November 2016 Letter to all New Zealand Councillors 8-11-16

8 November 2016

For the attention of all New Zealand Councils and Councillors

As recently elected representatives of residents in your region we acknowledge your responsibility and concerns for sustainable land use, limiting the consequences of releasing genetically engineered organisms into your environment, and preserving the reputation and integrity of regional economies for exporting clean, safe products that New Zealand overseas markets buy from us knowing they are GE-free.

Physicians and Scientists for Global Responsibility is a Charitable Trust established to provide independent scientific assessment and advice on matters relating to genetic engineering and other scientific and medical matters. In this capacity, informative letters have been regularly addressed to all New Zealand Councillors since 2003.

Recently, one Councillor admitted not knowing what genetically engineered organisms are. That Councillor was also unaware of the tremendous efforts over more than a decade made by the Northland Councils, Bay of Plenty Regional Council, and Auckland Council to protect ratepayers from the risks of releasing genetically engineered organisms into the New Zealand environment, or that Hawkes Bay is working towards the same goal and other Councils acknowledge the importance of action on this issue.

This situation has led us to send the following material.

We ask every re-elected and new Councillor to read and absorb so that each can meet their duty of care to those in their region from a sound knowledge base.

Note that genetic engineering, genetic modification and transgenic are used synonymously. Biotechnology is also used to describe the technologies. Biotechnology has made important advances adding much of value to our scientific heritage. However, the technologies of genetic manipulation are seriously flawed and comprise only a small part of biotechnology applications.

PSGR’s concern is with such novel organisms being released into the New Zealand environment.

Moving genes between species is changing our world. It, and the patenting of plants and animals, has extended property rights into biology, providing the potential for direct control over much agricultural production and the food supply.[1] In 1994, four seed companies controlled 21% of the market. Subsequently, mergers and the purchase of smaller companies means four transnational seed companies and four transnational agrochemical firms now control over half their respective markets globally.

Monsanto is the world’s largest seed producer, helped in this by selling glyphosate herbicide (Roundup) for use on its crops genetically engineered to withstand the chemical. In the US, overuse of glyphosate has resulted in weeds developing resistance and spreading over millions of hectares of farmland. Monsanto is now developing crops resistant to another toxic herbicide, dicamba.[2] Herbicide resistance, or herbicide tolerance, engineered into food crops is to allow farmers to spray freely without killing the crop. Scientists predict wide-spread heavy, use of dicamba will also lead to weeds becoming resistant to the chemical.

Commercial plantings of transgenic food crops were first grown in the mid 1990s. It was soon apparent that they threatened the environment.

In New Zealand, Northland Councils took action by establishing The Inter-Council Working Party on Genetically Modified Organisms (GMO) Risk Evaluation and Management Options (ICWP) in response to community concerns about transgenic organisms. Auckland Council is also represented in the working party.

The following is a summary from the Whangarei District Council website[3]:

Three major reports commissioned by the Working Party have identified a range of risks involved with the trialling and release of GMOs. They also include approaches to managing those risks.

Environmental risks

GMOs becoming invasive and affecting non-target species including indigenous flora and fauna
The development of herbicide or pesticide resistance creating 'super-weeds' or 'super-pests'
Long-term effects on ecosystem functioning.

Socio-cultural risks

Effects on Maori cultural beliefs of whakapapa, mauri, tikanga
Ethical concerns about mixing genes from different species including human genes
Concerns about the long term safety of genetically modified food.

Economic risks

Loss of income through contamination (or perceived contamination) of non-GMO food products
Negative effects on marketing and branding opportunities such as 'clean and green' or 'naturally Northland'
Costs associated with environmental damage such as clean-up costs for invasive weeds or pests.

Linked to these risks are limited liability provisions under the Hazardous Substances and New Organisms (HSNO) Act 1996.[4]

Challenges have been made to the right of Councils to have ‘precautionary statements’ in their Regional Policy Statements and a cautionary approach with their Plans, and Councils’ rights have been upheld in New Zealand Courts.

What is genetic engineering?

