NZ Bkpg Bee Diseases Organisation Information Contacts

 Advanced

Ministry of Agriculture and Forestry
Operational Plans for the Varroa destructor response

Summary of Submissions

Introduction

1. The decision-making process for response options

On 11 April 2000, varroa was diagnosed in a hobby beekeeper's hives in South Auckland. MAF initiated an exotic disease response, with the following primary objectives:

On 15 April 2000, the Controlled Area Notice came into force establishing movement controls for risk goods (including bees, hives and beekeeping equipment) in the infected area (as it was then known) and for movements from North to South Islands. On the 28 April 2000, the movement controls were revised to take in the entire upper North Island, to account for the delimiting survey findings.

MAF, AgriQuality New Zealand Ltd and beekeepers co-operated to undertake the delimiting survey. The survey was largely completed by 5 June 2000, but some testing continued subsequently in response to requests for movement permits. Approximately $2 million was spent on the delimiting survey. As of 20 July, the results were as follows:

MAF established 3 advisory groups to consider the technical, economic and regulatory issues related to the response options.

The Technical Advisory Group comprised National Beekeepers' Association (NBA) representatives, scientists from Crown research institutes (HortResearch, AgResearch and the Institute of Environmental Science and Research), consultant apiculturalists, horticultural industry representatives, and officials from MAF, AgriQuality, the Department of Conservation, the Ministry of Research Science and Technology, the Ministry of Health, and Treasury. Their primary role was to consider the technical feasibility of attempting eradication, for which they specifically considered the Draft Operational Plan for Eradication of Varroa that MAF had contracted AgriQuality to develop. The group met on three occasions, and was chaired by Dr John Hay, Chief Executive of the Institute of Environmental Science and Research.

The Economic Advisory Group comprised NBA representatives, horticultural industry representatives, Federated Farmers, and officials from MAF and Treasury. Their primary role was to assess the potential economic impacts to beekeeping, horticulture, and the pastoral and arable productive sectors from varroa, assuming beekeeper-only management. A series of assumptions was developed and refined after wide consultation, and an economic model developed. The group met on four occasions.

The Depopulation Advisory Group comprised a HortResearch scientist, representatives from the Regional Councils, and officials from MAF, the Department of Conservation and Ministry of Health. The primary role of the group was to consider regulatory issues arising from a trial examining means to depopulate feral and managed bee colonies. The group met on one occasion.

As a result of the collective efforts of these groups, MAF advised Cabinet that:

On 12 July 2000, Cabinet decided not to pursue eradication of varroa. We instructed MAF to work with the beekeeping industry to develop the three-phase management programme, and approved $1.3 million for the immediate programme. Cabinet also made a commitment in principle to fund the two-year interim programme, the details of which will be finalised after MAF completes consultation with the beekeeping industry.

2. Initial consultation draft

A consultation draft of the Operational Plan for the Eradication of Varroa and the Operational Plan for the Control of Varroa was notified in press releases during June 2000. Submissions were accepted up until the point of Government finalising the decision of the response.

The Ministry of Agriculture and Forestry received eighty submissions in total. 51 of these were form submissions in favour of eradication (please see appendix 1).

MAF received submissions from the following:

1. Pamela Adam, teacher of Wainuiomata. 7 July 2000. Form letter as in Appendix 1.

2. Gerard Martin, commercial apiarist, Murupara. 6 July 2000. Form letter as in Appendix 1.

3. Nola Lafferty, student of apiculture, Howick. 5 July 2000. Form letter as in Appendix 1.

4. Fay and Joe Gock, commercial growers, Auckland. 3 July 2000. Form letter as in Appendix 1.

5. N F Harris, beekeeper of Oamaru. 30 June 2000. Form letter as in Appendix 1.

6. Henry Aarts, beekeeper of Kurow. 28 June 2000. Form letter as in Appendix 1.

7. Richard Aarts, beekeeper of Kurow. 28 June 2000. Form letter as in Appendix 1.

8. Adamson's Apiary Ltd, Alexandra. 28 June 2000. Fax of one page from Earnest Adamson, in favour of eradication.

9. Bee Inn Apiaries. 28 June 2000. Form letter as in Appendix 1.

10. James Black, beekeeper of Feilding. 28 June 2000. Email of form letter as in Appendix 1.

11. Franklin Beekeepers' Club. 28 June 2000. Email of 1 page from Robert Russell (President). In favour of eradication.

12. John and Cushla Gavin, beekeepers of Whangarei. 28 June 2000. Email of form letter as in Appendix 1.

13. I Gheller, hobby beekeeper of Oamaru. 28 June 2000. Form letter as in Appendix 1.

14. Peter Goldsbury, beekeeper of Auckland. 28 June 2000. Email of 2 pages, summarised on page 14.

15. EEO Lawrence, beekeeper of Oamaru. 28 June 2000. Form letter as in Appendix 1.

16. Wolfgang Faber and Gisela Ludtke-Faber, Gore. 28 June 2000. Fax of 2 pages, in favour of eradication.

17. Robert Mann, consultant ecologist, Auckland. 28 June 2000. Email of 2 pages, summarised on page 10.

18. Johnathan Marshall, commercial beekeeper of Taranaki. 28 June 2000. Email of form letter as in Appendix 1.

19. Graham McCallum, beekeeper of Oamaru. 28 June 2000. Form letter as in Appendix 1.

20. R M McCallum, apiarist of Oamaru. 28 June 2000. Form letter as in Appendix 1.

21. Bruce I McGregor, corrections officer of Auckland. 28 June 2000. Email of form letter as in Appendix 1.

22. National Beekeepers' Association of NZ (Inc) Northland Branch. 28 June 2000. Email from Don Hoole (Chairman), Simon Peacey (Secretary), John Gavin, Dave Herbert, Arthur Tucker, Jim Sharp, Brendan Nichols (Committee members) and Terry Gavin, Edna Hoole, Cushla Gavin, Sarah Peacey, George Nichols, Pamela Nichols, 3 pages. Submission summarised on page 17.

23. MJ Parish, beekeeper of Kurow. 28 June 2000. Form letter as in Appendix 1.

24. Dennis B Pease, retired, of Auckland. 28 June 2000. Email of form letter as in Appendix 1.

25. Robert B Rawson, beekeeper of Oamaru. 28 June 2000. Form letter as in Appendix 1.

26. Robert Russell, commercial beekeeper of Drury. 28 June 2000. Email of form letter as in Appendix 1, including cover page.

27. Chrissie Tuffnell of Taumaranui. 28 June 2000. Email of form letter as in Appendix 1.

28. David and Maree Walker, farm manager and beekeeper of Oamaru. 28 June 2000. Form letter as in Appendix 1.

29. Nick Wallingford of Tauranga, Gerrit and Ineke Hyink of Katikati, Bruce Stanley of Whakatane. 28 June 2000. Email of 3 pages, summarised on page 33.

30. Paul West, Cambridge. 28 June 2000. Email of 3 pages, summarised on page 39.

31. Robert B Willis, retired/hobby farmer of North Otago. 28 June 2000. Form letter as in Appendix 1.

32. Murray Addison, company director of Auckland. 27 June 2000. Form letter as in Appendix 1.

33. Airborne Honey Ltd, Central Canterbury. 27 June 2000. Emailed submission of 15 pages including cover sheet, summarised on page 23.

34. Vicky Alexander, history researcher of Wainuiomata. 27 June 2000. Fax of form letter as in Appendix 1.

35. LA and L Bulmer, sales representative of Hawera. 27 June 2000. Email of form letter as in Appendix 1.

36. Grahame and Diane Colson, beekeepers of Papakura. 27 June 2000. Email of form letter as in Appendix 1.

37. Mike Fryer and Jenny Colson, horticulturist, medical assistant and beekeepers of Papakura. Email of form letter as in Appendix 1.

38. Alec and Meryle colson, retired beekeepers of Papakura. 27 June 2000. Email of form letter as in Appendix 1.

39. Bryan Cresswell, Beekeeper of Feilding. 27 June 2000. Form letter as in Appendix 1.

40. Beat Honegger, beekeeper of Auckland. 27 June 2000. Fax of form letter as in Appendix 1.

41. Frank Lindsay, Wellington. 27 June 2000. Email of 2 pages, summarised on page 35.

42. Maureen Maxwell, beekeeper of Auckland. 27 June 2000. Email of form letter as in Appendix 1 and cover page.

43. Allan Milmine, beekeeper of Oamaru. 27 June 2000. Form letter as in Appendix 1.

44. National Beekeepers' Association of NZ (Inc) Hawkes Bay Branch. 27 June 2000. Email of 3 pages, summarised on page 36.

