Make submissions by mail or on-line. www.ermanz.govt.nz
Ask ERMA to decline these applications.
Application GMC07012 to import live animals, sperm, embryos, human and monkey cell-lines, to develop GE animals;
Application GMD08012 for indoor development of GE animals for research, breeding and production;
Application GMF07001 for field tests in outdoor containment;
Application GMD07074 allowing outdoor production
Including cows, buffalo, goats, sheep, pigs, deer, llama, alpaca, horses, rats, mice, hamsters, guinea pigs, rabbits, possums, chickens, and cell-lines from humans and monkeys.
1) AgResearch are pushing the boundaries with these applications by applying to develop and commercialise use of GE animals, indefinitely, at sites around New Zealand
2) It is ignoring community values and risking New Zealand's reputation
3) The applications are unreasonably ‘general’ and vague. They are 'overlapping' and cover many experiments that AgResearch is 'legally covered' for but are not defined.
Points to note:
- The proposals are very different to existing approvals in terms of scale, wide-ranging objectives, use of a wide range of animals, multiple locations and unlimited timeframe.
- The lack of detail makes case-by case consideration of ethics and economic viability impossible and breaches the HSNO Act.
- The public have a right to be concerned about the ethics of using animals, and the harm to New Zealand's brand image.
- Application GMD 08012 should be defined as a 'conditional release' not just a field trial or research. It is a major step.
- It is impossible for ERMA or submitters to consider the details because there are none. This is a 'generic' application. It should not have been accepted, and cannot be approved.
- Alternative ways exist to produce many pharmaceuticals, which would avoid unethical use of animals. AgResearch admit there are deformities and animal sickness in its GM developments, meaning ethics are being weighed against cost-efficiency for manufacturers.
- The applications are not culturally acceptable in New Zealand. The Community expects reasonable and ethical uses of biotechnology.
- Cultural issues are not just spiritual or just relate to Maori.
There are cultural values for New Zealand like those established around nuclear-free, which include ethical uses of gene technology. The applications go far beyond what is reasonable.
- New Zealand's brand image benefits all of us and helps our exports and tourism. The public interest is best served by maintaining our international reputation for producing safe, natural, clean products.
- New Zealand's image will be damaged. There is a risk of stigma, impacting our reputation. Economic studies by the University of Lincoln clearly indicate the risk.
- Commercial and government-funded science should maintain the Brand reputation of New Zealand, but these applications jeopardise it.
- Overseas investors benefit more than the public. The commercial biotech investors will exploit New Zealand, but the public is liable for costs of clean-up when things go wrong. There is no commercial insurance, or bond paid by the biotech investors to cover risks.
- There is a risk of creating new diseases by experimenting on New Zealand animals which are currently free of BSE (Mad Cow Disease) and Scrapie. It is wrong to allow GE animal waste to be used as compost or sprayed onto fields.
- If approved, there will be a serious lack of transparency and openness over an indefinite period. Community values create an expectation that experiments are open to ongoing scrutiny for ethical and legal standards. There are rapid developments. New transgenic methods could create new risks not yet identified.
- The Bioethics council has called for review of use of human genes in animal created as models of disease.
- There is a lack of respect for intrinsic worth of animals raising ethical concerns that are completely ignored in the applications.
DEADLINE 31 October
Write a submission and post to:
ERMA New Zealand
PO Box 131
Wellington 6140
On-line: www.ermanz.govt.nz
Fax: 04 914 0433
Say your submission relates to all the applications (listed above) unless it applies to a particular one.
Ask to be heard by the committee and notified of hearings.
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