To PIRSA

Regarding the lifting of the GM moratorium in South Australia 2019

Dear Sir,

The GM moratorium in South Australia should NOT be lifted, and should be left in place until review in 2025. And there are a number of reasons which I believe the State Government have been amiss in their deliberations.

Mr Kym Anderson's report "Independent Review of the South Australian GM Food Crop Moratorium" released in March 2019, fails to take into account a report tabled by the WA Parliament released on February 2019 entitled "STANDING COMMITTEE ON ENVIRONMENT AND PUBLIC AFFAIRS Mechanisms for compensation for economic loss to farmers in Western Australia caused by contamination by genetically modified material". The link for the report is here: http://www.parliament.wa.gov.au/Parliament/commit.nsfAReport+Lookup+by+Conn+ID)/48C54E37 5ABB4DCB482583A1000D364D/Sfilegull%20GM%20rep0rt.pdf

In i t , on Chapter 6 page 43 is a reference to the contamination rates experienced under section 6.3 Evidence Received by the Committee — Contamination. It reads "GM contamination 6.3 The Committee received limited evidence o f GM contamination in Western Australia. For instance, CBH has found a very small percentage of non-GM loads over the last five harvests (an average of 0.04% (ref.237)) contain unintended low-level presence of GM canola above the 0.9% tolerance."(ref.238).

Now Mr Anderson's report on page xii states "The biggest handler o f GM grain, Western Australia's Co-operative Bulk Handling Group, has successfully segregated GM and non-GM canola to internationally acceptable levels such that there have been no contamination issues since the GM crop's introduction in that state in 2010. That is, the experience of GM canola production and marketing in other mainland stages over the past decade reveals that segregation and identity preservation protocols and practice codes can and do ensure the successful coexistence of GM and non-GM crops in Australia (Finding 3.3)." Mr Anderson's findings are at odds with the finding of the WA Parliament report!

Dig a little deeper to the reference given by the WA Parliament report (reference 237 on the same page) and it states quite clearly that — "This equates to 61 truckloads from a total of 155 060 loads. See David Paton, Government and Industry Relations Manager, CBH Group, Letter, 1 May 2018, p 1"

Go a little further into the practises of CBH in WA, as evidence given by Mr David Paton Government and Industry Relations Manager, CBH Group as per the Standing Committee on Environment and Public Affairs INQUIRY INTO MECHANISMS FOR ECONOMIC LOSS TO FARMERS IN WESTERN AUSTRALIA CAUSED BY CONTAMINATION BY GENETICALLY MODIFIED MATERIAL TRANSCRIPT OF EVIDENCE TAKEN AT PERTH WEDNESDAY, 11 APRIL 2018 SESSION TWO, you will find in transcript not only evidence from Mr David Paton but also from Mr GAVIN BIGNELL Operations Manager, CBH Group page 7....

"Mr BIGNELL: Okay; no problem. The first part o f the question around the grower providing a warranty is that specifically in relation to GM the standard is very clear, that i t is about an unintended low-level presence. So i t is fair and reasonable that we ask the grower to declare that to the best of their knowledge there is no presence at all of GM materials. That is the warranty. I guess, just to add to that, once again our supply chain starts from our receival point, and we do not have

control over the practices that a grower does on farm. We have no control over that, so we ask them to declare that those practices are as needs to be. The second question about the fact that we do not declare that it is GM-free is similar to, I think, the member's question prior. We store and manage our supply chain in relation to the standard, which is below 0.9 per cent, so we certainly do not commit to anything above that. Finally, indemnity: that is a standard requirement o f growers regardless of GM or any other delivery issue. Once again, to deal with this factor, we do not control the grower's on-farm practices, and if something occurs and there is an economic loss on the back of that, we have the option, i f required, to go back and seek damages from the grower. Hopefully, that answers your question."

