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Genetic Engineering Webinar: What do Consumers Want? Navigating GE Issues with Jon Carapiet

On 5th March 2024, the Soil & Health Association of NZ held an online webinar with Jon Carapiet, to discuss consumer issues around GE. This included the right to choose, labelling, traceability, and consumers overseas – our export markets. Scroll down to read more about the webinar and to access the full recording. If you benefited from this webinar, please consider donating to Soil & Health to support our vital work, details below.

Jon is a consumer advocate, market researcher and national spokesperson for GE Free NZ (in food and environment). For almost 20 years, Jon has spoken out about the need to moderate the powerful use of gene technology to protect New Zealand’s capacity to produce and sell non-GMO food and to protect the rights of consumers at home and overseas. As an advocate for Brand New Zealand, Jon draws on his years of experience as a senior market researcher and brand communications consultant. Jon has a Bachelor’s degree from Cambridge University and a Master’s from Auckland University, and as well as working in research, he is a keen photographer, regularly exhibiting his artwork.

Access the webinar here

The webinar can be viewed here: Jon Carapiet – 5th March 2024.

A copy of Jon’s PowerPoint presentation can be viewed here.

If you would like to view the other webinars in our GE series, please go to the GE Free Campaign page of our website.

Donate to support the vital work of Soil & Health

All webinars and events are free for all members of Soil and Health; otherwise we suggest a donation of $20. All funds go towards Soil & Health’s advocacy and campaign for a GE-free New Zealand, and are eligible for tax credits.

Make your donation by credit card: soilandhealth.org.nz/donate

Or transfer funds to our account: BNZ, account number: 02 0108 0058415 001
With the reference: GE donation

Genetic Engineering Panel Discussion: Where are we at in Aotearoa New Zealand

On 21 November 2023, the Soil and Health Association NZ held an online webinar for an update and discussion about GE. We had over 200 attendees and some great discussion! Scroll down to read more about the webinar and to access the full recording. If you benefited from this webinar, please consider donating to Soil & Health to support our vital work, details below.

What’s the current law, what’s in our food and fields, and what does the future hold? Join Dr. Jessica Hutchings, Papawhakaritorito Charitable Trust; Philippa Jamieson, OrganicNZ magazine; and Charles Hyland, Soil and Health Association NZ in conversation.

About the panelists:

Dr Jessica Hutchings, Papawhakaritorito Charitable Trust
Dr Jessica Hutchings (Ngāi Tahu, Ngāti Huirapa, Gujarati) is nationally and internationally recognised as a leader in Indigenous food systems and Māori food and soil sovereignty; she is a founding Trustee of the Papawhakaritorito Charitable Trust that works to uplift Māori food and soil sovereignty and Hua Parakore (Māori organics) through research, development and community practice.

Philippa Jamieson, Organic NZ Magazine
Philippa Jamieson is a writer and marketing manager of Organic NZ Magazine. Philippa is an organic advocate, gardener, editor, writer and celebrant living in Dunedin. She is chair of the Organics Aotearoa NZ GE policy group, a life member of the Soil & Health Association, and involved in her local community orchard project.

Charles Hyland, Soil & Health Association
Soil & Health National Councillor Charles Hyland is a soil scientist and biogeochemist who moved to NZ in 2013 after working as a scientist at Cornell University in the USA for over ten years. Organic agriculture and natural systems have always been central to his work and worldview.

Access the webinar here

Donate to support the vital work of Soil & Health

All webinars and events are free for all members of Soil and Health; otherwise we suggest a donation of $20. All funds go towards Soil & Health’s advocacy and campaign for a GE-free New Zealand, and are eligible for tax credits.

Make your donation by credit card: soilandhealth.org.nz/donate

Or transfer funds to our account: BNZ, account number: 02 0108 0058415 001
With the reference: GE donation

Heavy rain, soil and waterways – what’s the effect and what we can do about it?

About the video

We all know that heavy rains cause soil loss and runoff. And we understand these are harmful to fresh water and the wider environment.

But many farmers, gardeners and land owners are unsure about where to start fixing these problems.

Join Philippa Jamieson, former editor of Organic NZ magazine, in conversation with soil scientist Charles Hyland and freshwater ecologist Dr Mike Joy as they discuss some of the mechanics of these problems and the relative virtues of various solutions.

This webinar aims to empower the organic community to intentionally manage their soils in order to achieve their sustainability and environmental goals.

About the panelists

Charles Hyland is a soil scientist and biogeochemist who moved to NZ in 2013 after working at Cornell University in the USA as a scientist for over ten years.  His career has focused on identifying complex environmental problems associated with agricultural systems and implementing effective innovative solutions. Organic agriculture has always been central to his work and worldview.

Mike Joy began lecturing at Massey University in ecology and environmental science in 2003. After seeing first-hand the decline in freshwater health in New Zealand, he became an outspoken advocate for environmental protection. He has been working for two decades at the interface of science and policy in New Zealand with a goal of strengthening connections between science, policy and real outcomes to address the multiple environmental issues facing New Zealand.

Wake-up call on the environmental and human health harms of toxic agrichemicals

The Soil & Health Association is welcoming last week’s “Knowing what’s out there” report by the Parliamentary Commissioner for the Environment. The report criticises New Zealand’s lack of monitoring and regulation of environmental harm from chemicals.

Jodie Bruning, national councillor for the Soil & Health Association

“New Zealand lags behind other countries on monitoring and regulation of toxic agrichemicals, putting our health, environment and overseas trade agenda at risk,” says Soil & Health spokesperson Jodie Bruning.

“A more integrated framework, suggested by the report, will help the right hand know what the left hand is doing, this is currently not happening in New Zealand, when it comes to environmental chemicals.

“For example the Environmental Protection Agency, our government watchdog on these issues, had to make a public appeal last year for information on glyphosate use. Why do they need to resort to this?  Because they don’t monitor glyphosate’s use, availability, or impacts. There’s no feedback loop between the agencie and our territorial and local authorities.

“It’s been shown that glyphosate is a probable carcinogen and its widespread use in New Zealand must be stopped. 

“Glyphosate is the tip of the iceberg. Our regulatory settings are useless if we are not informed about environmental pollution, and if regulator is not keeping an eye on what’s happening on the ground.

