26 March 2012

Open letter to Teagasc Director

Dear Dr Boyle

I’m writing this letter to you in the context of Teagasc’s recent application to EPA for a licence to grow GM potatoes in trials at Oak Park.

It is universally accepted that transgenic organisms (this definition is inclusive of cisgenic organisms) can have unpredictable effects. This is the risk which underpins my concern regarding the recent Teagasc licence application. Unfortunately, the GM regulatory system in place has not accommodated a full public discussion of the issues relevant to GM technology and its introduction to Ireland.

To put a solution forward, as Teagasc has done, when it appears the problem has not yet been properly defined, is highly questionable. Particularly so, when that solution involves releasing a plant (by its very nature capable of reproducing itself and therefore ‘uncontrollable’ in nature) into a field, appears not to take the national interest into account. As such, such a solution is simply indefensible.

There are aspects other than farmers’ current use of ‘up to 20′ fungicide sprays per crop to be considered regarding potato cultivation in Ireland. Ironically, the Irish Times of 17 March noted a current over-production of potatoes in this country which further indicates the problem is not quite as straightforward as Teagasc’s stated position suggests.

My request is this: For Teagasc to explicitly state ALL the reasons it is doing the research at Oak Park described in its EPA licence application on GM potatoes.

I hope that when the information requested is in the public domain, there can then be a full public discussion about the issue and all of its implications.

Meanwhile, perhaps Teagasc would consider withdrawing its licence application so that the public discussion can take place without the immediate threat of a GM potato planting at Oak Park.

If you have any queries about any of the above do not hesitate to contact me.

Yours sincerely

Stella Coffey

CC

• Uachtarán na hÉireann
• An Taoiseach
• An Tánaiste
• Minister for Health
• Minister for Environment, Community and Local Government
• Minister for Agriculture, Food and the Marine
• Environmental Protection Agency
• MRFCJ: Mary Robinson Foundation for Climate Change Justice

The capacity of newly-minted language to confuse comes into sharp focus when one considers GM crops, whose defining feature is that they contain a gene transferred from another species by genetic engineering. Species can be usefully defined as a group of organisms all of whose members are capable of interbreeding and producing fertile offspring. So, the kind of ‘transgenic’ jump involved in the production of GM crops is not something which could ever happen in nature.

Click here to read this article as it was published in the Irish Times.

It is only in the past 20 years or so that GM/transgenic crops have existed – an invisible blip on the evolutionary timeline of 1.2 billion years since sex evolved. Essentially, the normal scale of evolutionary change in organisms has been completely overwritten by GM technology and we simply do not know what the long-term effects might be.

The first GM/transgenic commercialised crop, a tomato, hit the US in 1994 and today GM/transgenic maize, soy and canola make up a considerable portion of the food supply, primarily through animal feed. None of these crops were independently tested before their release on the US market. Not surprisingly, controversy dogged GM/transgenic crops and food and its commercialisation and, as more people became aware of the issues, it became hotly contested.

The EU door to GM/transgenic crops has been difficult to prise open. It was in the face of such opposition that the promoters of the GM industry seized upon the concept of ‘cisgenic’, a word that was literally invented in the course of a PhD thesis submitted to Wageningen University in 2004. Cisgenic is said to describe close relative breeding. It is a clever word in this context, what with its scientific connotations of opposites or mirror images, one labelled with the prefix cis- and its mirror image labelled trans-. From this usage in science, ‘cisgenic’ suggests itself to be the opposite of transgenic. Once the c-word, cisgenic, appeared in refereed journals – despite being challenged by fellow-scientists – it gained scientific currency and, by extension, began to be seen as a potential key to open the door which the EU had virtually closed to GM crops.

However, cisgenic is a classification subset of transgenic, that is, cisgenic clearly involves genetically engineered transferral of a gene from a different species and is unequivocally transgenic. It is the transformation process, not the source of the transferred gene, that gives rise to unpredictable effects. Cisgenic involves, in the case of the Teagasc GM potato, an Agrobacterium tumescens-mediated gene insertion with a vector, all of which contribute to unpredictable effects of the transgenic process.

Meanwhile those Wageningen University creatives set up a train of events to get cisgenic crops de-regulated so they could be grown complying with GM regulations. For all biotech supporters, the pototo is a perfect GM-vehicle, a veritable Trojan Horse, what with its cultural resonance throughout northern Europe, and the fallout from a new virulent blight strain. The Wageningen group’s initiative secured European Commission support to the extent the European Food Safety Authority published a scientific opinion on matters cisgenic in mid-February this year. One commentator dubbed these events and their results as ‘political science’.

Significant corporate involvement is evident in these EU potato circles to those who look carefully. For example, Wageningen University’s plant section got €16.2 million from industry in 2006, viz.13% of its total budget. All of this is closely relevant to Teagasc’s licence application to Environmental Protection Agency to grow GM potatoes. Teagasc’s application uses the term ‘cisgenic’ 48 times. However, and crucially, it does not at any point define the term. The observed, documented and widely acknowledged reality is that transgene technology is likely to cause unpredictable effects, i.e. effects that wouldn’t occur in many types of traditional breeding. We simply don’t know enough to know that these crops are safe. Haven’t we learned enough ‘late lessons’ on issues such as asbestos and PCBs, to be cautious in this case?

One of the side effects of having GM potatoes trialled here is the ‘thin end of the wedge effect’. The Teagasc GM potato will have established the GM precedent here, undermined consumer opposition and the EU door will be wide open to GM canola, maize, wheat and other food crops. Ireland, whose island nature gives scope to avoid cross-border GM contamination, is one of the few remaining EU countries not growing GM crops, so the Teagasc GM potato trial represents a hugely significant development.

The commercial and institutional interests which promote GM foods frequently cite/exhort us to take a scientific approach to their products and research. However, if the scientific method teaches us anything it is to adopt a healthy scepticism. The deadline for objections to Teagasc’s licence application is March 27. Rather than becoming cheerleaders for a risky questionable technology, perhaps now would be a good time to exercise our skepticism.

