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ERMA New Zealand
PO Box 131
Wellington 6140

Re: Applications
GMC07012 to import live animals, sperm, embryos, human and monkey cell-
lines, to develop GE animals;
GMD08012 for indoor development of GE animals for research, breeding
and production;
GMF07001 for field tests in outdoor containment;
GMD07074 allowing outdoor production


I am writing to express my deep concern at the nature of these
applications.  We wish to submit that all applications in this field
from AgResearch are declined, for the following major reasons:

1) AgResearch are pushing the boundaries with these applications by
applying to develop and commercialise use of GE animals, indefinitely,
at sites around New Zealand

2) It is ignoring community values and risking New Zealand’s

3) The applications are unreasonably ‘general’ and vague. They are
‘overlapping’ and cover many experiments that AgResearch is ‘legally
covered’ for but are not defined.

Furthermore, we would submit the following points:
* The proposals are very different to existing approvals in terms
of scale, wide-ranging objectives, use of a wide range of animals,
multiple locations and unlimited timeframe.
* The lack of detail makes case-by case consideration of ethics
and economic viability impossible and breaches the HSNO Act.
* The public have a right to be concerned about the ethics of
using animals, and the harm to New Zealand’s brand image.
* Application GMD 08012 should be defined as a ‘conditional
release’ not just a field trial or research. It is a major step.
* It is impossible for ERMA or submitters to consider the details
because there are none. This is a ‘generic’ application. It should not
have been accepted, and cannot be approved.
* Alternative ways exist to produce many pharmaceuticals, which
would avoid unethical use of animals. AgResearch admit there are
deformities and animal sickness in its GM developments, meaning ethics
are being weighed against cost-efficiency for manufacturers.
* The applications are not culturally acceptable in New Zealand.
The Community expects reasonable and ethical uses of biotechnology.
* Cultural issues are not just spiritual or just relate to Maori.
There are cultural values for New Zealand like those established
around nuclear-free, which include ethical uses of gene technology.
The applications go far beyond what is reasonable.
* New Zealand’s brand image benefits all of us and helps our
exports and tourism. The public interest is best served by maintaining
our international reputation for producing safe, natural, clean
* New Zealand’s image will be damaged. There is a risk of stigma,
impacting our reputation. Economic studies by the University of
Lincoln clearly indicate the risk.
* Commercial and government-funded science should maintain the
Brand reputation of New Zealand, but these applications jeopardise it.
* Overseas investors benefit more than the public. The commercial
biotech investors will exploit New Zealand, but the public is liable
for costs of clean-up when things go wrong. There is no commercial
insurance, or bond paid by the biotech investors to cover risks.
* There is a risk of creating new diseases by experimenting on New
Zealand animals which are currently free of BSE (Mad Cow Disease) and
Scrapie. It is wrong to allow GE animal waste to be used as compost or
sprayed onto fields.
* If approved, there will be a serious lack of transparency and
openness over an indefinite period. Community values create an
expectation that experiments are open to ongoing scrutiny for ethical
and legal standards. There are rapid developments. New transgenic
methods could create new risks not yet identified.
* The Bioethics council has called for review of use of human
genes in animal created as models of disease.
* There is a lack of respect for intrinsic worth of animals
raising ethical concerns that are completely ignored in the

For all these very major reasons I respectfully request that the
applications be absolutely declined.

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