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Update from Saskatchewan Organic Directorate on biotech wheat

(Thursday, March 20, 2003 -- CropChoice news) --The following information comes from Marc Loiselle, a Saskatchewan organic farmer and member of the Saskatchewan Organic Directorate. This contains the following:

  • 1. Response letter by the Saskatchewan Organic Directorate (SOD) to the invitation by the Canadian Wheat Board's (CWB) to comment on the 'Conditions for the Intro of GM Wheat'.
  • 2. A new resolution adopted at the recent Annual Convention of the Sask. Association of Rural Municipalities (SARM) regarding GM wheat.

1. Response letter by the Saskatchewan Organic Directorate (SOD) February 28, 2003

Adrian C Measner
President and Chief Executive Officer
Canadian Wheat Board
423 Main Street
P.O. Box 816, Stn. Main
Winnipeg, Manitoba R3C 2P5
Dear Mr. Measner,

In response to your letter of February 5, 2003, the Saskatchewan Organic Directorate (SOD) does not support any initiative that will compromise the future ability of farmers to grow non-GMO wheat and that will compromise the ability for people to choose food that is not genetically engineered.

In your letter you ask for support for the document which outlines the conditions necessary to pave the way for the introduction of GM wheat. The document, ‘Conditions for the Introduction of Genetically Modified Wheat' , was developed by the Canadian Wheat Board (CWB) along with representatives from the Canadian Seed Growers Association, the Western Canadian Wheat Growers Association, the Canadian Federation of Agriculture, the Western Elevator Association, the Inland Terminal Association, the Canadian National Millers Association, the Canadian Grain Commission, Agriculture and Agri-Food Canada, the Canadian Food Inspection Agency, Monsanto Canada, and a Farmer at Large.

This group known as the ‘Canadian Grain Industry Working Group on GM Wheat,’ does not represent the full spectrum of views held by farmers, and certainly not consumers of wheat products. Consumers after all, should be the final arbiters of any direction the food producing sector takes in regards to the introduction of GM wheat.

The Saskatchewan Organic Directorate does not support the thrust of this document which we believe is fundamentally flawed in many of it's assumptions. As one example, it is faulty logic to say that the ability to meet requirements for non-GM wheat markets would depend in part on the establishment of an “achievable tolerance level for GM wheat” in non-GM wheat shipments. It is implied in this wily language that we must be prepared to accept some level of GM contamination. Presently Saskatchewan farmers are able to achieve a zero GM contamination level to supply our market. We in the SOD believe it is our right to continue to have that ability. Customers of organic wheat do not want their wheat contaminated by genetically modified varieties... period. Furthermore, SOD believes that anyone who contaminates the food system at whatever level, with GM crops, and compromises our ability to serve that market; that they be held liable.

The Saskatchewan Organic Directorate believes there are no conditions under which GM wheat can be introduced, that will adequately protect the needs of customers of non-GM wheat. The segregation system alluded to in the document ‘Conditions for the Introduction of Genetically Modified Wheat’ would be a morass of very expensive regulations that will be impossible to implement, and ultimately will fail. The result would be widespread GM contamination of the food system, and probably an end to the ability to farm organically. The stark fact of this threat to organic agriculture clearly shows the falsehood of the assumption in this document that there is some kind of cost/benefit analysis that would apply to all farmers.

Your letter asks for confirmation from the Saskatchewan Organic Directorate that it believes the conditions developed in the document 'Condition for the Introduction of GM Wheat' are “necessary and sufficient to protect the interests of farmers and customers”. Furthermore you state that these conditions outlined in the document should be incorporated formally into the regulatory process.

In response, the Saskatchewan Organic Directorate states that adding the flawed principles of this document to an already flawed government regulatory system will not address the concerns and interests of organic farmers, nor those of our customers, about the introduction of GM wheat.

Therefore the Saskatchewan Organic Directorate will not endorse the enclosed draft "sign on" letter to the Minister of Agriculture Lyle Vanclief, asking for regulatory change which incorporates the conditions contained in the document ‘Conditions for the Introduction of Genetically Modified Wheat’ and more particularly the proposed regulatory market impact test as outlined in the supplementary document ‘Market Impact and the Potential Introduction of Genetically Modified Wheat’.