To expand language, according to the psychologist David Myers, is to expand the ability to think – to which one might add the caveat: except when the effect of such expansion is to generate confusion and ambiguity.

Click here to read this article as it was published in the Irish Times.

The capacity of newly-minted language to confuse comes into sharp focus when one considers the development and promotion of GM crops whose defining feature is that they contain a gene transferred from another species through genetic engineering. Species can be usefully defined as a group of organisms all of whose members are capable of interbreeding and producing fertile offspring. So, the kind of ‘transgenic’ jump involved in the production of GM crops is not something which could ever happen in nature.

It is difficult to convey a sense of the change involved in this jump. Agriculture’s 10,000 year history of selective breeding of food crops is only a grain of sand in the time since organisms starting reproducing sexually an estimated 1.2 billion years ago. It is only in the past 25 years or so that GM/transgenic crops have existed – an invisible blip on the evolutionary timeline. Essentially, the normal scale of evolutionary change in organisms has been completely overwritten by GM technology and we simply do not know what the effects of this might be, especially in the longterm.

Meanwhile history has some salutary lessons for us regarding unpredictable outcomes of industrial progress: from first warnings of risk to a complete ban becoming effective has taken 107 years for asbestos, 51 years for antimicrobials used as growth promoters, 42 years for PCBs, 65 years for radiation, according to a European Environment Agency (2001) report.. According to its case study analyses, the delays resulted from institutional failure, compromised science and industry pressure, and have caused irreversible environmental damage and a long toll of human illness and death.

The US biotech industry involved in developing the first GM/transgenic crops and bringing them to market, worked closely with US politicians: Vice-President Quayle’s Council on Competitiveness featured strongly. Political interest in revitalising an ailing US economy brought biotech interests and politicians together on committees to pave a fast route to market. The first GM/transgenic commericialised crop, a tomato, hit the US in 1994 and today GM/transgenic mainfood crops of maize, soy and canola make up a considerable portion of the food supply, primarily through animal feed. None of these crops were independently tested before their release on the US market.
The scientific opinion that GM/transgenic breeding is similiar to all other types of man-mediated breeding had meanwhile become the basis for the GM regulatory system and in a pernicious way came to be the basis elsewhere, nationally and internationally. That opinion has been simplisticly interpreted in a way that, while acknowledging that unpredictable genetic changes may result from GM/transgenic breeding, it failed to properly address the implications of those unpredictable changes.

Not surprisingly, controversy dogged GM/transgenic crops and food and its commercialisation and as more people became aware of the issues it became hotly-contested. Antipathy to GM/transgenic crops in European countries was further fuelled by a series of food-safety scandals particularly the BSE disaster. Consumers in the EU have been consistently dubious about GM while the US and other GM-producing countries brought a formal complaint to the WTO (World Trade Organisation) against the EU. And so trade treaties now play a major role in GM/trangenes crop regulation, to the point where free trade essentially overrides environmental and health concerns. Not having access to the significant EU market for their GM/transgenic soy, maize and canola is a major limitation of biotech business, not being able to sell their GM/transgenic seed is damping their expansion plans, and European reluctance for their GM products is not encouraging potential customers in Asia and Africa.

The EU door to GM/transgenic crops has been difficult to prise open. It was in the face of such opposition that the promoters of the GM industry seized upon the concept of ‘cisgenic’, a word that was literally invented in the course of a PhD thesis submitted to Wageningen University in 2004. Cisgenic is said to describe close relative breeding. It is a clever word in this context, what with its scientific connotations of opposites or mirror images, one labelled with the prefix cis- and its mirror image labelled trans-. From this usage in science, ‘cisgenic’ suggests itself to be the opposite of transgenic. I suspect that scientitsts unfamiliar with the term would presume it to mean the opposite to transgenic. Once the c-word, cisgenic, appeared in a few refereed journals – despite being challended by fellow-scientists – it gained scientific currency, an antidote, or key, for that closed EU door became obvious.

However, the controversy that greeted the cisgenic term in scientific circles didn’t stop a number of academics and others in Wageningen University’s potato projects. They authored papers with titles like ‘Societal costs of late blight in potato and prospects of durable resistance through cisgenic modification’ (2008) and ‘Cisgenesis, a new tool for traditional plant breeding, should be exempted from the regulation on genetically modified organisms in a step by step approach’ (2008). The peer-review system kicked in with its citations and, eureka: we have a new ‘scientific’ concept.

The nay-sayers, like the eight who responded to a Nature Biotechnology article in 2006 (volume 24:11), don’t agree. Cisgenic is a classification subset of transgenic, that is, cisgenic clearly involves genetically engineered transferral of a gene from a different species and is unequivocally transgenic. It is the transormation process, not the source of the tranferred gene, that gives rise to unpredictable effects. Cisgenic involves, in the case of the Teagasc GM potato, an Agrobacterium tumescens-mediated gene insertion with a vector, all of which contribute to unpredictable effects of the transgenic process.

Meanwhile those Wageningen University creatives set up a train of events to get cisgenic crops de-regulated so they could be grown without having to jump through the GM regulation hoops. For all biotech supporters, the pototo is a perfect GM-vehicle, a veritable Trojan Horse, what with its cultural resonance throughout northern Europe and the fallout from a new virulent blight strain. The Wageningen group’s initiative secured European Commission support to the extent the EFSA (European Food Safety Authority) published a scientific opinion on matters cisgenic in mid-February this year. One commentator dubbed these events and their results as ‘political science’.

Significant corporate involvement is evident in these potato circles to those who look carefully. For example, Wageningen University’s plant section got €16.2 million from industry in 2006, that is 13% of its total budget. Those two papers named above emanate from Wageningen, the first one is actually reference 19 in Teagasc’s application to EPA and some of its authors are part-owners of a patent attached to the GM potato being trialled by Teagasc. One author of the second paper is also a co-author of the first, and again based at Wageningen.

