3.
section 3.3 |
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
3.3
Strategic issues
40
Introduction
40
Key themes
40
Acceptability
42
Cultural acceptability
44
Environmental acceptability
44
Choice
45
Choice and food
45
Choice and organics
45
Choice and medical care
47
Risk management
47
Opportunities
48
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3.3 Strategic issues
Introduction
Thirty-nine submitters made substantial comment on strategic issues as a
component of the three Warrant items (items (1), (k) and (m)) dealing with
strategy.
Comments under this Warrant item (k) identified strategic issues with wide-
ranging theoretical and conceptual perspectives. Comments covered such issues
as: the need for a framework based on principles; the importance of balanced
solutions, justice and fairness in decision-making; clarity for future direction; and
responsibility towards future generations. Implications for various populations
such as future generations, Maori and sufferers of genetic-based diseases were
also noted. Other matters raised included health and safety considerations and
potential impacts on the environment and biodiversity.
Submitters' comments from the other Warrant items dealing with strategic
matters also traversed strategic `issues' and have been included in this section. For
the purpose of this analysis, strategic `issues' are broadly defined as the
considerations raised in the course of selecting a particular pathway (strategic
`option') to achieve a certain result (strategic `outcome').
Key themes
Throughout the comments on all three Warrant items dealing with strategic
matters, strategic issues generally grouped around four themes:
*
acceptability
*
choice
*
risk management
*
opportunities.
The matters raised under these four general types of strategic issues are outlined
below and a more detailed discussion follows.
Acceptability
The core issues grouped under this heading focused on whether particular
policies, actions and other outcomes were acceptable to certain groups of people,
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or to various industry sectors. Examples cited by submitters raised questions such
as:
*
Would this course of action be acceptable to the New Zealand public at
large?
*
Would it satisfy the demands and requirements of particular populations
such as industry groupings, organic farmers, sufferers of genetic-based
illnesses?
*
Is it ethically acceptable?
*
Would it affect the integrity or cultural values of any particular group?
Choice
The main issues raised affecting choice centred on whether certain pathways
affected our choice to pursue other alternatives. The strategic perspective of
choice was not so much what the choices were, but whether choice remained if a
certain pathway were adopted. In effect, do certain pathways close off other
choices?
For example, issues raised by submitters raised such questions as:
*
How would a decision to disallow genetically modified products such as
insulin affect diabetics? What other choices would they have?
*
How would such a decision affect medical researchers actively engaged in
pursuing diagnostic and palliative care solutions? What choices would it
constrain?
Risk management
The strategic issues raised in this area were about how risks could best be
managed. The strategic perspective on risk was therefore a question not so much
of what risks there were, but of how any risks associated with a particular strategic
pathway or option could be effectively managed. For example, strategic issues
raised included:
*
Could we effectively manage the risks of a `mixed' production system
allowing both genetically modified crops and organic produce?
Opportunities
Strategic issues raised in relation to opportunities centred around the extent to
which particular pathways would allow maximisation of opportunities. The main
strategic questions in this area concerned whether particular courses of action
were maximising opportunities, or reducing and closing off certain other
opportunities. Opportunities to be maximised included such business goals as
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innovation and productive capacity. Questions raised in comments from
submitters included:
*
What export opportunities would be missed if New Zealand failed to allow
genetically modified animals?
*
What opportunities would be lost if New Zealand failed to use genetic
modification technology for pest control?
*
What opportunities would be lost to New Zealand from organic farming if
commercial production of genetically modified organisms were allowed?
*
What applications of genetic modification were irreversible?
The following sections identify and summarise specific submitters' comments in
relation to acceptability, choice, risk management and opportunity.
Acceptability
The need for "acceptable" solutions with widespread public support was the most-
mentioned strategic issue. Decision-making grounded in a predetermined
framework and informed by public debate was a frequent call. Several submitters
emphasised the need for a system that ensured widespread public acceptance with
fair, just and participatory decisions. Submitters also mentioned acceptable
"cultural" and acceptable "environmental" strategies.
Submitters who emphasised the need for just and equitable solutions that had
widespread public support, included Interchurch Commission on Genetic
Engineering [IP49], which spoke of the need for "justice and equity to ensure that
all will benefit from any applications of GM technology".
