2014 Appendices to letter to all New Zealand MPs 20 November 2014

Appendix 1 - Further information

Genetic engineering

The application of genetic engineering technology alters the DNA of a living organism in ways which are much more radical than what occurs due to the generally incremental, slow processes of natural evolution. It does this in a way that is inevitably disruptive to some degree as a result of the essentially random insertion of transgenic (or cisgenic) DNA into the functional DNA of a host organism. It may cause noticeable changes in the appearance of the organism and/or differences in the biochemistry and physiology of the organism. These changes are unpredictable and may result in the production of new proteins within the transgenic organism with potential toxic effects,

When transgenic organisms are released into the environment transgenes can be transferred to other organisms so that the engineered characteristics spread through the eco-system. Farmers in the US face having to eradicate weed species that have developed herbicide-resistant traits, including some with resistance to multiple herbicides. These so-named ‘superweeds’ can grow aggressively and out-compete transgenic crops, and now infest large tracts of agricultural land. The over-application of herbicides and pesticides to transgenic crops has increased substantially the volume of agricultural chemicals used and this has aided in the development of weeds resistant to those chemicals.

Weeds cost Australia over AUD$4 billion/p.a. in control and lost production.[1] Wild radish (Raphanus raphanistrum) costs the Australian grain industry AUD$140 million/p.a.[2] Britain’s advisory committee on releases to the environment (ACRE) identified wild radish, wild turnip, hoary mustard, brown mustard and wild cabbage as species from which hybrids could be formed with transgenic canola/ rapeseed varieties. In one field trial plot, 46% of seeds in a wild turnip plant were contaminated with transgenic DNA.[3] N.B. Wild radish, wild turnip and wild cabbage grow in New Zealand.

Transgenic crops are now being released to resist 2,4-D (an ingredient in Agent Orange), dicamba (a herbicide in the 2,4-D family), HPPD-inhibiting herbicides, and glyphosate and AL (GAT).[4] Scientists confirm transfer to weeds and other species of this novel DNA is inevitable.

Industry claims transgenic crops benefit farmers. A film released in October 2013 shows a study on the socio-economic impacts of transgenic corn on the lives and livelihoods of US farmers after over 10 years of commercial growing. Farmers explain how they became indebted because of the rising cost of transgenic seed and the increasing cost and quantity of inputs such as herbicides being used.[5]

The International Assessment of Agricultural Knowledge, Science and Technology for Development (IASSTD) is a large, comprehensive UN study. It supports the thesis that transgenic crops could threaten food security.[6]

Genetic engineering in New Zealand - genetically engineered trees

Of concern to PSGR was the approval[7] for the New Zealand Forest Research Institute, trading as Scion, to plant pinus radiata with a number of engineered traits. The premise was that the trees would largely be engineered using what is commonly termed ‘terminator’ technology, making them sterile, i.e. not able to flower or replicate.

The variants of terminator technology offer no absolute guarantee of sterility. The traits can break down and the trees revert to flowering. Genes can spread horizontally in soil bacteria, fungi and other organisms in the extensive root system of forest trees. There could be long-term impacts on soil biota and fertility.

Trees that do not flower and fruit cannot provide food for the organisms that feed on pollen, nectar, seed and fruit; thus essential pollinating insects may not be available, especially for beekeepers, horticulturalists and crop growers.

Herbicide-resistant pines could lead to wilding pines becoming ‘super’ weeds; wilding pines being invasive in many parts of New Zealand. Conventional pinus radiata seeds have been found viable “at least up to twenty-four years”[8] and distance is no guarantee of safety from contamination. Singh el al (1993)[9] found pollen from pine trees had travelled over 600 kilometres.

It would need a failure rate of only a part of a percent for transgenes in tree pollen to contaminate other trees, potentially at great distances, in ways that could not easily be monitored.

The risks of releasing transgenic DNA are environmental and economic. Terminator technology has attracted a voluntary moratorium from many countries because of the risks involved. The effect on New Zealand’s reputation overseas and our export markets would be damaging.

Genetic engineering in New Zealand - proposed introduction of transgenic rye grass

New Zealand scientists are running experiments with transgenic rye grass in the US and Dr Michael Dunbier of AgResearch has said there are also plans to hold trials in Australia. He claims the benefits of transgenic grasses are “outweighed by the potential negative responses”. Confusion has entered the debate by the use of the term "cisgenic"; a form of genetic engineering that uses genes from a single species.[10] The key question is, are there potential benefits of the technology?

Ryegrass (Lolium rigidum) is a problematic weed in Australia. The country’s first glyphosate-resistant weed was annual ryegrass which emerged in 1996.[11] Commercial herbicide-resistant cotton was first grown there in 1996 and may have contributed. Glyphosate is the active ingredient in Monsanto’s herbicide, Roundup.

The Department of Primary Industries in the State of Victoria has published an overview of baseline biological information relevant to the risk assessment of genetically engineered forms of ryegrass species that may be released into the Australian environment.[12]

It states that Italian ryegrass, perennial ryegrass and tall fescue are “highly outcrossing, wind pollinated species”. Extensive gene flow can occur of viable and non-viable material, and dispersal of pollen can be “forward, backward and upward”. Pollen clouds can rise high into the atmosphere, move with wind patterns and be re-deposited in times of calm weather. It is conceivable that pollen could move significant distances from the source, and studies have shown that the amount of pollen dispersed/deposited does not always decrease with increasing distance from a source.

