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APP201774 Submissions
28 January 2014 Under section 34 of the Hazardous Substances and New Organisms Act 1996
Volume 1 of 1 Import and release of strains of Neotyphodium; a non-sporolating
endophytic fungus
www.epa.govt.nz Page 1
Contents
SUBMISSION103680………………………… …… …………………… …… … . . . Len Parker
SUBMISSION103681……………… …………… . . .Nursery & Garden Industry New Zealand
SUBMISSION105350… … … … … … … … … … … … … … … … … . … … Wilderness Trappers
SUBMISSION106209…………………………………………………………….Christopher Bourke
SUBMISSION108115… … … … … … … … … … … … . … . … … … . Te Rūnanga o Ngāi Tahu
SUBMISSION108125… … … … … … … … … … … … … … … Foundation for Arable Research
SUBMISSION108127… … … … … … … . . … … … NZ Plant Breeding & Research Association
SUBMISSION108443… … … … … … … … … … … … … … … … … … … … … … … Cliff Mason
SUBMISSION108450… … … … … … … … … … … … … … … … … … … … . Federated Farmers
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Submission concerning EPA application number APP201774, by AgResearch - Grasslanz
to release potentially toxic Neotyphodium fungi into the New Zealand cereal grains market.
Dr Christopher Bourke, Ph D, B V Sc (hons), Dip Agric (Hawkesbury), Registered Specialist
Consultant Veterinary Pathobiologist (Toxicology), “Tintern”, Spring Terrace Road, Millthorpe
NSW 2798, Australia, 13th
December 2013. I have worked in veterinary toxicology for the past
35 years, predominantly with the consumption by livestock of potentially poisonous pasture
plants and feedstuffs containing fungal contaminants. I have published (as principal author)
more than 50 papers in peer reviewed scientific journals and more than 100 papers in
conference proceedings.
If the application by AgResearch-Grasslanz is approved by the Authority this will have
inevitable implications for the citizens of New Zealand, their pets and their farm livestock, and
could have serious consequences for New Zealand exports of human foods and animal
feedstuffs. No other country is producing cereal grains (or products made from these cereal
grains) that contain endophyte insecticidal alkaloids, why would NZ choose to contaminate its
cereal grains with these compounds?
The cereal grains grown in NZ, and throughout the world, are endophyte free consequently
endophyte alkaloid free. AgResearch-Grasslanz is applying to release wheat, barley, rye,
triticale, and oats, seed lines into the market place that contain endophyte alkaloids. The insertion
of endophyte into a plant is akin to altering its genetics because it alters the plants gene switches
hence alters the amounts of specific types of chemical that the plant subsequently produces.
Alkaloids that were present in only small amounts in “wild” endophyte infected plants for
example can suddenly be produced in very large amounts in plants inoculated with a “selected
strain” of an endophyte. We have so far seen this adverse outcome in three AgResearch-
Grasslanz products, namely: the Perennial Ryegrass plus Endosafe endophyte combination
(found after release, to produce toxicity causing ergovaline alkaloid levels which were higher
than that of ‘ wild’ endophyte), the Perennial Ryegrass plus AR37 endophyte combination
(found after release, to produce toxicity causing janthitrem alkaloids capable of causing
outbreaks of ryegrass staggers in livestock more serious than those caused by ‘wild’ endophyte),
and most recently the Mediterranean tall fescue grass plus Max P (or sometimes Max Q)
endophyte combination (found after release to produce a new form of lethal toxicity in horses,
most likely due to the very high levels of a particular loline compound that are produced by this
combination). When the AgResearch-Grasslanz new selected endophyte containing cereal grains
are harvested and processed, the flour, bran or clean grain produced will end up in the diets of all
NZ humans, their pets, and their farm livestock. Endophyte alkaloids will in this way end up in
your breakfast cereal, your bread sandwich at lunch, your cakes or biscuits at afternoon tea and
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your pasta and pudding at dinner. Endophyte alkaloids will also end up in the processed dog and
cat foods sold as pet food in the supermarket, in the various dry feed concentrates sold to horse
owners, in the feedstuffs sold for pigs, milking cows and goats, stud sheep, cattle, deer, alpacas
and poultry. They will also be in the cereal fodders grazed by all of these livestock species and
they will be in the cereal hay products that NZ currently exports to racehorse owners, dairy farms
and feedlot operators throughout south-east Asia.
