2006 Crop & Food Application GMF06001, To field test genetically engineered 12-12-06

12 December 2006

ERMA
WELLINGTON

Submission to ERMA on Crop & Food Application GMF06001
To field test genetically engineered vegetable and forage brassicas

For the purposes of this submission, PSRG will use the term genetic engineering (GE) or genetically engineered/organisms (GEOs) to represent genetic modification (GM), genetically modified organisms (GMOs) or living modified organisms (LMOs) or any term that may be devised to represent the technology of genetic engineering.

PSRG upholds that all organisms have complex inter-relationships about which we have little knowledge, and the timescale for important biological phenomena can be much longer than ordinary ‘human’ time. Trialling GE brassicas can be claimed to be using short-term, vested-interest solutions and not recognizing or acknowledging the long-term consequences for the environment or humanity.

PSRG continues to maintain that a moratorium should be establishment on the release of any genetically engineered organisms into the common biological environment for the foreseeable future; that all experimentation should be restricted to high security laboratories.

PSRG maintains that spending substantial sums of money on research – often supplemented or maintained by the public purse – that may result in few or no benefits to humankind, and that may irreparably affect or damage the environment, its flora and/or fauna, and/or humankind, cannot be justified, and that there is sufficient evidence to date to show that any benefits from genetically engineering plants have gone to vested interests and not humankind.

PSRG advocates:
(a) that an on-going process of education in which public discussion and iterative evaluations are used to define public concerns, the potential risks and possible as yet unproven benefits of genetic engineering;
(b) that for the purposes of oversight on a case-by-case basis, that this should be organized and controlled by independent sources unimpeded by vested interest;
(c) and that any decisions, regulations and legislation, in respect of genetic engineering, should involve a broad range of public participants comprising individuals who represent a wide range of backgrounds and disciplines without affiliations to government, political parties or industries with vested interests: for example, scientists, physicians and others involved in the science, epidemiology, ethics, animal welfare and rights; experts in law and economics for technical aspects; and interested non-government organizations and the general public.

The Trustees and Members of Physicians and Scientists for Responsible Genetics advise the ERMA to decline Application GMF06001.

1. Considerations in reference to field trial summaries 2.1 and 2.2

1.1 The Application details field trials that focus on pests that are not a major commercial concern in New Zealand. These pests can be managed with sound, sustainable crop management strategies. CWB and DBM larvae and caterpillars are pests in part because the soils they are raised on lack organic matter, essential minerals, earthworms or other beneficial organisms, including soil microbes that contribute to the overall health, pest and pathogen resistance of a plant.

1.2 If brassicas are genetically engineered to be resistant to Bt, local CWB and DBM populations can readily become resistant to Bt as has been found overseas. Of particular concern with Bt, is that New Zealand’s organic farmers will not be able to control the caterpillars with one of the few biological sprays organic growers are permitted, Bt spray. N.B. DBM has been found to show widespread resistance to the Bt toxin in the field (Sayyed et al., 2000).

1.3 The application summary (ref. 2.2, para. 2) reads that: “while there are numerous chemical control methods available for these pests, there are also problems, particularly in DBM with the development of resistance to these chemicals.” Bt toxin is a protein, but acts as a chemical. There is well-documented scientific literature illustrating the possibility of the growth of Bt resistance in insects, of damage to non-target organisms, of an accumulation in soil and of toxicity to soil organisms.

1.4 In referring in this Application to the use of Bt sprays by growers, especially organic growers, to control pests (ref. para. 3, p.3), it is important to note that plants genetically engineered to resist Bt generally express the toxin throughout the plant and for the duration of the growing cycle, whereas pesticide sprays such as Bt degrade quickly when exposed to UV light (Glare and O’Callaghan, 2000 in Teulon & Losey, 2002).

1.5 It should also be noted that bacterial genes do not express well in plants, thus transgenic Bt genes have been substantially altered, may be truncated and engineered to produce up to a one hundred times higher expression in plants (Hilder and Boulter, 1999; Andow, 2002). It is, therefore, unscientific to directly compare plants infrequently sprayed with a bacterial spore suspension and plants engineered with a much higher concentration and different form of the cry protein or proteins than are found in bacterial preparations.

1.6 The expression of Bt toxins may affect non-target insects and other organisms, and of obvious concern is the effect on essential pollinators or insect predators of insects (Clark et al., 2005).

