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The Royal Commission on Genetic Modification - submissionsGreenpeace New ZealandSTRATEGIC ISSUES & OPTIONSSubmission Greenpeace submitted that as the release of genetically modified organisms (GMOs) into the environment is irreversible the applications of genetic modification (GM) technology designed for deliberate release must be judged according to the criteria of ecologically appropriate production. GMOs should be judged on their capacity to:
Greenpeace further submitted that the financial investment to date in applications designed for the release of GMOs should not be a deterrent to taking the necessary precautionary action. In their opinion, it would inappropriate to weigh this investment against the unknowable cost to the environment by releasing unpredictable organisms into the environment. They then called for a complete ban on the release of GMOs into the environment.
LAW & LEGISLATIONSubmission Regulation To prevent accidental contamination of the environment Greenpeace submitted that the Government should:
Furthermore, amendments will need to be made to the Hazardous Substances and New Organisms Act (HSNO) 1996 and other Acts will need to be carefully reviewed to implement the Biosafety Protocol when it enters into force. Definitions should be examined to implement Biosafety Protocol definitions in Article 3. For instance, there is no specific definition of ‘living modified organism’. The purpose and principles of HSNO should be brought into line with the objective of the Protocol. For example, the word ‘biodiversity’ is not specifically mentioned in section 6. Section 7 will need to be amended to be wider than a directive to take into account the need for caution. Consequential amendments will need to be made to implement the Advanced Informed Agreement procedure, the risk assessment procedure (Article 15 and Annex III), and the risk management requirements (Article 16).
Intellectual property Jonathan King argued that the revealing of gene sequences is useful, but does not constitute a process of invention. Gene sequences are products of nature, not products of invention, and thus rightfully outside the patent system. In his opinion, permitting patents on gene sequences is equivalent to granting patents on graphite to those who determined that the components of graphite were carbon atoms, or granting patents on the ocean bottom to those who determined its topology by echo ranging. He then argued that patents in fact retarded research as the need to prevent divulgence undermines and reverses the culture of open communication.
The development of significant social movements that oppose gene patents was then discussed. For example, he noted that the Dutch Government has formally appealed one of the decisions favouring gene patents to the European Court of Justice. He also emphasized dramatic public demonstrations that occurred in India in response to W. R. Grace obtaining patents on the Neem tree. Furthermore, the United Nations has recognized the necessity of protecting essential common resources from national sovereignty or private ownership. In his opinion, the earth's life forms need to be included as a common resource.
Overall, it was submitted by Greenpeace that patent law is not equipped to address cultural, social and ecological values around the status, use and conservation of biodiversity and ecosystems. There should be a halt, therefore, to the granting of any patents on life, its parts, products, and processes. Furthermore, Greenpeace noted that the imperative for culturally and ecologically appropriate protection of biodiversity and traditional knowledge is required under the partnership obligations of the Crown to tangata whenua. However, the current review of the Patents Act 1956 has not opened the way for the development of other mechanisms that would better embody the cultural, social and ecological rights and values of both iwi and pakeha. Instead, where there has been consultation, this has been conducted within the rigid framework of patentability. Greenpeace believes that the Ministry of Economic Development is not, therefore, the competent authority to be leading the review process.
RISKS & BENEFITSSubmission Dr. Doreen Stabinsky challenged the assumption that the changes at the metabolic/physiological level in respect to GM technology only have to do with novel synthesis of one protein. She noted that a cell is a very complex system where each protein plays one or many roles and interactions among proteins and other molecules in the cell are key to an organism’s proper functioning. She then went on to argue that a novel genetic construct, when inserted, could cause excessive production of some chemical in a plant that is toxic to humans (genetic — insertion-related event). Or, the novel gene product could cause metabolic alterations such that a toxic compound in the plant builds up to dangerous concentrations.
Possible down stream ecological disturbances through increased gene flow and possible increased invasiveness of GM plants were then addressed. Bergelson, et al. were stated to have documented increased outcrossing rates in an Arabidopsis thaliana plant engineered with an herbicide tolerance gene. She noted that A. thaliana is normally a self-pollinating plant, with very low rates of outcrossing. It was submitted that the implications of this study were that although A. thaliana itself is unlikely to become a pernicious weed, GM could substantially increase the probability of transgene escape, even in a species considered to be almost completely selfing.
