RCGM Witness Brief John Clearwater

Witness Brief Royal Commission on Genetic Modification

1. Name of Witness

John Clearwater

I am a scientist running a science based business. I have a Ph. D. from the university of Alberta,

Edmonton, Canada and a B.Sc. / M.Sc from Massey University, Palmerston North. I carried out

ecological research on the sorghum shoot fly at the International Centre of Insect Physiology and Ecology in Nairobi., Kenya (1975-79). I joined the DSIR in 1979 and transferred to Hort research in 1992. I developed a method of controlling codling moth with pheromones and in 1992 produced the first NZ export crop of organic apples with Tony Belcher of Waihi. After failing to convince my managers of the value of this achievement, I resigned from Hort research and set up a program of organic apple growing in the Hawkes Bay at the invitation of John Bostock (grower) and John Mangan (Freshco). The program has now grown to include over 50 growers and 5% of NZ apple growers. The best return to date is $80 /carton of organic Royal gala apples on the US market. This compares with $8.25 (loss of $1 /carton) for conventional apples. The biological insecticide Bacillus thuringiensis is a key tool in this activity. I provided the pheromone-based monitoring system for the successful program that eradicated the White-

Spotted Tussock Moth from the suburbs of Auckland. The monitoring allowed accurate placement of the biological insecticide B. thuringiensis.

2. Name of “Interested Person” (on behalf of whom the witness will appear)

Physicians and Scientists for Responsible Genetics New Zealand (PSRG)

3. Witness Brief Executive Summary

3.1 The successful use of Bt sprays in organic growing prompted the idea that plants could be protected by adding the genes that produce the BT toxins to the plants set of genes. The added genes would produce the toxins continuously and the plant would have an ever-present “bodyguard”. What a good idea……or is it??? The transfer of the genes has been accomplished with the molecular techniques of the Genetic Engineer.

3.2 Millions of hectares of North America are planted with corn Genetically Engineered to kill corn borer with Bt toxins. Any pest continually assaulted with a toxin will develop resistance and a great deal of thought has gone into ways of preventing the rapid development of resistance and the collapse of the effectiveness of the “bodyguard”. A large area of standard corn planted near the GE-corn might provide a safe refuge for corn borer. (The necessary size of this refuge is under debate-------each succeeding recommendation increases the size of the refuge needed!!) The thinking runs as follows. If a mutant resistant to Bt. toxin appears in the GE-corn, it would be more likely to find a mate from the larger numbers of borer moths living in the refuge than it would to find another rare resistant moth. The moths from the refuge should always be Bt. susceptible because they were not exposed to the Bt. toxin. The resistant mutant would be likely to be recessive, ie. if it mates with a susceptible moth, none of the progeny will be resistant. This expectation has just been shown to be false. Haung et .al.(1999) found that dominant resistant moths appear when challenged as caterpillars with Bt. toxin.

When these dominant moths mate with susceptibles from the refuge, half of the progeny will also be resistant (Cummins 1999). Rather than braking the spread of resistance, the refuges will accelerate the problem by providing a rich breeding ground for spread of the dominant resistance.

Not only would the value of the GE-plants be destroyed, the usefulness of the Bt for the organic farmer would be lost as well.

Valuable conservation species and the use of Bt.

3.3 The large acreage’s of Bt-corn grown in the USA are butterfly unfriendly places. The Genetically Engineered crop has Bt. genes spliced into the plant genes. The European Corn Borer sickens and dies when attempting to feed on the GE-plants. The synthetic pesticide sprays normally required are now dispensed with and this might be expected to be good for non-pest species of insects in the environment. Pollen from Bt-corn contains crystalline Endo-toxin from the bacterial genes. Corn is a wind-pollinated crop and the pollen can be blown more than 60 yards from the edge of the corn-field. Sweet-corn and maize produce enormous amounts of pollen. Drifts of yellow pollen cover the body and clog the windscreen wipers of cars parked near any corn field. \

3.4 Dr. John Losey (assistant Professor of Entomology at Cornell University) Linda Rayor and Maureen Carter fed milkweed leaves dusted with GE-corn-pollen to monarch caterpillars in the laboratory. These caterpillars ate less, grew more slowly and nearly half died. All the caterpillars fed leaves dusted with normal pollen or leaves without pollen survived the study.

3.5 Monarch caterpillars feed exclusively on the milkweed plant because the bitter tasting cardenolide chemicals provide a defence against bird predators. Milkweed grows best in ecologically disturbed areas like the margins of corn fields. Monarch butterflies are migratory insects, over-wintering in Mexico. The first generation flies to the southern US states. By May to June, the second generation of adults has emerged and heads north for the Mid-West corn belt. Monarch caterpillars are feeding on the milkweed at the time of pollen shedding. They are at the right place and at the right time to be poisoned by the GEpollen.

