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DSS user manual 4 June - Didymo Knowledge Sharing Collection

1. 8 IX rnnBiege Tuum Tai 8 Amount rate and uration ccccccccccccsscccessccccssscccssscecesscecesssecesssccsssescesseecessesecssseecesscecessseccensescestecesteseesseess 9 Discharge CECH Que e 9 Discharge rate computations eeeeseescesceeeeeesecneeseesecseesersecseeseesesesscasescssceceseseecatsnessesaesseesessesaeeaeeseeseeaeeaseeees 9 ber od Gs EEE 9 Dilton oe M E 9 bn ates hSesevses 9 Transport and storage of Gemex accu uu sime seen nndeachvedaepsiaab ssassn exposed k EtA Aaaa arannana annern annn 10 Managementof spills 5er erri e ERASER r EEA Ra EI E Aaa N Ae ia AREI REETTA EEE RAER 10 Gemex M authorisations MM RR 10 Evaluation of Optio IT 10 Some river Page 97 Available options LP LEE 10 Eyal ation ofOptiohS x6 sau ee seien onde e ete e aw EG Y EE Re hanes laste ia a aves 10 REGIONAL PLAN PROVISIONS eese nennen nnne nnne 11 seiten Mec 11 Relevant Regional Plan and Status eese eese eee eee eee eese enses senses sins tts senses stas en sens etas enses sens enses senten sn 11 Operative Regional Plan Requirements eerie esee e enitn eene n einst ta einst tn senses einst es sen
2. Location labels Show labels Show location of Record number Records o E Card number C Locality name I Font Retain on map editable Size 10 gt Style Normal m Symbol C Square Line colour C Circle C Cross Bi Plus C Triangle Line thickness 0 Symbol size 10 0 1 mm units 0 1 mm units v OK X Cancel 4 Pull down the menu Show location of to galfas first three letters of each part of latin name 5 Change the colour and shape of the symbol to how you want it to look in this case a red plus sign 6 Click OK and the locations of recorded Banded kokopu will be shown You can further enhance your map by labeling the upstream and downstream extent of infection choose the Text T option Lon the map menu click and type at the point where you want the text and adding a key to symbols Insert Marker and add the shape and colour of marker corresponding to the information on your map l E The resulting map can be copied to the clipboard File Copy to clipboard E or Saving as a Windows metafile wmf by clicking on the Save icon amp The map can then be pasted or inserted within your audit report in the same way it has been inserted in this report below There are a variety of other options to enhance your map which include showing towns meteorological recording sites even waterfalls View Place names The best way to see all these options is to ex
3. Table 6 4 Estimation of Cu build up in the Waioeka Estuary Waioeka River Estuary Value Units Source Treatment Dose Treatment Target 20 g m INIWA Dosing time 3600 sec INIWA INumber of treatments space time 6 IDSS Flow at time of treatment 15 82 Im s IDSS Mass of Cu in all doses 1350 kg DSS Natural sediment and Cu loads Total area of stream catchment 807 km DSS Total stream sediment load 684 3 kt yr webmodel Background Cu in stream sediments 12 mg kg Given Natural Cu load 8211 6 kg yr calculated CuG diluted into annual load 14 kg kt calculated Waioeka Estuary Settling Zone Area 0 09 calculated Estuary sediment mixing depth 0 15 m Auckland Proportion SS settling in estuary 10 Worse case Estuary area 0 75 km estimated Resulting Cu in estuary sediments calculated Increase in Cu calculated Sediment Quality Guidelines IANZECC 65 mg kg IANZECC 2000 Environmental Response Criteria Red 34 mg kg IARC 2004 Environmental Response Criteria Amber 19 mg kg IARC 2004 Assuming that 10 of the applied CuG deposits in the estuary there is a significant increase in copper concentrations compared with the other case studies but still less than sediment quality guidelines In this case however any deposited CuG is highly likely to be diluted and flushed out in subsequent years because of the sediment dynamics in this small estuary Conclusions on assessing Cu build up in sediments The above case studies indicate t
4. stock solution and stream river water Because of the 1000 fold dilution this is minor pH Describe the effects on pH as a result of the discharge Refer to the Didymo Gemex help file for supporting information Water hardness Describe the effects on water hardness as a result of the discharge Refer to the Didymo Gemex help file for supporting information Gemex is not expected to affect water hardness as defined by Ca and Mg concentrations Nutrients Describe the effects on nutrient as a result of the discharge Refer to the Didymo Gemex help file for supporting information Do not expect any significant affect on nutrient concentrations as adding Gemex other than any nutrient librated from dead didymo cells which is already part of the river ecosystem and would be expected to be recycled in time anyway Micro organisms Gemex and the associated tracer dye do not include any micro organisms Ecosystems The discharge of contaminants into a waterway can result in adverse effects on the flora and fauna that rely on the waterway for habitat food and water In assessing the effects of the proposed discharge on the ecosystem values of the waterway consideration is given to the existing species present and the potential impacts of the proposed discharge Consideration of the effects of on those same species will also be considered where relevant particularly where they may be a potentially significant adverse effect from Gem
5. 66 66 66 69 70 70 70 iii Didymo Gemex DSS User Manual Regional Plans District Plans 7 5 Activity Status Activity Status in Regional Plan Considerations Activity Status in District Plan Considerations 7 6 Undertake Preliminary AEE Types of effects for this assessment Preliminary consultation as part of AEE Considerations 7 7 Assess Timeframes Considerations 7 8 Prepare Resource Consent Application Considerations 7 9 RMA Emergency Provisions Considerations 7 10 Biosecurity Act exemption from RMA Provisions Considerations 7 11 Biosecurity Act Emergency Provisions Considerations 7 12 HSNO Act Emergency Provisions Considerations 7 13 Gemex Cannot be Applied 7 14 Consultation When to consult Who to consult How to consult 7 15 Decision on Regulatory Pathway 8 AUDIT TRAIL 8 1 Introduction 8 2 Storage and retrieval 8 3 Printing exporting your report 9 REFERENCES 74 74 75 75 75 76 76 78 79 79 80 80 81 81 82 82 87 87 87 88 91 APPENDIX 1 GENERIC AEE FOR USING GEMEX IN A RIVER TO TREAT DIDYMO iv Didymo Gemex Decision Support System User Manual 1 Introduction This Decision Support System DSS is designed to assist Regional Partner Groups decide on whether to use Gemex a copper chelate in the event that the invasive alga Didymosphenia geminata didymo is identified in a river This DSS does not contain background information
6. Didymo Gemex DSS User Manual 6 14 Frequently asked questions on environmental effects of Gemex An assessment of the environmental effects of applying Gemex to a river is not simply a top down process Stakeholders who fish gather food or who have a spiritual connection with the river reach in question will have concerns and need to understand the effects in order to feel assured that their interests will not be compromised Similarly abstractors of water will need to be assured that their usage of the water will not be affected by the Gemex treatment or can be managed In this section we set the concerns of different stakeholder groups and provide a list of frequently asked questions FAQs concise answers and references to further information Maori Issues of concern to Maori 1 Kaitikitangi governorship and management responsibilities 2 Spiritual values associated with water 3 Mahinga kai gathering food and the relationship of food species with the rest of the environment 4 How are cultural concerns weighed against environmental economic concerns in making a decision Customary practices to consider 1 Food gathering 2 Transport 3 Drinking and bathing 4 Healing 5 Special ceremonial practices Questions and answers to assist in understanding Gemex effects Question Short Answer Further Information hat is it Copper based biocide for didymo Section 6 2 hat is it made from Copper
7. Files created Didymo Gemex will create its own ini files Didymo ini This is a simple text file that records default directories and layout A Microsoft Access database file Didymo mdb will also be created This can be stored in the DIDYMO or any other directory You can make the program accessible by Creating a shortcut 1 Run Windows Explorer Choose Start Menu Programs Windows Explorer 2 Choose the directory that contains the Didymo program e g C Program Files DIDYMO Click on Didymo exe with the right button and select Copy 3 Move the mouse cursor so that it over the desktop or Quicklaunch bar click the right button and select Paste shortcut 4 Alternatively click on Didymo exe and then drag it over to the desktop or Quicklaunch bar Uninstalling Didymo Gemex To uninstall Didymo Gemex simply delete the program directory normally C Program Files DIDYMO and any directories and database files Didymo mdb that you have created Didymo Gemex DSS User Manual 3 2 First Login The first time that Didymo Gemex runs the Didymo Microsoft Access database Didymo mdb will not be found and you will see the following message Don t worry Press OK and you will be asked whether you want to locate an existing Didymo database or create a new database The databace fle wore mci could not be toured in the cunent deecton Do you want to locale the directory ot ceste anew databace For a new i
8. water air soil to a level which adversely affects the life supporting capacity of the ecosystem Issues for Assessment The assessment of relevant Regional Policy Statement objectives and policies indicates that the following assessment issues are present in relation to this proposal Effects of Gemex on aquatic ecosystems Effects on life supporting capacity e Effects on human health and well being e Effects on cultural values particularly those of Maori Consultation Clause 1 h of Schedule 4 of the RMA requires that an assessment of environmental effects should include h identification of the persons affected by the proposal the consultation undertaken if any and any response to the views of any person consulted 20 People Potential Affected by the Proposal The following people or groups have been identified as being potentially affected by the proposal Joe Bloggs 123 Swamp Road Abstracts water from the Someplace waterbody downstream of the treatment area Pete Piper 345 Swamp Road Abstracts water for domestic Someplace use Jack Flash 25 Lightening Road Commercial rafting operator Someplace who runs rafting trips down treatment waterbody Local runanga Someplace Traditional food gathering from waterway Cultural significance Consultation Undertaken While there is no duty to consult with people as part of an application neither the consent authority nor the applicant is obliged to c
9. 6 5 which enhances Cu toxicity to fish No trout survived at a site 1 9 km downstream Numerous dead resident wild trout were found in this length of stream where pH had recovered smaller numbers of dead fish were found upstream Survival was higher at sites further downstream 100 at 4 2 km Data from electric fishing surveys supported the caged fish data but 30 Didymo Gemex DSS User Manual nonetheless indicated minimal overall effect on the fish population 11 weeks post treatment although trout populations were not at pre treatment levels in localized reaches where the greatest toxicity had occurred Clearwater et al 2007 Subsequent laboratory trials in slightly harder water than Princhester Creek have shown 100 survival of juvenile rainbow trout after 1 h doses up to 36 mg Cu L i e 1 h LCso gt 36 mg Cu L For longer exposures there was a dose dependent response and a 4 h LC5o of 13 mg Cu L and an 8 h LCso of 9 mg Cu L Clearwater et al 2008 Together the field and laboratory data suggest that in locations that receive intermediate Gemex doses 3 10 mg Cu L there may be some localized mortality of juvenile rainbow trout and other salmonids particularly in soft waters hardness 25 mg L as CaCO Clearwater et al 2008 Native Fish NIWA artificial stream trials showed 100 survival of native galaxiids adult after a 1 hour exposure to 20 mg l Cu as Gemex Clearwater et al 2007 There was a small mortality o
10. If there is no name in the box type it in If you do not know the name type Unnamed tributary of knownname river Grid reference of upstream end of treatment reach 7 figure NZMS number from program Grid reference of downstream end of treatment reach as above Location name optional identifier to help you find the reach E g By Smith s woolshed Length of river to be treated with Gemex Calculated distance between upstream and downstream points 12 Didymo Gemex DSS User Manual One treatment reach or more The hydrological calculations and hence the volume and cost of Gemex assume a relatively uniform gradient down the reach When transitioning from mountainous to lowland regions hydraulic gradient may change over short distances and care needs to be taken in selecting treatment reaches Similarly if the flow changes suddenly within a reach e g a diversion for a power scheme then the most sensible course of action is to select one treatment reach above the change and one below it 4 2 Didymo Incursion Locations The location where didymo has become established is an important consideration in deciding whether Gemex treatment is practically feasible In most cases you will know whether there is didymo present at other locations within the catchment of the river in which infection has been identified or in neighbouring catchments However should you need to confirm sites where didymo is known to o
11. In a Conservation Act process Area s170 Confirm ERMA approvals Not provided Discretionary Managed by a rule in a for in regional Activity s15 RMA regional or district plan plan Pee Re eee oy Controlled Discretionary or non complying ee Outcomes of previous consultation Maori Complies with standards 2 x c0 key stakeholders etc Undertake preliminary AEE d BEB BBB BBB RBBB RBBB RBBB eee ee eee eee eee eee ee es Apply Gemex in accordance Timeframe Time available for Prepare acorns Consent granted consent process consent application m as SERERERERREEEERREEERREEEREEEEREEERREEREREEERRRA RMA emergency provisions Apply Gemex in Obtain retrospective Environment apply s330 accordance consents if required Court appeal BS Act exemption from Apply Gemex in Obtain retrospective RMA provisions apply accordance with s109 consents if required s7A amp 114 of BS Act Emergency provisions of Apply Gemex in BS Act apply s144 accordance Emergency provisions of Apply Gemex in HSNO Act apply s136 accordance with s137 Gemex cannot be 68 Didymo Gemex DSS User Manual Figure 2 above The Regulatory Process 7 2 Preliminary decision Are treatment sites in a Conservation Area or covered by other regulations Conservation Areas Some waterbodies that are being considered for treatment with Gemex may be within the conservation est
12. Parameter Rare and endangered species Trout and or salmon Other fish species Other aquatic biota Cu accumulation in sediment long term Relevant to assessment Significant Significant effects that effects that can t be managed can be managed Minor effects Comment No rare or endangered species recorded in reach from fish db rout present in reach Mortality likely however repopulation rom upstream and downstream likely to occur Very limited fishing occurs along reach as mainly private land so access is restricted Difficult fly fishing river due to steep etated banks Eel present but Gemex unlikely to have significant impact Some other species present effects unknown but repopulation from upstream and ributaries likely to occur reasonably rapidly Some crayfish mussels and snails present Unknown effects of Gemex but any mortality will be remedied through natural repopulation Green algae does occur during prolonged low flows but loss of this as a result of Gemex will have minimal impact No lakes estuaries below discharge area 62 Didymo Gemex DSS User Manual Social Cultural Waterbody significance to Maori general has significance to Maori minimal historical use and no special significance Regional council No drinking water supplies Water quality in river is not suitable for drinking ater Regional Council and local Health
13. particular regard to Of those matters the following are considered to be relevant to the assessment of this proposal a Kaitiakitanga aa The ethic of stewardship b The efficient use and development of natural and physical resources ba the efficiency of the end use of energy Some river Page 27 c The maintenance and enhancement of amenity values d Intrinsic values of ecosystems e Repealed f Maintenance and enhancement of the quality of the environment g Any finite characteristics of natural and physical resources h The protection of the habitat of trout and salmon i the effects of climate change j the benefits to be derived from the use and development of renewable energy Include a summary assessment of each of the relevant points above Explain how these matters have been recognised and provided for in the proposal Section 8 of the Act requires that all persons exercising functions and powers shall take into account the principles of the Treaty of Waitangi Summary of Part Il Assessment Include a summary assessment of Part 2 as a whole Section 104A 104B 104C and 104D Assessment The RMA specifies the matters that must be addressed when assessing controlled s104A discretionary or non complying activities s104B restricted discretionary activities s104C and non complying activities s104D As this is an application for a activity the following of the abovementioned sections are
14. the cupric ion Cu II weakly associated with water molecules Cu nH2O is the primary toxic form This free copper is usually a small percentage of the total copper Most dissolved copper is part of stronger complexes with various ligands complexing chemicals that interact with metals including dissolved organic compounds hydroxides carbonates and other inorganic ligands Substantial amounts of the total copper can also be adsorbed to or incorporated into suspended particles The concentration of Cu is therefore determined by the total concentration of copper and the chemistry of the water This chemistry determines how much copper is complexed by other ions and molecules in the water and hence the concentration of free reactive copper The most relevant components of the water chemistry are hardness alkalinity and pH and dissolved organic matter The alkalinity ions such as bicarbonate form non reactive complexes with copper as does natural dissolved organic matter However as described above the chelating agents tend to dominate the water chemistry for copper when applied as Gemex 34 Didymo Gemex DSS User Manual The toxic effect of Cu is also modified by other ions which compete with it for biologically active sites thus reducing its toxicity The most important of these are H and Ca As hardness increases and hence the concentration of Ca and Mg Cu toxicity decreases Therefore the hardness of t
15. 20 mg Cu L before spraying Multiple strategic follow up treatments by application to flowing water and hand spraying may be required Between 3 and 10 follow up treatments spaced 24 hours apart may be more effective than a single treatment Prior to commencing the application of Gemex to the waterway the flow in the river is estimated with dye tracing using the non toxic dye rhodamine Depending on the length of waterway to be treated Gemex will have to be applied at multiple locations down a waterway over several days These treatment points will be spaced anywhere from 1 5 6 km apart depending on the conditions in the waterway and the goals of the treatment 1 e didymo elimination versus suppression More intensive treatment will be required for elimination attempts These downstream applications would occur at least 24 hours apart after initial assessment of the preceding treatment Each pulse dose of Gemex must move downstream and dissipate before the next application is started to avoid excessive non target toxicity It is likely that to achieve long term elimination the process will have to be repeated 3 weeks to several months after the first set of Gemex applications As only one field trial of one application of this product has been completed on a well established infestation it is difficult to predict its long term efficacy if applied in more favourable circumstances 1 e on an early stage infestation 47
16. Any provisions of this plan that are not appealed will be regarded as being operative and therefore will supersede the provisions they replace in the operative plan Any provisions under appeal will result in the respective provisions in the Operative plan ing some weight Operative and Proposed District Plan Requirements Rule Assessment The following table identifies the relevant operative and proposed rules and standards applicable to this proposal and specifies the level of compliance achieved Plan Provision Rule Compliance Comment Activity Status 21 1 19 Hazardous Substances and Permitted Will not meet NIWA estimated the Facilities the volume hazard classification of a The total quantity of hazardous substances Gemex based on on the site shall not data on copper sulphate exceed the quantities for the relevant zone permitted anhydrous This specified as a Permitted Activity in Appendix activity reference substance is 2 1 Hazardous Facilities Consent Status regarded to be more Table and shall comply with the following toxic than Gemex TM standards ERMA has not i Site Design undertaken a full hazard Any part of a hazardous facility which is classification of the involved in the manufacture mixing substance but based on packaging storage loading unloading the concentration of the transfer use or handling of hazardous chelated copper present substances must be designed constructed and within Gemex
17. Medium to high granted or refused The Council it able to take into account any matters that are relevant to the assessment of the proposal Conditions can be attached to the consent that must be complied with Resource consent is required and it can be granted or refused Non complying activities are generally unlikely to be granted unless there are unique or exceptional circumstances Resource consent cannot be granted The Plan does not allow the activity to occur 71 Didymo Gemex DSS User Manual Activity Status in Regional Plan Rules in regional plan relate to all land and water regardless of ownership Even where the waterway is owned by the Crown or the regional council itself the provisions of the regional plan are still relevant It is preferable that the interpretation of the rules in a regional plan is undertaken by somebody who is experienced in plan assessment This may be a member of the Council s Consents Team Most Councils have their regional plans published on the internet Regional council websites can be found on the following site http www lgnz co nz l1g sector maps Each regional plan is constructed slightly differently and care should be taken to understand the way in which the relevant rules relate to each other If the activity is listed as a Permitted Activity in the regional plan you will need to check that the details of the proposed Gemex discharge meet the standards specified
18. River see below fee eS Clicking the Lu button on the location screen will move you to the module where you consider the practical feasibility of treating the selected reach Or you can use the upstream and downstream locator buttons for the selected treatment reach 14 Didymo Gemex DSS User Manual 5 Practical feasibility of using Gemex to control didymo Decisions relating to the practical feasibility of using Gemex in a particular river reach relate principally to the proximity of established didymo incursions flow characteristics channel characteristics and access Each of these aspects affects the effectiveness of Gemex at controlling didymo and or the cost of application Effectiveness and cost together give a measure of practical feasibility 5 1 Practicality of treatment The next screen you see is labeled Practicality of treatment r Practicality of treatment Tuapiro Creek at MR 2765742 6406297 REC data Flow at time of treatment cumecs Width m Depth rn Mean velocity m s Mean flow cumecs Mean annual low flow cumecs Catchment area km2 Gradient m per km Distance inland km Flow variability Medium malf mean 0 1 0 5 v TOM spe a a Length of treatment reach km Calculated range of possible gradients 1 238 13 761 m per km Specify reach data C Use instream habitat survey RHYHABSIM file Hate River characteristics R
19. Some regional councils and district councils have combined to form unitary authorities These authorities administer both regional and district roles from a single organisation and may also combine the district and regional planning components into a single plan Activity Status in District Plan Rules in district plans relate to all land and activities regardless of ownership Even where the land in question is owned by the Crown or the regional council the provisions of the district plan are still relevant It is preferable that the interpretation of the rules in a district plan is undertaken by somebody who is experienced in plan assessment This may be a member of the Council s Consents Team Most Councils have their district plans published on the internet District council websites can be found on the following site http www lgnz co nz l1g sector maps Each district plan is constructed slightly differently and care should be taken to understand the way in which the relevant rules relate to each other As discussed briefly above the most likely component of the activity will be the storage transportation and mixing of a hazardous substance Gemex See 6 4 Is Gemex Toxic to Humans for the hazard classification details for Gemex for use in assessment against district plan provisions A hazardous substance is a defined mixture of elements or compounds either naturally occurring or produced synthetically Such substances
20. The following was adapted from this USEPA report and lists some of the uses reported to the USEPA Aquatic Weeds and Algae Copper is extensively used in direct aquatic applications including the management of algae aquatic weeds and molluscs that may host harmful parasites Aquaculture ponds containing certain cyanobacteria species can cause off flavors in farm raised catfish As a preventative measure full pond treatments are sometimes used for cyanobacteria control to minimize potential algal blooms that may cause off flavors Copper is the only registered chemical for treatment of these off flavor causing algae 45 Didymo Gemex DSS User Manual Drinking Water Algae can clog water filters reducing filter run times and requiring frequent backwashing which all lead to greater coagulant demand and other treatments that impose greater costs to treatment facilities Some species of algae can cause various off flavors in drinking water such as cyanobacteria which can produce chemicals called cyanotoxins that lead to earthy or musty flavors Only rarely are taste and odor problems the result of algal toxins in drinking water Thus this requires early detection and treatment of algae to ensure effective treatment with the minimum amount of pesticide needed These cyanotoxins and other chemicals are often difficult and more expensive to remove during water treatment The use of copper for this application can be costly but often times neces
21. This will normally include neighbours downstream resource users and often also iwi authorities but exclude public interest groups such as environmental organisations however some locally based environmental groups may be considered affected parties Discussions with council consents staff should assist in identifying who will be considered to be an affected party Section 93 1 of the RMA states that an application for resource consent must be notified unless the following criteria are achieved a the application is for a controlled activity or b the consent authority is satisfied that the adverse effects of the activity on the environment will be minor If notification is not required by s93 1 s94 of the Act requires that 1 If notification is not required under section 93 1 the consent authority must serve notice of the application on all persons who in the opinion of the consent authority may be adversely affected by the activity even if some of those persons have given their written approval to the activity 2 However a consent authority is not required to serve notice of the application under subsection 1 if all persons who in the opinion of the consent authority may be adversely affected by the activity have given their written approval to the activity Mitigation Measures In order to avoid remedy or mitigate actual or potential adverse effects on the environment as a result of the proposal the following measures ha
22. also provide a methodology with worked examples to assist you evaluate the long term significance of Gemex to the environment downstream of the proposed application site As well as decisions on the feasibility of using Gemex there are a host of local factors that need to be taken into account These factors require local information which is best obtained locally While it is inappropriate to provide this information within a DSS framework we do provide a comprehensive list of stakeholders that may need to be consulted factors that may need to be considered and guidance on both where to obtain and assess this information We also provide a comprehensive list of frequently asked questions FAQs that different stakeholder groups are likely to ask together with concise answers and sources of additional information If the decision is made to treat the affected river with Gemex you will need to follow a particular regulatory pathway Within the DSS you will find guidance on which pathway is appropriate under particular circumstances Should a Resource Consent be required we provide a generic Assessment of Environment Effects AEE This will need to be tailored to the region where the infection has occurred but should markedly reduce the time needed to gain consent We emphasize that the DSS does not make the decision on whether Gemex treatment is appropriate It merely provides objective information and guidance The onus on making
23. can readily explode burn oxidise accelerate the combustion of other material or corrode metals or biological tissue and or be toxic to people and ecosystems District plans usually include rules that govern the use transportation storage and disposal of hazardous substances These rules often use a hazardous rating system to determine the hazardousness of the particular substance and therefore what controls need to be put in place For more information on hazardous substances please refer to the following websites http www ermanz govt nz http www qualityplanning org nz related laws faqs hsno rma php http www mfe govt nz issues hazardous http www mfe govt nz issues hazardous 73 Didymo Gemex DSS User Manual Where resource consent s is required under the relevant district plans it may be most efficient to apply for both the regional and district consents at the same time Regional and district councils are able to jointly assess applications for the same activity which can streamline the consent process and reduce costs Considerations District plans are subject to change so any previous assessment of the proposal against the rules should be checked to ensure that the relevant provisions have not altered There may be two or more district plans that apply to the one activity In most cases this will be an operative or transitional plan and a proposed plan Both plans will influence
24. didymo cells will be both killed and flushed from system i e minimize the chance of recolonisation in the event of lt 100 kill 2 Is it feasible to inject Gemex given the predicted river flow at the time of treatment 18 Didymo Gemex DSS User Manual The volume of Gemex required is directly related to the flow at the time of treatment Flow strongly influences feasibility and effectiveness as in general terms the greater the flow the more difficult it is to inject Gemex at a controlled rate sufficient to reach the target in stream concentration To date Gemex has only been applied to a small stream Princhester Creek Q 0 243m s where it was relatively straightforward to apply Gemex from a bankside installation where the portable diffuser covered the entire stream width Larger rivers may require more specialist equipment to apply Gemex including the possibility of multiple injection diffusers in order to reach the target concentration across the full width of the river In addition it may be difficult to transport large quantities of Gemex to the riverside If you have concerns over whether the flow will cause logistic difficulties you should contact a recommended applicator The Didymo Long Term Management Coordinator at MAFBNZ will be able to assist finding suitable applicators in your region The amount of Gemex required is also an important consideration Currently there is only 2 600L of Gemex
25. diluted into annual load 65 40 kg kt calculated Southern Lake Taupo Lake sediment mixing depth 0 05 m guess Sediment deposition rate in lake 0 0014 Im yr IL Taupo Dilution factor from mixing 37 calculated Resulting Cu in lake sediments 13 45 mg kg calculated Increase in Cu 1 45 mg kg calculated Sediment Quality Guidelines IANZECC 65 mg kg IANZECC 2000 Environmental Response Criteria Red 34 mg kg IARC 2004 Environmental Response Criteria Amber 19 mg kg IARC 2004 Case Study 3 Opotiki Estuary The Waioeka River drains through the Opotiki W estuary The estuary will trap some of the river suspended material but is probably a very inefficient trap because the relative large size of the river compared with the estuary In this case we consider the situation where 1096 of the river borne sediment settles in the estuary This is likely to be a worse case the estuary should be at least 8 20 km for effective settling whereas we estimate the settling zone is only about 0 75 km Table 6 4 estimates Cu concentration build up in estuary sediments This scenario requires 6 injections points along the treatment reach In this example there is a contribution from Opotiki urban and highway stormwater of about 27 kg yr of copper This is dwarfed by the natural Cu load and is massively diluted by the river sediment load 43 Didymo Gemex DSS User Manual Hospital ny Z 2 HY cy ZAR
26. examines the selected reached to calculate hydrological parameters The following window will appear 11 Didymo Gemex DSS User Manual Purpose and location Didymo Gemex will now assist you assess whether it is feasible to treat the selected river reach with Gemex The volume of Gemex required over the reach is calculated from the following parameters Flow at time of treatment Average water velocity More information The amount of organic material and alkalinity are other factors to be taken into consideration Purpose of evaluation I River information River name T uapiro Creek Location name Grid reference of 1 Grid reference of Ipi upstream end of downstream end of treatment reach treatment reach Length of river to be 4 9 treated with GEMEX Select treatment reach using River Network Select Fi Help Back The purpose and location information window contains the following Purpose and location Enter the Purpose of the evaluation in the blank window provided Examples may include Evaluating which rivers in my region are suitable for Gemex treatment in the event of didymo being detected or Suppression of didymo in xyz River The purpose of evaluation will be carried through to the audit trail at the completion of the evaluation River name This should be inserted automatically from the REC database However the names of some small tributaries will not be in the database