The rest of the transcript makes for pertinent and interesting reading. https://www.parliament.wa.gov.au/Parliament/commit.nsf/(Evidence+Lookup+by+Com+ID)/CEFBAO D98B112CE34825829E002192DO/Sfile/ev.ngm.180411.tro.001.CBH.pdf

This means that the canola from WA is NOT declared GM-free, if it is not actually GM BECAUSE THERE IS CONTAMINATION WHICH OCCURS! And this backed up by the evidence submitted to the "STANDING COMMITTEE ON ENVIRONMENT AND PUBLIC AFFAIRS Mechanisms for compensation for economic loss to farmers in Western Australia caused by contamination by genetically modified material" tabled in the Western Australian Parliament!

This is something very MAJOR TO CONSIDER PRIOR TO LIFTING THE MORATORIUM — WE WILL BE GOING FROM A STATE WHICH IS GM-FREE, TO THAT OF A STATE WHICH HAS GM CANOLA IN THIS CASE AND NON-GM CANOLA. You cannot have GM-FREE CANOLA in a state which has GM- CANOLA, simply because of the possibility of CONTAMINATION, which does occur, and is admitted as occurring by the CBH group in Western Australia!

We should LEARN from the mistakes of the other states, and do what is in the INTERESTS OF SOUTH AUSTRALIA ITSELF!

There is also concern that the agreement put forward involving the usage of GM CANOLA has not been circulated to farmers to see what it actually entails! I have done so with a few farmers — and they said they had NO IDEA what the signed contract to even use GM CANOLA entailed, including additional costs! Please actually read the contract, which is referred to as License and Stewardship Agreement. for yourselves — it makes for interesting reading too! http://varietycentral.com.au/wp-content/uploads/2011/03/Monsanto-RR-Canola-LSA.pdf

Regarding the Licence and Stewardship Agreement involving GM Canola, it is somewhat interesting that the document signed says there is no legal liability direct or indirect for use of the Roundup products by the person signing the agreement. This is rather disturbing, considering right now we have a court case against Roundup occurring right here in Australia, lodged June 03, 2019 https://www.farmonline.com.au/story/6204896/australias-first-glyphosate-court-case-confirmed/

Also, from the Monsanto Accreditation Course which is a compulsory part of the Agreement http://www.monsantoglobal.com/global/au/products/Documents/2018%20Accreditation%20Work book.pdf the document states "The best weed control is achieved with a two spray strategy of Roundup Ready Herbicide with PLANTSHIELD by Monsanto." So in fact you are spraying twice as much Roundup as you would otherwise normally do. Given the court case pending in Australia we

may want to think twice BEFORE allowing this to occur in any hurry. The third case of Monsanto being successfully sued over Roundup usage occurred last year in California, with another billion dollar settlement.

Why highlight GM Canola? Firstly, it is only one of three GM crops approved for use in Australia. The other is GM cotton and GM safflower. Only 21% of canola grown in Australia is GM canola. Even that figure — 21% uptake in Australia of growing GM canola should make you wary given that we have had GM canola in Australia for well over a decade in the other states, apart from South Australia and Tasmania!

http://www.ogtr.gov.au/internet/ogtr/publishing.nsf/content/9AA09BB4515EBAA2CA257D6B00155 C53/$File/11%20-%20Genetically%20m0dif1ed%20(GM)%20cr0p5%20in%20Australia.pdf

This is important because GM- Canola is the grain which the chairman of Grain Producers SA, Wade Dabinett, has been spruiking in South Australia since 2016, when in that particular year farmers were enjoying bumper yields! But even his information is wrong! He says "Canola is one GM crop that is well suited to grow in SA. Farmers want to reduce their chemical use by growing GM canola, which is not only higher yielding but also more resistant to pests and diseases." That is simply not true with GM-Canola! Yes you can get more yield because you can grow the rows closer together, but that has nothing to do with GM itself directly. If you read the agreement for GM-Canola, you are required to spray the crop TWICE with Roundup! Also the technology is not yet available to deal with resistance to pests and diseases in GM-Canola! There are some field trials, which Kym Anderson quoted in his report, but they remain field trials right now.

https://www.adelaidenow.com.a u/business/sa-business-jou rna l/record-sa-grain-crop-pou ring-into- gra in-silos-at-such-a-rate-that-it-may-exceed-the-officia 1-forecast-by-up-to-1-million-ton nes/news- story/fcc4a8c9bbcc56f467435198e8a7afil