All of this is closely relevant to Teagasc’s licence application to EPA (Environmental Protection Agency) to grow GM potatoes at Oak Park. Teagasc’s application uses the term ‘cisgenic’ 48 times, according to the find facility on my computer. However it does not at any point define the term. Definitions from other sources vary from tranferred genes within a single species to transferred genes within a kingdom – early GM crops involved transferring of viral, bacterial and other microbial DNA across to soy, corn, canola and other flowering plants much higher up the evolutionary tree. The observed, documented and widely acknoweldged reality is, transgene technology is likely to cause unpredictable effects, ie, effects that wouldn’t occur in many types of traditional breeding. We simply don’t know enough to know these crops are safe.

One of the convenient side effects of all this is that we become accustomed to GM crops being grown Europe-wide. The Teagasc GM potato will have established the GM precedent here, undermined consumer opposition and the EU door will be wide open to GM canola, maize, wheat and other food crops. Ireland, whose island nature gives scope to avoid cross-border GM contamination, is one of the few remaining EU countries not growing GM crops, so that Teagasc GM potato trial will be a notch on somebody’s gun.

The commercial and institutional interests which promote GM foods frequently cite/exhort us to take a scientific approach to their products and research. However, if the scientific method teaches us anything it is to adopt a healthy scepticism. Ergo, some skepticism applied to cisgenesic matters and Teagasc’s interpretation of it would be in the national interest.

Reference
Late lessons from early warnings (2001). European Environment Agency Environment Issues Report Number 22. http://www.eea.europa.eu/publications/environmental_issue_report_2001_22

What if the testing system itself isn’t up to the job? My recent digging / research around GM potato matters has uncovered a plethora of holes and flaws in the system. Here is one I want to share with you today: experimental GM crops, aka, GM crop trials can cause contamination.

Recall the GM-rice contamination furore in 2006-7 where over 30 countries worldwide found unapproved GM-rice in its rice supplies. Investigations traced one source for at least 2 of the contaminating GM-rice strains: a rice research station which seems to be attached to Louisiana State University. The official report [1, pp5, 7] describes how no physical explanation could be found for the contaminations – there was more than one – a situation described as an Act of God by a Washington Post article! Eventually Bayer paid $750 million to end the resulting lawsuits.

GM-contaminated Canadian flaxseed found in Germany in 2009 likewise caused an EU ban on all Canadian flaxseed and froze the flaxseed market in Canada. The culprit was a trial-stage GM flax, charmingly called CDC Triffid, the development of which was abandoned in 2001. Again the route of contamination from this trial has not been discovered.[2]

From 2004-2006 GM-contaminated papaya were detected by the Thai government which disrupted papaya exports. The source of the contamination was traced to a government research station doing trials on GM-papaya trees.[3]

These incidents show that trials of GM crops pose risks, even trials involving university and government institutions. The GM contamination situation reminds me that it took the Three Mile Island disaster for the nuclear industry to accept that human error must be factored into its risk management. Except that the GM industry and regulatory system
isn’t learning from its mistakes.

“Deliberate release” of GM plants it’s called in the legislation. That means it’s outdoor cultivation of a GM crop and it’s what Teagasc is planning to do at Oak Park with GM potatoes modified to resist late blight. This grandmother says its time to get real about the risks of contaminating our food in a way that unpredictable effects can happen. This is not a car or a new beverage we’re talking about: it’s our food – a fundamental and ongoing human need – and my grandchildren need safe food.

[1] http://www.aphis.usda.gov/newsroom/content/2007/10/content/printable/RiceReport10-2007.pdf
[2] http://agcanada.com/daily/testing-seen-as-best-defense-against-triffid/
[3] http://www.plantphysiol.org/content/147/2/487.full.pdf+html

The imperative for Teagasc’s decision-making
Pat Kenny (verbatim): “tell us what decision-making lay behind this application, what is the imperative?”

Suzanne Campbell (paraphrased): Blight is prevalent in potato crops in Ireland with new strains like Blue-13 coming on stream all the time.

Describing blight as the imperative is simply inaccurate. It also lacks sufficient depth of analysis to be useful in terms of trying to understand the forces at play in Teagasc’s planned GM potato trials.

One perspective – backed by a trail of evidence – indicates that the shots on this GM potato trial are being called at EU and international levels: Teagasc is merely a bit-player. The Teagasc trial is now part of an AMIGA EU-funded programme which started in December 2011, with 22 participants in 15 EU countries. Given the recent date of AMIGA’s inception, it is likely the proposed trial was previously part of another EU pototo blight consortium. An ever-changing cast of programmes, projects, partners and funders (DuRPh, European Potato Network, Endure, Eucablight, Potato Genome Sequency Consortium to name a few) have been emerging and merging at EU level alone. There are some international equivalents too, all of which address the potato and late blight.

Major agribusiness conglomerates are involved in these consortia and projects in a range of ways (funding universities, research institutions, research projects, conferences, websites among others), direct and indirect, and to varying degrees. For example, since 2001 regular major conferences of the Euroblight network have been funded by at least 18 agribusiness conglomerates including BASF, Syngenta, DuPont, Bayer, Aventis, Nufarm, Agrovision, Bioforsk, Dow and Cortis, some of which have GM potato products in development along with being major agrichemical producers.

According to FAO (UN Food & Agriculture Organisation) world potato production has increased from 267.99 million tonnes in 1991 to 325.30 million tonnes in 2007 and the world potato sector is undergoing major changes. In 2005 for the first time, the developing world’s potato production exceeded that of the rest of the world.

Conclusion
The humble potato is big business.

The Famine
The Irish potato famine crops up in most discussions of potato blight. Some aspects of the Irish potato famine should be noted: the predominance of the ‘lumper’ potato in most parts of the country (seemingly preferred for high yield and taste) at that time resulted in the blight sweeping without ‘opposition’ of resistant potato patches countrywide. The potato was the mainstay of the peasants. Meanwhile dairy, beef and cereal in vast quantities was being exported from Ireland to the UK. However the peasants did not have money to buy food. In other words, the social, political and economic conditions caused the million-plus deaths from starvation and related causes, and millions to emigrate. Ireland produced enough food to feed its population in those famine years: it was the system that distorted the distribution of that food.