The adverse risk most inadequately discussed by the applicants in their proposal, is the potential
toxicity of the endophyte alkaloid insecticides that they are proposing to contaminate NZ cereal
grains with. The applicants repeatedly call these substances “non-toxic” and “safe”, this is
misleading, these substances are more accurately described as ‘potentially toxic’ since no
comprehensive animal studies have yet been conducted to ascertain their toxic dose level in each
of the common animal species that are to be exposed to them. The literature frequently says that
various endophyte alkaloids are non-toxic or safe and then gives as a reference a piece of work in
which this assumption was stated but never tested, all the new reference does is to lead the reader
back to yet another reference that also says the substances are non-toxic or safe, but presents no
experimental data to verify this. The applicants in their current proposal are guilty of this same
misleading reference usage.
To understand the complexity of this adverse risk it is necessary to understand that toxin
sensitivity varies between animal species and this sensitivity is usually dose rate dependant. Most
alkaloids will exert toxicity in most species if a sufficiently high enough oral dose is
administered. Once this dose has been established it becomes possible to calculate how much of
the alkaloid is produced by the plant plus endophyte combination and how much of the plant will
be eaten each day by a particular animal species, from this a conclusion can be drawn as to the
maximum likely dose rate of alkaloid that will be ingested and how this relates to the known
toxic dose. In this way it will become obvious if toxicity is a risk or not. If the toxic dose for
each alkaloid were to be established in test groups of animals, representative of each major
animal species, then it would be possible to reasonably conclude what the human risk was likely
to be. There are five minimum test groups required, namely the sheep, the horse, the pig, the dog
and the chook. These groups cover the major digestive systems namely, ruminant, monogastric
herbivore, monogastric omnivore, monogastric carnivore and avian. Humans are monogastric
omnivores consequently the test results for pigs would offer a reasonable guide as to the human
toxicity risk. Rodent (mice, rats etc) toxicity data is frequently used internationally for toxicity
determinations but it provides little or no guide as to the real toxicity risk posed to other
mammalian species because rodents are notoriously tolerant of toxins. AgResearch-Grasslanz is
in a better position than anyone else to conduct this fundamental toxicity research and they have
the most to gain by it. It should be a prerequisite for the type of EPA application they are
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making. Presumably they have avoided carrying out these more comprehensive toxicity studies
because, no authority has so far required them to, they are expensive studies to conduct, they do
not produce any direct commercial dollar returns to the company, and if the results indicate
potential toxicity problems then this could prevent AgResearch-Grasslanz from pursuing the
development and release of a number of new products. Rather than constantly demanding that
other people demonstrate that the endophyte alkaloids are potentially toxic, and meanwhile
stating that they are non-toxic and safe, it would be much more reasonable to expect
AgResearch-Grasslanz itself to establish beyond any doubt what the toxic dose level is for each
alkaloid in each major animal species. After all it is AgResearch-Grasslanz that is sending these
endophyte products into the market place for their own commercial purposes.
To highlight the inadequacy of the adverse risk toxicity data provided in AgResearch-
Grasslanz’s application it is necessary to first consider an overview of the endophyte alkaloid
production principal and then to look at the individual groups of alkaloids that are the subject of
the AgResearch-Grasslanz application. Endophytes produce a limited range of alkaloids namely:
1. Ergopeptines (ergot alkaloids), typically ergovaline and ergotamine, but also the related
clavines and ergines (lysergic acid amide).
