2012 Northland Regional Council 1 November 2012

1 November 2012

The General Manager, Ian Walker, CEO Malcolm Nicolson and Regional Councillors

Northland Regional Council

36 Water Street

WHANGAREI

Dear Sir and Councillors

The Trustees and Members of PSGR thank Northland Regional Council for the opportunity to write in support of the Proposed Regional Policy Statement for Northland.

Recently, Bay of Plenty Regional Council (BOPRC) agreed to promote “a precautionary approach to the release, control and use of genetically modified organisms within the region.” This forms part of its Regional Policy Statement and supports sustainable management in the Bay of Plenty region.

We applaud your Council in anticipation of your maintaining your previous strong position on genetic engineering, and with the possible addition of a statement on nanotechnology complimenting BOPRC‘s Ten Year Plan 2012-2022 and RPS.

PSGR hopes these actions will encourage other Councils to do likewise.

Regional Policy Statements should support the continued wellbeing of communities and the environment and taking a precautionary and preventative approach to genetically engineered/ modified organisms supports this. PSGR has raised these two issues during a decade of correspondence with all New Zealand Councils.

Independent peer-reviewed research published over that time confirms the inadequacy of current assessment and regulatory frameworks to manage the risks of genetically engineered organisms and emphasises the need for a responsible precautionary approach.

In support of our position, we provide the following material:

Genetically engineered organisms: animals and the human population

While government established the Hazardous Substances and New Organisms Act, and the Environmental Protection Agency, there is a large body of scientific and public opinion in New Zealand that finds they fall short of what is required.

This same body suggests vested interest has in the past been shown to hold sway on decisions, at times without sufficient public input, and without that vested interest being held accountable for potential mishaps.

Claims of “being left behind” and not benefiting financially from the “bonanza” of genetic engineering do not stand up when overseas experiences are viewed objectively. Too many so-called advances are pushed for short term financial gain for the few without consideration for the long term effects on the many and future generations, or for the environment. There are also recognised economic benefits in avoiding loss of ecological systems, sustainable food production, and safe food.

A strong stance is vital in respect of genetic engineering, in not releasing these novel organisms into the environment, and for the placement and location of appropriate containment facilities for research, and the oversight of such establishments. Regrettably, research establishments have not generally shown an appropriate level of duty of care with transgene experimentation in field trials outside of the laboratory. These facts have been well publicised by the New Zealand media. Such shortcomings potentially threaten the human and physical environments, disregard accountability, and leave liability and costs to be met by Councils, ratepayers and the environment. We remind Council that David Benson-Pope, then Minister for the Environment, confirmed that dealing with transgene contamination would be the responsibility of the person/s affected and Councils, not the polluter.[i]

Much of the research for which genetic engineering technology is used can in fact be safely carried out using conventional methods such as selective breeding and marker assisted breeding, and also using alternative proven medical applications in containment. The consequences of these established methods are known whereas those arising from genetic engineering technology are not known with any degree of certainty, and experiences suggest they are not wholly safe. The complexity is the basis for the refusal of commercial insurers to cover the risk of damage from genetically engineered organisms and the resulting exposure of communities to costs.

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

The recent announcement of a single cow genetically engineered to produce milk with lower allergenic properties follows expensive experimentation with transgenic cows since 2006 and it is admitted that it is still some years away from being fully understood. While we do not know how the human gut will react to transgenes from this cow, we do know transgenes can transfer into bacteria in the human gut and remain functional.[iii] What effects that functionality will produce and how long they will continue are unknown.

In the future, the novel cow and any potential offspring will continue to produce waste matter which can potentially enter ground water and soil biota. The persistence and movement of transgenic DNA in agricultural and natural systems is largely unknown, particularly for animals.