Conclusion
Resistance to potato blight will not necessarily guarantee that people won’t go hungry or starve.

The Blight
The report describes the blight as a fungus despite it having been re-classified as an oomycete. Confusingly, the anti-blight sprays are still widely called fungicides.

Potato blight is a formidable enemy even in modern times as new strains evolve so rapidly. This means that any potato variety that is resistant today may be overcome by a newly-evolved blight strain next year. If this is the problem for which the Teagasc GM spuds trial is part of the solution, it seems the solution is utterly illogical. Why use a risky technology to come up with a resistant potato strain when a new blight strain may be capable of killing it within a short period? The situation could be described as a resistance vicious circle. I had hoped that agricultural and related sciences had their act together enough to be able to carry out a proper problem-definition phase early in their research. But then I recalled that GM technology is a technology looking for a market. . .

During the discussion PK said: “and technically with blight, if you have an outbreak of blight it will attack every potato if it is exposed to it”. This level of mis-information reflects poorly on the programme, especially as it went unchallenged.

Regarding blight’s rate of evolution, it is noteworthy that blight’s ability to sexually reproduce was first reported only in the 1950s in Mexico – up to that time the blight was known only to reproduce asexually, ie, without any mixing of genes from different blight strains. This capacity to sexually reproduce is the root of its ability to rapidly evolve. The mating strains of blight were first reported in Europe in the mid-1980s, in 2005 in the UK, 2007 in Northern Ireland and 2008 here in the Republic. The most recent strain is dubbed Blue-13. When I saw these dates I noted that a major shift in the evolution of the late blight (Phytophtera infestans: Pi) coincided with industrial agriculture, aided and abetted by globalisation: it is possible to buy blight-infected tubers as spuds for dinner in the local supermarket, such is the effect of globalised food distribution.

Non-GM blight-resistant potatoes are available, among them the Sarpo mira derived from Hungarian potato strains, and others. The not-for-profit Sarvari Research Trust in Wales breeds a range of Pi blight resistant potatoes including Sarpo varieties. However they’re used mainly by gardeners, producers growing for local markets and organic growers: Sarpos don’t qualify as ‘pretty potatoes’ as demanded by supermarkets/consumers and don’t fit the harvesting or processing machines of industrial producers. In other words, ‘the market’ has limited interest in these blight resistant spuds.

In South American countries farmers who grow for their own and local consumption would typically sow 10-12 potato varieties at any one time. This genetic diversity ensures enough to eat and sell no matter what nature throws at their spuds. Large scale commercial growers may have a 20 acre-plus field of a monoculture and if the variety was not Pi blight resistant or sprayed repeatedly, the field would be virtually wiped out by a blight infestation. Interestingly a report I saw recently of Blue-13 sites In Ireland for 2008-9 showed no infestations of the Type 1or 2 Blue-13 strains in the midlands or the west, except for Donegal and a limited area of Cork.

Conclusions: Monoculture – especially as the potato is usually propagated by cloning – contributes to the Pi blight problem.
Other production factors can also affect the potato’s ability to withstand disease.
In Ireland, Blue 13 infestations appear to coincide with large scale potato production.
‘The market’ for potatoes has huge influence in determining what varieties are grown by producers: if the real cost of producing potatoes was charged to consumers, non-GM potatoes with resistance would play a different role in producers’ choices.
A potato genetically modified for resistance to blight is an illogical solution to the potato/potato blight-resistance vicious circle problem.

“Set a precedent”:
PK did hit one nail on the head when he noted that the anti-GM lobby may be concerned about the Teagasc GM spud trial setting a precedent. However, he then laid out the argument that experiments being done in universities don’t mean it becomes “part and parcel of routine manufacturing”. However PK doesn’t seem to realise that plants , which are capable of producing seeds, growing in a field, are no longer controllable in that their pollen and seeds are dispersed by insects, wind, animals and/or man, (and potatoes also reproduce by tubers capable of reproducing new plants) and as such are uncontrollable: the Pandora’s Box effect, ie, once opened, its contents cannot be put back. At this point his reporter diverted into great detail about Monsanto and the Pandora’s Box aspect was not surfaced.

Not “the typical GM route”
“Just to fill you in, is that, what they did, they didn’t go down what they see as the typical GM route. It is a non-patented product, it is from a South American potato that they feel has had millions of years of different exposure to blight,” says SC. This simply does not tally with my information. Teagasc was not involved in development of the GM spud in question; it was done in Netherlands with part of it in collaboration with a UK lab. The part about the non-patented product is simply not true. Part of the potato (the gene from the South American potato, titled Rpi-vnt1-1) is very definitely patented – by a group of scientists (some already salaried by their institutions) including two who are co-authors of the paper in reference 19 (p11) of the Teagasc EPA application. More about this later. Other technical aspects of the genetic transformation process may also be patented.

The “South American potato”
The potato in question is Solanum venturii, a wild relative of Solanum tuberosum tuberosum, the botanical name for the cultivated potato and its varieties. Note Solanum venturii is a separate species from Solanum tuberosum tuberosum. Last time I looked, a species was defined as a group of organisms that is physiologically incapable of breeding (ie, producing live offspring) with organisms outside its species. Solanum venturii is not capable of breeding with S.tuberosum in nature or without technological intervention. While both S. venturii and S. tuberosum tuberosum may be near relatives, nevertheless they are separate species and it is simply untrue to describe them as the same species or sub-species.

“So this is a potato gene they’ve stuck in a potato”
So says PK, and adds “this is not Frankenstein because this is what rose growers do when they do hybrisazation of roses, yes, yes, they take a rose that has a nice smell and one that has a beautiful purple colour . . .and. . .get a beautiful purple rose that smells sweet . ..doing it in their potting sheds for ever and a day . . this is not taking the gene from a tsetse fly and transmitting it to a potato.”

“The one that really scares people is transgenic”
“The one that really scares people is transgenic” says SC, “that’s when you take a gene from one species to another and you introduce a gene from a tuna fish into a domestic trout . . .it scares the bejasus out of everybody. Cisgenic is what’s going on here. Which is where you isolate a gene from an existing similar, in fact exactly the same species, a sub-species is the difference”.

