Environment and Conservation Organisations of Nz Inc

ENVIRONMENT AND CONSERVATION ORGANISATIONS OF NZ INC.

Level 2, 126 Vivian St, Wellington, New Zealand; PO Box 11-057, WellingtonEmail: Website:
Phone/Fax 64-4-385-7545

The Decision making Committee,

Environmental Protection Authority

Private Bag 63 002
Wellington 6140

Email

Submission re AgResearch Limited application to the Environmental Protection Authority (EPA) seeking approval under the Hazardous Substances and New Organisms Act (HSNO Act) to release 18 new grass species. APP201894

This submission is from the Environment and Conservation Organisations of NZ Inc, ECO for short, and is submitted by Catherine Wallace, on behalf of the ECO Executive Committee of ECO.

This submission raises concerns about the environmental and human health effects of the release of the 18 new grass species, the lack of information about these aspects, and the plan for unrestricted release of these species. In ECO’s view, the application information is inadequate and the application should be withdrawn and not resubmitted until the information deficiencies are are remedied. Until that is done, we oppose the application but will remain open to new evidence and conditions.

The Decision sought is thus that the application be rejected – at least until more is known, and that any approval if it were to be given, should require secure containment not free release while weediness and health effects are studied.

ECO requests to be heard in support of this submission. Contact us on and 04-385-7545.

Introduction to ECO

Who we are

The Environment and Conservation Organisations of NZ Inc (ECO) is the national alliance of about 45 groups with a concern for the environment and conservation. Some of these member bodies are themselves federations or multiple groups. Not all are conservation or environmental groups.

ECO has followed issues of conservation and environmental management and practice, law and policy since its formation in 1971-2 and we have member groups from all around New Zealand. We have an Improved Environmental management and Law Working Group and another on Conservation, Biodiversity and Biosecurity. This submission was prepared by members of these working groups.

The Applicant:

Company Name: (if applicable) Margot Forde Germplasm Centre

Contact Name: KioumarsGhamkhar

Job Title: Director

Physical Address: AgResearch Limited, Tennent Drive, Palmerston North

Postal Address (provide only if not the same as the physical): AgResearch Limited, Private Bag 11008, Palmerston North

Phone (office and/or mobile): 06 3518182 Fax: Email:

The Application

The EPA’s summary shows this information:

Application code: / APP201894
Application Type: / Non-GM import or for release
Applicant: / AgResearch Limited - Grasslands (Palmerston North)
Applicant Postal Address: / Private Bag 11008, Manawatu Mail Centre, Palmerston North, 4442, New Zealand
Application State: / Open for Submissions
Decision:
Application Purpose: / To apply for the full release of 18 species of broadleaf grasses closely related to perennial ryegrass

As noted in the notes for submitters, “The release of 18 grass species closely related to perennial ryegrass is requested to provide New Zealand researchers and forage grass breeders with important and essential new genetic resources to improve pastoral production and reduce the impact of pests, diseases and climate change.”

“AgResearch scientists propose to use the 18 grass species, belonging to Lolium, Festucaand Micropyropsisgenera, to make inter-specific hybrids or crosses between different species within the same genus. New better performing hybrids could be created by integrating useful traits, such as drought tolerance, improved nutrient uptake and persistence, from the species in the application into existing ryegrass cultivars that are in large-scale use in pastures in New Zealand.’

ECO’s submissions:

Submission 1

It is not clear to us whether the application is for genetically modified or for the import of grass species to be genetically modified, or for the import and release of the 18 species with no genetic modifications. The summary uses the term “or” and we do not know how to interpret this. This needs to be clarified.

Submission 2

We submit that the proposed imports and release of the plants is fraught with uncertainty of effects on the environment and on human health and that crucial information is missing (especially in relation to human health) and inadequate (e.g. about weediness)

The notes for submitters lays down thesestatutory criteria and considerations that the Decision Making Committee has to use for its decision (pp2-3). We give our reasons in relation to these criteria, standards and considerations.

The statutory criteria and minimum standards for considering this application

In considering the application, the Decision-making Committee must take into account a range of matters set out in the HSNO Act.