27. harmful to humans and other mammals Excess algae and other vegetation in quiescent or near quiescent water bodies can impact overall water quality that may lead to decreased food availability and even fish kills Dense algal or weed mats can block sunlight from reaching submerged biota potentially affecting the entire ecological cycle and even pose physical barriers for mobile animals As the plant debris die back increased microbial decay would lead to the decrease of dissolved oxygen available to fish and other organisms living in the same water body 6 12 Is Gemex a problem for water abstractors The maximum treatment dose is 20 mg L while the MOH MAV for drinking water is 2 mg L Abstraction of large proportions of Gemex treated water is operationally difficult because it involves the uptake of a high proportion of the treated water Abstraction is restricted on the day s of treatment It is highly unlikely that abstraction will occur when river concentrations are above 2 mg L because this will involve abstraction within 1 few km of the application point which should be easy to prevent by the Gemex Treatment Management Plan GTCP Further downstream and within a few hours Gemex Cu is expected to drop to below 2 mg L Therefore in the unlikely event of inadvertent abstraction occurring on the day of application and it is highly improbable to envisage that there are many situations where Cu is not diluted or removed to concentr
28. into Lake Taupo Didymo Gemex will give you a list of all species found downstream including the Waikato River as far as Port Waikato As Gemex will not cause any effects below the confluence with Lake Taupo you should delete those species recorded only in the Waikato River Conversely some small coastal rivers may have no species at all recorded in the Freshwater Fish database In this case you may wish to add species likely to be present by looking at Species present in adjacent stream and rivers Use the View Fish location option to see all sites where there are fish records and click on those sites closest to your treatment reach to get the species present You can add those species to your list using the edit option mentioned in the paragraph above Note care should be taken with this option as just because species are present in neighbouring streams does not necessarily mean they will be present in your treatment stream If in doubt consult a fisheries biologist 2 Compare your final list of fish species with those species known to be susceptible to Gemex at the target concentration currently only trout are known to be susceptible but further work currently being carried out by NIWA may find other vulnerable species 3 Identify whether any of these fish species are rare and endangered through web resources e g http www seafriends org nz enviro reddata htm or consulting with Department of Conservation and or Regional Council
29. is required indicate what scale of assessment will be required Regional Plans Regional Plans are produced by regional councils to manage the natural and physical resources of each region Regional Plans contain rules that control discharges and other activities associated with water and waterbodies Rules can enable an activity such as the discharge of Gemex as a permitted activity or they can require that a resource consent for a controlled discretionary 70 Didymo Gemex DSS User Manual restricted discretionary or non complying activity is obtained from the Regional Council before the discharge can occur In some instances a regional plan will prohibit a particular activity in which case it is definitely not able to occur Where a regional plan does not contain a rule that addresses the proposed discharge i e the type of material to be discharged may not have been anticipated by the regional council resource consent for a discretionary activity is required This is because the Resource Management Act 1991 does not allow any person to discharge a contaminant unless it is specifically allowed by a rule in a plan or a resource consent District Plans District Plans are developed by district and city councils to manage the effects of land use There is some cross over between regional and district plans particularly in relation to hazardous substances but in general the roles of each plan are clearly defined The use of G
30. kg Jellyman et al 2006a p17 Similar copper chelates had lethal oral doses LD50 to several California birds bobwhite quail mallard duck of 72236 to 75620 mg kg and was classified as relatively non toxic CaDPR 2007 31 Didymo Gemex DSS User Manual 6 4 Is Gemex Toxic to Humans Based on the concentration of the chelated copper present within Gemex and the pH of the formulated product ERMA considers that the stock solution is harmful if ingested and is corrosive to skin and eyes NIWA has identified that adverse effects to human health and welfare may arise from the concentrated product or briefly when initially diluted in river water Consequently they recommend that risks to public and non treatment personnel could be reduced to a minimal level by restricting access of public and all non essential personnel to the treatment site and waterway on the day of Gemex application The Ministry of Health MoH Maximum Acceptable Value MAV for copper is 2 mg L for long term ingestion in drinking water Overseas pesticide data sheets state that there is no restriction on the use of similar type of herbicides i e other or similar copper chelates in respect to potable water or swimming e g CADPR 2007 which suggests a conservative approach has been taken by ERMA and NIWA However previously copper chelates have been used at maximum concentrations of 5 mg L generally for application to lakes or ponds Further e
31. of each of the plans plans that apply to this proposal Include Explain the level of weighting that should be any transitional operative and proposed attributed to the relevant provisions of the plans and any plan changes variations plan s Seek assistance from a Resource Management Planner where necessary Example Regional Freshwater Plan for the Plan made operative 17 December 1999 Wellington Region incorporating Plan Plan Change 2 made operative 31 January Change 2 2007 The Plan is fully operative and all provisions carry full weighting Operative Regional Plan Requirements Rule Assessment The following table identifies the relevant operative rules and standards applicable to this proposal and specifies the level of compliance achieved this example uses provisions from the Wellington Region which will not be relevant to other regions Plan Provision Rule Compliance Comment Activity Status Rule 1 Discharges of water and Permitted Discharge Gemex contains minor contaminants does not contaminants additional to The discharge of contaminants or comply those listed in the rule water into surface water other than f the discharge of stormwater is a therefore its discharge is not Permitted Activity provided the a permitted activity discharge complies with the conditions specified below Conditions 1 the discharge is not to any wetland lake or river being managed in its natural state Appen
32. of some species and not by others However if the Water Effects Ratio approach is considered it should reflect that copper toxicity is attenuated by the water chemistry i e the chelating agents Further explanation and notes for Water Quality Guidelines ANZECC Guidelines The ANZECC 2000 guidelines refer to total metals concentrations in the first instance If total concentrations exceed these guidelines then the ANZECC guidelines suggest a more detailed investigation including as a first step comparing dissolved levels with guidelines because these more closely approximate the bioavailable fraction The ANZECC 2000 guideline is unusually low for Cu and close to background levels but this may be an artifact of the way guidelines values are calculated rather than reflecting a real threat to aquatic life The guidelines are Trigger values for freshwaters Level of protection species 99 95 90 80 Copper ug L 1 0 1 4 1 8 2 5 Briefly the trigger values derived using the statistical distribution method were calculated at four different protection levels 99 95 90 and 80 Here protection level signifies the percentage of species expected to be protected The decision to apply a certain protection level to a specific ecosystem is the prerogative of each regional council in consultation with the community and stakeholders The 95 protection level trigger value is recommended
33. of the activity undertaken are avoided remedied or mitigated once the activity has been completed How this will be achieved should be a consideration in the assessment as to whether to use the RMA exemption provisions 7 11 Biosecurity Act Emergency Provisions The Biosecurity Act includes provisions to enable a response to a biosecurity emergency without the need to follow the normal regulatory procedures required by this and other acts A biosecurity emergency can only be declared by the Governor General on a recommendation by a Minister and a declaration can only be made in certain circumstances In the case of didymo a biosecurity emergency could only be declared by the Governor General and where the following tests are met 1 Didymo is established in part of New Zealand and it has the potential to cause significant economic loss significant environmental loss or both if it becomes established in other parts of New Zealand or 2 Where didymo has previously thought to be of restricted distribution or abundance in New Zealand but is becoming or has become so distributed and abundant in New Zealand or any 80 Didymo Gemex DSS User Manual part of New Zealand that it has the potential to cause significant economic loss significant environmental loss or both or 3 Didymo is or threatens to be beyond control by the application of the national pest management strategy for that pest and 4 tis in the public interest that a
34. of treating a river with Gemex and the regulatory pathway to be followed made in this assessment have been assisted by information in the help files and examples The user is responsible for understanding the information contained in these help files and obtaining further advice where they are unsure about the advice given User ian Evaluation time and date Saturday 3 May 2008 2 40 pm Stream Tuapiro Creek between map reference 2765742 6406297 and map reference 2758113 6406916 River and catchment characteristics from REC and entered data Characteristic Value Flow at top of reach 1 06 cumecs Reach length 4 8 km Percentage increase in flow through reach 5 Estimated average depth 0 3 m Estimated average width 120m Help Right click For Copy Ctrl C Save Ctrl 5 and Print Ctrl P menu For example let s take an example of a new infection in the Aorere River Tasman and let us make the assumption that you are particularly concerned about the effects of Gemex on Banded kokopu Galaxias fasciatus You can display sites where Banded kokopu has been recorded by 1 On the map menu View Fish records All sites where fish records have been recorded on the freshwater fish database will be displayed If you click on any sampling site the species found there will be a 2 Click on the Marker button 89 Didymo Gemex DSS User Manual 3 A site location markers window will open Site location markers
35. on the ecology of didymo or methods used to prevent its spread between New Zealand Rivers This information is contained within the synthesis of knowledge accompanying this DSS The DSS uses a combination of computer algorithms and supporting text to provide you with the information and knowledge to make an informed decision on whether Gemex application is appropriate Computer support is used to assist you identify the infected river reach abstract site specific information on flow characteristics and calculate the likely volumes and cost of Gemex that will be required to treat it Fish species known to exist downstream of the infection site are also tabled to assist in determining whether any rare or endangered fish species are likely to be in the path of a Gemex treatment Textual information is provided that will allow you to evaluate the significance of these fish species and their likely response to Gemex Much of the uncertainty surrounding the use of Gemex relates to potential environmental effects These can be categorized into short term acute effects on non target species and long term chronic effects due to elevated levels of copper Cu in the environment Short term effects on a number of non target species have been evaluated by NIWA and summary of this information is included in the DSS together with interpretation that will allow extrapolation where applicable to other species that have not yet been tested We
36. on the use of these types of herbicides i e copper chelates in respect to irrigation and stock watering e g CaDPR 2007 Further explanation and notes for toxicity to stock The Agricultural Compounds and Veterinary Medicines Group ACVM of the New Zealand Food Safety Authority NZFSA noted that sheep and some particular breeds are considered more sensitive to copper A recommendation was made that the applicant should ensure there are no stock water supplies being taken off for reticulated water systems e g being piped to troughs water tanks etc or supplying stock water races The Gemex Treatment Contingency Plan Clearwater et al 2007a requires cessation of water abstraction on the day of the treatment USA pesticide data sheets state that there is no restriction on the use of these types of herbicides i e copper chelates in respect to irrigation stock watering e g Californian Department of Pesticide Registration 2007 Sheep As described above sheep are relatively susceptible to copper toxicity not having the ability to regulate uptake in all circumstances Under current EU Legislation complete sheep feeds must contain no more than 15 mg Cu kg in total feed 17 mg Cu kg total feed DM Assuming a maximum DM intake of 2 kg ewe d the EU permits a maximum oral intake of about 34 mg Cu ewe d less pro rata for lighter sheep In NIWA trials at Princhester Creek didymo in the application area had Cu concentrat
37. section 93 in relation to minor effects a consent authority may grant a resource consent for a non complying activity only if it is satisfied that either a the adverse effects of the activity on the environment other than any effect to which section 104 3 b applies will be minor or b the application is for an activity that will not be contrary to the objectives and policies of i the relevant plan if there is a plan but no proposed plan in respect of the activity or 28 the relevant proposed plan if there is a proposed plan but no relevant plan in respect of the activity or i both the relevant plan and the relevant proposed plan if there is both a plan and a proposed plan in respect of the activity 2 To avoid doubt section 104 2 applies to the determination of an application for a non complying activity Notification The RMA requires that all resource consent applications be publicly notified unless they come within specified exceptions If a resource consent application is not notified interested parties have no right to make submissions on the application or to appeal the decision of the consent authority to the Environment Court The Act also makes provision for limited notification where only people who are adversely affected by the proposed activity are notified and given the opportunity to lodge a submission Adversely affected parties are people who have an interest greater than the public generally
38. so that they are reflected in the audit trail at the end of the decision making process 7 14 Consultation This section relates to consultation which should occur throughout the process of determining whether to use Gemex 82 Didymo Gemex DSS User Manual Fully understanding the effects of a discharge of Gemex requires that the activities of people who may potentially be affected by the discharge are clearly understood People s concerns about Gemex and its effects or perceived effects need to be taken into account when making a decision on whether or not to use Gemex as a treatment To properly understand these effects consultation with the potentially affected people should occur When to consult Consultation should take place as early in the decision making process as possible By consulting early some of the main concerns and issues will become apparent and will help in making a quick decision on the potential costs and benefits of the proposal Consulting early also enables those people being consulted to have time to understand the potential effects of the proposal on their activities and gives them time to meaningfully contribute to the decision making process Pressure placed on people to make a quick decision on a potentially complex matter will tend to result in negative responses as a precautionary stance is adopted Who to consult Every locality will be different as there will be different land owners w
39. sulphate a common Section 6 2 garden fungicide and chelating gents hat is the difference between Chelating agents bind the copper Section 6 6 chelated copper and normal making it more soluble but less copper available to other aquatic Does it break down naturally Plants and other organic matter Sections 6 6 6 8 6 9 hat happens to it adsorb the copper chelates When plants breakdown the copper becomes part of the copper cycle The chelating agents are commonly found are commonly found in living organisms are metabolic by products and are found in foodstuffs ill there be accumulation of It will accumulate in algae and Section 6 6 other plants It is not expected to accumulate in aquatic animals Didymo Gemex DSS User Manual Is it poisonous to humans The stock solution is harmful if Section 6 4 ingested and corrosive and to skin and eyes The GTCP prevents all non official access to rivers being treated The Ministry of Health Maximum Acceptable Value MAV for copper is 2 mg L c f dose of 20 mg L Can it change in the No after plants and sediments Sections 6 6 6 8 6 9 environment to become adsorb it it is expected to become poisonous to humans indistinguishable from natural Is it poisonous to animals that The MOH guidelines for Cu are 2 Section 6 5 drink it mg L for long term consumption The GTCP requires stock access to the stream and water take for stock watering is prevented during day s of applicatio
40. the decision is yours Whatever that decision is however will be subject to public scrutiny We have therefore provided a comprehensive audit trail and reporting facility so that the reasons for using or not using Gemex are clearly documented Didymo Gemex DSS User Manual 1 1 How this User Manual is organized The same information contained in this user manual is also embedded in the help file within Didymo Gemex In the Help file the user can navigate to a particular topic e g Accumulation of Gemex copper in sediments and the most important information on that topic will be displayed For users that need further information or explanation a link is provided to a more detailed explanation and case studies In this paper version this more detailed information has a grey background 1 2 Assumptions and limitations The user needs to be aware that the sole purpose of this Decision Support System is to assist in making a decision whether or not to use Gemex for a particular river reach Whilst computer assisted support is offered the user needs to be aware that certain assumptions have been made in calculating variables used in the decision making process e g length of reach that can be treated with a single Gemex injection volume and cost of Gemex required and that there are limitations to how this information should be used In addition there are limitations associated with the advice given on the impac
41. the RMA exemption provisions can be used all three of the following tests need to be met 1 The organism is not established in New Zealand the organism is not known to be established in New Zealand or the organism is established in New Zealand but is restricted to certain parts of New Zealand and 2 The organism has the potential to cause all or any of significant economic loss significant adverse effects on human health or significant environmental loss if it becomes established in New Zealand or if it becomes established throughout New Zealand and 3 It is in the public interest that action be taken immediately in an attempt to eradicate the organism Invoking this exemption may be successful for the first infection of didymo in the North Island but is unlikely to succeed for a further infection in the South Island even if in a new region Considerations The decisions whether to grant an exemption from the RMA specified RMA provisions is a decision that must be made by the relevant Minister The determination as to whether didymo has the potential to cause significant economic loss significant human health effects or significant environmental loss relates to the potential impact of didymo if it becomes established nation wide It is not necessarily the case that didymo will have any of those effects at the particular site where it is first discovered e Section 7A 9 of the Biosecurity Act requires that the adverse effects
42. the channel morphology suitable for GEMEX treatment Decision on treatment feasibility Note that Didymo Gemex calculates the number of injection points for the selected river reach based on the distance mean velocity and increases in flow from the upstream point due to tributaries In most cases there will be more than one injection point over a reach see next screen In some cases many injection points may be required to treat the whole reach Assessing whether this number of treatment points is practically feasible in terms of access and cost is one of the decisions you will need to make Clearly injecting Gemex at all point simultaneously is not practical and the most sensible application scheme is to start at the upstream site and work downstream 24 Didymo Gemex DSS User Manual Practicality of treatment GEMEX treatment with 3 30 g L concentrate and target dose 20 mg L Based on calculated mean velocity Gemex application would be effective over a 2 7 km reach Volume required for 1 h treatment over a 2 7 km reach is 2534 L with the cost of chemicals 8000 The cost of treating the total length of infected river is 10000 allowing for 2 multiple injection points and downstream flow increase The predicted flow at the time of treatment is 1 056 cumecs The estimated total volume of Gemex required to treat the selected river reach is 5317 L Yes The estimated total volume of Gemes is available and treatment i
43. the requirement for resource consent to be avoided or at least delayed until after the treatment has occurred This and the following sections outline how those alternative provisions work and when they can be used The Resource Management Act 1991 includes provisions to enable works or activities to be undertaken in an emergency These provisions become relevant where any natural or physical resource or area is affected or likely to be affected by an adverse effect on the environment which requires immediate preventative or remedial measures In these situations resource consents do not need to be obtained prior to the emergency works being undertaken however resource consents need to be applied for within 20 working days after the works have occurred To determine whether the emergency provisions of the Resource Management Act 1991 are applicable the following flow chart indicates the considerations that must be made Start by determining which box in the top row best relates to the proposed activity and then follow through each test below Public work for which any person has financial responsibility Any natural and physical resource or Any project of work or network utility area for which a local authority or operation for which any network utility consent authority has jurisdiction under operator is approved as a requiring authority the RMA under s167 of the RMA Y Will this be affected by an adverse effect on the environme
44. Act 1991 or any regulations made under that Act List all documents attached as appendices Address for service of applicant Enter a postal address Telephone Fax email Contact person Introduction This is a resource consent application and assessment of effects on the environment prepared in accordance with Section 88 and Schedule 4 of the Resource Management Act 1991 RMA The assessment of effects has been prepared to a level of detail that corresponds with the expected scale of the actual and or potential effects of the proposed activity This proposal involves the discharge into a waterway of the product Gemex which is primarily a copper chelate solution In favourable circumstances Gemex has been shown to be an effective method for the management or eradication of didymo Didymo is an exotic alga that has potentially significant adverse effects on waterways Background Didymo What is Didymo Didymosphenia geminata which is commonly known as didymo is a freshwater alga A single cell of didymo is microscopic it takes a number of cells to be present in the water before didymo is visible to the human eye Didymo attaches itself to streambeds by stalks The stalks grow to form a thick brown mat on rocks plants and other materials in the water Established mats form flowing streamers that turn white at the ends and look similar to tissue paper Didymo can grow to form large mats on the bottom of streams river
45. Didymo Gemex Decision Support System User Manual Prepared for MAF Biosecurity New Zealand By Diffuse Sources Ltd lan Jowett Consulting Perception Planning Ltd Didymo Gemex DSS User Manual TABLE OF CONTENTS 1 INTRODUCTION 1 1 How this User Manual is organized 12 Assumptions and limitations 2 SUMMARY OF DECISION PATHWAY 3 HOW DO I START DIDYMO GEMEX 3 1 Installation System requirements Files created 3 2 First Login 3 3 Normal Login 3 4 Using Didymo Gemex Help 4 RIVER NETWORK AND LOCATION 4 1 Selecting the river reach for potential Gemex treatment How do select the treatment reach One treatment reach or more 4 2 Didymo Incursion Locations 5 PRACTICAL FEASIBILITY OF USING GEMEX TO CONTROL DIDYMO 5 1 Practicality of treatment Default values Preferred values How do ensure that the best estimate of average stream velocity is used Flow variability 5 2 How do I decide whether use of Gemex is practical for the selected length of river Risk of reinfection Flow characteristics Channel characteristics The cost of Gemex Access Total cost of Gemex treatment 5 3 Decision on feasibility of treating the selected length of river with Gemex 6 ENVIRONMENTAL ASSESSMENT 6 1 Introduction Matters likely to be considered by regional councils 10 10 13 13 27 27 27 ii Didymo Gemex DSS User Manual 6 2 What is Gemex 6 3 What are the short te
46. Discretionary activity under the operative plan provisions Objectives and Policies Based on the above analysis the following objectives and policies of the operative plan are relevant to the assessment of this application The following table should be completed for the relevant plan s that control the proposed discharge The table includes examples of relevant objectives and policies from the Wellington Regional Freshwater Plan Relevant Objectives Relevant Policies 5 1 1 The quality of fresh water meets the range of uses and values for which it is required while the life supporting capacity of water and aquatic ecosystems is safeguarded 5 1 2 The quality of fresh water has the potential to meet the reasonably foreseeable needs of future generations 5 2 3 To manage water quality for trout fishery and fish spawning purposes in those rivers or parts of rivers identified in Appendix 4 subject to Policy 5 2 10 5 2 4 To manage water quality for contact recreation purposes in those water bodies identified in Appendix 5 subject to Policy 5 2 10 excluding Lake Waitawa managed according to Policy 5 2 6 and Lake Wairarapa managed according to Policies 5 2 2 and 5 2 6 12 Relevant Objectives Relevant Policies 5 1 3 The quality of water is as far as 5 2 6 Except for rivers and streams identified in practicable consistent with the values of the Appendix 7 to manage the water quality of all tangata when
47. Drinking water supplies Stock water supplies Contact recreation unconsented Majority are for cattle ater and takes can be easily restricted during treatment Some swimming by local children but only occurs during summer months Very limited and occasional gathering of watercress from Food gathering o Hydro electricity generation Product quality standards organi c production activities Industry takes No industry takes present d s 11 Consider the effects of a full didymo incursion i e no Gemex treatment on each of the appropriate parameters given above A formal assessment procedure to undertake this is not given here because our objective is to identify impediments to the use of Gemex rather than the effects of didymo Nevertheless it is useful to be aware of these possible effects in making a judgment on whether the effects of Gemex treatment outweigh the benefits 12 Make your assessment on the overall environmental effects of Gemex below You should note that any adverse effects that can t be managed probably mean that Gemex is not recreational eeling ith occasional commercial activity All food gathering activities can easily be restricted local knowledge Only one consented ake for irrigation below the treatment reach Take can be avoided during reatment period Regional council The river is not used or hydro electric generation No significant organi
48. LTATION mem S 20 People Potential Affected by the Proposal e eeeeeeeeeee eese esee eese nennen atn s etna seinen sensns sensns senten seen sensn 21 Consultation Undertake m e 21 Response to Consultation issues eese eese eee eene eee tn tense n tens tn saints sviss esos sesser sses s o sosoo nosivi sets s sess 21 ASSESSMENT OF EFFEGTOS 2 12 52 e rae ue ia ioc Een ERRIRERAPERM REDUX ASNUu UTE EUR DESEE CREDE 21 Activity Status E 21 Actual and Potential Effects ceo rtr Io SS REN eeose is eroa e Up Nena soatecsussnasvGnedeecsesssesseceedsess 22 MEISUOILIINASP DERE 22 ECOSYSTEM Sese tts e betta rte etia t tones Piedad eet e ertet eris iaa es Doe E de te 23 Earthworks and Vegetation ear nce eee re tems ex pen eerte attese duse esee ats 25 Effects on other waterbody USeTS 2 5 esed ete on P epe e erbe tet etti eese dee ts 25 Natural HaZards es ettet te acer i e t te eere e esee etx tal er lieti tite eats 25 Hazardous Substances estos a a aa e a e eaa aa sitecepaeedeeensvdeuuosedagesctecacddesaseece 25 Ground W ALCL T Sensei ENE E O EEE E a e e ES a sot EEEa aS 25 Economic Impacts e arie e a a RR Ee UI a este a A paS 26 Amenity Values osn nE a R S E E EE O A E 26 Health and safety scsscssssssssssssscsssssssssscsscsssssssssscsssssssssesssssssssssssssssssssssssssssssssssnssssssesssessessssssenssesscessesso
49. See Section 7 9 RMA Emergency Provisions if the timeframes available are limited The following table provides an indication of the timeframes likely for the various resource consent processes possible These timeframes are indicative only and provide an estimated bad case scenario Every application is different and the time taken to process it will be influenced by a large number of variables including the complexity of effects adequacy of the application scale or distribution of the effects the number of submissions received etc Where a well constructed application has been prepared and good pre application consultation completed in order to minimize the number of submissions through prior resolution of issues the application assessment process may be significantly quicker Likely Application Process Statutory Timeframe Likely Total Timeframe accounting for further information requests hearings etc Non notified 20 working days 6 7 weeks Limited notification affected 70 working days 15 18 weeks parties only Public notification 70 working days 15 20 weeks Environment Court Appeal Previous time plus 3 6 months Considerations Preparation of a good quality application that addresses the relevant issues will assist the Council greatly in making a quick decision e Discuss how the application is likely to be processed and ask for an estimate of timeframes from the Council s Consents Team This wi
50. actices to Consider 1 Times of activity seasonal and daily 2 Movement between catchments and waterways Questions and Answers to assist Hydro Electricity Generators to Understand Gemex Effects Short Answer Further Information ill Gemex corrode fittings The public are excluded at the Section 6 6 and components time water could be slightly corrosive Gemex treated water is only corrosive for lt a few km and lt a few hours 59 Didymo Gemex DSS User Manual ill the amounts of dead didymo increase after a Gemex treatment ill water takes have to cease Yes on the day s of treatment GTCP or be restricted while Gemex is applied ill the transfer of water Yes during application 1 day between catchments need to cease ill Gemex harm people if The GTCP excludes public from GTCP they come into contact with waterway on application day treated water 60 Didymo Gemex DSS User Manual 6 15 How do I decide whether treating the didymo infected reach will be environmentally acceptable 1 Use Didymo Gemex to obtain a list of fish species found downstream of the infection point Didymo Gemex will display a list of species found downstream of the upstream end of the treatment reach together with the distance downstream of this point You should edit the list double clicking on each species will give you options to ensure that the list is relevant For example if you are assessing a river flowing
51. activity The feedback loop in the diagram represents this checking process The same feedback loop applies to consideration of rules in district plans as well see below for further discussion on district plans If the discharge of Gemex is specified as a Prohibited activity in the plan you are not able to obtain resource consent for the discharge The only real alternative in this situation is to investigate whether any of the emergency provisions of other acts may be available which may avoid the need to comply with the Resource Management Act 1991 However prohibited activities are usually only listed in plans if the activity is known to have a major adverse effect on the environment In such cases it is unlikely that use of the emergency provisions could be justified Considerations Regional plans are subject to change so any previous assessment of the proposal against the rules should be checked to ensure that the relevant provisions have not altered 72 Didymo Gemex DSS User Manual There may be two or more regional plans that apply to the one activity In most cases this will be an operative or transitional plan and a proposed plan Both plans will influence the proposed activity so both should be assessed Seek advice from a planning expert or the Consents Team e Always confirm the assessment of the rules with a member of the Council s Consents Team to ensure that the correct interpretation has been undertaken e
52. ajority of the benthic invertebrate community three weeks post treatment Such an impact can be regarded as acceptable because invertebrate populations in rivers normally undergo wide fluctuations in population e g from flow perturbations NIWA expects rapid recolonisation from resistant life stages and from drift from upstream Laboratory trials also show minimal sensitivity of larval mayflies snails and juvenile koura to short term 1 8 hour exposures to Gemex Clearwater et al 2008 Note that longer exposures e g days to weeks even of very low Gemex concentrations 0 5 g m would probably have a significant impact on invertebrates Trout Gemex can be toxic to trout in some cases Predicting impacts on trout is complex and depend on the rate of loss of Gemex downstream and the water pH and hardness 28 Didymo Gemex DSS User Manual Most NZ freshwaters are soft and the following will apply to most NZ Rivers Gemex is quite acidic so it lowers the pH at the application site This low pH results in high trout survival and because exposure times are short the low pH is not toxic itself However as pH increases downstream and the Gemex dose is spread out significant impacts to trout may occur The zone of impact is from 1 km to 4 km for reaches with a high algal biomass and may be longer for rivers with a low algal biomass and hence less adsorption and removal of Gemex although this is difficult to predic