“The government needs to take this report seriously. This includes expediting a formal reassessment of glyphosate as a key next step in protecting New Zealanders and the natural environment from harm.”

ENDS

Notes

The PCE report is covered here: https://www.rnz.co.nz/news/national/462653/lack-of-mechanisms-to-govern-chemical-use-in-nz-commissioner

Joint Submission on the A1139 Potato to Food Standards Australia New Zealand

 Introduction

GE Free New Zealand in Food and Environment and the Soil & Health Association of New Zealand (“we” and “the submitters”) welcome the opportunity to comment on the application A1139 Food derived from Potato Lines F10, J3, W8, X17 & Y8 (“Application”).

GE Free New Zealand in Food and Environment (“GE Free NZ”) is an Incorporated Society.  It is a non-Governmental Organisation governed by a Board and has a nationwide membership base. It represents its members when making submissions and helps with gathering and disseminating information concerning genetically modified organisms (“GMO”) to its members and the wider public through regular newsletters and its website (www.gefree.org.nz).

The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.

We recommend that FSANZ decline the Application. We submit FSANZ cannot approve the potato lines in the Application without a serious breach of its duty of care as well as the principles of its own mission statement.

We note that there are insufficient data on both the sprays and novel proteins detailed in the Application.

We note that FSANZ’s legal requirements as stated in its mission statement are:

To protect, in collaboration with others, the health and safety of people in Australia and New Zealand through the maintenance of a safe food supply.

FSANZ Values are:

  • To be impartial, open and accountable;
  • To use the best available sciences and evidence to guide decision-making; and
  • To seek, respect and be responsive to the issues raised by others.

FSANZ Responsibilities are:

  • Provide information to consumers to enable better consumer choice;
  • Undertake dietary exposure modeling and scientific risk assessments; and
  • Provide risk assessment advice on imported food.

We have read the assessments for this Application and consider that FSANZ have led stake holders and consumers astray. We outline our concerns below.

Detailed submission

It is illegal to import viable GE plants or plant parts into New Zealand. Potato plants can readily regenerate from even small parts of raw tubers, therefore making any raw imported GE potatoes equivalent to live GE plant material. This will endanger the biosecurity status of New Zealand. It would be illegal to approve the entry of these GE potatoes/potato pieces into the country.

Not labeling GE-containing foods at the point of sale is a breach of consumer rights. The lack of labeling of GE potatoes sold in any form by restaurants is deceptive, as consumers will be unaware of this.  FSANZ should support rather than oppose the enforcement and monitoring of compliance around GE food labeling.

No independent food safety experiments have been carried out on these GE potato lines. Instead FSANZ has relied on data from within the GE industry, i.e., the applicant data.  This shows that FSANZ has not been impartial, open or accountable to the public. FSANZ has not required that any independent experimental food safety assessments be undertaken on these potatoes.  It can therefore not provide advice on the safety of these imported potato lines, such advice being its core responsibility.

The executive summary of the FSANZ evaluation reads:

The changes to levels of free amino acids and reducing sugars are not nutritionally consequential as they do not affect the levels of essential amino acids or other key nutrients important to potato.

This statement assumes that any changes in the amino acids, free or otherwise, do not affect the levels of all other compounds present in the GE potatoes. The amino acid glutamine, for example,  plays an important role in maintaining a healthy immune system, digestive tract and muscle cells.  Any changes to amino acid balance may cause alterations to the assimilation of other amino acids.  Studies have shown glutamine to reduce morbidity and mortality in periods of critical illness. [1]  This demonstrates that any changes to endogenous amino acid levels should not be ignored.

Statement on Compositional analyses:

A detailed compositional analysis was performed on W8, X17, Y9, F10 and J3 to establish the nutritional adequacy of tubers produced from these lines and to characterise any unintended compositional change. Analyses were done of proximates, fibre, vitamins, minerals, total amino acids, free amino acids, sucrose, reducing sugars (fructose and glucose), and anti-nutrients (glycoalkaloids). These showed that, even with the intended changes to sucrose, reducing sugars and asparagine, the levels of all analytes fell within the natural variation found across the range of conventional potato lines used for human consumption. No conclusion could be reached in relation to line E56 as no compositional data was provided. (iii)

The changes in concentrations of glutamine and asparagine in the GE potato lines may be of some concern.  Altered levels of asparagine can result in complications in fetal development, causing brain and neurological problems.[2]

There are concerns over the meaning of “biological relevant differences” as stated in the summary document:

Analysis of the events W8, X17, and Y9 have not revealed any biologically relevant differences compared to the conventional varieties, except for the intended late blight protection, low free asparagine, low reducing sugars, and low polyphenol oxidase activity.

Assuming “biologically relevant differences” translates as food safety, there are no feeding studies to back up this statement, so such assumptions are unable to be made.

Published research on GE potatoes has shown unexpected harmful effects on animals fed with these crops.  A 1999 study (Ewen and Puzstai) conducted on rats fed with  transgenic potatoes found that abnormalities occurred in the gastrointestinal tract (small intestine and caecum) within a short time.[3] This study found that the GE potatoes caused gut abnormalities with or without (an ‘empty construct’) the lectin gene.  Lectin is a harmless insecticidal compound produced by a number of plants. The authors concluded that:

“(b)ecause caecal thickness was similar in rats given boiled parent potatoes in the presence or absence of spiked GNA (a harmless lectin from the plant species Galanthus nivalis), we suggest that the decrease in caecal mucosal thickness seen in rats fed boiled GM-potato diets was the consequence of the transfer of the GNA gene into the potato.”

These GE potatoes were not subsequently commercialised.

Similar results were obtained in feeding experiments using GE potatoes by Fares et al.[4] , who found that there were changes to the mucosal lining and other cells of the ileum of mice. They called for comprehensive feeding tests to avoid any potential risks:

“Although transgenic crop plants used in food and feed production carry different beneficial transgenes… before releasing for marketing thorough tests and all possible consequences of these new types of heredity and new genetic structures must be evaluated to avoid any potential risks”

A 2007 study showed that the consumption of GE potatoes has been observed to cause an increase in immunoglobulin (Ig) levels in human participants.[5]

This is cause for concern, as antibody levels may well have increased as a result of novel proteins present in the GE food.