45. W Postlewaight, retired, of Waitakere. 27 June 2000. Email of form letter as in Appendix 1.

46. Allan W Rawson, beekeeper of Oamaru. 26 June 2000. Form letter as in Appendix 1.

47. Richard Robins, beekeeper/partner at Beeline Apiaries Ltd of Auckland. 27 June 2000. Email of form letter as in Appendix 1 and cover page.

48. Sensational Bee Products. 27 June 2000. Email of 1 page from Rob Coers and Carol Daley (Directors), summarised on page 21.

49. Robert van Ruyssevelt, courier of Auckland. 27 June 2000. Email of form letter as in Appendix 1 and cover page.

50. James Ward, Kintail Honey. 27 June 2000. Email of 2 pages, in support of the Coordinated Control plan.

51. Owen Watson, programmer and part-time beekeeper of Wellington. 27 June 2000. Email of form letter as in Appendix 1.

52. Raewyn Blair, beekeeper of Canterbury. 26 June 2000. Email of 1 page, in favour of eradication.

53. Browning Campbell, beekeeper of Drury. 26 June 2000. Fax of form letter as in Appendix 1.

54. Norman and Mary Dean, beekeepers of Tauranga. 26 June 2000. Email of 4 pages, summarised on page 13.

55. Brigid Ford, student of Waimauku. 26 June 2000. Email of form letter as in Appendix 1.

56. Comvita NZ Ltd. 26 June 2000. Fax from WJ Bracks, Board Chairman, 6 pages summarised on page 29.

57. Robert and Janey Johnston, beekeepers of South Auckland. 26 June 2000. Fax of form letter as in Appendix 1.

58. LT Jones, beekeeper of Massey, Auckland. 26 June 2000. Form letter as in Appendix 1.

59. Michael Lory, self employed, of Oamaru. 26 June 2000. Form letter as in Appendix 1.

60. I and M Lory, apiarists of Oamaru. 26 June 2000. Form letter as in Appendix 1.

61. National Beekeepers Association of NZ (Inc) Southland Branch. 26 June 2000. Fax from D Steadman, Secretary. 1 cover page and 1 page of comments in favour of eradication.

62. Donald Rae, retired, of Waiuku. 26 June 2000. Form letter as in Appendix 1.

63. J.D Slater, beekeeper of Oamaru. 26 June 2000. Form letter as in Appendix 1.

64. Company Bee Honey, Alexandra. 25 June 2000. Email from Michael Vercoe of 7 pages including cover page, summarised on page 22.

65. T L Fortune, beekeeper of Auckland. 25 June 2000. Email of 2 pages, in favour of eradication.

66. Rod Grigg, farmer/beekeeper of Kurow. 25 June 2000. Form letter as in Appendix 1.

67. Ross Abernethy, beekeeper of Manukau. 24 June 2000. Email of form letter as in Appendix 1.

68. Mark Horsnell, beekeeper of Auckland. 24 June 2000. Email of form letter as in Appendix 1.

69. S.M Hurst, beekeeper of Oamaru. 24 June 2000. Form letter as in Appendix 1.

70. Colin Iles, counsellor of Lower Hutt. 24 June 2000. Email of form letter as in Appendix 1.

71. Waikato Honey. 24 June 2000. Email from Bryan Clements of 1 page, in favour of eradication.

72. Happy Valley Honey, Auckland. 23 June 2000. Fax from B and D Rawnsley, P Dixon and S Johns. 1 covering page and 10 pages of comment summarised on page 15.

73. Peter Radcliffe of Plimmerton. 23 June 2000. Letter of 2 pages including cover page, summarised on page 19.

74. William Sell, civil servant and hobbyist beekeeper of Dunedin. 23 June 2000. Email of 1 page, in favour of eradication.

75. Barry Donovan, Donovan Scientific Insect Research, Lincoln. 20 June 2000. Email of 3 pages including cover page summarised on page 31.

76. Bay of Plenty Commercial Beekeepers' Group. 19 June 2000. Email sent by Gerrit Hyink, 4 pages including cover page summarised on page 9.

77. J & T Lorimer, R King, L Olsen, G MacKisack, B Clements, P Proverbs, D & C West, J & F O'Brien, S Lee, R Tod. Waikato beekeepers' group. Fax of 7 pages summarised on page 16.

78. Kevin Thomas of Te Puke. 18 June 2000. Email of 1 page summarised on page 38.

79. Arataki Honey Ltd. 15 June 2000. Fax from Russell Berry. 3 pages including cover page, summarised on page 11.

80. Don Bradford. 8 June 2000. Email of 2 pages summarised on page 12.

81. David Plowright, beekeeper. 1 June 2000. Email of 1 page, in favour of eradication.

Summary of Submissions

1. BAY OF PLENTY COMMERCIAL BEEKEEPERS' GROUP

1.1 Comments on the operational plan for eradication of varroa. In attendance were Neil and Wendy Mossop, Kevin Thomas, John Gordan and Gerrit Hyink. The group concluded that if eradication were to work, changes would need to be made to the operational plan.

1.2 Specific comments

The Group questioned the feasibility of baiting. This is unknown and has not been done before. They also had serious doubts after the Santa Cruz Island experience. Also a big concern is that the public could be at risk, in particular in the cities. The group also questioned the fact that drones could spread further than the testable level of 5 to 10km per year.

1.3 The delimiting survey is inaccurate for low infestations. The methodology of testing seems to rely on the multiplication of the mite until it reaches a testable population. This cannot give any confidence because, in the meantime, the mite will have spread. There is also a question mark on the effectiveness of tracing. Not every beekeeper keeps records and in particular this is very difficult with people using big dumpsites.

1.4 The nucleus colony should be a package of 2kg of bees with a young queen. This is to avoid alien brood frames and the risk of spreading American Foulbrood. The cost of this package should be $125 plus GST (as described by the Waikato Beekeeper Group).

1.5 There should be a centralised approach after depopulation and cleaning to store hives in CA storage. Hives should not be left in the field to be cleaned out by ferals. The estimated costs for cleaning and storing would be $20 per hive.

1.6 Beekeepers with a lot of sites in the eradication zone are exposed and have no where to go with their hives after repopulation. This could cause major strife among beekeepers and needs to be addressed.

1.7 Loss of income needs much more detailed attention. More ground rules are needed for assessing income. Variation in income with the seasons also needs to be considered. Beekeepers' income needs to be set out step by step.

1.8 Beekeepers who are based in the eradication zone will not be able to operate. This needs much more attention. In the buffer zone, any hive to be shifted needs to be diagnosed as absolutely mite free (not possible with current test). If eradication of varroa is to succeed, there can be no movement of hives in the buffer zone for a year or more. If movement is allowed, the whole of the buffer zone should be eradicated after the pollination season.

2. ROBERT MANN

2.1 This submission made some specific comments on the eradication and control plans. It concluded that any eradication proposal should include an improvement in border control. Eradication could be possible if a good scientific analysis justified it.

2.2 Border control must be improved

Any eradication proposal should include locked in, much improved border patrols. This would yield other benefits as well - keeping out other pests and weeds.

2.3 The question becomes whether we should accept the certain loss of so many bees for the proposed time, even assuming varroa-free repopulation could be achieved after that time, which is not certain. The Ministry of Agriculture and Forestry's analysis should state separately

a) the probability of eradication - with an estimate of uncertainty

b) the acceptability of that scenario

2.4 Control should not be with just one method

Indefinite control poses a delicate challenge to those drafting the legal requirements. On the one hand, we should not get needlessly locked into a rigid plan requiring just one poison, as if the government was an agent for compulsory sales of a particular chemical.

2.5 New methods for control should be considered

Any legal regime of varroa control should not be too rigid. Newly developed control methods should be considered from time to time. The control plan should incorporate money to get Dr Anderson (Principal Research Scientist (Bee Pathologist) from CSIRO) here for a time, and for ancillary R & D expenditure. It is our duty to work hard on improved control methods.

3. ARATAKI HONEY LTD, ROTORUA DIVISION. RUSSELL BERRY.

3.1 This submission was in favour of eradication for at least 12 months. If this was unsuccessful, Mr Berry felt that the eradication process would make control of varroa easier.

3.2 Feral bee depopulation

Probably not more than 5% of the ferals will have varroa in them. If we kill 95% of the feral bees, there would be a a very low chance of varroa spreading to hives going into pollination, particularly if Apistan strips are placed into the hives while they are in orchards. The hives should be taken out of the kiwifruit orchards and placed in sites (do not eradicate). No bee or hive movement should be allowed from between 1 January until 1 August 2001. This gives us a chance to eradicate varroa.