2. Lolines (pyrrolizidine alkaloids), typically formyl-loline, acetyl-loline and acetyl-norloline.
3. Pyrrolo-pyrazines usually peramine
4. Lolitrems, typically lolitrem B and paxilline, but also the related janthitrems.
When individual endophyte strains are isolated they can be selected for the different alkaloid mix
that they produce, for example a strain that does not produce ergot alkaloids can be selected but
as a consequence it would normally be expected to produce larger amounts of one or more of the
other three alkaloid types. This is the inherent danger of using selected endophyte strain
technology you run a great risk of creating new forms of animal toxicity because the new strain
may be producing large amounts of a previously innocuous alkaloid. The endophyte will always
compensate, selection pressure against one alkaloid will always result in automatic selection for
another alkaloid. For example the Max P endophyte (also known as AR542) was selected
because it does not produce ergot alkaloids or lolitrems, instead it producers large amounts of
lolines and significant amounts of peramine. The second problem with using selected endophyte
strains is that they interact with their plant host in unpredictable ways. For example the
combination Max P plus summer active strains of tall fescue grass producers small to moderate
amounts of lolines whereas the combination Max P plus winter active strains of tall fescue grass
producers very large amounts of lolines.
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Ergopeptines (ergot alkaloids)
AgResearch-Grasslanz have acknowledged that the ergot alkaloids are toxic, both to animals and
humans and the literature is full of examples of this toxicity. However, they seek to release an
endophyte strain that producers chanoclavine (a precursor of ergovaline) which they note lacks a
key structural feature of ergovaline hence would not be expected to produce the same form of
toxicity as ergovaline. They then say that they have no evidence that chanoclavine is toxic and
therefore it must not be toxic. This is an appalling conclusion, the reality is that there has never
been a comprehensive toxicity study carried out using chanoclavine and so its toxicity risk
remains unknown, it will have a toxic dose rate and this must be established. Just because it is
unlikely to intoxicate in the same way as ergovaline does not mean that it is unlikely to
intoxicate. An endophyte that produces lots of chanoclavine may be an endophyte that is going to
produce a new livestock toxicity state.
Lolines (pyrrolizidine alkaloids)
These are unusual pyrrolizidine alkaloids because a small change in their chemical structure has
meant that they are not hepatotoxic (ie liver intoxicants), most pyrrolizidine alkaloids are. In
2009 I published a paper that described a new form of intoxication in horses in Australia that had
ingested the combination Max P endophyte plus winter active tall fescue grass, it is called
Equine Fescue Oedema. AgResearch-Grasslanz argued at the time that this must be a peculiarly
Australian problem because it had not been reported in other countries where this combination
was being grown. Sometime between 2009 and 2013 AgResearch-Grasslanz conducted their own
horse grazing studies in New Zealand with this combination and on each occasion they found
that their trial horses became intoxicated in the same way as they had in Australia. They finally
agreed that the combination was toxic to horses regardless of country and so in 2013 ceased the
production and marketing of this endophyte plus grass combination (of course all of their
existing seed stocks had been sold into the market place by this time). The alkaloids produced by
Max P plus tall fescue grass are lolines and peramine, production of the latter is similar for both
winter active and summer active grass varieties. The stand out difference between winter active
and summer active plants with this endophyte is that the winter active plants produce very large
amounts of lolines and the summer active plants only produce small to moderate amounts. In
particular the combination Max P plus tall fescue grass results in the production of one specific
loline namely N-acetyl-nor-loline, and production of this alkaloid in the winter actives (being
2000 mg/kg) is at least seven times greater (Qawasmeh, Bourke, Lee et al Acta
Chromatographica 2011, 4, 621-628) than it is in the summer actives (being 286 mg/kg). The
summer actives are not toxic to horses whereas the winter actives are. AgResearch-Grasslanz has
not presented any of this data in their current application and continue to deny that these finding
are highly suggestive of a role for N-acetyl-nor-loline in this new type of horse toxicosis. Instead
they suggest the cause must be an as yet unidentified alkaloid produced by the endophyte, but
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after 5 years of work they still have no idea what this proposed new alkaloid is likely to be and
they have made no mention of it, or the toxicity risk that it would pose, in their current
application. The simplest approach that AgResearch-Grasslanz could have taken would have
been to administer an appropriate oral dose of N-acetyl-nor-loline to a group of horses and see if
toxicity occurred. One can only assume that they have either already done this and produced
toxicity which they have not reported, or that they have refused to do this for fear that it may
demonstrate loline toxicity (specifically N-acetyl-nor-loline) and this would require them to
acknowledge that lolines are not safe for mammals because they are potentially toxic to some
species at levels found in some endophyte grass or cereal combinations.
