Submission on Draft District Plan for the New Plymouth District Council

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12th March 2018

New Plymouth District Council

Submission on Draft District Plan for the New Plymouth District Council

Introduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) thanks the New Plymouth District Council for the opportunity to comment on the Draft New Plymouth District Plan (“Draft Plan”). This document is a comment on the current draft version of the plan.
2. Soil & Health is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organisation 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 composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly magazine Organic NZ – New Zealand’s leading organics magazine.
3. Soil & Health makes this submission on the Draft Plan requesting that it include policies and provisions relating to the management of genetically modified organisms (“GMOs”), as allowed under the Resource Management Act 1991 (“RMA”) and pursuant to the ruling in Federated Farmers of New Zealand v Northland Regional Council.
4. Soil & Health was party to both Environment Court proceedings concerning genetically modified organisms (‘GMOs’), where it supported provision for GMOs under regional policy statements. The Association was also party to the High Court proceeding on GMOs.2
5. Soil & Health has concerns about the potential risks posed by releasing GMOs into the environment. It considers that the science is unproven and the risk of biological and ecosystem harm is too great not to include precautionary provisions for GMOs under local plans.
6. Equally important is the risk to social, economic, and cultural wellbeing, even if the New Plymouth District Council considers that GMOs pose no biological or ecosystem risk. This is because GMO contamination could have significant adverse effects on the economic markets, and way of life, for both organic and non-GMO food producers, and the mauri and tikanga of tangata whenua.
Background
7. GMO activities have been of particular concern to Soil & Health, and its members, since the technology was developed in the 1980s. Organic NZ has published numerous articles about GMOs since the early 1990s to explain transgenic technology and investigate its safety.
8. Soil & Health’s membership has consistently called for action to prevent or restrain using this technology freely in the environment, unless or until it can be proven to be safe, healthy and beneficial for people and the environment, and to ensure users of the technology take financial responsibility for any negative consequences.
9. Soil & Health has monitored most of New Zealand’s GE field trials and reported on what it believed to be significant compliance breaches. These include breaches by Scion at its Rotorua facility where GE pine trees were being grown in an outdoor field trial.
10. No matter how carefully conditions of consent for GMOs are crafted, there inevitably remains a risk, even if small, that conditions may be breached by poor management, human error, natural events such as severe storms and even the sabotage of particular projects.
11. Once GMOs have been released into the environment, they would be very difficult if not impossible to eradicate. In the case of a food product, the “GE-free” status of a district would likely be lost permanently along with the market advantages of that status.
12. There is also a potential risk that escape of GMOs from a controlled environment would attract widespread publicity. Any such publicity of control breaches or even public criticism of a lack of an appropriate precautionary approach carries with it a significant risk of damage to ‘brand New Zealand’ or even particular organic farming sectors on the international stage.
13. From its work, Soil & Health is acutely aware of the importance of the precautionary regulation of GMOs to local communities. Feedback from members has made Soil & Health aware that many of them are primary producers and make their livelihood from farming, horticulture, forestry and beekeeping. They are very concerned about the risks posed to their businesses given past evidence of either human error in GMO activities, or unforeseen or unintended adverse impacts of outdoor use of GMOs.
14. GMOs pose a significant risk to the investment organic farmers and growers have made in businesses. This includes the many organic operations in the New Plymouth District. For the important and rapidly growing organic community, the impacts of any GMO contamination could have devastating and irreversible impacts.
Inter-council Working Party
15. Significant gaps exist in the law around GMOs in New Zealand. There is no provision under the HSNO Act for financial liability for GMO contamination resulting from the release of an approved GMO, meaning those causing harm may not be held liable. This is a significant financial and enterprise risk for organic and GE free producers, should GMO contamination occur. Fortunately, under the RMA, requirements for bonds for remediation and to cover the costs of contamination can be included in district plans. Further there is no mandatory requirement for the Environmental Protection Authority (“EPA”) to take a precautionary approach to the outdoor use of GMOs.
16. Due to these gaps in the law, the Inter-council Working Party on GMO Risk Evaluation and Management Options was established, and as a result a number of councils around New Zealand are moving to protect their primary producers and communities by introducing precautionary or prohibitive policies. Auckland Council, Far North District Council, Whangarei District Council and Hastings District Council have all included provisions in their planning documents to regulate the outdoor use of genetically modified organisms. All four councils have prohibited the release of GMOs on land and made field trials a discretionary activity with performance standards in regards to liability and the posting of bonds.
17. Soil & Health considers it vitally important that there should be an additional layer of protection at a local level (on top of the requirements of the HSNO), should contamination from outdoor use of GMOs occur. This is a safeguard for organic and GE-free producers who would otherwise have no recompense for GMO contamination damage to, or even the total loss of, their enterprise.
18. Soil & Health strongly supports the role of local councils (district, regional, city and unitary authorities) to manage natural and physical in a truly sustainable manner and safeguard the interests of their constituents and local communities when faced with uncertainty about environmental effects including the significant risks of the outdoor use of GMOs.
19. To maintain consistency with other member councils on the Inter-council Working Party it is submitted that New Plymouth District Council should include provisions relating to GMOs in the New Plymouth District Plan. These provisions could be the same (or similar) as those in the Auckland Unitary Plan.
The Law
20. Soil & Health was a party to Federated Farmers of New Zealand v Northland Regional Council. That decision ruled that local councils have the power under the RMA to control the use of GMOs via their local planning instruments.
21. In his decision Judge Newhook ruled that: “the RMA and HSNO offer significantly different functional approaches to the regulation of GMOs”.
22. HSNO is limited to regulating the introduction of new organisms (including GMOs) to New Zealand. HSNO “does not regulate the potential adverse effects of GMOs beyond approving them for release”, and does not provide for integrated management.
23. The RMA, on the other hand, enables authorities to provide for the use and protection of resources “in a fully integrated fashion, taking into account regional needs for spatial management that might differ around the country for many reasons”.
24. This decision was upheld in the High Court after Federated Farmers appealed the Environment Court’s decision.
25. Therefore, there is jurisdiction for the New Plymouth District Council to make provision for objectives, policies, rules and other planning tools in relation to GMOs under the Draft Plan.
26. This is further confirmed by the recent RMA amendments. On 18 September 2017 section 360D officially set down in law the right to place GMO provisions in Council plans without Ministerial interference.
Integrated Management
27. GMO proposals require approval from the EPA under the HSNO Act. The HSNO Act consenting process gives particular attention to the technical aspects of managing individual proposals. However, it does not involve:
(a) consideration of the geographic distribution of GMO projects;
(b) consideration of the need to geographically protect areas of particular value from GMO activities, such as sensitive farming practices (including organic farming, and all farming and forestry relying on a GE-free status, beekeeping etc.);
(c) consideration of the preferences of a community; or
(d) integration of the management of natural and physical resources, and the effects of GMO activities on natural and physical resources, on a geographic basis.
28. The HSNO Act does not, therefore, provide a planning framework through which GMOs can be geographically, spatially or culturally managed in an integrated manner.
29. The RMA establishes a regime whereby local authorities are called upon to prepare policy and plans to implement sustainable management on a geographic basis through the use of integrated management of natural and physical resources at a regional level, and integrated management of effects on the environment at a district level.
30. Consideration of the location and distribution of proposals involving GMOs on a district basis, together with protection of rural resources for organic, biodynamic or GE-free farming, forestry, marine farming, beekeeping or other primary production, are important resource management matters for consideration by territorial authorities in carrying out their functions under the RMA.
Potential Adverse Effects of GMOs
31. The outdoor use of GMOs has a potential to cause significant adverse effects on the environment. Adverse effects could include (inter alia):
(a) biological or ecosystem harm;
(b) harm to tangata whenua cultural values such as mauri and tikanga;
(c) harm to the cultural values and lifestyle decisions of people and communities at a local level concerning what constitutes their wellbeing; and
(d) harm from GMO contamination to existing or potential forms of land use including organic farming (including organic certification and the requirement to be GMO free) and farming, forestry, beekeeping, marine farming and other primary production activities dependent on an uncontaminated environmental brand. Adverse effects to these land uses could include:
(i) loss of organic and GMO free certification;
(ii) reputational damage;
(iii) loss of markets, both local, national and international and the premiums paid for GMO free produce; and
(iv) loss of livelihood.
32. GMOs have the potential to adversely affect ecological, economic, and resource management values, and the social and cultural wellbeing of people, communities and tangata whenua.
33. Application of integrated management and a precautionary approach to GMOs under the RMA is the best available technique for managing the potential adverse effects posed by GMOs within the region.
34. It is consistent with the sustainable management purpose and Part II of the RMA to establish district plan provisions (e.g. issues, objectives, policies, rules and methods) that manage the release, location and management of GMOs where they have the potential to adversely affect the environment and other land use activities.
Decision Sought Regarding GMOs
35. The decision Soil & Health seeks from New Plymouth District Council is that the Draft Plan be amended to include the following:
a. A new section specifically addressing GMOs which includes issues, objectives, policies and rules that are the same (or similar) as those in the Auckland Unitary Plan.
b. Rules that make outdoor field trialling of GMOs a discretionary activity and release of GMOs for outdoor use a prohibited activity;
c. Provisions for bonds to make consent holders financially responsible for monitoring and any adverse effects particularly since the economic cost of adverse effects could be very high and should not be borne by third parties;

