GM Crops Free Areas Exemption Order 2010

GENETICALLY MODIFIED CROPS FREE AREAS EXEMPTION ORDER 2010

Summary:
Section 4 of the Genetically Modified Crops Free Areas Act 2003 (WA) permits the Minister to make an order that designates part or all of the State as a place where GM crops (or a specified GM crop) must not be cultivated. Under Section 4 a statewide moratorium was imposed by the previous government.

Section 5(1) makes a breach of that order an offence, with a penalty of $200,000.

However, section 6 permits the Minister to make a further order exempting a person or class of persons from section 5(1). Exemption can be subject to conditions. The effect of exemption orders is that technically cultivation is still not allowed, but there is no way to enforce it as there is no penalty for breach.

In 2009, pursuant to a section 6 exemption, GM canola was cultivated on a trial basis to find out:

  • If it is possible to segregate GM from non GM canola, and
  • The agronomic viability of GM canola under WA conditions.

In January 2010 the trial was declared a success in a report by the Department of Agriculture and Food.

Subsequently the Minister made a further section 6 exemption order, published in the Government Gazette on 29 January 2010 which says: A person who cultivates genetically modified canola in Western Australia is exempt from the application of section 5(1) of the Act if the genetically modified canola is licensed for intentional release into the environment under the Gene Technology Act 2000 (Cth).

The exemption order was strongly opposed by the Network of Concerned Farmers, Organic Growers WA, GM Free Consumers Network, The Wilderness Society, Conservation Council of WA, Greenpeace and various members of the public, as well as by both the Greens and the Labor party.  Disallowance motions were brought by Labor in the Legislative Assembly and by the Greens in the Legislative Council; however both were defeated.  Hence the exemption order remains in place.

Concerns about GM

There are many different concerns about GM, and the Greens have repeatedly drawn Parliament's attention to this.  For this particular disallowance motion the Greens focussed on the alleged success of the trial and the impact of the exemption order on freedom of choice and freedom from interference to one’s livelihood.  A summary of those concerns is below.  Giz's full speech on 18 May 2010 is accessible via Hansard: www.parliament.wa.gov.au

Segregation is impossible

GM canola cannot be effectively segregated from non GM canola or other grains.   

Canola seeds are light, small and mobile. They get into crevices of farming machinery, can escape through tiny holes and cracks and can be carried on the wind.

The 2009 trial of GM canola included many precautions to try to prevent GM seed from escaping.  Yet despite this, segregation was not achieved.  Out of the trial's 52 plantings, 11 “incidents” occurred:

  • One incident of delivering the seed direct to site rather than to quarantine authorities as required
  • Two seed spills
  • One incident of planting too near a non GM canola crop
  • One incident of wind blowing seed into an adjacent cereal crop
  • One incident of the wrong amount of seed being sown; the site was abandoned but some of the seeds germinated on the site in a wheat crop
  • One incident of delay in delivery of grain while it was ensured it was within the limit for weed seed levels
  • One incident of grain left in the wrong place
  • One incident of wind blowing seed over a fence onto a neighbour’s land
  • One incident where machinery broke down so a second machine had to be cleaned down as well
  • One incident of grain being delivered without prior notification.
  • In addition, one site was planted with an extra 6 hectares of GM seed than was permitted by the exemption order that allowed the trial. Under section 7 of the Act, it is an offence to breach the conditions of an exemption and the penalty is $200,000. Yet this episode was not even registered as an “incident”, let alone prosecuted as an offence under the Act.

This inability to segregate is consistent with what has happened with GM canola elsewhere. For example, in answer on 2 March 2010 to Giz's Question on Notice 1392 the government conceded:

  • Spillage does occur from road transport
  • Roadside volunteers of crops following harvest and transportation are a normal occurrence
  • GM traces may be found in pollen in bee hives
  • GM traces have been found in Canadian mustard
  • GM canola volunteers are still being found in Tasmania at 12 of 57 trial sites from last decade
  • In answer to question 40 “Is it possible to completely avoid GM contamination in an environment where GM crops are grown?” the government said “If the agreed protocols for the segregation of GM and non GM canola are complied with any adventitious presence will be kept below the Australian Grains Industry threshold of 0.9 per cent presence”. That is, the answer was no.