Results found by Hart et al (2009) demonstrated the persistence of transgenic crop DNA residues within a food web.[iv] Soil micro-organisms are essential for building healthy, nutrient-rich soil, yet an analysis of fields planted with Monsanto’s transgenic cotton showed soil micro-organisms decreased dramatically.[v] Mulder et al (2006) found data supported the existence of transgenic-associated Bt-induced ecological shifts in microbial communities of croplands’ soils.[vi]

Working with over 30 scientists worldwide, Jeffrey Smith, executive director of the Institute for Responsible Technology, documented 65 health risks of transgenic foods. He said: “There are thousands of toxic or allergic-type reactions in humans, thousands of sick, sterile and dead livestock, and damage to virtually every organ and system studied in laboratory animals.” He continued: “The process of inserting a foreign gene into a plant cell and cloning that cell into a genetically engineered crop produces hundreds of thousands of mutations throughout the DNA. Natural plant genes may be deleted or permanently turned on or off, and hundreds can change their function. This massive collateral damage is why GE soy has less protein, an unexpected new allergen, and up to seven times higher levels of a known soy allergen. It also may explain why British soy allergies skyrocketed by 50% soon after GE soy was introduced.”[vii]

Seralini et al (2012) looked at the health effects on rats consuming transgenic Roundup-tolerant maize cultivated with or without Roundup, and Roundup alone over a period of two years. The researchers say the results can be explained by the non-linear endocrine-disrupting effects of Roundup and the over-expression of the transgene in the transgenic maize and its metabolic consequences. Examples of results include: chronic hormone and sex dependent pathologies provoked; female mortality increased 2–3 times; males developed liver congestions, necrosis, severe kidney nephropathies and large palpable tumours.

Over three generations and two years, researchers at the Institute of Ecology and Evolution of the Russian Academy of Sciences and the National Association for Gene Security looked at four groups each of five pairs of hamsters with a fast reproduction rate. One group was fed a diet without any soy, one with non-GE soy, a third included GE soy, and a fourth contained higher amounts of GE soy. By the third generation, the hamsters fed the most transgenic soy lost the ability to reproduce, suffered slower growth, and a high mortality rate among the pups.

In 2005, Dr Irina Ermakova of the Russian National Academy of Sciences found over half the babies from mother rats fed GE soy died within three weeks. An Austrian government study released in 2008 found the more GE corn fed to mice, the fewer the babies and the smaller those babies were.

In India, animals grazing transgenic cotton plants after harvest died in large numbers. Post mortems showed severe irritations and black patches in both intestines and liver, and enlarged bile ducts. In a follow up study by the Deccan Development Society, sheep fed Bt cotton plants died within 30 days, whereas sheep grazed on conventional cotton plants without adverse effects. Farmers on three continents link Bt corn varieties with sterility in pigs and cows, or deaths among cows, horses, water buffaloes and chickens.^iv

Few studies on these developments attract funding or receive monies to continue research findings. Consequently, the scientific and medical fraternity can professionally only speculate about a relationship between the introduction of transgenic food crops in about 1996 and the corresponding increase in infertility and other problems reported in the US population, where transgenic food crops form a substantial part of the everyday diet.

A position paper from the American Academy of Environmental Medicine (AAEM) stated animal studies indicate serious health risks associated with transgenic foods, “including infertility, immune problems, accelerated aging, insulin regulation, and changes in major organs and the gastrointestinal system.”

The young, the elderly and those with suppressed immune systems are especially vulnerable to potential harmful effects from genetically engineered organisms. The AAEM called on “physicians to educate their patients, the medical community, and the public to avoid GE foods”.[viii]

Genetically engineered organisms: emission into the environment

Unlike simple chemical or other potential contaminants that may be emitted into the environment, the complex nature of living organisms adds a new dimension to risk management of emissions and pest organisms. Gene flow via seed or pollen is a basic biological principle of plant evolution. Gene flow also occurs through vehicle and foot traffic, weather and animals. The problem of wilding pines is one example of the spread of organisms that can cost some Councils millions of dollars to remediate.

One study read: “Ecological risks associated with the release of transgenic crops include non-target effects of the crop and the escape of transgenes into wild populations.”[ix] Since the introduction of transgenic crops, herbicide-resistant transgenes have transferred to weed species creating ‘super’ weeds, in some instances weeds resistant to multiple herbicides, referred to as gene stacking. Australia’s annual bill for superweed damage to agriculture and the environment is AUD$4 billion. Scientists admit super weeds are a major problem for US farmers where a high percentage of transgenic crops are grown.[x] [xi]

The proposal to genetically engineer ryegrass for use in New Zealand pastures poses the same risks of contamination. Within a very short time of the first Roundup-resistant crops in Australia, Australian ryegrass became resistant to Roundup. Perennial ryegrass is a highly outcrossed wind-pollinated species and subject to extensive gene flow.[xii] Conventional New Zealand ryegrass seed is well-proven worldwide, and meets a substantial percentage of global demand.[xiii] This market would be at risk from transgenic ryegrass.