Although the proposed regulatory market impact test goes part way to addressing legitimate concerns, the suggestion that this additional criteria “…need not alter the current safety approval criteria nor the criteria currently assessed by registration recommending committees.” is unacceptable based on our determination of the fundamental flaws within both. The health, feed and environmental assessments for the current regulatory system are currently based on the ridiculous ‘substantial equivalence’ model that is a mockery of the necessary in-depth independent scientific research needed to determine the harmlessness of plants with novel traits and more specifically to those with GM transgenic traits such as for Roundup Ready wheat. This has been clearly revealed in the document titled ‘Elements of Precaution: Recommendations for the Regulation of Food Biotechnology in Canada’ by the Royal Society of Canada’s Expert Panel on the Future of Food Biotechnology; a panel of 15 eminent scientists from across the country. To the SOD’s knowledge, the federal government has to date completely ignored all of the 52 recommendations that this report determined; a report that was commissioned by the federal government’s own environment, health and agriculture ministries, all of whom are directly involved in determining regulatory approvals or denials. It is telling that to date in Canada there has never been a rejection of an application for a new transgenic crop variety.

As regards the criteria assessed by registration recommending committees, here too there are obvious inadequacies. For example, the protocols established for the Western Canadian Private Bread Wheat Registration Trial for evaluating Roundup Ready wheat within the Prairie Registration Recommending Committee for Grain (PRRCG) framework, have been called into question by the SOD. There is grave concern that the 30 metre wide isolation perimeter zone surrounding the ‘confined’ field test plots is inadequate. Whereas initial research determined without doubt that genetic out-crossing by pollen drift was measured at 27 metres, and hence on which the 30 metre distance was established; supplementary information shows the potential for pollen drift to be up to 80 metres . Without substantially increasing the isolation perimeter to allow for the still unknown overall potential out-crossing of wheat, there is already an open possibility that the Roundup Ready gene could be escaping beyond the confines that are currently established and despite the efforts of personnel doing the variety trials research and the on-site inspections that the Canadian Food Inspection Agency is supposed to be doing.

This single issue of potential GM gene transfer by pollen drift alone, to non-GM wheat, highlights to what extent the ‘unconfined’ release and commercial growing of a GM wheat would quickly contaminate organic and other non-GM wheat crops, regardless of any segregation protocols that could be imposed on farmers.

We know that any change and/or addition to the regulatory system regarding GMOs must specifically address the concerns of organic farmers and our customers about the safety, environmental, agronomic and social implications of this technology.

Saskatchewan organic farmers have launched a class action lawsuit against Monsanto Canada Inc. and Aventis Cropscience Canada Holding Inc. which in part seeks a permanent injunction against the release of Roundup Ready wheat. The Saskatchewan Organic Directorate knows that such a permanent injunction would best reflect the desires and protect the needs of our wheat customers and all Saskatchewan farmers. There is no other acceptable solution.

Furthermore, SOD’s position at this time is that any other GM crop introduction be prohibited.

Based on the Precautionary Principle, all countries have the right to impose a moratorium or outright ban on the introduction of GMOs into the environment and food chain. Concerted efforts must be done to ensure that Canada adhere to the Precautionary Principle that it is signatory to, and act immediately to stop further investment, development, testing, unconfined release approvals and commercial release of GE wheat.

We therefore urge the CWB to abandon the flawed work of the ‘Grain Industry Working Group on GM Wheat’, and put it's support behind organic and other non-GM producers that are working with the long term interests of their customers in mind.

Sincerely,

Marc Loiselle
Communications & Research Director, SOD Organic Agriculture Protection Fund (OAPF) Committee and member of SOD Research & Development Committee

cc: Minister of Agriculture and Agri-Food Canada, Lyle Vanclief
Minister Responsible for the CWB, Ralph Goodale
Canadian Food Inspection Agency
Canadian Grain Commission
Canadian National Millers Association
Canadian Seed Growers Association
National Farmers Union
Canadian Federation of Agriculture
Western Grain Elevator Association
Inland Terminal Elevator Association
Western Canadian Wheat Growers Association
Monsanto Canada, Inc.
Saskatchewan Association of Rural Municipalities
Agricultural Producers Association of Sask.
Saskatchewan Agriculture and Food & Rural Revitalization
================================================ 2. A new resolution adopted at the recent Annual Convention of the Sask. Association of Rural Municipalities (SARM) regarding GM wheat.

Hello all, March 17, 2003 Last week the Saskatchewan Association of Rural Municipalities (SARM) held their Annual Convention in Saskatoon. On behalf of our rural municipality where I am a councillor, I introduced 2 resolutions regarding GM wheat and Monsanto.