Yours sincerely

Name: Mischa Davis
Position: Policy Advisor

The Soil & Health Association
PO Box 9693
Marion Square
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz

Community Support for a GE free Waikato – submissions needed by Monday 22nd January 2018

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The Soil & Health Association is encouraging the Waikato District Council to adopt precautionary provisions in the Waikato District Plan for any genetically engineered organisms that may be trialled or commercially produced.

The plan as currently drafted fails to regulate, or make any mention at all of GMOs.

“We want to ensure that the Council adequately protects the district from the significant adverse effects posed by GMO use by including strong precautionary GMO policies and rules into its District Plan,” says Soil & Health National Council member Marion Thomson.

“We call on the Waikato District Council to follow the lead of the other councils around New Zealand that have already adopted precautionary provisions and banned the outdoor release of GMOs via their local policy statements and plans,” says Marion Thomson.

“Provisions in the Waikato District Plan should be the same or similar to those in the Auckland Unitary Plan to ensure a consistent approach across Auckland and the Waikato and eliminate cross boundary issues,” says Thomson.

Auckland Council, Far North District Council and Whangarei District Council have all prohibited the outdoor release of GMOs and made field trials a discretionary activity with performance standards regarding liability and the posting of bonds.

GMOs threaten the economic sustainability of a wide range of agricultural activities that benefit from having GE-free status. This includes the many organic operations in the Waikato District, as well as non-organic dairy, forestry, honey, horticulture and other producers.