My 2009 publication (Bourke, Hunt and Watson, Aust Vet J 87:492-498) had indirectly
illustrated that whereas an N-acetyl-nor-loline fescue plant level of 2000 mg/kg dry matter was
apparently toxic to horses within 3 to 5 days of continuous grazing it was not toxic to either
sheep or cattle. Assuming the livestock dry matter intake per day was 3% of body weight and the
weight of a horse is 500kg, the daily feed intake would be 15kg hence 30,000 mg of N-acetyl-
nor-loline per day or a total of 90,000 to 150,000 mg over 3 to 5 days. This implies toxicity for
horses occurs at an N-acetyl-nor-loline oral dose of between 180 and 300 mg/kg live weight
(being 60 mg/kg live weight per day) but that toxicity for sheep and cattle would require a much
higher dose rate. A recent AgResearch-Grasslanz publication by Gooneratne et al in 2012 (NZ
Vet J, 60:176-182) gave a daily oral dose of lolines (mixture unspecified) at 68 mg/kg live
weight to six ewe lambs for six days and produced no toxic effects. This is consistent with my
observations reported in 2009 and poses the question, why when AgResearch-Grasslanz were
already aware of my findings did they not challenge their experimental sheep with a much higher
dose rate than this, to try and ascertain what is the toxic dose for sheep? One can only conclude
that they wanted an outcome that said lolines are non-toxic. In the current application
AgResearch-Grasslanz have used mice as their experimental species and found that they
tolerated a repeated daily ingestion rate of a mixture (not specified) of lolines at 415 mg/kg live
weight. When N-acetyl-nor-loline or N-acetyl-loline were specifically administered, mice
tolerated up to 2000 mg/kg live weight, but with N-formyl-loline deaths started to occur at this
same dose rate. These findings would suggest that whereas horses are intolerant of lolines
rodents are very tolerant of them, with sheep and cattle presumably being somewhere in
between.
Pyrrolo-pyrazines (Peramine)
My 2009 publication had indicated that peramine levels of from 6 to 26 mg/kg dry matter occur
in tall fescue grass inoculated with the Max P endophyte. These are low levels of alkaloid and
unlikely to pose a toxicity risk. Even at a plant level of 30 mg/kg, the daily peramine intake rate
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in a 500kg horse would have been less than 1 mg/kg live weight. Sheep and cattle had also
grazed the same pastures without any signs of peramine toxicity hence were safe at this dose
rate. Likewise AgResearch-Grasslanz in 1995 administered a peramine oral dose rate of 0.8
mg/kg live weight daily (ie 40mg to a 50kg animal) for seven days to a group of 4 wether lambs
and found no toxic effects which is consistent with my observations. More recently AgResearch-
Grasslanz administered peramine at 2000 mg/kg live weight orally to mice (number not
specified) with no apparent toxic effects. Rodents are in general very tolerant of toxins, it would
have been more meaningful if sheep or horses or pigs or dogs or poultry had been used as the test
species for this much larger dose rate.
Lolitrems and janthitrems.
Selection for endophyte strains that do not produce lolitrems inevitably risks selection for strains
that produce related chemical groups such as janthitrems and terpendoles. In the current
application terpendole E has been nominated as a new potential toxin. A structural change in this
compound compared to that of lolitrem B would indicate it is unlikely to have a tremorgenic
effect at any dose rate. However the potential toxicity otherwise of this compound remains
untested. AgResearch-Grasslanz have tested it in mice (number unspecified) at a dose rate of
8mg/kg live weight and found it to be “non-tremorgenic”, but they did not specifically state no
toxic effects at all. This compound needs to be tested in a range of animal species at higher dose
rates than this to establish what its potential for toxicity is.