This is simply not so. Solanum. tuberosum is not a subspecies of S. venturii nor is the reverse true. Whether the transgene comes from another kingdom (as bacterium to soy, plant to animal) or from different families within the same phylum, or from within the same family, or even within a single species, a recombinant-DNA process was involved to ‘force’ the inserted gene into the nucleus of the organism being GM-transformed, ie, the gene movement would not have happened outside a laboratory. The technique involves using a penetrating cassette which incorporates Agrobacterium tumefaciens or other transfoming agents, and plasmids or other lab creations as vectors. The insertion event alone is likely to create unknown effects in the ‘host’s’ DNA, never mind the effect of the introduced gene from a sexually-incompatible ‘donor’.

It is widely accepted in science circles that the GM genetic insertion itself is likely to lead to unexpected effects. The theoretical basis for these effects are more recently better understood from the perspective of epigenetics (inheritable traits from outside the DNA), a newly-emerging field which exposes the over-simplified theoretical basis for genetic engineering, GM technology and GM food from its beginnings in the 1070s. Ironically, the Human Genome Project and its research findings exposed the over-simplification of genetics and its resultant dangers. However, this new knowledge has not yet been taken on board by the GM regulatory system and is not taken into account by EFSA in its GM guidance documents. These documents (EFSA Guidance on authorisation of GM food and feed in EFSA Journal 2011;9(7):2311 [165 pp]; Guidance on environmental risk assessment of GM plants EFSA Journal 2010;8(11):1879 [111 pp.] ) are the basis of the decision-making for this Teagasc GM potato trial. This situation makes its refusal doubly urgent.

SC’s explanation of the process of insertion of the gene from S. venturii into the nucleus of the S. tuberosum cv Desiree is confused and confusing, especially considering it’s explained by Teagasc in great detail on p14 of its licence application. Nowhere does SC mention the Agrobacterium-mediated transformation. This involves use of a bacterium, Agrobacterium tumefaciens, in a process called Agrobacterium tumefaciens-mediated transformation (ATMT) and a binary plasmid pBINAW2:Rpi-vnt1-1 to generate the S.tuberosum cv Desiree line. Then a complicated set of proceedures involving technical steps such as tissue culture take place before a single genetically modified S. tuberosum cv Desiree would be ready to plant. Surely a far cry from PK’s unchallenged notion of rose breeding in the potting shed.

Conclusion:
The journalist’s description of the plant type donating the resistant gene as “exactly the same species, a sub species is the difference” is factually incorrect.
Ineffective communication on complex issues is distinctly unhelpful

“Cisgenic is what’s going on here”
Teagasc uses the term ‘cisgenic’ 48 times in its application, without once defining it. The absence of a definition is simply unacceptable. Cisgenesis/cisgenic is getting bandied around a lot recently and there is considerable confusion about its exact meaning.

Cisgenics is a recently-coined term for genetic engineering involving crossable species (Jacobsen and Schouten, 2008) or cisgenesis has been described as being genetically engineered using a process in which genes are artificially transferred between organisms that could otherwise be conventionally bred. In other words cisgenesis is simply a subset of genetic engineering.

There appears to be an international movement afoot to have cisgenesis accepted as a term to describe technology-assisted breeding using near-relative genes. Just last week I discovered EFSA published a scientific opinion on cisgenesis in mid-February 2012 at the behest of the European Commission. Preliminary investigation on my part has uncovered a trail of self-referential documents, reports and articles in refereed journals. In Europe, Waginengen University seems to be the birthplace and ongoing source of cisgenesis thinking: see www.cisgenesis.com. The Haverkort et al 2008 paper mentioned already contains detailed statements about cisgenesis and claims that cisgenic plants warrant less stringent oversight in the EU. Haverkort headed the DuRPh (Durable Resistance against Phytophtera) project at Waginengen and his paper describes cisgenic plants as containing indigenous genes from crossable species.

I find it deeply ironic that GM crops got foisted on the world in the first place because scientists in the US National Academy of Science in the mid-1980s declared it was the product of genetic engineering, not the process itself, which should be regulated. Genetic engineering, according to the NAC worthies, was no different from other types of breeding that man had been doing since time immemorial. In this way, GM food was commercialised without testing by anyone other than the companies producing the food, legislation was deemed unnecessary other than what already existed, labelling was not required, and the GM food basis tenet became the basis for GM regulation internationally, WHO, FAO, OECD, Codex Alimentarius, and also to the EU.

The 21st century however shows continuing resistance to GM crops in Europe and here’s my theory about cisgenesis and potatoes: Some strategist recognised the significance of the spud – much more meaningful to a Northern European than maize, soy or canola. Ally the spud’s cultural resonance for Europeans with scourge of late blight and the rapidly growing scale of the potato industry and one has the perfect means to 1, create a new category of tech-plants – cisgenic. 2, Create a sidedoor by which cisgenic plants can get to market without regulatory hurdles and delays. 3. Link cisgenesis to potato blight and the potato to have GM potatoes trialled throughout the EU and so ease the path for acceptance of GM crops throughout the EU. This is a perfect Trojan Horse scenario: to gain acceptance for GM crops in EU countries via a claim that GM potatoes with genes inserted by genetic engineering technology from a wild relative species isn’t really GM at all.

Conclusion: The cisgenic concept is a controversial and contested tool and needs further examination. It is being used by some parties to try to get GM crops more accepted in EU countries.
Based on its frequent use of the term ‘cisgenic’, Teagasc appears to be a party to this cisgenic initiative.

“This is an important piece of background”
It seems that the anti-GM argument is distilled down to corporate domination of the food chain, seed patenting and untrustworthy research. But then Teagasc is repeatedly painted as the corporate-free saviour with no agenda, using arguments based on suppositions and assumptions. Meanwhile the report virtually ignored the valid worries about the biological issues and the risky technology.

“Know what?” said a friend, “she’s just gotten through saying ‘so we simply don’t know the answer to that. They could trial the potato, it could look brilliant, it could go to the market and in a few years time they could have major blight problems’ . . .”

