(PIRSA)

From: Alexandra Bunton Sent: Monday, 30 September 2019 10:35 AM To: PIRSA:GM Review Subject: Letter from NSW Farmers Attachments: 190927 PIRSA GM regs.pdf

Good morning

Please see attached letter from NSW Farmers regarding the draft GM regulations.

Regards

Alexandra Bunton I NSW Farmers I A/g Policy Director — Cropping, Horticulture and Young Farmers

www.nswfarmers.org.au

'Wry Growing FW the best 0 0 0

tistrongertogether

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n s w FARMERS

30 September 2019

GM Secretariat Support Primary Industries and Regions SA - PIRSA Government of South Australia GPO Box 1671 Adelaide SA 5001

Sent via email: PIRSA.GMReview@sa.gov.au

Dear committee secretariat,

NSW Farmers is grateful for the opportunity to provide comment on the proposed Genetically Modified Crops Management (Designation of Area) Variation Regulations 2019.

NSW Farmers supports the use of biotechnology to progress agricultural production provided that any genetically modified organism has been approved by an independent, science-based Australian regulator; and we support choice in relation to biotechnology provided that choice respects the rights of others to also choose.

As a member of both the National Farmers' Federation and Grain Producers Australia, we support the submissions of these organisations; we also support the submissions of Grain Producers South Australia and Croplife Australia.

NSW Farmers believes that there is a growing body of evidence that demonstrates the real economic and environmental impacts of GM technology. While we have no formal policy stance on South Australia's moratorium, we support the views of our colleagues at Grain Producers South Australia, who, according to their submission to this consultation, believe that "growers should have the freedom of choice to grow the cereal, legume and oilseed varieties that best f i t their farming system, which means having access to GM crops."

As stated in our submission to the 2017 Review of the National Gene Technology Scheme:

NSW Farmers represents the downstream users of gene technology and, as such, have an interest in ensuring that the regulation of gene technology is efficient and effective. NSW Farmers believes that existing regulation of access to genetically modified crops through the Office of the Gene Technology Regulator (OGTR) appropriately ensures there are no known detrimental implications for consumers of normal dietary proportions that are grown or fed with genetically modified (GM) produce.

Fundamentally, we believe that growers are best-placed to make their own business decisions, including whether or not to take advantage of GM technology. Many of those NSW growers who choose to grow GM

NSW Farmers' Association ABN 31 000 004 651 PO Box 459 St Leonards NSW 1590 Level 4 154 Pacific Hwy St Leonards NSW 2065

Member Service Centre 1300 794 000 T 02 9478 1000 F 02 8282 4500 www.nswfarmers.org.au

nsw FARMERS

canola have seen significant economic and environmental benefit. The GM Canola Impact Survey noted the following :1

• When compared to Triazine Tolerant (TT) canola, growers utilising GM Canola achieved more effective weed control, reduced overall pesticide use and improved farming practices (such as enhanced conservation tillage), lower risk of herbicide resistance developing and a lower environmental foot print.

• Concerns relating to the co-existence of GM and non GM canola crops prior to the introduction of

GM canola have failed to materialize, with the majority (84% - 89.3%) of GM canola respondents indicating that they had not received any complaints relating to their growing of GM canola. Of the complaints received, these primarily related to:

o Pre-existing beliefs that GM canola should not be grown. o Concern about the impact on non-GM products, such as canola, honey, dairy.

o Concerns about developing glyphosate-resistant weeds.

A number of reports produced by UK-based PG Economics have confirmed the contribution of GM technology to the ongoing environmental sustainability of the agricultural industry. Findings include:

• The adoption of GM insect resistant and herbicide tolerant technology has reduced pesticide spraying by 618.7 million kg (-8.1%) and, as a result, decreased the environmental impact associated with herbicide and insecticide use on these crops by 18.6%. The technology has also facilitated important cuts in fuel use and tillage changes, resulting in a significant reduction in the release of greenhouse gas emissions from the GM cropping area.2

• In 2015, the direct global farm income benefit from GM crops was $15.4 billion. This is equivalent

to having added 5.2% to the value of global production o f the four main crops of soybeans, maize, canola and cotton. Since 1996, farm incomes have increased by $167.8 billion.3

The Productivity Commission review on Regulation of Australian Agriculture noted that there is "no clear

case for governments to support non-GM producers' marketing activities at the expense of those who wish

to grow GM crops".4 The Commission also stated that " i f GM and non-GM systems can co-exist, producers of non-GM products would realise benefits regardless of whether GM products were in the market," and suggested that premiums could be delivered through branding of individual products and companies as there is a lack of demonstrated market failure to justify moratoria. Evidence from the Productivity

1 Hudson, David and Richards, Rosemary (2014). GM Canola Impact Survey: Information fo r growers, advisors and industry. Prepared for the Birchip Cropping Group and the Grains Research and Development Corporation. 2 Brookes, Graham and Barfoot, Peter (2017). "Environmental impacts of genetically modified (GM) crop use 1996-2015: Impacts on pesticide use and carbon emissions." GM Crops & Food, 8:2 3 Brookes, Graham and Barfoot, Peter (2015). GM crops: global socio-economic and environmental impacts 1996-2015. PG Economics Ltd, UK

Productivity Commission (2016). Regulation o f Australian Agriculture, Report no. 79, Canberra. NSW Farmers' Association

ABN 31 000 004 651 PO Box 459 St Leonards NSW 1590 Level 4 154 Pacific Hwy St Leonards NSW 2065 Member Service Centre 1300 794 000 T 02 9478 1000 F 02 8282 4500 www.nswfarrners.orgau

sw FARMERS

Commission also suggests that there are no net benefits from moratoria, and that they impose millions of dollars in net costs.5

A 2018 paper examining the impact of market-based moratoria in Australia noted that:

The environmental opportunity costs from delaying the adoption of GM canola in Australia include

an additional 6.5 million kilograms of active ingredients applied to canola land; a 14.3% increase in environmental impact to farmers, consumers and the ecology; 8.7 million litres of diesel fuel burned; and an additional 24.2 million kilograms of greenhouse gas and compound emissions released. The economic opportunity costs of the SEC-based moratoria resulted in foregone output of 1.1 million metric tonnes of canola and a net economic loss to canola farmers' of AU$485.6 million.6

NSW Farmers does not wish to inappropriately influence another state's regulatory process, and we provide the preceding comments as an overview of the GM experience in NSW. However, as a matter of principle, we believe it is fundamentally important that all growers have choice in relation to their farming

systems and that jurisdictions respect the independent scientific assessment of the Office of the Gene Technology Regulator. We support the adoption of these principles across Australian agricultural industries.

Yours sincerely,

David Mailler Chair — Agricultural Science Committee NSW Farmers' Association

5 ibid., p 280 6 Biden, Scott; Smyth, Stuart and Hudson, David (2018). "The economic and environmental cost o f delayed GM crop adoption: The case o f Australia's GM canola moratorium." GM Crops Food. 2018; 9(1): 13-20.

NSW Farmers' Association ABN 31 000 004 651 PO Box 459 St Leonards NSW 1590 Level 4 154 Pacific Hwy St Leonards NSW 2065

Member Service Centre 1300 794 000 T 02 9478 1000 F 02 8282 4500 www.nswfarmers.org.au