53. although local knowledge and topographic maps can provide more detailed information How do I do this On the river network map go to Format Roads A box Line format will appear Pull down the Show main roads to level 2 Click style solid ensure colour is black and make and pull down the line thickness box to 4 Your map will look like the one below with main roads in black and secondary roads in grey In the example below Bay of Plenty Didymo Gemex has determined that the target river length between the two yellow dots requires 9 injection points at 2km intervals You can use the scale on the map to position markers Insert Marker on the map The markers can be changed by clicking on the marker and then going to Edit Text marker In this case the markers have been changed to a red cross In this case you can see that that there is reasonably good road access to the planned injection points so there should be no problem In other cases however there will be no roads and you will need to ascertain whether helicopter access is feasible and factor that into your costs Total cost of Gemex treatment The total cost of Gemex treatment is the sum of Cost of chemicals Cost of transport and application Regulatory costs and monitoring Didymo Gemex provides an estimate of the cost of chemicals NIWA 2007 estimated that the cost of transport dangerous goods and application for the Princhester Creek tria
54. an limits the amount of Gemex with the above hazard classifications to less than 0 1 tonnes within 30 m of a water course The proposed amount of Gemex to be used exceeds this volume Note Agrichemical is not defined in the District Plan Definition from the Regional Discharges to Land Plan is means any substance registered under the Pesticides Act 1979 or Hazardous Substances and New Organisms Act 1996 as a pesticide This includes any herbicide fungicide insecticide vertebrate pest control chemical or other biocide For the avoidance of doubt it does not include fertilisers or lime and other soil conditioners or agricultural effluent Gemex is not currently registered as a pesticide under either of those acts Proposed use of Gemex will be undertaken to meet the 16 Plan Provision Rule Compliance Comment Activity Status of the quantities for the relevant zone specified specified standards as a Discretionary Activity in the Hazardous Facilities Consent Status Table Appendix 2 and the activity complies with the permitted activity performance standards in Rule 21 1 1921 1 1921 1 19 above Based on the above analysis the proposed activity is assessed to be a Discretionary activity under the Proposed District Plan provisions Objectives and Policies Based on the above analysis the following objectives and policies of the operative and proposed plan are relevant to
55. and operated in a manner which prevents the pH of the formulated 1 The occurrence of adverse off site effects product considers the from the above listed activities on people substance to trigger the ecosystems physical structures and or other following classifications parts of the environment unless permitted by a ERMA 2007 clause resource consent 4 24 2 The contamination of air land and or 8 3A Eye water including aquifers potable water Corrosiveness supplies and surface waters in the event of a e 8 2C Skin limit for Some river Page 15 Rule Activity Status Plan Provision Compliance spill or other type of release of hazardous substances ii Site Layout The hazardous facility must be designed in a manner to ensure that separation between on site facilities and the property boundary is sufficient for the adequate protection of neighbouring facilities land uses and sensitive environments iii Site Drainage Systems Site drainage systems must be designed constructed and operated in a manner that prevents the entry of hazardous substances into the stormwater and or sewerage systems unless permitted to do so by the network utility operator responsible for those stormwater and or sewerage systems iv Spill Containment Systems Any parts of the hazardous facility site where a hazardous substances spill may occur must be serviced by suitable spill containment systems that are 1 Constructed from i
56. anning Ltd and Ian Jowett The template should be used in conjunction with the help file associated with the Gemex Didymo DSS The resource consent application and assessment of environmental effects should ideally be prepared by a person who is suitably qualified and experienced in undertaking and or managing a comprehensive resource consent application Some river Page 95 Report prepared by Date 96 Contents APPLICATION lel me 2 INTRODUC TION MEINER 3 Background 3 Didy MO RII LI QU LLLI 3 Whatis Did yim p M EP 3 Where did it come from originally eessessseseeseseeeeneeneenenneenne nennen enne enne nete nnne nnne 3 lo ESI jur M MR 3 MEWuTdnUBgrg 4 What management options are available eeseeeseeseeeeeeeeeeenee eren eene nennen nne nennen 4 Gr gnc evraa tac GRERRHTPE EE 5 en Saee a E E UEM eM I MM 5 Whodeveloped at eieae 5 lure 5 How does it work on Didymo esesssssssssssseeseeseeeene eene ennt 6 PHIS SS MG ad ses 6 When and how was didymo discovered c cesccsseesesseeeseesceesecceeseesceesecesee
57. ardous Substances and New Organisms Act 1996 includes provisions to manage the incursion of unwanted organisms into New Zealand The Hazardous Substances and New Organisms Act 1996 contains provisions that enable actions to be taken where a hazardous substance or new organism will result in an a actual or imminent danger to human health or safety or b a danger to the environment or chattels so significant that immediate action is required to remove the danger Section 135 HSNO Act These provisions allow an emergency to be declared by an enforcement officer so that works and actions can be done to resolve the emergency Section 136 of the HSNO Act specifies the following assessment that must occur before an emergency can be declared 1 Where any enforcement officer has reasonable grounds to believe that a there is an emergency and 81 Didymo Gemex DSS User Manual b either i no state of emergency has been declared under the Civil Defence Emergency Management Act 2002 or 11 the emergency is not being dealt with under the Fire Service Act 1975 or iii no emergency has been declared under section 144 of the Biosecurity Act 1993 or iv no other enforcement officer has declared an emergency under this Act and c all or any of the powers set out in section 137 should be exercised in order to i enter any premises or dwelling or ii remove the cause of the emergency or iii stabilise the situation
58. ata go to Options Update River Network Data The following window will appear Didymo Gemex DSS User Manual Update River Network Data You are about to update the data used for the river network This requires you to first download files with the updated data from the internet To do this vou must have access to the Freshwater Fish Database fwdb niwa co nz For fish data you must have access to the Freshwater Fish Database Fwdb niwa co nz and search for all data and save as a text file For didymo sites access the Biosecurity Didymo Database www biosecurity govt nz pest and disease response pests and diseases watchlist didymosphenia geminata partners Go to the reports section select all regions and an export file type of Excel press export and save the file See the help file for detailed instructions eported didymo location file ls last update 18 03 08 een nee Note the dates the freshwater fish database and the Didymo Samples file were last updated If you decide that an update is necessary probably only necessary for the Didymo Samples file if the site of new infection is the South Island at this stage and if the date of last update is gt 1 month then follow the instructions given above Once you are satisfied that Didymo Gemex has the most relevant data you are ready to start the evaluation The River Network is the focal point of the DSS Click on this icon and the river netwo
59. ate and therefore come under the management of the Minister of Conservation Pursuant to Section 170 of the Conservation Act 1987 a concession is required from the Department of Conservation to undertake any activity in a Conservation Area except c any action or event necessary for the purposes of saving or protecting life or health or preventing serious damage to property or avoiding an actual or likely adverse effect on the environment or d any activity that is carried out by the Minister or Director General in the exercise of his or her functions duties or powers under this Act or any other Act Where the use of Gemex is proposed in a Conservation Area confirmation should be sought from the Department of Conservation whether or not a concession is required In most cases use of Gemex in these areas will already be under consideration with the Department of Conservation as a key stakeholder and any permissions required will be addressed quickly To determine whether the proposed Gemex application site is within a conservation area use the Department of Conservation s online mapping tool as follows 1 Goto the DOC website http gis doc govt nz website Internet NZMG_2005 viewer htm 2 Turn on the Conservation Units map layer in the menu on the left of the window Figure 2 Regulatory Assessment Process Department of Conservation Te Papa Atawhai GoTo Tools Help Refresh The Map Active Layer Conse
60. ater so This is highly unlikely because the GMTP FAQ 12 that animals don t drink it GTCP restricts exposure to stock Abstraction not allowed and it is very unlikely that stock water will exceed MOH MAV of 2 mg L see above ill Gemex corrode Abstraction is prevented at the GTCP pipework and fittings time water could be slightly corrosive Gemex treated water is only corrosive for lt a few km and lt a few hours 57 Didymo Gemex DSS User Manual ill the dead didymo cause Possibly Dead didymo is still filters to clog more often than if attached after Gemex treatment the didymo dies off naturally and is only removed by stormflows which also occurs with live didymo In this unlikely event Gemex is Section 6 6 6 12 taken up by live or dead organic matter and sediments However abstraction is restricted see above Sheep are susceptible to copper poisoning and must be kept out of riverbanks if didymo is deposited there by stormflows hat happens to Gemex if it is stored for a period of time e g in a reservoir or tank hat happens if stock eat Section 6 5 didymo that has been killed by Gemex Irrigators Irrigators include individuals and organisations that take water directly from waterways or from hydraulically connected aquifers to use for non drinking purposes This includes irrigation of pasture and crops Issues of Concern to Irrigators 1 Contaminants that cause crops to die
61. ater users and people interested in the particular waterbody Discussions should be held with the consent authority to assist in identifying who may be potentially affected The following list of people and groups should be considered but there are likely to be others Department of Conservation Fish and Game New Zealand Local Iwi and hapu Landowners who boundary the waterway People who take water for irrigation People who take water for water supplies Industrial water users Hydro electricity generators Recreational users including clubs and People who gather food from the waterbody associations including plants fish and other animals People who use the water or the waterbody for Local environmental groups aquaculture e g salmon farming Tourism operators who utilise the waterbody District councils particularly in relation to town water supplies Regional council How to consult More information on how to consult and what consultation involves can be found on the Ministry for the Environment s Quality Planning website http www qualityplanning org nz consents consultation php 7 15 Decision on Regulatory Pathway This section asks you to record your understanding of the regulatory situation with respect to the particular river reach and to make recommendations on the regulatory pathway to be pursued This information will be recorded in the audit trail of decision making Section 8 83 Didymo Gemex DSS User Man
62. athways see section 6 which may lead to alternative funding sources 5 3 Decision on feasibility of treating the selected length of river with Gemex Based on the guidance given above you will be asked to record your decision relating to the practical feasibility of Gemex treatment in the four tabs Screen shots of these tabs are given below 22 Didymo Gemex DSS User Manual Practicality of treatment s dE High Medium Low What is the risk of reinfection with didymo even if the Gemex treatment is successful C b If the risk is high are there local factors that would justify suppression of didymo Please document your reasons in the text box below River characteristics Reinfection risk Treatment considerations Gemex volume and cost Overall assessment Decision on risk of reinfection 23 Didymo Gemex DSS User Manual Practicality of treatment Decision based on available data and information sources Yes Is the amount of organic material in the river consistent with the estimated mean velocity Enter your reasons in the text box below The Didymo Gemex DSS assumes the river contains soft water which is usual for NZ rivers Is the selected river reach likely to have significantly harder water than average Treatment of the selected river reach will require 2 injection points Is road access to injection points possible If no is helicopter access to injection points possible Is
63. ations 2 mg L Levels 2 mg L are not expected to be toxic to humans stock animals or 46 Didymo Gemex DSS User Manual taint food products processed with this waters because the MOH MAV has been set to prevent these problems The Ministry of Health MoH commented on the Maximum Acceptable Value MAV of compounds present in the water downstream of the treatment site and suggests that no applications be made upstream of water supply intakes unless owners of water supply intakes are advised when and for how long copper exceeding 2 mg L will pass their intake and e the water supplier can arrange to close the intake while the water with more than 2 mg L of copper content passes or flow from a tributary or uptake or deposition has reduced the copper content to less than 2 mg L 6 13 How and how often will Gemex be applied Before treatment commences the personnel equipment and Gemex will be transported to the treatment site using trucks boats or helicopters There may be a requirement to redistribute some substance to larger tanks for distribution by the pumping equipment A sub surface diffuser would be placed across the width of the waterway at the treatment location The maximum target application rate would be 20 mg Cu L in receiving water Some follow up hand spraying may be undertaken of isolated interconnected backwaters and moist fragments Gemex used for hand spraying would be diluted to a maximum of
64. be of cultural concern Activities that may be affected by a contaminant in the waterway should be identified here so that they can be included in the following assessment of effects Consider discussing with the Regional Council s consents team Proposed Activity Summary It is proposed to discharge the algaecide Gemex into the enter water body name at enter the proposed discharge locations in order to eradicate manage an infestation of Didymo It is proposed to discharge approximately enter volume of Gemex to be discharged at a rate of enter approximate discharge rate to achieve a concentration of Gemex in the water body of enter the concentration of Gemex desired for the treatment The discharge will occur for a period of one hour and will be discharged via a diffuser pipe installed across the bed of the waterbody Describe in more detail how the discharge will take place in the following section Reason for discharge The discharge of Gemex into the subject waterbody is considered necessary to control a didymo infestation thereby minimising the adverse effects of didymo on the environment and waterway users Gemex has been shown to be an appropriate and feasible method for managing an infestation in the specified waterbodies through an initial feasibility analysis using the Gemex DSS application software A summary report of the initial feasibility analysis is attached Amount rate and duration Descr
65. being short lived It can also include effects that will be off set by the benefits achieved by eradicating controlling didymo Minor effects These include adverse effects that will have little impact or will have an impact for a very short period of time Preliminary consultation as part of AEE Figure 2 includes a box representing outcomes of preliminary consultation being included in the process Before completing the preliminary AEE and ideally before proceeding through the Environmental and the Regulatory assessment modules preliminary consultation with key stakeholders and potentially affected people should be undertaken This will increase the likelihood of the actual impacts of the proposed Gemex treatment being better understood early on and it also gives other people an opportunity to contribute ideas and information to the decision making process Further information and advice on undertaking consultation can be found in section 7 14 Consultation Considerations e Any adverse effects that can t be managed will probably mean that Gemex is not appropriate to use or that there is a high chance that resource consent will not be granted for the discharge The costs and feasibility of addressing adverse effects that are manageable should be considered against the anticipated Gemex benefits Where the cost of avoiding remedying or mitigating adverse effects is greater than the anticipated benefits to be gained from using Geme
66. biologists 4 If trout or salmon are present identify the significance of the didymo infected reach as a fishery Consult with Fish and Game and Ngati Tuwharetoa if in Taupo Region whether some localised impact to fish stocks is acceptable compared to prevention of didymo incursion 5 Identify any other species known to inhabit the river downstream of the infection point and that may be susceptible to Gemex Decide on their regional significance by using Didymo Gemex to display sites in the region but not downstream where these species have also been found see Section 8 3 for how to do this 6 Ifthere is a lake or estuary as opposed to open coast downstream of the treatment reach carry out the calculations see 6 10 to decide whether there is a risk of Cu accumulating in sediments of those ecosystems that may breach sediment quality guidelines 7 Use Regional Council databases and local knowledge to identify all consented abstractions and diversions along the selected treatment reach These may include drinking water takes irrigation takes hydroelectric generation and industrial takes Check whether stock water and or domestic drinking water is a permitted activity under the Regional Plan and will therefore not need a consent 8 Identify from local knowledge including Regional Council District Council resources all significant social cultural uses of the selected treatment reach 9 Consult with potentially affected parties G
67. ble the latter being a level where there is some evidence that effects on aquatic organisms will begin to occur Sediment quality guidelines are complex and controversial and there is little consensus on how to employ them or use them ANZECC 2000 guidelines are being revised and currently favour a weight of evidence approach using chemistry toxicity and other biotic evaluations but this is not much use for predicting effects Consequently we have used Sediment Quality Guidelines themselves as a conservative approach to evaluate under what circumstances Gemex addition would cause potential long term contamination in a series of case studies below Factors controlling Cu build up in sediments Where there is the potential for fine sediments to accumulate the concentration of Cu in sediments will depend on e The dose of Gemex The natural concentrations of copper background concentrations Other copper inputs The proportion of Gemex sourced copper CuG that settles in the receiving water sediments The combined contributory catchments sediment load e The degree of mixing of freshly deposited sediment with underlying sediments in the receiving waters 39 Didymo Gemex DSS User Manual The dose of Gemex depends on the river flow amount of algal cover and the number of application sites and the frequency of repeat applications Natural concentrations of copper in soils in New Zealand range from about 2 mg kg t
68. c crops are grown in his area Only water takes are or conventional arming activities No sensitive production 63 Didymo Gemex DSS User Manual appropriate to use or that there is a high chance that resource consent will not be granted for the discharge This does not necessarily mean that it can t be done but it does flag a serious impediment to getting regulatory approval Users are encouraged to consult with MAFBNZ Diffuse Sources and NIWA if they encounter significant barriers to a Gemex treatment Knowledge around didymo and Gemex is progressing rapidly and solutions may soon be available to some of the environmental concerns listed above In addition other information may be available about didymo its impacts or lack of impact in different environments and about how to manage it 64 Didymo Gemex DSS User Manual Preliminary environmental assessment Overall decision on environmental assessment My assessment is that the environmental effects of Gemex treatment will be gt Significant and can t be managed Significant but can managed Minor Note reasons for the asessment of effects here recommend that we do not proceed with further assessment Go to audit trail Bio Physical Social cultural Health Water use Overall Assessment Overall decision on environmental assessment Note if you click the Do not proceed box when you click the Next button you w
69. ccount the local environment and site specific issues A resource consent application and AEE should be prepared by someone who is experienced in preparing such documents such as a resource management planner This person will understand the standard of assessment expected by the council and will be able to ensure that the application is as complete as possible Technical input from biologists ecologists and other specialists is also likely to be required particularly where there are sensitive species or activities present Resource consent applications must include certain details and the template provided will provide guidance on these details It is important to speak with the person at the Council who is likely to be processing the application both before and during the application preparation process They will be able to provide guidance on the key issues to address as well as assistance with specific legal requirements of the application If resource consent is granted Gemex can then be applied in accordance with the conditions of that resource consent If resource consent is not granted two options are available Either follow the Environment Court appeal process set out in the RMA or investigate using one of the alternative regulatory methods described below Considerations Consider having the application prepared by a resource management planner or other professional who is experienced in preparing applications Discuss t
70. ccur then Didymo Gemex provides the location of positive identification from the Didymo samples database 1 With the River Network map displayed Click View Known Didymo Locations The locations will be shown as below Lares 2 Ifthe site of new didymo infection is in the South Island you may wish to pinpoint the exact location in relation to known didymo incursions 3 In this case use the click zoom icon or select the Zoom cursor changes to a cross Unzoom a will return you to previous views Select the required portion by clicking on the top left corner and dragging the selection area to the bottom right corner 4 You can show the site of new infection in relation to known didymo incursion from the insert menu Insert Marker You will note the cursor changes to a cross Position the option in the File menu The 13 Didymo Gemex DSS User Manual cursor at the point of the new infection and click You will note the cursor changes to an arrow again If you want to change the look of the marker symbol so that it contrasts with the red circles of didymo incursion click on the symbol and go to the Edit Text marker Change the fill colour to green and the site of the new infection will display as in the figure below N B You can delete markers from the map using Edit Text marker and clicking Symbols none In this case the new point of infection is above a known didymo incursion in the Sherry
71. concentrate stockpiled 1000L in North Island and 1600L in South Island NIWA GTPC 2007 Section 3 3 states that the manufacturer requires 4 weeks notice for quantities in excess of 2000L and that raw materials if not available in NZ may take 4 6 weeks to get here GTCP 2007 Therefore if the quantity of Gemex required exceeds 2 600L because of the river flow it would not be possible to treat the river for at least one month unless larger quantities of Gemex or raw ingredients have been stockpiled in the interim Given that Gemex is most effective on rivers at an early stage of infection Clearwater et al 2007 this is a cause for concern Stock access and recreational river use will also increase risk of didymo being spread during before treatment period Channel characteristics For Gemex application to be effective the in stream concentration needs to be maintained at 20g m for 1 hour Factors that will affect the distance downstream that this concentration will be maintained include the amount of organic matter in the river adsorbs Gemex and therefore reduces the concentration and the nature of the channel morphology i e as it influences the amount of dispersion You should consider the following in deciding whether the channel characteristics favour Gemex application 1 Is the observed organic matter content consistent with the predicted mean velocity Didymo Gemex uses mean stream velocity as a surrogat
72. consideration Making a decision as to whether or not the presence of didymo in a particular area constitutes an emergency must be supported by robust reasoning and argument The emergency provisions are not intended to be used as a method for circumventing the normal planning processes If the appearance of didymo is not an emergency then these provisions are not intended to be used e Several people or organisations are able to use the emergency provisions Full involvement of the consent authority and all other key stakeholders in the particular waterbody proposed to be treated should be involved in the decision making wherever possible Consider whether the effects of didymo on the environment will actually be significant Do the effects warrant immediate action The likelihood of didymo spreading from the current location to a far more sensitive location may be a consideration The effects on the presently affected water body may not be significant but the ease with which didymo may then spread to a more sensitive area may significantly increase as a result of this infestation therefore the environmental effects may be significant and warrant immediate action e Consideration should be given to whether the proposed preventative remedial measure i e Gemex is going to have less of an adverse environmental effect that if didymo were allowed to remain establish Consideration should be given as to whether Gemex will act
73. ction be taken immediately to manage or eradicate the organism and sufficient powers are not otherwise available to enable the organism to be effectively managed or eradicated There are several limitations and requirements associated with the use of the emergency provisions and these should be carefully considered refer to Section 144 of the Biosecurity Act 1993 See http www legislation govt nz for full details of New Zealand Legislation As with the other regulatory options that avoid the resource consent process full consultation with the consent authority should be undertaken Considerations Take particular note of point 4 above which requires that for the emergency provisions to be used sufficient powers should not otherwise available to enable the organism to be effectively managed or eradicated This may mean that a biosecurity emergency may not be able to be declared where there is sufficiently available time and other means to manage or eradicate didymo e g management via resource consents to use Gemex M The Biosecurity Act emergency provisions eliminate any requirement to obtain resource consent or to manage the effects on the environment associated with the treatment method Careful consideration should be given to the effects of treatment versus the benefits of managing didymo 7 12 HSNO Act Emergency Provisions Should the Resource Management Act and Biosecurity Act provisions be inappropriate to use the Haz
74. ction occurring on the day of application unless abstraction occurs within 1 km of injection point at the time of injection ill Gemex affect fish and Very unlikely Gemex would Section 6 10 shellfish in estuaries and be largely adsorbed by the time intertidal areas at river mouths flows reach estuaries Anglers and Food Gatherers Anglers and food gatherers include trout and salmon eel and whitebait fishers as well as people collecting edible plants Gathering of other species such as freshwater mussels and crayfish is also included Aquaculture activities fall within this sections for example salmon prawn and freshwater crayfish farms Issues of Concern to Anglers and Food Gatherers 1 Effects of human contact with Gemex 2 Human consumption of food 3 Access to waterways 4 Usability of waterways 5 Availability of fish food species Anglers and Food Gatherers Practices to Consider 1 Times of activity seasonal and daily 2 Access points to waterways 3 Movement between catchments and waterways 4 Consumption of food Questions and Answers to assist Anglers and Food Gatherers to Understand Gemex Effects Short Answer Further Information How long will fishing and food On the day s of treatment fish and up to six GTCP gathering have to stop for months plants 52 Didymo Gemex DSS User Manual ill Gemex harm people if they come into contact with treated water ill Gemex corro
75. d endangered species In conclusion caution should be exercised when rare or endangered species or large numbers of juveniles are present If significant mortality occurred some rare galaxiid populations with limited distribution 1 e especially non migratory species might not recover at all because of recruitment limitation Some pre testing of Gemex tolerance is recommended this can be conducted very quickly and management e g temporary removal of founder populations should be considered to reduce risks Clearwater et al 2008 Mussels and koura In laboratory trials both juvenile and adult koura survived a range of Gemex exposures expected to occur during a 1 hour river dosing There was no significant Cu bioaccumulation in adult koura The uptake of Cu from the diet via Gemex contaminated periphyton was not examined but dietary Cu bioavailability is low and so the risk is thought to be much lower than uptake from water These data indicate that a Gemex treatment will have minimal effects on koura populations or will present minimal risk to human consumers of adult koura Clearwater et al 2008 There was 100 survival of freshwater snails exposed to a range of Gemex concentrations for 1 to 8 hours The snails avoided exposure by retreating into their shells a similar response is expected of freshwater mussels Clearwater et al 2008 It should be noted that in general shellfish bivalves and snails are relatively
76. d in NIWA s Webmodel http wrenz niwa co nz webmodel Sediments contaminated with Gemex sourced copper will settle in quiescent environments onto other sediments uncontaminated by Gemex A feature of most quiescent environments is sediment mixing by bioturbation The degree of mixing can be a discontinuous and diminishes with depth but can often be represented by a mixing depth similar to visible bioturbation structures in the sediment For example in sheltered muddy estuaries in Auckland an effective mixing depth of 15 cm is observed Williamson et al 1999 The deeper the mixing the greater the dilution by underlying sediments If there is no mixing then the Gemex sourced copper is only diluted by the sediment that settles over the same time that sediment containing CuG settles Estuary mixing is understood relatively well in New Zealand lake sediment mixing is less well understood Case Study 1 Princhester Creek plus Hypothetical Lake or Estuary To scope the magnitude of sediment contamination two hypothetical cases are considered 1 a hypothetical lake and 2 a hypothetical estuary was placed at the bottom of Princhester Creek The reason for using this hypothetical case rather than a real case which are considered below is that conditions can be easily manipulated to give a worse case These hypothetical examples can also be linked to a real dosing trial carried out by NIWA NIWA dosed a reach of the Princhester Creek i
77. de fittings and components ill Gemex harm people if they eat food sourced from a treated waterway ill Gemex cause the flavour of food to be tainted ill trout be harmed or killed by Gemex The GTCP excludes public from waterway on GTCP application day The public are excluded at the time water could Section 6 6 be slightly corrosive Gemex treated water is only corrosive for lt a few km and lt a few hours No as long as don t eat dead fish Gemex is not expected to accumulate in fish Section 6 6 6 11 and so is not expected to taint flesh Overseas similar Cu products are used to prevent taints associated with cyanobacteria blooms in fish ponds It can be poisonous to trout depending on water Section 6 3 6 6 chemistry Some trout may die in localised areas on the treatment day s ill salmon be harmed or killed It is probably be poisonous to salmon Section 6 3 6 6 by Gemex ill aquatic or water edge plants be harmed by Gemex e g water cress ill freshwater mussels and crayfish be harmed by Gemex ill Gemex affect fish ill Gemex affect whitebait ill Gemex affect eel ill Gemex affect ducks and other hunted waterfowl ill Gemex affect species down up the food chain which may in turn affect species gathered for food sport depending on water chemistry It is probably toxic to some other algae and Section 6 3 6 6 plants However many common algae surviv
78. der of this section 7 2 7 12 before making your decision of the regulatory pathway to be followed Section 7 13 If your assessment suggests that a Gemex treatment would be appropriate you are encouraged to obtain regulatory approval ahead of time as the chances of successfully treating didymo will be much improved if it is treated quickly Summary of regulatory process This section summarises the regulatory process shown in Figure 2 The following sections expand on each of the steps in the assessment process and should be referred to as part of the decision making process Begin by determining whether the Gemex application site is within a conservation area administered by the Department of Conservation DOC If it is consult with DOC to determine permissions and other requirements before proceeding If it isn t within a conservation area proceed to considering whether the existing Environmental Risk Management Authority ERMA approvals for Gemex are in place Proceed to an assessment of the provisions of the relevant regional and district plans Where the use of Gemex isn t specifically provided for by a rule ina regional plan resource consent for a discretionary activity will be required Where the activity is controlled by a rule in a plan resource consent will be required Determine the activity status for the activity If it is permitted you may apply Gemex without resource consent Where the activity is a con