I was surprised that a number of listeners interpreted SC’s parting shot of “we will know in three months” as meaning that the experiment results will be known then. In fact, the experiment is planned to run until late 2015. It’s the EPA decision on whether to grant a licence that has the 3-month timeframe.

Thanks Suzanne and thanks Pat for the half-baked (potato) way in which you presented a complex topic, and misrepresented the core issues regarding Teagasc’s application to trial GM potatoes in Oakpark, and misinformed the Irish public about a matter that will, if it goes ahead, have an irreversible effect on food in Ireland. Food – not radio programmes or ipods or cars or disposible commodities – but food: a basic human need. While we could live without radio, ipods and cars, we cannot survive without food, and some of the food now in our food chain and fully approved by the food safety system, is making people ill.

This topic is too serious to be mangled into sexy soundbites: please give it the attention it deserves.

References
Jacobsen E, Schouten HJ (2008) Cisgenesis, a new tool for traditional plant breeding, should be exempted from the regulation on genetically modified organisms in a step by step approach. Potato Research DOI 10/s11540-008-9097-y

Haverkort AJ, Boonekamp PM, Hutten R, Jacobsen E, Lotz LAP, Kessel GJT, Visser R, van Der Vossen E (2008) Societal costs of late blight in potato and prospects of durable resistance through cisgenic modification. Potato Research 51:47-57

PK – Potato blight has plenty of resonance in Ireland. The fungicide known as blight was what triggered the immigration of hundreds of thousands of irish after it attacked the potato crop for several successive years in the 1840s. Blight is still a big problem effecting Irish potatoes and Teagasc, the state agriculture and research council, has applied to the EPA to grow genetically modified blight resistant potatoes at its research centre in Carlow. but many small producers and anti-gm groups say it’s a decision that will effect Ireland’s green clean image which is central to our thriving food export markets. Suzanne Campbell, food author and journalist, is here with us now to talk more about this issue. Suzanne, good morning. First of all can you tell us what decision making lay behind this application , what is the imperative?

SC – The imperative is that blight, despite some of us all thinking it is something long ago in the past, is very prevalent still in our potato crop. We have the conditions here, we all know them well, damp, climate, nice warm temperature, very mild, that produces the ideal climate for blight. So if you are a farming potatoes tomorrow you are still struggling with this disease. It is a fungus there are many types of it. it is very very pervasive. There are new streams coming on stream all the time mostly from Europe, varieties like Blue 13.

Teagasc has been examining the situation for quite a while. It has been breeding potatoes in at Oak Park anyway down in Carlow for about 40 or 50 years.

PK – But aren’t some types of potatoes naturally resistant?

SC – Yes they are

PK – and therefore they are not attacked by the fungus and others then will be effected by the fungus

SC – Yes, Roosters, which are very prevalent at the moment, developed by Teagasc, ironically enough, which we all buy, a very multipurpose potato, big seller, is susceptible to the blight, so are Maris Pipers which are used in manufacturing, potato chips etc. The smaller ones, Orla, Setanta, different varieties, are on a sliding scale of blight resistancy. So its quite a complex thing. Some might come in at 4, some might come in at 3, some might be more blight resistant in the tuber, some more in the leaf.

PK – OK and technically with blight, if you have an outbreak of blight will it attack every potato if it is exposed to it, and the crop will respond in those kind of percentages or might it just this year attack Roosters and next year….Maris Pipers…

SC – Exactly. Its very dependent on weather, its very dependent on the way the fungus develops over a season. Also the famous thing in the famine was, if you remember, I think it was the second season of the trauma of this disease, the leaves presented blight free but when they oppened up the ground the tubers were rotted. So its actually a real killer and it works in very kind of particular ways. Now what Teagasc want to do test a GM blight free potato, blight resistant potato, in order to stop the levels or minimize the levels of fungicide which are very very intensive in farming at the moment. So how we are controlling it is…

PK – So farmers are using fungicide and is the EU telling us to cut down on this at the moment?

SC – Yes, it has directives coming down the tracks and it already has them in, constantly limiting pesticide and fungicide use. So farmers are also paying out a fortune in this stuff, spraying into the environment. No one will say its good way to continue because it creates resistancy. So thats were these….

PK – So you are saying there may be a competition in trying to preserve our clean green image between the amount of fungicide to kill the fungus, versus the GM thing which people have reservations about.

SC – Yes, and that’s where this boils down to, Teagasc would say, isn’t it better to have a blight resistant potato trailed here. The anti-gm lobby would say no, its opening the door to proliferation of GMs in the environment it will hurt our international food markets who think and have, very strong research indicates that they love the terms clean green, an Island country and possibly GM free country. Does this damage our reputation as GM free

PK – Or in other words, set a precedent. Now this is an experiment, and the question is, why not experiment, might be one attitude, in the same way as they do all sorts of things in university which doesn’t mean it will become part and parcel of routine manufacturing in any area. What’s the argument against doing it at all?

SC – the argument against doing it, would be that, i think peoples relationship to GM in their thought processes, people in the food industry who are against it..and farmers is that it has been a veil of tears, with the big companies, BSF, Dupont and particularly Monsanto, in the Us where its been legal case after legal case, class action, a huge amount of opposition to it. It controls a massive part of the food chain. Monsanto earned 7 billion in selling seed alone last year. And then it also sells you the pesticide which the seed is resistant to. For example one of their big products, round up ready soy, They sell you the round up ready soy to sell you tons of round up then to put on the soil to kill everything else. So its like this closed circle which would be seen as unethical by a lot of people who are against…GM

PK – Give me that again…you’ve got soy which is resistant to round up…

SC – Yeah its called RR soy, round up ready…

PK – So in order to maximize your output from the field, get rid of anything else that grows in that field, you kill everything else with round up, so that the soy can be king of the castle in the field,

SC – Yeah, yeah, can you imagine how much round up you are putting on that field? Round up is a glyphosate. Glyphosate is an endocrine disrupter, it’s not the best of chemicals we all use it with warning in our gardens or on our pathways or whoever has at home and many listeners will. Putting that on in the amounts that they put it on in conventional intensive cereal farming in the States and South America is quite scary. And you have this loop where the same company that is selling you the seed is also selling you the product to kind of promote the growth of it, so its kind of a closed loop.

