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The Royal Commission on Genetic Modification - submissionsRoyal Forest and Bird Protection Society IncThe following is a summary of the submissions from The Auckland, Marlborough, and the Nelson/ Tasman branches of the Royal Forest and Bird Protection Society Inc (RFBPS).
STRATEGIC ISSUES & OPTIONSSubmission It was recommend that the Commission should not lose sight of the option of keeping New Zealand genetic modification (GM) free. As in other submissions, it was noted that consumer resistance to GM food products is very strong in some markets. In their opinion, other options should be explored for improving New Zealand’s agricultural horticultural and forestry productivity and global competitiveness for example, as a supplier of organic produce internationally. They also noted that the avoidance of GM as it affects field testing or releases could be seen as contributing to New Zealand’s "clean, green image". In support of this contention they stated that there is now a substantial world campaign to make areas "GM free", including individual cities and areas like the Austrian Alps.
Furthermore, the New Zealand government should place extra resources into the preservation of New Zealand’s unique environment. In their opinion, GM technology poses unique and significant risks and threats to New Zealand’s biodiversity. They submitted, therefore, that the precautionary approach, as defined in the HSNO Act s7, should be adopted. There should be no field release of GMO’s in the New Zealand environment because this is unproven technology with unknown long-term potentially irreversible side-effects. However, the RFBPS does not object to GMO and GM product work related to health issues provided this does not involve field testing or release. LAW & LEGISLATIONSubmission Regulation In respect to regulation of GM/GMOs the RFBPS recommended that:
The RFBPS stated that they were not satisfied with existing regulatory mechanisms for controlling GM research and possible entry of GMOs into New Zealand from overseas. They recommended that more Government resources need to be made available for this. The Nelson/Tasman branch recommended the establishment of a Ministry of Biosecurity, without links to commercial interests, to consider any environmental release of GMOs, the monitoring of any release, and for policy making. This Ministry would also have a role in policy and regulating border biosecurity. Liability In respect to liability it was noted that the cost of many environmental mistakes had been borne by the public, not by the group that had benefited from the use of the damaging technology. The RFBPS then discussed the introduction of a polluter pays system. This then raises the question of whether the posting of bonds is an adequate way of addressing potential damage. They noted that it would be difficult in many circumstances to estimate the potential cost of, for example, totally destroying a field crop, or investigating spread to other organisms and removing this GM entity from the environment. Intellectual Property Concern was also expressed in respect to the ownership of intellectual property rights in GM technology. In their opinion, such ownership lead to a decrease in information made to the public. The public, however, will need such information to determine the risk to the environment in respect to GM technology. They submitted that knowledge and ownership will ultimately have to be public property if we are to protect the environment.
International Agreements The RFBPS emphasised the importance of the Convention on Biological Diversity. In their opinion, taking the precautionary approach as exemplified in this Convention would allow New Zealand to protect its significant indigenous biodiversity by prohibiting field release or testing of GMOs.
Submission As in other submissions, concern was expressed over the continuance of the monoculture approach in respect to GM agriculture. Although not a GM issue in itself, in their opinion the technology has the potential to exacerbate this problem. Problems in respect to herbicide and pesticide resistant crops, the possible release of a transgenic virus, and the possible creation of superweeds were also outlined. These issues have been extensively covered in previous submissions.
Precautionary Principle The importance of the precautionary principle was emphasized throughout these submissions. For example, it was stated that in the Nelson Province there are examples of "experimental advances" turning sour with the adverse effects hidden from the public. The use of organochlorides, which were sold as ‘scientifically safe’, was given as an example. These toxins were stated to have entered the soils, water systems, and vegetation, and to be evident twelve years since the law forced a stop to these practices. It was feared that GMOs released into the environment will not have any stronger proof of safety.
Soil ecology In respect to soil ecology, the RFBPS expressed reservations about the introduction of GMOs as this may result in:
Aquatic ecosystems It was further submitted that the introduction of GMOs may have an adverse effect on aquatic ecosystems. Changing the organisms and their functions, through GM technology, may well affect the fine balance of these ecosystems. They also noted that the inter-relationships of the various organisms are poorly understood in these systems. It not clear, therefore, what array of these should be tested. The effect of GMOs on the death and decay cycle was also, in their opinion, uncertain. They stated, therefore, that before field trials are allowed, investigations need to be made on the fate of DNA that gets incorporated into the environment, for example fallen leaves, crop debris, seed, and decaying roots. If the recombinant DNA genetic material is passed on in any way to another animal, plant, bacteria or fungus, then the fate of the recombinant DNA should be studied.
Biosensors and bioremediation The RFBPS submitted that even the use of GMOs in the technologies of bioremediation and biosensor development is of concern. Though the aim of these technologies are agreed, the concern relates to possible transfer effects of the GMOs into the wider environment. Before any use of these GMOs, the RFBPS would like to know:
Overseas evidence The RFBPS then stated that they concerned that so many submissions and witness statements are from overseas enterprises which have little, or no, knowledge of our wildlife and ecosystems. In their opinion, these submitters will bear no responsibility for the outcomes of their experiments and exploitation of New Zealand as they do not live in New Zealand and will have no commitment or responsibility for long term consequences. Furthermore, the RFBPS submitted that New Zealand must strongly resist being used by overseas companies as a testing ground. Our scientists should have backbone and know when to get "off the band wagon" rather than "keeping up with the Jones".
Pest control Furthermore, it was the opinion of the RFBPS that the benefits of GM technology were being oversold. In their opinion, there is as yet no evidence that science has found a solution for the introduced pests, mustelids, possums, or old-man's-beard through the use of GM technology. Furthermore, such a panacea is likely to be many years away. It was feared that before proper long-term trials are done, New Zealand will have another 'calici virus' event which, in the long-term, may prove disastrous. Funding and concerted community action could deal with these pests now.
Specific concerns were expressed in respect to the control of possums. For example, the RFBPS (Auckland Branch) noted the possibility of a GM solution to New Zealand’s possum problem spreading to the Australian environment. They then expressed reservations about the work on GM proteins associated with the coat of sperm and ova to sterilise possums (see Landcare New Zealand submission). In their opinion, the proposal to incorporate these proteins into carrot baits is of concern until testing has been done on the ecological effects of this protein on other animals, particularly insects that might eat the bait and any bacteria that might be involved in the breakdown of the proteins. They were also hesitant in respect to efficiency of these proteins in sterilising the possums. If they are not 100% efficient in sterilising them, question will need to be asked about the propensity for the surviving population to multiply. They then called for this research to be compared with the effectiveness of 1080 and other chemicals currently being used.
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