TEN NEW Irish Sugar Beet Planting Trials?
MAKING A SUBMISSION TO THE (Irish) E.P.A.
Genetic Concern 3feb98

U.S. Multinational Monsanto has applied to the EPA for licenses to carry out planting trials on genetically engineered sugar beet around the country. Please make a submission and help us stop these trials. The public (including those outside Ireland) can make a submission to the EPA by February 18th objecting to the trials.

THE SUBMISSIONS MUST ARRIVE WITH THE EPA BY FEBRUARY 18TH OR THEY WILL BE INVALID.

• By e-mail to t.mcloughlin@epa.ie
• By Fax: +353-53-47119
• By Letter To The Environmental Protection Agency, Ardcavan, Co. Wexford, Ireland.

We have outlined some of the reasons why you might want to object - hopefully you may have a few more of your own. Either way, please make a submission to the EPA as soon as you can.

The trials are planned for the following locations;

• Co. Cork; - Shanagarry (Midleton), Belgooly (Kinsale), Brough (Doneraile) Grange (Buttevant)
• Co. Tipperary: Knocknaboher (Cahir),
• Co. Meath: Tankardstown (Navan), Thomastown (Dunshaughlin),
• Co. Wexford: Arthurstown (New Ross),
• Co. Kildare: Dairyfarm (Castledermot)
• Co. Carlow: Teagasc, Carlow.

The trials are to test sugar beet which has received genes from bacteria, viruses and a flower. The genetic changes render the beet immune to RoundUp, a weed-killer manufactured by Monsanto. If approved for commercial planting, this would lead to increased reliance on RoundUp as a single weed-killer. It would also enable Monsanto to enforce contracts on farmers which are already in use in the U.S.A. where farmers must pay Monsanto a technology fee, as well as a premium price for the seed. The farmer would be expected to use Monsanto's brand of weed-killer, and would be forbidden to save seed for future crops.

There are many risks associated with the trial, and we have outlined these below. There has been no public debate or Dail debate on whether Ireland needs or wants genetic engineering in its food and agriculture.

Write to politicians - If you are in Ireland, you may also want to write to your local T.D.s, and to the Minister for the Environment, Noel Dempsey. You can write to them at Dail Eireann, Kildare Street, Dublin 2. You might like to remind them that Joe Walsh and Noel Dempsey of Fianna Fail in a pre-election press release promised to implement a moratorium on planting genetically engineered crops in Ireland. They are now Ministers for Agriculture and the Environment respectively. Since their election, both have ignored requests for a meeting with Genetic Concern.

The following are some of the grounds on which you might wish to object. Don't feel you have to use all of them! Simply choose a few that you identify with and make a presentation to the EPA on the basis of those points, as well as anything else you can think of. We have a circular "objection letter". If you would like a copy of this, please let us know.

What the law says

Section 33(4) of the Irish GMO Regulations (1994) state that "The Agency shall not consent to a deliberate release unless it is satisfied that the deliberate release will not result in adverse effects on human health or the environment". Therefore the law provides a very strong test which the EPA must believe is met by Monsanto. Monsanto's World-wide Reputation

The EPA should not accept Monsanto's information at face value. Monsanto has a dreadful reputation for environmental pollution. They and their subsidiaries have been the subject of a number of investigations concerning fraudulent and misleading research presented to regulators such as the U.S. EPA and the FDA which under-estimated the risks associated with their products.

Ask the Irish EPA if they know of Cath Jenkins in the U.S. EPA and her findings which showed that Monsanto's research on dioxin had intentionally mixed up study victims who had been exposed to dioxin with those who had not.

Ask if they know that Eric Miller and Erik Millstone in the U.K. found that research presented recently to the U.K. Ministry for Agriculture, Food and Fisheries had errors and misleading summaries which negated the risk to cattle from using Monsanto's genetically engineered bovine growth hormone.

Ask the EPA if they know that a Monsanto subsidiary, Searle, obtained approval for aspartame in the U.S., even though rats in feeding trials suffered brain tumours. The tumours were operated on and the rats were returned to the trial without the matter being included in the final report.

Ask the EPA if they have studied information widely available on the internet about Monsanto. Ask them to check out sites such as Monsanto in the McSpotlight, or Rachel's Environmental & Health Web Site http://www.monitor.net/rachel/

Effects on the Environment not Assessed.

Trials in other countries have not included proper Environmental Impact Studies in their protocols. Yet such trials are claimed as safe because no adverse effects were detected. Ask the EPA to find out what tests were carried out to support these claims. Court Case Still Pending

The Judicial Review into last year's granting of a license by the EPA has not been heard as yet. In granting leave to seek a Judicial Review, Justice O'Sullivan said that there was a substantial case to be heard.

