The GM industry is pushing for coexistence trials to test if GM, non-GM and organic can coexist together. However, it is being ignored that it can be scientifically proven that coexistence plans will fail.
Have you looked beyond the Yes/No stance of the GM debate?
Do you think the principle of responsibility for coexistence for GM crops with non-GM crops should be based on ; the GM grower to keep GM crops contained ; or for the non-GM grower to keep GM contamination out (as proposed under current protocols)?
Should trade definitions in the coexistence plans comply with law? (The ACCC and lawyers have confirmed that under the Trade Practices Act, in order to make a positive label claim of either "non-GM" or "GM-free" there must be NO trace of contamination present. However the committee that have prepared coexistence plans claim that contamination is impossible to control so will be accepted.)
Prior to accepting coexistence plans, should there be proof of widespread education and acceptance, that no sector of industry is faced with unmanageable problems and that no sector of industry is faced with additional costs and liabilities without approval from that sector of industry?
Do you expect non-GM farmers to sell crops mixed with GM canola if crops and stock return a lower price or meets market resistance (as proposed under current protocols)?
If non-GM farmers must guarantee no contamination on delivery (as per receival point delivery dockets), should they accept any GM contamination in the Non-GM canola seed they plant (The seed industry currently allows a tolerance of 0.5% GM contamination in non-GM seed)?
Do you support the retention of the right for non-GM farmers to replant their own seeds (this right is denied in the proposed coexistence plans)?
Should there be risk management to ensure detection of an unwanted trace of GM contamination at delivery points does not trigger a deduction of a patent user fee from the non-GM growers income through end-point royalties?
If GM canola is introduced and contamination or loss of GM-free status causes economic loss to others, do you think farmers should be compensated?
Who do you think should be liable for any economic loss caused by GM contamination or loss of GM-free status: the non-GM grower (as proposed under current protocols); the GM grower; the owner of the patent (ie. Monsanto / Bayer Cropscience); and/or the government who approved GM release?
Would you support a strict GM liability regime in legislation to ensure farmers are protected from unfair liability under law?
Should states allow GM crops to be grown if market and economic risk can not be managed?
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Benefits are doubtful, alternatives are available:
Benefits:
Q1. Is there any scientific reason why GM canola will yield more than non-GM hybrids or chemical resistant canola? (A: Promotions claim increases in yield to 30% and one pro-GM activist even claimed visual evidence of 300% yield increases) *there is no scientific reason to support these claims as the single benefit of GM canola is for the chemical resistance trait.
See details regarding Bayers Invigor where Bayer admits 20% less vigour than non-GM hybrids (here) and Monsanto's Roundup Ready details (here)
Q2. What benefit? Where is the hard data showing yields in tonne/ha for independent trials and for previous trials to enable comparison between this information to the area average for the same season? Trials for GM canola have been done by the WA Ag Dept. WA Ag Dept testing showed Invigor yields similar to triazine tolerant varieties which are known for their yield penalties. The best yield Monsanto had on their website was 1.055 tonne/ha which is 17% below the national average. Both Monsanto and Bayer Cropscience have declined from participating in independent trials.
Q3. Is there proof that there is not a yield penalty using glufosinate or glyphosate post emergent? (A:not available yet it is claimed that there is no yield penalty) - The Scientist magazine reported a yield penalty for post emergent applications of glyphosate. We need independent data showing unsprayed/one/two applications of glufosinate or glyphosate to check this (with alternative weed control to ensure weeds do not influence results.)
Costs:
Q4. What is the price of GM canola seed?*it was revealed in the WA parliamentary hearing that Bayer Cropscience's Invigor canola "seed will sell for about $16/kg. Details are not available from Monsanto.
Q5. What is the price of glufosinate Ammonium (Liberty) per litre. (A: not available "commercial in confidence")
*it was revealed in the WA parliamentary hearing that the recommended retail price for Glufosinate ammonium at the recommended application of 2 passes (no residual) at 2 litres/ha would be $74/ha which equates to $18.50 / litre.
Q6. How effective is control, will additional post emergent selectives be needed on some weeds eg. radish? (A:information not available as radish has not been grown in OGTR trials to date) Note: The recently released 2004 WA Ag Dept Oilseeds Crop Updates (here) revealed (contrary to what has been promoted) that "Liberty does not control wild radish" and charts show similar ryegrass control as triazine.
Q7. What is involved in the crop management plans and what is the additional cost? (A: not available "commercial in confidence")
The additional costs for segregation and identity preservation estimated by ABARE was 10% of the farm gate value of the product, Susie O'Neill claimed in the WA parliamentary hearing that 5% was Bayer Cropscience's estimation for the GM grower. These costs are considerably more if less than 1% contamination is required.
*it was revealed in the WA parliamentary hearing that Bayer Cropscience would only charge a $10 fee for license, however Monsanto will not give details of their costs but significant user fees are expected to be recovered by end-point royalties.
Q8. What details are in the contract GM farmers will be expected to sign. (A:not available "commercial in confidence")
Q9. Farmers intending to grow GM must also gain legal liability advise:
If a farmer is to grow GM crops, are they liable for economic losses caused by contaminating neighbouring crops (This has been confirmed and considered acceptable by Bayer Cropscience in their parliamentary hearing) and is this liability insurable (not likely at this stage)?
Because of this liability, will growing GM canola affect a GM farmers land values and equity? (This has been confirmed)
These details confirm that both GM canola options will increase costs to farmers with little or no benefit. Not only are input costs higher but Glufosinate Ammonium (used on Invigor) is extremely expensive and Roundup Ready crops will encourage resistance to our most commonly used chemical.
At this stage, Australian farmers have far better alternatives in our existing non-GM varieties.