In her opinion, the dispersal of the GM crop or GM traits in the environment through gene flow and possible increased persistence, invasiveness and competitiveness with native plant species could change the population dynamics of the release site and the surrounding environment. For example, if native plant species suffer severe competition with an invasive plant and decline, there would also be reductions in the animal, insect and fungal species that directly and indirectly depend on the native plant species for survival. Protected ecological systems may be harmed by the invasion and change of habitats by plants with certain engineered traits.
Furthermore, certain engineered traits, such as salt tolerance, frost tolerance or drought tolerance can expand the growing range of plants with these traits. This could cause harm to a variety of ecosystems. Species that are highly evolved to fill specialised niches, such as salty soils or cold climates, are often part of particularly fragile ecosystems. For example, salt-tolerance could enable plants to invade coastal habitats that were previously outside their growing range. When a plant that is new to saline soils invades them, it could irreversibly change the characteristics of that soil and consequently that habitat.
The ability of field trials to assess these possible effects was then challenged. It was Dr. Stabinsky’s opinion that many field trials are primarily designed to assess the agronomic potential of the GM crop line, rather than to assess environmental impacts such as gene flow or effects on non-target species and the soil food web. Moreover, even studies designed to determine environmental impact are inherently flawed. This is because:
She then gave a comprehensive list of purported contamination events worldwide. For example, in May 1999, it was discovered by the Swiss Department of Agriculture that Pioneer Hi-Bred's (Des Moines, IA, USA) conventional maize seed varieties, Ulla and Benicia, had become contaminated with a GM Bt variety. Contamination of the seeds, which were produced in the United States, was "probably caused by stray pollen during the growing season," according to Ulrich Schmidt, managing director of Pioneer in Buxtehude, Germany, which represents the grain manufacturer in Switzerland. Before the contamination was discovered, Pioneer had sold enough Ulla and Benicia seeds to sow 400 hectares (roughly 0.5% of total maize cultivation in Switzerland), about 200 hectares of which had already been planted. Contamination was also found in France and Germany of this variety.
Horizontal gene transfer was then addressed. The potential negative effects of such transfers were submitted as follows:
Issues in respect to herbicide and pesticide resistant plants were then discussed. The effects of these plants have been discussed extensively in previous submissions and will not be outlined in this summary. In brief, these include non-target organism deaths, the development of insect resistance, and the possible disruption of the nutrient cycle. The development of virus resistant plants was also addressed. As in other submissions, the possibility of viral recombination was emphasised. Specifically, it was noted that mildly-infecting but otherwise defective viruses have been shown to replace their defective gene with the engineered gene. Such viruses have also been found to be able to infect previously inaccessible plant species, once they had recombined with the engineered gene. Other viruses, including a non-defective strain of Cauliflower Mosaic virus recombined with engineered genes and out-competed the original infecting virus. It was then submitted that because of this ability of viruses to recombine in plants, some virologists believe GM virus resistance may accelerate the evolution of new diseases.
GM tree species were then discussed. Once again this has been covered in previous submissions. Briefly, the long life span of trees, the lack of knowledge in respect to tree genetics, the possibility of wilding pines, the effects of higher growth rates and reduced lignin, and sterility was discussed. It was concluded that a proper risk assessment of trees was impossible. In the opinion of Dr. Stabinsky, trials of plantation trees are hampered by environmental variation within large plots, remote locations, and long life cycles. The long life cycles of trees and the range of seasonal and other environmental stresses that they have to withstand entail that any modifications made to them may be unstable. This further prevents reliable risk assessment. Furthermore, GM trees must also withstand a wide range of stresses, including seasonal changes. This increases the possibility of stress-related transgene instability.
Dr. Stabinsky then went onto discuss GM fish. It was noted that the primary traits targeted are growth rate, size, feed conversion efficiency, disease resistance and cold tolerance. However, it was noted that salmon engineered with growth hormones have shown gross deformities in second-generation progeny, with severe overgrowth of cartilage in the head and jaw leading to reduced feeding ability and increased mortality. Behaviour may also have been affected in that GM salmon were stated to be more aggressive. It was further contended that sterility was only partially successful in the inhibition of gene flow. Nor does sterility address the impact of competition between escaped farm fish and wild fish. Furthermore, it was contended that increased cold tolerance might lead to the spread of intensive fish farming into more northerly waters, with the concomitant disruption of marine and freshwater ecosystems in such areas. Escapes of GM cold tolerant fish may disrupt wild populations of fish in colder waters not normally exposed to competition with farmed fish species.
