3.
section 3.2 |
Analysis of
submissions from
Interested Persons
appendix 2
Outcomes of Consultation: Submissions
from Interested Persons
Section contents
3.
Analysis of submissions from Interested
Persons
28
3.2
Strategic options
31
Introduction
31
Continuum of attitude toward genetic modification
32
Strategic options to achieve industry goals
33
Competitiveness and innovation
33
Research and development and the knowledge-based
economy
34
"GM-free" nation
35
Strategic options to reduce risk
36
Prohibiting the use of genetic modification technology
36
Extending existing moratorium/delaying decision on use
of genetic modification
37
Undertaking formal assessment of risk
38
Report Appendix 2 | Royal Commission on Genetic Modification
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p31
Royal Commission on Genetic M odification | Report Appendix 2
3.2 Strategic options
Introduction
Nearly three-quarters of the total number of submitters with Interested Person
status (78) commented on strategic options as a component of the three Warrant
items (items (1), (k) and (m)) dealing with strategy. The main sectoral focus of
these submitters was the economic and productive sector (41 submitters).
The stance of most of these submitters was predominantly in support of genetic
modification technology. Fifty submitters were assessed as being `strongly for', or
`tending to be for', genetic modification, and 24 as being `strongly against', or
`tending to be against', genetic moderation. Four submitters were assessed as being
`neither for nor against' genetic modification.
This Warrant item elicited two general types of responses:
*
submitters who perceived strategic options available to New Zealand in
terms of using biotechnology to achieve specific business or industry
outcomes
*
submitters who saw New Zealand's options in terms of measures to reduce
risk from application of this technology.
Most supporters of industry-based use of genetic modification technology tended
to advance strategic options in terms of favourable business outcomes. They
highlighted the potential for improvement in competitiveness, innovation and
research and development through use of this technology. Achievement of
business objectives was promoted as the best strategic option for New Zealand.
These submitters essentially equated best business practices with best outcome for
New Zealand as a whole. This group of submitters tended to emanate from
industry networks and associations (21 submitters), research organisations (14),
other advocacy network and associations (14 submitters) and private companies
(seven submitters).
The other main group of submitters on this Warrant item generally had concerns
about (or strong opposition to) genetic modification. They tended to advance
strategic options that would reduce the level of risk to New Zealand. Their
preferred strategic options were to ban or delay the widespread use of such
p32 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
technology in New Zealand. These submitters usually came from consumer
networks and associations, Maori and religious groups.
Implicit in both types of response (ie, suggesting strategic options to achieve
industry goals or options to reduce risk) was the underlying attitude toward the use
of genetic modification technology. The `stance' evident in submitters' comments
was the common thread evident in all types of comments on strategic options. The
continuum of attitudes to the technology, in effect, formed the basis of the range of
strategic options that submitters saw as being available to New Zealand.
Continuum of attitude toward genetic modification
The continuum of attitude toward genetic modification spanned a wide range. At
one end were those submitters who supported most, or all, aspects of genetic
modification technology within a minimalist regulatory framework. At the other
end were those submitters who were against any use of genetic modification
technology in New Zealand. Middle-ground positions included submitters who
supported case-by-case assessment of genetic modification, those who wanted a
continuation of the current moratorium and those who wanted New Zealand to be
free of genetic modification technology except for a limited and selected range of
uses.
Taking into account the overall position apparent from the full text of submissions
from all Interested Persons, an overall stance was apparent for 78 submitters. (For
the remainder of submitters a clear and unequivocal position could not be
determined.) The main groupings (and numbers) of these 78 submitters were
identified as clustered around five positions:
*
accepted most or all aspects of genetic modification (27 submitters)
*
supported a system of case-by-case assessment of each application for use of
this technology (10 submitters)
*
wanted the current voluntary moratorium extended (15 submitters)
*
wanted New Zealand to be "GM-free" except for limited and selected uses
(17 submitters)
*
wanted no genetic modification technology, no genetically modified
organisms or products (nine submitters).
The following sections discuss the various specific strategic options advocated by
submitters under the two broad headings:
*
strategic options to achieve industry goals
*
strategic options to reduce risk.