1.7 This Application fails to mention research carried out previously on Bt broccoli that had been engineered with high levels of Bt Cry1C protein (Cao et al., 1999). Bt broccoli engineered with the Cry1C protein has been shown to control DBM larvae resistant to Cry1A or Cry1C. One author of this paper, Dr E Earle, supervised Applicant, Dr Mary Christey’s PhD at Cornell University. This paper also documents Bt resistance of the DBM and that it was observed seven years ago. This fact offers further evidence to counter the claims Dr Christey has made of there being “no scientific evidence” of insect resistance to Bt. It also illustrates that previous work on genetically engineered Bt broccoli and Bt resistant DBM has been ignored in this application.

2. Considerations in respect of insect resistance

2.1. Insect populations continually evolve. Hence, a substance designed to eradicate insects would also submit an insect population to selection pressures in respect of resistance to that same substance (Weaver & Morris, 2005); e.g. it has been noted in the development of antibiotic resistance in medicine and chemical pesticides resistance in agriculture. If insects develop resistance to an insecticide such as Bt, there will be environmental and human health consequences. Sustainable farming methods rely extensively on Bt protein as a non-toxic pest control. Resistant pests would require more toxic sprays, increasing occupational exposure, and increase adverse effects in soil and water by run-off (Weaver & Morris, 2005).

2.2. When Bt resistance is genetically engineered into organisms, it is expressed in all parts of the plant (see 1.4 and 1.5) and will present greater opportunity for insect resistance to develop. Also, with widespread cultivation of Bt crops, a greater variety and population of insect species will be subjected to selection pressure for resistance (Sayyed et al., 2003). Should resistant develop in NZ, it will affect the agricultural industry and relieve farmers of a valued, non-toxic spray.

2.3. In statements to the Christchurch Press and Radio NZ, Applicant, Dr Christey, has claimed “there is no scientific evidence of insects becoming resistant to the Bt toxin in genetically engineered Bt plants” (the Press, 1 November 2006; and Rural News, 2 November 2006). This contradicts a review (Glare and O'Callaghan, 2000) which found that, by 2000, published research on some 17 insect species revealed resistance to Bt in the laboratory and one species revealed extensive resistance in the field. In 2005, a subsequent review gave 41 examples of published work on insect resistance to Bt plants (Weaver & Morris, 2005).

2.4. Recent research has indicated that insects are becoming resistant to Bt at a faster rate with transgenic crops containing the Bt gene. Weaver and Morris (2005) tied the resistance to continual exposure to the Bt toxin. Sayyed et al (2003) indicated that larvae of the diamondback moth, Plutella xylostella (L), might use the toxin derived from Bt (Cry1Ac) as a supplementary protein food. The resistant moth larvae had a 56 percent higher growth rate when fed cabbage leaves genetically engineered with the Bt gene.

2.5. Chilcutt and Tabashnik (2004) indicated that a high dose/refuge strategy for delaying pest resistance requires refuges of non-Bt crops be planted near Bt crops to promote survival of susceptible pests. Application GMF06001 (p.13, para.2) reads as if insect resistance will not arise and that unsprayed non-transgenic Brassica are just controls.

2.6. Susceptibility to Bt resistance in insect pests may be an agricultural threat worldwide. In the US, the Department of Agriculture has found that 21 percent of the country’s Bt corn farmers in ten states did not meet refuge requirements (Bates et al., 2005).

2.7. Initially, Bt crops can potentially reduce insecticide use, but a study on the management of Bt crops worldwide has shown that any reduction wanes within a few years until chemical use on Bt fields approximately equals chemical use on conventional crops (Wang et al., 2006).

2.8. Professor Bruce Tabashnik, the scientist who assisted in establishing the US guidelines for transgenic crops, has warned that Bt crops could create a new generation of super bugs resistant to pesticides. A study (Chilcutt and Tabashnik 2004) on the contamination of refuges by Bt toxin, found that pollen-mediated gene flow of up to 31 metres from Bt maize produced low to moderate Bt toxin levels in the kernels of the non-Bt maize refuge plants. Previous studies focused on the potential effects on wild relatives of crops, landraces and organic plantings, and concluded that Bt toxin production in seeds of refuge plants undermined any high-dose/refuge strategy and could accelerate pest resistance.