The need for public education and informed debate was a frequently mentioned
issue. For example, New Zealand Catholic Bishops' Conference [IP38] called for a
public education and consultation process so that "an informed community can
participate fully in discussion, confident in their knowledge of both the scientific
facts and the ethical issues". Parliamentary Commissioner for the Environment
[IP70] stressed the need for development of policy frameworks to "facilitate
understanding about genetic science and engage in constructive debate". It saw a
need for a "more coordinated approach" with a "purposeful framework" for
dealing with genetic modification issues. Institute of Molecular Biosciences,
Massey University [IP15] expressed similar views. Noting that knowledge and
information' were the "key strategic issues", it maintained that in its experience
the wider community appreciated the knowledge and benefits that had already
accrued from the use of genetic modification technology but that the public
wanted "authoritative assurance that the new GM products will be safe". Genesis
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Research and Development [IP11] thought that "as a society, New Zealand needs
to continue to have open and informed discussions about the issues and the
concerns arising from using GMOs". It recommended that: "Appropriate forums
must be created where information can be made available in a format that will
allow the public to understand the basic technology, so that informed decisions can
be made."
Reinforcing the need for public support in New Zealand's use of genetic
modification technology, SAFE (Save Animals from Exploitation) [IP85] stressed
that "the ethical position of the general public is vitally important" and "should be
a major factor in the Commission's recommendations". This view was echoed in
the position adopted by University of Canterbury [IP7], which argued for a
"pragmatic approach" so that extreme positions were avoided. Noting that low-
risk genetic modification work had "great potential to benefit society", the
University said that some high-risk work was "beyond the bounds accepted by
society".
Safeguards to enhance acceptability and reduce perceived risks were frequently
advocated. For example, Greenpeace New Zealand [IP82] stressed the need for a
"strategic vision" to provide the "necessary critical framework within which the
appropriateness of new technologies ... should be assessed". Environment and
Conservation Organisations of New Zealand [IP102] argued for an approach to
assessing the safety and possible use of genetic modification "to be explored in as
wide a context as possible" that would include "ethical, cultural, social and
economic risks and benefits as well as looking at the science involved ...". New
Zealand Wool Board [IP30] argued that "it may be necessary to put in place an
interim management regime while values, ethics, risks and benefits are being dealt
with". Bio Dynamic Farming and Gardening Association [IP61] emphasised that
"genetic modifiers" had a "moral responsibility" to ensure that they also generated
ways to reduce the uncertainty created by genetic modification technology to
"acceptable levels".
Other submitters stressed the importance of clearly articulated public policy that
provided certainty for the public. For example, Aventis CropScience [IP14]
reinforced the importance of "clear policy directives from Government", noting
that "public confidence results from sound regulatory policy". Anglican Church in
Aotearoa New Zealand and Polynesia [IP42] commented that, in terms of "justice
and equity", there was a need "to establish monitoring and regulatory mechanisms
which will moderate the excesses of corporate enthusiasm and ensure the
sovereignty of this Treaty nation".
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Some submitters brought together the various strategic elements of acceptability,
choice, risk management and opportunity. For example, Landcare Research [IP12]
in its recommendation for a `conceptual framework' for analysis of risks and
benefits had `four moral principles' at its core. The guiding principles for such a
framework included such issues as "autonomy" (freedom of use and choice),
"justice and fairness" (such as in the distribution of risks, benefits and costs),
"beneficence" (good in matters such as health, environment and consumers), and
"non-maleficence" (no harm in matters such as ecological impacts or food safety).
Submitters also addressed specific cultural and environmental strategic issues in
terms of acceptability.
Cultural acceptability
Protection of the rights and the genetic heritage of indigenous peoples were
among the culturally acceptable strategic issues noted. Physicians and Scientists
for Responsible Genetic New Zealand (PSRG) [IP107] emphasised "protection of
diversity of cultural perspective ... especially that of indigenous peoples". Maori
Congress [IP103] maintained that "protection of Maori concerns" was
"paramount" and needed to be "actively promoted". WAI 262 claimants [IP89]
stressed that Maori must "fully understand and appreciate the consequences of
the modification of whakapapa" and that they must "say no to such modification
until the consequences are proven to be of benefit".