Genetic engineering (GE) is the artificial, direct alteration of an organism's DNA. It usually involves genes being taken from a natural host and inserted into a new host; for example, fish genes into tomatoes and strawberries.[5] The application of genetic engineering technologies alters the DNA of a living organism in ways that are much more radical than the generally incremental, slow processes of natural evolution.

PSRG sees fundamental research into these and other aspects of molecular biology as important to New

Zealand - for example, using the technologies to produce pharmaceutical and industrial materials – but also sees that health and scientific professionals in New Zealand, indeed worldwide, have grave concerns about aspects of genetic engineering technologies. As we have said above, biotechnology has added much of value to our agricultural and scientific heritage. However, the trial and error approach to evaluating the effects of genetic manipulation is inappropriate and dangerous when novel organisms enter the natural environment.

The natural complex inter-relationships between organisms are genetically determined in ways about which we have little knowledge. You can read more on our website www.psgr.org.nz. See Frequently Asked Questions http://www.psgr.org.nz/faqs.

Currently, a New Zealand Crown Research Institute, trading as Scion, runs a limited scale open field trial of genetically engineered trees near Rotorua. Other experiments are carried out in containment. Approving transgenic organisms for release into the New Zealand environment is the responsibility of this country’s Environmental Protection Authority (EPA). However, once the EPA approves a genetically engineered organism for release their responsibility ends. There is no independent monitoring of effects, good or adverse.

PSGR maintains that the risks revealed – proven overseas in abundance – should not be allowed to contaminate our environment. This is where Councils have a right to have a say. Northland, Auckland and Bay of Plenty have precautionary statements in their Plans. Hawkes Bay is a recent addition in taking action. Polls have shown that a significant portion of the population does not want genetically engineered organisms released into the environment.[6] Hastings District has gone so far as to become “GE Free”.[7]

Proposed changes to the Resource Management Act would bar Councils from protecting their region.

PSGR opposes the changes based on the record of past decisions made by New Zealand’s central government and regulatory authorities.

New Zealand is in a unique position in that our borders are bounded by extensive distances of sea.

Contamination is virtually impossible by air-borne DNA coming over those seas. We can protect this country’s environment and retain it as Clean Green and 100% Pure.

New Zealand’s Ministry of Primary Industries requires testing of imported seed for the presence of transgenic seed for specific species and varieties of the following genera: Brassica, Glycine, Medicago and Zea.[8] In testing hundreds of kilograms of imported maize seed for sowing annually[9] the presence of transgenes has been found in Sweet Corn and maize multiple times.[10]

Food imports contaminated by viable transgenic organisms represent a risk to the international food and feed trade.[11] New Zealand imports around 200,000 tons of animal feed annually. This includes engineered crops claimed as “non-viable” and inspected although we understand not tested by the Ministry of Primary Industries.

Some plants are genetically engineered with one trait, some with more than one; known as ‘gene stacking’.

The most common traits are herbicide resistance and using genes from the soil bacterium Bacillus thuringiensis to produce a Bt insecticide.

Since the introduction of transgenic crops resistant to glyphosate two decades ago, its use in the US has increased dramatically[12] and its effectiveness diminished. The industry solution is to use chemicals such as 2,4-D and dicamba, both of which belong to a chemical class that has been associated with increased rates of diseases, including non-Hodgkins lymphoma.[13] Another industry solution is to develop genetically engineered crops which scientists see as creating new generations of increasingly more intractable weeds controlled with yet more herbicides, leading to an era of much increased use of and dependence on pesticides.

Introduced genes can transfer to other species in a process called horizontal gene transfer (HGT). Transgenic

DNA has crossed between corn/maize varieties, between canola varieties, and between transgenic crops and wild relatives. Just five years after the release of the first genetically engineered commercial crops in Alberta,

Canada, chemical and DNA testing confirmed canola volunteers had acquired resistance to three chemicals: Roundup, Liberty and Pursuit.[14] In Argentina, transgenic soy and corn/maize comprise 100% of production of those crops. A survey by Friends of the Earth found agricultural chemical use between 1990 and 2013 has risen from 3 to 12 litres per hectare.