These afore-mentioned studies are but three of many published studies on the harmful effects of GE foods.  Please refer to the submission of the Physicians and Scientists for Global Responsibility (PSGR) for a more comprehensive list of publications on the harmful effects of GE crops, as observed in feeding experiments.

The obligation of FSANZ is to make themselves aware of such studies and treat all GE foods as potentially harmful.  It would be completely irresponsible to allow these potatoes onto the market. Feeding studies need to be conducted on the GE potato lines in this application before the potatoes are released. This will determine whether these lines have negative health impacts, or even life threatening responses, such as an allergic reaction.

Changes in Metabolites

Cellini et al. (2004) reported widespread changes to metabolite levels, both expected and unexpected in GE potato lines.  They recommended that data analysis tools need to be used.[6]

A study of potato metabolite production has found that field-grown vs laboratory-grown potato tubers showed a tenfold and greater differences across a range of compounds.[7] The potatoes with modified sucrose metabolism or inhibited starch synthesis revealed unexpected disaccharides (trehalose, maltose and isomaltose).[8] Such changes in metabolites cannot be overlooked, when assessing this application.

A particular cause for concern is that FSANZ has deemed the six GE potato lines  in this application as “safe”,  when there is no compositional data on one line E56.

Applicant data to APHIS[9]

We have outlined the comments from the data provided to APHIS about the potatoes.

7.3 Soft root testing with tubers

Of the events in that trial (E12, E24, F10, J3, J55, and J78), the only significant difference was that event F10 was more resistant  to this disease than the control. (APHIS p.46)

Late blight foliage testing

Considering both studies, we conclude that the events have similar susceptibility to bacterial soft rot as the controls. (APHIS, p.46)

7.4 Reducing Sugars.

Tubers of the events G11, H37, and H50 contain the same amount of reducing sugars as tubers of their untransformed (non-GE) counterparts. The inability of the silencing construct to limit glucose/fructose formation in H37 and H50 may be due to the fact that the H variety is naturally low in glucose and fructose. Thus, we concluded that silencing of the promoters associated with the PhL/R1 genes effectively lowered reducing sugars near the time of harvest in most events but these differences were not sustained throughout storage for 2-5 months”. (APHIS,p. 47)

Disease susceptibility – Appendix 8

Thus, independent lines of two chipping varieties and two French fry varieties with low Ppo expression in tubers were shown to have similar susceptibility to bacterial soft rot to the corresponding untransformed control for each variety.

Considerations

The APHIS document on the GE potatoes details some significant differences in the  compositions between the GE lines and non-GE controls.  These GE potatoes are of no nutritional benefit to consumers and could contain higher levels of anti-nutrients.

FSANZ has overlooked three fundamental issues, when allowing this application to proceed:

  1. There are currently non-GE potato varieties available that are ideal for chipping and processing .

In section 2.4.3 of the application it states that the applicant has indicated that reduced blackspot bruising of these GE potato lines can reduce wastage during storage and processing, and that the potatoes are resistant to the fungal disease known as foliar late blight.  There are already several non-GE varieties of blight-resistant potatoes (including ‘Waneta’ and  ‘Lamoka’), which have been released by plant breeders from the University of Cornell (US). These varieties are ideal for chips, because they store very well and produce a good colour when cut 9. The Cornell breeding programme develops chipping and tabletop varieties, focussing on colour, size, shape, texture and disease- and pest-resistance.

  1. New Zealand has a range of excellent climates and soils in which to grow these non-GE varieties of potatoes. This would support NZ growers and potato processing plants. Furthermore, the importation of potato products from the other side of the world, is an unnecessary source of carbon emissions that will contribute to what is already a major world problem.
  2. Acrylamide production can be reduced by the use of sensible cooking methods. There is much information available on this topic.

Conclusions

We ask that FSANZ decline approval of A1139.

  • An adequate risk assessment and evaluation of the effect/s of novel genes/proteins and subsequent changes in the A1139 potato lines has not been carried out.
  • No independent feeding test risk assessments have been undertaken or evaluated by FSANZ.
  • The Applicant information provided on safety is insufficient and lacking up to date metabolic profiling using proteomic testing for entry into the food chain.
  • The lack of information does not allow the consumer to make informed decisions and removes consumer choice
  • By not allowing for labeling of A1139, FSANZ has not provided information to consumers that will enable better consumer choice.
  • The assessment has no information about any novel protein/s, which may have been produced during the GE process.
  • There is a lack of scientific data necessary to protect and maintain a safe food supply for the health and safety of people in Australia and New Zealand.

The best available science has not been used to properly guide decision-making.

  • The reliance on applicant’s data has not shown impartiality, openness and accountability.

 

[1] Lacey, J., & Wilmore, D. (2009). Is Glutamine a Conditionally Essential Amino Acid?. Nutrition Reviews, 48(8), 297-309.

[2] Ruzzo,E., Capo-Chichi, J., Ben-Zeev., Chitayat, D., Mao, H., & Pappas,A. et al. (2013). Deficiency Asparagine Synthetase Causes Congenital Microcephaly and a Progressive Form of Encephalopathy. Neuron, 80(2), 429-441.

[3] Ewen, S., & Pusztai, A. (1999). Effect of diets containing genetically modified potatoes expressing Galanthus nivalis lectin on rat small intestine. The Lancet354(9187), 1353-1354.

[4] Fares, N., & El-Sayed, A. (1998). Fine Structural Changes in the Ileum of Mice Fed on δ-Endotoxin-Treated Potatoes and Transgenic Potatoes. Natural Toxins6(6), 219-233.

[5] Tacket, C. O. (2007). Plant-Based Vaccines Against Diarrheal Diseases. Transactions of the American Clinical and Climatological Association118, 79–87

[6] Cellini, F., Chesson, A., Colquhoun, I., Constable, A., Davies, H., & Engel, K. et al. (2004). Unintended effects and their detection in genetically modified crops. Food And Chemical Toxicology42(7), 1089-1125.

[7] Roessner, U., Wagner, C., Kopka, J., Tretheway, N., Willmitzer, L., 2000. Simultaneous analysis of metabolites in potato tubers by gas chromatography-mass spectrometry. Plant Journal 23, 131–142.