79. die 2 Contaminants that may cause products to be rejected or downgraded due to the presence of a contaminant 3 Availability of water 4 Reactions of contaminants with other additives or product ingredients Drinking Water Abstraction Practices to Consider 1 Timing of water takes seasonal and daily 2 Locations of water takes from backwaters or unconfined aquifers where flushing of contaminants may be slower than the main waterway channel 3 Storage of water 4 Discharges of unused or wastewater Questions and Answers to Assist Drinking Water Abstractors to Understand Gemex Effects ill water takes have to stop while Gemex is in the water How long will water takes have to stop for Does Gemex harm humans hat are the risks of Gemex contaminating drinking water supplies Short Answer Further Information On the day s of treatment The stock solution is harmful if ingested and GTCP Section 6 4 corrosive and to skin and eyes The GTCP requires that all non official access to rivers being treated is prevented The Ministry of Health Maximum Acceptable Value MAV for copper is 2 mg L c f one hour dose of 20 mg L The max treatment dose is 20 mg L while the Section 6 12 MOH MAV is 2 mg L Abstraction of large proportions of Gemex treated water is operationally difficult Abstraction is restricted on the day s of treatment In the unlikely event of inadvertent abstraction occurr
80. dix 2 part A and 2 the discharge shall not contain any contaminants other than Some river Page 11 contaminants at concentrations specified in conditions 3 to 7 below and 3 concentrations of free or combined residual chlorine in the discharge shall be no more than 0 5 g m3 and 4 concentrations of suspended solids in the discharge shall be no more than 50 g m and 5 concentrations of acid soluble aluminium in the discharge shall be no more than 0 15g m and 6 concentrations of fluoride in the discharge shall be no more than 1 5 g m3 and 7 the discharge temperature shall not differ from the ambient temperature of the receiving water by more than 5 Celsius and 8 the discharge does not cause erosion at the point of discharge and 9 the discharge does not alter the natural course of the river or stream Rule 5 All remaining discharges to fresh water The discharge of any contaminant or water into fresh water that is not provided for in Rules 1 2 3 and 4 and which cannot meet the requirements of Rules 1 2 3 and 4 and which is not a non complying activity in Rule 6 is a Discretionary Activity Discretionary This rule applies to the discharge This rule includes any discharges not provided for in the permitted activity above The proposed discharge of Gemex is a Discretionary Activity Based on the above analysis the proposed activity is assessed to be a
81. e Gemex treatment Macrophytes are expected to grow back quickly from rootstock No Latest laboratory trials show a wide safety Section 6 3 margin for koura and shellfish for a 1 hour Clearwater et al application to a river and for the longer 2008 exposures downstream It would be inappropriate to apply it at spawning times However it could be applied before spawning times to remove didymo from redds Gemex is not very toxic to adult galaxiids Section 6 3 and there is a wide margin of safety for one Clearwater et al hour applications and for the longer exposures 2008 downstream Juvenile fish whitebait will be more susceptible and application during whitebait runs should be avoided at this stage It is not expected to be poisonous to eels Section 6 3 because eels are relatively insensitive to normal copper Copper and copper chelates are relatively non Section 6 3 toxic to birds There is a very low risk that blue duck might be affected by the low pH for one hour immediately downstream of the treatment point but the treatment management plan could include efforts to keep birds out of the water for one hour Gemex is being applied This would reduce the risk to negligible Copper does not bioaccumulate in the food Section 6 6 chain Only very small amounts are taken up from food 53 Didymo Gemex DSS User Manual Recreational users Recreational users include organisations such as rowing je
82. e and multiple doses of Gemex 20 mg L One species of mayfly Coloburiscus was more sensitive than another Deleatidium spp while stonesflies were much less sensitive Clearwater et al 2007 On the basis of other NZ and overseas studies on copper toxicity NIWA expects macro invertebrates with a larger body size are less sensitive Daphnia magna a common toxicity test organism was sensitive to Gemex but this organism is not expected to be exposed to toxic doses in the real environment being a pond dweller Clearwater et al 2007c The Princhester Trials indicated that the Gemex treatment had a minimal effect on the macroinvertebrate community in Princhester Creek three weeks post treatment Clearwater et al 2007d p76 Recent laboratory trials have confirmed that Deleatidium spp are relatively resilient to a 1 to 8 hour Gemex exposure Clearwater et al 2008 Trout In field laboratory trials trout survived 4 mg L Gemex The LC50 for juvenile trout is about 50 mg L with 100 surviving a dose of 20 mg L for 1 hour In Princhester Creek field trials Clearwater et al 2007d 7096 of caged juvenile trout survived an application dose of 16 mg L for 1 hour but significant mortality occurred downstream where the copper dose was dispersed and diluted but pH had recovered to circum neutral values So although Gemex concentrations were lower the caged animals were exposed for a slightly longer time at a higher pH 6
83. e confirmed Document any specific use conditions that apply Evaluation of Options Available options Describe the available options for the controlling the infestation of didymo in this particular location or area Refer to the options in the previous sections see Table for possible inclusions Evaluation of options Evaluate the options that have been considered for controlling the infestation of didymo Outline the advantages and disadvantages of each option in relation to this particular infestation its location and surrounding environment Once the options have been identified describe why the use of Gemex is considered to be the most favourable This may relate to effectiveness cost feasibility urgency etc 10 Regional Plan Provisions Introduction Regional plans are prepared by Regional Councils to assist them in carrying out their functions under the Resource Management Act 1991 the RMA Regional plans contain rules methods objectives and policies that guide resource users and the Council in the use and management of natural and physical resources The following sections identify the relevant rules of the relevant regional plans and specify the objectives and policies in those plans that will later be addressed as part of the Assessment of Environmental Effects Relevant Regional Plan and Status Plan or Plan Change Variation Status List the names of each of the regional Specify the current status
84. e for the amount of organic matter present and therefore the length of reach that may be treated effectively There may however be local factors that mean there is more organic matter present than expected it is unlikely there will be less For example if the stream drains wetland soils there may be high levels of dissolved organic matter or point sources may add organic matter to the stream though this is unlikely in a didymo infected reach There may also be large amounts of benthic algae other than didymo present at moderate high velocity rivers which can occur in regulated rivers and this may reduce Gemex concentrations at a higher rate than expected simply on the basis of velocity Didymo mass will have a very strong influence on effective treatment distance Didymo mats can absorb huge quantities of Gemex Clearwater et al 2007b and when present will therefore be the primary determinant of effective treatment distance If you suspect that organic matter in the treatment reach is anomalously high or didymo mats are present you should seek advice from a 19 Didymo Gemex DSS User Manual qualified scientist as to what the implications might be in terms of reducing effective treatment length 2 Will channel morphology reduce the effectiveness of Gemex treatment The ideal stream for Gemex treatment is one in which a single channel is contained between two banks and inflows are defined tributaries With this config
85. e its uptake through excretion and storage Cu does not biomagnify i e Cu concentration are not magnified as it passes to higher trophic levels as e g mercury does There is also unlikely to be biomagnification of Gemex chelates because Cu is delivered to the cell in chelated form and there will be many strongly binding ligands and sites to dissociate copper from the Gemex chelates So once in the cell our current understanding is that CuG will behave like other Cu The above processes may increase copper concentrations in the water slightly because of some leakage into the water column but this would probably not be measurable because large volumes of water will pass over sites where the relatively slow decomposition and transfer processes occur Eventually Cu will be transferred to the sediments and buried or transported in that form 38 Didymo Gemex DSS User Manual 6 10 Accumulation of Gemex copper in sediments If treated rivers flow into quiescent receiving waters such as sheltered muddy estuaries or small lakes then copper applied in multiple treatments can accumulate in the sediment Threats to sediment dwelling organisms are indicated if concentrations exceed sediment quality guidelines Desktop modeling see case studies below suggests a low risk of concentrations exceeding sediment quality guidelines and only in very unfavourable circumstances Further explanation and notes on long term effects of Gem
86. e the potential for spills and to ensure that the transportation storage and use of Gemex is undertaken in an appropriate manner a Gemex Application Management Plan will be prepared prior to Gemex being transported to the discharge site The Gemex Application Management Plan will include a description of the risks and hazards associated with Gemex and the sites where it will be used The Plan will also include a procedures manual for the safe transportation storage and use of Gemex for each application Any spillage of Gemex from the pumping and storage of Gemex at the application sites will be contained within the bunded areas to prevent uncontrolled discharge of the chemical into waterways Where possible spilled Gemex will be collected and placed into an appropriate contained to be disposed of at an appropriate facility Where significant amounts of Gemex soak into the underlying soil the Consent Authority will be contacted and an assessment will be made as to the most appropriate method for containing or removing the contaminated soil will be The consent holder will be responsible for undertaking any necessary cleanup work Gemex authorisations Describe the current status of Gemex under the Hazardous Substances and New Organisms Act and whether it has Environmental Risk Management Authority approval for the proposed use Note that these approvals are subject to change and review so the current status needs to b
87. ease in Cu is relatively small This is only a hypothetical example of one case but it is very useful in determining under what circumstances that Gemex would represent a long term threat Case Study 2 Waiotaka River Taupo The Waiotaka River drains to southern Lake Taupo While it drains to the lake there are a great many other streams and rivers in the vicinity which also discharge sediment including the much larger Tongariro River 802 km 137 kt yr The scenario requires 6 injection points along the treatment reach Table 6 3 estimates the copper concentration in lake sediments after treatment assuming sediment inputs from Waiotaka and the adjacent Waimarino River only Natural sediment loads are probably much greater because of inputs from the nearby Tongariro River so there is very low risk of excessive copper build up in sediments 42 Didymo Gemex DSS User Manual Table 6 3 Estimation of Cu build up in southern Lake Taupo at the outlet of Waiotaka River IWaiotaka River and River Value Units Source Treatment Dose Treatment Target 20 g m INIWA Dosing time 3600 sec NIWA Number of treatments space time 6 DSS Flow at time of treatment 1 061 m s DSS Mass of Cu in all doses 1244 kg DSS Natural sediment and Cu loads Total area of stream catchment 73 km DSS Total stream sediment load 23 3 Ikt yr webmodel Background Cu in stream sediments 12 mg kg Assumed Natural Cu load 279 6 kg calculated CuG
88. eat water grown plants plants may adsorb enough Gemex in the treatment reaches to make consumers sick Don t eat dead plants The plants will recover as copper is washed out of the system and will probably be suitable to eat 6 months after the last treatment however no research has been done on this in New Zealand 50 Didymo Gemex DSS User Manual How quickly will didymo return This depends on many factors Section 6 13 after it has been treated Eradication can be achieved in favourable circumstances low infestations although the research has not been done to demonstrate this is achievable Suppression maybe achieved in situations where there is heavy infestations of didymo hat will happen in the event of The GTCP includes monitoring GTCP unanticipated effects occurring and stakeholders will be kept informed Any information will be fed back into didymo control knowledge database here else has it been used Similar compounds are commonly Section 6 11 used in some states in the USA to control waterweeds algae and some other pests Similar compounds are also used in aquaria Does is cause any smells Gemex itself does not smell Decaying didymo may cause odour when it is removed from the river ho will be responsible for the Depends on regulatory pathway ERMA 2007 GTCP Clearwater discharge used There is an expert on site et al 2007a coordinator responsible for the application hat happens if the ch
89. ed from the Gemex DSS software or from the Regional Council Data on multiple waterbodies may be able to be tabulated Describe how the waterbody interacts with groundwater and or other waterbodies This may also include how managed diversions will be controlled Biota present Describe the plant and animal life of the waterway and riparian margins upstream of the discharge point This information should be available from a freshwater scientist within your Regional Council with some basic data available from the Gemex DSS software fish only In particular species that are known to be susceptible to copper should be identified as well as any rare or endangered species This information assists in establishing an environmental baseline for the monitoring of any effects of the proposed discharge Other waterway users Describe the activities of other relevant waterway users downstream of the discharge point including activities such as water abstractions other discharges recreation activities food gathering and any culturally or spiritually significant sites or practices In determining who may be affected the distance downstream from the Gemex discharge point will need to be considered It may be appropriate to consider only those water users that will be using water where the concentrations of copper in the waterbody will be higher than the New Zealand Drinking Water Standard 2mg l however concentrations below that level may still
90. effects Some river Page 25 Economic Impacts Section 5 of the RMA states that a component of sustainable management is enabling people and communities to provide for their social economic and cultural wellbeing and for their health and safety The following assessment considers whether the proposal will enable this to occur within the context of the proposed development Assess the potential economic effects on other waterbody users of the use of Gemex This may include consideration of the cost to water abstractors of having to shut down their intakes for a period of time Consideration should also be given to the potential economic effects on tourism business which may need to avoid using the waterway for a period of time and therefore suffer a loss of business This can be balanced against the economic benefits of managing didymo in this particular waterbody Amenity Values Some waterbodies will have significant amenity value They may be particularly picturesque or be visible to a large number of people In most cases Gemex will be in the water body for a very short period of time and unless a die tracer is used will not be visible to observers It is unlikely that Gemex will result in any significant impact on visual amenity Consideration should be given to whether there will be an odour effect once the didymo has died There may be a large quantity of dead didymo decaying which may result in odours T
91. einfection risk Treatment considerations Gemex volume and cost Overall assessment Data on the RHS of the window is calculated directly from the REC and the user cannot change shaded items The Distance Inland is the distance from the sea of the upstream end of the treatment reach Flow adjustment for tributaries estimates the increase in flow downstream brought about by tributary inflows Without this calculation the amount of Gemex needed to raise the stream to the target concentration would be underestimated The flow adjustment is worked out for every reach of river between tributaries over the treatment length The treatment length weighted flow is 15 Didymo Gemex DSS User Manual Sum L Qi Sum Li where L is the length of reach between tributaries and Qi is the flow in that reach The flow adjustment is the reach weighted flow divided by the flow in the upstream reach Default values Data on the LHS contains some default information on the flow at the time of treatment and the average width and depth of the treatment reach The default Flow at the time of treatment is estimated from the flow statistics as the median flow 1 1597mean annual low flow 0 401 1mean flow The default Width Depth and Velocity values are calculated from NZ hydraulic geometry relationships Jowett 1998 unless a habitat survey has been used More information The stream width and depth are calculated from NZ hydraulic geometry relations
92. ek Scenario 20 Gemex doses Values changed from Table 6 1 are highlighted Princhester Creek Value Units Source Treatment Dose Treatment Target 20 g m INIWA Dosing time 3600 sec NIWA Number of treatments space time 20 Scenario Flow at time of treatment 0 25 m s NIWA Mass of Cu in all doses 360 kg calculated Natural sediment and Cu loads Total area of stream catchment 38 6 km webmodel Total stream sediment load 6 9 kt yr webmodel Background Cu in stream sediments 12 mg kg Longhurst et al 2004 Natural Cu load 82 8 kg calculated CuG diluted into annual load 64 17 kg kt calculated Princhester Estuary Settling Zone Area 4 Williamson et al 2000 Estuary sediment mixing depth 0 15 m Auckland Proportion SS settling in estuary 75 Williamson et al 2000 Resulting Cu in estuary sediments 1256777 mg kg calculated Increase in Cu 0 77 mg kg calculated Princhester Lake Lake sediment mixing depth 0 05 m guess Sediment deposition rate in lake 0 0014 Im yr IL Taupo Dilution factor from mixing 37 calculated Resulting Cu in lake sediments 13 42 mg kg calculated Increase in Cu 1 42 mg kg calculated Sediment Quality Guidelines IANZECC 65 mg kg IANZECC 2000 Environmental Response Criteria Red 34 mg kg IARC 2004 Environmental Response Criteria Amber 19 mg kg IARC 2004 http wrenz niwa co nz webmodel The calculated concentrations are again much lower than SQG and more importantly the incr
93. ellyman P G Biggs B J F Hickey C W Blair N Clayton J S 2007 Didymosphenia geminata experimental control trials Stage Three Phase One testing the effectiveness of Gemex a chelated copper formulation in a small river NIWA Client Report HAM2007 060 for MAF Biosecurity New Zealand Project No MAF07203 91 p Clearwater S J van Kooten M Bremner D C Farnsworth K Costley K Hickey C W 2008 Effect of Gemex use as a control agent for Didymosphenia geminata on non target aquatic species including trout native fish crustaceans molluscs and insect larvae NIWA Client Report HAM2008 040 for MAF Biosecurity New Zealand Project No MAF08205 xx p ERMA 2007 www ermanz govt nz search registers html id 21447 Jellyman P G Clearwater S J Biggs B J F Blair N Bremner D C Clayton J S Davey A Gretz M R Hickey C Kilroy C 2006 Didymosphenia geminata experimental control trials Stage One screening of biocides and stalk disruption agents Stage Two Phase One biocide testing NIWA Client Report CHC2006 128 for MAF Biosecurity New Zealand Project No MAF06504 109 p Jellyman P G Clearwater S J Blair N 2006 Assessment of effects on the environment of proposed trials of a method to control the alga Didymosphenia geminata in Princhester Creek and Monowai River Southland NIWA Hamilton Client Report HAM2006 155 for MAF Biosecurity New Zealand Project No MAF07203 57 p Lesl
94. emex may involve incidental activities that may trigger rules in district plans An example would be the transport storage or mixing of hazardous substances Gemex because of its corrosive and ecotoxic properties will often be regarded as a hazardous substance in district plans and its management will therefore need to meet the provisions of the district plan In contrast to discharges most land use activities can occur unless they contravene a rule in a district plan So if there is no rule in the relevant district plan controlling the activities proposed resource consent is not required 7 5 Activity Status The following table briefly explains the status of activities in regional and district plans Activity Status Requirement Likelihood of Public Notification The activity can occur without resource Will not be publicly notified consent however it will generally have to comply with a set of standards listed in the Regional Plan Resource consent is required but the Council must grant it Conditions can be attached to the consent that must be complied with Resource consent is required and it can be Low to medium granted or refused The Council can only refuse it in relation to the matters that it has restricted its discretion to Conditions can be attached to the consent that must be complied with Sometimes this is also referred to as Limited Discretionary Resource consent is required and it can be
95. emex on invertebrates can be found in Section 6 3 of the user manual Further input into the effects of Gemex on invertebrates within a specific waterway being treated may need to be contributed by an expert Trout Gemex can be toxic to trout in some cases Predicting impacts on trout is complex and depend on the rate of loss of Gemex downstream and the water pH and hardness Most NZ freshwaters are soft and the following will apply to most NZ rivers Gemex is quite acidic so it lowers the pH at the application site This low pH results in high trout survival and because exposure times are short the low pH is not toxic itself However as pH increases downstream and the Gemex dose is spread out the copper becomes more toxic and significant impacts to trout may occur The zone of impact is from 1 km to 4 km for reaches with a high algal biomass and may be longer for rivers with a low algal biomass and hence less adsorption and removal of Gemex In hard waters the effects are yet untested The high alkalinity buffers the water so pH is higher and this enhances Cu toxicity but this is offset by the inhibition of Cu toxicity by high concentrations of hardness ions Ca and Mg Baseline recording of the existing water quality should provide data on the hardness of the water in the particular receiving environment This data will assist in determining the likely effects of Gemex on the trout population present A descr
96. emical is The GTCP has instructions to deal ERMA 2007 GTCP Clearwater spilled accidentally with spills It will be diluted et al 2007a rapidly by water soil or sawdust How does the chemical work on Didymo adsorbs or absorbs Section 6 6 didymo Gemex after which Cu interferes with cell or cell membrane processes How often would the chemical Depends on extent of didymo Section 6 13 GTCP be applied infestation size of river flow amount of inorganic matter in river and management objective How would the chemical be From a storage tank e g 50001 FAQ 11 GTCP applied through an underwater diffuser here would the chemical be Based on expert appraisal of FAQ 11 GTCP infestation river size and locations hen would the chemical be As soon as possible after the See DSS GTCP didymo is discovered to increase chance ofsuccess Best applied in summer Based on expert appraisal hat does it do to water quality It increases chelated copper Section 6 6 in the short term concentrations and decreases pH hat does it do to water quality It is not expected to affect WQ in Section 6 8 6 9 6 10 in the long term the long term apart from effects on didymo Didymo Gemex DSS User Manual Do people need to stay out of the On the day s of treatment river For how long Does it affect land plants that No risk if GTCP followed Still Section 6 12 are irrigated with water from highly unlikely in the event of the river inadvertent abstra
97. er is a pipe with a series of controlled outlets that enables the Gemex solution to be emitted at sufficient concentrations across the waterway to enable full treatment of the water column The Gemex solution will be pumped into the diffuser apparatus using a sealed pump The length number of diffuser heads and pumping equipment will be adjusted depending on the requirements of the waterway width flow volumes and the distance upstream of the target area Full details of the discharge apparatus are included in Appendix X of this report Discharge rate computations Tracer Dye If it is proposed to include a tracer dye with the discharge or to discharge a tracer dye separately but as part of the overall treatment procedure describe the details of the dye and its use here Explain why the dye needs to be used what it is made from and whether it is a commonly used dye or one specifically designed for use with Gemex Dilution Prior to the discharge of the Gemex solution gauging of the waterway will be taken to enable an accurate calculation of the required dosage rate and period that is required to effectively treat the waterway as described above The Gemex application rate will be determined using the following calculation Enter discharge rate calculation Delete this because already specified above and below Timing Describe when the discharge is expected to take place for how long and at what frequency The timi
98. es in or on items that have not been rigorously decontaminated http www biosecurity govt nz pest and disease response pests and diseases watchlist didymosphenia geminata incursion www biosecurity govt nz faq Some river Page 3 What effects does it cause Thick growths can adversely affect freshwater fish plant and invertebrate species by reducing the number of suitable habitats Under favourable conditions for its establishment it is likely to have a large impact on trout fisheries hydro power schemes and irrigation takes The brown carpet of didymo is also very unsightly and is likely to make swimming an unpleasant experience and annoy anglers by fouling lines and lures It has no known human health risk What management options are available The use of Gemex is one of several options available for the management of didymo The currently available management options include the following Management Option Positive Negative Do nothing Exclude activities that might result in further spread No financial costs associated with treatment Avoids adverse effects associated with treatment options May reduce the likelihood of didymo spreading to other waterbodies Relatively low financial cost to implement although some cost associated with advertising and policing Does not control didymo High likelihood that didymo will spread to other waterbodies Existing species likely
99. ex Aquatic Plants Specify any significant aquatic plants that may be adversely affected by Gemex In most cases Gemex has little or no known adverse effect on aquatic plants other than alga Where there are Some river Page 23 rare or endangered aquatic plant species present downstream of the discharge point specialist input should be sought and included as part of this assessment In the absence of rare or endangered aquatic plant species present downstream of the discharge point there will be short term inhibition of some non target algae However rapid recovery is expected by the existing algae in treated reach and through recolonisation from upstream The magnitude of the impacts is expected to be comparable to impacts that occur in the normal hydrological cycle Invertebrates Some short term negative effects on benthic invertebrates may occur This can include the removal of some sensitive species such as the spiny gilled mayfly Coloboriscus affect other invertebrates during sensitive life stages and may impact on small invertebrates However such an impact can be regarded as acceptable because invertebrates normally undergo wide fluctuations in population e g from flow perturbations NIWA expects rapid recolonisation from resistant life stages and from drift from upstream which will result in any adverse effects of the discharge being resolved through natural processes Further details on the potential effects of G
100. ex needed to achieve the desired Gemex concentrations in the waterbody How does it work on Didymo GemexTM is thought to kill didymo cells through adsorption of the copper chelates into or onto cell walls This Site When and how was didymo discovered Describe how when and where didymo was discovered in this particular area Provide some background of its discovery and development Project Description Project Site Location Describe the location of the discharge point including a site map legal description relevant map references name of the waterway and a general description of the area surrounding the discharge point Where consent is being sought to use Gemex in a number of waterbodies describe the locations of those waterbodies Physical location Legal Description Map Reference Site Map Google Maps http maps google com is a useful source of map images Physical characteristics Describe the current nature of the waterway including dimensions volume flow rate water colour clarity bed and bank material Much of this information will be able to be sourced from the Gemex DSS computer program You may also need to source additional descriptive information from the Regional Council A description of each of the waterways proposed to be treated should be included in the case of a global consent application Description of didymo infestation Describe the extent of the didymo infesta
101. ex on the aquatic ecosystem Assessing Cu build up in sediments As described above in the long term Gemex sourced copper will be indistinguishable from copper from other sources in terms of its forms effects and fate As far as we know the only long term effect of Gemex would be due to the accumulation of copper in sediments Most copper added to the environment either naturally or through anthropogenic inputs will end up in fine sediments The accumulation of copper in sediments is a cause of concern in other situations In the past industrial and mining discharges high in copper have greatly contaminated receiving water sediments These are now largely under control or diverted to treatment facilities In recent times there have been concerns for copper accumulation in the sediments of waters receiving copper from more diffuse sources such as urban stormwater and boats The potential for impact by Gemex sourced copper depends primarily on the concentration of copper in sediments As with water quality guidelines ANZECC 2000 had trigger levels for sediment concentrations viz 65 mg Cu kg of sediment ANZECC guidelines for Cu in estuary sediments were recently reviewed by the Auckland Regional Council which derived two trigger levels called environmental targets for urban stormwater which is repeatedly discharged to receiving waters 19 mg kg Cu as a early warning and 34 mg kg as target not to be exceeded if possi
102. ffects on amenity values or the intrinsic values of ecosystems which may result from any use and development and on any natural or near natural areas are avoided remedied or mitigated Policy 13 To recognise the cultural relationship of the tangata whenua with rivers lakes wetlands and other water bodies and to promote the management of fresh water in ways that take into account iwi values and beliefs In addition to promote the protection and management of sites of significance to iwi within the beds of water bodies Policy 15 To protect water resources used for public water supply from abstractions of water and discharges of contaminants which may affect the suitability of those waters for water supply Page 19 Regional Policy Statement Objectives Policies Requirements Chapter 9 Ecosystems Objective 1 The overall quality Policy 4 To avoid remedy or of ecosystems in the Region is mitigate the adverse effects of increased activities on ecosystems and in particular to avoid remedy or mitigate any of the following effects 1 Reduction in the indigenous biodiversity of an ecosystem 2 Prevention of the natural processes of an ecosystem including nutrient cycles and energy flows from operating effectively 3 Simplification of the structure of indigenous ecosystems and 4 Reduction in the quality or quantity of the non living parts of an ecosystem e g decaying plant and animal remains
103. for apply to ecosystems that could be classified as slightly moderately disturbed The highest protection level 99 has been chosen as the default value for ecosystems with high conservation value pending collection of local chemical and biological monitoring data For ecosystems that can be classified as highly disturbed the 95 protection trigger values can still apply But it may be appropriate to apply a less stringent guideline trigger value say protection of 90 of species or perhaps even 80 36 Didymo Gemex DSS User Manual NIWA followed the ANZECC Guideline 2000 decision tree Jellyman et al 2006a and concluded that although a Gemex treatment of didymo will exceed the trigger value for Cu a biological effects assessment of chelated Cu shows that the management aim of long term didymo control with minimal long term effects on non target species especially fish can be achieved in keeping with the principles of the ANZECC WQG EPA aquatic life criteria EPA aquatic life criteria for copper have evolved over the last 30 years or so The first criteria were total copper but the USEPA moved to address bioavailability about 20 year ago The next set of aquatic life criteria documents for copper e g U S EPA 1980 1985 1996 expressed the copper toxicity as a function of water hardness They incorporated the effects of hardness on metal toxicity using empirical regressions of toxic concentrations versus hardness for a
104. for the permitted activity rule If the standards will be complied with you can apply Gemex without having to obtain resource consent Note that the Council may encourage you to obtain a Certificate of Compliance which is a written statement from the Council that your proposal complies with the permitted activity rules in the Plan A Certificate of Compliance is not essential but has the same effect as a resource consent and provides some protection to your activity if there are any changes to the regional plan provisions If the Gemex discharge falls within a Controlled Discretionary Restricted Discretionary or Non complying activity status you will need to obtain a resource consent for the activity The complexity and level of detail required in your application will depend both on the activity status and on the significance of the expected environmental effects The following sections of this document will help you determine the significance of the potential effects and provide guidance on whether a resource consent is likely to be granted Figure 2 shows a feedback loop below the controlled discretionary or non complying step Most plans have specific standards that have to be met even for controlled and discretionary activities If for example an activity is listed as a controlled activity but does not meet one of the controlled activity standards it will then fall under a more restrictive rule it may become a discretionary