3.3 Intentional spread of varroa would not happen

Nobody in New Zealand would be so stupid as to intentionally spread varroa mites. The statements that say this are malicious, put out to lessen Government support for the eradication option. People are stating this for their own personal short-term gain and not looking at the New Zealand economy as a whole.

3.4 Eradication should start immediately

We should eradicate the varroa-infected hives starting with the Te Puke area, and the feral bees, immediately. Not many ferals will be affected by varroa except in Auckland. There should be a complete ban on hive and bee movements from 1 January to 31 July 2001.

4. DON BRADFORD

4.1 This submission was in favour of eradication. Reasons follow.

4.2 We should not rule eradication out in New Zealand because it has not been successful elsewhere. The long-term effect of varroa in New Zealand will cost billions of dollars. It will affect the horticultural industry and pastoral agriculture.

4.3 Eradication would delay spread

Even if this eradication programme was not 100% successful, it would severely delay the spread of varroa throughout New Zealand and buy extra time for potential future biological or other controls, which are currently being developed overseas. 50 to 75 million dollars is a small amount for a nation to spend to protect its main future stream of export earnings.

4.4 Compensation should be fair

One of the main factors that will ensure the success of an eradication programme is the value placed on compensation for a depopulated hive. I understand that a figure of $75 has been suggested, but this should be doubled. Doing this would ensure the positive and active support of all beekeepers, which is absolutely essential for success. Doubling this compensation figure will not increase the total cost of eradication by much as it is a relatively minimal figure within the total budget. This would also ensure that beekeepers from non-varroa infected areas in the country will be active in multiplying their hive numbers to sell into important pollination regions, for example where kiwifruit are grown.

5. NORMAN AND MARY DEAN

5.1 This submission was in favour of eradication. The authors provided an assessment of the effects of varroa on their situation.

5.2 Need to budget

There would be a 30% bee loss minimum (possibly increasing to 60-70%p.a. - overseas estimates). Rising costs mean lower production. There would be an increase of hive holding by 30% minimum. There would also be rising costs of hive wood ware etc, a work load increase and a huge sugar bill increase to feed bees that would be killed by varroa.

5.3 Stress levels

This is an extremely uncertain time. Increased stress levels are untold with varroa possibilities. There is increased daily working of the hives - we are now checking 'how many hives are dead or dying?' from varroa. Nightly stress - 'who's going to pay the bank manager?'.

5.4 Queen rearing

There is an unknown effect of Apistan on developing queens or young queens. Apistan has been implicated in the death of young drones and in adversely affecting drone production (reference The New Zealand Beekeeper Journal June/00, Vol. 17:5 (17)).

5.5 Propolis

There is a danger of contamination from Apistan. This means that another market potential is endangered.

5.6 Active manuka honey

There is a huge potential for active manuka honey on the world market. This huge export potential for the medical world is in danger from possible contamination with the miticide.

5.7 Mite resistance to miticide

There is a danger of mites becoming resistant to miticide, as has happened overseas. Then what protection would we have for our bees? European honey bees are now an endangered species worldwide. Where's the clean green image going?

6. PETER GOLDSBURY

6.1 The author of this submission stated that he was totally committed to elimination of the varroa mite and tightening of border controls.

6.2 Government responsible for border control

The Government and its agencies are repeatedly being shown to be very lax in biosecurity border control and must be held responsible for the risks that these infections pose to our economy. In the light of the risk management commitment that Government agencies gave to the Y2k, fruitfly, moth and the Auckland power crisis, the official response to the varroa infection has been seen to be poor (despite the superb efforts of many coal-face people in the agencies involved). Beekeepers whose livelihoods are contingent on good decisions have felt marginalised, and that their voices, support and enthusiasm have been ignored.

6.3 Unanimous industry support

I have never ever seen a project situation before where such a disparate industry group has been so unanimously committed to a single action. Affected beekeepers are unanimous in their support for elimination and are prepared to sustain short-term losses and offer their services for the benefit of the nation. We need reciprocal boldness from Government.

7. HAPPY VALLEY HONEY (NZ) LTD, AUCKLAND

The submission from Happy Valley Honey (NZ) Ltd was in favour of an eradication attempt, moving to the control option if eradication failed.

7.1 New Zealand should not be deterred by overseas failure to eradicate.

7.2 The Department of Conservation has been successful in eradicating numerous mammal species from many off shore islands when the critics said 'it can't be done'.

7.3 Depopulation procedure

Use Methyl Bromide as a proven method of killing living organisms. Advantages are that it kills quickly, leaves no residue in wax and honey, will penetrate through the brood and will kill both larvae and varroa mites. It is relatively cheap.

7.4 Pollination hives

From October 1, bait stations should be removed from pollination areas to allow for nucleus hives to be brought in from outside the restricted zone. These hives are to be used for the pollination of stone and pip fruits and later to be built up to sufficient strength to be used for kiwifruit pollination units. Apistan strips to be placed in these pollination hives within two weeks of arriving in the (depopulated) restricted zone.

7.5 Border controls must be increased

Dealing with infestation of a foreign pest is costly and time consuming. It is imperative that the intensity of border controls be increased. Any live bees coming in through an airport should have been detected, and shipping containers should be routinely fumigated to kill any living organisms hitch-hiking a ride to our country.

7.6 Comments on Operational Plan for Control of Varroa

It is also important that, for the short period that we manage to keep the South Island mite free, no unethical commercial advantage be allowed to be taken by those producers in mite-free areas.

8. J & T LORIMER, R KING, L OLSEN, G MAC KISACK, B CLEMENTS, P PROVERBS, D & C WEST, J & F O'BRIEN, R TOD.

8.1 This submission was from notes taken at an informal meeting of beekeepers in the Waikato area. There was full support from the group that met for an eradication attempt. Reasons and some specific comments on the eradication plan were as follows.

8.2 Depopulation of beehives after kiwifruit pollination 2000.

Overall loss of beehives would be less than stated in the plan. The compensation figure for replacement colonies is too low and would have to be adjusted. It does not take into account the costs of labour. The estimated total replacement cost to the beekeeper should be $125.00 plus GST per hive. The cost of storage boxes and combs must be adjusted for individual beekeepers' needs.

8.3 The availability of beehives for kiwifruit pollination in 2001

Beehives will be available in 2001 if two conditions are met: firstly beekeepers must be encouraged to undertake repopulation of their own colonies by a realistic replacement cost, and secondly kiwifruit pollinators should have first call on available replacement bees. These could be in the form of a 2 kilo package, with young queen, in the summer of 2001. This is of lower risk than a nucleus colony in the autumn, and allows for the colony to grow on in better conditions (if the bees are coming up from the South Island).

8.4 Compensation

8.5 Compensation for loss of income is not covered by the draft eradication plan. Beekeepers' compensation should be made in staggered payments at different stages of the eradication process.

9. NATIONAL BEEKEEPERS' ASSOCIATION OF NEW ZEALAND (INC) NORTHLAND BRANCH

9.1 This submission was in favour of eradication. The submission was signed by Don Hoole (Chairman), Simon Peacey (Secretary), John Gavin, Dave Herbert, Arthur Tucker, Jim Sharp, Brendan Nichols (Committee members), Terry Gavin, Edna Hoole, Cushla Gavin, Sarah Peacey, George Nichols and Pamela Nichols. Reasons given in support of the plan are outlined as follows.

9.2 The control options will only delay the inevitable spread of varroa. The Government needs to take into account the huge costs to the economy in terms of agriculture and horticulture if varroa is not eradicated.

9.3 The eradication of varroa in New Zealand is feasible and the cost is small in comparison to the cost to the country of living with varroa. Living with varroa (i.e. not eradicating) for seven years would cost the New Zealand economy 100 times more than the one-off cost of eradication.

9.4 If varroa is not eradicated, it will kill all the feral hives in New Zealand. It is likely that much of the rolling to steep grassland farming will become nonviable because the clover crop will not be pollinated and the costs of nitrogen applications are so high. Many other crops, which presently do not need pollination by managed hives, will not be pollinated by feral bees once varroa kills them.

9.5 If the control options are adopted, there can be no guarantee of enough hives for the Auckland/Hauraki Plains kiwifruit pollination this year. Between 6000 and 7000 hives will be required in addition to the pollination hives available in the area. Without an eradication plan and compensation mechanism, very few beekeepers from outside the area will bring in pollination hives. By contrast, the eradication plan accommodates the need for pollination.