GE animal trials have been undertaken at AgResearch’s Ruakura research centre for several years, making the potential for GE escape or contamination of ongoing concern to Waikato residents.

“New Zealand has already seen several GE field trials breach the conditions of approval. No matter how carefully conditions are crafted, there inevitably remains a risk that they may be breached by poor management, human error, natural events such as severe storms or even sabotage,” says Thomson.

Current laws are inadequate to properly protect communities from the potential adverse effects of GE. There is no provision under the Hazardous Substances and New Organisms (HSNO) Act for financial liability for GMO contamination resulting from the release of an approved GMO, meaning those people or companies responsible for causing harm may not be held liable.

Once GMOs have been released into the environment, they would be very difficult if not impossible to eradicate. In the case of a food product, the GE-free status of a district would likely be lost permanently, along with the market advantages of that status.

Fortunately, under the RMA, requirements for bonds for remediation and to cover the costs of contamination can be included in district plans if local councils choose to implement them.

The Proposed Draft Waikato District Plan is now open for feedback, and Soil & Health is calling on Waikato residents to express support for precautionary and prohibitive GMO provisions, policies, and rules.

Submissions close on Monday 22nd January at 5pm.

Submission Template on Draft Waikato District Plan

Media contact

Marion Thomson, Soil & Health National Council

027 555 4014

Submission Template on Draft Waikato District Plan

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16 January 2018

Waikato District Council
2 Dominion Road
Tuakau 2121

Submission on draft Waikato District Plan

Introduction

1. I make this submission on the draft Waikato District Plan (“Draft Plan”) requesting that it include strong precautionary and prohibitive policies and rules relating to the management of genetically modified organisms (“GMOs”), as allowed under the Resource Management Act 1991 (“RMA”) and pursuant to the ruling in Federated Farmers of New Zealand v Northland Regional Council.

Risks of GMOs

2. I have concerns about the potential risks posed by the release of GMOs into the environment. GMOs have the potential to adversely affect ecological, economic, and resource management values, and the social and cultural wellbeing of people, communities and tangata whenua.

3. The release of GMOs has a potential to cause significant adverse effects on the environment, which could include:
(a) biological or ecosystem harm;
(b) harm to tangata whenua cultural values such as mauri and tikanga;
(c) harm to the cultural values and lifestyle decisions of people and communities at a local level concerning what constitutes their wellbeing; and
(d) harm from GMO contamination to existing or potential forms of land use including farming, forestry, beekeeping, marine farming and other primary production activities dependent on an uncontaminated environmental brand. Adverse effects to these land uses could include:
(i) loss of organic and GMO-free certification;
(ii) reputational damage;
(iii) loss of markets and premiums paid for GMO free produce; and
(iv) loss of livelihood.

4. No matter how carefully conditions of consent for GMOs are crafted, there inevitably remains a risk, even if small, that conditions may be breached by poor management, human error, natural events such as severe storms and even the sabotage of projects.

5. Once GMOs have been released into the environment, they would be very difficult if not impossible to eradicate. In the case of a food product, the “GE free” status of a district would likely be lost permanently along with the market advantages of that status.

6. Application of integrated management and a precautionary approach to GMOs under the RMA is the best available technique for managing the potential adverse effects posed by GMOs within the region.

7. It is consistent with the sustainable management purpose and Part II of the RMA to establish district plan provisions (e.g. issues, objectives, policies, rules and methods) that manage the release, location and management of GMOs where they have the potential to adversely affect the environment and other land use activities.

Decision Sought regarding GMOs

8.The decision I seek from Waikato District Council is that the Draft Plan be amended to include the following:
(a) A resource management framework for the management of GMOs that is regional specific taking into account environmental, economic and social well-being considerations.
(b) Strong precautionary and prohibitive provisions, policies and rules relating to GMOs that are the same (or similar) as those in the Far North District Plan, the Whangarei District Plan and the Auckland Unitary Plan, to ensure a consistent approach across Northland, Auckland and the Waikato and to eliminate cross boundary issues.

Submission on Proposed Regional Plan for Northland

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Introduction

  1. 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.
  2. Soil & Health makes this submission on the Proposed Regional Plan for Northland (“Proposed Plan”) requesting that it include policies and provisions relating to the management of genetically modified organisms (“GMOs”), as allowed under the Resource Management Act 1991 (“RMA”) and pursuant to the ruling in Federated Farmers of New Zealand v Northland Regional Council.
  3. Soil & Health further requests that amendments be made to the agrichemical section of the Proposed Plan to better protect people and the environment from the adverse effects of pesticides. A holistic approach to land and water use is required if land is to retain its productive capacity, and fresh water and marine habitats are to be restored. Agrichemical rules and policies must take special account of glyphosate use and other pesticide use in the region.
  4. Soil & Health wish to be heard in support of our submission.

