REQUEST; Gene Tech Bill be referred to the Primary Production Committee.

Dear Dr David Wilson,

Re: Committee Referral for the Gene Technology Bill

• I am writing to respectfully request that the Gene Technology Bill be referred to the Primary Production Committee.

• In addition, An extension to the hearing of evidence in regard to the Gene Technology Bill


I am an artist, my partner, Michael Kay is a second generation farmer, that works within a regenerative farming framework. I submitted on the Gene Technology Bill to the health committee, but am concerned that the market demand and farmer/manufacturer liability framework, protections for indigenous biodiversity and animal welfare is not the focus of health committee and these broader implications for farming and nature and export market are best addressed by the primary production committee.

In my submission; I noted that New Zealand farmers are one if not the only farmers in the developed world that do not receive government subsidies, as such they are highly sensitive to market demand. That GMO GE farming in the United States in particular is heavily government subsidised. GMO GE is a lower value product, on average reducing crop value by 15-20% to non-GMO crops and 115%+ less than organic crops.

By the year 2000, almost 50% of US farms received price support. These payments, comprised almost one-half of net farm income, reaching $20 billion that year. Most payments US farmers receive from the government are compensation for the difference between their high costs of production and the low market price. For example, in 2000 it cost farmers an average of $2.72 to grow a bushel of corn, while the market price was only $1.77.

Taxpayer subsidies covered the loss, maintaining farm solvency to skew the market to continue massive overproduction of low value product at rock bottom prices. Resulting in America farmers failing to move to produce higher value products.

Government support for commodity prices ultimately translates into government support for industrial inputs. The GMO industry has the US government to thank for its sales. These interventions have made it possible for agribusiness to sell products to farmers that actually increase their losses.

In January of this year, 2025; Mercardo released an article Why the GM Discount (which is the diplomatic way of saying GMO GE GM crops are worth less at market) : “Last harvest GM Canola sat at just a $25/t discount to conventional canola. This year the GM discount has ranged from $100 to $130/t. ‘

If GMO GE contamination is detected, the value at market will decrease to the GE GMO price regardless of method of production. This will significantly create a burden on non GMO GE and organic producers, particularly seed growers and honey producers with markets with zero tolerance for GMO contamination. Moreover if the government allows the newly developed GMO GE pesticides and herbicides, to be delivered by aerial spray and designed for the vast acres of monocultures crops in the america’s to be used on New Zealand farms, the pose an unknown risk to waterways and biodiversity (including bird and insect life) that environmentally conscious kiwi farmers (most) have retained on farms.

An example of contamination of Export:

Case Study: GE FLAX: linen production : European Flax in Canada.

Background: The genetically engineered flax “Triffd”, developed by Alan McHughen at the University of Saskatchewan’s Crop Development Centre (CDC), was resistant to residues ofsulfonylurea herbicides in soil. Registered for sale in 1998.

GMO Flax Triffid variety was being prepared for commercial release in Canada in 2001 but flax farmers were concerned that the GMO GE flax would contaminate exports bound for theEuropean market where it was not yet approved. Represented by the Flax Council of Canada and the Saskatchewan Flax Development Commission, farmers convinced the university to deregister the GM flax variety in 2001, stopping the seed from being introduced into the market. At the time it was deregistered, GM flax seed was being prepared to sell to farmers –about 40 seed growers had multiplied a total of around 200,000 bushels of the GM flax seed (this was purchased by the flax council and all seed believed to be destroyed)

Almost 10 years later, in September 2009, the GM flax was detected in Canadian flax export shipments and reached at least 35 countries that had not approved it. About 3.5% of farmer and elevator flax samples tested positive for the GM flax at or above 0.01% (one seed in 10,000), as did 10-15% of rail shipments and 7% of vessel holds.

Trade Implications : Canada was a world leader in flax production and export, and the economic consequences of the contamination were profound: Canada is still struggling to regain its most important flax export market, Europe.

