22 September 2010
Environmental Risk Management Authority, WELLINGTON
Submission on Application ERMA200479: To field test in containment Pinus radiata with genetic modifications to alter plant growth/biomass acquisition, reproductive development, herbicide tolerance, biomass utilisation, wood density and wood dimensional stability.
Applicant: New Zealand Forest Research Institute Limited, Rotorua, trading as Scion.
Physicians and Scientists for Global Responsibility is a Charitable Trust representing medical and scientific professionals and serving the public’s right to be independently informed. We will not be speaking to this submission.
1. Terminator gene technology
1.1. There has been such strong debate and objection internationally against the variants of terminator gene technology being used that a virtual voluntary moratorium is in place. If this Application to ERMA is approved, Scion – and thus New Zealand – will be seen to dishonour the decision made by countless scientists and countries worldwide to protect and maintain the integrity of Earth’s ecosystems.
1.2. Worldwide, a majority of scientists and members of the public believe terminator technology is dangerous. Most scientists dismiss the claims that the technology is an incentive to the development of new plant varieties. In respect of trees, they claim the disadvantages are:
The variants of terminator technology offer no absolute guarantee of sterility,
The potential horizontal gene transfer of the terminator trait to cultivated plants, or to wild plants;
The presumption of entitlement by developers;
The undermining of tree crop security.
We refer you also to “New Zealand Out in Front on GM Sterile Seeds” released by the Sustainability Council of New Zealand.
1.3. The claim is that trees developed using terminator technologies employ anti-sense genes or small regulatory RNA to prevent active gene products from being formed. Also employed is a kind of genetic abortion using a ‘suicide’ gene. This could be the barnase ribonuclease gene from the soil bacterium Bacillus amylolquefaciens, which is controlled by a promoter specific to floral or pollen development. Once activated, the gene product kills the cells in which the gene is expressed.
1.4. However, scientists at Sopanen University, Finland, have studied the control of flowering in silver birch trees, using a flower specific birch promoter gene, BpMADS1, to drive the barnase gene. They found that floral cell ablation prevented flowering, but that this had side effects to leaves and branching. These side effects may have been a pleiotropic effect of the gene insertion and the pleiotropic effects seen may extend into areas not yet detected.
(See The Institute of Science in Society (ISIS) Press Release, 2 March 2005, Terminator Trees.)
1.5. The ablation toxins used in creating sterile trees present dangers: e.g. barnase ribonuclease has proved toxic to the kidneys in rats; and barnase was cytotoxic in mice and human cell lines.
1.6. Even if totally sterile, terminator trees can spread by asexual means. The genes can spread horizontally to soil bacteria, fungi and other organisms in the extensive root system of the forest trees, which in turn could have unpredictable long-term impacts on the soil biota and fertility.
1.7. Preventing sexual reproduction radically reduces genetic recombination. It is genetic recombination that generates genetic diversity and evolutionary novelty in nature.
1.8. Transgenic traits tend to be unstable. They can break down, revert to flower-development, and potentially spread transgenes to native trees. They could create pollen that poisons bees and other pollinators as well as causing potential harm to human beings.
1.9. Trees that do not flower and fruit cannot provide food for the insects, birds and mammals that feed on pollen, nectar, seed and fruit. Local flora would thus lose pollinating insects in areas where transgenic trees are grown. This would inevitably have undesirable impacts on biodiversity, particularly in large areas of monoculture forests. The ability of an ecosystem to recover from disturbance and re-establish its stability, diversity and resilience would be damaged, possibly permanently.
1.10. Pleiotropic effects from the gene insertion may be immediately seen or may extend into areas not easily detected. There is little knowledge of how these effects would affect soil bacteria.
1.11. Sterile monocultures are known to yield more readily to disease or senescence, which in turn has the potential to devastate entire plantations over huge areas.
(See www.gefreeseeds.com; The NZ Herald, 29 May 2006, www.nzherald.co.nz/topic/story.cfm?c_id=220&ObjectID=10383921; www.esr.cri.nz/competencies/populationhealth/genetransfer.htm.)