3.6 New Zealand has two very attractive Nymphalid Butterflies that are much less common today than previously. The Yellow Admiral Bassaris itea is also found in Australia but the related Red Admiral, B. gonerilla is endemic to New Zealand. The NZ Red Admiral is reputed by international Butterfly collectors to be the most attractive of the worlds Red Admiral butterfly species. Possible reasons for their lower numbers are the increased use of pesticides today and the activities of two parasitiods, the ichneumonid Echthromorpha intricatoria that first appeared in NZ in 1915 and the Pteromalid wasp Pteromalus puparum that was introduced into NZ in 1932-33 for the control of the White cabbage butterfly (Gibbs 1980).

3.7 The Admiral butterflies are common in organic apple orchards in the Hawkes bay especially during harvest where they may be seen feeding on the juices of crushed apples. At other times they can be seen sunning themselves on the shelter belt trees. The carmine-winged day-flying moth Tyria jacobaeae introduced into NZ in 1929 for ragwort control is also common. Growing food-plants for the butterflies would increase the population and make a valuable contribution to the protection of our natural treasures. All of these most attractive species are now able to live in an apple orchard because of the absence of synthetic insecticides. If Bt. sprays are needed, they are applied at dusk when butterflies are inactive. The heavy use of Bt. sprays for eradication of the WSTM in Auckland would have also killed any resident Admiral caterpillars. This was recognised and the area re-stocked with reared butterflies released after the spraying was complete.

3.8 Introduction of Bt. genes into NZ apple varieties was being attempted in Project PI92/16. This project was carried out by Dr. Andrew Gleeve of the Horticulture and Food Research Institute of New Zealand Ltd. and was funded by levies on NZ apple growers via the NZ Apple and Pear Marketing Board. The GE-apple orchard planned for the future would be butterfly unfriendly and the opportunity to provide a refuge for these species within productive orchards would be lost once more. Commercial interest in GE-apples was never gained and this project has now been discontinued.

Bt-corn in New Zealand

3.9 The NZ Herald (May 21st 1999) carried an article describing the application from Pioneer New Zealand to the Environmental Risk Management Authority (ERMA) for permission to plant Bt. corn in the Waikato. The scourge of the American corn is the European Corn borer. This species is not found in NZ, but three other moth pest species are present. They are the Cosmopolitan Army-worm, Mythimna separata; the Greasy Cutworm, Agrotis ipsilon and the Corn ear-worm Helicoverpa armigera. The last named is the most important, infesting all the corn growing areas in NZ. It lays eggs on the cob silk. The hatching caterpillar chews through the silk and on into the kernels. All three of the above species would be likely to be controlled by the Bt. toxins in the GE-corn. The most important pest of NZ corn is the green Vegetable Bug Nezara viridula. The Bt. toxin will not control this pest. The Bug pierces the corn kernels and sucks out the contents, the attacked kernels go translucent and blacken, completely ruining the cob for any commercial purpose. The Bug is steadily expanding its range. Use of synthetic insecticides will be necessary on BT.-corn to control the bug. Most corn farms growing GE-maize will save very few sprays because of the presence of and the need to control the Bug.

3.10 New Zealand farms and orchards are typically mixed, with different types of plant grown next door to each other. Apple orchards share boundaries with corn fields along the Ngatarawa rd. in Hastings for example. Corn straw is used as a mulch in organic apple growing and many volunteer corn plants grow from seed left in the straw. An hour spent monitoring a corn field will cover me from head to toe in a fine mist of corn pollen. If GE-corn were grown in the area a bath and change of clothing would be necessary before entering organically certified corn or apple blocks. Movement of corn pollen can already impose commercial costs. Cross pollination of “Jubilee” and “Honey and Pearl” sweet corn produced pink kernels on a Fielding corn farm last year and the product from 25 acres was dumped.

3.11 Contamination of organic products with GE-material has been feared and has now happened. It is not surprising that an organic corn product was involved. DO-IT, a Dutch importer found genetic contamination in samples of corn chips from Terra Prima Inc. The importer destroyed all 87,000 bags. Cross-pollination was found to blame, not surprising now 25% of American corn is Genetically Engineered. Testing for GE-contamination is expensive but will now be a routine process for each batch of corn entering the factory. This adds significant costs to the product.

