(PIRSA)

From: Judy Pattermann Sent: Wednesday, 25 September 2019 1:02 PM To: PIRSA:GM Review Subject: Genetically Modified Food Crops Moratorium in South Australia - submission to

current public consultation Attachments: Submission to public consultation on SA GM Crops Management Act 25092019.pdf

Dear GM Secretariat,

Please find enclosed a submission from BASF Australia Ltd to the current public consultation on proposed amendments to the South Australian regulations under the Genetically Modified Crops Management Act 2004.

BASF appreciates the opportunity to contribute to this public consultation process. We give permission to publish our submission as it stands in the attached Adobe document. In making this submission I request that my personal details are protected under the Commonwealth Privacy Act 1988 and any associated South Australian State privacy legislation and/or policy.

Kind regards, Dr Judy Pattermann Regulatory Affairs Manager, Seeds, ANZ

Postal Address: BASF Australia Ltd. , Level 12, 28 Freshwater Place, 3006 Melbourne, Australia

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BASF Australia Ltd ABN 62008437867

This e-mail is confidential. If you are not the intended recipient you must not disclose, distribute or use the information in it as this could be a breach o f confidentiality. I f you have received this message in error, please advise us immediately by return e-mail and delete the document. The address from which this message has been sent is strictly for business mail only and the company reserves the right to monitor the contents o f communications and take action where and when it is deemed necessary. Thank you for your co- operation.

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BASF Australia Ltd submission to public consultation - proposed South Australian repeal of State moratorium on cultivation of genetically modified (GM) crops

BASF Agricultural Solutions is a division of BASF Australia Ltd that has breeding, seed multiplication and commercial product sale interests in non-genetically modified (non-GM) wheat and canola; in trait development and licensing of non-GM Clearfield varieties of wheat, barley and canola; and also genetically modified (GM) InVigor canola throughout Australia. Our GM canola varieties are marketed wholly and solely in Australian States which allow commercial cropping of GM crops.

As a stakeholder in the Australian seeds industry, BASF is in support of the South Australian Government's decision to lift the Genetically Modified Food Crops Moratorium on mainland South Australia. We encourage all involved parties to support this science-based decision so farmers in South Australia can access the clear environmental, agronomic and financial benefits of growing approved GM crops.

Reliance on the science-based risk assessment and risk management processes o f the Federal regulator — the Office of the Gene Technology Regulator (OGTR) — has worked effectively across Western Australia, Victoria, NSW and Queensland for a significant number of years. The grain segregation and supply chain in these States have also successfully managed co-existence of organic, conventional and GM seed since the lifting of moratoria in these parts o f Australia.' The practice of coexistence in farming is discussed in greater detail later in this submission.

Enabling farmer choice with respect to organic, conventional and GM crops in South Australia will only serve to benefit South Australian farmers. These growers, provided that the moratorium is lifted, will be able to avail themselves to current commercial cropping systems that allow utilisation of minimum-till systems which preserve soil structure and moisture, allowing for dry sowing of GM canola, tolerance to herbicide application in crop and consequent improved weed control and

AOF/GTA (2009), Market Choice in the Canola Industry: 2008/9 Final Stakeholders Report, Sydney: Australian Oilseeds Federation and Grain Trade Australia. http://www.australianoilseeds.com/ data/assets/pdf file/0018/5931/Market Choice Stakeholder Repor t Final Nov09.pdf; AOF/GTA (2010), Market Choice in the Canola Industry: 2009/10 Season, Sydney: Australian Oilseeds Federation and Grain Trade Australia. http://www.australianoilseeds.corn/ data/assets/pdf file/0008/7937/GM Stakeholder Report 09.10 Se ason V4 Final.pdf; AOF/GTA (2011), Market Choice in the Canola Industry: 2010/11 Season, Sydney: Australian Oilseeds Federation and Grain Trade Australia, October. http://www.australianoilseeds.com/ data/assets/pdf file/0007/8827/GM DRAFT Interim Stakeholder Report 10.11 Season FINAL.pdf; Alcock, K.T., "The Current Status o f GM/Non-GM Canola Coexistence in Australian Broadacre Farming Systems and Likely Future Challenges", Contributed paper at the Seventh International Conference on Coexistence between GM and non-GM based Agricultural Supply Chains, Amsterdam, 17-20 November 2015

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elevated yields.2 Other important GM traits are under development by a range of research organisations in Australia that will serve to benefit the South Australian and national farming community and consumers when they are developed into commercial crops.3 There is considerable Australian research into GM traits that will bring health benefits to South Australian consumers, such as cereals with increased iron levels, healthier starches and oils, or cooking oils modified to be lower in saturated fats and with improved cooking qualities.4 Lifting the GM moratorium would give South Australian farmers access to these innovations and would also support the state's agricultural research and development sector. The ability of farmers to avail themselves to these agronomic systems which have clear benefits to the environment, support food production with clear health benefits and will help improve farm production capabilities are extremely important in these times when sustainable primary production is paramount to the delivery of nutritious food to an increasing Australian and global population.

