Submissions Against GE Brassicas

Submission to: Environmental Risk Management Authority
Friday, December 8, 2006

Dear Members

Re: GE Brassica Field Trial

Crop & Food Research has applied to ERMA (Environmental Risk Management Authority) to spend taxpayers’ money on a 10-year field trial of genetically engineered brassicas: specifically cabbage, broccoli, cauliflower and forage kale. Plants would have genes spliced from bacteria and viruses, including ‘Bt’ (Bacillus thuringiensis), in order to kill cabbage white butterfly and diamond backed moth.

Soil and Health is supporting Organic Aotearoa New Zealand’s substantive submission opposing the trial, and putting in our own submission. We encourage members to write submissions to ERMA opposing the field trial.


You should quote Crop and Food Research’s application GMF06001. Submit in writing to ERMA NZ, PO Box 131, Wellington, 6140, by fax to ERMA NZ, 04 914 0433, or online at Include name, contact details, signature, the date, reasons for your submission, and the decision you seek.

As follows are some points you may wish to use, and websites for further information.

Thanks for considering this! We hope our submissions will lead to a rejection of the trial and protection of organic and GE-free crops and food. Let’s work together towards an Organic 2020.

Mike Palmers, Co-Chair



I/We strongly urge ERMA to decline this application for the following reasons:

Environmental Risks and Lack of Long-term Sustainability

* There is no point approving this field trial for genetically engineered brassicas unless they are to eventually be grown commercially. However, if grown commercially, these GE brassicas will cause GE contamination of other brassica crops and honey, and destroy New Zealand’s clean, green image.
* Target insect pests will become resistant to crops genetically engineered with Bacillus thuringiensis (Bt), as has happened overseas.
* Insect resistance could result in more use of toxic sprays to control pests.
* Brassica pollen is readilty spread by insects, and GE brassicas would cross easily with dozens of wild and cultivated cousins.
* Any short-lived benefits before white cabbage butterfly and diamond backed moth are resistant comes at the cost of irreversible GE contamination.

Removal of Farmer Choice

* Insect resistance to Bt-engineered plants will result in the loss of a safe and important tool (natural Bt) for organic and conventional farmers.
* Contamination will remove farmer choice to grow GE-free food.
* If commercially grown, GE brassicas will contaminate GE-free crops, potentially making farmers liable for having illegal GE plants.

Removal of Consumer Choice

* Contamination will remove people’s right to buy and grow GE-free food. New Zealanders have stated clearly and often that they want to protect the availability of safe, natural and organic food.

Loss of Markets

* GE contamination – even trace levels – threatens our economy because of loss of exports to overseas markets, which have rejected GE foods.
* This field trial would tarnish New Zealand’s clean green image and reputation for producing safe and natural foods.


* Current liability laws are not strict enough to hold GE experimenters financially accountable for unintended or unforseen adverse impacts on farmers, consumers or the environment.
* Communities face paying (through rates, taxes or indirectly) the costs of clean-up, compensation and dealing with insect pests that have become resistant.

Use of Public Money

* Public money should not be spent on GE products, which the majority of New Zealanders (67% in recent surveys) do not want.
* GE-free methods of pest control in brassicas are already being practiced in organic systems. Public funds should be used for further research into sustainable, organic spest reduction methods.

Potential Negative Health Impacts

* Evidence of health impacts from Bt crops on people and animals must be fully investigated before the application is even considered.
* GE plants containing antibiotic-resistant marker genes can add to existing problems in controlling disease.
* Some forms of Bt toxins have been identified as potential allergens in humans.

Lack of Information from Applicant

* ERMA should not approve this field trial because the precise combination of plant, bacteria, virus and other genes is not known.
* Blanket approval cannot be justified, as different re-combinations may present different risks and therefore should be considered on a case-by-case basis.
* Independent scientists cannot provide expert advice on proper risk-management without knowing the gene-profile of the GE plants created.

Decision Sought
The risks of this field trial far outweigh any potential benefits. For all the above reasons, this field trial application must be rejected.

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