Grass seeds are capable of germination after passing through the digestive systems of grazing animals. Viable seeds of perennial ryegrass, Italian ryegrass and tall fescue have been recovered from faeces 12-24 hours after feeding. Seeds of Italian and perennial ryegrass were found transported in sheep wool, the perennial ryegrass seeds still found after 1-2 months. Moving stock would increase the risk of spreading contaminated material. Viable Italian ryegrass seeds have been found in the faeces of European hares showing wild animals also assist in seed dispersal, as do birds, irrigation water and human activity.

Perennial ryegrass seed persists in soil, the length of dormancy varying. A study in NSW of tall fescue and perennial ryegrass indicated 14 months after seed production that the seed bank contained 14% of perennial ryegrass and 10% of tall fescue seed released. Under controlled conditions, seeds of tall fescue and Italian ryegrass maintained germination ability for at least 12 months, with the percentage dropping off after five years for Italian ryegrass seed.

The researchers found that the likelihood of weediness is increased by the intentional introduction of plants. Lolium species have many weedy characteristics and are capable of adapting rapidly to their environment, producing large amounts of seed which are easily dispersed. Italian ryegrass, perennial ryegrass and tall fescue are listed as weeds in native and agricultural ecosystems throughout Australia.

The ryegrasses in general are significant weeds among wheat crops worldwide. Italian ryegrass can be a difficult-to-control contaminant in turf-grass farms and causes decreased marketability of cool-season sod. Volunteer tall fescue growing near certified seed production enterprises requires control measures to prevent contamination of the seed. The ryegrasses and tall fescue occur as typical weed species in riparian zones in rural and urban areas of Australia: e.g. along waterways and wetlands, on floodplains, roadsides and public areas.

Gene flow is a natural phenomenon not unique to transgenic crops. It can occur via pollen, seed and vegetative propagules. Gene flow from transgenic glyphosate-resistant crops can result in the presence of the transgene entering the DNA of other crops or weeds, which may negatively impact markets. Gene flow can also produce glyphosate-resistant plants that may interfere with weed management systems.”[13]

Gene flow via pollen and seed from glyphosate-resistant canola and creeping bentgrass fields is documented and the presence of the transgene responsible for glyphosate resistance has been found in commercial seed lots of canola, corn and soybeans.

When a weed crossbreeds with a farm-cultivated relative and acquires new genetic traits – including engineered DNA that make it more hardy – the hybrid weed can pass the traits on to future generations. The result may be very hardy, hard-to-kill weeds. Farmers in the US have seen the significant impact of transgenic DNA outcrossing to weed species and contaminating large tracts of land.

New Zealand does not need transgenic pasture grasses contaminating agricultural land.

Field trial sites of transgenic canola in Tasmania

Monsanto Australia and Aventis (now Bayer CropScience) conducted field trials of transgenic canola in Tasmania in the late 1990s and in 2000. In 2001, the Tasmanian Government decided to pursue agriculture free of genetically engineered organisms.

The Office of the Gene Technology Regulator advises canola seeds can be viable for up to 16 years.[14] A Swedish study found transgenic canola seed can remain viable in the wild even 10 years after release, confirming Tasmania’s experience.[15] Management issues of the 57 sites included seed persistence. Consequently, regular audits of sites have taken place. In May 2013, 53 sites were inspected, four having canola volunteers. In 2008, volunteers were found at twelve of the 53 sites,[16] twelve different sites to the 2013 audit. The most recent audit (May 2014) showed volunteer canola plants at three former trial sites.[17] Over half the 2013 sites had not involved recent soil disturbance and it is acknowledged that these will have dormant canola seed in the soil that will not germinate until soil disturbance takes place. During audits, nearby roadsides and other areas are inspected to ensure containment is being achieved. This management protocol has been strengthened with a recent decision for an indefinite moratorium on the release of transgenic organisms into the environment to protect Tasmania’s brand and export economy.[18]

Australian farmers growing conventional canola regularly secure a higher price for their crops. A list of countries that ban transgenic crops and require food labelling for any transgenic element can be found on http://naturalrevolution.org/list-of-countries-that-ban-gmo-crops-and-require-ge-food-labels/.

Genetically engineered crops vs non-transgenic crops

US farmers growing transgenic corn say they now face a future of lower prices and higher inputs. The trend is to abandon transgenic seed because non-GE crops are more productive and profitable.[19]

Key markets want foods free of novel DNA, requirements driven by the demands of well-informed and discerning consumers from China, Japan, Europe, the US and elsewhere.

The global market for foods and beverages produced without the use of any transgenic ingredients has led many leading international food companies such as Unilever, Nestlé, and Coca-Cola to introduce or be developing non-GE versions of their products to meet the demands of consumers who do not want transgenes in their food.[20] Global sales of non-GE food and beverage products are predicted to double to US$800 billion by 2017.[21]

US farmers are using more hazardous pesticides to fight weeds

Dr Charles Benbrook is a research professor at the Centre for Sustaining Agriculture and Natural Resources at Washington State University. In a recent study, he found genetically engineered crops have led to an increase in overall pesticide use by 404 million pounds from the time they were introduced in 1996 through to 2011. This has aided in the appearance of the so called ‘superweeds’:

“Contrary to often-repeated claims that today’s genetically-engineered crops have, and are reducing pesticide use, the spread of glyphosate-resistant weeds in herbicide-resistant weed management systems has brought about substantial increases in the number and volume of herbicides applied. If new genetically engineered forms of corn and soybeans tolerant of 2,4-D are approved, the volume of 2,4-D sprayed could drive herbicide usage upward by another approximate 50%.”[22]

This is supported in New Zealand by the discovery of the first ‘superweeds’ caused by the over application of the herbicide, glyphosate.[23]

The Australian government has committed AUD$15.3 million over four years to establish a comprehensive National Weeds and Productivity Research Programme to reduce the impact of invasive plants such as weeds contaminated with novel DNA.[24]

Transgenic commercial crops

Scientists cannot easily quantify the exact effect/s novel organisms will have when released into the environment; each may differ to the next. Genes move naturally within a species, by seed dispersal and pollination, a basic biological principle of plant evolution facilitated by insects, wind, animals, humans and other factors. The ecological risks in releasing transgenic plants include non-target effects of the crop and transgenic DNA escaping into wild populations.[25]

The loss of genetic diversity is an acknowledged fact in commercially important crops. Despite crops being bred for superior resistance the current practice of genetic uniformity and monoculture increases the possibility of pests and diseases evolving to overcome a host plant’s resistance.