2. Vested interests, integrity and oversight
2.1. Testing of transgenic developments is almost always inadequate, with a reliance on industry/developer test results, and oversight of field trials is almost always scant or non-existent. Independent analysis and assessment is extremely rare. Vested interests dominate.
2.2. A partner in this proposed development is ArborGen LLC. Their Application No. 06-325-111r was made to the US Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS). It sought approval to continue field-testing transgenic Eucalyptus trees that may flower. The trees were cloned from a hybrid of Eucalyptus grandis X Eucalyptus urophylla, and engineered with three gene constructs; two that confer cold tolerance, one to reduce flower development.
2.3. This field test was originally planted under APHIS Notification 05-256-03r, a permit for Eucalyptus grandis, not the hybrid given on the current Application 06-325-111r. The question was then asked, was the Application to “continue field testing” valid?
2.4. In July 2006, ArborGen, having been charged with failure to maintain the identity of trees in their test plots, were directed to remove the trees, and US Federal Courts ruled against the USDA in three cases for failing to carry out proper environment impact assessment, thus making the original approvals illegal.
(See ‘A Silent Forest: The Growing Threat, Genetically Engineered Trees’ (44 min. DVD) discusses the threats posed by transgenic trees to the environment and to human health; narrated by Professor Emeritus, David Suzuki, an internationally respected geneticist, recognized as a world leader in sustainable ecology.
3. The economy, the environment and employment
3.1. This Application claims it will develop many thousands of experimental GE trees using a wide variety of genetically engineered experimental options. Numerous media reports have shown that Scion’s handling of the environmental effects at its transgenic trees field trial sites have been inadequate and irresponsible. Further, the research pertaining to these trials has not been academically peer reviewed or published. Scion’s actions do not suggest a creditworthy or trustworthy attitude to its obligations.
3.2. New Zealand’s Pinus radiata forests have been developed over more than 150 years using highly efficient, selective breeding. The reward is a major export earner that plays a dominant role in the New Zealand economy. In ‘Comparative Study of NZ Pine’ it is predicted that the total New Zealand forest harvest of Pinus radiata will be 35 million cubic metres by 2015. Any damage caused by the experimental trees could be significant and adversely affect the environment, employment and exports.
(See www.globalregister.co.nz/evergreen/reports/comparativestudy.pdf; Forest Genetic Resources Working Paper FGR/59E. Rome www.fao.org/docrep/008/ae574e/ae574e00.htm; www.i-sis.org.uk/UNCaution.php ‘A Concept to Engineer Male Reproductive Sterility in Conifers,’ Christian Walter;
3.3. To New Zealand’s GDP, the forest industry contributes approximately 4%, and just under 12% of the merchandise trade by value. It employs just under 1.5 % of the labour force. Any damage to this industry by the very real potential adverse effects of using gene or terminator technology would have substantial effects.
(Statistics New Zealand www.stats.govt.nz; Ministry of Agriculture and Forestry www.maf.govt.nz).
3.4. Because introduced genes can be unpredictable, unforeseen traits can develop and be passed on to future generations. The damage would be irreparable. Accountability would be impossible to police.
3.5. Where multiple traits are introduced into a new host – gene stacking – it cannot be predicted how stable each introduced gene will be, or how predictable or stable the development of the combination of introduced genes will be.
3.6. There will be environmental impacts if we replace diverse native forests with monoculture tree plantations. Transgenic trees could impact on local flora and fauna in ways that cannot be adequately predicted.
3.7. See 1.9.
4. Pollen drift
4.1. We read the risk of pollen drift being understated in the Application, despite this being the most obvious risk. Also, looking at Scion’s past practice, high risk is likely. Pollen particles can be so small they are invisible to the human eye. Containment in the open environment is neither practical nor possible.
4.2. We remind ERMA of its statement made in respect of Plant & Food’s transgenic brassica Application. Despite ERMA’s assessment to the contrary, pollen escape did happen.
4.3. We also remind ERMA that pollen catkins have appeared on inadequately managed transgenic tree seedlings at Scion’s Rotorua site.