3. Consideration of the use of two or more Cry proteins: gene stacking

3.1. The US Environmental Protection Agency has approved Bt gene stacking for corn varieties. A hybrid of Monsanto's MON 810 and MON 860 varieties, YieldGard Plus Corn, (May 2005) which would express the Cry3Bb1 and Cry1Ab proteins. Also, a two-Bt toxin cotton variety was approved in Australia and the US in 2002 (Bates et al., 2005). Bates et al claim that stacked varieties of Bt crops may be the most effective way to slow the development of Bt-resistance in insects (2005). However, combining two or more Bt toxins by releasing crops expressing single but different toxins, may effectively encourage Bt-resistance in insects. Such introductions would create toxin mosaics of exposure (Bates et al., 2005) and may maximize the number and variety of exposed insects and the heterogeneity of toxin concentrations. Such a mosaic can also be created in time by rotating crops with single but different Bt toxins.

3.2. Gene flow may also create a landscape mosaic. Residual volunteer plants or feral crops or wild relatives that express Bt toxins could undermine coordination of Bt cropping practices. Stacked varieties may not significantly improve Bt resistance management if they are introduced after the same toxins have been individually introduced through commercialised varieties or if toxin genes separate during transgene flow.

3.3. Expression of two different insect toxins in a single plant may slow the evolution of resistant insects where both resistances evolve simultaneously (Bates et al., 2005; Gould, 1998). However, this probability is optimistic, estimated as low as one in a trillion (Gould, 1998). Any probability will vary, dependent on refuge use and the nature of resistance, and any interpretation must be based on the size of a population and the rate of reproduction. Low probability rates may still be significant, producing a large, rapidly reproducing population. Gould (1998) claims that resistance could emerge in only seven insect generations.

3.4. Gene flow may potentially change Bt toxin concentrations in plant populations. The result could potentially be lower strength and effectiveness of high-dose refuge strategies (Bates et al., 2005). Saving seed practices may readily lead to heterogeneous mixtures of Bt and non-Bt plants in subsequent generations (Fitt et al., 2004).

3.5. Environmental variables must be rigidly controlled. An outbreak of Bt resistant insects would adversely affect farmers who grow transgenic crops and those who apply Bt as a pesticide (Chapman and Burke, 2006). The rate of resistance development would vary with the insect, and the number and range of plants upon which it feeds (Janmaat and Myers, 2005).

4. Consideration of secondary pests and the failure of Bt crops to reduce overall pesticide use

4.1. Analysis of expenditure on pesticides indicates that Bt farmers may save close to 45 percent of
Bollworm pesticide compared to non-Bt farmers, but expenditure on pesticides designed to kill
emerging secondary pests could increase 40 percent (Wang et al., 2006). It has also been found
that secondary pests that are not susceptible to Bt, may not be detected easily or controlled in a
Bt crop. Also, pests such as bollworm are natural controllers of secondary pests. Extra
expenditure would be required to control secondary pests and this would almost offset the
savings on primary pesticide cited in current literature (Wang et al., 2006).

4.2. The flow of Bt toxin genes, by design or by accidence, also increases the number of insects of
different types and susceptibilities exposed to the toxin. High-dose/refuge strategy success is
based on the assumption that heterozygote mortality is high. However, a Bt plant may deliver a
dose that is highly toxic to one species and moderately toxic to second (Bates et al., 2005). This
manifested in the exposure of clinically relevant and environmental bacteria to the overuse of
antibiotics (Levy, 1998). It was found that the larger a population and variety of insects exposed
to Bt toxin, the greater was the opportunity to select individuals with inherently less
susceptibility (Bates et al., 2005). Antibiotic resistance created by gene flow was a predictable
outcome of creating environments where the concentration of antibiotics waxed and waned
(Willms et al., 2006). Resistance will more probably evolve where Bt toxin expression is not
carefully managed, by direct selection of resistance in relevant pests, or following gene
flow from resistant insects to insects that are crop pests.

5. Consideration of monitoring of Brassica for resistant insects

5.1. Monitoring Brassica for resistant insects is not an effective way of identifying and eliminating them. Those that are located and removed (p 4, para.4) should be studied further, with a detail record of location, numbers, etc. kept. The application does not appear to have paid attention to whether or how this will be done. As CWB larvae, for example, feed deep inside a head of broccoli or cauliflower, it would be nearly impossible to locate and identify them in sufficient numbers. CWB larvae also crawl underneath the tightly packed exterior leaves of cabbages., and the near identical colour of curly kale and CWB larvae effectively camouflages the larvae.