With a large proportion of transgenic crops being glyphosate-resistant, US Department of Agriculture (USDA) data show glyphosate-based herbicide use increased 6,504% between 1991 and 2010.[26] In a survey of growers, Farm Chemicals International confirmed[27]:

· 61.2 million US crop acres have glyphosate-resistant weeds, nearly double the 2010 number;

· 49% of growers had glyphosate-resistant weeds on farms in 2012, up from 34% in 2011;

· 92% of growers in Georgia have glyphosate-resistant weeds;

· from 2011 to 2012 the acres with resistance almost doubled in Nebraska, Iowa and Indiana;

· total resistant acres increased by 25% in 2011 and 51% in 2012;

· more farms had at least two resistant species on their farm - in 2010 12%, in 2012 27%.

Herbicide-resistance is not confined to glyphosate-based herbicides. See the International Survey of Herbicide Resistant Weeds site[28] for details on resistant weeds. One study predicts total herbicide use in the US will rise from around 1.5 kilograms per hectare in 2013 to more than 3.5 kilograms per hectare in 2025 as a direct result of growing transgenic crops, and that the new technologies will also lose their effectiveness.[29] The increase in herbicide-resistant weeds species has led to the development of GE crops, and weeds, that are resistant to more toxic herbicides such as 2,4-D. With the increases in vineyards in this country, confining the areas in which hormonal herbicides such as 2,4-D can be used, the development of glyphosate-resistance here would be particularly problematic for growers of transgenic crops.

In August 2012, conventional farmer, Bob Mackley, spoke in New Zealand about transgenic crops and their effects in his native Australia. He reported that many farmers have suffered significant losses as a result of transgene contamination of their conventional crops, and legislation favours seed companies, not farmers. Legally without the means to protect his livelihood, Mackley has been forced to time his plantings to avoid contamination from transgenic crops grown by a neighbour. His is a critical balance between profit or contamination and loss.

There already exist effective, sustainable solutions to the problems that this novel technology claims to address. Conventional plant breeding, helped by safe modern technologies like gene mapping and marker assisted selection, continues to outperform genetically engineered crops in producing high-yield, drought-tolerant, and pest- and disease-resistant plants that can meet present and future food needs.[30]

Genetically engineered crops and human health

Consumers in the US have been ingesting significant quantities of foods containing novel DNA since the introduction of transgenic crops on a commercial basis in the mid 1990s.

About 94% of US soybean farmers and 72% of corn farmers use Roundup Ready (glyphosate-resistant) crops. Soy and corn go into a substantial range of food products, along with transgenic canola and cottonseed.[31]

In addition, animals fed glyphosate-resistant crops bio-accumulate[32] glyphosate and/or glyphosate metabolites, adding to the human end user intake. Glyphosate-resistant transgenic crops represent a large percentage of the transgenic seed market. For example, in 2009, in the US alone, nearly 93 percent of soybeans and 80 percent of corn came from Monsanto’s transgenic seeds.[33] Monsanto reportedly controls 85% of the GE seed market and a major percentage of that seed will be glyphosate-resistant.

A 2013 study detected glyphosate in 43.9 percent of human urine samples taken from participants living in urban areas in 18 European countries.[34] [35] When diets favoured organic produce humans excreted significantly less glyphosate. The levels in urine of generally healthy humans were significantly lower than levels in a comparative chronically diseased population.

Chronic diseases, in official US figures, have been increasing in step with increased use of glyphosate-tolerant crops.[36] The negative impacts of glyphosate ingestion on humans manifest slowly over time by damaging cellular systems, playing a part in most common diseases and conditions allied with a Western diet, including gastrointestinal disorders, obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.[37]

In the 1970s, glyphosate was identified as a chelator of minerals, a compound that combines with other minerals making them available only under certain conditions. Recent studies indicate plant uptake systems are susceptible to the chelating effects of glyphosate[38] which will affect the quality of crops and grasses, as well as making them more susceptible to pathogens.

One study[39] hypothesizes glyphosate mixed with hard water forms a complex with heavy metals like cadmium, resulting in its accumulation in the body. The study proposed a link between chronic kidney disease and glyphosate. Chronic kidney disease of unknown origin (CKDu) is increasingly common in poor farming communities in some developing countries. Identified in the mid-1990s, CKDu is estimated to afflict 15% of working age people in northern Sri Lanka alone: 400,000 patients with an estimated death toll of 20,000.

There remains no official monitoring of effects on the human population and consumers have no official notification of the risks related to commercial transgenic crops. With US consumers increasingly growing aware of the potential results of ingesting transgenic DNA, the fastest growing sector in its grocery industry is for foods free of transgenes, that sector now estimated to be at close to one third of the market. This is the result of consumer pressure, and from medical professionals recommending foods free of transgenes with consequent improved health for patients.[40] New Zealand is still well-positioned to help meet that demand for GE-free food.