    5. Genetically Modified Organisms
    Background

  5. Significant gaps exist in the law around GMOs in New Zealand. In the Hazardous Substances and New Organisms Act 1996 (‘HSNO Act’) there are inadequate liability provisions (e.g. ‘polluter pays’) for any unintended or unforeseen adverse impacts resulting from the outdoor release of an approved GE crop or animal, meaning those causing harm may not be held liable. There is no mandatory requirement for the Environmental Protection Authority (‘EPA’) to take a precautionary approach to the outdoor use of GMOs.
  6. Due to these gaps in the law, the Inter-council Working Party on GMO Risk Evaluation and Management Options was establish and as a result a number of councils around New Zealand have been moving to protect their primary producers and communities by introducing precautionary or prohibitive policies. Auckland Council, Far North District Council and Whangarei District Council have all included provisions in their planning documents to regulate the outdoor use of genetically modified organisms. All three councils have prohibited the release of GMOs on land and made field trials a discretionary activity with performance standards in regards to liability and the posting of bonds. Auckland Council (as a Unitary Authority) has also prohibited the release of GMOs in the Coastal Marine Area (‘CMA’) and made field trials within the CMA a discretionary activity with performance standards in regards to liability and the posting of bonds.
  7. The Regional Policy Statement (‘RPS’) for Northland contains provisions relating to GMOs. These provisions are not yet operative. However, they are likely to require a precautionary approach to outdoor uses of GMOs.
  8. To maintain consistency with other member councils on the Inter-council Working Party and in anticipation of operative precautionary provisions in the RPS it is submitted that NRC should include provisions relating to GMOs in the CMA in its Proposed Regional Plan for Northland. These provisions should be the same (or similar) as those in the Auckland Unitary Plan to ensure a consistent approach across Northland and Auckland and eliminate cross boundary issues.

    9. The Law

  9. Soil & Health was a party to Federated Farmers of New Zealand v Northland Regional Council.
  10. That decision ruled that local councils have the power under the RMA to control the use of GMOs via their regional planning instruments.
  11. That decision has recently been upheld by the High Court.
  12. Soil & Health therefore considers that there is jurisdiction for Northland Regional Council (‘NRC’) to make provision for objectives, policies, rules and other planning tools in relation to GMOs under the Proposed Plan.

    13. Integrated Management

  13. GMO proposals require approval from the EPA under the HSNO Act.
  14. The HSNO Act consenting process gives particular attention to the technical aspects of managing individual proposals. However, it does not involve:
    1. consideration of the geographic distribution of GMO projects;
    2. consideration of the need to geographically protect areas of particular value from GMO activities, such as sensitive farming practices (including organic farming, also all farming and forestry relying on a GE-free status, beekeeping etc.);
    3. consideration of the preferences of a community; or
    4. integration of the management of natural and physical resources, and the effects of GMO activities on natural and physical resources, on a geographic basis.
  15. The HSNO Act does not, therefore, provide a planning framework through which GMOs can be geographically, spatially or culturally managed in an integrated manner.
  16. The RMA establishes a regime whereby local authorities are called upon to prepare policy and plans to implement sustainable management on a geographic basis through the use of integrated management of natural and physical resources at a regional level, and integrated management of effects on the environment at a district level.
  17. Consideration of the location and distribution of proposals involving GMOs on a district basis, together with protection of rural resources for organic, biodynamic or GE-free farming, forestry, marine farming, beekeeping or other primary production, are important resource management matters for consideration by territorial authorities in carrying out their functions under the RMA.

    18. Potential Adverse Effects of GMOs

  18. The outdoor use of GMOs has a potential to cause significant adverse effects on the environment. Adverse effects could include (inter alia):
    1. biological or ecosystem harm;
    2. harm to other existing or potential forms of land use including:
      1. organic farming (including organic certification and the requirement to be GMO free); and
      2. farming, forestry, beekeeping, marine farming and other primary production activities dependent on an uncontaminated environmental brand.
  19. GMOs have the potential to adversely affect ecological, economic, and resource management values, and the social and cultural wellbeing of people, communities and tangata whenua.
  20. Application of integrated management and a precautionary approach to GMOs under the RMA is the best available technique for managing the potential adverse effects posed by GMOs within the region.

    21. Sustainable Management and Part II

  21. It is consistent with the sustainable management purpose and Part II of the RMA to establish regional plan provisions (e.g. issues, objectives, policies, rules and methods) that manage the release, location and management of GMOs where they have the potential to adversely affect the environment other land use activities.

    22. Decision Sought regarding GMOs

  22. The decision Soil & Health seeks from NRC is that the Proposed Plan be amended to include the following:
  23. Strong precautionary, restrictive and/or prohibitive GMO provisions in the ‘Tangata whenua’ section of the Proposed Plan which address tangata whenua opposition to outdoor use of GMOs and/or their products and specific concerns about the risks of GMOs to indigenous biodiversity, and keeps with the wording in the RPS as relates to tangata whenua.
  24. To include GMO provisions in the ‘Coastal’ and ‘Coastal activities’ sections of the Proposed Plan that are the same as in the Auckland Unitary Plan, that being to adopt a precautionary approach to the management of GMOs by:
  25. prohibiting the outdoor release of a GMO in the Coastal space; and
  26. making outdoor field-testing a discretionary activity in the Coastal space; and
  27. including performance standards in regard to liability and the posting of bonds.
  28. To include GMO provisions in the ‘Land & water’ and the ‘Discharges to land and water’ sections of the Proposed Plan that avoids toxic discharges to land and water from GMOs, thereby avoiding transgenic contamination of soils and waterways and adverse impacts on GE-free primary producers. We note that the vectors for transgenic contamination include soils, seeds, pollen, insects, machinery, water, plus human error.
  29. To adopt a resource management framework for the management of GMOs that is regional specific taking into account environmental, economic and social well-being considerations.
  30. To address and support the Far North District Council, Whangarei District Council and Auckland Council’s opposition to outdoor use of GMOs.
  31. Soil & Health considers that it is important that there is consistency between the Auckland Unitary Plan and the Regional Plan for Northland, thereby eliminating cross boundary issues.