9.6 Control will be expensive, and it is likely that the mite will become resistant to the chemicals used. Another concern, based on overseas experience, is that Apistan and other treatments will lead to infertility of drones and queens, with subsequent loss of bee numbers and contamination of wax, propolis and other hive products.

9.7 The use of chemicals and drugs is anathema to New Zealand beekeeping practices. The use of them will threaten our marketing of New Zealand honey and hive products as chemical free.

9.8 The Government is responsible for border control and surveillance, and is therefore responsible for eradicating varroa.

9.9 Unless varroa is eradicated there will be increased unemployment in the beekeeping, horticulture and agriculture industries.

9.10 There has been no consultation with the beekeeping industry over the eradication plan and only reluctant involvement of beekeepers (only two) over the control plan, and then only after the plan had been drafted. Beekeepers spent thousands of hours and dollars helping with the survey work, and our livelihoods depend on the outcome of decisions made about varroa. We deserve to be consulted before decisions are made.

9.11 The control proposals do nothing to control the movement of hives between the infection and the buffer zones and, if implemented, the buffer zone will quickly become infected.

9.12 The option for AgriQuality NZ Ltd to have control of the Apistan strips will lead to that organisation having a monopoly over the treatment. The proposal that its staff install the treatment strips in hives will be very expensive for beekeepers. Based on past performance, beekeepers have no faith in AgriQuality's ability, and view with grave concern the proposals for its involvement in the control of varroa. If the Government decides on controlling rather than eradicating varroa, beekeepers should be allowed to have control of the treatment of varroa.

10. PETER RADCLIFFE

10.1 This submission stated that eradication of varroa would be a far cheaper and more cost-effective approach than any of the control options listed.

10.2 The submission stated that varroa should be eradicated in all known infected hives (Rawene-Whakatane-Raurimu) before July 31 this year. Hive owners should be paid up to $75 compensation per hive killed. Supply the same owners with nucleus hives, as offered by southern beekeepers. MAF should conduct surveillance of the same area until winter 2001. Total costs for this would be NZ$12-15 million maximum.

10.3 MAF control strategies all lead to escalating costs for surveillance, control, and direct and indirect economic loss to commercial and private beekeepers, fruit growers and clover producers. Many beekeepers would be forced out of business.

11. WILLIAM SELL

11.1 This submission was in favour of an eradication attempt. The author stated that the cost of eradicating the mite would be considerably cheaper for the country in the long term. Eradication would benefit most New Zealanders in some way, from natural pollination of home gardens to ready pollination of agricultural crops, and a cheap and plentiful supply of bee products.

11.2 American foulbrood pest management strategy

New Zealand beekeepers have a pest management strategy in place to control and eventually eradicate American foulbrood (AFB) disease. Varroa is possibly more contagious than AFB, but the destruction of varroa is an easier proposition, particularly at the present while it is relatively localised. Compared with varroa, AFB is a minor disease. I do not see any point in complying with the pest management strategy for AFB, but not making every effort to eradicate the far more virulent and destructive varroa mite.

12. SENSATIONAL BEE PRODUCTS

12.1 This submission, signed by Rob Coers and Carol Daley (Directors), stated that Sensational Bee Products is vehemently opposed to any attempt to control the mite. The only measure they support is total eradication of beehives in the hot area and surrounds. Reasons follow.

12.2 New Zealand's 'green' image

New Zealand's green image would be tainted by the use of chemicals. Eradication would allow time for research into other methods of control. The international community would see that New Zealand is dedicated to quality and natural products. New Zealand pollen is one of the highest priced in the world. Our clean green image helps to justify this cost.

12.3 Cost of treatment chemicals

The cost of Apistan strips would send shock waves through an industry already just making ends meet. There aren't too many 'rich' beekeepers around, and many have a second job.

12.4 Adequate number of hives for pollination

It is essential that the agricultural and horticultural industries have enough hives for pollination. If some beekeepers were forced out of the industry because of the high cost for varroa management, and others had their hive numbers dramatically reduced because of high hive deaths, there may not be sufficient hives for pollination in some areas.

12.5 Adequate compensation

There must be adequate compensation to beekeepers for loss of income and the cost of building up nucleus colonies in time for pollination. This is the only fair response for the Government to take when they impose a mandatory action on anyone that will lose their income as a result of that edict. It will help ensure compliance amongst beekeepers, some of whom do not believe eradication is the best answer to the mite invasion.

13. MICHAEL VERCOE, COMPANY BEE HONEY

13.1 This submission was in favour of eradication.

13.2 The New Zealand public and the beekeeping industry want a drug free beekeeping industry. It is necessary to give the industry the time and resources to reorganise, given that 25% of New Zealand hives are in the infected zone. The cost of the eradication plan is money well spent and should be seen as an insurance policy to maintain the good health and wellbeing of industries involved.

13.3 It should not be forgotten that 75% of New Zealand's beekeeping industry would continue to function in its traditional, efficient manner under an eradication plan. In fact it will prosper by supplying replacement bees to the infestation zone and making up any minor shortfalls in honey, bee pollen, propolis and royal jelly. 75% of our industry equates to total domestic demand for honey, and packers report adequate stores created by several years of overproduction to meet ongoing retail pack exports (approximately 650 tonnes/annum). The only area of shortfall will be in bulk exports (300kg drums) which is generally the low returning, commodity priced end of the product spectrum anyway. These markets we have developed here are valuable and if we fail to supply, someone else will fill the gap.

13.4 Globalisation has increased imports to New Zealand exponentially over the last 20 years. On the other hand, border control effectiveness to ward off exotic pests has declined significantly. Any attempt to prevent and/or eradicate exotic pests must also be met by Government supplying adequate resources to our border control services

13.5 Many countries afflicted with varroa have economies with a large industrial base. New Zealand is almost entirely agriculturally based and does not have an industrial 'safety net' to rely on when things go wrong.

13.6 Organic honey production and export will be severely diminished and there may be serious chemical residue concerns from consumers of bee products. New Zealand's 'green' image will receive a serious setback.

13.7 If there are no feral colonies and fewer managed hives, costs will rise to a level which makes New Zealand's seed crop industry (among others) uncompetitive with Australia. The industry will then be transposed to Australia where bees are plentiful. This will result in lost New Zealand jobs in the agricultural sector, with flow on job loss in the manufacturing, commercial and service sectors.

13.8 Questions have been raised about beekeeper compliance to an eradication programme. The overwhelming support shown by beekeepers to MAF's eradication plan counters such logic. There will be beekeeper compliance if adequate compensation is paid.

14. AIRBORNE HONEY LTD, CENTRAL CANTERBURY

Airborne Honey Ltd was in favour of the idea of eradication. The only caveat was whether it was possible and a benefit, considering the cost. The submission concluded that the Operational Plan for Eradication of Varroa has absolutely no chance of success. Reasons follow.

14.1 Unable to eradicate feral colonies

14.1.1 Much difficulty was encountered in the ten year long attempt to eradicate feral bee colonies from Santa Cruz Island (off the coast of Southern California).

14.1.2 New Zealand feral colonies are largely represented by Apis mellifera mellifera (English or German black bees), while our managed colonies tend to be mostly the Italian A. mellifera liguistica. This difference reflects the ability of A. mellifera mellifera to survive in difficult conditions. Of the four main European races of honeybee, Italians are documented as having the greatest propensity to rob, while German black bees have the least. Previous attempts in the South Island to eradicate feral hives (Apis mellifera mellifera) with baits concluded that it is almost impossible to get them to rob.

14.1.3 Swarming behaviour of feral bees is different to that of managed colonies. Feral colonies can swarm several times in the same season, while managed colonies tend not to. This is the likely reason the Santa Cruz eradication killed 292 colonies after their initial estimate of 30.

14.1.4 Timing of the feral eradication attempt is at a time of year (Spring to Autumn) when flowering plants are most prolific. Bees are less likely to rob at this time of year, making it impossible to successfully bait all (or even the majority of) feral colonies.

14.1.5 Competition for remaining feral colonies will be reduced to almost zero by the depopulation programme for managed colonies and the baiting of the feral colonies. There is only one bait station per 100 hectares. As a comparison, effective pollination rates for various plants range from 1 to 8 managed colonies per hectare.

14.1.6 Most of the feral colonies that do survive the first round of eradication attempts, are also likely to have characteristics that have aided their survival, e.g. do not rob, prefer nectar to the baits. Their offspring will have a high degree of these characteristics, and because of the prolific nature of swarms coming from feral colonies, there will be many of these 'resistant' colonies going into the winter June 2001.

14.1.7 Research work has been contracted by MAF to try and determine the best methods of eradicating feral colonies. Determining if eradication of feral colonies from over 10,000 square kilometres is possible is not in the brief of the contract. This has already been assumed by MAF as being possible. The decision to eradicate or not eradicate will be made before this report is presented.