4.4. The New Zealand Forest Research Institute at Rotorua says security measures to stop cross-pollination include a buffer zone around the pine trees. However, pollen from transgenic trees could travel long distances. A study undertaken in India established that pollen from pine trees travelled over 600 kilometres (Sing et al, 1993).
4.5. Once in the upper atmosphere, pollen can travel huge distances. Nothing can protect a country’s ecosystem from pollen being blown across borders and contaminating native or commercial species.
4.6. It would need a failure rate of only part of a percent for transgenes to contaminate other trees, potentially at large distances, in ways that could not easily be monitored.
4.7. Pollen from transgenic trees and their introduced DNA would become untraceable.
4.8. There is potential for elements of terminator constructs to spread horizontally to other forest trees, affecting their fertility. Researchers have found that the dispersal or gene flow of pollen and seeds from forest trees can be measured in kilometres, and potentially hundreds or thousands of kilometres. Once released, transgenes from transgenic trees cannot be contained and pose serious threats to the integrity of forest ecosystems. The claim by developers that the solution to this problem is ‘terminator’ techniques that prevent flowering or pollen production does not stand up to scientific scrutiny.
5. Ethics, safety and the inadvisability of approval of this application
5.1. The UN’s Food and Agriculture Organization (FAO) surveyed 65 countries involved in transgenic forestry experiments; 49 countries responded.
5.2. The respondents saw consumer rejection and the cost of trials, intellectual property rights and regulations, as obstacles to their research.
5.3. They saw the perceived benefits as requiring years of costly biological and environmental assessment before commercialization is practical.
5.4. A final conclusion of the survey responses was that traditional forestry biotechnology - i.e. research and development that excluded genetic engineering technology - is less costly and requires less regulation.
5.5. Any proposed safety assessment framework for transgenic trees must acknowledge the diversity of existing forests and recognize the benefits of multiple uses of forests that conserve diversity.
(See ’Multiple uses of forests,’ SiS 25; www.wrm.org.uy/plantaciones/RECOMA.html.)
5.6. PSGR Trustee, Dr Elvira Dommisse is a geneticist. Speaking on the genetic engineering of pine trees, she says: “That does not mean that the same gene which has been genetically engineered into another species in an artificial gene construction will be harmless. It is in part true, but we cannot conclude from this that all is well. In its genetically engineered form, the gene is no longer under the control of its own DNA. It may well be a synthetic modified version of the original gene and is jammed into a complicated construct made up of bits of DNA from a number of different organisms. This means the gene is always switched on and is engineered to produce large amounts of a protein or proteins that pine trees don't normally make. The cellular machinery of a pine tree may produce a protein or proteins that are different from those used in the GE process. Such altered proteins can be harmful. This has already happened in genetically engineered peas, when a harmless bean protein became a toxin when engineered into the closely related pea.”
(Soil & Health www.organicnz.org, Scion Annual Report to ERMA, 2007 Annual Report GMF99001 & GMF99005 [Public version]; Organic NZ ‘Failure in GE Tree Reporting May Bring Tears To Crop & Food’s Onion Trial’ 5 February 2008; ‘Rotorua GE Tree Trial remains an environmental threat’ 16 March 2008, ‘GE Tree trial breach shows institutional contradictions’ 16 January 2008, ‘Christmas is over Scion, take the GE trees down’ 13 January 2008; Hawkes Bay Today, 16 and 19 January 2008.)
5.7. Because safety testing of anything produced using genetic engineering technology is generally left to the developer, the confidence of scientists and the public in the process is low. There is a very urgent need for independent oversight and safety testing of all experimentation using the genetic engineering technologies.
5.8. Pierre Sigaud, an expert in forest genetics at the UN’s Food and Agriculture Organization (FAO), has warned against rushing into growing transgenic trees commercially before running environmental risk assessments according to national and international protocols: “The issue goes beyond country level since pollen flow and seed dispersal do not take account of national boundaries and wood is a global commodity.”
