommendations, nor direct or prejudge the decision that the Authority might make on the application.

1.4The project team consists of the following ERMA New Zealand staff members:


Suzanne Lambie

Project Leader (Operations Group)

Abdul Moeed

Scientific Advisor (Science & Analysis Group)

1.5This report was reviewed and signed out by Donald Hannah (Manager, Science and Analysis)

2Timeline

2.1The application was formally received on 20 December 2001. The application was verified on 24 December 2001 to contain adequate information to be accepted for processing.

3Agencies notified

3.1The Ministry of Agriculture and Forestry (MAF) and Department of Conservation (DoC) were consulted in regard to this application. No comments were received by MAF.

3.2DoC recognises that the risks associated with Wollemia nobilis will be sufficiently mitigated if the proposed containment is adhered too.

4Organism description

4.1Class Coniferopsida; Order Coniferales; Family Araucariaceae; Wollemia nobilis Jones, Hill & Allen 1995, Wollemi pine.

4.2Wollemi pine is a monoecious multi-trunked tree growing to 40 m. Coppicing occurs from damaged trunk bases and produces a cluster of trunks of various ages. Trunks range up to 1.2 m in diameter and are broadest at about 1/3 the height of the tree. The crown is slender and columnar. On young stems the bark peels in thin, fragile, dark red-brown scales. On older trunks the bark becomes densely covered with soft and spongy nodules, 10 mm in diameter and 15 mm long, which form a layer up to 20 mm deep. Successive whorls of primary branches arise from the vertical shoot. Subsidiary branches in older trees grow from epicormic shoots that develop from the trunk where lateral branches have fallen. The adult lateral branches grow for three to eight years before termination in a male or female cone. Female cones are borne on branches above male cones. After bearing cones the tree sheds the branches. There are three kinds of shoots or branches produced according to the age and position of the branches:

  • Juvenile and lower canopy lateral shoots, which are horizontal, with leaves arranged in two opposite ranks. The leaves are twisted with the upper surface towards the sky and are linear to narrow triangular.

  • Adult vertically growing shoots, which have a helical (spiral) arrangement of leaves. The leaves taper to an acute angle at the tip, have a sharp point, are narrowly triangular and 3-10 mm long and 2-4 mm wide at the base.

  • Adult lateral shoots are initially nearly vertical, become horizontal and finally pendulous. Leaves are opposite or sub-opposite and present the upper surface to the sky.

4.3Wollemi pine is slow growing and produces a small amount of viable seed after at least 15 years. Seeds are flat, brown and papery with a single circumferential wing. Seeds are 7-11 mm long and 5-7 mm wide, and 5-9 mm wide with the wing (Jones et al. 1995; NPWS 1998.)

4.4ERMA New Zealand notes that Wollemi pine was discovered in the Wollemi National Park about 150 kilometres from Sydney. The park contains a rugged mountainous region of gorges, cliffs, and undisturbed forest. The trees were found growing on wet ledges deep in a sheltered rainforest gorge. There are no habitats like this near Rotorua, New Zealand where the plant material is destined to be imported into containment.

4.5Wollemai nobilis was only discovered in 1994 so there is little is known about its life history. However, based on studies of the New Zealand kauri (Agathis australis) and the Queensland hoop pine (Araucaria cunninghamii) it is highly likely that male and female flowers (cones) and seed will not be produced until the plants are at least 15 years old (Ecroyd 1982; Haines and Nikles 1987).

5Precedents

5.1ERMA New Zealand considers that the risks posed by this application cannot be distinguished from those identified in relation to the previous applications NOC01003 Sycios angulatus and NOC01002 Cuscuta species. Both these applications involved the importation into containment of a species that is closely related to a native New Zealand species. Both applications were approved with controls.

6Containment and Population Establishment

Ability to escape containment (under section 44 HSNO Act)

6.1As this application concerns the holding of imported organogenic and embryogenic derived plantlets in laboratory and plant house containment, and given that only mature trees produce seeds, have low viability and are poorly dispersed it is very unlikely that Wollemia nobilis will escape from containment. Based on the maturation time for kauri (Agathis australis) in New Zealand (Ecroyd 1982) and the estimated maturation time for Wollemi pine (applicant) it would probably be at least 15 years before male or female cones were produced.

6.2The laboratories to be used for the manipulation of Wollemi pine are routinely used for the importation of conifer (Pinus spp.) shoots, cones and seeds from Australia and Chile for organogenesis and embryogenesis research.