105. for the selected length of river Up to this point Didymo Gemex has provided factual information on the river characteristics and calculated estimates of the volume of Gemex that will be required together with its cost It is now up to you to use this information together with supplementary information gathered at a local level to decide whether using Gemex is practical in the circumstances This is a value judgment on your part and will depend amongst other factors on the value of the river under consideration the financial resources you have available or can get access to and your assessment of how effective Gemex will be in the circumstances The tabs at the bottom of the Practicality of Your local Regional Council should know whether or not habitat survey has been done for a particular river reach Any habitat surveys carried out under public good science funding are freely available Others that have been paid for by a particular client require permission of that client to use Ian Jowett i jowett ihug co nz is a good source of information on the availability of habitat survey data 17 Didymo Gemex DSS User Manual treatment window ask you to make decisions based on information prompted in the following sections Risk of reinfection Use the Didymo incursion map see section 4 to decide whether there is a high likelihood of reinfection from upstream and neighbouring catchments For example in the Sherry r
106. g element that is generally present in surface waters Copper is a micronutrient for both plants and animals at low concentrations and is recognized as essential to virtually all plants and animals However it may become toxic to some forms of aquatic life at elevated concentrations Thus copper concentrations in natural environments and its biological availability are important The toxicity of a chemical to an aquatic organism requires the transfer of the chemical from the external environment to biochemical receptors on or in the organism at which the toxic effects are elicited Often this transfer is not simply proportional to the total chemical concentration in the environment but varies according to attributes of the organism chemical and exposure environment so that the chemical is more or less bioavailable Definitions of bioavailability vary markedly and are often specific to certain situations but a useful generic definition is the relative facility with which a chemical is transferred from the environment to a specified location in an organism of interest Of particular importance to bioavailability is that many chemicals exist in a variety of forms chemical species Such chemical speciation affects bioavailability because relative uptake rates can differ among chemical species and the relative concentrations of chemical species can differ among exposure conditions In the absence of chelating agents such as those used in Gemex
107. g the use of Gemex for treating didymo and a statement on the sources of information within Didymo Gemex and how it has been used to make a decision Saving the report saves it as a rich format text file rtf that can be opened by virtually any word processing package The advantage of saving it in this format is that you can subsequently add maps or other information to the report to enhance its readability 7 Of course if you decide that Gemex is not worth considering further after the practical feasibility module the audit trail will contain only information on practical feasibility Likewise if the decision is that it is practically feasible but not environmentally acceptable then the audit trail will contain information on those two modules but not regulatory considerations 88 Didymo Gemex DSS User Manual Audit Trail The following report was generated from Didymo Gemex a Decision Support System developed to assist groups decide whether or not to use Gemex to treat rivers infected with didymo Default hydrological data has been generated from NIVVA s REC although the the user has the option of entering better data should it be available Data on fish species known to occur below an infected reach was generated from the NVA Freshwater Fisheries database Information on known location of didymo incursions has been generated from the Didymo samples database The decisions on practicality likely environmental effects
108. h and the relevant outcomes intended by the objectives and policies This section should summarise the key issues that will be assessed in the following AEE section e Risks to the environment and people from the transportation storage and use of Gemex Management of the risks of spills and accidental discharges Some river Page 17 Relevant Regional Policy Statement Provisions Introduction Regional Policy Statements are prepared by regional councils to provide a region wide policy direction on key issues Any council preparing a district or regional plan within the region shall have regard to the Regional Policy Statement Likewise Section 104 of the RMA requires that a consent authority shall have regard to the Regional Policy Statement Relevant Regional Policy Statement and Status Wellington example Status operative under review Regional Policy Statement Regional Policy Statement for the Wellington Region Operative Currently under review however only a draft of the revised version has been released at the date of writing The provisions of the operative RPS are attributed full weight for the purposes of this assessment Regional Policy Statement Requirements Regional Policy Statement Requirements Chapter 5 Fresh Water Objectives Objective 2 The quality of fresh water meets the range of uses and values for which it is required safeguards its life supporting capacity and has the potent
109. hat it will be difficult to Gemex treated rivers to cause exceedance of sediment quality guidelines downstream This is because of sediment loads carried 44 Didymo Gemex DSS User Manual by streams and the mixing of Gemex contaminated sediments with uncontaminated sediments in the quiescent receiving water downstream Large lakes like Taupo are highly unlikely to be susceptible to copper build up Many estuaries also have unfavourable settling conditions that result in Gemex contaminated sediments being widely dispersed However it is possible that small lakes and small sheltered estuaries could be susceptible to Cu build up from repeated Gemex treatments in tributary streams and rivers where these treated waterways constitute the majority of the inputs to the receiving water If this is suspected expert advice should be sought 6 11 Are copper or copper products used elsewhere to treat algal infestations Copper is commonly used as a treatment for fish diseases and algae in aquaria and many proprietary products utilize copper chelates Copper is also used as a herbicide in lakes and irrigation channels either as inorganic copper usually copper sulphate or as copper chelates e g K TEA a common algacide used in the USA also trailed by NIWA for didymo This isa widespread practice in some states in North America For example over 32 tonne of copper as active component were applied in Florida from 1987 89 for control of
110. he water How far downstream will it travel ill the flavour of fish etc be tainted here does it come from ill fish passage be affected living and dead plant material and by sediments and diluted downstream It is not expected to stay in the water longer than a day Uptake rates depend on the Sections 6 6 6 8 6 9 amount of organic material It becomes progressively diluted and dispersed as it travels downstream In trials concentrations reduced to below drinking water guidelines within 3 km Very low concentrations will travel some distance downstream 10 km or SO Gemex is not expected to accumulate in fish and so is not expected to taint flesh Overseas similar Cu products are used to prevent taints associated with cyanobacteria blooms in fish ponds It is made by mixing copper sulphate with the chelating agents This is unlikely to be a major effect because concentrations are high only for a short period hours day ill fish spawning be affected It would be inappropriate to apply ill it kill other plants that grow in the water it at spawning times However it could be applied before spawning times to remove didymo from redds It is probably toxic to some other Section 6 3 algae and plants However many common algae survive Gemex treatment Macrophytes are expected to grow back quickly from rootstock hat happens to our health if There is the possibility that water we
111. he chelating agents themselves are not expected to be toxic they are commonly found in living organisms are metabolic by products and are found in foodstuffs Who developed it Gemex was developed by the National Institute of Water and Atmospheric Research NIWA specifically for the treatment of didymo How is it used Before treatment commences the personnel equipment and Gemex will be transported to the treatment site using trucks boats or helicopters There may be a requirement to redistribute some substance to larger tanks before distribution by the pumping equipment A sub surface diffuser would be placed across the width of the waterway at the treatment location Gemex is metered into the waterway to a maximum target application rate of 20 mg Cu L in receiving water Some river Some hand spraying may be undertaken of isolated interconnected backwaters and moist fragments on shore Gemex used for hand spraying would be diluted to a maximum of 20 mg Cu L before spraying Multiple strategic follow up treatments by application to flowing water and hand spraying may be required Between 3 and 10 follow up treatments typically spaced 24 hours apart may be more effective than a single treatment Prior to commencing the application of Gemex to the waterway the flow in the river is measured with dye tracing using the non toxic dye rhodamine This information is needed in order to accurately calculate the precise amount of Gem
112. he proposal with a consents officer at the council to understand the type and level of information required e Section 6 of this user manual and FAQs for stakeholders will provide a lot of useful information to assist in the preparation of the application Some of this information has already been included in the application template but there may be additional relevant information that could be of assistance T Didymo Gemex DSS User Manual e Consultation should be undertaken with people who may be affected by the proposal Ask the Council s consents officer who they think might be considered as affected parties You may find the FAQ section useful for consultation particularly the relevant FAQs and answers for specific interest groups such as Maori water abstractors and recreational users Consultation is an important tool for identifying potential adverse effects Consult early to provide time to address any issues raised The details of the proposal included in the application and AEE will become a requirement of the resource consent Make sure that the details and methodology provided in the application reflects what will actually happen when the activity occurs 7 9 RMA Emergency Provisions Where the timeframes available are insufficient to obtain a resource consent or the resource consent process is not considered appropriate for the use of Gemex in a particular situation various acts provide opportunity for
113. he river water is important in determining the off target dose effects of Gemex Cu is also most toxic at circum neutral pH 6 7 As the pH drops below pH 6 H competition becomes increasingly important while at pH above 7 complexing with HCO increases thus reducing Cu When Gemex is dosed into water the chelating agents dominate the chemistry and free copper is mainly determined by the chemical equilibrium with the chelated copper which in turn is determined mainly by the concentration of Gemex in the water and only a limited extent by the chemistry of the water NIWA measured the fate and toxicity of Gemex in laboratory trials flume trials and in Princhester Creek Southland and subsequently summarized the likely toxicity and fate if Gemex was applied to the Kakanui River Clearwater et al 2007b The following is summarized from that report The active ingredients in Gemex are chelated copper compounds The chelates form a shell around the copper ion forming a stable compound and altering the properties of the copper ion rendering it chemically and biologically different from inorganic copper the usual form of the copper that contaminates the environment It reduces the concentration of the most toxic forms of copper chiefly the free metal ion Cu This free copper is toxic to fish through absorption by the fish gills Gemex is thought to be toxic to algae because it is transported by cell membra
114. here the NZCPS is relevant an assessment of the proposal against its relevant policies should be undertaken 26 At the time of preparing this guide there are no other national policies statements relevant to the discharge of Gemex however a national policy statement for freshwater management is in the process of being developed and may be relevant to this assessment Part Il Assessment Section 5 Assessment Section 5 of the RMA specifies the purpose of the Act as being to promote the sustainable management of natural and physical resources Sustainable management is thereafter defined as In this Act sustainable management means managing the use development and protection of natural and physical resources in a way or at a rate which enables people and communities to provide for their social economic and cultural wellbeing and for their health and safety while a Sustaining the potential of natural and physical resources excluding minerals to meet the reasonably foreseeable needs of future generations and b Safeguarding the life supporting capacity of air water soil and ecosystems and c Avoiding remedying or mitigating any adverse effects of activities on the environment Provide an overall assessment of the proposal against the provisions of s5 of the RMA with a summary statement in relation to a b and c Sections 6 7 and 8 Assessment Section 6 7 and 8 identify matter
115. hips Jowett 1998 unless a habitat survey is used The relationships are width 11 755 Flow area 3 713 Flow 9 Velocity Flow Area Depth Flow Width Velocity Jowett I G 1998 Hydraulic geometry of New Zealand rivers and its use as a preliminary method of habitat assessment Regulated Rivers 14 451 466 Preferred values The flow at the time of treatment is a critical parameter for determining how much Gemex will be required by simple dilution to get the required in stream concentration Whilst the default median value may be adequate as a first estimate it is much better to enter a more accurate estimate of flow at the time of treatment by estimating the median flow for the season for which the Gemex application is planned In Didymo Gemex mean velocity provides an estimate of the length of reach that may be treated by a single injection of Gemex NIWA tests in Princhester Creek suggested that the treatment was effective for about 2 km and that reinjection of Gemex would be required below this in order to treat further downstream Clearwater et al 2007 The principal reason for this is that when Gemex is injected into a stream its concentration gradually declines as organic matter in the stream absorbs it The amount of organic material in a stream will depend largely on the stream velocity streams with high velocity usually retain little organic material and consequently the target conce
116. his will need to be assessed on a case by case basis and will only be relevant where there are people within close proximity to the waterbody being treated Health and safety A significant assessment of the health and safety effects will have been addressed in the hazardous substances section above However consideration should be given to any health and safety effects that have not previously been considered Cultural Values Cultural values relate to activities practices or beliefs associated either with a specific area or with a resource Maori especially place cultural significance on waterbodies and on the ecosystems that they support Consultation with local iwi and runanga representatives should occur to develop an understanding of the potential effects of the discharge on those values Cultural values may also be associated with other users People that have traditionally used an area for whitebaiting or food gathering or who may hold a section of the waterbody in high regard should also be considered and their concerns addressed where appropriate Summary of Effects The following actual and potential effects on the environment have been identified List the identified effects identified above Relevant National Policy Statement Provisions Relevant National Coastal Policy Statement Provisions The New Zealand Coastal policy Statement will only be relevant where Gemex is likely to affect coastal or estuarine waters W
117. ial to meet the reasonably foreseeable needs of future generations Objective 3 Freshwater resources of significance or of high value for cultural spiritual scenic ecosystem natural recreational or other amenity reasons are protected or enhanced Policies Policy 4 7o maintain and protect the quality of fresh water so that it is available for a range of uses and values and 1 Its life supporting capacity is safeguarded and 2 Its potential to meet the reasonably foreseeable needs of future generations is sustained and 3 For surface water any adverse effects on aquatic and riparian ecosystems are avoided remedied or mitigated Policy 6 7o ensure that the effects of contaminants contained in point source discharges on the quality of fresh water and aquatic ecosystems are avoided Regional Policy Statement Objectives Requirements Some river Policies remedied or mitigated and allowing for reasonable mixing 1 Do not render any fresh water unsuitable for any purpose specified in any regional plan for that water 2 Do not prevent the receiving fresh water from meeting any standards established in any regional plan for that water 3 Do not render any water in the coastal marine area unsuitable for any purpose specified in a regional coastal plan for the Wellington Region Policy 11 To ensure that in respect of all water bodies not covered by Fresh Water Policy 10 any adverse e
118. ibe the details of application volumes rates and durations proposed This information can be sourced from the Gemex DSS software but should be confirmed using appropriate calculations by experts Where the application is for a global consent and the details of the exact dosages are not yet known include details to a level of accuracy to enable the Council and potentially affected parties to understand the quantities of Gemex likely to be involved In many cases the exact dosage of Gemex will need to be varied depending on the exact flows in the waterbody at the time of discharge Care should be taken when preparing the consent application that sufficient flexibility in dosage rates is provided for to enable variable dosage without having to amend the resource consent It may be appropriate to specify a maximum discharge volume rate duration Describe also whether the resource consent is for a single application of Gemex or whether multiple applications are proposed It may be appropriate to enable a number of applications to occur Discharge technique An experienced chemical application contractor will be selected and contracted to provide application equipment personnel and expertise for the application The contractor will be required to hold the Growsafe chemical applicators certificates Gemex will be applied to the waterway using a sub surface chemical diffuser placed across the width of the waterway to be treated The diffus
119. ible due to access low risk of infestation etc In this case describe the relevant characteristics above the viable treatment area Biota present Describe the plant and animal life of the waterway and riparian margins upstream of the discharge point This information should be available from a freshwater scientist within your Regional Council with some basic data available from the Gemex DSS software fish only In particular species that are known to be susceptible to copper should be identified as well as any rare or endangered species This information both assists in establishing an environmental baseline for the monitoring of any effects of the proposed discharge and also enables an understanding of the potential for natural recolonisation of the treated area Other waterway users upstream Describe the activities of other relevant waterway users upstream of the discharge point including activities such as water abstractions other discharges and hydro electricity generation activities Some activities upstream of the discharge point may influence the water quality and quantity downstream and therefore influence the timing or effectiveness of any treatment Some river Page 7 Downstream environment Physical characteristics Describe the current nature of the waterway downstream of the discharge point including dimensions volume flow rate water colour clarity bed and bank material This information can be obtain
120. ic ecosystems Effects on future generations Effects on the values of tangata whenua e Effects on contact recreation e Effects on groundwater Measurement against the specified water quality guidelines Relevance of a mixing zone e Whether there are any exceptional circumstances or justifications for any effects related to the above District Plan Provisions The purpose of District Plans is to assist District Councils in carrying out their functions under the Resource Management Act The most common district planning matters for the discharge of Gemex will relate to hazardous substances but there may be other requirements depending on the activities associated with the Gemex application e g earthworks to cut access tracks to application sites vegetation clearance etc 14 Introduction The proposed application site is with the enter district s name s The following provisions of the district plans for those districts are relevant Relevant District Plan and Status The Wellington RC examples in the following tables are for illustrative purposes only Plan or Plan Change Variation Status Operative South Wairarapa District Plan Fully operative Weighting attributed to each provision will vary depending on the status attributed to corresponding provisions in the Proposed Plan Proposed Combined Wairarapa District Proposed Decisions on submissions have Plan been released but the appeal period has not yet closed
121. ice from a qualified freshwater biologist How do I select the treatment reach With the river network is displayed use the hand cursor to select the reach If the cursor is not already a hand select the hand cursor from the icon tray at the top of the map window Then click on the map at the upstream end of the reach that you wish to treat The map can am x C be moved by using the grab cursor Lev or using the zoom buttons AS Click on the icon 10 Didymo Gemex DSS User Manual and then select a point on the map and holding down the mouse drag it over the area you wish to zoom in out on When you click on the map with the hand pointer a yellow dot will mark that location You are asked to confirm that this is the upstream location Edi Ip slalo aala v BIN M ITE j River location data 37 97 km2 catchment area 1 83 cumecs mean flow 278 Lis mean annual low flow East 2766476 North 6402514 Lat 37 54 Long 175 90 You are then asked to identify the downstream location and to do this you click downstream with the hand pointer and another yellow dot will be displayed You are asked to confirm that this is the downstream location Edit Format Help ey 4 v BIN ALE Ol ponis I 37 97 km2 catchment area 1 83 cumecs mean flow 278 Lis mean annual low flow a East 2766758 North 6396473 Lat 37 60 Long 175 91 Select as Sor aem When you confirm there is a short wait while the program
122. ie AJ 1990 Aquatic Use of Copper Based Herbicides in Florida Report to Florida Department of Natural Resources Bureau of Aquatic Plant Management Tallahassee Florida http www dep state fl us lands invaspec 2ndlevpgs pdfs copper pdf Leslie AJ 1992 Copper Herbicide Use Patterns in Florida WatersReport to Florida Department of Natural Resources Bureau of Aquatic Plant Management Tallahassee Florida Longhurst RD Roberts AHC Waller JE 2004 Concentrations of arsenic cadmium copper lead and zinc in New Zealand pastoral topsoil and herbage New Zealand Journal of Agricultural Research 47 1 23 32 Morrisey D J Williamson R B Van Dam L Lee D J 2000 Stormwater contamination of urban estuaries Testing a predictive model of the build up of heavy metals in sediments Estuaries 23 67 79 USEPA 2006 Reregistration Eligibility Decision For Coppers United States Environmental Protection Agency Prevention Pesticides and Toxic Substances EPA 738 R 06 020 July 2006 92 Didymo Gemex DSS User Manual USEPA 2007 Aquatic Life Ambient Freshwater Quality Criteria Copper 2007 Revision EPA 822 R 07 001 U S Environmental Protection Agency Office of Water Office of Science and Technology Washington DC Williamson R B Morrisey D J 2000 Stormwater contamination of urban estuaries Predicting the build up of heavy metals in sediments Estuaries 23 56 66 Williamson R B et al 1999 The build up of c
123. ill go directly to the audit trail without completing the regulatory module 65 Didymo Gemex DSS User Manual 7 Regulatory Assessment 7 1 Introduction If your decision has been that it is both practical and environmentally acceptable to apply Gemex to treat didymo then you will need regulatory approval to do so This section sets out a logical pathway for you to obtain the necessary approvals The normal route for applying a chemical to a river is through the resource consent process under the Resource Management Act 1991 but this consent process is designed for activities that can be planned a significant time in advance Unless applying Gemex to rivers for the purposes of treating didymo is specified in a regional plan as a permitted activity or a resource consent has been granted in advance of didymo being detected it is unlikely there will be sufficient time to go through the consent process Because of the invasive nature of didymo however there may be alternative regulatory pathways that avoid the need for resource consent particularly through the emergency provisions of various acts A flowchart demonstrating the regulatory pathways to be considered is shown in Figure 2 below This is an expansion of the regulatory module shown in Figure 1 If you are familiar with the regulatory processes then reading the summary below in conjunction with Figure 2 may be sufficient Otherwise you should read and understand the remain
124. ing on the day of application it is highly improbable that there are many situations where Cu is not diluted or removed to concentrations 2 mg L 55 Didymo Gemex DSS User Manual ill there be an accumulation No the MOH MAV of 2 mg L and abstraction Section 6 12 of copper in food products or in restrictions on day of treatment are designed to stored water prevent any possibility of this happening Copper will not biomagnify in the aquatic food web ill Gemex react with other Yes the chelating agents may react with chemicals added to drinking chlorine However abstraction is restricted on water e g chlorine fluoride treatment day s so this should not be an issue flocculants etc ill Gemex taint the taste of Yes near the application point but not after dilution to below MoH MAV level of 2 mg L Abstraction is restricted ill Gemex taint the taste of Tainting is unlikely if water is inadvertently food made using treated water abstracted on a treatment day Abstraction is restricted on treatment days ill Gemex corrode The stock solution is acidic and dosed water pipework and fittings may have low pH 3 5 for short periods 1 2 hours near the point of application pH rises to natural levels after a few km on the day of treatment and immediately after the treatment Remember abstraction is restricted on treatment days ill the dead didymo cause Possibly Dead didymo is still attached after filters
125. ions of 31 69 mg kg DW before the trials which is greater than the EU limit After application concentrations increased to 133 997 mg kg and after 42 days they were still high 109 367 mg kg Clearwater et al 2007 p37 However dead didymo is fixed to streambed by stalks until eroded by floods Therefore it is unlikely that sheep will be exposed to either live or dead didymo except where 33 Didymo Gemex DSS User Manual floods deposit dead didymo on flood plains Even if dead didymo were to be eaten by sheep it would be inadvertently while grazing pasture so it is likely that total Cu ingested would be less than the EU limit 6 6 What is the toxic action of Gemex Why is it more toxic to didymo than fish Reactive free copper is mostly the free uncomplexed ion Cu or its weakly hydrated forms This is the form that is widely toxic to a range of aquatic organisms especially salmonid fish Chelation makes the copper relatively non toxic to many aquatic organisms while still maintaining its toxicity to didymo The toxic action of Gemex to didymo appears to be due to the adsorption of the chelated copper compound directly into the algae Further explanation and notes for Gemex toxic action The following was adapted from the USEPA Aquatic Life Ambient Freshwater Quality Criteria Copper 2007 Revision USEPA 2007 Copper is an abundant trace element found in the earth s crust and is a naturally occurrin
126. iption of that potential impact should be included along with an assessment of the significance of those effects The adverse effects on the trout population in a particular waterway may be off set by the ability for recolonisation Native Fish Effects are expected to be insignificant on common galaxiids Bullies a non migratory species appear to be intermediate in sensitivity to Gemex compared to juvenile rainbow trout and galaxiids On the basis of the known toxicity of copper to eels Gemex is expected to pose minimal risk for eel populations Gemex will probably be more toxic to juvenile life stages of all species e g migrating whitebait so an increased impact of a Gemex treatment during spawning or larval recruitment seasons would be expected Further information of effects on native fish can be found in Section 6 3 of the User Manual Mussels snails and koura NIWA studies indicate that a Gemex treatment will have minimal effects on koura populations or will present minimal risk to human consumers of adult koura NIWA studies demonstrated no mortality in snails exposed to Gemex for 1 8 hours The snails avoided exposure by retreating into their shells a similar response is expected of freshwater mussels See Section 6 3 of the User Manual for details and references Birds 24 Birds are not sensitive to copper and no effects are expected There may be some issues associated with effects of low pH on wading or swim
127. ith each of the consent authorities I Full name of applicant apply for the following types of resource consent For an activity in the coastal marine area state coastal permit Otherwise state one or more of the following land use consent subdivision consent water permit or discharge permit Describe the activity for which the application relates The names and addresses of the owner or occupier other than the applicant of land to which the application relates are as follows Details The location of the proposed activity is as follows describe the location as it is commonly known and in a way that will enable it to be easily identified e g street address legal description name of any relevant stream river or other water body to which the application relates proximity to any well known landmark and or the grid reference No additional resource consents are needed for the proposed activity OR the following additional resource consents are needed for the proposed activity and have or have not been applied for Give details I attach in accordance with the Fourth Schedule of the Resource Management Act 1991 an assessment of environmental effects in the level of detail that corresponds with the scale and significance of the effects that the proposed activity may have on the environment I attach any information required to be included in this application by the district plan the regional plan the Resource Management
128. itional references should you require them It is important that you read and understand all the relevant issues covered in Sections 6 2 6 13 Section 6 14 guides you through the decision making process for whether treating the Didymo infected reach with Gemex will be environmentally acceptable 6 2 What is Gemex Gemex is a copper based biocide specifically designed to treat didymo while minimizing impacts on non target species It is a mixture of copper sulphate which is also a common garden fungicide with relatively simple organic molecules which act as chelating agents Clearwater et al 2007b ERMA 2007 Copper and copper chelates have been commonly applied to treat waterways for aquatic weeds especially in Florida They are also commonly used as a treatment for fish diseases and to remove algae in aquaria The chelating agents themselves are not toxic They are commonly found in living organisms are metabolic by products and are also found in foodstuffs 6 3 What are the short term non target impacts Algae There is short term inhibition of some non target algae However rapid recovery is expected by the existing algae in the treated reach and through recolonisation from upstream Benthic invertebrates Short term negative effects may include a minimal to moderate decrease in the numbers of some sensitive species e g amphipods and life stages However the Princhester Creek trial showed minimal impact on the m
129. ity modeling approach commonly termed the Biotic Ligand Models to acknowledge that the biochemical receptor is a metal binding ligand that is treated similarly to ligands in the exposure water except that it is on the organism and is the keystone for metal accumulation and toxicity The BLM accounts for all important inorganic and organic ligand interactions of copper while also considering competitive interactions that influence binding of copper at the site of toxicity or the biotic ligand The BLM s ability to incorporate metal speciation reactions and organism interactions allows prediction of metal effect levels to a variety of organisms over a wide range of water quality conditions These guidelines are not appropriate for use with Gemex because they do not take into account the direct toxicity of copper chelates through uptake into or onto living cells by some species and not by others 6 8 What is the Long Term Fate of added Gemex Gemex is rapidly adsorbed by organic material including didymo other periphyton macrophytes and decaying vegetation didymo and other algae killed by Gemex will slough off especially during high flows and be washed downstream These dead algae or algal mats will undergo biodegradation through bacterial breakdown and consumption by detritus feeders The copper associated with the Gemex dose will go through biotic cycles of breakdown uptake utilisation and excretion during its transition dow
