Call for submissions on gene editing / gene drive (DOC/Toitū Te Whenua (Land Information NZ) public consultation

GE FREE NZ Tai Tokerau call to action!
Submissions are needed in response to DOC's/Toitū Te Whenua (Land Information NZ) controversial public consultation on gene editing/ CRISPR and other controversial and risky new genetic technologies, including "gene drive").
DOC's question:
“How can innovation in the way we use  emerging technologies and information help biodiversity thrive?"
Deadline: by 5pm tomorrow, Sunday 14 November 2021
See GE FREE NZ's easy submission guide (but don't forget to mention your opposition to gene editing of native taonga like manuka, kauri etc)

While we strongly support robust protection of native flora and fauna, in our view experimentation with or use of such risky new genetic technologies on our public conservation lands (or elsewhere) would be counter productive and potentially create far more serious problems than desired solutions.
You can give DOC/LINZ feedback by email or online form
Include if your feedback is on behalf of an organisation.
Online form option:
This form will ask you the 5 prompt questions. You don’t have to respond to each one.
We oppose any outdoor use of risky and controversial gene edited organisms (CRISPR) or "gene drive" (a sterility technique that presents grave risks to NZ's biosecurity, indigenous biodiversity, and wider environment). Environmental risks  of GMOs include


  • GMOs becoming invasive and affecting non-target species including indigenous flora and fauna
  • the development of herbicide or pesticide resistance creating 'super-weeds' or 'super-pests'
  • long term adverse impacts on ecosystem functioning
  • destruction of indigenous species in their own habitat (for example, possums in Australia) due to gene drive
  • https://www.etcgroup.org/content/reckless-driving-gene-drives-and-end-nature
Professor Jack Heinemann (Professor of Molecular Biology and Genetics, School of Biological Sciences, Canterbury University) and the Centre for Integrated Research in Biosafety has lodged a substantive submission on this topic expressing concerns about the risks of gene editing and "gene drive". We agree with Professor Heinemann that the challenge is to identify solutions to problems, not just participate in a process that shifts harm (creates more problems) and defers solutions.
Forest and Bird's position will be along the lines that they consider there are a great deal many more tools available to both DOC and LINZ (and government generally) to stop loss of our indigenous species. For instance, a significant increase in pest control, including robust ground based feral control, work to eradicate / suppress browsing mammals, large scale restoration of our forests and proper legal protection to halt the decline of species and their habitats.

There are major concerns too about the current drafting of the RMA reform, a failure to introduce an NPS for indigenous biodiversity and exemptions to wetland destruction that is being proposed. Forest and Bird has a precautionary GE/GMOs policy and opposes any genetic engineering/ gene editing of indigenous species in Aotearoa.  The National Environmental Standards for Plantation Forestry (NES-PF) prohibits the use of any GE/GMO trees or rootstocks and NZ is a signatory to the Cartegena Biosafety Protocol (key tenant- the Precautionary Principle)


It is of concern to us that the biotech industry continues to advocate for outdoor experimentation with Genetically Modified Organisms (GMOs) here in New Zealand, including controversial and risky gene edited organisms (CRISPR) and "gene drive" on our public conservation lands.

This is despite NZ being a signatory to the Cartegena Biosafety  Protocol to the Convention on Biological Diversity, Aotearoa's valuable "Zero Tolerance Policy" for any GE/GMO content in imported seeds/ plants (including adventitious presence), the legitimate concerns about outdoor use of GMOs or "gene drive" by NZ's top independent scientists (of the calibre of Professor Jack A. Heinemann, director Centre for Integrated Research in Biosafety and Dr. Peter Wills, Physicians & Scientists for Global Responsibility Charitable Trust NZ), and significant deficiencies in the Hazardous Substances and New Organisms (HSNO) Act as regards outdoor GMO applications.

Further background:
"GENE EDITING myth & reality- a guide through the smokescreen".

GENE DRIVE:

"Reckless Driving: Gene Drives and the end of Nature" by Civil Society Working Group on Gene Drives

Forest and Bird's updated precautionary GE/GMOs policy specifically states the societies opposition to any genetic modification (including gene editing) of indigenous flora and fauna.
See 

The immediate past Minister of Conservation Hon Eugenie Sage clearly stated her opposition to any outdoor use of GE/GMOs, including gene edited organisms/ CRISPR or "gene drive" (which was conveyed in no uncertain terms to both the Department of Conservation and Predator Free 2050 Ltd).

"Gene editing is an unproven technology for predator control. Gene technologies are problematic and untested and have significant risks.


"They have no social licence to operate. There is a lot at stake and there is a need for the utmost caution.


"There would be serious questions around the risks to New Zealand's GE-Free reputation from being associated with any field trials of gene technology."

-former Minister of Conservation, Hon Eugenie Sage