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p33
Royal Commission on Genetic M odification | Report Appendix 2
Strategic options to achieve industry goals
In response to identifying the strategic options available to New Zealand in
addressing genetic modification technology, most submitters advanced options
focusing on the achievement of various industry goals and objectives. Industry
objectives included measures to sustain and improve New Zealand's productive
capacity, to increase its competitiveness and to ensure its place in the international
knowledge economy. Most submitters felt that New Zealand's interests would best
be served by using genetic modification technology to meet these objectives. A
minority felt that such objectives were best met by avoiding the use of such
technology. In short, most submitters felt that New Zealand's best strategic options
were the `best' business options.
Genetic modification techniques were generally viewed as an essential and integral
tool in achieving business outcomes. Although submitters advanced these goals as
strategic `options', many comments were more in line with discussion of `outcomes'.
Several comments dealt with strategic issues (ie, the questions that arise in
pursuing certain outcomes). The comments provided therefore anticipated some
of the discussion in the following sections on strategic `outcomes' and strategic
`issues'. These views are referenced in both sections.
Most submitters saw New Zealand's overall wellbeing as being dependent on its
ability to sustain a competitive and innovative knowledge-based economy drawing
on current strengths in the productive sector. New Zealand's productive capacity,
its research capability and global reputation were frequent themes in many
comments.
The comments below are typical of the views advocating overall business goals
such as competitiveness, innovation and the knowledge-based industries as key
strategies for New Zealand.
Competitiveness and innovation
Meat New Zealand [IP31] argued that New Zealand should have a strategic option
"consistent with the need to enhance sustainable competitiveness in the
international economy". Biotenz [IP25] and Crop and Food Research [IP4] argued
similarly, advocating that "New Zealand should choose an option that supports its
strategic aims to be a globally competitive knowledge economy founded on the
biological industries".
The role of New Zealand's Royal Commission on Genetic Modification in
reporting to Government was seen to present a "unique" opportunity to deliver
wide-ranging benefits. New Zealand Agritech [IP73] argued that the Commission
p34 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
had "the opportunity to lead the world with the development of the first national
strategy to manage and use GMOs to improve our international competitiveness,
to protect our fragile fauna and flora and provide substantial benefits to humanity".
Several submitters stressed the close interlinking of innovation and competitiveness.
Meat New Zealand [IP31] noted: "Innovation drives competition and is one of the
very significant issues surrounding global development." It stressed the importance
of being able to constantly adapt products to meet shifts in consumer preferences
and lifestyle changes. New Zealand Grocery Marketers Association [IP54] made
similar points arguing that:
New Zealand cannot and should not quarantine itself from the use of gene technology. To
do so would disadvantage the competitiveness and economic vitality of the industry.
New Zealand Dairy Board [IP67] maintained that New Zealand's current and
future standard of living was "overwhelmingly dependent" on biological products
that exceeded 60% of New Zealand's export earnings. It argued that there were
"no other exports growing rapidly enough to reduce that dependence" and that
this required New Zealand "maintaining and enhancing the competitiveness in
biological industries [which are] our only major source of international competitive
advantage". The Board saw New Zealand's only viable option with respect to
genetic modification, if it were to maintain its competitiveness, would be "to
ensure that the responsible use of GM is permitted".
Research and development and the knowledge-based
economy
The importance of New Zealand retaining its research capability and place in the
international knowledge economy was stressed by a number of submitters
representing farming, biotechnology, medical research and university interests.
They reinforced the importance of New Zealand's global credentials, seeing the
option of avoiding genetic modification technology as compromising New
Zealand's research and academic reputation.
Rural Women New Zealand [IP52] stressed the importance of New Zealand
maintaining its position in the "international knowledge economy through
supporting continued GM research" especially "in agricultural export markets
through ... leading edge science ... and leading edge food safety and environmental
risk management systems".
New Zealand Dairy Board [IP67] posed two questions:
... does New Zealand choose ... to abandon the strategy of pursuing the "knowledge
economy" by ceasing to be involved in the GM revolution ...?
... does New Zealand choose to adopt a policy which will enable it to maintain and improve
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p35
Royal Commission on Genetic M odification | Report Appendix 2
the competitiveness of its core industries, and to capture for all New Zealanders the
benefits of the "knowledge economy"?