As noted by the EPA, “the HSNO Act sets out minimum standards that must be met in order for a new organism to be released. This means that the 18 grass species cannot be approved for release if they are likely to:

 cause any significant displacement of any native species within its natural habitat

 cause any significant deterioration of natural habitats

 cause any significant adverse effects on human health and safety

 cause any significant adverse effect to New Zealand’s inherent genetic diversity

 cause disease, be parasitic, or become a vector for human, animal, or plant disease, unless the purpose of that importation or release is to import or release an organism to cause disease, be parasitic, or a vector for disease.

The Decision-making Committee is interested in any information about whether the 18 grass species meet the minimum standards.”

ECO considers each of these minimum standards below and then draws the conclusion that the application does not comply with these standards.

Submission set 3
Criterion, standard or consideration / ECOs concerns and submissions
Undesirable self-sustaining populations
The Decision-making Committee is required to consider the potential for the 18 grass species and their hybrids to establish undesirable self-sustaining populations, and the potential for eradication of undesirable populations.
The Decision-making Committee is interested in any information about a situation where a population of any of the 18 grass species or their hybrids might be considered undesirable. / 3.1 / 3.1
Undesirable self-sustaining populations
There is little substance to the applicant’s response on this issue. There is no indication as to how close to the native habitat of the plants proposed for import are the potential New Zealand conditions.
New Zealand is littered with pest plants and animals that were not weedy in their original context but became so here in New Zealand.
It is unclear why one would expect that species to be imported specifically for their genetic differences from related plants already in NZ, and for their ability to endure drier and other conditions, could be well understood for their weedinessby reference to the existing strains that are already in New Zealand.
The new traits that the imported grasses would have makes the assertion that because the species are not weedy in their original place they will not be in New Zealand inadequate and unsound. Evidence of similarity and differences is needed not a sweeping suggestion that it is unlikely.
The reference to the indigenous related grass species being confined to margins and cliffs probably reflects that these indigenous species are being pushed aside by introduced plants and practices. Many seabirds and other birds manage to “hang on” in refugia on cliffs and places inaccessible to predators but this does not mean that this is where they would be if they were not under pressure from exotic species. In the same way, indigenous grass species being marginalized to such places is not evidence that they would not grow elsewhere given the chance. The cultivated grasses and other weeds will probably be displacing the indigenous ones and the introduction of 18 more species is likely to exacerbate this competition and dominance by imports. The marginalization is not a symptom of lack of potential weediness of imports. It is rather, a symptom of vulnerability of the indigenous species.
We do not agree with a “suck it and see” approach since full release will be in-effect irreversible.
3.1 – Eradication / In ECO’s view the applicant does not provide evidence that the new traits that they want to select for greater resilience of the pastures in the face of climate change and other pressures will not also be traits that make the grasses harder to eradicate where they are not wanted. We are struck by the apparent surprise that DoC lists related grasses as weedy, as though pasture value makes biodiversity concerns invalid. We disagree with the applicant. Our native biodiversity is vital to so much of our life and identity as well as for its own sake. Many New Zealanders spend vast amounts of time combating pasture and other weeds in native ecosystems and we think it all too possible that these proposed imports could be “plant pollution” in our native ecosystems.
Displacement of Native species within their habitat / We do not consider that the applicant has demonstrated that the import will not cause any significant displacement of any native species within its natural habitat. On the contrary, we consider that the argument made by the applicant is unsound and that pasture grasses are already known to invade tussock grasslands, wetlands and other native habitats so the imports would likely do so too.
 Cause any significant deterioration of natural habitats / It is likely that such deterioration of such habitats as wetlands and native grasslands will occur. No uncontrolled release should be permitted. Any import should only be permitted in a full and secure containment and experiments and observations over several years are needed before release should be considered.
Cause any significant adverse effects on human health and safety / We consider the applicant has provided no information on this matter. Ryegrass is one of the most seasonally significant allergens and many of us suffer badly from rhinitis and other hayfever effects from ryegrass. The medical effects can be found easily by simply Googling for those who do not experience these symptoms themselves. See for instance:
“In New Zealand the introduced plants are the most troublesome source of allergenic pollen. The plant causing the biggest problem here is the perennial ryegrass. It is the biggest pollen producer of all and the major cause of springtime hay fever. The majority of atopics are sensitive to it. The pollen, being small, will travel in the wind for many miles and the patient’s exposure is dictated by their proximity to grasslands and the prevailing wind. In New Zealand the pollen season varies, starting about one month earlier at the top of the North Island than the bottom of the south Island. In Auckland the main pollen season is between October and February, but because the seasons are so variable the pollen season is not well defined as in Europe and certain parts of the USA.” -
We consider that no new ryegrass related strains should be permitted entry to New Zealand without allergen trials overseas. Of course if they proved to be less allergenic, that would be a big plus, but they may be worse. We are sorry that AgResearch has done so little to acknowledge this issue, let alone to research it. We consider that the application must fail on these grounds.
 Cause any significant adverse effect to New Zealand’s inherent genetic diversity / ECO considers that there has been little attempt by the applicant to consider in the application whether any significant adverse effect to our indigenous genetic biodiversity may result from the proposed import.
Cause any significant displacement of any native species within its natural habitat / Wetlands and tussock grasslands are already at severe risk. The very traits of tenacity and competitiveness that the imported grasses would have would make displacement of native grass and other species with which the imports compete likely to occur. We consider that any import should be confined to secure trials in laboratory and contained plot experiments – and results should be made public and the work closely monitored for compliance with stringent no escape conditions.
Cause disease, be parasitic, or become a vector for human, animal, or plant disease, unless the purpose of that importation or release is to import or release an organism to cause disease, be parasitic, or a vector for disease. / Any import will have the potential to introduce plant diseases and pathogens. We would need to see the very specific controls and conditions on any import of plant material and soils to evaluate whether these are likely to be adequate.