PK – OK, now back to the humble potato, and you’ve got a GM variety that is disease resistant. Does it keep that resistance right down through the generations, or can it loose it. Or if a new type of blight comes along, because I’m sure that fungus’ mutate…just like…

SC -Yes, They do, they do, they develop all the time. Again with GMs its very hard to generalize. Some species that have been bred for resistancy have kept their resistancy in plants. Some that have been bred with a resistant marker for a particular disease the resistancy is gone within 2 years. So we simply don’t know the answer to that. They could trial the potato it could look brilliant, it could go to the market, and in a 3 years time in fact it could have major blight problems.

But Teagasc’s answer to that, just to fill you in, is that, what they did, they didn’t go down what they see as the typical GM route. It is a non patented product, it is from a South American potato that they feel has had millions of years of different exposure to blight. So they have taken a gene from a particular potato. They think its a winner but who knows…you will only know when you try it.

PK – So this is a potato gene, they’ve stuck in a potato! This is not Frankenstein, because this is what rose growers do when they do hybridization of roses, yes, yes, they take a rose that has a nice smell and one that has a beautiful purple color, try and put them together, and they get a beautiful purple rose that smells sweet. And they’ve been doing that in their potting sheds for ever and a day. So this is kind of a kin to that. This is not taking the gene from the tsetse fly and transmitting it to a potato.
SC – Yeah, the one that really scares people is transgenic. That’s when you take a gene from one species to another, and you introduce a gene from a tuna fish into a domestic trout, a farmed trout. Like the Frankenfish, the big story in America, the growth promoted farmed salmon, that they are trying to get FDA approval for. People love this story, Frankenfish, great word, it scares the bejesus out of everybody!

Cisgenic is what’s going on here. Which is where you isolate a gene from an existing, similar, in fact exactly the same species, a sub species is the difference. You isolate it along the strand of DNA, you put it into cold storage. You then put it into the nucleus of the cell of your potato that you are working on, you grow that in plasma, you grow it on and and you plant it. Now lets remember, Teagasc have been doing this since 2002. They have these GM products down there they just haven’t put them into fields. And that is what this application is for.

What is the implication of when they get put into fields? How far does the pollen travel? This is what peoples fears are about. Who controls then the license of this product. Teagasc owns Rooster under license. So if i buy the seed of Rooster its owned by a marketing company which Teagasc work with because they have developed this crop. I think people’s fears surround the fact that food becomes in private hands, who controls that seed then?

Now Teagasc would say. They’re a state agency. They don’t want to commercially exploit this potato. But what they feel is, and this is an important piece of background, companies like BASF have put in for a blight free potato called Fortuna with EFSA the European Food Safety Agency, and the EFSA will look at probably licensing or not in the next 4 of 5 years. Teagasc’s view is that if EFSA license that potato and it comes to Ireland, any grower, with the permission of the EPA can then grow it. so they are saying, we would rather grow a blight resistant potato under our own terms in Ireland rather than take the research of BASF who are a private company, who conduct research that has had opposition from anti-gm groups, because they say it will always end up with results in favor of pushing their product. And I mean, a lot of people in the scientific community do have major difficulties with the research carried out by Monsanto, Dupont, BASF because it is always conducted with agencies and with institutions that they fund.

PK – Where as there is no agenda with Teagasc…

SC – That’s what Teagasc say. And the anti-gm will say well how can we trust you, how can we know that in 30 years time this potato won’t become your super product, licensed all over this part of the world. Teagasc say we are not interested to gain commercial viability we want to see what happens to the earthworms 30 meters away, to the bees 30 meters away, and isn’t it better that we test it than its tested by the agri-chem giants? And there is an argument there because the agri-chem giants have come again, and again, and again into realms of mistrust, realms of business practice that has been/found an awful lot of opposition where they operate.

PK – Suzanne that’s a very enlightening piece, I must say, on exactly what’s going on! Cisgenic rather than Transgenic, it’s a potato within a potato….

SC – Yes, and we will know in 3 months!

PK – Suzanne Campbell, thank you very much!

LATEST POINTER (apologies for lateness:have been up to proverbial tonsils)
“Cisgenic potato line”
In its application Teagasc describes the potato it’s using as a “cisgenic potato line”. All cisgenic lines are transgenic, ie, they have been produced using genetic engineering technology. It is universally accepted that transgenic organisms can produce unpredictable effects. This is the risk I want to avoid.
I’ve been beavering away at trying to make sense of the Teagasc application since it became public knowledge on 24 February (see Teagasc application) with a view to submitting an objection and making information associations or organisations to do so. Thank you to those who have been helping in the background.

The latest on Teagasc GM spuds from Mia Mullarkey on Vimeo.

PLEASE NOTE THE FOLLOWING IS A WORK IN PROGRESS. KEEP COMING BACK FOR LATEST ADDITIONS.

Tips & Pointers

See below for important information regarding postage and delivery to EPA office in Wexford

Objections must be in writing and accompanied by €10; online or digital format submissions are not accepted.

Note that the GM potato trial in the Teagasc has no direct link with Monsanto or other corporate biotech link, does not involve glyphosate (including Roundup), and does not involve an antibiotic-resistant marker. So, many of the commonly used arguments against GM crops do not easily apply to these GM spuds.

This translates as:
In your objection do not include aspects that are not relevant to the application, eg, Monsanto, Roundup Ready issues, Bt toxin issues, antibiotic-resistant marker issues.

To be taken seriously your objection should respond to the Teagasc application, and should avoid overblown or emotive statements (yes, I know, it can be sooo difficult).

Time for response
My sense is that 28 days for responding to a 35-page technical document is too little, especially for people who are not familiar with the topic and who therefore need additional research time. Also the time span is much to short for any organisation who wishes to engage in meaningful consultation with its members. If this feedback is included in your objection it may result in more time to respond to future licence applications. See below for tip to cement this point into EPA consciousness.

