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Submissions to New Zealand Government
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9 December
2003
Jane
Coombs
Environment
Division
Ministry
of Foreign Affairs & Trade
Private
Bag 18901
WELLINGTON
URGENT
REQUEST & ENQUIRY
Support
ratification of
CARTAGENA
PROTOCOL to the CONVENTION on
BIODIVERSITY
PIRM, founded in 1984, is an
organisation dedicated to sustainable use of the earth’s resources. We are
concerned about deteriorating global ecosystems, rapid depletion of natural
resources and degradation of the environment, examples being climate change,
loss of biodiversity, soil erosion, pollution of water systems and natural
habitats. Our objectives are to advocate respect for natural processes;
conservation of physical resources and integrity of all life forms. We
contribute to the establishment of
New Zealand
as a strong, independent active authority advocating
implementation of a world conservation strategy. We publish Pacific
Ecologist, make submissions and hold public meetings.
For the first time in more than 65 million years, the world is in the
early phases of a mass extinction of species, resulting from human impacts on
the biosphere. More than 500
New
Zealand
plant and animal species are categorised as threatened
(marine species excluded) by the International Union for the Conservation of
Nature. This is a serious matter, particularly as NZ is the only “developed”
nation that is wholly a biological hot spot.
The Pacific Institute of Resource
Management, (PIRM) urgently requests Ministry for Foreign Affairs & Trade to
counsel the government to ratify the
Cartagena Protocol to the Convention on Biological Diversity, to protect
New Zealand
’s and the world’s biodiversity from known and unknown
hazards of genetically modified organisms, and to fulfil our international
obligations under the international Biodiversity Convention to conserve
biodiversity. In a time of global
mass extinctions this is even more essential.
New Zealand
’s future will depend not only on the health of its own
biodiversity but also on the health of the world’s biodiversity.
New Zealand
’s biodiversity is already seriously under threat through
introduced species. As well, through not ratifying the Protocol,
New Zealand
is in contravention of obligations under basic Human Rights
Conventions, i.e. the rights of all people’s to food security. - see
E-F below
Some major points we would like
answers to from the Ministry, are noted A-R;
some references are documented at end of this submission - others can be found
in the enclosed issue of Pacific Ecologist.
A.
The prospect of more serious ecological
damage - e.g. loss of key pollinators - through the spread of GMOs that will not
be able to be recalled, is likely (see below)
- and will be impossible to remedy. This
will certainly affect trade. Precautionary action is essential with GMOs, since
little is known about their interaction in the wider environment over time, as
Minister for Environment, Marion Hobbs has said. Insurance companies are
refusing to insure against GMO damage.
Third
world countries & EU ratify protocol & want protection from GMOs - Why
not NZ ?
On Sept 11, the Cartagena Protocol to
the Convention on Biodiversity was ratified by over 55 countries, including
African and other third world countries and the EU. The protocol allows
countries to reject GMOs and GE food on grounds of threats to food security and
biodiversity.
(NB
- A faulty reason, often given by biotech enthusiasts and particularly
industrialised countries for supporting GM agriculture is that it will feed
poor, third world countries and starving people.
Yet it is well established that lack of food and hunger in the world is
largely caused through inequity and rigged terms of trade whereby the
US
insists third world
countries open their markets, while the
US
increases its subsidies
& protections, thus destroying livelihoods and incomes of millions of third
world farmers. This is what caused
third world countries to walk out on the
Cancun
trade talks in September
this year. For details, please see page 39 of Pacific
Ecologist. It is well known also that GM agriculture will increase inequity
and dependence and threaten food security in third world countries via patenting
of GM crops, terminator genes, requiring farmers to buy seeds each year, and the
need for increased pesticides via pesticide resistant crops, as well as threats
to food security via GM hasards - see below.)
Additionally,
it is to third world countries, and African countries in particular, that we owe
thanks for their efforts in initiating and encouraging others to ratify this
protocol, which allows countries to protect their biodiversity and food security
from the under-researched, under-regulated application of GM agriculture.
Third world countries and
the EU want to protect their countries biodiversity and food security from the
dangers of GMOs.
B.
Why are African
countries and the EU interested in protecting their biodiversity from GMO
hazards via the protocol but
New Zealand
is not?
It is ironic and dismaying that
New Zealand
is not energetically
supporting this initiative for environmental protection of our own and the
world’s declining biodiversity.
A major architect of the protocol is Dr
Tewolde Berhan Gebre Egziabher, plant biologist and Director-General of the
Environmental Protection Authority,
Ethiopia
. On Sept 4 Dr Egzhiabher said in response to US opposition
to the Protocol: ”Developing
world agriculture systems are adapted to their geography, economy and culture.