We believe that the EPA should not consider any more license applications until that case has been heard. With current delays in the courts, it is quite possible that a license would be granted and plants in the ground before the courts have had an opportunity to consider the safety of these trials.

Location secrecy

Monsanto in their 1997 application asked that the identity of farmers on whose land trials were to be conducted remain confidential. On that occasion, the EPA refused to grant confidentiality, as a result of which Monsanto pulled out of two of their three proposed trials.

At the time of writing we have been told that a number of aspects of the application are confidential, which we understand includes location.

We all have a right to know if experiments are being carried out on neighbouring farms. Such attempts at secrecy are not acceptable in a world which increasingly demands transparency.

Monsanto's demands for secrecy are thought to be to prevent protesters from damaging their crops. In 1997, four Monsanto tests in Germany had to be cancelled because the fields were occupied by protesters. Ireland should not be host to experiments which are so controversial that they require a secret location.

Genetic Ingredients Unknown

In their 1997 trials, Monsanto insisted that the plasmid map containing vital information about gene sequences be kept confidential for commercial reasons. This sort of information must be available to the public if they are to make a proper submission on the proposed release. Ask the EPA for a copy of the plasmid map, and see if they will let you have this.

UNPREDICTABLE SIDE EFFECTS

Taking alien genes from bacteria or viruses and inserting them into plants is not a natural means by which plants can evolve in nature. Such genes may behave differently and cause unexpected side-effects in their new host plant. Nobody knows what these side-effects may be, so they will only be detected in the light of experience. Nobody can test for a side effect if they don't know what they're looking for.

Insertion of these genes may cause other side effects or "position effects" because they affect neighbouring genes and their activities.

Escape of Genes.

Genes travel from plant to plant through pollination. This is how evolution has developed new varieties of plants for millennia. If genes which cause side-effects escape into other neighbouring weeds, there will be no way of reversing the error. Ragwort is a weed which escaped into nature from a botanical garden, but at least is can easily be seen and removed. We would have no way of knowing genetically engineered weeds from their traditional relatives, so the process is irreversible.

Some of the trials are located near coastlines where weedy sea-beet could cross-pollinate with pollen from the trial site should such pollen escape.

Who is liable?

If something goes wrong with these trials, A gene spill could not be cleaned up. Who would pay? Austria has introduced regulations which would make the company carrying out genetic engineering liable for compensation of any damage which may arise as a result of trials. Ireland appears to have no such protection.

Antibiotic resistance genes used.

In the process of developing these plants, genes are used which make an organism immune to antibiotics. There are real risks that these genes will not break down and can be transferred to more harmful diseases via bacteria in the stomach of insects or small animals which graze on the sugar beet.

Monsanto may claim that these genes no longer exist in the plant, but many scientists do not accept that this is so. It is possible for example for genes to exist and not be detected because they have become dormant. Dr. Ricarda Steinbrecher, a U.K. based geneticist has submitted a report in the injunction proceedings of Watson vs. EPA and Monsanto PLC in which she disputes claims by Monsanto that the antibiotic resistance genes cannot be present.

Genetic Engineering is not natural

In normal breeding, similar plants or animals breed and exchange genes with each other. You cannot cross a dog with a cat, or a daffodil with a cabbage. Genetic engineering enables genes to cross the species barrier enabling cross-breeding - even between different types of organism. Scientists can thus take genes from a virus and a bacteria for example and insert them into the sugar beet.

This is not a natural system of breeding, and we do not know what the effects may be over the years. Nor do we know the effects of eating produce from such cross-breeding. If genetic engineering is allowed to continue in its present form, we will have few seeds left which have not been contaminated with genes from alien organisms. This must be stopped at every point until the risks and side-effects have been fully assessed.

Effect on Soil Micro-Organisms.

A single teaspoonful of soil may contain as many as 100,000 different living micro-organisms. Some genes used in genetic engineering are even sourced from such organisms. There has been no study into the effects of genetically engineered crops on soil micro-organisms, or to establish what happens to this new genetic material when it breaks down in the soil.

Rabbits may graze on the beet.

In Monsanto's Carlow trials, there was no fence erected to prevent rabbits or other wild animals from grazing on the trial site. Since rabbits are part of the human food chain, human health effects need to be taken into consideration. No feeding trials have been conducted on the GE sugar beet.

Birds may fly away with the seed

Darwin in "The Origin of the Species" specifically states that beet plants are disseminated by birds who eat the seed and carry it to another site. Beet seeds can survive in the stomach of a bird and are planted complete with manure at their destination. The Carlow trial did not include any bird netting to prevent such dissemination.

Ethics

Genetic engineering is a science which interferes with the very building blocks of creation. Do we have the right to do this? In a country which has held numerous referenda on other ethical issues such as abortion and divorce, is it right that we allow scientists to tamper with creation in such a manner? Some ethicists would see such tampering with nature as a blasphemy.