The possible environmental disruption caused by either the intended or unintended release of GMOs was then discussed. It was contended that any release, whether into water, air or soil or by ingestion cannot be contained within the given environment of release. Microorganims released into soil can travel into the aquifers and into aqueducts of the ground water; release into sludge and sewage for clean-up (bioremediation) purposes can facilitate the spread of either the GMO or its transgenes to drinking water and rivers and back to land. It was further contended that given the current state of knowledge, it was impossible to understand the impact GMO release would have on the environment. In Dr. Stabinsky’s opinion, too little is understood about interactions, interdependency and antagonism amongst organisms populating soil, water or gut. For example, less than 1% of bacteria present in the natural environment have so far been described at species level. Soil and aquatic ecology was then discussed. (See Royal Forest & Bird Protection Society summary).
Bioremediation was then addressed. It was stated that most of the organisms that are potentially useful for bioremediation have been or can be isolated from the site of pollution. It was then contended, however, that it is difficult to get even these indigenous bacteria to perform effectively when reintroduced. It appears that isolation and re-growing in laboratories or industrial facilities affects their ability to re-establish themselves in the environment they originally were found in. It was Dr. Stabinsky’s opinion, therefore, that as bioremediation in open systems is not working to satisfaction, and posing risks and problems not yet assessed or solved, it is premature to rely on bioremediation as an alternative to pollution prevention. Adding GM technology to the formula would simply be adding additional risks and problems.
ECONOMIC ISSUESSubmission Bill Christison, the President, National Family Farm Coalition and Missouri Rural Crisis Centre, outline the effects of GM technology on farmers in the United States (US). He noted that farmers in the US have seen advertising for GM crops that claims to reduce costs and increase yields. However, his own experience is that by producing his own seed, his per acre cost of planting soybeans is $6.51 per acre. If he bought the same number of pounds of Round-up Ready (RR) seed, his per acre cost would be $42.00 per acre. Furthermore, yields of GM crops are no better and may be worse than comparable conventional varieties. In support of this contention he cited a two-year University of Nebraska study that was stated to show that RR soybeans have a genetic yield drag when compared to conventional soy.
He then submitted that resistance to GM crops in major markets is harming farmers in the US. Furthermore, farmers in the US are increasingly seeing their way of life threatened by the corporate control of the industry. In his opinion, GM technology increases the farmers’ dependence on biotechnology companies that control seeds and other inputs. In respect to liability, it was submitted that GM technology has brought with it risk and liabilities. He stated that he did not know of a single insurance company that is willing to cover genetic liability with insurance. He then submitted that all risk and liability should lie at the feet of the corporations that develop and sell the technology.
He then outlined the unethical behaviour of biotechnology companies in respect to intellectual property rights. Biotechnology companies were submitted to have been aggressive in tracking and monitoring farmers for so-called "seed piracy." They have placed radio and print ads to urge farmers to spy on their neighbours, going as far as offering bounties for suspected seed savers. They have hired private detectives to trespass on farmers' fields in order to sample a crop's genetics. In at least one instance, detectives hired by a biotech company posed as buyers in an attempt to entrap a seed dealer into selling "pirated" seed.
It was then submitted that many farmers have seen a decline in the availability of seed varieties that are not genetically modified. In the opinion of this witness, the biotechnology industry's purchases of most of the largest US (and world) seed companies in the past few years has meant a diminishing degree of choices for farmers who wish to avoid planting GMOs. Furthermore, the incentive for farmers to use fewer herbicides has also declined, since biotechnology companies now sell their chemicals cheaply and as a package with their seed. A study funded by the biotechnology industry admitted that herbicide use on soybeans has increased in the US.
SOCIAL, CUTURAL, & ETHICAL ISSUESSubmission As in other submissions, the contention that GM technology would feed the world was challenged. Anuradha Mittal, the Co-Director of the Institute for Food and Development Policy, stated that biotechnology is just another cosmetic tool, which is being sold all over the Third World in the name of eradicating hunger. In fact, given the high seed cost, royalty and the cost of other inputs that the farmers will have to use, the cost of cultivation will go up and so will the market price. Food will, therefore, go out of the reach of still more people. In her opinion, biotechnology will ultimately subject more people to hunger and starvation. She then argued that GM technology is based on the same principles as industrial agriculture: monoculture, technology, and corporate control. It is likely, therefore, to exacerbate environmental and social problems when in most countries stringent procedures are not in place to deal with the problems that may develop when modified plants are released into the environment
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