GM farming systems that require capital and chemicals threaten our agriculture
and food security.
Ethiopia
is strongly against
the hasty introduction of GM crops. As a centre of origin and diversity of
crops, we recognise the assets that come from biologically diverse, locally
adapted, small-scale agriculture. This is why African nations
have fought so hard for the Biosafety Protocol, which can provide a legal basis
on which to protect our own food sovereignty. We resent the way the stereotyped
image of the hungry in developing countries, has been used to force a style of
agriculture that will only exacerbate problems of hunger and poverty.”
US/NZ
oppose
Cartagena
Protocol
Threaten
biodiversity & food security of all countries
Currently the
USA
, the main creator and promoter of GE crops has bitterly
opposed any proper regulation of its revolutionary GE food and crops, against
true scientific and precautionary and processes. Before countries had approved
GE food or seeds their food supply was polluted with GE food & seed -
through US policies of non-segregation - causing biosecurity alerts in NZ and
worldwide. Carrying on in this
reckless way the
US
is challenging the EU in the WTO over its regulatory system
for GMOs - allowed under the protocol.
C.
Unfortunately,
New Zealand
is supporting the
USA
in its challenge, thus undermining the biosafety protocol,
our own biodiversity protection and the world’s.
Here is what Dr Egziabher, said about the
US
challenge on Sept 4:
“The
United States
' challenge to the
European Union in the WTO courts over Genetically Modified Organisms primarily
presents a threat to African and developing countries' food sovereignty and the
Biosafety Protocol. We in African countries, who have fought long and hard for
the agreement and ratification of the Biosafety Protocol, feel US actions are
intended to send a strong, aggressive message to us: that should we choose to
implement the Protocol and reject the import of GM foods, we may also face the
possibility of a WTO challenge. We cannot help but perceive that US actions are
a pre-emptive strike on the Biosafety Protocol and developing country interests.
“The Protocol, [now in force]…
coincides with the WTO's 5th Ministerial Meeting in
Cancun
,
Mexico
. At
Cancun
, the
US
/ EU GM debate is
expected to be high on the agenda. Part of the
US
argument for forcing
the EU to accept GM without any kind of labelling restrictions, is that the EU
rejection creates hunger in the developing world. Supposedly, we would willingly
grow GM crops if we weren't afraid of losing our lucrative European markets.
“But this premise is untrue. The only
African country to support the WTO challenge was
Egypt
, who soon retracted
support on the grounds of consumer and environmental concerns. Developing
countries, and African countries in particular, do not want to grow GM crops
uncritically, without the due process of their regulatory systems approving
them.
D.
They
will not have their crops contaminated by GM crops, for many reasons other than
market access to
Europe
. The one important
consideration is safety to human health, domestic animals and the environment.
This can only be assured, as provided by the Cartagena Protocol on Biosafety,
only through informed risk assessments and decisions based on the Precautionary
Principle.
Pollution
via cross pollination
“Secondly,
we reject the patenting of living things, as has been made clear by our
negotiations in the WTO.
E.
Otherwise, Article 34 of TRIPs would, in combination with the natural
processes of cross-pollination, not only contaminate our crops, but also turn
our farmers into patent infringers. This would remove control of food production
into the hands of multinational corporations, thereby wresting away food
sovereignty into the hands of these companies. Besides paying royalties, we
would lose food sovereignty.”
NZ flouts international
biodiversity & human rights conventions
F.
So, in supporting the US in its challenge in the WTO against GMO
regulations in the EU, New Zealand is not only acting against the protection of
our own and the world’s biodiversity and biosecurity - it is also acting
against human rights protocols on protection of people’s and countries food
security. Worse still, NZ is acting against the food security interests of the
poorest countries and the poorest people in the world. This is insupportable.
Non-ratification
exposes NZ - allows no protection
G.
We are also concerned that through not
ratifying the Cartagena Protocol,
New Zealand
will be exposed and unable to protect itself from continued
infringements of its biosecurity through illegal import of GMOs, in seed
consignments, while other countries will be able to protect themselves, and
reject GMOs. It could be that
New Zealand
through not ratifying the Protocol, will become a dumping
ground for the GE crops and food from the
USA
, when so many other countries refuse them.
More and more countries are rejecting GE crops e.g. the EU, has stringent
regulations; a recent UK study,
shows serious problems for biodiversity with GM corps;
and India this year has rejected two crops for commercialisation, after
the big failure of GE crops in previous months;
- please see article pages 50-55 of enclosed issue of Pacific
Ecologist; Japan is rejecting GE wheat and other GE crops.
Australian
states have powers to reject GMOs But NZ regions exposed
H.