6.3Forest Research containment facilities are MAF-registered in accordance with MAF Biosecurity Authority and ERMA New Zealand Standard 155.04.09 Containment Facilities for New Organisms (including genetically modified organisms) of Plant Species and MAF Biosecurity Authority and ERMA New Zealand Standard 154.03.02 Containment Facilities for microorganisms. The facilities meet the requirements of the Australian New Zealand Standard AS/NZS 2243.3 Safety in Laboratories: Part 3: (Microbiology) Laboratory and Plant House Physical Containment Level 2 (PC2).

6.4There have been no recorded breaches of containment from the Forest Research containment facilities.

6.5ERMA New Zealand notes that according to available information Wollemia plants are unlikely to reach sexual maturity for at least 15 years. In order to safeguard against production of sexual organs while the plants are in containment it may be appropriate to limit the duration of the research to less than 15 years. A time limit of 12 years is proposed as additional Control 6.1, in section 8 of this report.

6.6ERMA New Zealand notes that one of the purposes of this application is to send Wollemia nobilis plants to Australia and therefore in order to avoid ambiguity any viable Wollemia nobilis material leaving the containment facility shall only be for export and shall be carried to the border in secure containers and with MAF Supervisor approval. This requirement is reflected in proposed additional Controls 6.3 and 6.4, in section 8 of this report.

6.7ERMA New Zealand notes that the containment facilities and proposed controls (section 8 of this report) would make it very unlikely for Wollemia nobilis to escape from containment.

6.8If this application is approved, ERMA New Zealand recommends that within one year of the date of the approval, the applicant shall provide ERMA New Zealand with a report providing feedback on control wording and ease of compliance with controls. This would provide an opportunity for feedback relating to the controls set, which would be a positive opportunity for both the applicant and ERMA New Zealand. Similarly, at the completion of the work in containment, the applicant shall provide a final report to ERMA New Zealand and MAF outlining fully any difficulties or problems experienced with control compliance. As such, these reporting requirements are proposed as additional Control 6.2, section 8 of this report.


Ability to form self-sustaining populations (under section 37(a) of the HSNO Act)

6.9ERMA New Zealand considers that it is possible that Wollemia nobilis would succeed in surviving and forming a self-sustaining population in the external environment should there be an accidental release into the environment. However, containment controls are designed to minimise the likelihood of escape.

Ease of eradication (under section 37(b) of the HSNO Act)

6.10ERMA New Zealand considers that it is highly likely that should a population establish it could be easily eradicated due to its long, slow lifecycle. If eradication was necessary it could be achieved by pulling up seedling and young juvenile plants as is done for Norfolk Island pine (Araucaria heterophylla) on Raoul Island (Webb et al. 1988). Mature trees could be felled and their root systems poisoned.

7Risk Analysis

Adverse effects (risks and costs)

7.1Neither ERMA New Zealand nor the applicant identified any costs associated with this application that would be imposed on third parties.

7.2ERMA New Zealand has categorised potential adverse effects associated with this application into environmental, human health and Māori cultural areas of effect.

7.3Risks to the environment and human health:

ERMA New Zealand considers that the risks associated with this containment application to the environment and public health would be minimal as the Wollemi pine would be in containment. The risks to the environment and human health are considered insignificant and will not be discussed further.

7.4Risks to Māori culture:

ERMA New Zealand considers that the risks posed by this application to the relationship of Māori with their taonga are negligible. The organism will be contained in laboratory and plant house facilities.

7.5Beneficial effects

The applicant identified the following benefits:

    • enhancement of the ability of individuals and the applicant organisation to attract research funds both from New Zealand and overseas

    • enhancement of the reputation of New Zealand scientists

    • enhancement of the ability of New Zealand scientists to collaborate with colleagues overseas

    • accrual of benefits to New Zealand society as a whole should the research produce marketable results.

7.6Wollemia nobilis is a genus with a single known species. It is of considerable significance in the study of the evolutionary relationships of the early flora of the Gondwana continent. It is a newly identified genus and species in the family Araucariaceae, and although it possess morphological characteristics similar to the related genera Agathis and Araucaria, it also posses unique features (NPWS 1998). When Wollemia nobilis was discovered in 1994 Professor Carrick Chambers, Director of the Royal Botanic Gardens Sydney, described the discovery as “the equivalent of finding a small dinosaur still alive on Earth” (QFRI 1995). Thus it is of high scientific interest.

7.7From a conservation perspective the discovery of Wollemia nobilis highlights the importance of habitat conservation for the preservation of biodiversity (NPWS 1998). It is a model species to demonstrate how a species can be recovered from the brink of extinction.

7.8As the only living representative of what was believed to be an extinct genus of Southern Hemisphere conifer it is of cultural significance to the people of Australasia as other members of its family, Araucariaceae, are significant trees in the landscape. Prominent features in the Australasian landscape are the kauri, the Norfolk Island pines, and the bunya bunya (English 2001).