• At the time of contamination, 60% of Canada’s flax exports went to Europe but this still reduced to only 12% in 2017

• In 2009, the price of flax fell by 32% in Manitoba based on rumour alone, before contamination was confirmed

• Flax acreage in Canada dropped by 47% after contamination was discovered (from 692,000 planted hectares of flax in 2009, to 370,000 in 2010). Acreage did not recover until 2014

• At the time of report (2018): The total cost of the contamination incident to the Canadian flax industry is estimated at $29.1-million

GM flax was never wanted or needed. We knew it would destroy our European markets and now we fear this has happened
— Terry Boehm, past president of the National Farmers Union.


Further cost to farmers:

Under the auspices of cleaning up the contamination, the Flax Council of Canada policy mandated flax farmers to buy and plant only certified pedigreed seed. However this was reversed after contamination was discovered throughout the pedigreed seed system.

Ultimately, stocks of five varieties of breeder seed from the university’s CDC were found to be contaminated, which means that the contamination occurred in a stringently controlled, small breeding centre. Moreover these varieties could be a primary source of the contamination problem because roughly 80% of Canada’s flax acres were planted to CDC varieties.

In 2010, the federal government gave up to $3-million to the Flax Council of Canada to support testing. This included subsidies to allow approved labs to provide farmers a 50% discount on tests.

For many, this meant losing farm family saved, older varieties of flax that may no longer be easily available and which were adapted to specific local conditions and specific market demands. Before 2009, about 75% of Canada’s flax farmers used farm saved seed.

Ultimately it was farm saved seed that was tested and found free of GMO contamination, that allowed flax production to continue in Canada, albeit to a lower priced and smaller market segment.
— Terry Boehm, past president of the National Farmers Union,

….

New Zealand’s proposed Gene Technology Bill sets out no liability framework, no obligations to protect indigenous biodiversity, productive and speciality seeds, nor animal welfare. The bill appears to carve out liability- free framework for gene technologies. There appears no requirement to evaluate long tail risk, no obligations for disclosure and law appears to have been developed with only laboratory processes in mind.

….

Market demand;

GMOs have been greeted with a great deal of hostility by consumers around the world and this antagonism remains unabated (GfK, 2017). The global adoption of genetically modified organisms has been limited despite three decades of robust marketing.

  • As of 2018, Four countries of North and South America account for 85% of global GMO hectares:

    USA (40%),
    Brazil, (26%)
    Argentina (12%), and
    Canada (7%).

  • Another 20 countries have some GMO crops. Most countries (88%) have no GMO hectares.

GMO GE technology in food production has never been driven by consumer demand, it has, instead, been foisted on the public against their will or without their knowledge, by large chemical and pesticide companies who have a vested commercial interest in the uptake of GM crops over which they hold patents and for which they sell proprietary herbicides

Consumers of the world actively avoid GMO foods: A multi-national study of consumers across 17 countries, reported that

• 60% of Chinese consumers reject GMO food, for Mexico and Italy the figure is 49%, and for Spain, Russia, France, and Brazil the figure is 45%.

• As elsewhere, community surveys conducted in Australia over more than a decade reveal that GMO food and crops have failed to achieve a social licence. There is no majority support for GMO food in Australia. In one survey, 66% of respondents were either “concerned” (39%) or “alarmed” (27%) about Genetically modified GMO foods.

source: New World Map of Genetically Modified Organisms 

Moreover the discussion around GMO GE technology in New Zealand has included discussions of sterile seeds, which internationally are known as terminator technology and for which there has been a international moratorium on developing.

Based on cost analysis to Farmers should Sterile Seeds be introduced (from 2006):

The estimates, prepared by civil society organisation ETC Group in cooperation with farm organisations, show that if Terminator was commercialised and displaced all farm saved seed the extra seed costs for farmers in just seven countries could easily exceed $1.2 billion per year. Examples of the extra costs to replace farm saved seed used for major crops include:

• Soya beans in Brazil 70% of the planted area – additional costs- $407m/year.

• Wheat in Pakistan 88% of the planted area – additional costs $191m/year.

• Rice in the Philippines 59% of the planted area – additional costs $172m/year.

If Terminator technology were applied to all the seed lines around the world, the costs to farmers of buying fresh seed annually would be many billions of dollars. Even Canadian wheat farmers, whose government is one of the leading proponents of Terminator at the CBD, could be stung with an annual bill of US$85 million dollars.