Environmental acceptability
The uniqueness of New Zealand's biodiversity was a critical concern of several
submitters who argued that this was a major strategic consideration. However,
submitters were divided on whether this unique biodiversity was better ensured by
the use or by the avoidance of genetic modification technology. Landcare
Research [IP12] argued that "the protection of New Zealand's biodiversity is a
national imperative and an international obligation" and suggested that such
protection could be most readily achieved by giving conservation managers "a full
management toolbox that includes GM technology".
Supporting the need to retain New Zealand's biodiversity through acceptable
practices, PSRG [IP107] described the "protection of the biosphere against the
adverse effects of genetic engineering" as a key strategic issue. Royal Forest and
Bird Protection Society [IP79] argued similarly that "the key strategic issue is that
of the New Zealand Biodiversity Strategy" and that "protection of New Zealand's
unique wildlife is of international importance". Royal Forest and Bird Protection
Society, Nelson/Tasman Branch [IP43] listed as a key concern the "consideration
of effects over the whole ecosystem".
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Friends of the Earth [IP78] sought to contribute "to the integrity of the
ecosphere" by recommending "the institution of sound ecological principles as [a]
basis for resource management and related national and international policy".
Public Questions Committee (Methodist, Presbyterian, Churches of Christ,
Quaker) [IP93] argued that "the integrity of the biosphere is a sacred heritage
which we are ethically obliged not to harm" and that future generations "have a
right to celebrate its ... diversity intact".
Choice
The main strategic issues referenced by submitters as affecting choice centred on
whether choice to follow certain strategic pathways affected our pursuit of other
alternatives. In effect, did one person's choice concerning genetic modification
affect someone else's range of choices? For example, New Zealand Life Sciences
Network [IP24] queried whether New Zealand fulfilled its "fiduciary duty to
future generations if we knowingly reduce our options to address the looming
issues of the future at the very time when those issues are becoming increasingly
better defined?"
Most considerations raised by submitters involving choice concerned the general
right to exercise choice. Submitters offering specific comments on the exercise of
choice most frequently provided examples of health issues (especially genetically
modified foods) and organic farming.
Choice and food
Comments emphasising the right to choose in relation to food products included:
*
the rights of individuals "to distance themselves from GM if conscience
precludes the use of the technology or its products ... particularly in relation
to genetically modified foods" (New Zealand Catholic Bishops' Conference
[IP38])
*
the need for "respect for autonomy so that consumers will have a choice,
particularly in the areas of GM foods" (Interchurch Commission on Genetic
Engineering [IP49])
Choice and organics
Several submitters highlighted options for choice in relation to New Zealand's
"clean green" image. Opinion was clearly demarcated between those who felt that
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New Zealand could accommodate both organic agricultural systems and
genetically modified plants and those who felt that the two production systems
were incompatible.
Representative of comments that genetically modified production reduced choice
to use organic production methods were the following:
*
"The choice is stark" between "a knowledge-based, prosperous, safe and
sustainable future paid for by producing and selling to the high value and
exponentially expanding eco-tourism and certified organic, `clean and green'
IPM and GE-free markets of the world" or "a GE-contaminated, commodity
producing economy" (Canterbury Commercial Organics Group [IP65]).
*
"Genetic Engineering is no use to Organic agriculture and the environments
that surround it. The introduction of GE ... would effectively destroy
decades of hard work ... and the positive economic opportunity awaiting our
country in developing sound sustainable Organic agriculture, produce,
environments and related knowledge" (Organic Federation New Zealand
[IP81]).
*
"... genetic engineering and organic food production are incompatible"
[Soil and Health Association of New Zealand [IP97]).
*
"The introduction of GM crops and animals has the potential to compromise
[organic] systems to the extent that produce will not meet the requirements
[for certification] as organic thereby depriving New Zealand of a competitive
advantage and individual farmers of their preferred choice of production
method" (Commonsense Organics [IP66]).