To overcome the problem of herbicide-resistant weeds, industry proposes the application of chemicals which are known to be more toxic than those currently in general use. Crops are being developed 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).[xiv] DNA from these new herbicide-resistant crops will potentially transfer resistance to the new chemicals to weeds. Scientists in Nebraska have already found waterhemp resistant to 2,4-D[xv] and scientists at the University of Illinois have found waterhemp resistant to HPPD-inhibiting herbicides. Waterhemp is historically a problematic weed in the US Corn Belt.[xvi]

Feral transgenic plants are also established. In 2012, transgenic canola/oilseed rape was found growing in the port area of Basel, Switzerland, despite the importation of transgenic crops in foodstuffs and animal feed being prohibited.[xvii] In 2005, feral transgenic canola was discovered in Japanese ports. Transgenic canola is not cultivated in Japan.[xviii] In North Dakota, feral canola is commonly found, particularly growing beside highways.[xix] In one study of 288 feral canola plants tested, 80% (231 plants) “expressed at least one transgene” (CP4 EPSPS/glyphosate resistance) and 39% (112 plants) were positive for PAT/glufosinate resistance.[xx] A Swedish study found transgenic canola seed could survive in the wild and remain viable even 10 years after release.[xxi]

The UN Food and Agriculture Organization say 75% of crop genetic diversity has been lost in the last one hundred years. This is termed genetic erosion. According to Genetic Resources Action International "only 20% of local maize varieties reported in Mexico in 1930 are still known."[xxii] Mexico is the Centre of Origin[xxiii] for corn/maize and landraces have in the past provided material to breed viable improved or new varieties to replace commercial crops that have failed. For example, in 1970, the southern US corn crop was attacked by Cornleaf Blight and because the maize varieties were generally uniform, 15% of the harvest was lost, then worth around US$1 billion. Landraces were used in the recovery. Trucks arriving from the US carrying corn that is not milled, with loads that include viable transgenic corn, are largely blamed for the contamination of the remaining corn landraces in Mexico.

A New Scientist review reported that researchers at the Environmental Protection Agency found transgenic glyphosate-resistant creeping bentgrass can pollinate other grasses up to 21 kilometres away.[xxiv] [xxv]

Transgenes do escape and can potentially travel vast distances. Cross pollination is common. A study undertaken in India established that pollen from pine trees travelled over 600 kilometres (Sing et al, 1993). Since 2005, GeneWatch UK and Greenpeace International have maintained a Contamination Register of publicly documented incidents of intentional or accidental release of transgenic organisms, including illegal plantings of transgenic crops, and contaminated foodstuffs on www.gmcontaminationregister.org/.

Genetically engineered organisms and the precautionary principal

There is a growing amount of substantive material providing sound scientific reasons for the application of a precautionary approach to genetic engineering technology and its products. We attach further reference sources for your information.

The National Farmers Union of Canada has said: “Over the past decade, corporate and government managers have spent millions trying to convince farmers and other citizens of the benefits of genetically modified (GM) crops. But this huge public relations effort has failed to obscure the truth: GM crops do not deliver the promised benefits; they create numerous problems, costs, and risks; and … consumers and foreign customers alike do not want these crops. It would be too generous even to call GM crops a solution in search of a problem: these crops have failed to provide significant solutions, and their use is creating problems – agronomic, environmental, economic, social, and (potentially) human health problems.”[xxvi]

US farmers who decided to plant transgenic crops can be heard speaking of their experience after growing them on http://www.youtube.com/watch?v=jEX654gN3c4&feature=plcp (24 min).

The risks arising from commercial pressures and vested interest to exploit transgenic organisms must not be forced on communities, public health, ratepayers or the environment. In context of the incomplete scientific understanding of the significant risks of genetically engineered organisms, a Council policy of precaution will be viewed as a vital form of insurance for its local communities and the environment in which they live.

Nanotechnology

We also ask that Northland Regional Council consider making a statement regarding Nanotechnology as has the BOPRC. Responsible handling of waste material from the products of nanotechnology is vital. A recent study has established that manufactured nano-materials can enter soil and be taken up by plants.[xxvii]

We again refer you to the City of Berkeley in California website which details how the City took the first steps to safely control the waste created by the manufactured products of nanotechnology.