While New Zealand’s Primary Producer board may look at these figures and presume more tax revenue from seeds - it was revealed in the Gene Technology Health committee hearings that New Zealand seed companies export in the region of $500 million per annum of New Zealand grown seed, including supplying half of the worlds white clover seed. But overseas markets only bother to transport our New Zealand seed halfway around the world because of the GMO GE Free assurance. Indicating that this $500 million income market could collapse very quickly should GMO GE be introduced.

Moreover international corporations have very clever ways of avoiding local taxes, whereas New Zealand seed growers are like all local farmers, are a captured taxpayer.

….

PATTERN: ‘Taxes Americans pay support failures of GMO biotechnology, increasing the demand for GE/GMO seeds through government supports, subsidising their supply through public research, and helping to create a regulatory framework in which these products might receive society’s stamp of approval. All this has been done in the name of creating a more productive agriculture. But these claims are a smoke screen for the development and monopolisation of proprietary biotechnology platforms, on the backs of taxpayers’ and farmers, animal welfare and ecosystem harms.

I believe the demand or indifference to GMO GE in New Zealand is simply because their has been a failing by farmers and levy bodies to clearly evaluate the economic realities of GMO

GE farming in overseas countries, and with the understanding that New Zealand is exceptionally fertile; for example throughout the rest of the world, gorse is a beautiful flowering hedgerow, while in New Zealand gorse is an out of control blight that costs farmers significant resources to remove from taking over paddocks and hillsides.

Moreover I believe the New Zealand government is unwittingly reintroducing a form of subsidised agriculture abandoned in the 1980’s and making New Zealand the only nation rich from its agricultural production, by the misguided subsiding of GMO GE, [and Biotech] products for climate change. However well intentioned, there are huge implications with reimporting this agricultural funding model that needs broader evaluation within the electorate.

Gene technology framework ignores on ecological and on farm solutions for climate change, including meadowland seeds like sainfoin and birdsfoot trefoil in methane reduction and the discovery of soil methanotrophs (methane eating bacteria) common in soil and gut methanotrophs in ruminant animals.

It is estimated that 99% of soil remains unidentified, and this is an area where longterm grassland trials and gene sequencing could prove very profitable for NZ and refine NZ farmers best practice - without risking a gene editing component. Moreover the gene technology framework disregards the role of biological diversity in resilience to a changing climate, driving instead genetic uniformity and monocultures which have proven historically disastrous in food production.

With each passing year, the institutions we rely on for innovative agricultural solutions are more tightly yoked to a reductionist science whose frames of reference diminish the importance of holistic methods of inquiry. As a consequence whole-plant, and whole animal level research (such as traditional breeding), systems-level research programs (such as agroecology, farming systems and social + ecological assessments), and indigenous knowledge lack adequate support.

“Given the Gene Technology Bill’s significant implications for New Zealand’s agricultural and horticultural sectors, including livestock breeding, crop innovation, and sustainable farming practices, the Primary Production Committee is the most appropriate body to assess its provisions in depth. The committee’s established expertise in primary industries positions it to carefully consider the potential benefits, risks, and regulatory frameworks associated with new gene technologies in the agricultural context, while balancing production and climate change obligations with protecting indigenous biodiversity.

Ensuring that this legislation is reviewed by a committee with strong sectoral knowledge will promote robust scrutiny and help deliver practical, science-informed outcomes for New Zealand’s farmers, growers, and wider rural communities.”

Thank you for your consideration of this request


sources:

  • GM CONTAMINATION in Canada; The Failure to Contain Living Modified Organisms: Incidents and Impacts by Canadian Biotechnology Action Network, CBAN members include farmer associations, environmental and social justice organisations, and regional coalitions of grassroots groups.

  • How food became a casualty of biotechnology’s promise, By Michael Heimbinder, Fellow, Oakland Institute

  • New World Map of Genetically Modified Organisms (GMO) Agriculture: North and South America = 85% by Dr John Paull & Dr Benjamin Hennig

  • ETC Group; 2006 Report

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