    32. Agrichemicals
    Introduction

  32. Soil & Health is opposed to the use of harmful pesticides in Aotearoa New Zealand. As an organisation we advocate for farmers and growers to adopt natural, organic, non-harmful methods of pest and disease management. We believe that researchers, farmers and growers should be encouraged to develop and implement nonchemical alternatives to pesticides that foster soil microbial life instead of destroying it. Central and local government should promote and support farmers and growers to transition to more sustainable and environmentally friendly methods of farming and land use while also ensuring that regulations are in place to sufficiently protect people, communities and the environment from the adverse effects of pesticides.
  33. Numerous independent scientific studies have raised serious concerns about the effects that pesticides have on human health and the environment. There is a real risk of people living in rural communities, close to where commercial horticulture takes place, who may be exposed to spray drift. Young children are especially vulnerable as they often play outdoors and in the fields. Children at school can be subjected to pesticide exposures from nearby operations. A number of studies have linked exposure to pesticide drift to chronic conditions in children such as autism spectrum disorders and childhood acute lymphoblastic leukemia.
  34. Organic farmers and producers are also at risk. Environmental chemical pollution threatens the long-term viability of organic producers sourcing water for livestock and food production. Organic farmers become exposed when input quality cannot be assured. Water is the major input in agriculture.
  35. New Zealand currently applies an excessive amount of pesticides to soils. The Food and Agriculture Organization’s statistics database advises that in 2014 US$20,481,292.00 worth of pesticides were sold in New Zealand. This list doesn’t include hazardous pesticides like atrazine, which are sold here but are unauthorized in Europe. Herbicides accounted for nearly 50% of these sales.

    36. Gylphosate

  36. Of the many chemicals currently approved for use in New Zealand by the EPA of most concern is glyphosate, commonly known as Roundup. It is sprayed down most New Zealand roads, through our forestry plantations, and on most agricultural land.
  37. Glyphosate is a biocide meaning it has multiple pathways of toxicity. Glyphosate damages gut bacteria, beneficial species are vulnerable but pathogenic bacteria are resistant, it harms the immune system, has been demonstrated to impact serotonin production, is endocrine disrupting and neurotoxic. As a patented antibiotic, it may affect antibiotic resistance. Leaky gut syndrome is a particularly insidious and unpleasant consequence that is affecting increasing numbers of people.
  38. It is expected that the biggest users of glyphosate in New Zealand are forestry, agriculture, New Zealand Transport Agency and local councils. However the EPA doe not exactly know how much glyphosate is being used. In an Official Information Act release dated 16 June, an EPA Communications Advisor wrote: “We often get asked by journalists about the volume or extent of glyphosate use (which we can’t answer).”
  39. After more than 40 years of prolific global use, glyphosate was recently identified by the World Health Organisation’s International Agency for Research on Cancer as a ‘probable human carcinogen.’ Many countries are proactively applying the precautionary approach and are restricting, and in some cases completely banning, the use of glyphosate. These countries include the United Kingdom, most northern European countries, France, Spain, Canada, Colombia, Mexico, Sri Lanka, Bermuda and parts of the United States. Brazil and Argentina are likely to follow.
  40. In New Zealand some local governments are moving towards precautionary avoidance measures to transition away from the use of glyphosate-based herbicides. For example Christchurch City Council have recently proposed adopting a ban on glyphosate-based herbicides in built up areas in their draft Annual Plan. Tauranga City Council has also adopted measures to transition away from the use of glyphosate-based herbicides

    41. Effects on water quality

  41. Soil & Health recognises that New Zealand freshwater is in a dire state, with a staggering 62% of monitored waterways being unsafe for swimming. A big factor in the pollution of waterways is from the increasing intensification of agriculture and namely nitrates from soluble nitrogen fertilisers as well as increased pesticide use, so simply fencing off and planting around streams cannot solve this issue. Healthier fresh water is achievable by ensuring stock numbers are sustainable, and by shifting to organic and biological fertilising practices that involve nitrogen-fixing pasture species, and healthy living soils with good moisture-holding capacity.
  42. Regional Councils have an obligation under the National Policy Statement for Freshwater Management to maintain and improve water quality however the same document fails to monitor synthetic organic compounds, and particularly, pesticides. The National Standards for freshwater lists only eight attributes for monitoring: cyanobacteria; Escherichia coli; dissolved oxygen; ammonia; nitrate; periphyton; total phosphorus; and total nitrogen. Avoiding greater contaminant monitoring permits a kind of ‘manufactured ignorance.’
  43. We do not have data to demonstrate how New Zealand aquatic environment responds to the chemicals that may cause adverse effects to invertebrates, fish species and other aquatic fauna. Toxic synergies from multiple chemicals are ignored.
  44. While our national freshwater policy does not require monitoring of agrichemicals in our waterways the most common pesticide, glyphosate and its toxic (and persistent) metabolite AMPA (aminomethylphosphinic acid), is not routinely monitored anywhere, not in freshwater, groundwater, or drinking water. Public health policy-makers might take note that glyphosate does not degrade quite as quickly as the claims made by regulators, indicate.

    45. Decision sought

  45. Ensure that cultivation that is on land that is not certified organic becomes made a controlled activity requiring a 400m buffer for sensitive spray areas.
  46. Require that along with National Freshwater standards that are required SectionD.4.1- D4.4, that freshwater and sediment monitoring data (for the previous 5 years) for the following commonly used pesticide screens are required annually. If a freshwater body is identified as degraded, then require pesticide screens quarterly. Ensure this information is published and fully available online.