Of concern in New Zealand is the potential introduction of transgenic ryegrass. English perennial ryegrass is the principal seed used for permanent pasture for grazing, hay and silage. New Zealand ryegrass seed meets a substantial percentage of global demand, contributing significantly to the economy, and perennial ryegrass is dominant in herbage seed production, worth around NZ$50 million annually. This is supported by our international reputation as a supplier of high-quality seeds. Export markets - the US, Australia, Europe, Japan, China and South America - look for purity and trueness to type, qualities based on our solid reputation and the fact that we are free of the transgene contamination that has resulted overseas from growing GE crops. A key part of this success is the voluntary seed certification and isolation distance management systems (SCID) being operated for the industry by AsureQuality. Pasture seeds, primarily ryegrass and clovers, also support our livestock and dairy industry, which represents 60 percent of NZ's exports.

PGG Wrightson and the New Zealand taxpayer are partners to the development of a transgenic ryegrass by Australia’s Molecular Plant Breeding Cooperative Research Centre.

Perennial ryegrass is a highly out-crossed, wind-pollinated species, and is subject to extensive gene flow. A significant concern is the possibility of transgenes being taken up in other plants nearby. Certainly, the potential rate of natural cross-pollination reduces with distance, but it is unknown how many times cross-pollination can continue by a hop, skip or a jump, or what distances, or for what period of evolutionary time.

For example, researchers found evidence from a monitored planted area of a RoundUp-resistant transgene from genetically engineered bentgrass (Agrostis stolonifera L) in a related species (Agrostis gigantea) growing 14 km away and in wild-growing plants of the same species 21 km away. Most of the gene flow occurred within two kilometres in the direction of prevailing winds.

For anyone not convinced transgenes in pollen can travel that far, 'Pollen-Rain from Vegetation of Northwest India,' reported pine pollen found in Northern India over 600 km from the nearest pine trees. New Zealander, Faranty Desborough, an experienced pilot, speaking to the Hawkes Bay Times in October 2003 said, “I have flown in a thermal at 7000 feet altitude over a corn field that was being harvested and was surrounded by corn husks that were being sucked up by the thermal.” A southerly wind will carry sand from the Sahara Desert to settle on cars in London and just four days after the first bombing raid over Iraq in 2003, traces of depleted uranium were detected in New York. Once in the atmosphere, pollen and other particles can travel the globe.

Perennial ryegrass cross-pollinates freely with annual and Italian ryegrass. Consequently, many hybrid ryegrasses have developed. And ryegrasses are typical of invasive weed species found in rural and urban riparian zones. Grass seeds can germinate after passing through an animal's digestive system. Seeds recovered from faeces 12-24 hours after feeding proved viable and seedlings started to emerge one week after planting. Seeds have also been transported in the wool of sheep and, in the case of perennial ryegrass, remained in the wool for 1-2 months.

It would be impossible to protect the genetic purity and trueness to type of perennial ryegrass from artificially created transgenes. Transgenic escapees can simply go on spreading and contaminating. We cannot guarantee control over their movement: by human or mechanised traffic; by insects, birds and mammals; by wind and rain. Genetically engineered plants can potentially wreak ecological chaos.

Speaking on a DVD about genetically engineered trees - A Silent Forest: The Growing Threat, Genetically Engineered Trees – Dr David Suzuki of The Suzuki Foundation, says: “As a geneticist, I believe there are far too many unknowns and unanswered questions to be growing genetically engineered plants – food crops or trees – in open fields. . . . The rush to apply the ideas of genetic engineering is absolutely dangerous because we don’t have a clue what the long-term impact of our manipulations is going to be.”

A government report said the NZ clean green image is what sells, that NZ companies “need to understand who their customers are and what really makes a difference to those customers.” This applies to Councils serving their local industries. Common-sense should tell us that the sensible thing to do is to protect our environment, our economy and the well-being of New Zealanders. Why endanger that by releasing transgenes into the environment?

This country's primary exports are diary products, meat, fruit and fish; about 95% of our agricultural produce exported. New Zealanders and many overseas markets want “GE-free” foods. Germany, strongly anti-GE, buys our meat and dairy products worth some NZ$756 million/pa, Japan around 11% of our exports.