WE note that though the Australian government has recently granted a
license for unconditional release of GE canola, the eight state and territory
governments have powers and are interested in establishing local and state-wide
GE-Free zones - please see pages 21-23 of Pacific
Ecologist issue 6 enclosed.
New Zealand
regions do not have this potential line of defence for the
NZ environment, which makes it all the more important for NZ to ratify the
Cartagena Protocol.
One
year’s GM research the beginning only
I.
Why is the government now allowing releases of GMOs into the environment,
when only 1 year’s research has been done on the impact of GMOs in NZ?
Please see, pages 29-31 of the enclosed issue of Pacific
Ecologist for an article by Drs Stephanie Watson and Philip Carter on this
matter. One year’s research is just the beginning of estimating potential GMO
problems. It provides no assurance on the safety of allowing releases of GMOs in
the open environment. We should have
learnt the lesson on unintended problems associated with releases of exotic
plants and animals into NZ (which have caused havoc)
- and be very cautions with GMOs, since their impacts are likely to be
even more far reaching, given the potentials of horizontal gene transfer to a
wide variety of soil organisms and also to such essential creatures as bees,
butterflies, earthworms, ladybirds, birds etc. There is also the fact that GMOs
have been shown to be detrimental to
monarch and blacktail caterpillars in the wild - so
there are also concrete reasons NOT to allow GMO releases. - see below.
India
rejects GM crops
J.
Also,
India
has this year rejected two GE crops for commercial release
because of the large-scale failure of GE crops in
India
the previous months - see
pages 50-55 of Pacific Ecologist, enclosed.
Some GE agriculture biodiversity
dangers
Dr
Egzhiabher has pointed out in a fully referenced article in the enclosed issue
of Pacific Ecologist the following
risks:
Risks to human health posed by
GE maize
“A gene taken from the bacterium, Bacillus
thuringensis, made into a construct with a promoter, a terminator and a vector,
has been introduced into Bt maize. A gene that gives the maize plant resistance
to a particular herbicide, glyphosate, named Roundup Ready by Monsanto, has been
introduced into HT maize, again together with a promoter, a terminator and a
vector.
“The GE maize that may come to
Africa
is likely to be Bt or HT. But we cannot be certain. Given
the uncertainly of which transgenic maize variety or varieties may be given to
Ethiopia as aid food; and uncertainty about the herbicide to which the GE maize
has resistance, if any; and what are the promoters, terminators and vectors; it
is not possible to guess with any accuracy what the health hazards would be.
Even if and when these unknown variables are identified, there would still be
much uncertainty because of the impossibility of predicting how all these
introduced genes and the parental genes interact.
“We can however, be sure that we need
not fear toxicity since the maize varieties are presumably those being used as
human food in the USA, and any such toxicity would already have been detected. However,
there are also genetically engineered maize varieties in the
United States
meant only for animal feed, e.g. the Starlink maize. In
September 2000, food made from maize in the
United States
was found contaminated with Starlink. It was destroyed.
But, can we be certain that the maize that may be sent to us, is free from
contamination by Starlink or any other variety not cleared for human food?
“Because of the use of Substantial
Equivalence in certifying GE crops safe for human consumption, such possibly
long-term effects as build-up of allergenicity, carcinogeny, terratogeny etc.
have been ignored. However small, therefore, there are risks in giving GE food
to starving people which could be serious. A study showing the prevalence of
unexplained alimentary canal complications between Sweden and the United States
has shown that in Sweden, where GE food is not allowed, there has been no
increase but that in the United States, where GE food is eaten, there has been a
several fold increase.
“In the
United States
, GE maize constitutes
only a small portion of the diet. If GE maize were given to starving people, it
would constitute the whole of their diet. It is likely, therefore, that such
complications would be more devastating among victims of famine. When eaten in
large quantities, it is possible that human reproduction will be reduced as has
been reproduction among pigs. 1
Risks to Ethiopian agriculture [and all agriculture, we add ]
K. “Maize
is wind pollinated. Therefore, GE maize will easily have its pollen reaching
non-GE maize. Reports of such contamination are many. If, in the future, it is
found that any of the genes in the GE maize cause problems, it would be
impossible to bring back the original non-contaminated maize.2 Maize
is the most important food crop in most of Sub-saharan Africa. Such
contamination would, therefore, be a major set-back to
Africa
.
Africa
would then be barred from exporting maize to
Europe
and to developing countries in other continents. The current
size of Zambian maize export to
Europe
is worth US $ 400,000,000.
Risks
to animals -
L. “Domestic
animals refuse to eat the stems and leaves of Bt maize,3
and pigs, if made to eat Bt
M.
maize,
have their reproductive capacity greatly reduced.1
Therefore, even if hunger forces domestic animals to eat Bt maize residues, they
will not be able to reproduce effectively. Domestic animals would thus either
have their feed reduced, or their reproduction reduced. African agriculture, and
particularly Ethiopian and Eritrean agriculture, is based on mixed animal
rearing and crop production. The introduction of Bt maize would seriously
disrupt it.