Lack of proof of safety

The 2014 ‘Hot Debate’ at Lincoln University featured six experts representing those proposing and those against the release of into the environment of genetically engineered organisms. Panel members Dr Jon Hickford and Dr Tony Connor, proponents of the technology, stated transgenic foods were safe to eat. They were asked (a) if they could they provide 10 human studies to support this statement, and (b) would they also advise where the diagnostic tools are available for health professionals to identify if transgenic foods in the human diet are contributing or not to illnesses. Drs Hickford and Conner admitted there are no safety studies nor are there any diagnostic tools for monitoring public health impacts of trangenic foods.[41]

In Alliance for Bio-Integrity et al v Shalala (1998) over 44,000 pages of files produced by the US Food and Drug Administration (FDA) at the direction of the Court revealed it had declared genetically engineered foods to be safe despite disagreement from its own experts, and that it falsely claimed a broad scientific consensus supported its stance. Internal reports and memoranda disclosed agency scientists repeatedly cautioned that foods produced through recombinant DNA technology - that is, genetically engineered organisms - entail different risks than do their conventionally produced counterparts and that this was consistently disregarded when FDA policy was written in treating transgenic foods the same as conventional ones.[42]

In taking this stance, the agency violated the US Food, Drug and Cosmetic Act in allowing genetically engineered foods to be marketed without testing on the premise that they are ‘generally recognized as safe’ (GRAS) by qualified experts. The consensus of scientists working for the FDA was that transgenic foods were inherently risky, and might create hard-to-detect allergies, poisons, gene transfer to gut bacteria, new diseases, and nutritional problems. They urged rigorous long-term tests.⁴⁴

After almost two decades of commercial transgenic crops being grown the results to the environment and to consumers unknowingly ingesting transgenes are becoming obvious. The FDA has admitted it operates under a directive “to foster” the US biotech industry.

New Zealand exports

One of New Zealand’s export strengths is being able to guarantee products free of genetically engineered organisms. This assists in increasing exports to markets wanting products free of transgenic DNA and in supplying new markets.

Meat exported from New Zealand has to comply with the standards applying to cadmium levels in liver or kidney, particularly from animals older than three years.[43] Because of the known chelating qualities of glyphosate, growing glyphosate-resistant transgenic crops could increase the cadmium presence in feed, for example. The mineral may currently be present in imported feed and cadmium levels can affect stock grazed on transgenic crop stubble. Currently, transgenic crops are included in the near 200,000 tonnes of animal feed imported into New Zealand annually. These imported feeds are only tested for non-viability of transgenic crops. The reported practice is that loads are largely assessed visually rather than tested in a laboratory. Neither the glyphosate content, nor the other toxic ingredients in glyphosate-based herbicides are tested and MPI confirmed they will not be in the immediate future.

A recent privately tested sample of imported soy meal revealed 3.4 parts per million glyphosate and 1.4 parts per million AMPA[44]. That such feed is not adequately tested or labelled undermines the integrity of the New Zealand food system and consequently its export reputation. Stock fed such feed will ingest any viable transgenes that escape scrutiny, and pesticide residues, and can potentially pass the effects on to humans ingesting their meat or milk products.³

Russia recently announced it will not allow any seed or food containing transgenes into Russia, that the country has the land to grow its own conventional, organic foods. The Technical Expert Panel of India’s Supreme Court has also backed an indefinite moratorium on GEOs. Japan opposes transgenic crops, although canola imported from Canada has led to transgenic volunteers growing wild around Japanese ports and roads leading to major food oil processing companies. Ireland bans all GE crops. Austria, Hungary, Greece, Bulgaria and Luxembourg have bans on the cultivation and sale of GEOs. Germany bans the cultivation or sale of GE maize. In France public demand has successfully kept transgenic crops out of the country. Madeira has a countrywide ban on GE crops. Switzerland banned all GE crops, animals, and plants on its fields and farms in a public referendum in 2005, extended to 2013 and the Swiss Farmers’ Association is asking it to be extended to at least 2017. Californian counties Mendocino, Trinity and Marin have banned GE crops, and a number of US States are working towards at least adequate labelling to give consumers a choice.[45] [46]

Adopting transgenic crops would have negative impacts on New Zealand exports. New Zealand farmers already achieve premiums for non-transgenic food products. They will not receive such premiums for transgenic crops.

Public concerns over genetically engineered organisms

Local government’s responsibility is to work in service to the public interest of present and future generations, encompassing the environmental and social spheres in their regions. The precautionary approach discussed here speaks to this responsibility in regard to new technologies such as the proposal to release genetically engineered organisms into the environment.

Following community requests, the Bay of Plenty Regional Council included a precautionary statement on transgenic organisms in its Proposed Regional Policy Statement, which includes a policy directive to apply a Precautionary Approach to activities that have scientific uncertainty and where there is a serious risk of irreversible adverse effects.

An appeal by the NZ Forest Research Institute, trading as Scion, went to the Environment Court.

The Court’s decision released on 18 December 2013[47] allowed the Regional Council to retain its RPS reference to transgenic organisms. It recognised the community concerns regarding the outdoor use of transgenic organisms. It also indicated in its decision that the Council may propose more directive regulation in the future, including policies, objectives, and methods. These regulations would come as a result of further investigation (via a Section 32 report) showing that transgenic organisms are elevated to a matter of regional significance.

This decision sets a precedent, clearly indicating that the Resource Management Act can be used to manage such activities in the Bay of Plenty region. Communities and industries in the Bay can now work towards the inclusion of stricter rules in their District and City Plans to protect and keep their ‘GE-free’ environment status and marketing advantage.