The Board concluded that New Zealand "must pursue the use of GM in
agriculture" as a key aspect of its pursuit of the knowledge economy.
New Zealand universities gave particular emphasis to their role in New Zealand's
pursuit of a successful knowledge-based economy. For example, Lincoln University
[IP8] argued that "a University can only survive in a global market if it generates
new knowledge, utilises new technologies and delivers outcomes in its field of
expertise". The University said that it "must be involved in genetic modification in
its educational and research programmes, to ensure it remains globally
competitive". University of Otago [IP19] maintained that avoidance of genetic
modification technology "would seriously compromise the university's ability to
deliver teaching and research of an internationally satisfactory standard".
Submitters engaged in medical research advanced similar arguments. Researched
Medicines Industry Association of New Zealand [IP55] viewed biotechnology
industries as being critical to New Zealand's overall benefit. In an accompanying
witness brief, it maintained:
Biotechnology industries - with their emphasis on research and development, skills
development, technological innovation, and activities that target the high value end of
the market spectrum - are important to New Zealand's future economic and social
wellbeing.
The option of limiting the use of genetic technology was seen to have deleterious
effects. AgResearch [IP13] stated its belief that a strategy based on halting or
restricting this technology "would have serious adverse implications for New
Zealand science and consequently the nation's future economic, social and
environmental wellbeing".
"GM-free" nation
Although most submitters who put forward specific industry goals as the best
strategic options for New Zealand were generally in support of using genetic
modification technology, several submitters argued the converse. The latter felt
that nationwide industry goals would be best achieved by avoiding genetic
modification. Most of these submitters saw benefits in New Zealand's potential as
an organic `haven'. These views are discussed below (see "Prohibiting the use of
genetic modification technology").
p36 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
Strategic options to reduce risk
Submitters who opposed, or expressed reluctance about New Zealand's adoption
of genetic modification techniques often cited "risks" as a reason. Fears about the
"safety" of genetic modification, particularly its impact on the environment, were
the most commonly expressed concern. Strategic options available to New
Zealand recommended by these submitters included:
*
prohibiting the use of genetic modification technology
*
extending the existing moratorium or delaying any decision until risks are
better understood
*
undertaking formal assessment of the risks involved.
Indicative of the level and type of concern for future strategic directions were the
following stances. These stances generally give a clear indication of each submitter's
position on the continuum of opinion on genetic modification.
Prohibiting the use of genetic modification technology
Several submitters advanced "GM-free" status for New Zealand. Submitters
tended either to emphasise the benefits of a single-minded proactive policy for
New Zealand to be "GM free", or to emphasise the risks involved in widespread
use of this technology. Several submitters, however, stressed both the advantages
of actively promoting "GM-free" status and the negative effects of allowing the
use of genetic modification in New Zealand.
Submitters stressing the positive aspects of New Zealand identifying itself as "GM
free" saw virtue in New Zealand promoting itself as the first country to be totally
free of the use of genetic modification by choice.
For example, Green Party of Aotearoa/New Zealand [IP83] felt New Zealand
should become "the first consciously GE Free nation". It argued that this "would
be a major boost to our food exports" because such a policy would "profile New
Zealand as a nation which had chosen to base its prosperity on sustainability, a
sound understanding of ecological principles and respect for people and other life
forms".
Also typical of this position were the views of the Canterbury Commercial
Organics Group [IP65]. It argued that New Zealand's adoption of a "high-tech
GE-free-agriculture, `knowledge economy' future will ensure this country a much
more secure, sustainable, successful and prosperous future than will ... the GE
version". It maintained that New Zealand's geographical isolation gave it "an
opportunity to remain GM free and to develop the certified organic industry to
take advantage of the expanding export opportunity".
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p37
Royal Commission on Genetic M odification | Report Appendix 2
Other comments from submitters stressed the risks involved with genetic
modification technology. Representative of these views were the following
comments:
*
"New Zealand must maintain her GE-free status. This is because there are
so many unknowns about the technology and our considered opinion is that
it is inherently dangerous." (Physicians and Scientists for Responsible
Genetics New Zealand [IP107])
Some submitters argued especially for the prohibition or restriction of genetically
modified organisms because of the implications for the environment and
agriculture. Comments included:
*
Place "an immediate and indefinite ban on genetically engineered organisms
in our food and our environment" (GE Free New Zealand (RAGE) in Food
and Environment [IP63]).