    47. List of pesticides:

    1. Glyphosate and AMPA residues in freshwater and/or sediment
    2. Organonitrogen, Organophosphorus and Pesticides (ONOP) in Water and Soil.
    3. Multiresidue Pesticides (MR) in Water and Soil.
    4. Acidic Herbicides in Water and Soil
    5. Sulfonylureas (metsulfuron is widely applied on NZ roadsides)
    6. Semi-Volatile Organic Compounds (SVOC)
    7. Organochlorines
  47. Ensure that the data supplied to the NZ National Survey of Pesticides in Groundwater is publicly available. Ensure that the metabolites as well as the primary active ingredients are screened for.
  48. The notification period for neighbouring land owners before spraying be increased from 24 hours to 48 hours, at a minimum. The currently proposed 24 hour notification period is not sufficient to ensure that people and communities are protected from the adverse effects of agrichemical spraying, especially for spray sensitive areas.
  49. Any aerial spraying whatsoever should not be allowed as a permitted activity under the Proposed Plan. Due to the nature of application aerial spraying is virtually impossible to contain in order to ensure that spray drift or direct discharge to water does not occur – therefore it is impossible for aerial spraying to meet the permitted activity conditions of rule C.6.5.1.
  50. Soil & Health request that conditions be imposed to ensure agrichemical monitoring, including for air, freshwater and groundwater, takes place which is supported by evidence concerning children’s increased vulnerability to pesticides. Soil & Heath are skeptical of how and whether the permitted activity conditions will ever be enforced without any sufficient requirements for monitoring.
  51. In 2014 11 wells were sampled. Ensure that these wells correspond with regions where higher levels of pesticides may be being applied. Northland is detecting triazine herbicides in groundwater. Europe have banned these due to high mobility and leaching. OEHHA have recognised many triazine herbicides as reproductive toxicants.

Yours sincerely

Name: Mischa Davis
Position: Policy Advisor

The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz

A win for clean, green, GE-free New Zealand

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The Soil & Health Association is celebrating the decision by Federated Farmers to abandon its appeal against the right of councils to control the use of genetically modified organisms (GMOs) in their territories. Federated Farmers filed its latest appeal earlier this year in the Court of Appeal, after its appeals to the Environment Court and High Court had been dismissed.

“We congratulate Federated Farmers on this pragmatic and sensible decision,” said Soil & Health Chair Graham Clarke.

“Both the High Court and Environment Court have ruled that regional councils have jurisdiction under the Resource Management Act (RMA) to regulate the use of GMOs through regional policy statements or plans. The recent RMA amendments further entrench the legal rights of councils to do so. Challenging these decisions would only have cost us, the other parties involved and Federated Farmers themselves a lot of unnecessary time and money.”

Federated Farmers had argued that the Environmental Protection Authority had sole responsibility for the regulation of GMOs under the Hazardous Substances and New Organisms Act (HSNO).

The decision to withdraw its appeal comes after recent amendments were made to the RMA, which confirmed the High Court ruling, leading Federated Farmers to believe that they “are likely to have materially reduced the prospects of the appeal being prosecuted successfully.”

The RMA changes, which passed in April this year via the Resource Legislation Amendment Bill, included a controversial section which allows the Minister for the Environment to bypass parliament and make fundamental changes to the law if it is deemed that council plans duplicate or deal with the same subject matter as central Government laws. This would have allowed the Minister to strip councils of their ability to create GE-free food producing zones.

The National Government at the time needed the Maori Party votes to pass the changes. However, the Maori Party stated in December last year that it would not support changes to the RMA if they extended to allowing the Minister to overrule planning provisions controlling the use of GMOs.

Before the final reading of the Bill, an exemption was introduced under section 360D specifically for GE crops, effectively preventing the minister from permitting GMO crops in regions that had elected to remain GMO free or impose controls on the use of GMOs.

“We are so grateful to Maori Party for their determination to ensure that appropriate clauses in the RMA were included to protect regions from uncontrolled GMO use. Had they not stood firm against the changes, then we might not have had this decision from Federated Farmers to withdraw their appeal,” says Soil & Health National Council member Marion Thomson.

“The RMA amendment further confirms the ability of all local councils to determine GMO policies in their regions. Local communities can now have confidence that their values and concerns about the use of GMOs in their regions can be considered when drafting policy statements and plans.” says Thomson.

The economic sustainability of a wide range of agricultural export activities reliant on GMO-free status is also protected by this ruling. The global non-GMO food market is currently valued at US$250 billion, and trends show this is only going to grow. New Zealand producers benefit from access to this huge non-GMO market.

Soil & Health has found no economic, health or environmental case for GMOs. There are huge uncertainties around the adverse effects of GMOs on natural resources and ecosystems. The risks are large and consequences irreversible. If GMOs were to be released into the environment, they would be very difficult, if not impossible, to eradicate in circumstances where they adversely affected the environment. There is also potential for serious economic loss to regions marketing their products and tourism under New Zealand’s ‘clean green’ brand, if GMO land use were permitted.

Background:

Significant gaps exist in the law around GMOs in New Zealand. In the HSNO Act there are inadequate liability provisions (e.g. ‘polluter pays’) for any unintended or unforseen adverse impacts resulting from the outdoor release of an approved GE crop or animal, meaning those causing harm may not be held liable. There is no mandatory requirement for the EPA to take a precautionary approach to the outdoor use of GMOs.