Berkeley Municipal Code http://www.ci.berkeley.ca.us/uploadedFiles/Clerk/Level_3_-_General/BMC-Part1-T1-22--091807.pdf, title 15, pages 9 and 10.

Berkeley reports on: http://www.ci.berkeley.ca.us/uploadedFiles/Planning_(new_site_map_walk-through)/Level_3_-_General/Manuffactured%20Nanoscale%20Materials.pdf.

We also refer you to:

PSGR letter to the Right Hon. Helen Clark, Prime Minister, dated 3 October 2007.

http://www.psgr.org.nz/index.php?option=com_content&view=article&id=43:nanotechnology&catid=28:letters-to-government&Itemid=41 and to ‘Nano waste: How do we deal with it?’ Organic New Zealand, November/December 2010 and ‘Nanotechnology: safe or not?’ Organic New Zealand,September/October 2010.

Regional Policy Statement for Northland

PSGR claim it is irresponsible to release genetically engineered organisms into the environment, whether through animals, trees or crops grown for human or animal consumption or for use in producing biofuels[xxviii].

PSGR asks Council to take a bold responsible stand in the Proposed Regional Policy Statement for Northland in respect of genetic engineering and a preventative policy in respect of nanotechnology.

Genetic engineering technology raises questions of science, ethics, law, and economics which are still being debated. Transgenic crops were seen as advantageous to producers and/or consumers, promising increased yields, decreased costs and agri-chemical use, and a cheaper and/or more nutritious product. Experience has not met these promises. A study of 94 articles selected objectively found the existence of either financial or professional conflict of interest associated with study conclusions casting transgenic products favourably.[xxix] The vast profits available means only applying the precautionary approach to transgenic crops and food by the public and the public’s representatives is likely to offer protection in the immediate future.

Signed by the Trustees of Physicians and Scientists for Global Responsibility

Further relevant material:

PSGR website for Frequently Asked Questions

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

Geneticist, Dr David Suzuki speaks: A Silent Forest. The Growing Threat, Genetically Engineered Trees (Runs 46.13 min) on http://www.youtube.com/watch?v=w437uQf_A7c

‘Do escaped transgenes persist in nature? The case of an herbicide resistance transgene in a weedy Brassica rapa population.’ S I Warwick, A Legere, M-J Simard and T James, http://www.ncbi.nlm.nih.gov/pubmed/17971090

‘Hybridisation between Brassica napus and B. rapa on a National Scale in the United Kingdom’, M N Wilkinson et al, Science, 9 October 2003, http://www.highbeam.com/doc/1G1-109959048.html

‘Resistance to HPPD-inhibiting herbicides in a population of waterhemp (Amaranthus tuberculatus) from Illinois, United States’, Hausman NE et al, Pest Manag Sci. 2011 Mar;67(3):258-61. doi: 10.1002/ps.2100. Epub 2011 Jan 26. http://www.ncbi.nlm.nih.gov/pubmed/21308951.

http://www.mindfully.org/GE/Monsanto-Confirms-RR-Resistant.htm

‘Spread of herbicide-resistance from genetically modified creeping bentgrass into the wild’, The Nature Institute, 2008, http://natureinstitute.org/nontarget/reports/bentgrass_001.php

‘Vertical Trans(gene) Flow: Implications for Crop Diversity and Wild Relatives’, by David Quist, Third World Network, 2010, http://www.twnside.org.sg/title2/biosafety/pdf/bio11.pdf

http://www.twnside.org.sg/title2/biosafety/pdf/bio11.pdf

http://www.greenpeace.org/international/en/news/Blogs/makingwaves/banned-ge-canola-found-growing-in-swiss-port-/blog/40733/;

http://www.environmentalhealthnews.org/ehs/news/2012/gm-crops-escape-and-grow-wild

http://www.nature.com/news/2010/100806/full/news.2010.393.html

‘The Establishment of Genetically Engineered Canola Populations in the US’, Meredith G Schafer et al, www.plosone.org/article/info:doi/10.1371/journal.pone.0025736;

http://www.environmentalhealthnews.org/ehs/news/2012/gm-crops-escape-and-grow-wild;

'The Social Implications of Animal Biopharming in New Zealand' www.conversations.canterbury.ac.nz/documents/biopharming.ppt

References

[i] Northern Advocate, 26 July 2007

[ii] GMO Myths and Truths, An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops. http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.2.pdf.