A prime indicator of why New Zealand should not release or grow genetically engineered organisms is because insurance companies will not insure against damage and governments are reluctant to legislate on liability. When Minister for the Environment, David Benson-Pope, confirmed that if transgenic contamination occurs in New Zealand it will be those affected by the pollution who will pay - local councils and growers.

An increasing number of Councils are looking at how to handle genetically engineered organisms in their region. Concerns cover contamination, and the impact on local industry, agriculture, health and tourism. It is vital Councillors understand the risks and act accordingly to meet their duty of care to ratepayers.

Fortunately, New Zealand has strong bio-safety laws and application procedures. Despite this, not all decisions are seen as wise by independent scientists and experts. Government and regulators are heavily lobbied by industries. By having precautionary statements in hand, Councils can look after their immediate duty of care, their residents.

The Trustees and Members of Physicians and Scientists for Global Responsibility Charitable Trust

Further reference material:

‘Jurisdiction of Councils to Regulate GMOs under the RMA, Response to Christensen and Nicolle, Anderson Lloyd Lawyers’
Dr Kerry Grundy, Convener Inter-Council Working Party on GMO Risk Evaluation and Management Options http://www.rmla.org.nz/upload/files/obiter/jurisdiction_of_councils_to_regulate_gmos_under_the_rma_-_dr_kdy.pdf
Genetically Engineered Crops in the United States, Fernandez-Cornejo et al, Economic Research Report No. (ERR-162) 60 pp, February 2014 http://www.ers.usda.gov/media/1282246/err162.pdf
The International Survey of Herbicide-Resistant Weeds monitors the evolution of the most common herbicide resistance genes across a wide range of weedy species. See http://weedscience.org/ .
International Service for the Acquisition of Agri-Biotech Applications (ISAAA)
List of GE crops and information on them http://www.isaaa.org/gmapprovaldatabase/cropslist/
The ETC Group - Seeds & Genetic Diversity http://www.etcgroup.org/issues/seeds-genetic-diversity
The Union of Concerned Scientists Genetic Engineering Benefits: Promise vs. Performance

http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/genetic-engineering/genetic-engineering-benefits.html#.VtnefkCqCuI

Failure to Yield: Evaluating the Performance of Genetically Engineered Crops http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/genetic-engineering/failure-to-yield.html#.VtneykCqCuI
High and Dry: Why Genetic Engineering Is Not Solving Agriculture's Drought Problem in a Thirsty World http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/genetic-engineering/high-and-dry.html#.VtnfKECqCuI

Ends

[2] http://www.panna.org/sites/default/files/dicamba-NCAP.pdf

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

[4] https://www.boprc.govt.nz/media/321876/environment-court-decision-18-dec-2013-env-2012-339-000041-part-one-section-17.pdf

[5] http://thegreendivas.com/2011/06/10/waiter-theres-a-fish-in-my-tomato-a-gmo-story/

[6] http://www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Documents/GE-Poll/GE-Poll-Results-Auckland-Region.pdf; http://purehawkesbay.org/wp-content/uploads/2012/06/OverwhelmingSupportforGMFreeHawkesBay.pdf.

[7] http://www.nzherald.co.nz/hawkes-bay-today/news/article.cfm?c_id=1503462&objectid=11512135

[8] http://www.biosecurity.govt.nz/regs/imports/plants/gmo

[9] http://www.biosecurity.govt.nz/regs/imports/plants/gmo/corn-maize

[10] http://www.biosecurity.govt.nz/regs/imports/plants/gmo/corn-maize

[11] https://www.euractiv.com/section/agriculture-food/news/fao-study-cases-of-gmo-contamination-rise/ FAO study: Cases of GMO contamination rise, Philippe Collet, 20 March 2014 (updated: 27 Mar 2014)

[12] http://www.ers.usda.gov/amber-waves/2015-may/managing-glyphosate-resistance-may-sustain-its-efficacy-and-increase-long-term-returns-tocorn-and-soybean-production.aspx#.VtTiPECqCuI

[13] http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/industrial-agriculture/the-rise-of-superweeds.html#.VtYadkCqCuJ

[14] https://www.organicconsumers.org/old_articles/ge/superweed.phpl; http://weedscience.org/mutations/mutationdisplayall.aspx

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