Due to these gaps in the law, a number of councils around New Zealand have been moving to protect their primary producers and communities by introducing precautionary or prohibitive policies.

The Northland Regional Council is one such council which, after receiving hundreds of submissions from Northland ratepayers, district councils, Northland Conservation Board, iwi authorities, hapū and community groups, chose to adopt a precautionary approach around the outdoor release of GMOs in the proposed Northland Regional Policy Statement.

Federated Farmers of New Zealand lodged an appeal with the Environment Court in 2015 opposing these precautionary GMO provisions in the Northland Regional Policy statement. Principal Environment Court Judge L. Newhook however found that there is jurisdiction under the Resource Management Act for regional councils to make provision for the outdoor use of GMOs through regional policy statements and plans. Since comprehensively losing the appeal (which it initiated) on all points of law, Federated Farmers filed a second appeal against the Environment Court’s decision with the High Court.

Soil & Health, GE Free Northland, Taitokerau mana whenua, Far North District Council and several other groups and individuals joined the appeal in the High Court as section 274 (interested) parties pursuant to the RMA, in support of respondents Northland Regional Council and Whangarei District Council. Soil & Health was represented by Dr. Royden Somerville QC and Robert Makgill.

Dr Somerville argued that Environment Court Judge L. Newhook was correct in his decision that the RMA and HSNO Act hold complementary and not overlapping roles. The two Acts offer different purposes and functional responses to the regulation of GMOs in New Zealand. Thus, regional planning documents can control the use of GMOs as part of promoting sustainable management under the RMA, taking account of regional needs. This argument has been confirmed by High Court Judge Mary Peters.

Contact: Graham Clarke
Chair, Soil & Health Association
027 226 3103

Councils retain right to regulate GE trees

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The Soil & Health Association is thrilled that newly released standards for forestry no longer include a controversial clause that would have allowed the planting of genetically engineered (GE) trees across New Zealand.

Released by MPI last week, the National Environmental Standard for Plantation Forestry (NES-PF) provides regulations to manage the environmental effects of forestry. Soil & Health made a submission on the proposed policy document and, along with nearly 16,000 others, opposed the clause that would have permitted the planting of GE trees.

“We are thrilled by this result and congratulate all who submitted against the clause, and MPI for listening to us. They have done a great service to New Zealand in doing so,” said Soil & Health chair Graham Clarke.

The removal of the GE clause means that there will be no blanket approval for GE trees anywhere in New Zealand. Applications for GE trees to the Environmental Protection Authority must be assessed on a case-by- case basis, like all GE applications, with the opportunity for the public to make submissions. Any approvals are subject to regional and district plan provisions which may require additional conditions, or ban the planting of GE trees altogether.

“Including the GE clause would have jeopardised local authorities’ ability to manage the outdoor use of GMOs, and put at risk the economic sustainability of a wide range of agricultural export activities reliant on GE-free status,” said Mr Clarke.

Last year the High Court upheld the landmark Environment Court decision that regional and territorial authorities can manage the outdoor use of genetically modified organisms in the same way as any other land use in their regions, under the RMA. Soil & Health, which was a party in the High Court decision, considered the ruling a win not only in the fight against GE, but also for democracy in allowing local communities to have a say in the GE policies in their areas.

“The decision to remove the GE tree clause from the NES-PF confirms the ability of councils to respond to community concerns about the planting of GE trees and other crops in their region,” said Mr Clarke.

The Soil & Health Association of NZ is the largest membership organisation supporting sustainable, organic food and farming in New Zealand, and is one of the oldest organic organisations in the world, established in 1941. Our aim is to empower people and communities to grow, buy and support locally based sustainable, safe, GE-free and organic food in Aotearoa NZ.

Organic farmer new chair of Soil & Health

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8 August 2017

A fourth-generation farmer has been selected as the new chair of the Soil & Health Association, following its AGM. Until 2014 Graham Clarke was a sheep and beef farmer for over 30 years in South Otago at Marama Farm, which was certified organic by BioGro for close to 10 years. “I’m passionate about sustainable food production and see organic food as being essential to getting better quality nutrition to New Zealanders,” says Graham Clarke.

Mr Clarke, who was first elected onto the National Council of Soil & Health in July 2016, brings experience and enthusiasm for organics to the council table. He has had governance experience with Federated Farmers, the Beef Council and the Animal Health Board.

“I have now chosen to serve Soil & Health in the hope that this can mean more farmers can be supported to grow great nutrition for New Zealanders, and more people can achieve good health through their food. Organics needs to go mainstream,” said Mr Clarke.

Having experienced huge health improvements himself through eating well, Mr Clarke is now a certified Integrative Nutrition health coach and helps people improve their health and their lives through what they eat and other lifestyle choices. In his spare time, he leads a team of caregivers who look after a young man with disabilities caused by a car accident, with nutrition one of the key planks in his greatly improved health.

Graham Clarke paid tribute to outgoing chair Marion Thomson: “Marion has dedicated a huge amount of energy to Soil & Health for many years, particularly championing the rights of communities to control or ban GE in their areas, via several court cases. The Association is lucky to have her stay on as a member of the National Council and continue our important work,” said Mr Clarke.

“Times are changing locally and globally and the weight of evidence concerning the challenges of many of the current farming methods and the consequences of some of them continues to grow. This is both a health and environmental concern. Soil & Health is aiming for a fully organic New Zealand to address these concerns.”