Excellent economic data has been gathered over the more than 20 years since genetically modified

crops have been adopted by Australian farmers. The data supports the contention that farm level economic impacts have been extremely positive over this period since GM crops have been cultivated in Australia, and over the more than 10 year period since GM canola has been cultivated here.5,6 As an example, the average increase in Australian farm income from GM herbicide tolerant (HT) canola over the period 1996 —2015 was AUD $64.1 million, despite a significant portion of this period being marred by moratoria on commercial cropping of GM canola in Australian states.

Providing farmers with the choice to use GM HT crops tolerant to herbicides with a variety of modes of action offers the opportunity for economic savings compared with the production of current commercial crops in South Australia. Research has shown that farming with GM crops is in many cases less expensive, providing easier weed control for farmers and offers higher yields from the

crops that they produce due to their ability to improve on farm agronomic practices in the cropping

2G. Brookes (PG Economics), Adoption and Impact of GM (genetically modified) Crops in Australia (20 Years Experience). May 2016. https://www.croplife.org.au/wp-content/uploads/2016/05/CL 20- YearsGM Lores.pdf 3 http://www.ogtr.gov.au/internetiogtr/publishing.nsf/Contentiir-1

Ibid. s Brookes, G., Adoption and Impact of Genetically Modified (GM) Crops in Australia: 20 Years' Experience, Report prepared by PG Economics for CropLife Australia Ltd., Canberra, May 2016. 6 Whitelaw, A., M. Dalgleish and 0. Agar, Analysis of Price Premiums under the South Australian GM Moratorium, Report prepared by Mecardo for the GPSA and ABCA, Adelaide: Grain Producers of South Australia and Melbourne: Agricultural Biotechnology Council of Australia, March 2018. https://www.abca.com.au/wp-content/uploads/2018/03/Analysis-of-price-premiums-under-the-SA-GM- moratorium

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systems, e.g. conservation of soil structure and soil moisture in minimum till systems; and the ability to assist in the management of weed herbicide resistance.7

Coexistence is a foundation of Australian farming and is the practice of growing crops with different quality characteristics or for supply into different markets in the same vicinity without becoming commingled and thereby possibly compromising the economic value of both. Coexistence principles are practiced so that farmers are free to cultivate the crops of their choice using the production system they prefer, be it conventional, organic or genetically modified.

The coexistence of various production methods is not a new concept to the agricultural community. Farmers have practiced coexistence for generations to meet demands for different types of agricultural product and historical experience shows that a wide range of production methods can coexist, provided technical and procedural guidelines are carefully followed and cooperation between neighbouring farmers is encouraged. In addition, the agricultural industry has systems in place to ensure grain handlers can keep grains sufficiently separate in order to meet product specifications. The same systems apply to grains from GM crops, because grains from approved GM plants are no harder to steward and pose no greater risk than conventionally bred plants.

As an example, in Australia, GM and non-GM canola have been grown side-by-side successfully and productively without creating marketing issues. With 10 years under our belt of growing GM canola, there has not been one incident across more than 9 million tonnes of canola seed delivered domestically, or more than 23 million tonnes delivered internationally, where an end user (seed crusher / oil or meal buyer, or food/feed manufacturer) has not received what they had ordered in terms of the GM status.

To support the foundation that coexistence offers in Australian agriculture, recent market research has revealed no clear support for the argument that market premiums for non-GM produce supplied from South Australia exist compared with similar produce from States which do not have GM cropping moratoria.8 In States that have lifted their moratoria, successful segregation of grain in the seed supply chain has overcome concerns with market access and has resulted in the maintenance of premiums for segregated produce. An independent economic analysis on market access for South Australian primary produce provides strong evidence that this will also be the result for the state upon lifting of the moratorium on the mainland.9 These are important points to note, since in the past the arguments for maintaining a moratorium against commercial GM cropping in South Australia have been based upon improved market access and

https://www.croplife.org.au/resources/programs/resistance-management/herbicide-resistance- management-strategies-2/herbicide-resistance-management-strategies-2-draft/ 8 Whitelaw, A. et al, Op. cit. 9 K. Anderson, Independent Review of South Australian GM Food Crop Moratorium. March 2019. https://pir.sa.gov.au/ data/assets/pdf file/0006/339225/Independent Review of the South Australian GM Food Crop Moratorium.pdf

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increased premiums for non-GM agricultural produce grown in the State, arguments which are not supported by market data.

BASF appreciates the opportunity to contribute to this consultation on the proposed lifting of the moratorium to commercial cropping of genetically modified crops in South Australia. Our company strongly supports science-based regulation, such that it establishes that products we supply to farmers result in no adverse impact to human health and safety, nor adverse impacts to the environment. We support evaluation of new genetically modified traits to ensure they are soundly characterised and that any risk associated with development of new GM varieties and their sale in Australia are appropriately managed. We welcome the opportunity to commercialise our range of GM crop varieties in South Australia in the future and encourage the South Australian Government to provide this opportunity to farmers in the management of their cropping systems by repealing the moratorium on commercial cultivation of GM crops.