130. iver example shown previously it would be possible to treat this reach with Gemex because there are no points upstream of this site where didymo has been confirmed However in this hypothetical case new infection at the Kaihiku Stream has occurred upstream of a known didymo incursion in the Sherry River and with the presence of didymo in neighbouring catchments there is clearly some risk of re infection You need to evaluate this risk based on local knowledge e g river use by recreational users and conditions to decide whether it is worthwhile treating the river with Gemex Note while there have been reports of didymo moving upstream e g the Kakanui and conjecture that this has been caused by wading birds it is much more likely to have been due to fishermen since the sites of new infection coincided with known trout pools or the confluence with tributary inflows There may also be good reasons for simply controlling the extent of didymo growth in the reach e g keeping a swimming hole highly valued by the local community clear of undesirable growths during the summer in which case Gemex treatment may still be justifiable Flow characteristics The amount of Gemex required to treat the length of river selected is directly related to the flow at time of treatment Didymo Gemex has given you an estimate of this amount and its cost Didymo Gemex has also given you guidance on flow variability low medium high High flow variabili
131. l authority websites and contact details are available from http www lgnz co nz lg sector maps Where other regulatory provisions are relevant an assessment of their implications on the treatment process should be undertaken and the conclusion entered into the DSS Regulatory Section Explain in sufficient detail in the comments box in the DSS the reasoning behind the decision made with reference to the relevant regulation 7 3 Confirm ERMA Approvals The Environmental Risk Management Authority is responsible for controlling the manufacture importation and use of chemicals that are not otherwise approved for general use within New Zealand ERMA is able to grant approvals for the use of specific chemicals in specific situations Currently ERMA have granted approval for the use of Gemex when it is applied during a biosecurity emergency however this may be modified to enable its use pursuant to a resource consent or via other regulatory pathways If ERMA authority to use Gemex requires it to be used in accordance with a specific regulatory procedure this will streamline the regulatory assessment process Contact MAFBNZ to determine the current status of Gemex permits 7 4 Managed by a Rule in a Regional or District Plan This step in the regulatory decision making process requires that the rules on the relevant regional and district plans are assessed This will determine whether resource consent is required and if one
132. l load 14 61 kg kt calculated Princhester Estuary Settling Zone Area 496 Williamson et al 2000 Estuary sediment mixing depth 0 15 m Auckland Proportion SS settling in estuary 75 Williamson et al 2000 Resulting Cu in estuary sediments 12 04 mg kg calculated Increase in Cu 0 04 mg kg calculated Princhester Lake Lake sediment mixing depth 0 05 m guess Sediment deposition rate in lake 0 0014 Im yr IL Taupo Dilution factor from mixing 37 calculated Resulting Cu in lake sediments 12 07 mg kg calculated Increase in Cu 0 07 mg kg calculated Sediment Quality Guidelines IANZECC 65 mg kg IANZECC 2000 Environmental Response Criteria Red 34 mg kg IARC 2004 Environmental Response Criteria Amber 19 mg kg IARC 2004 The calculated concentrations are much lower than SQG Table 6 1 and more importantly the increase in Cu is relatively small However NIWA considered that potential threats would be only be achieved through repeated dosing so this case is considered next The following example uses 20 times the dose trailed by NIWA at Princhester Creek This might be equivalent to dosing at 2 km intervals on two occasions The cost of Gemex through repeated use would probably limit the total number of doses so this example represents a reasonable worse case scenario Table 6 2 41 Didymo Gemex DSS User Manual Table 6 2 Estimation of Cu build up in a hypothetical estuary and hypothetical lake at the outlet of Princhester Cre
133. l pass their intake and 32 Didymo Gemex DSS User Manual 2 the water supplier can arrange to close the intake while the water with more than 2 mg L of copper content passes or flow from a tributary or uptake or deposition has reduced the copper content to less than 2 mg L Suspending water abstraction for the entire day of treatment is a conservative approach since copper concentrations are unlikely to be greater than 2 mg L at any location in the waterway for more than 2 hours The Gemex Treatment Contingency Plan Clearwater et al 2007 states that water supplies for irrigation drinking and stock watering within the treatment area will be identified and arrangements made with the landowners occupiers to cease water abstraction on the day of treatment ERMA 2007 Clause 3 7 3 10 6 5 Is Gemex toxic to stock The Ministry of Health MoH Maximum Acceptable Value MAV for Cu in stock drinking water is 2 mg L The Gemex Treatment Contingency Plan Clearwater et al 2007a states that water supplies for irrigation drinking and stock watering within the treatment area will be identified and arrangements made with the landowners occupiers to cease water abstraction on the day of treatment This is consistent with recommendations from the Agricultural Compounds and Veterinary Medicines Group ACVM of the New Zealand Food Safety Authority NZFSA Californian pesticide data sheets state that there is no restriction
134. l was 8 10K however this was for a single injection point with good access and did not include regulatory costs 21 Didymo Gemex DSS User Manual and monitoring You will need to estimate costs based on local conditions and access If helicopter transport or special equipment is required these costs will be higher Regulatory and monitoring costs are highly variable and depend upon the conditions placed upon the Consent for Gemex application or other requirements if a different regulatory pathway is used see Section 7 You should discuss likely regulatory and monitoring requirements with the consents manager of your Regional Council at an early stage in order to estimate these costs The assessment as to whether the cost of Gemex treatment is justifiable is entirely a value judgment It will depend upon the value of the river and surrounding rivers in question A didymo infection of the Tongariro River for example could cost many millions of dollars in lost revenue to the tourism and trout fishing industries and the cost of Gemex treatment has to be measured in that context It should also not be assumed that Gemex treatment is not feasible if the estimated costs are high If for example the infection being considered is the first in the North Island it is in everyone s interest in the North Island anyway that every possible step is taken to eliminate it In such a case you may need to consider alternative regulatory p
135. list box Click the OK button or push ENTER If your name is not displayed as may happen if someone else has done the set up for you 1 Select File Add User 2 Enter the new user name in the User name text box 3 Click the OK button or push ENTER 3 4 Using Didymo Gemex Once you have logged in you will note the sequence to go through the decision making process is displayed on the right hand side of the screen see below When you click on the first block River Network it will be embossed As you complete each module in Didymo Gemex the programme will progress to the following one which will in turn be embossed Didymo Gemex DSS User Manual Didymo GEMEX DAR File View Options Window Help River Network Exit Didymo Gemex uses data from 3 existing databases to assist you make a decision on whether or not to use Gemex These are The NIWA River Environment Classification REC The NIWA Freshwater Fisheries database Fish db The MAFBNZ Didymo Samples database managed by ESR The REC is not expected to change within the next 5 years The Freshwater Fisheries Database will change as new records are added to it however for the purposes of Didymo Gemex such changes will be very minor The Didymo Samples database may change relatively frequently and users especially in the South Island who wish to make use of the Reinfection module should update the database monthly To check on whether you need to update d
136. ll give a more accurate indication of time Where the time available is limited consider whether using the emergency provisions of the various acts would be a more appropriate course of action e Didymo infection may or may not occur but if it does the sooner Gemex is applied the greater the chances of elimination Making provision for Gemex application as a permitted activity within a Regional Plan and or preparing a Resource Consent in advance for rivers most susceptible to didymo infection would ensure that Gemex application could proceed quickly in the event an infection was discovered 7 8 Prepare Resource Consent Application If has been determined that there is sufficient time available to go through the resource consent process and that the preliminary AEE has indicated that the effects of the proposed Gemex discharge can be managed a resource consent application and full assessment of environmental effects will need to be prepared A resource consent is required for any activity that is not specified as a permitted activity in a regional plan or which contravenes a rule in a district plan The resource consent process provides Because Resource consents generally lapse if not taken up within a defined period such consents would need to be renewed at whatever period was specified by the Regional Council 76 Didymo Gemex DSS User Manual the relevant council and others affected by the propo
137. m of the discharge point Any temperature difference will progressively and rapidly reduce to background levels In most cases because there is a thousand fold dilution 2 20 g L dilute to 20 mg L of the Gemex stock solution at the application point the discharge substance will not alter the temperature of the receiving water by more than 3 degrees Celsius To ensure that this is achieved the temperature of the receiving waterway and the solution to be discharged will be measured and the discharge will only occur where the temperature difference is within a range that will ensure that the water temperature in the receiving waterway below the discharge point will not be altered by more than 3 degrees Celsius Turbidity Gemex and the tracer dye contain only dissolved contaminants and the chelating agents keep Cu in solution after discharge The turbidity of the receiving waterway will not be adversely affected as a result of the discharge itself There may some minimal sediment disturbance by people walking on the bed of the waterway as the diffuser pipe is installed however any disturbed sediment will quickly dissipate and will not cause an adverse effect on the waterway Dissolved Oxygen Describe the effects on dissolved oxygen as a result of the discharge Refer to the Didymo Gemex help file for supporting information Gemex will only have very minor effects on DO levels due to any differences between the Do content of the Gemex
138. mex It provides the fundamental information on the characteristics of the river stream under investigation and provides a link to data from the Didymo Incursion database and the Freshwater Fish database 4 1 Selecting the river reach for potential Gemex treatment In order to progress through the decision making procedure you firstly need to locate the upstream and downstream points over which you will apply Gemex The upstream point will usually be 1 2 kilometers upstream of the point where didymo infection has been identified Because didymo cells may be readily washed downstream the downstream point which determines the length of the treatment reach will theoretically be the mouth of the river However there may be good reasons to treat over a shorter reach For example e The river may flow into a lake e The substrate of the river changes downstream to one which would not support didymo upland reach boulders cobbles gt lowland reach of silt e Reduced water clarity at a point downstream will not support didymo or other algae e Saline intrusion upriver mean will not support didymo In practice 2 or 3 of the above conditions may exist in combination from which you can have some certainty that didymo will not grow and hence you can reduce the length of the reach over which Gemex treatment will be required If you don t know whether downstream water quality or substrate will prevent didymo from becoming established seek adv
139. ming birds but there have been no studies to quantify these effects Riparian Plants Riparian plants are not expected to be sensitive because of the limited exposure route to Gemex i e short lived exposure Riparian animals including rare and endangered species Riparian animals are not expected to be sensitive because of the limited exposure route to Gemex i e short lived exposure Earthworks and Vegetation Clearance Assess the effects of any activities such as vegetation clearance and earthworks to create access to application sites In most cases earthworks and vegetation clearance will not be required as existing access tracks will be used However where there will be new tracking activity or significant vegetation clearance to enable access to a treatment site consideration should be given to the effects of sediment runoff erosion discharges to water and impact on flora and fauna Effects on other waterbody users A range of other users of the water body may need to be considered when completing this assessment In particular users that are likely to be consuming or coming into contact with the water during a treatment should be considered The assessment of effects on those users should address the nature of the use the potential impact on those users and how those impacts will be avoided remedied or mitigated It may be necessary particularly where there are sensitive users or large numbers of users to devel
140. ming of water takes seasonal and daily 2 Locations of water takes from backwaters or unconfined aquifers where flushing of contaminants may be slower than the main waterway channel 3 Storage of water Questions and Answers to Assist Stock Water Abstractors to Understand Gemex Effects Question Short Answer Further Information ill water takes have to stop Yes while Gemex is in the water How long will water takes have On the day s of treatment to stop for Does Gemex harm animals Abstraction not allowed See Section 6 5 above Sheep are susceptible to copper poisoning if they drink a lot of water The GTCP requires animals to be excluded from river on day s of treatment ill there be an accumulation This is highly unlikely Firstly of copper in animal tissue abstraction is not allowed See above Secondly Cu is sometimes added as a stock nutrient to stock feed ill Gemex affect the growth This is highly unlikely because the GTCP Section 6 5 6 12 of animals GTCP restricts exposure to stock Abstraction not allowed and it is very unlikely that stock water will exceed MOH MAV of 2 mg L see above ill Gemex react with animal This is highly unlikely because the GTCP Section 6 12 remedies and animal health GTCP restricts exposure to stock products added to drinking Abstraction not allowed and it is water very unlikely that stock water will exceed MOH MAV of 2 mg L see above ill Gemex taint the w
141. mpervious materials resistant to the hazardous substances used stored manufactured mixed packaged loaded unloaded or otherwise handled on the site 2 For liquid hazardous substances a Able to contain the maximum volume of the largest container present plus an allowance for stormwater or fire water and b Where the substances are stored in drums or other small packaging that the spill containment system is able to contain 50 of the maximum volume of substances stored plus an allowance for stormwater or fire water 3 Able to prevent the entry of any spill or other unintentional release of hazardous substances or any contaminated stormwater and or fire water into site drainage systems unless permitted to do so by a network utility operator For the purposes of this rule suitable shall mean compliance with the above include graded floors and surfaces bunding roofing sumps fire water catchments overfill protection and alarms and similar systems The following are exempt from complying with the above standards v Agrichemical use storage transportation and disposal where these activities are carried out in compliance with NZS8409 2004 Management of Agrichemicals k n Any hazardous facility where the total quantity of hazardous substances of any hazard classification on the site is in the range Discretionary Complies Comment Corrosiveness 9 1A Aquatic Ecotoxicity Appendix 2 1 of the Pl
142. n Is it poisonous to birds Copper sulphate is not very Section 6 3 poisonous to birds A similar product to Gemex was tested in California and found not to have low toxicity to 2 species of birds Is it poisonous to native fish It is not poisonous to common Section 6 3 galaxiids Bullies are slightly more susceptible but survival rates should be high Larval fish e g whitebait are likely to be vulnerable so treatment should be avoided when large numbers are present Is it poisonous to eel It is not expected to be poisonous Section 6 3 to eels because eels are relatively insensitive to normal copper Is it poisonous to shellfish When applied for one hour Section 6 3 mussels and koura Gemex is not toxic to snails and koura Snails and mussels are expected to avoid Gemex by closing their shells as the dose passes by Is it poisonous to introduced fishIt can be poisonous to trout and Section 6 3 such as salmon and trout salmon depending on water chemistry Does it affect the bugs that fish Some invertebrates will be killed Section 6 3 feed on However the effect is expected to be similar to the effect of storm flows and natural recovery will occur Does it have a colour It is blue in the stock solution Section 6 2 colourless in application reaches Does it change the colour of the No Section 6 2 water Didymo Gemex DSS User Manual Gemex is quickly adsorbed by Section 6 6 6 9 How long will it stay in t
143. n Southland which was flowing at about 0 25 m s The Princhester Creek flows for a further 8 km before discharging into the Mararoa River 25 m s The Mararoa River is relatively large mean annual flow 25 m s and offers approximately 100 fold dilution of any Gemex remaining in the in water column The estimated sediment yield 158 kt yr is about 22 times greater than in Princhester Creek The Mararoa is a tributary of the Waiau River which provides massive dilution of any CuG in dissolved suspended sediment or bed loads 40 Didymo Gemex DSS User Manual In these hypothetical examples we replace the Mararoa River with a hypothetical lake or estuary The resulting concentrations in the hypothetical lake and estuary sediments from a variant of the NIWA trials are shown in the following Table 6 1 Table 6 1 Estimation of Cu build up in a hypothetical estuary and hypothetical lake at the outlet of Princhester Creek Princhester Creek Value Units Source Treatment Dose Treatment Target 20 g m INIWA Dosing time 3600 sec INIWA INumber of treatments space time 1 Scenario Flow at time of treatment 0 25 Im s INIWA Mass of Cu in all doses 18 kg calculated Natural sediment and Cu loads Total area of stream catchment 38 6 km webmodel Total stream sediment load 6 9 kt yr webmodel Background Cu in stream sediments 12 mg kg Longhurst et al 2004 Natural Cu load 82 8 kg yr calculated CuG diluted into annua
144. nal councils when assessing the effects of a discharge to water e Water quality Comparison of discharge with defined water quality guidelines Rare and endangered species or e Areas of significant natural value species of national importance e Areas being managed in their natural e Non target species state Trout and salmon Human health Cultural values Groundwater implications e Water takes e Relationship to wetlands e Accumulation of copper Treatment methodology Management of spills e Discharges to air spray odour Impacts on other users Measures to mitigate effects e Term of consent Consultation undertaken Implications of other discharges Timing of discharge e Use of tracer dye e Property ownership Mixing zones relevance e Aquatic ecosystems Any exceptional circumstances that e Current ERMA approvals may justify effects e Other resource consents already held Potentially affected people or groups relevant to the use of Gemex Impacts of didymo on the environment versus impacts of Gemex 27 Didymo Gemex DSS User Manual The following sections sets out our understanding of the environmental effects of Gemex at the target concentration It is set out as frequently asked questions FAQs For each section a brief answer to the FAQ is presented in this Help file Links are provided to more in depth explanations and add
145. nes into the cell and copper is incidentally transported in the cell itself where it exerts toxicity intracellularly or during the transport process The copper chelates are thought to be less toxic to fish because e chelate reduces the concentration of bioreactive Cu in the water the chelate compounds are less readily transported by the fish gill membranes More detailed explanation of copper toxicity can be found in the NIWA reports e g Clearwater et al 2007b and many other sources e g USEPA 2007 Meyer et al 2007 6 7 Copper concentrations exceed Water Quality Guidelines Is that a problem Gemex is unquestionably toxic to the target organisms and some non target organisms in a finite zone of effect in the application area and further downstream Concentrations of copper greatly exceed water quality guidelines In addition Gemex M may exceed guidelines for pH in the application zone however this is all part of what is only a short term perturbation The Gemex concentrations recommended for effective treatment far exceed the water quality guidelines for some distance beyond that zone However there are some mitigating circumstances as described in the following Firstly water quality guidelines for copper are very low see Explanation and not much greater than background concentrations ANZECC 2000 guidelines are for copper and not Gemex itself The guidelines are for long term or continuous exposure and not sho
146. ng of the Gemex application will be dictated by the urgency with which it is required A new infestation that requires emergency action will prompt a rapid response in a short timeframe Where Gemex is to be used to manage an existed infestation the timing of the treatment is more likely to be restricted to a period of low flow to enable maximum treatment effectiveness with the minimum amount of Gemex Some river Page 9 Transport and storage of Gemex The Gemex required for the treatment will be transported to the site in sealed containers already mixed at the required concentration for application The containers will hold Enter volume of Gemex each container holds and will be transported to the discharge site s using a enter the method of transport The Gemex solution will be placed on a flat area close to the waterway to be treated and a temporary bund established around the storage area to ensure that any spills are prevented from entering a waterway The temporary bund will either be a proprietary spill bund or a bund constructed using soil from the surrounding area The bund will be designed to contain any spills from the storage containers or the application pump and will be of sufficient size to hold the entire volume of the storage containers The pump to be used to transfer the Gemex solution from the storage vessel to the diffuser apparatus will also be within the bunded area Management of spills To minimis
147. ng water is being managed and any effects of the discharge on that management purpose and any tangata whenua values that may be affected and the volume of water or concentration of contaminants being discharged and the area of receiving water that could potentially be Some river Page 13 Relevant Objectives Relevant Policies affected and the physical hydraulic and hydrological characteristics of the receiving water 5 2 16 To minimise the adverse effects of accidental spills on water quality Complete the above section with any other provisions of other relevant regional plans as appropriate Regional Plan Summary Based on the analysis undertaken above it has been assessed that the proposed activity is to be assessed as d cedet ets activity Issues for Assessment The assessment of plan compliance and the relevant objectives and policies indicates that the following assessment issues are present in relation to this proposal List the key assessment issues that are apparent from the rules and the objectives and policies These will generally be those standards of a permitted activity rule that cannot be complied with and the relevant outcomes intended by the objectives and policies This section should summarise the key issues that will be assessed in the following AEE section e Effect on water quality for water users Effects on trout fishery and spawning e Effects on aquat
148. ngicide for some crops ill there be an accumulation As above Section 6 12 of copper in plants ill Gemex affect the growth As above of plants ill the be an accumulation of No under the GTCP there will be GTCP Gemex in the soil little Cu in the irrigation water Anyway Cu is added as an essential nutrient Also see above ill Gemex react with No see above fertilisers ill Gemex react with No see above pesticide sprays ill Gemex corrode Water take is prevented at the time GTCP Section 6 5 pipework and fittings water could be slightly corrosive ill the dead didymo cause Possibly Dead didymo is still filters to clog more often than if attached after Gemex treatment the didymo dies off naturally and is only removed by stormflows which also occurs with live didymo hat happens to Gemex if it In this unlikely event Gemex is Section 6 6 6 12 is stored for a period of time taken up by live or dead organic e g in a reservoir matter and sediments However abstraction is restricted see above Hydro electricity generators Hydro electricity generators include major generators that either have dams and generators within the river and those that abstract water from a waterway to use for generation in a different location Also included in this category are small local generation systems Issues of Concern to Hydro Electricity Generators 1 Constraints on water use Hydro Electricity Generators Pr
149. nsseess 26 Cultural Values 26 SUMIM ALY Of Du EE M 26 RELEVANT NATIONAL POLICY STATEMENT PROVISIONS 26 Relevant National Coastal Policy Statement Provisions eese eee eese eee eene enses tn nennen tns tn sensn sensn 26 PART WASSESSMEND eccicuniicuuucecct laconic ceeds 27 Section 5 CETT UTS CL 27 Sections 6 7 and 8 ASS SSIIeTIL eere eost ee oaa eter epe eaae epa sa PYe Pee Ve ero ae eene ba reo be ia en ee rae eeu p eV EE a bap ero Po aee ue eY aee ao EU URE ER 27 Summary of Part II Assessment eeeeeeeeeee essent tn sensn sense tn sens tn sinas enses sins ess sensns senses senses sta setas en sensns ens 28 SECTION 104A 104B 104C AND 104D ASSESSMENT e 28 NOTIFICA TION eec 29 MITIGATION MEASURES ieeoeratoi diae pee aya n Ha buda n acu aa Cou usa netics ei Rai pnus Ap E Dna 29 Ius lennnijrm amp iIl e 29 APPENDICES sisii c 30 Some river Page 99 Application Form Form 9 Application for Resource Consent Section 88 Resource Management Act 1991 To Local authority Where resource consents are required from more than one council a joint application may be appropriate This approach should be discussed w
150. nstallation press Create and a new database Didymo mdb will be created in the directory that you select If you subsequently run Didymo Gemex and you receive the message database not found as above you can locate the appropriate directory Alternatively you can create Didymo databases in different directories and select the appropriate directory Options Select database for any stream evaluation After the new database is created you are then given instructions on how to proceed 1 Login as ANONYMOUS 2 Add yourself as user 3 Login as user 4 Start the evaluation process by selecting the river network In response you select ANONYMOUS from the User name drop down box and then click the OK button Didymo Gemex DSS User Manual An anonymous user cannot edit or delete records belonging to other users and database access is restricted Therefore you should add yourself as a user File Add User when logged on as ANONYMOUS and then login File Login under that name 3 3 Normal Login To start Didymo Gemex once it has been run for the first time simply double click the short cut you have created or if you haven t created a short cut go directly to the file e g C Program Files DIDYMO and double click on Didymo exe You will be prompted to enter a user name when the program is started The last user will be displayed as the default If the correct name is not displayed select your user name from the User name drop down
151. nstream to its ultimate receiving water In time the Gemex copper will be indistinguishable from natural copper occurring in similar forms and going through similar processes 37 Didymo Gemex DSS User Manual Dissolved copper is strongly adsorbed onto particulate matter especially organic matter so concentrations of dissolved copper in water will be very low In terms of water quality management the probable ultimate fate of most Gemex sourced copper is incorporation into fine sediments This occurs through settling and flocculation of particulate matter carrying copper and through adsorption of dissolved copper onto sediment particles However low levels of Cu will remain in the receiving water through physical and chemical equilibrium processes While these concentrations are expected to be very low the mass of Cu transported in the dissolved phase can be relatively high a function of flow rate and so can be a significant factor in the fate of Gemex sourced copper Where fine sediments are discharged into energetic receiving waters they are widely dispersed by currents and waves and Gemex signal will be rapidly diluted and indistinguishable from natural levels of copper in sediments However in quiescent waters such as sheltered estuaries or lakes fine sediments can accumulate along with any incorporated copper Slow moving lowland rivers will also accumulate sediment bound copper although on a less permanen
152. nt which requires immediate preventative measures Will this be affected by an adverse effect on the environment that requires immediate remedial measures Will this be affected by any sudden event causing or likely to RMA emergency cause loss of life injury or serious damage to property provisions do not apply Consider using provisions in the Biosecurity Act The cause of the emergency may be removed or the person who has the responsibility for the work project or resources specified above can mitigate the likely adverse effects of the emergency This may result in Gemex being considered as an appropriate course of action 78 Didymo Gemex DSS User Manual The above assessment diagram is an interpretation of section 330 of the Resource Management Act 1991 This section of the Act should be referred to directly if the use of these emergency provisions is being contemplated See http www legislation govt nz for the full text of New Zealand legislation If the emergency provisions are used once the activity has taken place to manage the emergency a resource consent application needs to be made to the relevant consent authority within 20 working days after the activity This is to regularize any non compliances with regional or district plans and to address any adverse effects that may be occurring on the environment after the activity Considerations e Use of the emergency provisions needs to be given careful
153. nt issued under the Resource Management Act 1991 however there may be alternatives Guidance on deciding on the regulatory pathway appropriate to the circumstances is given in Section 7 Didymo Gemex DSS User Manual What regulatory pathways do I need to follow Didymo infection confirmed Locate within river network generate hydrological data and proximity to known didymo incursions What is practicality of using Gemex What are environmental risks of Gemex treatment Document and Proceed with Gemex treatment Figure 1 Flow chart showing sequence of decisions in Didymo Gemex DSS Apply regulatory instrument Didymo Gemex DSS User Manual 3 How do start Didymo Gemex 3 1 Installation System requirements Before you install Didymo Gemex make sure your computer meets the minimum hardware and software requirements Any IBM compatible machine with an 80486 processor or higher A hard disk with a minimum of 50 megabytes available space for installation Windows 98 Windows 2000 and Windows XP it may also work with Windows Vista but it is likely that access to help files may be blocked by security measures see end of 3 4 on how to fix this problem Didymo Gemex will not run properly if your computer does not meet these requirements Didymo Gemex is installed simply by creating a directory such as c Program Files DIDYMO and then copying the files from the Didymo Gemex CD ROM provided
154. ntration of Gemex can be maintained over a longer length In Didymo Gemex we have assumed that the length of reach that can be effectively treated by an injection of Gemex is proportional to the average velocity assuming 2 km of effective treatment with an average velocity of 0 2 m s as in Princhester Creek The estimate of the number of treatment reaches required over the treatment length will be more reliable if an accurate measure of mean stream velocity is used This assumes that the didymo infestation is not well established Didymo is unusual in that large mats i e large quantities of organic matter form in high velocity flows See section 1 2 16 Didymo Gemex DSS User Manual How do I ensure that the best estimate of average stream velocity is used A calibrated RHYHABSIM file will give the most accurate measure of stream velocity and how it changes with flow but may not be available for many locations Where such information is available click the radio button Use instream habitat RHYHABSIM file and then browse your computer or network to input the appropriate file It should be noted that the RHYHABSIM data would only improve the accuracy of the mean velocity measurement which is used to estimate the number of Gemex injection points In most case the estimates based on hydraulic geometry should suffice Where habitat survey information is not available the default values provide a useful estimate f
155. nuisance planktonic and filamentous algal and vascular macrophyte growths but mostly in one major river and one major reservoir Note that Copper herbicides are banned from Washington State possibly because of extensive salmonid fisheries Despite its widespread use documented major copper induced non target kills of fishes and other fauna are rare in Florida This is in part due to movement of motile organisms from treated areas the general practice of not treating entire water bodies and poor monitoring Leslie 1990 Rules of application seem very vague apart from reaching target concentrations in the water column and have not been useful for assessing Gemex application in New Zealand In terms of toxicity and effectiveness the importance of alkalinity is however often emphasized It is not generally recommended to treat water with copper at low hardness or alkalinity because of the risk to fish Also high alkalinity can reduce the copper toxicity to the target organisms plants as well Copper sulfate in waters with high total alkalinity levels will precipitate the copper as copper hydroxides which settles before algae is completely controlled Algae control in waters with high alkalinity levels greater than 250 300 ppm can be improved by use of chelated copper compounds as well Further notes on uses of copper products to treat algal infestations The USEPA lists a number of uses for copper pesticides in waters USEPA 2006