“The introduction of GE maize will not increase yields. Various studies have
shown that GE crops usually have yield lower than their respective non-GE
equivalents.
Risks to the African
environment? - [and all environments - we add ]
“Maize has no closely related species in
Africa Therefore, the risk of the transgenes going into wild species through
cross- pollination is insignificant. Neither is it likely that maize in
Africa
will become a weed in the natural vegetation.
N.
However,
Bt maize is known to kill butterflies and thus presumably also moths.4Butterflies
and moths are important pollinators of crops (e.g. pulses) and wild plants. The
spread of Bt maize would thus be not only disruptive of the environment, it
would also be economically damaging.
Possible problems related to
patenting
“The genes or parts of genes (promoters,
terminators, whole genes) and vectors introduced during genetic engineering as
constructs are all patented. When they contaminate the non-genetically
engineered varieties, therefore, they turn them into patented varieties. Article
34 of the Agreement on Trade-related Aspects of Intellectual Property Rights of
the World Trade Organisation considers anybody found with a patented object in
his possession to be an infringer of the patent, a criminal. Therefore, our
peasant farmers would not only lose their own non-genetically modified varieties
of maize, they would also become patent infringers and thus also criminals.
“A farmer from Canada, who maintains that his field of rapeseed was
contaminated by cross-pollination from another field of GE rapeseed, was found
guilty and ordered to pay damages.
“
Ethiopia
is not a member of the World Trade Organization and its
peasant farmers could not be turned criminal just because they have their own
varieties contaminated. But they would become criminal when
Ethiopia
joins the World Trade Organisation. They would be forced to
pay fines and, in the future, be forced to pay royalties, every maize-planting
season. Most countries in
Africa
are members of the World Trade Organisation; and their
farmers would be criminals immediately.”
Conclusion
O.
Again, why is the New Zealand government,
not protecting its own biodiversity and the world’s, as the EU and third world
countries are, by ratifying the Cartagena protocol? NZ is currently exposed
through not ratifying. We request the
Ministry urgently to counsel the government to ratify the Cartagena Protocol to
the Convention on Biodiversity, for the protection of
New Zealand
and the world’s biodiversity and to protect our trade
interests. To risk all for an uncontained experiment with the whole of life -
especially at a time of mass extinctions - is unsupportable and inexplicable.
P.
It is also repugnant that
New Zealand
is acting against the Cartagena Protocol and interests of
other countries efforts to protect their own biodiversity from GMO contamination
by supporting the
US
challenge in the WTO against EU regulations on GM.
Many of the countries ratifying
the Cartagena Protocol, are third world countries that are world centres of
biodiversity and origin of crops.
Q.
Thus NZ, in opposing the Protocol, is
threatening the world’s biodiversity in support of GMOs. What is the
explanation for this ? We must at
least allow other countries to protect their food security and vital
biodiversity interests, otherwise NZ is also infringing basic human rights to
food security. For biosecurity and biodiversity now and in the future clearly NZ
must ratify.
R.
Economic studies by Professor Caroline
Saunders of
Lincoln
University
in
New Zealand
show release of
GM crops in
New Zealand
will harm NZ’s interests in key markets. Even the US Dept
of Agriculture study of 2002 found it could find no advantage to US farmers in
growing GE crops -see page 24/25 of enclosed Pacific Ecologist. Clearly
the
US
has sown for itself a bitter harvest with GM agriculture.
New Zealand
would do well not to get drawn in and to make this clear by
ratifying the Cartagena Protocol.
Yours
sincerely
Kay Weir
Editor
Pacific Ecologist
Executive
member,
Pacific
Institute of Resource Management
PO Box
12125
Wellington
Phone
9394553 - pirmeditor@paradise.net.nz
1.
Soil Association, 2002, p 36, Seeds
of doubt: North American farmers’ experiences of GM crops, Soil Association:
Bristol
,
UK
.
2.
Ibid pp. 25-34.
3.
Ibid p.12, More detailed information is found in Benbrook, CM 2001.
When does it Pay to plant Bt Corn? Farm-level Economic Impacts of Bt corn, 1996-2001. Benbrook Consulting serivces,
Idaho
. This document can be found at www.iatp.org
4.
National Research Council, Op cit p. 71-76 gives details on effects of Bt maize
on monarch butterflies. The original report was made by Losey, JE, LS Raynor and
ME Carter 1999, Transgenic pollen harms
monarch butterflies, Nature, no 399, p. 214.
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