*
Sustain a "strategic vision" for "an ecologically sustainable Aotearoa New
Zealand" which involved "a GE-Free environment, banning all releases of
genetically engineered organisms into the environment" (Greenpeace New
Zealand [IP82]).
*
"Only ... a complete and permanent ban of GM foods" and "a ban on
genetic engineering" will protect "the future of our agricultural economy
and the health and safety of the nation" (Soil and Health Association [IP97]).
*
Apply "the precautionary principle to Genetic Engineering technology and
ban all trials and releases of GE crops until it can be proven that they are
safe" (Northland Conservation Board [IP68]).
*
Have "no field release of GMOs in the New Zealand environment because
this is an unproven technology with unknown long term potential irreversible
side-effects" (Royal Forest and Bird Protection Society of New Zealand
[IP79]).
*
"The principal strategic option" should be that "New Zealand's natural and
agricultural environment be kept free of genetically modified organisms"
(Bio Dynamic Farming and Gardening Association in New Zealand [IP61]).
Extending existing moratorium/delaying decision on
use of genetic modification
Several submitters supported extension of the current voluntary moratorium and
other recommendations to delay any irrevocable decision on the use of genetic
modification. This view came from a variety of quarters, especially environmental
and Maori organisations and beekeepers. Views supporting an extension of the
moratorium, or other delays in New Zealand's use of genetic modification
p38 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
technology, focused on general concerns as well as particular issues for food and
the environment.
Typical of general comments were the views of the following two submitters:
*
Strategic options "should be defined by the kind of future that we want for
New Zealand. ... There are widely recognised risks in adopting GM
technologies. ... New Zealand has the opportunity to deliberately defer
from the global trend and take a more measured response" (Sustainable
Futures Trust [IP51]).
*
"A fully legislated moratorium, would give New Zealand time to have a wide
ranging and comprehensive discussion on our options before any irreversible
steps are taken" (Environment and Conservation Organisations of New
Zealand [IP102]).
Submitter views focusing on the environment included:
*
Impose a "10 year moratorium on all field tests or general release of
genetically modified organisms" so that New Zealand can "move away from
conventional chemical agri-technology industry and fully adopt organic
production by 2005" (Maori Congress [IP103]).
*
Introduce `a fully legislated moratorium, until there is definitive proof of its
[genetic modification technology] safety" because a "GE Free New Zealand"
is "the only option to allow the full protection of the biosphere and all
organisms presently residing within it" (Nelson GE Free Awareness Group
[IP100]).
*
New Zealand should "legislate to create a permanent GM Commission ...
responsible for ... the maintenance and review of a Moratorium on open-
environment research and scientific and commercial activity with GM
organisms" (National Beekeepers Association of New Zealand, Poverty Bay
Branch [IP62]).
Submitters' views specifically addressing food included:
*
To "delay commercial release of GM food until the extent of the negative
consumer attitude can be seen and the producer benefits become more
apparent" (New Zealand Council of Trade Unions [IP95]).
Undertaking formal assessment of risk
Several submitters with safety concerns proposed formal, independent testing and
assessment of risks. For example, Comvita New Zealand [IP74] felt that New
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p39
Royal Commission on Genetic M odification | Report Appendix 2
Zealand policy needed to achieve the following:
a) Support fundamental research to develop precision and predictability in gene
expression and gene transfer;
b) Develop a world-class independent testing regime, using evidence-based risk analysis
and the precautionary principle, to ensure the safety of any GM organisms that may
potentially be released into the New Zealand environment.
c) Prohibit the release of GM plants for commercial production in New Zealand for the
foreseeable future, and at least until there is general public acceptance that policy
objectives a) and b) have been met.
Specific research to assess impacts in various industries and sectors was also
recommended as a strategic option. For example, New Zealand Worm Federation
[IP94] recommended conduct of "appropriate research" on "the effects of
genetically modified organisms on soil microbial and worm health" and "the effect
of genetically engineered crops' residues on the microbial action of the soil" before
endorsement of "genetic modification of agricultural products in New Zealand".