Previously known as Physicians and Scientists for Responsible Genetics PSRGNZ - Charitable Trust
As required under the new 2005 Charities Act, PSGR has reregistered as a charitable trust.


17 September 2012


Mary-Anne Macleod CEO and Councillors

Bay of Plenty Regional Council

5 Quay Street

PO Box 364



Dear Madam and Councillors

The Trustees and Members of PSGR thank the Bay of Plenty Regional Council for making a bold statement in favour of a precautionary approach to genetically engineered/modified organisms and nanotechnology.  With genetic engineering, this particularly applies in respect of placement and location, and appropriate containment facilities and oversight.

Regrettably, research establishments have not generally shown an appropriate level of duty of care with transgene experimentation outside of the laboratory; these facts well publicised by the New Zealand media.  Such shortcomings potentially threaten the human and physical environment, and leave accountability, liability and costs to be met by councils and ratepayers.  Much of the research for which genetic engineering technology is used can be safely carried out using conventional methods such as selective breeding and marker assisted breeding, and also in alternative medical applications.


While government has established the Hazardous Substances and New Organisms Act, and the Environmental Protection Agency, there is a large body of scientific and public opinion in New Zealand that finds they fall short of what is required.  This same body suggests vested interest has shown in the past to have sway on decisions, at times without sufficient public input.

There is a growing amount of substantive material to provide reasons for the application of a precautionary approach.  We attach various references for your information.

In context of the incomplete scientific understanding of the significant risks of genetically engineered organisms, the council policy of precaution is to be considered a vital form of insurance for the local community.  The risks arising from commercial pressures to exploit transgenic organisms must not be forced on communities, local ratepayers or the environment.

The Trustees of Physicians and Scientists for Global Responsibility

Further relevant material:

Genetic engineering

The Executive Summary in GMO Myths and Truths, An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops says transgenic crops are promoted on the premise of false claims and it catalogues over 123 pages of detailed research.  Scientific and other authoritative evidence is increasingly confirming what many have claimed virtually since their introduction, that transgenic crops do not live up to their PR-promoted reputation.

Proponents of genetic engineering claim the technology is precise and host plants experience no unexpected effects.  Yet it is established that a single change in DNA can give rise to multiple changes within the organism.  Pleiotropic effects[1] occur because genes are not isolated units, they interact with one another.  Closing in on two decades after the first commercial releases, the process of genetically engineering gene/s into host DNA is still “crude, uncontrolled, and imprecise, and causes mutations – heritable changes – in the plant’s DNA blueprint.  These mutations can alter the functioning of the natural genes of the plant in unpredictable and potentially harmful ways.”

We refer you to Antoniou, Robinson and Fagan, Earth Open Source June 2012,

*See interviews with US farmers who decided to plant transgenic crops.  Hear of their experience after growing them - (24 min).



Transgenic trees


PSGR website Frequently Asked Questions, Key phrase ‘Genetic engineering and trees’,


A study released in 2012, looking at insect-resistant transgenic trees, concluded that the realized benefits in terms of yield were not reached.  An example given was, “one species . . . the leaf rolling beetle B. populi (Coleoptera) is utilizing the insect-resistant plants for oviposition[2] and feeding seemingly to a similar degree as the un-modified Wt.”

‘Performance of insect-resistant Bacillus thuringiensis (Bt)-expressing aspens under semi-natural field conditions including natural herbivory in Sweden’, E Petter Axelsson, Joakim Hjältén, Carri J LeRoy,

Geneticist, Dr David Suzuki speaks:  A Silent Forest.  The Growing Threat, Genetically Engineered Trees (Runs 46.13 min) on


Transgenes established in weed species, grasses and feral crop plants:


Gene flow via seed or pollen is a basic biological principle of plant evolution.  Gene flow also occurs through vehicle and foot traffic, weather and animals.  A study reads:  “Ecological risks associated with the release of transgenic crops include non-target effects of the crop and the escape of transgenes into wild populations.”

‘Ecological effects of transgenic crops and the escape of transgenes into wild populations’, Pilson and Prendeville,

Weed species:

Transgenes have jumped from genetically engineered crops to weed species creating what has been termed ‘super’ weeds.  Australia’s annual bill for superweed damage to agriculture and the environment is reportedly AUD$4 billion.