A legal opinion, given by Dr Roydon Somerville QC, states: ‘Managing Risks Associated with Outdoor Use of Genetically Modified Organisms’ (January 2013). A press release from the Inter-Council Working Party (ICWP) on GMO Risk Evaluation and Management Options[48] addresses some of the issues that Local government needs to consider in regards to the proposed uncontained use of transgenic organisms. A release from the ICWP said: “... there are significant risks to local government and their communities from outdoor use of GMOs, including environmental, economic and socio-cultural risks” and “the potential adverse effects of releasing GMOs into the environment could be significant – including possible major and long term harm. Moreover, these effects could be irreversible.”

Section 1.7 Precautionary approach: The ability to manage activities can be hindered by a lack of understanding about environmental processes and the effects of activities. Therefore, an approach which is precautionary but responsive to increased knowledge is required. It is expected that a precautionary approach would be applied to the management of natural and physical resources wherever there is uncertainty, including scientific, and a threat of serious or irreversible adverse effects on the resource and the built environment. It is important that any activity which exhibits these constraints is identified and managed appropriately. Although those intending to undertake activities seek certainty about what will be required of them, when there is little information as to the likely effects of those activities, public authorities are obliged to consider such activities on a case-by-case basis. Such consideration could be provided for in regional and district plans, through mechanisms such as zoning or rules enabling an assessment of effects through a resource consent process, or through other regulation such as bylaws. Any resource consent granted in such circumstances should be subject to whatever terms and conditions and/or reviews are considered necessary to avoid significant adverse effects on the environment and protect the health and safety of people and communities.

Similar moves are being made in the Northland and Auckland regions and, with the Bay of Plenty, represent close to half of New Zealand’s population.[49]

PSGR strongly endorses a precautionary approach to genetically engineered organisms at all levels of government and regulation.

For accurate information to guide decision-making PSGR recommends the comprehensive analysis of the myths and truths relating to genetically engineered organisms and peer-reviewed studies.[50]

Why New Zealand should remain GE free

In December 2013 a national poll by Colmar Brunton, undertaken for Pure Hawke’s Bay, shows 79% of New Zealanders support Councils being able to use the Resource Management Act (RMA) to protect farmers, exporters and their residents from the long-term unmanaged and unknown risks of genetically engineered organisms. The risks include exposure to increasingly more toxic chemicals.[51] See the ICWP poll on [52].

The UN's science-based International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD) states mixed approaches to agriculture, not transgenic monocultures, are needed to feed future generations. Systems should enhance sustainability and maintain productivity in ways that protect the natural resource base and ecological provisioning of agricultural systems.[53]

Reports from qualified bodies on genetically engineered organisms include New Zealand’s own McGuiness Institute, a privately funded, non-partisan think tank working for New Zealand’s sustainable future, contributing strategic foresight through evidence-based research and policy analysis.[54] Ten years after the moratorium on genetic engineering ended a McGuiness Institute study suggests it is time for it to be reinstated and time for a strategy to benefit the economy as a producer of food free of transgenic DNA for the world market. It found that despite huge investment in experiments on transgenic plants and trees, there has been little benefit and significant economic risk incurred. Protecting the value of New Zealand’s status as a producer of safe, high quality food, is of national strategic importance.

The ‘United Nations Conference on Trade and Development Review 2013 - Make agriculture truly sustainable now for food security in a changing climate’ states[55]: “Developing and developed countries alike need a paradigm shift in agricultural development: from a ‘green revolution’ to a ‘truly ecological intensification’ approach. This implies a rapid and significant shift from conventional, monoculture-based and high external-input-dependent industrial production towards mosaics of sustainable, regenerative production systems that also considerably improve the productivity of small-scale farmers. We need to see a move from a linear to a holistic approach in agricultural management, which recognizes that a farmer is not only a producer of agricultural goods, but also a manager of an agro-ecological system that provides quite a number of public goods and services (e.g. water, soil, landscape, energy, biodiversity, and recreation).”

An evidence-based examination of the claims made for the safety and efficacy of transgenic crops was published in June 2012.[56] See also PSGR website for Frequently Asked Questions on Genetic Engineering and on Glyphosate.[57]

Future agricultural planning

Plant breeding largely favours varieties determined by the vested interest providing funding rather than on end user choice. The current favourite is the development of transgenic food crops, and many of these are food crops resistant to herbicides, especially glyphosate. Important points are that:

(a) Such crops substantially increase the amount of herbicide applied to the crop;

(b) The novel DNA giving herbicide-resistance has transferred to an increasing number of major weed species in areas growing transgenic crops;

(d) Weed species now require more toxic chemicals to achieve eradication.³⁵

Glyphosate-resistance has already been identified in several locations in New Zealand, the cause being given as over application.[58] On the basis of experience overseas, growing transgenic glyphosate-resistant crops would increase that considerably.

Two studies give further evidence-based reasons for New Zealand farmers taking a precautionary approach and not adopting genetically engineered crops and thus releasing novel DNA into the environment, particularly those crops using glyphosate-based herbicides[59]:

· Thirty dairy cows from each of eight Danish dairy farms were investigated and all were found to excrete glyphosate in their urine. The study demonstrated that glyphosate is toxic to the normal metabolism of dairy cows.[60] The likely source of the glyphosate would be animal feed containing transgenic food and/or feed crops, and residual glyphosate from spraying.

(N.B. See page 10 paragraph 2 - glyphosate found in human urine.)