Bt. sprays in the organic orchard

3.12 Surely the use of Bt in organic orchards will equally readily cause the appearance of resistance and have bad affects on the butterfly populations?? A major difference is the sprays of Bt are applied only when monitoring shows that they are necessary. The Bt spray is not the foundation of pest control……naturally occurring wasp species do most of the work of controlling the pests. This has been demonstrated in vineyards in Gisborne where the two species of beneficial wasp (Goniozus jacintae and Dolichogenida tasmanica ) provide complete control of leaf-rollers. Growers may need a single spray of Bt. to assist the wasps to maintain control.

3.13 Application of a single spray of Bt. to a Gisborne vineyard in March 1999 provides an example of this. The leaf-roller population had increased to the point that the grower was concerned for the safety of his grapes. I examined the results after the Bt. was applied and found many empty leaf-roller shelters, and more than eight parasitic cocoons for every live leaf-roller left.

The grape bunches were completely free of leaf-roller at harvest. It should be noted that the full weight of control of the leaf-rollers does not fall on the Bt…………. the Bt is used to supplement the work of the beneficial wasps. The loss of the usefulness of the Bt. through resistance is most unlikely when used in this fashion. Even Bt is not entirely harmless to other live forms and food with the Bt. Toxins throughout the plant tissue is quite different to a plant that may have had only one Bt. spray during the season.

Bt is a critical tool for the defence of our pine forests against Tussock moths.

3.14 New Zealand has made an enormous investment in the planting of 1.5 million hectares of man-made forest of which 90.5% is Pinus radiata forest. This investment returns approximately $2.5 billion each year. I have made provision for my own retirement by investing in Pine Forest shares. This national investment is protected with a national surveillance program run by Ministry of Agriculture and Forestry. Bt was a crucial tool for the WSTM program, and would be vital to the effort to eradicate any future tussock moth invasion that may threaten to infest our planted pine forests. Surely it is common sense to safeguard this vital tool by preventing the field use of GE-plants with Bt genes that will squander this material due to rapid development of resistance?

Genetically engineered apples:

4. I ask that the commission ban the field testing of genetically engineered apples in NZ until unequivocal proof of safety is provided and until the returns on a carton of genetically modified apples exceeds the returns on a carton of organic apples I claim that Genetic Engineering projects for the NZ apple industry have demonstrated inadequate understanding of an apple orchard

4. Many Genetically Engineered species are the product of the “Magic Bullet” concept that seeks a single, dramatically effective solution to a problem. In this submission I would like to describe a “magic bullet” intended to protect apples from the attacks of leaf-rollers. Through ignorance of the ecology of an apple orchard and of the properties of the “bullet” and of the literature this “magic bullet” would endanger more than the intended target.

(A) Avidin in apples

4.1 Vitamin H is the name of biotin, a small molecule that is essential to animals from yeast to humans(1,2). Biotin functions as an intermediary in the transfer of a carboxyl group from a carboxyl donor or from carbon dioxide to an acceptor substance. This is one of the many fundamental metabolic steps in living organisms. The biotin is tightly bound to a protein by the carboxylated carbon chain. A molecule of ATP (the cellular energy currency) powers the attachment of carbon dioxide to one of the Nitrogens in the molecular lattice to form a carboxyl-biotinyl-protein complex which is capable of donating the carboxyl group to any molecule that requires one. \

4.2 Egg white contains Avidin, a basic protein with an extraordinarily high affinity for biotin (binding constant is 1021 at 25°C.) Avidin is an extremely effective inhibitor of biotin- requiring-reactions and is used by a biochemist to test for the requirement of a biotin complex in a given reaction. If Avidin is added and the reaction stops, then a Biotin-complex was involved. Very small amounts of Avidin are needed to completely halt such a reaction.

4.3 Dr. John Christeller of the Palmerston North laboratory of the Horticulture and Food Research Institute of NZ Ltd. had the idea of Genetically Engineering apple trees to enable them to produce the Avidin protein in the plant tissues. Any leaf-roller that started to eat the protected tissues would eat a dose of Avidin, the Avidin would bind the Biotin and prevent the leaf-roller from carrying out normal tissue transfers of carboxyl groups. The metabolically impaired leaf-roller would then die leaving the apple tree free to go about its business of producing perfect apples. This idea became project PI92/17 and was funded by the research levies from the NZ apple growers via the New Zealand Apple and Pear Marketing Board. The first years research involved the feeding of leaf-roller caterpillars on artificial diets free of biotin. This showed that the caterpillars needed Biotin and died without it. Most living animals would be expected to react like this, but it was perfectly reasonable to wish to demonstrate this. The next step would be to Genetically Engineer commercial apple varieties to produce Avidin to remove Biotin from the food of wild leafrollers.