Conclusion Under section 36 of the NZ environmental protection act the Authority is required to
decline an application to release new organisms if they are likely to cause any significant adverse
effects on human health and safety, or if they are likely to cause disease in, be parasitic to, or
become a disease vector for, animals. The toxicity data provided by the applicant is insufficient
to support beyond a reasonable doubt either of these minimum standards. In addition, under the
adverse risks section of the application the applicant has failed to declare all of the adverse
toxicity risk information that either they have in their own records or that others have published
on this subject in the scientific literature. The toxicity studies of AgResearch-Grasslanz are rarely
published in peer reviewed scientific journals consequently they are rarely assessed by other
scientists who do not have the same commercial conflict of interest that exists within
AgResearch-Grasslanz. Extensive toxicity studies using endophyte alkaloids in a range of
common animal species at increasing dose rates are urgently required, this company should be
obliged to carry out these studies and to have their results peer reviewed and published in the
mainstream scientific literature. It is in everyone’s long term interests, including those of
AgResearch-Grasslanz, for this to happen.
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
He tono nā
ki te
ENVIRONMENTAL PROTECTION AUTHORITY
e pā ana ki te
EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
17 December 2013
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
Contents
1. EXECUTIVE SUMMARY
2. TE RŪNANGA O NGĀI TAHU
3. TE RŪNANGA STATEMENTS OF POSITION ON APP201847
4. RECOMMENDATIONS
Chloe Rapson
Business Support Administrator I Te Rūnanga o Ngāi Tahu
[email protected] I Phone 03 397 40005 I PO Box 13-046 I Christchurch
Request to be heard Te Rūnanga o Ngāi Tahu wishes to appear to speak to this response.
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
1. Executive summary
Te Rūnanga o Ngāi Tahu has consistently urged a reduction in the use of
environmentally harmful agrichemicals and pest control tools and encouraged the
development of new technologies aimed at limiting the deployment of such toxins.
Innovative endophyte-containing ryegrasses have already achieved this in the
pastoral sector. We consider that the development of pest and disease resistant
endophyte-containing cultivars of key cereals will not only have production and
economic benefits for the arable sector - which includes Māori farming enterprises -
but will significantly reduce the use of synthetic chemicals in arable cropping. At the
same time, we are cautious regarding the public acceptability of cereals containing
these endophytes entering the human food chain and urge the researchers to
openly address the issue with the wider public.
We are also unsure of the stability of plant/endophyte associations, and the
possibility of the unexpected production of mammalian-toxic secondary metabolites,
such as ergovaline.
We support the release of the Neotyphodium endophytes from containment.
2. Te Rūnanga o Ngāi Tahu
2.1 This response is made on behalf of Te Rūnanga o Ngāi Tahu (Te Rūnanga). Te
Rūnanga is statutorily recognised as the representative tribal body of Ngāi Tahu
Whānui and was established as a body corporate on 24th April 1996 under
section 6 of Te Rūnanga o Ngāi Tahu Act 1996 (the Act). We note the following
relevant provisions of our constitutional documents:
(a) Section 3 of the Act States:
This Act binds the Crown and every person (including any body politic or
corporate) whose rights are affected by any provisions of this Act.
(b) Section 15(1) of the Act states:
Te Rūnanga o Ngāi Tahu shall be recognised for all purposes as the
representative of Ngāi Tahu Whānui.
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
(c) The Charter of Te Rūnanga o Ngāi Tahu (1993, as amended) constitutes Te
Rūnanga as the kaitiaki of the tribal interest.
2.2 Te Rūnanga respectfully requests that this response is accorded the status and
weight due to the tribal collective, Ngāi Tahu Whānui, currently comprising over
49,000 members registered in accordance with section 8 of the Act .
3. Te Rūnanga statements of position on APP201835
3.1 General comments
Ngāi Tahu holds concerns over the longstanding and widespread use of toxic
chemicals and other agrichemicals in the horticultural and agricultural sectors. At the
same time, we recognize the need to tackle those weeds, pests and diseases which
reduce the efficiency and profitability of the farming sector. The consistent position
that Ngāi Tahu has taken over the years is: first, to reduce if not eliminate the use of
these chemicals and the resulting potential environmental contaminations that they
cause, and, second, to support the development of alternative less environmentally
damaging pest control strategies.