The Power of Multinationals

Monsanto's declared intention is to have control over seed supply of the world's major staple foods. In the last year they have bought up several small seed companies to strengthen their hold on the market. Soon the majority of the worlds seeds will be controlled by just a few giant multinationals. Genetic Engineering and the granting of patents on such seeds facilitates this monopoly

Reduced Bio-diversity

Ireland from its famine times should know the risks of over reliance on a few strains of a particular plant. Bio-diversity ensures a range of versions of a plant which may be immune to different pests, fungi or climatic conditions.

Genetic Engineering reduces bio-diversity by reducing the number of varieties of seeds which will be planted. The expense involved in producing a new genetically engineered variety will inevitably mean fewer varieties available to farmers.

This is a Primitive Form of the Technology

Genetic Engineering is at a very early stage of its development. It is unreliable and unpredictable compared to methods currently being developed. Multinational companies have invested heavily in research and are rushing products to the market as soon as they have a plant in which genetic engineering has produced the desired traits from a financial point of view.

Thirty odd years ago, the nuclear industry produced power stations as soon as they found a system which worked (i.e. produced electricity). These early Magnox reactors have turned out to be particularly dangerous, and the cheap electricity they promised came with so many side-effects that they have become a terrible liability in the end.

The similarities between how industry utilised splitting atoms, and how industry now proposes to split DNA are quite disturbing. Such a rush to gain financial returns on research must not be allowed to happen with genetic engineering.

Premium Prices Paid For Non-Engineered Crops.

Many consumers do not want to buy genetically engineered foods. On the Rotterdam spot market, there is a 10% premium for soya beans that are not genetically engineered, and as Canada had no genetech beans last year, their produce automatically obtained this premium price. Ireland, by staying out of the genetic engineering race would qualify for a price premium on its food. Already our food has a reputation of being produced in a clean environment. Why let Monsanto spoil that?

The Usefulness or Otherwise of the Trials

These trials are not necessary. There have already been many trials in other countries. The sheer number of trials planned are basically a PR effort by Monsanto to make an unsuspecting public familiar with genetically engineered crops. Monsanto say that the trials are necessary to get approval for the use of their weed-killer in Ireland, but this only requires one trial. Running ten trials increases all of the risks tenfold.

Monsanto Carelessness on other Trials.

Monsanto's trials in Holland went terribly wrong. The trial crop was harvested accidentally and the beet sent to the factory and processed into sugar and pulp The pulp has already been used for animal feed and cannot be traced. At time of writing Monsanto are awaiting a decision from the Dutch authorities on what to do with 7,000 tonnes (350 lorry loads) of sugar into which the experimental beet has been mixed.

Lack of Public Debate

There has not been sufficient (or any) public debate. In Norway, a public consensus conference was briefed by experts from various organisations and from the genetic engineering industry. The conference concluded that Norway had no need for genetically engineered foods at this time and that the risks outweighed the benefits. Norway has since turned down a number of applications for genetic engineering trials.

In Ireland, the public has had little choice in the matter. Despite public opinion, Monsanto succeeded in getting their trial consents in Carlow last year - the EPA arranged for a public debate to take place a over a month after they had given consent - they subsequently cancelled the debate.

Irelands Clean Green Image up for Sale

Genetic Engineering experiments, and biotechnology in general threaten to spoil Ireland's reputation as a green and clean country. Tourism is our second largest industry and growing fast. Any experiments which put this at risk are simply not worth it. Isolation from other Beet Crops

Monsanto's first Irish trial took place in the middle of a 50 acre field of sugar beet. Growing the test crop in the middle of a crop of commercial beet takes unnecessary risks, both of accidental harvest, and of cross-pollination.

Trials for sugar beet should be as far away as possible from other beet to reduce the risk of cross-pollination.

Why Ireland?

Why have Monsanto not attempted to conduct sugar beet planting trials in Austria? The Austrian government and regulators are deeply concerned about the risks of genetic engineering. Austrian farmers believe that the future for their small farmers in the EU is with natural and organic farming. Monsanto may well fear the scrutiny to which regulators in Austria would subject their trials. Ireland should be seeking to emulate countries like Austria who clearly consider their environment to be more important that the financial ambitions of multinationals like Monsanto.

In Austria, there were 80,000 objections to recent trials proposed by another seed company. The trials were withdrawn after five of the ten farmers pulled out.

We must seek a similar response on these trials in Ireland.

Please ask anyone you know to write by Feb. 18th to the EPA.

GENETIC COCNERN Room 13, 24-26, Dame Street, Dublin 2. Ireland
Phone +353-1-670 5606
Fax: +353-1-670 5561
ge_campaign@geocities.com