4.4 A research review meeting was held by the NZAPMB in Hastings on the 18th August 1995. The first results of the Avidin-GE project was presented. I objected that it was foolish to make the apples toxic to humans as well as to the leaf-rollers. Dr. Christeller said that it was possible to Genetically Engineer the apple tree so that the Avidin was only expressed in the leaves (surely the only part of an apple tree of interest to a leaf-roller!!). The apples could be Genetically Engineered not to express or turn on the new gene that would produce the Avidin. The unmodified (or just gene-silenced) apple would then be perfectly safe for people to eat. Another scientist (also from the Horticulture and Food Research Institute of NZ Ltd.), with field experience of the life-habits of leaf-rollers, then described the movement of leafrollers from the leaves where they begin feeding, to the crevices between the apples. Hidden in these crevices the caterpillars chew through the apple skin and feed on the apple tissue below. Protecting the leaves and leaving the apples unprotected would increase damage as the caterpillars that moved promptly to the apples would survive in larger numbers in comparison to those that remained feeding on the leaves. Dr. Christeller was unable to think of any further defence of his project and the project was put to the vote. The review meeting, a group of scientists, apple growers and NZAPMB staff gave the Avidin project a uniformly poor grading. The response of the growers showed an appreciation of the objections posed, the NZAPMB accepted the low ratings and cancelled further investment in project PI92/7.

4.5 The Avidin is not in the least selective, being equally toxic to the target, the leaf-rollers as it is to people. The only thing that could be said is that the leaf-roller is restricted to the apple tree for its food while humans would be able to dilute the toxic protein by eating other foods with the Genetically Engineered apples. Good sources of Biotin are yeast, egg yolk and liver. Perhaps each box of Genetically Engineered apples would come with recipes involving apples, yeast, egg yolk and liver with a recommendation that this mixture was the safest way to eat the GE apples.

4.6 A review article entitled “The Safety of Foods Developed by Biotechnology” appeared in the prestigious scientific journal “Science” Volume 256 pp.’s 1747-1749,1832. on the 26th June 1992. The paper was written by David Kessler Commissioner of the Food and Drug Administration (FDA) Rockville MD USA, Michael Taylor Deputy Commissioner FDA, James Maryanski Biotechnology Coordinator, Center for Food Safety and Applied Nutrition FDA, Eric Flamm in the office of Biotechnology FDA and Linda Kahl from the Division of Food and Colour Additives Center for Food Safety and Applied Nutrition FDA. These authors are charged with the responsibility of ensuring the safety of American food supplies and the journal “Science” is the leading review journal and first choice for a scientist making the first announcement of an exciting new scientific discovery.

4.7 The authors of this paper state “However, a number of groups of proteins present in common food sources are known to be toxic or anti-nutritional……Sound scientific practices dictate that such toxic proteins not be introduced into food or animal feed components of new plant varieties…….certain groups of proteins are known to be toxic to vertebrates. These include bacterial and animal toxins, hemaglutinins, enzyme inhibitors, vitamin-binding proteins (Avidin) 1vitamin destroying proteins, enzymes that release toxic compounds and selenium-containing proteins” (3)

4.7 Project PI92/17 showed a profound lack of knowledge of the toxicity of the new component Avidin that could have been found in any biochemistry text. The information in this article came from 3 texts published in 1965(1) and 1966 (2,4). The article from Science was published before the start of project PI92/7. The information in these first class references should have sufficed to prevent project start-up. The lack of knowledge of the life-style and habits of wild leaf-rollers is inexcusable as competent field scientists were part of the organisation presenting the project. Once apple growers and staff of the NZAPMB were fully informed of the implications of adding Avidin to the apples, they had no reservation in cancelling the project.

4.8 The current interest by large European supermarkets in organic and GE-free food has resulted in a decision by the NZAPMB not to fund or support funding applications for the Genetic Engineering of NZ apples

(B) The identity of mealybugs

4.9 Mealybugs are persistent pests of NZ apples. Hidden in the calyx they are hard to reach with insecticide sprays. Their wax covering deflects spray droplets. The presence on NZ apples of Pseudococcus simulans, a close relative of the cosmopolitan P. calceolariae has given NZ exporters difficulty. Overseas buyers require that fresh produce from NZ be free of this NZ endemic species. The Genetic Engineering group at Hort research developed a DNA probe that distinguished between the two species. Two base differences can be detected by the sensitive probe and an identity assigned in the majority of examples. This probe is referred to in the statement in the Hort research submission that “DNA probe for mealybug has saved NZ over $1 million of quarantine costs in its first season on use”.