(FAO. 2004. Preliminary review of biotechnology in forestry, including genetic modification. Forest Genetic Resources Working Paper FGR/59E. Rome, www.fao.org/docrep/008/ae574e/ae574e00.htm; www.i-sis.org.uk/UNCaution.php, ISIS Press Release 12/10/05, UN Cautions Over GM trees.)
5.9. At the United Nation’s Convention on Biological Diversity (CBD) in Curitiba, Brazil, in March 2006, a formal declaration was passed to recognize the threats posed by genetically engineered trees. It urged all countries to approach the technology with caution. This declaration supported the FAO’s 2005 call for an international framework to assess the safety of GM trees.
(UK Telegraph, Ban decision could mean GM trees in the wild, Alice Klein, www.telegraph.co.uk/earth/main.jhtml?xml=/earth/2008/05/30/eagm130.xml. ISIS Press Release, 30 May 2006, UN Convention Recognises GM Tree Threat. ‘Why there must be a moratorium on commercialisation of GM trees, Sam Burcher, 12 October 2005.)
6. Herbicide tolerant trees
6.1. As has been shown overseas with herbicide tolerant transgenic crops, herbicide resistance has exacerbated the use of herbicides. There is no scientific evidence to suggest that this would not happen in New Zealand if Scion’s Application is approved.
6.2. Growing transgenic, herbicide-resistant crops has led to an increasing number of weeds becoming resistant, forcing farmers to apply greater amounts of weedkiller. The most common resistance is to glyphosate. Gene stacking (resistance to multiple herbicides) was reported in Canada’s Globe and Mail (15 June 2000) a mere five years after the commercialization of transgenic crops. Chemical and DNA tests confirmed canola volunteers (self-sown seedlings growing wild) were resistant to Roundup, Liberty and Pursuit herbicides.
(‘Monsanto farmlands plagued by superweeds,’ Jet Hermida, 26 April 2009, http://asiadhrra.org/wordpress/2009/04/26/monsanto-farmlands-plagued-by-superweeds. ‘Superweeds' jam the pesticide treadmill, 13 November 2009, http://greenbio.checkbiotech.org/news/superweeds_jam_pesticide_treadmill; International Survey of Herbicide-resistant Weeds www.weedscience.org/In.asp. http://southeastfarmpress.com/cotton/weed-resistance-0918/; Plant Health Initiative, http://cornandsoybeandigest.com/ag-issues/glyphosate-resistance-rising-0201; www.france24.com/en/20090418-superweed-explosion-threatens-monsanto-heartlands-genetically-modified-US-crops. http://deltafarmpress.com/cotton/palmer-amaranth-1226; Wilkinson et al, 2003, ‘Hybridization between Brassica napus and B. rapa on a national scale in the United Kingdon’, Science 17 October 2003: Vol. 302. No. 5644, pp.457-459, www.sciencemag.org/cgi/content/abstract/302/5644/457?etoc; ‘Glyphosate-resistant Palmer amaranth (Amaranthus palmeri) confirmed in Georgia’, Culpepper et al, 2006, Weed Science 54(4):620-626. 2006, www.bioone.org/doi/abs/10.1614/WS-06-001R.1; ‘Explosion Threatens Monsanto Heartlands France,’ 2 May 2009, www.scoop.co.nz/stories/WO0905/S00064.htm. ‘Glyphosate-resistant Hairy Fleabane in Spain’, Urbano et al, Weed Technology April 2007, Vol. 21, Issue 2, pp 396-401, www.bioone.org/doi/abs/10.1614/WT-06-096.1. ‘Identifying Glyphostate-resistant Marestail/Horseweed in the Field’, 21 July 2003, www.btny.purdue.edu/weedscience/. S I Warwick, A Legere, M-J Simard and T James, ‘Do escaped transgenes persist in nature? The case of an herbicide resistance transgene in a weedy Brassica rapa population,’ www.ncbi.nlm.nih.gov/pubmed/17971090.)