[8] Acrylamide Potential and Reduced Black Spot Bruise: Events E12 and E24 (Russet Burbank); F10 and F37 (Ranger Russet); J3, J55, and J78 (Atlantic); G11 (G); H37and H50 (H)  – 2013  https://www.aphis.usda.gov/brs/aphisdocs/13_02201p.pdf

[9] www.isaa.org/kc/cropbiotechupdate/article/default.asp?ID=7422

Clean Water Consultation 2017

 

Clean Water Consultation 2017

Ministry for the Environment

PO Box 10362

Wellington 6143

 

                         Clean Water Consultation 2017

 

  • This submission is on behalf of the Soil & Health Association of New Zealand Inc. (“Soil & Health”). Soil & Health was incorporated under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s objectives broadly include soil health and the promotion of organic gardening and farming. It has approximately 3000 members, chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Its age and membership make it the oldest and largest representative organic organisation in New Zealand.
  • Soil & Health appreciates the opportunity to comment on the consultation document Clean Water Package 2017 (Consultation Document).

Overview

  • Soil & Health supports a number of underlying concepts in the Consultation Document and National Policy Statement Freshwater Management (NPSFM) and believe that they have the potential to improve the management of freshwater in New Zealand. These include proposals for “swimmable rivers”, stock exclusion, clarification of “maintain or improve”, and the use of MCI (macroinvertebrate community index), DIN and DRP.
  • However Soil & Health has concerns with how the above proposals are to be incorporated. For environmental limits-based water management to be successful central government needs to install clear, directive, policy at a national level. Further the Consultation Document does little to address the issues of stock density and the excess application of nutrients on farms which leach through soils and into waterways.
  • The government has failed to take the steps necessary to prevent the freshwater crisis effectively leaving waterways across the country in a dire state and continuing to deteriorate. This is reflected in the National Policy Statement on Freshwater Management (NPSFM) which sets bottom lines at levels which are toxic to aquatic life. These bottom lines have been incorporated into regional plans, leaving no prospect that water quality in rivers will ever return to ecological health.
  • Further the main factor in the deterioration of waterways is due to nitrogen and phosphate pollution from the increasing intensification of (non-organic) dairy farming, which the government continues to actively promote.
  • Various mitigating measures that the government has so far suggested, including in this Consultation Document, such as fencing off waterways, planting stream banks, and establishing initiatives like the Clean Streams Accord and Healthy Rivers, for the most part, are only bandaids that attempt to address the symptom and do little to address the actual cause of the problem – that being the excess application of nutrients and in the wrong form. An estimated 750,000 tonnes of urea was applied in 2014 the majority of which was onto dairy farms. This is a 38-fold increase from the 20,000 tonnes applied in 1983.
  • Soil & Health strongly advocates for a transition to organic farming as part of the solution to fixing polluted fresh waterways in New Zealand. Organic dairy farming involves no soluble nitrogen fertilisers, lower stock numbers, more biodiversity, and grass-fed cows with no GE feed or palm kernel supplements.

Detailed submissions

Macroinvertebrate Community Index

  • Policy CB1 requires regional councils to monitor macroinvertebrate communities. Soil & Health considers this requirement to be weak and not directive. The requirement does not  implement the Land and Water Forum’s (LWF) recommendations that (in summary):[1]
  1. Plans be required to have a trigger for action if there is a downward trend in MCI, or it is below 100.
  2. The required action is to investigate and develop an action plan to either maintain or improve MCI scores in the water body. The key points in this process are:
  3. If the natural state is below 100, then the requirement is to maintain MCI at that level.
  4. If the MCI score in a water body is below 100 for human-induced reasons, then the requirement is to develop an action plan to improve the MCI score.
  • If there is a downward trend in MCI then the requirement is to develop an action plan to reverse the trend.
  • The LWF’s recommendations are based on advice given from a panel made up of independent scientists that MCI is scientifically robust and fit for purpose.

Relief:

  • MCI and the planning system proposed above be incorporated into the NPSFM as per the LWF’s recommendations.

Dissolved inorganic nitrogen and dissolved reactive phosphorus

  • The Consultation Document incorporates the setting of maximum concentrations of DIN and DRP through a “note” attached to the ecosystem health periphyton attribute table. This requirement is not sufficiently directive, and its legality and enforceability is unclear. It does not accord with or implement the LWF’s recommendations that (in summary):[2]
  1. The NPSFM include a requirement to set instream concentrations for DIN and DRP as objectives in regional plans.
  2. The development of a mandatory decision support tool to be used by regional councils to derive and set DIN and DRP concentrations.
  3. Research and develop a multivariate “look-up” table for DIN and DRP concentrations.
  4. The NPSFM incorporate nitrogen and phosphorus standards in order to achieve ecosystem health as measured through a desired MCI.

Relief:

  • The NPSFM be amended to include setting of DIN and DRP concentrations in the NOF at ecosystem health levels.
  • That a decision-support tool as per the flow chart attached to the LWF’s letter to Ministers of 19 August 2016 be confirmed and appended to the NPSFM. The text of the NPSFM must make clear that setting of DIN and DRP concentrations is to follow that process.

Gaps

  • The NPSFM Consultation Version does not reflect the full range of attributes that need to be managed. The most important missing parameters are:
  • Excessive sediment runoff from land is seen to be one of the main causes of water quality issues in New Zealand. Sediment however is not explicitly addressed in the Consultation Document. The four modes of impact from sediment are visual clarity, light penetration, suspended sediment concentrations, and deposited sediment. These are all capable of being included as attributes in the NOF.
  • Stormwater drains from roads and other impermeable surfaces like roofs contain dissolved metal contaminants such as zinc and copper. Another more potent source is from motor vehicle tyre and brake wear on cars. These heavy metal contaminants are now commonly found in waterways, and once carried through can accumulate in muddy sediment. These are difficult to control however as local government has no control over motor vehicle brake-pads and its control over roofing and building materials is not clear due to ambiguities of overlap with the Building Act and regulations.
  • Cadmium, which is a carcinogenic heavy metal, however has accumulated in soils and steams which is the result of the heavy use of superphosphate. Cadmium is something that we therefore can control by simply using fertilisers that don’t contain cadmium. The issue with cadmium is that it doesn’t readily leave the environment and can bioaccumulate in fish, plants and animals.
  • Inadequate focus on urban water issues has been evident at all stages of the freshwater reform process. This needs to change.