Thus, the government has conceded that segregation is impossible. The choice that is really being offered to growers and consumers is between canola with lots of GM content, and canola with less GM content.

Achieving an adventitious presence of no more than 0.9% is also impossible
The government's claim that contamination by GM canola can be held down to no more than 0.9% (reference: answer to question 40, Giz's question on notice no. 1392  answered 2 March 2010) is incorrect.

The May 2009 Information Paper on GM canola published by the Ministerial GMO Industry Reference Group chaired by Hon Kim Chance MLC includes at page 33 a table of estimated average escape rates at each of 9 different stages in GM canola production. Three separate estimates are provided. All three estimates show potential for contamination at at least 6 of the 9 stages of the production process. The total potential for contamination was estimated at 0.81%, 0.83% and 0.96% respectively. These figures are small, but remember that they are for a single year only. The report states at page 33 that these levels will increase exponentially (ie in multiples, not just by addition) every growing season if GM escapee plants are not controlled. This potential for exponential increase is the reason that adventitious presence of GM in non GM canola cannot be kept down to 0.9%.

The way the government proposes to keep adventitious presence down to 0.9% depends on people following procedures. The Department of Agriculture and Food suggests a number of procedures in Farmnote 409: “On-farm segregation of GM and non GM canola"   .  But people, even those with the best intentions, are fallible.  And even if GM canola growers follow all of the procedures, the Farmnote acknowledges that contamination can happen anyway. For example: a. officials from Western Power, telephone companies and others can access GM growing areas without notification and potentially transfer GM seeds, and b. livestock grazing on canola stubble can excrete viable GM seeds for up to seven days after the last feed from the paddock.

The risk might be small with each incident, but: a. the effects are exponential each growing season if escapee plants are not destroyed, b. GM canola seeds are tiny, and c. GM canola plants look like non GM canola plants.

During the 2009 trial, the Department took a very active role in inspecting, monitoring and ensuring destruction of the inevitable GM plants that grew in places they weren’t meant to be. But there is apparently no intention for the Department to continue that role. So the management mechanisms that now apply under the exemption order have not been trialled in Western Australia at all.

Consequences of escape of GM canola
Possible consequences of escape of GM canola for neighbours who are non GM canola growers include economic disadvantages to the individual farmer, unclear legal liabilities and risk regarding the nature of the grain produced, and social disadvantages to communities where non GM and GM canola growers are living as neighbours.

These include:

  • cost of strip tests
  • labour and cost inspecting, monitoring for and destroying escapee plants (destruction may need to be by hand because GM canola is resistant to particular herbicides);
  • possible legal proceedings as a result of providing canola contaminated by GMOs
  • possible loss of markets
  • possible loss of opportunity to get price premiums for non GM canola
  • for organic growers of non GM canola, who occupy a niche, highly valued market, the threat to livelihood is even greater
  • possible legal proceedings for infringing intellectual property of the GM seed manufacturer through “cultivating” GM grain without having paid for it. If legal proceedings are brought against a grower, s/he will still be put to the trouble and expense of defending the case even if s/he is ultimately successful.

Despite the potential economic losses for non GM growers through no fault of their own, no special laws (eg strict liability laws) have been introduced in respect of compensation. Instead growers will have to rely on ordinary common law mechanisms, for example suing for nuisance, or trespass, or negligence. But this is not a realistic mechanism for protection of a non GM grower against economic loss:

  • It may be impossible to prove where the GM canola seed came from.  There may be more than one nearby GM canola grower.  There also seems to be no enforceable legal duty to inform the neighbours if growing GM canola 
  • Even if a GM canola grower does all they reasonably can, the tiny GM canola seeds can still be spread by wind.  This happened twice in the 2009 trial
  • Litigation may not be limited to non GM grower against GM grower. A shire may be made a party to proceedings, since shires are responsible for any roadside spills . Transporters and contract harvesters may be liable if they cause spills, or if they have not cleaned their equipment thoroughly enough
  • The financial cost of litigation is an additional burden
  • There is no fast track process for any litigation
  • In December 2009 the Senate Standing Committee on Legal and Constitutional Affairs found that the legal system is not sufficiently providing members of the Australian community with access to justice
  • Litigation between neighbours is capable of splitting small communities. There may be impacts on the mental health of farming families. Rural men’s health has recently been the focus of a suicide prevention program run by Suicide Prevention Australia. Wheatbelt Men’s Health Inc (WMH) and the Kondinin Group, a farmer-based support organisation, joined forces to produce a DVD to assist farmers and their families to understand rural men’s mental health, including stress and depression. Fear of inability to cope with changed circumstances is a recognised major stress factor.

GM canola has not been shown to be agronomically viable in WA
Agrifood, Fibre and Fisheries Bulletin 4757 states at page 16 that WA’s non GM canola is recognized as the highest quality canola in Australia, with an average 2-4% higher oil content than other Australian canola.

GM canola does not contain a gene that makes it better quality than this, or yield more. The difference between GM canola and non GM canola is that GM canola contains a gene that makes it resistant to the weed killer used on it.  GM canola is a weed control tool.

Weeds grow in competition with canola crops and unless controlled, can reduce canola yield and contaminate the harvest. Other strategies for increasing yield of crops in general include crop rotation, crop diversification and development of improved varieties.

In Western Australia the main weeds that compete with canola and can reduce its yield are ryegrass and wild radish. Weeds are controlled mechanically (tilling) or more often by herbicides – provided the weeds have not developed resistance to the herbicide being used. Page 17 of the Information Paper lists the herbicides that can be used on canola, which weeds they control, and what level of weed resistance has developed.

GM canola is promoted as requiring fewer chemicals than non GM canola. However the 5 cases described in the report of the trial do not support this claim. In one case the paddock had a low weed burden, so the value of that trial was limited in this respect. In two cases the grower used additional herbicides to control weeds. In the remaining two cases the grower said s/he would like to spray after the 6 leaf stage to control weeds. 

In any event, limited details of 5 cases plus a statement in the report that a further 12 commercial growers think GM canola would be viable for their farms is inadequate evidence upon which to base an exemption order with such potentially negative impacts.

Further, the evidence regarding the 5 cases described in the report of the trial is entirely subjective. There is no reference in the report to any independent checking of the assertions made by growers regarding agronomic viability. This is notwithstanding that clearly some of the growers were not neutral, and held strong pro GM views before the trials were held. For example the grower in Case #3 is reported as saying “Frustrated for the last 10 years that we were denied similar opportunities [to Canada]” and the grower in Case #5 is reported as saying “Long interest in technology which could have been here 10 years ago…invited to visit Victoria in September 2008 by Monsanto to view crops and attend field days there, which reinforced positive view. Approached by Pacific Seeds to participate in 2009 trial”.

Last, the limited information in the report regarding agronomic viability does not include an adequate comparison between the GM canola used in the trial and other canola varieties, particularly the non GM triazine tolerant  variety which is the main alternative variety used in WA. At page 14 the Information Paper states that the triazine tolerant variety requires a longer growing period in order to avoid reduced yield, achievable by early sowing. However of the case studies provided in the report of the trial, only Case #3 gives the date of sowing of the triazine tolerant variety so as to enable comparison. That case indicates a late sowing, in late May, which probably explains the comparatively low yield reported; the Information Paper states at page 14 that in national trials, early season triazine tolerant varieties outyielded other varieties by an average of 39.7%.

Conclusion

The exemption order is based on trials that neither established ability to segregate GM canola from non GM canola in WA, nor agronomic viability of GM canola in WA. Inability to prevent contamination of non GM canola crops compromises our freedom of choice to grow and eat non GM canola.  It also exposes non GM canola growing families to risk of losing their livelihood and their way of life, through no fault of their own.

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