· Glyphosate enhances the growth of aflatoxin-producing fungi, lending an explanation for the substantial increase in fungal toxins now found in corn grown in the US.[61] In 2012, the USDA indicated 88 percent of US corn/maize grown was transgenic, increasing the potential for large areas of corn crops to be affected.[62] Aflatoxins affect grains, oilseeds and tree nuts, among other crops. Contamination of grains by aflatoxins threatens human and livestock health, and international trade. The UN Food and Agriculture Organisation estimates 25% of the world food crops are affected annually. Crop loss due to such contamination costs US producers over US$100 million/year on average.[63] Tate & Lyle, a British maker of sweeteners and starches, has said quality problems with US corn, primarily due to aflatoxin, were forcing changes to the firm’s buying programme.[64]

It is acknowledged that thousands of conventional crop varieties have been lost since the introduction of agrichemicals and monoculture practices, which include genetically engineered food crops.[65] Changes in genetic structure can be long term and affect several generations. No insurer will cover the complex and long-term risks. This fact alone is reason for precaution.

If transgenic crops are introduced into New Zealand, many of our farmers growing premium quality and organic crops stand to lose their livelihoods. There will follow, as it has in other countries, inadvertent contamination of non-transgenic crops and grasses, resulting in extortionist claims from the proprietors of the transgene to be compensated by the farmers for their unwilling and unknowing growing of contaminated crops. Farmers have no legal or insurance protection against this, and the end result can be financial ruin.[66]

Regulation of genetically engineered organisms

Should any approvals be made by the EPA leading to the release of transgenic organisms, PSGR supports the following additional protocols:

Making any outdoor experiments or field trials approved by the EPA a discretionary activity subject to stringent local additional conditions, particularly those not required under the Hazard Substances and New Organisms (HSNO) Act;

Applicants paying a substantial bond and being held fully accountable for any necessary remediation and other costs;

Establishing stringent on-going monitoring of releases by independent scientists. Under the HSNO Act, the EPA ceases to have responsibility or jurisdiction over an approved release of a transgenic organism once that new organism ceases to be considered as such. Little or no further attention or testing by an independent body applies.

Such requirements are needed to protect New Zealand’s –

· Biosecurity

· Unique biodiversity

· Producers and exporters of primary products from agriculture, horticulture, beekeeping, viticulture, silviculture and forestry, and its gardeners

· Food sovereignty

· Heritage seeds

· Growing domestic and export organic industry

· Environment and economy as a whole

· Public health from the proven and potential risks posed by releasing genetically engineered organisms into the environment.

PSGR supports fully contained and supervised use of genetically engineered organisms for the furtherance of science.

PSGR does not gain an advantage in trade competition.

We ask that the foregoing information is taken into account for current and future considerations to manage any potential release of genetically engineered organisms in the New Zealand environment.

It is important consideration of issues of concern at local and national levels extend beyond the timeframes of central government authorities like the Environmental Protection Authority.

In meeting their duty of care, the work undertaken by local Councils on behalf of farmers and other ratepayers and residents in their region has highlighted the shortcomings in the HSNO Act, including a lack of strict liability and no mandatory requirement for the EPA to take a precautionary approach to outdoor transgenic organisms’ experiments and releases.

In addition to the potential risks of release of transgenic crops into the environment and/or outdoor experiments, seaports pose risks. Genetically engineered soy enters the country, mainly from Argentina. The large poultry industry in the Waikato and elsewhere uses transgenic feed and our substantial dairy industry uses poultry manure, thereby widely disseminating any transgenic material.

The existing regulatory requirements are for visual assessment of any consignment of imported feed on arrival as the hatches are removed, with no obligation for further monitoring. A shipment may represent many thousands of tonnes. According to the Ministry of Primary Industries no inspection is done nor will be done under current requirements. Thus New Zealand is at risk, potentially from both the transgenic content and the glyphosate-based herbicides contained within the feeds, the levels of which are also not monitored.

Tasmanian Deputy Premier, Bryan Green, said the State’s “island status and our biosecurity system mean that our food and agricultural industries are well placed to take advantage of the State's GE-free status.”[67] New Zealand’s island status offers the same advantages.

New Zealand should reject growing transgenic food or feed crops, trees and grasses. Transgenes released into the environment have the potential to invade and damage the biological infrastructure of New Zealand’s primary industry sectors and our unique biodiversity. As has been shown overseas, once released into the environment, transgenes will spread and potentially irreversibly contaminate native and domestic gene-stocks alike.

For further information please refer to the following:

For more background on reasons to retain a precautionary approach to genetic engineering technology, we refer you to the following on the PSGR website www.psgr.org.nz:

· Testimony to Northland Regional Council 21 June 2013 http://www.psgr.org.nz/testimonies

· Letters to New Zealand Councils and to members of Federated Farmers to be found on

www.psgr.org.nz > home page > letters.

· Frequently Asked Questions on Genetic Engineering www.psgr.org.nz/index.php?option=com_content&view=article&id=54&Itemid=25.

· Frequently Asked Questions on Glyphosate

http://www.psgr.org.nz/glyphosate/finish/8-uncategorised/16-glyphosate/0

‘GMO Myths and Truths Report, an evidence-based examination of the claims made for the safety and efficacy of genetically modified crops, by Antoniou, Robinson and Fagan; June 2012, Earth Open Source. Download from:

http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf

Environment Court Decision November 2013 http://www.boprc.govt.nz/media/321876/environment-court-decision-18-dec-2013-env-2012-339-000041-part-one-section-17.pdf

Bay of Plenty Regional Council vs Scion http://www.boprc.govt.nz/media/321876/environment-court-decision-18-dec-2013-env-2012-339-000041-part-one-section-17.pdf

Inter-council Working Party on GMO Risk Evaluation and Management Options http://www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Documents/GE-Reports/Letter-to-Minister-re-GMO-Survey.pdf

Whangarei District Council on Genetic Engineering www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Pages/default.aspx#Expand

Far North District Council on Genetically Modified Organisms / Genetic Engineering

http://www.fndc.govt.nz/services/environmental-policy-and-forward-planning/the-far-north-district-plan/genetically-modified-organisms-gmo#a2