Legal right to information and input into decisions
Under the Aarhus Convention on Access to Information Public Participation in Decision-making and Access to Justice in Environmental Matters, people in Ireland have a legal right to information and input into decisions affecting their environment or their health when affected by the environment. The Aarhus Convention, having been ratified by the EU, obliges the Irish government via the Treaty of Rome to ensure those legal rights are upheld.

Over all, there has been negligible public participation in decision-making regarding GM crop, GM food or GM feed policies in Ireland since GM crops were first commercialised. An invitation to respond within 28 days to a licence application for a GM trial, in one discrete part of a GM policy and regulatory system, does not fulfill the information and input rights specified in the Aarhus Convention.

Teagasc’s stated purpose for the trial
The application states (F.1) “the purpose of this release is to” and then describes 3, the third of which states:
“employ the project’s resources as a tool for education and demonstration in order to proactively engage and discuss the issues that most concern stakeholders and the public at large in regards to the cultivation of GM crops in Ireland”.

In other words, one purpose of the trial is to enlighten people in Ireland AFTER the GM pototoes have been planted. These plants by their nature can reproduce themselves (potatoes do so both vegetatively and sexually, by tuber and seed) and therefore can spread uncontrollably so that they are un-recallable if later problems arise.

This purpose as stated by Teagasc is unreasonable.

Resistance
A reasonable and valid model of resistance in reproducing living organisms involves each organism – in this case, the potato and the late blight – developing resistance in reaction to stressors emanating from each other. This results in a vicious cycle of resistance developing. It is likely that looking at other elements in the relationship between the blight and pototo, eg, potato husbandry issues, would yield better results and less environmental damage.

More anon . . .

Further tip on time deprivation & EPA consciousness
It seems to me that if you also send a separate letter to the Director of EPA stating your views on the inadequate time for a proper response, and pointing out to the director that as far as you are aware the legislation sets out the minimum time for response but leaves flexibility regarding the maximum. Perhaps suggest that a 6-week period would be more appropriate in facilitating public participation.

5pm Tuesday 27 March at EPA office in Co Wexford
This is the legally set out time and date by which the objection must arrive at EPA HQ. Any later than that and it simply will not be looked at. An Post have a next day delivery service (cost €5.75) but its not guaranteed. As the deadline is on a Tuesday, it is advisable to post the objection by the previous Friday (23 Mar) to be sure to overcome the vagaries of the Irish postal service. Proof of postage is recommended – just in case.

Act now to prevent the license being approved. Click here for tips and pointers.

Last Tuesday (27 March) Teagasc announced that it has an application with the EPA (Environmental Protection Agency) for a licence to grow GM potatoes at Oakpark, one of its research stations that is located in rural Carlow. You have until 27 March (yes, that’s 27th of this month and before 5pm to boot) to lodge a ‘representation’ aka as an objection (see The Environmental Protection Agency Notice ). Remember, if Teagasc gets its way on this, the genie will be out of the bottle because there’s no way of recalling these spuds when problems become evident down the line. It took 20 years for the subtle effects of DDT to become obvious – that’s just one way Nature bites back.

I’ve been dreading this for months now – in fact since the coalition came to power – to the extent that I started an online petition for a 5-year moratorium on growing GM crops in Ireland. We, the people, have been conned: the upshot of how GM crops were commercialized is that we don’t know enough about their effects, particularly their long-term ones. But the GM industry spends billions ‘telling us’ GM crops are safe and lobbying politicians and bureaucrats with the same story. Once we’ve accepted growing GM crops in Ireland there will be no going back, NEVER EVER. Remember how the nuclear scientitsts said the nuclear power industry was safe? Well at least those over forty will remember their spin. But Three Mile Island disaster exposed the facts that their calculations had left out the human factor whereby humans make mistakes – including mistakes in judgement – and that systems involving humans are prone to error.

This GM moratorium petition needs you. It is fueled by a zero cash budget (except what’s squeezed out the household and farm one) and by voluntary effort – YOUR signature and your urging of family, neighbours and friends to sign, through word-of-mouth, email, facebook, tweets, posters in your local library, club and other places where people get together. Or other ways YOU can come up with to get the word around! There were over 1400 signatures last count and many more are needed. If you have already signed please proceed to the next paragraph but also consider another effort at getting word of the petition about. If you haven’t signed, take a look at http://www.gm-moratorium.com/index.php/theissue/ and consider signing: there is no time like the present!

Meanwhile back to the 27 March deadline for objections to EPA: despite Teagasc’s super-spin, it IS genetically engineered spuds they’re planning to grow in Oakpark. Teagasc’s use of the million-plus deaths from starvation during the Irish potato famine as a rationale for growing GM spuds uncontained in an Irish field is truely sick-making. As this news is Tuesday-fresh, I’m still researching the details of the Teagasc application and it will be a few more days before the specific issues are clear to me. For those of you who want to object (EPA charges €10 for each submission) I will shortly post a menu of points to hopefully ease your task, about which more later. It is important that objections don’t undermine their value by overstating their point(s) and also make their case relevant to the actual application. So Monsanto and glyphosate are irrelevant and should not be mentioned (I know that’s difficult but the cause is worth it!).

It was the thought of the effects of GM-madness (ok, irrationality) on my grandchildren that spurred me to do something that ended up in this petition campaign. What with another grandchild due next week, I can’t give up now. Nor can you – if you haven’t already signed the petition please go to www.contact.ie/node/137 now. Meanwhile sharpen your wits and your pencil to get that objection to the EPA before the 5pm, 27 March deadline. As my lovely partner says “if those GM spuds are allowed, this island will lose its GM-virginity” and that will open the door, making it much harder to keep other GM crops out of Ireland.

I'm not a science experiment

I’m gutted that Teagasc has applied for a licence to grow GM potatoes at Oakpark. It’s now more important than ever to get lots of signatures on the GM moratorium petition. Make it your March resolution to recruit at least 20 signers, please.