6.3. In Australia, ryegrass is a problematic weed and also a valuable pasture plant. In 1997, Monsanto Company confirmed that samples of this ryegrass were found resistant to glyphosate, the active ingredient in its herbicide, Roundup. That same year, samples of Malaysian goosegrass, a noxious weed, were also found resistant to glyphosate. This came after herbicide resistant crops being introduced a short time before. It is worth noting that Australia’s annual bill for superweed damage to agriculture and the environment is reportedly AUD$4 billion. Biocontrol agents can be useful, but not always possible.
(‘Herbicide Resistant Weeds’, J L Gunsolus, www.extension.umn.edu/distribution/cropsystems/DC6077.html#Biotypes; Ministry of Agriculture, Food and Rural Affairs, Ontario, ‘Herbicide Resistant Weeds’, www.omafra.gov.on.ca/english/crops/facts/01-023.htm; ‘Monsanto Confirms Australian Rye Grass Resistant to Roundup,’ Matt Brown, Weed World, ABC, 14 September 1997, www.abc.net.au/rn/talks/bbing/stories/s326.htm. ‘A first report of glyphosate-resistant goosegrass (Eleusine indica (L) Gaertn) in Malaysia’, Lim Jung Lee, Jeremy Ngim, Pest Management Science, Vol. 56, Issue 4, pp 336-339, March 2000, www3.interscience.wiley.com/journal/71000393/abstract.)
7. Working in New Zealand’s interest: economy; ecology
7.1. We remind ERMA that ArborGen is substantially owned by US interests. The one-third share of ArborGen owned by the New Zealand company, Rubicon, is in itself over 80 percent owned by US interests. The remaining two-thirds of ArborGen are owned by large US companies. The US has reportedly the world’s largest development of transgenic trees. They have a vested interest in this Application.
7.2. This experimentation is not in New Zealand’s best interests. Internationally, overseas interests will see New Zealand as the instigator of a new environmental threat likely to draw a similar response to that given to the initial appearance of Terminator Gene Technology. The adverse economic reverberations could be considerable. A major customer, Japan, does not tolerate transgenic products. European nations are reluctant to accept transgenic products.
7.3. Forestry interests growing conventional trees will see approval of this Application as a threat to their livelihood, as indeed it has the potential to be.
7.4.. The long lifespan of the intended final product, transgenic trees, makes the potential risks all the greater. A forest is its own ecosystem and that ecosystem could be destroyed during the average thirty year lifespan of a pine tree.
PSGR opposes this Application aware that there have previously been several issues of non-compliance by Scion at its Rotorua transgenic field trial site exposed. Approval would not be in the best interests of New Zealand forestry, environment, exports or employment.
Signed by the Trustees of Physicians and Scientists for Global Responsibility by Jean Anderson
Paul G Butler, BSc, MB, ChB, Dip. Obst. (Auckland), FRNZCGP, General Practitioner, AUCKLAND
Jon Carapiet BA (Hons), MPhil, Senior market researcher, AUCKLAND
Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM, MRCGP (UK), FRNZCGP, General Practitioner, MURUPARA
Elvira Dommisse BSc (Hons), PhD, Mus.B, LTCL, AIRMTNZ, Scientist, Crop & Food Research Institute (1985-1993), working on GE onion programme, CHRISTCHURCH
Michael E Godfrey, MBBS, FACAM, FACNEM, Director, Bay of Plenty Environmental Health Clinic, TAURANGA
Elizabeth Harris MBChB, Dip.Obst, Cert. NZ Sports Med., Cert. Proficiency in Child Health, Cert. NZ Family Planning, Dip. Musculoskeletal Med., FRNZCGP, General Practitioner, DUNEDIN
Frank Rowson BVetMed, Veterinarian in a large animal practice, MATAMATA
Peter R Wills, BSc, PhD, Associate Professor, Theoretical Biology, University of Auckland, AUCKLAND
Damian Wojcik BSc, MBChB, Dip.Theology, Dip. Obstetrics, Dip.Child Health (DCH), FRNZCGP, FIBCMT (USA), Director, Northland Environmental Health Clinic, WHANGAREI
Jean Anderson, Businesswoman retired, TAURANGA.