Fortunately the test plot one passed; unfortunately the stop buying Monsanto products one didn’t get past the endorsement stage to have it voted on as an acceptable resolution. These Point of Privilege resolutions are 'last minute' resolutions that don't appear in the convention programming booklets. They are submitted prior to noon of the last day then displayed on the large auditorium screens with PowerPoint as they are read then voted on for acceptability to be included on the roster of resolutions to be voted on later that day.

It is likely that the refusal to endorse the 2nd resolution stems from several possible reasons: the fact that Monsanto is a corporate sponsor of some SARM events (ie: a workshop to look at the AAFC's Ag Policy Framework the previous day), the fact the resolution was written in such a way as to 'demand/oblige' that SARM and RMs not purchase Monsanto products, the fact that farmers don't want to lessen their opportunity to purchase whatever is out there in the agro-chemical world, etc.

Here attached is the resolution in question. (See below for pasted in copy)

Please note the 2nd page of the 1st resolution which lists the SARM resolutions to date re: GM crops.

Here is the reconstruction of my arguments I presented in favour of the resolution on test plots.

"Mr. Chairman, I am speaking in support of this resolution.

Based on this association’s members’ previous voting on the issue of GM grains; it’s evident we think that RRW is a bad idea that threatens us in many ways!

I wasn’t present Tuesday to hear and question Lyle Vanclief, but I’ve heard he was defensive in response to a delegate’s question about market impact re: 82% rejection.

Based on Mr. Vanclief’s response to the 2002 SARM Midterm Convention resolution calling for a “… moratorium on the release of new GM cereal crops ...”; if the federal government thinks that by cooperating with Monsanto and others, including our CWB, that they can develop and implement an effective segregation system to prevent contamination and losing markets; then they are sadly mistaken.

This response by Vanclief is found in the 2002 Annual Reports that are in all of your package of items for this convention. On page 73 and 74, the second last paragraph reads as follows:

“ Once a biotechnology-derived crop has been granted approval for commercialization, it is treated just like any other commodity crop. Growers are free to implement identity preservation systems for certain specialized types of production and can co-operate with their neighbours to minimize the impacts of surrounding production methods. In 2001 in Canada, the majority of canola production was herbicide-tolerant. As a consequence, cultivation of organic canola using a zero-tolerance standard would not have been possible, but cultivation of other conventional varieties would have been unaffected.”

What a lie! 2 research studies have proven that the pedigree non-gmo canola seed stocks are greatly contaminated; and furthermore it is a reality that all canola production in the Prairies is deemed to be GM canola now because of widespread outcrossing.

Vanclief then continues “ The CFIA continues to sponsor public research into pollen flow from canola production, and the resulting data can be used by farmers who may wish to minimize the impact of pollen flow from surrounding crops.”

I invite you all to please read this letter and judge for yourself if he’s really listening to us?! He certainly didn’t address the demand of the resolution in question.

If our minister of Agriculture and his ministry think that the introduction of RRW or other GM grains might only affect organic farming, then they’ve got their collective heads buried in the sand!

This particular resolution is quite self explanatory, although lengthy but necessary to highlight the fact that the very test plots of RR wheat may be threatening the integrity or our current non-GMO market; and RMs and landowners aren’t given opportunity to say no to test plots.

Therefore, I ask that you please support this resolution."

I have contacted the SARM office requesting copy of letter received from Vanclief. If you want copy I'll pass it around when I get it. If I don't get it, I will print up the entire text from my SARM report and send that out.

Here is the full text of the resolution that was sent to Vanclief to respond to:

Under the category: Federal Agriculture and Agri-Food:

Resolution No. 29-02M
RM of Francis No. 127
Placing a Moratorium on Release of GM Cereal Crops

WHEREAS, the ratepayers of the RM of Francis No. 127 feel that GM Wheat could cause major problems with the marketing of both organic and domestic wheat as well as other cereal grain crops;

THEREFORE BE IT RESOLVED, that SARM petition the Federal Government to place a moratorium on the release of new GM cereal crops until such time as it can be proven that their release and subsequent use will not affect out marketing of cereal grains.

(... was adopted unanimously after the RM of Francis and Marc Loiselle spoke in favour of the motion)

------------------------------------------------------------------------------------ Point of Privilege resolution #4
Brought forth at the 98th Annual Convention of the Saskatchewan Association of Rural
Municipalities (SARM), March 13, 2003.

Submitted by the RM of Grant #372, Division 4 councillor Marc Loiselle, and overwhelmingly approved by delegates representing 292 of the 297 Saskatchewan rural municipalities.