156. o 30 mg kg An average undeveloped soil contains 11 4 mg kg Longhurst et al 2004 Concentrations in uncontaminated rivers are typically lower e g 5 mg kg For the sake of this assessment other copper inputs are assumed to be zero The proportion of copper that is incorporated into receiving water sediments in sheltered muddy estuaries is assumed to be 75 the rest being more widely distributed and dispersed in the environment Williamson et al 1999 The methodology for calculating contaminant build up in estuarine sediments was developed for stormwater discharge into urban estuaries Williamson amp Morrisey 2000 Morrisey et al 2000 While the settling behaviour in muddy largely intertidal estuaries is reasonably well characterized and can be calculated settling in lakes will exhibit different behaviour This is likely to be no settling near shore because of wave action and progressively less settling from source A simple way to take this into account is to use measured sediment deposition rates Thus the proportion of copper that is incorporated into receiving water sediments in lakes is calculated on the basis of sediment settling rate in lake The total catchment fine sediment load depends on the size of the catchment the erodibility of source materials soils and rocks and the rainfall For long term impacts such as the build up of copper in sediments long term average loads are of greatest interest These are estimate
157. o be easily observed The tracer dye will change the colour of the water quite distinctly close to the discharge point As the dye Gemex solution dilutes as it moves downstream the colour change in the water will be less pronounced The effect on the colour of the water from the tracer dye will eventually become imperceptible as dilution and dispersion takes effect and the discharge of the dye ceases The dye is an inert substance and will only be present in the waterway for as long as it takes for dilution to take effect after the discharge has stopped Figure 1 below shows tracer dye being released into a small waterway in a manner similar to how the substance is proposed to be discharged as part of this proposal The short duration of dye presence in the water body and the lack of toxicity to aquatic species means that the use of dye will have no more than minor adverse effects on the environment monitoring schedule Photo Kevin Trainor Southern Technical Services Ltd Source www biosecurity govt nz Temperature It is possible that the temperature of the solution to be discharged will be at a different temperature than the receiving water due to the Gemex being held in a controlled environment This would include both temperature alternatives the receiving waters being warmer than the discharge or being cooler than the discharge 22 Any changes in water temperature are expected to be limited to that area immediately downstrea
158. ocity The volume of Gemex concentrate 30g L required for a one hour treatment of this river reach and its cost 3 The cost of treating the whole length of river selected the number of equidistant injection points and the total cost of chemicals allowing for the downstream flow increases Explanation The cost of Gemex concentrate 30g L quoted by the manufacturer is 3 50 L The cost quoted is simply the number of litres x 3 50 It does not include the cost of transport or application of Gemex Nor does it include the cost of monitoring for regulatory compliance These costs are discussed further in the next section Access Gemex treatment will not be effective unless the target concentration is maintained for l hour along the entire length of river selected Adsorption of Gemex on to organic matter reduces this concentration and determines the river reach length over which it can be applied Didymo Gemex estimates this length using velocity as a surrogate for organic matter and determines the number of injection points required Gaining access to the identified injection points or close by is therefore critical to the effectiveness of the Gemex treatment Didymo Gemex can assist you to determine Gray D and Harding J S 2007 Braided river ecology Department of Conservation Science for Conservation Series No 279 20 Didymo Gemex DSS User Manual road access to the identified injection points
159. ons of that consent If the resource consent isn t approved by the council investigate the Environment Court appeal process or consider alternative regulatory avenues Where the timeframes in which Gemex needs to be applied are urgent the resource consent process is likely to be too time consuming so alternative regulatory approaches should be investigated Begin with examining whether the Resource Management Act 1991 RMA emergency provisions can be used If they can undertake the Gemex treatment and arrange for retrospective resource consent to be obtained An alternative to the RMA emergency provisions are the provisions of the Biosecurity Act 1991 that allow the normal RMA provisions to be circumvented prior to Gemex treatment but retrospective resource consent will need to be obtained A subsequent alternative is to use the Biosecurity Act 1991 emergency provisions where Gemex may be able to be used in accordance with the specific requirements of those provisions The Hazardous Substances and New Organisms Act 1996 HSNO Act provides a further alternative in emergency situations If none of the regulatory alternatives support the use of Gemex M it is likely that the use of Gemex is not able to occur lawfully and it should not be applied 67 Didymo Gemex DSS User Manual Prohibited Prohibited Activity status Complies with Can apply Gemex rule standards Gemex is physically feasible No Conservation
160. onsult according to s36A of the RMA the Applicant has chosen to consult the following parties Consulted Party Views Expressed Response to Consultation issues Describe the adjustments and any changes that have been made to the proposal in response to consultation that has been undertaken Refer here to any specific controls or proposed conditions that are suggested to satisfy the concerns of affected people Assessment of Effects The following assessment of effects addresses the matters that are required to be assessed by the relevant district and regional planning documents and by the RMA Section 104 of the RMA requires the following 1 When considering an application for a resource consent and any submissions received the consent authority must subject to Part 2 have regard to a any actual and potential effects on the environment of allowing the activity and b any relevant provisions of i a national policy statement ii a New Zealand coastal policy statement ii a regional policy statement or proposed regional policy statement iv a plan or proposed plan and c any other matter the consent authority considers relevant and reasonably necessary to determine the application Activity Status The proposed activity has been identified in Section 0 as a as assessed against the rules of the relevant planning documents The Plan has limited control discretion to the following matters Some rive
161. ontaminants in urbanised estuaries Proceedings of the Comprehensive Stormwater and Aquatic Ecosystem Management Conference Auckland February 1999 Vol 1 pp 59 66 93 Appendix 1 Generic AEE for using Gemex in a river to treat didymo Some river Resource Consent Application and Assessment of Environmental Effects June 2008 Perception Planning Ltd 2008 This template has been produced as an Appendix to a Decision Support System on using Gemex to treat rivers infected with didymo It may be used freely for the purposes of applying for a resource consent to use Gemex to treat rivers infected with didymo The use or modification of the template for any other purpose is expressly forbidden without the written approval of Perception Planning Ltd This resource consent application and assessment of environmental effects template has been prepared as a guide only It provides some generic information and headings but should not be regarded as a complete template for every situation Each environment and each regional council will have different requirements and issues This variability cannot be encapsulated in a generic template and should be considered on a case by case basis The assessment of environmental effects should be supported with reports from experts wherever possible This template has been prepared as part of the Didymo Gemex DSS developed on behalf of MAF Biosecurity New Zealand by Diffuse Sources Ltd Perception Pl
162. op a management plan to guide notification of those people and the management of any problems or complaints Refer to the FAQs in the Didymo Gemex DSS help file for information on the effects on particular users e g irrigation stock water etc Natural Hazards Assess any risk to the neighbourhood the community or the environment through natural hazards particularly flooding during or immediately after a discharge This is highly unlikely to be a concern in most cases as Gemex will generally be applied during low flow periods when stable weather is forecast because high flows will render Gemex ineffective Hazardous Substances Describe the effects of Gemex as a hazardous substance In particular areas where food may be gathered such as watercress and fish and human consumption is involved Handling of the chemical and the method of storage transport and application should be discussed in detail with the risks identified and managed It may be appropriate to develop a hazardous substances management plan which details how use storage and transportation of the chemical will take place for each application site including procedures for managing and cleaning up any accidental spills Groundwater Assess whether Gemex will make its way into groundwater and what the potential effects of this might be It may be necessary to seek expert input to assess the potential scale of groundwater contamination and the potential
163. or typical streams However because they are typical streams the hydraulic geometry equations used may underestimate the width of braided rivers or overestimate the width of spring fed or confined rivers Didymo Gemex provides a check on the accuracy of the geometry by comparing the range of calculated stream gradients with the REC stream gradient If the actual reach gradient falls outside the range of possible range of results calculated from the stream geometry the estimate of stream geometry is probably incorrect and should be modified The Calculated range of possible gradients will be highlighted in red if it is outside this range 1 To change the gradient to bring the calculated range within the actual REC gradient simply enter a new estimate of stream width and revised estimates of mean velocity and range of gradients will be displayed Changing stream depth will also change the range of gradients and velocity but changing stream width is generally preferred Local knowledge and common sense should prevail to ensure that the mean width and depth entered are consistent with what is observed Flow variability The LHS panel also has an assessment of flow variability categorized as low medium or high This estimate is based on the ratio of the mean to median flow This information assists in deciding whether Gemex treatment is feasible or desirable in the circumstances 5 2 How do I decide whether use of Gemex is practical
164. or be damaged 2 Contaminants that may cause a product to be rejected or downgraded due to the presence of a contaminant 3 Availability of water Irrigation Practices to Consider 1 Timing of irrigation and therefore water takes seasonal and daily 2 Locations of water takes from backwaters or unconfined aquifers where flushing of contaminants may be slower than the main waterway channel 3 Transfer of water between catchments 4 Storage of water Questions and Answers to Assist Irrigators to Understand Gemex Effects Question Short Answer ill irrigation have to stop Yes while Gemex is in the water How long will irrigation have to On the day s of treatment stop for hat are the risks of Gemex The max treatment dose is 20 contaminating irrigation water mg L while the MOH MAV is2 supplies mg L Abstraction of large proportions of Gemex treated water is operationally difficult Abstraction is restricted on the day s of treatment In the unlikely event of inadvertent Further Information GTCP GTCP Section 6 12 abstraction occurring on the day of application it is highly improbable that there are many situations where Cu is not diluted or removed to concentrations 2 mg L 58 Didymo Gemex DSS User Manual Does Gemex harm crop Abstraction stops at the time of Sections 6 11 6 12 species treatment See above Anyway it is highly unlikely because copper is used as a fu
165. periment 90 Didymo Gemex DSS User Manual 9 References ANZECC 2000 Australian and New Zealand Guidelines for Fresh and Marine Water Quality National Water Quality Management Strategy Australian and New Zealand Environment and Conservation Council Agriculture and Resource Management Councils of Australia and New Zealand Canberra Australia Auckland Regional Council 2004 Blueprint for monitoring urban receiving environments ARC Technical Publication No 168 revised CaDPR 2007 Californian Department of Pesticide Registration Public Report 2007 7 http www cdpr ca gov docs registration ais publicreports 3547 pdf Clearwater S J Jellyman P G 2007 Gemex Treatment Contingency Plan for Didymosphenia geminata Version 3 NIWA Client Report HAM2007 058 for MAF Biosecurity New Zealand Project No MAF07203 79 p Clearwater et al 2007 Treatment of Didymosphenia geminata in the lower Kakanui River using Gemex an Assessment of Environmental Effects Contract Report for MAF Biosecurity New Zealand 2007 pp 93 pp 91 Didymo Gemex DSS User Manual Clearwater S J Jellyman P G Biggs B J F Blair N Clayton J S Hickey C W 2007 Didymosphenia geminata experimental control trials Stage Two Phase Two testing the effectiveness of Gemex a chelated copper formulation NIWA Client Report HAM2006 174 for MAF Biosecurity New Zealand Project No MAF07203 95 p Clearwater S J J
166. plate for preparing a preliminary AEE and this should have already been completed by the time you reach this point in the decision process You may find that some additional information is now available that wasn t at the time the preliminary AEE was completed so the assessment should be revisited Where the preliminary AEE shows that there are likely to be some significant adverse effects from the proposal a decision will need to be made whether to proceed with the resource consent process or to consider an alternative method of enabling the activity using the emergency and other provisions of the RMA and other acts Bear in mind that where the anticipated adverse effects of Gemex will be significantly greater than the potential effects of didymo itself the decision may be made not to proceed with the Gemex treatment option at all Types of effects for this assessment Significant effects that can t be managed These are adverse effects that cannot be avoided remedied or mitigated or that cannot be off set by the overall positive effects of managing didymo 74 Didymo Gemex DSS User Manual Significant effects that can be managed These are adverse effects that are significant but can be managed in a way that avoids remedies or mitigates their impact This can include implementing measures that will resolve the problems caused by Gemex or may include situations where the natural processes will result in the adverse effects
167. ppropriate hydrological parameters flow and velocity used to later estimate the amount of Gemex required to treat the selected reach Map options also allow you to see sites of known didymo incursion in relation to the new infection Practicality Determine whether it is practically feasible to treat the selected reach with Gemex Didymo Gemex assists you decide on risk of reinfection the likely effectiveness of treatment access considerations the volume of Gemex required and the cost of treatment Guidance on deciding whether Gemex treatment is feasible is given in Section 5 Environmental effects If the decision is made that the Gemex treatment is practically feasible the next step is to determine whether the environmental effects of Gemex application are acceptable The elements that need to be considered are similar to those needed for an AEE but at a coarser level The idea here is to identify any critical effects at this preliminary stage and assist in making the decision whether any potential environmental effects outweigh the environmental benefits of controlling didymo Guidance on deciding whether the environmental effects of Gemex treatment are likely to be acceptable is given in Section 6 Regulatory options If from the preceding steps you decide that you wish to continue with Gemex treatment then you will need to have regulatory approval to do so Normally this will mean gaining a Resource Conse
168. r Page 21 The following assessment has been undertaken addressing those matters over which the Council has control discretion or which are required to be assessed by the RMA The assessment focus on the assessment issues that have been identified through the analysis of the relevant plans and policy documents that will guide the consent authority in making its decision on this application Actual and Potential Effects This assessment considers the effects of the proposed activity on the environment To undertake this assessment the proposal must be measured against the existing environment to determine whether there are likely to be any effects on that environment Previous sections of this report have described the existing environment and have specified the baseline against which the effects of the proposal are to be assessed The following assessment considers how the proposed activity will impact on that existing environment Water Quality Where there are specific water quality guidelines specified in a plan or other policy document identify those guidelines and assess how the proposed discharge will compare Colour When discharged Gemex is a colourless liquid that will not alter the colour of the water below the discharge point Only include the following comments if a dye tracer will be used However it is proposed to introduce a tracer dye to the discharge to enable the pattern of chemical distribution within the waterway t
169. relevant 104A Determination of applications for controlled activities After considering an application for a resource consent for a controlled activity a consent authority a must grant the resource consent unless it has insufficient information to determine whether or not the activity is a controlled activity and b may impose conditions on the consent under section 108 for matters over which it has reserved control in its plan or proposed plan 104B Determination of applications for discretionary or non complying activities After considering an application for a resource consent for a discretionary activity or non complying activity a consent authority a may grant or refuse the application and b if it grants the application may impose conditions under section 108 104C Particular restrictions for restricted discretionary activities When considering an application for a resource consent for a restricted discretionary activity a consent authority a must consider only those matters specified in the plan or proposed plan to which it has restricted the exercise of its discretion and b may grant or refuse the application and c if it grants the application may impose conditions under section 108 only for those matters specified in the plan or proposed plan over which it has restricted the exercise of its discretion 104D Particular restrictions for non complying activities 1 Despite any decision made for the purpose of
170. rk information will load Once the map is loaded you can progress sequentially through each of the four modules At the end of each decision module you will be asked to make a decision The information you enter will be stored and can be exported or printed in the Audit Trail Note Didymo Gemex is designed so that there are Exit points at the end of each module see Figure 1 If you decide to exit your decisions for so doing can be saved with the record If you subsequently decide to make further assessment the site being considered can be retrieved using File Select Record To start the process click on River Network Help There is a help button on each main page Clicking the help button will take you to the appropriate page of this manual If you cannot see the help files after clicking the button or you get Didymo Gemex DSS User Manual a message The page cannot be displayed then it is likely that a Windows security update is blocking your access to the help file didymo chm The solution is to run Windows Explorer right click on the CHM file and select Properties from the popup menu Click on the Unblock button immediately below the Advanced button on the General page Click Apply to show the content Once the CHM file has been unblocked the Unblock button disappears You will now be able to access the help files 4 River Network and Location The River Network is the engine room of Didymo Ge
171. rm non target impacts Algae Benthic invertebrates Trout Native Fish Mussels and koura Birds Algae Macro invertebrates Trout Native Fish Other Aquatic Vertebrates Birds 6 4 Is Gemex Toxic to Humans 6 5 Is Gemex toxic to stock 6 6 What is the toxic action of Gemex Why is it more toxic to didymo than fish 6 7 Copper concentrations exceed Water Quality Guidelines Is that a problem 6 8 What is the Long Term Fate of added Gemex 6 9 What is the Intermediate Fate of added Gemex 6 10 Accumulation of Gemex copper in sediments Conclusions on assessing Cu build up in sediments 6 11 Are copper or copper products used elsewhere to treat algal infestations 6 12 Is Gemex a problem for water abstractors 6 13 How and how often will Gemex be applied 6 14 Frequently asked questions on environmental effects of Gemex Maori Anglers and Food Gatherers Recreational users Drinking water abstractors Stock water abstractors Irrigators Hydro electricity generators 6 15 How do I decide whether treating the didymo infected reach will be environmentally acceptable 7 REGULATORY ASSESSMENT 7 1 Introduction Summary of regulatory process 7 2 Preliminary decision Are treatment sites in a Conservation Area or covered by other regulations Conservation Areas Other regulatory provisions 7 3 Confirm ERMA Approvals 7 4 Managed by a Rule in a Regional or District Plan 33 34 35 37 38 39 44 45 46
172. rt term high 35 Didymo Gemex DSS User Manual concentration doses so they are not appropriate to apply in this situation The guidelines are effectively trigger levels where exceedance only denotes potential effects and triggers further investigations These investigations follow a decision tree which takes into account the management aims of the activity and bioavailability of copper In the case of Gemex following this decision tree would establish that Gemex is toxic to didymo and some non target species in the application zone Further downstream total copper may still exceed trigger levels but will be less toxic because of complexation by the chelating agents in Gemex USEPA Guidelines have often been used in NZ for water quality management They include long term typically average concentrations over 4 days and short term guidelines average concentrations over hour the latter appear more relevant to short term dosing The USEPA guidelines have evolved over many years starting with total recoverable copper then moving to dissolved copper then incorporating hardness effects then effects of other water chemistry Water Effects Ratio and the latest development being the use of the Biotic Ligand Model to estimate guidelines EPA 2007 The latest guidelines are not really appropriate for use with Gemex because they do not take into account toxicity through uptake of copper chelates into living cells
173. rvation Units NZ Geodetic Datum 1949 NZ Map Grid Projection 3 Map Layers i DOC Biodiversity i DOC Terrestrial DOC Freshwater DOC Marine DOC Ecology 69 Didymo Gemex DSS User Manual 3 Zoom to the application site on the map 4 Use the Identify tool to find the name of the relevant Conservation Unit if the Gemex application site is within one Other regulatory provisions In some circumstances other regulations or bylaws may have effect over the activities that are proposed These are often specific to particular waterways or activities An example is the Mount Cook National Park Bylaws 1981 which is specifically designed to manage activities within the Mount Cook National Park Section 3 of that bylaw states No person shall o a Willfully or carelessly pollute in any manner the waters of the park or o b Willfully or carelessly spill or cause to be spilled any petrol oil or similar substance in the park Approval may therefore be required form the Minister of Lands to discharge a contaminant into a waterway within the National Park Often bylaws and regulations specific to particular areas or activities will not be well publicised and it will be necessary to ask for advice from the relevant council In most cases councils will include relevant bylaws on their websites but not always National bylaws regulations and orders can be located at www legislation govt nz Loca
174. s i e large quantities of organic matter form in high velocity flows Need to increase the number of injection points and hence volume and cost of Gemex where large mats of didymo have established in high velocity waters The volume and cost of Gemex is related to flow and number of injection points over the treatment reach While this is a valid assumption the user should be aware of the limitations above and that of the flow estimates The volumes and costs are approximations which will be sufficient for the 2 Didymo Gemex DSS User Manual purposes of making a decision but they are not an accurate quotation The impact of Gemex on non target species is While this is a valid assumption the user needs based on current knowledge to be aware that much of the information of non target species has been generated from a single field trial Princhester Creek and a laboratory ecotoxicology experiments 2 Summary of decision pathway A flow chart showing the logic path behind the DSS is shown in Figure 1 The decision pathway that should be followed once a didymo infection is confirmed is as follows 1 Location Determine the location of the new infection on the NZ River Network map Didymo Gemex gives guidance on selecting an appropriate treatment reach downstream of the infection point and provides hydrological information on that reach Guidance is given on how to select a
175. s and occasional lake edges where there is a wave action Thick growths can adversely affect freshwater fish plant and invertebrate species by reducing the number of suitable habitats While it has no human health risk it has potentially significant impacts on the amenity values of waterways and can be a nuisance for recreational users Where did it come from originally Didymo was first detected in New Zealand in the Lower Waiau River in Southland in October 2004 during a routine survey of the river It has since been detected in several South Island rivers but has not yet been discovered in any North Island waterbodies The Ministry of Agriculture and Forestry website contains a chronology of didymo discoveries in New Zealand While the exact means by which didymo arrived in New Zealand is unknown it is considered most likely that it arrived here from overseas on contaminated recreational or industrial equipment How is it spread Didymo is a microscopic organism and a single cell is sufficient to establish a new infestation Because of its size didymo cells can be transported to new waterbodies on any equipment that remains wet It can also be spread by transferring water from an infected waterbody to another waterbody Biosecurity New Zealand promotes a check clean dry programme to encourage people to minimise the chances of didymo being transferred to new waterways However even with significant vigilance didymo readily surviv
176. s of national importance other matters and Treaty of Waitangi respectively Section 6 requires that all persons exercising functions and powers in achieving the purpose of the RMA shall recognise and provide for the matters listed in a to g Of those matters the following are considered relevant to the assessment of this proposal a The preservation of the natural character of the coastal environment including the coastal marine area wetlands and lakes and rivers and their margins and the protection of them from inappropriate subdivision use and development b The protection of outstanding natural features and landscapes from inappropriate subdivision use and development c The protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna d The maintenance and enhancement of public access to and along the coastal marine area lakes and rivers e The relationship of Maori and their culture and traditions with their ancestral lands water sites waahi tapu and other taonga f the protection of historic heritage from inappropriate subdivision use and development g the protection of recognised customary activities Include a summary assessment of each of the relevant points above Explain how these matters have been recognised and provided for in the proposal Section 7 lists the matters that all persons exercising functions and powers under the Act shall have
177. s practically possible C Enter your reasons in the text box below Enter your reasons in the text box below Transport and application 420 Regulatory and monitoring River characteristics Reinfection risk Treatment considerations Gemex volume and cost Overall assessment Decision on cost of Gemex treatment Note the cost of chemicals is calculated by Didymo Gemex but the user has to enter cost estimates for transport and application and regulatory and monitoring requirements 25 Didymo Gemex DSS User Manual Practicality of treatment Overall decision on practicality After considering river characteristics reinfection risk treatment considerations and the volume of GEMEX required My assessment is that Gemex treatment of the selected reach will be C not physically practical do not proceed with further evaluation is marginally practical proceed with environmental assessment C physically practical Enter reasons in the text box below then go to Audit and exit River characteristics Reinfection risk Treatment considerations Gemex volume and cost Overall assessment Overall decision on practical feasibility Note if you click the Not physically practical box when you click the Next button you will go directly to the audit trail without completing the environmental or regulatory modules 26 Didymo Gemex DSS User Manual 6 Environmental Asse
178. sary for drinking water quality Current labels for copper compounds allow for up to 1 ppm of copper in drinking water which is in accordance with the Agency s 1 3 ppm MCLG for residues of copper in drinking water Irrigation Conveyance Systems In the western part of the US 68 of the crops produced rely on irrigated water Thus regular maintenance of distribution canals in important for optimal water flow to receiving fields Dense mats of vegetation can be a mechanical hindrance to valves and gates which divert and control the flow of water Cyanobacteria and filamentous algae can lead to clogging of water intake screens in lakes and aqueducts This reduction in water flow can result in millions of dollars lost due to failed crops as well as up system flooding of areas surrounding the canal Aquatic weed control in irrigation systems is essential since debris from weeds can decrease water flow In addition physical clogging by weeds can cause obstructions to valves and gates needed to control or divert water flow to receiving fields Quiescent Water Bodies Recreational Ornamental Control of aquatic weeds in quiescent water bodies such as ponds and lakes is needed to maintain the safety of recreants and recreational activity operations that include fishing water sports or swimming In addition many of these water bodies are also used as drinking water supplies On rare occasion cyanobacteria are known to produce hepatotoxins that may be
179. seceseesesesesaeensecaeeeaeseneeseeeseeneeeseeas 6 PROJECT DESCRIPTIQN nanc ke bruce cuia cu e aaa cabs sheeeeeccecccsetctepencauesacenteesbssslecean lt tuene 6 PROJ CCUG e 6 locnm 6 Physical chatactertsties E 6 Description of didymo infestation eessseeseseeeeeeeeenene teeth trennen nnne teens tne tetne nne tne nne tenns 6 Property ownership ciiise edebant dere E aei a RAE catiascaneacdehscrescesenesunesdededaso aSK Aaa 7 Nveqninn rao nav varv N E 7 Upstream environment ieena Seren equ Perle P I ER DUBII eye PA RI a RN CES ERIT DER RERER RA I Pap teas Jg Physical characteristics ecrire enr terr P DRE RE E RE SNP UMS ARN GHERI RU ER eSI IE Y Biota presentan EE 1 Other waterway users upstream sess ennt etnt etes innt treten eetetnse tentes serre tres enn nennen nnns 7 IDobstream envVIFODmelll c ere terre Pe prr EE Pr ER ERE E UNS ESERER E a GE MA ses apeupaedusesens EREI E ESENES E RI ERPE 8 Physical Characteristics oe ose toe etaed ineo gu ed E d etm sempe l EPOR SER 8 Biota presentissonacti eost a eaten dme nto ubt ette 8 Other Waterway users ehe ere RERO REED M HERE TE eer p ce serere ESTONA 8 Proposed Activity M 8 iip
180. sed activity time to give it due consideration and to determine whether it will have adverse effects on them or the environment To apply for a resource consent the Resource Management Act 1991 requires that details of the proposal and an assessment of environmental effects AEE are provided The details of the AEE need to reflect the scale of the effects likely from the activity So an activity that is very minor in scale and has little or no adverse effects will only need a small AEE whereas a proposal that is of a significant scale or has the potential to affect a number of aspects of the environment will need a comprehensive AEE The speed at which a resource consent application is assessed is often related to the quality of the application submitted Applications that provide minimal assessment or do not adequately address key issues will tend to be delayed as more information is requested and matters are clarified Wherever possible it is best to provide a sufficiently comprehensive AEE to minimise the possibility of processing delays Included in Appendix 1 of this documentation is a template to assist with the preparation of a resource consent application and AEE for the discharge of Gemex The template provides some generic background information on didymo and Gemex as well as some of the known effects of Gemex M It is intended only as a guide to assist with preparing an application and will require significant input to take into a
181. sensitive to copper 96 h LCso 20 ppb so if a different 29 Didymo Gemex DSS User Manual Gemex dosing regime were used resulting in exposures lasting longer than 8 hours much greater toxicity would be expected Birds Birds are not sensitive to copper and no effects are expected There may be some issues associated with effects of low pH on wading or swimming birds but there have been no studies to quantify these effects In cases where birds are rare or endangered a precautionary approach should be taken such as keeping them out of the water during the 1 h that the main pulse passes Further explanation and notes on short term non target impacts Algae NIWA found significant growth inhibition but lt 46 of a sensitive green alga Pseudokirchneriella subcapitata at a Cu dose of 20 mg L as Gemex for one hour Jellyman et al 2006 p13 Trials at Princhester Creek found negligible long term effects on non target algae Clearwater et al 2007d p44 such as the green alga Ulothrix sp and Phormidium sp and the diatoms Eunotia sp and Gomphoneis sp Rapid recovery is expected A similar response is expected from periphyton biofilms and macrophytes in the treatment area Rooted macrophytes would be expected to recover rapidly as a portion of the plant below the sediment substrate would remain as root stock Jellyman et al 2006a p13 Macro invertebrates NIWA found 60 70 survival of mayflies and stoneflies from singl