3.1.1 Endophytes and pest management
The development of pest resistant pasture grasses through the utilization of
endophytic fungi has transformed pastoral farming, at least from the pest
management point of view. As the applicant explains, pest-resistant ryegrass and
fescue cultivars have been incorporated in pastoral systems for some years with
considerable benefit to production, reduced use of pesticides, and no apparent
adverse effects. The present application seems to us to offer similar benefits to the
arable sector.
3.2 The proposal
We find that while the application explains the big picture of the development and
use of the cereal/endophyte associations at some considerable length, it does not
adequately detail the actual objectives of the applicant envisaged by the release
from containment, i.e. just what material is to be taken out of containment should the
application be approved. Some discussion with the applicant was needed to
ascertain that it will be living plants (or their seeds) containing one or other of the
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
numbered 45 fungal strains which will be released from containment (John Caradus,
pers. comm.). And we understand that at present the only infected plants to be
removed from containment will be rye corn – it has not yet proved possible to insert
the endophyte into other cereals of interest.
3.2.1 Human food chain
Rye corn is not likely to enter the food chain. However, the applicant has explained
that a key objective is to infect wheat and barley with one or other endophyte, in
order to protect these species against pest or fungal attack (John Caradus pers.
comm.). Discussion has clarified that cereal/endophyte associations which lead to
the production in the plant of the bioactive loline will be a focus of the research.
While we accept the published evidence that the metabolites peramine and loline
are not toxic to mammals, there is nevertheless an issue regarding the long-term
aim of producing for human consumption wheat and barley, and possibly rye and
oats, containing such bioactives. It is an issue which should have been explicitly
addressed in the application, but which was not. To date, only farmed animals have
been fed peramine- or loline-containing grasses and these have been shown to be
safe. But we can foresee objections to the production of loline-containing cereals for
human consumption, and suggest that research on public attitudes to this form of
modification of staple human foods be undertaken. The trade-off for the consumer,
of course, is a more sustainably-produced food, grown with a much-reduced
dependence on toxic agrichemicals.
3.2.2 Stability of secondary metabolite production
We note that many of the endophyte strains produce chanoclavine (see pp. 6-7).
This metabolite is not itself toxic to livestock and so is not, presumably toxic to
humans (p. 17). However, it is an intermediary in the ergovaline pathway, and
ergovaline is a known human toxin (ergot poisoning) (p. 17). This raises in our
minds the possibility that plant/endophyte associations that are reported as being
‘safe’ and not producing mammalian-toxic metabolites, might suddenly change and
begin to do so. The question is one of the stability of the secondary metabolite
production. The application says nothing about this matter, which seems to us to
require further discussion and/or research.
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EPA APPLICATION APP201774 – Release of Neotyphodium endophytes.
3.2.3 Impacts on Māori
We note the information in the application resulting from the applicant’s engagement
with Māori organisations. We support the matters raised by Te Rūnanga Ō Te
Aupouri and Ngāti Whātua Ōrakei, and consider that the applicant’s responses dealt
adequately with them. We do not consider that there will be a negative impact on
native species or ecosystems; rather there is likely to be a benefit from the reduction
in the use of pesticides (as noted by Te Rūnanga Ō Te Aupouri).
Māori arable farmers should be able to gain productivity gains and economic benefit
from the newly-created cereal cultivars, as Māori pastoral farmers have from the
endophyte-containing ryegrass cultivars.
4. Recommendation
Te Rūnanga o Ngāi Tahu supports the release from containment of non-toxic
Neotyphodium fungi.
We would like our submission to be heard.