5.2. This Application identifies DBM or CWB larvae as not moving 50 cm distances (p 13, para. 2) when, in fact, it common to see such larvae move such distances freely and directionally, even on dry soil. Caterpillars also move off the host plant and may do so to form a pupa. There is no reference substantiating the assumption made that larvae will not move off the plants.

5.3. This Application (p.13, para. 4) says: “natural populations of CWB and DBM will be used to infect (sic) the field trial.” And that, “CWB and DBM butterflies …will be deliberately released at the trial site (if weather conditions were not appropriate). CWB and DBM will be obtained from either laboratory-reared populations or from other field sites in NZ.” As a field trial, the performance of plants should be assessed under normal field conditions. Wild populations may differ from caterpillars raised in the laboratory and cause different results.

6. Considerations of insect transmission of transgenic DNA to non Bt plants

6.1. This Application does not cover the probability of aphids becoming carriers and transferring
transgenic DNA to non-transgenic Brassica or weeds. Spraying aphids will not necessarily
prevent this occurring. Aphids do move freely from plant to plant.

7. Consideration of the effects on non-target organisms

7.1. This Application claims that, “there is no information to suggest that the field testing of these
GE brassicas will have any consequences (positive or negative) on … non-target organisms,”
(p.22, para.1) and there are no references to substantiate this claim.

7.2. Because of the high expression of Bt toxins in transgenic plants throughout their growing
season, there is the potential to disrupt the beneficial role of predators, parasitoids and other
organisms through direct feeding on the Bt plant, feeding on herbivores on the Bt plants or
exposure in the soil (Groot and Dicke, 2001). A recent paper found that Bt toxicity has been
established for hookworms (Cappello et al, 2006).

7.3. Researchers at the University of Cornell (1999) used pollen from Bt corn to dust milkweed
leaves. Milkweed grows in corn fields and is an important food source for monarch
butterfly larvae. Significant numbers of the monarch butterfly larvae that ate the dusted leaves
died while all the control larvae fed on leaves dusted with non-GE pollen survived (Losey, et al.,
1999). Currently, there are seven published studies alone on the negative effects of Bt plants on
monarch larvae (Weaver and Morris, 2005).

7.4. Lang and Vojtech (2006) found harmful effects of Bt176 pollen on a European common
swallowtail butterfly, Papilio machaon L. The researchers used moderate pollen densities
that matched the densities found in the field. Field pollen densities can be much higher in the
pollen shedding period, which lasts from 5-14 days. During this pollen shedding period, the
researchers observed the toxic effects of Bt exposure were more marked, including greater
larvae mortality rates and reduced reproductive success in butterflies. These effects were
specific to Bt176 pollen and not the result of herbicide applications. This study used Bt176
maize (a Syngenta cultivar). Bt toxins were produced in most tissues of the Bt maize,
and pollen with toxin was transported by wind to adjacent plants and consumed by larvae of
non-target species feeding on these plants. Ingestion of Bt176-maize pollen had adversely
affected the common swallowtail butterfly: the larvae had a lower survival rate, a lower
weight-increase rate, a longer development time, and lower body-weight and smaller wing size
as adults; the effects significantly associated with Bt pollen density. The researchers also found
that Bt ingestion enhanced the negative impact of bacterial infections on Lepidoptera larvae.
The scientists concluded that this study must be evaluated more rigorously before Bt maize
could be cultivated over large areas.

7.5. This Application says that the transgenic brassicas in this trial will be removed before bud
burst. However, the aforementioned clearly document the harm done to non-target organisms
by flowering Bt plants. Bt corn flowers and produces copious quantities of pollen before seed
set, and similar non-target organism effects could be widespread.

8. Consideration of the effects of Bt on soil and soil organisms

8.1. Bt toxicity has been established for some life stages of worms from soil (Huffman et al, 2004;
Vercesi et al, 2006). Research carried out in Australia involving Cry1Ac toxin relates to Bt cotton,
but the conclusions can be extrapolated to other transgenic Bt plants.

