grdc · 2019-10-10 · investing in research and commercialisation that would benefit australian...
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Australian GovernmentGrains Research and
Development Corporation
GRDCGRAINS RESEARCH & DEVELOPMENT CORPORATION
30 September 2019
GM Secretariat SupportPrimary Industries and Regions SA - PIRSAGovernment of South AustraliaGPO Box 1671 Adelaide SA 5000By email: [email protected]
To whom it may concern
RE: Statutory Consultation on Draft Genetically Modified Crops Management (Designation of Area) Variation Regulations 2019
The Grains Research and Development Corporation (GRDC) welcomes the opportunity to provide a submission to the statutory consultation on the draft Genetically Modified Crops Management (Designation of Area) Variation Regulations 2019
GRDC is a statutory corporation charged with investing funds received from grain farmer levies and from the Commonwealth Government in research, development and extension (RD&E) across the grain value chain.
GRDC’s strategic purpose is:
To invest in Research, Development and Extension to create enduring profitability for Australian Grain Growers.
The creation of sustainable profit is the major driver of growers adopting the outputs of RD&E and therefore key to the GRDC’s ability to create the social, environmental and economic spill over benefits sought by Government’s investment in rural RD&E.
Operationally GRDC invests in a RD&E portfolio that addresses profitability constraints and opportunities spanning temperate and tropical cereals, coarse grains, pulses and oilseeds. This involves coordinating and investing in RD&E initiatives; monitoring, evaluating and reporting on their impact; and facilitating the dissemination, adoption and commercialisation of their results.
The comments below seek to assist PIRSA understand the impact of the proposed regulation as part of its statutory consultation.
P PO Box 5367 Kingston, ACT 2604 Australia Page 1T +61 2 6166 4500 F +61 2 6166 4599 E [email protected]
GRAINS RESEARCH & DEVELOPMENT CORPORATION ABN 55 611 223 291grdc.com.au
Draft Genetically Modified Crops Management (Designation of Area) Variation Regulations2019
Overview
The draft Genetically Modified Crops Management (Designation of Area) Variation Regulations 2019 seeks to implement the South Australian Government’s response to the independent review of the moratorium on the cultivation of Genetically Modified (GM) food crops undertaken by Emeritus Professor Kim Anderson AC.
The effect of the regulation is to restrict the operation of the moratorium to Kangaroo Island, providing grain growers located on the South Australian mainland with the ability to produce GM crops where they consider it beneficial to their farming system.
All commercially released GM crops have been approved by the Office of the Gene Technology Regulator (OGTR). This approval requires the identification of potential risks to human health and the environment and where necessary mandates risk management requirements that have been developed in accordance with the best available science.
Additionally, Australia has developed mature supply chain arrangements that manage segregation of GM from non-GM crops. The Australian experience has demonstrated the capability of Australia’s grains supply chains to export both GM and non-GM canola to the satisfaction of buyers and specific export market requirements.1
Impact of the regulation
Research commissioned by GRDC indicates that farmers choosing to grow GM crops do so on the basis of the long-term impact of the crop on their business’ profitability. This includes a consideration of both the gross margin made by the GM crop and its broader impact on the grower’s farming system, such as long term weed management.2
Immediate Impact
Presently, Australian grain growers have access to commercial varieties of GM canola that that carry a trait that confers herbicide tolerance. Growing GM canola provides production benefits to farmers by facilitating best practice minimum/no tillage methods and expanding the suite of strategies for weed management. As a result, the most immediate impact of the draft regulation would be to increase the flexibility of the weed management options available to South Australian grain growers. This is particularly important to the South Australian grain production system due to the growth of herbicide resistance in weeds of economic significance, such as annual rye grass.
University of Adelaide research, conducted with investment from GRDC, has identified the need for long term systemic approaches to managing annual rye grass due to the
1 See Department of Primary Industries, Victorian Government, 'Review of the moratorium on genetically modified canola in Victoria: Final Report’ (Final Report, 2017) 34-42; see also Evidence to the Legislative Council Standing Committee on Environment and Public Affairs, Parliament of Western Australia, Perth, 11 April 2018 (Mr Gavin Bignell) 2; and Mercado, ’Analysis of price premiums under the South Australian GM moratorium’ (Research report, Grain Producers South Australia and the Agricultural Biotechnology Council of Australia, March 2018).2 D Hudson and R Richards ’GM Canola Impact Survey: Information for growers, advisers and industry’, (Research Report, GRDC and Birchip Cropping Group, March 2014).