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APP201774
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Nick Pyke
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Foundation for Arable Research
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2
Submission Form
September 2012 EPA0190
I support the application
I oppose the application
I neither support or oppose the application
The reasons for making my submission are1:
The Foundation for Arable Research strongly support this application. This technology is proven in forage grasses in New Zealand and in cereals this technology has significant potential to reduce the use of agrichemicals in cereal growing and increase yields not only in New Zealand but also internationally. This technology represents the only potentially viable and sustainable method of managing some key pests in cereals (eg nematodes). Endophyte technology is probably the only new or novel method internationally that is being developed for pest, disease and stress management in cereals. The resarch team are of extremely high calibre and are world leading in their field thus any research undertaken on endophyte in cereals will be of high quality.
I wish to be heard in support of my submission (this means that you can speak at the hearing)
I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing)
I wish for the EPA to make the following decision:
Allow release of the organism in New Zealand.
1 Further information can be appended to your submission, if you are sending this submission electronically and attaching a file we accept the
following formats – Microsoft Word, Text, PDF, ZIP, JPEG and JPG. The file must be not more than 8Mb.
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11 December 2013 Graham Young Environmental Protection Authority Private Bag 63002 Wellington 6140 By email: [email protected] Dear Mr Young
New Zealand Plant Breeding and Research Association submission on the Application for fungus to protect annual cereal crops (APP201774)
I am writing on behalf of the New Zealand Plant Breeding and Research Association in response to the Environmental Protection Authority invitation to the public to make submissions on the Application for fungus to protect annual cereal crops (APP 201774). The Association represents plant breeders, intellectual property owners and marketers of proprietary seed. The Association’s members include: Cropmark Seeds Ltd, DLF Seeds Ltd, Genetic Technologies Ltd, Germinal Seeds NZ Ltd, Grasslanz Technology Ltd, New Zealand Agriseeds Ltd, PGG Wrightson Seeds Ltd and Seed Force Ltd. The Association is an active champion of a regulatory environment favourable to research into, development of and trialling of new plant technology considered to be of potential benefit to New Zealand primary industries. The Association also champions greater freedom to import and use new plant material, within the boundaries of New Zealand’s biosecurity measures, that is not detrimental to this country’s human health, environment or international obligations and is considered to be of potential benefit to the New Zealand primary sector. The Association supports the Application (APP 201774) The Association wishes to express its support for the Application (APP 201774) made by Grasslanz Technology Ltd and AgResearch Ltd.
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The Association considers that the release of the endophytic fungus, Epichloe/Neotyphodium could confer important advantages for cereal crops against insect pests, disease and drought. The endophyte genus Neotyphodium has already proven to be of significant economic benefit to New Zealand farmers through enhanced pasture productivity and animal performance. Use of Epichloe/Neotyphodium in cereal crops has the potential to continue improving New Zealand production as well as reducing pesticide use. The Neotyphodium genus that a number of our members are researching is contained within the host plant. Transfer from the host to other plants is considered extremely unlikely under natural conditions and only occurs in the laboratory with considerable difficulty. The Association urges the EPA to seriously consider and approve the release of Epichloe/Neotyphodium. Yours sincerely Thomas Chin General Manager
NZ Plant Breeding & Research Association 185 Kirk Rd, Templeton, Christchurch P.O. Box 8605, Christchurch, 8440 Phone: + 64 3 341 6059 Fax: +64 3 341 6060 cell: +64 021 679 989
email: [email protected] website: www.nzpbra.org
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Once you have completed this form
Send by post to: Environmental Protection Authority, Private Bag 63002, Wellington 6140
OR email to: [email protected]
SUBMISSION FORM
www.epa.govt.nz
Once your submission has been received the submission becomes a public document and may be made
publicly available to anyone who requests it. You may request that your contact details be kept
confidential, but your name, organisation and your submission itself will become a public document.
Submission on application
number:
APP201774
Name of submitter or contact for
joint submission:
Dr Cliff Mason
Organisation name
(if on behalf of an organisation):
N/A
Postal address:
Telephone number:
Email:
I wish to keep my contact details confidential
The EPA will deal with any personal information you supply in your submission in accordance with the Privacy Act
1993. We will use your contact details for the purposes of processing the application that it relates to (or in
exceptional situations for other reasons permitted under the Privacy Act 1993). Where your submission is made
publicly available, your contact details will be removed only if you have indicated this as your preference in the tick
box above. We may also use your contact details for the purpose of requesting your participation in customer
surveys.