8.2. In 2004, Gupta and Watson found that the leaves, stubble and roots of Bt cotton contain large
concentrations of Bt Toxin. Therefore, they may potentially be a reservoir of Bt toxin. The
results of their research suggest that Bt toxin has the potential to enter the soil system
throughout the Bt cotton-growing season, through both a root release process and root turnover.
The scientists concluded that levels of Bt toxin entering the soil system could therefore be
significantly higher than previously suggested.

8.3. Gupta and Watson also discovered that roots with Bt toxin are in constant contact with the soil
system (including soil biota). Bt toxin levels in fine roots were found to be as high as that in
younger leaves. Their results - large concentrations of Bt toxin in Bt cotton roots and
demonstrated root release – led them to conclude that more detailed investigations are needed
on the environmental effects of the root-derived Bt toxin, binding to soil components and build-
up, and movement beyond the rhizosphere and root zone.

8.4. Bt toxins produced by transgenic plants have been shown to bind rapidly to surface-active
particles, e.g. clays and humic substances, leading to their accumulation in the soil (Saxena et al.,
2002). This is in contrast to bacterial Bt toxin. Bound toxins resist biodegradation and continue
insecticidal activity for at least the longest time studied, 180 days. Insect pests appear resistant
to the toxin because of its permanent presence in the plants and non-target organisms continue
to be harmed by the toxin.

9. Consideration of horizontal gene transfer (HGT)

9.1. No detail is given on intended HGT work other than generalized statements (p.27). The HGT
explanation refers to only one 1998 publication. A large quantity of work has been published
subsequently, thus a single reference is not indicative of what is now known about HGT.

9.2. The statement in the Application that kanamycin-resistant micro-organisms already exist in soil
and thus the contribution of the transgenic derived NPTII gene to natural kanamycin resistance
is minimal, is based on a single research paper published 15 years ago (p.27, para.3) by a scientist
who has worked for the Applicant. Much work on HGT has been published subsequently.
There is no research to substantiate the assumption that the transgenic derived NPTII gene
controlled by a Brassica viral promoter (CaMV35S) will behave in the same manner as the
natural kanamycin resistance displayed by soil bacteria. This statement is therefore not valid
and possibly incorrect.

9.3. This Application should outline their detection of HGT limits and whether those limits are
relevant to capturing gene transfers that can result in environmental damage. For example, the
optimisation of the cry codons for expression in plants was asserted to be a barrier to
expression in bacteria should the gene transfer occur (p.27, para.2) with no references given.
New Zealand scientist, Associate Professor, Jack Heinemann, actively involved in HGT
Research, has said that to his knowledge there has been no demonstration of this phenomenon.

9.4. This Application claims that the risk of HGT is negligible based on the ESR studies (p.27,
para.4). The Watson ESR studies are generally regarded as fundamentally flawed and they have
not been published in any serious journal (Assoc. Prof. Jack Heinemann). A detailed critique of
the ESR work has been published (Heinemann and Traavik, 2004 and 2005).

10. Consideration of the claim to environmental benefits of Bt brassicas

10.1. This Application claims Bt Brassica with reduce insecticide use (p.29, para.2). Currently,
sustainable growing practices do not use organophosphates, carbamate and other such toxic
insecticides or synthetic pyrethroids, such as those used by most conventional growers. Such
sustainable methods have already led to a 50-65 percent reduction in total insecticide
application to Brassica in New Zealand (Teulon and Losey, 2002).

11. Consideration of Brassica field trials previously carried out by Crop & Food

11.1. It is understood that transgenic Brassica cultivars have previously been allowed to flower in Crop & Food field trials, making it inevitable that transgenic pollen escaped to the surrounding area.

12. Consideration of current world acreage of Bt crops

12.1. This Application claims that about 30 million hectares of Bt crops are grown worldwide. This
figure is misleading and differs to that quoted by Bates et al. (2005) and Marvier and Van
Acker (2005). These studies say Bt plants are grown on around 12 million hectares globally.

12.2. The number of hectares on which transgenic plants are grown (p.4, para.1) does not equate to safety assurances as food or environmentally.

13. Consideration of feeding experiments

These experimental Brassica should undergo feeding tests on laboratory animals before any consideration is given to field-testing: Consider the following examples..