Relief:

  • Include sediment attributes in the NOF or signal intention to include sediment attributes in the NOF and begin development of those and in the interim, include policy direction on sediment management.
  • Include copper, zinc and cadmium attributes in the NOF.
  • National regulation for vehicle brake-pads should be investigated and developed.
  • Control of heavy metals from building materials should be investigated and legislative amendments/guidance/regulation ensuring effective local government control for NPSFM purposes developed.

Swimming

  • Soil & Health supports the underlying concept of a time-based approach to achieving water quality suitable for “swimming”. However the detail underpinning this concept and providing the course of action for its achievement need significant work.

Terminology

  • The Consultation Document refers to improving water quality to enable “swimming”. The document refers to a target of 90% of rivers and lakes being “swimmable”[3]. This is not defined and not referred to elsewhere in the document. Instead the concept of “suitable for immersion” is applied.
  • Lack of consistency in terminology is confusing and unclear. Reference solely to “swimming” is misleading as swimming is only one of many activities involving immersion or primary contact.
  • The objective that water quality is “suitable for immersion more often” is not sufficiently directive. As defined any reduction in frequency and magnitude of coli exceedances over any time frame would qualify as achieving the NPSFM’s proposed new objectives and policies.[4]
  • Consistent and clear terminology should be used. The NPSFM should set a clear and definitive goal that water quality be suitable for primary contact recreation.

Relief:

  • Replace references to “swimming”, “swimmable, “suitable for immersion” in the Consultation Document preamble, Objective A3, Policy A5, Policy CA2(f) with “primary contact recreation”.
  • Delete definition of “suitable for immersion” and insert the LWF definition of “primary contact recreation”.

Qualifying as swimmable

  • It appears that amended Appendix 2 is inaccurate. It does not reflect the categories and attribute states and defining metrics set out by the Ministry for the Environment (MfE) on its website as being proposed to be inserted in the NPSFM. It is unfortunate that the table was not included in the Consultation Document’s NPSFM Consultation Version.
  • Those parameters should not be left to a “readers note”. The legality and enforceability of a “readers note” in national policy is unclear.

Relief:

  • That the coli attribute table in NPSFM Consultation Version be amended to incorporate in full the tables as set out on MfE’s website.

Waterbodies to which the target applies

  • The Consultation Document’s “swimming” proposals only apply to “large rivers and lakes” which is defined to capture 4th order rivers or above and lakes large than 1.5km in perimeter on average. This excludes the vast majority of waterbodies. Because the current coli attribute table is deleted in the NPSFM Consultation Version to make way for that applying to “swimming” there is no is no E.coli attribute table or bottom line applying to those other ‘smaller’ waterways. This is a serious oversight.
  • The “swimming” proposal is also inconsistent with the interconnectedness of freshwater bodies and the ocean. Failure to appropriately control contaminants in smaller streams that may themselves not necessarily be frequently used for swimming can result in significant pollution of the coastal environment into which they flow. This is a significant issue for Auckland City.
  • This interface issue with the coastal environment may result in the proposed additions to the NPS being inconsistent with the provisions of the NZCPS.

Relief:

  • That the new primary contact coli attribute table apply to all waterbodies. Primary contact recreation targets should be set for all regions.

Monitoring

  • Soil & Health supports the inclusion of monitoring requirements for coli in Policy CB1 and Appendix 5 in principle. As drafted Appendix 5 is not sufficiently clear. It fails to identify that there are 2 separate monitoring requirements:
  1. Monitoring for meeting Coli freshwater objectives in the long term.
  2. Monitoring for surveillance to inform the public on suitability for primary contact recreation at various times and locations.
  • Appendix 5’s monitoring guidelines are based on the 2003 microbiological guidelines which are outdated. Many councils’ are employing more sophisticated methods.

Relief:

  • Amendments to ensure the 2 separate monitoring requirements are clear.
  • Urgent review of the 2003 microbiological guidelines.

Overarching Goal

  • The preamble to the NPSFM Consultation Version sets an overarching goal that 90% of rivers and lakes will be swimmable by 2040 and an interim goal of 80% to be swimmable by 2030. This goal is supported in principle. However it is undermined by 2 issues:
  • The rivers and lakes to which this goal will apply have not been defined. It is not clear whether only large rivers and lakes will be relevant or a broader group.
  • The goal is not legally enforceable. It is only set out in the NPSFM Consultation Version preamble. No relevant objectives or policies are proposed. Instead it is proposed that a letter from the Minister to regional councils outlining the goal is distributed. This lacks regulatory compulsion.
  • It is not clear how this goal is intended to be worked into existing plan processes/plans recently amended to give effect to the NPSMF 2014.

Relief

  • Incorporate the goal of 90% of rivers and lakes to be suitable for primary contact recreation into the NPSFM provisions. This should apply to all rivers and lakes.
  • Provide policy direction on how this goal is to be incorporated into plans at different stages of the planning process.
  • The year by which 90% of rivers by suitable for primary contact recreation be changed to 2030.

NPSFM Consultation version text

  • Comments and relief relating to the NPSFM Consultation Version text in relation to the issues discussed above are not repeated.

Timeframes

  • Freshwater objectives need to be set, and they need to be set fast. Implementation needs to be accelerated for public confidence in the fresh water reforms to be retained. This is particularly so given the controversy subsequent to release of the Consultation Document. The timeframes in the consultation version are to drawn out to impress any urgency on regional government or land users to change. They need to be revisited.

Relief:

  • The NPSFM be amended to set minimum timeframes for when regional freshwater objectives are to be met.
  • The date of implementation of the NPSFM in Policy E1 be brought forward to 31 December 2020. Any extension should be limited to 2025.

Objectives A2 and B1 – economic wellbeing

  • The Consultation Document amends Objectives A2 and B1 to refer to providing for economic wellbeing and opportunities. It is not clear why this is necessary or why the amendment to each objective is different. If the intention is to clarify that use of water for inter alia economic purposes can only occur only within environmental limits then this should specifically addressed.
  • Of particular concern is the amendment to B1 which requires economic wellbeing to be provided for “while” meaning “at the same time as” safeguarding the life supporting capacity of freshwater. This is inconsistent with an environmental limits approach to water management based on providing for use within the capacity of the environment to sustain itself.