*
"Commercial production of GM food in New Zealand could impact
negatively on the export of kiwifruit to Europe in particular, but also to
Japan and Southern Asia. Adverse consumer opinion and retail trade action
could lead to non tariff barriers to market access." This would jeopardise the
kiwifruit export industry including "$400m of export earnings" (ZESPRI
International [IP46]).
Submitters who felt that organics and genetically modified production systems
could coexist included submitters with the following views:
*
"Organic production is compatible with GMs as other nations have shown in
a robust regulatory framework ... General concerns about GMOs will
become less over time and such concerns, unless based on scientific
evidence, should not restrict genetic modification utilisation" (Association of
Crown Research Institutes [IP22]).
*
"New Zealand can maintain both organic production and the production of
GM crops ... competitive advantage lies in the rapid adoption of
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biotechnology ... Consumer resistance to GM foods will disappear ..."
(New Zealand Arable-Food Industry Council [IP56]).
Choice and medical care
Submitters representing patient groups of those who had genetically based
conditions were unanimous in their call for the right to exercise choice as regards
therapeutic care. Typical of these comments were the following:
*
Say "yes" to genetic modification technology "because we can manage
concerns and safety issues and at the same time gain great benefits in the
health of our population, and take advantage of the technology for
employment and economic growth" (Lysosomal Diseases New Zealand
[IP99]).
*
"... patients should have access to a choice of therapeutic products. Patient
information and informed consent underpin real choice. If real choice and
informed consent exist then ethical and cultural risks are minimised and
environmental, social and economic benefits are maximised" (Diabetes
Youth New Zealand [IP60]).
*
"... people suffering haemophilia and other genetic bleeding disorders,
should have access to choice in therapeutic products ... limiting access to
recombinant therapeutic products is unthinkable" (Haemophilia Foundation
of New Zealand [IP48]).
*
"Freedom of choice is important when making decisions in life or death
situations - Cystic Fibrosis sufferers must be allowed to have access to
genetically modified products if that is what they choose" (Cystic Fibrosis
Association of New Zealand [IP39]).
Risk management
Several submitters saw the way in which New Zealand managed the risks
associated with use of genetic modification technology as an important strategic
issue. Submitters suggested a variety of ways in which risks could be most
effectively managed. Most submitters advocated robust regulatory frameworks and
assessment procedures.
Submitters who felt that risks of using genetic modification technology were
manageable generally favoured the institution of robust regulatory frameworks
and assessment procedures. Comment representative of this position included:
*
... the risks are manageable, in particular through a regulatory framework
that relies on comprehensive assessment and transparency in its functions"
(Carter Holt Harvey /Fletcher Challenge Forests [IP17]).
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*
"The issues surrounding biotechnology are based around ... potential risk
and flow-on consequences of that risk becoming a reality. ... Risk
management and a robust regulatory framework ... should minimise the
negative consequences of biotechnological research and development"
(Federation of Maori Authorities [IP69]).
*
"A robust regulatory environment that promotes safe research and
development is necessary" (Wrightson [IP3]).
Submitters with concerns about the risks associated with genetic modification
technology also saw risk management as a key strategic issue. Several suggested
adoption of the precautionary principle or argued for new approaches to managing
risk. Comments representative of these viewpoints included:
*
New Zealand should "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]).
*
"... consideration [of uncertainties] must include the widest possible survey
of scientific and societal experience of new departures and new processes. ...
We do not manage the risks of any technology by relying on knowledge of
the manufacturing process. ... Empirical investigation is imperative. ... New
designs require new tests" (Bio Dynamic Farming and Gardening Association
[IP61]).
Opportunities
A smaller number of submitters specifically noted opportunities from the use or
from the avoidance of genetic modification technology as a key strategic issue
when commenting on Warrant items in relation to strategic `options', `issues' and
`outcomes'. Most discussion of opportunities to be gained or lost was raised by
submitters in discussion of other Warrant items, in particular Warrant item (i).
Therefore much of the detailed comment on strategic issues as opportunities lost
or gained is recorded in the section "Opportunities for use or avoidance". In
commenting on strategy, submitters mostly saw opportunities in terms of benefits
in productive capacity and development of a knowledge-based society.