7.9Wollemia nobilis is a beautiful ornamental tree with a cultural place in the Australian landscape.

7.10Moderate non-monetary benefits are likely to accrue to the applicant as they gain further recognition for being leaders in pine recovery.

7.11Moderate increase in scientific collaboration is likely between Australia and New Zealand scientific organisations.

Evaluation of potential risks, costs and benefits

7.12Following the Methodology, clauses 9, 10, 12 are considered particularly relevant to the risk assessment. Section 6(d) of the HSNO Act was also considered. ERMA New Zealand considers that there are moderate scientific benefits and negligible risks.

8Containment Controls

8.1Containment controls are designed with the aim of reducing the probability of any escape from containment and the likelihood that a self-sustaining population may form in the event of an escape. However, such controls cannot totally eliminate the possibility that unintended release will occur, as complete compliance cannot be guaranteed.

8.2The containment controls proposed by ERMA New Zealand below are grouped according to matters addressed under the Third Schedule of the HSNO Act (Part II): Matters to be addressed by containment controls for new organisms excluding genetically modified organisms. The Authority may also include controls that provide for any other matter in order to give effect to the purpose of the HSNO Act (section 4 of the Act). The Authority may wish to amend the proposed controls (ie to make them more or less ‘strict’) to achieve a level of probability of escape that is appropriate for the organism.

Proposed containment controls


  1. To limit the likelihood of any accidental release of any organism or any viable genetic material1:

    1. The construction, operation, and management of the containment facility shall be in accordance with the:

MAF Biosecurity Authority and ERMA New Zealand Standard 154.03.02 Containment Facilities for microorganisms;

  1. Ministry of Agriculture and Forestry (MAF)/ERMA New Zealand Standard 154.04.09 Containment Facilities for New Organisms (including genetically modified organisms) of Plant Species;

  2. Australian New Zealand Standard AS/NZS 2243.3 Safety in Laboratories: Part 3: (Microbiology), Plant House Physical Containment Level 2 (PC2); and the controls of the Authority.

2. To exclude unauthorised people from the facility:

    1. The identification of entrances, numbers of and access to entrances, and the security requirements for the entrances and the facility shall be in compliance with the standards listed in Control 1.1.

3. To control the effects of any accidental release or escape of an organism:

3.1 Control of the effects of any accidental release or escape of an organism shall be in compliance with the standards listed in Control 1.1.

3.2 If for any reason a breach of containment occurs the facility Supervisor2, MAF Biosecurity Authority and ERMA New Zealand shall be notified immediately the event is noticed (and at least within 24 hours of the breach being detected).

3.3 In the event of any breach of containment of the organisms, the contingency plan for the attempted retrieval or destruction of any viable material of the organism that has escaped shall be implemented immediately. The contingency plan shall be included in the containment manual in accordance with the requirements of standards listed in Control 1.1.



4. Inspection and monitoring requirements for containment facilities:

4.1 The inspection and monitoring requirements for containment facilities shall be in compliance with the standards listed in Control 1.1.

4.2 The Authority or its authorised agent or properly authorised enforcement officers, may inspect the facility at any reasonable time.

4.3 The containment manuals shall be updated, as necessary, to address the implementation of the controls imposed by this approval, in accordance with MAF/ERMA New Zealand Standard 154.03.02.



5. Qualifications required of the persons responsible for implementing those controls:

5.1 The training of personnel working in the facility shall be in compliance with the standards listed in Control 1.1.




  1. Other Matters:


Additional controls


    1. The approval is for a period of 12 years from the date of the signed decision.




    1. Within one year of the date of this approval the applicant will provide ERMA New Zealand with a report providing feedback on control wording and ease of compliance with controls. At the completion of the work, the applicant shall provide a final report to ERMA New Zealand and MAF outlining fully any difficulties or problems experienced with control compliance while conducting the research.




    1. At the completion of the work all remaining viable Wollemia nobilis plant material shall be destroyed by autoclaving or shall be shipped out of New Zealand.




    1. Viable Wollemia nobilis material leaving the containment facility shall only be for export and shall be carried to the border in secure containers with MAF Supervisor approval.



9Glossary


Coppicing is the production of multiple stems.

Epicormic growth occurs from dormant buds usually on the stem.

Monoecious plants have both male and female cones spatially separated on the same plant.

Organogenesis is the differentiation of organs



Embryogenesis is the formation of an embryo

1 Viable Genetic Material is biological material that can be resuscitated to grow into tissues or organisms. It can be defined to mean biological material capable of growth even though resuscitation procedures may be required, eg when organisms or parts thereof are sublethally damaged by being frozen, dried, heated, or affected by chemical.

2 An inspector appointed under the Biosecurity Act.



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