182. ses senses sense en seasons 11 Rule Assessment z c tpe edtassetiue iaa apetece ette edd 11 Objectives and Policies dee litera neas NERA EO O ER e hts 12 IXCGDIEIBUE TINI MUT a 14 ISSUES for ASSeSSImEnt uc et eei er Ue p ree bte bo e PED UD e eet 14 DISTRICT PLAN PROVISIONS uon rion niae cene runter a uana n nana gna n inan er rASEESeEeEcn 14 Introductio Eee 15 Relevant District Plan and Status ciesicccccssscesedsseccossisscencssecesensenssseadesunssccnsscesteepereesocearessssensesscedugsoseeseuasseossseoneese 15 Operative and Proposed District Plan Requirements sccsccsscssscscsssssssesssssssssssscessssssesesssssscesssaseesesasees 15 Rule Assessment ete nose tte oe tet dado uud at oe oat ee et 15 Objectives nd Policies o DR re RON GERE GE HERR ENT RV UR NR A TERR 17 District Plan Summary 17 Issues for Assessment 4 eee e te Deve e ti ade b be e cem Easter AE eres e pe deer en s 17 RELEVANT REGIONAL POLICY STATEMENT PROVISIONS 18 sqb pce 18 Relevant Regional Policy Statement and Status Wellington example reser eene eene tn ntnntn 18 Regional Policy Statement Requirements eres e eese eee eee eene stent tn st tn stessa inse tn stas etes ense en sense tn sense tn sensn 18 Issu s for Assessment wie ceo E DORT REOR diem RN ts dem te mpeg 20 CONSU
183. ssment 6 1 Introduction Adding any chemical to a natural waterbody will have an environmental effect It is however the significance of the environmental effects on non target instream species as well as users of the resource which regulatory authorities must take into account when deciding whether to allow the application of the chemical to go ahead In the case of Gemex the maximum in river target concentration is 20 g m3 for a period of one hour This provides a useful boundary condition upon which to assess the significance of environmental effects Didymo Gemex provides information on the fish species downstream of the identified treatment reach from the NIWA Freshwater fisheries database However this is only one of a large number of factors that must be taken into account when deciding whether Gemex treatment will be environmentally acceptable While the object at this stage is to identify any major problems a similar range of issues to that for a full Assessment of Environmental Effects see Section 7 and Appendix 1 needs to be canvassed only in less detail It is important that all affected stakeholders are comfortable with the proposed treatment and therefore the assessment of effects needs to go beyond simply the biophysical effects and include social cultural and economic considerations Matters likely to be considered by regional councils The following matters while not exhaustive are likely to be considered by regio
184. t 8 2 Storage and retrieval When you have finished evaluating a particular river reach you should save the record File Save Infection Record If you forget to do this Didymo Gemex will prompt you to save when you exit Didymo Gemex A Notes window will also appear in which you can record notes relevant to the evaluation The data maps references hydrological data etc and decisions from the evaluation will be saved along with any notes you make You can retrieve an evaluation at any time File Select Infection Record displays a list of all evaluations carried out by the User 87 Didymo Gemex DSS User Manual E Didymo Records D Didymo Didymo mdb Stream Location reference Local name User D Kaihiku Stream 2249541 5442097 Test location ian 08 04 08 4 38 33 p m new records E W aitahuna River 2245137 5447637 ian 09 04 08 8 43 40 a m Clicking on a particular evaluation will open it and you can carry on with or modify the evaluation 8 3 Printing exporting your report The audit report contains all the input data derived values and your decisions on the practical feasibility likely environmental acceptability and likely regulatory pathways You may copy save or print the audit trail report by right clicking anywhere in the window and choosing the appropriate option The first part of a typical audit report is shown below The report contains your name the date of the assessment your purpose in assessin
185. t In hard waters the effects of Gemex are yet untested The high alkalinity will buffer the water so pH is higher and this enhances Cu toxicity but this will probably be offset by the inhibition of Cu toxicity by high concentrations of hardness ions Ca and Mg Native Fish In general Gemex appears to be less toxic to native fish species than juvenile rainbow trout Both migratory and non migratory galaxiid species appear to be relatively resilient to Gemex exposures Upland bullies a non migratory species were intermediate in sensitivity to Gemex compared to juvenile rainbow trout and galaxiids Clearwater et al 2008 Gemex treatment effects are therefore expected to be insignificant on common galaxiid populations On the basis of the known toxicity of copper to adult eels Gemex is expected to pose minimal risk for eel populations Gemex will probably be more toxic to juvenile life stages of all species e g migrating whitebait so an increased impact of a Gemex treatment during spawning or larval recruitment seasons should be accounted for in the assessment of potential environmental effects Clearwater et al 2008 Although Gemex has been tested on 4 native fish species which increases our confidence in the prediction of impacts on other species we cannot predict effects on all species particularly those with physiological adaptations to unusual environments this would potentially include rare an
186. t basis than sheltered estuaries or lakes NIWA have identified the accumulation of copper in sediments of quiescent water bodies lakes and sheltered estuaries as the result of repeated Gemex applications as being of potential concern One off applications are unlikely to have any significant effect 6 9 What is the Intermediate Fate of added Gemex The immediate 1 day fate of the Gemex is adsorption and absorption onto into biota didymo other algae leaves bacteria macrophytes Dead or living algae with elevated levels of Cu or Gemex may cause toxic responses in invertebrate grazers Any toxic response under this circumstance could be viewed as part of the effects of the original perturbation brought about by the application After the applied Gemex is adsorbed or flushed downstream the intermediate fate of Gemex Cu CuG depends mainly on the fate of the plant biomass Initially CuG is transferred downstream in or on dead or sloughed biomass during high flows This organic detritus will undergo complex grazing metabolism excretion decomposition processes as it passes downstream So there will be more Cu in the biotic component of the stream ecosystem This CuG is not readily bioavailable being bound to organic matter Its release from this form depends mainly on bacterial decomposition and grazing by detritus feeders which is a relatively slow process Cu is an essential element and many organisms can regulat
187. tboating kayaking and rafting clubs as well as individuals using the waterway for bathing or water based activities This group includes people or organisations that have physical contact with the water in the waterway Issues of Concern to Recreational Users 1 Effects of human contact with Gemex 2 Access to waterways 3 Usability of waterways Recreational Users Practices to Consider 1 Times of activity seasonal and daily 2 Access points to waterways 3 Movement between catchments and waterways Questions and Answers to assist Recreational Users to Understand Gemex Effects Short Answer Further Information ill Gemex corrode The concentrated stock will corrode metal fittings Section 6 6 fittings and components but once the Gemex is diluted in the river it will only be slightly corrosive for the hour that it is present at high concentrations The public are excluded from the river on the day water could be slightly corrosive ill recreational use have to Yes stop while Gemex is in the water How long will water uses On the day s of treatment have to stop for ill the dead didymo cause a Dead didymo is still attached after treatment and drowning hazard is only removed during subsequent storm flows so risks are probably similar to live didymo Is Gemex toxic to humans Toxicity via drinking is very unlikely because an GTCP Section 6 4 if they drink water that has adult would have to drink 31 L of the treated wa
188. ter been treated with it while river concentrations remained at their highest i e within an hour The GTCP prevents all non official access to rivers being treated The Ministry of Health Maximum Acceptable Value MAV for copper is 2 mg L c f a one hour dose of 20 mg L ill Gemex harm people if See above they come into contact with treated water ill Gemex cause harm to The stock solution is corrosive The public is GTCP Section 6 4 eyes excluded from treated reaches during the treatment day s The day after the treatment the water will not cause harm to eyes ill Gemex harm dogs There may be some harm to dogs drinking the GTCP Section 6 5 swimming in the waterway orwater on the treatment day or swimming near the 6 6 drinking the water application point Restricting public access during application will minimize this risk 54 Didymo Gemex DSS User Manual Drinking water abstractors Drinking water abstractors are individuals and organisations that take water for the purposes of human drinking water This includes municipal water supplies small community water supplies and individual private supplies This category also includes individuals or businesses taking water to use in food processing industries where products are for human consumption e g freezing works breweries fruit vegetable packing houses etc Issues of Concern to Drinking Water Abstractors 1 Contaminants that cause people to become ill or
189. the proposed activity so both should be assessed e Always confirm the assessment of the rules with a member of the Council s Consents Team to ensure that the correct interpretation has been undertaken Some regional councils and district councils have combined to form unitary authorities These authorities administer both regional and district roles from a single organisation and may also combine the district and regional planning components into a single plan 7 6 Undertake Preliminary AEE Now that it is confirmed that resource consent is required for the proposed Gemex treatment consideration needs to be given to the likelihood of the success of the consent application If the consent application is unlikely to be successful spending significant time and money preparing an application and comprehensive assessment of effects is probably not justified Undertaking a preliminary assessment of environmental effects allows for consideration of the likelihood of the success of a resource consent application and ultimately the likely impacts of the proposed activity on the environment The preliminary AEE identifies whether there are any show stoppers impacts that are likely to be so significant that they will cause the proposal to be abandoned It does not take the place of a comprehensive AEE that will need to be completed as part of any resource consent application The Environmental Assessment section of this document includes a tem
190. the assessment of this application Relevant Objectives Relevant Policies 15 3 1 Objective Haz1 Adverse Effects of 15 3 2 Hazl1 Policy Hazardous Substances a Establish thresholds of acceptable risks To protect the natural and physical from the use storage transportation and environment including community safety disposal of hazardous substances on the and health from the adverse effects of health and safety of people and the hazardous substances environment b Establish controls to ensure that potentially hazardous facilities are located designed constructed and managed to avoid remedy or mitigate adverse effects from hazardous substances including unacceptable risks to the environment and or human health c Promote better understanding of the potential adverse effects of hazardous substances and the methods and controls for avoiding remedying or mitigating such effects District Plan Summary Based on the analysis undertaken above it has been determined that the proposed activity is to be assessed AS a activity Issues for Assessment The assessment of District Plan compliance and the relevant objectives and policies indicates that the following assessment issues are present in relation to this proposal List the key assessment issues that are apparent from the rules and the objectives and policies These will generally be those standards of a permitted activity rule that cannot be complied wit
191. tion approximate area cover and location within waterway Where didymo has not yet been discovered describe the reaches of the waterbody that are considered most likely to be infested based on physical characteristics or vector presence Property ownership Please provide the details name address and phone number of all property owners occupiers at the point of and downstream from the Gemex discharge where physical access for treatment or monitoring will be required Surrounding Environment Generally describe the nature of the catchment topography sensitivity of the receiving environment and surrounding landuses Include the proximity of people local iwi parks natural areas and other waterbodies The information provided in this section contributes to establishing the existing environment so that the effects on that environment of the proposed discharge can be assessed Without an accurate description of the state of the receiving environment the scale and intensity of any adverse effects cannot be determined Upstream environment Physical characteristics Describe the current nature of the waterway upstream of the discharge point including dimensions volume flow rate water colour clarity bed and bank material This information can be obtained from the Gemex DSS software or from the Regional Council Where the discharge point is not certain there may be an area above which treatment is unlikely to be feas
192. to be adversely affected by didymo Potentially high financial costs to water users through screen fouling loss of production etc Does not control didymo already within the waterway Existing species likely to be adversely affected by didymo Potentially high financial costs to water users through screen fouling loss of production etc Does not prevent spread of didymo downstream Policing and enforcement likely to be difficult to prevent all activities Use a treatment agent to kill Likely to minimise the May be a high or manage didymo further spread of financial cost of didymo treatment Prevents didymo from Treatment agent adversely affecting may have adverse other stream biota effects on biota Protects water users Effectiveness may from effects of be limited by didymo physical characteristics of the waterbody or by the nature of reinfestation TM Gemex What is Gemex Gemex is a copper based biocide specifically designed to treat didymo while minimizing impacts on non target species It is a mixture of copper sulphate which is also a common garden fungicide with relatively simple organic molecules which act as chelating agents Clearwater et al 2007b ERMA 2007 Copper and copper chelates have been commonly applied to treat waterways for aquatic weeds especially in Florida They are also commonly used as a treatment for fish diseases and to remove algae in aquaria T
193. to clog more often than if Gemex treatment and is only removed by the didymo dies off naturally stormflows which also occurs with live didymo hat happens to Gemex if it In this unlikely event Gemex is taken up by Section 6 6 6 12 is stored for a period of time live or dead organic matter and sediments e g in a reservoir or tank However abstraction is restricted see above hat happens if stock eat Sheep are susceptible to copper poisoning and Section 6 5 didymo that has been killed by must be kept out of riverbanks if didymo is Gemex deposited there by stormflows Other stock should also be kept away from riverbanks ill Gemex affect fresh Abstraction is restricted on treatment days products that are washed in Inadvertent traces of Gemex will not taint food as long as the MoH MAV of 2 mg L is not exceeded Stock water abstractors Stock water abstractors are individuals and organisations that take water for the purposes of animal drinking water This includes pastoral farmers and businesses holding or rearing stock in enclosures or buildings e g horse stables poultry farms etc Issues of Concern to Stock Water Abstractors 1 Contaminants that cause animals to become ill or die 56 Didymo Gemex DSS User Manual 2 Contaminants that may cause animals to be rejected or downgraded due to the presence of a contaminant 3 Availability of water Stock Water Abstraction Practices to Consider 1 Ti
194. to limit the actual or likely adverse effects of the emergency or iv protect the health and safety of people chattels or the environment from the actual or likely adverse effects of any emergency the enforcement officer may declare a hazardous substance or new organisms emergency This and other provisions of this Act give specific but reasonably wide ranging powers to address an incursion of an unwanted organism Considerations The intention appears to be that where the emergency is already being managed by the provisions of the Biosecurity Act or another of the listed acts the HSNO Act emergency provisions do not apply e Careful consideration will need to be given to whether the appearance of didymo in a waterbody would meet the definition of an emergency Will it cause a danger to the environment so significant that immediate action is required to remove the emergency 7 13 Gemex Cannot be Applied This last box in the Figure 2 flow chart is arrived at when all of the regulatory options for using Gemex have been exhausted Reaching this point despite the use of Gemex being considered to be feasible and to have manageable impacts on the environment indicates that there are some wider issues that mean that Gemex cannot be applied Please note that the decision support tool only provides a suggested process for decision making and that the ultimate decision is left to the user Any decisions made should be documented
195. trolled discretionary discretionary restricted or non complying activity resource consent will be required Check that the activity meets the relevant performance standards for the particular rules in the plan it may be listed as a controlled activity but not meet the relevant standards and therefore needs to be considered against other more stringent activity status rules If the activity is a prohibited activity no resource consent can be granted and you should then consider whether one of the alternative regulatory pathways is available 66 Didymo Gemex DSS User Manual Once the activity status of the proposal is known a preliminary assessment of environmental effects AEE should be completed to determine whether there are any show stopper effects that will prevent resource consent being approved To assist in completing the preliminary AEE consultation should have been undertaken with key stakeholders and people potentially affected by the proposal If the effects are likely to be more than minor resource consent probably won t be approved and the alternative regulatory provisions should be explored Where the effects are considered to be no more than minor proceed to deciding whether there is sufficient time available for the resource consent process If there is sufficient time available to follow the resource consent process prepare a resource consent application and if granted apply Gemex according to the conditi
196. ts of Gemex to non target species The main assumptions and limitations are given in the table below Assumptions Limitations The decision making framework relates only to a l h application of Gemex to a river at a maximum in river concentration of 20 mg L The decision criteria will not apply for longer applications e g days to weeks Stream velocity is used as a surrogate measure of organic matter see Section 5 1 which absorbs Gemex and therefore reduces the treatment length over which a single injection of Gemex will be effective In general high velocity waters retain little organic matter whereas at low velocity there is deposition of organic matter Whilst this assumption is reasonable for most rivers there are exceptions and limitations These are 1 Under stable flow regimes periphyton can accumulate at quite high velocities 2 Using velocity as a surrogate results in a high upper limit for downstream effective distance of Gemex 3 Some waters may contain atypical amounts of organic matter unrelated to velocity e g streams draining a peat swamp In such cases the user should utilize their local knowledge use the information generated by the DSS on treatment length circumspectly and seek professional advice if necessary The stream velocity organic matter relationship also assumes that large mats of didymo have not yet established Didymo is unusual in that large mat
197. ty indicates that there is a high likelihood of a flood event in the near future that could a scour the bed and flush didymo growths out of the affected reach or b coincide or be near with the time of treatment Conversely low flow variability indicates high bed stability and little likelihood of a flood event in the near future that could affect didymo growths or interfere with Gemex application You should consider the following in deciding whether the flow characteristics favour Gemex application 1 Is my objective to a simply control nuisance growths of didymo or b to eliminate if possible didymo from this reach of river If you simply wish to control nuisance growths consider the flow variability If it is high then there is a high likelihood of nature doing the job for you If it is low then Gemex application is your only realistic option A low flow variability also indicates that you can plan the Gemex treatment with more confidence that flow at the time of treatment will be as predicted If the river has medium flow variability then more analysis of the flow record may be justified in order to determine for example whether there is a strong seasonal bias in flood events that might influence your decision If your objective is elimination then Gemex is the only option However Gemex application during a period of low stable flow immediately followed by a flood event is likely to increase the chances that
198. ua surface water bodies in the Region for aquatic ecosystem purposes subject to Policy 5 2 10 5 2 7 To manage all groundwater in the Wellington Region so that there are no net adverse affects on its quality as a result of discharges to surface water or groundwater subject to Policy 5 2 10 5 2 8 To have regard to the relevant guidelines in Appendix 8 when deciding whether a discharge is able to satisfy Policies 5 2 1 to 5 2 7 above when considering applications for resource consents subject to Policy 5 2 10 5 2 10 To allow the discharge of contaminants to fresh water which do not satisfy Policies 5 2 1 to 5 2 9 whichever is are relevant only where 1 the discharge is of a temporary nature or 2 the discharge is associated with necessary maintenance works or 3 exceptional circumstances justifying the granting of a permit or 4 the discharge was present at the time the Plan was notified and is not likely to cause a decrease in the existing quality of water at that site and the person responsible for the discharge has defined a programme of work for upgrading the discharge within a specified timeframe or 5 that in any event it is consistent with the purpose of the Act to allow the discharge 5 2 11 To ensure that any zones allowed on a discharge permit for reasonable mixing of contaminants or water with the receiving water are determined by having regard to the purpose for which the receivi
199. ual E Regulatory Process Comments Is the selected reach within a conservation area Does GEMEX have Current ERMA approval Are there any relevant bylaws or non RMA regulations Yes T Is the use of GEMEX covered by a Regional Plan rule e In the Regional Plan is the activity Ent t Fanon ts bel Permitted This is a a nter comments on Regional Plan requirements below A discretionary activity if not covered by a Discretionary restricted Regional Plan rule Discretionary Non complying Prohibited a Yes No In the District Plan is the activity Is the use of GEMEX covered by a District Plan rule C e Permitted C This is a permitted Enter comments on District Plan requirements below Controlled 7 activity if not covered by a District Plan rule Discretionary restricted C Discretionary C Non complying C Prohibited C Cancel Back Next Plan considerations Overall decision 84 Didymo Gemex DSS User Manual E Regulatory Process SE 85 Didymo Gemex DSS User Manual 86 Didymo Gemex DSS User Manual 8 Audit Trail 8 1 Introduction The purpose of the audit trail is to provide 1 A means of storing the input data which may be later restored for review and 2 A simple means of compiling a report on your decision whether Gemex is a suitable treatment Didymo Gemex also provides a number of mapping options that can be used to enhance your repor
200. ually be an effective remedial or preventative measure If it is not likely to be effective in being remedial or preventative then the discharge of it under the emergency provisions may not be justified Any decision to use the emergency provisions should be comprehensively documented 7 10 Biosecurity Act exemption from RMA Provisions Where the emergency provisions of the Resource Management Act 199 are not considered relevant or are not able to be applied the provisions of the Biosecurity Act 1993 may apply The Biosecurity Act 1993 includes a provision Section 7A that enables the responsible Minister to waive the requirements of the Resource Management Act where steps are to be taken under Part 6 of the Biosecurity Act in an attempt to eradicate an organism The power of exemption can only be exercised in specific circumstances The exemption has a duration of up to 20 working days and may after that period be extended by making regulations for that purpose see the Act for more details 79 Didymo Gemex DSS User Manual The decision to utilise the RMA exemption provisions is a decision that needs to be made by the Minister responsible for managing the didymo eradication effort In most cases this will be the Minister of Biosecurity but may also include the Minister of Conservation Comprehensive discussions should be undertaken with the relevant Minister s advisors as part of this process In making a decision as to whether
201. uidance is given in Section 7 12 on who and how to consult for the regulatory process The same list of parties should be involved at this preliminary stage but clearly the amount of consultation required will be less Consulting with stakeholder representatives is probably all that is required at this stage though you may wish to hold a public meeting close to the proposed treatment point to ensure stakeholders in the 61 Didymo Gemex DSS User Manual immediate locality have an opportunity to be informed and understand the situation The idea is to decide whether there are any other social cultural or economic or human health show stoppers can be identified at this stage that mean obtaining regulatory approval for Gemex treatment is unlikely You should make use of the FAQs for stakeholder groups 6 14 Frequently asked questions on environmental effects of Gemex to assist stakeholders understand the effects of Gemex on their river and water uses and to identify effects that can and cannot be managed 10 Considering the outcomes from 1 10 above complete the preliminary Assessment of Environmental Effects on the effects of Gemex treatment in the following matrix An example of a completed assessment for the Tiraumea River is given below complete with the reasoning and reference to sources of information Example preliminary Assessment of Environmental Effects for the Tiraumea River Type of Effect Biophysical
202. uration we can assume that most didymo cells in the river will come into contact with Gemex at the target concentration However for braided and or spring fed rivers these conditions may not be met In a braided river multiple mobile channels flow across and within a gravel floodplain The lateral and vertical limits of the river include the entire width of the floodplain and the saturated depths of the alluvial aquifer within and across which the river moves as a single body of water In such a braided river system we cannot assume that all didymo cells present will come into contact with Gemex at the target concentration although there is some evidence this may be achievable Even single channel can have significant groundwater input which if not recognized could dilute Gemex to below target concentrations Flow gauging above and below the suspect reach may be necessary to confirm if this is the case and make allowance in terms of initial dose Monitoring of actual Gemex concentrations at multiple locations on the waterway during treatment is essential to detect such influences on efficacy The cost of Gemex Once you are happy that the hydrologic and hydraulic geometry estimates are the best possible in the circumstances Didymo Gemex calculates the volume of Gemex required and the cost of chemicals The information displayed is as follows 1 The length of river reach over which Gemex will be effective based on mean vel
203. vailable toxicity data across a wide range of hardness Such regressions provided the relative amount by which the criteria change with hardness but have certain limitations The regressions incorporated any other factor that was correlated with hardness in the toxicity data set used for the regressions particularly pH and alkalinity Existing EPA metals criteria also address bioavailability by using dissolved metal as a better approximation for metal bioavailability than total metal U S EPA 1993 This approach accounts for the low bioavailability of metal on suspended matter To address more completely the modifying effects of water quality than the hardness regressions achieve EPA issued guidance in the early 1980s on the water effect ratio WER method The WER is a biological method to compare bioavailability and toxicity in receiving waters versus laboratory test waters A WER is calculated by dividing the acute LC50 of the metal determined in water collected from the receiving water of interest by the LC50 of the metal determined in a standard laboratory water sample after adjusting both test waters to the same hardness However a WER accounts only for interactions of water quality parameters and their effects on metal toxicity to the species tested and in the water sample collected at a specific location and at a specific time There is also significant cost to generate a single WER A new approach by USEPA 2007 uses a bioavailabil
204. ve been proposed These measures have been assessed as reducing the adverse effects of the proposal to a level that is no more than minor Proposed Conditions of Consent In order to avoid remedy or mitigate actual or potential adverse effects on the environment the following conditions of consent are proposed You may choose to recommend conditions of consent or you may choose to simply summarise the measures you propose to put in place for the consent authority to prepare conditions on Measures could include prepare and implement management plans for managing hazardous substances river access pre treatment notification etc Some river Page 29 Appendices It may be appropriate to commission specialist reports on particular aspects of the proposal This could include reports on waterway ecology treatment methodology etc It would also be appropriate to include background details on Gemex and didymo 30
205. ver two weeks 5 which could have been related to repeat applications of Gemex Caged common galaxiids in the Princhester Creek field trials Clearwater et al 2007d were not affected by the Gemex treatment although a few dead resident wild galaxiids were found in the treated reach Population data from electric fishing surveys showed minimal effect on the native galaxiid population The common bully was tested in artificial streams only at 4 mg L Cu as Gemex for 1 hour and showed no sensitivity at this concentration Jellyman et al 2006 In subsequent laboratory trials the dwarf galaxias showed similar resilience to Gemex exposures as the galaxiid species in Princhester Creek Upland bullies were intermediate in sensitivity to juvenile trout and the galaxiids Clearwater et al 2008 Both longfin and shortfin eels are not expected to be affected based on the relative sensitivity of juveniles to copper sulphate Jellyman et al 2006a p 16 Other Aquatic Vertebrates NIWA regard molluscs as potentially vulnerable Clearwater 2007d p89 Lamprey juveniles which spend 4 5 years in silty burrows on stream margins and backwaters may be sensitive 1f present in the application area Jellyman et al 2006a p 17 Dosing may need to avoid spring periods when adult lampreys migrate Birds The ERMA application 2007 describes birds as relatively insensitive to Gemex M The lowest lethal dose for copper sulphate in ducks is 600 mg
206. x it may be decided that use of Gemex is not justifiable Where initially significant adverse effects can be avoided remedied or mitigated there is a high chance of resource consent being granted e Where most or all of the effects are considered to be no more than minor resource consent is likely to be granted 7 7 Assess Timeframes This step in the regulatory assessment process assists with determining whether there is sufficient time available to follow the required resource consent process The Resource Management Act 1991 requires that proposals are notified where the effects are likely to be more than minor or where particular people are considered to be affected The public notification process will due to having to provide people with an opportunity to contribute to the assessment process take significantly longer to complete than if the application is processed without notification non notified At this stage in the regulatory assessment process it will be useful to consider whether the time available before treatment of didymo is required will be sufficient to allow the resource consent to be assessed and hopefully granted If there is insufficient time available to complete the resource consent process the use of Gemex may need to be fast tracked through one of the alternative regulatory options emergency provisions under 75 Didymo Gemex DSS User Manual the Resource Management Act or Biosecurity Act
207. xplanations and notes for effects on humans The stock solution is harmful if ingested ERMA 2007 clause 4 10 NIWA estimated the hazard classification of Gemex based on data on copper sulphate anhydrous This reference substance is regarded to be more toxic than Gemex ERMA has not undertaken a full hazard classification of the substance but based on the concentration of the chelated copper present within Gemex concentrate and the pH of the formulated product considers the concentrated substance to trigger the following classifications ERMA 2007 clause 4 24 8 3A Eye Corrosiveness e 8 2C Skin Corrosiveness e 9 1A Aquatic Ecotoxicity The Agency considers that adverse health effects may occur as a result of the corrosive properties of Gemex concentrate NIWA has identified that adverse effects to the human health and welfare may arise from the concentrated product or while diluted in river water Overseas pesticide data sheets state that there is no restriction on the use of similar type of herbicides i e other or similar copper chelates in respect to potable water or swimming e g CADPR 2007 The Ministry of Health MoH commented on the Maximum Acceptable Value MAV of compounds present in the water downstream of the treatment site MoH suggests that no applications be made upstream of water supply intakes unless 1 owners of water supply intakes are advised when and for how long copper exceeding 2 mg L wil

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