13.1. Mice fed transgenic peas, engineered with a gene from the closely related common bean, were shown to develop immunological damage, evident in their lungs (Prescott et al., 2005). The researchers reported that diversity in translational and post-translational modification pathways between species could potentially lead to discrete changes in the molecular architecture of the expressed protein and subsequent cellular function and antigenicity. They illustrated that transgenic expression of a plant protein (-amylase inhibitor-1) from the common bean, Phaseolus vulgaris L. cv. Tendergreen, in a non-native host, i.e. the transgenic pea, Pisum sativum L., led to the synthesis of a structurally modified form of this inhibitor. They also showed that the consumption of the engineered inhibitor as compared with its native form caused an antigen-specific (CD4+ Th2-type) inflammation in the lungs of mice.

13.2. This study looked at a gene introduced from a species that is in the same family as the pea, Fabaceae. The GE Brassica proposed in this Application deals with a highly modified, synthetic version of a bacterial gene. Therefore, the ramifications of post-translational modifications should be researched as a high priority, given this and other research in this area. The transgenic Brassica Application does not refer to post-translational modification or rat/mice feeding tests.

13.3. In 2005, application was made to release into the food chain Monsanto’s MON 863 Bt corn and Syngenta’s BT10 corn, the latter containing a gene for antibiotic (ampicillin) resistance. Reports claimed that hundreds of thousands of tonnes of BT10 had already been illegally introduced into the world’s food supply (http://news.independent.co.uk). Concern arose about MON 863 corn when a German court granted public access to a confidential feeding study run by Monsanto which had found that rats fed with this GE corn developed smaller kidneys and raised levels of white blood cells and lymphocytes compared with those fed a non-GE corn. Food Standards Australia New Zealand had approved MON 863 corn without reference to the Monsanto feeding study, and also approved BT10. Trustee, Dr Elvira Dommisse, previously of Crop & Food, was told by Paul Brent from FSANZ that no independent feeding tests or independent assessments of company data are necessary and confidential company data are fine for safety assessments. This raises grave concerns.

14. Consideration of secondary (pleiotropic) effects, insertional mutagenesis and other effects

14.1. This Application does not refer to unexpected pleiotropic effects; i.e. unforeseen secondary effects of a genetic change. Saxena and Stotzky (2001) studied Bt corn genetically engineered to produce the Cry1Ab protein to kill lepidopteran pests. This transgenic Bt corn had higher levels of lignin, a pleiotropic effect. High levels of lignin are associated with disease resistance to insect and microbial pests, thus this looked positive. However, it is known that animals feeding on grasses or corn with high lignin content utilize the food inefficiently.

14.2. This Application also makes no mention of the effects of insertional mutagenesis, genome scrambling, recombination hotspots and unstable integration into host DNA. All of these are well documented. Weaver and Morris (2005) have reviewed papers on these topics.

14.3. New Zealand scientist, Professor David Williams, working on medical genetic engineering research at the San Diego School of Medicine in California, said (January, 2004): “I’m afraid that most of us who work with transgenics are pretty uncritical. Most of us assay for the transgenic product and ignore the secondary effects. Even those people doing functional genomics on transgenics mostly ignore changes that ‘don’t make sense,’ i.e., cannot be seen as immediately attributable to the transgene. Hence, it’s hard to get an idea of the extent and prevalence of downstream effects from insertional mutagenesis and simple imbalances caused by transgene expression. The biggest risk is that we don’t know. The problem with transgenics that are released into the environment and used in the food supply, however, is that the potential consequences of deleterious unknowns are clearly greater.” In a communication with PSRG Trustee, Dr Elvira Dommisse, Professor Williams provided a paper on insertional mutagenesis of transgenic Arabidopsis thaliana, a member of the Brassicaceae. Precise locations of insertional mutations were determined for more than 88,000 T-DNA insertions, which resulted in the identification of mutations in more than 21,700 of the approx. 29,454 predicted Arabidopsis genes (Alonso et al., 2003).

15 Consideration of the effects of GE Bt crops on farming in NZ

15.1. Reference page 79 of the Appendix (para. 4) of this Application: “Three biological control agents based on Bacillus thuringiensis are registered for use on vegetable and forage brassicas in NZ for control of DBM and CWB.” Thus, resistance to Bt in either species would render the Bt spray ineffective and adversely affect NZ agriculture, especially growers using organic and other sustainable methods. Current demand for organically grown food continues to increase rapidly world wide, particularly in countries that form a high percentage of NZ export markets. NZ organic produce has the potential to expand rapidly. (See www.organic-europe.net/country_reports; www.organic-europe.net/news-2005-07-01.asp; Soil Association Food and Farming report 2002 p45; www.maf.govt.nz/mafnet/rural-nz/sustainable-resource-use/organic-production/international-developments-in-organic-agriculture/index.htm).