[iii] ‘Assessing the survival of transgenic plant DNA in the human gastrointestinal tract’, Netherwood et al, 2004, http://www.stopogm.net/sites/stopogm.net/files/netherwoodsurvival.pdf.

[iv] http://www.agronomy-journal.org/index.php?option=com_article&access=standard& Itemid=129&url=/articles/agro/abs/2009/04/a9079/a9079.html.

[v] Justice and Sustainability News, 6 March 2009, Issue No 164.

[vi] http://www.ploscompbiol.org/article/info%3Adoi%2F10.1371%2Fjournal.pcbi.0020128.

[vii] ‘Eating GM foods is a health risk’ Jeffrey Smith, 28 November 2007, http://www.theage.com.au/ news/opinion/eating-gm-foods-is-a-health-risk/2007/11/27/1196036889507.html.

[viii] http://www.huffingtonpost.com/jeffrey-smith/genetically-modified-soy_b_544575.html.

[ix] ‘Ecological effects of transgenic crops and the escape of transgenes into wild populations’, Pilson and Prendeville, http://fbae.org/2009/FBAE/website/images/PDF%20files/ Imporatant%20Publication/ecological%20effects%20of%20transgenes.pdf.

[x] Prentis et al, ‘Adaptive evolution in invasive species’, Trends in Plant Science, 13:6, June 2008, pp 288–294; www.cell.com/trends/plant-science/abstract/S1360-1385%2808%2900126-X; ‘Stop the superweeds: Adelaide biologist,’ 6 April 2009, Independent Weekly, www.independentweek ly.com.au/news/local/news/environment/stop-the-superweeds-adelaide-biologist/1479477.aspx.

[xi] ‘Superweeds, Day of the triffids?’ Organic New Zealand, January/February 2011.

[xii] www.nature.com/hdy/journal/v88/n5/full/6800071a.html.

[xiii] ‘Ryegrass: Purity and trueness to type more valuable than GE’, Organic New Zealand July/August 2010 Vol. 69 No. 4.

[xiv] http://www.soils.wisc.edu/extension/wcmc/2012/ppt/Davis_2.pdf.

http://www.nytimes.com/2012/04/26/business/energy-environment/dow-weed-killer-runs-into-opposition.html?_r=2&ref=geneticengineering.

[xv] http://cropwatch.unl.edu/web/cropwatch/archive?articleID=4669108.

[xvi] ‘Resistance to HPPD-inhibiting herbicides in a population of waterhemp (Amaranthus tuberculatus) from Illinois, United States’, Hausman NE et al, Pest Manag Sci. 2011 Mar;67(3):258-61. doi: 10.1002/ps.2100. Epub 2011 Jan 26. http://www.ncbi.nlm.nih.gov/pubmed/21308951.

[xvii] http://www.greenpeace.org/international/en/news/Blogs/makingwaves/banned-ge-canola-found-growing-in-swiss-port-/blog/40733/.

[xviii] The Great Escape: Gene-altered crops grow wild. http://www.environmentalhealthnews.org/ehs/news/2012/gm-crops-escape-and-grow-wild.

[xix] www.plosone.org/article/info:doi/10.1371/journal.pone.0025736.

[xx] ‘The Establishment of Genetically Engineered Canola Populations in the US’, Meredith G Schafer et al, www.plosone.org/article/info:doi/10.1371/journal.pone.0025736.

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

[xxii] http://www.agriculturesnetwork.org/magazines/global/ge-not-the-only-option/mexico-centre-of-diversity-of-maize-has-been.

[xxiii] See FAQ www.psgr.org.nz, Centres of Origin.

[xxiv] http://www.newscientist.com/article/mg18324661.400-bentgrass-breaks-record-for-spread-of-modified-genes.html.

[xxv] New Scientist, 9 August 2006, www.newscientist.com/article.ns?id=mg19125643.100.

[xxvi] http://earthopensource.org/index.php/5-gm-crops-impacts-on-the-farm-and-environment.

[xxvii] ‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012, www.pnas.org/content/early/2012/08/14/1205431109?utm_source=HEADS-UP+24-30+AUGUST++2012&utm_campaign=SMC+Heads-Up&utm_medium=email.

[xxviii] ‘Biofuels: Filing a Gap’, Organic New Zealand, September/October 2011.

[xxix] Diels J, et al, Food Policy, 2011; 36; 197-203.

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