P PO Box 5367 Kingston, ACT 2604 Australia Page 2T+61 2 6166 4500 F+61 2 6166 4599 E [email protected]
GRAINS RESEARCH & DEVELOPMENT CORPORATION ABN 55 611 223 291grdc.com.au
inadequacy of pre-emergent herbicides and growing resistance to selective post emergent herbicides.3 Given the lack of post emergent control options during a cereal phase of a crop rotation, the canola phase is critical to annual ryegrass management in the farming system. The research demonstrates growing RT canola, that is canola that has conventionally bred triazine tolerance combined with genetically modified glyphosate tolerance, increases the flexibility and efficacy of managing annual ryegrass in the farming system.4
Longer Term Impact
In the perspective of the medium to long term, the lifting of the moratorium on mainland South Australia will facilitate the opportunity for South Australian grain growers to benefit from existing and future research into GM crops.
This includes gaining access to the following GM crop varieties that have been developed through GRDC investment to produce a higher value commodity that targets end user/consumer benefits and preferences; such as health and wellbeing issues and also environmental sustainability issues (eg native fish stocks).
• A GM super-high-oleic safflower has been deregulated and was be made available for commercial production by GO Resources in the 2019 growing season.
• GM canola varieties carrying a trait that confers the production of long-chain omega-3 fatty acids. NuSeed plans to commercialise the varieties prior to 2020.
In addition to GM varieties commercially available or nearing commercial availability, the OGTR has approved field research into a number of GM crops. In particular, the research effort into these GM traits is focused on advancing transformational opportunities for Australian grain growers through developing cereal grains with:
• Increased tolerance and resistance to abiotic stresses, such as frost, salt, and drought.
• Improved water use efficiency and nitrogen use efficiency.
• Improved nutrition and dough functionality.
• Resistance to fungal disease.
Impact on research investment
The removal of the moratorium on mainland South Australia will also reduce the national complexity of the regulatory framework for GM crops. This will in turn make Australia a more attractive destination for investment from the global life science companies who are important partners in the research and commercialisation of GM technologies.
These global businesses are subject to internal competition for the direction of resources to specific international jurisdictions. Australia’s relatively small grains industry market, by
3 C Preston, P Boutsalis, S Kleeman, R Saini and G Gill, 'Herbicides For Control Of Clethodim-Resistant Annual Ryegrass' (GRDC Update Paper, GRDC, 10 February 2015) < https://grdc.com.au/resources-and-publications/grdc-update-papers/tab-content/grdc-update- papers/2015/02/herbicides-for-control-of-clethodim-resistant-annual-ryegrass>.4 C Preston, 'Managing Clethodim Resistant Annual Ryegrass' (GRDC Update Paper, GRDC, 29 February 2016), <https://grdc.com.au/resources-and-publications/grdc-update-papers/tab-content/grdc-update-papers/2016/02/managing-clethodim-resistant-ryegrass>.
P PO Box 5367 Kingston, ACT 2604 Australia Page 3T+61 2 6166 4500 F+61 2 6166 4599 E [email protected]
GRAINS RESEARCH & DEVELOPMENT CORPORATION ABN 55 611 223 291grdc.com.au
global comparison, combined with fragmentation driven by regionally unique agricultural production environments, risks being ill-suited to the resource allocation models used by these global plant science companies.5 Fragmentation and inconsistency of the policy and regulation of GM technologies is seen by these companies as a further impediment to investing in research and commercialisation that would benefit Australian agriculture.
Conclusion
GRDC believes the impact of the draft Genetically Modified Crops Management (Designation of Area) Variation Regulations 2019 will be to:
• Immediately provide mainland South Australian grain growers with access to GM canola varieties that will create production benefits by facilitating best practice minimum/no tillage methods and expanding the suite of strategies for weed management.
• Ensure grain growers on mainland South Australia are able to participate in the benefits created by GRDC’s investment in new GM crops, such as long-chain Omega 3 Canola and super-high-oleic safflower.
• Reducing impediments to international investment by global life science companies into Australian agriculture.
If PIRSA would like to further discuss any matter contained in this submission, please contact Justin Crosby, Head of Industry and Government relations on 02 6166 2600 or by email [email protected].
Yours Sincerely
Dr Steve Jefferies AMManaging Director
5 M Keogh, R Heath, M Henry and L Darragh, 'Enhanding Private-Sector Investment in Agricultural Research, Development and Extension (R,D&E) in Australia’ [Research Report, Australian Farm Institute, December 2017] 2.
P PO Box 5367 Kingston, ACT 2604 Australia T +61 2 6166 4500 F+61 2 6166 4599 E [email protected]
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GRAINS RESEARCH & DEVELOPMENT CORPORATION ABN 55 611 223 291