WHEREAS, SARM has 2 previously passed resolutions opposing the registration and release of GM transgenic wheat and cereal crops; and

WHEREAS, in July 2002 Monsanto filed for health approval in Canada, then in December 2002 filed for regulatory approval in Canada and the United States to release its Roundup Ready wheat on an unconfined basis for feed use and commercial production; and

WHEREAS, wheat does spread its pollen, despite its mostly self-pollinating nature, and that the pollen then does drift by wind, insect and other activity; which results in genetic out-crossing to other wheat and similar species of plants; and

WHEREAS, initial research data in Saskatchewan has demonstrated conclusively that wheat pollen drifts to 27 metres and supplementary information indicates as far as 80 metres; and

WHEREAS, the isolation perimeter zone surrounding the Roundup Ready wheat confined field test plots is set at only 30 metres, according to the protocols established for the variety registration trials within the framework of the Prairie Registration Recommending Committee for Grain (PRRCG); and

WHEREAS, there are many more field test plots of Roundup Ready wheat in Saskatchewan, besides the few done for the PRRCG variety registration purposes, for which it is not known what, if any, isolation perimeter zones are established; and

WHEREAS, without substantially increasing any isolation perimeters to allow for the still unknown overall potential out-crossing of wheat, there is already an open possibility that the Roundup Ready gene could be escaping beyond the confines that are currently established; and

WHEREAS, the exact locations of Roundup Ready field test plots is a closely guarded secret known only to Monsanto, Agriculture & Agri-Food Canada’s (AAFC) Food Inspection Agency (CFIA), and to Saskatchewan Agriculture, Food and Rural Revitalization’s (SAFRR) Provincial Oilseed and Transgenic Crops Specialist; and

WHEREAS, Rural Municipalities and individual landowners/ratepayers are not notified when and where Roundup Ready wheat test plots are located;

THEREFORE BE IT RESOLVED, that SARM lobby AAFC/CFIA and SAFRR to disclose the locations of all field test plots of Roundup Ready wheat in Saskatchewan and to give prior notification to SARM, rural municipalities and landowners of the intent to set up such test plots; and

BE IT FURTHER RESOLVED, that in order to safeguard the genetic purity of non-GM wheat, SARM lobby AAFC/CFIA to stop further confined field testing of Roundup Ready wheat until it is known to what extent genetic out-crossing (cross-pollination) of wheat and related species is possible.

Previously passed SARM resolutions regarding GM wheat, other GM cereal grains and Monsanto:

2002 Midterm PoP No. 10-02M (submitted by the RM of Grant #372 and overwhelmingly approved by the delegates, Nov 15, 2002)
THEREFORE, BE IT RESOLVED, that no member of the Board of Directors or staff of SARM be allowed to be part of any committee directed by Monsanto or other such company involved in developing, promoting and commercializing genetically engineered crops in Saskatchewan.

2002 Midterm No. 29-02M (submitted by the RM of Francis #127 and unanimously approved by the delegates, Nov 15, 2002)

THEREFORE BE IT RESOLVED, that SARM petition the Federal Government to place a moratorium on the release of new GM cereal crops until such time as it can be proven that their release and subsequent use will not affect out marketing of cereal grains.

2001 Annual PoP No. 6 (submitted by the RMs of Humboldt #370 and Eye Hill #382 and unanimously approved by the delegates, March 15, 2001)

THEREFORE BE IT RESOLVED, that SARM vigorously oppose the registration of GMO wheats in Canada; and

BE IT FURTHER RESOLVED, that Canada ban the introduction of any and all GMO wheats into Canada.

2000 Midterm No. 4

BE IT RESOLVED, that SARM investigate and report back to the membership at the SARM annual convention in March 2001, on the impact of any licensing of and subsequent growing of GMO (genetically modified organisms) wheat in Canada, taking into consideration such things as: the noxious weed aspect due to the resistance to Roundup; and the impact on the sale of all wheat on world markets.

Marc Loiselle
Communications & Research Director, SOD Organic Agriculture Protection Fund (OAPF)
*Loiselle Organic Family Farm*
Holistic Stewardship for Abundant Life
ph 306-258-2192
fax 306-258-2169

Saskatchewan Organic Directorate
Box 310
Rockglen, SK S0H 3R0
Phone: 306-476-2089
Fax: 306-476-2146
Email: debbie.miller@saskorganic.com
http://www.saskorganic.com