Dear National Institute of Water and Atmospheric Research Limited,

I previously asked Landcare Research some questions about testing for fluorocitrate (a metabolite of 1080) and its potential adverse effects on algae and nitrogen fixation (Gallon et. al article), given that Predator Free 2050 intends to use more 1080 and the ZIP method involves double bait sowing.

Since then, I have had further conversations with scientists in NZ and overseas and have compiled some additional questions.

Richard Gordon at Landcare Research stated that the concentration of 1080 used in Gallon et al. (1978) was above any measured concentration in NZ water samples. He also stated that Landcare Research does not test for fluorocitrate because of inadequate funding and insufficient demand for the test. (NB. New Zealand currently uses approximately 80% of the world supply of 1080).

However information from the ERMA reassessment of 1080 indicates that the measured concentrations in water samples in NZ may not reflect actual concentrations, as follows:

“it is essential that the issue of stability of 1080 in stored samples is resolved...the results must be disseminated to all laboratories that undertake 1080 analyses.” (ERMA Committee Decision p. 119; this research had still not been carried out by late 2015 (Dr P. Fisher, Landcare Research).

“Loss of 1080 from soil stored at -20oC was identified in a Landcare report...(2003)...the Agency sought clarification from Landcare Research...their response highlights the uncertainty around the loss of 1080 from stored samples and suggests that concentrations of 1080 in such samples may have been under-reported” (ERMA Agency, page 350)

“The accuracy of results from other laboratories may be similarly uncertain, with details of sample collection and storage similarly absent from the published literature” (page 350)

“The timing of sampling [of environmental media] relative to an operation and the storage of samples before analysis is critical to interpretation of the results of monitoring” (p 467)

“In relation to environmental monitoring, the Agency notes the concerns about storage [e.g.] Eason...refers to water samples being frozen “within 5 hours” of collection, which seems a…long period before appropriate storage” (p 472).

Furthermore measured concentrations in NZ water samples may only pertain to streams and rivers. Aquatic species also live in relatively still water for instance in wetlands, ponds, dense weed beds, deep pools in rivers, mountain tarns and lakes.

Aquatic organisms have shown sensitivity to 1080 at low concentrations and a lack of robust studies on these organisms was highlighted in the ERMA reassessment of 1080 in 2007, as follows:
“Data gaps…Toxicity to...aquatic invertebrate species given the high toxicity to mosquito larvae” (ERMA Agency Appendix C, page 349.)
“Mosquito larva..48 hours [test]..15% mortality at 0.025 mg/L..40% mortality at 0.05 mg/L..65% mortality at 0.1 mg/L” (ERMA Agency Appendix C, page 361.)
“there is significant uncertainty regarding the aquatic classification of 1080 due to the quality of the data available. None of the aquatic plant studies has been conducted to current international standards” (Appendix C, page 360.)
“the Agency was not able to locate, any data on the aquatic toxicity of the metabolite fluorocitrate” (Appendix C, page 360.)
“Blue-green algae..toxicity threshold 0.4 μg/l” (Appendix C, page 361.)
“73% reduction in frond growth rate [in duckweed] at 0.5 mg/L” (Appendix C, page 362.)
“the responses of plants to 1080 are highly variable. Some synthesise and hyper-accumulate the substance” (Appendix C, page 383.)
“three different species of duckweed..proved..sensitive to [1080]..the frond multiplication rates being halved by 0.5mM [1080]..duckweeds could be used as a sensitive bioassay system” (Bong et al., 1980) (Applicants’ References , page 18)
"The sensitivity of a species to 1080 poison is difficult to predict from toxicity data from other, closely related species" (McIlroy 1986) (Applicants’ References, page 119.)

Please can you tell me:
a. What level of confidence do you have in the historic water sampling results from routine monitoring in NZ?
b. Should water monitoring and sampling follow the Landcare Research protocol, which includes a recommendation to test water at 5-8 hours, because this is the time that 1080 is most likely to be detected? (Note: Most pest control agencies only test water at 24 hours)
c. Are concentrations of toxin introduced by 1080 baits likely to be higher and more persistent in relatively still water environments, than in rivers?
d. Are the measured concentrations in NZ water samples you have referred to from streams and rivers (rather than relatively still water environments)?
e. What has been documented (researched or proposed) regarding effects of 1080 baits in relatively still water environments?
f. Given that the few studies that have been carried out show that aquatic plants and invertebrates are sensitive to 1080 poison, what effects are likely when baits land in relatively still water environments?
g. When aquatic plants and aquatic organisms metabolise 1080 to fluorocitrate is this likely to poison up the food chain (eg snails, fish)?
h. Is 1080 likely to enter aquifers?
i. What monitoring of 1080 in aquifers been carried out?
j. How are modern practices (including not avoiding waterways and double bait sowing under the new ZIP method (ZIP, 2017)) likely to affect levels in water?
k. How might the double bait sowing under the ZIP method affect aquatic invertebrates/zooplankton?
l. What research has been done to assess risk in terms of a reduced aquatic invertebrate population causing algal growth to go unchecked? (This was a question from a professor at Swansea University in the UK) .
m. And one final question, which is unrelated to the others, what research has been done on the production of fluoro-methane in the biodegradation process and has this been calculated in a risk assessment connected with increased use of sodium fluoroacetate in the Predator Free 2050 programme (especially with the double bait sowing method of ZIP)?

References

ERMA Reassessment 2007. Environmental Risk Management Authority's reassessment of 1080, 2007, Application HRE05002.

Gallon et al. 1978. Fluoroacetate metabolism in gloeocapsa sp. LB795 and its relationship to acetylene reduction (nitrogen fixation). Journal of General Microbiology 106, 329-336. University College of Swansea.

ZIP 2017. http://zip.org.nz/findings/2017/11/1080-...

Many thanks for your attention to these questions.

Yours faithfully,

Kathy White

Waikato Regional Councillor for Taupo-Rotorua
Chair, Environmental and Services Performance Committee (WRC)