4.10 Another Hort research scientist, Mr. John Charles was also studying the mealybugs using unsophisticated, classical entomological techniques. He found that changing the temperature at which colonies of mealybug were reared would change one species into the other. A single female mealybug could have both species in her brood. Males of both “species” happily mated with both groups of females. P. simulans is no more than a variant of P. calceolariae. The work has been accepted by the USDA that regulates the entry of fresh fruit into the USA and P. simulans is no longer a problem to NZ exporters. The presence of the DNA probe only served to perpetuate the myth of the existence of P. simulans as a distinct species. This study provides an example of the value of a wider scientific competence over a narrow focus.

I claim that the field release of Genetically Engineered apples will result in contamination of the organic product by the GE material followed by loss of Bio-Gro certification and loss of consumer confidence.

4.11 A recent newspaper article contained the news that an application to the Environmental Risk

Management Authority (ERMA) by the Horticulture and Food Research Institute for permission to field test genetically engineered Royal Gala apple trees on the grounds of the Mt. Albert Research Centre has been withdrawn. This good news has given the organic apple industry a breathing space. Pollen from the flowers of these trees has the potential to contaminate the organic fruit now commanding a premium price in Europe. Though the field trial was to have been screened, screens can be damaged. For example the screens around the South Canterbury trial of genetically engineered Canola have developed holes according to Dr. Basil Walker of ERMA. Genetically engineered apples are not yet growing in New Zealand orchards. If ever approved for release the genetically engineered Gala trees would present a continuous threat to the organic orchards. Bees distribute apple pollen and the hiring out of commercial hives would rapidly spread the genetic contamination throughout the Hastings region.

4.12 A buyer from the giant Tesco supermarket chain visiting NZ had a very clear message. They will buy every carton of organic apples we can produce and genetically engineered apples are completely unwanted!! The Australians have already seen benefits from the choice of European buyers of GE-free food. The largest shipment of Canola seed ever to leave Australia, worth $26 million has just left for Europe. This shipment replaced cancelled Canadian orders, orders cancelled because of the GE content of the Canadian product. European food retail chains are moving fast to eliminate GE food from their shelves. Seven major supermarket chains are launching a consortium (March 1999) to jointly source non-GE food. Headed by the Sainsburys supermarkets they are seeking direct contracts with growers able to guarantee GE-free food and are tracking the products through the processing chain to ensure freedom from contamination. The members of the consortium are Marks and Spencer (UK), Carrefour (France), Italy’s Effelunga, Migros of Switzerland, Delhaize of Belgium and Superquin of Ireland. Tescos supermarkets are the latest recruit to this group.

4.13 Iceland the British frozen food store that first moved two years ago to guarantee its customers GE free food has gained big increases in customer support and profit. The company is getting hundreds of letters every week from new and old customers complementing them on their choice. People are choosing to shop at Iceland because of their GE-stance. Iceland’s sales grew 12% last year (industry av. 2-7% ) and profit increased 27%.

I claim that the performance of the NZ organic apple industry in avoiding the use of synthetic biocides is superior to the performance of the Genetic Engineering industry.

The organically certified apples that NZ is producing are completely free of synthetic biocides. We have therefore already achieved what Genetic Engineers are promising.

Summary

NZ organic apples and are currently fetching substantial premiums on the international market place. These returns are threatened by the field release of genetically modified apples. Overseas experience provides the certainty that organic apples will be contaminated by Genetically engineered material following such a field release. The value of organic apples has been demonstrated and it is unacceptable that the unproven promises of the Genetic Engineers be allowed to threaten this. The projects begun by NZ Genetic Engineers have demonstrated an inadequate understanding of the NZ apple industry and provide no basis for confidence.

Our recommendations are:

PSRG appeal to the Commission to recommend to Government that we have in place an indefinite moratorium on the release of genetically engineered organisms (GEOs). And that the precautionary principle should dictate that we declare an immediate moratorium on

(i) the release of any genetically engineered organisms into the environment, and

(ii) the incorporation of GEOs, their parts, processes and products, into the food chain.

References

(1) Bonner, J. and Varner, J. (1965) “Plant Biochemistry” Academic Press NY and London

(2) Conn, E. and Stumpf, P. (1966) “Outlines of Biochemistry” Wiley International Edition

(3) Kessler, D., Taylor, M., Maryanski, J., Flamm E. and Kahl L. (1992) “The Safety of Foods Developed

by Biotechnology” Science Volume 256 pp.’s 1747-1749,1832

(4) Mahler, M. and Cordes, E. (1966) “Biological Chemistry” Harper International Edition

RCGM Witness Brief John Clearwater

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