Minimum standards:

ECO considers that the applicant has failed to demonstrate that it meets the statutorily required minimum standards on most criteria and that the application does thus not comply with the requirements of the Act.

Submission set 4: Adverse and beneficial effects

The Decision-making Committee is required to weigh the potential beneficial (positive) effects against the potential adverse effects of releasing the 18 grass species into the New Zealand environment.

If the adverse effects outweigh the beneficial effects, the organisms cannot be released.

The Decision-making Committee is interested in any information about benefits or adverse effects that could result from the release of the 18 grass species, in particular, any effects on the environment, human health and safety, the market economy, Māori culture and traditions, and society and communities.

We have provided a brief summary of the potential risks and benefits of this application based on the information in the application. This can be found in Appendix 1 of this document.

As above in relation to the minimum standards, ECO’s view is that the applicant has not demonstrated that the potential adverse effects are outweighed by the benefits.

The applicant does not explore human health impacts.

We acept that there could be benefits from greater pasture productivity and reslience but we are not convinced at all that these would outweigh the harms caused by:

a)rye-grass related hayfever and the losses of productivity and the suffering of those affected;

b) the irreversibility of biodiversity and biosecurity impacts of the imports;

c)any intensification of ruminant production impacts on the land, on fresh water quality, aquatic ecosystems, and on the climate due to greenhouse gas emissions.

d)One rationale for the importation in the application stresses the Dairy NZ goal of doubling production and the need predicated on this to find more resilient strains and grasses of greater productivity and ability to withstand climate change. The benefits alluded to are the market values of production.

e)We consider it is unlikely that the proposed doubling of production is sensible economically or environmentally. The increase of production would, if it eventuated, come from greater intensity of stocking cattle (or sheep). This would mean more agriculturally productive grasses with more cows/ha and/or greater production per cow (or cattle beast or sheep if we are thinking about meat production).

f)We consider that such increased production is a mis-placed goal which is likely to lead to misplaced investment. The stress on soils and water quality, theaquatic environment and on the atmosphere, and in some places on biodiversity suggest to us that such increased production will be a social disbenefit, albeit leading to private financial gain and short-term increases in GDP. We cannot continue with business as usual or business expansion from dairy production for the sake of our natural environment and climate.

In conclusion, ECO considers that there is no demonstrable net benefit to New Zealand and that there are significant costs that have not been addressed by the applicant.

As such, we consider that the application must be denied.

As noted above, we wish to be heard in support of this application.

Catherine Wallace,

For ECO NZ

All submissions must be submitted in writing via emailto:,or mail to Private Bag 63002, Wellington 6140, New Zealand.

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