It is not "up to freedom of choice" for farmers, as Wade Dabinett says, Advertiser August 2019. The consequences is that all the farmers will be giving up GM-free status to become non-GM! Those who have no interest in growing Canola at all! Therein lies the difference!! https://www.adelaidenow.conn.au/business/sa-business-journal/sa-farmers-permitted-to-grow- genetically-modified-crops-but-moratorium-remains-on-kangaroo-island/news- story/b3eb517e33eb4ef4b51123a8fe46056a Just as, in the same article, it is quoted that It found the moratorium had cost SA grain growers at least $33 million since 2004. This simply isn't true as it reads. Quoting from Kym Anderson's report, "With these assumptions, the cumulative cost to canola farmers o f South Australia's GM crop moratorium is estimated to be up to $33 million over 2004-18, and will be at least another $5 million i f the moratorium is kept until 2025 — and possibly much more i f Omega 3 canola proves to be higher priced and more profitable than current Roundup Ready canola (Finding 4.1)".. It was an estimate, with assumptions — and works out as an estimated cumulative cost to the canola farmers of $33 million is over a 14 year period! That works out to be $2.35m a year. So the calculated "loss" to canola farmers is $2.35 m a year.

"The grains industry continues to be a significant contributor to South Australia's economy adding almost $5.3 billion to the state's gross food revenue in 2016-17 and supporting thousands of jobs"... .Tim Whetstone MP 31.07.2018

https://premier.sa.gov.au/news/south-australia%E2%80%99s-2018%E2%80%9319-grain-harvest- estimated-at-69-million-tonnes

But what percentage is the Canola crop to that of other grains? Taking figures from the most recent PIRSA crop estimates for South Australia against 5 year average and 2019/2020 estimate the following figures are: Wheat (in hectares) 2 128 200 and 2 173 200

( in tonnes) 4 512 800 and 4 704 200

Barley (in hectares) 793 000 and 897 400

(in tonnes) 2 000 600 and 2 221 100

Canola (in hectares) 227 000 and 184 400 (in tonnes) 304 100 and 254 110

*wheat figures do not include durum

https://www.pir.sa.gov.au/ data/assets/pdf file/0020/347501/PIRSA Crop and Pasture Report July 2019-20.pdf - page 8.

This puts the canola industry into perspective relative to our other grain industry in South Australia! And this is what we are seeking to change our GM moratorium for?

Given that our overall food and wine industry is worth $20 billion a year as IT CURRENTLY STANDS! Is it really worth lifting this GM moratorium, a technology which is now acknowledged as being able to contaminate unintentionally? https://pir.sa.gov.au/primary industrv/aginsight/news feed/south australias food and wine reve nue reaches record $20.3 billion

What BENEFITS have we seen so far with the other states in Australia using GM? Given that they have had it in place so far for over a DECADE? Is it worth us losing our GM-free status for currently?

South Australia is phylloxera free, fruit fly free and GM-free CURRENTLY! That gives us a MARKETING ADVANTAGE! If this was not the case, why is Kangaroo Island allowed exemption from GM moratorium being lifted? This action in itself acknowledges that THERE IS an advantage to our status as it stands currently!

PIRSA in fact published a document, "Grains in South Australia - Premium Food and Wine from Our Clean Environment 2015", which outlines highlighted the advantages we in South Australia have being GM-free! Particularly noteworthy is that statement "Full traceability from the farmgate and paddock to the customer — with direct marketing systems where a customer buying grain is supplied direct from the farmer enabling complete traceability i f desired by the customer or consumer." With the status of GM-free being lifted, this will no longer be the case!! The best you could say is that it is non-GM https://www.accc.gov.au/system/files/PIR006 Grains%20in%20SA v6-SINGLES.PDF

This is not a decision which should be made just to satisfy political needs. It is not a decision that should be hurried. It is much like any agreement or contract where the fine print needs to be considered as well. This has not been done so far, and the information we have so far is not convincing that it is indeed in SA's best interest to lift the moratorium. At least not until 2025 when it will again be reviewed.

They say you don't know what you have until it's gone. But the truth is you knew exactly what you had — you just thought you'd never lose it.

Karen Ballard Port Augusta South Australia