Relief:

  • Delete the proposed amendments to Objective A2 and B1 referring to provision for economic wellbeing.
  • If references or new provisions are to be included these must be drafted to ensure that water quality based on ecosystem and human health is the first priority. Promotion of and provision for economic opportunities must be within environmental limits.

Objective A2 – maintain or improve

  • The clarification of the “maintain or improve” requirement in Objective A2 needs further work. Soil & Health supports the requirement that water quality be maintained or improved within a FMU in principle. It allows for natural fluctuations and is consistent with the scale at which freshwater objectives are set.
  • However, the adequacy of that requirement turns on the definition of FMU. Currently that definition is extremely broad and affords regional councils’ unfettered discretion to identify FMUs at as large or small a scale as they please. Setting of large FMUs allows for gaming of the system and an ‘unders and overs’ calculation due to power imbalances. A desire to avoid these outcomes was one of the drivers behind the proposed amendments. Fish and Game submitted on this issue in 2014, and it has not been addressed.

Relief:

  • The NPSFM provide guidance on appropriate minimum scale/scale-setting process for FMUs. Consequential amendments to the FMU definition will likely be required.

Policy A3 and Appendix 3

  • Appendix 3 has not been populated. This should occur. Policy CA3 only applies to infrastructure listed in the Appendix.
  • The Consultation Document includes amendments attempting to define “benefits provided by listed infrastructure”. This singles out renewable electricity generation and then lists employment and economic wellbeing as “benefits”. This is unhelpful. First, there are many different types of hydrological modification that may qualify as significant infrastructure. It is not necessary to single out electricity generation. Second, a general statement that employment and economic wellbeing are sufficient benefits to trigger application of the exception in Policy A3 is too broad. Almost any activity will have employment and economic outcomes. A higher threshold should be applied in the context of freshwater limits. Care needs to be taken in determining criteria allowing infrastructure to qualify for an exception. In some instances poor water quality results from infrastructure that may be regionally significant but which is outdated and should be upgraded.
  • The amendment clarifying that Appendix 3 only applies to infrastructure exiting prior to the date on which the NPSFM 2014 came into effect is supported.

Relief:

  • Appendix 3 be populated. This should include the infrastructure title and its specific benefits.
  • The final paragraph to Policy CA3 be deleted.
  • Appendix 3 include specific, detailed criteria that must be considered when determining whether an Appendix 3 exception is appropriate.

STOCK EXCLUSION

  • The stock exclusion proposals are broadly acceptable. Two crucial elements are missing:
  1. A workable scheme for deciding what slope class a parcel of land falls within. Such a scheme exists within the new NES on Plantation Forestry, and it could be used in this case.
  2. Integrating stock exclusion fencing requirements with riparian management. This is a significant omission, ignores recommendation 31 of the LWF’s 4th Report, and is not consistent with integrated and strategic resource management. Stock exclusion and riparian setbacks are intimately linked. Although exclusion prevents stock from entering waterways it does not prevent overland or subsurface flow of nutrients. Setbacks, in particular vegetated setbacks, act as a filter. They preserve and enhance natural riparian habitats and prevent erosion. Without a complementary setback requirement, any stock exclusion regulation risks placing a significant cost on land owners for insignificant environmental outcomes. Setbacks and riparian management are heavily influenced by context and depend on factors such as terrain, soil, and flow patterns.

Relief:

  • The Consultation Document’s stock exclusion proposal and any subsequent regulation(s) include a scheme for consistent slope class assessment and a requirement that fencing erected to exclude stock be placed at an appropriate distance from the waterbody, with appropriateness being determined by reference to a nationally applicable assessment tool as outlined above.

Measures not addressed in the Consultation Document

  • Soil & Health strongly believes that limits on stock numbers need to be set, and strictly enforced. The Consultation Document makes no mention at all on limiting stock numbers on farms. A large factor in nitrogen pollution in waterways is cow urine diffusing through soils and pasture root zones. A landmark report released by the Ministry of the Environment on the 27th of April highlighted that there has been a 69 percent increase in dairy cattle numbers between 1994 and 2015.[5] The report found that freshwater biodiversity was declining and 72 percent of native fish were threatened or at risk of extinction.  The fact remains that even if farmers adopt mitigation techniques like riparian planting, stock exclusion from waterways, water quality will keep declining if we continue to expand dairying in this way.

 

  • Further, with this expansion of dairying there has been an overreliance on nitrogen fertizliers to get pastures to grow. There are however many efficient and cost effective ways of applying nitrogen that ensure pasture gets all the nitrogen required to grow and at a significantly lower environmental cost. These include:
  1. Converting the nitrogen into effluent ponds that are less leachable, organically bound forms, and applying the effluent to folia as opposed to discharging to waterways.
  2. Increasing clover cover and promoting nitrogen fixing pasture species, effectively increasing the health of the soil, the structure of soil and its moisture holding capacity.
  3. Promoting the drawdown of the 78 percent free nitrogen in the atmosphere by promoting the free-living and associative nitrogen-fixing bacteria and archaea in soils.

 

  • The above are productive, smart management practices that would allow for significant cost savings for farmers and would reduce nitrogen leaching through soils and into waterways. Putting in place these measures, as regulatory requirements, would effectively address the cause of the problem and in doing so work to reverse the damage already caused to waterways.

 

Yours sincerely

 

Name: Mischa Davis

Position: Policy advisor

 

The Soil & Health Association

PO Box 340002

Birkenhead

Auckland 0746

Phone: 021 266 7754

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

 

[1] LWF letter to Ministers 19 August 2016.

[2] LWF letter to Ministers 19 August 2016.

[3] NPSFM Consultation Version pg 5 preamble.

[4] NPSFM Consultation Version 1 pg 10 interpretation, pg 23 Objective A3, pg 14 Policy A5.

[5] Ministry for the Environment & Stats NZ (2017). New Zealand’s Environmental Reporting Series: Our fresh water 2017. Retrieved from www.mfe.govt.nz and www.stats.govt.nz.