The EPA is likely to post your submission on its website at www.epa.govt.nz. We also may make your submission
available in response to a request under the Official Information Act 1982.
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Submission Form
September 2012 EPA0190
I support the application
I oppose the application
I neither support or oppose the application
The reasons for making my submission are1:
The release from containment of any organism that is new to the New Zealand environment is an act of such biological significance that it warrants the utmost caution and the strongest justification. I find the Application wanting in certain respects in both of these areas.
Unassessed Risks
The risk of these Neotyphodium strains escaping from their biological confinement seems very small. The evolution of these asexual endophytes is thought to have involved superinfection of the host and subsequent intrahost hybridisation. Such a process clearly provides a potential route for the acquisition of the ability for stromal growth and dispersal by means other than direct vertical transmission. There is no assessment of the possibility of such events occurring. This would presumably require the infection of the host plant by a species that is competent in horizontal transmission. To assess the risk of this process occurring, there needs to be information about the presence of such competent organisms in New Zealand; the membership of the 'epichloae' in NZ. The phylogenetic uncertainties in this group of fungi means that such a wide range must be considered.
There is also the requirement for effective transmission of a competent endophyte to the host plants. The assessment of this element of a potential risk pathway requires information not only about the ability of competent epichloae to colonise the crop plants directly (probably nonexistent) but also and more importantly about the presence of potential vectorssuch as aphids, the range of plants used by these vectors and the presence of epichloae in this feeding range.
This is a very large information requirement, but without at least this, the sustained biological confinement of the endophytes that is fundamental to the safety of their release cannot be assumed.
Unjustified claims of benefit
The major benefit claimed for the release of endophytes is the reduced use of chemical pesticides that will result. This is a highly questionable claim, largely because of the unrealistic assessment of the agronomic situation in which the agent will be employed. There is an unsupported assumption of proportionality between the reduction in pest damage that can be achieved in the presence of the endophytes and the reduced use of pesticides. I contend that because of the economic pressures to maximise production volume and quality, pressures that a market economy ensures are unrelenting, there is unlikely to be any significant reduction in pesticide use because pest damage is not eliminated but only marginally diminished by the presence of the endophytes. Empirical evidence of sustained reduction in pesticide use in arable farming as a result of a marginal reduction in pest damage by non-chemical means is required to justify this claim.
Furthermore, the Application includes a graphical representation of growth in arable sector production in NZ. If this growth is sustained, it will in itself overwhelm any small reduction in pesticide use that might occur; the total quantity of pesticides released into the environment will increase.
The main benefit in reduced use of pesticides is presented as being from reduced insect damage and insecticide use. The figures given in the Application indicate that arable use of fungicide is an order of magnitude greater than that of insecticides. The evidence for reduced damage from fungal pathogens in the presence of endophytes is relatively scant and the agronomic effect not well established.
The proposed benefits in crop plant physiology (drought tolerance, yield increases) seem highly conjectural.
1 Further information can be appended to your submission, if you are sending this submission electronically and attaching a file we accept the
following formats – Microsoft Word, Text, PDF, ZIP, JPEG and JPG. The file must be not more than 8Mb.
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Submission Form
September 2012 EPA0190
I accept that some of these agronomic effects can only be well assessed following release and large scale use of the endophyte-crop plant association. However, if benefits are to be considered in the deliberations of the EPA, they need to be supported by documentary evidence and more convincing than is presently the case.
In summary, I believe that the risks of uncontrolled spread of these organisms has not been comprehensively assessed and the benefits have not been accurately represented. Unless these deficiencies can be addressed, the Application should be rejected.
I wish to be heard in support of my submission (this means that you can speak at the hearing)
I do not wish to be heard in support of my submission (this means that you cannot speak at the hearing)
I wish for the EPA to make the following decision:
Reject the Application
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