Hasting District Council on Genetic modification http://www.hastingsdc.govt.nz/geneticmodificatio

Pure Hawkes Bay National Poll, posted 2 December 2013 http://purehawkesbay.org/overwhelming-support-for-local-decisions-on-gm-free-status-national-poll/

Radio NZ News - 79% want councils to have power over GM crops – 2 December 2013 www.radio nz.co.nz/news/national/229508/79-percent-want-councils-to-have-power-over-gm-crops-poll

See also –

· The Sustainability Council of New Zealand http://www.sustainabilitynz.org/council.asp

· GE Free New Zealand www.gefree.org.nz/

· GM Watch http://www.gmwatch.org/

· The ETC Group http://www.etcgroup.org/

· The International Survey of Herbicide Resistant Weeds on http://www.weedscience.org/In.asp

· Up-to-date list of herbicide-resistant weeds on http://www.weedscience.org/summary/MOASummary.asp.

[1] http://www.csiro.au/en/Outcomes/Safeguarding-Australia/Aust-Weed-Management.aspx

[2] http://www.daff.gov.au/natural-resources/invasive/national_weeds_productivity_research_program

[3] www.guardian.co.uk/science/2003/jul/10/gm.sciencenews

[4] www.soils.wisc.edu/extension/wcmc/2012/ppt/Davis_2.pdf

[5] Ten years of failure: farmers deceived by GM corn, Masipag 12 June 2014, http://www.grain.org/bulletin_board/entries/4958-ten-years-of-failure-farmers-deceived-by-gm-corn

[6] www.agassessment.org/docs/SCReport,English.pdf.

[7] PSGR submission to the Environmental Risk Management Authority, now the jurisdiction of the EPA: www.psgr.org.nz/index.php?option=co m_content&view=article&id=80: submission-on-application-erma200479-to-field-test-in-containment-pinus-radiata&catid=24:environmental-risk-management&Itemid=39

[8] ‘The Fire Pines’, Richard Warren and Alfred J Fordham, http://arnoldia.arboretum.harvard.edu/pdf/articles/1040.pdf

[9] G. Singh et al., “Pollen-rain from vegetation of North-west India.” New Physiologist 72, 1993, pp. 191-206.

[10] NZ scientists running GM field trials, 1 September 2012, New Zealand Herald, http://www.nzherald.co.nz/business/news/article.cfm?c_id=3&objectid=10830932

[11] Sydney Morning Herald, 8 May 2012.

[12] ‘The Biology of Lolium multiflorum Lam. (Italian ryegrass), Lolium perenne L. (perennial ryegrass) and Lolium arundinaceum (Schreb.) Darbysh (tall fescue)’, #AG1241; 1 May 2008 Version. Australian Government Office of the Gene Technology Regulator http://www.ogtr.gov.au.

[13] ‘Gene flow from glyphosate-resistant crops’, Mallory-Smith and Zapiola, Pest Manag Sci. 2008 Apr; 64(4):428-40. doi: 10.1002/ps.1517. http://www.ncbi.nlm.nih.gov/pubmed/18181145

[14] Former GE Canola Trial Sites Audit Reports, Dept Primary Industries http://www.dpipwe.tas.gov.au/internnsf/WebPages/CART-6795X9?open

[15] ‘Long-term persistence of GM oilseed rape in the seedbank’, D’Hertefeldt T et al, Biol Lett. 23 June 2008; 4(3): 314–317. www.ncbi.nlm.nih.gov/pmc/articles/PMC2610060/.

[16] http://safefoodfoundation.org/contamination-from-field-trials-in-tasmania/

[17] Dept Primary Industries, Parks, Water & Environment – Biosecurity Tasmania. http://dpipwe.tas.gov.au/Documents/GM%20Canola%20Former%20Trial%20Sites%20Audit%20Report%20May2014.pdf

[18] http://www.abc.net.au/news/2014-01-09/tasmania27s-gmo-ban-extended-indefinitely/5192112

[19] http://modernfarmer.com/2013/12/post-gmo-economy/

[20] http://www.packagedfacts.com/Non-GMO-Foods-7822141/

[21] http://www.environmentalleader.com/2013/11/12/non-gmo-food-market-to-hit-800-billion-by-2017/ http://www.globalresearch.ca/american-farmers-abandoning-genetically-modified-seeds-non-gmo-crops-are-more-productive-and-profitable/5366365; Global Research, 27 January 2014 offthegridnews.com.

[22] http://www.nlpwessex.org/docs/benbrook.htm.

[23] http://www.3news.co.nz/Weeds-herbicide-resistance-a-big-concern/tabid/1160/articleID/280328/Default.aspx .

[24] http://www.daff.gov.au/natural-resources/invasive/national_weeds_productivity_research_program

[25] ‘Ecological effects of transgenic crops and the escape of transgenes into wild populations’, Pilson D and Prendeville, H, Annu. Rev. Ecol. Evol. Syst. 2004. 35:149–74

http://fbae.org/2009/FBAE/website/images/PDF%20files/Imporatant%20Publication/ecological%20effects%20of%20transgenes.pdf

[26] National Pesticide Information Centre Technical Factsheet on: GLYPHOSATE http://npic.orst.edu/factsheets/glyphogen.pdf. Glyphosate-resistant genetically engineered plants were introduced on a commercial scale in the mid 1990s.