 

Photo credit: Mischa Davis

Clean waterways

New Zealand’s waterways are in a dire state with a staggering 60% of monitored rivers being unsafe for swimming and 74% of freshwater fish species are threatened. A big factor in this is nitrogen pollution from the increasing intensification of agriculture. Much of the nitrogen pollution comes from cattle urine diffusing through soils and pasture root zones, and from soluble synthetic nitrogen fertilisers, so while planting stream banks and fencing off streams is good, it cannot solve this issue on its own. Going organic is part of the solution to fixing polluted fresh waterways in New Zealand. Organic dairy farming does not use any soluble nitrogen fertilisers, has lower stock density, promotes greater biodiversity, has grass-fed cows, and feed supplements are free of GE ingredients and palm kernel.

Soil & Health Association believes that the bottom line for human health in fresh water bodies should be that they are safe for primary contact i.e. for swimming. Soil & Health believes that freshwater pollution is not merely about farmers breaching rules. What is required is government intervention to lift water quality standards and incentivise more sustainable and organic methods of farming.

Soil & Health supports:

Fencing off stock from waterways.

Riparian strips and buffer zones of vegetation.

Sustainable stock numbers.

Organic and biological farming methods that involve nitrogen fixing pasture species, and healthy      living soils with good moisture-holding capacity.

Mixed rotational farming.

                                            Photo credit: Nick Holmes

 

Submission on the Health (Fluoridation of Drinking Water) Amendment Bill

Introduction

  1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) was incorporated under the Incorporated Societies Act 1908 on 4 December 1942. Soil & Health’s objectives broadly include soil health and the promotion of organic gardening and farming. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Its age and membership make it the oldest and largest representative organic organisation in New Zealand.
  2. Soil & Health is aware that currently in New Zealand around 60% of public water supplies have fluoride added as a treatment for dental decay. We are also aware that there is conflicting evidence on the benefits of water fluoridation to dental health and that there is growing medical concern about the cumulative negative wider health impacts of ingestion of fluoride and its adverse effects on the environment. The main chemicals used to fluoridate drinking water are known as silicofluorides. These fluorides are not pharmaceutical-grade fluoride products but unprocessed toxic industrial chemical by-products of the phosphate fertiliser industry.
  1. As an organisation that advocates for organics we are opposed to the use of toxic chemicals in New Zealand. We are therefore opposed to the artificial fluoridation of public water supplies. We believe that adding fluoride to local body water supplies is a form of forced medication and therefore is a breach of section 10 of the Bill of Rights Act 1990. We strongly believe that individuals should have a right to choose whether they want to ingest fluoride or not. We believe that dental health is best achieved through a healthy diet and eating fresh, wholesome organic foods.

Detailed submissions

The role of the DHBs and local democracy

  1. The Health (Fluoridation of Drinking Water) Amendment Bill (“the Bill”) was introduced to Parliament in order to enable District Health Boards (“DHBs”) rather than local councils to decide whether community water supplies are fluoridated “with the intention that the change would benefit over 1.4 million New Zealanders who live in areas where networked community water supplies are not currently fluoridated.”[1] This Bill therefore is fundamentally about facilitating the roll out of fluoridation of community water supplies across New Zealand. The Bill itself states in its Explanatory Note that: “Transferring decision-making to DHBs is expected to enable extended fluoridation coverage”.[2]
  2. The Regulatory Impact Statement says: “The Ministry of Health has considered a range of options for managing fluoridation and increasing the proportion of the population having access to fluoridated water supplies.”[3] We argue that “having access” implies having a choice. Under the Bill however there will not be a choice and in fact the Bill is about removing the ability for local communities to have a say on fluoridation. The Bill is therefore dishonest.
  3. It has been argued in the first reading of the Bill that democracy is upheld because the DHB’s have locally elected representatives, and are better placed to make decisions about the health benefits and risks of fluoridation. Part 1 Clause 8(2) of the Bill however sets out only two things the DHBs must consider when making a decision on, which are:

(a) the scientific evidence on the effectiveness on dental health; and

(b) whether the benefits outweigh the costs.

There is no provision for the DHBs to take on board community views, nor to assess health risks or environmental effects. Nor can the DHBs go against Ministry of Health objectives.

  1. The process as it currently exists for considering fluoridation enables local decision making amongst the communities affected. All residents of local councils who want to participate in the process can voice their opinion and a council decision can be appealed in court – as has recently happened in the case of Health New Zealand Inc v South Taranaki District Council.[4] Transferring the decision making from councils to DHBs will effectively remove the ability of communities to be fully involved in the investigation and reporting of any health, community or ecological impacts.
  1. We consider that the DHBs are also less representative of communities than councils because they are not independent. Under the New Zealand Health and Disability Act 2000 DHB’s “must pursue its objectives in accordance with any plan prepared under section 38, its statement of intent, and any directions or requirements given to it by the Minister”[5] and “The Minister may give a direction to all DHBs to comply with stated requirements for the purpose of supporting government policy on improving the effectiveness and efficiency of the public health and disability sector.”[6]

The toxicity of fluoride

  1. The type of fluoride that is added to drinking water is not naturally occurring calcium fluoride, or even pharmaceutical grade sodium fluoride.[7] It is a contaminated chemical by-product of the phosphate fertilizer manufacturing process, known as hydrofluorosilicic acid (“HFA”).[8] It is concentrated, highly toxic and contains hazardous impurities. Due to it’s toxicity by law it cannot be dumped onto the land, into rivers or the sea and cannot be discharged to air. Uranium and radium are found in HFA, both of which are known carcinogens. Two decay products of uranium are even more carcinogenic: radon-222 and polonium-210. Polonium decays into stable lead 206, raising significant health risks, especially for children. Research has shown that drinking fluoridated water increases lead absorption.[9]
  1. New Zealanders are already ingesting elevated levels of fluoride from plants and animals raised on land treated with phosphate which contains naturally occurring fluorides and many people already manifest dental symptoms of fluorosis – fluoride overdose. Further there is no antidote for fluoride toxicity and fluoride does not absorb to activated charcoal in filters.[10]
  1. A further concern is that the Bill’s is sole focus is on dental health with no requirement for the DHBs to assess risk to other parts of the body such as kidneys, liver, brain and thyroid.