14.2 The Tracing Programme

Great importance has been placed on the tracing programme and its relevance to the delimiting survey. This relies entirely on beekeepers' honesty, accuracy of their memory or record keeping, and thorough and accurate interpretation of this information.

14.2.1 There has been an increase of over 30% of new apiary sites in the Auckland region that were not on the National Apiary Register at 11 April 2000. Some of these are errors in MAF processing, some are delays in the processing of changes to the register, and some are from beekeepers not informing MAF. It is unreasonable to believe that the tracing operation is complete and accurate.

14.2.2 Many beekeepers have related stories of being contacted by MAF and asked various questions regarding the tracing operation. One case of a 'hot' trace not being followed up related to a hive being shifted from the danger area to Central Otago. It would seem that this trace would not have been followed up if further prompting had not come from the person reporting it in the first place. How many out there slipped through the cracks?

14.3 Size of eradication zone not large enough

At present the eradication zone is created by a 15km radius around infected places. This is based on the assumption of a 'natural spread' of 5km per year. This is wrong.

14.3.1 The vectors of varroa spread are not entirely understood. Factors contributing to spread of bees are people, drifting, robbing and swarming. These factors can cause bees to move 10 to 20km distances. An example of swarms in Africanised honey bees (A. scutellata) travelling up to 30km in 3 months during good nectar flows and 210km in 3 months in dearth conditions was cited (Villa, JD; Labougle, JM. 1988. Range expansion of Africanized bees in Mexico. American Bee Journal 128:12 (810-11)).

14.3.2 Drones' travel from hive to hive is suspected as being the primary source of long distance dispersal of varroa. The outer limits of distance that drones travel is a great unknown and very little research has been done on it. A Danish beekeeper in an informal experiment found a marked drone 25km away from the original bee yard.

14.4 Lack of sensitivity of Apistan/sticky board test

The accuracy of the Apistan/sticky board test is entirely reliant on enough mites being carried externally on bees in the hive at the time of the test to succumb to the active ingredient in Apistan. At any time in the life cycle of varroa, the majority of mites are breeding in the cells and cannot be detected with this test.

It is considered that an infection of less than 4 months will have a less than 50% chance of detection.

14.5 Beekeeper honesty variable

There was a 12% increase in registered apiaries in the Nelson region during the European Foulbrood (EFB) scare. At the time of the EFB outbreak scare in Nelson, a beekeeper attempted to shift his hives out of the quarantine zone. We believe the lack of integrity shown by many beekeepers will lead to the same actions that have occurred in most other countries that have attempted to eradicate or control varroa, i.e. beekeepers knowingly and willingly flouting the regulations in an attempt to survive. There have even been cases of beekeepers deliberately spreading varroa to speed a 'return to normality'. This will contribute to the failure of the plan.

14.6 Beekeeper motivation and cohesion - for or against the op

14.6.1 A National Beekeepers' Association press release stated that those opposed to eradication were changing their minds as proposed compensation figures rose. This shows that a number of beekeepers are only in favour of eradication if they think there is money in it for them - not because they believe it has a chance for success.

14.6.2 Under the eradication plan it is assumed that all beekeepers will be motivated by money. This is not the case. We know many beekeepers who would be directly affected by eradication and are opposed to it because they believe it will fail - for several reasons. Money will not make them change their mind.

14.7 Lack of overseas experts

14.7.1 To date there is no evidence of a wealth of overseas expert support being utilised. Instead, the sum total of experience of the creators of the eradication plan is extremely limited. Some of the plan's creators do not even have significant experience with honey bees.

14.7.2 We are told "Epidemiology tools are being used to successfully model and predict mite behaviour" and yet there are serious shortcomings in both the Apistan/sticky board test and knowledge of many of the vectors (particularly swarm and drone movement).

14.7.3 The American Foulbrood (AFB) argument doing the rounds:

"If other countries had been asked if it was possible to eradicate American Foul Brood they would have said it was not, so it therefore follows that other countries' failure to eradicate varroa, should not be taken as a negative."

While we do have a (so far) successful AFB pest management strategy (PMS), there are significant fatal flaws with this argument making it completely irrelevant.

This argument only highlights its proponents' shortcomings in understanding Varroa.

14.8 No evidence of overseas support of eradication attempt

To date, there has been no published information from overseas experts that confers support on the eradication attempt. Typically opponents of the eradication plan are well read, well informed individuals, often with personal experience with varroa. No amount of persuasion from New Zealand experts will change their mind. Only a wealth of information from respected and credible overseas experts has a chance of doing that - information that is totally lacking.

14.9 Exports will suffer if eradication is attempted

14.9.1 Our 8,500 tonne average crop (of which 1,800 tonnes avg. is exported) will reduce to 6,375 tonnes. This will leave the domestic market short (by around 325 tonnes) without allowing anything for the export market, driving up prices locally. In the past the inelastic nature of our domestic honey market has been well documented, by both market research of consumer attitudes and empirical data from events in the market place. The New Zealand consumer has historically paid any general increase in prices with no decrease in consumption. With a domestic increase in price of honey out of step with world market prices, exports will cease (the domestic market price will increase until they do) while the domestic market is supplied.

14.9.2 Added value retail lines (packed honey) will suffer irreparable damage. A fall off (in this case a complete stop) in supply would overnight undo the hard work that has been done in retail packed honeys in the export market over the last 10 years by many exporters. Airborne Honey alone has spent close on $500,000 in export market development in the last 15 years. Some people are willing to believe that there are sufficient stocks in the country to bridge the gap for two years of reduced supply. Our calculations show there is no large surplus stock at all.

14.9.3 Attempting eradication of varroa will not only do immense damage to many beekeepers as they struggle to supply sufficient bees to repopulate hives. It will give long term reduced income to all beekeepers just when they need increased income due to the extra cost of managing hives with varroa after the eradication attempt fails.

14.10 Cost is greater than cure

14.10.1 Living with Varroa is not as bad as portrayed. Around the world varroa is certainly a significant problem. However it is difficult or impossible to assess the outcome of varroa in most numerical or financial outcomes due to the effect being so small that it is not statistically significant. If they were measurable and significant, it would show up in the various world statistics available.

14.10.2 It is human nature to accentuate the horror stories of varroa overseas. Also there are sometimes good market ("poor crop" = higher prices) or business related (government assistance) reasons for highlighting these. The outcomes for varroa are not, however, as bad as most of the anecdotal stories would indicate. World honey production continues to rise in spite of varroa being in countries contributing to 95% of world honey production for more than 10 years. In the USA, approximately 1 million hives (1/3 of all hives in the USA) are moved into almond pollination each year in a logistical exercise that makes our kiwifruit pollination (80,000 hives) look tiny by comparison. To date, there has been no appreciable change in cost structure for almond pollination in the USA. Varroa was discovered in the USA in 1986 and it took around 4-5 years to spread across the country. Production over the following 10 years increased from 88,644 tonnes (10-year average to 1990) to 93,600 tonnes (10-year average to 1999).

14.10.3 The clean green image of New Zealand's products may suffer. However, the major bee product export, honey, will not suffer. New Zealand competes directly on the world market with Canada and the USA for clover honey. Canada and the USA both have varroa. The price New Zealand receives for clover honey is comparable with Canada; i.e. there is no price premium for New Zealand honey. New Zealand supplies less than 1% of world trade in honey, so few overseas marketers are prepared to say that New Zealand honey is better than other honeys -thereby implying that the rest of the honey they trade is flawed. Varroa therefore does not represent a significant market setback for New Zealand honey.

14.10.4 The commercial cost of living with Varroa is likely in the short term to be around $10 - 15 per hive in New Zealand for commercial hives. With around 280,000 hives in this category, the interest cost of the $56 million eradication attempt would be greater than the cost of control, as calculated by Airborne Honey Ltd.

14.10.5 There will be some offset of control costs as commercial beekeepers are likely to become better beekeepers with better per hive production also aided by decreased competition as many inefficient and hobby operators exit the industry. Passing the cost on in the products and services of the beehive will make up the remainder. Annual honey production averages 30 kilos/hive/year. Much of the pollination currently provided in pastoral areas of the country is free to the landowner. This is a potential source of revenue along with small increases in horticultural pollination.

14.10.6 Varroa free areas in New Zealand

The rugged nature of much of New Zealand lends itself to natural barriers against bee movement (most notable being the South Island at present). If other countries' experiences are similar to ours, there could be areas, even in the North Island, that will not have Varroa in 3-4 years. The South Island could be Varroa free for much longer than that.