 

Contact: Graham Clarke
Chair, Soil & Health Association
027 226 3103

Health not herbicides: time to phase out glyphosate

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Our public agencies must protect human health and ecosystems, and use rigorous independent science rather than industry data, says the Soil & Health Association. Soil & Health welcomes the release of a paper by the Green Party that exposes many flaws in an Environmental Protection Authority (EPA) report on glyphosate-based herbicides (such as Roundup).

The EPA commissioned a report last year that found glyphosate to be safe and unlikely to be carcinogenic.   Only months before, the world-leading authority International Agency for Research on Cancer (IARC) determined that glyphosate was a ‘probable carcinogen’.

The paper released by the Green Party last week revealed that the EPA’s conclusion was based on flawed science and data provided by industry. The paper dispels the so-called safety claims made by the EPA and highlights the urgent need to reassess the authorisation of products like Roundup that contain glyphosate.

“Many countries have banned the use of glyphosate due to its toxicity,” says Soil & Health chair Graham Clarke, who is a fourth generation farmer. “Even exposure to very low doses, below the risk analysis guidelines, creates a very real risk to human health. This paper raises serious concerns about the adequacy and quality of the EPA’s hazardous substances assessments.”

“Roundup in particular has been a cornerstone of chemical agriculture in New Zealand for decades but as each day goes by new compelling evidence emerges showing the downside of this product,” says Clarke.

“Soil & Health congratulates organic farmers, home gardeners and others who are using safe and effective ways to grow food and to control weeds, with no need for harmful herbicides. We’d like to see more government support for research into non-chemical alternatives to glyphosate as demonstrably the high chemical input system is not serving anyone in New Zealand well except the marketers of said products.”

Glyphosate is sprayed on numerous crops, including about 80% of genetically engineered crops that are bred to be tolerant to the herbicide. It is also used in New Zealand and overseas as a pre-harvest desiccant, so crops such as wheat are uniform at harvest time, and to make crops like potatoes easier to harvest. Residues of glyphosate (or its metabolites) are likely to be in many foods that Kiwis are eating every day, with the notable exception of organic foods. Buying certified organic foods is the best consumer guarantee to avoid residues of harmful chemicals such as glyphosate. The herbicide is also widely used in home gardens and public places including roadsides, parks and playgrounds.

“By deeming glyphosate safe and allowing for its widespread sale and use in New Zealand we believe the EPA has failed in their statutory obligation to protect the health and safety of people and communities, by preventing or managing the adverse effects of hazardous substances,” says Clarke.

Soil & Health believes that glyphosate should be phased out immediately.

“The use of glyphosate in public places, home gardens and for pre-harvest desiccation should cease immediately as these are the routes that expose most people to glyphosate. Other uses should be restricted and phased out as soon as possible,” says Clarke.

 

Links

Soil & Health’s policy on pesticides:

https://soilandhealth.org.nz/policies/pesticides/

Green Party paper:

https://www.greens.org.nz/sites/default/files/Published%20Paper%20-%20Why%20did%20the%20NZ%20EPA%20ignore%20the%20World%20Authority%20on%20Cancer%20-%20July%202017.pdf

IARC report:

http://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf

EPA report:

http://www.epa.govt.nz/Publications/EPA_glyphosate_review.pdf

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

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 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 Lancet, 354(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 Toxins, 6(6), 219-233.

[5] Tacket, C. O. (2007). Plant-Based Vaccines Against Diarrheal Diseases. Transactions of the American Clinical and Climatological Association, 118, 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 Toxicology, 42(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

GE free

GE potatoes set to sneak into our food

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The Soil & Health Association has serious concerns about another GE food line being approved in New Zealand – this time for six food lines derived from potatoes.

Food Standards Australia New Zealand (FSANZ), the organisation that controls food approvals for New Zealand and Australia, is calling for submissions on an application to permit GE potatoes for human consumption. The potatoes have been genetically engineered to reduce bruising, to reduce acrylamide formed during cooking, and to protect the potatoes from a type of blight.

Soil & Health is concerned about the growing number of genetically engineered foods approved for sale in New Zealand and the long-term and cumulative health effects of consuming them. While New Zealand does not grow any GE crops or animals, there are many imported GE ingredients in food for sale here.

“Since 2000 FSANZ has approved every single application for GE food lines, and there are now a staggering 71 different GE food lines approved for sale in New Zealand,” says Soil & Health chair Marion Thomson.

“An estimated 70% or more of processed non-organic foods for sale in New Zealand contain genetically engineered ingredients, but consumers have no idea because our labelling laws mean that almost all GE ingredients don’t have to be listed on the packaging.”

“In addition to human food, New Zealand imports large quantities of animal feed that is almost certainly genetically engineered, but again, not labelled as such,” says Marion Thomson.

While a FSANZ safety assessment on the GE potato application has not identified any public health and safety issues, previous FSANZ assessments have been shown to be incomplete, with an absence of biological studies on the impacts of the foods when eaten. Further, assessments have largely been reliant on industry assurances of safety, with no independent science to back up industry assertions.

“One of the main concerns about eating GE foods is that many have been grown with dangerous levels of pesticides,” says Thomson. “Many GE crops are designed to be resistant to pesticides. These crops are designated ‘safe’ for human consumption by FSANZ and the Ministry for Primary Industries, despite not having undergone adequate safety tests independent of the companies developing them.”

The best way to avoid consuming GE foods is to grow, buy and eat certified organic food, says Soil & Health.

The GE potatoes application is open for public submission until 7 July 2017.