‘Adaptive evolution in invasive species’, Trends in Plant Science, Prentis et al, 13:6, June 2008, pp 288–294,;

‘Stop the superweeds: Adelaide biologist,’ 6 April 2009, Independent Weekly,


‘Do escaped transgenes persist in nature?  The case of an herbicide resistance transgene in a weedy Brassica rapa population.’ S I Warwick, A Legere, M-J Simard and T James,

‘Hybridisation between Brassica napus and B. rapa on a National Scale in the United Kingdom’, M N Wilkinson et al, Science, 9 October 2003,

‘Resistance to HPPD-inhibiting herbicides in a population of waterhemp (Amaranthus tuberculatus) from Illinois, United States’, Hausman NE et al, Pest Manag Sci. 2011 Mar;67(3):258-61. doi: 10.1002/ps.2100. Epub 2011 Jan 26.

Pasture and other grasses:

New Zealand ryegrass seed is well-proven worldwide and meets a substantial percentage of global demand.  Establishing genetically engineered ryegrass in pastures as is proposed would potentially lead to transgenes contaminating conventional ryegrass and adverse effects on this substantial established market.  Within a short time of the introduction of genetically engineered crops in Australia, Australian ryegrass was contaminated with herbicide-resistant transgenes; a fact confirmed by Monsanto, creator of the transgenes (

A New Scientist review found plants of transgenic glyphosate-resistant creeping bentgrass as far as 3.8 km from the edge of a control area containing trials of the grass, commonly used on golf courses (9 August 2006,

‘Spread of herbicide-resistance from genetically modified creeping bentgrass into the wild’, The Nature Institute, 2008,


Feral crop (wild) transgenic plants:

Since 2005, GeneWatch UK and Greenpeace International have maintained a Contamination Register of publically documented incidents of intentional or accidental release of transgenic organisms, including illegal plantings of transgenic crops, and contaminated foodstuffs on

Transgenic plants revolve around a limited number of varieties and the supply of seed for traditional varieties has become threatened (see * above).  Gene banks have been established to counter this threat to crop biodiversity.

‘Vertical Trans(gene) Flow:  Implications for Crop Diversity and Wild Relatives’, by David Quist, Third World Network, 2010,

In May 2012, transgenic canola/oilseed rape was found growing in the port area of Basel, Switzerland.  It is suspected seed was spilled during transit on barges or trains.  Of the 136 canola plants Greenpeace Switzerland had tested, 29 were found positive for Monsanto´s herbicide-tolerant canola, GT73 (also called RT73).  Feral transgenic canola was discovered in Japanese ports in 2005.

In North Dakota, feral canola shows transgenic plants have escaped from crop fields and/or in transit.  In one study of 288 plants tested, 231 (80%) “expressed at least one transgene”; 112 (39%) were positive for PAT/glufosinate resistance; 2 (0.7%) were “a phenotype[3] not produced by seed companies”. offers a map of the ‘Distribution and density of feral canola populations in North Dakota road surveys’ (2010).;

‘The Establishment of Genetically Engineered Canola Populations in the US’, Meredith G Schafer et al,;;

A Swedish study found transgenic canola seed could survive in the wild and remain viable even ten years after release.

‘Long-term persistence of GM oilseed rape in the seedbank’, D'Hertefeldt T et al, Biol Lett. 2008 June 23; 4(3): 314–317.



Cloned and transgenic animals

A 2007 report from scientists at Lincoln University found introducing transgenic organisms into our dairy sector “has a potential to cause a minimum of NZ$539.6 million in losses to the dairy and tourism industries” if unsuccessful.  ‘Biopharming’ would need to offset losses before being positive for our economy.

'The Social Implications of Animal Biopharming in New Zealand'

We also refer you to our previous correspondence on the activities of AgResearch, of their statement that they would not reveal where their cloned and genetically engineered stock are held outside of Ruakura, and the effects of transgenic animals on the environment, in terms of their waste matter, ground water contamination, and on soil biota, etc.


A recent study has established that manufactured nano-materials can enter soil and be taken up by plants.

‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012






[1] Producing more than one effect

[2] Oviposition is the process of laying eggs by oviparous (egg-laying) animals

[3] A phenotype is the observable physical or biochemical characteristics of an organism, resulting from the expression of an organism's genes, the influence of environmental factors, and the interactions between the two.