14.10.7 World wide research on varroa control

There is a significant amount of research being done on varroa worldwide. Dr. Dennis Anderson from Australia feels confident that there could be a cure within 5 years time. Elsewhere a pheromone attractant type product was recently launched onto the market. All are likely to lead to cost improvements and improved management outcomes for Varroa in the future.

15. COMVITA NEW ZEALAND LTD

15.1 The submission stated that Comvita does not believe that an eradication programme is feasible within the parameters set forth in the draft eradication plan. It was stated that eradication may be possible, but it would require hive depopulation in the North Island at levels greater than the 75,909 hives predicted. Reasons are outlined as follows.

15.2 There is an acknowledged lack of sensitivity of the current test being used to detect mite infestations.

15.3 Comvita is unable to predict what the final number of hives depopulated will be in the eradication programme. We are, however, confident that the number will be in excess of 50% of all North Island hives. Depending on the location of new blips (for instance in horticultural areas such as Katikati or the Hawkes Bay requiring depopulation of pollination hives), the number could be in excess of 75%. A 75% depopulation of beehives in the North Island would cause a catastrophic and long-lasting negative impact on beekeeping in New Zealand.

15.4 Impact of eradication on company

In section 10.13 of the eradication plan there is a prediction of a substantial reduction of both honey and bee products production in the North Island in both the 2000-01 and 2001-02 seasons caused by the shift away from honey production to replacement nucleus production. The honey crop will suffer a far greater reduction than the predicted 44% in 2000-01, and that there will be greater effects the next season. A reduction in honey production would curtail Comvita's ability to supply Manuka honey, and a reduction of over 75% would mean Comvita would be unable to supply all export markets and a substantial amount of the domestic market. The eradication programme is therefore likely to result in a substantial reduction of income and profitability for Comvita from lost sales of Manuka honey.

15.5 Lack of compensation

In section 9.8 of the eradication plan ('Downstream Losses'), MAF suggests that there may be an 'anomaly' in the Biosecurity Act relating to downstream losses. Comvita would not qualify for compensation since as a company it does not keep beehives as well as manufacture bee products. This puts Comvita at a substantial disadvantage compared to some of its competitors who do maintain beehives as well as compete with Comvita in the retail market. This is grossly unfair, and any compensation paid to such companies for loss of profits from manufactured product sales would increase the negative impact on Comvita caused by the eradication programme.

15.6 MAF should seek a legal opinion on the compensation provisions of the Biosecurity Act, and make this legal opinion public so that companies and individuals potentially affected by the eradication programme are aware of the government position on this matter. MAF should also seek opinion from other government departments (e.g. Treasury) regarding potential compensation outside the confines of the Biosecurity Act, and make this information also available to companies and individuals potentially affected by the programme.

15.7 Support for decision

Comvita will pledge its support for a decision to attempt eradication despite the company's reservations and the likely consequences for the profitability of the company. Likewise, if a decision is taken by government not to eradicate, Comvita will pledge its support to both the beekeeping industry and government in helping to ensure the impact of the mite is minimised.

15.8 Registration of control products

Essential oils are proving popular overseas as an alternative mite control method. Comvita therefore wishes to work with Government to investigate both the supply and registration of essential oils, so that New Zealand beekeepers have access to low-cost, natural varroa control substances.

15.9 Support for beekeeper education

Comvita is supportive of an extension programme to assist beekeepers in learning to control varroa, including a varroa control manual and the provision for short courses and field days.

15.10 Income diversification to pay for varroa control costs

Comvita has a significant long-term demand for propolis, a bee product that beekeepers often do not take the time or effort to collect from their hives. We are currently encouraging beekeepers around New Zealand to add propolis collection to their management as an income diversification.

On average, beehives have sufficient available propolis without using collection devices to finance annual varroa control material costs for the hive. Use of collection devices is likely to double propolis production per hive.

For the foreseeable future, Comvita is prepared to purchase all of the propolis New Zealand beekeepers are able to produce from their hives, with payment immediately upon supply. Comvita pledges to ensure pricing and procurement policies for propolis continue to compensate for mite control costs in the foreseeable future, regardless of how much propolis our beekeepers are able to produce.

15.11 Need for surveillance review

Once decisions are made and programmes are put in place regarding New Zealand future response to varroa, Comvita calls upon Government to carry out a full-scale review of honey bee exotic disease surveillance.

15.12 Need for extension services

Comvita strongly supports an extension programme financed at least partly by Government. We are fortunate that much of the skill base of the previous extension service is still intact in the form of Apiary Officers from AgriQuality NZ. We therefore recommend to government that it reinstates an apiculture extension service as part of its response to varroa, and that AgriQuality NZ is considered favourably as a provider of these extension services.

16. BARRY DONOVAN, DONOVAN SCIENTIFIC INSECT RESEARCH

16.1 The submission stated that it is not possible to kill every mite in New Zealand with the resources said to be available.

16.2 Santa Cruz Island eradication attempt

The attempt to exterminate all feral honey bees on Santa Cruz Island is very instructive. Santa Cruz Island lies off the coast of southern California. It consists of about 250 square kilometres of pasture and scattered forest. When the extermination attempt began, it was estimated that there may have been 30 feral colonies on the island. After 12 years of effort, which included introducing varroa in an attempt to kill unlocated feral colonies, nearly 300 colonies had been located and killed, and only now are possibly all bees dead. One feral colony increased to 14 over 2 years.

16.3 Varroa possibly more widely distributed than thought

Experience in other countries has shown that varroa is always more widely distributed than thought. There has been a report of hives disappearing from sites within the infected Auckland zone at night. If true, the hives could now be anywhere in the North Island. The flight distance of drones, which can carry varroa, is unknown.

16.4 Ability of parasitoids to locate host

Even if varroa is exterminated, because it has reached here once, it may well do so again.

I have worked at attempted control of chalcid parasitoids of leafcutting bees, and have introduced and established a parasitoid of wasps. A characteristic possessed by these parasitoids is that they have an amazing ability to locate their hosts and survive. Overseas experience suggests that varroa possesses this attribute par excellence.

16.5 World wide research on varroa control

Varroa in other countries (except South Africa) is controlled primarily with the use of Apistan strips. The easiest and cheapest approach for the immediate future in New Zealand is to adopt the use of Apistan.

World wide research is looking at many ways of controlling varroa, from searching for and selecting resistant bees, to use of cultural methods and other chemicals, including 'green' approaches. Genetic engineering has also been raised as a possibility, but in my extensive reading on the subject, I have not uncovered one example of genetic engineering of any bee species. Such an approach may be very appealing, but it will be very costly, and in my opinion will not produce useable results in the foreseeable future. This approach should be left to overseas researchers who have more resources at their command.

16.6 Possible biocontrol of Varroa with South African Pseudoscorpions

If reports from South African beekeepers are correct, pseudoscorpions, which occur naturally in their hives, eat varroa, so that no control measures are necessary. If correct, and if we could establish these pseudoscorpions in our hives, varroa would be controlled forever at no further cost, and no hives would be killed. Urgent attention should be given to this approach.

17. GERRIT & INEKE HYINK, NICK WALLINGFORD, BRUCE STANLEY

17.1 The conclusion of this submission was that the proposal to eradicate varroa would not be successful.

17.2 Bee flight

Drones are known to fly longer distances than the 15km stipulated in the eradication plan. Some evidence from overseas suggests that it could be 100km or more. Single mite infestations go unnoticed for longer, so many more 'blips' are expected.

17.3 Sensitivity of test

The surveying has been done with a low sensitivity test for low infestations. The methodology of testing relies on the multiplying of the mite over time until there is a detectable mite population. This cannot give any confidence because, in the meantime, the mite will have spread over a wide area.

17.4 Tracing operation

Although a big effort has been made by way of tracing to find infected areas, it is general knowledge that not all beekeepers keep records and a lot of beekeepers use dump sites during pollination. This means that it becomes near impossible to trace single hives.

17.5 In the event of an eradication attempt

To have a better chance of succeeding with eradication, no hive movements should be allowed in the buffer zone for at least a year. During this year, all the infected areas could be eradicated and the 'blips' will show up with the ongoing surveying and can be eradicated. This also means that those industries serviced by the beekeeping industry will have to sacrifice in the short term too.

17.6 Disruption to the beekeeping industry during eradication

Under the eradication option, a big part of the local beekeeping industry will be hampered by major disruption, to the extent that a number of very dedicated beekeeping businesses could either opt out or be forced out. As the beekeeping industry is relatively small this could be a serious long-term problem.

