GE free animals
- - Round Two: Let's stop this craziness again!
- - Submissions close 5pm Friday 18 December, 2009
As you will know, Soil & Health has long been active in opposition to genetic engineering (GE) in our food and the environment. Along with you, we as an organisation continue to oppose applications to the Environmental Risk Management Authority (ERMA) for new GE experiments that we believe are risky and/or ethically flawed.
We are asking you to join with us in making a submission to stop the latest GE application, and to keep New Zealand animals GE free.
Many of you will have put in submissions opposing a previous application by AgResearch to release a large range of GE animals at unknown locations throughout New Zealand. These GE animals would potentially have infinite combinations of plant, animal and microbial material that included human and monkey DNA.
You will also be aware that GE Free NZ was successful in the High Court in having the applications thrown out – a tremendous achievement. GE Free NZs argument was that the applications were too wide-ranging, which meant the public would not be able to understand the risks to the environment and economy.
Although AgResearch, a Crown Research Institute owned by the NZ taxpayers, is still in the process of appealing the High Court decision, with the hearing scheduled for January 25, AgResearch is yet again applying for permission to engineer GE animals. This time it plans to genetically engineer goats, sheep and cattle at its Ruakura base and has an enormous list of foreign GE DNA it might want to insert into animals, including antigens, biopharmaceuticals, enzymes, hormones and other proteins.
Although now listed, the application’s 700 pages of genetic descriptors once again make AgResearch’s toy box effectively infinite. The genetic material being applied for again makes it impossible to assess environmental and economic risks and costs.
Like the previous one, this application is based on the unethical treatment of animals and other life and includes human DNA.
AgResearch has presumptuously made contractual arrangements with overseas bio-pharmaceutical companies, assuming ERMA consent, and now both government agencies appear hell-bent on ensuring that commercial outcome regardless of risk, justice or ethics.
New Zealand has a distinct advantage being GE free and with your input we can help keep the unethical and risky GE activity from being further developed.
Please make a submission today. The deadline is 5pm this Friday 18 December 2009.
You may use your own wording or the points below, and email or post as below. You can speak further to your submission at the later hearing if you choose and ERMA has the facility for you to do that by telephone or by personal appearance.
Thankyou for your support,
Steffan Browning
Spokesperson, Soil & Health Association of New Zealand
021 725 655
greeny25@xtra.co.nz
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Make a submission using the points below, and your comments.
Deadline 5pm 18 December 2009
Submission to ERMA on a notified application ERMA200223
Email to: submissions@ermanz.govt.nz
Or post to: ERMA New Zealand, PO Box 131, Wellington 6140
Name of submitter: (or contact for organisation)
Your address:
Email:
Phone:
This application should never have been accepted by ERMA and should be declined for the following reasons:
1) The application is in direct contradiction of the findings of the Royal Commission on Genetic Modification (RCGM) that recommended food-animals not be used as ‘bioreactors’.
2) It is a breach of natural justice for ERMA to have accepted this application while the High Court decision finding flaws in the development application is still under appeal.
3) It is not reasonable for ERMA to expect one to make an assessment of the all-encompassing list of genetic elements requested by the applicant. Appendix II is an enormous library download of genetic stock strains, many of which are not described and are unknown. None of the proteins that will be created is fully identified. Without such identification, it is not possible to make a reasoned scientific assessment of the application.
4) This application does not allow one to understand just what is being created with respect to the identity, modification or expression of foreign DNA in the GM animal, how many proteins are going to be inserted/made or what those proteins are. Furthermore, we are dealing with a situation where the DNA being inserted is not just crossing species barriers, but crossing kingdom barriers, eg. from prokaryotes to eukaryotes or from plants to animals. AgResearch understands full well that proteins from another source will very likely not behave in the same way when inserted into animal cells. They may also not be expressed in the correct target cells. An example of this is a foreign protein being produced in the blood of a GE cow instead of the milk of this cow. There is no cast iron guarantee that this will not happen.
5) It is not possible for one or even for scientists and experts in ethics to make informed submissions, as ERMA has not required the applicant to specify what they are actually doing that is different from already existing proteins and patented products.
6) It is wrong to put New Zealand’s bio-security or the economic value and public-benefit of the New Zealand Brand at risk. Any risk of creating new diseases by experimenting on NZ animals outdoors threatens markets overseas, especially if animal waste, effluent and blood products contaminate land, water or air.
7) I do not agree to the creation of deformities and suffering in animals in order to make ‘cheaper’ pharmaceuticals, when other highly effective and much safer production methods are available. Treating animals in this way is against my moral, ethical, spiritual, and religious values. To go further, cruelty to animals is against the law. The Bioethics Council has also called for an ethical review of such practices.
8) This application is so undefined and generic that I do not know how it will affect me or my family, lifestyle or my grandchildren.
I wish ERMA New Zealand to decline the application and restore public confidence.
- - I do / do not wish to be heard in support of my submission.
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Soil & Health Association of New Zealand Inc (est 1941)
PO Box 36170, Northcote, Auckland