Fluoride in the environment

  1. Fluoride ions are directly toxic to aquatic life, and accumulate in the tissues, at concentrations where absorption rates exceed excretion rates.[11] In a scientific journal article titled ‘Fluoride toxicity to aquatic animals’ Julio A. Camargo states how even at concentrations as low as 0.5 mg F/l fluoride in soft water can adversely affect invertebrates and fishes. Camargo further states that “safe levels below this fluoride concentration are recommended in order to protect freshwater animals from fluoride pollution.[12] There are other studies that indicate levels below water fluoridation level, 1.5ppm, have lethal and other adverse effects on fish. Delayed hatching of rainbow trout has occurred at 1.5ppm6, brown mussels have died at 1.4ppm7; an alga (Porphyria tenera) was killed by a four-hour fumigation with fluoride with a critical concentration of 0.9ppm 8, and levels below 0.1ppm were shown to be lethal to the water flea, Daphnia magna.[13]
  1. Only 1% of water from community water supplies is ingested by humans, the remaining 99% is discharged into the environment via the wastewater systems. Fluoride is not filtered out by wastewater plants. In 2015 an investigation found that approximately half a tonne of HFA is discharged every year into Lake Taupo via the Hangarito stream from the township of Turangi alone.[14] The safety datasheet for HFA by Orica states it is an exotoxin and to avoid discharge to waterways. New Zealand waterways are already in a dire state with a staggering 62% of monitored waterways being unsafe for swimming. Increasing the amount of fluoridation in local body water supplies will only make this worse.
  1. Of concern for the Bill is that transferring the decision making to the DHBs will mean that environmental effects of fluoride will no longer be taken into account. The DHBs role is to deliver public health services, not to take into account environmental effects. Whereas councils can assess environmental effects when considering fluoridation, DHBs cannot, because their statutory role is restricted to the delivery of health services.

The need for a precautionary approach

  1. Principle 15 of the Rio Declaration mentions the precautionary approach as follows:

In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation

  1. The precautionary approach has been considered a milestone in its ability to reduce environmental risk as it involves an anticipatory preventative action in response to uncertainty. In its use public authorities are not only required to anticipate possible adverse effects that could arise from activities but also to act to control the risks even when it is still uncertain whether adverse effects will occur.
  1. A report compiled in 2013 for the Government of Ireland, the European Commission and the World Health Organisation titled ‘Public Health Investigation of Epidemiological Data on Disease and Mortality in Ireland related to Water Fluoridation and Fluoride Exposure’ found that public health authorities have pursued a policy of medicating the population with fluoridation chemicals for half a century without undertaking any clinical trials, medical, toxicological, scientific or epidemiological studies to examine how exposure to such chemicals may be impacting on the general health of the population. The report concludes that in the absence of any scientific data proponents of water fluoridation continue to believe that the policy is both safe and effective for all sectors of society regardless of the age, nutritional requirements, medical status or total dietary intake of fluoride of individuals.[15]
  1. While studies have shown that a lifetime exposure to fluoride can lead to health risks, especially to those with challenged immune systems and the young and the elderly, [16] it is still unknown at what point HFA causes harm. Our health authorities in New Zealand have not yet found the real safe level to protect sensitive groups, particularly people with kidney disease, diabetes and bottle-fed babies. No safety studies have ever been conducted anywhere in the world.
  1. Soil & Health strongly endorses a precautionary approach to fluoridation of local body water supplies at all levels of government and regulation. Due to the uncertainties of the safety of water fluoridation we consider that applying the precautionary approach should involve a moratorium on the fluoridation of local body water supplies until further research is undertaken.

Conclusion

  1. As set out above Soil & Health opposes the introduction of the Bill. Under the Bill local decision making will be removed, making fluoridation of local body water supplies easier to implement. A number of independent scientific studies have raised serious concerns about the adverse effects that HFA has on human health and the environment.
  1. We consider that to transfer decision making to the DHB’s the government is showing disregard for appropriate decision making, especially when any risk for those affected is not required to be assessed, nor can the DHBs assess environmental effects or go against Ministry of Health objectives.
  1. We urge the select committee to apply the precautionary approach and implement a moratorium on the fluoridation of local body water supplies until an ‘independent’ review of its effects on human health and the environment is undertaken.

Soil & Health wish to be in heard in support of our submission.

 

Yours sincerely

Name: Mischa Davis

Position: Policy Advisor

The Soil & Health Association

PO Box 340002

Birkenhead

Auckland 0746

Phone: 0212667754

Email: advocacy@organicnz.org.nz

Website: www.organicnz.org.nz

[1] Background to Bill https://www.parliament.nz/en/pb/bills-and-laws/bills-digests/document/51PLLaw24221/health-fluoridation-of-drinking-water-amendment-bill

[2] Page 1 the Bill.

[3] Page 1 Regulatory Impact Statement.

[4] New Health New Zealand Inc v South Taranaki District Council – [2014] NZHC 395

[5] Section 22 (2).

[6] Section 33B (1).

[7] https://www.cdc.gov/niosh/ipcsneng/neng1233.html

[8]http://www.waternz.org.nz/Folder?Action=View%20File&Folder_id=315&File=140604_nzwwa_f_gpg_revision_final.pdf

[9] http://cof-cof.ca/wp-content/uploads/2012/08/Masters-Coplan-Water-Treatment-With-Silicofluorides-And-Lead-Toxicity-International-Journal-Of-Environmental-Studies-1999.pdf and https://www.ncbi.nlm.nih.gov/pubmed/17420053

[10] http://emedicine.medscape.com/article/814774-overview

[11] http://www.env.gov.bc.ca/wat/wq/BCguidelines/fluoride/fluoridetoo-04.html

[12] http://www.sciencedirect.com/science/article/pii/S0045653502004988

[13] Dave G. Effects of fluoride on growth reproduction and survival in Daphnia magna, Comparative Biochemistry and Physiology, 78c (2)

[14] http://fluoridefree.org.nz/campaigns/taupo-turangi/

[15] http://www.enviro.ie/feb2013.pdf

[16] http://www.sciencedirect.com/science/article/pii/S0892036214001809 and https://www.atsdr.cdc.gov/ToxProfiles/tp11-c2.pdf

You can address your submission to:

Committee Secretariat

Health

Parliament Buildings

Wellington