17.7 Doubt over the success of feral bee baiting

Feral bee baiting relies on the robbing properties of the bees. It is known that most feral colonies show less robbing behaviour than managed hives. It has not been proven that baiting can work under all conditions, including rugged native bush areas. There could also be decreased competition for nectar because all managed hives will have been depopulated. It is well known that bees, when foraging, prefer nectar above honey. It is unacceptable that such an important part of the plan has not been tested, and is even likely to fail.

17.8 Counselling should be made available

Under the eradication or control option, there should be a provision in the budget for making counselling available for people who are hurting because of the hardship they will have to face.

18. FRANK LINDSAY, LINDSAY'S APIARIES

18.1 The author of this submission would have liked both plans put into operation - eradication, then if that failed, control. The submission concluded that the varroa mite is not easily controlled and that it was found far too late for any sort of eradication proposal to be successful. The system of coordinated control (5.5), continued movement controls and provision of assistance to the beekeeping industry are the best options.

18.2 Assistance to beekeepers

Assistance should be given to beekeepers in the form of free treatments until the mite is widely established in both islands. Also needed is a research package to determine population dynamics for New Zealand conditions, and the appointment of a virologist to research the viruses that come with this mite. Money should be put aside to provide comprehensive training and surveillance packages. A grant should be given to the National Beekeepers Association to cover all the money spent on the response.

18.3 Some assumptions of the eradication plan challenged

18.3.1 The eradication plan stated that spread of the mite would be 4.5 km per year. Honeybees have been found at a feeding station 10-km away from a hive (reference: Karl Von Frisch, The Dancing Bees - page 119). Beekeepers have noted that bees will fly 12.5 km over clover pasture to collect manuka nectar.

18.3.2 The test used to establish the infestation of the mite was not sensitive enough to pick up light infestations.

18.3.3 Nobody has actually researched the spread of the varroa mite. In Germany, they believed it traveled up to 60 km a year. Dr Anderson (Principal Research Scientist (Bee Pathologist) from CSIRO), believes that when the mite enters a country, it goes into a spread mode and is difficult to detect until it starts breeding in numbers.

18.4 Reasons for MAF financing miticides

All beekeepers would like to see this mite eradicated from the country. Many will not have the ability to switch hives on to a higher revenue earning honey (such as manuka), and therefore could resort to taking shortcuts (including making their own*?) in an attempt to stay in business. For beekeepers to control the mites after such a long time will place a heavy financial burden on them and the chances of successfully treating heavily infected hives is not high. Assistance should be provided so these beekeepers can compete with those without mites.

18.5 Many beekeepers leaving the industry could create a honey shortage, which could be answered by opening our borders to imports of foreign honey, and the possibility of further introductions of exotic diseases. This will in turn cripple the beekeeping industry and the subsequent industries that rely on pollination.

19. NATIONAL BEEKEEPERS' ASSOCIATION OF NEW ZEALAND (INC) HAWKES BAY BRANCH

19.1 Present at the meeting to discuss the operational plans were Peter Berry, John Berry, Ian Berry, John Thomas, James Ward, Keith Pegram, Rod Walker, Barbara Bixley, Tom Taylor. The result of the meeting was a show of support for a coordinated control plan.

19.2 Apistan availability

Members indicated that regardless of whether an eradication attempt was made, beekeepers in the infected area with infected hives should have Apistan available to them immediately.

19.3 Beekeeper non-compliance

Beekeeper non-compliance in any choice of operational plan was considered a major concern, as already breaches appear not to have been pursued with prosecutions. One beekeeper freely admitted that money influenced his vote for eradication.

19.4 Use of chemicals

Concern was raised about the disposal of used strips in regards to the Resource Management Act 1991. It was felt that if the strips were administered by a management agency, the issue could be handled safely.

Members favoured the need for responsible use of chemicals and felt an area-based distribution would be best. They all felt the Government should supply the Apistan free of charge.

Discussion took place on resistance to Apistan and the possible illegal use of Maverick. It was suggested that companies such as Yates and Coopers have the Maverick base chemicals sold as a signed product, and that a warning label be attached against Maverick being used to treat varroa.

19.5 Pollination hives in the infected zone

It was felt the beekeepers in the surveillance zone, who have traditionally taken hives into pollination in the now infected zone, should receive some form of compensation. They will not be in a position to undertake the task because they will be unable to return them back to their own beekeeping area, regardless of the chosen plan. Some 9000 hives would be affected.

19.6 NBA eradication plan

The group was unsure why the National Beekeepers Association (NBA) had re-written the eradication plan. It was felt that while there were some good ideas in it, many of the ideas were 'pie in the sky' (i.e. spraying trees with toxic solutions - beneficial bugs and small invertebrates would be killed). The paper did not have a budget or scientific support. It was understood that the NBA was, as was everyone, invited to write submissions on the papers written already, not to re-write the plan.

19.7 Vote for indication of those for and against eradication

In a vote to give an indication of those in favour of eradication, 8 people represented by 14,550 hives were against eradication. 4 people representing 3,180 hives were for eradication.

While 4 people voted for eradication, there seemed to be a recognition that eradication would probably not be possible, hence a further motion was made by John Berry seconded by Tom Taylor, that the group was in favour of the third option in the control plan - the coordinated control plan.

20.KEVIN THOMAS

20.1 This submission concluded that the only plan that will work is the 'Beekeeper Treatment without Movement Control'. Kevin Thomas wrote that the following are important points to consider:

20.2 Effects on the kiwifruit industry

If the control plan were put into use, there would be no disruption to the kiwifruit industry during the crucial pollination period. There would also be no delays in receiving hives, or massive price increases. The following years would provide full strength hives to the orchardists, which would not be possible if eradication went ahead.

20.3 Likelihood of compliance

The 'Beekeeper Treatment without Control' option means no restrictions on beekeepers, so it is more likely that they will comply with this option than any other. If eradication were the chosen option, it would take only one or two beekeepers to resist cooperating and the whole plan would be sabotaged. This also applies to the other options of the control plan.

20.4 Effects on beekeepers relying solely on honey production

Beekeepers who do not use their hives for pollination, but rely on honey as their main source of income, will find it hard to absorb the cost of Apistan strips. Using this method of treatment will eat into a large portion of their profit. It is important to have the Apistan strips subsidised, so all beekeepers can afford to comply. Ideally, the strips would be subsidised for 4 to 5 years during the 'settling down period'. This settling down period is the time during which feral bee numbers are diminishing. After this period of time, a 10 percent price increase per kg of honey to the consumer could absorb the cost.

20.5 Faults with the eradication plan

21. PAUL WEST

21.1 This submission concluded that eradication by the current plan is not possible. The opportunity for successful eradication passed before we knew we had varroa.

21.2 Potential for poisoning of non-target species

With the intensive poisoning of bush areas planned to eradicate feral bees, there is great danger of horrendous ecological damage if non-target native invertebrates cannot be safeguarded. There is potential, if eradication is rushed ahead in an ill-considered way, to cause significant damage low down in the bush food chain. To develop a bait and bait-station able to kill 100% of bees whilst harming 0% of non-target species, even if possible, would require extensive testing, and more time than the proposed schedule allows.

21.3 Poisoning of feral bees difficult

Overseas experience has shown feral bees to be far more difficult to wipe out than the eradication plan allows for. Santa Cruz Island was a fraction of the area. It was unable to be repopulated naturally, yet took over ten years to eradicate feral bees, using many combined methods, including remote poisoning.

Even ignoring non-target kill, the poisoning itself looks dubious. Too fast a poison will not reach the hive. Too slow will merely weaken it, and increase the risk of the poison getting into the food chain. Some hives display reduced propensity for robbing, especially if there is a good nectar flow on. The feral bees will persist for years.

21.4 Low sensitivity of diagnostic test

Varroa is already far outside the officially delineated infection zone. The overseas experience has been that the mite is always farther afield than human perception. The best testing used (Apistan) is poor at detecting early infestations, yet a hive is mite-infectious even with the lightest infestation.

My own hives in the buffer zone were bought from Auckland within the past 2 years, and moved to their current location well outside of the delimiting survey. This movement was notified to the register, yet my hives have not been tested. It seems to me that my own hives should have been the subject of a "hot trace". How many others similarly were missed? And the off-the-record movements?

21.5 Natural varroa spread underestimated

Natural varroa spread has been underestimated. Studies have shown that individual drones (the preferred host) can go over 100km in a season. Even without hive movements, bees can inadvertently hitchhike in vehicles. I personally have had bees trapped in the car for many kilometres before finding the window, thence to adopt a new hive.