[27] http://www.farmchemicalsinternational.com/crop-inputs/herbicides/glyphosate-resistance-spreads-in-the-u-s/ 5 February 2013

[28] http://www.weedscience.org/summary/home.aspx,http://www.weedscience.org/summary/MOA.aspx?MOAID=12,

[29] Mortensen et al, BioScience 62, 75–84 (2012). http://www.jstor.org/discover/10.1525/bio.2012.62.1.12?uid=3738776&uid=2129&uid=2&uid=70&uid=4&sid=21103352335931

[30] ‘An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops’ (June 2012) Earth Open Source http://earthopensource.org/index.php/reports/58

[31] http://www.soyconnection.com/soyfoods/product_overview.php

[32] http://extoxnet.orst.edu/tibs/bioaccum.htm, http://www.saferchemicals.org/resources/chemicals/pbts.html

[33] http://www.foodandwaterwatch.org/factsheet/monsanto-a-corporate-profile/

[34] ‘Determination of Glyphosate residues in human urine samples from 18 European countries’, carried out by Medical Laboratory Bremen, Germany, http://www.foeeurope.org/sites/default/files/glyphosate_studyresults_june12.pdf.

[35] http://www.foeeurope.org/sites/default/files/press_releases/foee_1_introducing_glyphosate.pdf

[36] http://gmfreescotland.blogspot.co.uk/2013/10/us-public-health-trends-after-gm.html

[37] ‘Glyphosate’s Suppression of Cytochrome P450 Enzymes and Amino Acid Biosynthesis by the Gut Microbiome: Pathways to Modern Diseases’, Samsel et al, Entropy 2013, 15(4), 1416-1463; doi:10.3390/e15041416 http://www.mdpi.com/1099-4300/15/4/1416

[38] Roemheld et al., 2005; Neumann et al., 2006; Eker et al., 2006

[39] ‘Glyphosate, hard water and nephrotoxic metals: are they the culprits behind the epidemic of chronic kidney disease of unknown etiology in Sri Lanka?’ Jayasumana C1, Gunatilake S2, Senanayake P3. Int J Environ Res Public Health. 2014 Feb 20;11(2):2125-47. doi: 10.3390/ijerph110202125. http://www.ncbi.nlm.nih.gov/pubmed/24562182

[40] http://www.aaemonline.org/gmopost.html.

[41] http://www.scoop.co.nz/stories/PO1404/S00063/myths-revealed-about-safety-of-ge-food.htm.

[42] Alliance for Bio-Integrity http://www.biointegrity.org/list.htm.

[43] http://www.crc.govt.nz/publications/Plans/rps-hearing-cadmium-nz-agriculture-horticulture-strategy.pdf. Confirmed by MPI officer.

[44] AMPA (aminomethylphosphonic acid) is the primary degradation product of glyphosate in plants, soil, and water.

[45] http://naturalrevolution.org/list-of-countries-that-ban-gmo-crops-and-require-ge-food-labels/ 19 June 2013

[46] http://www.gmo-free-regions.org/

[48] Inter-council Working Party on GMO Risk Evaluation and Management Options http://www.wdc.govt.nz/Plans PoliciesandBylaws/Plans/Genetic-Engineering/Documents/GE-Reports/Letter-to-Minister-re-GMO-Survey.pdf

[49] http://www.stats.govt.nz/

[50] http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf

[51] http://purehawkesbay.org/overwhelming-support-for-local-decisions-on-gm-free-status-national-poll/

[52] http://www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Pages/default.aspx

[53] http://www.greenpeace.org/belgium/PageFiles/16954/iaastd-recommendations.pdf

[54] http://mcguinnessinstitute.org/Site/Publications/Project_Reports.aspx. ‘An Overview of Genetic Modification in New Zealand 1973-2013: The first forty years’ published in August 2013.

[55] http://unctad.org/en/PublicationsLibrary/ditcted2012d3_en.pdf.

[56] http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf

[57] FAQ http://www.psgr.org.nz/index.php?option=com_content&view=article&id=54&Itemid=25.

Glyphosate http://www.psgr.org.nz/glyphosate/finish/8-uncategorised/16-glyphosate/0.

[58] http://www.far.org.nz/index.php/media/entry/glyphosate-resistance-confirmed-in-new-zealand.

[59] The active ingredient in the commonly applied herbicide, Roundup. Glyphosate-resistant crops are largely RoundupReady.

[60] ‘Field Investigations of Glyphosate in Urine of Danish Dairy Cows’, Krüger et al., J Environ Anal Toxicol 2013, 3:5, http://dx.doi.org/10.4172/2161-0525.1000186

[61] Carla L Barberis, Cecilia S Carranza, Stella M Chiacchiera, Carina E Magnoli. Influence of herbicide glyphosate on growth and aflatoxin B1 production by Aspergillus section Flavi strains isolated from soil on in vitro assay. J Environ Sci Health B. 2013 ;48(12):1070-9. PMID: 24007484

[62] ‘Influence of herbicide glyphosate on growth and aflatoxin B1 production by Aspergillus section Flavi strains isolated from soil on in vitro assay’, Barberis et al, J Environ Sci Health B. 2013; 48(12): 1070-9. doi: 10.1080/03601234.2013.824223; http://www.ncbi.nlm.nih.gov/pubmed/24007484.

[63] http://www.icrisat.org/aflatoxin/aflatoxin.asp

[64] Reuters, ‘Tate & Lyle says aflatoxin in U.S. corn complicates grain sourcing’, 8 November 2012

[65] International Federation of Red Cross and Red Crescent Societies, http://www.ifrc.org/PageFiles/89755/Photos/307000-WDR-2011-FINAL-email-1.pdf.

[66] Report ‘Seed Giants vs US Farmers’ http://www.centerforfoodsafety.org/reports/1770/seed-giants-vs-us-farmers

[67] http://www.theguardian.com/world/2014/jan/09/tasmania-gm