16. Consideration of the effects on native members of transgenic Brassicaceae

16.1. Coastal peppercress, Lepidium banksii Kirk, is a member of the Brassicaceae family. In 1990,
only 26 plants were known in the wild. Such wild relatives are potentially fatally vulnerable
to Bt resistant CWB larvae (Bain, 2006). Brassicaceae in NZ include members of the
Lepidium and Pringlea genera.

17. Consideration of the potential hybridization with other members of the Brassicaceae

17.1. A recent British study concluded that increased attention should be focused on wild Brassica
oleracea and similar species that yield hybrids with GE rapeseed, Brassica napus (Ford et al.,
2006). The researchers observed that while the frequency of F1 hybrids of B.oleracea X B.
napus was lower than that of (wild) B.rapa X B. napus, it should be remembered that
B.oleracea is a polycarpic perennial and thus, a single hybrid produces second generation
introgressants over many years.

17.2. This Application, however, states that, “intercrossing with native Brassicaceae is not possible”
(p.4 para. 2.). Such wide-hybrids are questionable, but they cannot be ruled out, especially as
the consequences of even one hybrid are potentially very damaging.

17.3. In a submission to MAF, Stuart Gowers, forage brassica breeder from Crop & Food
Research, Lincoln, describes the Brassica species as being highly promiscuous, and says
crosses occur readily between all species within the genus either directly or via an
intermediary. Cross-pollination will occur within each species and between species of
B.campestris, B napus, B.oleracea, B. nigra, B juncea.

18. Consideration of the economic costs of Brassica research

18.1. At the conclusion of the Application’s ten-year trial, Crop & Food will have carried out Brassica research for nearly 30 years, without any high performing, commercially viable cultivars being produced. This is a drain on the public purse. Ten years given to traditional and DNA marker-assisted (non-transgenic) breeding techniques could produce Brassica that would be accepted, grown and eaten by the public and provide income for Crop & Food.

18.2. The public and export markets are demanding non-GE foods. Any contamination of the food supply by transgenic crops would cost the industry steeply. Many NZ food producers (e.g. George Weston, Griffins, Heinz Watties, Sanitarium and Sealord) have non-GE ingredient policies (see www.gefreefood.org.nz). Potential markets for GE Brassica may not exist.

PSRG will not present this submission in person.

Signed by the Trustees of Physicians and Scientists for Responsible Genetics

Paul G Butler, BSc, MB, ChB, Dip. Obst. (Auckland), FRNZCGP
General Practitioner, Trustee PSRG, AUCKLAND

John R Clearwater, BSc, MSc, PhD
Principal Scientist, Clearwater Research and Consulting, Trustee PSRG, AUCKLAND

Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM, MRCGP (UK), FRNZCGP
General Practitioner, Trustee PSRG, MURUPARA

Elvira Dommisse BSc (Hons), PhD, Mus.B, LTCL, AIRMTNZ
Scientist, Crop & Food Research Institute (1985-1993), working on GE onion programme.

Michael E Godfrey, MBBS, FACAM, FACNEM
Director, Bay of Plenty Environmental Health Clinic, Trustee PSRG, TAURANGA

Neil Macgregor, BSc, MSc, PhD
Soil Microbiologist, Institute of Natural Resources, Massey University,
Trustee PSRG, PALMERSTON NORTH

Peter R Wills, BSc, PhD
Associate Professor, University of Auckland, Trustee PSRG, AUCKLAND

Robert G Anderson, BSc, PhD
Lecturer retired, Trustee PSRG, TAURANGA

Jean Anderson
Businesswoman retired, Trustee PSRG, TAURANGA.

Signed on behalf of PSRG
Jean Anderson
Secretary

References
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2. Andow, D.A. (2002). Resisting resistance to Bt corn. in: Letourneau, D.K., Burrows, B.E. (ed.). Genetically modified organisms. Assessing environmental and human health effects. CRC Press, Boca Raton, pp 99-124.
3. Bain, H. (2006). Rare plant saved from extinction. Forest and Bird (NZ) 322: 6.
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