21.6 Reduced genetic diversity

A failed eradication attempt would severely reduce the genetic diversity of the New Zealand honeybee population. This further restricts the chances of developing varroa-resistant honeybees, which must ultimately happen.

21.7 Non-Apistan control methods

The control plan must not compel beekeepers to adopt any particular varroa control. Many alternatives to Apistan are showing promise, especially when used in an integrated manner. Organic beekeeping is still the future for this country, and even with varroa it may still be possible to avoid using pesticides in hives, be they natural or synthetic. Screened bottom boards, small-size foundation, constant selection pressure etc are methods not given sufficient consideration compared to aggressive use of pesticides. Beekeepers must be allowed to experiment with organic control in order to find alternative treatments effective in New Zealand conditions.

The control costing so far has not looked at alternative bio/organic control methods, nor their efficacy. There are successful producers of organic hive products in varroa infested countries. It is possible to live with varroa without Apistan. I am disappointed at the lack of investigation in non-Apistan control methods in the plans as presented so far. The currently known non-pesticide techniques (as well as non-Apistan pesticide techniques e.g. formic, essential oils, mineral oils etc) need to be evaluated for New Zealand conditions to determine efficacy and cost before the control plan can be considered near complete.

21.8 Frequent re-evaluation of plan

There must be frequent re-evaluation of any plan adopted, to ensure that ineffective or counter-productive strategies are quickly recognised; the plan must be flexible to allow for fast correction of such errors, where they are recognised. Movement control, for example, can greatly fetter the industry, and may be a useless impediment. Movement controls within each island are not going to work. The mite is already ahead of the survey.

APPENDIX 1 - FORM SUBMISSION SENT BY 51 PEOPLE

SUBMISSION

Page 1 of 3

To: MAF Biosecurity Authority
PO Box 2526
Wellington
Attn: Lucy Martinez
Email: Martinezl@maf.govt.nz

Copied to:

VARROA MITE : ERADICATION VS CONTROL

I/We ___________________________, ______________________
(Name[s]) (Occupation)

of ____________________________
(Town/city)

SUPPORT in principle MAF's plan to eradicate the varroa mite from New Zealand.

I/We DO NOT SUPPORT any of the options included in MAF's plan to control the varroa mite in New Zealand.

SPECIFIC COMMENTS:

1) Firstly, beekeepers are not stupid! They are practical people who make a living from a healthy, vibrant beekeeping business. That is why they support MAF's Eradication Plan, because it is a practical, cost effective solution which best ensures the long term well being of New Zealand's beekeeping industry.

2) I/We am/are under NO illusion that someone can wave a magic wand and make varroa mites decamp beehives, en masse, overnight. It will require a concentrated effort in the Infested Zone for the first year to eradicate all bees from registered/managed hives, and to carry out a poison baiting programme for unregistered/feral hives. It will require an extensive, on-going surveillance programme to detect recurrences inside the Infested Zone and "blips" outside. It will require on-going, but diminishing eradication of "blips" as/when they occur. MAF's Eradication Plan calculates for at least a four year duration to total annihilation of varroa inside and around the Infested Zone.

Varroa is like cancer, we wouldn't wish it on our worst enemy. Some suggest chemical treatments (eg. Apistan); but like chemotherapy to a cancer patient, it reduces the symptom but inflicts pain over a longer period. And besides, the end result is still the same. Overseas beekeepers tell horrifying stories of living with varroa in "do nothing" and controlled environments. They encourage New Zealand beekeepers to break the cycle of despair and do everything to reinstate our varroa-free status.

2) The cost of an ongoing Eradication Plan is $56 million over a FOUR year period. That is to say: Year 1 = $31 million, Year 2 = $13 million, Year 3 = $6 million, Year 4 = $6 million. I/We believe it is money well spent. It is substantially less than the $87 million allocated to the Arts in the recent Budget, and should be seen as an insurance policy to maintain the good health and well being of industries which underpin the viability of the New Zealand economy; namely, beekeeping, kiwifruit, apples, pears & other pipfruit, stonefruit, foodstuffs such as honey & jams, clover & other pasture grasses for dairying, meat & wool, seed cropping and a host of other ancillary industries. One third of the horticulture industry's $2.2 billion annual contribution will be placed directly at risk if we have to live with varroa. Over the life of the Eradication Plan, horticulture alone will be spared that risk (from pollination) and can continue to generate safely $3,000 million for our economy (750 million x 4 years). In addition, the wellbeing of New Zealand's primary industries is pivotal to regional development, and creates substantial downstream employment through a financial sector rule of thumb: " ONE primary sector job creates FOUR industrial, commercial & service sector jobs." Living with varroa, for the sake of a meagre $56 million, will put all this at risk.

3) It should not be forgotten that 75% of New Zealand's beekeeping industry will continue to function in its traditional, efficient manner under an Eradication Plan. In fact it will prosper by supplying replacement bees to the Infestation Zone and making up any minor shortfalls in honey, bee pollen, propolis & royal jelly. 75% of our industry equates to total domestic demand for honey, and packers report adequate stores created by several years of overproduction to meet ongoing retail pack exports (approx. 650 tonnes/annum). The only area of shortfall will be in bulk exports (300kg drums) which is generally the low returning, commodity priced end of the product spectrum anyway.

4) We will only get ONE chance to eradicate varroa, and the longer we leave it the more it will cost. New Zealand's unique geography as a relatively remote island nation lends itself to eradication. Czechoslovakia tried an eradication programme but its continental location facilitated waves of mites crossing the border continuously from its not-so-vigilant neighbours. The topography of our Infestation Zone is mainly flat to rolling and readily accessible, which makes any eradication work easier.

5) Globalisation had increased imports to New Zealand exponentially over the last 20 years. On the other hand border control effectiveness to ward off exotic pests had declined significantly. This has been highlighted in recent months/years by such cases as: varroa, snakes, tussock moth, calisi virus, paper wasps, Australian mosquitos, and a host of others. Any attempt to prevent and/or eradicate exotic pests must also be met by government supplying adequate resources to our border control services. It is in the overall, long term national interest to see their effectiveness outpace any increase in imports, NOT vice versa.

If we do not implement an Eradication Plan for varroa the prospects are frightening. Some obvious concerns are:

6) Many countries afflicted with varroa have economies with a large industrial base. New Zealand is almost entirely agriculturally based and does not have an industrial "safety net" to rely on when things go wrong. If we opt to live with varroa there is NO turning back.

7) Disease control experts say we have an 80-90% chance of success with an Eradication Plan, so it is surely worthwhile trying. At best we have achieved a milestone in history, at worst we have still left our options open.

8) With no eradication programme organic honey will be lost forever, there will be serious chemical residue concerns from honey, bee pollen, propolis & royal jelly customers, and New Zealand's "clean, green" image will receive a serious setback which may have flow on effects to other primary industries.

9) With no eradication programme there will not be enough hives for pollination long term. Overseas experience shows that (post-varroa) the honey bee can only survive in hives managed by humans (albeit with difficulty). Feral hives become a thing of the past, and large tracts of the New Zealand countryside will be without bees.

If their are no feral colonies and fewer managed hives, costs will rise to a level which makes New Zealand's vibrant seed crop industry (among others) uncompetitive with Australia. The industry will then be transposed to Australia where bees are plentiful. This will result in lost New Zealand jobs in the agricultural sector, with flow on job losses (4X) in the manufacturing, commercial & service sectors.

9) With no eradication programme varroa will become immune to the miticides commonly used and recommended under MAF's Control Plan. This phenomenon is already causing major headaches for overseas beekeeping industries; and in New Zealand we only have to look at parallel problems surrounding the calisi virus and the onion beetle.

10) Questions have been raised about beekeeper compliance to an eradication programme, and yet the overwhelming support shown by beekeepers to MAF's Eradication Plan counters such logic. As long as beekeepers in the Infestation Zone perceive they are being treated in the spirit of the Biosecurity Act and are left "in no better or worse position than any person who is not directly affected" by varroa, the eradication programme should progress smoothly. It should also be said that a fair and adequate level of compensation will go a long way to cementing in such compliance.

Conversely, it could be argued lack of compliance would create more serious setbacks for any of the Control options, which the majority of beekeepers oppose. In a worst case scenario, some of the more errant beekeepers may exhibit behaviour akin to someone knowing they are HIV+ but having unprotected sex anyway. They could become despondent/desperate from weakening hives and may feel little responsibility of passing their varroa problem onto a neighbouring beekeeper.

SIGNED: DATE:


Home     NZ Bkpg     Bee Diseases     Organisation     Information     Contacts

, webmaster of the site...
© 2002, NZ Beekeeping Site.